No. 05-3-02755-1 Andrew Rife v. Jennifer Rife Aka Lesourd Nka Mehaddi

FILED
05 OCT I 9 PH 3: I+ l1
P ,\ML. D,\iJIELS
. COIJ~ITY CLERK
SNOHOMISH CO.Wt, SH.
3
6
SUPERIOR COURT OF WASHINGTON
7 COUNTY OF SNOHOMISH
s In re the Marriage of:

05 3 0 27 55 J
Andrew Scott Rife
9 Petitioner, NO.
and
10 PARENTING PLAN
Jennifer Rae Rife [)(PROPOSED (PPP)
11 Respondent. [ ] TEMPORARY (PPT)
[ ] FINAL ORDER (PP)
12
his parenting plan is:
13 proposed by Andrew Scott Rife.
14 IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
15 I. GENERAL INFORMATION
16 his parenting plan applies to the following children:
17
Name Age
18 Lauren Emily Rife 1
19
2 0 II. BASIS FOR RESTRICTIONS

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
21
contact with the child(ren) and the right to make decisions for the child(ren).
22
2.1 PARENTAL CONDUCT (RCW 26.09.191(1), (2)).
23
RESERVED
[ ] Does not apply.
24
[ ] The [] mother's [ ] father's residential time with the child(ren) shall be limited or
restrained completely, and mutual decision-making and designation of a dispute
25
resolution process other than court action shall not be required, because [ ] this
26
CARLJ.GAUL
Attorney at law
27
302 Bank of America Bldg.
n n IGINAL
1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT. PP) - Page I Everett WA 9820 I
WPF DR 01.0400 (912001)- RCW 26.09.181; .187tJSf\ 425 259-4147 FAX 259 7081
(•
1 parent [ ] a person residing with this parent has engaged in the conduct which
follows.
2
[ ] Willful abandonment that continues for an extended period of time or
3 substantial refusal to perform parenting functions (this applies only to
parents, not to a person who resides with a parent).
4 [ ] Physical, sexual or a pattern of emotional abuse of a child.
[ ] A history of acts of domestic violence as defined in RON 26.50.010(1) or
5 an assault or sexual assault which causes grievous bodily harm or the fear
of such harm.
6
2.2 OTHER FACTORS (RON 26.09.191(3)).
7
RESERVED
8 [ ] Does not apply.
[ ] The [ ] mother's [ ] father's involvement or conduct may have an adverse effect
9 on the child(ren)'s best interests because of the existence of the factors which
follow.
10
[] Neglect or substantial nonperformance of parenting functions.
11 [X] A long-term emotional or physical impairment which interferes with the
performance of parenting functions as defined in RON 26.09.004.
12 [X] A long-term impairment resulting from drug, alcohol, or other substance
abuse that interferes with the performance of parenting functions.
13 [l The absence or substantial impairment of emotional ties between the
parent and child.
14 [X] The abusive use of conflict by the parent which creates the danger of
serious damage to the child's psychological development.
15 [l A parent has withheld from the other parent access to the child for a
protracted period without good cause.
16 [] Other:
1 7 III. RESIDENTIAL SCHEDULE

18 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
19 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
2 o 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
21 Paragraph 3.13.
22 3.1 SCHEDULE FOR CHILDREN UNDER SCHOOL AGE
23 There are no children under school age.

Prior to enrollment in school, the child(ren) shall reside with the mother AND father,
24
Alternating weeks with each parent, exchanging the child on Wednesdays at 6:00
25 p.m.
every week
26
CARLJ.GAUL
Attorney at law
27
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT, PP) - Page 2 Everett WA 9820 I
WPF DR 01.0400 (912001) - RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
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1 3.2 SCHOOL SCHEDULE.
2 Does not apply
3 3.3 SCHEDULE FOR WINTER VACATION.
4 Does not apply
5 3.4 SCHEDULE FOR SPRING VACATION.
6 Does not apply
7 3.S SUMMER SCHEDULE.
8 Does not apply
9 3.6 VACATION WITH PARENTS.
10 Does not apply.
11 3.7 SCHEDULE FOR HOLIDAYS.
12 The residential schedule for the child(ren) for the holidays listed below is as follows:
13 Does not apply
14 3.8 SCHEDULE FOR SPECIAL OCCASIONS.
15 The residential schedule for the child(ren) for the following special occasions (for
example, birthdays) is as follows:
16
With Mother With Father
17 (Specify Year (Specify Year
Odd[Even[Eve!}'.) Odd[Even[Eve!}'.)
18
Mother's Day every none
19
Mother's Birthday every none
20
Father's Day none every
21 none every
Father's Birthday
22 Child's Birthday odd even
23
24 3.9 PRIORITIES UNDER THE RESIDENTIAL SCHEDULE.
Does not apply.

25
26
CARLJ.GAUL
Attorney at law
27
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT. PP) - Page 3 Everen WA 9820 I
WPF DR 01.0400 (912001) -RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
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1 3.10 RESTRICTIONS.
2 RESERVED
3 3.11 TRANSPORTATION ARRANGEMENTS.
4 Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.
5 Transportation arrangements for the child(ren), between parents shall be as follows:
6 the exchange of the child shall occur at the Everett Police Station
7
3.12 DESIGNATION OF CUSTODIAN.
8 The child named in this parenting plan is scheduled to reside substantially equal periods
of time with each parent.. Both parents are designated custodians of the child(ren)
9 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
10 responsibilities under this parenting plan.
11 3.13 OTHER.
12
13
14
15
16
17
18
19
20
21
3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A CHILD.
22
This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
23
If the person with whom the child resides a majority of the time plans to move, that
24 person shall give notice to every person entitled to court ordered time with the child.
25
26
CARLJ.GAUL
Allorney at Law
27
1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT. PP) - Page 4 Everett WA 9820 I
WPF DR 01.0400 (912001)-RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
...
1 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
2 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
3 after learning of the move. The notice must contain the information required in RON
26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A Child).
4
If the move is within the same school district, the relocating person must provide actual
5 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 RON 26.09.260.
6
Notice may be delayed for 21 days if the relocating person is entering a domestic
7 violence shelter or is moving to avoid a clear, immediate and unreasonable risk to health
and safety.
8
If information is protected under a court order or the address confidentiality program, it
9 may be withheld from the notice.
1o A relocating person may ask the court to waive any notice requirements that may put
the health and safety of a person or a child at risk.
11
Failure to give the required notice may be grounds for sanctions, including contempt.
12
If no objection is filed within 30 days after service of the notice of intended
13 relocation, the relocation will be permitted and the proposed revised residential
schedule may be confirmed.
14
A person entitled to time with a child under a court order can file an objection to the
15 child's relocation whether or not he or she received proper notice.
16 An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting
17 Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
18
The relocating person shall not move the child during the time for objection unless: (a)
19 the delayed notice provisions apply; or (b) a court order allows the move.
2o If the objecting person schedules a hearing for a date within 1S days of timely service of
the objection, the relocating person shall not move the child before the hearing unless
21 there is a clear, immediate and unreasonable risk to the health or safety of a person or a
child.
22
IV. DECISION MAKING
23
.1 DAY-TO-DAY DECISIONS.
24
Each parent shall make decisions regarding the day-to-day care and control of each child
25 while the child is residing with that parent. Regardless of the allocation of decision
26
CARLJ.GAUL
Attorney at law
27
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT. PP) - Page 5 Everett WA 9820 I
WPF DR 01.0400 (912001)-RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
,.
1 making in this parenting plan, either parent may make emergency decisions affecting the
health or safety of the children.
2
4.2 MAJOR DECISIONS.
3
Major decisions regarding each child shall be made as follows:
4
Education decisions joint
5 Non-emergency health care joint
Religious upbringing joint
6
7 4.3 RESTRICTIONS IN DECISION MAKING.
8 RESERVED
[ ] Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
9 above.
[ ] Sole decision making shall be ordered to the [ ] mother [ ] father for the
10 following reasons:
11 [ ] A limitation on the other parent's decision making authority is mandated

by RON 26.09.191 (See paragraph 2.1).
12 [ ] Both parents are opposed to mutual decision making.
[ ] One parent is opposed to mutual decision making, and such opposition is
13 reasonably based on the following criteria:
14 (a) The existence of a limitation under RON 26.09.191;

(b) The history of participation of each parent in decision
15 making in each of the areas in RON 26.09.184(4)(a);
( c) Whether the parents have demonstrated ability and desire
16 to cooperate with one another in decision making in each of the
areas in RON 26.09.184(4)(a); and
17 (d) The parents' geographic proximity to one another, to the
extent that it affects their ability to make timely mutual decisions.
18
[ ] There are limiting factors in paragraph 2.2, but there are no restrictions on
19 mutual decision making for the following reasons:
20
21
. DISPUTE RESOLUTION
22
The purpose of this dispute resolution process is to resolve disagreements about carrying out
23 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
24 modify the plan or a motion for contempt for failing to follow the plan.
25 Disputes between the parties, other than child support disputes, shall be submitted to
(list person or agency):
26
CARLJ.GAUL
Attorney at law
27
1604 Hewitt Ave.
WPF DR 01.0400 (912001) - RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
,,
1 mediation by Volunteers of America Dispute Resolution Service in Everett WA ,or
2 The cost of this process shall be allocated between the parties as follows:
3 50% mother 50% father.
4 The counseling, mediation or arbitration process shall be commenced by notifying the

other party by written request by certified mail.
5
In the dispute resolution process:
6
(a) Preference shall be given to carrying out this Parenting Plan.
7 (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
8 financial support.
(c) A written record shall be prepared of any agreement reached in counseling or
9 mediation and of each arbitration award and shall be provided to each party.
(d) If the court finds that a parent has used or frustrated the dispute resolution
10 process without good reason, the court shall award attorneys' fees and financial
sanctions to the other parent.
11 (e) The parties have the right of review from the dispute resolution process to the
superior court.
12
13 OTHER PROVISIONS
14 There are the following other provisions:
15 All provisions of this parenting plan may be reviewed on motion after receipt of a report
and recommendation from the guardian ad litem.
16
17
18
19
20
I. DECLARATION FOR PROPOSED PARENTING PLAN
21
[l Does not apply.
22 [l (Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under
the laws of the state of Washington that this plan has been proposed in good faith and
23 that the statements in Part II of this Plan are true and correct.
24
Andrew Scott Rife
25
26
CARLJ.GAUL
Attorney at law
27
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1
III. ORDER BY THE COURT
2
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and
3 approved as an order of this court.
4 WARNING: Violation of residential provisions of this order with actual knowledge of its terms
is punishable by contempt of court and may be a criminal offense under RCW 9A.040.060(2) or
5 9A.40.070(2). Violation of this order may subject a violator to arrest.
6 hen 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.
7
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
s planarenotaffected. UNSIGNED
9
10
Dated: 'Welf&
Q~ e missioner
Presented by: Copy Received:
11
12
13 Jan Dyer WSBA# 20355

Attorney for Jennifer Rae Rife
14
15
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25
26 CARLJ.GAUL
Attorney at Law
27
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
·•
.~·
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III/II/I llllU~fI/Il l Ml l/ l l lmt~/I/Illllllllll
CL11169191
FILED
05 OCT I 9 PH 3: 1+4
p 1\M L 0/1.~~IELS
COUNTY CLERK
SNOHOMISH CO.\'(,\ SH.
Washington State Child Support Schedule

Worksheets (CSW}
Mother: Jennifer Rae Rife
Countv: SNOHOMISH
Father: Andrew Scott Rif(}5
Superior Court Number:
() 27 •~!i
Children and Ages: LER, 1
Part I: Basic Child Support Obligation (See Instructions, Page 5)

1. Gross Monthly Income Father Mother
a. Waaes and Salaries $4.327.00 $3,900.00
b. Interest and Dividend Income - --
c. Business Income -
d.
e.
Soousal Maintenance Received
Other Income $600.00
- -
-
f. Total Gross Monthly Income
(add lines 1a throuah 1el $4,927.00 $3,900.00
2. Monthly Deductions from Gross Income
a. Income Taxes {Federal and State) $633.00 $286.88
b. FICA ISoc.Sec.+Medicarel/Self-Emolovment Taxes $875.59 $596.70
c. State Industrial Insurance Deductions - -
d. Mandatory Union/Professional Dues - -
e. Pension Plan Pavments $90.86 -
f. Spousal Maintenance Paid - -
a.
h.
Normal Business Exoenses
Total Deductions from Gross Income
- -
{add lines 2a throuch 2al $1,599.45 $883.58
3. Monthly Net Income
{line 1f minus 2h l $3,327.55 $3,016.42
4. Combined Monthly Net Income
(Line 3 amounts combined) $6,343.97
{If line 4 is less than $600, skip to line 7.l
5. BASIC CHILD SUPPORT OBLIGATION: Combined~
LER $899.00
- $899.00
-
-
-
WSCSS-Worksheets (CSW) 9/2000 Page 1 of 5 Continue to Next Page
,. I
• 'i
Father Mother
6. Proportional Share of Income
(Each parent's net income from line 3 divided bv line 4 l .525 .475
7. Each Parent's Basic Child Support Obligation
(Multiply each number on line 6 by line 5)
(If line 4 is less than $600, enter each parent's support
obligation of $25 per child. Number of children: 1
(Skip to line 15a and enter this amount.\ $471.98 $427.02
Part JI: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 7)
B. Health Care Exnenses
a. Children's Monthlv Health Insurance $47.00 -
b. Children's Uninsured Monthlv Health Care - -
c. Total Monthly Health Care Expenses
(line Ba plus line Bb)
$47.00 -
d. Combined Monthly Health Care Expenses
ladd father's and mother's totals from line Bel $47.00
e. Maximum Ordinary Monthly Health Care
(multiolv line 5 times .05\ $44.95
f. Extraordinary Monthly Health Care Expenses
(line Bd minus line Be., if "O" or negative, enter "O") $2.05
9. Dav Care and Special Child Rearinq Expenses
a. Dav Care Expenses - -
b. Education Expenses - -
c. Lona Distance Transoortation Exoenses
d. Other Special Expenses (describe)
- -
- -
- -
- -
e. Total Day Care and Special Expenses
(Add lines 9a throuqh 9d)
- -
10. Combined Monthly Total Day Care and Special Expenses
(Combine amounts on line 9e) -
11. Total Extraordinary Health Care, Day Care, and Special
Expenses (line Bf plus line 10) $2.05
12. Each Parent's Obligation for Extraordinary Health Care,
Day Care, and Special Expenses $1.08 $.97
Part Ill: Gross Child Support Obligation
13. Gross Child Suooort Obliqation (line 7 plus line 12) $473.06 $427.99
Part JV: Child Support Credits (See Instructions, Page 7)
14. Child Sunnort Credits
a. Monthly Health Care Expenses Credit $47.00 -
b. Dav Care and Special Expenses Credit
c. Other Ordinary Expenses Credit (describe)
- -
-- -
--
-
d. Total Suooort Credits I add lines 14a throuah 14cl $47.00 -
1
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Part V: Standard Calculation/Presumptive Transfer Payment {See Instructions, Page 8)

15. Standard Calculation Father Mother
a. Amount from line 7 if line 4 is below . .
$600. Skip to Part VI.
b. Line 13 minus line 14d, if line 4 is over $426.06 $427.99
$600 lsee below if annl.\
Limitation standards adiustments
c. Amount on line 15b adjusted to meet 45% . .
net income limitation
d. Amount on line 15b adjusted to meet . .
need standard limitation
e. Enter the lowest amount of lines 15b, 15c or 15d: $426.06 $427.99
Part VI: Additional Factors for Consideration {See Instructions, Page 8)
16. Household Assets Father's Mother's
(Present estimated value of all maior assets.\ Household Household
a. Real Estate . .
b. Stocks and Bonds . .
c. Vehicles . .
d. Boats . .
e. Pensions/IRAs/Bank Accounts . .
f. Cash . .
a. Insurance Plans . .
h. Other: . .
. .
. .
. .
17. Household Debt
{List liens against household assets, extraordinary debt.)
a. . .
b. . .
c. . .
d. . .
e. . .
f. . .
18. Other Household Income
a. Income Of Current Spouse
(if not the other oarent of this action\
Name . .
Name . .
b. Income of Other Adults in Household
Name . .
Name . .
c. Income of Children lif considered extraordinarvl
Name . .
Name . .
d. Income from Child Sunnort
Name . .
Name . .
Father's Mother's
Other Household Income (continued) Household Household
e. Income From Assistance Proarams
Proqram - -
Proa ram
f. Other Income (describe)
- -
- -
19. Non-Recurrina Income ldescribel
- -
- -
20. Child Suooort Paid For Other Children
- -
Name/age: - -
Name/age: - -
21. Other Children Living In Each Household
(First names and ages)
22. Other Factors For Consideration

Husband's income based on payroll report through week 40 (10/5/05) see sealed financial source
document.
Husband works for his father on most Saturdays. He is paid in cash for this work, estimated at $600
per month, which is included as "other income."
Wife is self-employed as a mobile notary working through title companies. Her income is estimated
at $3900 per month based on historical averages. The entry for social security is doubled in order
to account for the self employment tax.
WSCSS-Worksheets (CSW) 912000 Page 4 of 5 Continue to Next Page

Other factors for consideration (continued)
Signature and Dates

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

Photocopying of the worksheet is permitted.
WSCSS-Worksheets (CSW) 9/2000 Page 5 of 5 SupportCalc® 2005

FILED
S!DiOHI9l COUNTY SUPER! IJ1T

PAM L. DANIELS
SHOHOOSH C!lJNTV Ill
I\\\\\\\\\\\\\\\\\\\\\ Ill\\\\\\\ \Ill\\\\\\\\\\\\\\\\\\\\\\\\ FILED Everett llA
CL11169197
05 OCT I 9 PH 3: I+ 4 05-3-02755-1
PAM L. DANIELS RCPt. Date Acct. Date Ti.re
COUNTY CLERK 10/19/2005 10/19/2005 03:41 PM
SNOHOMISH CO. r1 f,SH.
ReceiPt/ltem U Tran-Code cket-r.ooe
2005--01-24661101 uo3 m
!'.ashier: RMB
SUPERIOR COURT OF WASHINGTON Paid BY: GAUL, GARI.
COUNTY OF SNOHOMISH Transaction Amount: $250.00
In re the Marriage of:
Andrew Scott Rife 05 3 0 27 55 1
Petitioner, NO.
and SUMMONS
Jennifer Rae Rife (SM)
Res ondent.
TO THE RESPONDENT:
The petitioner has started an action in the above court requesting that your
marriage be dissolved. Additional requests, if any, are stated in the petition, a
copy of which is attached to this summons.
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.
Your written response to the summons and petition must be on form WPF DR
01.0300, Response to Petition (Domestic Relations). This form may be obtained
by contacting the clerk of the court at the address below, by contacting the
Administrative Office of the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
http://www.courts.wa.gov/forms
CARLJ.GAUL
Auorney at Law
1604 Hewitt Ave.
SUMMONS (SM) - Page 1
WPF DR 01.0200 (6/2002) - CR 4.1 '.JRIGINAL Everett WA 9820 I
425 259-4147 FAX 259 7081
..
1 If this action has not been filed with the court, you may demand that the
petitioner file this action with the court. f you do so, the demand must be in
2
writing and must be served upon the person signing this summons. Within 14
3 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.
4
5 5. If you wish to seek the advice of an attorney in this matter, you should do so
promptly so that your written response, if any, may be served on time.
6
7 6. One method of serving a copy of your response on the petitioner is to send it by
certified mail with return receipt requested.
8
9 Washington. . /1
This summons is issued pursuant to SupzeriorCourt Civil Rule 4.1 of the state of
lO
11
Dated: October 17, 2005 1/fol/ l ,Jdi
1
o\RL J. GAUL Wfi,BA# 8341
12 Attorney for Andi'~ Scott Rife
13 FILE ORIGINAL OF YOUR RESPONSE SERVE A COPY!o~

YOUR RESPONSE ON
WITH THE CLERK OF THE COURT AT: PETITIONER'S LAWYER:
14 Snohomish County Courthouse
3000 Rockefeller CARLJ.GAUL
15
M/S 605 Attorney at Law
16 Everett WA 98201 302 Bank of America Building
1604 Hewitt Ave.
17 Everett WA 98201
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CARLJ.GAUL
Attorney at Law
27
1604 Hewitt Ave.
SUMMONS (SM) - Page 2 Everett WA 9820 I
WPF DR 01.0200 (6/2002) - CR 4.1 425 259-4147 FAX 259 7081
..
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6 SUPERIOR COURT OF WASHINGTON
05 3 0 27 55 1
NO.
PETITION FOR DISSOLUTION

OF MARRIAGE
(PTDSS)
Andrew Scott Rife
1317 McDougall Ave.

Everett WA 98201
Snohomish
Jennifer Rae Rife
2416 - 5th St.

Everett WA 98201
Snohomish
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PET FOR DJSSO OF MARRIAGE {PTDSS) - Page 1
WPF DR 01.0100 (7/2003) - RCW 26.09.020 0 RIGINAL Everett WA 9820 I
425 259-4147 FAX 259 7081
I
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1.3 CHILDREN OF THE MARRIAGE DEPENDENT UPON EITHER OR BOTH SPOUSES.
2
he husband and wife are both the parents of the following dependent children:
3 Name Lauren Emily Rife Age 1
4
5 he husband is and the wife is not the parent of the following dependent children: NONE
6 he wife is and the husband is not the parent of the following dependent children: NONE
ALLEGATION REGARDING MARRIAGE.
This marriage is irretrievably broken.
DATE AND PLACE OF MARRIAGE.

The parties were married on April 10, 2004 at Snohomish County WA.
SEPARATION.
Husband and wife separated on October 2, 2005.
JURISDICTION.
This court has jurisdiction over the marriage.

This court has jurisdiction over the respondent because:
the respondent is presently residing in Washington.
the petitioner and respondent lived in Washington during their marriage and the
petitioner continues to reside, or be a member of the armed forces
stationed, in this state.
the petitioner and respondent may have conceived a child while within
Washington.
PROPERTY.
There is community or separate property owned by the parties. The court should make
a fair and equitable division of all the property.
The division of property should be determined by the court at a later date.
DEBTS AND LIABILITIES.
25 The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.
26
CARLJ.GAUL
27 Attorney at law
1604 Hewitt Ave.
PET FOR DISSO OF MARRIAGE (PTDSS) - Page 2 Everett WA 9820 I
WPF DR 01.0100 {7/2003) - RCW 26.09.020 425 259-4147 FAX 259 7081
'
1 The division of debts and liabilities should be determined by the court at a later date.
2 1.10 SPOUSAL MAINTENANCE.
3
Spousal maintenance should not be ordered.
4
1.11 CONTINUING RESTRAINING ORDER.
5
Does not apply.
6
PREGNANCY.
7 1.12
8 The wife is not pregnant.
9 1.13 JURISDICTION OVER THE CHILDREN.
10 This court has jurisdiction over the children for the reasons set forth below:
11 This state is the home state of the children because
12
the children lived in Washington with a parent or a person acting as a parent for
13 at least six consecutive months immediately preceding the
commencement of this proceeding.
14
No other state has jurisdiction.
15
[] Other:
16
17 1.14 CHILD SUPPORT AND PARENTING PLAN FOR DEPENDENT CHILDREN.
18 Support for the dependent children listed in below, should be set pursuant to the
19 Washington State Child Support Schedule.
20 Name Mother's Name Father's Name

21 Lauren Emily Rife Jennifer Rae Rife Andrew Scott Rife
22
The petitioner's proposed parenting plan for the children listed above:
23
is attached and is incorporated by reference as part of this Petition.
24
During the last five years, the children have lived:
25
26 CARLJ.GAUL
Attorney at Law
27 302 Bank of America Bldg.
1604 Hewitt Ave.
PET FOR D/550 OF MARRIAGE (PTDSS) - Page 3 Everett WA 9820 I
WPF DR 01.0100 (7/2003) - RCW 26.09.020 425 259-4147 FAX 259 7081
1 in no place other than the state of Washington and with no person other than the
petitioner or the respondent.
2 Claims to custody or visitation;
3
The petitioner does not know of any person other than the respondent
4 who has physical custody of, or claims to have custody or visitation rights
to, the children.
5 Involvement in any other proceeding concerning the children;
6 The petitioner has not been involved in any other proceeding regarding
the children.
7
8 Other legal proceedings concerning the children.
9 The petitioner does not know of any other legal proceedings concerning
the children.
10
1.15 OTHER.
11
12
13
14
II. RELIEF REQUESTED
15
he petitioner REQUESTS the court to enter a decree of dissolution and to grant the relief
16
below.
17
Approve the petitioner's proposed parenting plan for the dependent children.
18 Determine support for the dependent children pursuant to the Washington State Child
Support Schedule.
19 Divide the property and liabilities.
20 Other:
21
22
23
Dated:
24 CARL J. GAUL WSBA 8341
Attorney for And\:'ew)scott Rife
25
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewin Ave.
PET FOR DISSO OF MARRIAGE (PTDSS) - Page 4 Everett WA 9820 I
WPF DR 01.0100 (7/2003) - RCW 26.09.020 425 259·4147 FAX 259 7081
•
•
1
I declare under penalty of perjury under the laws of the state of Washington that the
2 foregoing is true and correct.
3 Signed at
Dated: lb\\ 1 loS Andrew Scott Rife
4
5
6 [] JOIN DER.
7 The respondent joins in the petition. By joining in the petition, the respondent agrees to
the entry of a decree in accordance with the petition, without further notice.
8
Dated:
9
!--~~~~~~~~~~~~
Signature of Respondent
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PET FOR DISSO OF MARRIAGE {PTDSS) - Page 5 Everett WA 9820 I
WPF DR 01.0100 {7/2003) - RCW 26.09.020 425 259-4147 FAX 259 7081
:FILED
I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ \Ill\\\\\\\\\\\ \\Ill\\\\\\\\
CL 11169190 05 OCT I 9 PM 3: 41.i
PAM L. Oi\t!IELS
cou~nY CLERK
4 SNOHOMISH CO.HA SH.

COUNTY OF SNOHOMISH
8
In re: <J5 8 02755
9 ANDREW scon RIFE NO.
l
10 Petitioner, FINANCIAL DECLARATION
And [X]PETITIONER
11 [ ]RESPONDENT
JENNIFER RAE RIFE (FNDCLR)
12 Res ondent.
13 Name: Andrew Scott Rife Date of Birth: 03/22/73
14 I. SUMMARY OF BASIC INFORMATION

Declarant's Total Monthly Net Income (from § 3.3 below) $3,327.55
15 Declarant's Total Monthly Household Expenses (from§ 5.9 below) $3,245.80
Declarant's Total Monthly Debt Expenses (from§ 5.11 below)
16 Declarant's Total Monthly Expenses (from§ 5.12 below) $3,245.80
Estimate of the other party's gross monthly income (from§ 3.1g below) [X] $3,900.00
17 [l Unknown
18 II. PERSONAL INFORMATION

2.1 Occupation: Electrical Systems Designer
19 2.2 The highest year of educalion completed:
2.3 Are you presently employed? [X] Yes [ ] No
20 a. If yes: (1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
21 (2) When did you start work there? (month/year)
22 b. If no: 1. When did you last work? (month/year)
23 2. What were your gross monthly earnings?
24 (3) Why are you presently unemployed?
25
FINANCIAL DECLARATION (FNDCLR) - Page 1 of 6 CARL J. GAUL
WPF DRPSCU 01.1550 (6/2004)- RCW 26.18.220 (1) Attorney at Law
302 Bank of America Building~
1604 Hewitt Avenue
Everett WA 98201
ORIGINAL
SupportCa/c/FD 2005 425 259 4147 fax 259 7081
I\(
1
2 Ill. INCOME INFORMATION
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip
3
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
4 optional.)
5
3.1 GROSS MONTHLY INCOME.
6 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
7 you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that
amount below.
8 Andrew Rife Jennifer Rife
a. Imputed Income
b. Wages and Salaries $4,327.00 $3,900.00
9
c. Interest and Dividend Income
d. Business Income
10 e. Spousal Maintenance Received
From
11 f. Other Income $600.00
g. Total Gross Monthly Income $4,927.00 $3,900.00
12 {add lines 3.1a through 3.1e)
h. Actual Gross Income (Year-to-date)
13
14 3.2 MONTHLY DEDUCTIONS FROM GROSS INCOME.

Andrew Rife Jennifer Rife
a. Income Taxes $633.00 $286.88
15
b. FICA/Self-employment Taxes $875.59 $596.70
c. State Industrial Insurance Deductions
16 d. MANDATORY Union/Professional Dues
e. Pension Plan Payments $90.86
17 f, Spousal Maintenance Paid
g. Normal Business Expenses
18 h. Total Deductions from Gross Income $1,599.45 $883.58
{add lines 3.2a through 3.2g)
19
3.3 MONTHLY NET INCOME. (Line 3.1f minus line 3.2h $3,327.55 $3,016.42
20
QLline 3 from the Child Support Worksheet(s).)
21
22
23
24
25
302 Bank of America Building
1604 Hewitt Avenue
Everett WA 98201
SupportCa/c/FO 2005 425 259 4147 fax 259 7081
f
1 3.4 MISCELLANEOUS INCOME. Andrew Rife Jennifer Rife

a. Child support received from other relationships
2 Name:
Name:
3 b. Other miscellaneous income
(list source and amounts)
4 Income of current spouse

Name:
Name:
5 Income of children
Name:
6 Name:
Income from assistance programs
7 Name:
Name:
8 Non-recurring income
Name:
9 Name:
Other Income:
10
11
c. Total Miscellaneous Income
12 (add lines 3.4a through 3.4b)
13 3.5 Income of Other Adults in Household

Name:
Name:
14
3.6 If the income of either party is disputed, state monthly income you believe is correct and
15 explain below:
16 IV. AVAILABLE ASSETS

4.1 Cash on hand
17 4.2 On deposit in banks
4.3 Stocks and bonds
18 Cash value of life insurance
4.4 Other liquid assets:
19
V. MONTHLY EXPENSE INFORMATION
20 Monthly expenses for myself and dependents are: (Expenses should be calculated for the future, after
separation, based on the anticipated residential schedule for the children.)
21
5.1 HOUSING.
Rent, 1st mortgage or contract payments $927.00
22 Installment payments for other mortgages or $100.00
encumbrances
23 Taxes & insurance (if not in monthly payment)
Total Housing $1,027.00
24
25
1604 Hewitt Avenue
Everett WA 98201
SupportCa/clFD 2005 425 259 4147 fax 259 7081
,
1
5.2 UTILITIES.
Heat (gas & oil)
2 Electricity $120.00
Water, sewer, garbage $80.00
3 Telephone $80.00
Cable $61.80
4 Other: cell $100.00
Total Utilities $441.80
5
5.3 FOOD AND SUPPLIES
6 Food for persons $200.00
Supplies (paper, tobacco, pets) $50.00
7 Meals eaten out $250.00
Other:
8 Total Food Supplies $500.00
5.4 CHILDREN.
9
Day Care/Babysitting $100.00
Clothing $50.00
10 Tuition (if any)
Other child-related expenses $75.00
11 Total Expenses Children $225.00
12 5.5 TRANSPORTATION.
Vehicle payments or leases $527.00
13 Vehicle insurance & license $208.00
Vehicle gas, oil, ordinary maintenance $100.00
14 Parking
Other transportation expenses
Total Transportation $835.00
15
5.6 HEALTH CARE. (Omit if fully covered)
16 Insurance $47.00
Uninsured dental, orthodontic, medical, eye
17 care expenses
Other uninsured health expenses
18 Total Health Care $47.00
5.7 PERSONAL EXPENSES. (Not including children).
19 Clothing $50.00
Hair care/personal care expenses $20.00
20 Clubs and recreation $20.00
Education
21 Books, newspapers, magazines, photos
Gifts $80.00
22 Other:
Total Personal Expenses $170.00
23
24
25
WPF DRPSCU 01.1550 (6/2004) - RCW 26.18.220 (1) Attorney at Law
1604 Hewitt Avenue
Everett WA 98201
SupportCa/c/FO 2005
425 259 4147 fax 259 7081
J
1
5.8 MISCELLANEOUS EXPENSES.
Life insurance (if not deducted from income)
2 Other:
Other:
3 Total Miscellaneous Expenses
5.9 TOTAL HOUSEHOLD EXPENSES $3,245.80
4
(The total of Paragraphs 5.1 through 5.8)
5 5.10 INSTALLMENT DEBTS INCLUDED IN PARAGRAPHS 5.1 THROUGH 5.8.
Creditor/Description of Debt Balance Month of Last Payment
6 VISA $1,900.00 10/05
10
5.11 OTHER DEBTS AND MONTHLY EXPENSES NOT INCLUDED IN PARAGRAPHS 5.1 - 5.8
11 Month of Amount of
Creditor/Description of Debt Balance Last Payment Monthly Payment
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FINANCIAL DECLARATION (FNDCLR)- Page 5 of 6 CARL J, GAUL
1604 Hewitt Avenue
Everett WA 98201
SupportCafc/FD 2005 425 259 4147 fax 259 7081
•
"
1 Total Monthly Payments for Other Debts and Monthly
Expenses
2
TOTAL EXPENSES (Add Paragraphs 5.9 and 5.11) $3,245.80
3
VI. ATIORNEY FEES
4
6.1 Amount paid for attorney fees and costs to date:
5
6.2 The source of this money was:
6
6.3 Fees and costs incurred to date:
7 6.4 Arrangements for attorney fees and costs are:
8 6.5 Other:
9
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
1 o correct.
11
Signedat C~ . [City] ~ [State] on ( cJ /r $/o ~ [Date].
I I
12
13
14 Signature of Declarant
15 The following financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:

16
[] Individual [] Partnership or Corporate Income Tax returns for
17 the years: including all W-2s and schedules;
18 [ ] Pay stubs for the dates of
19 [] Other:
20 DO NOT ATIACH 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
21
(WPF DRPSCU 09.0220). IF FILED SEPARATELY USING THE COVER SHEET, THE RECORDS
WILL BE SEALED TO PROTECT YOUR PRIVACY (ALTHOUGH THEY WILL BE AVAILABLE TO THE
22 OTHER PARTIES IN THE CASE, THEIR ATIORNEYS, AND CERTAIN OTHER INTERESTED
PERSONS. SEE GR 22 (C)(2)).
23
24
25
1604 Hewitt Avenue
Everett WA 98201
SupportCalc/FD 2005
425 259 4147 fax 259 7081
(
IlllllllllllllCL11169192
Ill lllll llllllllll lllll lllll lllll lllll llll llll .F\\._ED
1 05 OCT I 9 PH 3: 44
PhM L. !)/;i'l\ELS
2 couin Y cLERI\
·SH OHO MISH CO. 'ii t, SH.
3
4
5
6
COUNTY OF SNOHOMISH
8
05 3 0 27 55 1
NO.
9 Andrew Scott Rife
Petitioner, EX PARTE RESTRAINING
10 and ORDER/ORDER TO SHOW CAUSE
(TPROTSC)
11 Jennifer Rae Rife
Clerk's Action Required
12 Res ondent.
'it Restraining Order Summary:
~ 13
...j Restraining Order Summary is set forth below:
14 Name of person(s) restrained: Andrew Scott Rife, Jennifer Rae Rife

~
"3. 15 Name of person(s) protected: Jennifer Rae Rife, Andrew Scott Rife
See paragraph 4.1.
~
16
\U 17 KNOWLEDGE OF ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50

RCW AND WILL SUBJECT THE VIOLATOR TO ARREST. RCW 26.09.060.
18
I. SHOW CAUSE ORDER.
19
It is ordered that the wife appear and show cause, if any, why the restraints below should not be
continued in full force and effect pending final aetermination of this action and why the other
20
relief, if any, requested in paragraph 1.3 of the motion should not be granted. A hearing has been
set for the following date, time and place:
21
22 Date: NOVEMBER I, 2005 Time: 9:00 a.m.

Place: Snohomish County Courthouse Room/Department:
23 3000 Rockefeller As Assigned
Everett WA 98201 commissioner's Department B or c
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
EX PARTE RESTRAINING ORD (TPROTSC) - P9{}.e_6 r'-
WPF DR 04.0170 (6/2004) - CR 65 (b); RCW ~lj9\qs~ INAL Everett WA 9820 I
42S 259-4147 FAX 259 7081
1 If you disagree with any part of the motion, you must respond to the motion in writing before the
hearing and by the deadline for your county. At the hearing, the court will consider WRITTEN
2 sworn affidavits or declarations. Oral testimony may NOT be allowed. To respond you must:
(l) tile your documents with the court; (2) provide a copy of those documents to the judge or
3
commissioner's staff; (3) serve the other party's 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
4 need more information, you are advised to consult an attorney or a courthouse facilitator.
FAILURE TO APPEAR MAY RESULT IN A TEMPORARY ORDER BEING ENTERED BY THE
5 COURT THAT GRANTS THE RELIEF REQUESTED IN THE MOTION WITHOUT FURTHER
OTICE.
6
7
FAILURE TO APPEAR MAY RESULT IN A TEMPORARY ORDER BEING ENTERED BY THE COURT
8 HAT GRANTS THE REUEF REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE.
9
II. BASIS
10 motion for a temporary restraining order without written or oral notice to the wife or that party's
lawyer has been made to this court.
11
III. FINDINGS
12
e court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte
13 Restraining Order and for an Order to Show cause (Form WPF DR 04.0150) as its findings, except
as follows:
14
IV. ORDER
15
It is ORDERED that:
16
17
18
19
20
21
22
23
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
EX PARTE RESTRAINING ORD (TPROTSC) - Page 2 Everett WA 9820 I
WPF DR 04.0170 (6/2004) - CR 65 (b); RCW 26.09.060 425 259-4147 FAX 259 7081
1 '1.1 "~.;,I. - • ..
2 VIOLATION OF A RESTRAINING ORDER IN PARAGRAPH 4.1 WITH ACTUAL NOTICE
OF ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL
3 SUBJECT THE VIOLATOR TO ARREST. RCW 26.09.060.
Both parties is restrained and enjoined from molesting or disturbing the peace of the
4 other party or of any child.
The wife is restrained and enjoined from going onto the grounds of or entering the
5 home, work place or school of the other party.
The wife is restrained and enjoined from knowingly coming within or knowingly
6 remaining within 100 yards of the home, work place or school of the other
party
7
CLERK'S ACTION. The clerk of the court shall forward a copy of this order, on or
8 before the next judicial day, to City of Everett Police Department [name of the
appropriate law enforcement agency] which shall enter this order into any
9 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 J?arty's
10 attorney and provided with this order before this order will be
entered into the law enforcement computer system.)
11
12
4.2 OTHER RESTRAINING ORDERS.
13
14 Both parties are restrained and enjoined from transferring, removing, encumbering,
concealing or in any way disposing of any property except in the usual course of
15 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.
16 Both parties is restrained and enjoined from removing any of the children from the state of
Washington.
17 Both parties is restrained and enjoined from assigning, transferrin~, borrowing, lapsing,
surrendering or changing entitlement of any insurance policies of either or both
parties whether medical, health, life or auto insurance.
18
Other:
19
20
21 4.3 SURRENDER OF DEADLY WEAPONS.
22 Does not apply.

The court finds that irreparable injury could result if an order is not issued until the
time for response has elapsed. (See RCW 26.09.060(2)(b).)
23
4.4 EXPIRATION DATE.
24
This order shall expire on the hearing date set forth above or 14 days from the date of
25 issuance, which ever is sooner, unless otherwise extended by the court.
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
EX PARTE RESTRAINING ORD {TPROTSC} - Page 3 Everett WA 9820 I
WPF DR 04.0170 {6/2004) - CR 65 (b); RCW 26.09.060 425 259-4147 FAX 259 7081
"
1
4.5 WAIVER OF BOND.
2
The filing of a bond or the posting of security is waived.
3
4.6 Other:
4 The Petitioner's Motion for Temporary Orders shall also be heard at the date and time
established in Part I of this Order.
5
6
Dated: OCT 19 2003
7
Presented bY)
8
9
10
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12
13
14
15
16
17
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22
23
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26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
EX PARTE RESTRAINING ORD {TPROTSC} - Page 4 Everett WA 9820 I
WPF DR 04.0170 (6/2004) - CR 65 (b); RCW 26.09.060 425 259-4147 FAX 259 7081
I Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
FILED
CL11169195 05 OCT 19 PM 3: l+l+
2 PAtl l. Di'.Nl:Cl.S
COUNTY CLrnK
S?WHOMISH CO. 'ii A SH.
3
4
5
COUNTY OF SNOHOMISH
7
8
Andrew Scott Rife 05 3 02755 I
Petitioner, NO.
9 and
MOTION/DECLARATION FOR EX
10 Jennifer Rae Rife PARTE RESTRAINING ORDER AND
Respondent. FOR ORDER TO SHOW CAUSE
11 (MTAF)
12 I. MOTION
13 Based upon the declaration below, the undersigned moves the court for a temporary order and
order to show cause.
14
1.1 EX PARTE RESTRAINING ORDER.
15
temporary restraining order should be granted without written or oral notice to the other
16 party or the other party's lawyer because immediate and irreparable injury, loss, or damage will
result before other party or the other party's lawyer can be heard in opposition. This order
17 should restrain or enjoin:
18 each of the parties from transferring, removing, encumbering, concealing or in any way
disposing of any property except in the usual course of business or for the
19 necessities of life and requiring each party to notify the other of any
extraordinary expenditures made after the order is issued.
20 each of the parties from molesting or disturbing the peace of the other party or of any
child.
21 Jennifer Rae Rife from going onto the grounds of or entering the residence of Andrew
Scott Rife. Andrew Scott Rife waives confidentiality of the address which is 1317
22 McDougall Ave., Everett WA 98201
Jennifer Rae Rife from going onto the grounds of or entering the home, work place or
23 school of the other party
each of the parties from removing any of the children from the state of Washington.
24 each of the parties from assigning, transferring, borrowing, lapsing, surrendering or
changing entitlement of any insurance policies of either or both parties whether
25 medical, health, life or auto insurance.
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MTNIDECL FOR EX PARTE RESTRAINING ORD (MTAF) - Page I Everett WA 9820 I
WPF DR 04.0150 (612004)- CR 65 (b); RCW 26.09.060. 425 259-4147 FAA 259 7081
1 other:
2
The other party should be required to appear and show cause why these restraints should
3 not be continued in full force and effect pending final determination of this action.
4 1.2 OTHER EX PARTE RELIEF
5 Does not apply.
7 Does not apply.
8 1.4 OTHER TEMPORARY RELIEF.
9 Jennifer Rae Rife should also be required to appear and show cause why the court should
not enter a temporary order which:
10
orders child support as determined pursuant to the Washington State Child Support
11 Schedule.
approves the parenting plan which is proposed by the husband.
12 makes each party immediately responsible for their own future debts whether
incurred by credit card or loan, security interest or mortgage.
13 divides responsibility for the debts of the parties.
authorizes the family home located at 2416 5th St., Everett WA to be occupied by
14 the husband.
orders the use of property, particularly to grant the husband the temporary use
15 and possession of the 2004 BMW 325i, WA license 563 SEV.
requires the wife to vacate the family home.
16 appoints a guardian ad litem on behalf of the minor child.
17 1.5 OTHER.
18
Dated: October 17, 2005
19
20
21
22 2.1 INJURY TO BE PREVENTED.
23 The ex parte restraining order requested in paragraph 1.1 above is to prevent the following
injury [define the injury]:
24
To avoid dissipation of assets, disturbance of the peace and unilateral changes to
25 insurances.
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MTNIDECL FOR EX PARTE RESTRAINING ORD (MTAF) - Page 2 Everett WA 9820 I
WPF DR 04.0150 (612004) - CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
,.
3
4 2.2 REASONS WHY THE INJURY MAY BE IRREPARABLE.
5 This injury may be irreparable because:
6 To avoid dissipation of assets. Wife has expressed through counsel a need for funds not
understood by husband. The assets should be preserved.
7
The wife has used domestic disagreements as occasions for extreme discord and has
8 involved the police in situations she fomented. Such conduct should not be allowed to
occur in the future.
9
The parties need the insurance they have.
10
2.3 REASONS FOR OTHER EX PARTE RELIEF.
11
It is necessary that the court issue the other ex parte relief in paragraph 1.2 above for the
12 reasons set forth below:
13 The parties should both be prohibited from participating in situations likely to create new
incidents of discord.
14
2.4 CLEAR AND CONVINCING REASONS WHY WEAPONS SHOULD BE SURRENDERED.
15
Does not apply.
16
2.5 REASONS FOR A TEMPORARY ORDER.
17
It is necessary that the court issue a temporary order with the relief requested in
18 paragraph 1.3 above for the reason set forth below:
19
Financial Restraints
20
I am asking the court to prohibit dissipation of assets, incurring new community debt or
21 taking unilateral action with the personal property. I believe this is necessary to keep my wife
from unilaterally taking the bulk of the household furniture and furnishings which I owned before
22 the marriage. The insurances which protect us both should remain in place. Each of us should be
responsible for our own individual obligations to be incurred in the future.
23
We have lived a generally debt free life. The only debts we are paying are for the house,
24 which is my separate property as I purchased it three years before the marriage, which was
before I ever met her, and the BMW which I purchased three months before the marriage. The
25 mortgage is paid by automatic withdrawal from the Washington Mutual bank account, $927 per
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
WPF DR 04.0I50 (612004)- CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
-------------·- -
1 month. The BMW debt is paid by payroll deduction because it is financed through the PUD Credit
Union. That debt is $527 per month. The money that pays these debts is my current earnings. I
2 had a VISA account with PUD Credit Union. This was my account and Jennifer was an authorized
signer but was not liable on the account. I cancelled the account at the time of separation, and I
3 expect to pay the approximately $1900 balance outstanding. There were no other credit cards.
4 Personal Restraints
5 The court is doubtless aware that my wife and I have recently had an explosive
relationship. She has falsely accused me of being violent with her, while the cause of the
6 incidents of which she complains is her physical aggression. These incidents have uniformly
occured when she has been intoxicated. I have no intention of contacting her. But she has been
7 contacting me, for example see the attached letter I received from her about October 13. I need
the protection of having a restraining order reventing annoying conduct, and from the possibility
8 she would come to my home or workplace. She has driven by the place where I am now living.
9 Use of Real Property / Personal Property
10 I am asking the court to grant me the temporary use and possession of my separate
property real estate, 2416 Fifth Street, Everett WA. I am attaching a copy of the deed from when
11 I purchased the property. It is my separate property. Jennifer should be required to vacate the
premises immediately. I am also asking for the contents of the house, except the kitchen table
12 and cookware which she brought.
13 There is also a computer and a desk Jennifer uses in her work. They were purchased
during the marriage but there is no reason she should not take them.
14
There is also a BMW 325i which belongs to me as it is my premarital separate property. I
15 want it, and I do not want to leave it with her. Her attorney has volunteered that she would make
the payments on the car, but I do not trust her to do this. Her history does not justify the faith
16 she would make the payments.
17 At the time we met Jennifer was living in a condominium at 14007 69th Dr. SE,# T- 3,
Snohomish. Her mortgage payments were in arrears and it was in the foreclosure process. She
18 sold it just before the foreclosure date. I paid the seller's closing costs approximating $3200. She
was bankrupt. She had filed a chapter 13 bankruptcy sometime before I met her, but had not
19 made the payments. Jennifer returned her 1999 BMW 323i to the Seattle Metropolitan Credit
Union in February 2004. She was approximately six months in arrears on her BMW payments
20 when she turned it in. She converted her chapter 13 to a chapter 7 bankruptcy in March 2004. I
paid $1200 to the IRS on her old obligations.
21
Parenting Plan
22
I am asking the Court to appoint a guardian ad litem for our daughter.
23
My wife will doubtless claim that I have engaged in domestic violence conduct. I do
24 acknowledge that I have used force against her, but only after she has commenced assaults of me
and only to prevent or restrain her from the assaults she has commenced. My wife is not at all
25 afraid of me, because she knows I will not hurt her. Her lawyer pointed out to mine that I have a
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
WPF DR 04.0150 (612004) - CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
1 black belt in Karate, which is true. My lawyer pointed out to her lawyer that I have never used
those skills on Jennifer, nor would I. I have done such things as to grab ahold of her so that she
2 would not fall, than taken her feet out from under her and put her on the ground in order to
prevent her from continuing an assault of me. Her sister claims I had a fist full of Jennifer's
3 sweatshirt in the car one time. That much is true, but I was using it to hold Jennifer at arm's
length away from me. She had been assaulting me in the car. Of course the incident was loud
4 and unpleasant. Neither Jennifer nor I will look back on these incidents with any pride, but what I
did was not domestic violence.
5
Jennifer's attorney has told my attorney that she is not involved in any substance abuse
6 therapy. This is disturbing news. Jennifer and her family have told me that she was at
Edgewood, a chemical dependency treatment hospital on Vancouver Island, from October 2002
7 through December 2002. She went there after her parents, sister, brother in law and a counselor
conducted an intervention. While she was there she was being treated for cocaine abuse and
8 behavioral problems. I was never told what the behavioral problems might have been. I met her
the following April. When I first met her Jennifer would still occasionally use cocaine. I do not
9 know for sure when she discontinued use, I only know that after we had established a dating
relationship I was not aware of any ongoing use. During the months we were dating, roughtly
10 pril through August 2003, we would do dinners, movies, hikes, shopping, sight seeing and other
ordinary couples activities. These frequently included drinking. She liked white wine, Maragaritas
11 and beer. I was more predominantly a beer drinker preferring light American beers. This pattern
continued until we learned she was pregnant, in January 2004. At that point her drinking stopped,
12 and mine diminished sharply. Except the day we were married, to my knowledge she did not
drink during the balance of the pregnancy. As the birth of our daughter approached Jennifer was
13 eagerly anticipating her first Margarita. About a week after Lauren was born she got it. I do not
believe she has let a week go by without a drink since then. Jennifer likes to drink. Most evenings
14 she would have wine or beer to drink. I was drinking also, but less quantity and less frequently.
rough the summer of 2005 she was drinking to the point that I considered her to be under the
15 influence of alcohol several times per week. I would go to bed while she would continue to watch
television and sip, then would come to bed later. I would wake up when she came to bed, and
16 often noticed that she had slurred speech. About every two weeks or so we would have an
explosive incident involving loud arguments over trivial things. These generally occurred when she
17 had been drinking. I noticed that it did not always require booze for her behavior. The times she
assaulted me, however, were all times when she had been drinking. Twice she has assaulted me
18 while I had our daughter in my arms. Both times she was drunk.
19 I believe that my wife's assaults and her explosive temper are at least partly caused by her
alcohol consumption. Our daughter has been witness to the arguments between Jennifer and me.
20 e arguments are frightening for Jennifer and for me. Certainly they must be frightening for
Lauren also.
21
I do not expect the court to lightly dismiss my wife's claims of domestic violence. Neither
22 do I expect the court to lightly dismiss my report of her history of abusing herself with alcohol and
cocaine. I do expect the court to want to have a report from a guardian ad litem and to get the
23 GAL's specific evaluation of these factors. Until the GAL makes a report I am asking the court to
enter a parenting plan providing for equal time with each parent.
24
I do not know if I will want to be the primary residential parent. But I do know that I
25 could be.
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MTN/DECL FOR EX PARTE RESTRAINING ORD (MTAF) - Page 5 Everett WA 9820 I
WPF DR 04.0I50 (612004)- CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
1 Our ordinary routine was that I would go to work at the PUD, starting work at 6:30 a.m.
Because I live and work in town, I was able to come home during my break between 8:00 and
2 8: 15 a.m. every day. Jennifer would be just getting up herself and I would get Lauren up, change
her, get her swing ready and set her up for her morning bottle. While I was doing that, Jennifer
3 would be preparing the bottle. We would visit for a few minutes, then I would go back to work
and Jennifer would go back to bed. Lauren would fall asleep in her swing, then wake up again
4 when Jennifer got going later in the day, usually about 11:00 a.m. I generally would not come
home at noon. Sometimes I would go home during the afternoon break to play with the baby and
5 visit with Jennifer for a few minutes then return to work. I would generally get home about 4:30
p.m. We would visit a little before Jennifer would go out. She worked as a mobile notary through
6 First American Title's Everett and Marysville offices. She would pick up documents for real estate
closings, travel to the places where the vendors and purchasers would sign, then return the
7 documents then come home. If she had signings during the day Lauren was babysat by Jennifer's
sister, her mother or my mother. I was home alone with the baby about half the evenings.
8 Sometimes she would drop off the documents at First American Title's office, other times she
would come home with the documents, in which case I would ordinarily deliver them for her that
9 evening or the next day. Jennifer worked three to four days each week. Lauren is one year old
now. I spent a lot of time with her in my lap, pulling her around in her wagon, playing with her on
10 the floor with her toys. I spent a lot of time almost every day in one-on-one interaction with our
daughter. I read to her in the rocking chair, though she had a tendency to grab the book and
11 gnaw on it. Jennifer and I prepared and fed Lauren dinner jointly if we both were there. We also
did the bathtime / bedtime routines jointly. I was always the one to put her into bed, every night.
12
Jennifer has told me that she knows she cannot continue to work as a mobile notary and
13 that she will be getting a job where she is actually located in a title company's office. This means
that there will be a need for child care. I have found a suitable in-home daycare within about five
14 minutes of the house and my office.
15 Pending receipt of a Guardian ad Litem's report I ask the court to establish an alternating
days residential schedule. ;J /
~~tJftl tC6 ·
1
1: Dated:
An rewscott Rife 1
18
19 DO NOT ATTACH FINANCIAL RECORDS TO THIS DECLARATION. FINANCIAL RECORDS SHOULD
BE SERVED ON THE OTHER PARTY AND FILED WITH THE COURT SEPARATELY USING THE
20 SEALED FINANCIAL SOURCE DOCUMENTS COVER SHEET (WPF DRPSCU 09.0220). IF FILED
SEPARATELY USING THE COVER SHEET, THE RECORDS WILL BE SEALED TO PROTECT YOUR
21 PRIVACY (ALTHOUGH THEY WILL BE AVAILABLE TO THE OTHER PARTIES IN THE CASE, THEIR
TTORNEYS, AND CERTAIN OTHER INTERESTED PERSONS. SEE GR 22 (C)(2)).
22
23
III. EFFORTS TO GIVE OTHER PARTY NOTICE.
24
he following efforts have been made to give the other party or other party's lawyer notice and
25 the following reasons exist why notice should not be required:
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
WPF DR 04.0150 (612004) - CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
•
2
CARUJ. GAUL WSBA# 341
3
Attorney for Andrew S o,5Rife
4
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
WPF DR 04.0150 (612004)- CR 65 (b); RCW 26.09.060. 425 259-4147 FAX 259 7081
----- ------------
Washington State Child Support Schedule\ LED

Worksheets (CSW) - -- ~ OC1 25 PH 12: 00
Mother: Jennifer Rife Father: Andrew Rife .· .:.ri L. DANIELS
- COUNTY CLERK
.SHOHOtllSH CO.WASH.
c ouncv:
t s no h om1s. h s uperior c ourt c ase N um ber: 05 -3 -02755 -1 .•.
Children and Ages: LR. - 1
a. Wages and Salaries $4,438 $2,798
b. Interest and Dividend Income $ $
c. Business Income $ $
d. Spousal Maintenance Received $ $
e. Other Income $ $
(add lines 1a through 1e) $4,438 $2,798
a. Income Taxes (Federal and State) $338 $700
b. FICA (Soc.Sec. +Medicare)/Self-Employment Taxes $60.50 $
c. State Industrial Insurance Deductions $ $
d. Mandatory Union/Professional Dues $ $
e. Pension Plan Payments $166 $166
f. Spousal Maintenance Paid $ $
g. Normal Business Expenses $ $
h. Total Deductions from Gross Income
(add lines 2a through 2g) $564.50 $d66.00
(line 11 minus 2h) $3,873.50 $1,932
(add father's and mother's monthly net incomes from line 3) $5,805
(If combined monthly net income is less than $600, skip to line
7.)
5. Basic Child Support Obligation
Child: $837
$837
Father Mother
(each parent's net income from line 3 divided by line 4) .67 .33
(multiply each number on line 6 by line 5)
(If combined net monthly income on line 4 is less than $600,
enter each parent's support obligation of $25 per child. Number
of children: . Skip to line 15a and enter this amount.) $561 $276
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 7)
8. Health Care Expenses
a. Monthly Health Insurance Premiums Paid for Child(ren) $47.00 $
WSCSS-Worksheets (CSW) 9/2000 Page 1
b. Uninsured Monthly Health Care Expenses Paid for Child(ren) $ $
(line Ba plus line 8b) $ $
(add father's and mother's totals from line 8c) $41.85
(multiply line 5 times .05) $
(line 8d minus line Be., if "O" or negative, enter "O") $5.15
9. Day Care and Special Child Rearing Expenses
a. Day Care Expenses $ $
b. Education Expenses $ $
c. Long Distance Transportation Expenses $ $
d. Other Special Expenses (describe) $ $
$ $
$ $
(Add lines 9a through 9d) $ $
10.Combined Monthly Total Day Care and Special Expenses (add
father's and mother's day care and special expenses from line See order of
9e) child support
Expenses $5.15
(line Bf olus line 10)
12. Each Parent's Obligation for Extraordinary Health Care, Day
Care, $3.45 $1.70
and Special Expenses (multiply each number on line 6 by line
11)
13. Gross Child Support Obligation (line 7 plus line 12) $566.15 $277.70
Part IV: Child Suooort Credits (See Instructions, PaQe 7)
14.Child Suooort Credits
a. Monthly Health Care Expenses Credit $47 $
b. Day Care and Special Expenses Credit $ $
$ $
d. Total Support Credits (add lines 14a through 14c) $ $

Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 8)
a. Amount from line 7 if line 4 is below $600. Skip to Part VI. $561 $276
b. Line 13 minus line 14d, if line 4 is over $600 (see below if $519.15 $277.70
appl.)
Limitation standards adjustments
c. Amount on line 1Sb adjusted to meet 45% net income limitation $ $
d. Amount on line 15b adjusted to meet need standard limitation $ $

Part VI: Additional Factors for Consideration (See Instructions, Paqe 8)
(List the estimated present value of all maier household assets.) Household Household
a. Real Estate $ $
b. Stocks and Bonds $ $
c. Vehicles $ $
d. Boats $ $
e. Pensions/IRAs/Bank Accounts $ $
f. Cash $ $
g. Insurance Plans $ $
h. Other (describe) $ $
$ $
$ $
17. Household Debt
(List liens aaainst household assets, extraordinarv debt.)
$ $
$ $
$ $
$ $
$ $
18.0ther Household Income
a. Income Of Current Spouse (if not the other parent of this
action)
$ $
Name
$ $
Name
b. Income Of Other Adults In Household

Name $ $
$ $
Name
c. Income Of Children (if considered extraordinary)

Name $ $
$ $
Name
d. Income From Child Support

Name $ $
$ $
Name

Father's Mother's
e. Income From Assistance Programs
Program $ $
$ $
Program

$ $
$ $
--
19.Non-Recurring Income (describe)

$ $
$ $
--
20. Child Support Paid For Other Children

Name/age: $ $
Name/age: $ $
Name/age: $ $


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.
Date City Date City
Judge/Reviewing Officer Date
This worksheet has been certified by the State of Washington Office of the Administrator for the
Courts.

'• .. "'-
·,.:I LE 0
"'i OC1 2t. Ali\ I: 22
CL 11100648
\I\~\ \ \ \~\ ~\ \ \ im\\\
\\ \1\ 1111\11\\I\\\\\\\\\\
,. h L. DANIELS
. fouHTY CLERK
sHOHOHISH CO.WASH.
SUPERIOR COURT, IN AND FOR THE COUNTY OF SNOHOMISH, STATE OF

WASHINGTON
IN RE THE MARRIAGE OF: Cause#: 05 3 02755 1
ANDREW scon RIFE,
Plaintiff/Petitioner
Declaration of Service of:
vs. SUMMONS AND PETITION FOR DISSOLUTION OF
JENNIFER RAE RIFE, MARRIAGE EX PARTE RESTRAINING ORDER ORDER TO
Defendant/Respondent SHOW CAUSE, MOTION/ DECLARATION FOR EX PARTE
RESTRAINING ORDER AND FOR ORDER TO SHOW
CAUSE, PROPOSED PARENTING PLAN PROPOSED,
FINANCIAL DECLARATION PETITION, WASHINGTON
STATE CHILD SUPPORT SCHEDULE WORKSHEETS.
SEALED FINANCIAL SOURCE DOCUMENTS.
CONFIDENTIAL INFORMATION FORM,
Hearing Date: Nov 1 2005
Declaration:
The undersigned hereby declares: That s(he) is now and at all times herein mentioned, a citizen of the United
States and a resident of the State of Washington, over the age of eighteen, not an officer of a plaintiff
corporation, not a party to nor interested in the above entitled action, and is competent to be a witness
therein.
On the date and time of Oct 20 2005 6:49PM at the address of 2416 FIFrH ST EVERETT, within the
County of SNOHOMISH, State of WASHINGTON, the declarant duly served the above described
documents upon JENNIFER RAE RIFE by then and there personally delivering 1 true and correct
copy(ies) thereof, by then presenting to and leaving the same with JENNIFER RAE RIFE A White female
approx. 35-40 years of age 5'6"-5'8" in height weighing 160-180 lbs with blonde hair.
No information was provided that indicates that the subjects served are members of the U.S. military.
I hereby declare under penalty of perjury under the laws of the State of Washington that the foregoing is true
and correct.
Dated: October 21, 2005 at Everett, WA
by Service Fee Total:$ 75.55

D. Bennett 2004-22 """'
ABC Legal Services, Inc. Gaul, Carl

(206) 521-9000 ORIGINAL 1604 Hewitt Ave, #502
Tracking#: 3687213 PROOF OF SERVICE Everett, WA 98201
11m~n~moo1~
425 259-4147
Page I of I
. . .....,,_
~
J... '
SUPERIOR COURT OF WASHINGTI0"-1

COUNTY OF SNOHOMISH
Andrew Scott Rife
Petitic>neer, ~~ 3 0 27 55
and SUMMONS
Jennifer Rae Rife (SM)
Res nilemt
TO THE RESPONDENT:
The petitioner has started an action in the above court requesting that your
marriage be dissolved. Addi!:ioniJI requests, if any, are stated in the petition, a
copy of which is attached to thi:S s11111 mcnns.
You must respond to this summcms a1ndH petition by serving a copy of your
written response on the person sigrnhg this summons and by filing the original
with the clerk of the court. [f you a:Jo ncnt serve your written response within 20
days (or 50 days if you are S€rved 1101Dtsiiide of the state of Washington) after the
date this summons was served on '(fo1u, ·exclusive of the day of service, the court
may enter an order of default against yrou, and the court may, without further
notice to you, enter a decree and a1i:;proove or provide for the relief requested in
the petition. In the case of a dissol l~ti:iom of marriage, the court will not enter the
final decree until at least 90 da)'s a;fterffiling and service. If you serve a notice of
appearance on the undersigned peu-s:Jn,, you are entitled to notice before an
order of default or a decree may be entxered.
Your written response to the sumrmcns ;and petition must be on form WPF DR
01.0300, Response to Petition (Doll'lle!sti1ic Relations). This form may be obtained
by contacting the clerk of the court alt tlhe address below, by contacting the
Administrative Office of the Courts at (3!50) 705-5328, or from the Internet at
the Washington State Courts home1 p11gee:
http:/ /www.courts.wa.g• Olll/fforms
CARLJ.GAUL
Attorney at law
1604 Hewitt Ave.
SUMMONS (SM) - Page 1 Everett WA 9820 I
WPF DR 01.0200 (6/2002) ·CR 4.1 425 259-4147 FAX 259 7081
2UD5 NOV - I PM 12: 34
1
rki'i L. DANIELS
2 Illlllll llllll Ill lllll lllll lllll lllll lllll l l l I/Ill llll llll COUNTY CLERK
CL 11209200 SNOHOMISH CO. \'/ASH.
3
5
IN THE SUPERIOR COURT OF WASHINGTON
6 IN AND FOR SNOHOMISH
7 In re the Marriage of:
c)1..-:r.;;:s- - i.
8 Andrew Scott Rife NO. O-§, °3- 6'.>El""), '/ (j
Petitioner,
9 and ORDER OF CHILD SUPPORT
(ORS)
Respondent.
11 Clerk's Action Required
12 I. JUDGMENT SUMMARY
13 Does not apply because no attorney's fees or back child support has been ordered.
14 II. BASIS
15 2.1 TYPE OF PROCEEDING.
16 This order is entered pursuant to:
a hearing for temporary child support.
17
2.2 CHILD SUPPORT WORKSHEET.
18
The child support worksheet which has been approved by the court is attached to this order
19 and is incorporated by reference or has been initialed and filed separately and is
incorporated by reference.
20
2.3 OTHER:
21
22
III. FINDINGS AND ORDER
23
IT IS ORDERED that:
24
3.1 CHILDREN FOR WHOM SUPPORT IS REQUIRED.
25
26 CARLJ. GAUL
Attomey at Law
27
ORD~so~~HILD SUPPORT CORSI -
WPF DR 01.0500 {9/2001) - RCW 26.09.175; 26.26.132(5)
Page 1 ·~ ( ~..... I ~Al_ 302 Bank of America Bldg.
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
Name Cfirstflastl Age
LER 1
PERSON PAYING SUPPORT (OBLIGOR).
Name (first/last):
Birth date:
Service Address: [You may list an
address that is not your
residential address where you
agree to accept legal /b 17 fl/'' f.Jo'-'--PI( ~
documents.]
C~, &-A- rt8W I
THE OBLIGOR PARENT MUST IMMEDIATELY FILE WITH THE COURT AND THE
WASHINGTON STATE CHILD SUPPORT REGISTRY, AND UPDATE AS NECESSARY, THE
CONFIDENTIAL INFORMATION FORM REQUIRED BY RCW 26.23.050.
THE OBLIGOR PARENT SHALL UPDATE THE INFORMATION REQUIRED BY PARAGRAPH

3.2 PROMPTLY AFTER ANY CHANGE IN THE INFORMATION. THE DUTY TO UPDATE THE
INFORMATION CONTINUES AS LONG AS ANY MONTHLY SUPPORT REMAINS DUE OR ANY
UNPAID SUPPORT DEBT REMAINS DUE UNDER THIS ORDER.
Monthly Net Income: $ 3 ·s 3 ~

PERSON RECEMNG SUPPORT (OBLIGEE):
Name (first/last):
Birth date:
Service Address: [You may list an
address that is not your
residential address where you
agree to accept legal
documents.]
THE OBLIGEE 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 OBLIGEE PARENT SHALL UPDATE THE INFORMATION REQUIRED BY PARAGRAPH

3.3 PROMPTLY AFTER ANY CHANGE IN THE INFORMATION. THE DUTY TO UPDATE THE
INFORMATION CONTINUES AS LONG AS ANY MONTHLY SUPPORT REMAINS DUE OR ANY
UNPAID SUPPORT DEBT REMAINS DUE UNDER THIS ORDER.
CARLJ.GAUL
Attorney at Law
OROER OF CHILO SUPPORT (ORSI - Page 2 1604 Hewitt Ave.
WPF DR 01.0500 (9/2001) - RCW 26.09.175; 26.26.132(5) Everett WA 98201
425 259-4147 FAX 259 7081
1
Monthly Net Income: $ -z_. f ()Q
2
3 The obliger may be able to seek reimbursement for day care or special child rearing
expenses not actually incurred. RON 26.19.080.
4
3.4 SERVICE OF PROCESS.
5
SERVICE OF PROCESS ON THE OBUGOR AT THE ADDRESS REQUIRED BY
6 PARAGRAPH 3.2 OR ANY UPDATED ADDRESS, OR ON THE OBUGEE AT THE
ADDRESS REQUIRED BY PARAGRAPH 3.3 OR ANY UPDATED ADDRESS, MAY BE
7 ALLOWED OR ACCEPTED AS ADEQUATE IN ANY PROCEEDING TO ESTABUSH,
ENFORCE OR MODIFY A CHILD SUPPORT ORDER BETWEEN THE PARTIES BY
8 DEUVERY OF WRITTEN NOTICE TO THE OBUGOR OR OBUGEE AT THE LAST
ADDRESS PROVIDED.
9
3.5 TRANSFER PAYMENT. s,.,_ 3. -i-z.. - ~,.,.., ....,,
10 .. J <J(/_ :&:, .... ('.('.r<"c- ._.\,...... ~ ....-""""'-1-
4-'-'-ML.:!__.-
The obliger parent shall pay$ __ _ _ per month. ~ o..1<>.
11
THE OBUGOR PARENT'S PRIVILEGES TO OBTAIN OR MAINTAIN A UCENSE,
12 CERTIFICATE, REGISTRATION, PERMIT, APPROVAL, OR OTHER SIMILAR
DOCUMENT ISSUED BY A UCENSING ENTITY EVIDENCING ADMISSION TO OR
13 GRANTING AUTHORITY TO ENGAGE IN A PROFESSION, OCCUPATION,
BUSINESS, INDUSTRY, RECREATIONAL PURSUIT, OR THE OPERATION OF A
14 MOTOR VEHICLE MAY BE DENIED OR MAY BE SUSPENDED IF THE OBUGOR
PARENT IS NOT IN COMPUANCE WITH THIS SUPPORT ORDER AS PROVIDED
15 IN CHAPTER 74.lOA REVISED CODE OF WASHINGTON.
16 3.6 STANDARD CALCULATION.
17 $ __ cf.......,,~~·_.,.-__ per month. (See Worksheet line 15.)
18 3.7 REASONS FOR DEVIATION FROM STANDARD CALCULATION.
19 The child support amount ordered in paragraph 3.5 does not deviate from the
standard calculation.
20 The child support amount ordered in paragraph 3.5 deviates from the standard
calculation for the following reasons:
21
22 3.8 REASONS WHY REQUEST FOR DEVIATION WAS DENIED.
23
A deviation was not requested.
24
25 3.9 STARTING DATE AND DAY TO BE PAID.
26 CARLJ. GAUL
Attorney at Law
ORDER OF CHILD SUPPORT (ORS) - Page 3 1604 Hewitt Ave.
425 259-4147 FAX 259 7081
1 Starting Date:
Day of the month support is due: The first day of each month \ \
2
~<...>,\.... ~ ... A- <:> \"" (J c}." ... ~\. \._~ '()
\, \\ '" "
3.10 INCREMENTAL PAYMENTS.
3 G_;_ ..,j.1..,,,.,,..~ {"°<H'" \--)...ou-<-1,,-<.r 7'-'<>S:._
Does not apply. \c:. >t,...~,_.. .,,\ ""be.~ ,..., ~c.... 200""·
4
3.11 HOW SUPPORT PAYMENTS SHALL BE MADE.
5
Enforcement and Collection
6
Enforcement and collection: The Division of Child Support provides support enforcement
7 services for this case (this includes public assistance cases, cases in which a parent has
requested services from DCS, and cases in which a parent signs the application for services
8 from DCS on the bottom of the support order). Support payments shall be made to:
9 Washington State Support Registry

P. 0. Box 45868
10 Olympia, WA 98504
Phone: 1-800-922-4306 or
11 1-800-442-5437
12 A party required to make payments to the Washington State Support Registry will not
receive credit for a payment made to any other party or entity. The obliger parent shall
13 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.
14
3.12 WAGE WITHHOLDING ACTION.
15
Withholding action may be taken against wages, earnings, assets, or benefits, and liens
16 enforced against real and personal property under the child support statutes of this or any
other state, without further notice to the obliger parent at any time after entry of this order
17 unless an alternative provision is made below:
18
3.13 TERMINATION OF SUPPORT.
19
Support shall be paid:
20
provided that this is a temporary order, until a subsequent child support order is
21 entered by this court.
22 3.14 POST SECONDARY EDUCATIONAL SUPPORT.
23 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.
24
25
26 CARLJ.GAUL
Attorney at Law
ORDER OF C::HILD SUPPORT IORS) - Page 4 1604 Hewitt Ave.
WPF DR 01.0500 {9/2001) - RCW 26.09.175; 26.26.132(5) Everett WA 98201
425 259-4147 FAX 259 7081
1 3.15 PAYMENT FOR EXPENSES NOT INCLUDED IN THE TRANSFER PAYMENT.
2 Does not apply because all payments, except medical, are included in the transfer
payment.
3
The mother shall pay S( % and the father I,, Q
% (each parent's
4 proportional share of income from the Child Support~orksheet, line 6) of the
following expenses incurred on behalf of the children listed in Paragraph 3.1:
5
6 Payments shall be made to the provider of the service .
7 3.16 PERIODIC ADJUSTMENT.
8 Does not apply.
9 Other:
10
11
3.17 INCOME TAX EXEMPTIONS.
12
Does not apply.
13
3.18 MEDICAL INSURANCE FOR THE CHILDREN LISTED IN PARAGRAPH 3.1.
14
Unless one or more of the boxes below are checked, each parent shall maintain or provide
15 health insurance coverage if:
(a) Coverage that can be extended to cover the child(ren) is or becomes available to each
16 parent through employment or is union-related; and 7l-
(b) The cost of such coverage for the mother does not exceed $ ~ (25 percent of
17 mother's basic child support obligation on Worksheet Line 7), and the cost of such
coverage for the father does not exceed $ ~ (25 percent of father's basic child
18 support obligation on Worksheet Line 7). /--z.,--z..,-
19 The pare t-below shal aintain or provide health insurance coverage if coverage that can
be extend to cov e child(ren) is or becomes available to that parent through
20 employmen r · union-related and the cost of such coverage does not exceed $ _ _
(25 percent at parent's basic child support obligation on Worksheet Line 7).
21
~c...~\.. ... .; •--'<h '\'r~~,.9,._)
c..u r<-<.. c....\..~l....J k ... l~l....,
22 \""!>->re.Jee., a......9 ~•.., ""\.....L\ ~ c...a-\,.,...,~ ... J-
23 ............. ~..,. ...,-Ir r~v,r-...0
--\- ~r"'~'..9-" .
The parent(s) shall maintain health insurance coverage, if available for the children listed
24 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
25 continue coverage following termination of employment.
26 CARLl.GAUL
Attorney at Law
ORO ER OF' CHILO SUPPORT (ORSI - Page 5 1604 Hewitt Ave.
425 259-4147 FAX 259 7081
J
1
A parent who is required under this order to provide health insurance coverage is liable for
2 any covered health care costs for which that parent receives direct payment from an
insurer.
3
A parent who is required under this order to provide health insurance coverage shall
4 provide proof that such coverage is available or not available within 20 days of the entry of
this order to the physical custodian or the Washington State Support Registry if the parent
5 has been notified or ordered to make payments to the Washington State Support Registry.
6 If proof that health insurance coverage is available or not available is not provided within
20 days, the obligee or the Department of Social and Health Services may seek direct
7 enforcement of the coverage through the obliger's employer or union without further
notice to the obliger as provided under Chapter 26.18 RCW.
8
3.19 EXTRAORDINARY HEALTH CARE EXPENSES.
9
The OBLIGOR shall pay (JJ__ % of extraordinary health care expenses (the obliger's
10 proportional share of income from t3C'ld Support Schedule Worksheet, line 6), if
monthly medical expenses exceed $ (5% of the basic support obligation from
11 Worksheet line 5).
12 3.20 BACK CHILD SUPPORT.
13 No back child support is owed at this time.
14
15
16 3.21 BACK INTEREST.
17 No back interest is owed at this time.
18
25
26 CARLJ.GAUL
Attorney at Law
ORDER OF" CHILD SUPPORT CORSI - Page 6 1604 Hewitt Ave.
425 259-4147 FAA 259 7081
•
1 Copy Received:
2
3 (
CARL J. GAUL WSB
4
Attorney for Andre•w L'' ""''
5
6 I apply for full support enforcement services from the DSHS Division of Child Support.
7
Signature of Party
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLJ. GAUL
Attomey at Law
ORDER OF" CHILD SUPPORT (ORSI - Page 7 1604 Hewitt Ave.
425 259-4147 FAX 259 7081
'•
-~
I-~
r rin~·
,,._., - I 1-'1;
. . " ,..J! 22
Pi\il l. Df,IJIELS
\ \\\\Ill\ill\ Ill 1111111111111111111111111\\Ill11111 Ill\ Ill\ SUPERIOR COURT OF C'.JUN; Y CLER A
L - CL 1~2-~6182_ - --~ WASHINGTON
SlillHOH!SH CO. r; .'.SH
FOR SNOHOMISH COUNTY
ANDREW RIFE CAUSE NO.: 05-3-02755-1

(PETITIONER) COMMISSIONER: ARDEN J. BEDLE
AND CLERK: HEATHER HOTTINGER
JENNIFER RIFE DATE: 11/01/05 AT 9:00 AM
(RESPONDENT) DIGITALLY RECORDED
THIS MATTER CAME ON FOR: SHOW CAUSE HEARING

CONTINUED/HEARING DATE SET AND CALENDAR/CONTINUANCE CODE: 12/6/05 @ 9 AM (Dl)
ACTION: REVIEW HEARING
ACTION: * TO BE HEARD W/ #05-2-02755-1 *
HEARING STRICKEN/CODE:
PETITIONER APPEARED: YES COUNSEL: CARL GAUL I I I

RESPONDENT APPEARED: YES COUNSEL: JANIS DYER
GUARDIAN AD LITEM APPEARED: NOT PRESENT
FACILITATOR PRESENT: NO
DOCUMENTS FILED:
ORDERS ENTERED: ORDER; TEMPORARY ORDER; ORDER OF CHILD SUPPORT; AND ORDER
APPOINTING GUARDIAN AD LITEM ON BEHALF OF MINOR, TO BE FILED BY COUNSEL GAUL.
PROCEEDINGS/COURT'S FINDINGS:
THE USUAL AND CUSTOMARY RESTRAINING ORDERS ARE TO ENTER.

THE COURT FINDS IT IS CLEAR BY THE POLICE REPORTS THAT THERE HAS BEEN
DOMESTIC VIOLENCE PERPETRATED BY PETITIONER. THE COURT ALSO FINDS THAT
WITHDRAWING ECONOMIC RESOURCES, VEHICLES AND THE USE OF A HOME, WHILE NOT
PHYSICALLY ABUSIVE, ARE ALL INDICATIVE OF A PERSON WHO HAS A BATTERER'S PROBLEM.
PETITIONER IS TO RECEIVE AN EVALUATION FROM CHUCK DEVORE THAT UTILIZES
COLLATERAL SOURCES. THE COURT PROVIDES RESPONDENT WITH THE OPPORTUNITY TO
PROVIDE MR. DEVORE WITH COPIES OF THE PLEADINGS IN THIS ACTION. MR. DEVORE IS
TO SUBMIT AN AMENDED EVALUATION AFTER REVIEW OF THESE PLEADINGS.
THE COURT IS CONCERNED REGARDING RESPONDENT'S ALCOHOL USE AND RE~NS
1 DOMESTIC MINUTE ENTRY '1'\7'

'•
#05-3-02755~1; ANDREW AND JENNIFER RIFE
HER FROM USING OR POSSESS.ING ALCOHOL OR DRUGS AT ANY TIME AND FROM BEING IN A
PLACE WHERE THEY ARE MADE AVAILABLE.
THE COURT DESIGNATES RESPONDENT AS THE PRIMARY RESIDENTIAL PARENT. SHE
IS TO HAVE USE OF THE FAMILY HOME UNTIL PETITIONER PROVIDES HER WITH $2,500.00
TO OBTAIN ANOTHER RESIDENCE. RESPONDENT HAS TWO WEEKS TO VACATE THE RESIDENCE
ONCE SHE RECEIVES THESE FUNDS FROM PETITIONER. RESPONDENT IS TO PROVIDE
PETITIONER WITH A LIST OF PROPERTY SHE WISHES TO REMOVE FROM THE HOME AND SHE
MAY ONLY TAKE ITEMS THAT ARE AGREED UPON AND ON THE LIST. THE LIST MAY BE
SUBMITTED TO THE COURT IF THERE ARE ANY OBJECTIONS TO ANY OF THE ITEMS. THE
COURT APPROVES RESPONDENT TAKING HER PERSONAL EFFECTS AND THE CHILD'S EFFECTS.
THE COURT ACCEPTS RESPONDENT'S PROPOSAL FOR THE PARTIES TO SPLIT THE MORTGAGE
WHILE RESPONDENT IS RESIDING IN THE HOME. THEREAFTER, PETITIONER IS TO THE
ENTIRE MORTGAGE. THE PORTION OF THE MORTGAGE THAT PETITIONER PAYS WHILE
RESPONDENT RESIDES IN THE HOME IS DESIGNATED AS SPOUSAL MAINTENANCE.
RESPONDENT IS TO HAVE USE OF THE VEHICLE UNTIL PETITIONER PROVIDES HER
WITH $2,000.00 TO OBTAIN A NEW VEHICLE. PETITIONER IS TO CONTINUE TO PAY FOR
THE VEHICLE. TO THE EXTENT RESPONDENT IS USING THE VEHICLE, THE COURT
DESIGNATES THIS AS SPOUSAL MAINTENANCE, SUBJECT TO REALLOCATION BY THE TRIAL
COURT.
PENDING A GUARDIAN AD LITEM REPORT, THE COURT RESERVES FINDING ANY
26.09.191 LIMITATIONS ON PETITIONER BUT FINDS SUFFICIENT EVIDENCE OF DOMESTIC
VIOLENCE TO RESTRICT HIS CONTACT WITH THE CHILD AT THIS TIME. THE COURT FINDS
THERE SEEMS TO HAVE BEEN A SIGNIFICANT RELATIONSHIP WITH PETITIONER AND THE
CHILD AND THE COURT HAS TO BALANCE THE POTENTIAL RISK TO THE CHILD VERSUS
MAINTAINING THAT IMPORTANT RELATIONSHIP. THE COURT USES THE CHILD DEVELOPMENT
GUIDELINES OUTLINED IN KING AND SPOKANE COUNTIES, AND FINDS IT APPROPRIATE FOR
PETITIONER TO HAVE TWO THREE HOUR VISITS EACH WEEK DURING THE WEEK ONE FOUR HOUR
VISIT DURING EACH WEEKEND. THE COURT ORDERS THIS CONTACT TO BE SUPERVISED BY
ONE OF PETITIONER'S RELATIVES AS A LAYPERSON. THE SUPERVISOR IS TO SIGN ONE OF
BRIDGET LLEWELLYN'S SUPERVISOR CONTRACTS, OR IF THIS IS NOT AVAILABLE, DISCUSS
WITH MS. LLEWELLYN, HER EXPECTATIONS OF THE VISITATIONS. THE SUPERVISOR IS TO
BE PRESENT AT ALL TIMES. IF MS. LLEWELLYN IS UNSATISFIED WITH THE SUPERVISOR
THEN SHE MAY SUSPEND THIS PERSON'S SUPERVISION RIGHTS AND APPROVE ANOTHER PARTY
TO SUPERVISE. PETITIONER IS TO PROVIDE A LIST OF NAMES, ADDRESSES, PHONE
2 DOMESTIC MINUTE ENTRY

"
#05-3-02755-1; ANDREW AND JENNIFER RIFE
NUMBERS FOR THE PROPOSED SUPERVISORS. THE PARTIES ARE TO EXCHANGE THE CHILD AT
THE DAYCARE OR AT ANOTHER NEUTRAL LOCATION WHERE RESPONDENT IS NOT PRESENT. THE
SUPERVISOR MAY PROVIDE THE TRANSPORTATION AS LONG AS THAT PERSON IS LICENSED AND
INSURED.
THE COURT ENTERS CHILD SUPPORT FINDING PETITIONER'S MONTHLY NET INCOME
TO BE $3,800.00, MINUS THE AMOUNT HE IS PAYING FOR SPOUSAL MAINTENANCE, AND
RESPONDENT'S MONTHLY NET INCOME IS $2,100.00. THE STANDARD AMOUNT OF SUPPORT
IS TO BE PAID.

•
21105 NOV - I PM f2: 34

• 1-1f•i l. DAN/ELS
~ COUNTY CLERK
:>NOHOM!SH CO. \'/ASH.

Worksheets (CSW)
Mother .t \( (( :..{;._
::I-4..._,..:. Father /\"'.L_....J ~- R.~k
County 5";.__ J~) l__ Superior Court Case Number J_~~::_-::;3L:~~~;-~,~;~,:Sj·/~zA~-
Children and Ages: r;; ~ I .2. 1?.

a. Wages and Salaries $ $
b. Interest and Dividend Income $ $
c. Business Income $ $
d. Soousal Maintenance Received $ $
e. Other Income $ $
(add lines 1a through 1e) $ $
a. Income Taxes (Federal and State) $ $
b. FICA (Soc.Sec.+ Medicare)/Self-Employment Taxes $ $
c. State Industrial Insurance Deductions $ $
d. Mandato"' Union/Professional Dues $ $
e. Pension Plan Pavments $ $
f. Soousal Maintenance Paid $ $
I!. Normal Business Exoenses $ $
(add lines 2a through 2g), $ $
(line 1f minus 2h) $ '371~ $ LID<.)
•II s<{J50 •I
(add father's and mother's monthly net incomes from line 3)
(If combined monthlv net income is less than $600, skip to line 7.)
$~'-f 5(;
5. Basic Child Support Obligation (enter total amount in box )
Child #1 ~'L Tl Child #3

Child #2 == Child #4
WSSR
,,
Father Mother
(each parent's net income from line 3 divided bv line 4) /o( :~ 0
(multiply each number on line 6 by line 5)
(If combined net monthly income on line 4 is less than $600, enter
each parent's support obligation of $25 per child. Number of
children: . Skin to line 15a and enter this amount.) $
4cg:
$ <, {-Z.,,,.
B. Health Care Expenses
a. Monthly Health Insurance Premiums Paid for Child(ren) $ /no, $ ~
b. Uninsured Monthly Health Care Expenses Paid for Child(ren) $ l $
--
(line Ba olus line Bb) $
(add father's and mother's totals from line Be) $ .:J>q
(multiolv line 5 times .05)
(line Bd minus line Be., if •o• or negative, enter "0")
9. Day Care and Soecial Child Rearinl? Exoenses
a. Dav Care Expenses
•
~~';,
~l~
$
~~ $
.
~
$ 4o
$
-
b. Education Expenses $ $
c. Long Distance Transoortation Exoenses $ $
d. Other Soecial Exoenses (describe) $ $
$ $
$ $
(Add lines 9a through 9d) $ $
·1
10.Combined Monthly Total Day Care and Special Expenses (add
father's and mother's day care and special expenses from line 9e)
.' $ II
•
11.Total Extraordinary Health Care, Day Care, and Special Expenses
(line Bf plus line 10) '· •· $
12.Each Parent's Obligation for Extraordinary Health Care, Day Care,
and Special Expenses (multiolv each number on line 6 bv line 11) $ $
Part Ill: Gross Child Sunnort Obligation
13.Gross Child Sunnort Obligation (line 7 olus line 12) $ $
Part IV: Child Sunnort Credits '(see Instructions, Paee 7)
14.Child Sunnort Credits
a. Monthlv Health Care Exoenses Credit $ $
b. Dav Care and Soecial Exoenses Credit $ $
$ $
d. Total Sunnort Credits (add lines 14a throueh 14c) $ $
WSCSS-Worksheets CCSW) 9/2000 Page 2 of 5 Continue to Next Page
Part V: Standard Calculation/Presumotive Transfer Pavment (See Instructions, Page 8)
15.Standard Calculation Father Mother
a. Amount from line 7 if line 4 is below $600. Skip to Part VI. $ $
b. Line 13 minus line 14d. if line 4 is over $600 (see below if annl.) $ $
c. Amount on line 15b adiusted to meet 45% net income limitation $ $
d. Amount on line 15b adiusted to meet need standard limitation $ . $
e. Enter the lowest amount of lines 15b, 15c or 15d: $ /J Xf'.. $
Part VI: Additional Factors for Consideration (See Instructions, Page 8)
(List the estimated oresent value of all maior household assets.) Household Household
a. Real Estate $ $
b. Stocks and Bonds $ $
c. Vehicles $ $
d. Boats $ $
e. Pensions/IRAs/Bank Accounts $ $
f. Cash $ $
g. Insurance Plans $ $
h. Other (describe) $ $
$ $
$ $
17. Household Debt
(List liens against household assets. extraordinarv debt.)
$ $
$ $
$ $
$ $
$ $
18.0ther Household Income
a. Income Of Current Spouse (if not the other parent of this action)
Name $ $
Name $ $
Name $ $
Name ' $ $
c. Income Of Children (if considered extraordinary)
Name $ $
Name $ $
d. Income From Child Support
Name $ $
Name $ $
WSCSS-Worksheets (CSW) 9/2000 Page 3 of S Continue to Next Page

·i
Father's Mother's
e. Income From Assistance Programs

Program $ $
Program $ $
$ $
$ $
19. Non-Recurring Income (describe)
$ $
$ $
20.Child Support Paid For Other Children
Name/age: $ $
Name/age: $ $
Name/age: $ $
21.0ther Children Living In Each Household
22.0ther Factors For Consideration

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.
Date Ci~ Date City
. J. ~
7
~ NOV 0 1 2005
Judge/Reviewing Office~ Date
This worksheet has been certifie the State of Washington Office of the Administrator for the Courts.
WSCSS-Worksheets (CSW) 9/2000 Page S of S

.-
·~
'
ZIJOS NOV - I Pl'l 12: 34

rr;f·i L. DANIELS
COUNTY CLERK
SNOHOMISH CO. \'/ASH.

COUNTY OF SNOHOMISH
Petitioner,
ORDER APPOINTING GUARDIAN AD
LITEM ON BEHALF OF MINOR
(ORAPGL)
Respondent.
I. BASIS
I.I BASIS FOR THE APPOINTMENT.
This appointment is being made pursuant to
~
RCW 26.09 Dissolution
RCW 26.26 Parentage Act
[l RCW 26.50 Domestic Violence
1.2 CHILDREN TO WHOM THE ORDER APPLIES.
The [ ] father [ ] mother [ ] court moved for appointment of a guardian ad !item for the following
minor child(ren) in this action:
Age/
ORD APPOINTING GAL (ORAPGL) - Page I of 4

WPF DR 04.0200 (612002) -RCW 26.09.110; .140; .220.
II. FINDINGS
After reviewing the case record to date and the basis for the motion, the court FINDS that the
motion should be granted because appointment of a guardian ad litem is in the best interest of the
child(ren).
III. ORDER
IT IS ORDERED TIIAT:
3.1 APPOINTMENT OF GUARDIAN AD LITEM.
_/j...:./=n'-''J~c--"'e.....:::f,___.L=/'---<.:._:c..J:::...:e,={i:.!.'(-=!-....IL.-"...~---- is appointed as guardian ad !item for

the above- amed minor child(ren) of e parties and shall receive copies of all pleadings and notice
of all court proceedings regarding the child(ren).
3.2 DUTIES OF 1HE GUARDIAN AD LITEM.
The guardian ad !item shall investigate and report factual information to the court concerning
parenting arrangements for the child(ren), and shall represent the child(ren)'s best interests. The
guardian ad !item may make recommendations based upon an independent investigation regarding
the best interests of the child(ren). The guardian ad !item shall report a child(ren)'s expressed
preferences regarding the parenting plan to the court, together with the facts relative to whether any
preferences are being expressed voluntarily and the degree of the child(ren)'s understanding.
The guardian ad !item shall make a full and complete written report to the court and counsel/parties
on or before:D:<.c. _ lo J_ {.),)-::;- [Date] and at least 60 days before trial provided that an
.
those recommendations.
.
extension may be granted by the court. This report shall include recommendations and bases for
[~] other: ' I ....., \-<.r ',.__ r '- (' ~ r \r I.... '-l.-uu .;-
~ '"' ...) r-<-{' .o c i.- I' " . .. ( -+<::, -\. " '-.J.:
3.3 OTIIER DUTIES.
Other duties of the guardian ad !item include appearing at all court hearings and pretrial conferences
within the scope of appointment unless excused by the court and assisting the parties and counsel in
reaching a resolution of the matters involving said child(ren).
3.4 GUARDIAN AD LITEM ACCESS TO CHILD(REN), RECORDS AND INFORMATION.
To facilitate reasonable investigation of information pertaining to the best interest of the child(ren),
the guardian ad !item shall have access to the child(ren) and to all records and information,
including authorization to speak with interested persons, from the following sources: law
enforcement agencies; Child Protective Services (or the equivalent ou~of-state agency); health care
providers; mental health care providers; child care providers; the Department of Social and Health
Services (or the equivalent agency in another state); and educational institutions.
ORD APPOINTING GAL (ORAPGL} - Page 2 of 4
WPF DR 04.0200 (612002) -RCW 26.09.J JO; .140; .220.
r ..,.
• These agencies may withhold or blackout portions of requested information as warranted by Jaw or
by court order. The guardian ad !item shall maintain the confidentiality of information except as
necessary to fulfill his or her duties as guardian ad !item.
Within the scope of appointment, the guardian ad !item shall have access to all Superior Court and
Juvenile Court files, including any sealed/confidential portions thereof, other than records sealed
pursuant to RCW 13.50.050(7). All information obtained from sealed or confidential files shall
remain sealed or confidential, and the guardian ad !item shall inform the court ifthe guardian ad
!item report contains sealed or confidential information.
The court clerk shall provide certified copies of this order to the guardian ad !item upon request and
without charge.
Upon good cause shown, the guardian ad !item or the parties may move that the court make
confidential any reports or documents placed in the court file by the guardian ad !item.
3.5 PAYMENT OF FEES AND COSTS.
The guardian ad !item fee is $/0 CJ per hour up to$ ;@tJ , the maximum the guardian ad
!item may charge without additional court review and approval.
The fees and costs of the guardian ad !item shall be paid as follows:
00 l 0 <.:. % by father and % by mother % by other : - - - - - - -

['!l Other: -,::~ i;::..,,..., ..,,..._c-c~J ~l'ls-CJ!:> -\-\....,_ ,.,.,.._ .,.£ a..~por.1.,.,, .... ~·-""-
......._0 'o..,._ I"'(.. .... \..<......J-"'....9 <-+ ~~ + ...-.-c:-
The total amount awarded shall be at the discretion of the court up to the maximum amount allowed
•
after the guardian ad !item files an itemized statement of time with the court, along with a specific
request for fees and a proposed Order. Guardians ad !item who are not volunteers shall provide the
parties with an itemized accounting of their time and billing for services each month.
3.6 CONSENT OF CHILDREN OVER TWELVE TO INVESTIGATION.
M" Does not apply.

[l
has/have reached the age of twelve. Written consent for the guardian ad !item to consult
with and obtain information from medical, psychiatric, or other experts who have served the
child(ren) in the past[ ] has [ J has not been given by the child.
3.7 AUTHORIZATION FOR RELEASE OF INFORMATION.
Does not apply.

Each party's signature hereunder constitutes an authorization for release of information by
that party to the agencies listed in paragraph 3.4, above.
ORD APPOINTING GAL (ORAPGL) - Page 3 of 4

WPF DR 04.0200 (612002) -RCW 26.09.110; .140; .220.
( ,.
3.8 TERMINATION OF APPOIN1MENT.
The appointment terminates:
M Upon entry of the final parenting plan or residential schedule.

[] Other:
3.9 OTIIER:
NOV 0 1 2005
Approved for entry:

Notice of presentation wai
Signature Signature
~("§ ' b: °'--"3 <(

Print or Type Name Print or Type Name
ACCEPTED UPON APPROVAL BY

TIIECOURT
Guardian Ad Litem
Father's Signature
Child's Signature Child's Signature

(See Paragraph 3.6) (See Paragraph 3.6)
ORD APPOINTING GAL (ORAPGL) - Page 4 of 4

WPF DR 04.0200 (612002)-RCW 26.09.I 10; .140; .220.
21l05 NOV - I PM 12: 3~
i"hl'i L. DANIELS
COUNTY CLERK
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF SNOHOMISH
~ )~ft--'?«~ )
)
PLAINTIFF I PETITIONER )
)
<:r~.,.r~ R-- p., ~

) NO. ~ ''.:> - 6 2 +5 S )
)
DEFENDANT/RESPONDENT ) ORDER
)
)
Presented By:
&'01 page1ot2
.. .
Page# __;"2.=---
Case Name {(_ ,· k .r ) Q•/!_ Case No. OS· "'3 · e" ~ / z8 -UL-=f 'S'S"-\
(_-\ .
(),_J ~-. (,, 1.-<...o

<
<
DONE IN OPEN COURT this date: --~t~f+-/_,__,r.,_./.-"CJ~)~,,-------

Present:
Copy Received:
1084-4
1
2
2005 NOV - I PM 12: 34
3 Illlllll llllll Ill lllll lllll lllll lllll lllll l l l lllll llll llll
CL 11209204 . AM L. DANIELS
4 COUNTY CLERK
SNOHOHISH CO. WASH.
5
6
7
SUPERIOR COURT OF WASHING TON
9
10
ANDREW S. RIFE, NO. 05-3-02755-1
11 Petitioner,
12 and DECLARATION OF JENNIER RIFE
IN RESPONSE TO MOTION FOR
13 JENNIFER R. RIFE, TEMPORARY ORDERS AND IN
Respondent. SUPPORT OF HER REQUEST FOR
14 A DOMESTIC VIOLENCE
15 PROTECTION ORDER
16
17 I am the Respondent named above. I make this declaration under penalty of perjury and
18
based on my own personal knowledge. I am over 18 and otherwise competent to testify.
I May of 2005 my husband was arrested and jailed for assaulting me. Shortly after
19
getting out of jail he moved back into our home and continued abusing me. I have been so
20
confused and beaten down that it has been very hard to stand up for our one year-old daughter or
21
myself. His abuse has only escalated. As the date for his trial came near I realized that he was
22
actively trying to keep me away from our home so that I would not receive the subpoena to
23
testify. I also realized that he was trying very hard, in concert with his brother, to set me up to be
24
charged with assaulting him. I see this all clearly now in hindsight.
25
His trial was set for Monday Oct. 3, 2005. On the weekend prior to that day he pulled
26
every dirty trick in the book to try to incite me into taking some type of action against him.
27
Instead I just took our daughter and stayed with my sister. But unfortunately, both my daughter
28
and I were sick. She needed to be home in her own bed with her medicine. I called Andy and
29
left a message asking him to leave so we could come home. He ignored my messages. I finally
30
just went back to our house and rang the doorbell until he dpened the door. He flew into a rage
Dyer & Primont
503~.E
DECLARATION OF JENNIFER RIFE
Page I
~4,~;
OR/G/i··JAL
~------------ --- -
1 and ultimately the police were called. He tried to tell them that I hit him but his story did not
2 ring true. He kept changing the place on his body that he claimed I hit him. There were no
3 marks, because l had not touched him, and ultimately the officers realized he was lying. They
·4 noted that there was a criminal no contact order against Andy from the previous assault and they
5 ultimately arrested him for violating the no contact order. Sec attached Exhibits A and B,
6 Everett Police Reports, Incident numbers 05-10775 and 05-21287, incorpcratcd herein by
7 this reference.
8 I did show up to testify against him at his trial. Once he realized that I was going to
9 follow through he took the prosecutors offer and the case was disposed of. l don't know if he
10 pied guilty or what but I do know that he is required to participate in DY treatment and be on
11 probation for two years. The criminal no contact order is to remain in place for that entire time.
12 Attached No Contact Order from Everett Municipal Court, Exhibit C.
13
HISTORY OF DOMESTIC VIOLENCE
14
One of the first instances was in 2003 when we went to dinner. When we came home, he
15
realized he had locked the keys in the house. The first thing out of his mouth was that it was my
16
fault because I wanted to go to dinner, and that he wouldn't have locked the keys in the house if
17
it hadn't been for me. Then he proceeded to break out the garage window with a ladder (at
18
midnight) waking up neighbors, who called the police.
19
Within a couple of months of living together we had an argument after being at a friend's
20
house for a New Years Eve. He was yelling, screaming, and crying. He called his Mother in the
21
middle of the argument to tell her I was being "mean" and being awful to him. After hanging up,
22
he punched his fist thru the bedroom closet door, shattering it.
23
A day after giving birth to our daughter by caesarean (9125104) I tried to talk to my
24
husband about how upset I was that his family kept trying to invite too many of their friends into
25
my hospital room. l asked him to have a talk with his Mother about this. He became very
26
agitated, saying he did not want to hurt his Mother's feelings, and that l was being too sensitive.
27
The nurses heard the commotion in the room, and came in to see if l was all right. They asked
28
me if l wanted my husband to leave.
?9 Within a month of the birth of our daughter, we had another argument. As l walked down
30
the hall to get away from him, he grabbed a handful of my hair and drug me back down the hall .
Dyer & Pnmont
503 Twelfth A••· E
S.attl<, WA 98102
ORlGINAL
DECLARATION OF JENNIFER RIFE (206) 343-1528
Page 2
1 towards him. When I started to cry he said he only meant to grab my jacket and that I was
2 overreacting.
3 Last December we went to visit my sister and brother-in-law and their two children. My
4 husband and my brother-in-law left saying they were going to pick up appetizers to bring back
5 and that they'd be back in half an hour. They came back in three hours and Andy appeared to be
6 intoxicated. We had a disagreement about it when he came back and he immediately became
7 verbally abusive, calling me a "whore" and "stupid". I tried to leave, with our daughter, but he
8 followed right behind me. He got into the car, and continued screaming at me, yelling within an
9 inch of my face, calling me a "whore" and "a piece of shit." He kept screaming that he could do
10 whatever he wanted to do whenever he wanted to do it, without my permission. He pulled and
11 shook me so hard by the sweatshirt I was wearing that he left cuts and abrasions on the back of
12 my neck. He also pulled me my hair to pull me closer to him so he could yell at me. He screamed
that he hated me and that he wanted out. Our 3-month-old daughter was in the car during this.
13
My sister heard all of this, as well as her 4 year-old son, and 2-year-old daughter. My sister came
14
out to the garage and saw what was happening in the car. Later that night at home, he apologized
15
to me, saying he didn't mean to hurt me. He helped to clean and dress the abrasions on my neck.
16
It became routine for him to become extremely angry and verbally abusive during any
17
disagreement. One time he said he hoped that the next time I was out driving that I'd get hit by a
18
semi truck and die. He calls me a "whore, a loser, a piece of shit, fat" and says that he "made me
19
who I am", and that I "would be nothing without him", and that I am "stupid." He tells me all of
20
the time, with a look of hatred in his face that he wants to break my neck, or punch me in the
21
face. He will mimic this, showing me the motions of it with his hands. He gets so angry, he
22
breaks out in a sweat, his face becomes very red and his lips thin and white and his mouth so dry
23
he can barely speak more than a couple of sentences at a time. In a lot of cases he would rip
24
whatever shirt he was wearing off of his body and flex his muscles in front of me. After leaving
25
bruises on me, he will say that I bruise easily, and that he really didn't grab me very hard.
26
There was an instance in the kitchen where he shoved me up against the kitchen counter,
27
and pulled the water hose out of the sink, and sprayed water in my face. When he screams at me
28
with his nose almost touching mine, he has at times purposefully spit in my face when he was
29
done yelling.
30
Dyer & Primont
503 Twelfth Av<. E
Seattle, WA 98102
Page 3
ORlGIN/\L
1 In February/March 2005 my husband and I were having an argument that quickly
2 escalated. He said to get my attention that he was going to call the police and say that I had hit
3 him. Once he called, he hung up. When the 91 I dispatcher called back, they informed my
4 husband that they were sending out a patrol car. My husband forced me to get in the car and
5 leave. I did has he asked, and went down Colby Avenue and parked in a quite residential area
6 until my husband called me on my cell phone and said I could come back home. He told the
.7 officers that night that the reason he called was he thought our daughter was sick or choking, and
8 after a few minutes he realized she was okay.
9 The night my husband was arrested in May, he became very aggressive and agitated after
10 a disagreement. He repeatedly shoved me to the floor, knocking me down every time I got back
11 up. He kicked me while I was down trying to prevent me from getting up. He was also calling
12 me "whore", "cunt", "stupid", "loser" and a "worthless piece of shit". That same night he
13 grabbed me from behind, and rubbed my face in the carpet. He told me he wanted to "see me
dead" and that he wanted to "punch me in the face and break my neck." With gestures he showed
14
me what he wanted to do to me. After he was booked into the county jail, l was the first person
15
he called. He was crying. He told me he was afraid of where he was at, that he was sorry for
16
what he had done and that he was afraid of losing "his family".
17
During another altercation, my husband cornered me in the kitchen, and while screaming
18
at me right in my face, he lowered his head and bit my left cheek close to my chin. Not hard
19
enough to draw blood, but hard enough to leave teeth marks in my skin.
20
In another instance, while we were having an argument regarding our sex life he said that if l
21
wanted to get laid more he'd be happy to show me how it's done. He grabbed me around my
22
waist and bodily picked me up, pinning me against the kitchen counter, and forcefully pretended
23
like he was having intercourse with me.
24
When we were remodeling our bedroom, we had only a single mattress lying on the floor.
25
During another disagreement, he grabbed me by one arm and threw me across the room. I
26
landed hard and on the floor, injuring my arm. The pain was excruciating, and I could not move
27
it without pain for two days. Later that night l told him I thought my arm was really hurt, and
28
that maybe l should go the hospital. He told me to just sleep it off a little bit, and that maybe it
29
would feel better. He even helped to arrange two pillows for me to sleep with my arm propped
30
Dyer & Primont
503 Tw<lfth Ave. E
S.attle, WA 98102
Page 4 ORI Glt~AL a06134J-1sis
..
1 level to my body. He apologized once again saying that he didn't mean to hurt me; I just landed
2 wrong.
3 On another occasion I was trying again t get away from him. l ran out to the garage to get
4 into the car to leave but he grabbed the keys from me before l could leave. He pushed me out the
5 door and down the garage steps then chased me around the car, trying to get a hold of me while l
6 tried to keep away. When he could not catch me, he picked up dirty clothes from the laundry
7 basket in the garage and thru clothes in my face.
8 He has broken many things in our home. He has broken two closet doors,_ a phone, two
9 kitchen chairs, our daughter's toys and a kitchen cupboard. He punched out the screen door in
10 our garage; he has left holes in the walls of our family room. When he punched the closet door
11 he nearly broke his hand; it was purple and swollen for almost two weeks. He got mad when our
12
daughter was a newborn, because l was stressed out and tired. I told him that l needed help. He
told me that l should have told him that I didn't want to be a mother, as he would have made me
13
have an abortion. He has repeatedly told me in anger that he never wanted to be married, and
14
never wanted kids. He has thrown baby bottles, pop bottles, and other breakable items.
15
He would always call his brother or mother when we fought, and they would always take
16
his side. His mother is so abused by her ex husband and sons that her life is no longer her own.
17
She would sometimes show up unannounced and continued to argue along side my husband,
18
goading me, telling me I should call the "cops" on her, the way l called them on my husband in
19
May. On a recent evening while she was there, my husband held the car keys away from me so l
20
could not take my daughter and leave. Eventually, he threw them at me, telling me and told me
21
to get out of his house. By that time, our daughter was asleep, and l was not going to leave
22
without her. His mother asked him to leave but he refused. He said that he was, "staying right
23
where he was, and that he was going to make my life miserable."
24
Recently he came home from work early mad because I had slept on the couch the night
25
before. He cornered me in our daughter's bedroom, and started screaming in my face because 1
26
was arguing back with him. When he got too close, l lifted my left arm in front of me, to protect
27
myself. He hit my arm down so hard that he left a large bruise directly on my forearm, going up
28
into my bicep. l got upset and left to go into the bedroom. He followed behind me, and grabbed
29
me by the arms and started to violently shake me. He picked me up and threw me onto the bed.
30
Then he forcibly kept me there by putting his weight on me. He kept telling me to "shut-up" and .
DiJer & Pnmont
503 Twelfth Ave.£
Seattl<, WA 98102
Page 5
1 to listen to him. I tried very hard to break free of him. By the next evening, I noticed that I had a
2 very large, black and purple bruise under my right bicep, and large painful bruise on my left
3 forearm, and a strained muscle in my neck.
4 During the entire time I have known him Andy has driven erratically and dangerously
5 with my daughter and me in the car. Anyone who looks at him, or doesn't drive to his liking, will
6 send him into a rage. He will yell obscenities (normally "stupid cunt"), flex his harm and curl his
7 fist in the rear view mirror or driver's side window at the person he is upset with. At times, I
8 have been extremely frightened, thinking we were going to be in an accident, or get into an
9 altercation with the person that he is yelling at.
10 He has done this many times with our daughter in the car. One incidence, up near the
11 corner of 1o•h and Colby, he jerked the car over to the curb, got out of the car, leaving the drivers
12 side door open, and chased after a car he thought was driving too closely behind us. The second
time, we were up near Rucker Hill and Andy became very agitated, as he thought a passing car
13
gave him a nasty look. He came to an abrupt stop on the side of the road, got out of the car and
14
grabbed what I believe is a tire iron out of the trunk. He was yelling and screaming at the car
15
driving off to come back and fight him.
16
I have filed for a Domestic Violence Protection order against him. He has filed for
17
divorce and obtained an ex parte restraining order against me. This is all in retaliation. There is
18
no basis for any restraints against me. He is just using this to try to have my daughter and I
19
removed from his house and to make my life hard.
20
21
HUSBAND'S FALSE ALLEGATIONS OF ALCOHLISM
22
In the beginning of our relationship, I told him in confidence because I thought I could
23
trust him that I had been in a treatment center the previous year in 2002. Edgewood is a
24
treatment center on Vancouver Island that deals with Depression, Chemical Dependency, and
25
many other addictions, such as gambling and sexual addictions. My family confronted me
26
because they thought that I looked tired and depressed; they were concerned hat I was self-
27
medicating myself for personal issues that I was dealing with at that time in my life. I listened to
28
what everyone had to say, and agreed that the best thing for me was to go, and to learn and listen.
29
I knew I had been drinking too much and knew this was not how I wanted to live my life. I took
30
in a lot of information from Edgewood that I think has dramatically changed the outlook I have
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 9$102
DECLARATION OF JENNIFER RIFE a06J 34.J-1528
Page 6
l.
1 on life. It made me more secure in who I am. I learned that during tough times in my life I do
2 not need to lean on alcohol to help me. Having willingly gone there and taken responsibility for
3 what I was doing wrong, greatly empowered me.
4 At first my husband told me that my parent's must have been crazy sending me there, he
5 couldn't understand why. Once the abuse started, he began constantly putting me down for
6 going, calling me a drug addict and a loser. He also tried to break down my confidence, by
7 telling everyone in his family, his friends, and even co-workers about my past struggle. I know
8 this, as he would tell me in an argument, that I was a loser, and everyone that he told knew it.
9 When I met him and fell in love with him, I decided I wanted to change my life, and live
10 with more integrity and responsibility. I did this on my own and am proud of how my life has
11 turned out. I feel I was a great wife and a wonderful Mother. I was very excited about the arrival
12 of our daughter. I have been with her and taken care of her every day of her life.
13
FINANCIAL ISSUES
14
I acknowledge that the house we live in and have lived in during our marriage was his
15
house prior to our marriage. Also, he bought the car I drive just a month before we got married,
16
although we were living together when he bought it. While I understand that these may or may
17
not be separate assets that is a matter that should be resolved later. I am willing to move out of
18
the house but I will need some time to make those arrangements. I am asking that I be allowed
19
to remain in the home for the next 90 to 120 days. I need to continue using the car as my
20
business requires that I drive to offices. Without it I would be completely unable to earn a living.
21
To compound matters, I have no money. I have no money right now because Andy took
22
all of the money out of our joint checking account. There was about $7,500.00 in that account.
23
See attached Exhibit D, Sept. 2005 bank statement. Earlier this month, the day after he was
24
arrested the second time, I decided to take half of the money out so that I would be able to move
25
and hopefully pay an attorney. But before I could, I found out that he had taken all of it out and
26
closed the account. Sec attached Exhibits D and E. He left me with no money and now he
27
wants my daughter and I to have no place to live and no car to drive. I am asking that he be
28
required to pay me one-half of the money he took from our joint account within I 0 days of this
29
order.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 7
0 RIGIf\11\ L
1 I am self-employed. I do not believe I make as much as Andy claims 1 do on his
2 proposed support worksheet. The only records 1 have arc my invoices. Looking back over the
3 last year, my average gross monthly income has been $2, 798.00, sec attached Exhibit F.
4 Andy's withholdings and mortgage interest deductions have always been enough to allow us to
5 pay no taxes on my income but still get a refund. I estimate that my taxes will be roughly 25%
6 of my income. In looking at Andy's most recent pay stub I believe he has under reported his
7 income by about $100.00 per month. I have attached a child support worksheet that I believe
8 more accurately reOects our monthly incomes.
9
10 PARENTING PLAN
11 Andy is asking the court to appoint a GAL for our daughter and to either give him
primary residential custody of our daughter or have us both have her half the time. I am opposed
12
to either. He is an abusive man, both has a husband and as a father. I believe that our daughter
13
would be in real danger if left alone with him at this point. I may feel differently ifhe enters into
14
some meaningful treatment for the domestic violence which also deals with parenting in this
15
context but right now he continues to blame it all on me and take no responsibility for his own
16
actions. I have done some research into the different DV treatment programs and would ask that
17
the court order that he attend treatment at Family Services in Seattle. The reason I want him to
18
go there is that they not only have a batterers treatment program but that have two different
19
programs for parents as well: one is called DV Dads and the other is called Respectful
20
Parenting. I know of no other program that also has programs dealing with parenting. I cannot
21
stress enough how much danger I believe our daughter would be in if he is allowed unbridled
22
contact with her at this point. I am asking that court to order that there be no visitation until he
23
has completed at least 60 days of treatment at Family Services and has received positive monthly
24
progress reports.
25
I have no objection to the appointment of a GAL but I have no money right now to pay
26
any retainer for one. I have had to borrow money from my parents for my attorney's retainer. I
27
make enough from my job to support my daughter and I but I have no extra income. I will have
28
to use every penny I have to find another place for us to live. Andy makes more money than I
29
and 1 would ask that he be required to pay any initial retainer for a GAL.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 8
ORIGlr. .JAL
..
1
I declare under penalty of perjury of the laws of the state of Washington that the
2
foregoing is true and correct. Signed this_ day of October 2005 in Seattle,
3
Washington.
4
5
6
7 ~#~~24)
J IFER JFE
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Dyer & Primont
503 Trvelfth Ave. £
Seattle, ivA 98102
DECLARATION OF JENNIER RIFE
Page 9
ORIGlt··J/\L (206) 343-1528
1
2 2005 NOV - I PM 12: 3~
3 r/-\l·1 L. DANIELS
4
111111111111111111111111111111111111111111111111111111111111 COUNTY CLERK
CL 11209201 SNOHOMISH CO. Vlf\SH.
5
6
7
8
9
COUNTY OF SNOHOMISH
10
11
NO. 05-3-02755-1
12 ANDREW S. RIFE,
Petitioner, FINANCIAL DECLARATION
13 and OF PETITIONER
(FNDCLR)
14
JENNIFER R. RIFE,
15 Res ndent.
16
Name: Jennifer Rife Date of Birth:
17
18
I. SUMMARY OF BASIC INFORMATION
19
20 Declarant's Total Monthly Net Income (from§ 3.3 below) $3026.42
21 Declarant's Total Monthly Household Expenses (from§ 5.9 below) $3836.00

Declarant's Total Monthly Debt Expenses (from§ 5.11 below) $0
22
Declarant's Total Monthly Expenses (from§ 5.12 below) $3836.00
23
Estimate of the other party's gross monthly income (from§ 3. lf below) $
24
25 II. PERSONAL INFORMATION
26 2.1 Occupation: Self employed.
27 2.2 The highest year of education completed: 14
28 2.3 Are you presently employed? Yes

a. If yes: (I) Where do you work Snohomish Mobile Notary
29 (2) When did you start work there {month/year)? April 2004
30
FINANCIAL DECLARATION (FNDCLR) - Page I
WPF DRPSCU 01.1550 (6/2004) - RCW 26.18.220 (/) Dyer&P~·m
503Tw<I v
t
Se•ttle,
(206) 5,
1
2
Ill. INCOME INFORMATION
3
3.1 GROSS MONTHLY INCOME.
4
5 a. Wages and Salaries $3900.00
b. Interest and Dividend Income $0
6
c. Business Income $0
7
d. Spousal Maintenance Received $0
8 e. Other Income $0
9 f. Total Gross Monthly Income $3900.00
10
11 3.2 MONTHLY DEDUCTIONS FROM GROSS INCOME.
a. Income Truces $286.88
12
b. FICA/Self-employment Taxes $586.70
13
c. State Industrial Insurance Deductions $0
14 d. MANDATORY Union/Professional Dues $0
15 e. Pension Plan Payments $0
16 f. Spousal Maintenance Paid $0

g. Normal Business Expenses $0
17
h. Total Deductions from Gross Income $873.58
18 (add lines 3.2a through 3.2g)
19 3.3 MONTHLY NET INCOME. $3,026.42
20
3.4 MISCELLANEOUS INCOME.
21 Child support received from other relationships $0
a.
22 b. Other miscellaneous income (list source and amounts) $0
23 c. Total Miscellaneous Income $0
24 3.5 Income of Other Adults in Household $0
25 IV. AVAILABLE ASSETS
26
4.1 Cash on hand
27 4.2 On deposit in banks
4.3 4.3 Stocks and bonds, cash value of life insurance
28
29
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FINANCIAL DECLARATION (FNDCLR) - Page 2
WPF DRPSCU 01.1550 (612004)-RCW 26.18.220 (/) Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
OR\Gll~AL
1
V. MONTHLY EXPENSE INFORMATION
2
Monthly expenses for myself and one dependent are:
3
5.1 HOUSING.
4
Rent, I st mortgage or contract payments $ 1,000.00
5 $0
Installment payments for other mortgages or encumbrances
6 Total Housing $ 1,000.00
7
5.2 UTILITIES.
8 Heat (gas & oil) $100.00
9 Electricity $75.00
10 Water, sewer, garbage $50.00
Telephone $150.00
11
Cable $30.00
12
Total Utilities $405.00
13
5.3 FOOD AND SUPPLIES.
14
Food for 2 persons $500.00
15 Supplies (paper, tobacco, pets) $!00.00
16 Meals eaten out $200.00
17 Other $0
Total Food Supplies $800.00

18
19 5.4 CHILDREN.
Day Care/Babysitting $250.00
20
Clothing $50.00
21
Other child-related expenses $0
22 Total Expenses Children $275.00
23
24 5.5 TRANSPORTATION.
Vehicle payments or leases (Honda lease) $500.00
25
Vehicle insurance & license $121.00
26
Vehicle gas, oil, ordinary maintenance $200.00
27 $0
Parking
28 Other transportation expenses $0
29
30
WPF DRPSCU 01.1550 (612004)- RCW 26.18.220 (I) Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
ORIG\l\lAL
1 Total Transportation $821.00
2
5.6 HEALTH CARE. (Omit if fully covered)
3
Insurance $0
4 Uninsured dental, orthodontic, medical, eye care expenses $75.00
5 Other uninsured health expenses $0
6 Total Health Care $75.00
7
5.7 PERSONAL EXPENSES (Not including children)
8 Clothing $200.00
9 Hair care/personal care expenses $60.00
10 Clubs and recreation $0
Education $50.00
11
Books, newspapers, magazines, photos $50.00
12
Gifts $100.00
13 $460.00
Total Personal Expenses
14
5.7 MISCELLANEOUS EXPENSES.
15
Life insurance (if not deducted from income) $
16 $
Total Miscellaneous Expenses
17
5.9 TOTAL HOUSEHOLD EXPENSES (fhr toi.J of Paragniphs 5.1 through 5.81 $3,836.00
18
5.10 INSTALLMENT DEBTS INCLUDED IN PARAGRAPHS 5.1 THROUGH 5.8.
19
Description Month of
20 Creditor of Debt Balance Last Pavment
21
22
23 5.11 OTHER DEBTS AND MONTHLY EXPENSES NOT INCLUDED IN PARAGRAPHS 5.1 THROUGH
5.8.
24 Description Month of Amount of
Creditor of Debt Balance Last Payment Monthly
25 Pavment
26
Total Monthly Payments for Other Debts and Monthly Expenses $
27
28 5.12 TOTAL EXPENSES (Add Paragraphs 5.9 and 5.11) $3,836.00
29
30
WPF DRPSCU 01.1550 (612004) - RCW 26.18.220 (I) Dyer & Primont
503 Twelfth Avt. E
Seattlt, WA 98102
Q06) 343-1528
1 VI. ATTORNEY FEES
2 6.1 An1ount paid for attorney fees and costs to date: $I 0,000.00
6.2 The source of this money was: loan from parents
3 6.3 Fees and costs incurred to date: $.
6.4 Arrangements for attorney fees and cOsts are: advance fee deposit
4
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
5
6 Signed at Seattle, Washington on {)Ck/.l'Ar 01.1/ 'f I., , 2005.
7
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WPF DRPSCU 01.1550 (612004)- RCW 26.18.220 {I) Dyer & Primont
503 Tzvclfth Ave. E
Seattle, WA 98102
(206) 343-1528
FR i
1 u- rt.a.ED
2
21105 NOV - I PM 12: 34
3
PAM L. DANIELS
4 I1111111111111Ill111111111111111111111111111111111111111 Ill\ COUNTY CLERK
CL 11209199 SNOHOMISH CO. \YASH.
5
6
7
9
10
11 Petitioner,
and DECLARATION OF
12
CAROL HOLLAND
13 JENNIFER R. RIFE,
Respondent.
14
15 In summer and fall of 2002 my husband and I noticed that Jennifer was drinking
16
too much and missing some work. We asked her employer at work if they had noticed a
17
18 change in behavior and they said she didn't seem her efficient self. We asked an
19 intervention specialist to help us present our concern to her. Jennifer recognized that she
20
had gotten off track and volunteered to go to a high-end treatment program. People from
21
all walks of life were treated there for many different reasons. The education was the
22
23 equivalent of a year of college. People that attend the facility have free will to leave. She
24
voluntarily remained and completed the program.
25
When I think back on that time I believe now that we may have overreacted but it
26
27 was a positive experience for her. She took responsibility for her previous actions. With
28 the knowledge she learned from the program she did not fall back into the behavior she
29
had for that short time in 2002.
30
Dyer & Primont
503 Twelfth Ave. E
S.attle, WA 98102
~~
1 I am very proud of her for the person she is today. I do not see in her what I saw
2 in her during that time in 2002. She is a responsible adult, mother and wife.
3
I know she has been very confused, withdrawn and sometimes depressed over the
4
situation at home. On the surface Andy can be a very likable guy, but I can now see how
5
6 he tried to control Jennifer's live, financially and socially, in a very unhealthy way.
7
Although I believe he loves his daughter, he has never taken full responsibility for her
8
and I am concerned that he lacks the skills to care for her on his own.
9
10 I declare under penalty of perjury of the laws of the state of Washington that the
11 foregoing is true and correct. Signed this 25th day of October 2005 in Seattle,
12
Washington.
13
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27 •
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Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
.-
INCIDENT
D !ASSAULT DV
I
•
OCCURRED ON
EVERETT POLICE INCIDENT REPORT
I DAY
OCCURRED TO
YEAR
........,f NUMBER
DD 05-10775
•REPORTED ON
DAY
PAGE 1 OF
YEAQ
0
":....
-...;
D
--~~
DAY YEAR TIME TIME MONTH
A MONTH
pcwDRESSJlOCATION OF INCIDENT
I I MONTH
I 5
~
21
FORCE
200~·~
u t.iti :" POL BEAT
T 2416 5™ ST QNOFORCE ~ 1 11
A
OFFENSE AS4DVM
CODES AOC 181
I I AOC 0
I 0
0
OFFICER SAFETY
OFFICER ASSAULT
ESP
rGN
JUVENILE
0 CHILO ABUSE
181 DOM. VIOLENCE
0 COMPUTER USED
0 DRUG RELATED :Jl.~
181 ALCOHOL RELATE
'II ~ ~!_ IAS
R ON-LOSS$
RACE ETH SEX 0.0.B. /AGE HGT

' l 'EYES HAJR
NO. PERSON'S NAME {LAST, FIRST, MIDDLE)
p VIC RIFE, JENNIFER R w M 8/18/1974
..
5-02 'f~ BLU BLND
E
STREET ADDRESS ANO APT NO.
2416 5TH ST
CITY
EVERETT
3
' sr:u ZIP
98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENTIOCCUP.JSCHOOL ' T IAS VICTIM INJURY
(425) 259-9828 ( )
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• t ~ • 5
•
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX 0.0.B.~ HGT WGT EYES HAJR
p
3 3
,r-.,'
STREET ADDRESS ANO APT NO. CITY ,~ STATE ZIP
E _(l
RESIDENCE PHONE BUSINESS PHONE EMPLO'.MENT/OCCU~vvL HATE/BIAS VICTIM INJURY
I
(
R ( ) I
. -~
r:.-
• • •
s
NO.
A-1
CIN/IDENTIFICATION NO.
369221
NAME (LAST, FIRST, MIDDLE)
BOOKED/INHERE
SNO COUNTY JAIL
- LOCATION OF
RACE
... JT
SEX 0.0.B I AGE

ARRESTEE ARMED WITH
HGT WGT EYES HAIR

u RIFE, ANDREW SCOTT
~
~ ... M 3/2211973 5.08 175 BLU BRN
STREET ADDRESS AND APT NO. STATE ZIP
•
s 24165TH ST WA 98201
RESIDENCE PHONE BUSINESS PHONE JiNT/OCCUPATJON/SCHOOL
p (,
(425) 259-9828 ( I D
E
ALIAS NAME(S) SOC. SEC. NUMBER
531-e8.a901 ()
DRIVER'S LIC.11.0. CARO
RlFE•AS279D2
STATE
WA
I EXP
MISC. IDENTIFIERS
c .J'.'.
CHARGES & CITATION# QfiWARRANT # & AGENCY ...\..: CHARGES & CITATION #QB_WARRANT #&AGENCY
T 1. 10 M CJ F CHARGE ASSAULT DV CIT CR 00677.fB...
NAME/ RELATIONSHIP OF PERSON NOTIFIED (JUVE~.,.
2. aMaF CHARGE
DATE/TIME NOTIFIED
CIT
INOTIFIED BY
. " .... YEAR I

v VEH. NO. ' LICENSE NUMBER ~"I STATE MAKE MOO EL STYLE COLOR
.....~...
SPECIAL IDENTIFYING FEATURES I V.l.N."4 DAWAGE $ REGISTERED OWNER'S NAME
I I I
v VEH. NO. LICENSE NUMBER
SPECIAL IOENTIFYING FEA'-'J'l.N.

-- VI STATE YEAR MAKE
DAMAGE$
MODEL
REGISTERED OWNER'S NAME

STYLE COlOR
I certifv for declareJ under "\-.t, of aerfurv under tire laws of the State of Washlnnton that the fonnolna Is true and col19Ct tRCW 9A.72.0B5J
OFFICER SIGNATURE.{~ DATE: FORCE USED
OFFICER NAME/~
5122105 NO
PURSUIT
NO
UNIT
I AFPjO~: I PERS. NO.
A WILLIAMS ':F 421 ~- f¥LUL.
CLEARANCE: ~ OUNDED DISTRIBUTION:
ov JUV TRAF OTHER:
ARRJA ,. EXCIA PA
CPS HD OET
L5RED
ATE
2krt.~aJk
INITIALS
ARRJJ _,.l } EXCIJ ADMIN
OSHS MH PAT
1. "") '//_'-) I I'

t" •-dREDRMS ATE INITIALS
ENTEREDWACIC/ NCIC
DATE INITIALS
I CLEARED WACIC/ NCIC
CATE INITIALS
I
v. PO 03 (REV. 1104 TLK) FORM ID: IRF00.07.W95
EXHIBIT_._..._
.-
Page .Loi_
00 _ _ _ 00
•Everett Police Department
D FOLLOW-UP REPORT ~·ORIGINAL NARRATIVE ~/\)
INCIDENT CASE NUMBER
0
Assault DV DD 05-10775
REPORT OATE:
5121/05
DA oc DA DC DA DC DADC DADC DADC
INCIDENT RECLASSIFIEO TO: DATE OF RECLASSIFICATION REL.A TED CASE NUM
0
On 5/21/05 I was dispatched to 2416 51" St for a physical domestic. The caller, a fl!!mille, called 911 and told the
call taker·"My husband is abusive." The call taker could hear a male yelling in tPie....,Datkground. The female hung
upb~~- '
When I arrived, Andrew Rife answered the door. I asked him if there was --~ument
inside the house. He told
me that he and his wife, Jennifer Rife, were arguing but quickly added t~~~n't physical." I asked Andrew to
step out and talk to Sgt. Myers while I interviewed Jennifer inside. ~...._
Jennifer was still upset and crying. I could smell the odor of into~icoming from her, but it did not appear that
she was intoxicated. Jennifer told me that she and Andrew went dinner in Seattle. On their way home, he
wanted to go to a casino. She did not. They started to argu~ it.
When they got home, the. argument continued. Andrew copti_!)ued to escalate until he grabbed her by the arms and
started shaking her in anger. She fell to the ground. Sb,.~t up and they continued to argue. She eventually
called911. . ~
I asked her if she had any injuries or marks as a re~~the
assault. She told me "No. But I have bruises from
last Saturday Night." She pulled up her sleeves A"1thowed me two bruises, one on each arm. The bruises were
purple, about the size of a thumb. I asked her ho~e had gotten them. She told me that he had assaulted her
last week as well, in the same fashion. Jen~iId me that her husband is "a really nice guy, but when he gets
angry he has a terrible temper." The bruis her arms were consistent with Andrew grabbing her by the biceps
and shaking her. ~
Next I interviewed Andrew. Andrew al~ld me that they had gotten into an argument on the way home. He told
me that it "wasn't physical" but alsi;i ~e he had "grabbed" her.
~
Due to the history of un reporte~ssaults involving Andrew and Jennifer and the victim's injury from a previous
DV, I placed Andrew under a~r assault DV. Sgt. Myers remained on scene to obtain written statements.
Andrew was booked int;i ~ohomish County Jail.

I certify (or declare) under ~~~.f pel'jury under the laws of the State of Washington that the foregoing Is true and correct (RCW 9A. 72.085.)
OFFICER SIGNATURE DATE

FORCE USED PURSUIT
5122105 NO NO
OFFICER NAME/NU UNIT APPROVED BY:/PERS.NO.
A Wllllams 1183 421 _;;;;(J),,,,,;,r?
DISTRIBUTION: () JUV ()TRAF OTHER: LOGGED:
()PA ()CPS ()HO ()DET
( ) AOMIN () OSHS ()MH ()PAT DATE INITIALS
OEN 0ENTERED WACIC I NCIC -O~A~TE~ -~~ 0 CLEARED WACIC I NCIC --~ -;:-=-,,..,,-
CATE INITIALS INITIALS DATE INITIALS
EXHIBIT:h_ _
. -- . ...
EVERETT POl,..ICE D CASE #: __,_:o=-1...:.1_;__:')_~
oo,_ _ch-=...,,::._
'
THIS STATEMENT WAS W~N ON MY BEHALF BY: -------------------

1DECLARE UNDER T~AL TY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THAT THE
FOREGOING WRITTE TEMENT, CONSISTING OF _L_ PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST OF MY PEtlS~ KNOWLEDGE. EACH PAGijEDALL CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ'bi}~ VE BEEN READ [ ) THE FO 0 G DECLARATION AND UNDERSTAND THAT THIS
DO MENT MA~E ·SEO IN A COURT OF LAW.
-/(), -;:::;z:z
_ _ _ _..L.-L.,O~FF~~~.R~O~R~w=rr?.NE~~~.~.GNA~TU~~=,-----
EXHIBIT -A.--
EVERETT POLICE INCIDENT REPORT PAGE 1 OF _ I
INCIDENT SE NUMBER
D IOLATION NO CONTACT ORDER-CV DD 05-21287
OCCURRED ON OCCURRED TO REPORTED ON
MONTH· CAY YEAR TIME MONTH DAY YEAR TIME MONTH DAY YEAR TIME
A 02 2005 0330 10 02 2005 0330
10
DDRESS/LOCATION OF INCIDENT 0 FORCE CODE POL BEAT
T 2416 5'" STREET, EVERETT WA 98201 0 NO FORCE 011 11
RESP SGN D JUVENILE 0 COMPUTER USED D HATE/BIAS
OFFENSE (D VI DL .'\S '1 Cw 0 OFFICER SAFETY 0 CHIUD ABUSE 0 DRUG RELATED 0 ARSON-LOSS$
A CODES 0 OFFICER ASSAULT 181 DOM. VIOLENCE 0 ALCOHOL RELATED
A0Cl8! AOCO
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.O.B.IAGE HGT WGT EYES HAIR
p V1 RIFE, JENNIFER RAE w N F 8/08/74 5'02 160 BLU BLN
3 3
STREET ADDRESS AND APT NO. CITY STATE ZIP
E 2416 5TH STREET EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENTIOCCUP JSCHOOL HATE/BIAS VICTIM INJURY
R (425) 259-9828 ( ) 88 I 1
4 5 8
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.0.B./AGE HGT WGT EYES HAIR
p W1 RIFE, JEFFREY DAVID w N M 6/27/75 6'02 208 BLU BRN
3 3
E 1320 HOYT AVE EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUP./SCHOOL HATE/BIAS VICTIM INJURY
R (425) 252-0366 (425) 231-9218 88 1
4 5
•
s
NO
A1
I CIN/tDENTIFICATJON NO. BOOKED/WHERE
SNOH. COUNTY
LOCATION OF ARREST
2416 5'" ST, EVERETT
ARRESTEE ARMED WITH
NONE
NAME (LAST, FIRST, MIDDLE) RACE ETH SEX 0.0.B. I AGE . H.GT WGT EYES HAR
u RIFE, ANDREW SCOTT w N M 3122173 5'11 180 BLU BRN
3 3
STREET ADDRESS ANO APT NO. CITY STATE ZIP
s 2416 5TH STREET EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUPATION/SCHOOL
p
(425) 259-9828
E
ALIAS NAME(S)
( )
SOC. SEC. NUMBER
531-68-8901
PUBLIC UTILITY DISTRICT
DRIVER'S LIC. / 1.0. CARD
RIFE•AS279D2
I STATE
WA
I EXP
MISC. IDENTIFIERS
c
CHARGES & CITATION# QB.WARRANT# & AGENCY CHARGES & CITATION# QB.WARRANT# & AGENCY
T 1. Ill MO F CHARGE VIOL NO CONTACT ORDER err 2. 0 M 0 F CHARGE CIT
CR0069259
DATE!TS~;~~1 d~~Y cH:·1~1r:rn:natie~1 JJf~hi;D aY

NAME/ RELATIONSHIP OF PERSON NOTIFIED (JUVENILE) 1
dor.11rn:~~t J::: :<ot :.1;1·:h:;rj7µ,-!

v VEH. NO. I LICENSE NUMBER I STATE I YEAR MAKE MODEL I STYLE I COLOR
SPECIAL IDENTIFYING FEATURES /V.l.N. DAMAGE$ REGISTERED OWNER'S NAME
V VEH. NO. LICENSE NUMBER STATE YEAR MAKE MODEL STYLE COLOR
SPECIAL IDENTIFYING FEATURES I V.1.N. DAMAGE$ REGISTERED OWNER'S NAME
under the Jaws of the State of Washln ton that the fore oin is true and correct. RCW 9A.72.085.
DATE: FORCE USED PURSUIT
lcJ -o 2--0r- YES 0 N018J YES 0 N0181
OFFICER UNIT
C.OLSEN 422
CLEARANCE: DISTRIBUTION: OTHER:
(J5!§Y
UNFOUNDED
PA
~ JUV TRAF
!"\Ir\":. L~/)/
EXCIA CPS HD DET
ARR/J
EXCIJ ADMIN
OSHS MH PAT l'ros ai.,:h:.v
1. ENTERED RMS ENTERED WACIC/ NCIC
DATE INITIALS IALS
PD 03 (REV. 1/04 .W95
--- - - - - ------------
EVERETT POLICE DEPARTMENT

ADDITIONAL PERSONS PAGE ,6 OF L
f:iCIDENT IDcSE NUMBER
IOLATION NO CONTACT ORDER-DV D 05-21287
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.0.B./ AGE HGT WGT EYES HAIR
p W2 RIFE, JAMES JOSEPH w N M 8/17/47 5'08 180 BRN BLK
3 3
E 1317 MCDOUGAL AVENUE EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENTIOCCUP.ISCHOOL HATE/BIAS VICTIM INJURY
R (425) 259-1928 ( ) RETIRED 88 1
4 5 e
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX 0.0.8./AGE HGT WGT EYES HAIR
p W3 RIFE, WENDY SUZANNE w N F 12/10/49 5'03 200 BLU BRN
3 3
E 2716 LEONARD STREET EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENTIOCCUP.ISCHOOL HATE/BIAS VICTIM INJURY
R (425) 252-2817 ( ) SAFEWAY 88 1
4 5 8
NO. CIN/IDENTIFICATION NO. BOOKED/WHERE LOCATION OF ARREST ARRESTEE ARMED WITH

s
I
SUSPECT'$ NAME (LAST, FIRST, MIDDLE) RACE ETH SEX 0.0.B. /AGE HGT WGT EYES HAIR
u
3 3
s
p RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUPATION/SCHOOL
( ) ( )
ALIAS NAME(S) SOC. SEC. NUMBER DRIVER'S LJC. / l.D. CARD STATE EXP
E
MISC. IDENTIFIERS
c
CHARGES & CITATION# QB_WARRANT# & AGENCY CHARGES & CITATION# QB.. WARRANT# & AGENCY
T
t. 0 MD F 2. 0 M 0 F
NAME/ RELATIONSHIP OF PERSON NOTIFIED (JlNENILE) DATEfffME NOTIFIED NOTIFIED BY
NO. CINI IDENTIFJCATION NO. BOOKED I WHERE LOCATION OF ARREST ARRESTEE ARMED WITH
s
I
SUSPECTS NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.O.B.I AGE HGT WGT EYES HAIR
u
3 3
s
( ) ( )
ALIAS NAME(S) SOC. SEC. NUMBER DRIVER'S LIC. / l.D. CARD STATE EXP
E S1.1cn~·1-:J-·,··- 'l'
; ! ;:-<; .:1 1..i::·1
- ,,, : ;··:.:::'.:)·;:;d:1 ..... !i..'
MISC. IDENTIFIERS {J(J(;.f!~n;.~!1·' ;.-..... ~ .. - ·· ""'' ... ,,..:;
c . ···~·· t I·~ ;su;. aurnorized
CHARGES & CITATION# QB.WARRANT# & AGENCY CHARGES & CITATION# OR WARRANT# & AGENCY
T
1. 0 M D F 2.0MOF
NAME/ RELATIONSHIP OF PERSON NOTIFIED (JUVENILE) DATE/TIME NOTIFIED NOTIFIED BY
DATE
o -o:z.-or
OFFICER NAME/NUMBER UNIT APPROV!'°'BY: I PERS. NO.
C. OLSEN 1196 422 .5?.r(:J!p.d '1?'f
PD 329 (REV. 5199 TLK) FORM ID: APR00.03.W95
EXHIBIT _ __
")
Page !_of _If_
DD oy-1- t-i.£>1
aEverett Police Department

D FOLLOW-UP REPORT ~ ORIGINAL NARRATIVE
INCIDENT I CASE NUMBER

Violation No Contact Order-DV DD 05-21287
REPORT DATE:
C.O U ( OL A-~ '-1 l> vfr! 10/02/05
DA l>3 C DA !!'IC DA DC DA DC DA DC DA DC
INCIDENT RECLASSIFIED TO: DATE OF RECLASSIFICATION RELATED CASE NUMBER(SJIW. S. P. CONTROL NO
On 10/02/05 at approximately 0330 hours I responded to a report of a physical domestic violence situation at 2416
51t1 St. While en route, dispatch updated me that the male, Andrew S. Rife (3/22173) is the respondent to a no-
contact order. The protected party was his wife Jennifer R. Rife (8/08/74).
I arrived on scene and was met by a male who identified himself as Jeffrey D. Rife (6/27/75), the brother of
Andrew. At the front of the residence was Jennifer sitting on the porch. Officer Cracchiolo began to interview her
·abouUhe situation: I entered the house were Andrew was, he stated that earlier that night he was at his brother,
Jeffrey's house. Andrew's mom called asking if Jennifer could come over to Andrew and Jennifer's house while he
was gone. He told his mother that he did not want her over at the house. Later thatnight he returned home and
went to bed. At approximately 0330 hours Andrew heard someone banging on the front door. It was his wife,
Jennifer and their child, at first he did not let her inside because he said he was worried about the no-contact order.
He let her in the house and Andrew said Jennifer struck him on the right side of the face with a closed fist and then
kicked him in the shin on the right leg while he was holding their 1 y/o daughter. I looked at Andrew's face and leg,
neither of them showed any redness or indication of a physical altercation. Andrew showed me a telephone in the
kitchen that had been broken by Jennifer the previous day when they got into an argument. The phone was on the
wall and the earpiece had been broken, connected by the wires only. Andrew told me that they have both been
staying at the house the past couple weeks. When I asked he stated he realized that he was in violation of the no
contact order against him.
Andrew then got on the phone and called his brother Jeffrey to come over because he said he was worried about
being arrested and he wanted Jeffrey to witness Jennifer hitting him. Jeffrey arrived at the house while I was
arriving on scene.
When talking with Jennifer she said that she had repeatedly called her house trying to contact her husband.
Jennifer wanted to come home because she was sick and wanted to get medicine and possibly stay at the house.
After repeated attempts to contact Andrew, Jennifer went over to the house. She knocked on the door and Andrew
would not let her in at first. Andrew eventually let her in. Jennifer stated that no assault had taken place and that he
had made that up prior to Andrew calling his brother to come over. SSC(?:i(Lc;!·;,. c'fi:·;;;,:"'':nN·"• ilf 'h'"
ducun:~~:rf ;.-~ ;i!·;·!··,.';-1~;:~:: :~. -~' u~
..
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing 'is 'trrie"and'corTect.1'4BCW 9A.72.085.)
DATE FORCE USED PURSUIT

/0-02-0 \ YES 0 NOS. YES 0 NO§il'.
UNIT APPROVED BY:IPERS.NO.
-:97 7' CJ .().o "76"/ I
IBR CLEARANCE ( ) UNFOUNDED DISTRIBUTION: () JUV ( ) TRAF OTHER: LOGGED:
()qARRIA
()ARR/J
()EXC/A
()EXC/J
() PA ()CPS ( ) HD
() ADMIN () DSHS () MH
( ) DET fV'. IA "'1' ~°""'
()PAT
r DATE INITIALS
DENTERED RMS -DA_T_E~ -,-NIT_IA_L~S DENTERED WACIC I NCIC - - - · - - - 0 CLEARED WACIC I NCIC --:~:-·---
DATE INITIALS DATE INITIALS
Rev. 1/2004
EXHIBIT~=--
y
. . Pagel,of ~
. DD 12r--2 t 'LI:\'?
Jennifer and· Andrew are married and have been living at 2416 5th street for awhile. They have a child in common
and share custody of the child along with the house.
After talking with Andrew's brother, Jeffrey he said that the two have had multiple problems in the relationship.
Andrew has been trying to keep his distance from his wife, but it has not been possible with them having a 1 y/o
daughter in common. ·
Both of Andrew's parents showed up at the house while I was on scene. The father James J. Rife (8/17/47) stated
that his son had been staying with him at his house the past weekend, due to problems between Andrew and
Jennifer. The mother, Wendy S. Rife (12/10/49) said that Jennifer had called her asking if she could call Andrew to
get permission to come over to the house. Wendy checked with Andrew and he had said that he does not want
Jennifer over there. Wendy called Jennifer back at Jennifer's parents and told her that Andrew does not want her to
come home.
I explained to Andrew that the no-contact order restricts him from coming within 150 feet of Jennifer's residence.
Andrew said he knew he was in violation of the court order and that he had tried to get the order quashed earlier
this week 9/29/05. I told Andrew that the order has not changed and that he was still in violation. When I placed
Andrew under .arrest he began to complain of chest pains. I called for an Aid-car, they arrived on scene and
checked Andrew out. The determined he was alright and it was likely anxiety.
I read Andrew his constitutional rights from my department issued rights card, he said he understood and wanted to
talk to his lawyer. I advised him once we got to the jail he would be able to call his lawyer. I transported Andrew to
the Snohomish County Jail and booked him for violation of no-contact order.
I am referring this case to the prosecutors' office for additional charges against Jennifer R. Rife for assault.
OFFICER~~E ~ DATE FORCE USED PURSUIT

~~;;:;;.,-~~~~:;:::'.'.'.::::
~::::=-___________j__1~0:::_:-0~)~-o~)"'~_l~~YE~S~0~N~O~J&.~_J-~Y~ES~0~N~O~OO.:_j
OFFICER NAME/NUMBER UNIT APPROVED BY:/PERS.NO.
1
r. 111 't;; 1I q L{'L -5':,re5.oc'7oe7
IBRCLEARANCE~(7)~UN~F~O~U~N~D~E=o--"--'-~~D~l=sT=R~l=e=uT=1o=N=:-~(7
)J~UV,,..L--,~)T~RA;:..,!F;.__o=T=H=E=R-:L..__~_L_O_G_G_E_D_:_.:__ _ _ _~
('ltARR I A () EXC I A ()PA ()CPS ()HD () DET ;v..~~;, •. .,,-f
()ARR/J ~()~E_x_c_1_J_ _ _ _ ___,_(~)_A_D_M_IN__:(~)_os_H_S__:(~)_M_H_ _:_:<>_P_A_T~~~·~e~~"'1.!~!!:.__ _L_D_A_T_E_ _1_Nl_T~IA~LS.:_~__j
CENTERED RMS--~--- CENTERED WACIC I NCIC -=-==-'·-~~ C CLEARED WACIC I NCIC - - - ' - - -
DATE INITIALS DATE INITIALS DATE INITIALS
Rev. 1/2004
EXHIBrT 3
•Everett Police Department
IZl FOLLOW-UP REPORT D ORIGINAL NARRATIVE
INCIDENT CASE NUMBER
COURT ORDER VIOLATION DD 05-21287
REPORT DATE:
10/02/05
DADC OADC OADC DA OC DA DC DA DC
INCIDENT RECLASSIFIED TO: DATE OF RECLASSIFICATION RELATED CASE NUMBER(S)/W. S. P. CONTROL NO
On 10/02/05 at approximately 0330 hours I responded to 2416 5th Street to assist Officer Olsen with complaint of a
violation of a No-Contact Order and physical domestic violence. While I was on my way to the call I received
information from dispatch that there was a valid order in the system that showed Jennifer Rife as the protected
person and Andy Rife as the respondent in the order.
The reporting person was Andy Rife and he advised the 911 call-taker that a female was at the location and that
she had punched him in the face while he was holding his daughter. Supplemental text was added by the call-
taker that the female was Andy's wife, Jennifer, and that she was now locked outside of the residence. There was
said to be an associated white BMW outside of the residence.
Upon arrival I contacted a male west of the house that identified himself as Jeff. Rife,. the brother of Andy Rife. Jeff
told me that he was phoned by Andy and told to come over to the residence because Jennifer had returned and
assaulted him. Jeff said he was there to support his brother. I asked Jeff to remain in his.vehicle and not enter ttie
home until officers could sort out what was occurring.
I then contacted Andy while Officer Cracchiolo spoke with Jennifer. Andy said that he was hit in the face and
pointed to his right eye. I could see no marks that substantiated his claim, but did not rule out the possibility. It
should be noted that Andy's first complaint of the assault only included the area directly above his right eye and no
other part of his body.
Andy was adamant that he did nothing wrong and that he was awakened by Jennifer ringing the doorbell over and
over again. His appearance certainly lent itself to his statements about being awakened suddenly as he was only
wearing jeans that were not completely fastened. Andy was holding his daughter .~1:1i;ir~n1sifld expressed great
concern about Lauren being brought to the residence by Jennifer at the odd hour. rio' ',". 0 Oic;i:e•nin:.lfion of .
""'
.''."Y
C(•f ·•n~· :. ·· 111 /'"'u
~';'t··:1. :;:.; !lut uu1·ncri"7']
Andy told me that Jennifer had left the house the day prior and he was under the understanding that she\vouktt\e
staying in Clearview with family. Jennifer was said to have contacted Wendy Rife, Andy's mother, about her
returning to the house and Wendy told her not to because Andy would be home. Immediately I could see some
discrepancy in who actually resides at the residence in which we were currently at. Both Jennifer and Andy alleged
that the residence was their primary address and with a valid No-Contact Order in the system there is the obvious
problem with the two of them residing under the same roof.
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. (RCW 9A.72.085.)
OFFICER SIGNATURE FORCE USED PURSUIT

YES 0 NO!)(. YES 0 NO 15...
OFFICER N
IBRCLEARAN DISTRIBUTION: ( ) JUV D:

( )ARR/ A ()PA ()CPS ()HD
()ARR/J ( ) ADMIN () DSHS () MH E INITIALS
DENTERED RMS-~~-~~ DENTERED WACIC I NCIC ----'--~

DATE INITIALS DATE INITIALS DATE INITlALS
Rev. 1/2004
EXHIBIT---<===.._
Page 2 ot..3
DD l?s:-"""°3-J '2..81
I returned outside and contacted Jeff and asked him to complete a written statement for me regarding the phone
conversation that he had with his brother. Jeff began working on the statement in his vehicle. As I was leaving
Jeff's vehicle another vehicle pulled up to the residence. The woman driving the vehicle was identified as Andy's
mother Wendy.
Andy had called Wendy after the police responded and she had come to support Andy. While I was speaking with
Wendy, yet another vehicle drove up to the residence. The driver of that vehicle was identified as James Rife, the
father of Andy. James had also arrived at the residence to support Andy. I spoke with both James and Wendy and
together they explained that Jennifer is a constant problem to Andy. They advised me that Andy and Jennifer have
been living at the residence though it is a clear violation of the order. Apparently in the days just prior to this
incident, Jennifer and Andy had gone to dinner and an argument ensued because Andy refused to drink alcoholic
beverages with Jennifer at the restaurant. That is what sparked Jennifer's leaving to be with family in Clearview.
James told me that Andy had also left the residence after that incident and was staying at his residence. James
said that he had hoped Andy would remain there but Andy told him that since Jennifer had gone to Clearview, he
wanted to return home. Both James and Wendy completed written statements for me describing their knowledge
of the current living situation of Andy and Jennifer.
I told James and Wendy about the nature of the call in which I had responded to with other officers and explained
to them that there was indeed an order violation. I also stated that we were investigating the assault that Andy had
alleged occurred. I advised them that it was quite possible that the incident could result in Andy being arrested. To
this James adamantly replied that Jennifer was the ongoing problem and .that the house had belonged ·to Andy
prior to the marriage and it was not right for his son to have to leave due to the order. I explained to him that it was
my understanding that neither Jennifer nor Andy appeared to have a clear understanding of who was to remain at
the. residence and that perhaps clarification was needed so we could prevent further violations of the Judge's court
order.
I again.contacted Andy inside the residence. I asked him a second time to show me where Jennifer had hit him.
This time Andy pointed to the side of his head above his right ear. I noted that this was a different location than he
had initially pointed out to me the first time I asked. I was also advised by Officer Olsen that Andy had advised him
that he was kicked by Jennifer in his leg but no mark or any other physical evidence could substantiate that claim. I
found it odd that the story of the alleged assault appeared to be evolving as the time passed.
I had brief interaction with Jennifer and she appeared to me to be very agitated and unwilling to answer questions
directly. To my knowledge, Officer Cracchiolo had the most interaction with Jennifer and his follow up should be
referenced for her account of the incident. I can say that in my brief interaction with her she seemed to be unclear
on the matter of who should reside in the residence and who should not. I also suggested to her that a parenting
plan would be a good tool in reference to Lauren.
Ultimately Andy was taken into custody and booked at the Snohomish County Jail for the order violation. I phoned
James and advised him of the outcome as he had indicated to me while he was on scene that he would appreciate
my doing so. James was of course displeased with the final result and I suggest~d to him that he should continue
to support Andy as he clearly was already doing and encourage Andy to not violaleitl;ieJof9j!r;ih·;./;·c;f;nn .•. , , ....
' . '·'·~~1!~1r• 0 • ll.J'~
IJOCLJ:T 1 :;~r.~1--~.,.; .. · · ' .....
:it;i :..IU1!1ti!f7Pri
111 4
··' • .;;
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing Is true and correct. (RCW 9A.72.11s'5.)
FORCE USED PURSUIT

//4/ 0 YES 0 NO J\! YES 0 NO ~
OFFI RO BY:/PERS.NO.
I
IBR CLEARANCE ( ) UNFOUNDED DISTRIBUTION: ( ) JUV LOG ED:

()ARR/A ()EXC/A () PA ( ) CPS ()HD
( )ARR/J ()EXC/J () ADMIN () DSHS () MH INITIALS
DENTERED RMS -D~A~TE~ _1_NIT=IA-L~S DENTERED WACIC I NCIC --~_,,,==-=-

Rev. 1/2004
EXHiBrT --==-
Page3 oJ
DD o"'f- -)IZ-5 7
No further action was taken. End of report.
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing Is true and correct (RCW 9A.72.085.}
DATE FORCE USED PURSUIT

10/oz./os YES 0 NO
OFFICER NAMEINUMBER
UNIT le/
- c,'-'- /( ""
IBR CLEARANCE ( ) UNFOUNDED DISTRIBUTION: ( ) JUV ()TRAF
()ARR/A ()EXC/A ()PA ()CPS ()HD ()DEL
()ARR/J ()EXC/J () ADMIN () DSHS () MH (fPA ATE INITIALS
DENTERED RMS~=,....,-~~~
DATE INITIALS DATE INITlAlS
Rev. 1/2004
EVE~ETT POLICE DEPARTMENT STATEMENT FORM CASE#: DD c) ) - L ( 2_6/
ir(_
STATEMENT OF:
LAST NAME
~,Ii JtA;
FIRST NAME
-. ~o\-f-
MIOOLENAME
IJ.JVJ\- . W1
RACE SEX
01 r)-?-
D.t. TE Of WRTii
75 5'-j(
HEIGi-fr
/10 ~w
EYECOtOR
p/2,v
IWRCOlOR
WEIGllT
RESIDENCE: /) l/ I (:, S--1 J, <;

STREET ADORESS
+ <'.'.(,
CITY
µ;rUA; l.V.I\
STATE
'1 ?) t> I
ZIP
HOME PHONE #:L.{ ;:I 5 ~ ft,f { WORK/CELL#: -~-'-'~~<:,.:_-_;d-_~"'-'-1-'1'1-1

-- ? - EMPLOYMENT: P'-' D
·~"•c U·'"'~ ·r··· •····

1 .. _·····"'-'" · u·· 1111·~
, .-i
, .. ,n.t ;) ;1G·: ;,·;;i·?,., ... ;ZP.d ..
• ·-· l-.1{1 l i '
I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF THE S ATE OF WASHINGT N THAT THE
FOREGOING WRITTEN STATEMENT, CONSISTING OF --1::;-PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST.OF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS..
I HAVE READ [(]I HAVE BEEN READ ( ) THE FOREGOING DECLARATION AND UNDERSTAND THAT THIS
DOC:~~IN A COURT OF LAW. ( l
~~&r ~ ~-Wit~
fv-U-LiJ v-r lit> 'k< 1
r
/(_ · (CITY~ STATE W1iERE SIGNED)
Page_;>-_ of ___c · QNIT.)~

EXHIBIT~--!;<"'°"'
!=VERETr POLICE DEPARTMENT STATEMENT FORM CASE#: OD dJ- ? I L..$37
sTATEMENTOF: R.1 re ft:tJ!v/ tre:?L l< klZ'

LAST NAME FIRST NA.Me MIOOLE NAME
t.J '·
RACE
f 0At1~2i ft:J- WOOHT
BL.J
RESIDENCE: J </I~ ,tf"/k- 5'fk.EE/ 1 £-</£le e-rrCffY ; , ~ ,q

STREET ADORESS ' STATE
9 .P~I
. ZIP
HOMEPHONE#: 2)'f, tz%&J.tl W~: /ft../f·t,/t../ff/ EMPLOYMENT:_.i)''-'£1F~----
ALTERNATE CONTACT (IN
..
.. • . · (~ l.i 'Uf :zea

THIS STATEMEN1:WAS WRITTEN ON MY BEHALF BY:
I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THAT THE
FOREGOING WRITTEN STATEMENT, CONSISTING OF _ _ PAGES, IS TRUTHFUL AND ACCURATE TO THE .
BEST OF MY PER_$(1NAL KNOWLEDGE. EACH PAGE AND All CORRECTIONS, IF ANY, BEAR MY INITIALS.
·I HAVE READ(./} /HAVE BEEN READ ( .1 THE FOM.Jl~G DECLARATION AND UNDERSTAND THAT THIS
OOCUME AY~EUSEDINACO RTOFLAW.~ . ff .
Wlfl!v1·u ~ JI. Ctf?/:f-cC.!-l!CJC..0 /17"</
~TVRE (OFFICER OR W1TNESS SIGNATURE)
(DATE Of STATEMENT)
EXHIBIT ~~l,-_,..,...--
Page _ _ of _ _
.EVERl;Tr POLICE DcPARTMENT STATEMENT FORM o~·~~--~-l~'2..~i3~'-
CASE#: DD_ _
STATEMENT CJF: _~E=~··~_Cl_=~---J-=..,Q__~~~·~~··

lASTNAME FIRS~.__.------,.,='~~·
MtOO(~'="'\)~;~'-------
f <lJHcf $ ~~ {:J °".TE OF BIRTii W8()lfT EYECOtOR HAIR COLOR
RESIDENCE: I ~ a-9 ti?± t-· ~ }Jl. '(, J,~f(.)f· W(t- 1 '{ 2CJ /
sTREtii ADORESS CITY srAre ZlP
HOME PHONE#:
11
<--( ) ") '
;f-C)J-0:,(. '-' WORK/CEU#: --'J-:.....::;.).,._) PuD
__,'f""';)'-"/'-i_,._._ _ _ _ EMPLOYMENT: _ _ _ _ __
..=)er:n.•ir.1~. ~.
~-·--·.;nJ:; ea
THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: - - - - - - ' - - - - - - - - - - - - -
FOREGOING WRITIEN STATEMENT, CONSISTING OF PAGES, IS TRUTHFUL AND ACCURATE TO THE
BESTOF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS..
I HAVE READ [ ) I HAVE BEEN READ [ ) THE FOREGOING DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT MAY BEU DIN A COURT OF LAW. ( )
(CITY ARO STATE WHERE SIGNED) (DATE OF STATEMENT)
Page _ _ of _ _ <'Vu•srr _.e_ (INIT.) ~,--

0 _l()..()(M
~I kcv: S/2004
. ·EyER.ETT POLICE DRARTMENT STATEMENT FORM CASE#: DO {!>::;;-- 'J.-11-.fi; 1
STATEMENTOF: ·~~ \ ;/))~{/\ 5 . -
--- LAS 1 MIOOt.E NAME
. . ·13
FIRST NAME
ALTERNATE CONTACT ON CASE OF RELQCA.TION):
.,
-~
. • j JL.ij{
THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: 4':::~Lft.~::0:~~L.,x;,/=.\;2~~?-----

I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF TH TATE OF WA NGTON THAT THE
FOREGOING WRITTEN STATEMENT, CONSISTING OF _L_ PAGES, IS T HFUL AND A CURATE TO THE
BEST OF MY PERSONAL KNOWLEDGE. EACH PAGE AND All CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ [ ] I HAVE BEEN READ [ ] THE F~~EGOIN DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT MAY BE USED IN A COURT OF LAW. •
,.!)1_,,,,~ y;6? """

i:u:&/2JL STA~ SIGNED)
(CtTY AHO
, ;o/:~~::-wrrNEss•~,_,
(DA.TE OF STAT'EMEHT)
,
Page _ _ of EXHIBIT s::,_(!!:!!J.) - - -
r0-004 Rev: snoo-i
EVER.ETT POLICE_GEPARTMENT STAT~T FORM CASE #: DD !9 , ; ; - .J- f 2--B 7
~TATEMENTOF: ·fj [z_

LAST NAME
Jf)(bte,S
FIRST N.lME.
0
M!OOlEHAME
i1/l
. SEX
Ul?J.<1,1
OF B ·
ft r?
EIGHT
!PT
Z,WEJGHT EYE COLOR
RESIDENCE: _ _ _ 1~3~1--!z~·m~t:"==--lJ._0,=.-A_t_lf_f'.l.-----
_ ___,6""'~~~,,.-----,;w==-/::?_ _~~-·:k?--,:(""'.-
STREET AOORESS CITY STATE • Z'
HOME PHONE#: ¢: s= 2.59-JCj~ WORK/CELL#: _ _ _ _ _ _ _ _ _ EMPLOYMENT: ·~.k_/ .
ALTERNATE CONTACT (IN CASE OF RELOCATIONt.
t.
THIS STATEMENT WAS WRITIEN ON MY BEHALF BY: ~#~~:25::::::::__ __;__________

I DECLARE UNDER THE PENALTY OF PERJURY UNDE E LAWS OF THE STATE OF WASHINGTON Tl-IAT THE
FOREGOING WRITTEN STATEMENT, CONSISTING OF PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST.OF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ [ ] I HAVE BEEN READ [ ] THE FOmG DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT BE U · 1N A COURT OF LAW.
;$:_--~ //'"fO
(CITY AND STATE 'MiERE SIGNED) (DATE OF STATEMENT)
Page _ _ of _ _ """"BIT Q.\ (INIT.) _ __

""'11 -J:.Lrt>-004 llct: 5/lO().I
. .
IN THE ~VERETT MUNICIPAL COURT, SNOHOMISH COUNTY, WASIDNGTON
CITY OF EVERETI, ) CASE NO. ®1110

) ( NO CONTACT ORDER
Plaintiff, ) !
~~DTfR\f=~
vs. )
) ~Pre-trial CERTIFIED COPY
) D Post-conviction
Defendant. )
DEFE1''DANT INFORi'\1ATION: DOB: -%.;;J..h3 SEX rn RACE W

HT5'g"' WT 175 EYES /3LLL HAIR AAJJ
THE COURT finds that the defendant has been charged with, arrested for, or convicted of a domestic
violence offense, and further finds that to prevenfpossible recurrence of violence, this Domestic Violence No
Contact Order shall be entered pursuant to RCW I0.99 and EMC I0.22.
IT IS HEREBY ORDERED THAT, pursuant to RCW I0.99.040, RCW 10.99.050, EMC 10.22.010 and
EMC 10.22.020 the DEFENDANT shall have no contact, directly or indirectly, in person, in writing, by telephone,
·by mail, or by an other means with:
lJ!j_sEX ~RACE /__;)

or knowingly come with.in or remain within
D For a period of one (1) year OR ~untiI_~l..,...0-~5~-~D~iJ,__ _ __

WARNINGS TO DEFENDANT
VIOLATION OF THE TERMS OF THIS ORDER WITH ACTUAL NOTICE OF ITS TERMS IS A
CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL SUBJECT A VIOLATOR TO
ARREST. ANY ASSAULT, DRIVE-BY SHOOTING, OR RECKLESS ENDANGERMENT THAT IS
A VIOLATION OF THE ORDER IS A CLASS C FELONY. YOU CAN BE ARRESTED IF ANY
PERSON PROTECTED BY THE ORDER INVITES OR ALLOWS YOU TO VIOLATE THE ORDER'S
PROHIBITIONS. YOU HAVE THE SOLE RESPONSIBILITY TO AVOID OR REFRAIN FROM
VIOLATING THE ORDER'S PROVISIONS. ONLY THE COURT CAN CHANGE THE ORDER.
A VIOLATION OF THIS NO CONTACT ORDER INVOLVING TRAVEL ACROSS STATE LINES

OR THE BOUNDARY OF A TRIBAL LAND, OR INVOLVING CONTACT WITHIN THE SPECIAL
MARITIME AND TERRITORIAL JURISDICTION OF THE UNITED STATES, WHICH INCLUDES
TRIBAL LANDS, MAY SUBJECT YOU TO CRIMINAL PROSECUTION IN FEDERAL COURT. IN
ADDITION, FEDERAL LAW PROHIBITS YOU FROM OWNING OR POSSESSING A FIREARM
WHILE THIS ORDER IS IN EFFECT.
A COURT IN ANY OF THE 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO AND
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 Prosecutor shall forward a copy of this order to the record keeping agency,
which shall duly enter the order as indicated above.
10-5 ,2o_o5. .
..
..... -
10/23/00 ORIGINAL - Court CANARY -Defendant PINK - EPD
_,,.,..
Snohomish County PUD Credit Union PAGE:
1328 Broadway - Everett, WA 98201
(425) 256-8599 NOTICE:
www.pudcu.com PLEASE ADVISE US
IF YOUR ADDRESS IS IN ERROR
QUESTIONS ABOUT YOUR STATEMENT?

PLEASE CALL: (425) 258-8599
MEMBER NUMBER
0001277390
ANDREWS RIFE OR JENNIFER RIFE

24165THST
EVERETT, WA 98201
STATEMENT PERIOD
09/01 /2005 TO 09/30/2005
SOOO - SAVINGS
PERIOD BEGINNING DATE 09/01/2005 PERIOD ENDING DATE 09/30/2005
DMDENDS YEAR TO DATE 34.03
DATE pESCRJPTlON AMOUNT DATE DESCRIPTION AMOUNT

PREVIOUS BALANCE 7,255.53 09/22 OEPOSIT 966.17
09/02 WITHDRAWAL -50.00 09/26 WIDlDRAWAL TRANSFER-RIFE,JENNIFER. -100.00
09/06 CR CARD •••••••••••••••8059 PMT 150.00 09/28 WITHDRAWAL TRANSfiR-RIFE,JENNIFER -50.00
09/06 CR CARD •••••••••••••••S059 PMT 150.00 09/29 WfTHDRAWAL -200.00
09/07 CRCARo·······••*·····so59 PMT 300.00 09/30 WfTHDRAWAl -300.00
09/07 .DEPOSIT 950.00 09/30 DEPOSITOMOEND 4.07
09/12 . \vrJHDRAWAL-\VASH MUTUAL •E• -947.14 NEW' SHARE BALANCE 7,528.63
ACH: LOAN PVMT COMPANY ID: 321180748 SEC".PPD
DMDEND PERIOD 09/01/2005 TO 09/30/2005

DMDEND EARNED 4.0T·
ANNUAL PERCENTAGEYIW> EARNED 0.65%
AVERAGE DM.Y BAlANCE 7,612.19
·,. .,
S020 - CASH MANAGEMENT
PERIOD BEGINNING DATE 09/01/2005 PERIOD ENDING DATE 09/30/2005
DMDENDS YEAR TO DATE 0.46
DATE DESCRIPTION AMOUNT DATE DESCRIPTION AMOUNi

.PREVIOUS BAJANCE 18.111 NEW SHARE BALANCE 18,121
09/30 DEPOSITDMDEND 0.01
DMDEND PERIOD 09/01/2005 TO 09/30/2005

DIVIDEND EARNED 0.01
ANNUAL PERCENTAGE YIELD EARNED 0.67%
AVERAGE DAILY BALANCE 18.11
SOI 0 - CHECKING
PERIOD BEGINNING DAlE 09/01/2005 PERIOD ENDING OAlE 09/30/2005
PREVIOUS BALANCE 12.21 NEW SHARE BAIANCE 15.48
TOTAL DRAFT DEPOSITS 1,144.10
TOTAL DRAFTwrTHORAWALS 1,140.83
DATE DESCRIPTION AMOUNT DATE DESCRIPTION AMOUNT

09/06 DEPOSITTRANSFER-RIFE,JENNIFER 300.0009/13 DRAFT#002824 -61.81
09/06 WllllDRAWAl -150.0009/l6 DRAFT#002825 -116.05
09/07 DEPOSrTTRANSFER-RIFE,JENNIFER 50.0009/14 DRAFT#002826 -150.00
09/07 DEPOSIT· 544.1009/14 DRAFT#002827 -208.16
09/16 DEPOSIT 250.0009/14 DRAFT#002828 -21.00
0$/23 CHECK PYMT COMPANY 10: 2004020301 SEC: A 09/23 DRAFT #002829 "E" -200.41
09/13 DRAFT#002822 -101.65 09/22 DRAFT#002830 -27.02
09/14 ORAFT#002823 -81.38 09/26 DRAFT#002831 -23.35
EXHIBIT 4)
... PAGE: 2
MEMBER NUMBER
0001277390
STATEMENT PERIOD
09/01 /2005 TO 09/30/2005
DATE CHECK AMOUNT DATE CHECK AMOUNT DATE CHECK AMOUNT

2822 101.65 2826 ' 150.00 2830 27.02
2823 81.38 2827 208.16 2831 23.35
2824 61.81 2828 21.00
2825 116.05 2829 • 200.41
DIVIDENDS YEAR 10 DATE 0.00
LOOl -
i"orAL PRINCIPAL. PAID nus PERIOD 437.41 TOTAL INTEREST PAID THIS PERIOD 89.59
CREDrTUMIT 0.00
DATE DESCRIPTION TRANSACTION PAYMEHIS, CREDITS FINANCE . FEES OR LATE BALANCE

AMOUNT OR DEBl'TS:•• CHARGE CHARGES
PREVIOUS BALANCE 26,372.00
09/22 LOAN PAYMENTS PAYROll-PUD PAYROLL 527.00 437.41 .· 89.59 0.00 25,934.59.
NEW LOAN BALANCE 25 934.59
SUMMARIZATION
All LOANS DESIGNATED wrrn A(#) PRECEDING lHE NOTE NUMBER ARE QPEN·END LOAN~
(#) .NOTE LOAN LAST LAST PERIODIC ANNUAL FINANCE FINANCE PAYMENT NEXT PAST
NUMBER ID FINANCED LOAN RATE PERCENT CHARGE CHARGE AMOUNT DUE DUE
AMOUNT DATE DAILY . RATE PAID Tl!IS PERIOD PAID YEAR 1ll DATE DATE
• 0 01 33,577.62 3/12/04 0.0109589'Jll 4.000% 89.59 843.67 527.00 10/22/05
IN CONNECTION WITH OUR ROUTINE ANNUAL SUPERVISORY COMMITTEE EXAMINATION,

. PLEASE CONFIRM TO OUR AUDITORS MOSS ADAMS LLP
IF ANY OF THE ABOVE INFORMATION IS NOT CORRECT,
IF INFORMATION IS CORRECT, NO REPLY IS NECESSARY;
PLEASE MAIL ANY DISCREPANCIES DIRECTLY TO
MOSS ADAMS LLP. 2707 COLBY AVE., SUITE 801, EVERETT, WA 98201-3510
EXHiBIT..,,D_
·-
POST OATE 10/03/2005 TIME 7:56~14 MEMBER 0001277390 RIFE.ANDREW S TELLER HARA SEO ff 053000003 PAGE
IO TRAN TYPE AMOUNT BALANCE FEES PRINCIPAL INTEREST NEXT DUE
sooo Will TRANSFER 7. 500. 00 26. 63
ec RIFE, JAMES J
sooo AVAIL SllR Bl1L 23.63
~u
Snohomish county POD
CASfl RECEIVED 0.00 CASH DISBURSED 0 . 00 CHECK RECEIVED 0. 00 CHECK DISBURSED 0. 00
Credit Union
P:verett OWN YOUR OWN HOME?
425-250-9599 ANDREW S RIFE IF SO Cl IECK OUR HOME EOUIT V LIM:
Arl in9ton 2416 5TH ST OF CREDIT (lfELOC> LOAN PROGRAM!
360-435-5409 EVERETT WA 96201
Signature-------------------
.,
"
'\
m
~
5:i
=I
~
Jennifer Rife - Gross receipts for 2005
January $ 200
February $1,500
March $1,725
April $2,250
May $3,640
June $4,265
July $5,425
August $3,925
September $3,000
October to date I 0/24 $2,050
Total to date this year so far is $27,980 which comes out to $2798 per month.
·-:.:
EXHi81T
--'f-:: --···
I.' : •,•
•
F~~-ED
71105 NOV - I PM 12: 3~
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll ?A~J l. DANIELS
CL 11209197 COUNTY CLERK
SNOHOHIS/-1 CO. \'/ASH.

COUNTY OF SNOHOMISH
ANDREWS. RIFE, NO. 05-3-02755-1

Petitioner,
and
-C-<i!..-f> • rc-.r"CI 0 r ....9.~ .
JENNIFER R. RIFE,
Respondent. ___ _______
._......._...._
CLERKS ACTION REQUIRED __,~----
I. JUDGMENT/ORDER SUMMARIES
I. I RESTRAINING ORDER SUMMARY:

[ ) Does not apply. !}] Restraining Order Summary is set forth below:
Name ofperson(s) r e s t r a i n e d : - - - - - - - - - - - - - - - - · Name ofperson(s)

protected: . See paragraph 3.1.
VIOLATION OF A RESTRAINING ORDER IN PARAGRAPH 3.1 WITH ACTUAL NOTICE OF

ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL SUB.JECT
THE VIOLATOR TO ARREST. RCW 26.09.060.
------------------~
1.2 MONEY JUDGMENT SUMMARY:
1{J Does not apply.

[] Judgment Summary is set forth below.
A. Judgment creditor
B. Judgment debtor
$ _ _ _ _ _ _ _ _ _ _ _ __
c. Principal judgment amount
Interest to date of judgment $ _ _ _ _ _ _ _ _ _ _ _ __
D.
$ _ _ _ _ _ _ _ _ _ _ _ __
E. Attorney's fees
F. Costs $ _ _ _ _ _ _ _ _ _ _ _ __
TEMP ORDER ((MO) - Page I of4

WPF DR 04.0250 (912001)- RCW 26.09.060: .110: .120: .194
WSSR
----------
,.
'
..
G. Other recovery amount $ ---------------
H. Principal judgment shall bear interest at % per annum
I. Attorney's fees, costs and other recovery amounts shall bear interest at - - - - - % per annum
J. Attorney for judgment creditor
K. Attorney for judgment debtor
L. Other:
II. BASIS
A motion for a temporary order was presented to this court and the court finds reasonable cause to issue
the order.
Ill. ORDER
It is ORDERED that:
3.1 RESTRAINING ORDER:

VIOLATION OF A RESTRAINING ORDER IN PARAGRAPH 3.1 WITH ACTUAL NOTICE OF
ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL SUBJECT
THE VIOLATOR TO ARREST. RCW 26.09.060
[] Does not apply.

bJ' The ~lrnsband{!\f wife is restrained and enjoined from molesting or disturbing the peace
of the other party or of any child.
[] The [] husband [] wife is restrained and enjoined 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:
---------------------~
[] The []husband [] wife is restrained and enjoined 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 these children:
CLERK'S ACTION/LAW ENFORCEMENT ACTION:
[J This order shall be filed forthwith in the clerk's office and entered of record. The clerk of
the court shall forward a copy of this order on or before the next judicial day to
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (name of appropriate
law enforcement agency) which shall forthwith 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 hy the
party or the party's attorney and provided '"'ith this order before this order '''ill he entered
into the la"' enforcement computer system.)
EXPIRATION DATE:
This restraining order will expire in 12 months and shall be removed from any computer-based
criminal intelligence system available in this state used by law enforcement agencies to list
outstanding warrants, unless a new order is issued, or unless the court sets forth another
expiration date here: (month/day/year).
TEMP ORDER (IMO) - Page 2 of4

WPF DR 04.0250 (912001) - RCIV 26.09.060; .110; .120; .194
3.2 TEMPORARY RELIEF.
The [~husband [] wife shall pay the other party$ ~ .,Y per month maintenance.
5~:,0/1> ~+ ~"'~.-... ""-o--<-N'<-', luo"lo u~ C,,,...'-' f'~,
Starting Date: ~"'" • \ , "2 uu'S
Day(s) of the month payment is due: --'"'""-"---------
Payments shall be made to:
[] the Washington State Child Support Registry (if child support is ordered).
[] directly to the other spouse.
[] the clerk of this court as trustee for remittance to the other spouse (if there are no
dependent children).
[~] 4' ~ Other: ~ \..v> \oc-J t.\.....I.\. ""?() 'Ii.. ~- ""'~~~'ls'- """.J> I oi:fh
o+ .y...._, c.o.. \"""u ... -"- ~ ~"""'->. ll\-.lr -:.uc.l... ~ ....... "'"' \.,0,1.,-~.J' ?"'\'
u...- .. k... "\'2,.':;UC '~ "'>""-<....\.\.. ~..,.,_ "Z. u.J<-<-".> ~ \Jc...(.~-'ct. ~ 1,...o....... '>.-c.... ..t...._
M-<1 ..;....,_><. '"-"1'<>..,.,.Ji .... ,\.\._ '<>.... l.o""'Jo ru \'•,...,.I.,'-.. ~r h<>~'>'- ~'ti..-.._,,-_
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.
The I'll husband 111 wife 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 pa1ty to notify the other
of any extraordinary expenditures made after the order is issued.
The [°3-husband [I.I wife is restrained and enjoined from removing any of the children from
the state of Washington.
[~ The [;ghusband ff.l wife 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 [] h n ] wife shall surrender any deadly wea ier immediate

poss sion or co itrol or o iate possession or control to: _ __
_:__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (Name or agency).
[¥J, Each party shall be immediately responsible for their own future debts whether incurred by
credit card or loan, security interest or mortgage.
[] Responsibility for the debts of the parties is divided as follows:
['1,1 The family home shall be occupied by the [ l husband NI wife. w\....v-> ~ ...._.,.,,..., ... J
\>~()s '\o-;;>Su. -'-s~ .
TEMP ORDER (TMO)- Page 3 o/4
WPF DR 04.0250 (912001) - RCIY 26.09.060;. 110; .120; .194
['f" Use of property shall be as follows: "'C1..,... V- ,l;_ "'>"-.~ \..-.. ... "'- \J <;,-c.
o ~ *'--' ~,,,._..J - ".:. "?'5 : · u ..,1..,\. "\'-... \...~•1,,._.Jl 1?<-1:>\ k.._r
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-+'~ .._, I,._.. 1"'1:1' .l,.\,...,, o~--..A "'"- ._.,_,l\. ~
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[] The [] husband [ ] wife shall vacate the family home. You have a right to keep your
residential address confidential. [ ] [Name] waives confidentiality
of the address which i s : - - - - - - - - - - - - - - - - - - - - - - -
[] The [ ] husband [ ] wife shall pay temporary attorney's fees, other professional fees and
costs in the amount of$ to:
[] Other:
3.3 BOND OR SECURITY.
[.y' Does not apply.

[l The filing of a bond or the posting of security is waived.
[l Other:
3.4 OTHER:
NOV 0 1 2005
Dated:-----------------
Presented by: Approved for entry:

Notice of presentation
(
Print or Type Name Print or Type Name
TEMP ORDER ({MO) - Page 4 of 4

WPF DR 04.0250 (912001) - RCW 26.09.060.. 110: .120: .194
F\LED
'/.\\US NO'i I 0 PK z: zI
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CL 11398406 'i'P.M L. oAl\IELS
2 COUl\T'l' CLERK
.Sl\OHOMISH CO. VIASH.
3
5
UPERIOR COURT OF WASHINGTON
7 In re:
s ANDREW SCOTT RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF JAMES RIFE

and
IO
JENNIFER RAE RIFE
11 Respondent.
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13 Please see attached.

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26 CARLJ.GAU
Attorney at La ~~I'\
27 302 Bank of America Bldg \B /)..,.\)
1604 Hewitt Ave /
Everett WA 9820
425 259-4147 FAX 259 708
•' "
6 UPERIOR COURT OF WASHINGTON

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3·00314·8 ~G.-w\-2-~£,:tS
\~ +i He ~l(~ t
and
10 Declaration of
Jennifer Rae Rife
11 Respondent.
12 1, .J~m/· s, K-1\€... , declare under penaltv of perjury.of the 1aws of the
State of was ington, that the following is true and correct.
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1. · IDENTITY AND PURPOSE
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1 am ~ l\J~ ~ ~ t=°lk -t \le ~ 1 make this declaration to
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Executed at
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G ~ l ~ H UJ 1t 't t.a o I
26 CARLJ.GAUL
Attomey at Law
1604 Hewitt Ave.
OR\G\NAL Everett WA 98201
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CL 11398404
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1 In re:
g ANDREW SCOTT RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF WENDY A. RIFE

and
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JENNIFER RAE RIFE
11 Respondent.
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26 CARLJ.GAU
Attorney at La
27 302 Bank of America Bldg
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAA 259 708
.J

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3·00314·8 W~\'f\, ~l~
and
10 Declaration of {j;,JJ ;i Urn z 9
Jennifer Rae Rife
12 I, , declare under penalty of perjury of the laws of the

state of Washington, that the following is true and correct.
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1. IDENTITY AND PURPOSE
/)htM~J-C2j
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I am, I make this declaration to
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CARLJ.GAUL )
Attorney at Law
1604 Hewitt Ave.
ORIGINAL Everett WA 98201
425 259-4147 FAX 259 7081
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rCOUHiY CLERK
2 SHOHOHISH CO. WASH.
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5
7 In re:
8 ANDREW SCOTT RIFE NO. 05-3-02755·1
9 Petitioner, DECLARATION OF VANESSA L. UHDEN

and
10
JENNIFER RAE RIFE
11 Respondent.
12

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Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
,•I(.
1•
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1
(I-'' -
2
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3·00314·8
and
10 Declaration of '\tf,u.s;<a. 1. IJIYIP/2
Jennifer Rae Rife
11 Respondent.
1--~~~~~~~~~~~~~~~~~~~~~~~~~~
12 I, rUAP'U,., Uhkll ,
J... declare under penalty of perjury of the laws of the
State of Washington, that the following is true and correct.
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1 am ~'04.- l. UN.u/ I make this declaration to
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Executed ')'}iol(JUA~~
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on0~l5 1,3J»J
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26 CARLl.GAUL
Attorney at Law
,
ORIGINAL 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 Ff>:/. 259 7081
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CL 11398400
PAM L. UAHIELS
2 COUNTY CLERK
SHOHOHISll CO. WASH.
3
5
7 In re:
8 ANDREW SCOTT RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF JEFFREY RIFE

and
10
JENNIFER RAE RIFE
11 Respondent.
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Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
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COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9
and
Petltlonec, NO. 05·3·00314-8 '-.(--,a:r~ ((;Q
10 Declaration of ~ 1·d1or«:
Jennifer Rae Rife
11 Respondent.
12 1, (t ~
._jeft .\Z ;{(__ ,
declare under penalty of perjury of the laws of the
state of washing on, that the following is true and correct.
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I am AtJclf< v....1<. b01fu ( 1 make this declaration to
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Executed at
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on 10- t-<o- o~
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26 t(.vu·f tl wA q 8<1 oI CARLJ.GAUL

Attorney at Law
27
R\G \\\ , \ \\ \ j\302 Bank of America Bldg.

f-\ L
0 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
i
I'm writing this declaration in regards to the wellbeing of Lauren Emily Rife.
Andrew Scott Rife is my brother. I could not ask for a more honest, loving, kinder
brother. I am proud to say that he is my brother. Andrew and I became very close when
my parents James and Wendy Rife divorced twelve years ago. No one knows him quite
as well as I do. Andy became a father of a precious little girl on September 25th 2004.
Her name is Lauren Emily Rife. I watched Andy form to be a great father. I have never
seen a father more loving to his child in all my life. Most of my friends have children
and that's why I can say that Andrew is a wonderful father. He does not hang out in the
taverns. He is home night after night with his child while Jennifer is out working or
drinking with her sister and parents. Andy and his family have been accused by Jennifer
of being "tea toddlers" no one in my family drinks at all. Sorry her family cannot say
the same. On the 25th of September Lauren celebrated her first birthday. Both families
were invited I did all of the cooking. My family spent the entire afternoon playing with
Lauren in the back yard. Her family and Jennifer sat on the back deck smoking cigarettes
and drinking beer and wine. On nwnerous occasions I have been called to Andrew and
Jennifer's home to help settle disputes. I have been wakened up by the telephone at all
hours of the night by Jennifer usually intoxicated. She is very irrational and you can't
seem to settle her down. The first time she lied and had my brother arrested for domestic
violence she called me around 3:30am. She had told me that Andy had been taken to jail
for hitting her. Her behavior and her statements were very strange that night the second
thing she said to me after she had said he was in jail was that she had problems with her
weight. I could not believe my ears I thought your husbands in jail and you are worried
about your weight. That is one of many examples of her behavior. My family was
having dinner at my aunt Kate's house while Jennifer was pregnant. She was starting to
show. My grandmother made a nice statement about her belly getting bigger and Jennifer
took so much offense to her statement she raised her fist and threatened to hit my
grandmother. Several people saw this. There was another incident when Andrew and
Jennifer had been in a fight and Andrew had brought Lauren over to my mother's house
to get her away from the wrath of Jennifer. My wife and I were at my mothers when
Andy and Lauren came. Lauren was clearly upset and Andy as well. Andy asked me to
call Jennifer and try to settle her down, I agreed and when I called her she was going
ballistic. She said "She was going to have all of us bastards arrested for kidnapping
Lauren" I told Jennifer no one had kidnapped her and she could come over and get
Lauren she refused her mother came instead. Her family refers to her as the Pitbull and
in your face Jennifer I wonder why. We all know how pitbulls behave.
Jennifer is a very cold person I have never seen her show affection to her daughter nor
have I ever seen her shed a tear when she had her husband arrested both times or in any
fight they had been into. I have been called to console her many times by my brother
after a fight to try and settle things down. Jennifer had tom apart an antique dining chair
in one of their fights and I spent all day one Sunday rebuilding the chair so it seemed like
the fight never happened. I can't count the number of times my brother has come over to
our house to get away from her. I have been told that she has had two other men arrested
for similar things, what a coincidence. Andy is a good man and a great father it would
be a shame ifthe courts keep this wonderful child away from him and his family. Your
Honor I could write for hours about Jennifer's behavior. I could only hope that you make
the right decision. Thank you.
FILED
21105 HOV I0 PH 2: 21
2
rAML. DANIELS
I1\\1\\1111\11 \\III\\\II\\\1111\1\11\11\\I11\\I11\11\\\I1\\1 COUNTY CLERK
CL 11392114 SNOHOMISH CO. WASH.
3
5
1 In re:
9 Petitioner, DECLARATION OF JILL MCKENZIE

and
IO
JENNIFER RAE RIFE
II Res ndent.
I2
I3 Please see attached.

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Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
l •'.
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./.: ·~'
•\ ..•

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05-3-00314-8
and
10 Declaration o~ ( \ fl/\'- I(~ Li-<
Jennifer Rae Rife
11 Respondent.
12 I, ~ ~ ?eclare under penalty of perjury of the laws of the
state of washing on, t a e allowing is true and correct.
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I am ~?/ #d~e I make this declaration to
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Executed at EY~?lJ· V<e- ,
on Oc~~ .,.,'5 / cl t!Jc?~
~&~~
Name-->
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26 CARLJ.GAUL
Attorney at Law
27 302 Bank of America Bldg. /
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
·'··(<'
'" -
Oct 25, 2005
To whom it may concern,

I am Jill Rife McKenzie, Andrew Rife' s first wife. During the time of our marriage I
never experienced any verbal or physical aggression against my person. I have always
known Andy to treat women, children and animals with kindness and respect. Although
I have never seen Andy with the baby or Jennifer, I cannot believe that Andy would act
in the way she has described in the material shown to me. Nothing of the nature
described ever happened between myself and Andy.
Sincerely,
Jill Rife Mc Kenzie
~~~
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FILED
ZUOS NOY I0 PH 2: 21
2
I-AM L. DANIELS
COUNTY CLERK
SNOHOMISH CO. WASH.
3
5
1 In re:
8 ANDREW scorr RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF
and EVELYN O. KRISCHANO
10
JENNIFER RAE RIFE
11 Respondent.
12

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Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
1
2
3
4

OUNTY OF SNOHOMISH
7
a In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3·00314·8
10
and
Declaration Of Q \ I ±fO td e R
11
Jennifer Rae Rife
Respondent. £"~ '1"' D. l<.r-t.,c..~-;:i
1
1--~~~~~~~--'-=.:;..;;.;.;..;..;;.;....;.'-L..~~~~~~~~~~~~~
12 "'1L.., I, cf>(Z;11
'.s.:- 1-I A"
o , declare under penalty of perjury of the laws of the
State of was mgton, that the following is true and correct.
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1 am · ~ft..t .tou4-= ~~ I make this declaration to
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16 -d· .. 2??J'~~- ']~.Lo,.,,,.,.~~
17 ~ _vb-JZ-ir cyrZ!"-="'£'-ud, q~ ~- Jk.. 4 ,
18 .~ CLJ-6/ ~ ~ <+'-~ ..h.u.;
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Lri?&?LJ -7,c..Q7 2?4-<c61
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Executed at c~i;t, ~u.J.~
Name->
on ~7 I~ L<. o"-YVJi DR V
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26 I o - J. & . o ~- . CARLJ.GAUL
Attomey at Law

Everett WA 98201 I
FILED
21!05 NOV I 0 PH 2: 21
2 ll/Pllffe!IP!llllll!IP!IPll/llP
CL11392113
PAl·I L. DANIELS
COUNTY CLERK
SNOHOMISH CO. IVASH.
3
5 T OF WASHINGTON
SUPERIOOR
6 COUNTY
FC~~~HOMISH
7 In re:
8 ANDREW SCOTT RIFE NO 05_3-02755-1
9 Petitioner, .
DECLARATION OF JANICE HAYHURST
and
10 JENNIFER RAE RIFE
11 Respondent.
12

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26 CARL J. GAU ~}._ \ I\
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Attorney at Lai
302 Bank of Ameri~ Bldy
\F (\t3\J.
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1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 7QJ3
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2 l
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4'·

OUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9
and
Petitioner, NO. 05-3-00314-8 I
U
. c..e
()..IA I
Hc...-.L.4.~t
T
10 Declaration of cpbi1 J, ON< t;

Jennifer Rae Rife
11 Respondent.
12 1~ ~I-I~(. H~~ur.sf-declare under penalty of perJurv of the laws of the
tate o as mgton, ha he following is true and correct.
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· IDENTITY AND PURPOSE
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1 am .Jl\l\Ji«. ~4k'hciY)± I make this declaration to
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Executed at
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25 -iG 1 L\eN Iflu.I \-~
26 ~~~ \3.-t/Rl ff.I. I C ,4- CARLl. GAUL
tf°3) I b Attorney at Law
1604 Hewitt Ave.
Everett WA 98201 I
I
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October 25, 2005
To Whom it may concern:
I have known Andy Rife since he was born. He was a wonderful boy and has
grown into a wonderful young man. I am especially impressed by what a loving
and caring father he is. He is a very proud father. He not only changes
Lauren's diapers, but he also bathesher, puts her to bed, but most of all
plays with her and makes her feel loved. There is no doubt the love is
reciprocated as Lauren's eyes light up whenever she looks at her Daddy.
They have a very special bond.
Thank you,
Janice Hawxhurst
---------------------------------
2ll05 NOV I0 PH 2: 21
PAM L. DANIELS
2 COUNTY CLERK
SNOHOMISH CO. WASH.
3
5
7 In re:
g ANDREW SCOTT RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF
and CANDACE KRISCHANO
IO
JENNIFER RAE RIFE
II Res ndent.
I2
I3 Please see attached.

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26 CARLJ. GAU
Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
•

COUNTY OF SNOHOMISH
7
s In re:
Andrew Scott Rife
9 Petitioner, NO. os-3-00314-8
and
10 Declaration of&"'da..u \(r~ '>.:.l..<1<..1AAJ
Jennifer Rae Rife
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1.
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make this declaration to
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Executed at
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26 0 CARL J. GAUL
27 RJ G/NA L 302 Sank ~tt;r:~rc:~f%;

1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
.
.' .
•
Fl LED
11
t~«tf!fINB
2ll05 NOV 10 PH 2: 2 I'
2
i !'AM L. DANIELS
COUNTY CLERK
SNOHOMISH CO. WASH.
3
5
1 In re:
9 Petitioner, DECLARATION OF STACIE RIFE

and
10
JENNIFER RAE RIFE
11 Res ndent.
12

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Attorney at La
1604 Hewitt Ave
Everett WA 9820
425 25~4147 FAX 259 708
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1005 C1 1 ..n 9·5S

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; OP.,! .IE.LS
· ~· ERK
2 l).;U-11'< -0 Wt>.S\t
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3

COUNTY OF SNOHOMISH
7
s In re:
Andrew Scott Rife
9
10
and
Petitioner, NO. 05-3-00314-8
Declaration of
sd. :")
'-<- l<,,1~
a~'±iot v /(_,
1
~(') .
Jennifer Rae Rife I
12 ~~~~~~~i:;a-r,:' declare under penalty of perJurv of the laws of the

e ollowing is true and correct.
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· IDENTITY AND PURPOSE
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I am ~ SJ (./fA Jtt- {(UJ . I make this declaration to
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Executed at
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26 v CARLJ. GAUL
(Q.;){p·0.5 Attorney at Law

Everett WA 98201
.
To whom it may concern:
I have known Andy, my brother in law for the last 8 years. He is a not only my brother in
law, he is a good friend, a good man, and exemplifies what every father should be. The
day that Lauren was born he was the happiest I have ever seen him. The way he held that
little baby and could not stop smiling, you could tell he was absolutely in love with her.
He is a loving, kind, caring, attentive, and gloating father (the list goes on)
Every time I have been around Andy, Jen, and Lauren as a family, it is Andy who
demonstrates what a parent is, not Jen. When she is fussy, it is Andy who cares for her;
gets her a bottle, holds her, makes her laugh, talks to her, plays with her. When Lauren
cries it is Andy that can calm her down, and it is Andy that she wants.
I have NOT ONCE seen Jennifer kiss Lauren and ifl had a penny for every time I have
seen Andy kiss her I would be a very wealthy person. Andy cannot seem to kiss and
adore her enough. I think I can count on 1 hand in the last year that I have seen Jennifer
hold Lauren, and if she does she is quick to give her up- (anyone that will take care of her
"burden" was fine with her-this is how I saw it) it wouldn't even matter if it's a complete
stranger. I have seen her give her baby to total strangers in a restaurant to hold and they
left her sight WITH the baby. (I am not parent, but I definitely saw something wrong with
that picture-most people would) She seemed more concerned with her cocktail than her
baby.
I have felt from the moment Jennifer had Lauren that there was something missing. From
what I have observed since her birth I never saw Jen bond with the baby like most
gloating mothers do. Seeing my close friends have children I know having a baby is
stressful, but there didn't seem to be a bond, a sense of keeping harm from her, a natural
nurturing with Jennifer and Lauren. I observed Andy being more conscientious of
Lauren's needs and acting more like a nurturing mother to Lauren than Jennifer did. It
worried me, and still worries me. After having a baby as precious as Lauren and for Jen
to NOT gloat over her and absolutely adore her like Andy does, baffles me.
Jennifer seems to be a very volatile person She takes offense to everything that is said to
her, conjures up paranoid stories about others, and is very unpredictable and displays
irresponsible behavior. From what I have observed in the past it has always been what is
good for Jen, not what is good for Lauren. I once witnessed Andy and Jennifer having a
conversation about setting up a college fund for Lauren (Andy's idea) and she was
against that because she expected someone else would fork out the money for college.
One night we were all at a family birthday party and Lauren was upset. Jennifer picked
her up and shook her and said "wah, wah wah", very irritated and annoyed that the baby
was crying. I have also witnessed on another occasion where Andy's 78 year old
grandmother mentioned she was getting further along in.her pregnancy and gaining
weight. Jen raised a closed fist at this 78 year old lady and threatened to give her a fat lip
and she was not joking. I have seen her intoxicated on a few occasion's in the presence of
Lauren leaving Andy to attend to her. (As he does regardless)
She has told Andy's family members including me, of her sister's behavior of giving her
children Benadryl to go to sleep so her sister could go out and party, yet she relies on her
sister to watch Lauren. What kind of responsible mother would do this?
She seems to be a very ungrateful, selfish, irresponsible, and pretentious person that has
only her best interest at heart. It seems the most important things to her are about money
and her image. The only thing she talks of is designer clothes, how much money other
people make and material possessions, not what is important in life like Lauren's best
interest. (Prime example keeping Lauren from seeing her Daddy)
Andy's family has been extremely gracious with Jennifer and has done nothing but try to
make her feel like she is part of the family from the time they met. (As they did me when
I married Andy's brother) But as much as we have all tried, nothing we have ever done
has been good enough for Jennifer. She is critical and _ostentatious.
Jennifer's parents seem to be very nice people, but Jennifer never had anything good to
say about them; as she never had anything good to say about anyone, including her sister.
She has always seemed to demonstrate negative behavior and seems extremely bitter
towards life and everyone in her life.
Since Andy and Jen's separation I have seen Andy almost everyday. And everyday that
goes by that he cannot see his little girl it tears him apart. It is so hard to see a father who
loves his little girl with all his heart and so willing to be a DAD, forced to be away from
her because of one person's selfishness. Jennifer, in my opinion is using Lauren for her
anger against Andy.
Andy is one of the best father's I have EVER seen. Most women only wish they could
have a father like him involved in their children's lives. The only person it is harming by
him being away from Lauren IS Lauren. I am sure if Lauren was able to talk she would
say how much she misses her Daddy!
Jt.is always a shame when a divorce happens where children are involved but it is even
more of a shame to keep a father from seeing his daughter. Especially when he loves her
more than life itself and anyone who saw him interact with her would know this to be
true.
Stacie Rife
,
f\LED
Zll05 NOV I 0 PM 2: 22
' llllllll llllll Ill lllll lllll lllll lllll lllll lllll lllll l l llll
CL 11398403 rAM L. OAHIELS
2 COUNTY CLERK
SNOHOMISH CO. WASH.
3
5
6 UNTY OF SNOHOMISH
1 In re:
8 · ANDREW SCOTT RIFE NO. 05-3-02755-1
9 Petitioner, DECLARATION OF LANCE UHDEN

and
10
JENNIFER RAE RIFE
II Respondent.
12

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26 CARL J. GAU~ ~
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Attorney at La
302 Bank of America Bldg
1604 Hewitt Ave
~
Everett WA 9820~
425 259-4147 FAX 259 708~
{\.
•
•·"' .
1
2

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. OS·3·00314·8
and
10 Declaration of ( a "'-c.e t )IA.d..e "-
Jennifer Rae Rife
11 Respondent.
1--~~~~~~~~~~'--~~-'-~~~~~~~~~~~~~~
12 I, L.<1ac.£ uyof.O , declare under penalty of perjury of the laws of the

state of wasnmgton, that the following is true and correct.
13
14
I am t.Anc E. !II/DE a I make this declaration to
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Executed at M~rz.ysvz1.-1.-r;. 1 .,,.A
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OcroBEJl. zs1 z.00£
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26 CARLJ.GAUL
Attorney at Law

Everett WA 98201
425 259-4147 FAX 259 7081
. '
•
•
October 25, 2005
RE: Andrew Rife
To Whom It May Concern:
This letter is to serve as a witness to Andrew Rife' s character and specifically his abilities
to parent. To support my credibility I feel it is important that you know a little bit about
myself My name is Lance Uhden, I am 32 years old and I have known Andrew since we
were babies. Our parents were close friends and I spent my entire childhood with Andrew
and his family. I have been married for 8 years and have 2 boys of my own, a 12 year old
and a 4 year old. My first son was born when I was only 20 years old; his mother and I
did not marry and I have had legal custody of him since he was 6 years old. Andrew's
interaction with my boys has always been very fun loving-he has always given me the
impression that he would be a great father. When Andrew and his wife gave birth to
Lauren you could tell that she meant the world to him. He was always very hands on and
willing to take care of her. There has NEVER been a time when I felt Andrew was a
threat to anyone, especially children. My wife and I have spent a lot of time with Andrew
since his separation from his wife and the impact of him not being with Lauren everyday
has been very upsetting to Andrew. I know he would be a positive influence to Lauren
and would always be attentive to her needs while in his care.
If there is anything else I can do to enable Andrew to have the rights to see his daughter
please call me @ 360 658-5478 or 425 508-1231.
Sincerely,
Lance Uhden
'\.•r ,,
f\LED
7.\lUS NO~ I 0 PK 2: 22
I Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
CL 11398399 ?AM L. Of>.H\ELS
2 couHT'< CLERK
SNOHOMISH CO. WASH.
3
5
7 In re:
ANDREW SCOTT RIFE
8 NO. 05 3 02755 1
Petitioner, DECLARATION OF KATE KRISCHANO
Respondent.
CARL J. GAU
Attorney at La
~( n
~
302 Bank of America Bldg
1604 Hewitt Ave
Everett WA 9820
425 259-4147 FAX 259 708
•
-
1

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3·00314·8K. 1
_ 1 ,, _
1
_
and l\,,~ "'""!.~\)
10 Declaration of IJ b-nonN e&?
Jennifer Rae Rife
11 Respondent.
12 1-;;.~~~/,).,~~~~({/,eclare under penalty of perjury of the laws of the
state o e o owing is true and correct.
13
1. IDENTIJ: PURPOSE
14
15
1 am lfbt&J Rr f'G- 15 /!rU.pr . 1 make this declaration to
16 2. "Sllltrll.6 Ht< y tJISSetl.VtffZutUs OE tbu?Jeeu.l lf-S

17 /le ~ll·
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Executed at I
2s on ) '-.oc, ;t.111Vfl?(_ AvG
U'vl">l~fr, {J)# 'f<tt?-1 I CARLJ.GAUL
26
Attomey at Law
Everett WA 98201 I
425 259-4147 FAX 259 7081
!
..
-- •
October 25, 2005
Andrew Rife is my nephew. He is a polite, kind. and responsible man. He is well

liked by everyone who meets him. He has many lifelong friends and I think
that says something about his character. I am proud to have him for a
nephew.
I have always been proud of Andrew, but he surpassed all of my

expectations when he became a father. He was instantly in love with Lauren
when she was born. I have never seen a prouder Dad. He is constantly kissing
her and hugging her and asking everyone, "Isn't she the most beautiful baby
you have ever seen?" When Lauren is in the room, she is his number one
priority.
He is a hands-on Dad. He bathes her, he dresses her, he feeds her, he puts

her to bed, but most importantly he showers her with love and affection. He
is always the parent that is down on the floor playing with Lauren. It is
obvious that she loves him, because the minute she hears his voice she is
looking for him. He is the one she always wants to go to.
Truthfully,
Kate Krischano
.
.••.
•
October 25, 2005
Jennifer Rife is a volatile personality. On two separate occasions at my

house she has gotten mad and her mother-in-law has had to talk her in
another room. On one occasion Jennifer raised her fist to my mother (a 78
year old woman) and asked how she would like to be punched, because she
mentioned that Jennifer had put on some weight. Jennifer was pregnant at
the time.
We were always told to be careful what we say around Jennifer, because she
would take things we said and use them against Andy. I think that Jennifer
is an abuser, because she was constantly trying to isolate Andy from his
family and friends. She has no friends. I think that says something about
her character.
Jennifer keeps Lauren clean, but I have never seen her kiss or hug Lauren. I
have never seen Jennifer get down on the floor and play with Lauren. When
given the choice of who to go to, I have always seen Lauren choose her Dad.
She had Lauren in the car and had been drinking when she drove to Andy's at
3:00 in the morning after she had agreed to stay at her mother's house that
night.
Truthfully,
Kate Krischano
Illlllll llllll Ill lllll lllll 111111111111111111111111111111111
CL 11398402
5
7 In re:
s ANDREW SCOTT RIFE NO. 05-3-02755·1
9 Petitioner, DECLARATION OF JOAN SWENDSEN

and
10
JENNIFER RAE RIFE
11 Res ndent.
12

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26 CARLJ.GAU
Attorney at La
1604 Hewitt Ave
Everett WA 9820
q2S 2S9-q1q7 FAX 259 708
I'
2
3
4

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05·3-00314·8
or:IO~ ~ ~ .J4A,cl&c:tV'
and
1o Jennifer Rae Rife
Declaration
12 I, 5 ~ {J ~«1~dec1are under penalty of perjury of the laws of the

tate of Was mg on, a e ollowlng is true and correct.
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1 am <)Olfk? S01e//Jd~ -e41. . I make this declaration to
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Executed at e;"tJQ re ffI tJtf.
on oc:f. ).:); d--<XJ,S-
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26 CARLJ. GAUL
Attomey at Law
OR\G\NAL 1604 Hewitt Ave.
Everett WA 98201
Oct. 25, 2005
To whom it may concern,

My name is Joan Swendsen and I was Andrew Rife's mother-in-law. During that time
he was living in my basement apartment with my daughter. I have never known him to
be physically abusive to my daughter or anyone in my household. Andy was always
polite, kind and considerate to me and my family. I still enjoy chatting with him when we
meet. I believe Andy to be an upstanding young man and do not believe he would
intentionally hurt any woman, animal or child.
Sincerely,
Joan Swendsen
. ~c ..i,"'::)\)_\c... \\-r1-o'\
q~c:V °'""""
1 F\LED
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?U05 NOV I 6 ~1'111: 3 I
'I
i'Afi L. OAHIELS
COlJHTY CLERK
I1111111111111Ill11111111111111111111111111111111111 Ill\ Ill\ sHOHOMISH CO. WASH.
CL 11282894
6
7
COUNTY OF SNOHOMISH
9
10
NO. 05-3-02755-1
11 ANDREWS. RIFE,
Petitioner, DECLARATION OF ATTORNEY FOR
12
and JENNIFER RIFE OPPOSING ENTRY OF
13 AN AMENDED TEMPO RAY ORDER ON
JENNIFER R. RIFE, SHORTENED TIME AND FOR BAD
14 FAITH SANCTIONS
Respondent.
15
Counsel for the Petitioner actions in demanding entry of an Amended Temporary
16
Order on shortened time are in bad faith. Commissioner Beadle heard this matter on
17
November I, 2005 and Temporary Orders were entered. Thos~ temporary orders set out
18
certain requirements for the wife and child to vacate the family home and return a vehicle
19
to the Petitioner. The temporary order also sets out mutual financial restraints and that
20
neither party will molest or disturb the peace of the other. There is also a full Domestic
21
Violence Protection ·Order against the husband on behalf of the wife.
22
The requirements set out in the temporary order have been met. Via
23
correspondence counsel have agreed on dates when the property would be exchanged.
24
These were all routine transactions in a family law matter, all matters that can be handled
25
without the expense and necessity of entering an Amended Temporary Order.
26
Yet, counsel for Petitioner has insisted that an Amended Temporary Order must
27
be issued to, "establish Mr. Rife's possession of his separate property items." This is
28
simply not true. His possession of his separate property items is established in the
29
original temporary order and by correspondence between counsel. There is no d·;spute.
30
DECLARATION OF A rf'ORNE\'
OPPOSING [:\'TR\' OF Dyer & Primont
AMENDED TEMPOR,\ \'ORDER 503 Twelfth Ave. E
ON SHORTENED Tl~IE AND FOR Seattle, WA 98102
BAD FAITH SANCTIONS (206) 343-15ef·
Pagt I
9f-/;
1 More importantly, counsel did not bring a motion on normal notice; he obtained
2 an order to shorten time to have his unnecessary motion for an amended temporary order
3 entered. There is no emergency here. There is no disagreement.
4 The real bad faith here however, is that the Amended Temporary Order that
5 counsel for petitioner is proposing adds restraints not ordered by Commissioner Beadle.
6 In the original order both parties were restrained from molesting or disturbing the peace
7 of either party. This proposed amended order adds that both parties are restrained from
8 going onto the grounds or of entering the home, work place or school of the other party.
9 That provision is not agreed to nor was it ordered in the Temporary Orders. It is simply
10 something that counsel for Petitioner has inserted and is urging the court to sign.
11 The DV Protection Order prohibits Mr. Rife from coming near or contacting the
12 Jennifer Rife. Counsel for Mr. Rife is attempting to insert restraining orders against her
13 that were requested by him at the original hearing but that were flatly denied by the court.
14 This is bad faith. I would imagine that counsel for petitioner will say that this was just a
15 mistake. We do not believe it was.

This is a very serious domestic violence case. Mr. Rife has been arrested twice in
16
the last seven months for domestic violence offenses against Ms. Rife. The court reserved
17
on the issue of restrictions in the parenting plan until a GAL could make an interim report
18
but the court made a clear finding that there was substantial evidence of the husband's
19
domestic violence. The court entered a DV Protection Order on behalf of the wife and
20
ordered the father to have supervised visitation only pending the interim report.
21
The father's whole case was an attempt to blame the victim and to assert that he
22
needed restraints against her. The court was not convinced and made a point of entering
23
the wife's protection order. The court agreed that neither party should molest or disturb
24
the peace of the other party, but the court certainly never even hinted that the wife should
25
be restrained in any other way.
26
When the father could not convince the court to blame his victim, he did not
27
request that the order be revised or reconsidered. Instead he is attempting to shove an
28
unnecessary "Amended Temporary Order" down our throats on shortened time. An
29
30
DECLARATION OF ArroRNE\'
OPPOSING ENTRY OF Dyer & Primonl
AMENDED TEMPOR,\ \'ORDER 503 Twelfth Ave. £
ON SHORTENED TIME AND FOR
,~ L
Seattle, lVA 98102
BAD FAITH SANCTIONS (206) 343-1528
Page 2
n10''
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,r ·•
1-.c ,.,,. ... ; \
l \ \ """'-"" I l
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1 amended temporary order that issues previously denied restraints against the victim of his
2 client's domestic violence. This is nothing but bad faith.
3 There is no disagreement about the terms of the original order and no need for an
4 amended order. This motion on shortened time was brought solely to harass the victim
5 and to cause a needless increase in the cost of litigation.
6 We are requesting that the motion be dismissed and terms and sanctions issue in
7 the amount of $1,400.00 to be paid within 5 days. It should be noted here that Mr. Rife
8 stood in court and swore that he had no money and could not afford to pay Ms. Rife any
9 money, even though he had taken all of the funds in their joint account (approximately
10 $7,500). The court ordered that he had to pay Ms. Rife certain sums before she had to
11 move out of the family home or return the vehicle. Although he claimed in court he
12 could not pay, the full amount was miraculously delivered to this counsel's office within
13 a week of the hearing.
15 foregoing is true and correct. Signed and dated this 16th day of November 2005 in Seattle
Washington.
16
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20
21
22 I am the Respondent named above. I have reviewed the above declaration of my
attorney. The facts contained therein are based on my personal knowledge and are true
23 and correct. I declare under penalty of perjury of the law of the State of Washington.
24 Signed this \S"""~ day of November 2005 in Se~ , Washington.
25
26
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DEC LARA TIO:-; OF,\ rroR:-;EY
OPPOSl:-;G E:-;TRY OF Dyer & Primont
A~IE:-;DED TEMPOR,\ \'ORDER 503 Twelfth Ave. E
o:-; SHORTE:-;ED Tl~IE A:-;D FOR Seattle, WA 98102
BAD FAITH SA:SCTIO~S (206) 343-1528
Pagt 3
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2 CL11199725 , .g~~~~i co. w~sH.
~> \"1
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO.. 05·3·02755-1
and
10 REPLY DECLARATION OF
Jennifer Rae Rife ANDREW SCOTT RIFE
11 Respondent.
I, ANDREW SCOTT RIFE, declare under penalty of perjury of the laws of the State of
ashington, that the following is true and correct.
IDENTITY AND PURPOSE
I am the Petitioner in this matter. I make this declaration to Reply to my estranged wife's
declaration.
SUMMARY OF RESPONSE
I am not a violent person, and I explain the incidents leading to my arrest below. I have
learned that my wife is chemically dependent, which I did not know when I met and married
her. We have a daughter, who should be residing with me as much as possible. My
separate property home and car should be restored to me.
CHEMICAL DEPENDENCY
Edgewood is an addiction treatment center at Nanaimo BC. It uses the 12-step model of
recovery.
Edgewood states as its goal "The objectives of the treatment process at EDGEWOOD
are abstinence from mood-altering behaviours or chemicals and an improved life
style."
My wife's responding declaration does not acknowledge any addiction. Jennifer's Edgewood
treatment was just the inpatient phase. Graduates also need ongoing treatment, or
aftercare. I met her in April 2003, just a couple of months after she graduated from
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
REPLY DECLARATION OF Everett WA 98201
ANDREW SCOTT RIFE 425 259-4147 FAX 259 7081
1 Edgewood. In thirty months I have known her, Jennifer has not attended even one single
meeting of a 12 step organization. She has never once made a comment that she was
2 grateful to have her sobriety, not even at Thanksgiving. She completed in-patient
treatment, then stopped.
3
My wife spent 60 days at Edgewood. Edgewood would not have let her spend even one day
4 there if she had not qualified for their services.
5 Edgewood states "Unique to EDGEWOOD, the length of stay is determined solely

by the individual's progress. Treatment is individualized to meet our patients'
6 specifc needs giving them the best chance of recovery."
7 Addictions are incurable. Consequently, her drug and alcohol history during the last 30
months are a long relapse. Her refusal to acknowledge her relapse is a part of the problem,
8 and heightens the risk to our daughter.
9 I never had the experience of being involved with an addicted person until Jennifer. Drug
and Alcohol Abuse do not exist within my family. So, when Jennifer told me that her
10 parents overreacted to send her there I found her story credible. If we had a couple of
drinks with dinner it did not seem like a big deal. But over time it did become a big deal.
11 By the summer of 2005 she was drinking nearly daily. Her outbursts of physical aggression
had become uncontrollable. And her pattern of staying up late, and getting up late were
12 inattentive to our daughter. I asked her to discontinue drinking, and volunteered to do the
same myself. She refused. She told me that she had the right to have a drink whenever
13 she wanted. She was more than adamant about it, and we had one of our loud
disagreements. The incident on the Friday before my arrest was about her having a drink
14 and me not.
15 3. DOMESTIC VIOLENCE
16 FACTS
17 Jennifer and I have a horrible relationship. It has been punctuated by loud arguments. In
those arguments we have said horrible things to each other. She has called me a "fuck
18 face," a "cocksucker" told me to "fuck your mother," and also to "fuck Stacie (my brother's
wife)", and told me to "lick your father's balls." I acknowledge reciprocating, saying terrible
19 things to her. The words are probably most useful in understanding the intensity of the
disagreements. They are probably not particularly useful in trying to assess blame or
20 determine that one of us was more culpable than the other in the causation of the incidents.
21 I was arrested for a domestic violence assault. The police report states that it is being
referred to the city prosecutor for consideration of filing an assault charge against Jennifer.
22 I do not know the status of that issue. When I was released I stayed at my father's home.
A few days later, Jennifer and I met at the Municipal Court and jointly requested the no-
23 contact order be terminated. The court granted the request and I returned home. I was
involved in a program. Later, without notice to me, the prosecutor obtained a new ex-parte
24 no contact order, erroneously believing I had discontinued treatment. Jennifer and I
continued to live together, thinking that the prosecutor would get notice that I was still in
25 treatment and vacate the no contact order. That was an error.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
ANDREW scan RIFE 425 259-4147 FAX 259 7081
------------ ------
1 The second incident began when Jennifer, our daughter Lauren and I went to dinner at El
Paraiso restaurant. Jennifer had a large Margarita. We had a disagreement at the
2 restaurant over me not drinking. We left the restaurant after about ten minutes, at my
insistence, because she had loudly called me a "teetotaling a**hole" and I could see that
3 she was not going to become calm any time soon. When we got home the disagreement
continued. She continued to be upset that I would not have a drink. We were hardly in the
4 door when she said she was tired of me getting one up on her, having a stick up my a**
and being a teetotaler like the rest of my family. At the time Lauren was in my arms. I
5 don't know what I said that caused her to become more agitated and violent, but she
suddenly pushed me twice (with Lauren still in my arms) and Lauren started to cry. At that
6 point I said Oh my God, What are you doing? And she continued to rage. I set Lauren in
the crib in her room so she would not see more of this. I stayed with her a while to calm
7 her also hoping that Jennifer would calm herself too. Lauren calmed a bit and I left her,
hoping she would fall asleep soon. When I came out of Lauren's room Jennifer told me
8 (epithets omitted) that she was leaving and I could stay with our daughter. I told her if she
wanted to leave, at least Lauren would not see more of us fighting, and that I would stay
9 home with her. At that point she threw the cordless phone at me. She left for about an
hour and a half. I asked my brother and my mother to come over while Lauren slept. I
10 went to my father's home for the night, anticipating that Jennifer and I would not be
fighting. Jennifer came home about an hour later and my brother and mother left. The
11 next morning (Saturday), my mother got a call from Jennifer saying that she was taking
some things and leaving. To my knowledge she had left the home, not intending to return.
12 But that evening when I was visiting my brother at his house, I got another call from my
mother stating that Jennifer was sick and would like to come home. I said she should not
13 return, perhaps staying at her parents home. I went home that night and went to bed. At
about 3:30 the next morning the doorbell rang, and there was Jennifer with Lauren.
14 Jennifer had been drinking. She said "I hope you're happy, you bastard. I'm sick, the baby
is sick and you're sleeping." I said that if the baby is sick, we should get her inside. So
15 Jennifer and I proceeded to change her, put fresh clothes on her and get her to bed.
Before we could even get Jennifer into her crib, Jennifer started to argue again about
16 nothing. Again, while I was holding Lauren, she kicked me in the right shin, pushed me and
punched me on the right side of my face. At that point she grabbed the phone, looked at
17 me and pressed 911 and hung up. The operator called back to ask me what had been
happening, and I told her that I had been assaulted and to send an officer. At that point
18 Jennifer ran out of the house. I locked the door.
19 The officer arrived, and we both told him our respective stories. He did not write any
assault citations. Instead, he arrested me for violation of a no-contact order.
20
Legal Proceedings
21
For the assault charge, the prosecutor offered me a Stay of Proceedings. As a condition of
22 the stay of proceedings I am to remain in treatment with a state certified therapist. My
therapist is Charles Devore. I see him every Friday at noon.
23
When the Violation of Restraining Order action came up for arraignment, the prosecutor
24 offered to have the case resolved by including it in the same stay of proceedings, again
requiring exactly the same treatment.
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
NDREW SCOTT RIFE 425 259-4147 FAX 259 7081
1 The city prosecutor recognized Jennifer's complicity in the events forming the basis of the
criminal prosecutions.
2
Even since the second arrest, Jennifer has continued to contact me by telephone and has
3 even sent me a love letter, copy attached.
4 4. PARENTING ISSUES
5 I have a great relationship with our daughter. Jennifer does not really challenge the things
I have said. She just says that I am a terrible abusive person. She does not claim to have
6 done a single thing with our daughter.
7 I want the court to consider the active, "hands-on" things I described in my prior
declaration. I also want the court to consider the declarations I am submitting along with
8 this declaration.
9 I anticipate that the court will require me to remain involved with Charles DeVore. I do not
think it is appropriate for Ms. Dyer to try to dictate where I seek therapy for my problems.
10 Though the statement is signed by Jennifer, she could not know the things she has to say
about programs available in. King County. That information certainly came from Ms. Dyer.
11
5. PROPERTY ISSUES
12
When I found myself banned from my own home I did empty $7500 from my savings
13 account, which Jennifer erroneously describes as a checking account. I had established the
account before the marriage. It had $15,000 at the time we were married. Tnen money
14 got spent. At the time I emptied it, only $7500 remained. I am not aware that Jennifer ever
put any money into that account. I allowed her name to be added to the account only a
15 month ago. I needed to find shelter for myself and hire an attorney. I used my separate
property funds.
16
I did not empty any other account than my savings account. She has attached a September
17 30 statement for our joint accounts. But Jennifer had a separate operating account at the
PUD credit union. She did not provide a statement for her operating checking account.
18 Since separation she has closed the old operating checking account and opened a new one.
I have no details about it, but I know of it because when I make my deposit the teller's
19 have a new account number. She has not revealed the money she has.
20 The house and the car should be returned to me. My wife is a mobile notary. She claims
a gross income of $2798 per month. This results in a net income of $2133. She is saying
21 she will pay for the car and the mortgage, but she lacks the cash to do it. The car and the
mortgage total $1454. She would have less than $700 left for all other expenses, including
22 her business expenses.
23 I get a regular paycheck of $2019 exactly as my gross income twice per month. It is as
regular and predictable as can be. The last two checks I have made deposits of $200 into
24 Jennifer's checking account. I did not know what child support might be, so I guessed.
Perhaps this money could help her find more economical transportation.
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
1
2
She may need a car to go to her customers, but she does not need a $527 per month white
3 BMW. My wife does not have the money to pay for a $927 monthly mortgage payment.
5
Executed at Everett WA ~~rr-<2~ 0.,..
on October 26, 2005 ANDREW SCOTI RIFE
6
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CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
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From: Carl Gaul 425 259 7081 To: Carl Gaul Date: 10/2612005 Time: 2:51 :14 PM Page2of11
" EPGEWOOD Philosophy Page I of I
I believed that because I grew up in a healthy

00
-:w,W'\"~·
environrnent, and because I came fro1n a
successful fa111ily of scientists and doctors, iffliill)
The successful treatment of addiction depends on a philosophy of
and because 'everybody does this anyways,· I
treatment that is based on a holistic view of the individual as capable of
was just experiencing a silty 'youth phase,· self-correction. At EDGEWOOD we understand that addiction Is an lllnes·
and I'd outgrow it. but it is an illness that is predictable and treatable.
Using a 12 Step framework, our treatment programs are lndlvidualfzed

and paced at a level each individual responds to best. Our patients are
accorded the respect and dignity that all individuals suffering with an·
illness deserve.
We are here to help our patients regain the life that was lost when they
Most true happiness comes fro1n one's inner started down the road of addiction.
life, fro1n the disposition of the mind and
soul. Adrnittedly, a good inner life is difficult
to achieve, especially in these trying times. !t
takes reflection and conteinplation and self· !'
discipline.
··\Villia111 L. Shirer-·
Famtty Education
10/30/2005 9:00AM ·EDGEWOOD
Family Education Day is offered to friends and

family me1nbe~ of our residential patients.
This 3 hour educational seminar provides
infonnation about the nature of addictions
and the recovery process. There is no cost for
this progra rn.
~t~~:;;:;;;;;,,,"'"'~-_;:;:2f:::;;,'..MC.P,i',#'i1
21ll P.:ir.vood !lood l!a113iloo. BC r.!rtllla V9S 4l1 info@edge: VO-Od ca I 1-000-68').()
- ... 2511-751-0111!tell .2fil.751-ll:i!lf:u! . . . -- . - ... . .. ' "-···. "
Cof!¥rioht © 2!l04 Edgawll!ld ~I ri9h11 relaivad -Vernion 2.0 - Minimim """"" ra:mlu!ion of 800.SOO and bm""''"" 4.0 and abow "" raquierad.
Dooigned ~f l~~nd lntsmat lno.
http://www.edgewood.bc.ca/aboutus_philosophy.asp 10/26/2005
l
From: Carl Gaul 425 259 7081 To: Carl Gaul Date: 10/2612005 Time: 2:51:14 PM Page6of11
Page I of I
I believed that because I grew up in a healthy

environ1nent, and because I came fro1n a
successful fan1ily of scientists and doctors,
and because 'everybody does this anyways; I
was just experiencing a silly 'youth phase,'
EDGEWOOO's Inpatient Program ls intense - seven days a week from 12-1

hours a day. It consists of group therapy, lectures, Individual counselin&
psychological evaluations, peer and self-assessments, as well as
conferences with family and referral sources. Fundamentals of the 12
Steps are incorporated throughout our program.
Unique to EDGEWOOD, the length of stay is determined solely by the

individual's progress. Treatment is Individualized to meet our patients'
specific needs giving them the best chance of recovery.
Treatment Process
--Willia1n L. Shirer-- The objectives of the treatment process at EDGEWOOD are abstinence
from mood -altering behaviours or chemicals and an improved lifestyle.
Short-term goals:
1. Help the patient recognize the disease and its implications.

2. Help the patient admit they need help and that they are able to
Family Education cope with the disease.
10/30/2005 9:00AM ·EDGEWOOD 3. Help the patient identify what they need to change in order to
live with the disease.
4. Help the patient translate the understanding into action; this is,
Family Education Day is offered to friends and to initiate the change.
family me1nbers of our residential patients.
This 3 hour educational seminar provides
inforrnation about the nature of addictions
and the recovery process. There is no cost for
this program.
21ll e.;r.wod Eood Na113il00, Br. r.inada vss 4l2 info@edge' vood ca I 1-800-693-0
. . . __25{).751-0111ltell .Zb-151.V!!!lfa.<!. . . . .. . .. . .. ' . -· ........ .
Copyright© 2IJOI Edge-Hood All right> re!ervad . Version 2.il - Minimun i;crsan rasalution of800r.JOO and bmY.'' "' 4.fi and above ara requ'ersd.
09!ignod e., !xlanrl lrrroomt tnc.
http://www.edgewood.bc.ca/programs_inpatient.asp 1012612005
6
14 Name of person(s) restrained: Andrew Scott Rife, Jennifer Rae Rife.
Name of person(s)protected: Andrew Scott Rife, Jennifer Rae Rife. See paragraph 3.1.
15 !--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
16 llIOLATION OF A RESTRAINING ORDER IN PARAGRAPH 3.1 WITH ACTUAL NOTICE OF

'-s\ ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.so' RCW AND WILL SUBJECT
r:) 17 ~·~·H=E~VI-=-=-O=LA~T~O~R~T~O~A~R~R=E=ST~·~R=C~W~2~6~·~09~·=0~6~0·:__~~~~~~~~~~~~~~
~ 18 1.2 MONEY JUDGMENT SUMMARY:
-sf: 19 Does not apply.

II. BASIS
20
II. motion for a temporary order was presented to this court and the court finds reasonable
21 cause to issue the order.
22 III. ORDER
23 It is ORDERED that:
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
AMENDED TEMP ORDER (TMO) - Page 1 Everett WA 98201
WPF DR 04.0250 (912001) - RCW 26.09.060; .110; .120; .194 425 259-4147 FAX 259 7081
1 RESTRAINING ORDER:
3.1
2 VIOLATION OF A RESTRAINING ORDER IN PARAGRAPH 3.1 WITH ACTUAL NOTICE OF ITS
TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.SO RCW AND WILL SUBJECT THE
3 VIOLATOR TO ARREST. RCW 26.09.060
Each of the parties is restrained and enjoined from molesting or disturbing the peace of
4 the other party or of any child.
5 The husband and the wife are each restrained and enjoined from going onto the grounds
of or entering the home, work place or school of the other party.
6
Husband's home is: 2416 - Fifth Street
7 Everett WA 98201
Husband's workplace is: Snohomish County PUD No. 1
8
2320 California St.
Everett WA 98201
9 Wife's home is:
Wife's workplace is:
10
11
CLERK'S ACTION/LAW ENFORCEMENT ACTION:
12 This order shall be filed forthwith in the clerk's office and entered of record. The clerk of
the court shall forward a copy of this order on or before the next judicial day to
13 Everett Police Department which shall forthwith enter this order into any
computer-based criminal intelligence system available in this state used by law
14 enforcement agencies to list outstanding warrants. (A law enforcement
information sheet must be completed by the party or the paiTt's attorney
15 and provided with this order before this order will be entered into the law
enforcement computer system.)
16 EXPIRATION DATE:
This restraining order will expire in 12 months and shall be removed from any
17 computer-based criminal intelligence system available in this state used by law
enforcement agencies to list outstanding warrants, unless a new order is issued, or
18 unless the court sets forth another expiration date here:
_ _ _ _ _ _ _ _ _ _ _ _ _ _{month/day/year).
19
20 3.2 TEMPORARY RELIEF.
21 Child support shall be paid in accordance with the order of child support, signed by the court.
22 Each of the parties is restrained and enjoined from transferring, removing, encumbering,
concealing or in any way disposing of any property except in the usual course of
23 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.
24 Each of the parties is restrained and enjoined from removing any of the children from the
state of Washington.
25
Each of the parties is restrained and enjoined from assigning, transferring, borrowing, lapsing,
26
CARLJ.GAUL
Attorney at Law
AMENDED TEMP ORDER (TMO) - Page 2
1604 Hewitt Ave.
Everett WA 98201
WPF DR 04.0250 (912001)- RCW 26.09.060; .110; .120; .194 425 259-4147 FAX 259 7081
•
. ,.
1 surrendering or changing entitlement of any insurance policies of either or both parties

whether medical, health, life or auto insurance.
2
Each party shall be immediately responsible for their own future debts whether incurred by
3 credit card or loan, security interest or mortgage.
Commencing at Noon on November 19, 2005, the family home located at 2416 - Fifth Street,
4 Everett WA 98201 shall be occupied by the husband and he shall be responsible to
make the monthly mortgage payments on it.
5
Use of property shall be as follows: Commencing at Noon on December 5, 20051 husband
6 shall have the temporary use and possession of the 2004 BMW 325i, ano he shall be
responsible to make the monthly payments on it.
7
8 The wife shall vacate the family home.
9 [] Other:
10
11 3.3 BOND OR SECURITY.

12 The filing of a bond or the posting of security is waived.
13
14 3.4 OTHER:
NOV 1 7 2005 g::;,, /u
15
Dated:
16 udge I Commissioner
/'.)
u
17 Presented b ;,
18
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20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
AMENDED TEMP ORDER (TMO) - Page 3 Everett WA 98201
WPF DR 04.0250 (912001) -RCW 26.09.060; .110; .120; .194 425 259-4147 FAX 259 7081
! I~ ED
r.".
t
:.. : fiJV I 7 Pti 3: 2 7

SUPERIOR COURT OF ~/\li L. Ut. . rJ:ELS
WASHINGTON COUNTY CLERK
oPrnHOHISH CO. 'ri :. SH.

AND CLERK: HEATHER HOTTINGER
JENNIFER RIFE DATE: 11/17/05 @ 9:00 AM
THIS MATTER CAME ON FOR: MOTION FOR AMENDED TEMPORARY ORDER

CONTINUED/HEARING DATE SET AND CALENDAR/CONTINUANCE CODE:
ACTION:
PETITIONER APPEARED: NO COUNSEL: CARL GAUL I I I

RESPONDENT APPEARED: NO COUNSEL: JAN DYER
DOCUMENTS FILED:
ORDERS ENTERED: AMENDED TEMPORARY ORDER, TO BE FILED BY COUNSEL DYER.
THE COURT FINDS IT APPROPRIATE TO ENTER A MUTUAL RESTRAINING ORDER

PREVENTING BOTH PARTIES FROM BEING AT ONE ANOTHER'S RESIDENCE. THE COURT DOES
NOT FIND THE MOTION TO BE IN BAD FAITH AND FINDS IT APPROPRIATE TO MODIFY THE
TEMPORARY ORDER UNDER THIS CAUSE OF ACTION AND UNDER THE PARTIES' COMPANION
DOMESTIC VIOLENCE ACTION, UNDER CAUSE NUMBER 05-2-01268-2.
PETITIONER IS TO HAVE USE OF THE FORMER FAMILY HOME AFTER NOON ON
NOVEMBER 19, 2005.
SEE MODIFIED PROTECTION ORDER ENTERED UNDER CAUSE NUMBER
05-2-01268-2.

FILED
:,:J NOV I 0 PH 4: 0 I
1
Pi\M L. Df,NJELS
2 , ,~OlJNTYCLERK
->H,JtiOMISH CO. •r; .'.SH.
3
4
I lllllll llllll Ill lllll lllll 111111111111111111111111111111111
5 CL 11003065

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05 3 02755 1
and
10 Motion for
Jennifer Rae Rife Amended Temporary Order
12
comes now Andrew Scott Rife, Petitioner above named, and moves this court
13 to enter an Order granting the relief requested in Part I below:
14 I. Relief Requested
Andrew Scott Rife moves this court to enter an Amended Temporary Order.
15
11. statement of crounds
16 The house and car now in wife's possession are scheduled to be returned to
him. An Amended Temporary Order is needed to assure that the orders and the
17 situation are consistent.
18 Ill. Evidence Relied Upon

Facts stated in motion and declaration for ord shortening time.
19 7
20
Dated: November 10, 2005
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
FILED
l-J .'\QIJ I 0 PH 4: OI
PCH! L. D .~ /i/C:l s
. OUNn· c1 "RK
2 SNOH0/1/Sf/ co'\:;.~ SH.
Illlllll llllll Ill lllll lllll lllll lllll l l l lllll lllll llll llll
3 CL 11003064
4
6
In re:
7 Andrew Scott Rife
Petitioner, NO. 05·3·02755·1
8 and
MOTION FOR ORDER SHORTENING TIME
9 Jennifer Rae Rife
Respondent.
IO
COMES NOW Andrew Scott Rife and moves the Court for ym OJ;qer shortening time to
11
schedule hearing on Motion for Amended Temporary Order on l{rj7.(f>
12 support hereof, Andrew Scott Rife relies upon the affida'l·t1subjoil).e'd her . /
at 9:00 a.m. In 7
Dated: November 10, 2005 b /I_., ··
13 CARL J. GAUL WS 8341
Attorney for Andr w ott Rife
14
15
DECLARATION
16
I, Carl J. Gaul, declare under penalty of perjury of the laws of the State of Washington, that
the following is true and correct.
17
1. IDENTTIY AND PURPOSE
18
I am attorney for Andrew Rife. I make this declaration to in support of Andrew Scott Rife's
19
motion for an order shortening time.
20 2 · BASIS
21
At prior hearing Commissioner Bedle entered an order leaving wife in possession of Mr.
Rife's separate property real estate and automobile, but ordering possession to change after
22 Mr. Rife had paid sums of money to facilitate her change of residence and change of
vehicle. Those sums have now been paid.
23
A new temporary order is needed to establish Mr. Rife's possession of his separate property
24 items. The wife's attorney has agreed to dates for change of possession of the house and
the car. Possession of the house is to transfer at noon on Saturday, November 19, 2005.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 9820 l
425 259-4147 FAX 259 7081
Wife's attorney did not, however, make any response about the amended temporary order,
either to agree or disagree to its terms. A hearing should be scheduled to present an
2 amended temporary order. )
3 Executed at Everett WA
on November 10, 2005 CAR J.GAUL
4
IO
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 9820 I
425 259-4147 FAX 259 7081
FILED
u:i ~rnv 10 PM 1;: 01
"'~ML. DANIELS
2 COUNTY CLER~
SNOHOMISH CO. r! f, SH.
Illlllll llllll Ill lllll ll/1111111111111111/ lllll lllll 11111111
3 CL11003063
4
6
In re:
7 Andrew Scott Rife
Petitioner, NO. 05·3-02755-1
8 and
ORDER SHORTENING TIME
9 Jennifer Rae Rife
Respondent.
lO
This matter having come on before the court on the ex parte application of Andrew Scott
11 Rife for an order shortening time for hearing on \\ )q I •r , and the court having considered
the motion and declaration for an order shortening time and the other the records and files herein
12 and being sufficiently advised in the premises, now therefore
13 It is hereby ordered
14 1. Petitioner's motion for amended temporary order shall be heard on the

Commissioner's Domestic Motions Calendar on (\J ..... ~~.v 17 i 00.f' at 9:00 a.m.
'
15
Dated: NOV 1 0 2005
16 :mc!ge I Commissioner
r
17 Presented by:
18
19
~
CARL J. GAUL W B.4.# 8341
20 Attorney for An rew\s · ott Rife
21
22
23
24 ~\
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 9820 l
425 259-4147 FAX 259 7081
'• 1
F\LED
7\\GS NO'I 23 Ii.I'\ IQ: 22
P.h. oMHELS
I11111111111111111111111111111111111111111 ll\111\lll Ill\ Ill\ rcouN°tY CLERK
CL 11284569 .sNOHOH\SH CO. W~SH.
5
6
7
In Re the Marriage of:
8
Andrew Scott Rife, No. 05 3 02755 1
9 Petitioner
and CALENDAR NOTE
10 (COMMISSIONER S
1
DOMESTIC
Jennifer Rae Rife MOTION C::ALENOAR)
11 Respondent
12 TO: CLERK OF THE COURT
AND TO: Jan Dyer, attorney for Jennifer Rae Rife
13
14 FAMILY LAW / DOMESTIC Date: December 6, 2005

CAL EN DAR- (Except matters relabng to Daily at 9 a.m.
15 trial dates, continuances, and revisions) Nature of Hearing:
Presentation of ORDER DENYING
16 Court Commissioner MOTION FOR BAD FAITH SANCTIONS
Department B or C, As Assigned
17 Matters set before a Court Commissioner will be assigned later to a particular department. The assignment
will be posted the day of the hearing. Extended motions are set by the Court Commissioner, not a party or
18
counsel. If a presentation, or if a particular Court Commissioner has already hard a recent motion on the
matter, please indicate Court Commissioner COMMISSIONER BEDLE
19
WARNING: The moving party MUST CONFIRM by noon two (2) court days prior to the hearing in order
20 for the matter to be argued. Failure to notify the Court of a continuance or strike may result in sanctions
and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for tr' I settings. SCLMAR 2.1 40(b).
21
22
23
24
25
26
27
28
CALENDAR NOTE
CARLJ.GAUL
Allorney al low
~~
~
Everett WA 98201
1
(COMMISBIONER 5 DOMESTIC MOTION CALENDAR) (425) 259-4147 Fax 259-7081
l
·.

COUNTY OF SNOHOMISH
7
s In re:
Andrew Scott Rife
9 Petitioner, l'fQ. 05 3 02755 1 , L7 D >_ / 7
and .l-'K'o f'os- 60 0 /<.... c• '-
10 ORDER DENYING
Jennifer Rae Rife MOTION FOR BAD FAITH SANCTIONS
12 THIS MATIER having come on regularly before the court upon the
Respondent's motion for an award of bad faith sanctions in response to the
13 Petitioner's motion for entry of an amended temporary order, and the court having
considered the records and files herein and the arguments of counsel, and the court
14 being fully advised in the premises, now therefore
15 IT IS HEREBY ORDERED
16 Respondent's motion for an award of sanctions against Petitioner for bad
faith is hereby denied.
17
Judge I comm1ss1oner
Copy Received:
JAN DYER WSBA# 20355

Attorney for Jennifer Rife
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1
2 2ll05 OEC -2 PM ti: 30
3
Illlllll llllll Ill lllll lllll l l l lllll lllll lllll lllll llll llll
CL 11300282 l .L.i·\ L. OAHIELS
4 COUNTY CLERK
SUPERIOR COURT OF WASHINGTON SHDHOHISH CO. WASH.
7
8 Petitioner,
and SUPPLEMENTAL DECLARATION
9 OF JENNIER RIFE IN SUPPORT OF
10 HER REQUEST FOR A DOMESTIC
JENNIFER R. RIFE,
VIOLENCE PROTECTION ORDER
11 Respondent. AND LIMIT ATIO NS IN
TEMPORARY PARENTING PLAN
12
13
The court reserved final determination on my request for a Protection Order and
14
15 on the issue of a Temporary Parenting Plan. The court appointed a GAL for our daughter
16 and asked that an interim report be issued. A review date was set for December 6, 2005.
17
The following information is offered as an addendum to the declaration supplied with my
18
19 petition.
20 PATTERN OF DOMESTIC VIOLENCE

21
Andy Rife has physically assaulted me on several recent occasions. One assault
22
resulted in his arrest. There were others that I was too ashamed to come forward about.
23
24 During 2003/04 his violence was primarily directed at property. He broke out a window
25
with a ladder, prompting our neighbors to call the police. He punched his hand through a
26
wall in our house. Shortly after our daughter was born (9/25/04) his violence escalated.
27
28 Instead of just going into a rage and breaking something, this time he grabbed a handful
29 of my hair and yanked me down the hall. The next time was in the car, with our infant in
30
SUPPLEMENTAL DECLARATION
IN SUPPORT OF REQUEST FOR Dyer & Primont
A DV PROTECTION ORDER
503 Twelfth Ave. E
AND LIMITATIONS IN TEMPORARY
Seattle, \VA 98102
OR IG!i~l~L
PARENTING PLAN
(206) 343- I 528
Page I
1 the back seat. That was around Christmas of 2004. That time he grabbed my sweatshirt
2
collar and shook me violently, so hard that I ended up with abrasions around my neck.
3
He also grabbed me by the hair, again, and pulled my face right up to his and screamed
4
5 horrible names at me.
6 After that time his abuse became routine. Not only physical but constant
7
emotional and verbal abuse. By the spring it was becoming difficult to hide the cuts and
8
9 bruises. Andy would always apologize and swear it would never happen again but it
10 always did. I was depressed and felt trapped. He began to make attempts to control all of
11
our money and we had no friends outside of our two families. I was so embarrassed and I
12
13 tried hard to hide this all from my parents.
14 By May of 2005 the abuse was so bad that I finally called the police. After he got
15
out of jail he promised to get into counseling or treatment and I got it all set up for him.
16
The prosecutor and judge allowed us to move back in together but Andy stopped going to
17
18 counseling and slowly started becoming abusive again. When the prosecutor found out
19 he was not in compliance with his treatment she requested that the No Contact Order be
20
put back in place. The judge did just that but that did not stop Andy. He moved back in
21
22 to our house, continued his abuse and continued to deny that there was any problem,
23 except with me.

24
Just days before his criminal trial for assaulting me, Andy tried to have me
25
26 arrested for assaulting him. After listening to his stories and those of his brother the
27 police did not believe him. They arrested him for violating the No Contact Order. At
28
that point we permanently separated. (Please see initial declaration for my detail).
29
30
IN SUPPORT OF REQUEST FOR Di;er & Primont
A DV PROTECTION ORDER 503 Twelfth Ave. E
AND LIMITATIONS IN TE~IPORARY Seattle, l·VA 98102
PARENTING PLAN (206) 343-1528
Page 2
~------ --- -
1
2
ISSUES WITH ALCOHOL
3
I filed for a Protection Order, Andy filed for divorce. Rather than admit that he
4
5 has a problem, Andy has continued to blame me in any way he can. Knowing that I had
6
gone to a treatment facility years ago at my parents request he suddenly tells the court
7
that I am a problem drinker. When I drink I don't abuse people. I don't drink to excess.
8
9 I don't drink and drive. 1 don't accost people when I am driving. Andy does all of these
10 things. I think he really does have a problem with alcohol, along with his problem with
11
rage and abuse. The following is what I know about Andy's drinking and it concerns me.
12
13 When Andy and 1 first started dating in 2002, I noticed right away that he drank
14 quite a bit. Because I had just recently been at a treatment center in Vancouver I had
15
concerns that maybe he was an alcoholic. He explained is drinking to me telling me,
16
"Drinking is how I relax and get to know people." He also told me that he didn't really
17
18 know of any other way to have a good time. During that time, and up until he filed for
19
divorce, Andy has never expressed any concern over my alcohol consumption.
20
Andy has bragged to me that, before we met, he used to go out 3-4 times a week
21
22 with his friend and get very intoxicated. He bragged that he missed work from hangovers.
23 He also told me that he and his buddy got into many bar room brawls, and fist fights with
24
strangers that they met in these bars. He spoke with pride of the fights he would get into
25
26 while driving his car. He was a "regular" at a bar in Everett on Hewitt Ave. called
27 "Bucks American Cafe". They even specially ordered an imported Italian beer for him
28
called "Moretti". He told me that sometimes he got so drunk there, that one of the staff
29
30
A D\' PROTECTION ORDER
503 T1velfth Ave. E
Seattle, \-VA 98102
PARENTING PLAN
Page 3
OR\G\hlAL (206) 343-1528
L
1 would follow him home after closing. He would spend 4-6 days a week there, usually
2
after work, and on Saturdays.
3
He also confided in me at one point, that sometime before we met, his family had
4
5 mentioned that they were concerned that he was gaining weight from drinking to much.
6 His Mother and Aunt have also expressed concern that they do not like to see him
7
drinking so much. Alcoholism runs rampant in Andy's family. Both his Mom and Aunt
8
9 completely abstain, as both of their parents were alcoholics. His maternal Uncle is an
10 alcoholic who no longer drinks due to the many problems in his life associated with
11
alcohol. His sister in-law is also an alcoholic and she also no longer drinks. I believed
12
13 she stopped after getting a DUL
14 Andy's Father is an alcoholic as well. He is a reclusive man that rarely visits

15
anyone in his family. He has never invited us to his home for dinner or any other kind of
16
social event. He drinks scotch daily. There have been times where Andy has been on the
17
18 phone with his father and would look at me with an exaggerated "drunk" look on his face
19
while his Dad was talking.
20
Routinely, Andy would walk into the house in the early afternoon on Saturdays
21
22 with a beer in his hand after working with his father that day. He has told me on several
23 occasions that it is routine for he and his Father to stop at the liquor store for Scotch and
24
beer to drink in the van on the way home.
25
26 I have no problem abstaining from alcohol but I do not believe it is a problem in
27 my life. I took my treatment very seriously. I am completely willing to have an

28
additional alcohol/drug evaluation but I would request that Andy also be required to have
29
30
IN SUPPORT OF REQUEST FOR Dyer & Primonl
A DV PROTECTION ORDER 503 Tivelfth Ave. E
AND LIMITATIONS IN TEMPORARY Seattle, \.VA 98102
PARENTING PLAN
OR\Gl~·J;\L
(206) 343-1528
Page 4
1 an evaluation. But if either of us does l would like the evaluator to have access to more
2
information than just self reported information.
3
REQUEST FOR RESTRICTION ON ANDY'S TIME WITH OUR DAUGHTER
4
5 Because of Andy's escalating pattern of abuse, both physical and emotional,
6 have real concerns about him spending time alone with Lauren. Below are some other
7
issues that 1 believe bear on his ability to adequately and safely parent Lauren alone.
8
9 Andy is a dangerous driver and 1 believe this presents a danger to our daughter. 1
10 have witnessed firsthand many frightening acts of rage when Andy is behind the wheel.
11
He has told me of many instances of he or his Dad screaming out the car window at the
12
13 person driving next to them. Both Andy and his father refer to women drivers most often
14 as, "stupid cunts" and "fat bitches." 1 have witnessed him driving too fast and erratically,
15
even with our daughter in the car. Many times he has stopped the car and challenged
16
someone to come and fight him while Lauren and 1 were in the car. 1 have felt that we
17
18 were in danger on many occasions.
19
Andy refuses to let a woman drive when he is in the car, regardless of his level on
20
intoxication. There are many times that 1 can think of where he has clearly been
21
22 intoxicated but has refused to let me drive, opting instead to have Lauren and l
23 passengers in his car when he is intoxicated. l do not trust that he will not drive with
24
Lauren in the car after drinking because he does not believe there is anything wrong with
25
26 this. It is about his power, not about good parenting to him.
27 Andy is extremely racist and sexist. He talks constantly about how women are
28
lying, manipulative bitches. He has told me over and over again, that women don't
29
belong in politics, and how awful they are to work with. He says all they do is call in
30
IN SUPPORT OF REQUEST FOR Dyer & Primonl
A DV PROTECTION ORDER 503 Ttvelfth Ave.£
AND LIMITATIONS IN TEMPORARY Seattle, iVA 98102
Page 5
·...
1 sick to work and make up excuses to not work hard. He is also very hateful towards any
2 minorities, gays and liberals and states his opinions to everyone who will listen.
3
In mid-September, Andy and I went on a long walk around Everett Community
4
5 College with Lauren in her stroller. Coming back up towards our neighborhood, we
6 passed a house where we could here a man and woman arguing, when we heard someone
7
being hit. I'm assuming it was the woman, as we heard her start crying, then the man
8
9 slammed out of the house and got in his vehicle and left. I said "Oh my god, I think he
10 just hit her." Andy turned towards me, with a very nasty look on his face and said, "she's
11
a raving bitch, she probably deserved it."
12
13 During our marriage Andy did not take responsibility for child care and rearing
14 duties in fact he was rarely home. A normal weekly routine in our house was this: Andy
15
would get up at 5:00 a.m. and go to her father's house for breakfast then to the Elks club
16
for a steam and shower and off to work by 7:00 a.m. For every lunch break he would go
17
18 back to the Elks club for a "workout and steam." When he got off work he would go
19
back to the Elks club for another steam bath and swim. He would come home for dinner
20
and then go back to the Elks club in the evening. On Saturdays he would get up at 6:00
21
22 a.m. and leave to go lay clean carpets with his father. Often he would work on Sundays
23 also. If he did not work on Sundays he made several trips to the Elks club. In short, he
24
was rarely home. If he was home he was mowing our lawn or washing the cars. He was
25
26 not spending time with our daughter. If he was in the house he wanted to be talking to
27 me, not playing with the baby. Once she got old enough to sit up he would prop her in
28
front of the TV to watch a video rather than play with her himself. He has almost no
29
tolerance for her crying and I am fearful of what he would do if he had her alone and she
30
503 Tivelfth Ave. E
Seattle, \.VA 98102
PARENTING PLAN
(206) 343-1528
Page 6
0 RIG IiO.: ;\ L
1 would not stop crying. Andy cannot tolerate any type of mess and having her toys all
2
over the floor drove him crazy. While we were living together I was able to be the buffer
3
for these shortcomings but I am very concerned about what he might do when or if he is
4
5 taking care of Lauren alone. I am very fearful that if she had a tantrum or cried for more
6 than a few minutes he would strike or shake her or worse. He has told me over and over
7
that the sound of her crying "hurts his ears." I have witnessed first hand how agitated he
8
9 gets when she cries too long.
10 I am very concerned that unless and until Andy voluntarily takes honest
11
responsibility for his attitudes and actions, he poses a risk to our very young daughter. I
12
13 do not want to keep her from him or he from her but I have also witnessed a spiraling
14 cycle of abuse in his life, including injury causing physical violence in our relationship
15
on multiple occasions. I see no evidence that he has changed. He is doing everything in
16
his power to make this as hard as he can for me, which in turn harms our daughter.
17
18 I do not believe he is engaging in any meaningful domestic violence treatment.
19
do not believe he is in compliance with his criminal sentence in that regard either. He
20
claims to be in treatment but no intake or assessment records have been seen. For our
21
22 daughter's sake he needs to learn how much of a negative influence his sexist, racist and
23 violent behavior will have on her.

24
I am requesting that Andy immediately have an assessment and begin treatment at
25
26 a domestic violence treatment program. Not a program of his choosing but one
27 recommended by experts in this field. There is a United Way treatment program in

28
Seattle called Family Services that has batterers' treatment, and also two specialized
29
programs for parents who have committed acts of domestic violence. It comes highly
30 SUPPLEMENTAL DECLARATION
503 Ttvelfth A11e. £
Seattle, lVA 98102
PARENTING PLAN
Page 7
ORl' 01ri t,
u l l . . . j· \ L (206) 343-1528
• •• 1
1 recommended. I would ask that he be ordered to immediately obtain an assessment for

2 domestic violence and begin treatment as per their recommendations. I am most
3
concerned that this cycle of violence be stopped before our daughter becomes the next
4
5 target of his uncontrolled rage and abuse. He should be in treatment and in full
6 compliance in order to have any visits with Lauren.

7
The current visitation is too frequent for Lauren and is very disruptive. It is clear
.8
9 to me that she is not doing will with all of this back and forth every other day. She has
10 been cranky and out of sorts since this every other day visitation started. Most cays when
11
Andy returns her at 6:30 p.m. she is asleep (not her naptime) which throws off her routine
12
and makes it very difficult to get her back to sleep on her normal schedule. It is clear to
13
14 me that he is not playing with her while he has her but is instead, letting her fall asleep.
15
I would suggest that we opt for 2 or 3 visits per week with one or two during the week to
16
be from 3:30 p.m. to 5:30 p.m. I would ask that a real effort be made to not just let
17
18 Lauren sleep but to interact with her during that time. The third visit could be on the
19 weekend and for up to four hours.
20
CONCLUSION
21
22 On November I, 2005 the court appointed Bridgett Llewellyn as the Guardian Ad
23 Litem and ordered us to return to this court for a review on Dec. 6, 2005. Ms. Llewellyn
24
was on a vacation for two weeks during that time and only returned on Nov. 28'h. It is
25
26 my understanding that she will not have any interim report, as she has not yet been able
27 to conduct any type of thorough investigation.

28
29
30
AND LIMITATIONS IN TEMPORARY Seattle, WA 98102
Pages
12/02/2005 11:30 3606685072 HOLLAND PAGE 01
. ..
I wo\lld ask that the issue of Andy's visitation be continued for an additional 8
1
2 weeks to allow Ms. Llewellyn the time necessary to conduct her investigation. That
3 Andy be required to have a DV assessment with Family Services in Seattle. If he is in
4
treatment I have no objection to the continuation of bis visitation, supervised by his
5
6 mother as I have outlined above.
7 . I am begging this court to enter an Order for Protection as requested in J.nY
8
Petition for Proteetion. I am terrified on Andy. 1 believe he still wants to control me and
9
10 that he will continue to abuse if he is siven the ch:mce. l undt!ll"Stand tl1Jlt any Protection
11 Order would make allowances for the Parenting Plan in our family law case.
12
I declare under penalty of perjury of the laws of the State of Washington
13
14
that the foregoing is true and correct. Signed and dated thisJnd day orWeozkv.
15 2oos in Anakrn<4 /</ , Washington.
16
17
16
19
20
21
22
;23
24
2!5
26
27
28
29
30 SUPPL£ML"O"AL DECLAIU.TION Dip & Primont
IN SUPPORT OF JlltQUEST l'QR SD! ftarljth A°'"£
/I. DV PROTECTION ORDER S..tt!r, WA 9810}
AND LIMITATIONS IN TEMPORARY (l-06) 34.3-1 '2 B
PARENTING PLAN
Page9
21105 OEC I5 PM 2: 23
1
Illlllll llllll Ill lllll lllll l l l lllll lllll lllll lllll l l llll L. DANIELS
' Mi1
2 CL 11307743 COUNTY CLERK
5HOHOMISH CO. WASH.
3

COUNTY OF SNOtt<>MISH
7
a In re:
Andrew Scott Rife
9 Petitioner. NO. 05 3 02755 1
and
10 Declaration of /l..::rl Tltf/Vl""k.-
Jennifer Rae Rife
11 Respondent.
12
13
1. --.JErf'.- µf&L.A !'JD
the State of Washington, that the following is true ;~~~~~der penalty of pel)ury of the laws of
.
26
CARLJ.GAUL
Altomey at Law
27 302 Bank of Amertca Bldg.
1604 Hewitt Ave.
Everett WA 98201
125 259-1117 FAX 259 7081
ORIGINAL
~art 425 259 7081 To: andrew rtfe Date: 121512005 Tima: 6.56:38 PM Page 1 of2
!\105 OEC 15 PH 2: 23
,;i.hL. DANIELS
11/lllllllllll Illllllllllll llllllllll I/Illlllll lllll llllllll cou1HY CLERK

COUNTY OF SNOHOMISH
7
s In re:
Andrew Scott Rife
9 Petitioner, NO. 05 3 02755 1 I!", R~'?a.......J.s
and
10 Declaration of '/4W11fhlo'£ ft>
Jennifer Rae Rife
11 Respondent.
12
13
I, -:S-
1'.'.c"-ltrt::O JW<..- '.'.'.) tf
, declare under penalty of perjury of the laws of
the State of Washington, that the following is true and correct.
14 1. IDENTITY ANO PURPOSE
15 I am Co-'NQ~,:'.~ .Y ~6"A..!~ . I make this declaration to

VtrC- Suenz1an C)@w,- of:. Wtt5iVAVefltJ
16
2.
17
18
19
20
21
22
23
24
Executed at b V6f2err
on IG./J/C)5
25
26
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
~\
425 259-4147 FAX 259 7081
ORIGl~~AL
J. Renae Pauls
17122 2"ct St NE
Snohomish, WA 98290
425-335-0700
December 1, 2005
To Whom it May Concern:
I have known and worked with Andrew Rife for the past four years. Through this
working relationship I discovered that Andy played soccer for SPU and I asked him to
come run a coaching clinic for my Snohomish United select team.
Andy helped on multiple occasions; he was always friendly, helpful, fun and encouraging
with my players. He started helping me when the girls were 10 and continued through
their U-12 year. Andy stopped helping me only once his wife became pregnant and his
daughter Lauren was born, he wanted to spend more time with his family.
Andy was never disrespectful and never displayed any sexual innuendos toward my
players or any fellow female co-workers. While working with Andy, I always found him
fun, yet professional and easy to work with.
If you have any further questions, please feel free to contact me.
~<?~--
ZU05 DEC 15 PH 2: 23
l'Ah L. DANIELS
COUNTY CLERK
2 SNOHOMISH CO. VIASH.
3

COUNTY OF SNOtf<>MISH
7
a In re:
Andrew Scott Rife
9 Petitioner, NO. 05 3 02755 1·
10
and
Declaration of /t"FI~J k.-z.."5: G...IL
Rd; (£;?' . / /
Jennifer Rae Rife
11 Respondent.
12
13
1• ~\ll.v~ V,rz.~~O:.Jt...- ,declareunderpenaltyof
the State of Was lngton, hat the following is true and correct.
·u 0 tth
pel'J ry e laws
01
14 1. IDENTITY AND PURPOSE
:: A1~pe v&Q9,MA ~\7JJ¥ 1 ~bf4 op sriOltio~l~k~ this declaration to
2· Wy _~o...~ tsfK vi oi,,+ O'Y' w~ ~r 1.01tK \'us: d~M.kv

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CARLJ.GAUL
Attorney at LiJw
1604 Hewitt Ave.
Everett WA 98201
425 259-1147 FAX 259 7081
OR/Gf~fAL
'•v111 . ..,.. ,, .,. ... _, .._:...'" ,~, '"· ~•..,.•v•• '""
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F1\il': L. DMllELS
4 COUNTY CLERK
S'iOi:U 11S:1 CO. WASH.
5
8 In re:
Andrew Scott Rife
and
10 Declaration of ft..,,iT/tJ/Vct(_/
Jennifer Rae Rife
11 Respondent
12
13 the State of Washington, that the following is true ;~~~~nder penalty of perjury of the laws of
15
16
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17
18
19
20
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~ecutedat 5_~c.(,.<)k
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CARLJ. GAUL
Attorney at [.;Jw
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7061
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i CL 11307738
4

COUNlY OF SNOHOMISH
7
s In re:
Andrew Scott Rife .
9 Petitioner, NO. 05 3 02755 1 -.To S ~ Kol'z_:
5
;,J:_
10
and
Declaration of /l-rrP.o vr:11 '
1
j
Jennifer Rae Rife
11 Respondent.
12
1, j£>\l k~~'j( SI~
k. . declare under penalty of perjury of the laws of
13 the State of Washington, that t e following is true and correct.
S.<ar-v.f~ ,0,~~ \-:tvW~O \ bjq~1!.;~\.-~ ~ I )'eke this declaration to
·r ~ ~ t-1\d'i t,\,,A ,,.,._J ~b-~ wd"'-

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Signed/l / / • 2
~nled~
25
Jo~if ~z..'{~1~L
26
CARLJ. GAUL
Attorney at liJw
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
ORIG\NAL
. Illlllll llllll Ill lllll lllll l l l lllll lllll lllll lllll llll llll ·2uos DEC 15 PM 2: 23
I CL 11307745
L. IJAHIELS
rA11
COUNTY CLERK
2 SNOHOMISH CO. WASH.
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 CHARLES DEVORE'S CERTIFICATE AS
Jennifer Rae Rife STATE CERTIFIED DOMESTIC VIOLENCE
11 1----------...;_R:...:e~sPc:. .O: . ;n. .;_d:.;_e::. :n. :.:t;.;. .L.P-"E"-'R;.;_P;_:A. .;_TR.. ;_A.. ;_T;_:O:. :.R:. cS=-T.
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I
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
Everett WA 98201
425 259-4147 Ff>:I. 259 7061
~
Department of Social and Health Services

· VICTIMS ASSISTANCE UNIT
CERTIFIES
Charles DeVore
PO Box 851
Mukilteo, WA 98275
AS QUALIFIED FOR REGULATED PRACTICE ACCORDING TO
THE DOMESTIC VIOLENCE PERPETRATOR TREATMENT PROGRAM STANDARDS
August 1, 2005
Certification Date
.Q.
7~
.Washinlfon
fate S. July 30, 2007
DEPARTMENT OF
7~
SOCIAL & HEALTH Expiration Date
SERVICES
q~q~
IP'
Domestic VioJ,ence Progra.m Manager
- ~-
• Illlllll llllll Ill lllll lllll lllll /11111111/ lllll lllll llll llll
CL 11233046
FILED
2110s oEc 13 AH
, f\M L. DANIELS
9l~3wv CT'r,::~:iJVzrd
COUNTY CLERK ,
3 SNOHOMISH CO. WASH. NOV 2 9 r.EC ~
4 C.ti.CL J. GAUL
Attorney :.i.t L::\'!
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 ORDER DENYING
Jennifer Rae Rife MOTION FOR BAD FAITH SANCTIONS
11 Respondent.
12 THIS MATTER having come on regularly before the court upon the
• 15
Respondent's motion for an award of bad faith sanctions in response to the
13 Petitioner's motion for entry of an amended temporary order, and the court having
considered the records and files herein and the arguments of counsel, and the court
14 being fully advised in the premises, now therefore
IT IS HEREBY ORDERED
16 Respondent's motion for an award of sanctions against Petitioner for bad
faith is hereby denied.
17
18 Dated:
19
20
21
22
23
.,
I /;~·;i
~.~/\.,.'\
24
•
25
26
~
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
ORDER DENYING Everett WA 98201
MOTION FOR BAD FAITH SANCTIONS 425 259-4147 Ff>:/. 259 7081
·=~LED
'lllU5 OEC I 5 PH 2: 23
1-1M L OAHIELS
. Illlllllllllll Ill llllllllll l l llllll lllll lllll lllll llll llll
1 'couHT'I' CLERK
• CL 11307741 SHOHOMISll CO. VIASH .
3
6 SUPERIOR COURT Of WASHINGTON

COUNTY OF SNOttOMISH
7
e In re:
Andrew Scott Rife .
and
10 Declaration of /}e,r1noN C1[/
Jennifer Rae Rife
11 Respondent.
u
13
15 I am ,4-µ~tlt::->-J 1 S ;:--tU(:-'N'::!. . I make th~s declaration to

«S'.4 k- S:Ue@M dcunir-o rCUJt51Hu~TOiV
16
2.
17
is
19
20
21
22
23
24
Executed al evl:14'7// f;JA-
on
25
I z/t,/o ~ 4:tJV f/VI
26
CARLJ.GAUL
Attorney at l.iJw
1604 Hewitt Ave.
Everett WA 98201
425 2S!H147 FAX 259 7081
ORIGINAL
•
j
December 6, 2005
I've had the pleasure of knowing Andy Rife and his family for nearly 20 yeais. I've always admired the
Rife family for their strong work ethic, commibnent to family and their ability to enjoy the simplicity of
togetherness.
Andy is one of the people in my life that I have always adored. He has never been anything but kind,
gentle and devoted to his family. He loves his child more than anything in this world and is committed to
her safety and well being. All Andy has ever wanted is to provide his own family with the same caring and
loving environment that he was fortunate enough to have as a child
I have never witnessed violent behavior with Andy. I have never seen Andy abuse alcohol or drugs. I have
never felt threatened or vulnerable in his company.
Andy is compassionate, sensitive, hard working and a man of his word.
Anyone would be lucky to have him in his or her life.

-
......... ............,,., ............. __ ........ .
.~:~LED
ZU05 DEC 15 PM 2: 23
1 L. DANIELS
1·AM
COUNTY CLERK
: . \ll~~~J!9}~\I
SNOHOMISH CO. WASH.
4 1,

COUNTY OF SNOtt<>MISH
7
e In re:
Andrew Scott Rife
9 Petitioner, NO. 05 3 02755 1 R~Vv\l.~
10
and
Jennifer Rae Rife

Declaration of /b<R 'Rtll..~
11 Respondent.
12
I, ~ P,. (\:\4r!it>JlS n._ , declare under penalty of perjury of the laws of
13 the State of Washington, that the foll<Mling is true and correct.
15 I Cd '-~=o~ ?o;., c':1F:a/1!t;,vt; Tl'~ make this declaration to

16
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20
21
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Executed at 6NO!'W>F'\.\S~ l'\JD Signed -
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on 12...\lo\os-
25
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CARLJ.GAUL
Attorney at l.i1w
16CM Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
ORIGINAL
,•
,
i;;~t.E D
1
21105 DEC 15 PH 2: 23
; ''f'l
L. DANIELS
COUNTY CLERK
Illlllll llllll Ill l\lll lllll l l l lllll lllll lllll lllll llll llll ._$NOHOHISH CO. WASH.
CL 11307748
4

COUNTY OF SNOHOMISH
7
8 Jn re:
Andrew Scott Rife
9 Petitioner, NO. 05-3-02755-1
and
10
SUPPLEMENTAL DECLARATION OF
Jennifer Rae Rife ANDREW SCOTT RIFE
11 Respondent.
12 I, ANDREW SCOTT RIFE, declare under penalty of perjury of the laws of the State of
Washington, that the following is true and correct.
I am the Petitioner in this matter. I make this declaration to respond to my estranged wife's
Supplemental Declaration.
CREDIBILITY
My wife has taken a few true facts, then embellished them to the point that they convey a
false impression. Her statements are not to be believed.
One Example: I do work out at the gym at the Elks club. Reading my wife's supplemental
declaration, she would have the court believe that I am at the Elk's club four times each day
during the work week and frequently on the weekends, in addition to my work with my
father and spending vast quantities of time (and money) at Buck's American Cafe, where
I get into fights. I do work out at the Elks club. The frequency is an embellishment. The
story about Buck's American Cafe is false, as I did spend time there before I met her, but
hardly since. I have never been in fights as she falsely claims, at Buck's or any other place.
CHEMICAL DEPENDENCY
Jennifer attempts to make this case be simply about domestic violence. She ignores her
own chemical dependency and her own aggressive behavior that she uses to facilitate her
ongoing chemical abuse. I am in a state certified domestic violence treatment program, and
I do not mean to minimize my own problems. I do mean to tell the court that I am not the
CARLJ.GAUL
Attorney at Law
~
\ \,
;\
302 Bank of America Bldg. l,\
1604 Hewitt Ave.
REPLY DECLARATION OF
ANDREW SCOTT RIFE ORIGINAL Everett WA 98201
425 259-4147 FAX 259 7081
~--------------------- --
1 sole owner of problems. Jennifer's chemical dependency and her contribution to the
problems that lead us to this divorce need to be recognized and addressed also.
2
Jennifer was in treatment for chemical dependency when she was in high school. She was
3 an unpleasant aggressive person when drunk even then. See declaration of Kim Drake.
4 Jennifer spent 60 days in Edgewood, a Nanaimo BC addiction hospital. She was there
because she needed to be. She was a chemically dependent person. My own fault was in
5 not recognizing the significance of her recent treatment when I met her. While there are
alcoholics in my family, the ones I know are recovering, not continuing to abuse. For
6 example, I have an uncle who is an alcoholic, but has 20 years' sobriety to his credit. I
have never personally lived with an active alcoholic before Jennifer. She has been using
7 alcohol throughout the time I have known her. Her incidents of rage generally are the
times she is drinking. She does not admit her daily drinking is simply relapse.
8
Jennifer tries to make me into a drunk. In my 20's I did frequent Buck's American cafe.,
9 but never 4-6 days a week as she claims, now only occasionally visiting there. As I grew
out of my 20's I grew out of spending time and money in the bar. I did not substitute any
10 other bar, I just found other things to do. I have never missed work due to a hangover or
other effects of drinking. Please refer to the declaration of Robert McManis I have never
11 been an any bar room brawl. I have never been in a fist fight since high school. Buck's
American Cafe does have an Italian beer that I like, Peroni. I never left Buck's American
12 Cafe intoxicated. Their staff did not follow me home or anywhere else after closing. Please
see declaration of Jeff Hegland.
13
Jennifer misses the most basic point: She is an alcoholic in relapse. I am not an alcoholic
14 at all. I presently do not drink, having recognized that alcohol consumption contributed to
the breakdown of our marriage and our current problems. Jennifer continues to drink. She
15 says that "I have no problem abstaining from alcohol but I do not believe it is a problem in
my life. I took my treatment very seriously." What she does not do is explain why she
16 continues to drink.
17 Jennifer is not content to let this divorce be between us. She makes comments about other
members of my family. My father does drink, but is not an alcoholic. Jennifer dislikes him.
18 He is no recluse. He does not drink on the job, nor in the car, and I never came home from
working with him with a beer in my hand. Please refer to the declaration of my father, Jim
19 Rife.
20 As to the request for chemical dependency evaluation, I suggest that the GAL be given
explicit authority to require either or both of us to go through any evaluation she deems
21 appropriate.
22 4. DOMESTIC VIOLENCE
23 Jennifer again requests that the court require me to enter into her attorney's favorite DV
treatment program. I am in a state certified domestic violence perpetrator's treatment
24 program with Charles Devore. This was begun before the divorce began, and is part of
what I am required to do as a condition of the stay of proceedings in the Everett Municipal
25 Court. There is no reason to require me to change programs. I am submitting a copy of
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
ANDREW scon RIFE 425 259-4147 FAX 259 7081
~---------------------------------
1 Mr. DeVore's certificate.
2 The basic fact pattern to our domestic violence was simple. Jennifer would drink,
sometimes I would also. She would get loudly argumentative and enraged. There would
3 be no reasoning with her. We both got loud. Sometimes she would become physically
aggressive. I never initiated physical aggression. I would sometimes grab her to restrain
4 physical violence against me, and I know that I overdid it. In all my previous life I never
had to deal with such a situation, and I dealt with it badly. But I am in a treatment program
5 designed to teach me how to not repeat the mistakes. There is light at the end of my
tunnel.
6
My wife takes an incident where I broke out a window BECAUSE WE WERE LOCKED OUT
7 OF THE HOUSE and makes it into an incident of violence. It was late at night and I did not
want to call a locksmith. I did not use a ladder, I used a brick. There has never been
8 another incident when I intentionally broke a window. I have a friend who works as a
window installer. He came over the next day and replaced the window I had broken. I got
9 a fair amount of teasing about this. The neighbors did call the police. They asked for my
identification to verify that I was the homeowner and left. Jennifer and I both laughed
10 about it.
11 Other incidents she fabricates. There was never an incident when I punched a hole through
the wall. The only hole in the wall of my home is in the kitchen where Jennifer threw a
12 phone at me. That hole is still there.
13 There was no incident when I grabbed her hair or dragged her down the hall. This is
another embellishment. We were in an argument. I did grab her coat, in a misguided
14 attempt to calm her down. I accidentally got some of her hair. I should never have
grabbed her. I did not drag her down the hall or anywhere else.
15
Before Christmas 2004 my brother-in-law, Mike Brunsman, and I went to Toys R Us. On
16 the way home we stopped at Applebee's Grill to pick up dinner and we had one (1) beer.
When we arrived back at Mike and Lisa's home, Jennifer became irate because we had been
17 gone too long. She told me that she and her sister were going to put on their make up an
dgo out and party down and meet some guys. Mike and I tried to explain why were gone
18 as long as we were. Jennifer was busy with her tirade and would not hear about it. The
argument escalated. We both yelled and screamed at each other and grabbed each other's
19 shirts. This argument subsided by the time we got home and we both felt bad about it.
I felt horrible that this happened in front of Lauren.
20
She simply repeats her claim about an incident in the car, which she included in her
21 previous declaration. As I told the court before, she was drunk when we got into the car,
we were arguing. When she started hitting me I did grab her sweatshirt to stop the
22 ongoing assault by her. She did struggle, and there were transitory red marks on her skin,
not abrasions. I had similar transitory red marks. There were no bruises. We were both
23 loud. It was an ugly incident. I did tell her she was behaving stupidly. I did not call her
horrible names. She shouted at me about my family members who do not drink and that
24 I did not get intoxicated with her.
25 Jennifer got no cuts from me. As our relationship neared its end, her behavior got more
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
--- ----
1 violent, not less. She tried to be controlling, using her temper as a weapon. She wanted
only to be with her family, not mine, and found fault with my family and friends. When I
2 would attempt to leave during an argument she would tell me that I would never see our
daughter or the dog again. She also shouted at me that I was weak because I did not want
3 to stay and continue an argument with her. When I became more willing to simply leave
during an argument, she called the police. This is exactly what she did with her prior
4 husband, Inga Klenner.
5 My wife falsely claims that I was out of compliance with my domestic violence treatment
program. It is true that the prosecutor erroneously thought I was. I was assessed at Davis
6 and Company. For treatment, however, I started at Summit Counseling. I decided to
change programs because I learned that Summit was not a state certified program. I then
7 commenced treatment in Charles DeVore's program. The prosecutor did not know that I
was in treatment and obtained a No Contact Order without notice to me. When I learned
8 of it I moved out. Over the course of a weekend I found out that Jennifer had moved from
my home, so I returned. Then Jennifer came back. I should have left immediately, but it
9 was late at night and we both were there. At the time things were calm. But the next day
there was a new argument and Jennifer called 911. I got arrested, not for an assault, but
10 for violation of restraining order.
11 5. MONEY
12 Jennifer is right about some things here. I have controlled the money. I have an excellent
credit rating. I own my own home and I pay my bills on time. Jennifer just could not
13 handle the day-to-day responsibilities of handling money. When I met her she was in
bankruptcy. I provided money to pay off an arrearage on her condominium to prevent
14 foreclosure. I paid $3200 to the Luke and Castille law firm. Jennfer had a 1999 BMW she
was about to lose. She had me take it to the PUD credit union to turn it in because she was
15 too embarrassed to do it herself. She did not make her payments on her Chapter 13
bankruptcy, and eventually rolled it into a Chapter 7 to clear the debt. She over-drafted
16 several times in her business checking account and maxed out the family credit card. So
I took over the money.
17
6. PARENTING ISSUES
18
Jennifer does not know our daughter. My own opinion is that any crankiness that Jennifer
19 sees is likely a result of our daughter wanting to spend more time with me and missing me
since the present legal situation has caused a reduction of our time together.
20
Our daughter is sleepy when I deliver her. Taking her for a drive is nearly certain to cause
21 her to fall asleep. But our visits are too short for much sleeping. She is awake as we play
together and speak in languages other than English, just like most all one-year-olds and
22 their parents.
23 I have frequently taken our daughter for walks in the neighborhood. Please see
declarations of Mary and Josh Krzysiak and Shelly Pattison.
24
Jennifer complains about my dangerous driving, claiming road rage. This is fabrication. I
25 have witnessed her driving while displaying her middle finger to people she was tailgating,
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
1 and saying the most outrageous foul things to and about other drivers. I simply would not
do that.
2
I attended a conservative Christian university, and I am comfortable in a conservative
3 Christian environment.
4 Jennifer is correct that I am not a social liberal. However, that is a far cry from being an
intolerant bigot. I neither seek nor avoid interactions with people who are different from
5 me. I do not care whether a person I may meet may be of a different gender, gender
preference or ethnicity than me. If I meet someone I like, then I may have a friend. If I
6 meet someone I do not like, then I may not have a friend. But there is not any filter that
screens people in or out based on gender, sexuality or race. That would be as irrational as
7 filtering people based on whether they might be left handed.
8 One of my college roommates was African American. We got along great. I attended
college on a soccer scholarship. Many of my college teammates were from other countries
9 or of other ethnicities, which presented no difficulties at all. I played for the university all
four years. I loved the game and the people.
10
I am presently working as a systems designer in the engineering section of the PUD. Many
11 of the people I work with are of other ethnicities, which means nothing. The issue there
is not whether any particular worker celebrates or decries diversity, but whether each of us
12 can do our assigned job and how well we work together.
13 Likewise, I have had acquaintances and coaches who were homosexual. Again, it is not an
issue. I do not seek out associations with homosexuals, but I do not avoid associations with
14 homosexuals, either.
15 Jennifer just flat lies when she claims that I refer to women in disparaging negative terms.
I have coached girls soccer, without any sexual inuendo or problem. I work with women
16 all the time, without problem. Please refer to the declaration of J. Renae Pauls. Please also
refer to the declarations of Stephanie Sears and Shelly Pattison.
17
18
on December 15, 2005 ANDREW SCOTT RIFE
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CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
ANDREW SCOTT RIFE 425 259-4147 FAA 259 7081
'""''·-·· , _ --........ .
.............. ......
21105 OEC 15 PH 2: 23
OAHIELS
i·i.i.ti L.
1111\11\ \\\I\\ Ill \\II\ \\Ill\\\\\ 11\\I \II\\ \1111 \\\\I \I\\ \II\ COUHTY CLERK

COUNlY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9
and
10
Jennifer Rae Rife
11
15 I am d-- ~ ~ ~ -w~ I make this declaration to

, a'?tf,, G29Ufltn;M£ft4,,ar 06ClJAs1n~roAJ
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CARLJ. GAUL
AJtJJmey at law
27 302 Bank of America Bklg.
1604 Hewitt Ave.
Everett WA 98201
425 259-1147 FAX 259 7081
ORIGINAL
.,
I would like to take this opportunity to say what my personal observations of Andy are
here at work; he has been that of a responsible, ambitious, pleasant, out going, hard
working individual, and most importantly a loving father and husband.
This situation/spit was a total surprise to me because Andy is so dedicated and appeared
to strive to provide not only love to his family but a wonderful home.
Thank You
Stephanie Sears
.....,........... _......, ............ __ ..........
.
~~LED
1
\ll~~~f)fi\I 21105 OEC 15 PH 2: 23
: ,, 1 1L.
DANIELS
COUNTY CLERK
2 ..SNOHOMISH CO. WASH.
3
5 ,,
.
COUNTY OF SNOttOMISH
7
s In re:
Andrew Scott Rife .
9
and
Petitioner, NO. 05 3 02755 1 (f~ """"'- R ,k
10 Declaration of /?E-7717.tJ d!C<l(. •
Jennifer Rae Rife
11 Respondent.
12
13
1, QtrA J?, {<..- declareunderpenaltyofperjuryofthelawsof
the State of Washington, that the follO\Ning is true and correct.
14 1.
15 . 1..I make this declaration to

?;J~ri.,..
16
2.
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Executed at
24 on
25 I 31 7 m })pttfl'ltt tJv-
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erc-4 w~ 9;;-,2t1~17.//
CARLJ.GAUL
Altomey at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 f,\)( 259 7081
ORIGINAL
-·--------
December 9, 2005
This letter is in response to Jennifer Rife's allegations of alcohol abuse and

being a recluse. I retired from the Snohomish County P.U.D. where there
was random drug testing for members of the line crews. I never showed
positive for alcohol or drugs any of the many times that I was tested. To
this day I carry my CDL (combination driver's license) license, which requires
a yearly physical examination. At no time has my family doctor ever talked to
me about an alcohol or drug problem throughout my medical history. I do
drink socially.
In reference to her accusations of my being a recluse, I have a very active

social life. I see my sons on a regular basis for breakfast. I also spend a lot
of time with my brothers, Charles and Joe. I have many friends from my 30
years of working at the P.U.D. I still have many friends that stop by the
house and I occasionally attend a retiree's breakfast. I have been a member
of the Everett Elks club for 30 years. I have many friends and acquaintances
that I see on an almost daily basis. I own a carpet cleaning business and I
deal with the public and property managers on a daily basis. I make it a habit
to take the property managers out to lunch and dinner to thank them for
their continued support of my business.
We get together as a family when Andy has Lauren for visitation to show
love and support for our granddaughter. I have taken the entire extended
family out to dinner to celebrate when we have Lauren with us.
\
--- ----------
e In re:
Andrew Scott Rife
and
10 ORDER
Jennifer Rae Rife
11 Respondent.
12
THIS MATTER having come on regularly before the Court for review of temporary
13 orders, and the parties having reached agreement on the following provisions, IT IS HEREBY
ORDERED
14
1. All provisions of the existing Amended Temporary Order shall remain in full force and
15 effect, except as specifically modified by this order.
16 2. Father shall be entitled to residential time with the child on Christmas Eve 2005 from
1 :OO p.m. through 7:00 p.m. The father shall not have residential time with the child on
17 Christmas Day 2005.
18 3. Commencing the dale of this order, the father's two hour residential time on Fridays is
eliminated, and the father's residential time on Saturdays is extended by two hours.
19 The times for the father's Saturday residential time shall be from 11 :00 a.m. to 5:00
p.m. Times for Saturday, December 24 shall be as provided in paragraph 2.
20
4. The exchange of the child shall be as follows:
21 A. The mother will deliver the child to the father's mother's home at the
commencement of his residential time.
22 B. The father will deliver the child to the mother's mother's home at the
commencement or her residential lime.
23 C. Al the times and places or the exchanges, neither parent will communicate
directly with the other, and all communications shall be limited to subjects which
24 strictly pertain to the child.
5. Other:"°"''· ~ ...~<~ ,.,.. ... \.1..... .... r \ Q...,-lt" ..~ "ir. ... .,.i,.c.- .. •_.. • \c..._, ~\...._\,
25
26
CAR.LJ,GAUL
A ttomey at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
.. .. .. .. ! o, ?B ~ ~e-..,,..... ., . .,.,...,.,.,. ======.. ,. ,.,....,.,.,.. ,.,. .,.. ,-!!.XU ..~ H.1... s?ii.? f. !. <BJ
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'·
/,
?. From: earl 425 259 7061 To; jan dyer Date; 1212112005 Time: :):39:20 PM Page 2 of2
1
2
3
Dated: DEC 2 2 2.005
4
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26 CARLJ. GAUL
Attorney at Law
27 302 Sank of America Bldg.
1604 Hewitt Ave.
Everett WA 98201
125 259-1l17 FIOI. 259 7081
............. :. :.:. :.~ :.o:. j'.'] ..•......•............•.............•.........•.•......•....................... ···•··· ...............•........•... 11'(1!(. 1..~ ... ~.I.. Ii f I i1' J.~/i I
~--------------- - - - - --- --
;:-p_ ED
"0 DEC 22 All II: SL1
r .111111111111111111111111111111111111111111111111111111111111 • SUPERIOR COURT OF r'/\;-1 L. O,"..t~JELS
CL 11218474 WASHINGTON COU,HY CLERK
l FOR SNOHOMISH COUNTY SNOHOMISH CO. 'ii,\ SH.

AND CLERK: S. HUBER/K. GUNN
JENNIFER RIFE DATE: 12/22/05 @ 9:00 A.M.
THIS MATTER CAME ON FOR: PRESENTATION OF ORDER DENYING MOTION FOR BAD FAITH
SANCTIONS; REVIEW HEARING ON TEMPORARY ORDER.
CONTINUED/HEARING DATE SET AND CALENDAR/CONTINUANCE CODE: 01/30/06 @ 9 AM (D2) HCNTPA
ACTION: PRESENTATION OF ORDER DENYING MOTION FOR BAD FAITH SANCTIONS; REVIEW
HEARING ON TEMPORARY ORDER.
ACTION: * TO BE HEARD WITH #05-2-01268-2 *
RESPONDENT APPEARED: NO COUNSEL: NOT PRESENT
GUARDIAN AD LITEM APPEARED: NO
DOCUMENTS FILED:
ORDERS ENTERED:
THIS MATTER WAS HEARD WITH COMPANION CASE CAUSE #05-2-01268-2. THE MATTER
IS CONTINUED BECAUSE THE GUARDIAN AD LITEM WAS NOT AVAILABLE TODAY.

.. . •
1
F\LE.D
2 1005 OEC 29 PH z: 35
~Il /IllII/I
3 PAH L. Oft.NIELS
COUNTY CLERK
4 Illlll/l llllllIllI/Ill lllll lllll /111/lllll lllll SNOHOHISH CO. WASH.
CL 11256534
5
6
7
IN AND FOR SNOHOMISH COUNTY
9
10 CASE NO. 05-3-02755-1
11
12 ANDREW RIFE,
Petitioner/Plaintiffls)
NOTE FOR TRIAL SETIING AND INITIAL
STATEMENT OF ARBITRABILITY
13 (NlTSNA OR STA)
vs.
14
15
JENNIFER RIFE,
16 Respondent/Defendant(s)
17
TO: The Clerk of the Court; the Diredor of Arbitration (by separate copy serviced at Room 502,
18 Superior Court Administration) and the attorneys or parties listed below:
19 I hereby affirm that this case is at issue; that no affirmative pleading remains unanswered; that to my knowledge no
other parties will be served with summons; and that the case in all respects is ready for trial and/or transfer to
20 arbitration.
Type of Case: Dissolution with child _ _ _ _ _ _ _ __ Estimated Trial Time: Four days
21
22 (Check one)
A jury of D twelve is requested and a jury demand and fees have been filed with the Clerk pursuant to CR 38.
23 Osix
(Check one)
24 trhis case D is arbitrable.
~ is not arbitrable.
25
Please note that as of 12-19-2003 there is a mandatory arbitration fee of$220.00 which must be paid at the
26 time of filing this document with the County Clerk. Documents that indicate the case IS arbitrable that are
~ubmitted without the fee will be returned to the submitting party.
27 NOTE: Arbitrable, non-jury cases should not be noted for presentation to the Superior Court
Administrator's Office for trial setting at this time (See SCLMAR 2.1 (e) and 7.1)
28
29 Date (mm/dd/yyyy): 01/16/2006 _ ___;at I0:00 AM this case will be presented to the Court
Administrator's Office for Trial Setting.
30
IT IS NOT NECESSARY TO APPEAR FOR TRIAL SETTING. Dyer & Primont
503 Twelfth Ave. E
~~~
RRU: 07JOl/200J
•
1 INITIAL STATEMENT OF ARBITRABILITY (SCLMAR 2.1)
2 is case is ARBITRABLE because: (Check one)

0 The sole relief sought is a money judgment and involves no claim in excess of $50,000 exclusive of any
3 attorney fees, interest and costs (RCW 7.06.020 SCLMAR 1.2) or
4
0 The sole relief sought, regardless of the number or amount of payments, is the establishment, termination or
modification of maintenance or child support payments or arrearages (RCW 7.06.020 SCLMAR 1.2) or
5 0 The undersigned waives any claim in excess of$50,000 in order to have this case arbitrated; or
0 This is a Small Claims matter appealed from District Court.
6
is case is NOT ARBITRABLE because: (Check one)
7 0 Relief other than or in addition to a money judgment is being sought and/or a claim, counterclaim or cross
claim exceeds $50,000 exclusive of attorney fees, interest and costs; or
8 [8:1 This domestic lawsuit presently involves issues other than or in addition to the establishment, modification
or termination of child support or maintenance payments or arrearages; or
9 0 This case is an appeal from a Municipal or District Court decision (which is not a Small Claims matter); or
0 This case is otherwise statutorily exempt from mandatory arbitration.
10
11 RCW:
12
Civil Cases not subject to MANDA TORY Arbitration may be submitted to arbitration pursuant to MAR 8.1 (b),
13 SCLMAR 8.1 and SCLMA 2.1 (d) by stipulation which must be filed with the Clerk of the Court and a copy served
pon the Director of Arbitration.
14
15 0 The undersigned hereby requests that this matter be transferred to arbitration pending formal stipulation by
the parties.
16
17 Any Response to this Statement of Arbitrability must be filed with the Clerk of the Court and a copy served upon the
Director of Arbitration within 14 days after this docum as been served and fi LMAR 2.1 (b))
18
CERTIFICATE OF MAILING
19 1 certify that I mailed a copy of this document to
the attorneys listed hereon, postage prepaid on the
20
21 Date (mm/dd/yyyy): 12/28/2005 ~~~~~~~~~~
22 NOTE: File the original of this document with the

Clerk of the Court: Serve a copy on the Director of
Jan M. Dyer
23 Arbitration, Room 502, Superior Court ADDRESS:
Administration & a copy
24
on all parties. 50312 1h Avenue East, Seattle, WA 98102
25 TELEPHONE: (206) 343-1528 ext.
26
ATTORNEY FOR: (Check one)
27 0 Petitioner/Plaintiff
[8:1 Respondent/Defendant
28
29
30
Dya & Primont
5113 Twelfth Ave. E
Seattle, WA 98102
C:\Documenls and Setlings\Compaq_Owner\My Documcms\dic:nu\J RifelC2CMl.TrialScltinsNote.doc RRU: 07Allf200J
(206) 343-1528
ORfG\NAL
-
• .. •
1 PLEASE LIST THE NAMES, ADDRESSES, ETC. OF ALL OTH ER ATTORNEYS IN THIS CASE
AND/OR ALL OTHER PARTIES REQUIRING NOTICE.
2
3 NAME: WSB A#: 8341
4 Carl Gaul TELE PHONE: (425) 259-4147 ext.
ADDRESS: ATTORNEY FOR: (Check one)
5
[83 Petitioner/Plaintiff
6 1604 Hewitt Avenue #302, Everett, 98201 D Respondent/Defendant
7
8 NAME: WSB A#:~~~~~~~~~~~~~
9 Bridget Llewell;rn, GAL TELE PHONE: (425) 339-2382 ext.
10
D Petitioner/Plaintiff
11 3114 Oaks Avenue, Everett, WA 982001 D Respondent/Defendant
12
13 NAME: WSB A#:~~~~~~~~~~~~~
14 TELE PHONE: ( ) ext.
15
16 D Respondent/Defendant
17
18 NAME: WSB A#:~~~~~~~~~~~~
ADDRESS: ATTO RNEY FOR: (Check one)
20
22
23 WSB A#:~~~~~~~~~~~~~
NAME:
25
OPetitioner/Plaintiff
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
C:\Doa.uncnls and Scaings\CompML°"'11c:s\My [)oaimc:nU'dicJls\J Rife'OCivilTrialScaingNote.doc RRU: 0710lf2003
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COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. 05 3 027551
and
10 MOTION FOR JUDGMENT
Jennifer Rae Rife
11 Respondent.
12 Comes now Andrew Rife, Petitioner above named, and moves this court to
enter an Order granting the relief requested in Part I below:
13
I. Relief Requested
14 Andrew Rife oves this court to enter a Judgment against Jennifer Rife in the
amount of $1242.00, and for an award of attorney fees based on her intransigence.
15
II. statement of crounds
16 Jennifer Rife took items of personal property and real property fixtures to
which she was not entitled at the time she moved from Mr. Rife's home, contrary
17 to the orders and agreements in this matter.
18 Ill. Statement of Issues
Should Jennifer Rife compensate Andrew Rife for her wrongful taking of his
19 property?
20 IV. Evidence Relied Upon
Declaration of Andrew Rife submitted herew·th.
21 !
22 Dated: January 5, 2006
23
24
DECLARATION
25 1, Andrew Rife, declare under penalty of perjury of the laws of the State of·
26 CARLJ.GAUL
Attorney at Law
MOTION FOR JUDGMENT

Page 1
Everett WA 98201
425 259-4147 FAX 259 7081
1 ashington, that the following is true and correct.
3 I am the Petitioner in this matter. I make this declaration to explain to the
court the reasons I am asking for a judgment against my estranged wife.
4
2. MY RESIDENCE - Items wrongfully Taken
5
My wife and I resided at my home, which I owned the home before we
6 married. A the time of filing I was temporarily residing with my father. The
court directed that my wife should move from the residence and could take
7 with her agreed personal property.
8 Ms. Dyer sent us a letter November 4, 2005 which attached a list of personal
property my wife wanted to take with her. we responded that I agreed to
9 her taking all the items she had listed. She supplemented the list by letter of
November 7, indicating that she wanted certain additional personal property
10 items.
11 MY attorney wrote back to Ms. Dyer on November 16. The letter included a
number of topics. The portion dealing with personalty stated:
12
Concerning personalty, you have written concerning the personal
13 property Mrs. Rife intends to take from the home. For the most part, her
lists are entirely unobjectionable. Mr. Rife agrees that Mrs. Rife may
14 take all the items you have listed. Concerning kitchen stuff, linens and
the like, we are presuming that Mrs. Rife will take some and leave some,
15 doing her best to make a fair division. You have suggested that Mrs. Rife
is only requesting the temporary use and possession of some items. Mr. Rife
16 will not be requesting the return of those items. Mrs. Rife may take them
on a permanent basis. He is not intending to make this into litigation over
17 widgets. Partly this is genuine generosity. Partly this is practicality. He
does not intend to spend dollars pursuing dimes. More practically though,
18 he will need to obtain a bed for himself. At that point he will not need to
have the bed Mrs. Rife is taking. Simpler to just let her take it. If she does
19 not want it later, she can dispose of it.
20 <Emphasis addedl.
21 3. ITEMS MISSING
22 1regained possession of my home on Saturday, November 19 at noon. When
1 returned 1found several items were missing. They are:
23
Gas BBQ
24 Shop vacuum
De wait drill
25 The bathroom mirror
26
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
MOTION FOR JUDGMENT Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
1 Wall mounted calendar and telephone
Pot rack
2
3 MY lawyer wrote to Ms. over on November 23, 2005, copy attached. Ms. over
has not responded to that letter. My lawyer sent her a reminder letter on
4 December 9, 2005, copy attached. Ms. Dyer has not responded to that letter.
5 until recently, we have been exchanging our daughter at the home of my

wife's parents. I typically stay in the car while my mother takes the baby to
6 and from the house. While sitting in the car I have been able to see into my
in-law's garage. The things I have listed are in their garage.
7
4. VALUES
8
When it was apparent that the items would not be returned, I sought values
9 for the items. They total $1242.00.
10 The Barbeque was purchased on July 8, 2005 for $599.00.
11 For the other items, I went to Loew·s on December 19, 2005 and looked for
equivalent items and their costs. They are:
12
13
Mirror s 216.00
14
Shop vac s 79.00
Dewalt Drill s 129.00
15
wall Phone s 59.00
16
Wall Mounted Chalk Board & s 100.00
17
Calendar
18
Kitchen Pot Rack s 60.00
5. ABUSIVE USE OF CONFLICT

19
The court has heard before about my wife's temper and her rages. This is just
20 another example of it. There was no legitimate reason for her to take these
things. None of them relate to her or to our daughter. There was even less
21 reason for her to retain them. And there is no reason at all for her to fail to
pay for them.
22
6. JUDGMENT
23
I am asking the court to grant me judgment against Jennifer Rife for $1242.
24 I am also asking for judgment for $1000 terms/attorney fees. I offered to just
let them be returned, and to arrange for the drayage. No response. And
25 there was no response to the reminder letter. The items taken were
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 wrongfully taken. They should have been returned. I should not have needed
to come to court for them.
2
January 5, 2006
4
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
CARLJ. GAUL Attorney at law 425 259-4147 fax 425 259-7081
Admitted to practice in Washington, Oregon and California 302 Bank of America Building
1604 Hewitt Avenue
Everett WA 98201
November 23, 2005 Faxed to 206 343-7781 at 2:09 pm
Jan Dyer MATTER: Rife Dissolution

Attorney at Law No. 05 3 02755 1
503 Twelfth Ave. East RE: Personalty
Seattle WA 98102
Dear Ms. Dyer
We have received Mrs. Rife's cashier's check for $278.10, thank you. This should
conclude the exchange of cashier's checks for small items due between the parties. It is
nice to have one problem resolved.
Unfortunately, not all problems are resolved as a new one has arisen. You will recall
that your letters have included a listing of personalty Mrs. Rife desired to take with her at
the time of vacating Mr. Rife's home. Mr. Rife authorized me to agree to every item she
requested, without exception, and I communicated that position to you.
Last Saturday Mr. Rife regained possession of his home. Before he entered the
dwelling the home was inspected and photographed by private investigator Michael
Schoonover (425 259 4595) to document the condition at the time Mrs. Rife vacated.
Thereafter, Mr. Rife entered his home. He found that there are several items missing.
Please have them returned at once. These items are:
Gas BBQ
Shop vacuum
De Walt drill
The bathroom mirror
Wall mounted calendar and telephone
Pot rack
At the present time Mr. Rife is willing to assume that perhaps Mrs. Rife's assistants
were overenthusiastic in their assistance. But none of the foregoing items were listed in
your letters. Mrs. Rife's unilateral action in taking these non-agreed items was improper.
The gas barbeque is not even paid for. The shop-vac was Mr. Rife's from before the
marriage. The DeWalt drill was a birthday present to Mr. Rife from Mrs. Rife's parents.
The bathroom mirror, wall mounted calendar and phone and the pot rack were all attached
to the house with screws and should have been left there. At the time they were taken
Jan Dyer
November 23, 2005
Page 2
they were realty or fixtures, but not personalty. None of them should have been taken.
All should be returned.
Return of these items likely can best be accomplished by a person having a pickup
truck. Mr. Rife's father or uncle can do the job in the next few days. Please have Mrs. Rife
call Charles Rife (425 438 9373) or Michael Rife (425 508 6813) to arrange pick up. These
individuals are Mr. Rife's uncles. Mr. Rife tells me that these individuals may have met Mrs.
Rife, but that there has not been frequent contact with them, and he expects that they
should be unobjectionable for drayage service.
Certainly there are other methods of return of the personalty. Constructive

suggestions will be constructively received. Now that Mrs. Rife has notice through you that
these items should be returned a failure to do so will not be viewed as innocent. A failure
to be constructively involved will result in a return to court for judicial assistance.
I am tickling this matter back to my attention on December 1.
Yours truly
Faxed Without Signature

To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife

CARLJ.GAUL Attorney at Lalv 425 259-4147 fax425 259-7081
1604 Hewitt Avenue
Everett WA 9820 I
December 9, 2005

503 Twelfth Ave. East RE: Personalty
Seattle WA 98102
Dear Ms. Dyer
I await a response to my letter of November 23, copy enclosed.
Yours truly
CARLJ.GAUL
OG/s
cc: Andrew Rife

Bridget Llewellyn
1 ·F\LED
. nfi JM~ 11 Al'\ \O: 3Z
I lllllll llllll Ill lllll lllll 111111111111111111111111111111111 PAM L. Di\Hlf.LS
COUNT y CLERK
CL 11373450 ~ SllOHOHISH CO. WA SH.
5
6 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
7 IN AND FOR THE COUNTY OF SNOHOMISH
8
9 Petitioner
and CALENDAR NOTE
10 (C:::CMMISSIONER's DOMESTIC
Jennifer Rae Rife MOTION CALENDAR)
11 Res ondent
13
14 FAMILY LAW / DOMESTIC Date: January 30, 2006

CA LEN DAR- (Except matters relating to
17
Matters set before a Court Commissioner will be assigned later to a particular department. The assignment
18
matter, please indicate Court Commissioner
19
and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for trial settings. SCLMAR 2.1 40(b).
21
Dated: January 11, 2006
22
23
24
25
26
27
28 /
1
(o I
CARLJ.GAUL
CALENDAR NOTE Allorney al Law
Everen WA 9820 I
1
(COMMIBSIONER S DOMESTIC MOTION CALENDAR) (425) 2594147 Fax 259-7081
I
Illlllll llllll Ill lllll lllll lllll lllll lllflllll llll llll
CL 11385444
::iLED
,, J;'.i! 30 fli-; 10: Li 1
r' "''' L. l);\ri\ELS
COUH1 'I CLER.~
~ciOIWl"\ISH CO. \,•·SH.
IN THE SUPERIOR COURT OF THE STATE OF WASHING TON

)
)
and fl ~ NO. t9? - "3 -6"'2... 7 5"~- I

~~~ ~?:;; ((°'-..._ ~:1-<. )
DEFENDANT/ RESPONDENT ) ORDER
)
)
-
~·
1 1"0 A'1d0=~1
•• ....
.... t-.1
SUPERIOR COURT OF
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll l\lll llll llll WASHINGTON , ,.;iL.cJ,\ld~LS
CL11385445 FOR SNOHOMISH COUNTY
COUHTY CLERK
,;10HOr\ISH CO 'ii f. SH.
ANDREW SCOTT RIFE CAUSE NO.: 05-3-02755-1

(PETITIONER) COMMISSIONER: LESTER H. STEWART
AND CLERK: S. HUBER
JENNIFER RAE RIFE DATE: 01/30/06 AT 9:00 A.M.
SANCTIONS; REVIEW HEARING.
CONTINUED/HEARING DATE SET AND CALENDAR/CONTINUANCE CODE: 03I 20I 06 @ 9 AM ( D2) HCNTU
ACTION• PRESENTATION OF ORDER DENYING MOTION FOR BAD FAITH SANCTIONS; REVIEW
HEARING #58
ACTION: * TO BE HEARD WITH #05-2-01268-2
HEARING STRICKEN/CODE1
PETITIONER APPEARED 1 YES COUNSEL: CARL GAUL I I I

RESPONDENT APPEARED 1 YES COUNSEL: JANIS DYER
GUARDIAN AD LITEM APPEARED: YES, BRIDGET LLEWELLYN ADDRESSED THE COURT
FACILITATOR PRESENT 1 NOT PRESENT
DOCUMENTS FILED1
ORDERS ENTERED: ORDER.
THIS MATTER WAS HEARD WITH CAUSE #05-2-01268-2.

THIS MATTER IS CONTINUED TO MARCH 20, 2006 SO THE GUARDIAN AD LITEM CAN
COMPLETE HER REPORT.
THE TEMPORARY ORDER OF NOVEMBER 1, 2005, SHALL REMAIN IN EFFECT, EXCEPT
THAT THE PLACE OF EXCHANGE SHALL BE AT PETITIONER'S HOME.
ITEMS OF PERSONAL PROPERTY LISTED IN PETITIONER'S MOTION FOR JUDGMENT
SHALL BE RETURNED TO HIM BY NOON FEBRUARY 4, 2006 OR THE COURT WILL ENTER THE
REQUESTED JUDGMENT. THE ISSUE OF FINAL DISPOSITION AND CHARACTERIZATION OF SAID
PROPERTY IS RESERVED FOR TRIAL.

1
r:~1.
........ ED
2
3 \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\~\ \ ~\ \ ~\\\\ 200fi FEB I 0 PM z: I 1
CL11347358 PAM L. OAHIELS
4 COUHTY CLERK
SHOHOMISI\ CO. WASH.
5

7
8
9 Petitioner
and CALENDAR NOTE
10 {CDMMISSIONER S
1
DOMESTIC
11 Respondent
13
14
15
16
17
18
matter, please indicate Court Commissioner C. Stewart
19
20 for the matter to be argued. Failure to notify the Court of a continuance or strike may suit in sanctions
and/or terms. SCLCR 7(b)(2)(E). This form cannot be used fo'it settings. SCL R 2.1 4 (b).
21 -/-----
Dated: February 9, 2006
22
23
24
25
26
27
~I\.XJh
28
CARL J. GAUL
CALENDAR NOTE Auorney at law
E ..·erett WA 98201
1
(COMMIS610NER S DOMESTIC MOTION CALENDAR) (425) 259-4147 Fax 259-7081
~fil,ED
200& FEB I 0 PM 2: 18
1
PAM L. DANIELS
2 COUNTY CLERK
Illlllll llllll Ill lllll lllll l l l lllll lllll lllll lllll llll llll SNOHOMISH CO. WASH.
3 CL11347359
4

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 MOTION FOR PROTECTIVE ORDER
Jennifer Rae Rife
12
comes now Andrew Scott Rife, Petitioner above named, and moves this court
n to enter an order granting the relief requested in Part I below:
Andrew Rife moves this Court to enter an Order which protects his
15 confidential communications from discovery.
16 II. statement of crounds
Respondent's attorney has issued a subpoena seeking production of Mr. Rife's
17 confidential records.
18 Ill. statement of Issues
DOES RESPONDENT'S SUBPOENA FOR RECORDS OF CHARLES DEVORE VIOLATE
19 PETITIONER'S RIGHT TO CONFIDENTIALITY?
Subpoena Duces Tecum and Notice of Deposition, copy attached.
21
v. Legal Authority
22
The treatment records maintained by a licensed counselor are confidential.
23 Mrs. Rife's attorney has issued a subpoena for all records and all communications
between Mr. Rife and Mr. Devore.
24
confidential communications are outside the scope of CR 26·37, and not
25 subject to discovery. The court should enter a protective order.
26 CARL J. GAUL !;'\\\\ \

27
Attorney at Law
W \Ul0J\
1604 Hewitt Ave.
Motion for Protective Order Everett WA 98201
Page 1 425 259-4147 Ff>!/. 259 7081
1 RCW 18.19.180 confidential communications.
2 An individual registered under this chapter shall not disclose the
written acknowledgment of the disclosure statement pursuant to RCW
3 18.19.060 nor any information acquired from persons consulting the
individual in a professional capacity when that information was necessary to
4 enable the individual to render professional services to those persons except:
(1l With the written consent of that person or, in the case of death or
s disability, the person's personal representative, other person authorized to
sue, or the beneficiary of an insurance policy on the person's life, health, or
6 physical condition;
(2l That a person registered under this chapter is not required to treat
7 as confidential a communication that reveals the contemplation or
commission of a crime or harmful act;
8 (3l If the person is a minor, and the information acquired by the person
registered under this chapter indicates that the minor was the victim or
9 subject of a crime, the person registered may testify fully upon any
examination, trial, or other proceeding in which the commission of the crime
10 is the subject of the inquiry;
(4l If the person waives the privilege by bringing charges against the
11 person registered under this chapter;
(5l In response to a subpoena from a court of law or the secretary. The
12 secretary may subpoena only records related to a complaint or report under
chapter 18.130 RCW; or
13 (6l As required under chapter 26.44 RCW.
14
WAC 388-60-0135 What information about the participant must the
1s treatment program keep confidential?
16 (1l Treatment programs must follow the confidentiality requirements
contained in chapter 18.19 RCW for registered counselors and certified
17 professionals.
(2l All program participants and guests must agree in writing not to
18 disclose the identity of group participants or personal information about the
participants.
19 (3l A treatment program must keep all communications between the
participant and direct treatment staff confidential unless:
20 (al The participant has signed a release of information; or
(bl The program is legally required to release the information.
21 (4l The treatment program may audio or video tape group sessions only
when all participants grant written consent that gives details about the
22 specific uses for the tape. The program must obtain an additional consent
statement from each participant to permit use of the tape for any purpose
23 other than the purposes specified in the original consent.
24 WAC 388-60-0145 What releases must a program require a participant to
sign?
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 Fl>:!. 259 7081
1 For a treatment program to conduct case monitoring and periodic
safety checks, the program must require all participants to sign the following
2 releases which must remain in effect for the duration of the client's
treatment:
3 (1l A release allowing the treatment program to notify the victim
and/or the victim's community and/or legal advocates that the perpetrator
4 has been accepted or rejected for treatment;
(2l A release allowing the program to provide the victim with periodic
5 reports about the perpetrator's participation in the program;
(3l A release allowing the current domestic violence perpetrator
6 treatment program access to information held by all prior and concurrent
treatment agencies, including domestic violence perpetrator treatment
7 programs, mental health agencies, and drug and alcohol treatment programs;
(4l A release allowing the treatment program to provide relevant
8 information regarding the participant to each of the following entities:
(al Lawyers, including prosecutors;
9 (bl courts;
(Cl Parole officers;
10 (dl Probation officers;
(el Child protective services, child welfare services, and other DSHS
11 programs;
(fl court-appointed guardians ad litem;
12 (gl DSHS certifying authorities; and
(hl Former treatment programs that the participant has attended.
13 (5l A release for the program to notify any person whose safety appears
to be at risk due to the participant's potential for violence and lethality. This
14 includes, but is not limited to:
(al The victim;
15 (bl Any children;
(Cl Significant others;
16 (dl The victim's community and legal advocates; or
(el Police.
17
An award of attorney fees is mandated whedprote is granted.
18
19
Dated: February 9, 2006
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 fr.;;. 259 7081
02/09/2005 18:20 4252597081 CARL J GAUL PAGE 01
1
2
3
4
COUNTY OF SNOHOMISH
5
6
Jn re the matter of:
7
ANDREW RIFE,
8 Petitioner,
9 and NOTICE OF DEPOSITION UPON
ORAL EXAMINATION
10 JENNIFER RIFE,
11 Re ndent.
12
TO: CHARLES DEVORE:
13
YOU, AND EACH OF YOU, WILL PLEASE TAKE NOTICE that the testimony of
14
Charles Devore, will be taken upon Oral Examination at the instance and request of the respondent
15
in the above entitled and numbered action, before a Notary Public at the offices of Jan M. Dyer, 503
16
17 Twelfth Ave. East, Seattle, Washington, 98102, Thursday the J6<h day of February 2006,
18 commencing at the hour of 10:00 a.m.. Said Oral Examination to be subject to continuance or
19 adjournment from time to time or place to place until completed, and to be taken on the ground and
20 for the reason the said witness will give evidence material to the establishment of the Respondent's
21
case.
22
You shall not be required to be in attendance on the above noted day if the listed materials
23
are provided to Jan M. Dyer, counsel for Respondent at 503 Twelfth Ave. East, Seattle, Washington
24
25 98102 at least 5 days prior to the noted date.
26
DATED this 26th day of January, 2006.
27
28
29
30
Dyer & Primont
503 Tw~lfth AtlC'. E
StAttlt. ~VA 98102
(206) '43·1528
1
' 02/09/2006 18:20 4252597081 CARL J GAUL PAGE 02
1
2
IN 1HE SUPERIOR COURT OF 1HE STATE OF WASHINGI'ON
3 SNOHOMISH COUNTY
4
Jn re the Marriage of:
5 ANDREW RIFE, NO. 05-3-02755-1
Petitioner,
6
and SUBPOENA DUCES TECUM
7
8 JENNIFER RIFE,
Respondent.
9
10
THE STATE OF WASHINGTON, TO: CHARLES DEVORE·
11
12 You are hereby commanded to be and appear in the offices of Dyer and Primont, 503 12"'
13 Avenue East, Seattle, Washington 98102, at HJ:OO a.m. on the 16th day of February, 2006 then
14 and there to testify as a witness in the above captioned matter and to remain in attendance unli.l
15 discharged. You are further directed to and commanded to bring with you for the purpose of
16 copying, reproducing, and entering into evidence the following papers and documents now in
your possession or under your control: Any and all information or documentation in your
17
control relating to the Petitioner, Andrew Rife, dob 3-22-1973, social security # 531-68-8901
18
including but not limited to: progress reports, assessments, evaluations, homework
19
assignments. The obligation shall continue so long as Mr. Rife remains enrolled in your
20
Domestic Violence Treatment Program.
21
22 You shall not be required to be in attendance on the above noted day if the listed
23 materials are provided to Jan M. Dyer, counsel for Respondent at 503 12" Avenue East, Seattle,
24 Washington 98102 at least 5 days prior to the noted date.
25 HEREIN FAIL NOT AT YOUR PERIL
26
DATED this 26th day of January, 2006.
27
28
29
30
Dyer & Primonl
50J 1"wdfth Ave.£
Seattlt, ivA 98101.
(206) 343-1528
2
------------------------------------------
. 02/09/2006 18: 20 4252597081 CARL J GAUL PAGE 03
1
2
3
4
5
IN THE SUPERIOR COURT OF THE STATE OR WASHINGTON
6 FOR SNOHOMISH COUNTY
7
8 ANDREW RIFE, No- 05-3-02755-1
9 Petitioner,
DECLARATION CERTIFYING
10 And AUTHENTICITY OF
11 JENNIFER RIFE, RECORDS
Respondent.
12
13 I, _ _ _ _ _ _ _ _ _ _ _ _ _ declare:
14
I am an employee of and am a duly authorized
15
and qualified witness to certify the authenticity of the attached records.
16
The copies of the records which are enclosed within the attached sealed envelope are true
17
copies of all records maintained by this office as described in the subpoena.
18
These records were prepared in the ordinary course of business at or near the time of the
19
acts, conditions or events described in the records
20
I declare under penalty of perjury that the foregoing is true and correct.
21
22 Executed o n - - - - - - - - - - ' 2006 a t - - - - - - - - - ' _____
Date City State
23
24
25
26 By:
Signature
27
28 Title:
29
30 Dept.
Dyer & Primon t

SOJ Ttvclfth Ave. E
Seattl~ WA 98102
(2Q6) 343-1528
3
• 02/09/2006 18:20 4252597081 CARL J GAUL PAGE 04
2
3
4
5
6 IN THE SUPERIOR COlJ"RT OF THE STATE OF WASHlNGTON

7 FOR SNOHOMISH COUN1Y .
8 In re the. marriage of:

NO. 05-3-02755-1
9 ANDREW RIFE,
Petitioner,
10 DECLARATIO~ OF 1\1.ffi,JNG
and
11
JtNNIFER RIFE,
12
Respondent
1,3
14
15 The undersigned under penaJty of perjury of the laws of the State of Washill~'1:on, states
16 that on this the 27m day of January, 2006, at Seattle, Washington, I deposited in the mails oftbe
17
United States of America, by first class mail, a properly stamped and addressed envelope,
18
19 containing Subpoena Duces Tecum, Notice. of Deposition Upon. Oral Examination and
20 Declaration Certifying Authenticity of Record,s; directed to: Charles DeVore, 304 Lincoln
.21
22
.... ·--·- --· --2"'·-·
24
25
26
27
28
29
30
Dy£.r & Prin1on;
503 t'welfthAr.c. l
Sc.:.~!~, tVA 9S1.0:
(206) 3i3-152'
4
1 ~=u • - ""'t,
ED
2
2006 FEB IO PM z: 19
3
PAM L. DANIELS
\\~U\\CL~\ \11347332
\ \ \ Il ~\~\ \ \Ill\\\~U\I\ \
4 COUNTY CLERK
SNOHOMISH CO. WASH.
5 \\\\\\\\
6
7
9
10
CASE NO. 05-3-02755-1
11
12 ANDREW RIFE,
Petitioner/Plaintiff{s) NOTE FOR TRIAL SETIING AND INITIAL
13 STATEMENT OF ARBITRABILITY
vs. (NITSNA OR STA)
14
15
JENNIFER RIFE,
16 Respondent/Defendant(s)
17
18 TO: The Clerk or the Court; the Direetor or Arbitration (by separate copy serviced at Room 502,
Superior Court Administration) and the attorneys or parties listed below:
19 I hereby affirm that this case is at issue; that no affirmative pleading remains unanswered; that to my knowledge no
other parties will be served with summons; and that the case in all respects is ready for trial and/or transfer to
20 arbitration.
Type of Case: Dissolution with child Estimated Trial Time: Four days
21
22 (Check one)
A jury of 0 twelve is requested and a jury demand and fees have been filed with the Clerk pursuant to CR 38.
23 Osix
(Check one)
24 This case 0 is arbitrable.
25 t8J is not arbitrable.
Please note that as of 12-19-2003 there is a mandatory arbitration fee of$220.00 which must be paid at the
26 time or filing this document with the County Clerk. Documents that indicate the case IS arbitrable that are
submitted without the fee will be returned to the submitting party.
27 NOTE: Arbitrable, oon-jury cases should not be noted for presentation to the Superior Court
28
29 Date (mm/dd/yyyy): ...,0,,_2-'/1"'7-"/2'""0"'"'0_6---,....-----at 10:00 AM this case will be presented to the Court
Administrator's Office for Trial Setting.
30
IT IS NOT NECESSARY TO APPEAR FOR TRIAL SETTING. Dtjer & Primont
503 Twelfth Ave. E
-~
RRU: 07itll/2003
·-
2 This case is ARBITRABLE because: (Check one)

0 The sole relief sought is a money judgment and involves no claim in excess of $50,000 exclusive of any
3 attorney fees, interest and costs (RCW 7.06.020 SCLMAR 1.2) or
4
0 The sole relief sought, regardless of the number or amount of payments, is the establishment, termination or
modification of maintenance or child support payments or arrearages (RCW 7.06.020 SCLMAR 1.2) or
5 0 The undersigned waives any claim in excess of $50,000 in order to have this case arbitrated; or
0 This is a Small Claims matter appealed from District Court.
6
This case is NOT ARBITRABLE because: (Check one)
7 0 Relief other than or in addition to a money judgment is being sought and/or a claim, counterclaim or cross
claim exceeds $50,000 exclusive of attorney fees, interest and costs; or
8 ~ This domestic lawsuit presently involves issues other than or in addition to the establishment, modification
or termination of child support or maintenance payments or arrearages; or
9 0 This case is an appeal from a Municipal or District Court decision (which is not a Small Claims matter); or
0 This case is otherwise statutorily exempt from mandatory arbitration.
10
11 RCW:
12
Civil Cases not subject to MANDATORY Arbitration may be submitted to arbitration pursuant to MAR 8.1 (b),
13 SCLMAR 8.1 and SCLMA 2.1 (d) by stipulation which must be filed with the Clerk of the Court and a copy served
upon the Director of Arbitration.
14
15 0 Th·e undersigned hereby requests that this matter be transferred to arbitration pending formal stipulation by
the parties.
16
17 Any Response to this Statement of Arbitrability must be filed with the Clerk of the Court and a copy served upon the
Director of Arbitration within 14 days after this document has been served and filed. (SC R 2.1 (b))
18
19 I certify that I mailed a copy of this document to
the attorneys listed hereon, postage prepaid on the
20
21 Date (rnmldd/yyyy): -'-02"'1~0"'9n=-'-oo-'-6'------
NAME:
22 NOTE: File the original of this document with the
Clerk of the Court: Serve a copy on the Director of
Jan M. Dyer
23 Arbitration, Room 502, Superior Court ADDRESS:
24 on all parties. 503 l2 1h Avenue East, Seattle, WA 98102
25 TELEPHONE: (206) 343-1528 ext.
26
27 0 Petitioner/Plaintiff
~ Respondent/Defendant
28
29
30
Dyer & Primont
5iJ3 Twelfth Ave. E
Stattle, WA 98102
RRU: 07101/2003
(206) 343-1528
.... ~
1 PLEASE LIST THE NAMES, ADDRESSES, ETC. OF ALL OTHER ATTORNEYS IN THIS CASE
2
3 NAME: WSBA#: 8341
~~~~~~~~~~~~~
4 Carl Gaul TELEPHONE: (425) 259-4147 ext.

5
[8l Petitioner/Plaintiff
6 1604 Hewitt Avenue #302, Everett, 98201 D Respondent/Defendant
7
8 NAME: WSBA#:~~~~~~~~~~~~~
9 Bridget Llewellyn, GAL TELEPHONE: (425) 339-2382 ext.
10 ADDRESS: ATTORNEY FOR: (Check one)

11 3114 Oaks Avenue, Everett, WA 982001 D Respondent/Defendant
12
13 WSBA#:
NAME: ~~~~~~~~~~~~~
14 TELEPHONE: ~<~~>~~~-e_xt_·~~~~

17
18
NAME: WSBA#:~~~~~~~~~~~~
19 TELEPHONE: ~<~~>~~~-"ex~t~·~~~~
22
23
NAME: WSBA#:~~~~~~~~~~~~~
24 TELEPHONE: ~<~~>~~~~ex_t·~~~~-
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
SeRttle, WA 98102
RRU: 07.0112003
(206) 343-1528
12 1. I am over the age of 18 years, and I am not a party to this action.
13 2. I served Jan over, attorney for Jennifer Rife with the following documents:
14 Motion for Protective Order, with attachment

Calendar Note for hearing on February 23, 2006
15
3. The date, time and place of service were !if by mail refer to Paragraph 4 below>:
16 Date: February 9, 2006 at 6:48 p.m.
by fax to 206 348 3998
17 Ms. over's stationery shows her fax number to be 206 348 3998
18 Address: 503 12th Ave. E
Seattle WA 98102
19
4. Additionally, another copy was sent to Ms. over by ABC Legal Messengers, Inc.
20
5. Other: on February 17, 2006 at 5:50 p.m. I faxed a copy of this declaration
21 of service to Ms. Dyer at her fax number listed above.
I declare under penalty of perjury under the laws of,.)he state of Washington that the
22
foregoing is true and correct. / . //
23
Dated: February 17, 2006 /
24 CA J. GAUL # 8341
Attorney for drew Rife
25
26
CARLJ. GAUL
t \I· \ {' \
Attorney at Law
"' ~ \
(1- . , ,1", . . \ ·-· 1604 Hewitt Ave.
DECLARATION OF SERVICE ' Everett WA 98201
425 259-4147 fp;j. 259 7081
·'\ ' v..r
1
CL 11912236
F \LED
2 06 FEB I 1 Pt\ 2: 52
.. Atl L OAH\ELS
3 t' ouNT y CLERK
SNOCHOHISH CO. WASH.
4
5
6
7
9
10
ANDREW S. RlFE, NO. 05-3-02755-1
11
Petitioner,
12 and RESPONSE TO PETITIONER'S
MOTION FOR A PROTECTIVE
13 ORDER RE DISCOVERY
JENNIFER R. RIFE,
14 Respondent.
15
Into court comes Jennifer Rife who, through her undersigned attorney,
16
respectfully request that this court deny the Petitioner's request for a Protective Order
17
preventing her from discovering information relating to Andrew Rife's participation in a
·1a
Domestic Violence Treatment Program. The request is based on the following:
19
20
I. The Motion for a Protective Order was not served in a timely fashion. The
21
motion was delivered to counsel for Respondent on Feb. 13· 2006 for a
22 hearing on Feb. 23, 2006. It also contains no declaration to support the
23 motion.
24 2. This matter is noted on the Commissioner's Domestic Motion Calendar.
25 According to SCLCR 7(2)(1), discovery motions are to be held on the Court
26 Commissioner Civil Calendar, not the Domestic Motion Calendar.
27
28
29
30 RESPONSE TO
PETITIONER'S MOTION
FOR A PROTECTIVE ORDER Dyer & Primont
503 Twelfth Ave. E
RE DISCOVERY
Page I n. l r- ~ • I ..~ L Seattle WA 98102
1 Q/
0 ;.__. > • I ; : I
l '\ l '--"' i i ..: ,-,
(206) 343.1szy
1 3. The information sought is material to the Respondent's case and should be
2 released.
3 a. There is currently a temporary Domestic Violence Protection Order as
4 well as a Criminal No Contact Order stemming from Mr. Rife's criminal
5 domestic violence charges in Everett Municipal Court. See attached
6 Exhibit A.
7 b. Mr. Rife has been ordered to successfully complete a state certified
8 Domestic Violence Treatment program.
9 c. Mr. Rife enrolled in a Domestic Violence Treatment Program at Davis and
10 Associates in June of2005 but was subsequently terminated from that
11 program for non-compliance in August of2005 .. See attached Exhibit B.
12 d. Mr. Rife has apparently now enrolled in Mr. DeVores Domestic Violence
13 Treatment Program.
14
e. The information sought has already been provided to the Guardian Ad
15
Litem in this matter and she has shared that same information with the
Respondent and moving party.
16
f. The information sought has already been provided to the below signed
17
counsel. On Monday, February 13, 2006, the same day we received
18
Petitioner's motion for a Protective Order, we also received a copy of Mr.
19
Rife's file from Mr. Devore. Mr. Devore even included a copy of Mr.
20
Rife's motion with his file, so he appears to have been aware of Mr. Rife's
21
request that the information not be released.
22
4. Mr. Rife has refused to sign any releases, even releases that would allow his
23
treatment provider to, "provide the victim with periodic reports about the
24
perpetrator's participation in the program" WAC 388-60-0145 (1) and (2), a
25
releases that allows the treatment program to, "provide relevant information
26
regarding the participant to each of the following entities: Lawyers," WAC
27
388-60-0145 (4)(a) or a release that allows the treatment agency to "notify any
28
person whose safety appears to be at risk due to the participant's potential for
29
violence and lethality," WAC 388-60-0145 (5).
30 RESPONSE TO
PETITIONER'S MOTION
RE DISCOVERY 503 Twelfth Ave. E
Page 2 Seattle, WA 98102
(206) 343-1528
1 5. Confidential communications are not outside the scope of Civil Rules 26
2 through 37.
3 6. Counsel for Mr. Rife has refused to confer in good faith, and in fact has made
4 no effort to confer with counsel regarding this discovery, as required by
5 CR26(i), "Any motion seeking an order to compel discovery or obtain
6 protection shall include counsel's certification that the conference
7 requirements of this rule have been met." No such conference has ever taken
8 place and counsel for Mr. Rife attaches no such certification to his motion.
9 7. Mr. De Vore will certainly be called as a witness at trial. The respondent and
10 moving party will definitely be calling him as a witness at trial and we would
11 also expect that Mr. Rife would be calling him as a witness at trial.
12 8. We are asking that the court deny and award Ms. Rife $1,500.00.00 in
13 attorney fees and sanctions for Mr. Rife's failure to note this motion timely
14 and correctly, for their failure to confer with counsel prior to bringing this
15 motion and for their refusal to sign releases allowing information required by
the Washington Administrative Code to be released to the relevant parties.
16
This motion for a protective order is without merit.
17
Respectfully submitted this l 71h day of February 2006.
18
19
20
21
22
23 I have read the foregoing response t for a protective order.
24 The factual information contained therein is based on my own personal knowledge
25 and it asserted under penalty of perjury of the laws of the State of Washington and is
26 true and correct. Signed and dated this l 71h day of February 2006 in Seattle,
27 Washington.
28
29
30 RESPONSE TO
PETITIONER'S MOTION
RE DISCOVERY 503 Twelfth Ave. E
Page3 Seattle, lVA 98102
(206) 343-1528
.· \
.- .
FILED
05 OCT -3 PM 3: 22
r:.i·1 L. [);;r·JIELS
COU11TY CLERK
S~JOHO!~ISH CO. ri .'.SH
05-~-01269-I
SUPERIOR COURT OF WASHINGTON NO.
p.p_e. TEMPORARY PROTECTION ORDER AND

NOTICE OF HEARING (HARASSMENT)
,Jenniflv R. l!1fe._
Petitioner (First Middle Last Names)
& ~ ~DOB
(TMORAH)
(Clerk's action required)
VS, NexDijring Dateffime:~
(}[_~ / 71 200:Jf. I :00 P.M.
At: Snohomish County Courthouse, st oar,
3000 Rockefell r Avenue, Everett, WA, 98201
Department B IIC
WARNING TO THE RESPONDENT: Violation of the provisions of this order with actual notice of
its terms is a criminal offense under chapter I 0.14 RCW and will subject a violator to arrest. Willful
disobedience of the terms of this order may also be contempt of court and subject you to penalties
under chapter 7.21 RCW.
Minors addressed in this order:
Name (First, Middle Initial, Last) Age Race Sex
7 II 11V1J;Yl C ~ C11 I /7: LI,, I ('I_ ~
J
Based upon the petition, testimony, and case record, the court finds that the respondent committed
unlawful harassment as defined in RCW 10.14.080, and IT IS THEREFORE ORDERED THAT:
Respondent is RESTRAINED from making any attempts to keep under surveillance petitioner
and any minors named in the table on page one.
Respondent is RESTRAINED from making any attempts to contact petitioner and any minors
named in the table on page one.
TEMP PROTECTION ORD/NT OF HRG (HARASSMENT) (TMORAH) • I of2

UH-03.0200 (912004) CR 65(b), · RCW 10. 14.080 (I), (2)
Cler~:s Office: S:IFORMSIFCOURTSERVICES\Anti-Harassment\AH Petition 1·~~11:,•§po17~r,h;tl·doc
EXH!BIT ~• I
':fi~·11u
·""' :ff! ~ • AL
'. v ..
Other:
It is further ordered that the clerk of court shall forward a copy of this order on or before the next
&ial day to: 0 · County Sheriffs Office
N_ Pt
!B(f'1f Police Department WHERE
PETITIONER LIVES which shatt';,nter it in a computer-based criminal intelligence system available
in this state used by law enforcement to list outstanding warrants.
DThe clerk of court 0 petitioner shall forward a copy of this order on or before the next judicial day
to:
Q-_--------~~--.+------·_county Sheriffs Office
ID- tiJf'rP ff Police Department WHERE
RESPONDENT LIVES which shall personally serve the respondent with a copy of this order
and shall promptly complete and return to this court proofof service.
OR 0 Petitioner has made private arrangements for service of this order.
OR 0 Respondent appeared; further service is not required.
The respondent is directed to appear and show cause why the court should not enter an order for protection
effective for one year or more and order the relief requested by the petitioner or other relief the court deems
proper, which may include payment of costs. FAILURE TO APPEAR AT THE HEARING OR TO
OTHERWISE RESPOND WILL RESULT IN THE COURT ISSUING AN ORDER FOR PROTECTION
PURSUANT TO CHAPTER 10.14 RCW EFFECTIVE FOR A MINIMUM OF ONE YEAR FROM THE
DATE OF THE HEARING. THE NEXT HEARING DATE AND TIME IS SHOWN BELOW THE
CAPTION ON PAGE ONE.
A copy of this Temporary Protection Order and Notice of Hearing has been filed with the clerk of the
court.
....... -·
This Temporary Order for Protection is effective until the next hearh1g d~te and time shown below
::~::~~~n;;g;;;;· at 3:1 ~~ .m. K:b~

E/COU RTGSJMMISSIONER-·
- .. - -
I acknowledge receipt of a copy of this Order: I acknowledge receipt ofa copy of this .Order:
~444;;,1.) 'I(. -&jv

ettttoner
IO/o3/tJS"
Date Respondent Date
TEMP PROTECTION ORD/NT OF HRG (HARASSMENT) (fMORAH)- 2 of2

UH-03.0200 (9/2004) CR 65(b), - RCW 10.14.080 (I), (2)
Clerk's Office: S:IFORMSIFCOURTSERVICES\Anti-Harassment\AH Petition Packet\3-Temporary Order AH.doc
EXt!!BIT __._~.._-.....\ -
FILED
06 JAN 30 AM IQ: 19
? f,M L. Df,NIEt.:5
COUNTY CLERK .
SNOHOtllSH CO. vu;sH

NO. OS-2 -0120~-2
REISSUANCE OF TEMPORARY
_._Ao~;ew0tut±
ORDER FOR PROTECTION AND
NOTICE OF HEARING (ORRTPO)
Respondent (Firs~Middlc,Last Names) (Clerk's Action Required)
~ The Temporary Order for Protection issued on '\ \. - \ - _. S""' , is hereby extended
• through the new ru'\hearing date on this matter On ""C-r<..~ °?. <!) I c uo ( ,at 1:00
p.m. in Dept. B 'V'' floor, 3000 Rockefeller Avenue, Everett, WA.
D Other:
--------------------------------
The Clerk of the Court shall forward a copy of this order on or before the n:cu~icial day to the
cy:J County Sheriff's Office aJ. tYC+f Police
• Department where petitioner lives which shall enter this order in any computer-based criminal intelligence
system available in this state used by law enforcement to list outstanding warrants.
O·the Clerk of the Court shall also forward a copy of this order on or before the next judicial day to
_ _ _ _ _ _ _ _ _ _ _ County Sheriff's Office Police Department
where respondent lives which shall personally serve the respondent with a copy of this order, the Temporary
Order, and the Petition, and shall promptly complete and return to this court proof of service.
0 Petitioner has made private arrangements for service of this order.
0 Petitioner shall serve this order by 0 mail 0 publication. · ·
t%J Respondent appeared and was informed of the order by the court; further ser:vi '·i~ nqt re~uir~d.
. .
Presented by: I acknowledge r.eceip( of a copy of thisoOrder.
~·-.~-------1/k/o~
Respondent · . •· :; ~ bate I
REISS OF TEMP ORD FOR P CTJON/NT HRG (ORRTPO}- Page I on

WPF DV-l.010 (912004). RCW 26.50.060(3)
0RIGINAL
CLERK'S OFFICE: S:IFORMSIFCOURTSER.VJCES\Domcsti~io~cc\Rcissuancc Ord•.
EXH!BIT __.___,,__'---
JENNIFER RIFE PAGE 01/12
10/13/2005 12:56 4253041333
.. .,
IN THE EVERETT MUNICIPAL COUitT, SNOHOMISH COUNTY, WASHINGTON
CITY OF EVERETI, ) CASE NO. CR/.alTJO

)
Plaintiff, )
NO CONTACT ORDER ·
~~,-(~\r=G .. ··.
·•· ·'•·· .,, )
)
) ~Pre-bi~ CERTIFIED COPl
·. . .··:. . .. ..
) 0 Post-conviction
~~~--=D~e~fe~n~dan~t·~~~-~-...--l
D~FENDANTINFORMATION: DOB:~h3 ff}

SEX RACE uJ
HT5'g" WT 175 EYES ,/SUI.. HAIR~
THE COURT finds·that the defendant has been charged with, arrested for, or convicted of a domestic
violence offense, and further finds that to prevenfpossible recurrence of violence, this Domestic Violence No
Contact Order shall be entered pursuant to RCW 10.99 and EMC 10.22.
IT IS HEREBY ORDERED THAT, pursuant to RCW 10.99.040, RCW 10.99.050, EMC 10.22.010 and
EMC 10.22.020 the DEFENDANT shall have no contact, directly or indirectly, in person, in writing, by telephone,
by mail, or by an other means with:
NAME: -:J.i.™W.f.I£>JU~:6:__.(5.'tf)J.l&::~
or knowingly come within or remain within feet of his/her residence.
0 For a period of one (1) year OR D~:5.-L-<--O_.._i]_,.__ _ _

l}?(until_--"l..... . ··_··_
WARNINGS TO DEFENDANT
VIOLATION OF THE TERl\{S OF THIS ORDER WITH ACTUAL NOTICE OF ITS TERMS IS A
CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL SUBJECT A VIOLATOR TO
ARREST. ANY ASSAULT, DRIVE-BY.SHOOTING, OR RECKLESS ENDANGERMENT THAT IS
A VIOLATION OF THE ORDER IS A CLASS C FELONY. YOU CAN BE ARRESTED IF ANY
PERSON PROTECTED BY THE ORDER INVITES ORALWWS YOU TO VIOLATE THE ORDER'S
PROlilBffiONS. YOU HAVE THE SOLE RESPONSIBILITY TO AVOID OR REFRAIN FROM
· VIOLATING THE ORDER'S PROVISIONS. ONLY THE COURT CAN CHANGE THE ORDER.
A VIOLATION OF TlllS NO CONTACT ORDER INVOLVING STATE LINES TR;\YELA~OSS

OR THE BOUNDARY OF A TRIBAL LAND, OR INVOLVING CONTACT WITHIN THE SPECIAL
MARITIME AND TERRITORIALJURISDICI'ION OF THE UNITED STATES, WHJCH INCLUDES
TRIBAL LANDS, MAY SUBJECT YOU TO CRIMINAL PROSECUTION IN FEDERAL COURT. IN .
ADDffiON, FEDERAL LAW PROHIBITS YOU FROM OWNING OR POSSESSING A FIREARM
WHILE THIS ORDER IS IN EFFECT.
A COURT IN ANY OF THE SO STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO AND
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 Prosecutor shall forward a copy of this order to .the record keeping agency,
which shall duly enter the order as indicated above. .
Done in open court in the pr
·~
Defendant Received -..J:.6."""'==JjZ:...-=-===d;;r~0 '<..
I 0123/00 ORIGINAL - Court CANARY - Defendant PINK - EPD GOLDENROD - Copy PD 322
EXt{'.131T ~-"L
01/17/2006 03:02 4253483676 ET5 PAGE 07
·.
Davis & Company

Domestic Violence/Ange.- Management Program
3105 Hoyt Ave, Suite A
Everett, WA 98201
Phone (425) 388-0277
Fax (425) 252-8527
MONJHLYPROGRESSREPORT
July I, 2005
TO: Everett Municipal Court
2930 Wetmore Avenue
Everett, WA 98201- 4073
RE: Rife, Andrew

CASE#: CR 67770
DOB: 3/23173
TREATMENT MODALITY COMPLIANCE Y 0 N CXl

Group Counseling: Yes Dates:
Missed Dates: Excused Y 0 N () Missed:
Individual Counseling: Dates:
Missed Dates: Excused Y 0 N () Missed:
Information Classes: Dates:
Statement of progress: Mr. Rife has not been attending as required. We are
closing his file at this time.
Recommendation: Referring Mr. Rife back to the court.
If final report, summary/prognosis: Prognosis for Mr. Rife appears to be poor

due to the fact that he has not completed bis treatment program.
Kit Davis ./'/a__

Counselo~ M.A.C. Anger Program Specialist
State Certified Provider, Supervisory Level
_-=='--
EXil!81T'l:i
'•
...
.. ;. '....
,_
FILED
05 FEB 2 r AM iI: 3s
111111111111111111111111111111111111111111111111111111111111
CL 11249692 i-'t1M L. DANIELS
COUNTY CLERK
SNOHOMISH CO. \'/II SH.

Andrew Rife,
No. 05-3-02755-1
vs. COVERSHEET
Jennifer Rife,
Defendant/Respondent
ATTACHED HERETO IS:
Notice of Trial Setting
S:\FORJ\IS\Co"·er Sheet.DOC - 1
TO:
Carl Joseph Gaul

Attorney at Law
Suite 302
1604 Hewitt A venue
Everett, WA 98201
Date: February 17, 2006
Fold Bili!
NOTICE OF TRIAL SETTING
and
CERTIFICATE OF TRIAL CONFIRMATION
RE: Cause No.: 05-3-02755-1
Andrew Rife
Plaintif17Petitioner
vs
Jennifer Rife
This is to notify you that the above case has been set for Non-Jury trial on August 21, 2006
at 9:00 am, in the Superior Court, Presiding Judge's Department, Courthouse Building.
Court Administrator
Snohomish County Superior Court
IMPORTANT NOTICE: Your attention is directed to SCLR 40(d) and CR 41(e) which read as follows:
SCLR 40(d) TRIALS- CONFIRMATION
It shall be the duty of each attorney of record or party pro se in a case set for trial to jointly or
separately confirm, no sooner than 12 noon of the first court day of the week [817/2006) and no later than
12 noon of the last court day of the week [8/11/2006] two weeks prior to the trial date, in such written
form as approved by the court. The court may strike the trial date and may impose sanctions and/or terms
against the parties or counsel for failure to so confirm.
CR41(E)
Notice of Settlements. If a case is settled after it has been assigned for trial it shall be the duty of
the attorneys or of any party appearing pro se to notify the court promptly of the settlement. If the
settlement is made within 5 days before the trial date, the notice shall be made by telephone or in person.
All notice of settlement shall be confirmed in writing to the clerk.
UTILIZE THE NEXT PAGE OF THIS LETTER OR A COPY THEREOF
AS THE FORM FOR CERTIFICATE OF TRIAL CONFIRMATION.
TO:
Janis Marie Dyer

Attorney at Law
502 - 12th Avenue East
Seattle, WA 98102

and
RE: Cause No.: 05-3-02755-1
Andrew Rife
vs
Jennifer Rife
'
Court Administrator
- fllli!
IMPORTANT NOTICE: Your attention is directed to SCLR 40(d) and CR 4l(e) which read as follows:
SCLR 40(d) TRIALS - CONFIRMATION
separately confirm, no sooner than 12 noon of the first court day of the week [8/7/2006] and no later than
12 noon of the last court day of the week (8/11/2006] two weeks prior to the trial date, in such written
CR41(E)
... '
TO:
Bridget Llewellyn
Guardian ad Litem
3416 Broadway, Suite 1
Everett, WA 98201

and
RE: Cause No.: 05-3-02755-1
Andrew Rife
vs
Jennifer Rife
Court Administrator
IMPORTANT NOTICE: Your attention is directed to SCLR40(d) and CR4l(e) which read as follows:
separately confirm, no sooner than 12 noon of the first court day of the week [8/7/2006] and no later than
12 noon of the last court day of the week (8/11/2006] two weeks prior to the trial date, in such written
CR41(E)
UTILIZE THE NEXI' PAGE OF THIS LETTER OR A COPY THEREOF
·,
1
2 Illlllll llllll Illlllll l/1111111/ lllll 11111 l l l lllll llll llll
CL 11346340
3
4
5
7
8
ANDREW RIFE,
9 Petitioner,
N0.05-3-02755-1
10
v.
11 SUPPLEMENTAL INFORMATION
JENNIFER RIFE, FOR 2/23/2006 MOTION FOR
12 ·Respondent PROTECTIVE ORDER HEARING
13 .
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Dyer & Primont
503 Twelfth~ve.
E
Seattle,. WA 9 02
0 RI GI ~·.!AL (206) 343-
r\\)
'--'
CHARLES B. De VORE, MA LMHC

304 LINCOLN A VE., ROOM 203
MUKILTEO, WA 98275 (425) 353-0922
Beeause ensuring yout privacy.is a vitalconcem to<us,-pleilse.consult with your therapisfbeforefilling out any of the information
below. ·
CLIENT'S CONSENT FOR

TWO-WAY RELEASE OF INFORMATION
I, ~'O $..J ¥ \. r-;e._ ,

hereby authoriz.e CHARLES B. DeVORE, MA LMHC to release information about
my treatment to and discuss the history of my case with the following individuals and/or agencies: ..
NAME ADDRESS PHONE#
(ALLEGED) VICTIM ZAI <. ,,...., sr

CURRENT PARTNER~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
~ "~ ...;¢7.,.,......_
PROBATION/PAROLE
COURT C~ V\i\~ly~
OTHERS: ALL VICTIM ADVOC4CY PROGRAMS. ALL STATE DOMESTIC VIOLENCE TREATMENT PROGRAMS
ATTORNEY~=~=~=-'-~~G~~-~~\Ji'=--~-.c-i~J~~--~d-S"__,_1-~~q~{-~~2-·~~~~~~~
OTHER~~~{)=-~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-
I agree to allow these individuals and agencies to release to each other, any and all confidential information regarding the treatment
of myself, including but not limited to: psychological, psychiatric, medical, and educational information that may help in treatment.
My consent for disclosure shall expire at the end of treatment (successf\il or termination), allowing sufficient time to complete the
appropriaie reports to the Courts (PO's, etc.) and the victim, unless otherwise specified. I am aware of and expect that all personal
information is confidential except when I give written permission to release and that the specifics of the exchange of information
about me are spelled out more completely in the policies and procedures descnbing CHARLES B. DeVORE'S program and in the
policies of the agencies requesting and receiving the above information, and by State and Federal Regulations. I understand that this
consent can be revoked in writing at any time with the understanding that a final report will be submitted to the Court (PO's, etc.) and
the victim following the receipt of any such revocation. I understand, also, that I may be charged a reasonable fee for the cost of
photocopying records and that this authorization may not be honored until the fee is paid.
C~- . . -Date~1-~~1-'Y~>~,~1~~-3~~~~~~~~~~-
Parent/Guardian Signature Witness (optional)
Therapist
0D I ~ I ' I :'.
l\tvoi.r1
L
,
FILED
06FEB23 PH :52
PAHL.DANIE S
COUNTY CLER
~NOHOHISH CO. · I\ SH.
This matter having come on regularly before the court on the motion of
13 Petitioner for a protective order concerning the discovery subpoena directed to
Charles Devore, a licensed counselor, and the court having considered the records
14 and files herein and the arguments of counsel, and the court being fully advised in
the premises
15
IT IS HEREBY ORDERED that the subpoena is modified as follows
16
1. The information Charles Devore is mandated by statute or administrative
17 code to disclose shall be produced in response to the subpoena.
1s 2. The information which would be disclosed pursuant to any release
authorization Andrew Rife is mandated by statute or administrative code to
19 sign, shall be disclosed whether he has signed such an authorization or not.
20 £\.hl}11lfoymatig.i:rCtYcfrles DEl)IOreJ<aS dis.PFetionxOdis se und~tat1:1tes¥K1
'V'5'.r.ffni~tratilffl cafle may tfe py6ducecYor not/in ti discretiofi ofMf. De'ifore.
21
22
23
24
25
26
CARLJ.GAUL
Attomey at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAA 259 7081
1 6. OTHER
2
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7
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8 \
10
LESTER H. STEWART
FEB 2 3 2006
11 Dated: ~OURT '''MMJSSIONER
ge comm1ss1oner
.. ··
12 Presented by: copy Received:
13
14
CARL J. GAUL WSBA# 8341
15 Attorney for ANDREW scan RIFE
16
17 3 ·
18 /{ti LQUJ,/ ~la ~~< Ot' y

:t> ...
~ tv ~ vi),e411 t-/ ~ Le y
19
20 f?;Y
21
22 ?~ ~ J 'OvJ_ Vl l) \v?{:t,A \i\--fzn't

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23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
FILED
C~ FEB 23 Pii 2= 52
SUPERIOR COURT OF PAM L. D,"\NIELS
COUIJT i' CLERK
WASHINGTON SNOHOHISH CO. \'If, SH.

AND CLERK: CAROLE MACY
JENNIFER RAE RIFE DATE: 02/23/06 @ 9:00 AM
THIS MATTER CAME ON FOR: MOTION FOR PROTECTIVE ORDER #64

ACTION:
HEARING STRICKEN/CODE•
PETITIONER APPEARED• YES COUNSEL' CARL GAUL I I I

RESPONDENT APPEARED• YES COUNSEL: JANIS DYER
FACILITATOR PRESENT• NOT PRESENT
DOCUMENTS FILED•
ORDERS ENTERED: PROTECTIVE ORDER.
BASED UPON THE FACTS PRESENTED TO THE COURT, THE COURT FINDS THE
REQUESTED INFORMATION IS DISCOVERABLE. THE PARTIES WILL REACH AN AGREEMENT
REGARDING WHAT IS TO BE RELEASED AND WHAT IS NOT TO BE RELEASED.
ATTORNEY'S FEES ARE AWARDED TO THE RESPONDENT IN THE AMOUNT OF $500.00,
FEES TO BE PAID WITHIN 30 DAYS.

f'\\
1 ,,, "
· ... ~! \I r-~
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• • • ,1.:_:.
DJI
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1\~\ I111\\I\ l~\ I~\ \1 1 1\ ~1\1\1 1\ \''\II1\\1

I
CL1130B139
?1!05 DEC - 7 Pil 2: 2 I
I L. 0.1\i~IELS
: At
4 COUNTY CLERl~
SNOHOVilSH CO. ¥/ASH.
5

7
8
9 Petitioner
and CALENDAR NOTE
10 (CDMMISSIONER S
1
DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: December 22, 2005
CALENDAR-(Exceptmattersrelatingto DATE SET av AGREEMENT oF' couNsEL
15 trial dates, continuances, and revisions) Daily at 9 a.m.

Nature of Hearing:
16 Court Commissioner
Department B or C, As Assigned REVIEW HEARING ON TEMPORARY ORDERS
17
18
matter, please indicate Court Commissioner COMMISSIONER BEDLE
19
and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for tri I-settings. S . 40(b).
21 I
Dated: December 5, 2005
22
23
24
25
26
27
28
CALENDAR NOTE
(COMMISBIONER B
1
DOMESTIC MOTION CALENDAR)
CARLJ.GAUL
Allorney al law
Everett WA 98201
(425) 259-4147 Fax 259-7081
3
<f:
1
FILED
2
3 2005 DEC -9 PH 2: 28
4 r·AM L. DANIELS
COUNTY CLERK
\ ~\I\~\l\~I\~~~1\\1
5 SNOHOMISH CO. WASH.
6 Il\\l\\llll\n\111\\111\\\11111
CL 11309904
7
9
10
Inre:
11 ANDREW RIFE,
Petitioner, NO. 05-3-02755-1
12
And
13
JENNIFER RIFE, NOTICE OF ABSENCE OF
14 Respondent COUNSEL
15
16
TO: CLERK OF COURT
17
AND TO: All parties and counsel of record.
18
19 PLEASE TAKE NOTICE that Jan Dyer will be out of the State or otherwise unavailable
20 from December 16, 2005 to January 3, 2006. It is requested that motions and other court hearings
21
scheduled so there is sufficient time to prepare for them following the end of the absence. There is
23
no other attorney available with sufficient factual knowledge of this case to respond to any
24
25 substantive request for relief during my absence.
26 Dated this 6th day of December, 2005.

27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
z;
Seatth, WA 91n02
't-~i l)' •._I'.

O " ' l 'l
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1 \ I V l l ••
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I Fl l_ F n
I
! lllll/l llllll Ill llllllllllIll/I lllll lllll llllllllll llll II/I
CL 11751082
05 tl~R 20 A;i ·9: 28
,., __ ... :,J_S
· Cbui~iTY cLr:::;;~
SNOHOHISH CO. l'I ASH.
IN THE SUPERIOR COURT OF THE STATE OF WASHING TON

Q,Cr PLAINTIFF I PETITIONER

)
)
)
)
Rc.:_nd )
)
NO. O 5 - ·3 .. o ·-z.. 7 SS ·- I
)
)
I: IS HEREBY ORDERED: -=· ~ /M_ri-, ,,____ -c~ ~"":°" 1 b /' L ~

iS,~C~yl ~~~,1= /!;;;~7
I I
DONE IN OPEN COURT this date: --.~77!,_2.='-o,l_t0=--:::k:::::::::--
l I
Copy Received:
.c:J' "'.v i) '"1 "4'
6101 pago1of2 ~ ~-
- · hr ,~J
f\LED
Ob \'\~R 20 ~M \Q: Li 2
11WJl~~ll~IJ~~'--··~~
IL--------~- 0'IUll~. • SUPERIOR COURT OF
WASHINGTON
PAii L. OAHIELS
COUNT·; CLERK
sNOHOHiSH CO. 'rl f. SH.

(PETITIONER) PRO TEM COMM: DONALD A. SENTER
AND CLERK: S. HUBER
SANCTIONS; REVIEW HEARING.
CONTINUED/HEARING DATE SET AND CALENDAR/CONTINUANCE CODE: 04/19/06 @ 9 AM (D2) HCNTSTP
ACTION: PRESENTATION OF ORDER DENYING MOTION FOR BAD FAITH SANCTIONS
ACTION: REVIEW HEARING #58
ACTION: * TO BE HEARD WITH CAUSE #05-2-01268-2 *

FACILITATOR PRESENT: NOT PRESENT
DOCUMENTS FILED:
ORDERS ENTERED: ORDER, TO BE FILED BY COUNSEL GAUL.
THE PARTIES' REQUEST THAT THIS MATTER BE CONTINUED IS GRANTED. THIS

MATTER TO BE HEARD WITH CAUSE #05-2-01268-2.

1 FILED
2
06 APR I 11 Pri :2: 28
3
I1111111111111Ill1111111111111111111111111111111111111111111 PAM L. D;HJIELS
SNOHOMiSH CO. WA SH.
5
6
7
9
10
ANDREW RIFE,
11 Petitioner,
NO. 05-3-02755-1
12
and
13 NOTICE OF ABSENCE OF
JENNIFER RIFE, COUNSEL
14
Respondent.
15
16
17
TO: CLERK OF COURT
18 AND TO: All parties and counsel of record.
19
20 PLEASE TAKE NOTICE that Jan M. Dyer will be out of the State or otherwise unavailable
21 from May I 0, 2006 through May 23, 2006. It is requested that motions and other court hearings not
22 be scheduled to occur during the time of this absence and that motions and other hearings be
23 scheduled so there is sufficient time to prepare for them following the end of the absence. There is
24 no other attorney available with sufficient factual knowledge of this case to respond to any
25
substantive request for relief during my absence.
26
Dated this 3rd day of April, 2006.
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
a06>~
ORlGlt~AL
1\o
\\\\\\\\ \\\\\\ \\\ \\\\\\\\\\\\\I\\\\\\ \\\I\\\\\\ \I\\\ \Ill\\\\
CL11261215

)
)
)
Y(-K_ and l No.BS- 3-o'2?55-.J
,~
)
DEFENDANT/ RESPONDENT ) ORDER
)
)
7
DONE IN OPEN COURT this date: ---lllM~A¥l-410-i!3'-<2:.UJ00LW6---
i?f"3 1 JUD E OUR COMMISSIONER
&01~ \'c,,,~, ~~L-@~<\

B~e-t ew~-µ «(~
;~!LED
[ilMj~~!~IJDDm
t,otiAY-3 AHll=59
SUPERIOR COURT OF
:'A~i L. DJ\ NIELS
- - . - - --- ________, FOR SNOHOMISH COUNTY >NOHOMISH CO. I'/ f. SH.

AND CLERK: S. HUBER
SANCTIONS REVIEW HEARING.
ACTION:

GUARDIAN AD LITEM APPEARED: BRIDGET LLEWELLYN
DOCUMENTS FILED:
ORDERS ENTERED: ORDER, TO BE FILED BY COUNSEL DYER.
THIS MATTER WAS HEARD WITH CAUSE #05-2-01268-2.

THE GUARDIAN AD LITEM HAS NOT COMPLETED HER REPORT. THE PARTIES CAN
RENOTE THE MATTER WHEN THE REPORT IS COMPLETED, OR EITHER PARTY CAN BRING A
MOTION UPON NEW FACTS OR CIRCUMSTANCES.

1
' ' -
2
3
2006 JUN 15 Pi'l z: 18
PAt'i L. DAi!IELS
4 COUNTY CLERK
SNOHDi'ilSH CO. \'./ASH.
5
6
7
9
10
ANDREW RIFE,
11 Petitioner,
NO. 05-3-02755-1
12
and
JENNIFER RIFE, COUNSEL
14
Respondent.
15
16
17
TO: CLERK OF COURT
19
21 from July 3, 2006 through July 11, 2006. It is requested that motions and other court hearings not
22 be scheduled to occur during the time of this absence and that motions and other hearings be
23 scheduled so there is sufficient time to prepare for them following the end of the absence. There is
24 no other attorney available with sufficient factual knowledge of this case to respond to any
25
substantive request for relief during my absence.
26
Dated this 12th day of June, 2006.
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
a06J 343-1528
ORIGINAL
FILED
: I \ \\\\\\\ \\\\\\ \\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\ \\\\ 2006 JUN 23 AH 11: 40·
3 CL11755792
PAM L. DANIELS
4 COUNTY CLERK
SNOHOMISH CO. WASH.
5
6 INTHESUPERIORCOURTOFTHESTATEOFWASHINGTON
FOR SNOHOMISH COUN1Y
7
8 No. 05-3-02755-1
9 ANDREW RIFE,
Petitioner, MOTION AND DECLARATION TO
10 COMPELANSWERS TO
11 INTERROGATORIES
and
12
13 JENNIFER RIFE,
Respondent.
14
15
Respondent moves the court for an order compelling Petitioner to answer the
16
interrogatories propounded, as more particularly described in the attached declaration. This
17
18 motion is based upon Civil Rule 26 and 37 and, pursuant to Civil Rule 37(a)(4). Respondent
19 requests that she be awarded her costs incurred in bringing this motion, including reasonable
20 attorney fees regardless of whether or not the petitioner supplies the respondent with answers
21 prior to the court hearing this matter. Respondent also request that petitioner be prohibited from
22
testifying to any matter for which he does not provide complete answers to the discovery request.
23
24
Respectfully submitted this 22"d day of June 2006.
25
26
27
28
29
30
Dyo&Pt<
503 Twelfth Ave. E
Seattle, WA 98102
ORIG/Nld
(206) 343-1528
1
DECLARATION
2
3
I am counsel of record for Jennifer Rife. On April 18, 2006 my legal assistant
4
5 messengered to Mr. Gaul, attorney for petitioner Andrew Rife our requests for answers to
6 interrogatories and request for production. The answers were due back on May 19, 2006, but
7
were not provided. On May 23, 2006 I sent a letter to Mr. Gaul (see attached) scheduling a
8
9 telephonic Lr37 conference for June I, 2006 at 10:00 am. At 10:00 a.m. June I, 2006 we called
10 Mr. Gaul's office and was told he was unavailable. Our Lr37 conference was re-scheduled for
11
I :30 pm the same day. At I :00 pm that day Mr. Gaul faxed a letter (see attached) to our office
12
indicating that the interrogatory answers would be provided June 12, 2006. Today is June 22,
13
14 2006 and answers to those interrogatories have not been received. Trial in this matter is set for
15
August 21, 2006.
16
I am requesting that even if answers are provided before this motion is scheduled to be
17
18 heard that the court still order payment of fees and prohibit the Petitioner from testifying at trial
19
to any matter for which he does not provide complete answers to the discovery request.
20
21
22 foregoing is true and correct. Dated June 22, 2006.
23
24
25
26
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
OR/Gl~:~
Seattle, WA 98102
Q06) 343-1528
~. .....
'
1 RECEIVED
2 APR 1 9 2006
3 : . . . lAW OFFICE OF
IN THE SUPERIOR COURT OF THE STATE OF WASHING'JJMllM. DYER
4 IN· AND FOR SNOHOMISH COUNTY
5
In Re the Marriage of
6
7 ANDREW RIFE, N0.05-3-02755-1
Petitioner
8 and RESPONDENT'S FIRST SET
9 OF INTERROGATORIES ·
AND REQuESTS FOR PRODUCTION.
10
11-+~~~~~~--'--~~~~~~.!.._~~~~~~~~~--'--~-'--~~~
TO: Andrew Rife, Petitioner.
. 12
13 AND TO: Carl Gaul, his attorney of record.
.,
14
Definitions and Procedures CJUU, J. GAUL
15
AttGrney at L-1vi
16 A. Procedure for futerrogatories.
17
PurSuant to Rule 33, Civil Rules for Superior Court,. State of Washington, please answer
18 . each of the following .interrogatories, separately and fully, in writing, under oath. The
19 answers are to be signed by the party to whom they are' addressed andmust be served within
thirty (30) days after service of the interrogatories.
20
21 These interrogatories call for all information (including information. contained· in or on
writings, computer files, recordings, photographs or any other tangible thing or material)
22
· that is known or available to you; including· all inforination in the possession of your
23 officers, employees, agents, attorneys, accountants, auditors or other professional persons or
experts and any investigators or ·any person acting in your behii!f or under your or your
24
attorney's employment, direction and/or control ·
25
26 . If you cannot answer any interrogatory fully and completely after exercising due diligence
to make inquiry and secure the information to do so, ·please so state and answer each
27 uiterrogatory to the extent possible. Specify that portion of each interrogatory you claim
28 you 'are unable to answer fully and completely, and further specify the facts on which you.
rely to .support your contention that you are unable t9· answer each such interrogatory fully
29
.and. completely. State what knowledge, information
- or belief you
. have concernin.g the · ·
30
Dyer & Primont
503 Twelft~ Ave. E
Seatle, WA 98102
(206) 343-1528
•" . ',. '
DYER AND PRIMONT

. Attorneys qt law
50512">. Avenue E
Seattle, WA 98102
. 206/343-1528
May 23, 2006
Carl Gaul
1604 Hewitt Avenue #302
·Everett, WA 98201
Re: Rife v. Rife 05-3-02755~1 ·
Dear Mr. Gaul,

. .
On April 18, i006 , you were sel"Ved with a .sef of Interrogatories aJid Requests for Production .
· for you client, Andrew Rife, to respond to, More than thirty days have elapsed since that time. ·
Hence,
..
the
, answers are now overdue> ·
'
Because this matter appears to be proceeding to trial, I must insist upon receiving the answers
inunediately. Pursuant to Local Rule 37, I have scheduled a telephonic discovery conference
for Thursdriy, June 1", 2006 at 10:00 am; my office will initiate the call. I will expect either ·
complete answers to the interrogatories before that time, ,or to speak with you on that 'date tci
determine why the answers have not been provided .. Please let my office know if this time ·will·
not work for you·so we can choose a differ~nt mutually agreed upon time.
lfthe·answers are not satisfactorily provided by the conclusion of the conference, then we will ..
move for an order compelling the answers. If you have any qudtions, please do not hesitate to
contact my office. . . . .
Best regards,
' ' Cc:. j <,•.1 ~- R_
',
Date: 6/112006 Time: 1 :00:30 PM Page 1 of 1
'"
0 Frp~m:._carf 425 259 7081 To: jan dyer
'
CARLJ.GAUL Attorney at Law 42.S 2.S9-4147 fax 423 259·7081
1604 Hewitt Avenue
Everett WA 98201
June 1, 2006

503 Twelfth Ave. East RE: Discovery
Seattle WA 98102
Dear Ms. Dyer
Thank you for your recent inquiry concerning discovery. Mr. Rife has provided draft answers
to the interrogatories and the requests for production propounded. Upon reviewing them, I notice
a few answers appeared to miss the question asked and I believe a few more documents need to
be acquired. I expect to meet with Mr. Rife on this subject Monday, June 5. I would expect him to
complete his supplementation of responses by the end of that week and to provide the discovery
responses to you approximately June 12.
Thank you for your continuing courtesies.
Yours truly,

To Avoid Delay
CARLJ.GAUL
OG:mg
cc: Andrew Rife
cc: Andrew Rife <.. Q..~ "'.\ c. • ~ .\:: . +l--.•) d..L.>t o

Bridget Llewellyn
l<L'>==1 '-"- f. ._,....,
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s .... 1........_...Q~\...,....Q
i,. v-\- I"'- r . c. -
0-':- ~ \~1~ ~- ........ - ~ >c-.\

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FIL.ED
200& .JUN_2 3 AH 11 : I+ Q.
I lllllll llllll Ill lllll lllll 111111111111111111111111111111111 rAli L. DANIELS
CL11755791 COUNTY CLERK
SNOHOMISH CO. YIASH.

CASE NO. 05-3-02755-1
ANDREW RIFE CALENDAR NOTE: (NTC)

Petitioner
FAMILY LAW MOTIONS
This form must be filed with Clerk not later

vs. than twelve (12) calendar days pre<eding
date requested. SCLCR 7(b)(2)(C). Responses to
motion must be filed five (S) £!!!!!:! days before the
JENNIFER RIFE bearing. Replies to responses must be filed three (3)
Respondent court days before the bearing.
TO: The Clerk of Court:
FAMILY LAW/DOMESTIC CALENDAR Date Requested July 13.. 2006

Daily at 9:00 am.
Depanrnent B or C as assigned. Nature of Hearing: Motion to Compel
(Confirm at (425 388-3587)
CHILD SUPPORT MODI FICATIO NS Date Requested (mm/ddlyyyy): _ _

Mondays at I :00 p.m. OR
Fridays at 9:30 am. Depanrnent D Nature of Hearing: _ _
For Hearings Scheduled on or after Sept. 6, 2005
(Confirm at (425 388-3587)
PRO SE DISSOLUTION CALENDAR Pro Se Dissolution Calendar

Wednesday at 12:30 p.m. only Date Requested (mm/ddlyyyy): _ _
Depanrnent C
(No confirmation required)
Matters set before a Court Commissioner will be assigned later to a particular depanrnent. The assignment will be
posted the day of the hearing. Extended motions are set by the Court Commissioner, not a party or by counsel. If a
presentation, or if a particular Court Commissioner has already heard a recent motion in the matter, please indicate that
Court Commissioner here: Comissioner Lester Stewart
S:\Wcb Forms\Ck:rb Office\word\Dom!amilyLawCalcndarNotc.doc
RAU(if//GINAL I of2
•.......
WARNING: The moving party MUST CONFIRM by 12:00 noon two (2) court days prior to the hearing in order
for the matter to be argued. Failure to notify the Court of a continuance or strike may result in sanctions and/or terms.
SCLCR 7(bX2XH).
This fonn cannot be used for trial settings. SCLMAR 2.1 40(b).
See Below for other confinnation and noting information.
FOR MATTERS NOTED BY COUNSEL:

I hereby certify that I messengered a copy of this
document
to the attorneys/parties listed below, postage prepaid J
on the:
Date June 22, 2006
Counsel for: (CHECK ONE)

0 Petitioner/Plaintiff
0 Respondent/Defendant
FOR PARTIES PRO SE: If service is required Noted by:

you must also file a RETURN OF SERVICE.
Failure to do so may result in your bearing not
being heard. (Signature)
Please check in the Law Library for more information
regarding service. CHECK ONE
D Respondent/Defendant
WHERE TO NOTE VARIOUS MATTERS:
FAMILY LAW/DOMESTIC MOTIONS: Most are heard on a Court Commissioner's calendar. The exceptions
are matters relating to trial settings and continuances or revisions. Please refer to the Civil Motion Calendar Note
regarding these motions.
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar or Court Commissioner
Calendars must be confirmed at (425) 388-3587. All other matters noted before an individual judge must be
confirmed/continued by his/her law clerk. Adoptions, reasonableness hearings and minor settlements are specially
set and confirmed through the Civil Motions Judge's Law Clerk (425) 388-3421. If you reach voice mail when
confirming, you must leave the requested information or the matter will not be confirmed/continued.
Calendar Notes should be filed at: All Motions Heard At:

Snohomish County Snohomish County
Superior Court Clerk's Office Superior Court
3000 Rockefeller Ave MIS 605 3000 Rockefeller Ave
Everett, WA 9820 I Everett, WA 9820 I
S:\Web Fonm\Clab Office\wonN>omflunilyLawCalemiarNotcdoc

R&VfJfl/GINAL 2of2
I
lllllll llllll Ill llllllllll lllll lllll lllll lllll lllll 11111111
CL 11759173 F~lED
Z006 JUN 27 AM IQ: 59
PAl'i L. DANIELS
COUNTY CLERK

IN AND FOR THE COUNlY OF SNOHOMISH
)
) No. 05-3-02755-1
)
) CERTIFICATE OF COMPLETION
) OF PARENTING SEMINAR
THIS CERTIFIES THAT
Andrew Rife
HAS COMPLETED:
FOR THE KIDS' SAKE: A PARENTING SEMINAR.
Date: June 9, 2006 ashington
621. A Qd
Divorceifeune
~®JAN Divorce lifeline
Seminar Staff Seminar Staff
I1111111111111Ill111111111111111 \\Ill I\\\\ 1111111111 Ill\ Ill\
FILED
CL11516429 06 JUL - 7 PM 3: l ~
4 P 1\i1 L. DANIELS
COUNTY CLERK
5 SUPERIOR COUR¥'1EllfC1iHB-1s:ID\ hE\©i. WASHINGTON
COUNTY OF SNOHOMISH
6
7
In re: Case No.05-3-02755-1
8 ANDREW S. RIFE
9 Petitioner, GR17 DECLARATION
and
10
11 JENNIFER R. RIFE
Respondent
12
13
14
I, Jan Dyer, declare as follows:
15
16 I am the attorney for the Respondent in the above-captioned matter and I make the
following statements pursuant to ORI 7a(2):
17
18 I have examined the Motion/Declaration of Jennifer R. Rife which consists of 4
pages not including this declaration. The fax transmission is complete and legible.
19
20 The Declaration was faxed to me at 503 Twelfth Avenue, Seattle, Washington
98 l 02, telephone number 206-343-1528 and fax number 206-343-7781.
21
22 I declare under penalty of perjury under the laws of the State of Washington that
the above statements are true and correct.
23
24 Dated this 29th day of June, 2006 in Seattle, Washington.
25
26
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102 ~
ORIGINAL (206) 343-1528
~
"r .,.
FILED
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll 06 JUL - 7 PM 3: ! 4
CL11516428
PAHL. DAlllELS
COUNTY CLERK
4 SNOH0t11Sfl CO. W l\SH.
5
6
7
8 Superior Court of Washington
County of Snohomish
9
11 ANDREW S. RIFE, No. 05-3-02755-1
12 Petitioner,
and Motion/Declaration for Ex Parte
13
Restraining Order and Order to
14 JENNIFER R. RIFE, Show Cause
Respondent MTSC)
15
16 I. Motion
17 Based upon the declaration below, the undersigned moves the court for a temporary order and order to
sho\v cause.
18
1.1 Ex Parte Restraining Order
19
20 Does not apply.
21 1.2 Other Ex Parte Relief

22
Order that all future visitation is contingent on Andrew Rife being enrolled and
23 making satisfactory progress in an acceptable (to the GAL and to the
24 Respondent) DV treatment program. Until such time as he is enrolled in such a
program that all of his visits be professionally supervised at his expenses.
25
26 1.3 Surrender of Deadly Weapons
27
Does not apply.
28
29
30
Mtn/Dec/ for Ex Parle Restraining Ord (MTSC) - Page 1 of 4
WPF PS 04.0150 (612006) - CR 56(b); RCW 26.26.590 Dyer & Primont (
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
0
r
1 1.4 Other Temporary Relief

2 Andrew Rife should also be required to appear and show cause why the court should not enter a
3 temporary order which continues these parenting and treatment requirements in full force and
effect pending our trial, which is currently scheduled for August 21, 2006.
4
1.5 Other: N/A
5
6
7 Dated: --fh1--1--(~1~1-._o_o_6_ _ __
8 MICHAEL PRIMONT, WSB #20568
Dyer & Primont
9 Attorneys for Jennifer Rife
10
II. Declaration
11
2.1 Injury to be Prevented
12
13 Andrew Rife has been arrested twice in the last year on DY charges. The first arrest was for
brutally assaulting me while we were married. Although he was arrested and a no contact order
14 was issued he moved back in with us as soon as he got out of jail. There was a long history of
physical abuse as well as continued emotional and verbal abuse. I was very afraid of him at that
15
time and still hoping that he would get help.
16
He was ordered to get into treatment at that time and he did but quickly quit. When the
17 prosecutor found out he had dropped out of treatment they filed more charges against him for
18 violating the No Contact Order. He was not in any treatment program from August 2005 to
November 2005. Then he enrolled in a treatment program at with Chuck De Vore. During that
19 time it was clear that he was gaining zero insight into his issues with abuse and in fact continued
to blame it all on me. Ultimately the state of Washington began investigating Mr. DeVore for
20 running a program that does not adhere to the WAC provisions for DY treatment.
21
When our GAL found out that Mr. De Yore's program did not meet the WAC requirements she
22 recommended that Andy start in a program with Dale Todd. Andy did that but was demanding
that he be given credit for Phase I treatment, which, according to the WAC's, is supposed to be
23
weekly group sessions. Both the GAL and Dale Todd consulted with the state enforcement
24 agency and were informed that Phase I must be in group sessions and that since Mr. Rife had not
done group sessions he could not get credit for them. Mr. Todd, the GAL and me all thought the
25 issue was resolved but apparently it was not.
26
I was informed last week that Mr. Todd was terminating Andy from his program because Andy
27 went to the Everett Municipal Court (where is criminal case is) and without Notice to me or to
the GAL, convinced a judge there that he should "group" credit for his "non-group"
28 participation. Both Mr. Todd's and the GAL's letter regarding this issue are attached and
29 incorporated into this motion. The GAL's report is also attached for your reference.
30
Min/Deel for Ex Parle Restraining Ord (MTSC) - Page 2 of 4
WPF PS 04.0150 (612006) - CR 56(b); RCW 26.26.590 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1
It has now been over one year since Andy was ordered to enter into and complete a DY treatment
2 program. He has burned through three separate programs and has yet to finish the first phase.
3 The GAL, in her report, made it clear that Andy needed to immerse himself in Mr. Todd's
treatment program so that he could make changes that would allow him to be a functioning and
4 healthy father for our child. It is clear that he has no intention of immersing himself in any
treatment program. In his mind it is all still my fault and he wants nothing more than to get back
5 at me. That kind of attitude is frightening. It is even more frightening given the fact that he has
6 been through three treatment programs and he is still blaming his victim.
7 His visitation with our daughter has been daytime only and supervised by his mother. While I
like his mother and do not want to cause any problems with her I do not feel that she is an
8
appropriate supervisor under the circumstances. Andy has made it abundantly clear that he will
9 do whatever he wants and his mother is equally clear that she is afraid of him and will not cross
him. I hope that I can always keep a good relationship with Andy's mom because she is
10 important to our daughter but I don't think it is fair to make her continue to supervise Andy's
11 time with Lauren given that he continues to blame me for his abuse. We need a professional
supervisor that will actually keep notes and direct Andy when he is not appropriate.
12
Our trial is set for August 21, 2006 and I am very concerned that we are so close yet Andy is still
13 not making any progress in treatment. I am asking that professional supervision continue until
14 the trial or until Andy can prove that he is in an acceptable treatment program and making
satisfactory progress, whichever comes first.
15
I am attaching my prior declarations that outline the history of abuse in more detail so that you
16
can see that I am talking about a very violent man who show no signs that he has changed.
17
With Andy not in treatment and only being supervised by his mother I am very concerned for our
18 daughter's safety (both emotional and physical) while in his care. His time must be
19 professionally supervised or suspended all together.
20 2.2 Reasons why the Injury may be Irreparable

21
See above.
22
2.3 Clear and Convincing Reasons why Weapons Should be Surrendered
23
24 Does not apply.
25 2.4 Reasons for a Temporary Order

26 See above in 2.1.
27
2.5 Service Member or Dependent of Service Member
28
Does not apply.
29
30
Mtn/Dec/ for Ex Parle Restraining Ord (MTSC) - Page 3 of 4
WPF PS 04.0150 (612006) - CR 56(b); RCW 26.26.590 Dyer & Primont
503 Twelfth Ave. £
Seattle, WA 98102
(206) 343-1528
·r·. . ..
correct.
I I? .
Signed at~ h / , [City] WR · [State] on \)fM1£ OC/V- 1 19L70~Date].
J ER RT.F
Ill. Efforts to Give Other Party Notice
The following efforts have been made to. give the other party or other party's lawyer n·otice and the
following rea5ons exist why notice should not be required: Both Mr. Gaul (Mr. Rife's attorney of record,
and the GAL (Bridget Llewellyn) have been given notice of this hearing.
-~---+-C_i_2-_0_ _ 6_ __
0
Dated:
MICHAEL PRIMONT, WSB #20568
DYER AND PRIMONT
Attorneys for Jennifer Rife
Min/Dec/ for Ex Parte Restraining Ord (MTSC) - Page 4 of 4

WPF PS 04.0150 (612006) - CR 56(b); RCW 26.26.590
12
1, WENDY RIFE, declare under penalty of perjury of the laws of the State of
14 1. IDENTITY AND BACKGROUND
15 I am Wendy Rife. I am Andrew Rife's mother. Andrew and his wife Jennifer
Rife are in the process of a divorce. I make this declaration to respond to
16 statements attributed to me in a declaration of Jennifer Rife.
17 1 have been designated by the Guardian ad Litem to be one of the persons

approved to supervise Andrew's visitation with their one year old daughter.
18 The routine for visitation is that Jennifer is responsible to deliver the child at
Andrew's home. She does this by having a family member do the actual
19 delivery so there is no contact between Andrew and Jennifer. Ordinarily carol
Holland is the person who actually delivers. Andrew is responsible to deliver
20 Lauren to Jennifer's parents' home. He remains in his car, and I take the baby
from the car to the front door to deliver her to Jennifer or one of her family
21 members. Again, the system is designed to assure that there is no contact
between Andrew and Jennifer.
22
Jennifer Rife has a pattern of conduct of calling on the telephone to shout at
23 me and threaten me that she will cause Andrew's (and by implication my> time
with Lauren to be restricted simply because she is angry. The most recent
24 such incident was last Saturday.
25
26
CARL J. GAUL
Attorney at Law 511fl.
1604 Hewitt Ave.
Everett WA 98201
i ~
425 259-4147 FAX 259 7081

1 2. JENNIFER LIES
2 1 reside just a few blocks from my son Andrew. He and I see each other
practically every day, just as we have for the last several years. When this
3 divorce was filed there was concern about domestic violence issues. The
court required supervised visits, and specified that Andrew's family members
4 would be acceptable to the court, subject to GAL approval. I met with Ms.
Llewellyn and learned her rules, which I agreed to follow. I have been the
5 designated visitation supervisor ever since.
6 Jennifer is just plain making up her story when she claims that Andy thinks he
can do anything he wants. He knows that there are rules and he must follow
7 them. But the rules do not prevent him from doing whatever he wants to do,
as he does not want to do anything inappropriate to the care of his daughter.
8
9 Jennifer claims I am afraid of my son. What Balderdash! I have no fear of

Andrew. I have never had any reason to be afraid of him. I would not
10 hesitate to "cross" him if an occasion were to arise where I thought he was
doing something inappropriate, whether this were to relate to his daughter
11 or anything else.
12 Jennifer is completely wrong when she claims that Andrew blames her for his
conduct. I know my son. He recognizes his responsibility for his own actions.
13 He does not pretend that he likes Jennifer, and he does not take
responsibility for her actions. But most of the time he has nothing to say
14 about her as they are not much of a factor in each other's Jives any more.
15 3. JULY 1, 2006 INCIDENT
16 on July 1, 2006 Lauren was delivered at Andrew's house by Lisa Brunsman. She
delivered the baby at 10:45 a.m. She was driving Jennifer's BMW. I went out
17 to the car to get Lauren from her. Lisa never left the immediate vicinity of
the car.
18
While Lisa was delivering the baby, my son Jeff Rife came over to Andrew's
19 house. He parked behind Lisa's car, got out and cut across the lawn and went
in the front door. cutting across the lawn was the most direct route from his
20 truck to the front door. There was no contact at all between Jeff and Lisa,
not a word, not a glance, not a gesture, nothing. I finished gathering up
21 Lauren and took her into the house. Lisa left.
22 At 11:00 a.m. the phone rang, Jeff answered. It was Mike Brunsman. After a
couple of minutes of friendly conversation Mike asked to speak with me. Jeff
23 gave me the phone. Mike told me that Jennifer wanted to speak to me and
asked that I call her on her cell phone about visitation. I called from Andrew's
24 home telephone to speak with Jennifer as requested. Jennifer told me that
Lisa said that Jeff had pulled in fast and jumped out of his truck, slamming the
25 truck door and walked angrily to the house and that he had a mean look on
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1 his face. I told her that Jeff and his actions had all looked very normal and not
angry or upset to me. I reminded her that Jeff was specifically asked by
2 Andrew and his attorney to avoid all contact with Jennifer and her extended
family. At this point she became noticeably upset, she was angry. Her anger
3 came on like somebody had flipped a light switch. She told me emphatically
that Lisa would not lie about this. I just asked what she wanted me to say.
4
Jennifer then told me She is "sick of all of you." She complained of Andy
5 being angry. She said that we are all liars in our declarations about her. Then
she demanded that we immediately deliver Lauren, ending the visit that had
6 just begun. She then told me that we could not see Lauren at the scheduled
visit on Monday, July 3, 2006. Before I could make any response she hung up
7 on me.
8 Shortly after, the phone rang and there was a hangup. *69 showed that the
call came from a "private" number. About fifteen minutes after that there
9 was another hang up phone call.
10 Andrew and I discussed what to do. 1told him that the court order was clear
and we should comply with it, delivering Lauren at the customary time, S:30
11 p.m. I called and left a message for Bridget Llewellyn to tell her of the
incident. When we delivered Lauren Mike Brunsman came out to get her.
12 Mike's behavior was perfect. Both Jennifer and Lisa's cars were there, but I
did not see either of them.
13
on Monday, July 3, 2006 1got a call from Mike Brunsman. He asked me if he
14 could bring Lauren to Andrew's house for the visit. I asked Mike if Jennifer
and Lisa were afraid to bring Lauren in to town. He just chuckled and did not
15 answer. Andrew was happy to have Mike do the delivery. Mike delivered the
baby without incident. Another Great Visit. At the delivery, Mike again came
16 out of the house to get Lauren.
17 4. MY OPINIONS
18 Jennifer's motion serves no useful purpose. I am a grandmother and I am a
supervisor for visitation. She is trying to feign concern for me to get to my
19 son. Better she should find a different way to express her frustrations.
:: e>ewted atEverett WA on ;2c,a ~ ~,j"

'"'v 7.2006\. WEDY RIFE;,
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
FILED
UD JUL - 7 Pll !1: / 3
1
t',\ri L. DANIELS
COUNT'( CLE/?~
2 SNOHOMISH CO. ;'{ t. SH.
4 I1111111111111Ill11111111111111111111111111111111111 Ill\ Ill\

CL 11692468
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Declaration of Andrew Rife
Jennifer Rae Rife
12
I, Andrew Rife, declare under penalty of perjury of the laws of the state of
15 1 am the petitioner in this matter. I make this declaration to respond to

Jennifer Rife's current motion concerning my contact with my daughter
16 Lauren.
17 2. A BRIEF PROCEDURAL HISTORY
18
There is no order of the superior court requiring me to engage in any
19 counseling or treatment. My wife has filed a motion seeking to enforce a
nonexistent requirement. MY only requirements for counseling or treatment
20 are in the Everett Municipal court. I am in compliance with the requirements
of that court.
21
1was charged with Assault 4 <DVl in May 2005. That matter was resolved by a
22 stay of Proceedings. At the end of September 2005 I was charged with
Violation of Restraining Order and that matter was resolved by being
23 combined in the same Stay of Proceedings with the prior matter.
24 There are two superior court files, the divorce and a companion ov case.
There is no order in either file mandating any treatment or counseling.
25
J~8
26
27
~a~~l~ration of Andrew Rife 1))/6//J/r{_

CARL J. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
i1
425 259-4147 FAX 259 7081
•
JENNIFER'S FICTION
1have not had occasion to communicate with Jennifer Rife at all since at least
October 1, 2005. There has not been a word between us, not a note, not a
glance. Her declaration is filled with statements of my attitudes and activities
and statements that necessarily post-date October 1, 2005. She states as facts
things she could not know. And she is wrong. Her statements are false. Her
declaration is the purest of fiction.
A BRIEF FACTUAL HISTORY
Jennifer Rife and I were involved in a domestic assault in May 2005. At the
time I was arrested. The Everett Municipal court entered a no contact order
against me. 1resided with my father instead of in my own home until mid-
June 2005 when Jennifer and I jointly requested that the Everett Municipal
court terminate the no contact order. After the no contact order was
terminated I moved back to my own home with my wife and daughter.
My DV assault case was resolved by a stay of proceedings. Essentially, I am
required to obtain Domestic Violence Perpetrators Treatment and maintain
good behavior for two years and the charge will be dismissed.
My Treatment History
1have been continuously involved in therapy. Jennifer attempts to mislead
the court by claiming 1quit treatment. I have changed treatment providers
more than I would have wished, but have done so for good reasons.
Davis and co.
I was evaluated by Davis and company for my amenability to treatment. I
started their program but quickly became disillusioned with it. When I
commenced attending group sessions, the quality of the program seemed to
be less than it appeared when I was being evaluated. This was about the time
the business was sold by its founder to new owners. Perhaps that had
something to do with the changed atmosphere there. I sought out a
different program.
summit counseling
1returned to summit counseling, where Jennifer and 1had gone for marriage
counseling. I commenced a program there, attending in August and
September, 2005, time when Jennifer falsely claims I was not in any treatment
program. I but learned that summit's program was not state certified, and
therefore could not satisfy the Everett Municipal court. Going to summit
counseling was a mistake on my part. I recognized that I needed to transfer
to a state certified program.
Charles Devore
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Declaration of Andrew Rife Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
1 At that point I again sought out a program. I happened to get a referral to
Charles Devore. He does have a state certified program. I commenced his
2 program on October 12, 2005.
3 All seemed well with Charles Devore and his program. I was happy and
enthused to be attending with him. Jennifer and her attorney Jan over
4 objected to his manner of conducting his business as he utilizes individual
sessions rather than group sessions'. Because of their objections I inquired
5 and learned that under WAC 388-60-0075 2 group sessions are the norm, but
clinicians have the ability to determine that some individuals should be seen
6 in individual sessions instead. Everett Municipal court Probation Department
was satisfied with my participation in this treatment program. I completed
7 phase 1 in this program.
8 Even though there was no requirement of any treatment program in my
divorce or in the companion ov action, Jennifer Rife and Jan over complained
9 frequently about the program with Charles Devore. They complained to
Bridget Llewellyn. She eventually recommended that I transfer to Phoenix
10 counseling male Todd> or Options man Reynolds>. Charles Devore
recommended to me that I should transfer to one of these programs. He was
11 very pragmatic, explaining that the complaints about his program would
never cease and the only way to put this behind me was to acquiesce in
12 changing programs.
13 Dale Todd
14 I commenced Phase II with Dale Todd at Phoenix counseling.
15 When 1 moved to Phoenix counseling the Probation Department scheduled
my case for a review, May s, 2006. A review was scheduled because I had
16 changed providers with out Probation's consent. My attorney explained the
circumstances. Jan Dyer did not appear, but Jennifer Rife appeared at that
17 hearing and handed forward to Judge Odell a letter from Jan Dyer in which
she argued that I should not get credit for the time I had spent with Charles
18 Devore. Judge Odell's oral comment at the time was that he wanted me to
get credit for what I had done.
19
By the time of Judge Odell's ruling on May s I had already commenced the
20 program with Dale Todd. There was controversy among the attorneys and
the GAL about whether I had to start at the first day of Phase 1 or if I should
21
22 1
Interestingly, the complaint has always been that DeVore emphasizes individual therapy rather than
group therapy. The complain is with DeVore's methods. There has never been a complaint about the quality of the
23 treatment he provides.
2
24 WAC 388-60-0075 provides in part:
(1) All participants must attend consecutive, weekly group treatment sessions. A F.rogram may develop
policies which allow excused absences to be made up with the program director's approva .
25 Exception: Another type of intervention may be approved for certain documented clinical reasons, such as
psychosis or other conditions that make the individual not amenable to treatment in a group setting.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 be given credit for the time 1had spent with Devore. Since the only person
I need to satisfy is the judge who ordered me into the program, we returned
2 to Judge Odell for resolution 3• His order was to allow me credit for the time
I was in that program.
3
When Dale Todd received a copy of Judge Odell's ruling he contemplated
4 what to do. He determined that this case had enough headaches in it that he
no longer wished to be involved in it. He terminated my involvement in his
5 program, noting that I was in compliance with program requirements at the
time of termination.
6
Recent Events
7
On June 23, 2006 Everett Municipal court Probation called me in for a Risk
8 Assessment on the afternoon of June 30, 2006. I participated in that Risk
Assessment, of course. I expect the Probation Department to make a
9 recommendation to the court. I anticipate the court to take action consistent
with Probation's recommendation. And I expect to comply with whatever
10 orders may be entered.
11 5. THE INTECRITY OF THE MUNICIPAL COURT
12 The standard Domestic Violence Perpetrator's Treatment program involves 32
sessions. I have completed 35 sessions. Jennifer wants the court to believe
13 that I have not completed Phase I. She necessarily is asking this court to
determine that Judge Odell made an erroneous determination, and is asking
14 this court to substitute her judgement for his.
15 I completed Phase I with Charles Devore. Jennifer disagrees with Judge Odell's
decision that I should receive credit for the sessions I attended. But she
16 cannot avoid that it was Judge Odell's decision to make. His decision has not
been appealed. She simply chooses to make assertions contrary to his
17 decision.
18 6. MY ATTITUDES
19 Jennifer tries to tell the court what my present attitudes are. She has no way
of knowing how I think. The only thing she could do to find out would be to
20 review the monthly compliance reports filed with the Municipal court. I
believe copies have been sent to her attorney.
21
I have better things to do than plot how to "get back at" Jennifer. Twiddling
22
23 3
Jennifer complains that notice of the hearing was not given to her or to the GAL. Neither of them is a
party to the Everett Municipal Court cases and would not have been heard in any event. The prosecutor had notice
24 of the hearing. But more importantly, the Everett Municipal Court orders do not purport to have any effect in the
Superior Court's proceedings. The Superior Court has not directed any treatment at all. If Jennifer or her attorney
25 had wanted the Superior Court to order some particular treatment program, they could have filed an appropriate
motion, but they did not.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
my thumbs would be more profitable than trying to "get back at" her. Why
she would make the statement escapes me. Why she would think she knows
any current facts about me to make the statement escapes me as well. She
invents her assertion that I am somehow still blaming my victim. I have no
problem accepting responsibility for my own actions. I have nobody to blame
but myself for my own conduct. Jennifer's statement that I continue to
blame her is just her own statement, not a reflection of my attitudes.
MY MOTHER
MY mother, Wendy Rife, has had the spine to stand up to Jennifer. Perhaps
that is why Jennifer now wants to remove her from the visitation. Last
Saturday Jennifer called my mother demanding that my visit end just 1s
minutes into the visit. MY mother ordinarily assists with the exchange of the
child at the end of the visits. Jennifer demanded immediate return. we
returned Lauren at the regular time, without incident.
My mother has been the visitation supervisor. The only complaint we have
received was that Lauren came home over tired on one occasion. There is no
indication that there has been any conduct during the visits that would
warrant any concern about Lauren's safety, either physical or emotional.
Jennifer continues to make her wild claims she has no factual basis for. She
just flat lies when she claims that I have made it "abundantly clear" that I will
do whatever I want to. I have complied with the treatment requirements of
the Municipal court and the visitation requirements of the superior court. I
have never contemplated anything else.
Jennifer's claim that my mother is afraid of me is simply absurd. It is another
flat lie.
MY OPINIONS
Trial is approaching. It is a tense time for any litigant. But I have been doing
what I am supposed to do. And there has been no problem with the visits.
And there will not be a problem with the visits. one of the reasons I have
supervised visitation is that Jennifer and her attorney made wild and
exaggerated claims at the time of temporary orders. I think this motion is not
related to any new concern about our daughter, nor about my mother or me,
but is an expression of anger. The court should not entertain a motion to
change the conditions of visitation.
'~
.____---
22
-
.
Executed at Everett WA
on July 7, 2006
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 5 425 259-4147 FAX 259 7081
FILED
06 JUL - 7 PM 3: I ~
Pl\r-11 o··
SN cou~ii--, ,, iJ/fL s
DHOH1s1·1 ~CoLfRK
.. " ·WASH.

)
)
)
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and f1 ) NO. 0 t;; 3 0 2 7 5°"5' ·- I
_J~T<v-
' . } Q.. IA. k., ',_+--<... )
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)
DONE IN OPEN COURT this date: ~ 1, '1.--bt:Jh

Presented By:
lk. .pA ~wSf>A U>~c; ~
1(184.4
1
\ \ \ \ \ Ii \~\ \l\i\\\\
4
5
I\\\\\\\li\i\\\\\\\\\\\\\\\\\\
CL 11492328
6
7 IN THE SUPERIOR COURT FOR THE STA TE OF WASHING TON
No. 05-3-02755 I
Guardian ad Litem's
Letter of07-12-06 to
Counsel
Date: 08-21-06
Time: 9:00 am
16
I DECLARE UNDER PENALTY OF PERJURY under the laws of the State of Washington,
17 County of Snohomish that the foregoing is true and correct and based upon my own personal
knowledge.
18
Executed this /2.--oay of July, 2006
r::, WuJ_l\ l;L

..J
21
Bridget Llewellyn Guardian Ad Litem
22
23
24
25
RIFE Bridget Llewellyn
Page - I Guardian ad Litem
3114 Oakes Avenue
Everett, WA 9820 I
4?~ 'HQ ?1Sl?
l:JI ORIGINAL
·.
1 FILED
2 06 JUL I LI PM 12: 37
3 I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ Pr.~1tl.D>1:::~-'- l
COU1HY CL£.:;< '
CL 11546603 SNOHOMISH CO. \'!fl SH. \i
4
7 IN THE SUPERIOR COURT FOR THE STATE OF WASHINGTON
9 In Re the Marriage of ) No. 05-3-02755 1

)
10 ANDREW SCOTT RIFE ) Guardian ad Litem
Petitioner ) Report
11 ) PUBLIC
and ) Date: O'i ·J..t-o(p
12
) Time: 9:00 am
JENNIFER RAE RIFE )
13
Respondent )
)
14
15
Comes now Bridget Llewellyn having been appointed by order of the court as the
16 Guardian ad Litem for the following children on November 11, 2005:
17 Name Age
LAUREN RIFE 21 months old
18
Issues
19
20
Residential Placement
Domestic Violence
21 Drug and Alcohol
22 Information Relied Upon
23 Extensive legal file

Guardian ad Litem questionnaires from both parties.
24 Drug and Alcohol Evaluations of both from Edgewood (Canada) OPTIONS and
25
RIFE - GAL Report Bridget Llewellyn
a
Page - I Guardian ad Litem
3114 Oakes Avenue
OmG1NAL Everett, WA 98201
4?~ 'HQ ?1R?
1 Residence 12
Domestic Violence Treatment notes from Chuck Devore M.A. (Father)
2 Evaluation of mother by Marion Hillfrink M.S.W. LIC SW CDP and Dr. Keller
Domestic Violence Notes from Dale Todd . Phoenix Counseling
3
Mental Health Evaluation of father from Fountaingate.
4
5
Telephonic or in person interviews with:
6
Carol Holland Maternal Grandmother
7 Steve Holland Maternal Grandfather
Lisa Brunsman Maternal Aunt
8 Mom's Therapist
Marion Hillfrink
Wendy Rife Paternal Grandmother
9
James Rife Paternal Grandfather
10 Jeffrey Rife Paternal Uncle
Stacie Rife Paternal Aunt
11 Kate Krischano Paternal Great Aunt
Candace Krischano Paternal Great Aunt
12 Jennifer Rife Mother
Andrew Rife Father
13 Carl Gaul Father's Attorney
Jan Dyer Mother's Attorney
14 Dale Todd Phoenix Counseling
Chuck DeVore Treatment Provider
15
16
My recommendations are:
17 1. The Mother should be the residential placement for the child.
18 2. The father must remain in his Domestic Violence Treatment with Dale Todd and follow all
recommendations of such.
19
3. When he has finished the first phase of Domestic Violence Treatment he should enroll in
20 the appropriate parenting class through Family Services.
21
4. The mother must remain in her therapy until such time as the therapist deems it no longer
22
necessary.
23 5. The mother must follow all recommendations of her Drug and Alcohol Evaluation.
24 6. The father's visitation should continue as is until he has completed the first phase of his
Domestic Violence Treatment successfully and the mother has spoken with Dale Todd and
25
Page - 2 Guardian ad Litem
3114 Oakes Avenue
Everett, WA 98201
4?'\ 11Q ?111?
..
1 he is satisfied that the father is progressing.
2 7. If he is, then the visits shall become unsupervised and the hours shall remain the same.
3
8. The father shall provide proof to the mother's attorney that he is enrolled in the appropriate
4
parenting class.
5 9. When the father has successfully completed his Domestic Violence Perpetrators Treatment
and provided proof of such then he can move to expand his unsupervised time either by
6 agreement or by further court order.
7 I 0. The mother must enroll in and complete an age-appropriate parenting class and provide
proof of such to father's attorney.
8
I I. Neither parents shall use alcohol at any time.
9
12. The Domestic Violence Protection Order shall stay in full force and effect.
10
11 I 3. The Grandparents/family members shall provide transportation to and from visitation.
12
13
14
Bridget Llewellyn Guardian Ad Litem
15
16
17
18
19
20
21
22
23
24
25
3I14 Oakes Avenue
Everett, WA 98201
4?~ 'HQ ?<R?
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4 COUNTY CLERK
·SNOHOMISH CO. WA Sl1.
5
6
County of Snohomish
8
10 ANDREWS. RIFE, No. 05-3-02755-1
11 Petitioner,
and Motion and Declaration for
12 Temporary Order
13 JENNIFER R. RIFE, (MTAF)
Res ondent
14
15 I. Motion
16 Based on the declaration below, the undersigned moves the court for a temporary
17 order which: Orders father's visitation to be professionally supervised pending trial in this
matter.
18
19
20 Dated: +- \'-\ - ~ L
21
22
23
II. Declaration
24
Andrew Rife has been arrested twice in the last year on DV charges. The first
25
arrest was for brutally assaulting me while we were married. Although he was arrested
26
and a no contact order was issued he moved back in with us as soon as he got out of
27
jail. There was a long history of physical abuse as well as continued emotional and
28
verbal abuse. I was very afraid of him at that time and still hoping that he would get
29
help.
30
Min/Deel for Temp Ord (MTAF) - Page 1
WPF DR 04.0100 (612006) - RCW 26.09.060;. 110; .120;. 194 Dyer & Primont
503 Tzvelfth Avr..
Seattle, \-VA 9810
(206) 343-15
~~
.,
1 He was ordered to get into treatment at that time and he did but quickly quit.
2 When the prosecutor found out he had dropped out of treatment they filed more
3 charges against him for violating the No Contact Order. He was not in any treatment
.4 program from August 2005 to November 2005. Then he enrolled in a treatment
5 program at with Chuck Devore. During that time it was clear that he was gaining zero
6 insight into his issues with abuse and in fact continued to blame it all on me. Ultimately
7 the state of Washington began investigating Mr. Devore for running a program that
8 does not adhere to the WAC provisions for DV treatment.
9 When our GAL found out that Mr. DeVore's program did not meet the WAC
10 requirements she recommended that Andy start in a program with Dale Todd. Andy did
11 that but was demanding that he be given credit for Phase I treatment, which, according
12 to the WAC's, is supposed to be weekly group sessions. Both the GAL and Dale Todd
13 consulted with the state enforcement agency and were informed that Phase I must be
14 in group sessions and that since Mr. Rife had not done group sessions he could not get
15 credit for them. Mr. Todd, the GAL and me all thought the issue was resolved but
16 apparently it was not.
~7
I was informed last week that Mr. Todd was terminating Andy from his program
18
because Andy went to the Everett Municipal Court (where is criminal case is) and
without Notice to me or to the GAL, convinced a judge there that he should get "group"
19
credit for his "non-group" participation. Both Mr. Todd's and the GAL's letter regarding
20
this issue are attached and incorporated into this motion. The GAL's report is also
21
attached for your reference.
22
It has now been over one year since Andy was ordered to enter into and
23
complete a DV treatment program. He has burned through three separate programs
24
and has yet to finish the first phase. The GAL, in her report, made it clear that Andy
25
needed to immerse himself in Mr. Todd's treatment program so that he could make
26
changes that would allow him to be a functioning and healthy father for our child. It is
27
clear that he has no intention of immersing himself in any treatment program. In his
28
mind it is all still my fault and he wants nothing more than to get back at me. That kind
29
30
Mtn!Dec/ for Temp Ord (MTAF) - Page 2
WPF DR 04.0100 (612006)- RCW 26.09.060;. 110; .120;. 194 Dyer & Primont
503 Ttvelfth Ave.£
Seattle, lVA 98102
(206) 343-1528
1 of attitude is frightening. It is even more frightening given the fact that he has been
2 through three treatment programs and he is still blaming his victim.
.3 His visitation with our daughter has been daytime only and supervised by his
4 mother. While I like his mother and do not want to cause any problems with her I do
5 not feel that she is an appropriate supervisor under the circumstances. Andy has made
6 it abundantly clear that he will do whatever he wants and his mother is equally clear that
7 she is afraid of him and will not cross him. I hope that I can always keep a good
8 relationship with Andy's mom because she is important to our daughter but I don't think
9 it is fair to make her continue to supervise Andy's time with Lauren given that he
10 continues to blame me for his abuse. We need a professional supervisor that will
11 actually keep notes and direct Andy when he is not appropriate.
12 Our trial is set for August 21, 2006 and I am very concerned that we are so close
13 yet Andy is still not making any progress in treatment. I am asking that professional
14 supervision continue until the trial.
15 I am attaching my prior declarations that outline the history of abuse in more
16 detail so that you can see that I am talking about a very violent man who show no signs
17 that he has changed.
18 With Andy not in treatment and only being supervised by his mother I am very
concerned for our daughter's safety (both emotional and physical) while in his care.
19
His time must be professionally supervised or suspended all together.
20
Addendum: This declaration was written earlier and I want to give the court an
21
update which I believe bears heavily on the issue of having Andy's mother as the
22
supervisor. Andy's mother is the person who has been the supervisor of Andy's
23
visitation from the beginning. The exchanges have been at my parent's home because
24
I have asked that my address remain confidential. Sometimes my mother is there for
25
the exchanges, sometimes she is not. Primarily I am the one who is there when Lauren
26
is dropped off and picked up. The exchange is between Wendy Rife (Andy's mom) and
27
myself.
28
29
30
Mtn!Decl for Temp Ord (MTAF) - Page 3
WPF DR 04.0100 (612006)- RCW 26.09.060; .110; .120; .194 Dyer & Primont
503 Ttvelfth Ave. £
Seattle, \VA 98102
(206) 343-1528
07/13/2006 16:59 4253041333 JENN I FER RIFE PAGE 01/01
Andy's 111om recently obtained an ex parte restraining order against me, claiming
that I am harassing her. Although I agree that there is a lot of tension between our
families, I have not harassed or threatened her in any way. I am not surprised by this
move however, given the history of Andy and his family. In the past Andy has tried to
have me arrested on DV charges and has also sought a protection order against me.
The police did not believe him when he tried to have me arrested and arrested him
instead. His requests for a protection order have been denied. It is crystal clear to me
that Andy and or his family wants desperately to have something "against" me when we
· come to trial. I believe his mother's petition for a restraining/antiharrassment order is
just such an attempt.
The problem is, Wendy's order that I not contact her in any way makes visitation
impossible. I note that.in her petition she asked that visitation exchanges be excluded
from the no contact provision but the temporary order makes no mention of any
exception to the no contact provision. If I were to take my daughter or pick my daughter
up from visitation I would be in violation of the order that Wendy obtained. I would
undoubtedly be arrested and then Andy could say, "See, she was also arrested on a DV
charge."
It is very sad that this whole situation has degenerated to this. I recognize that I
have issues that I need to deal with and have been consistently working with a
counselor and have followed all recommendations of the GAL and my own counselor.
Andy, on the other hand, has been through three treatment plans and has not yet even
finished Phase One of any of them. He is currently not in any treatment program,
contrary to the recommendations of the GAL in our case.
I declare under penalty of perjury under the laws of the state of Washington that
the foregoing is true and correct. Signed at . M-t2)i&014../I 4)
on July I 2 , 2006.
Mtn/Dec/ for Temp Ord (MTAFJ - Page 4

WPF DR 04.0100 (61'2006) - RCW 26.09.060; .110; .120; .194
1
2
3
4
5
6
7 SUPERIOR COURT OF THE STATE OF WASHINGTON
COUNTY OF SNOHOMISH
8
9
In re: Case No.05-3-02755-1
10 ANDREW RIFE, GRI7 DECLARATION
11 Petitioner,
And
12 JENNIFER RIFE,
Respondent.
13
14
15
following statements pursuant to GR! 7a(2):
17
18 I have examined the Declaration of Jennifer Rife which consists of four pages
including this declaration. The fax transmission is complete and legible.
19
98102, telephone number 206-343-I 528 and fax number 206-343-7781.
21
23
24 Dated this 17th day of July, 2006 in Seattle, Washington.
25
26
27 JAN 55
Atto
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Q06) 343-1528
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9 Andrew Scott Rife NO. OS 3 02755 1

Petitioner,
10 and MOTION/DECLARATION FOR AN
ORDER TO SHOW CAUSE RE
11 Jennifer Rae Rife CONTEMPT
Respondent. (MTSC)
12
I. MOTION
13
Andrew Scott Rife moves the court for an order directing Jennifer Rae Rife to appear
14 personally before the court and show cause why an order should not be entered:
15 1.1 FINDING CONTEMPT.
16 Finding contempt for failure to comply with:
17 the parenting plan/custody order

lt/r/rJ~
18 entered ori(in &rfs matter.
19 1.2 ESTABLISHING A JUDGMENT.
20 Does not apply.
21 1.3 GRANTING SANCTIONS.
Granting sanctions for contempt, including a forfeiture for each day the contempt of court
22
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,
23
as may be appropriate under Chapter 7.21 RCW, Chapter 26.09 RCW, Chapter 26.10 RCW,
Chapter 26.26 RCW, and RCW 26.18.040.
24
25 Imprisonment is sought as a sanction.. n r;::.. ~ ~~

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26
.
1 1 11
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CARLJ.GAUL
Attorney at Law
.. ~ 1302 Bank of America Bldg.
27 '\I 1604 Hewitt Ave.
MOT/DEC ORD SHOW CAUSE RE CONTEMPT (MTSC) - Page I Everett WA 98201
WPF DR 05.0100 (912000) - RCW 26.09.160 425 259-4147 FAX 259 7081
1 1.4 OTHER:
3 This motion is based upon the declaration which folio
4 Dated: July 12, 2006

5
6
II. DECLARATION
7
Jennifer Rae Rife should be held in contempt for the following reasons:
8
Failure to comply with the parenting plan as follows: By denying residential time on
July 8, 2006.
9
This order was violated in the following manner:
10
11 Jennifer Rife denied my residential time on Saturday, July 8, 2006. My daughter was
scheduled to be with me from 11:00 a.m. to 5:00 p.m. Jennifer Rife was to deliver her to my
12 front door. She refused to do so. Requests for make up time have not been answered.
13 Under the temporary parenting arrangement we have a "delivering parent" rule: Jennifer Rife
is responsible to deliver our daughter to me at my residence at the commencement of my
14 residential time, then I am responsible to deliver our daughter to her at the commencement
of her residential time. Jennifer never comes to my home, instead she has a member of her
15 family handle the delivery for her. I have never been told where Jennifer resides and she has
me deliver to her parents' home. The delivery is made to other family members (her mother
16 carol Holland, her father Steve Holland, her sister Lisa Brunsman, her brother-in-law Michael
Brunsman) as Jennifer is generally not visible.
17
The most common event for transfer of my daughter is for carol Holland to deliver to my
18 mother Wendy Rife at my front door, then for my mother to deliver to carol Holland at the
end of the visit.
19
On July 6, 2006 my lawyer received a fax from opposing counsel that he would appear on
20 July 7, 2006 in ex parte department to request an immediate order which would either
require my visitation with my daughter to be professionally supervised or be suspended
21 altogether.
22 On July 7, 2006 my mother obtained an order of protection from unlawful harassment against
Jennifer Rife in the Everett District Court, case U06-215, copy attached. That order restrains
23 her from surveillance of my mother, from making any attempts to contact her or from being
within 300 feet of my mother's residence. That order was served on Jennifer Rife at the
24 courthouse five to ten minutes before the hearing set by Mr. Primont commenced.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CA USE RE CONTEMPT (MTSC) - Page 2 Everett WA 98201
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 7081
1 Jennifer appeared at the July 7 hearing, along with her sister and her lawyer, Michael
Primont. I was there with my attorney Carl J. Gaul. Commissioner Stewart heard argument.
2 During the argument Mr. Primont mentioned the unlawful harassment order obtained by my
mother. Commissioner Stewart denied immediate relief and he denied the requested order to
3 show cause, leaving the existing residential time arrangement in place without change.
4 I left the courthouse while a handwritten order was being prepared. An order was signed by
Commissioner Stewart.
5
Mr. Primont told my lawyer in the presence of the GAL that the next day's visit (Saturday, July
6 8, 2006) would not occur. Ms. Llewellyn volunteered to handle the exchange of the child
herself. Both Jennifer and her sister Lisa had declined her offer.
7
On the afternoon of July 7, 2006 my attorney sent a letter to Mr. Primont, copy attached. In
a it he recounted the day's events and informed him that I would be ready to receive my child
on Saturday morning at 11:00 a.m., exactiy as the court's orders mandate.
9
On Saturday July 7, 2006 Lauren was not delivered. There was no telephone call or other
10 communication from Jennifer Rife or anyone on her behalf.
11 Jennifer Rife simply refused to obey the court's order. She came to court with a request and
the court denied that request. Then she granted herself the relief the court had just denied.
12
Another visit was scheduled for Monday, July 10, 2006 at 5:00 p.m. My attorney sent a letter
13 to Mr. Primont, copy attached. Later in the day Ms. Llewellyn also wrote, copy attached.
Again, there was no telephone call or other communication, but at 5:00 p.m. Jennifer's
14 mother Carol Holland brought my daughter to my front door.
15 Other:
My lawyer's letter of July 10, 2006 invited Mr. Primont and his client to schedule make up
16
time to compensate for the time lost on July 8, 2006. No response has been received to that
invitation.
17
18
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
true and correct.
19
20
Signed at Everett WA
21
Dated: ~1s&av(i}l_
22
7/yoc,. Andrew Scott Rife
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CA USE RE CONTEMPT (MTSC) - Page 3 Everett WA 9820 I
WPF DR 05.0100 (912000)-RCW 26.09./60 425 259-4147 FAX 259 7081
CARLJ.GAUL Attomey at law 42.S l.S9""4147 fax 423 l.S9-7081
Admitted to practice in Washington. Oregon and California 302 Bank of America Building
1604 Hewitt Avenue
Everett WA 9820 I
July 7, 2006 Fax only to 206 343 7781
Michael Primont MATTER: Rife Dissolution

503 Twelfth Ave. East RE: Saturday, July 8, 2006 Visitation
Seattle WA 98102
Dear Mr. Primont
This Jetter is to confirm today's discussion. Mrs. Rife's motion seeking to restrict Mr. Rife's
residential time with Lauren Rife was denied, and the court did not enter an order to show cause.
Though Mrs. Rife's issues may be argued at a subsequent hearing, as of this afternoon, the present
parenting arrangement remains in effect without change.
In discussions involving you and me and Ms. Llewellyn, your client and her sister were
standing nearby. Mrs. Rife and Mrs. Brunsman were telling Ms. Llewellyn the reasons that
tomorrow's residential time would be denied. After the court had just denied'her motion to modify
the residential schedule, Mrs. Rife was granting herself the relief Commissioner Stewart had denied.
I told you that Mrs. Rife's obligation is to deliver and that Mr. Rife will take the child from
whomever might deliver, even a yellow cab. It was plainly apparent that Mrs. Rife simply will not
allow tomorrow's residential time. At that point I asked you if you would accept service of an Order
to Show Cause to avoid the necessity of demonstrating that Mrs. Rife's address is easily enough
found. You graciously agreed to accept service.
I am waiting for good sense and resourcefulness to save me from preparation of documents
on Monday. Please do discuss with Mrs. Rife her opportunities to simplify rather than complicate this
issue.
Mr. Rife will be at his home, along with Wendy Rife, to receive Lauren from the delivering
person at 11:00 a.m., exactly as the court's orders mandate.
Yours truly,

To Avoid Delay
CARLJ.GAUL
OG:mg
cc: Andrew Rife

Bridget Llewellyn
1
CARLJ.GAUL Attorney at law 425 2j9-4147 fu 42.j 259·7081
1604 Hewitt Avenue
Everett WA 9820 I
July 10, 2006 Fax only to 206 343 7781
Michael Primont MATTER: Rife Dissolution

503 Twelfth Ave. East RE: Saturday, July 8, 2006 Visitation
Seattle WA 98102 Monday, July 10, 2006 Visitation
Dear Mr. Primont
It was not unanticipated that Lauren Rife was not delivered to Mr. Rife's home on July 8, 2006
at 11:00 a.m.
There is another visit scheduled for this afternoon. Please remind Mrs. Rife of her obligation
to deliver the child.
Of course we intend to proceed against Mrs. Rife for her contempt of court for failure to
deliver the child as required. Having two incidents would simply make her defiance of the court's
order more clear. If Mrs. Rife is interested in avoiding the contempt process, she might have you
respond about scheduling make up time to compensate for that denied on Saturday.
Yours truly,

To Avoid Delay
CARLJ.GAUL
OG:mg
cc: Andrew Rife

Bridget Llewellyn
1
0711012006 02:43 FAX 425 252 8016 BRIDGET LLEWELLYN li!J 002
Bridget Uewel/yn
Guardian ad Litem
3114 Oakes Avtmue
Everett WA 98201
Ph # 425-339-238
VIA FAX
July 10, 2006
MICHAEL PRJMONT
503 Twelfth Avenue East
Seattle, WA 98102
Re: RIFE
Dear Mr. Primont:

I am observing the faxes going forth this moming with interest.
I am concerned that visitation is not taking place given the court's ruling on Friday.
As I believe you know I am open to assisting in smooth transfer in any way possible. Do you
have any suggestions as J believe there is another visit scheduled for this afternoon?
Sincerely,
'BW-/:LlL.
Bridget Llewellyn
Guardian ad Litem
BL:jld
Cc: Carl Gaul
2
SNOHOMISH COUNTY DISTRICT COURT
EVERETT DIVISION
CASE NO. U06-215

Wendy Suzanne RIFE DEC 10, 1949 TEMPORARY PROTECTION
-Pe-t-iti-o-ne-r.-(-F-irs-t.-M-,-.d-dl_e_&_Las_t_N_a_m_e_s)_ _ _ _ _ _D_O_B_ _ __, ORDER AND NOTICE OF
HEARING
UNLAWFUL HARASSMENT
Next Hearing Date: JULY 21, 2006
Jennifer Rae Rife AUG 18, 1974 Hearing Time: 11:00 AM-DEPT 3
_R_e_s-po-n"""'d-en-t-.<"'F-irs-t,"""'M...,,.,id~d'"""ie"""'&c-c-La-s"""'tN~a-m_e_s_)-----D~O~B--~ At: SCDC-Everett Division
3000 Rockefeller, 3rd Floor, Everett WA
WARNING TO THE RESPONDENT: Violation of the provisions of this Order with actual notice
of its terms is a criminal offense under chapter 10.14 RCW and will sub)ect ·a viol~tor to arrest.
Willful disobedience of the terms of this Order may also be contempt of court and subject you to
penalties under chapter 7.21 RCW.
Minors addressed in this order:

Name (First, Middle Initial, Last) Age Race Sex
UH Tempor:ir;.· Order Packet.doc

Based upon the petition, testimony, and case record, the coun finds that the respondent committed
unlawful harassment as defined in·RCW 10.14.080. and IT IS THEREFORE ORDERED THAT:
x Respondent is RESTRAINED from making any attempts to keep under surveillance petitioner
and any minors named in the table on page one.
x Respondent is RESTRAINED from making any attempts to contact petitioner and any minors
named in the table on page one.
Respondent is RESTRAINED from entering or beinOvithin 'fpo t:.t; 7 (distance) of
petitioner's ,KJ residence 0 place of employment other:
~
0 Petitioner's address is confidential 0 Petitioner waives confidentiality of the address
which is:
Other:
Other=----------------------------------
UH Temporary Order Packet.doc

It is further ordered that the Clerk of Court shall forward a copy of this Order on or before the next
judicial day to: 0 EVERETT Police Department WHERE PETITIONER 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 Court D petitioner shall forward a copy of this Order on or before the next judicial
d!X to:
LJ SNOHOMISH County Sheriffs Office WHERE RESPONDENT LIVES which shall
personally serve the respondent with a copy of this Order and shall promptly complete and return
to this court proof of service.
OR D Petitioner has made private arrangements for service of this Order.
OR 0 Respondent appeared; further service is not required.
The respondent is directed to appear and show cause why the court should not enter an order for
protection effective for one year or more and order the relief requested by the petitioner or other relief
the court deems proper, which may include payment of costs. FAILURE TO APPEAR AT THE
HEARING OR TO OTHERWISE RESPOND WILL RESULT-IN THE COURT ISSUING AN
ORDER FOR PROTECTION PURSUANT TO CHAPTER 10.14 RCW EFFECTIVE FOR A
MINIMUM OF ONE YEAR FROM THE DATE OF THE HEARING. THE NEXT HEARING
DATE AND TIME IS SHOWN BELOW THE CAPTION ON PAGE ONE.
A copy of this Temporary Protection Order and Notice of Hearing has been filed with the clerk
of the court.
This Temporary Order for Protection is effective until the next hearing date and time shown below
the caption on page one.
DATED_~J_-~1_·-~C)~t,~_at j/:pO AM/PM
I acknowledge receipt of a copy of this Order: I acknowledge receipt of a copy of this Order:
- J-Gl
Petitioner Date Respondent Date
UH Tempor.iry Order Packet.doc

. ·.... .,.
Illlllll l l !l Ill l!lll lllll lllll lllll lllll lllll lllll llll llll
CL 11824440
Slfl'KRl(JK ClJlJ KT 01• w ASlllNGTON F !LED
IN AND FOR SNOHOMISH COUNTY 06 JUL 17 PH :~: 36
I ·"Jr''
l.. D /.;...·.("P.i ..i
1:L·
COUNTY CLERK
CASE NOSNCUiP~IJ(jittSS· WA Sil.
ANDREW RIFE, CALENDAR NOTE: (NTC)

Petitioner
FAMILY LAW MOTIONS
vs.
than twelve (12) calendar days preceding
motion must be filed five (5) court days before the
bearing. Replies to responses must be f"ded three (3)
JENNIFER RIFE, court days before the bearing.
Respondent
TO: The Clerlrnf Court:
FAMILY LAW/DOMESTIC CALENDAR D::te Requested : July 31. 2006

Daily at 9:00 a.m.
Department B or C as assi!!lled. "':""~-~~- .. ~~ ~ .. ;~;,......;..;~-
• "-"!"'"'-"• ..... ,J .............. , • ,_. ' ...,.u........... .
(Confirm at (425 3&8-3587)
CH!!.Ll Sl!PPOR.T ~iO!JIF!C.t\TIONS

""·--·•·--··- .... 1.nn _ _ *"'"
lVIVllUdY~ Ut I .UV j.J.111. VA.
Fridays at 9:30 a.m... DePfl_rtment D

Furl lcarittgs &hOOtiicd uu or after Sept. 6. 2005
(Confirm at (41:S 1RR-1:iR7)
PRO SE O!SSOL!.JT!ON C.4..LENn.4..R Pro Se !>!ssa!!!!!!l!! C2!ends:r

'-"Vcdn,~da~' at i2:30 p.m. uu:y Di:ile Rcqi.ie:sle<l (riiiii/<ld/yyyy):
Dc.Ptu-tinent C
(NQ ('.('lntim1~ti0n n7(n.tin;•(t)
Matters set before a Court Commissioner '.vin be assi!!ned later to a na.rticu!ar detiartme!1!. The assh!!'!me!'!t wi!! be
pusted the day of the hea.-in.E. Extended mvtivn;:; ill"e set t;y the Court Cvmmissivner. rrot a P<llt~' VT by wunseL If a
.-..-r;.;r.-.i:.;:i;;;;o •••if:.; r.:.;~i;-;;!;.;.- {"";,;;<1 {"';o..-;..,i..::..:iHtt,....- !-;;.;:..; ;.;h·,;.;.::,;;h; !-;,;.;.:.;r;! :.; ,,.,. ...,,.: <T"".o.ti.-ott in it-..,. ..-;:::::r:- .-.!.;.;.,......., ir.;!i.o-:.;:r ih:.;:
' . .. . , ..
\-VAH.:'~tNf~: ·~he mnving pa..'t)· l\1tJS'f (~(~NFll{l\~ hy 12:0U nr-ff")n tnn (_2) ~nurt day:. pMnr t..1 the hca..-fng in order
for the matter to be a..~.ied. !'ai!u..re to notifV the Cou..rt of a ccn!!n!lance or striJ.:e m_ry resi.tl! !n sanctions and/or terms.
SCLCR 7(b)(2)(H).
This f!!!'!!! !:2!!!1U! be t!S!"J fi.n· t!ia! Sf'!tines. SCL!vf.A.R 1. ! 4Q(b).

See oe;ov~· for other c..onfirmation dttd notiii!.! information.
i uf2
·-·
This form cannot be used for trial settings. SCLMAR 2.1 40(b).
See Below for other confirmation and noting information.
FOR MATIERS NOTED BY COUNSEL: Noted by:

I hereby certify that I mailed a copy of this document Jan .M:-5''81:..
to the attorneys/parties listed below, postage prepaid
on the: 17"' day of July 2006 (Signature)

~ Respondent/Defendant

you most also file a RETURN OF SERVICE.
Failure to do so may result in your bearing not
being beard. (Signature)
WHERE TO NOTE VARIOUS MATIERS:
FAMILY LAW/DOMESTIC MOTIONS: Most are beard on a Court Commissioner's calendar. The exceptions
Calendars must be confirmed at ( 425) 388-3587. AU other matters noted before an individual judge must be
confirmed/continued by bis/her law clerk. Adoptions, reasonableness hearings and minor settlements are specially
set and confinned throngh the Civil Motions Judge's Law Clerk (425) 388-3421. Ifyou reach voice mail when
confirming, you must leave 1he requested infonnation or the matter will nOt be confirmedfcontinned.

Superior Court Oerl<'s Office Superior Court
Everett, WA 9820 I Everett, WA 98201
RRU:07JOI/2003 2of2
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CL 11933349
3

COUNTY OF SNOHOMISH
7
NO. 05 3 02755 1
8 Andrew Scott Rife
Petitioner, ORDER TO SHOW CAUSE RE
9 and CONTEMPT
Jennifer Rae Rife (ORTSC)
10 Respondent.
11 IT IS ORDERED:
12 Jennifer Rae Rife 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.
13
14
Date:
Place:
7 /st /O(o
Snohomish County Courthouse
Time: 9:ooa.m.
Room/Department:
3000 Rockefeller Commissioner's Department B or C
15 As Assigned
Everett WA 98201
16
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.
17
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court
18 to appoint an attorney to represent you.
Other:
19
20 Dated: Jul 12, 2006

Judge / Commissioner
21
22
23
24
p
c~ rD> 0 If?~ 1ij~~ i
25
CA J.GAUL
\i_,1/~i~t\51/1 '\\' (til~
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ORD TO SHOW CAUSE RE CONTEMPT (ORTSC} - Page 1
'~\:\ u \(_, U [ j \J , 1
- _J
Attomeyatlaw
~(,14.Bank of Amenca Bldg.
1604 Hewitt Ave.
Everett WA 98201
I
WPF DR OS.01SO {9/2001) - RCW 26.09.160 425 259-4147 FAX 259 7081
q1
•
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· 2006 JUL 24 AM 10: 52 ·

1
PAM L. DANIELS
2 COUNTY CLERK
·\ \ \ ~\\\\\\CL11821284
SNOHOMISH CO. WASH.
3
\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\ \\\\
4

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 DECLARATION OF ANDREW RIFE
Jennifer Rae Rife
12
1, Andrew Rife, declare under penalty of perjury of the laws of the state of
13 Washington, that the following is true and correct.
14

16 I am the petitioner in this matter. I make this declaration to respond to my
estranged wife's latest attempt to further restrict or eliminate my time with my
17 daughter. The motion is brought in bad faith, and I am asking the court to impose
terms for the necessity of defending.
18
2. THIRD TIME AROUND
19
First Time - October 2005. My estranged wife now asks the court for the third time
20 to grant the same relief. Review of her declaration from last October, when the case
had just been filed, shows that she requested essentially the same order then that
21 she requests now.
22 Second Time. July 7. 2006. Substantially the same motion was argued before
Commissioner Stewart on July 7, 2006. Ms. Dyer prepared and signed the motion
23 to restrict or eliminate my residential time. Her partner, Mr. Primont, appeared and
argued the matter. I was present for the argument of the domestic motion and
24 heard the arguments, the colloquy between the court and counsel, and I heard the
rulings. Shortly before the matter was argued my attorney served my mother's
25
26
cAR°LlkGAUL
Attorney at Law
DECLARATION OF ANDREW RIFE
Page 1
ORIGINAL 1604 Hewitt Ave
Everett WA 9820~
4~5 259-4147 FAX 259 708~
I I.
..
1 petition and a temporary order of protection from unlawful harassment on my wife 1 •

Mr. Primont informed the court of the existence of the no contact order.
2
Domestic Violence Perpetrator's Treatment. I have complied with all
3 treatment requirements and I have successfully completed that portion of my
education 2 • My wife's declaration falsely claimed that I am out of compliance
4 with an order requiring DV treatment. Mr. Primont falsely claimed argued
that I am out of compliance with an order concerning domestic violence
5 perpetrator's treatment. Commissioner Stewart recognized that there is ~o
order of the Superior Court requiring me to be involved in such treatmentar:id
6 that the Municipal Court can vindicate its own authority by enforcing its own
orders.
7
No Basis. Mr. Primont argued because of my supposed non-compliance with
8 the non-existent treatment requirement, that my residential time with my
daughter should be further restricted. Though my mother has been the
9 supervisor of my time, he was requesting a professional supervisor or that my
residential time be eliminated entirely. In part, he was relying on my
10 estranged wife's false statement to the effect that my mother is frightened of
me and cannot control my behavior3 • My mother has no fear of me, there
11 has never been any reason for her to fear me. And there is no need to
control my behavior as I have not wanted to do anything that I should not
12 have done.
13 No Emergency. Finally, Commissioner Stewart saw no reason to present the

matter on the ex pa rte calendar, where the Commissioner has no opportunity
14 to prepare for the hearing and he wondered why the motion was evidently
unnecessary between October and July but needed to be filed on an
15 emergency basis six weeks before trial. He denied the motion without
prejudice, allowing it to be noted on the regular domestic motions calendar.
16 Ms. Dyer has noted it on the regular domestic motions calendar, but she still
17
18 1-----------
states no new facts relating to our daughter or to our father-daughter
relationship or to the conditions of exercise of my residential time.
,
1
The temporary order of protection prohibits Jennifer Rife from having any
19
contact with Wendy Rife.
20 2
I was charged with Assault 4 and with Violation of a Restraining Order in the
21
Everett Municipal Court. Those charges were resolved by a Stipulated Order of
Continuance or Stay of Proceedings. The charges will be dismissed if I comply with the
22
terms set by the court. One of those terms was to participate in DV treatment
program. I did so. The Municipal Court has determined that I have complied and I
23
have no further treatment obligation to that court. There is no other order requiring
me to participate in DV treatment.
24 3
I am curious when or how my mother made such a statement to my wife as
25 they have had only incidental contact at the visitation exchanges and at court since this
matter was filed last October.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave:
DECLARATION OF ANDREW RIFE Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
1 I filed responsive materials to the prior motion, but none of the facts I submitted
seem to make any difference to my estranged wife and her attorney, they simply
2 submit the same thing all over again.
3 3. TERMS
4 Jennifer Rife and her attorneys have already lost this motion once. They have not
provided any new or additional basis for the request: they have simply repeated it.
5 In the interim, my daughter has been denied her time with me. Immediately after
the court denied their motion on July 7, Mr. Primont informed my attorney that the
6 scheduled visit on July 8 would not occur. The GAL volunteered to handle the
exchange, but Jennifer Rife refused her, so the July 8 visit did not occur. My
7 daughter was delivered for the following Monday and Wednesday time, but I my
daughter and I have not seen each otfler since. My attorney wrote suggesting
8 methods of resuming the scheduled visitation, but Ms. Dyer has made no response.
The GAL wrote saying that visitation should resume with three different suggestions
9 for methods of exchange of our daughter. She wrote again mandating that
"visitation shall resume", specifying the manner of exchange. Instead, visitation is
10 still being denied.
11 The court should punish misconduct. My wife has again demonstrated her anger.
While she is busy demonstrating her arbitrary power, defying the authority of the
12 court, she is also harming our daughter, and wasting time and money with repeated
motions. Evidently, this is encouraged by her attorney. I really do not mind if they
13 waste their own time and money, but I object to them choosing to waste mine.
, /~
14
Executed at Everett WA ~f / =::>
15 on July 24, 2006 ANDREW RI E /
16
17
18
19
20
21
22
23
24
25
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
DECIARATION OF ANDREW RIFE Everett WA 98201
Page 3 425 259-4147 FAX 259 7081
I Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll F\LEO_
CL 11820806
oti JUL 2~ PM ti;: Jl .
1
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i''I CLERK
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sNOHOtilS ·-:""'
3

COUNTY OF SNOHOMISH
7
NO. 05 3 02755 1
8 Andrew Scott Rife
9 and CONTEMPT
10 Respondent.
11 IT IS ORDERED:
12 Jennifer Rae Rife shall appear in person before this court at the place and time below and show
13
Date: August 8, 2006 Time: 9:00 a.m.
14
15 As Assigned
Everett WA 98201
16 If you fail to appear in person and defend at these proceedings the court may grant all of the relief
17
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court
18 to appoint an attorney to represent you.
19 Other: :JUL 2 4 2006

20 Dated: July 21, 2006
I Commissioner
21 Presented by:
22
23 Jan Dyer WSBA# 355

Attorney forJennifer ae Rife
24
25 CARLJ.GAUL
Attorney at law
26
1604 Hewitt Ave.
27
ORD TO SHOW CAUSE RE CONTEMPT (ORTSC) - Page 1 Everett WA 9820 I
WPF DR 05.0lSO {9/2001) - RCW 26.09.160 425 259-4147 FAX 259 7081
1

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Declaration of Stacey Rife
Jennifer Rae Rife
12
I, Stacey Rife, declare under penalty of perjury of the laws of the state of
15 I am Andrew Rife's sister-in-law. I am married to Andrew's brother, Jeff Rife.
I make this declaration to inform the court concerning events of Saturday,
16 July 22 and Monday, July 24, 2006.
17 2. BACKCROUND
18 Andrew Rife and his wife Jennifer Rife are involved in a divorce. I know that
Andrew's mother supervises his time with his daughter Lauren. I was designated by
19 Bridget Llewellyn to serve as Andrew's transfer agent. I was to go to the Everett --~
Police Department to pick Lauren up from Jennifer at the beginning of Andrew's

20 time with Lauren and also to deliver her back to Jennifer at the end of Andrew's
residential time. I was happy to be of assistance.
21
3. SATURDAY, JULY 22, 2006
22
1 went to the Everett Police Department on Saturday, July 22, 2006 about 5
23 minutes before the scheduled 11:00 a.m. drop off. 1 waited there until 11:15 a.m.
During the time I was there Jennifer Rife did not arrive to drop off Lauren for her
24 time with her father. I left the police department at that time, recognizing that
ennifer would not be appearing.
25
26
CARL J, GAUL {J..
Attorneyatlaw /-.y
27
1604 Hewitt Ave.
j\tt\
Declaration of Stacey Rife Everett WA 98201
Page 1 425 259-4147 FAX 259 7081
.. ~
1 4. MONDAY, JULY 24, 2006

2 1went to the Everett Police Department on Monday, July 24, 2006 about 5
minutes before the scheduled 4:30 p.m. drop off. I waited there until 4:45 p.m.
3 During the time I was there Jennifer Rife did not arrive to drop off Lauren for her
time with her father. I left the police department at that time, recognizing that
4 ennifer would not be appearing. -~
6
5
Execute.fl at Evef_ett WA
on 7/~~(0lf'
~:.ST~IFE
!.-,."!\>~L,~f'il,;-~~f---H--l----
7
10
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13
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15
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22
23
24
25
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Declaration of Stacey Rife Everett WA 98201
Page 2 425 259-4147 Ff>X 259 7081
••• "
1
2
3 I\\\\\\\ 111\11 \\\ \\\\\ \\\\\\\\\\\Ill\\\\\\ \\Ill\\\\\ \Ill\\\\
4
\ CL11932606
,\
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9
10
11 Petitioner,
12 and DECLARATION OF JENNIER RIFE
IN RESPONSE TO MOTION FOR
13 JENNIFER R. RIFE, CONTEMPT
Respondent
14
15
I am the Respondent named above. I make this declaration under penalty of perjury and
16 based on my own personal knowledge. I am over 18 and otherwise competent to testify.
17 Andy Rife is asking that I be held in contempt because I have not been willing to bring
18 our 22 month old daughter to visitations. Andy's own actions have prevented visitation from
19 taking place, not mine. We have had a pattern of having our mother's help with the transfers and
20 his mother, Wendy Rife, has been the "visitation supervisor." This divorce started in October,
21 after Andy was arrested the second time. All of Andy's visitations are supervised and there is a
22 criminal No Contact Order and a DY Protection Order in Place. On July 7, 2006, Andy and his
23 mother, without notice to us, went to District Court and obtained Protection Orders that prevent
24 my mother from having any contact with Andy and Wendy (the visitation supervisor) from
25 having any contact with me, making visitation, as we have been doing for the last 8 months,
26 impossible. Our responses to those petitions are attached and incorporated herein. My family
27 will no longer have anything to do with the Rife family. We are convinced that they are bent on
28 revenge and that Andy is in complete denial about the effects of his abuse and his abusive
29 attitude, which continues unabated and in fact has only gotten stronger.
30 First I want to make sure that the court understands the history of this case so you
Dyer & Primont
503 T1velfth Ave. E
Seattle, WA 98102
Page I
ORIGINAL (206) 343-152~
\0
,;
1 understand why I can not send my very young and vulnerable daughter to visitation until we
2 have some safe parenting rules set up and appropriate supervision in place. Every court that has
3 ever looked at this divorce case has agreed quickly that all of Andy's visitation time with our
4 daughter should be supervised and that both she and I should have a protection order against
5 Andy. There is a very good reason for that. During our marriage I learned first hand that Andy
•6 is a very violent husband and father. He brutally physically abused me on several occasions.
7 My prior declarations in that regard are attached and incorporated by this reference.
8 Andy also has shown in the past that he will lie to the police or the court. One of my trial
9 witnesses (trial in this matter is set for August 21, 2006) is the officer that arrested Andy at our
1o home in October 2006. That officer will testify that Andy tried to have me arrested but that the
11 police did not believe the story that he and his brother were telling, (with help from their mother
12 Wendy) and refused to arrest me. Instead they arrested Andy for violation of the criminal no
13 contact order that was issued when he was arrested for assaulting me the prior May.
14 I bring this up because the court needs to understand where we stand in this case at this
15 point. We are less than a month from our trial date. Andy has yet to complete a state certified
16 DV treatment program and maintains that he has already learned every1hing he needs to learn
17 about domestic violence. I am convinced beyond a doubt that, despite clear court rulings
regarding the issue of domestic violence, despite two arrests and mountains of evidence to the
18
contrary, Andy continues to blame everything on me and to want revenge for the fact that I
19
brought his behavior to light. He has been unrelenting in this task during the last 8 months.
20
Andy was arrested for DV Assault against me in May 2006. He was ordered to get into
21
DV Treatment. At that time we were still trying to work on our relationship and the court lifted
22
the criminal no contact order on condition that Andy be in treatment. Andy went to Davis and
23
Company. They did an assessment and he started treatment there. He only went a few times
24
before he quit. He told me that basically he was fine and that he did not like their program. He
25
kept saying it was about me, not him. 1 am attaching a copy of the Davis and Co. assessment
26
from that time. As you can see, Andy was lying to me. Davis and Co. found that he had major
27
issues with domestic violence that needed to be addressed. He just was refusing to deal with
28
them.
29
When the criminal court found out that he was no longer in treatment they put the no
30
contact order back in place. Andy would not leave Lauren and I alone yet his trial date was
Dyer & Primont
503 Tlvelfth Ave. E
iCJ/f'/A/AL Seattle,WA98102
Page 2
O ntlJl/Ylt 1206)343-1s2s
1 quickly approaching. It is clear to me in hindsight that Andy was trying to keep me from
2 testifying against him at his trial. He called the police on me when I tried to bring our sick child
3 back home. I did not want to be there but it was Lauren and my home and there was a protection
4 order keeping Andy from being there and we should have been allowed to live there in peace.
5 But, Andy insisted that it was HIS HOME and he had a right to be there. He had complete
6 disregard for our daughter's health or safety and was only bent on revenge. When the police
7 arrived they quickly understood that he and his brother were lying to them and that in fact he was
8 the one that was not supposed to be there.
9 After that I got an attorney and so did Andy. He filed this divorce action. We both
10 brought motions to the court. The court granted my request for a protection order and supervised
11 visitation. The court ordered the appointment of a GAL and ordered that there be an interim
12 emergency assessment in 30 days. We agreed to the appointment of Bridgett Llewellyn as the
13 GAL.
14 I felt strongly at the time that an emergency assessment was just what we needed. I was
15 very concerned about what seemed to me to be a clear continuing of the vendetta against me and
16
having I 8 month old Lauren in the middle of it. I wanted to have faith in the system and the
professionals in it. I waited for the assessment. It never came. The court, at the first hearing on
17
Nov. I, 2006, had set a review hearing for Dec. 6, 2006. The GAL did not produce any report
18
for that hearing. It was the same story every month. The case bounced along on review with
19
monthly hearings until March when my attorney finally forced the issue. The GAL never did
20
issue any type of interim report. The GAL finally did issue her final report but not until early
21
June of 2006. We agree with her recommendations. They are that Andy should engage in the
22
domestic violence treatment program with Dale Todd (which he has since been dismissed from),
23
upon successful completion of that program he attend the Respectful Parenting program with
24
Family Services, that his visitation should continue to be supervised and that our daughter should
25
reside primarily with me.
26
I agreed with those recommendations. Unfortunately Andy did not. Since she issued her
27
report Andy has been terminated from his third DV Treatment Program. He has made it clear
28
that he has learned what he needed to learn although his behavior has continued unabated. For
29
example Andy makes a point of being in the car when his mother brings Lauren back to my
30
mother's house at the end of visitation. He does not have to be there and frankly he should not
Dyer & Primont
503 T?velfth Ave. E
i{J/~/A/ AL
O
DECLARATION OF JENNIFER RIFE Seattle, WA98102
Page 3 ntuttYl1 (206)343-1528
1 be. But he insists on being there and always, always, does something to make transfers strained
2 and difficult. He honks the horn, makes inappropriate comments, makes faces at me through the
3 car window and generally acts stupid. His mother, the alleged supervisor, makes no attempts to
4 stop him. If my mother or I try to talk to her about this she defends Andy to the death. She uses
5 the visitation exchange time to discuss issues about this case or between Andy and I that are
6 inappropriate subjects for the visitation time. I have asked her repeatedly to stop and help us
7 make the exchanges pleasant for Lauren but she insists and pushing the issues during the time we
8 are supposed to be focusing on Lauren.
9 I have been very troubled for months about how it was that Andy continues to be in
10 denial and continues to be abusive yet no one seems willing to stand up to him. I have known
11 since my marriage to Andy that his mother is not a person that can but I hoped she would be
12 willing to put the best interest of her granddaughter before her need to continue to lie for her son.
13 I was wrong. She, and every member of their family, have made it clear to us that we are the
14 enemy. Eight months of supervised visitation and requests by the GAL that Andy really engage
15 in treatment and stop blaming me and where do we find ourselves? We get served with No
Contact Orders. No contact orders that are based on lies, not even half truths. There is nothing
16
intimidating or threatening about any of our actions. Please read our declarations in response to
17
those petitions.
18
On July 7th Andy alleges that he was so threatened by my mother that he needed protection from
19
her. Yet, his allegations stem from October and December of2005 and early June of2006. He
20
felt threatened by her yet he continued to come to her house when his mother would return
21
Lauren. He continued to sit in his truck and make rude comments to her or honk his horn or
22
otherwise act the fool. Yes, it is clear he felt very threatened by her. The same is true as to
23
Wendy. The incident she alleges happened in May. She has the dates wrong, it happened on
24
May 61h, not the 3'd. There was a visitation on the third where Andy made a rude comment to my
25
mother. At the end of the visit I asked Wendy to try to keep Andy from making those types of
26
comments as they make the transfers harder and stressful for everyone, including Lauren. On the
27
next visit transfer, when Andy and Wendy arrived at my parent's home, Wendy insisted on
28
talking to me about the divorce case and I did not want to talk to her. She insisted and demanded
29
to talk to me. She essentially forced her way into my mother's home so that she could confront
30
me about my perceptions of Andy. She even made the statement to me that, "Andy would never
Dyer & Primont
503 Twelfth Ave.£
ORIGINAL
Seattle, lVA 98102
(206) 343-1528
Page 4
1 hurt me." Andy has physically hurt me on many occasions. I have seen no evidence of any
2 change. She forced her way into my mother's house demanding to speak with me yet she alleges
3 that I somehow was threatening to her.
4 The transfers for visitation have been very difficult. Andy and his mother have made
5 certain of that. But at least they have been consistent. Our little daughter has been a trouper
6 through all of this but it has been hard on her. Her schedule has been very disrupted with this
7 schedule and Andy's refusal to have her take naps when she is with him. I have been very
8 concerned for her. Andy has had eight months of "supervised visitation" and, according to the
9 GAL, continues to need supervision. I agree but I do not believe his mother is an appropriate
10 supervisor. Nor do I feel that any other member of his family is appropriate. They are all in his
11 "camp" and the goal is to discredit me or my family at any costs, not to watch out for the best
12 interest of our child. That is not appropriate supervision.
13 We were also in court on July 7, 2006 but we were there on notice to Andy and his
14 attorney, unlike their secret trip to District Court on the same day. At that time I was requesting
that Andy's time with Lauren be professionally supervised. The court denied my motion without
15
prejudice because it felt there was no emergency. Well, apparently there was an emergency but
16
not one that Andy was willing to tell the Commissioner about. That same day he and his mother
17
were in District Court telling Andy's Elks Club buddy, who happened to be sitting as a pro tern
18
on the bench that day, that there was such an emergency involving the visitation exchanges that
19
they needed ex parte protection from my mother and me.
20
After I was served with the order stating that I could have no contact with Wendy, my
21
child's visitation supervisor, I filed a motion asking that the court order that Andy's time with
22
Lauren be professionally supervised, as Wendy could clearly no longer fill that roll. That motion
23
is also before this court today. During the week after I was served with Wendy's No Contact
24
Order we continued to attempt to keep visitation going. My mother was able to cover two of the
25
visits for me but was out of town for the weekend visit and so there was no one available or
26
willing to take Lauren to the exchange. Then, my mother was served with Andy's No Contact
27
Order. This was just too much of a shock. It turned out Andy got his order on the 7th at the same
28
time as Wendy got her order against me but, since my mom was out of town, they waited to
29
serve her until later the next week; after she had delivered Lauren twice to Andy's house and
30
Dyer & Primont
503 T1velfth Ave. E
Seattle, WA 98102
Page 5 ORIGINAL (206) 343-1528
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1 Andy and Wendy had brought her back to my mom's house twice. How afraid of my mother
.2
·was Andy really?
3 My family and I have thought this over and discussed it at length. We cannot figure out
4
what in the world the Rife' s are thinking but it is clear to us that they will stop at nothing to
attempt to have us arrested or discredited in some way. We are not willing to put ourselves in
5
such a dangerous situation. None of us wishes to be arrested.
6
By their actions in filing these false allegations in District Court and obtaining these
7
"temporary orders" they made further visitation impossible. I have sought the court's direction
8
and have taken a course of action designed to protect Lauren. I know Andy and have been the
9
frequent recipient of his abuse. I know that he is in a very bad place right now and is really
10
wound up into clearing his name and his record. I know he is very angry and I know what he is
11
like when he is angry. I do not want my daughter around that. He has never truly engaged in
12
meaningful treatment and in fact has done everything in his power to not have to engage in
13
meaningful treatment. He has continued to blame me and my family for everything and wants
14
nothing but revenge. This is not a healthy environment for my child to be in and could be
15
potentially very dangerous to her. I do not want to wait until she is injured or emotionally
16
scarred like I did.
17
I am aware that the GAL has advocated for resumption of visits. I want to say clearly
18
that she has done so without talking with me or any member of my family. It is her duty to
19
"investigate the facts" and present an unbiased recommendation. How can she make any
20
recommendations about the resumption of visitation without ever even talking with me? Andy
21
has completely ignored every recommendation of her report. He and his mother brought
22
completely false petitions against my mother and me, making visitation impossible. Without
23
even talking with me she says that I have to bring my daughter to the police station and hand her
24
over to someone other than the person she has been used to being picked up by. I have been
25
raising these issues to the GAL for many months as the supervision and transfers seemed to be
26 getting worse and more tense. She has just ignored me. In fact, the transfer on May 6th (the one
27 that Wendy alleges I threatened her after she forced herself into my mother's home so she could
28 talk to me) was so upsetting to me that I called the GAL immediately; she never even returned
29
30
my call.
.
Dyer & Prirnont
503 Ttvelfth Ave. E
Seattle, WA 98102
Page 6 ORIGINAL (206) 343-1528
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1 Commissioner Stewart denied my motion on July 7'h because there was no emergency.
2 Well there is now. According to Andy and Wendy's Petition's for protection from my mother
·3 and myself there was an emergency on July 7•h, just not one that they felt comfortable telling
4 Commissioner Stewart about.
5 1 am asking the court not to find me in contempt. I am not. I am trying to protect my
6 child from being in the middle of Andy's need to punish me and my entire family. I am trying
7 to protect my child from her father's rage and abuse, which continues unabated and is completely
8 enabled by his family members.
9 Andy needs help and he 1s not getting it. Until he does he remains a threat to our
10 daughter's safety. I have seen him when he looses his temper and how quickly he looses it; it is
11 scary and dangerous. Please do not put my daughter in a position where she is not protected.
12 Please order that, pending trial, we will use a professional supervisor. I would recommend Don
13 Layton.
14
15 foregoing is true and correct. Signed this 25•h day of July 2006 in Everett, Washington.
16
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18
JENNIFER RIFE
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Dyer & Primont
503 Ttvelfth Ave.£
ORIGINAL
Seattle, WA 98102
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0.7/.25/2006 17: 24 3606685072 HOLLAND PAGE 01
07/25/2006 15:35 FAX ~ 007 /007
1 Commissioner Stewart denied my motion on July 7th because there was no emergency.
2 Well there is now. According to Andy and Wendy's Petition's for protection from my mother
3 and myself there was an emergency on July 7tb. just not one that they felt comfortable telling
4 Commissioner Stewart about.
5 1 am asking the court not to find me in contempt I am not. I am trying to protect my
6 child from being in the middle of Andy's need to punish me and my entire family. I am trying
7 to protect my child from her father's rage and abuse, which continues unabated and is completely
6 enabled by his family members.
9 Andy needs help and he is not getting it. Until he does he remains a threat to our
10 daughter's safety. I have seen him when he looses his temper and how quickly he looses it; it is
11 scary and dangerous. Please do not put my daughter in a position where she is not protected.
12 Please order that, pending trial, we will use a professional supervisor. I would recommend Don
13 Layton.
foregoing is true and correct. Signed this 25th day of July 2006 in Everett, Washington.
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IF RIFE
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Dyer & Primont
5113 TW<l/llr Jlor. E
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DECLARAT!ON OF JENl<11'ER RIFE (2~ 343-7528
Pa&< 7
ORIGINAL
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8 EVERETT DIVISION
9
10 WENDY RIFE,
11 Petitioner, No. U06-215
and
12 Declaration Carol Holland
13 JENNIFER RIFE,
Res ondent
14
15 My name is Carol Holland. I am Jennifer Rife's mother. I was present when
16 Wendy Rife alleges Jennifer threatened her. I am over 18 and competent to testify. I
17 make the following declaration based on my own personal knowledge.

First, Wendy has her dates mixed up. I have kept very clear records of the
18
visitation exchanges, as was suggested to us by my daughter's attorney at the beginning
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of this case. I know that Wendy is referring to the May 61h exchange, not the May 3rd
20
exchange. On May 3rd there was an incident when I dropped Lauren off to Wendy.
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Andy made a rude and uncalled for comment to me. As far as I am concerned, Andy
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should not even be at the visitation transfers but he always makes sure he is. He only
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makes it uncomfortable for everyone. I now know that he was physically abusing my
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daughter during their entire marriage. It breaks my heart. We opened our home and
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heart to Andy and it has been very hard on all of us. Now I see Andy in a different way.
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I have worked hard and sought help this last year to be able to do what is best for our
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granddaughter. I know that children love their parents and I have done everything I can
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to help facilitate the visitation between Andy and Lauren. I have tried to maintain an
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upbeat and positive attitude around the exchanges and have tried to get others to follow
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my lead. I have not been negative or argumentative .. I have, at times, had to be firm and
Dyer & Primont
503 Tivelfth Ave. E
Seattle, WA 98102
Declaration Carol Holland (206) 343-1528
Page I
1 stand my ground but I've always tried to find a solution or a peaceful way around a
2 problem.
3 As I said, I don't think Andy should insist on being at the exchanges, especially if
4 he feels so threatened by me, as he asserts in his petition against me. However, he insists
5 on always being in the car. Making faces, honking the horn, causing distractions and
6 now making rude comments directly to me.
7 Wendy, his mother and supposedly the visitation supervisor, did nothing and
8 frankly refused to even consider that anything was wrong with Andy's behavior. Later,
9 Andy, Wendy and Wendy's sister Kate drove up to my home to drop Lauren off. My.
10 daughter Jenn was there, as she often is, and took Lauren from Wendy. Wendy, not Jenn,
11 started the conversation and it was an inappropriate conversation, especially from the
12 supervisor. We have repeatedly asked that all conversations at transfers be confined to
13 just what needs to be communicated at the exchanges. This is Lauren's time. If the
14 adults have issues they can talk to each other at different times. But no; Wendy has to
15 start talking to Jenn about non visitation issues. She began insisting that Jenn give her
16 Lauren's social security number.
17
Now, please understand that this is a sore spot issue for Jenn and was not a good
thing for Wendy to talk about or ask Jenn for. Andy has Lauren's social security number
18
and Wendy had no business asking Jenn for it. In the context of the divorce, Andy had
19
refused to communicate with Jenn about how they should file their 2005 taxes and his
20
attorney had rebuffed all attempts by her attorney to get the information or some
21
agreement prior to April 15 1h. What we know is that Andy filed married filing separately
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and took Lauren as an exemption. He has her social security number. He had no right to
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unilaterally decide how a community tax return would be filed and how the child
24
deduction would be used. Like I said, this was not a good subject to bring up with Jenn
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and it was quite upsetting to us all. It only proved to all of us how little Wendy knows
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about Andy and how ineffective she is as a visitation supervisor.
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Jenn told Wendy to ask Andy for the social security number but Wendy would not
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accept that answer. At this point I intervened and explained to Wendy that asking Jenn
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for this was not a good idea and again requested that she simply get it from Andy and
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leave these kinds of issues out of the visitation exchanges. There was some further
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 2
1
2 discussion between Jen, Wendy and me about the rude comment by Andy earlier in the
3 day. Then they left and we all went back into the house. That is all that happened at the
'4 May 3'd exchange.
5 It was at the May 6'h exchange that the things that Wendy alleges happened on
6 May 3rd actually happened, except not how Wendy describes them. Wendy brought
7 Lauren to the front porch asleep. Jenn was the only one available so she came out on the
8 porch and took the sleeping child. When I walked out to the porch, Jenn and Wendy
9 were talking and Jenn seemed distressed. At this point I intervened and told Jenn to go in
10 and lay Lauren down. I told Wendy and we could meet for coffee and come up with
11 "something fair for everybody." Jenn went inside. Wendy wanted to continue talking to
12 Jenn but I wanted the conversation to end. I again told Wendy that now was not a good
13 time and that we could meet another time to discuss it. Wendy insisted two more times
14 and I said no two more times but Wendy kept insisting that she had to talk to Jenn; she
15 had something she wanted to say to her.
16 When it became clear she was not going to leave until she talked to Jenn I opened
the door. Wendy went right in past me and started in on Jenn, with Lauren sleeping right
17
next to her. This irritated me. She was not being friendly and she was in my house
18
against my wishes. I got in front of Wendy and stopped her from going any farther. I
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asked Jenn to come to the entry as Wendy wanted to say something to her. Wendy
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proceeded to launch into a lively defense of Andy's behavior to Jenn, including saying,
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"he would never do anything to hurt you." It was very upsetting and such a lie. He has
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physically abused Jenn on several occasions, I have seen the bruises. I could see that
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Jenn was very upset and so again I intervened. Jenn turned around and walked back to
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the couch were Lauren was sleeping. Wendy finally left at my final request. I did meet
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later in the week with Wendy to discuss things but it has just become crystal clear to me
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that she is blind to Andy's behaviors and so there is simply no talking to her about these
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issues. At no time did Wendy say anything about feeling threatened by Jenn.
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Jenn was upset by Wendy on both May 3rd and May 61h that was clear to see. But
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at no time did she make any threatening statement or take any action that would seem
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threatening. Wendy was on my private property to drop off my granddaughter. She was
Dyer & Primont
503 Twelfth Ave.£
Seattle, \.VA 98102
Page 3
07/~5/2006 17:55 3606685072 HOLLAND PAGE 04
not invited for any other purpose. She insisted on coming in roy house and when she did
I felt that she was not appropriate in her approach. J was glad when she was gone.
As I said earlier, we have worked hard .. to remain calm and to take things in stride
over this last year but it has been hard. Wendy has never at any time appeared to have
any fear of Jenn or me. Likewise, Andy has never appeared to have any fear of me or
Jenn. Neither of them has ever mentioned being threatened by the fact that I drove by his
father's house in December, although we have discussed the fact that it meant I knew he
was working that day. We have had several dozen more visitations s.ince the o.nes on
May 3rd and 61~ and at no time has Wendy asked that Jenn not be around or made any
issue of feeling afraid of or threatened by Jenn. Likewise, Andy has been around me on
the same dozen or so visitations since the drive by appraisal of his house in early June yet
at no time has he seemed the least bit threatened or afraid of me.
This .is all a ruse to have an edge in the divorce trial. From what I have read this
last year, it is also very typical of abusers who are not ready to stop the abuse. It seems
sad but these are the only reasons I can think of they would go to all of this trouble and
expense. It has made visitation between Andrew and Lauren impossible. It has made our
entire family, me included, completely unwilling to help with visitation exchanges at all.
It has left Jenn feeling very vulnerable and has made her recovery from Andy's abuse
take that much longer and be that much more difficult. He is still abusing her only now
he is using the system to do it.
I was present during the time Wendy was at my home on both May 3ro and May
6111 and at no time did Jenn do auything that would appear threatening in any way towards
Wendy or anyone else.
foregoing is true and correct. Signed and dated this J5 day of July 2006 in Everett,
Washington.
f!1M-tt. I~
CAROL HOLLAND
0..claratlon Carol Holland

Page4
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8 SNOHOMISH COUNTY DISTRICT COURT
9 EVERETT DIVISION
10
In re: Case No. U06-215
11
WENDY RIFE, ORI 7 DECLARATION
12 Petitioner
And
13
14 JENNIFER RIFE,
Respondent.
15
16 I, Jan Dyer, declare as follows:
18 following statements pursuant to ORI 7a(2):
19 I have examined the Declaration of Carol Holland which consists of 4 pages not
20 including this declaration. The fax transmission is complete and legible.

22 98102, telephone number 206-343-1528 and fax number 206-343-7781.
24 the above statements are true and correct.

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Dyer & Primont
503 Twelfth Ave. E
Seottle, WA 98102
(206) 343-1528
IFUIL!EIQ) . ---.::--
JUL 0 7 2006
SNO. CO. DISTRICT COURT
EVERETI DIVISION .
Petitioner (First, Middle & Last Names)

PETITION FOR AN
ORDER FOR PROTECTION
.UNLAWFUL HARASSMENT
1. I am petitioning for .an Order for Protection against Unlawful Harassment. ·'
2. D I am ihe victim o.f unlawful harassment committed by respOI!dent, as described in the statement ·
below. . ,.- -
0 ram the parent or guardian of chiid(ren) under. age 18 and seek to restrain a perso~ age' i 8 years
or over from contact with my child(ren) because contact is detrimental, as described in the -
statement below. ·
3. ;El-The harassment took place in this judicial district. !B-1l.espondent lives in this judicial district. ·
4. Identification of the Petioner: · 5. Identification of the Respondent:

\Name \ ~ CS-~~'"~·.(:;.,,-K,._"-R,"~;£
Age. 5(,, . . Age 3 ·--z_ .
6. Identification of Minors:
Name How Related to Resides
(First, Middle Initial, Last) Age . Race Sex Petitioner Respondent with'
I I
I I I
I
I I I
I I I
\ ..
,'. .
. EXHIBIT+
'I
5. Other-·courtcases or any orher protecti6n, restraining or no.:cont:.i.ct orders involvine. me. Lt-ie ffiinors
and the respondent: - - ·
REQUEST FOR TEMPORARY ORDER: AN EMERGENCY EXISTS as described in the

statement below. I need a temporary restraining order issued immediately withouc norice to the
respondent until a hearing to avoid great or irreparable harm. I request a Temporary Order for
Protection that will: YOU MUST CHECK BOTH BOXES FOR EACH REQUEST.
14 I REQUEST AN ORDER FOR PROTECTION following a hearing THAT WILL:
Day l Year
/ v RESTRAIN respondent from making any attempts to keep under surveillance,

£lme D the minors named in paragraph 6 above .
..
v ./ RESTRAIN respondent from making any attempts to contact, except for mailing cif
court documents, D me D the minors named in paragraph 6 above,~
EXCLUDE respondent from any place I may reside.
RESTRAIN responden~Ocr uctng within
- (distance)
of my D reside~ r lace other:
;
_9.:!P.J::K: E~t o...<, ~~ <-, ~J +.,,

(J (.LLVV' ,..,,, .
' ' '.::;> ~·. . . }e > u-<...~ ~....;f-.fv <: Y.c?,,_,'lA._,
..
· v, s ,~h'1J;: .flA.,(Jt;:::;l_ "jj:-.fp 5 _ 3 - o 2--i ~ ·- / ·
REMAIN EFFECTIVE longer than one year because respondent is likely to resume
· acts of unlawful harassment airainst me if the order exnires in a vear.
,. REQUIRE the respondent to pay the fees and costs of this action.
Unlawful harassment means a knowing and willful course of conduct directed at a specific person
which seriously alarms, annoys, or harasses, or is detrimental to such person and which serves no
· legitimate or lawful purpose. The course of conduct shall be such as would cause a reasonable person
to suffer substantial emotional distress and shall acrually cause substantial emotional distress to the
petitioner or when the course of conduct would cause a reasonable parent to fear for the well-being of
their child. Course of conduct means a pattern of conduct composed of a series of acts over a period of
time, however short, evidencing a continuity of purpose. "Course of conduct" includes, in addition to
any other form of communication, contact, or conduct, the sending of an electronic communication.
Constirutionallv orotected activities are not included within the meaninl! of " course of conduct."
ST ATEl\<IENT: The respondent has committed acts of unlawful harassment as follows. (Describe
soecific aces of harassment and their appro:ocimare dates, beginning with die most recent act. You may
.r:~C
want ro include i:_olice responses.)
S'-e e_ 'ti<-<--~ a-'6""" 4 /, 1"-'-<--<-Jlts:..• . -s..
;
STA TEME"1T: (Continued)
---
,/
I certify under penalty of perjury under the laws of the state of Washington that the foregoing is uue and
correct.
DA.TED _ _._7_·. . (,.,,~_·_,0"'"-

. _G=-___ ar -l.0.A..d.l/~-11....1<-/;;f:?"""-.c...-----Washingmn.
1
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3 \?U\1=J~@
4 JUL O7 2006
5 SNOE~~R~~T~1~11f6iuRT
6
COUNTY OF SNOHOMISH
7
s In re:
9
Wendy Rife
and
Petitioner, NO. lA 00- J(cJ
10
Jennifer Rife
11 Respondent.
12 I, WENDY RIFE, declare under penalty .of perjury of the laws of the State of
13
1. IDENTITY AND BACKCROUND
14
I am Wendy Rife. I am Andrew Rife's mother. Andrew and his wife Jennifer
15 Rife are in the process of a divorce. I make this declaration to explain to the
court why I now need an order for protection from unlawful harassment. .·
16
I have been designated by the Guardian ad Lltem to be one of the persons
17 approved to supervise Andrew's visitation with their one year old daughter.
The routine for visitation is that Jennifer is responsible to deliver the child at
18 Andrew's home. She does this by having a family member do the actual
delivery so there is no contact between Andrew and Jennifer. Ordinarily carol
19 Holland is the person who actually delivers. Andrew is responsible to deliver
Lauren to Jennifer's parents' home. He remains in his car, and I take the baby
20 from the car to the front door to deliver her to Jennifer or one of her family
members. Again, the system is designed to assure that there is no contact
21 between Andrew and Jennifer.
22 Jennifer Rife has a pattern of conduct of calling to shout at me and threaten
me that she will cause Andrew's (and by implication myl time with Lauren to
23 be restricted simply because she is angry.
24 There are several family members on each side of this case.
25 2. CAST OF PLAYERS
26
CARll.GAUL
27 . Attorney at Law
EXHIBIT-1>~-- 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FfVI. 259 7081
1
Lauren Rife The Child
2 Andrew Rife MY son, Lauren's father, Jennifer's estranged
husband
3 Jeff Rife My other son, Andrew's brother.
4 Jennifer Rife MY daughter in law, Andrew's estranged wife
Lisa srunsman Jennifer Rife's sister
5 Mike Brunsman Lisa Brunsman·s husband
carol Holland Jennifer & Lisa's mother
6 Steve Holland Jennifer & Lisa's father
7 Bridget Llewellyn Guardian ad Litem
8 3. MAY 3, 2006 INCIDENT
9 on May 3, 2006 there was a hearing in the divorce case. That hearing was
continued at the request of GAL Bridget Llewellyn. By coincidence, visitation
10 was scheduled for that day. carol Holland delivered the baby at the ordinary
time. It was a great visit. Lauren is so happy when she is with her father.
11
At the time of the return, Jennifer was not in the house, she was in the
12 driveway cleaning her car when Andrew and I arrived. She approached the
car directly to get Lauren. I was out of the car attending to getting Lauren
13 out of the car. While she and I were both there at the car, I asked Jennifer for
Lauren's social security number so I could open a savings account for her.
14 Jennifer was irritated and told me to get it off Andrew's income tax
documents. Lauren would not go to Jennifer, so I carried her from the
15 driveway up onto the porch. 1handed Lauren to her on the porch. Jennifer
immediately went into the house. Jennifer's mother carol Holland was coming
16 out onto the porch and heard Jennifer's angry response. carol told me it was
a bad day for Jennifer and I asked the wrong question as she was upset that
17 Andrew had filed married/separate for 2005. I told carol that I only wanted
the social security number to open an account and that I did not want to be
18 involved in the controversies between her and Andrew. I asked carol if I could
talk to Jennifer to explain why I had asked for the social security number.
19 carol let me into the house. When I got inside, Jennifer wanted to talk about
the declarations filed in the divorce action and the visitation. carol told her
20 I did not want to discuss that issue. Jennifer brought it up again. Her mother
repeated that I did not want to talk about those issues. Jennifer returned to
21 the topic a third time. carol stopped her a third time. Jennifer left where we
had been standing and started toward their family room. As she was walking
22 away she was shouting at me that I would have supervised visitations along
with Andy from now on.
23
There was no reason for Jennifer to raise that issue with me. I am a
24 grandmother and 1 have no right to visitation myself. I have only been
designated as one of the visitation supervisors. The only reason that Jennifer
25 would have been telling me about future visitation conditions was specifically
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201 .
. . 425 259-4147 FAX 259 7081
:..
to threaten and upset me. She succeeded. I called the guardian ad !item and
told her of this explosive temper incident. I also went into her office and
discussed it at some length.
After the May 3 incident and my discussions with the GAL, 1hoped that there
would be no similar future incidents.
JULY 1, 2006 INCIDENT
on July 1, 2006 Lauren was delivered at Andrew's house by Lisa Brunsman. She
delivered the baby at 10:45 a.m. She was driving Jennifer's BMW. 1went out
to the car to get Lauren from her. Lisa never left the immediate vicinity of
the car.
While Lisa was delivering the baby, my son Jeff Rife came over to Andrew's
house. He parked behind Lisa's car, got out and cut across the lawn and went
in the front door. cutting across the lawn was the most direct route from his
truck to the front door. There.was no contact at all between Jeff and Lisa,
not a word, not a glance, not a gesture, nothing. I finished gathering up
Lauren and took her into the house. Lisa left.
At 11:00 a.m. the phone rang, Jeff answered. It was Mike Brunsman. After a
couple of minutes of friendly conversation Mike asked to speak with me. Jeff
gave me the phone. Mike told me that Jennifer wanted to speak to me and
asked that 1call her on her cell phone about visitation .. 1called from Andrew·s
home telephone to speak with Jennifer as requested: Jennifer told me that
Lisa said thatJeff had pulled in fast and jumped out of his truck, slamming the
truck door and walked angrily to the house and that he had a mean look on
his face. I told her that Jeff and his actions had all looked very normal and not
angry or upset to me. I reminded her that Jeff was specifically asked by
Andrew and his attorney to avoid all contact with Jennifer and her extended
family. At this point she became noticeably upset, she was angry. Her anger
came on like somebody had flipped a light switch. She told me emphatically
that Lisa would not lie about this. I just asked what she wanted me to say.
Jennifer then told me She is "sick of all of you." She complained of Andy
being angry. She said that we are all liars in our declarations about her. Then.
she demanded that we immediately deliver Lauren, ending the visit that had
just begun. She then told me that we could not see Lauren at the scheduled
visit on Monday, July 3, 2006. Before I could make any response she hung up
on me.
Shrotly after, the phone rang and there was a hangup. *69 showed that the
call came from a "private" number. About fifteen minutes after that there
was another hang up phone call.
Andrew and I discussed what to do. I told him that the court order was clear
and we should comply with it, delivering Lauren at the customary time, 5:30
p.m. I called and left a message for Bridget Llewellyn to tell her of the
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259·4!47 FAX 259 7081
1 incident. When we delivered Lauren Mike Brunsman came out to get her.
Mike's behavior was perfect. Both Jennifer and Lisa's cars were there, but 1
2 did not see either of them.
3 on Monday, July 3, 2006 I got a call from Mike Brunsman. He asked me if he
could bring Lauren to Andrew's house for the visit. I asked Mike if Jennifer
4 and Lisa were afraid to bring Lauren in to town. He just chuckled and did not
answer. Andrew was happy to have Mike do th·e delivery. Mike delivered the
s baby without incident. Another Great Visit. At the delivery, Mike again came
out of the house to get Lauren.
6
5. MY OPINIONS
7
Jennifer's conduct serves no useful purpose. I am a grandmother and 1 am a
a .supervisor for visitation. She is trying to intimidate me to get to my son. But
in the process she is upsetting me. She.wants to upset me. That way the visit
9 will be unpleasant for all concerned.
10 I believe that Jennifer will behave the same way in the future if the court
does not limit her ability to communicate with me. There is really no reason
11 for direct communication. I don't need the aggravation, and Jennifer needs
to find a different way to express her frustrations.
12
:: Executed at Everett WA on July 6, 2006. wi:irR#{~ (/211·) .

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CARLJ.GAUL
27 Attorney at Law
· 302 Bank of America Bldg.
1604 Hewitt Ave.
Everett WA 98201
425 259-4147FAX 259 7081
"
1
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6
EVERETT DIVISION
8
9
ANDREWS. RIFE,
10 Petitioner, No. U06-216
11 and
Declaration Carol Holland
12 CAROL HOLLAND,
13 Res ondent
14
15 My name is Carol Holland and I am the respondent named above. I am over 18
16 and otherwise competent to testify. I am making this declaration based on my own
17 personal knowledge.
18
Andrew Rife is my son-in-law. He has filed for a divorce from my daughter
Jennifer. Jennifer is the respondent in Andrew's mother's companion request for a No
19
Contact Order in case No. U06-2 l 5. Andrew was arrested for assaulting my daughter
20
and for violating the No Contact Order that was issued by the criminal court after he
21
assaulted her. Now they are in the middle of a divorce. Andrew's visitation with our
22
granddaughter is supervised. Because our daughter has a DV Protection Order and a
23
Criminal No Contact Order preventing Andrew from coming near her I have helped with
24
the visitation between Andrew and his daughter Lauren. I have been the person who
25
primarily takes Lauren to Andy's home at the beginning of her visits and then he and his
26
mother return her to my home at the end of the visit.
27
The first incident Andy alleges is a complete fabrication. Andy did not have
28
residential time with Lauren in October of 2005 as the first court order was entered in
29
November and Andy had no visitation until that time. I did not drive by Andy's dad's
30
house, slowly rev my engine and give them bad looks. That is simply a lie.
Dyer & Primont
503 Twelfth Ave. £
Seattle, WA 98102
Declaration Carol Holland
1206) 343-1528
Page I EXHIBIT ---'(__,'"'---
..... \/' .
1 The only time I have driven by his father's house in the last year was on Dec. 17,
2 2005. Andy only knows this because I told his mother that I drove by there and saw
3 Andy's truck. I was in that part of town on business and had I 0 minutes to kill. I was
4 curious if Andy was really working with his dad because Wendy had made what seem
·5 like a lame and unbelievable excuse for Andy not to have visitation on that Saturday.
6 did not drive to this part of town to drive near this house. I needed to pick up a
7 prescription at the Bartell's there as it was were my prescription had been called in
8 previously and where I had it filled before. I was told by the pharmacist at the drive
9 through window to come back in I 0 minutes. So I drove around. I checked out a couple
10 of houses I had listed or was interested in hooking clients up with in that part of town and
11 then drove back to the pharmacy via a street that went near Andy's dad's house. (See
12 attached Exhibits A, B and C). Andy's truck was in fact at his dad's house and we
13 continue to believe that the visit was changed by Wendy/Andy to suit Andy's need to
14 make extra cash working for his dad.
15 The 3rd incident is also benign, and again I am afraid it is the Rife camp, in the
16 form of Mr. Gaul, who acted in a threatening manner in this instance. My daughter's
attorney in the divorce had asked me to have a "drive-by" appraisal done of Andy's
17
home. In early June of 2006 I did just that. I hired an appraiser and we drove to Andy's
18
address but parked across the street and several houses down. The appraiser walked over,
19
on the public sidewalk and took a couple of pictures. I stayed across the street at my car.
20
We saw that Andy was there but we did not attempt to make any contact with him as we
21
were only there to look at the house and get a photo of it. The appraiser has also written
22
a declaration and it is attached. To my knowledge there has been no court finding that
23
this house is Andy's separate property and that the community has no interest in it at all.
24
He has no basis to make those assertions.
25
Shortly after that I received a call from Andrew's attorney, Carl Gaul. Mr. Gaul
26
tried very hard to intimidate me. He demanded to know why I had been near Andy's
27
house and told me that if I did not answer him, "it was going to cost somebody a lot of
28
money." When I tried to respond to him that it was a free country and that nothing I had
29
done was illegal or wrong, he yelled back at me saying, "Don't give me that crap." I felt
3p
quite threatened yet did not obtain any protection order for myself.
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Declaration Carol Holhtnd
(206) 343-1528
Page 2
' -.
1 To be clear, Andrew has filed a Petition asking that his me, his mother-in-law and
2 the person who has facilitated visitations with his daughter. not come near him or near his
3 home. He filed this claiming that he felt threatened by me. He feels threatened now
4 because I allegedly drove by his father's house back in October of 2005 at a time when
5 he says he was having residential time with Lauren but we know he was not. He feels
6 threatened now because in December of 2005, when I was in the neighborhood with 10
·7 minutes to kill 1 drove near his father's house when he was not even there. And finally
8 he feels threatened because a month ago I brought a real estate appraiser to his
9 neighborhood to see and photograph his house, which is subject to the divorce action.
10 The court should note that he signed the declaration on the 28 1h of June yet did not bother
11 to go to court until the 7•h of July, when he was on notice that Jennifer's attorney was
12 going to go to ex parte, in Superior Court. My daughter got served with her order while
13 she was at court. I was out of town and did not get served until the following Thursday,
almost a week later. In fact I did not even know that an order had been obtained against
14
me. Andy knew though. Two more times before I was served, I brought Lauren to his
15
house for visitation and he continued to come to my house with his mother when she was
16
returned. He is not threatened by me. He is only seeking this order to hurt Jenn and our
17
whole family. I have done nothing to threaten him.
18
This Petition was brought by Andrew in complete bad faith and only obtained for
19
the express purpose of harassing our family and exacting some type of revenge. It should
20
be dismissed and I should be awarded attorney fees and costs in defending myself against
21
these false allegations. I understand that these types of orders are necessary in some
22
cases but I can certainly see how easily they can be obtained and used for an improper
23
purpose. I am trusting that the court will see that there is no basis for this Petition and
24
that it's issuance has harmed more people than any protection it offered.
25
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Dyer & Primont
503 Trvelfth Ave. E
Seattle, \-VA 98102
Declnration Carol llolland (206) 343-1528
Page 3
'l ~.!. 25/ 2006 . 18: 01 3606685072 HOLLAND PAGE 05
I declare under penalty of perjury of tbe Jaws of the state of Washington that tbe
foregoing is true and correct. Signed and dated this !J., 1 day of July 2006 in Everett,
Washington.
bx.1~
· CAROL HOLLAND
Dccl•ratinn Carol HollAnd

P111ged
'.:. l -··
1
2
3
4
5
6
7
EVERETT DIVISION
9
10
In re: Case No. 006-216
11
ANDREW SCOTT RIFE, GR17 DECLARATION
12 Petitioner
And
13
14 CAROL LEA HOLLAND,
Res ondent.
15
18 following statements pursuant to GRl 7a(2):
20 including this declaration. The fax transmission is complete and legible.


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Dyer & Primont
503 Twelfth Ave. E
SeRttle, WA 98102
a06> 343.1s28
07/25/2006
Patient Profile Detail

10:46 3606685072
. .-..-·· -·
HOLLAND
·~.·~=-
PATl,ENT.PROFILE DETAIL (1)-·----~\
--·· -. PAGE 04
Page 1 of 1
BARTELL DRUGS #48 07/1912006 02:25PM
1825 BROADWAY
EVERETT, WA 98201
(425) 303-2584
FROM: 01/0112005 THROUGH: 07/1912006

RECORD OF PRESCRIPTIONS FOR:
CAROL HOLLAND
9724 146TH PL SE A/lergieS:
SNOHOMISH, WA 982SO
SEX: F
PRIM
RX# ITEM RPH QTYO RFL# CAM REF#
HYDROCHLOROTHIAZIDE 25MG TABLET (!VAX) RBR2 90.000 0 T40509052EYVE1

25MG TABLET DR. SALAZAR-, MARIAM
NOC: 00172-2063-SO PAT PAY: S 16.19 CVG: CASH
__llNS+R;~~,PNE TABLET DAILY FOR HIGH BLOOD PRESSURE DAYS: 90
173736 HYDROCHLOROTHIAZIDE 25MG TABLET (STAD1· RBR2 90.000 1 TA05121749H4T1
MG TABLET DR. SALAZAR-, MARIAM
NDC:67253-0S20-11 PAT PAY: S 1B.19 CVG:CASH
.----~KE ONE TABLET DAILY FOR HIGH BLOOD PRESSURE DAYS: 90
173736 HYDROCHLOROTHIAZIDE 25MG TABLET (STAD1 RBR2 90.000 2 TD0603155WBHY1
N/C: MG TABLET DR. SALAZAR.., MARIAM
NOC: 67253-0820-11 PAT PAY: S 16.19 CVG: CASH
ONE TABLET DAILY FOR HIGH BLOOD PRESSURE DAYS: 90
173736 HYDROCHLOROTHIAZIDE 25MG TABLET (PLVA) WES 60.000 3 1603317961409
MG TABLET DR. SALAZAR .., MARIAM
NOC: 50111-0886-03 PAT PAY: S 12.59 CVG: CASH
INSTR: TAKE ONE TABLET DAILY FOR HIGH BLOOD PRESSURE DAYS: 60
TOTAL PATIENT PA.Y AMOUNT FOR PRESCRIPTIONS LISTED: $81.18

GRAND TOTAL: $81.16
Sort Order: Facility, Patient Name, Dispense Data, RX#
Criteria: .. EXliiBIT
' . HOLLAND PAGE 06
07/~5/2006 10:46 3606685072
ML::> Northwest Reports (502) Page I of2
71
~-T: 23-·-------- ---- ·---~-: ____ ~- ---- --- ---~-'=-~~'.'_~~-e_:e_t_t_____ -~~~'.~~~'.2''._~;, ~----::~
L M u BR: 2 AR: 740 SP: 182.0oo""•-'•"
BR 2 BTH: 1.00 MAP: 396 GRD:E-1 OLP: 188,000 )
FUL 1 SF: 988/988 Stat 02103/05
LO: ~2/08104
1 1
3/4 BDI: Stick Built Off Stte STY: 0- Story
1/2 BOC: Good TX#: 0043883530<300 SLO : 02/01105
KIT X GAR: 1 TXS: 1925 YR: 2004
KES GR: Garage-Detached ENS: Natural Gas
FAM YBT: 1949 HTC: Forced Air ---
so: Windermere Real Estate GH LLC BRM LSZ: VEW: Territorial
(ID: 7487) DNO ACR: 0. 14016098 WFT:
Phone: 425-348-5960 RRM MBD: M/M TRM: Cash Out, Conventional
EFR DIN: Main FLS: Hartlwood, Vinyl, Wall to Woll Carpet
FP AOU: RF: Composition EXT: Wood
BSM: None ARC: Contemporary
------·----~---- ------· -----·-----·---- .. ... -----·--···-----·· ---- -- . ·····--· ....... _____ ··----·-......................................................._______ ..
_, -~·-···----··-·
SD: Everett EL: Everett High ...... -

OTVP: Tenanl SOC: 3.0 LO: RE/MAX Northwesl Realtors (ID: 6144) Pho · 4< 1-8888
PTS: 425-418-4311 LAG: Carol Holland(ID: 90100) Phone:206-964-1743
OWN: Watkins Family LLC OPH: 360-568-4007 CLO:
KEY: MLS Keybox, Pet In House, Renter-Call First
-:-'.:···-~·
-.. -::.:::·-·-·=-·--=
..·--=-.---=""""":::::;:'"·""·-="
·- -=-----=:_
......... •--·-------·-·---
Directions: From Broadway east on 17fh two bloeks, right on Rainier, home on right
----------··----- -- ______________ .. .,, __________ ---·-------
Agent Only Romarks : Cooperative tenant monlh to month, pis call for appt, no answer OK to show, 9AM-8PM. Pis be con~iderate. Dog Cleo
will be in beekyard or garage, do not let out. Firat AM Title #497262. Great for 1st time or step down buyer or investor!
------·-------------------------·------------------·-----------"------------------
Marketing Remarks : Very clean rambler In nice established neighbort'lood. Two very generous Gi%ed bedrooms_ Kitclien opens to dining
nook, full of charm, built in china hutch and eabineta with glass fronts, Gas heat, hot water & range. All appliances stay. Newer carpet and
paint. Detached one c.ar garage off alley access, room for R:V pkng. Fenced rear yard with deck. room to garden tool Nice location - close to
schools, snopping and hospi!Jll.-:-::::::::===--..,,"=:::-.~ ··---~··....~,·····----------·--..--., •. ._. _____......,.....,.__ ......... _________,.,__ _
all Ave Venttt 98201 Snch ST: Sold
-'\
LT:1
BR 2
BR:
LK:496
2
BTH: 1.00
COM: Everett
-·""'""··-··-----·------··'"'"'"'-··-·- .. ----·--~-·--------
AR: 740 SP: 190,000
187,900
---·-- ' \ '
'
MAP: 396 GRO:E-2 OLP:
FUL 1 SF: 0/ StatDt 09/16/05
3/4 BDI: Stick Built On Lot
STY: 10-1 Story LO: 08/08105
SO: CENTURY 21 Real Estate Cenler

112
KIT
KES
FAM
BRM
x
BDC: Good
GAR: 1
GR:
LSZ:
Garage-Detached
YBT: 1964
TX#: 00401649600101 SLOT:
TXS: 1748
ENS: Electric
HTC: Baseboard
VeN: Territorial
YR:2005
09116/05
)
(ID: 7441) ONO ACR: 0.000/ 0 WFT:
Phone: 425-252-0333 RRM MBO: M/M TRM: Gash Out, Convention.al
EFR DIN: FLS: Hardwood, Vinyl. Wall to Wall Cerpet
FP ADU: RF: Composition EXT: Wood
BSM: None ARC: Con!emporary
SD: Everett EL: Buyer To Verify JH: North Mid SH: Everett l:i_igh
.-. .. - ...-----·---·-- ---·----~ ....-- ·-··-----:~~ -~_, ... .. ________ _
OTVP: Vacant SOC: 3.0 L : RE/MAX Northwest Rea11orn (ID: 6144) Phone:
PTS: 000-ollO·OOOO : Carol Holland(ID: 90100) Phone:20S-964-1743
OWN: Watkins Family LLC OPH: 360-568--4007 CLO:
KEY: MLS Keybox, Vacant· CLA:
Directions : From BroadWay. east on 23rd 2 blocks 10 Medougan, house on comer
A.gent Only Rom.ark.&: Preliminary title ordered through Firsl American. The back yard landscaping to be spruced up by Friday B/12. Please
be sure to leave card and lock all doors (except front deadbolt). Front door can be sticky. Thanks!
Marketing Rom.arks; Very eute and clean rambler on sunny lot in N. Everett. Tree llned street close to amenltlras. New carpets throughout
and most rooms recantly painted. Kitchen cabinets and countertop are newer, plenty of storage. All appliances stay. Detached garage WS$
converted to e rec room/office but _oou/d easily be changed baek.. Addtt.ional slorage behind garage_ Fenced yard with block patio.
http://locator.nwmls.com/scripts/mgrqispi.dll 7/17/2006
PAGE 05
HOL.LAND
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2
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6
7
9 EVERETT DIVISION
10
In re: Case No. U06-216
11
ANDREW SCOTT RIFE, GRl 7 DECLARATION
12 Petitioner
And
13
14 CAROL LEA HOLLAND,
Res ondent.
15
18 following statements pursuant to GRl 7a(2):
19 I have examined the Declaration of Cynthia Everroad which consists of 1 page
20 not including this declaration. The fax transmission is complete and legible.


26
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28
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30
Dyer & Primont
503 l'w<lfth Av.. E
Seattle, WA 98102
(206) 343-1528
HOLLAND PAGE 03
07/2~/200'6' 10:46 3606685072
..
I Cinthia Kristine Everroad, declare under penalty of perjury of the laws of the State of
I met Carol Holland Oil the street near property address 2416 5th Street in the city of
Everett, WA. At that time we had an appointment to do a "drive by'' appraisal of the
property listed above. I was informed that there would be no access to the interior of the
property no would I. be granted access to the property in any form.
The appointment was set for 10:30am on June 22, 2006. We met across the street from
the property, noted that the home owner was in his drive way and proceeded to drive
around the street to discuss the appraisal information needed.· After approximately 15
minutes we drove back to the home, parked across the street in a similar position from the
home. At no time did either I or Carol erter onto private land, nor did I come closer to
the home than to take a photo of the front of the subject and side. I took these photos as
Carol was standing in front of her car writing a check for services rendered. At no time
when I was present did she "cross the street to the South side of 5th Street". She at all
times that l was present was cautious to stay near her car and left at the same time I did,
approximately lO:SOam.
Signed in Mill Creek, Washington, on July 20, 2006

STATE OF WASHINGTON:
COUNTY OF SNOHOMISH:} ss.
·· ····· ······-· · ·111e-unaer$fgneuum-orura-C0W1.w.xs-11t:reb1 certtt).. tMt 'this·· ·· ··
trul
fFDIL~IQ)
instrument is a :ind correct copy of tile origin:il on file in this court.
Dated thi:; ""';;'] day of - \ ' ·~ . . 20 ..11!:::{
By Evett:n~~kafCaun ~ · .
Snohomish County Oi:'ct Court Evercn Division JUL 2 1 2006

SNO.co DIS
. EVEFien1;~~~182UflT
EVERETT DIVISION
Andrew Scott RIFE MAR22, 1973 CASE NO. U06-216

Petitioner, (First, Middle & Last Names) DOB
REISSUANCE OF TEMPORARY
ORDER FOR PROTECTION AND
NOTICE OF HEARING
vs
UNLAWFUL HARASSMENT
Carol Lea HOLLAND OCT 14, 1949
Respondent. (First, Middle & Last Names) DOB
The Temporary Order for Protection issued on JULY 7. 2006, is hereby extended through the new
court hearing date on this matter on A'"'")",.;.- 4 ,'·''"~(date), at II:""' fl-:t!ime) at .
· (location).
'if Other:
.f<._:,
The Clerk of the Court shall forward a copy of this Order on or before the next judicial day to the:
D EVERE'IT Police Department where petitioner lives which shall enter this Order in any
computer-based criminal intelligence system available in this state used by law enforcement to list
outstanding warrants.
5\SNOHOMISH County Sheriffs Office where respondent lives which shall personally serve the
respondent with a copy of this Order, the Temporary Order, and the Petition, and shall promptly
complete and return to this court proof of service.
~_.::;..\- -
EXI-liBIT
-.·
SNO. CO. DISTRICT COURT

EVERETT DIVISION

EVERETT DIVISION
_c,.-..J-S-cJ-rl--:T=-~.'-h-0~0-.-3(_-z._-z-{__7---i.3 CASE NO.
._j,._\6,,_J I)._ v0 - ~ f0
Petitioner (Firsr. Middle & Last Names) DOB
PETITION FOR AN
vs. ORDER FOR PROTECTION
UNLAWFUL HARASSMENT
Respondent (First, Middle & Last Names) DOB
1. I am petitioning for a.n Order for Protection against Unlawful Harassment. /

2. gj I am tbe victim of unla~ harassment cominitted by respondent, as described in rite statement
below.
0 I am the parent or guardian of child(ren) under age 18 and seek to restrain a person age 18 years
or over from com:acr with my child(ren) because contact is deirimenral, as described in rhe
stateme:ut below.
3. Ef The harassment cook place in this judicial district. ~Respondent Jives in th.is judicial district.
4. Idemification of the Petioner: 5. Identification of the Respondent:

IName IP\od.~e ") 5. n f
6. Identification of Minors:
Name How Reblted to Reside•
(First. Middle lnid.al. Li.st) ,:\!?e Race Sex Pericion~r Resnondent \\·ith
D,~,., ,. J'0iv- J\
' I
\ I •
I
'
I I
!
I i I I
I ! j I i r
'
1'0 39\ld GN\lllOH

I ..
··- __ --- ·-··~~.<VU\.• v1U.1.t<:.K: AN EMERGENCY EXISTS as described in me

statement below. I need a cemporury resi:raining order issu~d immediai:ely wit:houc notice to che
respondent until a nearing to avoid greac or irreparable harm. I requesc a Ternpor;iry Order for
Proteetion mac will: YOU MUST CHECK BOTH BOXES FOR EACH REQUES1'.
14 1 REQUEST AN ORDER FOR PROTECTION following a hearing THAT WILL:
Day 1 Year
RESTRAIN respondent from making any attempcs to keep under surveillance,
x. )( (A' me 0
tbe minors named in paragraph 6 above.
RESTRAIN respondent from malcing any attempts co contact, except for mailing of
court documencs, 0 me 0 tb.e minors named i.a paragraph 6 above.
EXCLUDE respondent from any place I may reside.
RESTRAIN respondent from enterin~ or bein~within '/~ """ k
x >( of my r:il residence 0 workplace other: - f=pf' .~ ,'d..•-.7"
(distance)
:n:i ~fi..,,~ ..L
tJf c..i-.../ t• f;':,.,..•>•"f-,,_'f,"z).,..,_ "-? ~'f't-<Ovi ;i.-<<f hJ ~
e:I'HER:
c:J. •v •.....-...a. 'f liL · .
REMAIN EFFECTIVE longer than one year because respondent is likely ro resume
acts of unlawful harassment against me if Ille order ex:oires in a year.
REQUIRE the respondent to pay rhe fees and costs·ofthis action.
Unlawful harassment means a knowing and willful course of conduct directed at a specific person
which seriously alarms, annoys, or harasses, or is detrimental co such person and which serves no
· legitimate or lawful purpose. The couI'lle of conduct shall be such as would cause a reasonable person
co suffer substantial emotional distress and sbaU acrually cause subsr.ancial "motional dist:ress ro che
petitioner or when the course of conduct would cause a reasonable parem co fear for r:he well-being of
rheir child. Course of conduct means a pattern of conduct composed of a series of acts over a period of
time. however shore, evidencing a conrinuiry of purpose. "Course of conduce" includes. in addition ro
any other form of communication. l!omact. or conduct. the sending of an elecrron.ic commurtication.
Constirucionall orocected activities are nor included within the mean.in of" course of conducr." ·
I
STATE!'YIENT: Tue respondent ha.s commiaed acts ofuruawfu\ harassment as follows. (Describe
soecific acis of harassment and their npproximace dares. beginning wich the most recent acr. You may
wanr co include police respo~s .) ,·1. /'_
S-c < ~- {~,,_/, ,,..-.._ f-"-. <
nn •r7 nnn..,. ,,.... ... ' , ....

7.J CfCQQQr.:lOe"
S0 39\ld GN\lllOH
I certify und<lr p.:nalty of perjury under !he law; of the state of Washington rhat the ioregoing is mie :'llld
correct.
£~~
:it----~--'--------- W:!.Shington.
90 39\;'d GNllllOH
\ .
··'
4 SNOEf~R· 0/STRrcr COURT

ETT 01vrs10N
5
6
COUNTY OF SNOHOMISH
7
a In re:
9
Andrew scott Rife
and
Petitioner, NO. uoev -J-' 0
10
Carol Holland 1:1... ...C-t-'k~ l.J~ "6 °';l,'k
11 1--~~~~~~~~-'-R~e~s~p~o~n~d~e~n~t._,_~~~~~~~~~~~~~~
12 I Wendy Rife , declare under penalty of perjury of the laws of the State of
ashlngton, that the following is true and correct.
13
14
I am Andrew Rlfe's mother. 1 make this declaration to inform the court of
15 Carol Holland's attempts to monitor Andrew Rife and his activities.
16 2. RELATIONSHIPS
17 My son Andrew is presently Involved in a divorce from carol Holland's

daughter, Jennifer. AS grandmothers, carol Holland and I have been involved
18 in the visitation exchanges to assure that the stresses of the divorce do not
get directly expressed bY our children to each other.
19
3. DECEMBER 18, 2005 INCIDENT
20
Carol Holland called me and asked to reschedule visitation set for Saturday,
21 December 17, 2005. After some discussion we settled on having that
weekend's visit occur on Sunday December 18. My own work schedule at
22 Safeway's In Snohomish was a factor in the selection of the time.
23 sunday, Andrew and I picked up the child at Holland's home at 10 a.m .. the
time carol had suggested. Andrew stayed in the car while I went to the door.
24 ·carol answered the door. When she saw me, her first words were, "Did you
change the time so Andy could do what he wanted and work with his dad?"
25 carol said that she had driven In to Everett, to pick .LIP a prescription at
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
<25 259-< 147 FA;;t 259 70CJ
P1 39'i'd QN'i'llOH
EXtliBIT _;Y:..----
___ - - - - , ... - · · - · · - ......... .......... \;O", vvu'"'' a11u u1u 11ut 11t=t:lu Lo ar1ve a11 tne way
4 into Everett. It would have saved her a trip. There is a Bartell's right next to
Safeway In Snohomish, much more convenient to their residence, which is
s only four miles away.
5
a
9
lO
11
12
13
l4
l5
15
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
27 AtnJmey at Lew
1504 Hewitt Ave.
Everett WA 98201
425 259-4l47 FAX 259 7081
51 39';1d ON';'llOH
•.,.
6
COUNTY OF SNOHOMISH
7
a In re:
9
Andrew scott Rife
and
Petitioner, NO. Uo&. - :i I(p
10
carol Holland
"D.., .. c-... -1.·~ °£ Jiv ....<L.r.... 4.> R:k
11 1--~~~~~~~~---'-R~e~s~p~o~n~d~en_t~..L...~~~~~~~~~~~~~~
12 1 Andrew Rife, declare under penalty of perjury of the laws of the state of
ashington, that the following ls true and correct.
13
14
I am the Petitioner in this matter. I make this declaration to explain to the
15 court the facts behind my request for an anti-harassment order.
16 2. RELATIONSHIPS
17 1am presently married to carol Holland's daughter, Jennifer. We separated
on October 1, 2oos. Jennifer and I have a one-year-old daughter together.
18 Transfer of the child between us for residential time is accomplished by the
respective grandmothers.
19
3. STALKINC
20
First Known Incident. In the time following our separation, 1resided with
21 my father at 1317 McDougall. I did not record the date, but in October shortly
after the separation, during mv residential time with my daughter, I
22 recognized carol Holland's car driving by. When she reached the stop sign at
14'" street, she gunned the engine, quite slowly. she did not simply happen
23 to drive by the neighborhood, she was looking for something.
24 second Known Incident. on Saturday, December 17, 2005, carol Holland

again drove by my father's house to check up on me. Visitation had been
25 rearranged from Saturday to Sunday, December 18, 2005. She was checking
/
26
CARLJ. GAUL
AttDmey at Law
27 302 Bank of Amenca Bldg.
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAA 259 7081
GNllllOH <:L0S89909E 00:Ez 900l/E!/l0

L0 3911d
EXHIBIT .f:J:~
l to be sure verify whether 1was working with my father in his business. I know
that this is what she was doing because she had a discussion with tny mother,
2 Wendy Rife, described in my mother's declaration. Carol Holland was upset
that visitation might have been rearranged in order to accommodate my
3 father"s business. It was actually rearranged at my mother's request due to
a change in her work schedule. In fact, my truck was parked at my father's
4 home and I was at a job site helping him: As though it is any of her business.
s Third Known 1ncide 06 was a Thursday. I got off work early.
1went to my home 2415 - S'" Street verett WA to get my towel, intending
'5 to go to the Elks Club or an afternoon workout and steambath. When I drove
up to my house 1found.Carol Holland and another person at my home. They
.7 were each in a car, and when I drove up they both drove away quickly. carol
Holland had a look on her face that showed plainly she had been surprised bY
8 my appearance. The_ other person was not known to me and I had not really
paid much attention to that car until they left simultaneously.
,9
I went Into my house and spent a few minutes getting my things together.
10 When 1 left the house 1carried my towel in a visible manner to be sure that
any one watching would think I was on my way to the gym. I went out to my
11 truck and got In and left. I only drove around the block and parked. I warted
1 s minutes. Then I drove back around the block. carol Holland and the other
12 woman were at my house again. This time they were out of their cars and
were obviously looking for something. The other person was taking plctu·res.
13 When they saw me drive up to my own house the got back into their cars.
quite quickly, and left rapidly. carol Holland's face had a panicked ·1·m caught''
14 look. When she drove away she was actually spinning her tires she was in such
a hurrv.
15
4. NO LECITIMATE PURPOSE.·
15
carol Holland has been stalking me. There is no reason for her to be
17 monitoring where 1am, or what I am doing. There is no reasonable purpose
for carol Holland to be at my home. I owned the home three years before
18 ,Jennifer moved in. My wife's name was never put on the title. It is my
·separate property. It is not marital property to be divided in the divorce.
19
I had my lawyer call carol Holland. She works for ReMax RealtY. and she
20 claimed that she had been looking at a ·neighbor's house for sale ·by
Lamareaux Realty. That house is at 2214 s '"street, two full blocks from my
21 house. When he asked her about photographs she acknowledged that
pictures were taken, but then declined to say more until she had spoken .to
22 her (unnam~dl attorney.
'
•:,.. ...
, , ' " ' ' . , '" 11u.i 1111\,j ' ' 'Y "'"L' a11yeu wire wou1a wanttrom the home. Even though
4 it is my separate property home, Jennifer staved in that home until
November 18, 2005. 1was staying away from my home for her convenience.
s Her attorney sent my attorney a list of the things she wanted to take from
the home. We wrote back agreeing to every single item she listed. Her
6 attorney has not written suggesting any additional items should be made
available. ·
7
In the time since last Thursday, 1have found myself listening to cars passing
s by, wondering whether one is going to be carol Holland coming again to
harass me. When I am not at home I find my mind wandering to whether
g there may be a burglary in progress at mv house.
10 1am surprised at the extent of my reaction. But the more 1thinl< about this
situation. the more convinced 1am that 1am reacting exactly as carol Holland
11 would want me to.
12
13
14
15 on June 28, 2006
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CARLJ.GAUL
27 . Attorney at Law
1604 Hewitt Ave..
Everett WA 98201
qzs ZSSl-41q7 FAX 259 7081
60 391/d GNllllOH ll0S89909E 00:e:z: 900l/E1/L0

i•i--·-
1
2 'J50CT 25 Mill: 5~
3 . 3i:i 9 HBJ.lJ Sti (,';,0 UJtli;:f
SUPERIOR COU!.i··'i 0©t1H.
f I l E·o
,4
OCT 2 5 2005
5
PAM L. DANi£LS CARL J. GAUL
6 SNOHO.~ISH COUNTY CLERK
EX . Or:-IC:o r~ERK OF ~OU:i1 ..llttcrne~r at ·Lav·7
7
~ECEIVED
9
OCT 2 7 2005
10
ANDREW S. RIFE, NO. os.3.003.14.sl.AWoFF1ceo-·
11 ' Petitioner, · . JAN M. DYa{
12
and DECLARATION OF JENJ'll"IER RIFE
IN RESPONSE TO MOTION FOR.
13 JEJ'll'HFER R. RIFE, TEMPORARY ORDERS Al'i'D IN
Respondent. SUPPORT OF HER REQ1J"EST FOR
14 A DOMESTIC VIOLENCE
15 PROTECTION ORDER
16
· I am the Respondent named above. I make this declaration under penalty of perjury and
17
based on my own personal knowledge. I am over 18 and otlierwise competent to testify.
18
I May of 2005 my husba..TJd was .arrested and jailed for assaultir1g me. Shortly after
19
getting out of jail he moved back into our home a..TJ.d continued abusing me. I have been so
20
21
confused and beaten down that it has been very hard to stand up for our one year-old daughter or
mysel{ His abuse .has only escalated. As the date for his trial came 'near l realized that he was·
22
ac:tively trying to keep me away from our home so that I would not receive the subpoena to
23
testify. I also realized that he w;i.s trying very hard, in concert with his brother, to set me up to be·
24
· charged with assaulting him. I see this all clearly now in hi..-idsight.
25
His trial was set for ·Monday Oct. 3, 2005. On the weekend.prior to that day he pulled
26 ' '
every dirty trick in the book to try to ·incite me into taking some type of action agai~st him.
27
Instead I just took our daughter and stayed with my sister.. But unfortunately, both my daughter
28
a..TJd I were sick. She needed to be home in her own bed with her m.edicine. I called Andy ·and·
29
left a message asking him.to leave so we could come borne. He ignored my messages. I finally
30
. just went back to our house and rang the doorbell until he opened the door. He flew into a rage
. . Dya & Primo
503 Twelf.h A°'
Seattle, WA 98J
DECLARATION OF JENNIFER RIFE (206) 343-1'
Page 1 EXHIBIT__,_\...\-
__
1 and ultimately the police were called. He tried to tell them that I hit him but his story did not
2 ring true. He kept changing' the place on his body that he claimed I hit him. There were no
·3 marks, because I had not touched him, and ultimately the officers realized he was lying. They
4 noted that there was a criminal no contact order against Andy from the previous assault and they
5 ultimately arrested him for violating the no contact order. See attached Exhibits A and B,
6 Everett Police Reports, Incident numbers 05-10775 and 05-21287, incorporated herein by
7 this reference.
8 I did show up to testify against him at his trial. Once he realized that I was going to
9 follow through he took the prosecutors offer and the case was disposed of. I don't know if he
1o pied guilty or what but I do know that he is required to participate in DV treatment and be on
11 probation for two years. The criminal no contact order is to remain in place for that entire time.
12 Attached No Contact Order from Everett Municipal Court, Exhibit C.
13
14 HISTORY OF DOMESTIC VIOLENCE
15 One of the first instances was in 2003 when we went to dinner. When we came home, he
16 realized he .had locked the keys in the house. The first thing out of his mouth was that it was my
17 fault because I wanted to go to dinner, and that he wouldn't have locked the keys in the house if
18 it hadn't been for me. Then. he proceeded to break out the garage window with a ladder (at
19
midnight) waking up neighbors, who called the police.
Within a couple of months ofliving together we had an argument after being at a friend's
20
house for a New Years Eve. He was yelling, screaming, and crying. He called his Mother in the
21
middle of the argument to tell her I was being "mean" and being awful to him. After hanging up,
22
he punched his fist thru the bedroom closet door, shattering it.
23
A day after giving birth to our daughter by caesarean (9/25/04) I tried to talk to my
24
husband about how upset I was that his family kept trying to invite too many of their friends into
25
my hospital room. I asked him to have a talk with his Mother about this. He became very .
26
agitated, saying he did not want to hurt his Mother's feelings, and that I was being too sensitive.
27
The nurses heard the commotion in the room, and came in to see if I was all right. They asked
28
me if! wanted my husband to leave.
29
Within a month of the birth of our daughter, we had another argument. As I walked down
30
the hall to get away from him, he grabbed a handful of my hair and drug me back down the hall
Dyer & Primont
503 Twelfth Ave. E
DECLARATION OF JENNIFER RIFE Seattle, l-VA 98102
Page 2 (206) 343-1528
1 towards him. When I started to cry he said he only meant to grab my jacket and that I was
2 overreacting.
3 Last December we went to visit my sister and brother-in-law and their two children. My
4 husband and my brother-in-law left saying they were going to pick up appetizers to bring back
5 and that they'd be back in half an hour. They came back in three hours and Andy appeared to be
6 intoxicated. We had a disagreement about it when he came back and he immediately became
7 verbally abusive, calling me a "whore" and "stupid". I tried to leave, with our daughter, but he
8 followed right behind me. He got into the car, and continued screaming at me, yelling within an
9 inch of my face, calling me a "whore" and "a piece of shit." He kept screaming that he could do
10 whatever he wanted to do whenever he wanted to do it, without my permission. He pulled and
11 shook me so hard by the sweatshirt I was wearing that he left cuts and abrasions on the back of
12 my neck. He also pulled me my hair to pull me closer to him so he could yell at me. He screamed
13 that he hated me and that he wanted out. Our 3-month-old daughter was in the car during this.
14 My sister heard all of this, as well as her 4 year-old son, and 2-year-old daughter. My sister. came
15 out to the garage and saw what was happening in the car. Later that night at home, he apologized
16 to me, saying he didn't mean to hurt me. He helped to clean and dress the abrasions on my neck.
It became routine for him to become extremely angry and verbally abusive during any
17
disagreement. One time he said he hoped that the next time I was out driving that I'd get hit by a
18
semi truck and die. He calls me a "whore, a loser, a piece of shit, fat" and says that he "made me
19
who I am", and that I "would be nothing without him", and that I am "stupid." He tells me all of
20
the time, with a look of hatred in his face that he wants to break my neck, or punch me in the
21
face. He will mimic this, showing me the motions of it with his hands. He gets so angry, he
22
breaks out in a sweat, his face becomes very red and his lips thin and white and his mouth so dry
23
he can barely speak more than a couple of sentences at a time. In a lot of cases he would rip
24
whatever shirt he was wearing off of his body and flex his muscles in front of me. After leaving
25
bruises on me, he will say that I bruise easily, and that he really didn't grab me very hard.
26
There was an instance in the kitchen where he shoved me up against the kitchen counter,
27
and pulled the water hose out of the sink, and sprayed water in my face. When he screams at me
28
with his nose almost touching mine, he has at times purposefully spit in my face when he was
29
done yelling.
30
Dyer & Primont
503 Twelfth Ave. £
Seattle, WA 98102
(206) 343-1528
Page3
1 In February/March 2005 my husband and I were having an argument that quickly
2 escalated. He said to get my attention that he was going to call the police and say that I had hit
3 him. Once he called, he hung up. When the 911 dispatcher called back, they informed my
4 husband that they were sending out a patrol car. My husband forced me to get in the car and
5 leave. I did has he asked, and went down Colby Avenue and parked in a quite residential area
.6 until my husband called me on my cell phone and said I could come back home. He told the
7 officers that night that the reason he called was he thought our daughter was sick or choking, and
8 after a few minutes he realized she was okay.
9 The night my husband was arrested in May, he became very aggressive and agitated after
10 a disagreement. He repeatedly shoved me to the floor, knocking me down every time I got back
11 up. He kicked me while I was down trying to prevent me from getting up. He was also calling
12 me "whore", "cunt", "stupid", "loser" and a "worthless piece of shit". That same night he
13 grabbed me from behind, and rubbed my face in the carpet. He told me he wanted to "see me
14 dead" and that he wanted to "punch me in the face and break my neck." With gestures he showed
15 me what he wanted to do to me. After he was booked into the county jail, I was the first person
he called. He was crying. He told me he was afraid of where he was at, that he was sorry for
16
what he had done and that he was afraid of losing "his family".
17
During another altercation, my husband cornered me in the kitchen, and while screaming
18
at me right in my face, he lowered his head and bit my left cheek close to my chin. Not hard
19
enough to draw blood, but hard enough to leave teeth marks in my skin.
20
In another instance, while we were having an argument regarding our sex life he said that if I
21
wanted to get laid more he'd be happy to show me how it's done. He grabbed me around my
22
waist and bodily picked me up, pinning me against the kitchen counter, and forcefully pretended
23
like he was having intercourse with me.
24
When we were remodeling our bedroom, we had only a single mattress lying on the floor.
25
During another disagreement, he grabbed me by one arm and threw me across the room. I
26
landed hard and on the floor, injuring my arm. The pain was excruciating, and I could not move
27
it without pain for two days. Later that night I told him I thought my arm was really hurt, and
28
that maybe I should go the hospital. He told me to just sleep it off a little bit, and that maybe it
29
would feel better. He even helped to arrange two pillows for me to sleep with my arm propped
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 4
1 level to my body. He apologized once ag:iin saying tkt he didn't mean to hurt me; I just landed
2 wrong.
3 On another occasion I was trying again t get away from him. I ran out to the garage to get
4 into the car to leave but he grabbed the keys from me before I could leave. He pushed me out the
5 door and down the garage steps then chased me around the car, trying to get a hold of me while I
.6 tried to keep away. When he could not catch me, he picked up dirty clothes from the laundry
·7 basket in the garage and thru clothes in my face.
8 He has broken many things in our home. He has broken two closet doors, a phone, two
9 kitchen chairs, our daughter's toys and a kitchen cupboard. He punched out the screen door in·
10 our garage;. he has left holes in the walls of our family room. When he punched the closet door
11 he nearly broke his hand; it was purple and swollen for almost two weeks. He got mad when our
12 daughter was a newborn, because I was stressed out and tired. I told him that I needed help. He
13 told me that I should have told him that I didn't want to be a mother, as he would have made me
14 have an abortion. He has repeatedly told me in anger that he never wanted to be married, and
15 never wanted kids. He has thrown baby bottles, pop bottles, and other breakable items.
16 He would always call his brother or mother when we fought, and they would always take
17 his side. His mother is so abused by her ex husband and sons that her life is no longer her own.
18 She would sometimes show up unannounced and continued to argue along side my husband,
goading me, telling me I should call the "cops" on her, the way I called them on my husband in
19
May. On a recent evening while she was there, my husband held the car keys away from me so I
20
could not take my daughter and leave. Eventually, he threw them at me, telling me and told me
21
to get out of his house. By that time, our daughter was asleep, and I was not going to leave
22
without her. His mother asked him to leave but he refused. He said that he was, "staying right
23
where he was, and that he was going to make my life miserable."
24
Recently he came hoine from work early mad because I. had slept on the couch the night
25
before. He cornered me in our daughter's bedroom, and started screaming in my face because I
26
was arguing back with him. When he got too close, I lifted my left arm in front of me, to protect
27
myself. He hit my arm down so hard that he left a large bruise directly on my forearm, going up
28
into my bicep. I got upset and left to go into the bedroom. He followed behind me, and grabbed
29
me by the arms and started to violently shake me. He picked me up and threw me onto the bed.
30
Then he forcibly kept me there by putting his weight on me. He kept telling me to "shut-up" and
Dyer & Primont
503 Twelfth Ave. E
DECLARATION OF JENNIFER RIFE Seattle, WA 98102
Page 5 (206) 343-1528
1 to listen to him. I tried very hard to break free of him. By the next evening, I noticed that I had a
2 very large, black and purple bruise under my right bicep, and large painful bruise on my left
3 forearm, and a strained muscle in my neck.
4 During the entire time I have known him Andy has driven erratically and dangerously
·5 with my daughter and me in the car. Anyone who looks at him, or doesn't drive to his liking, will
6 send him into a rage. He will yell obscenities (normally "stupid cunt"), flex his harm and curl his
7 fist in the rear view mirror or driver's side window at the person he is upset with. At times, I
8 have been extremely frightened, thinking we were going to be in an accident, or get into an
9 altercation with the person that he is yelling at.
.10 He has done this many times with our daughter in the car. One incidence, up near the
11 corner of 10th and Colby, he jerked the car over to the curb, got out of the car, leaving the drivers
12 side door open, and chased after a car he thought was driving too closely behind us. The second
13 time, we were up near Rucker Hill and Andy became very agitated, as he thought a passing car
14 gave him a nasty look. He came to an abrupt stop on the side of the road, got out of the car and
15 grabbed what I believe is a tire iron out of the trunk. He was yelling and screaming at the car
16 driving off to come back and fight him.
17 I have filed for a Domestic Violence Protection order against him. He has filed for
18 divorce and obtained an ex parte restraining order against me. This is all in retaliation. There is
no basis for any restraints against me. He is just using this to try to have my daughter and I
19
removed from his house and to make my life hard.
20
21
HUSBAND'S FALSE ALLEGATIONS OF ALCOHLISM
22
In the beginning of our relationship, I told him in confidence because I thought I could
23
trust him that I had been in a treatment center the previous year in 2002. Edgewood is a
24
treatment center on Vancouver Island that deals with Depression, Chemical Dependency, and
25
many other addictions, such as gambling and sexual addictions. My family confronted me
26
because they thought that I looked tired and depressed; they were concerned hat I was self-
27
medicating myself for personal issues that I was dealing with at that time in my life. I listened to
28
what everyone had to say, and agreed that the best thing for me was to go, and to learn and listen.
29
I knew I had been drinking too much and knew this was not how I wanted to live my life. I took
30
in a lot of information from Edgewood that I think has dramatically changed the outlook I have
Dyer & Primont
503 Twelfth Ave. E
DECLARATION OF JENNIFER RIFE Seattle, WA 98102
Page6 (206) 343·1528
1 on life. It ·made me more secure in who I am. I learned that during tough times in my life I do.
2 not need to lean on alcohol to help me. Having willingly gone there and taken responsibility for
3 what I was doing wrong, greatly empowered me.
4 At first my husband told me that my parent's must have been crazy sending me there, he
5 couldn't understand why. Once the abuse started, he began constantly putting me down for
6 going, calling me a drug addict and a loser. He also tried to break down my confidence, by
7 telling everyone in his family, his friends, and even co-workers about my past struggle. I know
8 this, as he would tell me in an argument, that I was a loser, and everyone that he told knew it.
9 When I met him and fell in love with him, I decided I wanted to change my life, and live
10
with more integrity and responsibility. I did this on my own and am proud of how my life has
11 turned out. I feel I was a great wife and a wonderful Mother. I was very excited about the arrival
of our daughter. I have been with her and taken care of her every day of her life.
12
13
FINANCIAL ISSUES
14
I acknowledge that the house we live in and have lived in during our marriage was his
15
house prior to our marriage. Also, he bought the car I drive just a month before we got married,
16
although we were living together when he bought it. While I understand that these may or may
17
not be separate assets that is a matter that should be resolved later. I am willing to move out of
18
the house but I will need some time to make those arrangements. I am asking that I be allowed
19
to remain in the home for the next 90 to 120 days. I need to continue using the car as my
20
business requires that I drive to offices. Without it I would be completely unable to earn a living.
21
To compound matters, I have no money. I have no money right now because Andy took
22
all of the money out of our joint checking account. There was about $7,500.00 in that account.
23
See attached Exhibit D, Sept. 2005 bank statement. Earlier this month, the day after he was
24
arrested the second time, I decided to take half of the money out so that I would be able to move
25
and hopefully pay an attorney. But before I could, I found out that he had taken all of it out and
26
closed the account. See attached Exhibits D and E. He left me with no money and now he
27
wants my daughter and I to have no place to live and no car to drive. I am asking that he be
28
required to pay me one-half of the money he took from our joint account within I 0 days of this
29
order.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
DECLARAT!ON OF JENNIFER RIFE (206) 343-1528
Page 7
.1 I am self-employed. l do not believe I make as much as Andy claims l do on his
2 proposed support worksheet. The only records I have are my invoices. Looking back over the
3 last year, iny average gross monthly income has been $2,798.00, see attached Exhibit F.
4 ·Andy's withholdings and mortgage interest deductions have always been enough to allow us to
5 pay no taxes on my income but still get a refund. I estimate that my taxes will be roughly 25%
6 of my income. In looking at Andy's most recent pay stub I believe he has under reported his
7 income by about $100.00 per month. I have attached a child support worksheet that I believe
8 more accurately reflects our monthly incomes.
9
10 PARENTING PLAN
11 Andy is asking the court to appoint a GAL for our daughter and to either give him
12 primary residential custody of our daughter or have us both have her half the time. I am opposed
13 to either. He is an abusive man, both has a husband and as a father. I believe that our daughter
14 would be in real danger ifleft alone with him at this point. I may feel differently if he enters into
15 some meaningful treatment for the domestic violence which also deals with parenting in this
16 context but right now he continues to blame it all on me and take no responsibility for his own
17 actions. I have done some research into the different DV treatment programs and would ask that
the court order that he attend treatment at Family Services in Seattle. The reason I want him to
18
go there is that they not only have a batterers treatment program but that have two different
19
programs for parents as well: one is called DV Dads and the other is called Respectful
20
Parenting. I know of no other program that also has programs dealing with parenting. I cannot
21
stress enough how much danger I believe our daughter would be in if he is allowed unbridled
22
contact with her at this point. I am asking that court to order that there be no visitation until he
23
has completed at least 60 days of treatment at Family Services and has received positive monthly
24
progress reports.
25
I have no objection to the appointment of a GAL but I have no money right now to pay
26
any retainer for one. I have had to borrow money from my parents for my attorney's retainer. I
27
make enough from my job to support my daughter and I but I have no extra income. I will have
28
to use every penny I have to find another place for us to live. Andy makes more money than I
29
and I would ask that he be required to pay any initial retainer for a GAL.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
DECLARATION OF JENNWER RIFE
(206) 343-1528
Page 8
1
2
foregoing is true and correct. Signed this _day of October 2005 in Seattle,
3
IVashington. ·
4
5
~44~}~)
6
7
J IFER E
s·
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Dyer & Primont
503 Twelfth Ave. E:
Seattle, WA 98102
DECLARATION OF JENNIER RIFE (206) 343-1528
Page 9.
1
2
SuPERIORCOURTOFWAS~GINI LE D
3
4
5 COUNTY OF SNOHOMISH DEC O2 20U~
6 In re the Marriage of:·
7
ANDREW S. RIFE,
8 Petitioner,
and SUPPLEMENTAL DECLARATION
·9
OF .J!!:NNIER RIFE IN SUPPORT OF .
10 HER REQUEST FOR A DOMESTIC
JENNIFER R. RIFE,
. .VIOLENCE PROTECTION ORDER
11 Respondent. AND LIMITATIONS IN
TEMPORARY PARENTING PLAN ·
12
13
The court reserved final deten:Ilination on my request for a Protection Order and
14
15 on the issue of a Temporary Parenting Plan. The court appointed a GAL for our daughter
16 and asked that an interim report be issued. A review date was set for December 6, 2005.
17
The following information is offered as an add.endum to th~ declaration supplj§~ wi\Smy
18 . - . . -~::: <..n ·=--·
J052 0 ...
19 Petition. O~·
- rq
C-')
::c:-I. !
20 PATTERN OF DOMESTIC VIOLENCE o ;:;; "' ~
. . . . . g :c
21 . -
-~
Andy Rife has physically assaulted me on sev~ral recent occasions. G~ as§iiult :i
·-o·
-
:-:
22 . n~ ~ ~
·. O·--<
resulted in ~s arrest. There were others that I was too ashamed to come forward a80tit.
23 :>:
24 During 2003/04 his violence was primarily directed at property .. He broke out a window
25
..• prompting our. neighbors to· call the police. He punched his hand through. a·
with a ladder,
26
wall in our house. Shortly after our da_ughter was born (9/25/04) his violence escalated~
27
28 . Instead of just going into a rage and breaking something, this time he grabbed a handful
29 of my hair and yanked me down the hall. The next time was in the car, with our infant in
30
IN SUPPORT OF REQUEST FOR Dyer & Pn"mont
PARENTING PLAN
EXHIBIT
---- 503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 1
1 the back seat. That was around Christmas of 2004. That time he grabbed my .sweatshirt
2
collar and shook me violently, so hard that I ended up with abrasions around my neck.
3
He also grabbed me by the hair, again, and pulled my face right up to .his and. screamed
4
5 horrible names at me.
6 After that time his abuse became routine. Not only physical but constant
7
emotional and verbal abuse. By the spring it was becoming difficult to hide the cuts and
8
9 bruises. Andy would always apologize and swear it would never happen again but it
10 always did. I was depressed and felt trapped. He began to make attempts to control all of
11
our money and we had.no friends outside of our two families. I was so embarrassed and I
12
13 tried hard to hide this all from my parents.
14 By May of 2005 the abuse was so bad that I finally called the police. After he got
15
out of jail he promised to get into counseling or treatment and I got it all set up for him.
16
The prosecutor and judge allowed us to move back in together but Andy stopped going to
17
18 counseling and slowly started becoming abusive again. When the prosecutor found out
19
he was not in compliance with his treatment she requested that the No Contact Order be
20
put back in place. The judge did just that but that did not stop Andy. He moved back in
21
22 to our house, continued his abuse and continued to deny that there was any problem,
23 except with me.

24
Just days before his criminal trial for assaulting me, Andy tried to. have me
25
26 arrested for assaulting him. After listening to his stories and those of his brother the
27 police did not believe him. They arrested him for violating the No Contact Order. At
28
that point we permanently separated. (Please see initial declaration for my detail).
29
30
AND LIMITATIONS IN TEMPORARY Seattle, \.\'A 95102
PARENTING PLAN (206) 343-1528' •
Page 2
-----------
1
2
ISSUES \VITH ALCOHOL
3
I filed for a Protection Order, Andy filed for divorce. Rather than admit that he
4
5 has a problem, Andy has continued to blame me in any way he can. Knowing that I had
6
gone to a treatment facility years ago at my parents request he suddenly tells the court
7
that I. am a problem drinker. When I drink I don't abuse people. I don't drink to excess.
8
9 I don't drink and drive. I don't accost people when I am driving. Andy does all of these
10 things. I think he really does have a problem with alcohol, along with his problem with
11
rage.and abuse. The following is what I know about Andy's drinking and it concerns me.
12
13 When Andy and I first started dating in 2002, I noticed right away that he drank
14 quite a bit. Because I had just recently been at a treatment center in Vancouver I had
15
concerns that maybe he was an alcoholic. He explained is drinking to me telling me,
16
"Drinking is how I relax and get to know people." He also told me that he didn't really
17
18 know of any other way to have a good time. During that time, and up until he filed for
19
divorce, Andy has never expressed any concern over my alcohol consumption.
20
Andy has bragged to me that, before we met, he used to go out 3-4 times a week
21
22 with his friend and get very intoxicated. He bragged that he missed work from hangovers.
23 He also told me that he and his buddy got into many bar room brawls, and fist fights with
24
strangers that they met in these bars. He spoke with pride of the fights he would get into
25
26 while driving his car. He was a "regular" at a bar in Everett on Hewitt Ave. called
27 "Bucks American Cafe". They even specially ordered an imported Italian beer for him
28
called "Moretti". He told me that sometimes he got so drunk there, that one of the staff
29
30
SUPPLEMENTAL· DECLARATION
IN SUPPORT OF REQUEST FOR Dy!!r & Primont
ADV PROTECTION ORDER 503 Twelfth Ave. E
Page 3
1 would follow him home after closing. He would spend 4-6 days a week there, usually
2
after work, and on Saturdays.
3
He also confided in me at one point, that sometime before we met, his family had
4
5 mentioned that they were concerned that he was gaining weight from di-inking to much.
6 His Mother and Aunt have also expressed concern that they do not like to see him
7
drinking so much. Alcoholism runs rampant in Andy's family. Both his Mom and Aunt
8
9 completely abstain, as both of their parents were alcoholics. His maternal Uncle is an
10 alcoholic who no longer drinks due to the many problems in his life associated ·with
11
alcohol. His sister in-law is also an alcoholic and she also no longer drinks. I believed
12
13
she stopped after getting a DUI.
14 Andy's Father is an alcoholic as well. He is a reclusive man that rarely visits

15
anyone in his family. He has never invited us to his home for dinner or any other kind of
16
social event. He drinks scotch daily. There have been times where Andy has been on the
17
18 phone with his father and would look at me with an exaggerated "drunk" look on his face
19
while his Dad was talking.
20
Routinely, Andy would walk into the house in the early afternoon on Saturdays
21
22 with a beer in his hand after working with his father that day. He has told me on several
23 . occasions that it is routine for he and his Father to stop at the liquor store for Scotch and
24
beer to drink in the van on the way home.
25
26 I have no problem abstaining from alcohol but I do not believe it is a problem in
27 my life. I took my treatment very seriously. I am completely willing to have an

28
additional alcohol/drug evaluation but I would request that Andy also be required to have
29
30
PARENTING PLAN' (206) 343-1528
Page 4
1 an evaluation. But if either of us does I would like the evaluator to have access to more
2
information than just self reported information.
3
REQUEST FOR RESTRICTION ON ANDY'S TIME WITH OUR DAUGHTER
4
5 Because of Andy's escalating pattern of abuse, .both physical and emotional, I
6 have real concenis about him spending time alone with Lauren. Below are some other
7
issues that I believe bear on his ability to adequately and safely parent Lauren alone. ·
8
9 Andy is a dangerous driver and I believe this presents a danger to our daughter. I
10 have witnessed firsthand many frightening .acts of rage when Andy is behind the wheel.
11
He has told me of many instances of he or his Dad screaming out the car window at the
12
13 person driving next to therri. Both Andy and his father refer to women drivers most often
14 as, "stupid cunts" and "fat bitches." I have witnessed him driving too fast and erratically,
15
even with our daughter in the car. Many times he has stopped the car and challenged·
16
someone to come and fight him while Lauren and I were in the car. I have felt that we
17
18 were in danger on many·occasions.
19 Andy refuses to Jet a woman drive when he is in the car, regardless of his level on
20
iiltoxication. There are many times that I can think of where he has clearly been
21
22 intoxicated but has refused to Jet me dTive, opting instead to have Lauren and I
23 passengers in his car when he is intoxicated. I do not trust that he will not drive with
24
Lauren in.the car after drinking because he does not believe there is anything wrong with
25
26 this. It is about his power, not about good parenting to him.
27 Andy is extremely racist and sexist. He talks constantly about how women are
28
lying, manipulative bitches. He has told me· over and over again, that women don't
29
belong in politics, and how awful they are to work with. He says all they do is call in
30
li'I SUPPORT OF REQUEST FOR Dyer & Primont
AND LIMITATIO NS L'I TEMPORARY Seattle WA 98102
1

~age 5
1 sick to work and make up excuses to not work hard. He is also very hateful towards any
2 minorities, gays and liberals and states his opinions to.everyone who will listen.
3
In mid-September, Andy and I went on a Jong walk around Everett Community
4
5 College with Lauren in her stroller. Coming back up towards our neighborhood, we
6 passed a house where we could here a·man and woman arguing, when we heard someone
7
being hit. I'm assuming it was the woman, as we heard her start crying, then the 'man
8
9 slanimed out of the house and got in his vehicle and left. I said "Oh my god, I think he
10 just hit her." Andy turned towards me, with a very nasty look on his face and said, "she's
11
a raving bitch, she probably deserved it."
12
During our marriage Andy did not take responsibility for child care and rearing
13
14 duties in fact he was rarely home. A normal weekly routine in our house was this: Andy
15
would get up at 5:00 a.m. and go to her father's house for breakfast then to the Elks club
16
for a steam and shower and off to work by 7:00 a.m. For every lunch break he would go
17
18 back to the Elks club for a "workout and steam." When he got off work he would go
19
back to the Elks club for another steam bath and swim. He would come home for dinner
20
and then go back to the Elks club in the evening. On Saturdays he would get up at 6:00
21
22 a.m. and leave to go Jay clean carpets with his father. Often he would work on Sundays
23 also. If he did not work on Sundays he made several trips to the Elks club. In short, he
24
was rarely home. If he was home he was mowing our lawn or washing the cars. He was
25
26 not spending time with our daughter. If he was in the house he wanted to be talking to
27 me, not playing with the baby. Once she got old enough to sit up he would prop her in
28
front of the TV to watch a video rather than play with her himself. He has almost no
29
tolerance for her crying and I am fearful of what he would do if he had her alone and she
30
Page 6
. "
1 would not stop crying. Andy cannot tolerate any type of mess and having her toys all
2 over the floor drove him crazy. While we were living together I was able to be the buffer
3
for these shortcomings but I am very concerned about what he might do when or if he is
4
5 taking care of Lai.iren alone. I am very fearful that if she had a tantrum or cried for more
6 than a few minutes he would strike or shake her or worse. He has told me over and over
7
that the sound of her crying "hurts his ears." I have witnessed first hand how agitated he
8
9 gets when she cries too iong.
10 I am very concerned that unless and until Andy volilntarily takes honest
11
responsibility for his attitudes and actions, he poses a risk to our very young daughter. I
12
13
do not want to keep her from him or he from her but I have also witnessed a spiraling
. 14 cycle of abuse in his life, including injury causing physical violence in our relationship
15
on multiple occasions. I see no evidence that he has changed. He is doing everything in
16
his power to make this as hard as he can for me, which in turn harms our daughter.
17
18 I do not believe he is engaging in any meaningful domestic violence treatment. I
19 do not believe he is in compliance with his criminal sentence in that regard either. He
20
claims to be in treatment but no intake or assessment records have been seen. For our
21
22 daughter's sake he needs to learn how much o.f a negative influence his sexist, racist and
23 violent behavior will have on her.

24
I am requestmg that Andy immediately have an assessment and begin treatment at
25
26 a domestic violence treatment program. Not a program of his choosing but one
27 recommended by experts in this field. There is a United Way treatment program in

28
Seattle called Family Services that has batterers' treatment, and also two specialized
29
programs for parents. who have committed acts of domestic violence. It comes highly
30
A DY PROTECTION ORDER 503 Twelfth Ave. E
AND LIMITATIONS IN TEMPORARY Seattle~ WA 98102
Page 7
1 recommended. I would ask that he be ordered to immediately obtain an assessment for
2 domestic violence and begin treatment as per their recominendations. I am most
3
concerned that this cycle of violence be stopped before our daughter becomes the next
4
5 target of his uncontrolled rage and abuse. He should be in treatment and in full
6 compliance in order to have any visits with Lauren.

7
The current visitation is too frequent for Lauren and is very disruptive. It is clear
,8
9 to me that she is not doing will with all of this back and forth every other day. She has
10 ·been cranky and out of sorts since this every other day visitation started. Most days when
11
Andy returns her at 6:30 p.m. she is asleep (not her naptirne) which throws off her routine
. -
12
and makes it very difficult to get her back to sleep on her normal schedule. It is clear to
13
14 me that he is not playing with her while he has her but is instead, letting her fall asleep.
15
l would suggest that we opt for 2 or 3 visits per week with one or two during the week to
16
be from 3:30 p.m. to 5:30 p.m. I would ask that a real effort be made to not just let
17
18 Lauren sleep but to interact with her during that tirrie. The third visit could be on the
19 weekend and for up to four hours.
20
·CONCLUSION
21
22 On November 1, 2005 the court appointed Bridgett Llewellyn as the Guardian Ad
23 Litem and ordered us to return to this court for a review on Dec. 6, 2005. Ms. Llewellyn
24
was on a vacation for two weeks during that time and only returned on Nov. 28th. It is
25
26 my understanding that she will not have any interim report, as she has not yet been able
27 to conduct any type of thorough investigation.

28
29
30
ADV PROTECTION ORDER 503 Twelfth Ave. £
AND LlMITATIONS IN TEMPORARY Seattle, WA 98102
Page8
rz/ 0212005 11: 30 3606685072 HOLLAND PAGE 01
1 wo\lld ask that the issue of Andy's visitation be continued for an additional 8
1
2 weeks to allow Ms. Llewellyn the time necessary to co11duct her investigation. That
3
Andy be required to have a DV assessment with Family Services in Seattle. If he is in
4
treatment I have no objection to the continuation of his visitation, supervised by his
5
a· mother as I have outlined above.
7
. I am begging this court to enter an Order for Protection as requested in my
B
Petition for Protection. I am terrified !JO Andy. 1 believe he still wants to control me a."ld
13
10 that he will continue to abuse if he is given the ch:mce. l understand that any Protection
11 Order would make allowances for the Parenting Plan in our family law case.
12
I declare under penalty of perjury of the laws of the State of Washington
13
,4 that the foregoing is true and correct. Signed and dated this Jnd day of IJuern/iev
15 2005 in ~rnr4/u , Washington.
16
17
16
19
20
21
22
;23
24
25
26
27
26
29
30 SUPPL£ME.'!TAL DECLM!A TION
IN SUPPORT OF llltQUEST FOR Dyer & Primont
A DV PROTECTION ORDER SO.! 1:1:'rlfti: A11i:-. E
M'D LIMITATIONS L-; TEMPORARY S•A:tlr, WA 98lQ2
PARENTING PLAN (2ilil! 34S·152B
l'•ge 9
H; H: ll 900G!oO/Zl
,•.
;-11 ~t D
( '-- -
~·i\\:5B
p.f .
.SUPERIOR COURT OF WASHINGTON

Na
!,,..
6s --z... -<:i(-:z.~ ~- <__,. .,
~~d...e..e.4 ..·C/I ...
~,.e_ .:s ,_,. ~ ~,., \Zc._,_
Petitioner (First Middle &_Last Names)
e.-r~ 'TEMPORARY ORDER FOR PROTECTION
AND NOTICE OF HEARING (TMORPR1)
(Clerk's Action R<:quired) · ·
vs.
Ncit H.earing D~tcffimc:
-< "- - ii to , 2. 4(,$' @'f~oo KM .
Respondent (First Middle & Last Names) DOB At:· Snohomish County Courthouse, 3"' floor
3000 Rockefeller A~eriue, Everett,. WA, 98201
Room .· [ I 301 [ J305
Identification of Minors: D No Minors Involved. ·

. Na!ne Age ·Race Sex
I•
(First, Middle initial, Last)
For good cause shown, the court finds that an emergency exists and that a Temporary Prot.,,,tion Order should be. ·
issued witl1out notice to tl1e respondent to avoid irre le harm. IT IS THEREFORE ORDERED THAT:
l. Respondent is RESTRAINED from causing petitioner physical harm, bodily irijuiy, assault, including,
se:-.-ual assault. and from 1nolest.ini. hMassi..'!g, threateriing, ·er steJking rn
petjtioner ~the rninors named
_(£. in the table above D these minors only: · · · ·
\J\~\.\-a_.!.,.._;.~ Qi, -±,.,.:.. DS--; -00~\'-\ -"i ),.._ \,.\. ,.._..\- ~ .;,__· V\.«\..~.i; ... ...:,.
2. Respondent is RES1RAINED from coming near and from having any contact whatsoever, in person
or through others, by phone, mail:
or any ineans, directly or indirectly, except for mailing or service of
precess of court _documents by a 3"' party or centact_by respondent's lawyer(s) with [Xi petitioner tl1e m
·nqrs !12med. in.the table above D these minors oriJy: ·
TEM~ ORD FOR PROTEci-zONj~~T OF HRG (TI-10RPr:.7) ~ ?age 1 of 3.

W?F DV-2.ois (6/2002)- RCW 26:so.030
Oe:i<'s Office: S:\FORMS\FCOURTSERVICES\Domestic Violence\PETI110N PACi(ET\4-Temp Order-DV.doc
3. R~spondent is RESTP~INED from going onto the grounds of or entering petitioiier's
00 residence (gJ workplace D school; 0 the day care or school oflKI the minors named in the table
l1 above D these minors only:

D other:
& D Petitioner's address is confidential. III Petitioner waives confidentiality of the address .which is:
C)...,. \ (a ""- s-
-s.i, { -1.~ :~u -l:c- \-\ '- \.,J (::.,..
I
4. Petitioner shall have exclusive right to the residence petitioner and respondent share- The
respondent shall immediately VACATE the residence. The respondent may take respondent's
X;,
(11 I .
pe:-sonal clothing and respondent's tools of trade frorn the residence while a Ia;v enforcement officer
is present. 0 This address is confidential. 0 Petitioner waives confidentiality of t.liis address ·which
is· 2'-1 L\o '5~ <-.>..l, • 2".u~c~'<'< 1..o.I./'.
'
' '
~
5. Respondent is PROHIBITED from knowingly coming within, or knowingly remaining within
l <.!>(.") · "'-CcJ) . · (distance) of:_p_et\ti_gner's CTresidence LI workplace D school; 0 the I
day care or seho~J ofOO.the minors named in the table above D these minors only:
y Col.her:
I
G. Pcti'tioncr shaf1 1
• .. - • osscssicin of essential personal belongings, including the following:
"-
I
~
7. Petitioner is granted use of the following vehicle:
Year, Make·& Model 2 u o'-i ~,"V\.l._) 3;.5; License No,
. ~c.......Y-~\ e.-!;~ r .,...&.c..A\. .\.i \..),.._~~ ,__..::;~.
1tt.:COfri~ 8. OTHER:
t--l.ti .. os-·· -
. . .
ooo.,L<-'is'
-
'., ~-:\" "'-- \J'-~ \...c.......\.-1...u....) .. ...rs-~-
'-' ,., .Q " '
-TL"'
C. ~ - C.c..u \.t._
c rc;Q-t..r.
I
"iICtc t"h~·f;)l'fO,.Yi ~-g :O:riIY-~irrn·r,oteCtiO n'.iS,1~~~t'e'<fii~tYOi~ingf:i{ni;iiiji~.:::=t:- '"'''.];'' . ' ..
··.'>,:
12. Petitioner is GR.ANTED the te1iiporary care, CU?tody, and "con~o.J of ro the minors nan1ed in the
Q~
.~
table above
0 these n1inors only:
.
'
13. Respondent is RESTRAINED from interfering with petitionds physical or legal custody of
I
~the minors named in the table above D these minors only:
lJ.4. Respondent i~ RESTRAINED from removing from the state l[J the minors named in the table
above· D these mmors only: .
/
... I
TI1e 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 U1e petitioner or 0U1er relief which
may indude elecLronic monitoring, payment of costs, and treaiment. FAILURE TO APPEAR AT THE
·HEARL"NG fvlA Y REStJLT li~ THE COURT GRANTif"iG SUCH RELIEF. THE t-i"EXT HEA.Ra.~G
DATE AND TThfE IS SHOWN BELOW THE CAPTION ON PAGE ONE.
TE.MP ORD FOR PROTECTION/NT OF HRG (TMOR?RT) ·Page 2 o.f 3

WPF DV-2.015 {6/2002) ·RON 26.50.030 .
Clerk's Office: S:\FORMS\FCOURTSERVICES\Dom.estic Violence\PETTTION PAO<ET\4-Temp Order-DY.doc
' .
WARNINGS TO THE RESPONDENT: Violation of the provisions of this order with actual notice of its terms
is a criminal offense under chapter 26.50 RCW and will subject a violator to arrest. If the violation of the ·
protection order involves travel across a state line or U1e boundary ofa tribal jurisdiction, or involves conduct
within the .special Inariti.1ne a...'1d tcrritoria!jI:trisdiction of the United States. which includes tribal lands, the
I defendant may be subject to criminal proseculi6n in federal coun under I~ U.S.C. sections 2261, 2261A, or 2262.
Violation of this ofd~r is a gross 1n!sde1nc.."lnor u..i1less one of the fc!!o\ving conditions apply: .A~ny. assault that is a
I
violation of this order and that docs not amount to assauit in tl1e first degree or second degree under RCW
· 9A.36.0 I I or 9A.36.02 I is a class C felony. A.~y conduct in violation of U1is orderthat is reckless and creates a.
I substantial risk of death or serious physical injwy to another person is a class C felony. Also, a violation of U1is
I
order is a c!ass C felony if the respondent has at least 2 previous ccn".tictions for violating a pfotection order
issued under Titles !O, 26 or 74 RCW. ·
If the court issues a final protection order, the respondent may not possess a firearm or ammunition for as
Ion:: as that final protection order is in effect. 18 U.S.C. scctio'n 922(g)(8). A violation of this federal
firearms Jaw carries a maximum possible penalty of 10 years in prison and a $250,000 fine. An exception
cxist_s_ for la.'v enforcement Officers and mi!it~ry pcrSon_ncl wl;tcn carrying dcpartmcntigovcrnmcnt-issucd
I~~~:c:~·~~n:~v~i~:r:~:~~:~;~~1i~~fr!~~~o~~~s~~~~~~~~::;·~~:~~~~i~i:~~':s ;~;~c;;~t~~!~~~(~~); I 0
. ,. ~~~~~~~;·ARRESTED EVEN~ TH~ PERSON OR PERSONS wHO OBTAINED THE ORDE~

·. . ,
INVITE OR ALLOW YOU TO VIOLATE THE ORDER'S PROHIBITIONS. You have !lie sole
~ponsibility lo avoid of reftaip froin violating the o~d~r's provisio!lS. Only the court can change ll1e order upon
• \vri~ten appli~tion. · . . .
·Pursuant to 18 U.S.C. section 2265, a court in any of the 50 states, the District of Columbia, Pueno Rico, any
United States territory, and any tribal land \vi thin tl1e United States shall accord full faitl1 and credit to U1e order.
It is fur.her ordered that !lie clerk of the court shall forward a copy of this order on or before the next judicial day
to · C\, ...,,,-<-~ · · . D County ·sheriffs Office 0 Police ·
Dcpartn1cnt WHERE PETITIONER LIVES \Vhich shall enter it in a coxnputcr-based crizninal inteiiigencc
· systcrn available in this ~tatc used by la\v enforcerricnt to list outstanding \variants~ · ·
0 TI1c clerk of the coun shall also forward a copy of t11is order on or before the ne>."tjudicial day to
= - - - - - - - - - - - - - - - - - - - - - - - - - - - 0 CcUnty S~1erifrs Office
0 Police Department WHERE RESPONDENT LIVES which shall personally se.rve the respondent with a
copy of 1his o·rdcr and shall promptly complete and return to U1is· coun proof Of serv~e· _,J-<..-'< · · .
~ Petitioner has nmde private arrangements for service oftltis order. ~ __ -~ 'i'.r~..>< """ Cuur'<-,
.GP Tiie law enforcement agency wliercSQpetitioner D respondent lives .shall assist ~petitioner 0 respondent
.
·· in obtaining: ~ossession of petitioner's/respondent's. D residence 0 personal belongings located at: D
the shared residence 0 other: ' · · . · · · · I..
· I CjlU:ustody of.the above-named minors, including laking .physical custody for delivery to petitioner (if
applicable). . · . . . . . · . ·: . · · · ·
I 0 Ot11er: · .
.1 his 1 cmporary Order for rrotcction is effective untii the next hearing dat~.Sh.cwn beiol~ the caption on
. page one. .
nATEn~~~~~~·~No~v~·~·o_1~20_0_5~~~~-
, ..
~I
c""'" :;), c. v \ , \.J..r.>e, s].. ';'~" \
TEt·~P ORD FOR PROTCCTION/r~T OF HRG (T}10R?RT) - Page 3 of 3 ??-~

. WPF DV·2.015 (6/2002) • RCN 25.50.030 .
Oerk's Office: S:\FORMS\FCOURTSERV!CES\Domestic Violence\PETITION PACKc'T\4-Temp Order·DV.doc
,,
·•·. -, '• ...... _,, ...• , .
_
FILED
05 OCT -3 PH 3: 22
.
. . ~cte..
05-2-01268-2
_J~e~n~n~;'l-l~fJuv~R~·-,e~i~P~___r%/!~IH
NO.
Petitioner (First Middle & Last Names) DOB PETITION FOR ORDER
FOR PROTECTION
~~~r1~.\J~0~S[.{)=
..vs~~-f-~R~1~·{L
__ ~bc;.£13 (PTO RP RT) (A II Cases)
Respondent (First Middle & Last Names) DOB
I. Gll am 0 A member of my family or household is the 3. My age is:

victim of domestic violence committed by the 0 Under 16 D 16 or 17 ~over
res ondent as described in the statement below.
2. live in this county. Respondent's age is:
0 ! left my residence because of abuse and this is the 0 Under 16 0 16 or 17 ~over
county of my new or former iesidence.
0 current or former dating Din-law
relationship 0 parent or child
0 stepparent or Stepchild Ob!ood relation other
0 current or former than parent or child
·" O l re:. '.:>
5. Identification of Minors (If applicable) ONo Minors involved.
Name How Relate.d to Resides
(First, Middle Initial, Last) Age Race Sex Petitioner Respondent with
l.1111rtvi Prn\l.i
0
'/?,JJ,/ I c/ f fnOf,kv ~J.uzr fhol-kv-
;
PETITION FOR ORDER FOR PROTECTION (PTORPRT) ·Page I ofS
WPF DV-1.015 (712005)- RCW 26.50.030 scorr~,sE~asec/'
S:\FORMS\FCOURTSERVICES\Domestic Violcncc\Petition Packct\2-Pc1ition-DV.doc
1. / z: 3.b .
s.:=2"7. r/sy:-£..d.
' '
6. Other court cases or other restraining, protection or no-contact orders involving me, the minors and
the respondent:
CASE NAME
f1ti 1lY'UJ f . ,(),fl
....,
CASE NUMBER
- ' •
COURT/COUNTY
S110·- i'llJrWvO h
~oo~"Tr'TO
REQUEST FOR TEMPORARY ORDER: AN EMERGENCY EXISTS as described in the
statement below: I need a temporary restraining order issued immediately without notice to the
respondent until a hearing to avoid irreparable injury. I request a Temporary Order for Protection that
will:
14- I REQUEST AN ORDER FOR PROTECTION following a hearing THAT WILL: .
DAY I YEAR/PERMANENT
J, .).
1
RESTRAIN respondent from causing any physical harm, bodily injury, assault,
incl~ sexual assault, and from molesting, harassing, threatening, or stalking
-. e G!"fhe
minors named in paragraph 5 above D these minors only:
x)( (lfthe court orders this relief, and the respondent is your spouse or former spouse, the
parent ofa common child, or a current.or former cohabitant as intimate partner, the
respondent will be prohibited from possessing a firearm or ammunition under federal
law. for the duration of this order. An exception exists for law enforcement officers and
military personnel when carrying department/ government-issued firearms.
18 U.S.C. § 925 (a)(I).)
x)(
2
RESTRAIN respondent from coming near and from having any contact whatsoever,
in person or through others, by phone~,~ means, directly or indirectly, except
for mailing of court documents, with · e e minors ·named ·in paragraph 5 above,
subject to any court-ordered visitation D these minors only, subject to any court-
ordered visitation:
,
EXCLUDE respondent from ~red residence D my residence

3
0'i,y workplace D my school; the day care or school of~inors named in
k,'X
paragraph 5 above D these minors only: ·
0 other:
' You have a right to keep your residential address confidential.
x x
- ~
4
DIRECT respondent to vacate our shared residence and restore it to me.
PETITION FOR ORDER FOR PROTECTION (PTORPRT)- Page 2 of 5

WPF DV-1.015 (712005) - RCW 26.50.030
S:\FORtl.1S\FCOURTSERVJCES\Domes1ic Violence\Petiiion Packet\2-Petiiion-DV.doc
' PROHIBIT respondenyfrom knowingly coming within, or knowingly remaining
wit~ 100 yards of: r:Your shared res_jPence 0 my residence. /
Cid'f'.ny workplace 0 my school; Dl1he day care or school ofCMfie minors named in
paragraph 5 above. 0 these minors only:
0 other:
6
GRANT me possession of essential personal belongings, including the following:
Grant me use of the followin)l ~ehicle:

7
. .
Year, Make & Model ()06'-f f3rt1iA.J%1 License No. _ _
'OTHER:
9
DIRECT the respondent to participate in appropriate treatment or counseling services.
rn REQUIRE the respondent to pay the fees and costs of this action.
11
REMAIN EFFECTIVE longer than one year because respondent is likely to _resume
acts of domestic violence a ainst me ifthe order ex ires in a vear.
12
Subject to any court-ordered visitation, GRANT me the care, custody and control of
Gl"fhe minors named in paragraph 5 above 0 these minors only: ·
13
RESTRAIN respondent from interfering with my physical or legal custody oflid1he
minors named in paragraph 5 above D these tninors only:
4
RESTRAIN the respondent from removing from the state: 0 the minors named in
paragraph 5 above D these minors only:
REQUEST FOR SPECIAL ASSISTANCE FROM LAW ENFORCEMENT AGENCIES:
I request the court order the appropriate law enforcement agency to assist me in obtaining:
- ~ssession of my residence.~ of designated vehicle.

D Possession of my essential personal belongings at ~hared residence 0 respondent's
residence 0 other.
D Custody of~ minors named in paragraph 5 _above 0 these minors only (If applicable):
PETITION FOR ORDER FOR PROTECTION (PTORPRT) - Page J of 5

WPF DV-1.015 (7/2005) - RCW 26.50.030
S:\FORMS\FCOURTSERVJCES\Domcstic Violcnce\pc1ition Packe1\2-Pcti1ion-DV.doc
.. '·
Domestic violence includes phys ~al harm, bodily injury, assault, stalking, OR inflicting fear of
imminent physical harm. 1x,:.iJ·.: hj'."Y or assault between family or household members.
STATEMENT: The respondent has committed acts of domestic violence as follows. (Describe specific
acts of domestic violence and their approximate dates, beginning with the most recent act. You may
want to include police responses.)
Describe any violence or threats towards children: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
PETITION FOR ORDER FOR PROTECTION (PTORPRT)- Page 4 of 5

WPF DV-1.015 (7/2005)- RCW 26.50.030
S:\FORMS\FCOVRTSERVJCES\Domestic Violence\Petition Packet\2·Petition-DV.doc
' .
Describe medical treatment you received and for w h a t : _ - : - ; , ; , r - - - - - - - - - - - - - - - - - -
Does the respondent own or possess firearms? D Yes o
If you are requesting that the protection order lasts longer than one year, describe the reasons why: _ _ _ _ __
Other: _______________________________________
(Continue on separate page if necessary)
Check box if substance abuse is involved: 0 alcohol 0 controlled drugs D o t h e r - - - - - - - - - - - -
I certify under penalty of perjury under the Jaws of the state·ofWashingtonihat·theforegoing is true and
coriect.
DA TED (}D/.otz r gr~ cf/CJ CJ;} at _ _W,~-~e,~y:._JV!--/-__,,,,-------~Washington.
WJ<U 'Ju).,£ -dAR./
illat~ of fS'etitioner ..,.
You have a right to keep your residential address confidential. if you have one, please provide an
address, other than your residenc?-,')'her~you may receiv~ 1.egal documents:_~---------
91 ;q /J:/k 'fh t2 Sc, S'hM{l(llWh. j
111&-- qf- i991P
PETITION FOR ORDER FOR PROTECTION (PTORPRT) ·Page 5 of5

WPF DV-1.015 (712005) • RCW 26.50.QJO
S:\FORMS\FCOURTS ER VIC ES\Domestic Violence\Petition Packet\2-Petition-D V.doc
FIL L.co·
as OCT -3 P'1I ,3·..,
• C. 2
P ;\ H L. 1J .; f."EL c
COUF1T '( ~ 1 ·~ .)
1
SNOliOl·!/S'I c"·)''.YK
_, .u. ''"'-SH

05-2-01268-2
NO.
Petitioner/Plaintiff\ s),
vs. DECLARATION OF:
Respondent/Defendant(s).
I certify under penalty of perjury under the laws of the State of Washington that i have read the above statements,
know their contents, and believe them to be true and correct.
Signed in Everett, Washington on _ _,_/_..(J'-f/~34/""IJ.""L'---- ~-

(date) Signature
S:\FORMS\FCOURTSERVICES\Domestic Violcnce\Declaration Packct\3Declaration.doc

STATEMENT: (Continued
- (, Cl/11/
(Continue on separate page ifnecessaiy)
I certify under penalty of perjury under the laws of the state of Washington that the foregoing
is true and correct.
DATED tfj/ 10)3 /O.t) at _ _.~[1;,~'f.,_V:_~_/~j-

_ ___ Washington.
. J F i
Signature of Petitioner
PETITION FOR ORDER FOR PROTECJ10N - Statement page_ of_.
(912000) - RCW 26.50.030
S:IFORMS\FCOURTSERVICES\Domcstic Violence\Statcment Continued.doc
•
CHILD CUSTODY INFORMATION SHEET

05-2-o1268~2
NO:~~~~~~~~~~~~
If you are seeking protection for your child(ren) from domestic violence or are requesting custody of
. your child(ren), please answer the questions and provide the information requested in paragraphs A-E
below and check the boxes about the court's jurisdiction that apply to your case:
Information for the courts:

.
A. Do the child(ren) listed in Paragraph 5 of the petition currently live with you? If not, IV'Yes ONo
with. whom do the child(ren) currently live?
/"
B. Do you know of any other court cases involving the child(ren)? If known, list: DYes o-No
the court the case number the kind of case
C. Have you been involved in fil!Y other litigation concerning custody or visitation with DYes Q/No
the child(ren) in this or any other state? If known, list the court, the case number and
the date the parenting plan, residential schedule, visitation schedule or custody decree
was entered:
the court the case number the date
D. Do you know of any persons, other than you and the respondent, who claims rights of DYes Dl'io
custody or visitation with, the child(ren)? If known, list their names in the space
provided below and their present addresses in the Confidential Information Form:
Name
Name
Name
E. List the places where the· children have lived during the past five years, the dates they lived there and the
persons with whom they lived. (The present addresses of those persons must be listed in the required
Confidential Information Form.) j A Rile
,
\.)i2, YJ YI I ¥'
I
e fJvutvicO J2J k.
9., YI /JJdt'l-0 f5:.L-°r-
· B erv e..(.-{ i 14- CJ.g';:?O l
CHILD CUSTODY INFORMATION SHEET- Page I of2

WPF DV-1.030 (9/2001)- RCW 26.050.030, 26.27.201- .291
CLERK'S OFFICE: S:IFORMS\FCOURTSERVICES\Domestic Violence\Petition Packet\3-Child InfoDV.doc
•
Jurisdiction:
This court has jurisdiction over this proceeding for the reasons below: [Check all the boxes that apply to
your case.]
D This court has exclusive continuing jurisdiction. The court has made a child custody, parenting
plan, residential schedule or visitation determination in this matter before and retains jurisdiction
under RCW 26.27.211.
D d'state is the home state of the children because:

the children lived in Washington with a parent or a person acting as a parent for at least six
consecutive months immediately before the beginning of this proceeding. ·
D the children are less than six months old and have lived in Washington with a parent or a
person acting as parent since birth ..
D any absences from Washington have been only temporary.
D Washington was the home state of the children within six months before the beginning 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. .. · ·
D The children and the parents, or the children and at least one parent or a person acting as a parent,
have significant connections with this state other than mere physical presence; and substantial
evide ce is available in this state concerning the children's care, protection, training and personal
rel 10nships and
the children have no home state elsewhere.
D the children's 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.
D 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.
0/ No other state has jurisdiction.
D 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.
I certify under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Dated orJ.e,&y p~ 8C05'at Evvrh!-f , Washington
CHILD CUSTODY INFORMATION SHEET- Page 2 of2

WPF DV-1.030 (9/200I) - RCW 26.050.030, 26.27.20I - .29I
CLERK'S OFFICE: S:IFORMSIFCOURTSERVICES\Domestic Violence\Petition Packet\3-Chiid InfoDV.doc
ETS PAGE 03
01/17/2005 03:02 4253483575
._..,,.·
RECEIVED
JAN 3 0 2006
LAWo.,.,.., .
. JAN,;(b~F
Davis &.Company .
Domestic Violence & Anger Management Program
3105BoytAve,SuiteA · .. ·-
Everett, WA 98201
Phone: (4':25) 388-0277-Fax: (425) 252-8527 C.r-:..~"-~. . :; . (1/,_.(Jl.·
.PJ.tt.~-:. r!l-r:;::- ~t J.. 2\:.:;r .
May25, 2005 r
'
Everett Municipal Court

2930Wetmore Avenue
Everett, WA 98201- 4073 ·
Proposed Assessment & Report for: Andrew Rife

Case#: CR67770
DOB: 3/23/73
SS#: 531-6~8901.
I have completed a diagnosis &. assessment for Mr. Rife who has been charged and/or has
a pending case with courts and/or attorneys with Domestic Violence. My findings are as
-follows:
1. Mr.. Rife has a problem that has reached the stage that UnJess treated there is a
strong probability of future similar violations.
2. Long-term treatnieiit can be effective and should be required.
3. The effective treatment for Mr. Rife is available.
4. It is my opinion that Mr. Rife is amenable to treatment.
These fihdings & recommendations are

based upon a history of Domestic Violence
indicated by the attached assessment. For case history, also see the attached assessment.
These findings & recommendations support treatment & recommend the following:
Mr: Rife presents in_ manner consistent with criteria established by the diagnostic criteria.
ma.Tiual JV for: 324. 34 V61.1 · · ·
EXH/Brr \c
01/17/2006 03:02 4253483676 ETS PAGE · 04
Page 2
Mr. Rife is scheduled to start treatment with our agency on May 31, 2005. He will be in
the Tuesday, 5:30 PM group.
Mr. Rife is a 32 year-old male. He is living without spouse and has one child. His parents
are both living. He states his relationship with his family is good at this time. He
maintains contact with his family.
Mr. Rife completed the 12"' grade and has additional education.
CHEMICAL DEPENDENCY
Significant indications include: None

Previous Treatment: No
RECOMMENDATIONS & TERMS:
!. Recommend Mr. Rife go to any State Certified Domestic Violence Program

for a one-year program.
KitDavis,
Counselor,
~c.11~
ttfs'
'ril"M.A.C Anger Program Specialist
01/17/2005 03:02 4253483575 ETS PAGE 05
---
Davis & Company

Domestic Violence/Anger Management Program
3105 Hoyt Ave. Ste A
Everett, WA 98201
Phone (425) 388-0277
Fax (425) 252-852
JlUle 7, 2005
Everett Municipal Court

2930 Wetmore Avenue
Everett, WA 98201- 4073
RE: Rife, Andrew

CASE#: CR 67770
DOB: 3/23n3
Your Honor,
Mr. Rife has requested informing you of his enrollment in the Domestic Violence
Treatment Program with this agency. Mr. Rife has attended one group session.
Respectfully,
Raymond Davis
Administrator
COUNSELOR:
Kit Davis CDS III M.A.C. Anger Program Specialist
01/17/2006 03:02 4253483676 ETS PAGE 06
.__ ,,, ..
Davis & Company

31 OS Hoyt Ave, Suite A
Everett, WA 98201
Phone (425) 388-0277
Fax ( 425) 252-8527
MONTHLY PROGRESS REPORT
June I, 2005
2930 Wetmore Avenue
Everett, WA 98201- 4073
RE: Rife, Andrew

CASE #: CR 67770
DOB: 3/23173
TREATMENT MODALITY COMPLIANCE Y 00 N 0

Group Counseling: Yes Dates: May 31, 2005
Missed Dates: Excused Y ON () Missed:
Missed Dates: Excused Y () N 0 Missed:
Information Classes: Dates:
Statement of progress: Mr. Rife has entered the Domestic Violence Program
(Phase I-weekly).
Recommendation:
If final report, summary/progoosis:
Kit Davis AL
Counselor, CDS III M.A.C. Anger Program Specialist
01/17/2005 03:02 4253483575 ET5 PAGE 07
·.
Davis & Company

3105 Hoyt Ave, Suite A
Everett, WA 98201
Phone (425) 388-0277
Fax (425) 252-8527
MONTHLY PROGRESS REPORT
July 1, 2005
2930 Wetmore Avenue
Everett, WA 98201- 4073
RE: Rife, Andrew

CASE#: CR 67770
DOB: 3/23/73
TREATMENT MODALITY COMPLIANCE Y 0 N CX)

Group Counseling: Yes Dates:
Missed Dates: Excused Y ON () Missed:
Missed Dates: Excused Y O N () Missed:
Infonnation Classes: Dates:
Statement of progress: Mr. Rife has not been attending as required. We are
closing his file at this time.
Recommendation: Referring Mr. Rife back to the court.
If final report, summary/prognosis: Prognosis for Mr. Rife appears to be poor

due to the fact that he has not completed his treatment program.
Kit Davis ,//' ~

Counselo~ M.A.C. Anger Program Specialist
01/17/2006 03:02 4253483676 ETS PAGE 08
Davis & Company

Domestic Violence & Auger Management
3105 Hoyt Ave Suite A
Phone: {425) 388-0277
Fax: (425) 252-8527
_ _,.'.5<...l..-'/J.-"-"?'"'"/_o"'----5'--_,, 2 oos
I, at.Jdn...,,,_ !?.. {19 acknowledge that I have read the foregoing report. I
accept the report as true and accurate. I fully understand and agree with the
following:
1) That I am In need of treatment I counseling,
2) That it is my responsibility to comply with the treatment I counseling plan

that I signed with Davis & Company,
3) That If I am removed for breach of any terms or condition, the court will
enter judgment immediately and I will be sentenced pursuant to RCW
10.05.022,
4) That I have eJ[amlned the fee structure for Davis & Company and I agree
that I am responsible for these services, being in rmancial compliance with
Davis & Company.
I hereby certify under penalty

. of perjury under the laws of the State
. of Washington
that the foregoing is true and correct.
Dated at C ,/ o OL rt , Washington, this .i)..5 day of IV\"j , 2005
Attaciunents
01/17/2005 03:02 4253483575 ETS PAGE 09
··-·
Davis & Company
CONSENT TO TREATMENT
• J hereby volunt..ily con1ent lo enter Domesl(., Vlolenee/Anaer Management

Tnalrnenl Pmgnrn at Davi. & Com11aoy.
• I agree fo abide by all nae rule• 11nd regulations establhibed by the treatment
fadllty, aud underetand tlu1t any lnlhldlon of11ueh ruin and re1ulatlon1
could result In 111.f Immediate dumiHRI.
• J ngreo tltat tlio tniatment faclllty 1hall NOT boar responalblo for lou or
deal ruction Of Dly penonal property,
• I laavo bee11 l11formed oflbo right lo 1efoct or be ..ererred to ally 11pproprl1tle

treatment facility lbr 1ervlce1 consl•lent with the re1alt• of my dla11no1la.
• J •area to r.a1m1 nay finandnl obUgallon of S {9 b
facility. to me frealn1enf
• I have 1-ec:elved a copy ofregulallons concernlna the conRdenllally patient

records. ·
1•at1e11t's sl11111ture_~~"'-"'=-----~---------l>•fe ~/ 2. ~p S
...... ~ . .
01/17/2006 03:10 4253483676 ETS PAGE 01
~DOMESTIC VIOLENCE INVENTORY

* * * * * * * * * * * * * *
NAME Andrew Rife
AGE: 32 SEX: Male CONFIDENTIAL REPORT
ETHNICITY/RACE : Caucasian
EDUCATION/GRADE: College graduate
MARITAL STATUS : Married DATE DVI SCORED: 05/25/2005
Domestic Violence Inventory results are confidential and are working

hypotheses. No diagnosis or decision should be based solely upon these
results. These test results are to be used in conjunction with experi-
enced staff judgment and review of available records.
MEASURES %ile DVI PROFILE

+---------------+-----------+-------+---+
LOW RISK MEDIUM -PROBLEM-MAX-
TRUTHFULNESS 77 *******************************
ALCOHOL 54 ********************** ..... .
CONTROL 95 *************************************** -
DRUGS 39 *********** ***** - 0 0 0 o 0 0 0 0 0 I 0 - 0 0 0 0 o 0 0 - o ' o -
VIOLENCE 72 ***************************** ...... .

STRESS COPING 12 *****..... . . . . . . . . . . . . . . . . . . . ..... .
+--------~------+-----------+-------+---·
0 40 70 90 100
----------- PERCENTILE SCORES -----------
ADDITIONAL INFORMATION PROVIDED BY CLIENT
Age of first conviction ...... 32 Times sentenced to jail .......... o

Misdemeanor convictions ...... o Times sentenced to prison ........ O
Felony convictions . . . . . . . . . . . o Years in jail and prison ......... O
Times on probation . . . . . . . . . . . 0 Domestic violence arrests ........ l
Probation revocations . . . . . . . . 0 Alcohol-related arrests .......... O
Times on parole. . . . . . . . . . . . . . o Drug-related arrests . . . . . . . . . . . . . o
Parole revocations . . . . . . . . . . . o Assault (not D.V.) arrests ....... O
Total number of arrests ...... 1
STAFF MEMBER SIGNATURE DATE (DVI TEST # 20 )
Risk & Needs Assessment, Inc., P.O. Box 44828, Phoenix, AZ 85064-4828
DVI Copyright (C) 1991, 1996
01/17/2006 03:10 4253483676 ETS PAGE 02
NAME: Andrew Rife -2- DVI REPORT

* * SUMMARY PARAGRAPHS EXPLAINING CLIENT'S ATTAINED SCALE SCORES * *
TRUTHFULNESS SCALE: PROBLEM RISK RANGE RISK PERCENTILE:77

This person's response pattern on the Truthfulness Scale is in the
Problem Risk (70 to 89th percentile) range. Truth-Corrected scores
should be accurate, however, there is the possibility of some distor-
tion. A conscious or perhaps subconscious attempt to present self in
an overly favorable light is evident. This person is defensive and
guarded regarding self-disclosure. Denial and resistance to further
inquiry and self-report can be anticipated. This individual is self-
protective and minimizing self-report information.
ALCOHOL SCALE: MEDIUM RISK RANGE RISK PERCENTILE: 54
This person's response pattern on the Alcohol Scale is in the Medium
Risk (40 to 69th percentile) range. Some indicators of alcohol (beer,
wine or liquor) use are present, however, an established pattern of
alcohol abuse is not evident. RECOMMENDATIONS: With regard to alcohol,
a low-intensity probationary response appears appropriate. Review this
person's court-related records and if additional alcohol-related con-
victions are revealed, treatment and probation should be upgraded
accordingly. In summary, the least restrictive disposition consistent
with public safety is recommended.
CONTROL SCALE: MAXIMUM RISK RANGE RISK PERCENTILE: 95
This person's scale score is in the Severe Problem (90 to lOOth per-
centile) risk range. Focal issues involve control of 'self and others.
Severe problem risk scorers are often described as domineering, bully-
ing, dictatorial and abusive. Family members may live in terror of
this person's temper, anger and violence. This person's significant
other may be held in bondage through intimidation and raw violence.
This person's court records should be reviewed for a history or pat-
tern of domestic violence. Counseling, anger management or psycho-
therapy appear warranted.
DRUGS SCALE: LOW RISK RANGE RISK PERCENTILE:39
This person's response pattern on the Drug Scale is in the Low Risk
(zero to 39th percentile) range. Low risk scorers reveal few, if any,
significant indicators of illicit drug use or abuse. Drug use may, if
present, be historical, experimental or minimal involvement. A person
that does not use drugs may score higher than z.ero, but will still be
in the low risk range. RECOMMENDATIONS: This person's court-related
records should be reviewed and if drug-related convictions are reveal-
ed, recommendations should be upgraded accordingly. A low intensity
probationary response is indicated.
VIOLENCE SCALE: PROBLEM RISK RANGE RISK PERCENTILE:72
This person's response pattern on the Violence Scale is in the Problem
Risk (70 to 89th percentile) range. Problem risk scorers are capable
of committing acts of physical, emotional or verbal abuse. They
frequently have communication difficulties and family/relationship
problems. Many harbor a lot of poorly repressed resentment, anger and
even hostility. RECOMMENDATIONS: Structure characterized by clearly
understood behavioral expectations and consequences should be con-
sidered, along with close supervision. When upset (or during periods
of substance abuse), this person's emotions all to easily interfere
01/17/2006 03:10 4253483675 ETS PAGE 03
NAME: Andrew Rife -3- DVI REPORT
with his or her judgment. Family or domestic violence counseling or

anger management program involvement is needed. When under perceived
stress this individual could be assaultive and potentially dangerous.
STRESS COPING SCALE: LOW RISK RANGE RISK PERCENTILE:12

This person's response pattern on the Stress Coping Abilities Scale is
in the Low Risk (zero to 39th percentile) range. Such individuals cope
very well with stress, tension; anxiety and pressure. Superior stress
coping abilities are indicated. Stress-related treatment or counseling
does not appear to be needed at this time. RECOMMENDATIONS: The Stress
Coping Abilities Scale correlates highly significantly with clinical
scales on the MMPI. Thus, an elevated Stress Coping Scale score (90th
percentile or higher) indicates mental health problems. However, this
is a low risk score.
SIGNIFICANT ITEMS: The following self-report responses represent direct

admissions or unusual answers.
ALCOHOL DRUGS
17. Admits drinking too much Lack of items may be deceptive.
51. Acknowledges drinking problem Review Truthfulness Scale.
DOMESTIC VIOLENCE CONTROL
10. Admits anger control problem 72. Admits dominates/controls
15. Admits has violent temper 82. Apologizes, and does it again
65. Usually tries to get even 84. Admits hurts/abuses others
89. Concedes pushes and hits
TREATMENT NEEDS (PROGRAMS) SELECTED
138. Anger Management

140. Domestic Violence Counseling
145. Temper Control
STRUCTURED INTERVIEW: These answers, with all of their biases, are the
answers selected by the client.
146. Temper problem: slight 151. Drug treatment: unmotivated
147. Drinking problem: no problem 152. D.V. counseling: wants help
148. Drug problem: no problem 153. No emotional/mental hlth prob.
149. D.V. problem: slight 154. Past year: not dangerous
150. Alcohol treatmnt: unmotivated 155. Anger management program
DVI RESPONSES
1- 50 TFTFFFFTFT TFFFTFTTFF TFFFFTFFFT FFFFTFFTFF FFFFFFFFFF
51-100 FTTFTFFFFF FFFFTFFFFT FTTFFTFTFF FTFTFFFFTF TFFT44l414
101-150 31·14141144 2121211323 1421242113 14l42NNYNY NNNNY34434
151-155 41442
_____ v _____ v _____ v _____ v _____ v _____ v _____ v ____ _
--·--- -------------
138. Anger Management
140. Domestic Violence Counseling
145. Temper Control
STRUCTURED INTERVIEW: These answers, with all of their biases, are the
answers selected by the client.
-----------------------------------------------------------------------
151. Drug treatment: unmotivated
146. Temper problem: slight
147. Drinking problem: no problem 152. D.V. counseling: wants help
148. Drug problem: no problem 153. No emotional/mental hlth prob.
149. D.V. problem: slight 154. Past year: not dangerous
150. Alcohol treatmnt: unmotivated 155. Anger management program
DVI RESPONSES
l- 50 TFTFFFFTFT .TFFFTFTTFF. TFFFFTFFFT FFFFTFFTFF FFFFFFFFFF

51-100 FTTFTFFFFF FFFFTFFFFT FTTFFTFTFF FTFTFFFFTF TFFT441414
101-150 3114141144 2121211323 1421242113 l4142NNYNY NNNNY34434
151-155 41442
EVERETT POLICE INCIDENT REPORT PAGE 1 OF _ I
INCIDENT OASENUMBER
D ~IOLATION NO CONTACT ORDER-DV DD 05-21287
OCCURRED ON OCCURRED TO REPORTED ON
MONTH DAY YEAR TIME MONTH DAY YEAR TIME MONTH OAY YEAR TIME
A
10 02 2005 0330 I 10 02
0 FORCE
2005 0330
COOE POL. BEAT
,DDRESS/LOCATION OF INCIOENT
T 2416 5TH STREET, EVERETT WA 98201 0 NO FORCE 011 11
RESP ~SGN
1:0 JUVENILE 0 COMPUTER USEO 0 HATE/BIAS
OFFENSE (OV<l>L .'\SL{ Dv~ 0 OFFICER SAFETY 0 CHIUD ABUSE 0 ORUG RELATED 0 ARSON-LOSS $
A CODES A0C181 A0C0 0 OFFICER ASSAULT , 181 DOM. VIOLENCE 0 ALCOHOL RELATED
2
NO. PERSON"S NAME (LAST. FIRST, MIDDLE) RACE ETH SEX D.O.B. /AGE HGT WGT EYES HAIR
p· V1 RIFE, JENNIFER RAE w N F 8/08/74 5'02 160 BLU BLN
3 3
E 2416 5TH STREET EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUP JSCHOOL HATE/BIAS VICTIM INJURY
R (425) 259-9828 ( ) 88 I 1
4 5 6
NO. PERSON'S NAME (l.J\ST, FIRST, MIDDLE) RACE ETH SEX D.O.B./AGE HGT WGT EYES HAIR
p W1 RIFE, JEFFREY DAVID w N M 6/27/75 6'02 208 BLU BRN
3 3
E 1320 HOYT AVE EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUP }SCHOOL HATEJBIAS VICTIM INJURY
R (425) 252-0366 (425) 231-9218 88 1

4 5 8
s
NO
A1
I CIN/IOENTlFICATJON NO_ BOOKED/WHERE
SNOH. COUNTY
LOCATION OF ARREST
2416 5TH ST, EVERETT
ARRESTEE ARMED WITH
NONE
NAME (LAST, FIRST, MIDDLE) RACE ETH SEX 0.0.8. I AGE . H_GT WGT EYES HAIR
u RIFE, ANDREW SCOTT w N M 3/22/73 5'11 180 BLU BRN
3 3
STREET ADDRESS ANO APT NO .. CITY STATE ZIP
s 2416 5TH STREET EVERETT WA 98201
RESIDENCE PHONE BUSINESS PHONE EMPLOYMENT/OCCUPATION/SCHOOL
p
(425) 259-9828
E
ALIAS NAME(S)
( )
SOC. SEC. NUMBER
531-68-8901
PUBLIC UTILITY DISTRICT
DRIVER'S UC./ l.D. CARD
RIFE'AS279D2
I STATE
WA
I EXP
MISC. IDENTIFIERS
c
CHARGES & CITATION # OR WARRANT # & AGENCY CHARGES & CITATION# QB..WARRANT# & AGENCY
T C!1 M D F CHARGE VIOL NO CONTACT ORDER CIT
1. 2. 0 M 0 F CHARGE CIT
CR0069259
NAME/ RELATIONSHIP OF ~ERSON NOTIFIED (JUVENILE) DATEfflME NOTIFIED l NOTIFIED BY
Sec0ndacy di;;,;r~rn:nation of this

d Or.llrn~:-rf i~: :iO't .:.!:rihr:ri7orf
v VEH. NO. i LICENSE NUMBER I STATE I YEAR MAKE MODEL I STYLE I COLOR
SPECIAL IDENTIFYING F.EATURES /V.1.N. DAMAGE$ REGISTERED OWNER'S NAME
v VEH. NO. I LICENSE NUMBER I STATE I YEAR MAKE MODEL I STYLE I COLOR
SPECIAL IDENTIFYING FEATURES I V.1.N. DAMAGES REGISTERED OWNER'S NAME
under the laws of the State of Washington that the fore oin is true and correct. RCW 9A. 72. 085.
DATE: FORCE USED PURSUIT
YES 0 NO 181 YES 0 NO 181
OFFICER UNIT AP~~BY: I PERS. NO.

C.OLSEN 422 J? ¥~7
CLEARANCE: DISTRIBUTION: OTHER:

UNFOUNDED JUV TRAF
<J§P PA
CPS HD
fV\ 1,-\-Y\: •
EXC/A DET
ARR/J
EXC/J
ADMIN
DSHS MH PAT fl.'"D sei.,.·lw-
1. ENTERED RMS ENTERED WACIC/ NCIC. CLEARED WACIC/ NCIC
DATE INITIALS
EVERETT POLICE DEPARTMENT
ADDITIONAL PERSONS PAGE _6 OF L
i.:;iclDENT foASE NUMBER
IOLATION NO CONTACT ORDER-DV D 05-21287
NO. PERSON"S NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.O.B./AGE HGT WGT EYES HAIR
p W2 RIFE, JAMES JOSEPH w N M 8/17/47 5'08 180 BRN BLK
3 3
E 1317 MCDOUGAL AVENUE EVERETI WA 98201
R (425) 259-1928 ( ) RETIRED 88 1
4 5
NO. PERSON'S NAME (LAST, FIRST, MIDDLE) RACE ETH .SEX D.O.B. /AGE HGT WGT EYES HAIR
'
p W3 RIFE, WENDY SUZANNE w N F 12/10/49 5'03 200 BLU BRN
3 3
STREET AODRESS AND APT NO. CITY STATE ZIP
E 2716 LEONARD STREET EVERETI WA 98201
R (425) 252-2817 ( ) SAFEWAY 88 1
4 5 6
NO. CIN/IDENT1FICATION NO. BOOKED/WHERE LOCATION OF ARREST ARRESTEE ARMED WITH

s
I
SUSPECTS NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.O.B./AGE HGT WGT EYES HAIR
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STREET ADDRESS AND AP"T: NO. CITY STATE ZIP
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( ) ( )
ALIAS NAME(S) SOC. SEC. NUMBER DRIVER'S UC. 11.D. CARO STATE EXP
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MISC. IDENTIFIERS
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NO. BOOKED I WHERE LOCATION OF ARREST
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CIN / IDENTIFICATION NO. ARRESTEE ARMED WITH
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SUSPECT'$ NAME (LAST, FIRST, MIDDLE) RACE ETH SEX D.O.B./AGE HGT WGT EYES HAIR
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. ._,,,~
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or
OFFICER NAME/NUMBER
C.OLSEN 1196
UNIT
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I APPRO~~Y: I PERS. NO.
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EX1·::a!T _B_
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Page !_of _!:j_
DD oy-t_ l"'t.?>1
BEverett Police Department

D FOLLOW-UP REPORT l;g] ORIGINAL NARRATIVE
INCIDENT
Violation No Contact Order-DV
I DD 05-21287
CASE NUMBER
REPORT DATE:
C-0 it(OL A-)Lll>VM 10/02/05
DA 181 C DA l!!IC DA DC DA DC DA DC DA De
INCIDENT RECLASSIFIED TO; DATE OF RECLASSIFICATION RELATED CASE NUMBER(S)IW. S. P. CONTROL NO
On 10/02/05 at approximately 0330 hours I responded to a report of a physical domestic violence situation at 2416
5th St. While en route, dispatch updated me that the male, Andrew S. Rife (3/22173) is the respondent to a no-
contact order. The protected party was his wife Jennifer R. Rife (8/08/74 ).
I arrived on scene and was met by a male who identified himself as Jeffrey D. Rife (6/27/75), the brother of
Andrew. At the front of the residence was Jennifer sitting on the porch. Officer Cracchiolo began to interview her
about-the situation:· t entered the house were Andrew was, he stated that earlier that night he was at his brother,
Jeffrey's house. Andrew's mom called asking if Jennifer could come over to Andrew and Jennifer's house while he
was gone. He told his mother that he did not want her over at the house. Later thatnight he returned home and
went to bed. At approximately 0330 hours Andrew heard someone banging on the front door. It was his wife,
Jennifer and their child, at first he did not let her inside because he said he was worried about the no-contact order.
He let her in the house and Andrew said Jennifer struck him on the right side of the face with a clos.ed fist and then
kicked him in the shin on the right leg while he was holding their 1 y/o daughter. I looked at Andrew's face and leg,
neither of them showed any redness or indication of a physical altercation. Andrew showed me a telephone in the
kitchen that had been broken by Jennifer the previous day when they got into an argument. The phone was on the
wall and the earpiece had been broken, connected by the wires only. Andrew told me that they have both been
staying at the house the past couple weeks. When I asked he stated he realized that he was in violation of the no
contact order against him.
Andrew then got on the phone and called his brother Jeffrey to come over because he said he was worried about
being arrested and he wanted Jeffrey to witness Jennifer hitting him. Jeffrey arrived at the house while I was
arriving on scene.
When talking with Jennifer she said !~at she had repeatedly called her house trying to contact her husband.
Jennifer wanted to come home because she was sick and wanted to get medicine and possibly stay at the house.
After repeated attempts to contact Andrew, Jennifer went over to the house. She knocked on the door and Andrew
would not let her in at first. Andrew eventually let her in. Jennifer stated that no assault had taken place and that he
.had made that up prior to Andrew calling his brother to come over. Seco;1r!:i:v
.
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or th;.s
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I certify (or declare) under penalty of perjury under the laws of the State of Washington that the forego1niJ7S trUe·and·cor£ect.i«BcW 9A.72.085.)
OFFICER SIGNAllJRE ~ DATE FORCE USED PURSUIT

.//.;;;:- / /0--02 -0 \
UNIT
YES 0 NOg_
APPROVED BY:/PERS.NO .
I YES 0 NO.g
OF. ·--"'"AME/NUMBER
.,:S7j ;r CJ.() ,o "76'? I
{ .°' (. ( evJ I ( 'r c l(}.. >
IBR CLEARANCE ( ) UNFOUNDED DISTRIBUTION: ()JUV () TRAF OTHER: LOGGED:
()9ARR I A ()EXC/A ()PA ()CPS ()HD () DET I
()ARR/J ()EXC/J ( ) ADMIN ( ) DSHS ()MH ()PAT
" " " ' " ' ,· <-CM/'I- DATE INITIALS
0 . 'I,,,
DENTEREO RMS I DENTERED WACIC I NCIC I 0 CLEARED WACIC I NCIC I

DATE INITIALS DATE INITIALS DATE INITIALS
i i i I -.~~.
Rev. 1/2004
EXi"!r - ____ , _ _.
l{
Pagei_of ~
DD oJ::-? l Lf;')/
Jennifer and Andrew are married and have been living at 2416 5'" street for awhile. They have a child in common
and share custody of the child along with the house.
After talking with Andrew's brother, Jeffrey he said that the two have had multiple problems in the relationship.
Andrew has been trying to keep his distance from his wife, but it has not been possible with them having a 1 y/o
daughter in common.
Both of Andrew's parents showed up at the house while I was on scene. The father James J. Rife (8/17/47) stated
that his son had been staying with him at his house the past weekend, due to problems between Andrew and
Jennifer. The mother, Wendy S. Rife (12/10/49) said that Jennifer had called her asking if she could call Andrew to
get permission to come over to the house. Wendy checked with Andrew and he had said that he does not want
Jennifer over there. Wendy called Jennifer back at Jennifer's parents and told her that Andrew does not want her to
come home.
I explained to Andrew that the no-contact order restricts him from coming within 150 feet of Jennifer's residence.
Andrew said he knew he was in violation of the court order and that he had tried to get the order quashed earlier
this week 9/29/05. I told Andrew that the order has not changed and that he was still in violation. When I placed
Andrew under arrest he began to complain of chest pains. I called for an Aid-car, they arrived on scene and
checked Andrew out. The determined he was alright and it was likely anxiety.
I read Andrew his constitutional rights from my department issued rights card, he said he understood and wanted to
talk to his lawyer. I advised him once we got to the jail he would be able to call his lawyer. I transported Andrew to
the Snohomish County Jail and booked him for violation of no-contact order. ·
· I am referring this case to the prosecutors' office for additional charges against Jennifer R. Rife for assault .
•..
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I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct (RCW 9A.72.085.)
DATE
OFFIC~:E_c2
II I
FORCE USED PURSUIT
(0 -0) - o ) YES 0 NOJi'>. YES 0 NO 00..
OFFICER NAME/NUMBER UNIT APPROVED BY:/PERS.NO.
r. Qi~{;' I 11 "! ', L(2 ~

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IBR CLEARANCE ()UNFOUNDED DISTRIBUTION: ()JUV () TRAF OTHER: LOGGED:
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{) - '(' ,_.._..1c>,r
0ENTERED RMS I DENTERED WACIC I NCIC I 0 CLEARED WACIC I NCIC I
DATE INITIALS DATE INITIALS DATE INITl&S
Rev. 1/2004 EXl-'·~~

11011 \-:>
-
Pagel_of.3
DD e»:- .;<.1 2- 8 7
BEverett Police Department
~ FOLLOW-UP REPORT . D ORIGINAL NARRATIVE
INCIDENT
COURT ORDER VIOLATION
I DD 05-21287
CASE NUMBER
REPORT DATE:
10/02/05
DA DC DA DC DA DC DA DC DA DC DA De
INCIDENT RECLASSIFIED TO: DATE OF RECLASSIFICATION RELATED CASE NUMBER(S)IW. S. P. CONTROL NO
On 10/02/05 at approximately 0330 hours I responded to 2416 5th Street to assist Officer Olsen with complaint of a
violation of a No-Contact Order and physical domestic violence. While I was on my way to the call I received
. information from dispatch that there was a valid order in the system that showed Jennifer Rife as the protected
person and Andy Rife as the respondent in the order.
The reporting person was Andy Rife and he advised the 911 call-taker that a female was at the location and that
she had punched him in the face while he was holding his daughter. Supplemental text was added by the call-
taker that the female was Andy's wife, Jennifer, and that she was now locked outside of the residence. There was
said to be an associated white BMW outside of the residence ..
Upon arrival I contacted a male west of the house that identified himself as Jeff. Rife, the brother of Andy Rife. Jeff
told me that he was phoned by Andy and told to come over to the residence because Jennifer had ·returned and
assaulted him. Jeff said he was there to support his brother. I asked Jeff to remain in his.·vehicle and not enter ttie ·
home until officers could sort out what was occurring.
I then contacted Andy while Officer Cracchiolo spoke with Jennifer. Andy said that he was hit in the face and
pointed to his right eye. I could see no marks that substantiated his claim, but did not rule out the possibility. It
should be noted that Andy's first complaint of the assault only included the area directly above his right eye and no
other part of his body.
Andy was adamant that he did nothing wrong and that he was awakened by Jennifer ringing the doorbell over and
over again. His appearance certainly Jent itself to his statements about being awakened suddenly as he was only
wearing jeans that were not completely fastened. Andy was holding his daughter,l;:§!!JftrR/~fld ~~pressed great
concern about Lauren being brought to the residence by Jennifer at the odd hour. doc,.:'.';, ?',''"9'1111l:Jiio 11 of th"
U1;1..,;!L Ji) nut di.it10ri--..'l IS
Andy told me that Jennifer had left the house the day prior and he was under the understanding that she woufcfSe
staying in Clearview with family. Jennifer was said to have contacted Wendy Rife, Andy's mother, about her
returning to the house and Wendy told her not to because Andy would be home. Immediately I could see some
discrepancy in who actually resides at the residence in which we were currently at. Both Jennifer and Andy alleged
that the residence was their primary address and with a valid No-Contact Order in the system there is the obvious
problem with the two of them residing under the same roof.
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. (RCW 9A.72.085.)
OFFICER SIGNATURE FORCE USED PURSUIT

//'70 YES 0 NO!:;( YES 0 NO 5.,
OFFICER N
IBR CLEARANCE ( ) UNFOUNDED DISTRIBUTION: ()JUV

()ARR/A ()EXC/A ()PA ()CPS ()HD
()ARR/J ()EXC/J ( ) ADMIN ( ) DSHS ()MH INITIALS
0ENTERED RMS DENTERED WACIC I NCIC _~~-=cc:-::-

DATE INITIALS DATE INITIALS DATE INITtALS
Rev. 1/2004
EXHiBIT- ..
Page 2 ot..3
DD ;§"-:i./ '2...13(
I returned outside and contacted Jeff and asked him to complete a written statement for me regarding the phone
conversation that he had with his brother. Jeff began working on the statement in his vehicle. As I was leaving
Jeff's vehicle another vehicle pulled up to the residence. The woman driving the vehicle was identified as Andy's
mother Wendy.
Andy had called Wendy after the police responded and she had come to support Andy. While I was speaking with
Wendy, yet another vehicle drove up to the residence. The driver of that vehicle was identified as James Rife, the
father of Andy. James had also arrived at the residence to support Andy. I spoke with both James and Wendy and
together they explained that Jennifer is a constant problem to Andy. They advised me that Andy and Jennifer have.
been living at the residence though it is a clear violation of the order. Apparently in the days just prior to this
incident, Jennifer and Andy had gone to dinner and an argument ensued bec<!use Andy refused to drink alcoholic
beverages with Jennifer at the restaurant.. That is what sparked Jennifer's leaving to be with family in Clearview.
James told me that Andy had also left the residence after that incident and was staying at his residence. James
said that he had hoped Andy would remain there but Andy told him that since Jennifer had gone to Clearview, he
wanted to return home.. Both James and Wendy completed written statements for me describing their knowledge
of the current living situation of Andy and Jennifer.
I told James and Wendy about the nature of the call in which I had responded to with other officers and explained
to them that there was indeed an order violation. I also stated that we were investigating the assault that Andy had
alleged occurred. I advised them that it was quite possible that the incident could result in Andy being arrested. To
this James adamantly replied that Jennifer was the ongoing problem and that the house had belonged to Andy
prior to the marriage and it was not right for his son to have to leave due to the order. I explained to him that it was
my understanding that neither Jennifer nor Andy appeared to have a clear understanding·of who was to remain at
the residence and that perhaps clarification was needed so we could prevent ·further violations of the Judge's court
ord~r.
I again.contacted Andy inside the residence. I asked him a second time to show me where Jennifer had hit him ..
This time Andy pointed to the side of his head above his right ear. I noted that this was a different location than he
had initially pointed out to me the first time I asked. I was also advised by Officer Olsen that Andy had advised him
that he was kicked by Jennifer in his leg but no mark or any other physical evidence could substantiate that claim. I
found it odd that the story of the alleged assault appeared to be evolving as the time passed.
I had brief interaction with Jennifer and she appeared to me to be very agitated and unwilling to answer questions
directly. To my knowledge, Officer Cracchiolo had the most interaction with Jennifer and his follow up should be
referenced for her account of the incident. I can say that in my brief interaction with her she seemed to be unclear
on the matter of who should reside in the residence and who should not. I also suggested to her that a parenting
. plan would be a good tool in reference to Lauren.
Ultimately Andy was taken into custody and booked at the Snohomish County Jail for the order violation. I phoned
James and advised him of the outcome as he had indicated to me while he was on scene that he would appreciate
my doing so. James was of course displeased with the final result and I suggest~~ to him that he should continue
to support Andy as he clearly was already doing and encourage Andy to not violatel~elogl_llrf!js;.;~!!Tiiii::JHGn of I";,
.
aocun1"n·' -., . . .
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- ··• 1d, I 1 r:'li
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct (RCW 9A.72.0i5:'}
PURSUIT
YES0 NO~
BY:/PERS.NO.
I
DISTRIBUTION: () JUV LOG ED:

()PA ()CPS ()HD
() ADMIN () DSHS () MH INITIALS
DENTERED RMS DENTERED WACIC I NCIC --~·--~

DATE INITIALS DATE INITIALS DATE INIT
Rev. J/2004
Page 3 ot--'S
DD o"'f- iI2-8 7
No further action was taken. End of report.
I cerlify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. (RCW 9A.72.0BS.)
OFFICER SIG~AT~ . . DATE PURSUIT

~ /(~-r. 10/oi./os YES 0 NO
OFFICER NAME/NUMBER
- ~l-(,. /{ Ji-o
UNIT f 1/ VED BY:IPERS.NO.
I
IBR CLEARANCE () UNFOUNDEO DISTRIBUTION: ( ) JUV ()TRAF

()ARR/A ()EXCIA ()PA ()CPS ()HD () DET.
()ARRIJ ()EXCIJ () ADMIN () DSHS ( ) MH ()'PA ATE INITIALS
DENTERED RMS _ _~.--- DENTERED WACIC I NCIC --~-·-~="'7 0 CLEARED WACIC I

Rev. 1/2004
. EVERETT POLICE DEPARTMENT STATEMENT FORM CASE#: DD c) ) - "2_ ( ?__t)/
STATEMENTOF: f.,"(<-- ~/:;ch.AJ ~ ScotJ-

LAST NAME FRST NAME MIDDLE NAME
lU Vv4-
RACE
W1
SEX
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Di .f ~1F mRTH
5· - / (
HEIGHT.
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EYE COLOR HAIR COLOR
RESIDENCE: /) l/ I " <;- 7· J,

STREET ADORESS
s+ c:(,.
CITY
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STATE
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ZIP
HOME PHONE #:t.( if 5 ~ fg;-1 wORKJcewt. LI') <;,- ;). s I 'i'l-i '6 EMPLOYMENT:_'--p_tJ_D_ __
ALTERNATE CONTACT (IN CASE OF RELOCATION):
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THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: _SJ::.J::'.l::lj::_.-!!.::::.j::'.:__.,--;~'1L,}~__Jlk:i~:__-
I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF THE S ATE OF WASHINGT N THAT THE
FOREGOING WRITTEN STATEMENT, CONSISTING OF _d:::-PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST OF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS..
I HAVE READ [fl I HAVE BEEN READ [ ) THE FOREGOING DECLARATION AND UNDERSTAND THAT THIS
ooc:~::rlN A COURT OF LAW. ( )
~TVRE)~ ~ ~R·W~
f_v~w..EF£<;;!: c?(5 'k< ( '°"reoFsTATEM~o u2-(o 5 .
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Page~of~ (X;-;;~:; .. <\3 i~t~

EVERETT POLICE DEPARTMENT STATEMENT FORM CASE#: DD ~r- "2 t "2-B7
STATEMENT OF: R..t JFE

LAST MAME
JE!tJA/f?e72--
FIRST NA.ME
R !}=IE:
· MIOOLE NAME
w '-
RACE
F
SEX
'J. 'f·7'i
DATE Of BIRTH
fio,P.
HEIGHT WEtGHT
RU/
EYECOl.OR
BLJJ
HAIR COLOR
RESIDENCE: d cf/~ ,~ 5'~ I £.,</£le err , µ.) 4 9 .P;4:71 . ZIP
t{,;;;~ W~:
CITY ; STATE
HOMEPHONE#: 25"f,
·,
THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: _ _ _ _ _..:.___ _ _~~--'-----
I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THATTHE
FOREGOING WRITTEN STATEMENT, CONSISTING OF PAGES IS TRUTHFUL AND ACCURATE TO THE
. BEST OF MY PER$6NAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS. .
I HAVE READ[-./). H/HiAVE BEEN READ ( . ] THE FO)}ff._91~G DECLARATION AND UNDERSTAND THAT THIS
DOCUME AY ~E USED IN A ~O RT ~FLAW. "fT--1 . -# .
lllh1f1.1·11 '-f. J1. C~/fcCHft7LO (177
(OFFICER OR WITNESS SIG«>.TURE)
GV~aT w4
{CrTY MO STATE WHERE SIGNet)
Page _ _ of _ _
EVERETT POLICE DEPARTMENT STATEMENT FORM CASE#: DD_~u~~~--~-·-\'2.-~/!;_r_ _
. :?
''l, \l. In "'· •. . Ci·~·
STATEMENT OF: -~L::--....,.,.,....~-----'V""IL~{;l..___~"'1'1'-----...,,~·~-
~·c"-'\J.-1_.<P!_ _ _ _ _ _ _ __
LAST NAME FIRST . MIOOl'.~ME
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DA.TE BIRllf
Cq e>Q
HE!GHT
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WEIGHT
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EYE COlOR HAIR COLOR
RESIDENCE: 1~'ft-0 rfDt.tf-· ..,~ C0 i,~d ev"A-· 1 q ?di

STREfr ADORE.SS CfTY STATE ZIP
HOME PHONE#: L{) 'J 'J-C:,J-6; (.. '-' ~:>~J_'f"-¢~/_.'"f,~.____ EMPLOYMENT: __:..P_!J_t)_·- - -
WORK/CEU#:-')-'-'
f)er:rL"ir.1... ... ..
THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: - - - - - - - ' - - - - - - - - - - - - -
FOREGOING WRITTEN STATEMENT, CONSISTING OF _ _ PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST OF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS ..
I HAVE READ [ ) I HAVE BEEN READ ( ) THE FOREGOING DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT MAY BEU DIN A COURT OF LAW. ( l
SIGNATURE) . _(OFFJCERORWITNESSSiGNATURE)
(CfTY ANO STATE 'MiE.RE SfGNED) (DATE OF STATEMENT)
Page of·
-- txJ,:::.i .. b (INIT.) _ __
p[).004 lo: Sl200-I
. '
. EVERETT POLICE DE ARTMENT STATEMENT FORM
..
I DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF TH

FOREGOING WRITTEN STATEMENT, CONSISTING OF _j__ PAGES, IS T HFUL AND A CURATE TO THE
BEST OF MY PERSONAL KNOWLEDGE. EACH PAGE AND All CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ [ ] /HAVE BEEN READ [ JTHE FO~EGOING DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT MAY BE USED IN A COURT OF LAW. t/Jik.{p
""" /U_/.../~ J/ /''-.._ ~ //~('.)
d.L ~ (OFFICERORWrTNESSSIGNATURE)
iuvu!!ll £J.1[_
(CITY ANO STAT~SIGNED)
, ;o/oz/o~ .,
_ _ __:_-!.--'.(OA=TE""OF=ST:"'.'ATE=::MENT)=------
page _ _ of D!si'.2!T .b (!NIT.} _ __

'SEX OF Bl ' · EIGHT tweGHT EYE COLOR HAIRCOl..OR
RESIDENCE: ----'/'-'}"--·.:....I +,7=£-'/J1~~°'=l2;._0'""'-'-A'-l_lf..:_fl_·_ __;(3,""'~=:;,=vz;r-

STREET AOORESS CITY
_ ___;·_,,,/-<.1=-'/:::'---_=cfV-:k?---,(!:;;--._
STATE . Z'
HOME PHONE#: 'ft? s=@-J<92? WORK/CELL#: _ _ _ _ _ _ ~_ _ EMPLOYMENT: ~A::_d .
THIS STATEMENT WAS WRITTEN ON MY BEHALF BY: _.,.4t;~QZ5::.::::::._ _ _c._._ _ _ _ _ _ __
I DECLARE UNDER THE PENALTY OF PERJURY UNDE E LAWS OF THE STATE OF WASHINGTON THATTHE
FOREGOING WRITTEN STATEMENT, CONSISTING OF PAGES, IS TRUTHFUL ANO ACCURATE TO THE
BEST OF MY PERSONAL KNOWLEDGE. EACH PAGE AND ALL CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ [ ] /HAVE BEEN READ [ ) THE Fo;;.p~G DECLARATION AND UNDERSTAND THAT THIS
DOCUMENT BE US 'IN A COURT OF LAW. ·
~· //"fO
(CITY ANO STATE 'M-tffiE SIGNED) (CATE OF STATEMENT)
Page _ _ of ·
-- "v""R~ _AJ
Q
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(INIT.) _ __
pD-()0.t Rcr. ~
'
I
JNCIOENT
D )ISSAULTDV
I
OCCURRED ON
EVERETT POLICE INCIDENT REPORT
' OCCURRED TO
~ENUMBER
DD 05-10775
•REPORTED ON
PAGE 1 OF
m
......_
n ....,;
A
MONTri DAY YEAR TJ~E
I
MONTH DAY
I
YEAR TIME MONTH
5
DAY
21
YEA~
20W~ .~
T
ADDRESS/LOCATION OF INCIDENT
2416 5TH ST
~ FORCE
0 NO FORCE JC ~, POL. BEAT
1 11
OFFENSE AS4DVM I 0
0
OFFICER SAFETY
ESP
bSGN 0
JUVENILE
CHILO ABUSE
0 COMPUTER USED
0 DRUG RELATED _~
• ~ t_:=rtlAS
R ON-LOSS$
A CODES AOC l8I AOCO OFFICER ASSAULT 181 DOM. VIOLENCE ~ ALCOHOL RELATED
... l'
NO- RACE ETH SEX 0.0.B.IAGE HGT EYES HAIR
...._r5'!
PERSON'S NAME (LAST, FIRST, MIDDLE}
p VIC RIFE, JENNIFER R w M 8/18/1974 5-02, BLU BLND
3 3
E
STREET ADDRESS AND
24165TH ST
RESIDENCE PHONE
APT NO.
BUSINESS PHONE
CITY
EVERETT
EMPLOYMENT/OCCUP./SCHOOL
=.o
~EJelAS
ZJP
98201
VICTIM INJURY
R (425) 259-9828
NO. PERSON'S NAME (LAST. FIRST, MIDDLE)

( )
RACE ETH SEX D.O.B.~

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HGT WGT
•
EYES
5
HAIR
•
p
3 3 -~
STREET ADDRESS MIO APT NO, CITY ,~ STATE ZIP
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RESIDENCE PHONE BUSINESS PHONE EMPLOYMENTIOCCUP~OOL HATE/BIAS VICTIM INJURY
-~
( ) ( )
R
,-;:!"'
• ' •
NO. I CIN/lDENTJFICATION NO. BOOK~DIWHERE
LOCATIO::t
_.r
I
ARRESTEE ARMED WITH
s A-1 369221 SNO COUNTY JAIL

NAME (LAST, FIRST, MIDDLE) RACE SEX 0.0.B /AGE HGT WGT EYES HAIR
-~
~•
u RIFE, ANDREW SCOTT 3 M 3/22/1973 5--08 175 BLU BRN
STATE ZIP
~
STREET ADDRESS AND A?T NO.
s 2416 5TH ST WA 98201
RESIDENCE PHONE BUSINESS PHONE J:'NT/OCCUPATION/SCHOOL
p ¢.,
(425> 259-9828 D
I
( )
ALIAS NAME($) SOC. SEC. NUMBER "ORNER'S UC. / l.D. CARD STATE
E
531-68-8901
(') RIFE•AS27902 WA
EXP
MISC. IDENTIFIERS
c .t"'.
CHARGES & CITATION #.QB_WARRANT # & AGENCY CHARGES & CITATION# QB_WARRANT# & AGENCY
T 1. ~ M 0 F CHARGE ASSAULT DV err CR 00677 .._~· 2. D M 0 F CHARGE CfT
NAME! RELATIONSHIP OF PERSON NOTIFIED (JUV? v OATEfTIME NOTIFIED
' NOTIFIED BY
i"
• .I"
v VEH. NO. I LICENSE NUMBER _N.""'I STATE YEAR MAKE MODEL I STYLE COLOR
SPECIAL IDENTIFYING FEATURES /V.l.N.<l!l

,... ....... DAMAGES REGISTERED OWNER'S NAME
v VEt-1. NO. I LICENSE NUMBER .-~- l STATE YEAR MAKE· MODEL I STYLE I COLOR
SPECIAL IDENTIFYING FEA!!~ ~l.N. DAMAGES REGISTERED OWNER'S NAME
I certifv (or declare) under n~ ~ of periurv under the laws of rhe State of Washlnaton that the fonono/na Is true and cotTeCt fRCW 9A. 72.085. J
OFFICER SIGNATURE,£ift.J DATE:
5122105
FORCE USED
NO
PURSUIT
UNIT
NO I APF]O~' I PERS. NO.
OFFICER NAME/WU
A WILLIAMS 421 ~--~UL
CLEARANCE' ~OUNOEO DISTRIBUTION:
OV JUV TRAF OTHER:
L5./>EO"
ARR/A EXC/A PA
CPS HO OET
::/frrK,.Y>k
Are
ARR/J A} EXC/J AOMIN
OSHS MH PAT
INITIALS
1. .dRED RMS - 'J '/)1 I \I ENTERED WACIC/ NCIC I CLEARED WACICI NCIC I
11 • · ATE INITIALS DATE INITIALS DATE INITIALS
PO OJ (REV. 1/04 TLK) FORM ID: IRF00.07.W95
~-
A.t
EXHIBIT Iii
,.
•
Pagej_of _
DD_ _ _ _ _ _ )...
•Everett Police Department 0v

0 FOLLOW-UP REPORT [Zj ORIGINAL NARRATIVE ~/\)
INCIDENT I -0
~-
CASE NUMBER
Assault DV DD 05-10775
~
REPORT DATE:
5/21/05
DA DC DA De DA DC DA DC DA DC DA DC
,
INCIDENT RECLASSIFIED TO: DATE OF RECLASSIFICATION RELATED CASE NUM~)i'W. S. P. CONTROL NO
_Q
...
On 5/21/05 I was dispatched to 2416 5•h St for a physical domestic. The caller, a f.ernple, called 911 and told the
call taker "My husband is abusive." The call taker could hear a male yelling in t~Oai:kground. The female hung
~~e~~. . '
When I arrived, Andrew Rife answered the door. I asked him if there was --~ument
inside the house. He told
me that he and his wife, Jennifer Rife, were arguing but quickly added t~~~n't physical." I asked Andrew to
step out and talk to Sgt. Myers while I interviewed Jennifer inside. ~.....,
Jennifer was still upset.and crying. I could smell the odor of into~icoming from her, but it did not appear that
she was intoxicated. Jennifer told me that she and Andrew went dinner in Seattle. On their way home, he
wanted to go to a casino. She did not. They started to argu85 it.
When they got home, the. argument continued. Andrew coi;ll'.!:lued to escalate until he grabbed her by the arms and
siarted shaking her in anger. She fell to the ground. Sb.~t up and they continued to argue. She eventually
called911. ~
I asked her if she had any injuries or marks as a re!a~the
assault. She told me "No. But I have bruises from
last Saturday Night." She pulled up her sleeves ~"llhowed me two bruises, one on each arm. The bruises were
purple, about the size of a thumb. I asked her hoMe had gotten them. She told me that he had assaulted her
last week as well, in the same fashion. Jen~if Id me that her husband is "a really nice guy, but when he gets
angry he has a terrible temper." The bruis her arms were consistent with Andrew grabbing her by the biceps
and shaking her. ~
Next I interviewed Andrew. Andrew al~ld me that they had gotten into an argument on the way home. He told
me that it "wasn't physical" but alsc;i ~e he had "grabbed" her.
~
Due to the history of un reporte~ssaults involving Andrew and Jennifer and the victim's injury from a previous
DV, I placed Andrew under arr~r assault DV. Sgt. Myers remained on scene to obtain written statements.
Andrew was booked int;i ~ohomish County Jail. .
f perjury under the laws of the State of Washington that tho foregoing is true and correcl (RCW 9A.72.085.)
OFFICER SIGNATURE DATE

FORCE USED PURSUIT
5122105
NO NO
UNIT APPROVED BY:/PERS.NO.
421 _;;;,@..,.,,,;?,,.,
DISTRIBUTION: () JUV ()TRAF OTHER: LOGGED:
()PA ()CPS ()HD ()DET
() AOMIN () DSHS ()MH ()PAT DATE INITIALS
CJENTERED WACIC I NCIC _ _ _ ._ __ CJ CLEARED WACIC I NCIC --~·---

CATE INITIALS DATE INITIALS DATE INITIALS
~
---
,.
•
EVERETT POLICE D CASE#: DDc___cf)=-=::....-_\....::O:_l.c_l...:...c')_~
"
THIS STATEMENT WAS W~N ON MY BEHALF BY: -------------------

1 DECLARE UNDERT~AL TY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THAT THE
FOREGOING WRITTE TEMENT, CONSISTING OF _i__ PAGES, IS TRUTHFUL AND ACCURATE TO THE
BEST 0. F MY PE~S~ KNOWLEDGE. EACH PA~ALL CORRECTIONS, IF ANY, BEAR MY INITIALS.
I HAVE READ'b·0~ VE BEEN READ [ ) THE FO 0 G DECLARATION AND UNDERSTAND THAT THIS
on_MENT MA~E SEO IN A COURT OF LAW.
~~~~:!&#v ,~ORWrrNESSS•GNATURfl
f \LED
ns J\.lL z.a ·~~ \o: ·~o
1
0 i\ \l\EL:-
~µI IL. CLERK
2 · our.ff 'l · As1-1.
st<OCHOt-1\Stl co. 'ii __.....'
3
Illlllll llllll Ill lllll lllll lllll l l l lllll lllll lllll l l llll
CL 11930613
4
s

NO. OS 3 027SS 1
Andrew Scott Rife
8 Petitioner, ORDER TO SHOW CAUSE RE
and CONTEMPT
9 Jennifer Rae Rife (ORTSC)
Respondent.
11 IT IS ORDERED•
Jennifer Rae Rife shall appear in person before this court at the place and time below and show
12 cause why the relief requested in the motion should not be granted.
13 Date: August 11, 2006 Time: 9:00 a.m.

14 Place: Snohomish County Courthouse Room/Department:
Everett WA 98201 As Assigned
lS
16
17 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.
18
Other:
19 L 28 2006
Dated:
20 Judge / Commissioner
Copy Received:
21
22
Jan Dyer W A# 203SS
23 Attorney Jennifer Rae Rife
24
2S CARLJ.GAUL
Allorney at Law
26
1604 Hewitt Ave.
27
WPF DR OS.0150 (9/2001) - RCW 26.09.160 425 259-4147 FAX 259 7081
1
FILED
2
3
ll~J//llllllCLlllfI/If11932605
/II~//I/fl l /111/lllll~l l 06 JUL 26 nl'i n~ 55
h\i·1 L. DANIELS
4 COUNTY Ct.ERK
SNOHOMISH CO.\"/ A SH.
5
•'
6
7
Superior Court of Washington
8 County of Snohomish
9
10
11 ANDREWS. RIFE, No. 05-3-02755-1
Petitioner,
12 and RESPONDENT'S OBJECTION
13 TO LACK OF PERSONAL
JENNIFER R. RIFE, SERVICE RE CONTEMPT
14 Res ondent
15
16
On behalf of the respondent, Jennifer Rife, we object to any finding of contempt ..
absent personal service or sufficient service and acceptance by Jennifer's below signed
17
attorney. Andrew Rife has obtained an Order to Show Cause re Contempt against
18
Jennifer Rife. That hearing is set for July 31, 2006 at 9:00 a.m.
19
Today is July 25, 2006. As of this date Ms. Rife has not been personally served
20
with the Motion and Order to Show Cause or the Motion for a finding of Contempt.
21
Also, as of this date, the copy of this order that has been received by counsel for Ms. Rife
22
is a copy that was faxed to my office. If it was Mr. Gaul trying to serve a copy via fax he
23 is well aware that my office does not accept service via facsimile absent prior
24 arrangements and agreement to accept such service. Although we are in receipt of a copy
25 of the Motion and Order to Show Cause, at no time has Mr. Gaul, on behalf of Mr. Rife,
26 requested that we accept service on behalf of Jennifer Rife. There was no form for
27 Acceptance of Service faxed with the copy of the Motion and Order to Show Cause nor
28 has one been provided to me since this order was obtained on the l 7'h of July.
29
30
Dyer & Primont
RESPONDENT'S OBJECTION 503 Tivelfth Ave. E
TO LACK OF" SERVICE Seattle, lVA 98102
RE CONTEMPT
(206) 343-152Sf
Page I
,o
1 Mr. Gaul has indicated to me on the telephone that the other attorney in my office
2 who covered a hearing in this case last week did say that we would accept service. That
3 is true. But saying we will accept service still requires that we receive adequate service
4 and a form for accepting service that we can sign and which can be filed with the court.
5 At this point, no adequate service has been accomplished on either Jennifer Rife
6 or her attorney. We object to any finding of contempt as there is insufficient service on
7 either the party or her attorney for the court to make such a finding.
8 In an abundance of caution, with this objection we are filing and serving our
9 response to the motion for contempt. The court is free to consider the information
10 provided in support of Jennifer Rife's request that a professional visitation supervisor be
11 appointed and that Mr. Rife's future visitation be professionally supervised. That motion
12 was filed and pending for hearing on the 31 51 prior to the time Mr. Rife obtained and filed
13 his Motion and Order to Show Cause.
14 Respectfully submitted this 25 1h day of July 2006.
15
16
17
18
19 Atto ey r Jennifer Rife
20
21
22
23
24
25
26
27
28
29
30
Dyer & Primont
RESPONDENT'S OBJECTION
TO LACK OF SERVICE
RE CONTEMPT
Page 2
ORIGINAL 503 Twelfth Ave. E
Seattle, 1VA 98102
(206) 343-1528
1
2 . ..
~·
3
CL 11930609
II~
11/lllllllllllI//fIllI/IllI/IllIll/II/Ill Jin/Ill/I/I
4
6
9 Andrew Scott Rife NO. 05 3 02755 1

Petitioner,
Respondent. (MTSC)
12
I. MOTION
13
18 entered on November 1, 2005 in this matter.
20 Does not apply.
22 Granting sanctions for contempt, including a forfeiture for each day the contempt of court
23 any other relief, including reasonable attorney fees and costs and make up residential time,
24 Chapter 26.26 RCW, and RCW 26.18.040.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CA USE RE CONTEMPT (MTSC) - Page I Everett WA 9820 I
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 708!
1 Imprisonment is sought as a sanction.
2 1.4 OTHER:
3 This is the third similar motion filed with the court. Andrew Rife requests triple
make up time.
4
is motion is based upon the declaration which follows.
5
Dated: July 25, 2006
6
8 II. DECLARATION
9 Jennifer Rae Rife should be held in contempt for the following reasons:
10
Failure to comply with the parenting plan as follows:
11
This is the third contempt motion filed for my wife's ongoing refusal to allow residentail
12 time.
13 This is an extreme case of adamant refusal to allow residential time. On November 1, 2005
the court entered an order providing for three visits per week as arranged by the Guardian
14 ad Litem. GAL Bridget Llewellyn established a pattern of Monday and Wednesday from
4:30 to 6:30 p.m., and Saturday from 11:00 a.m. to 5:00 p.m. Ms. Llewellyn also
15 established a "delivering parent" rule, though the transfer of the child has been handled by
other extended family members to assure no direct contact between my wife and me. My
16 deliveries have been handled exclusively by my mother, Wendy Rife. My wife's deliveries
have been handled by her mother (carol Holland), by her sister (Lisa Brunsman) and her
17 brother in law (Michael Brunsman).
18 On Friday, July 7, 2006, my estranged wife's motion for an immediate order requiring my
residential time to be professionally supervised or suspended was denied. Immediately
19 after that ruling from Commissioner Stewart, my wife's lawyer informed my lawyer that the
residential time for the following day would be denied. My lawyer wrote her lawyer
20 suggesting the decision be reconsidered 1• There has been no response to that letter.
21 On Saturday, July 8, 2006 my daughter was not delivered as required. An Order to Show
cause re contempt was obtained for that denial of residential time. On Monday, July 10,
22 2006 my lawyer wrote suggesting make up time. On July 10 my lawyer wrote again
informing my wife's lawyer that the July 8 residential time did not occur and that residential
23 time was scheduled for the afternoon of July 10. That residential time did occur, as did the
residential time on Wednesday, July 12.
24 1----------
1
25 Copies of all the correspondence mentioned are attached to this declaration.
CARLJ.GAUL
26 Attorney at law
27 1604 Hewitt Ave.
WPF DR 05.0100 (912000)-RCW 26.09.160 425 259-4147 FAA 259 7081
- - - · - - - - -------
1 time was scheduled for the afternoon of July 10. That residential time did occur, as did the
residential time on Wednesday, July 12.
2
On July 14, 2006 my wife's attorney wrote claiming that visitation is now "impossible" based
3 on restraining orders obtained by my mother and by me. My mother obtained an order of
protection from unlawful harassment based upon unnecessary and unpleasant
4 communication from Jennifer Rife. I obtained an order of protection from unlawful
harassment based upon stalking by Carol Holland. Hearings on both matters were set for
5 July 21, 2006. There is no order limiting contact by Lisa Brunsman or Michael Brunsman.
My attorney wrote back to her suggesting transfer between the grandmothers someplace
6 other than my home as Carol Holland is mandated to remain at least 300 feet from my
home. Ms. Dyer has not responded to that letter.
7
On July 17, 2006 the GAL sent a letter (dated July 15, 2006) suggesting a simple means for
8 the transfers to occur, by having the two grandmothers meet to exchange the child. There
has been no response to that letter.
9
On July 18, 2006 Ms. Dyer left a message about continuance of the District Court hearing
10 on the Unlawful Harassment actions. My attorney responded by letter the same day
agreeing to continuance if an agreed order was signed resuming the residential time and
11 making up the missed time. Ms. Dyer did not respond, but she did have her partner, Mr.
Primont, appear for her at that hearing.
12
On July 21 GAL Bridget Llewellyn sent another letter mandating resumption of visitation.
13 She decreed that the exchange would occur at the Everett Police Station, with Jennifer to
deliver and my brother's wife Stacey to receive my daughter for me. Stacey was there on
14 Saturday, July 22, 2006 from 10:55 to 11:15 a.m. to receive my daughter, but Jennifer did
not appear. Stacey was there again on Monday, July 24, 2006, from 4:25 to 4:45 p.m. but
15 Jennifer did not appear and the residential time was again denied. My attorney has
received a copy of Ms. Llewellyn's letter of July 24, 2006 which mentions Ms. Dyer's
16 telephone message responding to her July 21 letter.
17 HISTORY OF THE LITIGATION
18 The Everett Municipal Court required me to complete domestic violence perpetrator's

treatment. I have done so and completely satisfied that court's requirements. There is no
19 order in any other court requiring me to be in any other counseling or treatment.
20 My wife's declaration of October 2005 states that "I am asking that the court to order that
there be no visitation until he has completed at least 60 days of treatment at Family
21 Services and has received positive monthly progress reports."
22 The court's order of November 1, 2005 does not contain any requirements consistent with
my wife's request.
23
My wife filed another declaration, December 2, 2005, in which she states "He should be in
24 treatment and in full compliance in order to have any visits with Lauren."
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CA USE RE CONTEMPT (MTSC} - Page 3 Everett WA 9820 I
WPF DR 05.0/00 (912000) - RCW 26.09.160 425 259-4147 FAA 259 7081
1 There have been communications among the attorneys and the GAL on these topics, but no
pleadings with the court, until this month. In support of the July 7, 2006 motion my wife's
2 declaration states "With Andy not in treatment and only being supervised by his mother I
am very concerned for our daughter's safety (both emotional and physical) while in his care.
3 His time must be professionally supervised or suspended altogether." After the court
denied that motion without prejudice, yet another motion was filed, this time omitting
4 suspension, but requesting "father's visitation to be professionally supervised pending trial
in this matter." This time my wife signs a July 13, 2006 declaration in which she claims
5 "He is currently not in any treatment program, contrary to the recommendation s of the
GAL in our case."
6-
Jennifer continues to make the same or similar allegations. Her position has not changed.
7 She does not recognize my involvement with DV treatment providers. She simply pretends
that the treatment I received had no effect.
8
Jennifer does not recognize that the court's order has not changed. I am still entitled to
g three visits per week as arranged by the GAL. She refuses to comply with that order.
10 I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
true and correct.
11
12 Signed at Everett WA
13
14
15
16
17
18
19
20
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 7081
OYER & PR/MONT
Seattle, W<tshlngton 98102
Jan Dyer, Attorney Amy Pasco, Paralegal

Mi<hael Primont. Attorney Geotg!a Ross, L<g•I Asslst>nt
July 14, 2006
Carl Gaul Sent via facsimile

302 Bank of America Bldg. Original to follow by legal messenger
1604 Hewitt Avenue
Everett, Washington 98201
Re: Rife dissolution
Dear Mr. Gaul:

My client and her mother have provided me with copies of the ex parte (District Court) no
contact orders that you helped your client's obtain. Given that Jen is to have to no contact with
Wendy and her mother is to have no contact with Andy, the current visitation arrangements can no
longer be used and visitation will simply not be feasible. Wendy certainly can no longer act as
supervisor when she has a no contact order against the mother of the child. Jenn's mother can not
have any contact with Andy and is no longer willing to be involved in the transfers. Neither of the
orders make any exceptions for the visitation transfers and I am advising them both to strictly adhere
to these temporary no contact orders. Unfortunately for your client this makes any supervised
visitation or transfer for such visitation impossible.
Best regards,
~ ~ \o,_-'l-
9:~"'"-~
0..\)b~ ~....\.c""\
"'"°
Jan M. Dyer -........l
Cc: Jenn Rife

Bridgen Llew¢llyn
;206/343-15l0 www.i:t~rprtrncmt.com
"
2
CARLJ.GAUL Attorney at law 425 2'9-4147 fix 42j 259·7081
1604 Hewitt Avenue
Everett WA 98201
July 14, 2006 Fax Only To 206 343 7781

503 Twelfth Ave. East RE: Upcoming Visitation
Seattle WA 98102
Dear Ms. Dyer
I read your fax of this afternoon with some sense of wonderment. One would think that
somehow Wendy Rife wanting to enforce her right to be free from harassment constitutes a waiver
by Andrew Rife of his right to visitation. I don't follow the logic. Likewise, from your fax one would
think that Andrew Rife is somehow at fault for objecting to being stalked. I don't follow that logic,
either.
I do remember that the motion to suspend my client's visitation or have it supervised by

someone other than Wendy Rife was denied. And I also remember that my suggestion of arranging
make up visits has not generated any response. And I remember that Mrs. Rite's extended family
being "unwilling" to continue to assist with the visitation exchanges was evident immediately after
the court denied that motion.
There is nothing in any order preventing the two grandmothers from having contact. Wendy
Rife will be perfectly happy to walk down the street to accept the child from Carol Holland so she will
remain at least 300 feet from Mr. Rite's home. If there is a desire to solve problems, this is easy to
arrange and hardly requires any imagination. On the other hand, if the real purpose is to prevent
the visitation, any convenient excuse will do. Alternatively, transfers could occur atthe Everett Police
Department. It is the only local department whose office is open 24/7. Certainly Mr. Rife will be
happy to provide constructive responses to other constructive suggestions.
Yours truly
Fa.xed Without Signature

To Avoid Delay
CARLJ.GAUL
OG/s
enc
cc: Andrew Rife

Bridget Llewellyn
1
...... oihs/2066'' iii :·53 'F'.U'':12·5 .. 25'2' foiti' ....... ... ..iiRiDGET ..i.iiiliiii.i.YN ................................................ iai o'62 .................. .
Bridget Uewellyn
Guardian ad Lilem
3114 Oakes Avenue
Everett WA 98201
Ph # 425-339-238
VIAFAJ{
July 18, 2006
JAN DYER
Seattle, VIA. 98102
CARL GA.UL
1604 Hewitt Avenue
Everett, VI A 98201
Re: RIFE
Dear Jan and Carl:

In reviewing the November 11, 2005 Court Order that clearly states that visitation times, days,
etc shall be determined by the Guardian ad Litem and the fact that I have received no direct response
to my letter of yesterday, July 17, 2006 J would recommend that the following occur:
I. Visitation shall resume.

2. All exchanges shall be between the Grandmothers, with no other persons in attendance.
3. The exchange shall take place as follows:
Maternal Grandmother shall deliver to the home of the Paternal Grandmother

and the Paternal Grandmother shall return the child to the Maternal
Grandmother's home OR the exchanges can take place at the Everett Police
Deparbnent OR at midway point agreed to between the Grandparents.
4. There will be no interference in this process by ANY other party.
I realize that this will only come about if the Grandmothers agree to it. Since neither is a party
to the action I am hoping that these two marure women can commwticate as they have been able to in
the past and we can move forward again.
S~ely, .
8~~ ·i-~ ~~-Lti.;

Bridget Llewelfyl;
Guardian ad Litem
BL:jld
Cc: file
1
···· ··· ······· ·· ··· ·········.... ·· ··@0·01 ···
1
Bridpt Llewellyo, Guardian ad Lilrm
2 3114 Oakes Avenue
Everett, WA 98201
3 Phone: 425-339-2383
Far. 425-252-$016
4
5
CarlGaul
6
7
Jan Dyer
8 July 21, 2006
9 Re: Rife Vlllitation
10 Dear Carl & Jan,
11 I believe this is the third letter I have sent in Re: visitation or the lack thereof There bas
been no acknowledgment of my correspondence thus far.
12
Visitation shall resume immediately. I believe that it is up to Jennifer to make the child
13
available and since I understand that her sister and her mother do not wish to be involved
14 and there are Restrdining Orders in place, Stacey will meet Jennifer at the Everett Police
Department fur pick up and drop off. There will be no other individuals involved.
15
As a side note and for your infortoation, it is my understanding that Mr. Rife will finish
16 his Parenting Class this coming week and will commence his Domestic Violence
Treatment at Catholic Comm1mity Service also this coming week.
17
Again, I stress that stopping and starting visitation is not in the best interest of this child.
18 Like all children, she needs consistency in her schedule.
19
20
Yours Truly,
LL
21
22
23
24
25
1 Title Michele Patzer
Page- Guardian ad Litem
1
BRIDGET. LLEWELLYN............................................... ~fii°o 2................... .
':I:.·
.. Bridget LJeW(lllyn
Gua/Tiian ael Litem
· 3114 Oakes Avenue
· Everett WA 98201
Ph # 425-339-238
VIAFAX
July 24, 2006
JAN DYER
Seattle, WA 98102
CARL GAUL
1604 Hewitt Avenue
Everett, WA 98201
Re: RIFE
Dear Jan and Carl:

I am in receipt of your phone message of July 21, 2006, Jan. While I find your attitude and
accusations offensive I will simply remind you that the Court Order of November, 2005 clearly states
that visitation should be determined by the Guardian ad Litein and I am simply following that order.
On another note I have been called for Jury Duty starting July 31, 2006. We have a hearing
that day and it is too important to try and extend it to a later time and so I would suggest that we try to
move it to Friday, July 28, 2006 at 9:00 am. Please advise.
I attach a copy of my Jury Summons for your edification.
Sincerely, L
~~ Guardian ad I.item
BL:jld
Cc: file
l
.. iiiffocii'i'. LLiiWiiLLYN ·····. ························ ·· iai 1Yoi/oof ·· ·· ·······
Bridget Uewel/yn
Guardian ad Litem
3114 Oakes Avenue
£Everett WA 98201
Ph # 425-339-238
VIAFAX
July 12, 2006
JAN DYER
Seattle, WA 98102
CARL GAUL
1604 Hewitt A venue
Everett. WA 98201
Re: RIFE
Dear Jan and Carl:

Today, July 11, 2006 I have been in contact with Keith Osborn who is Mr. Rife's Probation
Officer through Municipal Court.
The information I received is:

Mr. Rife is in compliance with Municipal Court and Judge O'Dell is satisfied that Mr. Rife has
fully satisfied the terms of his Court Order.
Mr. Osborn was asked to do a Risk Assessment and did so. He found that Mr. Rife is not a
risk to the community. Mr. Osborn will now be monitoring Mr. Rife until his two (2) year is up.
As far as Municipal Court is concerned he has satisfied all of his terms and he is done.
I asked if there would be anything in writing and was told "no" but the docket is available. It
is now up to Family Court to proceed as they see fit.
I am simply sharing the information with you both. I am sure you will both let me know what,
if anything, you choose to do with it, in due time.
~in~~t-·
Bridget Llewellyn
Guardian ad Litem
BL:jld
Cc: Court file
1
CARLJ. GAUL Attorney al Law 41J 1$9-4147 Cu:41J 2.59·7081
1604 Hewitt Avenue
Everett WA 9820 I
July 18, 2006 Fax Only To 206 343 7781

503 Twelfth Ave. East RE: Hearing Date Unlawful Harassment
Seattle WA 98102
Dear Ms. Dyer

I received a telephone message about your availability (unclear whether you, Mrs. Rife or
Mrs. Holland, or some combination thereof) for hearing on July 21, 2006, along with the suggestion
that the hearings be continued.
I will consider a continuance when you have signed the enclosed order in the domestic
relations case, but no later than noon tomorrow. If I have a signed order, we can continue the
unlawful harassment hearing with a reissuance. Otherwise not.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
enc
cc: Andrew Rife
Bridget Llewellyn
1
..

COUNlY OF SNOHOMISH
In re:
Andrew Scott Rife
Petitioner, NO. 05 3 02755 1
and
AGREED ORDER RE FATHER'S
Jennifer Rae Rife RESIDENTIAL TIME
Respondent.
Pursuant to the agreement of the parties,
IT IS HEREBY ORDERED
1. Father shall have make-up residential time on Sunday, July 23, 2006 from 11 :00 a.m.
to 5:00 p.m. to compensate for the residential time denied to him on July 8, 2006.
2. Father shall have make-up residential time on Tuesday, July 24, 2006 from 4:30 p.m.
to 6:30 p.m. to compensate for residential time denied to him on July 17, 2006.
3. Father shall have make-up residential time on Sunday, July 30, 2006 from 11 :00 a.m.
to 5:00 p.m. to compensate for the residential time denied to him on July July 15, 2006.
4. All future exchanges of the child for residential time with each parent shall occur by
Mother being responsible to have the child delivered to the father's representative at the
home of Wendy Rife, 2716 Leonard Dr., Everett, WA at the commencement of the
father's residential time and the father being responsible to have the child delivered to
the mother's representative at the home of Carol and Steve Holland,
Snohomish WA at the commencement of the mother's residential time.
4. All future exchanges of the child for residential time with each parent shall occur by both
parents' representatives meeting at the Everett Police Department to exchange the
child.
5. Neither Jennifer Rife nor Andrew Rife will be present at the time and place of exchange
CARLJ. GAUL
Attorney at l.iJw
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
2
. .
of the child.
Dated:
Judge I Comm1ss1oner
So Stipulated So Stipulated
CARL J. GAOL WSBA# 8341 JAN DYER WSBA# 20355

Attorney for Andrew Rife Attorney for Jennifer Rife
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
3
"
::!LED
I Illlllll llllll Ill lllll lllll lllll llllrlllll lllll lllll llll llll
CL11557419 LU J!JL 31 ~.I'\ 11: 39
" ' ' i l Dt,NIELS
'cout<TY CLERP:,,"
~HOHOHISH CO. 'ii" ,H.

PLAINTIFF I PETITIONER
J PJJ;
U
/
v-
and
DEFENDANT/RESPONDENT
Presented By:
Copy Received:
fetj'GE/ CO~MMISSIONER
6101 page 1ol2
Page# 2-..
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of~
Presented By:
Copy Received:
H)DG~RT COMMISSIONER
w 1 page 2 or 2 1084·4
. . .
JUL 8 12006
DONE IN OPEN COURT this date: _ _ _ _ __
Presented By:
T COMMISSIONER
Copy Received:
Mil page 2 of 2 1084-4

.. ,..J
--
1 ZOilo JUL 31 Pll 2= 20

2
I1111111111111Ill11111111111111111111111111111111111 Ill\ Ill\ .

CL 11937148

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Andrew Rife's
Jennifer Rae Rife Parenting Class certificate
11 Respondent.
12 Please see attached certificate of completion of Ages & Stages Class
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAA 259 7081
. ., ._ - CGMPASS
I
··~>-·.'
.. ;
' f Health
4.ndr-ew §cutt l?ife

Participated in and completed the (parenting) class
~tie§ & §taee§

This class has no entrance or exit requirements other than attendance. The
participant completes this class when he or she has attended and participated.
Completion of this course does not necessarily guarantee change in behavior or
attitude on the part of the participant
Class Date(s): July I Ith, July 18th & July 25th 2006
@ COMPASS HEALTH'S FEDERAL AVENUE CAMPUS SITE
~~ July 26, 2006

Sii,rnaturc l)atc
•
7
1LED
1
·; JUL 3 I Ml II: S6
SUPERIOR COURT OF i't,fl ~- DAr~JELS
WASHINGTON COUNTY CLERX
O>NOH0/1/SH CO. '>'!.'.SH.

(PETITIONER) COMMISSIONER: TRACY G. WAGGONER
AND CLERK: L. MARTIN
JENNIFER RIFE DATE: 07-31-06 ® 9:00 AM
THIS MATTER CAME ON FOR: TEMPORARY ORDERS; SHOW CAUSE RE CONTEMPT

ACTION:

RESPONDENT APPEARED: YES COUNSEL: JAN DYER
GUARDIAN AD LITEM APPEARED: BRIDGET LLEWELLYN
DOCUMENTS FILED:
ORDERS ENTERED: ORDER RE 1) RESPONDENT'S MOTION FOR SUPERVISED VISITS 2)

PETITIONER'S MOTION FOR CONTEMPT.
RESPONDENT'S OBJECTION TO SERVICE AS TO THE CONTEMPT MOTION: THE COURT

WILL HEAR THE CONTEMPT MOTION AS THE COURT BELIEVES THERE WAS AN AGREEMENT TO
ACCEPT SERVICE.
IT HAS BEEN AN OVERSIGHT THAT THIS COURT DID NOT ORDER FATHER TO BE IN
A DOMESTIC VIOLENCE TREATMENT PROGRAM. THIS COURT DOES NOT ACCEPT WHAT WAS DONE
IN DISTRICT COURT. FATHER SHALL ENROLL IN AND COMPLY WITH A DOMESTIC VIOLENCE
TREATMENT PROGRAM THAT COMPLIES WITH THE WASHINGTON APPELLATE CODE. THE COURT
DOES NOT FIND PATERNAL GRANDMOTHER CAPABLE AS A SUPERVISOR BECAUSE OF THE
ADVOCACY INVOLVEMENT. FATHER'S VISITATION SHALL BE SUPERVISED AS ARRANGED BY
GUARDIAN AD LITEM; THE COURT HAS NO OBJECTION TO JUDY DYER OR DON LAYTON.
VISITATION SHALL RE-COMMENCE UPON VERIFICATION OF FATHER'S ENROLLMENT

·-
ANDREW RIFE AND JENNIFER RIFE, 05-3-02755-1
DOMESTIC VIOLENCE TREATMENT. THE COURT DOES NOT FIND THE MOTHER IN CONTEMPT
AS TO THE PARENTING PLAN. THE COURT THINKS THE MOTHER OVER-STEPPED BY
SUSPENDING ALL VISITS CONTRARY TO THE DIRECTION OF THE GUARDIAN AD LITEM AND
THINKS MOTHER WAS DOING SO AT THE ADVICE FROM COUNSEL WHICH IS A DEFENSE. IF
FATHER CAN FINANCE MAKE-UP VISITATION, IT MAY COMMENCE AT HIS EXPENSE.
CALCULATION OF MAKE-UP VISITATION SHALL BE FROM THE DATE OF THE LETTER FROM THE
GUARDIAN AD LITEM INDICATING VISITS SHALL COMMENCE.

I\\\\\\\\\\\\\ \\ill\\\ Ill\\ \\Ill\\\\\ Ill\\ \Ill\ Ill\\ \Ill\\\\ FILED
CL11871596
1 2006 AUG - 7 PM 12: 56
2 ,·AM L. DANIELS
COUNTY CLERK
3 SNOHOHISH CO. WASH.
5
6
8
g ANDREW SCOTI RIFE
Plaintiff,
10 NO. 05-3-02755-1
vs.
11
JENNIFER RAE RIFE MOTION I DECLARATION FOR
12 ORDER TO SHOW RECONTEMPT AND
Defendant. ORDERTO SHOW CASUE FOR
13
RECONTEMPT
14
15
The undersigned hereby declares: That he is now and at all times herein mentioned, a
16
citizen of the United States and a resident of the State of Washington, over the age of
17
eighteen, not an officer of a plaintiff corporation, not a party to nor interested in the above-
18
entitled action, and is competent to be a witness therein.
19 On July 29, 2006, at approximately 1:05 p.m. and witnessed by Laura Chunyk, I
20 served the above-described documents in the above-entitled matter upon Jennifer Rife at the
21 location of 70th and 69th Drive SE in Snohomish County, in the immediate proximity of
22 defendants residence located at 14200 69th Drive SE, Unit A, within the County of
23 Snohomish, State of Washington.
24
... \'
Upon arrival at 14200 691h Drive SE, I turned onto 701h Street just prior to drviveway
1
at 14200 691h Drive SE, where the defendant then also turned, stopping her car next to mine. I
2
asked subject for her first name, she replied that her name was "Jennifer". With confirmation
3
of her first name, visual identity verification based on a reference picture, and a match on the
4
vehicle description, and having witnessed her leaving the forementioned residence, I then
5
presented and left said documents with Jennifer Rife. No information was provided to indicate
6
the subject served is a member of the military.
7
I hereby declare under penalty of perjury under the Jaws of the State of Washington
8 that the foregoing is true and correct.
9 Dated: July _ ____, 2006
10
11
12 Jerry W. Gillentine, Jr.

13
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, .
'1
1
2 F /LEO
3
OFi HAR 29 AM 10: 22
4
r'r\1'1 L. DAf\!IELS
5 111111111111111111111111111111111111111111111111111111111111 COUNTY CLERK
CL11730160 SNOHOMISH CO. \'I A SH.
6
7
9
10
11
Petitioner,
12 SATISFACTION OF PAYMENT
and
13
JENNIFER R. RIFE,
14 Respondent.
15
COMES NOW the respondent Jennifer R. Rife, through her undersigned attorney and in
16
17 consideration of the sum of $500.00 the receipt of which is hereby acknowledged, does hereby
18 satisfy in full the amount ordered by this court to be paid to the respondent, including interest and
19
costs, by order entered in the above entitled cause number on the 23'd day of February, 2006.
20
DA TED THIS 17th day of March, 2006.
21
22
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25
26
27
28
29
30
SATISFACTION OF ORDERED AMOUNT
Dyer & Primont
503 Twelfth Ave. f
Seattle, WA 98102
ORIGlt·~AL (206) 343-1528

STATE OF WASHINGTON )
)ss.
COUNTY OF KING )
1 certify that I know or have satisfactory evidence that Jan M. Dyer is the person who
appeared before me, and said person acknowledged that she signed this instrument, on oath stated
that she was authorized to execute the instrument and acknowledged it to be her free and voluntary
act for the uses and purposes mentioned in the instrument.
Given under my hand and official seal this 17TH day of March 2006.
~- p
At: Seattle
·:· ...
SATISFACTION OF ORDERED AMOUNT

Dyer & Primont
503 Twelfth Ave. f
Seattle, WA 98102
ORIGl~~AL
(206) 343-1528
FILED
06 MAY 3o Pri r2: 26
rAM L. DANIE.LS.
COUNTY CLERK
.SNOHOMISH CO.WASH •
.,
.

In re: ) os-- -s- a~7S"'f>- I Z,(5
'A,~ J..r~.......i ~-~ ) No. 05 3 ooat4 8

Petitioner, )
vs. ) CERTIFICATE OF COMPLETION
)
J -<,..., ..... -f'.c.r e_.\='._ . Respondent, OF PARENTING SEMINAR
THIS CERTIFIES THAT
Jennifer R Rife
HAS COMPLETED:
FOR THE KIDS' SAKE: A PARENTING SEMINAR.
Location: Lynnwood, Washington
«J'(L:_k/k!
Divorce Lifeline
Seminar Staff
ORIGINAL
~ ...
3 -· ..,
4
6

Petitioner,
Respondent. (MTSC)
12
I. MOTION
13
18 entered on November 1, 2005 in this matter.
20 Does not apply.
Granting sanctions for contempt, including a forfeiture for each day the contempt of court
22
any other relief, including reasonable attorney fees and costs and make up residential time,
23
24
Imprisonment is sought as a sanction.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CA USE RE CONTEMPT (MTSC) - Page I Everett WA 98201
WPF DR 05.0100 (912000)-RCW 26.09./60 425 259-4147 FAX 259 7081
.:-
..
1 1.4 OTHER:
3 This motion is based upon the declaration whic
4 Dated: July 21, 2006

CARL J. GAUL WSBA#
5 Attorney-for Andrew S
6
II. DECLARATION
7
8 Failure to comply with the parenting plan as follows: By denying residential time on
July 15, 17, and 19, 2006.
9
This order was violated in the following manner:
10
11 Under the exiSting order of November 1, 2005, I am entitled to residential time three times
per week as determined by the GAL. The GAL has established the times as being Mondays
12 and Wednesdays from 4:30-6:30 p.m., and Saturdays from 11:00 a.m. to 5:00 p.m.
13 Under the temporary parenting arrangement we have a "delivering parent" rule: Jennifer Rife
is responsible to deliver our daughter to me at my residence at the commencement of my
14 residential time, then I am responsible to deliver our daughter to her at the commencement
of her residential time. Jennifer never comes to my home, instead she has a member of her
15 family handle the delivery for her. I have never been told where Jennifer resides and she has
me deliver to her parents' home. The delivery is made to other family members (her mother
16 carol Holland, her father Steve Holland, her sister Lisa Brunsman, her brother-in-law Michael
Brunsman) as Jennifer is generally not visible.
17
On July 6, 2006 my lawyer received a fax from opposing counsel that he would appear on
18 July 7, 2006 in ex parte department to request an immediate order which would either
require my visitation with my daughter to be professionally supervised or be suspended
19 altogether.
20 Commissioner Stewart heard argument. During the argument Mr. Primont mentioned the
unlawful harassment order obtained by my mother. Commissioner Stewart denied immediate
21 relief and he denied the requested order to show cause, leaving the existing residential time
arrangement in place without change. I left the courthouse while a handwritten order was
22 being prepared. An order was signed by Commissioner Stewart.
23 Mr. Primont told my lawyer in the presence of the GAL that the next day's visit (Saturday, July
8, 2006) would not occur. Ms. Llewellyn volunteered to handle the exchange of the child
24 herself. Both Jennifer and her sister Lisa had declined her offer.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CAUSE RE CONTEMPT (MTSC) - Page 2 Everett WA 9820 I
WPF DR 05.0100 (912000) - RCW 26.09.160 425 259-4147 FAA 259 7081
,,.
1 Lauren was delivered to my home on July 10 and July 12 by carol Holland, Jennifer's mother.
I am informed through counsel that carol Holland declines to be involved in future transfers,
2 but my wife and her attorney have declined to respond to communications about visitation
from my attorney and the GAL.
3
Jennifer Rife simply refuses to obey the court's order. She came to court with a request and
4 the court denied that request. Then she granted herself the relief the court had just denied.
5 My lawyer's letter of July 10, 2006 invited Mr. Primont and his client to schedule make up
time to compensate for the time lost on July 8, 2006. No response has been received to that
6 invitation. Instead, my estranged wife has simply refused visitation again.
7
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
a true and correct.
9
Signed at Everett WA
10
11 Andrew Scott Rife
12
13
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15
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19
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21
22
23
24
25
CARLJ.GAUL
26 Attorney at law
27 1604 Hewitt Ave.
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 7081
2006 AUG IS PH 3: I6
1
'/-\M L. DANIELS
1
2 COUNTY CLERK
SNOHOMISH CO. WASH.
3
7
9
In re:
11 and
NOTICE OF UNAVAILABILITY OF COUNSEL
Respondent.
13
14 0: THE CLERK OF THE COURT

AND TO: Andrew Scott Rife
15 AND TO: Jan Dyer, attorney for Jennifer Rae Rife
AND TO: Bridget Llewellyn, G.A.L.
16
PLEASE TAKE NOTICE that earl J. Gaul, attorney for Andrew Scott Rife, will be
17 unavailable from september7 through September 12, 2006, inclusive. It is requested
that motions, depositions and other court hearings not be scheduled to occur
18 during the time of my absence, and that motions and other hearings be scheduled
so that there is sufficient time to prepare for them following the end of the
19 absence. There is no other attorney available with~fficient f tnJal knowledge of
this case to respond to any substantive requesr;o?reli du nJ/ny absence.
20
21
Dated: August 14, 2006 (A/ /
CARL J. GAUL W · # 8341
f
Attorney for w Scott Rife
22
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 98201
NOTICE OF UNAVAILABILITY OF COUNSEL R ~I G1f\1A1 _ 425 259-4147 FAX 259 7081
12
comes now Andrew Rife, Petitioner above named, and moves this court to
13 enter an Order granting the relief requested in Part I below:
Andrew Rife moves this court to enter an Order which enforces the
15 settlement agreement reached on August 7, 2006 and enters Findings of Fact and
conclusions of Law, Decree of Dissolution of Marriage, Parenting Plan, Order of Child
15 support and requires Respondent Jennifer Rae Rife to sign a Quitclaim Deed to clear
title to husband's separate property.
17
Andrew Rife also seeks an award of attorney fees against Respondent and her
18 attorney for the delay and the cost incurred.
19 II. statement of crounds

The parties entered into an agreement to settle this highly contentious case.
20 suitable documents have been forwarded to wife's attorney. Those documents
have not been returned properly endorsed for entry. Letters inquiring concerning
21 the delay have not been answered. Mr. Rife needs the court's assistance to resolve
this matter.
22
Ill. statement of Issues
23 SHOULD A SETTLEMENT AGREEMENT BE ENFORCED BY THE COURTS?
24 SHOULD MR. RIFE BE COMPENSATED FOR DELAY AND ADDED EXPENSE OCCASIONED
BY THE INTRANSIGENCE OF THE WIFE AND HER ATTORNEY?
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
OR IGJ/\iA L Everett WA 98201
425 259-4147 FAX 259 7081
~-----------

The declaration of Andrew Rife submitted herewith.
2
v. Legal Authority
3 CR 2A
Chapman vs. Perera, 41 wn. App. 444, 704 P
4
5
10
11
12
13
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21
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25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
.
•• • 1 r
2006 OCT 19 PH 2: 41+

1
Pt,~I L. DA~HELS
2
3
IlllllllllllllIlllllllllllllllllllllllllllllllllllllllllllll
CL 11587488
COUNTY CLERK
SNOHOi·llSH CO. WASH.

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. as 3 027SS 1
and
10 DECLARATION OF ANDREW RIFE IN
Jennifer Rae Rife SUPPORT OF MOTION TO ENFORCE
11 1--~~~~~~~~~-'-~~~L-~~~~~~~~~~~~~
Respondent. SETILEMENT AGREEMENT
12
1, ANDREW RIFE, declare under penalty of perjury of the laws of the state of
15 I am the petitioner in this matter. I make this declaration to support my

motion to enforce the settlement agreement in this matter. A set of Findings
l6 of Fact and Conclusions of Law and Decree of Dissolution of Marriage has been
received and agreed upon. My wife and her attorney have not returned a
17 Parenting Plan, Order of Child Support with worksheets, a Quitclaim Deed or
the Excise Tax Declaration.
18
2. BACKCROUND
19
This divorce has been highly contentious. Because a settlement agreement
20 was reached, 1 am not detailing all the allegations made. From the time the
case was filed until August 7, 2006 there was no reason to expect the case to
21 settle. Rather, the case appeared to be headed for a week long trial.
22 Ms. over scheduled my deposition for August 7, 2006 at her office. My
attorney and 1arrived on schedule. Guardian ad Litem Bridget Llewellyn and
23 her assistant Judy over attended also. At the time the deposition was to
begin, Ms. Llewellyn stated that this case should settle and that we should talk
24 about it. My attorney had sent a letter to her outlining ideas for settlement.
Ms. Llewellyn shared her copy of it. Ms. over's partner, Michael Primontjoined
25 the group and participated in discussions.
26
CARL J. GAUL
Attorney at Law
'fJ J
;·I\\
27
DECLARATION OF ANDREW RIFE IN SUPPORT
OF MOTION TO ENFORCE SETTLEMENT AGREEMENT
0 RI G'/N JI L .
1604 Hewitt Ave.
Everett WA 98201
\
Page 1 Ii 425 259-4147 FAX 259 7081
L
1 settlement discussions continued for the balance of the morning. The first
issue addressed was parenting plan. It had always been the most contentious
2 issue, and we needed to resolve it to be able to resolve the other issues in the
divorce. Discussions focused on trying to identify the concerns of each
3 participant and attempting to find methods of accommodating each other's
concerns. The effort was successful. With the parenting plan resolved, there
4 was little further area for controversy. we settled upon the remaining issues.
we agreed to "guidelines" child support without specifying a dollar amount,
5 and we agreed that my wife would sign a quitclaim deed to assure that title
to my separate property house is not clouded. I agreed to pay $18,500 to Ms.
6 over as my contribution to my wife's fees. Ms. over left the group for a few
minutes in order to call her client, who was not present during these
7 discussions. Ms. over reported that Jennifer Rife agreed to all the terms of
the agreement, and we had a deal. The notes Ms. over had been writing were
8 signed and initialed, copies distributed, and the deal was done.
9 There were a few housekeeping details. My attorney was to produce the
Findings of Fact and conclusions of Law, Decree of Dissolution of Marriage,
10 Quitclaim Deed and Excise Tax Declaration. Ms. Dyer was to prepare the
Parenting Plan and the Order of Child Support. To save the cost of getting Ms.
11 over from Seattle, my attorney and I agreed to present formal proof.
12 Ms. over received my lawyer's Findings of Fact and conclusions of Law and
Decree of Dissolution of Marriage. I provided a cashier's check payable to Ms.
13 over for $18,500 to my lawyer. He is still holding that check. Ms. over wrote
requesting two detail changes, which we agreed to. A revised set was sent to
14 her, which she has approved for entry.
15 When Ms. over's draft documents were received there were problems with
them. The largest problem was that Ms. over included among her documents
16 an order of protection from domestic violence, which had not been discussed
at all during the negotiations and it is not mentioned in the notes of the
17 settlement negotiations. Since it was outside the scope of the agreement, my
attorney objected to including a restraining order as a part of the final
18 documents 1• Additionally, in the Parenting Plan she had inserted an exchange
place which was a dangerous choice, Mccollum Park 2 • No specific exchange
19 place was included in our settlement, and the place she selected will soon be
a dark and unpopulated secluded place for the exchange. I was unwilling to
20 agree to that location. There is no present agreement concerning the
exchange place, but 1am hopeful that Ms. Llewellyn will help us establish an
21
22 1
My wife filed a DV action about the same time as the divorce was filed. That
23 action has now been dismissed.
2
24 Neither my wife nor I have any desire to go to the other's home, nor to have
the other at our respective homes. While we agree that the exchange place should not
25 be at either home, we have not been able to settle upon the middle ground for the
exchanges.
26
CARLJ.GAUL
Attorney at Law
DECLARATION OF ANDREW RIFE IN SUPPORT 1604 Hewitt Ave.
OF MOTION TO ENFORCE SETTLEMENT AGREEMENT Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
~-------------- - ---------------- - -----
1 acceptable place.
2 For child support we had Ms. over's draft Order of Child support erroneously
computed my Federal Income Tax at S/04 and did not consider my social
3 security substitute at all 3 • These omissions caused her calculation of support
to be about $120 more than the amount under the temporary order. Ms.
4 Dyer also did not include the special expense of supervision, which is over
$2600 per month.
5
our trial date was August 21, 2006. Because both sides believed that we had
6 a settlement, trial did not occur. The matter was continued for settlement
only. on August 21, 2006 Ms. Dyer wrote" ...Jenn is coming in and will sign the
7 Quit Claim Deed and Excise Tax Affidavit. I will provide you with a copy and
will forward the originals when I get the amended Decree and Findings."
8
The forms of Parenting Plan and Order of support Ms. Dyer provided were not
9 even endorsed by her for entry with the court.
10 Recent letters to her concerning the closing documents have not been
answered.
11
3. DOCUMENTS ATTACHED
12
1am submitting as attachments documents evidencing our agreements
13
1. Notes of settlement (3 pagesl
14 2. Letter August 17, 2006, Gaul to Dyer (erroneously dated July 27, 2006l
3. Letter August 21, 2006, Dyer to Gaul
15 4. Letter August 29, 2006 Gaul to Dyer
5. Letter, August 31, 2006 Gaul to Dyer
16 6. Letter, September 15, 2006 Gaul to Dyer
7. Letter, October 6, 2006 Gaul to Dyer
17
4. PROPOSED ORDERS
18
1 am submitting my proposed parenting plan and order of support. I remain
19 ready to pay the $18,500. My estranged Wife should also be required to
deliver an executed Quitclaim Deed and Excise Tax Declaration.
20
21
22
on October 17, 2006
23
24 3
1work for the PUD. As a governmental agency it has opted out of the
25 social Security System. Accordingly, I contribute to both PERS 2 and a 401K plan.
26
CARLJ.GAUL
Attorney at Law
DECLARATION OF ANDREW RIFE IN SUPPORT 1604 Hewitt Ave.
OF MOTION TO ENFORCE SITTLEMENT AGREEMENT Everett WA 98201
Page 3 425 259-4147 FAX 259 7081
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s~ CARLJ. GAUL AttomeyatLaw 425 lSJl-.U.47 WC '" 25Sl·7011
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Admitted t.o practice in W'f1S.hington, Oregon and California
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(A .j August 4, 2006 Fax only to 252 8016
1'-' ~ ~)l0j,ridget
s
Llewellyn
Guardian ad Litem
MATTER:
No.
Rife Dissolution
os 3 02755 1
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~ 3114 Oakes Ave.
"" Everett WA 98201
~Dear Ms. Llewellyn
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~. fa mil\' wi~ cc:;, ccs will provide the ordinary progress reports. Req1:1irement of ees
<f diSCOiltinued U~eA tfste fil 3t eeAta6t freffl ]ftfl 9)'9F Qr any member of Jpnojfer's extended
aS v ~ f<1111il 1 : ;itl'l CES. GAL to have unlimited contact with CCS for any purpose .
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m GAL's recol'ITT11c11EJatio11 e11e Sfi'86ify 1:tiat eqoioalelit / slltlllar courses to 'be
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'o ~ "'l abu~ive '1se of ~opfljct b)' ieClJ:!ifer.
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CARLJ. GAUL Attorney at Law 42' 2!i9-4147 fax425 239-7081
1604 Hewitt Avenue
Everett WA 9820 I
July 27, 2006

503 Twelfth Ave. East RE: Settlement
Seattle WA 98102
Dear Ms. Dyer
At the time set for deposition of Mr. Rife we reached an oral settlement. I agreed to
prepare the Findings of Fact and Conclusions of Law, Decree of Dissolution of Marriage,
Quitclaim Deed and Excise Tax Declaration. Those documents are enclosed. You agreed to
prepare the parenting plan and Child Support Order. I enclose a copy of Mr. Rife's
7/31/2006 paystub to assist in drafting the support order. I trust that the documents are
forthcoming. Mr. Rife and I agreed to appear for formal proof to save you and Mrs. Rife the
inconvenience and expense of appearing for trial.
It has taken both of us more time than we probably expected to draft documents and
trial is set for next Monday. In Snohomish County we can readily obtain a continuance of
a couple of weeks for settlement only, which might be convenient in this case. Let me know.
Lastly, my client hopes to be able to pay the $18,500 in a single lump sum at or
before the entry of decree. For that reason there is no mention of attorney fees in these
documents. Should he not be able to obtain so much money by the time of entry, of course
the judgment will be added.
Yours truly
CARLJ. GAUL
OG/s
cc: Andrew Rife

Bridget Llewellyn
L
- - - - -------
OYER & PR/MONT

503 Twelfth Avenue E;i5t ·.
Se<ittle, W<ishington 98102
J;in Dyer, Attorney Amy Pasco. Poralegal

Mich;iel Primont. Attorney Geot-gia Ross, L~gal Assistal1t
August 21, 2006
Carl Gaul Sent via facsimile

302 Bank of America Bldg. Original to follow by legal messenger
1604 Hewitt Avenue
Everett, Washington 9820.J
Dear Mr. Gaul:

I have reviewed your proposed documents and letter and have a couple of needed changes.
understood from o~r phone conversation that Andy did not want a judgment entered for the attorney
fees and planned to pay them prior to the decree being entered. I told you I have _no problem with
that. I did not expect to see documents that do not eve_n mention payment of any fees. I expect a
reference to them under attorney fees as that is what we actually agreed to, I have no objection to a
reference. that they have already been paid (if in fact they have), or that they will be paid by a date
certain. I have no objection to having no judgment in the decree but I do want them mentioned. By
the same token, Jenn gets the barbeque and that needs to be referenced in the decree as well.
With those two changes we will be ready to sign the decree and findings. Jenn is coming in
today and will sign the Quit Claim Deed and Excise Tax Affidavit. I will provide you witll a copy
and will forward the originals when I get the amended Decree and Findings.
I have the parenting plan drafted and am working on the order of child support. Hopefully it
will be ready to go out to you tomorrow. ·
Best regards,
. Dyer
Cc: Jenn Rife
206/343-1528 206/343-7781 fX www.dyetptimont.com

--------- - - -
CARLJ.GAUL Attorney at Law 425 259-4147 fax425 259.7011
1604 Hewitt Avenue
Everett WA 9820 I
August 29, 2006

503 Twelfth Ave. East RE: Settlement
Seattle WA 98102
Dear Ms. Dyer
I have reviewed your proposed edits to the Findings of Fact and Conclusions of Law
and Decree of Dissolution of Marriage. Your suggestions have been incorporated.
I have in my office Mr. Rife's cashier's check payable to you alone in the amount of
$18,500. As usual, I am authorized to forward the check as soon as I have the complete set
of closing documents in hand.
I expect to respond concerning the parenting plan and the child support order you
drafted tomorrow. We will have some differences, but I do not expect them to be
insurmountable.
I noticed discussion of an order of protection from domestic violence in your materials

as you discussed in your letter. I will not respond to the substance of it. On the procedure,
at the time set for Mr. Rife's deposition we settled the divorce. There was no reference to the
collateral DV restraining order by anyone during those discussions. Neither is there any
reference to it in the CR 2A agreement. We have settled the divorce. An attempt by either
of us to incorporate an additional concession from the other concerning the collateral action
is simply outside the agreement. Let's just get the divorce finalized. Then, if we need to do
something more with a 26.50 action, we can either come to an agreement or obtain rulings
from the court.
Yours truly
CARLJ.GAUL
CJG/s
cc: Andrew Rife

Bridget Llewellyn ·
1
CARLJ. GAUL A ttomey at law 42.'! 2.'!9-4147 fax42!12.'!9·70Sl
1604 Hewitt Avenue
EverettWA9820l
September lS, 2006 Fax only to 206 343 7781

503 Twelfth Ave. East RE: Closing Documents
Seattle WA 98102
Dear Ms. Dyer

I received a call from your assistant Amy today inquiring about closing documents.
I have reviewed the form of parenting plan you provided, and I have some detail
changes which should not hold up settlement. I have more substantial difficulty with the
proposed child support order and worksheets. Mr. Rife's employer does not participate in
the Social Security system, so no FICA is noted on his paystub and no deduction made in the
worksheets you provided. However, the PUD does participate in an alternative system, the
details of which I am still acquiring. Whatever it is, the Social Security substitute should be
considered in the worksheets.
Additionally, the worksheets you provided do not recognize the cost of supervision
of visitation. That cost does need to be considered in arriving at the guidelines child support
amount. While we did agree to "guidelines" child support, we did not anticipate the need
to define what "guidelines" child support might be. I do not think this is a topic that needs
to become a source of controversy, merely of some reasoning and negotiation.
I expect to forward Mr. Rife's proposals concerning parenting plan and child support
at the beginning of the week.
Yours truly
To Avoid Delay
CARL J. GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
L
CARLJ.GAUL Attorney at Law 42.5 259-4147 fu:4J.j 259-7081
1604 Hewitt Avenue
Everett WA 98201
September 21, 2006 Fax only to 206 343 7781

503 Twelfth Ave. East RE: Closing Documents
Seattle WA 98102
Dear Ms. Dyer
It seems we have some differences of opinion on the guidelines child support

amounts.
Initially, I attempted to verify the computation of Mrs. Rife's income. I revisited the
child support worksheets you provided. I do not find the $700 amount listed for income tax
to be credible. I used my Support Cale Circular E calculation for Single 2. Self employment
tax is not included in the worksheets you submitted, so I simply doubled the FICA amount.
I have no reason to believe that Mrs. Rife contributes to any pension plan, so I have not
included that deduction.
Concerning Mr. Rife's income, at long last I have been able to connect with the right
person at the PUD to explain Mr. Rife's paystub. Partly it says what I expected, partly not.
You can verify what I am saying in this letter by contacting Dana at 425 783 8735.
Mr. Rife's filing status (Single/ 04) is erroneous. He should be withholding at Single
1. He is currently changing the withholding status. The worksheets I submit are based upon
correct withholding.
Working from Mr. Rife's 7/31/06 paystub, I learned that the Flex Reduction relates
to a smorgasbord of benefits. In Dana's list there were both deductible and nondeductible
items. I believe Mr. Rife's Flex selections are all nondeductible for child support purposes.
I learned that the PERS2 deduction is mandatory, Mr. Rife's contrary assertion in response
to your interrogatories was erroneous. The PERS2 deduction is included at the full amount
as a deduction because of its mandatory nature. Mr. Rife's 40 lK deduction is included at
$167.00 as it is voluntary. The total of the PERS2 and 401K is reflected in the Pension Plan
Payments line item.
If one completely disregards the supervision costs Mr. Rife is paying, guidelines
support is a modest increase from $544 to $562. Mr. Rife authorized me to offer to settle
support at $562, upon the condition that so long as he is incurring supervision costs there
will be no liability for items normally found on lines 8 and 9 of the worksheets beyond the
medical insurance cost already there. Once the supervision is discontinued, the lines 8 and
9 factors should be treated in the ordinary manner.
If Mrs. Rife wants to include lines 8 and 9 factors, Mr. Rife will reciprocate. Mr. Rife
is incurring special child rearing expenses for supervision of his residential time. He pays
Mr. Layton $110 per hour for two hours per week, and he pays Judy $40 per hour. Of late
he has been getting the Layton time, and two hour visits twice per week owing in part to Ms.
•
Jan Dyer
September 21, 2006
Page 2
Dyer's scheduling difficulties. Mr. Rife is entitled to twelve hours per week. The supervision
doubtless is intended to benefit the child. The supervision cost works out to a monthly
figure as follows:
Recent Recent Agreement Agreement

Supervisor Rate Hours Cost Hours Cost
Layton $ 110.00 2 $ 220.00 2 $ 220.00
Dyer $ 40.00 4 $ 160.00 10 $ 400.00
Weekly
Subtotal $ 380.00 $ 620.00
Monthly
Total $ 1,645.40 $ 2,684.60
Mr. Rife's child support obligation works out to be $25.00 per month if his supervision
cost is more than $1618 per month.
Under my computation, if the supervision cost is disregarded entirely, support is

$562.52. I think a court is likely consider the cost of supervision in some manner, either as
an expense or as a deviation factor. It may not quite meet the requirement of being "Costs
anticipated to be incurred by the parents in compliance with court-ordered reunification
efforts under chapter 13.34 RCW or under a voluntary placement agreement with an agency
supervising the child" but it may be close enough to move a court's conscience. Either way,
I do think that it will be considered if a court must decide it.
Mr. Rife's solution is to set support at • per month. A form of order and
worksheets is faxed with this letter.
I am also faxing a copy of Mr. Rife's proposed parenting plan.
Yours truly

To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife

Bridget Llewellyn
CARLJ.GAUL Attorney at Lalv 423 259-4147 fu:425 259·7081
1604 Hewitt Avenue
Everett WA 98201
October 6, 2006 Fax only to 206 343 7781

503 Twelfth Ave. East RE: Trial Date
Seattle WA 98102
Dear Ms. Dyer

Please return to me the Findings of Fact and Conclusions of Law, Decree of
Dissolution of Marriage, Parenting Plan, Order of Child Support, Quitclaim Deed and
Excise Tax Declaration which I have forwarded to you by next Friday, October 13, 2006.
Upon receipt of the properly endorsed documents I will forward to you Mr. Rife's
cashier's check for $18,500 and Mr. Rife and I will present formal proof to resolve this
case.
If the closing documents are not received, I will simply return Mr. Rife's check to
him so the funds can be benefitting him and will request a new trial date.
Please understand that Mr. Rife is not attempting to avoid his agreement to settle
the case. If we have settled, we should finalize the divorce. If we have not settled, the
case should resume its progress but should not be left in limbo.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
1
1 r--1L'D
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2 flfi HOV -3 Ml IO: 19
3 •'H•I L. DAi~!EL'
. COUNTY CLERF:
SNOHOMISH CC. VI.\ SH.
6
7
9
10
11
Petitioner,
12 and DECLARATION IN RESPONSE TO
MOTION FOR PRESENTATION
Respondent.
14
15
I am the attorney of record for Jennifer Rife, the Respondent above. The Petitioner has
16
filed a motion for presentation in what I believe is also a motion to enforce our CR2a agreement.
17
Attached to this declaration you will find our proposed parenting plan, order of child support and
18
child support worksheet. You will also find Mr. Gaul's proposed Decree and Findings, which I
19 have previously signed.
20 This was a very long and litigious case and frankly we did not expect it to settle. There is
21 a history of domestic violence and the father has continued to be in denial about this issue right
22 up to the end. The settlement came about at Mr. Rife's deposition, which I was taking in
23 preparation for trial. As can be seen from our written settlement document, attached as Exhibit
24 A and incorporated by this reference, we did not conduct formal settlement negotiations. We
25 tried hard to take advantage of the sudden willingness to settle and hammer out the agreements
26 necessary to get this matter done and behind us. That was not to be the case.
27 The agreement was I would draft the parenting plan and child support order and Mr. Gaul
28 would draft the Decree and Findings. I did and sent my proposals to him on August 28, 2006.
29 We have had a series ofletters back and forth. As a result of those letters and information I have t/!J
30 made modifications to the order of support and parenting plan. But, I feel that I have gone as far J
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
\\~
Page I
1\fNl91HO
1 as I can go in acqmescmg to their demands without watering down the prov1s1ons of the
2 parenting plan. It seems most of the difference has to do with simple difference in language. We
3 all know what is meant and we all know it can be said a variety of ways.· To continue to write
4 back and forth because they disagree with the use of a certain phrase or word is a waste of
5 attorney fees at some juncture. It seems we have gone as far as we can go and we need the court
6 to decide which parenting plan and order of child support to sign.
7 There is no basis for any deviation in child support for Mr. Rife. His own long history of
8 domestic violence, including multiple arrests with Ms. Rife as his victim, as well as the fact that
9 he continued to deny this history and contest custody of this child right up to the end has resulted
10 in a GAL recommendation that he continue to have supervised visitation. Had he openly and
11 honestly engaged in treatment in the beginning when he was arrested and first ordered into
12 treatment (May 2005) he would have been done by now and supervision would have likely
13 ceased for him. Instead he is still in Phase One of his treatment program at his fourth treatment
14 agency. The cost involved in supervised visitation should not be a basis for any deviation.
15 Mr. Rife has provided only two pay stubs for all of 2006 and both are attached. I have
16 calculated his income by using his year to date income and adding back in the pre tax items that
17 are denoted on his paystub with an asterisk then dividing that by 7, since his pay was through
18 July 31 ". Jenn's income so far in 2006 is far below what she made in 2005 and is far below
19
imputed income. For purposes of settlement I have left her income as it was in the prior order of
child support which is something we apparently agree on.
20
The GAL has filed her report and it is in the file. This parenting plan is based on her
21
report and our settlement negotiations. The GAL was present during these negotiations. Our
22
proposed parenting plan represents a fair and accurate recitation of our agreements and should be
23
adopted by the court.
24
25
foregoing is true and correct. Signed this 2"d_ day of November 2006 in Seattle, Washington.
26
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 2
ORIGINAL
From: earl 425 259 7081 To: bridge! Hewellyn Date: 814/2006 Time: 5:36:50 PM Page 1 of 1
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{ 't)
6
~_p~ridget
~
Llewellyn
Guardian ad Litem
MATTER:
No.
Rife Dissolution
05 3 02755 1
,,.. 3114 Oakes Ave. RE: Compliance Reports
~ :. Everett WA 98201 ~ ,. .9 ,
!- f·? Dear Ms. Llewellyn »"'~ v-i~ v-c.t"-~''-'j. ·
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Try this: <"'{ ,1.,- ' - ' x:of · b .\ ~
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Tues & Th, 3 hours, Sat 8 _hours, unsupervised when coITTpleted pi'lase 1 at CCS, 01 sooner. r- 1
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~ f
diseo11tint1ed upoA ti'le fif3t eoAt:aGt tfem Jan Dyer er any member of Jennjfe(s extended
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"t '12..<X> ~~\=?er-<..~'-
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~ ooe ca11 list the spec1nc courses Q'ofCr.
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:> ~ ~Overnight weekends commence upon cG~ple~ien ef pi'lase 2 at:CCS. :kmially Satur8a¥ 5:00
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2'. ~ PCU te Sctnday 5.00 p.111. r:ilus Tues &Tu tiooe contim1es. After G A'lOntlis;·Fliday at 5 to
f l ~ ,, Sunday at 7. pll!s WeGlResday even10~.
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J . B""J Either: Ne lirniti11g Factor. Oi:.IW l\i:iGlrsw's limiti 0 g faGtGir pl11s 'f:le1"ieal de13eAdeAey and
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10/12/2006 01:48 FAX 425 252 8016 BRIDGET LLEWELLYN
.. '
141002
Bridget Llewellyn
Guardian ad Utem
3114 Oakes Avenue
Everett WA 98201
Ph # 425-339-238
VIA FAX
October l 2, 2006
JAN DYER
Seatde, WA 98102
CARL GAUL
1604 Hewitt A venue
"'~"--If;erett, WA 98201
Re: RIFE
Dear Jan and Carl:

Enough is enough. I have tried to allow this couple to have some say in where they should do
the exchange for visitation but it appears that they are unable to agree, and that is ridiculous.
As the Case Manager I am making the decision.
They will exchange the child at Q.F.C. on I 12th in Silver Lake. It is a busy public spot and so
there should be no problems.
They will start this exchange this coming weekend and can firm plans with )udy.
Sincerely,
~~~t-L Bridget Llewellyn

Guardian ad Litem
BL:jld
,,
/
Cc: file
l;ll. I llJ. UL!-' t. l:i.:1.H.. I\ Nl.IMIJI H 0%%
PUD 012773 601662 305 0000822~5.3 1 Earnings Statement
i>uo
+ •I'"·""·'" 1a1 -·••
PUBLIC UTILITY DISTRICT NO.
OF SNOHOMISH COUNTY
2320 CALIFORNIA STREET
Period Ending:
Pay Date:
07/31/2006
08/0i/2006
EVEREJT. WA 98201
T~xabh? Mti.rilal Ste?u~: Srng!Q ANDREWS RIFE

Exernptioris/Allowa1ices:
Federal: 4
Stat": No St.!l.tQ lncon1e Tax 2416 STH ST
EVERETT, WA 98201
Social Security Number: XXX·XX-8901

Earnings r:at9 hour~ thie · period year to date · Other Benefits and
Regular 2458.33 77.50 2,458.33 33,896.98 Information this period tot01I to dat~
Paid Time Off 10.50 PTO Bal 542.19
Overlime 1;373.02 Sick Bal 152.88
Yend Pio Pout <1,659 99
39,929.99
Deductions ~5i.S:lu"'lory
Federal Income Tax '201 . 13 3,908.84

Medicare Tax -33.78 551.01
Othgr
Child Support -272.00 4, 13<1.00
Flex Reduction -126. 64* 1 ,929.60
Pern2 -Slat -86.04• 871 .32
s PF -2.43 38.36
401 K Plan -22<1.37• 3 ,712. 91
Credit Union 22 3,661.96
• Excluded from federal taxable wages
Your federal taxable wages this period are

$2,019.28
co .. FILE DEPT. CLOCK NUMBER 1OO"l
PUO 0-:2773" 601652 305 00008.219<:6 1 Earnings Statement
PUBUC UTILITY DISTRICT NO. Period Eliding: 05(31/2.005
PUD OFSNOHOMISHCOUNTY Pay Oa:e: 05/07/2005
EVERETT, WA 98201
Te.xabJe Me.ri:1:1l S~:Us: Single ANDRE\.V S RIFE

Exitmp:ior.:-;/Allowanees;
Fede:cl: 4
s:ate: No s:11te Income Tu: 2416 STH ST·
EVERETT, WA 98~01
- Social Security Nutn:ler: ~·>QC·!901
Earnincs - ""' rah~·:- .hOUrS ·-.: ·:thi? ·period yetir to dato Other Benefits and
Regular :.g,"4_58.33 24,053.66 Information thi!; poriod" to:al lo d~I
Holiday .' ,,.

.
? T 0 Bal 53.1 .:;.
overtime ~-~ 1,373.02 Sick Sal 145.'2
Yend Pto ?out 4,559.99
Gfb1fSJl11iJ.Y?&!!LZifit.~/!§flt~2-Y..4Ss;ti3] 30,095.67
.. ·;.
Deductions Statuto"?y: ·
Federal.· J:icor:ie. Tax: ··~20s.~ ~.09i;74
M~dita~e..;~T~· . -33'.78 . 415.89
ot!ier
Child- SU;:iport·. -272.od 3,045.00
Rex ·f\edlidon · -12ir.54•' 1 ,4i5.04
Pers.2- s:at ·-55.31* 583.11
s· p· F· -'2.75 28.. 55
.401!(,·P!an ~· -227 .,µ.• 2,s69.-s5·
cre~i! UniOn 22 2,535.00
Ex°e;::lud~d. tiorit, iederaf iaxa~le Wages ·
Your f~er.il tiixzbre ~g!?S this period zre '

$2,646.94°
..
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· . -~ .. ·.·.. i :··;'."" ... ...•.
. ~-· .·" .
. . .
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'·.
,_
iGD6 NOV -6 Pi/ t.,: 03

.... L. t.lAiliELS
COUNTY CLERK
..:NOHOMISH CO. \'/ASH.
\\11\11\ 1111\\ Ill \Ill\ 1111\ 1\11111111 \l\\l l\l\l ll\11 Ill\ Ill\
CL 11598660

Andrew Rife,
No. 05-3-02755-1
Plainti ffIP eti tioner
vs. COVERSHEET
Jennifer Rife,
ATTACHED HERETO IS:
Notice of Trial Setting
S:\FORl\1S\Cover Sheet.DOC - 1
..
TO:
Carl Joseph Gaul

Attorney at Law
Suite 302
1604 Hewitt Avenue
Everett, WA 98201
Date: November 3, 2006
f2l!!
and
RE: Cause No.: 05-3-02755-1
Andrew Rife
vs
Jennifer Rife
This is to notify you that the above case has been set for Non-Jury trial on April 4, 2007
Court Administrator
f2l!! f2l!!
IMPORTANT NOTICE: Your attention is directed to SCLR 40(d) and CR 41(e) which read as follows:
SCLR 40(d) TRIALS - CONFIRMATION
separately confirm, no sooner than 12 noon of the first court day of the week (3/19/2007] and no later
than 12 noon of the last court day of the week (3/23/2007] two weeks prior to the trial date, in such
written form as approved by the court. The court may strike the trial date and may impose sanctions
and/or terms against the parties or counsel for failure to so confirm.
CR41(E)
AS THE FORM FOR CERTIFICATE OF TRIAL CONFIRMATION
TO:
Janis Marie Dyer

Attorney at Law
503 - 12th Avenue East
Seattle, WA 98102

and
RE: Cause No.: 05-3-02755-1
Andrew Rife
vs
Jennifer Rife
Court Administrator
l'9]Jl l'9]Jl
separately confirm, no sooner than 12 noon of the first court day of the week (3/19/2007) and no later
than 12 noon of the last court day of the week (3/23/2007] two weeks prior to the trial date, in such
CR41(E)
..
TO:
Bridget Llewellyn
Guardian ad Litem
3416 Broadway, Suite 1
Everett, WA 98201

f2l!l
and
RE: Cause No.: 05-3-02755-1
Andrew Rife
VS
Jennifer Rife
Court Administrator
f2l!l !'oM
separately confirm, no sooner than 12 noon of the first court day of the week [3/19/2007] and no later
than 12 noon of the last court day of the week [3/23/2007] two weeks prior to the trial date, in such
CR 41(E)
UTILIZE THE NEXT PAGE OF THIS LEITER OR A COPY THEREOF
AS THE FORM FOR CERTIFICATE OF TRIAL CONFIRMATION
- ~ ,.
1
2 I I/11/lll llllll Ill lllll lllll lllll lllll lllll l l l lllll llll llll 7.006 NOV - 7 P/-1 3: 25
CL11954378
3
. . . ' L. GA~:tELS
4 ' coyh TY CLERK
Superior Court of Washington ,,OHD: : 1s1J CO. \'/ASH.
6
7
ANDREWS. RlFE, No. 05-3-02755-1
8
Petitioner,
9 and Parenting Plan
Final Order (PP)
10
JENNIFER R. RIFE,
11 Res ondent
12
This parenting plan is the final parenting plan, reached by agreement between the parties, signed by the
13 court pursuant to a decree of dissolution.
14 It Is Ordered, Adjudged and Decreed:

15
I. General Information
16
This parenting plan applies to the following children:
17
18
19 Lauren Emily Rife . 2
20
II. Basis for Restrictions
21
22 2.1 Parental Conduct (RCW 26.09.191 (1 ), (2))
23 The father's residential time with the child shall be limited or restrained completely, and
24 mutual decision-making and designation of a dispute resolution process other than court
action shall not be required, because this parent has engaged in the conduct which
25 follows:
26 A history of acts of domestic violence as defined in RCW 26.50.010(1) or an assault
27 which causes grievous bodily harm or the fear of such harm.
~8 2.2 Other Factors (RCW 26.09.191(3))

~9
Does not apply.
3;0 Parenting Plan (PPP, PPT, PP) - Page 1
WPF DR 01. 0400 (612006) - RCW 26. 09. 181; . 187; . 194 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1
Ill. Residential Schedule
2
3 3.1 Schedule for Children Under School Age
4 Prior to enrollment in school, the child shall reside with the mother, except for the following
5 days and times when the child will reside with or be with the other parent:
6 On Tuesday and Thursdays for three (3) hours and on Saturdays for eight (8) hours each week.
All visits to be supervised by Don Layton or a person designated by Mr. Layton and otherwise
7 agreed to by the Case Manager. All visitations are subject to section 3.10 below.
8
3.2 School Schedule
9
Reserved pending Case Manager Recommendation.
10
11 3.3 Schedule for Winter Vacation
12 Reserved pending Case Manager Recommendation.
13
3.4 Schedule for Other School Breaks
14
16 3.5 Summer Schedule

17 Reserved pending Case Manager Recommendation
18
3.6 Vacation With Parents
19
20 Reserved pending Case Manager Review.
21 3.7 Schedule for Holidays

22
Prior to school, the residential schedule for the child for the holidays listed below is as follows:
23
24
-
Christmas Eve Every
Christmas Day Every
25
-
Memorial Day Evelf'~
26 July 4th Even Odd
27
Labor Day ~ ..... ~
Thanksgiving Day Even Odd
28
For purposes of this parenting plan, a holiday shall begin at 11 :00 a.m. and end at 7:00 p.m. All
29 holiday time is subject to section 3 .10. If Holiday time is missed due to the visitation
supervisor's schedule a make up visit may be arranged.
30
Parenting Plan (PPP, PPT, PP) - Page 2
WPF DR 01.0400 (612006) - RCW 26.09.181; .187; .194 Dycr & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1
3.8 Schedule for Special Occasions
2
3 The residential schedule for the child for the following special occasions (for example, birthdays)
is as follows:
4 With Mother With Father
Mother's Day Every
5
Father's Day Every
6 Mother's Birthday Every
Father's Birthday Every
.7
8 For purposes of this parenting plan, a special occasion shall begin at 11 :00 a.m. and end at 7:00 {l,
p.m. All special occasion time is subject to section 3.10. If Special Occasion time is missed due ~
9 to the visitation supervisor's schedule a make up visit may be arranged -' _ f'S:'\
~. s-.....~\ -.....:........... .\=l~,-1. ..() bp-<.<- O<....S.::.•~ .i;;., l-.~~ .. ..:,, ~-r~0"?-.. ~ ~
10
3.9 Priorities Under the Residential Schedule '<>· ..._ ..........~ ':.> ~"" ~ ... J,
( \:.-.'r•·~ ~r .. ~«) oli- 1-.~r ,..,M'..~"'o·
~·. ""''"'°"
11
Does not apply.
12
13 3.10 Restrictions
14 The father's residential time with the child shall be limited because there are limiting factors in
paragraphs 2.1 and 2.2. The following restrictions shall apply when the children spend time with
15
this parent:
16
I. Father shall enroll in and successfully complete a state certified domestic violence
17 perpetrators treatment program. He is currently enrolled at Catholic Community Services,
(CCS). The father shall sign appropriate releases so that the treatment program can
18
communicate with the mother and provide monthly progress reports to the Case Manager,
19 counsel for mother and counsel for father.
2. The father shall enroll in and successfully complete the DV Dads program and the
20 Respectful Parenting program at Family Services in Seattle.
21 3. Visitations will be supervised by Don Layton or his designee. Don Layton is appointed as a
Therapeutic Visitation Supervisor to work directly with the father. Mr . Layton may expand
22 or contract the visit times or durations, however, there shall be no expansion of time until the
father has successfully completed Phase I of his treatment program.
23 4. Bridgett Llewellen is appointed as Case Manager (she has been the appointed GAL during
24 the case). She shall communicate with all parties and professionals working with the father
and make written recommendations on future expanded access for the father.
25 5. At such time as the Case Manager determines that the father has progressed and visitation
should be expanded, she will write a report and make recommendations. The parties may
26
agree to those recommendations or modify those recommendations by their agreement.
27 Absent written agreement there shall be no change expect by court order. The Case Manager
shall remain appointed until such time as all of the father's requirements under this section
28 are completed. She may, from time to time, write interim reports and recommendations. She <,f;,f(_
29 shall write a final report with recommendations at such time as the father has completed_ all 1
of the requirements set out above.\,\..,. ~-~J.. ,..._ ~~ r.Jc ..,\.._.._\\ ~ ...\..,~ "-- (' ,.(\.
30 . <.~""-<.-<_.. af C\-J?a cl.-..-~ 1"' ~ ~"«'-~ 1,.,,_ c...r.J) f-<.<•.,.-~_J .... ~....-'.l - \ . )
Parentmg Plan (PPP, PPT, PP) - age 3 ..,,,,_ ,..,....,,_ ,___I..<.. U
WPF DR 01. 0400 (612006) - RCW 26. 09. 181; . 187; . 194 ~ . Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
..
1
3.11 Transportation Arrangements
2
3 Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Support and should not be included here.
4
Transportation arrangements for the child, between parents shall be as follows: Exchanges shall
5 b so long as they are
supervised. The Case Manager shall make recommendations for transportation arrangements at r"
6 such time as visitation is no longer supervised. ~
~ "l?.AC c"C.u:i.,....,....1~"'-.1.';'-~ ot' Ct...,..c.. ~"-"ts'-""· (.\........ \...c..:l (... . . ~., .. ~ ~
7
3.12 Designation of Custodian \ ... ,.,'::.-1<-.,., ...,.. '!>'"'"' ....... ~~ \"h" ~'"'"""' ~)
8
9 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 child solely for purposes of all other
10 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.
11
12 3.13 Other: N/A
13 3.14 Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child

14
15
If the person with whom the child resides a majority of the time plans to move, that person shall
16 give notice to every person entitled to court ordered time with the child.
17 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
18 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
19
notice must contain the information required in RCW 26.09.440. See also form DRPSCU
20 07.0500, (Notice oflntended Relocation of A Child).
21 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
22 may ask for modification under RCW 26.09.260.
23 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.
24
If information is protected under a court order or the address confidentiality program, it may be
25 withheld from the notice.
26 A relocating person may ask the court to waive any notice requirements that may put the health
27 and safety of a person or a child at risk.
28
If no objection is filed within 30 days after service of the notice of intended relocation, the
29 relocation will be permitted and the proposed revised residential schedule may be
30 confirmed.
WPF DR 01.0400 (612006) - RCW 26.09.181; .187; .194 Dyer & Primont
503 Twelfth Ave. £
Seattle, WA 98102
(206) 343-1528
.. .
1 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.
2
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07 .0700,
3 (Objection to Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
4 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
5
delayed notice provisions apply; or (b) a court order allows the move.
6
If the objecting person schedules a hearing for a date within 15 days of timely service of the
·7 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 .
.8
9 IV. Decision Making
10 4.1 Day-to-Day Decisions
11
Each parent shall make decisions regarding the day-to-day care and control of each child while
12 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
13 children.
14
4.2 Major Decisions
15
16
17 Education decisions mother*
Non-emergency health care mother
18 Religious upbringing mother
19
*The issue of whether the child will attend public or Catholic schools shall be reviewed by the
?O parents when she reaches the age of four years old, if there is a disagreement.
21 4.3 Restrictions in Decision Making

22
Sole decision making shall be ordered to the mother for the following reasons:
23
A limitation on the other parent's decision making authority is mandated by RCW
24
26.09.191 (See paragraph 2.1).
25
V, Dispute Resolution
26
27 Disputes between the parties, other than child support disputes, shall be submitted to the Volunteers of
America Dispute Resolution Service in Everett Washington.
28
The cost of this process shall be allocated between the parties as follows based on each party's
29 proportional share of income from line 6 of the child support worksheets or as determined in the
30 dispute resolution process.
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
- - - ------------------~
. ' ..
1
The dispute resolution process shall be commenced by notifying the other party by written
2 request.
3
4
5 (b) Unless an emergency exists, the parents shall use the designated process to resolve
6 disputes relating to implementation of the plan, except those related to financial support.
(c) A written record shall be prepared of any agreement reached in counseling or mediation
7 and of each arbitration ·award and shall be provided to each party.
(d) If the court finds that a parent has used or frustrated the dispute resolution process
8
without good reason, the court shall award attorneys' fees and financial sanctions to the
9 other parent.
(e) The parties have the right ofreview from the dispute resolution process to the superior
10 court.
11
VI. Other Provisions
12
There are no other provisions.
13
14 VII. Declaration for Proposed Parenting Plan
15
Does not apply.
16
VIII. Order by the Court
17
18 It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an
order of this court.
19
WARNING: Violation ofresidential provisions of this order with actual knowledge of its terms is
20 punishable by contempt of court and may be a criminal offense under RCW 9A.40.060(2) or
22 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.
23
24 If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
25
26
27
28
29
30
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
4 ' ... ..
1
2
3 Presented by: Approved for entry:
4
5
6
7
8
,: ~~.!
11 ~
(0 C.,
t.w-e..t...lfN ~·It· "-"'- L.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Parenting Plan (PPP, PPT, PP) · Page 7
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
•, I •,
·.~·n
.., . ' 1'-
- ...
1
r.=D
~'' '
'uU6 HOV - 7 PM 3: 25
2 · . -· uMllELS
:::0:.i;ny CLERK
3 ' :olio: ·;s~ 1 CO. \'/ASH.
4
111111111111111111111111111111111111111111111111111111111111
5 CL 11954380
6
COUNTY OF SNOHOMISH
Petitioner,
lO and FINDINGS OF FACT AND
CONCLUSIONS OF LAW
Jennifer Rae Rife (FNFCLl
14 he findings are based on:

15 agreement.
16
II. FINDINGS OF FACT
17 Upon the basis of the court record, the court FINDS:
18 RESIDENCY OF PETITIONER.
2.1
19
The petitioner
20 is a resident of the state of Washington.
21 2.2 NOTICE TO THE RESPONDENT.
22 The respondent
23 appeared, responded or joined in the petition.
24 2.3 BASIS OF PERSONAL JURISDICTION OVER THE RESPONDENT.
25 The facts below establish personal jurisdiction over the respondent.
26 The respondent is presently residing in Washington.
27
CARLJ.GAUL
ORIGINAL Attorney at Law

Everett WA 9820 I
FNDNG5 DF FACT AND CDNCL DF LA w !FNFCLI. Page 1
WPF DR 04.0300 !9120011·CR52; RCW 26.09.030; .070 !31 425-259-4147 Fax 425-259-7081
L
The parties lived in Washington during their marriage and the petitioner
continues to reside, or be a member of the armed forces stationed, in
this state.
The parties may have conceived a child while within Washington.
DATE AND PLACE OF MARRIAGE.
The parties were married on April 10, 2004 at Snohomish County WA.
STATUS OF THE PARTIES.
Husband and wife separated on October 2, 2005.
STATUS OF THE MARRIAGE.
The marriage is irretrievably broken and at least 90 days have elapsed since the
date the petition was filed and since the date the summons was served or
the respondent joined.
SEPARATION CONTRACT OR PRENUPTIAL AGREEMENT.
There is no written separation contract or prenuptial agreement.
COMMUNITY PROPERTY.
The parties do not have real or personal community property.
SEPARATE PROPERTY.
The husband has the following real or personal separate property:
Item Value
Real property commonly known as 2416 Fifth Street, $300,000
Everett WA
All 401K, Retirement, and Investment accounts in his undetermined
name only
Household furniture and furnishings undetermined
The wife has the following real or personal separate property:

Item Value
Business commonly known as Mobile Notary undetermined
All 401K, Retirement and Investment accounts in her name undetermined
only
ORIGINAL CARLJ.GAUL
Attorney at Law
FNDNGS DF FACT AND CDNCL DF LAW IFNFCL) - Page2
Everett WA 9820 I
WPF DR 04.030019120011·CR52; RCW 26.09.030; .070131 425-259-4147 Fax 425-259-7081
L
..
Household furniture and furnishings, including gas barbeque undetermined

2
3
4 2.10 COMMUNilY LIABILITIES.
5 There are no known community liabilities.
6 SEPARATE LIABILITIES.
2.11
7
8 The husband has incurred the following separate liabilities:
9 Creditor Amount
10 Indebtedness secured by his separate property real 200,000
estate
11
12
The wife has incurred the following separate liabilities:
13 None Known
14 2.12 MAINTENANCE.
15 Maintenance was not requested.
16 2.13 CONTINUING RESTRAINING ORDER.
17 Does not apply.
18 2.14 FEES AND COSTS.
19 There is no award of fees or costs because: based upon the agreement of the
parties to these closing documents.
20
2.15 PREGNANCY.
21
The wife is not pregnant.
22
2.16 DEPENDENT CHILDREN.
23
The children listed below are dependent upon either or both spouses.
24
25
26
27
ORIGINAL CARLJ.GAUL
Attorney at law
Everett WA 98201
FNDNGS DF FACT AND CDNCL DF LAW IFNFCLJ. Page3
WPF DR 04.03001912001! - CR 52; RCW 26.09.030; .07013! 425-259-4147 Fax 425-259-7081
L
--------------- --- --
Name of Mother's Father's

of Child Age Name Name
2
Lauren Emily Rife 1 Jennifer Rae Rife Andrew Scott Rife
3
4 2.17 JURISDICTION OVER THE CHILDREN.
5 This court has jurisdiction over the children for the reasons set forth below.
This state is the home state of the children because:
6 the children lived in Washington with a parent or a person acting as a
parent for at least six consecutive months immediately preceding the
7 commencement of this proceeding.
8
2.18 PARENTING PLAN.
9 The parenting plan signed by the court on l--.\.,.\f. -=!- • 'uci L [Date] is
10 approved and incorporated as part of these findings.
This parenting plan is the result of an agreement of the parties.
11
2.19 CHILD SUPPORT.
12
There are children in need of support and child support should be set pursuant to
13 the Washington State Child Support Schedule. The Order of Child Support
signed by tile court on N.." . ~ '2.%1.... [Date] and the
14 child support worksheet, which hase~n approved by the court, are
incorporated by reference in these findings.
15
2.20 OTHER.
16
17
18
III. CONCLUSIONS OF LAW
19
20 he court makes the following conclusions of law from the foregoing findings of fact:
21 3.1 JURISDICTION.
22 The court has jurisdiction to enter a decree in this matter.
23
3.2 GRANTING OF A DECREE.
24
The parties should be granted a decree.
25
3.3 DISPOSmON.
26
27
ORIGINAL CARLJ.GAUL
Altorney at law
Everett WA 9820 I
F'NDNGS DF' F'ACTAND CDNCL DF' LAW IF'NF'CLJ. Page4
WPF DI/ 04.0300 1912001! ·Cl/ 52; I/CW 26.09.030; .070 13! 425-259-4147 Fax 425-259-7081
·... : '
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 the maintenance of either spouse, make provision for the disposition
of property and liabilities of the parties make provision for the allocation of the
children as federal tax exemptions, make provision for any necessary continuing
restraining orders, and make provision for the change of name of any par_ty. The
distribution of property and liabilities as set fortll in the decree is fair and
equitable.
CONTINUING RESTRAINING ORDER.
Does not apply.
ATTORNEY'S FEES AND COSTS.
Mr. Rife has paid $18,500 attorney fees to Jan Dyer prior to entry of these
documents.
OTHER.
15 Dated:
16
Copy Received:
17
18
19
20
21
22
23
24
25
26
27
ORIGINAL CARLJ.GAUL
Attorney at Law
Everett WA 9820 I
FNDNGS DF FACT AND CDNCL DF LA w fFNFCLJ - Page 5
WPF DI? 04.030019120011·Cl?52; l?CW 26.09.030; .070131 425-259-4147 Fax 425-259-7081
?006 ~lOV - 7 Pil 3: 25
SUPERIOR COURT OF
WASHINGTON

(PETITIONER) JUDGE: RONALD L. CASTLEBERRY
AND REPORTER: MICHAEL JAY
CLERK: E. MCCARTNEY/B.
JENNIFER RAE RIFE MACDOUGALL
(RESPONDENT) DATE: 11-7-06 @ 9:30 A.M.
THIS MATTER CAME ON FOR: MOTION TO ENFORCE CR 2A SETTLEMENT/FORMAL PROOF

CONTINUED/HEARING DATE SET AND CONTINUANCE CODE:
ACTION:
PETITIONER APPEARED: YES, SWORN AND TESTIFIED COUNSEL: CARL GAUL
RESPONDENT APPEARED: YES, SWORN AND TESTIFIED COUNSEL: JAN DYER
GUARDIAN AD LITEM APPEARED: YES, BRIDGET LLEWELLYN
DOCUMENTS FILED:
ORDERS ENTERED: PARENTING PLAN FINAL ORDER; ORDER OF CHILD SUPPORT FINAL ORDER;
FINDINGS OF FACT AND CONCLUSIONS OF LAW; DECREE OF DISSOLUTION
PETITIONER'S MOTION TO ENFORCE CR 2A SETTLEMENT: NOT RULED UPON.
10:50 AFTER DISCUSSION, THE PARTIES HAVE REACHED SETTLEMENT AND WILL PROCEED
TO FORMAL PROOF.
THE COURT FINDS THE MARRIAGE IS IRRETRIEVABLY BROKEN; APPROVES THE
DISTRIBUTION OF ASSETS AND LIABILITIES; FINDS THE PARENTING PLAN IS IN THE
CHILD'S BEST INTERESTS; AND APPROVES THE ORDER OF SUPPORT AGREED TO BY THE
PARTIES.

FHed in C~CFI CJ~rt
//-7 20~
PAM L. DANIELS
2
3
4
111111111111111111111111111111111111111111111111111111111111
5 CL 11954377
6
9
Andrew Scott Rife NO. 05 3 027551
10 Petitioner,
and DECREE OF DISSOlUTION IDCDl
11
Jennifer ~e Rife
12 Res ondent. Clerk's action required
13
14 I. JUDGMENT/ORDER SUMMARIES
15
1.1 RESTRAINING ORDER SUMMARY:
16
Does not apply.
17
1.2 REAL PROPERTY JUDGMENT SUMMARY:
18
19 Does not apply.
20 1.3 MONEY JUDGMENT SUMMARY:

21 Does not apply.
22
END OF SUMMARIES
23
II. BASIS
24
Findings of Fact and Conclusions of Law have been entered in this case.
..,,
~
..,,
25
26
~ 27
~\
ORIGINAL CARL]. GAUL
Attorney at Law
DE:CRE:E: IDCDI (DCLSP) IDC/NMGI- Page I
Everett WA 98201
WPF DR 04.0400 (912001) - RCW 26.09.030; .040; .070 (3) 425-259-4147 Fax 425-259-7081
•
III. DECREE
2 IT IS DECREED that:
3
3.1 STATUS OF THE MARRIAGE.
4
The marriage of the parties is dissolved.
5
3.2 PROPERTY TO BE AWARDED THE HUSBAND.
6
7 The husband is awarded the following real or personal separate property:
Item Value
8
Real property commonly known as 2416 Fifth Street, $300,000
9 Everett WA
10 All 401K, Retirement, and Investment accounts in his undetermined
name only
11
Household furniture and furnishings undetermined
12
Any automobiles titled in his name undetermined
13
Other: The wife shall execute a quitclaim deed transferring to the husband
14 any interest she may have had in the real property awarded to
husband
15
16
3.3 PROPERTY TO BE AWARDED TO THE WIFE.
17
The wife is awarded as her separate property the following property
18
19 The wife has the following real or personal separate property:
Item Value
20
Business commonly known as Mobile Notary undetermined
21
All 401K, Retirement and Investment accounts in her name undetermined
22 only
23 Household furniture and furnishings, including gas barbeque undetermined
24 Any automobiles titled in her name undetermined
25
26
27
ORIGINAL CARLJ.GAUL
Attorney at Law
DECREE IDCDJ IDCLSPI IDC/NMGJ- Page 2
Everett WA 98201
WPF DR 04.0400 (912001) - RCW 26.09.030; .040; .070 (3) 425-259-4147 Fax 425-259-7081
......____ _ _ _ __
Other:
LIABILlTIES TO BE PAID BY THE HUSBAND.
All liabilities secured by the real property awarded to him.
Unless otherwise provided herein, the husband shall pay all liabilities incurred by him
since the date of separation.
LIABILlTIES TO BE PAID BY THE WIFE.
All liabilities associated with the Mobile Notary business.
Unless otherwise provided herein, the wife shall pay all liabilities incurred by her
since the date of separation.
HOLD HARMLESS PROVISION.
Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable
attorney's fees and costs incurred in defending against any attempts to
collect an obligation of the other party.
SPOUSAL MAINTENANCE.
Does not apply.
Does not apply.
JURISDICTION OVER THE CHILDREN.
The court has jurisdiction over the children as set forth in the Findings of Fact and
Conclusions of Law.
PARENTING PLAN.
The parties shall comply with the Parenting Plan signed by the court on
~·a,, 3,1 ~ll~ [Date]. The Parenting Plan signed by
the court 1s approve and incorporated as part of this decree.
CARLJ.GAUL
ORIGINAL Attorney at Law
DECREE fDCDI (DC LS Pl (DCINMGI- Page 3 Everett WA 98201
WPF DR 04.0400 (912001) - RCW 26.09.030; .040; .070 (3) 425-259-4147 Fax 425-259-7081
... l
3.11 CHILD SUPPORT.

2
Child support shall be paid in accordance with the order of child SUIJDOrt signed by
3 the court on kll>u 1e
.< e,,o L.
incorporated as part of this ecree.
[Date]. This order is
4
5 3.12 ATTORNEY'S FEES, OTHER PROFESSIONAL FEES AND COSTS.
6 Does not apply.

7
3.13 NAME CHANGES.
8
/ Does not apply. ,_...,.. . l c::.
9 \f The wife's name is hereby changed to ...Ja..,w,\f.:t£ \t.c.,e.. iz.<..Jo..ir~
10 OTHER.
3.14
11
12
13
14
Dated:
15
16 Copy Received:
17
18
19
I
# 8341 JAN D R WSBA# 20
Scott Rife Attar ey for Jennifer
20 'I
21
22
23
24
25
26
27
ORIGINAL CARLl.GAUL
Attorney at Law
DE:CRE:E: IDCDJ IDCLSPJ IDCINMGJ- Page 4
Everett WA 98201
WPF DR 04.0400 (912001) - RCW 26.09.030; .040; .070 (3) 425·259-4147 Fax 425·259-7081
.------..---------------------------
!l:'H
• I ~, ,.,. E Df
·r.:11
2006 NOV 21 AM 9 ,29

PAM L. OAHIEL&M L. ANlE!..S
COUNTY CLERKNOHOMISHC NTYCL~RK
SNOHOMISH co. w1115mc10 CLE: Oi COURT

CASE NO. 05-3-02755-1
JENNIFER RIFE, CALENDAR NOTE: (NTC)

Petitioner
FAMILY LAW MOTIONS
vs.
than twelve (12) calendar days preceding
motion must be filed five (5) court days before the
ANDREW RIFE, hearing. Replies to responses must be filed three (3)
Respondent court days before the hearing.
FAMILY LAW/DOMESTIC CALENDAR Date Requested (mm/dd/yyyy): 1210612006

Daily at 9:00 a.m.
Department B or C as assigned. Nature of Hearing: Protection Order
(Confirm at (425 388-3587)
CHILD SUPPORT MODIFICATIONS Date Requested (mm/dd/yyyy): _ _

Fridays at 9:30 a.m. Department D Nature of Hearing: _ _
(Confirm at (425 388-3587)

Wednesday at 12:30 p.m. only Date Requested (mm/dd/yyyy): _ _
Department C
Matters set before a Court Commissioner will be assigned later to a particular department. The assignment will be
Court Commissioner here:
------------------------------
S :\Wcb Fonns\Clerks Office\word\Domfamil yLa wCalcndarNote.doc RRU:07/0l/2003

ORIGINAL I of2
.------.----------------------------------------------- -
,,
I
SCLCR 7(b)(2)(H).
FOR MATTERS N~~g,?-l!Y..1,.COUNSEL:

I hereby certify that I ;'Ct'a copy of this document
to the attorneys/parties listed below, postage p<epaid
en the:
Date (mm/dd/yyyy): 11/21/2006

~----------
CarI Gaul WSBA# 20355
---------------~
1604 Hewitt A venue #302
Everett, WA 9820 I Counsel for: (CHECK ONE)
X Petitioner/Plaintiff

Failure to do so may result in your hearing not
FAMILY LAW/DOMESTIC MOTIONS: Most are heard on a Court Commissioner's calendar. The exceptions

3000 Rockefeller Ave M/S 605 3000 Rockefeller Ave
S:\Wcb Forms\Clerks Office\word\DomfamilyLawCalcndarNote.doc RRU:07/011200J 2 of2

RI FE DISSOLUTION 11-7-06
09,25,02 1 EVERETT, WASHINGTON, TUESDAY, NOVEMBER 7, 2006

e 09,25,02 2 MORNING SESSION
09,26,02 3 - -ooOoo- -
10,50,26 4
10,50,26 5 THE COURT: We're going to go on the record in

10,52,53 6 the matter of Rife and Rife. Let's have the parties step
10,52,56 7 forward, as well as the guardian ad litem. For purposes
10,53,00 8 of the record, this is cause No. 05-3-02755-1.
10,53,09 9 It came on this morning's civil motions calendar
10,53,14 10 for a motion to enforce a CR 2(a) settlement agreement.
10,53,22 11 The court denied that motion, making a determination that
10,53,27 12 in fact the parties had not reached a full and final
10,53,32 13 accord on all of the issues, but did invite the parties
9 10,53,38 14 to continue to negotiate to see if in fact a complete and
10,53,44 15 final settlement could be done.
10,53,47 16 It's my understanding that the parties in fact
10,53,51 17 have done that and are now willing to enter into the
io,53,59 18 final decree of dissolution, findings of fact,
io,54,07 19 conclusions of law, parenting plan and order of support
10,54,09 20 that have been tendered to the court and are now before
10,54,13 21 the court indicating that in fact they have reached such
10:54:17 22 an accord.
10,54,18 23 With that, what I'm going to do is swear both of
10,54,24 24 the parties in and we can take formal proof and anything
e 10,54,28 25 else that needs to be done. So let's have both parties
COLLOQUY
2
RIFE DISSOLUTION 11-7-06
1 raise your right hands.

e
10,54,31
10,54,34 2 (Parties sworn.)

10,54,41 3 THE COURT: Who's going to be doing the formal
10,54,45 4 proof?
10,54,45 5 MS. DYER: I win. Shall I ask both parties?
10,54,50 6 THE COURT: Why don't you just ask your client
10,54,53 7 and Mr. Gaul can ask his client.
10,54,53 8
10,54,53 9 EXAMINATION
10,54,56 10 BY MS. DYER:
10,54,56 11 Q. You're Jennifer Rife?
10,54,57 12 A. Yes.
e 10,54,59
10,55,00
13
14
Q. Were you married and are you married at this
moment to Andrew Rife?
10,55,02 15 A. Yes.
10,55,02 16 Q. And are you seeking to have this marriage
10,55,06 17 dissolved?
10,55,06 18 A. Yes.
10,55,07 19 Q. Is this marriage irretrievably broken?
10,55,oa 20 A. Yes.
10,55,oa 21 Q. Jennifer, has more than 90 days or three months
10,55,12 22 gone by since this petition for dissolution was filed?
10,55,14 23 A. No.
10,55,15 24 Q. Are you pregnant?
e 10,55,16 25 A. No.
JENNIFER RIFE - By Ms. Dyer

3
RI FE DISSOLUTION 11-7-06
1 Q. Are you in the military?

e
10,55,16
10,55,17 2 A. No.
10,55,17 3 Q. To your knowledge, is Andrew in the military?
10,55,20 4 A. No.
10,55,21 5 Q. Is it your belief that these documents equally and
10,55,24 6 fairly divide your -- the community assets of this
10,55,27 7 marriage?
10,55,27 8 A. Yes.
10,55,27 9 Q. And there is a child support order that is based
10,55,30 10 on the child support worksheets that are attached and
10,55,32 11 it's a fair and equitable child support apportionment?
10,55,36 12 A. Yes.
e 10,55,37
10,55,40
13
14
Q. And there is a parenting plan. You believe that
parenting plan is in the best interest of your child?
10,55,42 15 A. Yes.
10,55,42 16 MS. DYER: We have nothing further, Your Honor.
10,55,44 17 MR. GAUL: Andrew, if I asked you the same series
10,55,43 18 of questions, would you provide substantially identical
10,55,51 19 answers?
10:55:51 20 MR. RIFE: Yes.
10,55,52 21 THE COURT: All right. Ms. Llewellyn, you are
io,55,56 22 apparently the guardian ad litem and now you're going to
10,55,59 23 be designated as a case manager; is that right?
10,56,02 24 MS. LLEWELLYN: Yes, that's correct, Your Honor.
e 10,56,03 25 THE COURT: You've had a chance to be involved
JENNIFER RIFE - By Ms. Dyer

4
• 10,56,06 1 not only in terms of the investigation of the case, but

10,56,12 2 obviously in terms of the resolution of this case. Do
10,56,18 3 you believe that this parenting plan is in the best
10,56,23 4 interest of the child?
10,56,24 5 MS. LLEWELLYN: I do.
10,56,25 6 THE COURT: All right. I'm going to ask a couple
10,56,32 7 questions of both of the parties. It's going to be the
10,56,35 8 same question to both of the parties.
You understand by agreeing this morning to this,
10,56,46 10 this is a complete and final resolution of the division
10,56,51 11 of assets and liabilities?
MS. RIFE: Yes.
10,56,56 13 MR. RIFE: Yes, Your Honor.
10,56,57 14 THE COURT: You understand that you're not going
10,51,00 15 to be able to change your mind, you're not going to be
10,57,02 16 able to go out in the hallway and say, you know, I gave
10,57,07 17 away too much there, I should revisit this? You're not
10,57,10 18 going to be able to do that, do you understand that?
10,57,12 19 MS. RIFE: Yes, Your Honor.
10,57,14 20 MR. RIFE: Yes, Your Honor.
10,57,15 21 THE COURT: Likewise, in terms of the parenting
10,57,17 22 plan, there may be modifications of the parenting plan
10,57,21 23 that would be available to you if you meet certain
10,57,26 24 statutory threshold requirements, but you understand this
• 10,57,34 25 is the parenting plan that you're agreeing to and you
COLLOQUY
5
•
io,51,37 1 can't go out in the hallway and say let's change the
io,51,42 2 place of the pickup, you understand that?
10:57:46 3 MS. RIFE: Yes, Your Honor.
io,57,47 4 MR. RIFE: Yes, Your Honor.
io,57,49 5 THE COURT: And although probably both of you
io,57,55 6 have talked long and hard to your attorneys about this,
io,57,59 7 you're willing to accept this as the parenting plan?
io,59,04 8 MS. RIFE: Yes, Your Honor.
io,59,05 9 MR. RIFE: Yes, Your Honor.
io,50,06 10 THE COURT: A11 right. Very well . Given the
io,59,n 11 representations that have been made to this court, I'll
10:58:17 12 find that the marriage is irretrievably broken. I'll
• io,59,27
io,59,35
io,59,39
13
14
15
approve of the distribution of the assets and
liabilities. I'll find that the parenting plan is in the
best interest of the child and approve the same, and will
10,59,43 16 also approve of the order of support that has been agreed
10,59,47 17 to by the parties and I'll sign that.
10,59,59 18 You may have asked her this and I was looking at
10,59,01 19 the paperwork, she does not want her name changed?
10,59,05 20 MS. DYER: There is a name change in the decree,
10,59,01 21 Your Honor. It's already been inserted into the decree.
10,59,10 22 I did not ask.
10,59,n 23 THE COURT: What's the name change, just for the
10,59,12 24 record?
• 10,59,13 25 MS. DYER: To Le Sourd from Jennifer Rife.
COLLOQUY
6
Jennifer Le Sourd.
e
10,59,17 1
10,59,19 2 THE COURT: Given that, I will also sign the

10,59,25 3 decree of dissolution and that will conclude this matter.
10,59,29 4 If you want for convenience purposes, I can have my clerk
10,59,34 5 make a copy of all of these for you and you can take them
10,59,37 6 now if you want.
10,59,39 7 MS. DYER: That would be so helpful, Your Honor.
10,59,41 8 Thank you very much.
10,59,42 9 THE COURT: You're welcome.
10,59,44 10 MS. DYER: Thank you, Madam Clerk.
10,59,46 11 THE COURT: Now, let me give my word of advice to
12 both of the parents. Number one, I want to tell you both
e
10,59,49
10,59,55 13 that I recognize that there are differences between you

11,00,01 14 and there will continue to be differences between you. I
11, 00' 06 15 don't expect you to leave this courtroom and put all of
11'00,12 16 those differences aside.
11,00,16 17 You can leave this courtroom and you can be one
11,00,21 18 of these cases that comes back to me occasionally growing
11,00,29 19 from one volume to three volumes to ten volumes. I think
11,00,36 20 I had one the other day with 14 volumes. The parties
11,00,41 21 just continue to fight. They fight over every little
11,00,45 22 aspect of the case. The loser in that situation
11,00,55 23 oftentimes is the child. Obviously you need to engage in
11,01,os 24 terms of treatment and be totally committed to it,
9 11,01,14 25 otherwise, obviously the amount of time you get to spend
COLLOQUY
7
11,01,10 1 with your child is going to be severely limited.

• 11,01,21 2 You, on the other hand, have to recognize despite
11,01,20 3 whatever he may have done in terms of the domestic
11,01,33 4 violence area, he is the father of the child and will be.
11,01,40 5 If in fact he does the things that he says he's going to
11,01,44 6 do, I guess you have to kind of put your personal
11,01,51 7 animosity for the things he did to you aside and go along
11,01,57 8 with the agreement.
11,01,59 9 MS. RIFE: I wi 11 , Your Honor.
11,02,01 10 THE COURT: I emphasize this to you because I see
11:02:04 11 so oftentimes that people don't, either one spouse
11,02,12 12 doesn't go through with the treatment they're supposed
• 11,02,14 13 to. Even then if sometimes they do go through it, I see
11'02'18 14 the other spouse kind of hanging on to a lot of

11,02,21 15 resentment and anger, and I'm not saying it's not
11,02,26 16 justified. I'm just saying that's the way it is, and the
11,02,20 17 end result of that is just a continuous battle. As I
11 '02 '34 18 say, the loser in that is the child.
11,02,37 19 And I dare say eventually the loser of it is the
11,02,43 20 relationship the parent has with the child. At some
11,02,46 21 point the child is going to be old enough to make their
11,02,53 22 own decisions in terms of where things lie. I've also
11,03,00 23 said that, you know, you are forever more going to be
11,03,07 24 intertwined in some degree in the other person's life
• 1L03'11 25 because you have a child in common. You're going to have
COLLOQUY
8
. . ..
11,03,15 1 grand kids in common. You're going to go to college

• 11,03,1a 2 graduations and things of that nature. Hopefully those
11,03,22 3 can be things that both of you can attend without rancor
11,03,27 4 and animosity.
11,03,28 5 So congratulations on being able to work out
11,03,34 6 whatever the differences were this morning. I just hope
11,03,33 7 that you continue to do that in the future and I
11,03,40 8 appreciate the attorneys and the guardian ad litem for
11,03,42 9 helping them do this. It did save a lot of animosity, a
11,03,50 10 lot of attorney fees, a lot of cost. Hopefully you can
11,03,55 11 continue to do that in the future. All right.
11,03,57 12 MS. DYER: Thank you, Your Honor.
• 11,03,53
11:04:00
13
14
15
MR. GAUL: Thank you.
(Proceedings concluded.)
16
17
18
19
20
21
22
23
24
25
COLLOQUY
9
'·f,,
,/ "
,.,...._.tr,
,..-. """
. : ·' )
1
7n06 llOV 22 PM 3: 20
2
~~i1 l. DAlll[LS
SNOHg~1lJcCoLERK
3
4
ii Illlllll llllllCL11817568
Ill lllll lllll lllll lllll lllll lllll lllll llll llll ·WASH.
5 I
6
7
8 WASHINGTON
JENNIFER RIFE, Cause#: 05 3 02755 1
9
10 Declaration of Service of:

VS.
CALENAR NOTE, PETITION FOR ORDER FOR
ANDREW RIFE, PROTECTION DECLARATION OF PETITONER IN
11
Defendant/Respondent SUPPORT OF PROTECTION ORDER, EXHIBITS 1
THROUGH18
12
Hearing Date: Dec 6 2006
13
14
15 Declaration:
16 States and a resident of the State of Washington, over the age of eighteen, not an officer of a plaintiff
17 therein.
On the date and time of Nov 22 2006 7:42AM at the address of 2320 CALIFORNIA A VE EVERETT,
18 within the County of, State of WASHINGTON, the declarant duly served the above described documents
upon ANDREW RIFE by then and there personally delivering 1 true and correct copy(ies) thereof, by then
19 presenting to and leaving the same with ANDREW RIFE A White male approx. 30-35 years of age 5'10"-
6'0" in height weighing 160-180 lbs with brown hair.
20
No information was provided that indicates that the subjects served are members of the U.S. military.
21
22 and correct.
, 2006 at Everett, WA
23
24
25 Service Fee Total:$ 101.55
26
27
28
ABC Legal Services, Inc. Dyer, Jan

206 521-9000 ORIGINAL 503 12th Ave E.
i"i~~~liil
823 PROOF OF SERVICE Seattle, WA 98102
206 343-1528
Page I of I
---
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CL 11996546
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
11 Respondent.
12
I, Andrew Rife, declare under penalty of perjury of the laws of the State of
13 Washington, that the following is true and correct.
14 I. SUMMARY OF RESPONSE
15 This action should be dismissed. The present request for a restraining order is not
based on any recent facts. The substance of the present petition is to amend the decree
16 of dissolution of marriage entered by agreement on November 7, 2006. There is no basis
or relief from the agreed orders.
17
18 II. DECREE SHOULD BE ENFORCED
19 We settled this case on November 7, 2006 by entry of a decree of dissolution of
marriage.
20
This divorce was active from October 2005 until late summer 2006. There were
21 settlement discussions on August 7, 2006. At the time set for my deposition the GAL
announced that she thought the case should settle. Though I did not think a settlement
22 was possible, my attorney and I participated in discussions that appeared to be successful.
My attorney and I thought that we had reached an agreement to finalize the divorce. Jan
23 Dyer did not sign and return the closing documents submitted to her. So we filed a motion
to enforce the agreement.
24
The motion to enforce the apparent settlement was heard by Judge Castleberry.
25 Judge Castleberry orally denied the motion to enforce the attempted settlement agreement
26
CARLJ.GAUL
Attorney at Law
Page 1
DR/GfNAL 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1 because that the parties had not reached a full agreement on all issues. But he also
recognized that the differences between the two sides were not great. He encouraged both
2 sides to step out and attempt to resolve those outstanding issues. Judge Castleberry told
us that the motions calendar is not a trial, and consequently he would not decide any
3 contested issue, such as to determine the exact amount of guidelines child support. He
assured us that he would happily take formal proof and finalize the divorce if we did reach
4 a complete settlement.
5 We stepped out to negotiate. The attorneys and GAL Bridget Llewellyn were in a
conference room, going over their differences and finding solutions. The negotiations were
6 successful. Immediately after reaching our settlement and signing the documents, we
appeared again before Judge Castleberry. Judge Castleberry questioned both Jennifer
7 and me to be sure we understood what we were doing and that we each wanted to do it.
We both assured him that we understood, and that we desired to resolve our divorce with
8 the closing documents which were presented to him.
9 My former wife ignores the settlement reached on November 7, 2006. Jennifer's

present petition is simply an attempt to modify the agreement. I would not have agreed to
10 the specific Paragraph 3.4 (Continuing Restraining Order) states "Does not apply." Jennifer
states (p2/117) that "we had never given any indication that we did not want a full protection
11 order." But the decree she approved does not contain a protection order. Rather, she
should admit that neither she nor her attorney told Judge Castleberry that a protection
12 order might be desired.
13 Jennifer did request a domestic violence protection order in Snohomish County

Superior Court case 05-2-01268-2. The court did reissue the temporary order several
14 times. I always thought it was because there were factual or procedural defects making
a permanent order inappropriate. I think that Jennifer agreed there was no need for a
15 permanent order as she allowed the reissued order to expire and did nothing to reactivate
the case. It was dismissed by Judge Wynne on October 10, 2006. Jennifer did not seek
16 reconsideration. At the time she undertook no action at all to reactivate the case. And she
did nothing to include a continuing restraining order in the final documents on November
17 7, 2006.
18 Jennifer alleges no new facts pertaining to domestic violence involving me, involving
her or involving our daughter. Jennifer fails to state that she never even requested any
19 order requiring me to be involved in any domestic violence perpetrator's treatment program
until Commissioner Waggoner entered such an order at the end of July 2006 1. Throughout
20 the time this case was pending, Jennifer and her attorney complained to the superior court
commissioners and to the guardian ad !item that I was out of compliance with the
21 requirements of the Municipal Court even though the Municipal Court was satisfied with my
compliance with its orders.
22
23 Ill. RED HERRINGS
24
1
There was an order requiring me to be in domestic violence perpetrator's treatment in the
25 Everett Municipal Court. The Municipal Court has determined that I have complied with that requirement
and there is no requirement of any further treatment.
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
1
DV Perpetrator's Treatment. I have never denied my own domestic violence. I think
2 that Jennifer's complaint is based on my refusal to take all the blame for the breakdown of
our marriage. Her explosive temper and her alcoholism had a lot to do with it. For this she
3 claims I am blaming my victim. She misses the point deliberately.
4 Jennifer complains about my involvement in domestic violence perpetrator's

treatment. She and her attorney have complained a great deal that my programs and my
5 involvement and my progress do not satisfy them.
Here is the history of my enrollment in domestic violence perpetrators treatment
6 programs. Jennifer attempts falsely to claim I hop from program to program without
involving myself in them.
7
There were two incidents between Jennifer and me for which I was arrested. After
8 my first arrest I went to Davis & Co. briefly. The Everett Municipal Court's no-contact order
was terminated pursuant to a joint request from Jennifer and me. I moved home. Jennifer
9 and I went together to Summit Counseling for marriage therapy2 . I found that the Davis &
Co. program was not to my liking 3 • so I got court permission to change to private
10 counseling. I went to Summit Counseling, the same place Jennifer and I were already
going. I first learned that Summit was not state certified to do DV work when the Everett
11 Municipal Court issued a noncompliance order on September 22, 2005. Thereafter I went
to Charles Devore. I attended for 20 sessions with Charles Devore. Even though there
12 as no order concerning DV treatment in the superior court, the probation department told
me of numerous contacts from Jennifer and her lawyer trying to have me ordered to start
13 the program over again. They were communicating with GAL Bridget Llewellyn also, to the
same substance. Bridget Llewellyn recommended that I change treatment providers to
14 Dale Todd. I did so. I had to appear before the municipal court to explain why I had
changed providers. My then-wife appeared at that hearing. She proffered to the judge a
15 copy of a letter from Ms. Dyer to municipal prosecutor Teresa Cox. In that letter Ms. Dyer
argued that I should not get credit for the time I was with Charles Devore. See attached
16 Memo from Jan Dyer to Teresa Cox, May 11, 20064 • The court did not rule on her request.
Dale Todd became the recipient of ongoing communications about the sufficiency of my
17 prior treatment with Mr. De Vore. Against this background, I did seek a definitive ruling from
the Municipal Court. Dale Todd elected to recuse himself from my case because he could
18 see the same avalanche of difficulty about to beset him the same way it had beset the GAL
and the probation department.
19
The Municipal Court ruled that I should receive credit for the time with Charles
20
21 2
See attached September 29, 2005 letter from Steven M. Altabef. His letter is inconsistent with
ennifer's current claim that abuse was increasing during the summer of 2005. Her drinking was
22 escalating during that period.
3
23 I have since learned that the staff at Davis and Company is not licensed to provide DV
treatment. When the company was sold the licensure was not automatically transferred. If I had stayed
24 with Davis and Company I would have had to change programs when the licensing problem was
discovered.
25 4
The prosecution did not offer that letter to the court.
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 Devore. It has also determined that I have satisfied the domestic violence perpetrator's
treatment portion of the SOC.
2
Thereafter, I signed up with Catholic Community Services on a voluntary basis
3 because I thought I could use additional education on the subject of domestic violence. I
arranged this to satisfy the GAL before Commissioner Waggoner's ruling and before the
4 August 7, 2006 attempted settlement. My first regular weekly meeting was on August 12,
2006.
5
Catholic Community Services has declined to allow credit for the time I was with
6 Charles Devore, and also grants no credit for the time I was with Davis & Co., Summit
Counseling or Dale Todd. I think that is an unfair position, and I have expressed this to the
7 administration there. To my knowledge, this is the only source of Ms. Poier's comment that
I was "fighting" the program there.
8
Spat with Carol & Steve Holland. This is just an ugly incident telling more about the
9 depths of enmity than anything else. It certainly tells nothing about domestic violence.
10 Jennifer's parents were at court on November 7, 2006. When I arrived at court that
morning, GAL Bridget Llewellyn told me to ignore Carol Holland who was giving me dirty
11 looks. I told her I intended to ignore Carol Holland's presence.
12 After the negotiations were over, and Judge Castleberry had finalized the divorce,
my attorney and I were leaving court. As I stepped out of the court Jennifer's parents,
13 Steve and Carol Holland, were standing in the hallway. Carol made eye contact with me.
I responded to that eye contact by saying "See you, folks." Carol responded by hissing at
14 me that she hoped to never see me again. Since I am the father of her granddaughter, the
likelihood of that is slight. I turned back to her and gave her a piece of my mind. Steve,
15 who was standing behind Carol from where I was standing, yelled at me "Fuck you, Andy."
I responded to Steve that if he had something to say to me he could come talk to me any
16 time, and that he did not need to hide behind his wife when he says it. At that point my
lawyer came by and told me to come with him. My lawyer certainly never "grabbed" me as
17 Jennifer colorfully claims. And, I never assumed a fighting stance and I never made any
ighting gestures. My lawyer and I went to the law library. Carol Holland came into the
18 library and scowled at me as she made additional eye contact, but was silent.
19 Unlawful Harassment. My mother filed a petition seeking an order of protection from

unlawful harassment in the Snohomish County District Court, Everett Division. After a
20 hearing the case was dismissed. I believe the judge made a mistake in denying the
petition. Ms. Dyer represented Jennifer in that action. Ms. Dyer's request for attorney fees
21 was denied.
22 I filed a petition seeking an order of protection from unlawful harassment in the

Snohomish County District Court, Everett Division. I might not have filed it if Carol Holland
23 had answered honestly when asked why she had been at my home at midday. But it was
apparent that she was lying when asked to explain. At trial she had an apparently innocent
24 explanation (that she was involved in an appraisal of my home), though I do not believe that
as the only reason for her presence, and she never did explain why she lied to my lawyer
25 about her reasons for being there.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
~----- - -- -- ----- - - - - - -
1 Jennifer claims the judge made comments about the reasons why my mother and
I brought the cases. My recollection differs from Jennifer's. I do not remember him
2 impugning the reasons for bringing the cases, though it was obvious to everyone that there
as a highly contentious divorce case.
3
Child Support. I don't know where Jennifer is getting her legal advice on this
4 subject. After I read her declaration I looked at RCW 26.09.060 and found that her legal
position is wrong. The support due November 1, 2006 under the temporary order remained
5 due when the divorce was finalized. She claims I have "refused to pay child support for
November" as though I have any control over it. My child support is deducted from my
6 paychecks, just like everybody else's. I have no control over what may be deducted as this
is determined by orders from the Division of Child Support. Support has continued to be
7 deducted from my paychecks. I am attaching copies of the two paychecks for November,
check pay dates November 7, 2006 and November 22, 2006.
8
The support under the decree commences the first day of the first month following
9 entry of the decree. The date December 1, 2006 is interlineated by Ms. Dyer. If Jennifer
has a problem with the support, perhaps she should address that problem to Ms. Dyer or
10 to the Division of Child Support, but once it is deducted from my paycheck, my involvement
is concluded. My employer has done its part by making the deduction. Beyond that I am
11 not responsible.
12 Jennifer hyperbolizes: "He is not worried about Lauren and I having no money he
is just thinking about how he can get back at me." If she is on public assistance as she
13 claimed, she assigned her right to receive support to the state and she would lose only the
$50 pass through if I were to fail to pay. The entire statement has no truth: it is intended
14 only to inflame.
15
IV. DISQUALIFY MS. DYER
16
I have been aware that Jennifer signs declarations using vocabulary she would not
17 ordinarily use, and specifically saying things that are not true. For example, her recitations
of how terrible and violent I was become more exaggerated over time. Ms. Dyer has filed
18 as attachment 12 to Jennifer's declaration her own declaration concerning unlawful
harassment actions my mother and I had to file last summer.
19
Ms. Dyer has now conflated her roles as an advocate and now as a witness. The
20 court must now judge her personal credibility as well as the merits of the cause she
advocates. She should not be permitted to be both a witness and an advocate. She has
21 made herself a witness. She should no longer be allowed to be an advocate in this cause.
22
V. ATTORNEY FEES & COSTS
23
I have been wrongly required to defend this motion. It is brought in bad faith. I am
24 asking the court to impose a sufficient cost on both Jennifer and her attorney to
compensate me for the cost and also sufficient to discourage future similar misconduct.
25 Jennifer refers to "economic terrorism" when she makes her false claim concerning the
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 5 425 259-4147 FAX 259 7081
1 child support. I want the court to remember that she brings this baseless bad faith motion
as a form of litigation terrorism.
2
The bad faith is evident from a number of facts. For examples:
3
1. This action was filed even though contrary to the terms of the agreed
4 settlement of our divorce.
2. This action was served on me on Wednesday, the day before Thanksgiving,
5 making my response due by noon on the Tuesday following Thanksgiving,
which is the third business day following service. The timing bespeaks an
6 intent to shorten the time available for consultation with my attorney and a
desire to make less joyful the holiday.
7 3. Jennifer brought this action without any factual basis. She makes no
reference to any act of domestic violence occurring since the time the divorce
8 was filed. She brought this action without reference to any act of domestic
violence occurring since her prior DV case was dismissed by Judge Wynne
9 on October 10, 2006. She brought this action without reference to any act
of domestic violence occurring since the decree was entered on November
10 7, 2006.
4. Jennifer lies. She claims to be on public assistance and going to school, but
11 she still advertises herself on the internet for her mobile notary service. She
also lies when she claims I have refused to pay support and when she claims
12 to have not received any child support in November.
13 I will be charged about $2000.00 for about 9 hours of lawyer time in representation
on this post-decree matter. I am asking the court to grant judgment in the full amount
14 against Jennifer and also against her attorney. I have my doubts that I will ever be paid by
Jennifer. Imposing the cost against Ms. Dyer will help dissuade future similar misconduct.
15
Executed at Everett, Snohomish County Washington on November 27, 2006
16
17
18
~~
ADREWRI
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 6 425 259-4147 FAX 259 7081
SuMMi I Counseling "New Heights for Healthy Living"
September 29, 2005
To Whom It May Concern:
Re: Andrew and Jennifer Rife
My name is Steve Altabef; I am a Licensed Mental Health Counselor. I have been

working with Andrew and Jennifer Rife in a counseling setting since June 2, 2005. To
date .1 have seen them a total of seven times.
Mr. and Mrs. Rife have made considerable progress in their counseling. In June, when
they first came to my office, their marriage was rather unstable. Since that time they
• have corrected the problems which led to that instability and are now able to work out
conflicts without escalating into a dangerous situation.
If-you have any further questions-regarding Andrew and Jennifer, please feel free to call
me at 425-353-4428.
ully,
fo~ M- ~i
' Steven M. Altabef,
M iv, MA, LMHC
Licensed Mental Health Counselor
Iii\ i).\I, ""'l>i L"'t{C_
.
• 518 Pecks Drive PO Box 2738 Everett, Washington 98213-0738 Voice: (425)353-4428 Fax: (425) 438-0358 SumCoun@AOL.com
• )AN M. DYER
Attomey
206/543-1526
206/343-7791 (,,
MEMO
TO: Theresa Cox

FROM: Jan Dyer
DATE: Mayll, 2006
RE: Andy Rife review/revocation hearing
I understand that the court is having a hearing to look into

Mr. Rife 's treatment status. Since I have been the person most
closely observing his treatment status, from his victim's
perspective, I wanted to share some information with you.
• ftfr. Rife was initially ordered into treatment in May 2005. He

went to Davis and Company. The records we have from that
time make it clear that their assessment was that Mr. Rife had
a significant problem with domestic violence. No long after
their assessment came out Mr. Rife quit going to treatment, I
believe that was sometime in}i_NKH&i of 2005.
()fie.....
He was arrested again in October of2005, this time for
violating the no contact order. He was at the house and he
was the person that called the police trying to get Jen arrested.
The cops could tell he was lying and arrested him instead.
At about the same time this was filed as a divorce and we

started our process in the family law courts. When he hired
his family law attorney he was apparently directed to enroll in
•
• )AN M. DYER
Attorney
206/340-1529
206/543-7701 (x
treatment with Chuck De Vore, which he did. Mr. DeVore's

treatment does not comply with the WA C's and his state
·certification is currently under investigation. I have personal
experience with Mr. De Vore and his "treatment" progra1n. In
my opinion it is a useless program, at least for the stated
purpose. Unfortunately what I have seen is that the offending
parent actually gets worse while in treatment with Mr. De Vore.
That certainly seems to be the case with Mr. Rife as he is still
quite abusive and continues to blame his victim for everything.
Our family law case is all about him trying to prove what a
bad person she is to deflect this charge of domestic violence.
• The issues has been raised by Mr. Rife's attorney several tbnes
and much investigation has been done but Mr. Rife 's visitation
with his daughter is still supervised and not overnight.
So now our .GAL has insisted that Andy get into a program
that is compliant with the WAC and that operates in a group
therapy setting (as mandated by the WACs) versus individual
sessions (forbidden by the WACs but what Mr. De Vore does).
He has switched programs but now/ understand he wants
advanced standing because of all the time he has already been
in treatnient. I urge you to argue strongly against this. HE
SHOULD NOT GET CREDIT FOR SOMETHING HE HAS
NOT DONE. A 12 month DVprogram mandates that Phase I
be weekly group sessions. Andy has never done this and
should certainly not he given credit for it now. All he has done
it to try to avoid treatment. Davis and Co. tried to hold him
•
• )AN M. DYER
Attorney
;l06/343-1520
206/343-7781 Ii<
accountable and he quit. Chuck De Vore never tries to hold

anyone accountable and that suited Andy just fine.
Accountability is what treatment is all about and its time Andy
had to take some.
Jen and I have worked very hard to get the matter this far and
us
we are trusting that you will not let down. Mr. Rife needs to
be in a real WAC compliant treatment program. The reality is
he has gone a year and still has not really done treatment.
Been kicked out at Davis and Co, and then went to an
unqualified treatment center. Looks like noncompliance to
• me.
Let us know what happens.
•
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~'i<El'.~ilED BY
NOV-22-2006 16:42 FROM-CUSTOllER ENG !NEER ING 425-783-8650 T-378 P.001/001 F-319
co. FILE D~PT- CLOCK NIJMaER 570
PUD 012773 601662 305 0000823297 Earnings Statement
PUBLIC UTILITY DISTRICT NO. 1 PeraOCI Ending: 11115/2006
OF SNOrlDMISH COUNTY Pay Date: 11122/2006
EVERETT. WA 98201
lax.able Marital Status; Single ANDREW S RIFE

ExemptlOM/A\lowances;
Fodefal: 4
Sta.le; No State Income T a>1. 2416 STH ST
EVERETT, WA 98201
earnings
Regular
Holiday
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Yend Pto
Deductions
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NOV-22-2006 13:39 FROM-CUSTO~£R ENG I NEER! NG 425-783-8650 T-371 P.DDl/DDI F-309
Earnings Statement
Andrew S Rife
2415 5th St
Everett, WA 98201
Ale# \/Ilk Pay Date Period E"d Paid Dept Paid Clock Gtoes Pay Net Pay Check ft Chk/Vor Vaid
PUD 12773 45-1 11/07/2006 10/31/2006 601682 305 2,458.33 1.316.52 00823181 ChecK
Earnings Rare Hours This Period

ReglJlar 96.00 2,458.33
Deductions Slatutory
Federal income Tax -201.13
Medie&1e -33.78
Others
Sp Pension F•n<l -3.00
PERS Plan 2 -86.04
401 k L.oan 7tn
CCMa·s~~
Flex R&a1.1e1i0n7
401k Plan
~ ·224.37
Memos
Custom HoursrSiCk 96.00
Pers Hours 96.00
401k Maten 16.83
Pers Pran 2 Earnings 2,458.33

FTE Paid Hrs 96.00
1
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1
10 Br"d
No1 get Llewellyn's
11 Jennifer Rae Rife vember 27 • 2006 Letter
Respondent
12 Please see att ached. .
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLl.GAUL
27 302 Bank ,;;errney
at Law
1604mHenc_a Bldg.
E ew1tt Ave
425 259~f~jtF~}2599820i
~ 7081
. iiiiiDcEi'. LLEWELLYN ....... . .......................... ·14f1l"02
iii:?thooa
_.,,. o:i:si f'A.X 425 2si soia·
BRIDGET LLEWELLYN
GUARDIAN AD LITEM
3114 OAKES AVE.
EVERETT WA. 98201
425-339-2382
425-2528016
Don Layton M.S.W
Bridget Llewellyn
Guardian ad Litem /Supervisor.
3114 Oakes Ave.
Everett WA. 98201
11-27-06
Re: Rife
Dear Don,
Thank you for your update on the Rife matter.
I have supervised a few of the visits myself as of late due to Judy's illness and I
agree with your observations that Andy is demonstrating more than adequate
Parenting Skills.
It makes sense that we put your skills to better use as you suggest and that we
try to work toward some Co-Parenting skills and so please know that you have
my support in this and that I too would like to meet with Sandy Poirer. Maybe we
could do that together so that we are all getting the same information at the same
time.
I will leave it up to you to schedule your meetings with Andy and Jennifer. Move
forward at your own pace and let me know when things are in place.
I also agree that the visits should be extended to three hours and I can speak
with them about this if you would like.
As you know Judy is still out on sick leave and I do not expect her to return full
time until in the latter part of December. I cannot commit her to anything until
2
BRIDGET LLEWELLYii ....................................... Qi il°o:i" ............ .
such time as she has been cleared to return to work by her M.D. I am doing my
best to fill in the gaps and provide the visitation but with my caseload being what
it is my hands are full so I cannot promise as to when the extended time can
start.
Thank you for your hard work and investment in this case.
Respectfully,
LL_
Bridget Llewellyn. Case Manager
3
••
.- -
.J
:1 Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
CL 11996545

COUNTY OF SNOHOMISH
7
8 In re:
Jennifer R. Rife
9 Petitioner, NO. OS 3 02755 1
and
10 MOTION TO DISMISS AND TO DISQUALIFY
Andrews. Rife COUNSEL
11 Respondent.
12 comes now ANDREW scan RIFE, Respondent above named, and moves this
court to enter an Order granting the relief requested in Part I below:
13
I. Relief Requested
14 ANDREW SCOTT RIFE moves this court to enter an Order which
1. DISMISSES the Petition for an Order of Protection from Domestic
1s Violence filed on November 21, 2006.
2. DISQUALIFIES attorney Jan Dyer from further participation in this case.
16 3. AWARDS Andrew Rife judgment against Jennifer LeSourd and Jan Dyer
for his reasonable costs and attorney fees incurred in the defense of
11 this matter.
18 II. statement of Grounds
19 This action should be dismissed because it is a refiling of a case previously
dismissed.
20
This action should be dismissed because it is barred by a CR 2A agreement
21 read into the record and incorporated in the Findings of Fact and conclusions of
Law and in the Decree of Dissolution of Marriage in this matter on November 7, 2006.
22
This action should be dismissed because the procedure specified by CR 60 and
23 RCW 4.72 has not been used.
24 This action should be dismissed because the factual basis required by CR 60
and RCW 4.72 are not present.
25
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1 This action should be dismissed on its merits because the facts alleged do not
state a cause of action.
2
3 SHOULD A FINAL SETILEMENT MADE A PART OF THE SUPERIOR COURT RECORD AND
INCORPORATED INTO FINAL ORDERS BE ENFORCED?
4
SHOULD AN ATTORNEY WHO HAS MADE HERSELF A WITNESS IN THE MATIER
5 BEFORE THE COURT BE ALLOWED TO CONTINUE AS AN ADVOCATE?
6 SHOULD AN ATIORNEY AND A PARTY WHO HAVE BROUGHT A BASELESS CLAIM BE

REQUIRED TO COMPENSATE THE OTHER PARTY FOR THE COST OF DEFENSE?
7
IV. Evidence Relied Upon
8
Declaration of Andrew Scott Rife November 27, 2006
9 Reporter's Transcript, November 7, 2006
Letter, Don Layton to Bridget Llewellyn, November 20, 2006
10 Letter, Bridget Llewellyn to Don Layton, November 27, 2006
The records and files herein
11
v. Legal Authority
12
CR 2A
13 CR 11
CR 60
14 RPC 3.7
15
16 CARL J. GAUL WSBA#8341
Attorney for ANDREW RIFE
17
18
19
20
21
22
23
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
From: Marianne 425-259-7081 To: earl Date: 1112712006 Time: 11:16:42AM Page 2 of 4
Washington Courts Page I of3
WASHfNGTON
C-<E> lJ-----
.
RFf S
.- ::~ . . .:·:11:·.
.· ~
Courts Home I Court Rules Search I Site Map 16.-J eService Center
RPC RULE 3.7

LAWYER AS WITNESS
(a) A lawyer shall not act as advocate at a trial in which the lawyer is
likely to be a necessary witness unless:
(1) the testimony relates to an uncontested issue;
(2) the testimony relates to the nature and value of legal services
rendered in the case;
(3) disqualification of the lawyer would work substantial hardship on

the client; or
(4) the lawyer has been called by the opposing party and the court
rules that the lawyer may continue to act as an advocate; or
(b) A lawyer may act as advocate in a trial in which another lawyer in

the lawyer's firm is likely to be called as a witness unless precluded
from doing so by Rule 1.7 or Rule 1.9.
Comment
[1] Combining the roles of advocate and witness can prejudice the
tribunal and the opposing party and can also involve a conflict of
interest between the lawyer and client.
Advocate-Witness Rule
[2] The tribunal has proper objection when the trier of fact may be
confused or misled by a lawyer serving as both advocate and witness. The
opposing party has proper objection where the combination of roles may
prejudice that party's rights in the litigation. A witness is required to
testify on the basis of personal knowledge, while an advocate is expected
to explain and comment on evidence given by others. It may not be clear
whether a statement by an advocate-witness should be taken as proof or as
an analysis of the proof.
[3] [Washington revision] To protect the tribunal, paragraph (a)

prohibits a lawyer from simultaneously serving as advocate and necessary
witness except in those circumstances specified in paragraphs (a) (1)
through (a) (4). Paragraph (a) (1) recognizes that if the testimony will be
uncontested, the ambiguities in the dual role are purely theoretical.
Paragraph (a) (2) recognizes that where the testimony concerns the extent
and value of legal services rendered in the action in which the testimony
is offered, permitting the lawyers to testify avoids the need for a second
trial with new counsel to resolve that issue. Moreover, in such a
situation the judge has firsthand knowledge of the matter in issue; hence,
there is less dependence on the adversary process to test the credibility
of the testimony.
http://www. courts. wagov/court_rules/?fa=court_rules.display&group=ga&set=RPC&rul... 11/27/2006

----------------~
From: Marianne 425-259-7081 To: earl Date: 11/2712006 Time: 11 :16:42 AM Page 3 of 4
p~· Washington Courts Page 2 of3

•
[ 4] Apart from these two exceptions, paragraph (a) (3) recognizes that a
balancing is required between the interests of the client and those of the
tribunal and the opposing party. Whether the tribunal is likely to be
misled or the opposing party is likely to suffer prejudice depends on the
nature of the case, the importance and probable tenor of the lawyer's
testimony, and the probability that the lawyer's testimony will conflict
with that of other witnesses. Even if there is risk of such prejudice, in
determining whether the lawyer should be disqualified, due regard must be
given to the effect of disqualification on the lawyer's client. It is
relevant that one or both parties could reasonably foresee that the lawyer
would probably be a witness. The conflict of interest principles stated in
Rules 1.7, 1.9 and 1.10 have no application to this aspect of the problem.
[ 51 Because the 'tribunal is not likely to be misled when a lawyer acts

as advocate in a trial in which another lawyer in the lawyer's firm will
testify as a necessary witness, paragraph (b) permits the lawyer to do so
except in situations involving a conflict of interest.
Conflict of Interest
(6] [Washington revision] In determining if it is permissible to act as

advocate in a trial in which the lawyer will be a necessary witness, the
lawyer must also consider that the dual role may give rise to a conflict
of interest that will require compliance with Rules 1.7 or 1.9. For
example, if there is likely to be substantial conflict between the
testimony of the client and that of the lawyer, the representation
involves a conflict of interest that requires compliance with Rule 1.7.
This would be true even though the lawyer might not be prohibited by
paragraph (a) from simultaneously serving as advocate and witness because
the lawyer's disqualification would work a substantial hardship on the
client. Similarly, a lawyer who might be permitted to simultaneously serve
as an advocate and a witness by paragraph (a) (3) or (a) (4) might be
precluded from doing so by Rule 1.9. The problem can arise whether the
lawyer is called as a witness on behalf of the client or is called by the
opposing party. Determining whether or not such a conflict exists is
primarily the responsibility of the lawyer involved. If there is a
conflict of interest, the lawyer must secure the client's informed
consent, confirmed in writing. In some cases, the lawyer will be precluded
from seeking the client's consent. See Rule 1.7. See Rule 1.0(b) for the
definition of ''confirmed in writing'' and Rule 1.0(e) for the definition of
''informed consent."
{7] Paragraph (b) provides that a lawyer is not disqualified from

serving as an advocate because a lawyer with whom the lawyer is associated
in a firm is precluded from doing so by paragraph (a). If, however, the
testifying lawyer would also be disqualified by Rule 1.7 or Rule 1.9 from
representing the client in the matter, other lawyers in the firm will be
precluded from representing the client by Rule 1.10 unless the client
gives informed consent under the conditions stated in Rule 1.7.
Additional Washington Comment (8)
(8] When a lawyer is called to testify as a witness by the adverse

party, there is a risk that Rule 3.7 is being inappropriately used as a
tactic to obtain disqualification of the lawyer. Paragraph (a) (4) is
intended to confer discretion on the tribunal in determining whether
disqualification is truly warranted in such circumstances. The provisions
of paragraph (a) (4) were taken from former Washington RPC 3. 7 (c).
http://www. courts. wa. gov/court_rules/?fa=court_rules.display&group=ga&set= RPC&rul... 11/27/2006

,.
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41 CL 11996542

COUNTY OF SNOHOMISH
7
8 In re:
Jennifer R. Rife
and
10 MOTION TO STRIKE
Andrew s. Rife
11 Respondent.
12 comes now ANDREW scon RIFE, above named, and moves this court to enter
an order granting the relief requested in Part I below:
13
1. Relief Requested
14 ANDREW SCOTT RIFE moves this court to enter an Order which strikes portions
of the declaration of Jennifer R. Rife dated November 21, 2006.
15
16
The declaration of Jennifer R. Rife dated November 21, 2006 includes
17 numerous statements concerning the process of negotiation occurring August 7,
2006 through November 7, 2006.
18
19 numerous statements concerning events predating the decree in this matter, now
merged into that decree.
20
21
ARE STATEMENTS MADE DURING SETILEMENT NEGOTIATIONS ADMISSIBLE IN
22 EVIDENCE?
23 DOES A SETILEMENT READ INTO THE RECORD AND APPROVED BY THE COURT AND
EMBODIED IN A DECREE OF DISSOLUTION OF MARRIAGE RESOLVE ALL ISSUES
24 BETWEEN THE PARTIES?

26
CARLJ.GAUL
Attorney at Law
lJR/G/fVAL 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1
DECLARATION OF PETITIONER IN SUPPORT OF PROTECTION ORDER
2 A copy of that declaration showing the portions which should be
stricken is attached hereto.
3
v. Legal Authority
4
CR 2A
5 ER 408
6
7 CARL J. GAUL WSBA#8341
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1
2
3
4
5
6
7
.8 SUPERIOR COURT OF WASHINGTON
FOR SNOHOMISH COUNTY N 0: 05-3-00314-8 .
9
10 JENNIFER R. RIFE, 8/18/74
11 Petitioner DOB DECLARATION OF PETITIONER IN
12 v. SUPPORT OF PROTECTION ORDER
13 ANDREWS. RIFE, 3122173

14 Respondent DOB
15
16 My name is Jennifer LeSourd. Prior to my divorce my name was Jennifer Rife. I am the
17 petitioner named above. I am attaching 18 exhibits to this declaration and ask that they be
18 incorporated by their reference herein. An index to those pleadings is attached. Andy Rife and
I were married and we have a child in common. The divorce essentially started when Andy was
19
arrested for the second time in Jess than six months on a domestic violence related charge. I
20
obtained a temporary protection order at that time and Andy filed for a divorce.
21
For reasons that I have never understood the court reissued my temporary protection
22 order month after month, (exhibit 14). There was never any real question that I would have a
23 protection order but the way it started out"it just kept getting reissued. Finally in April we were in
24 court again on the re-issuance of the protection order in front of Commissioner Stewart. Our
25 trial was set for mid August. The court gave us the choice of having it issue a full protection
26 order at that time or reissue to the trial date.
27 Since we believed that this case was going to trial 'we opted to reissue the protection
order to the trial date so that we could present the evidence all at once and with live testimony.
28
When I say that I believed the case was going to go fo trial I don't mean to sound like I was not
29
willing to settle. We believed it was going to trial because, although Andy had been arrested
30
twice (exhibit 16), although the court had ordered that his visitation with our daughter be
Dy1ST & Primont
503 Twelfth Ave. E.
Seattle, WA 95102
(206) 343-1528
1 supervised, although he had been dismissed from one DV treatment program (exhibit 17),
2 chose another that did not comply with state ·law regarding treatment programs and was forced
3 to go to yet another program but was also dismissed from that program for continuing to attempt
to subvert the law regarding Phase I treatment, (exhibit 6) he continued to be in complete denial
4
about his abuse and continued to blame everything. on me. He continued, right up to two weeks
5
before trial, to assert that he should be the primary parent of our daughter. This despite the
6
GA L's recommendations that she live primarily with me and that Andy have "therapeutic"
7
supervised visitation, complete DV treatment at Catholic Family Services, enroll in and complete
8 DV Dads and Respectful Parenting at Family Services, he continued to assert that he should be
•
t 10
9 the primary parent. I believed we were going to have no choice but to go to trial. In many ways
now I wish I had.
. . .. . . .. ..
111 - .. ~·
.. , . ' ... _J 0 • ·- -· - 11.-
•*~~i;R&'' ;u:Ru&Q aRei *Re Q,o,b '•\•es ~AeFe ee '•!ell. IAeleee eP "e111i~~ e e1e,,esitio11 he e11e l1i!5
~12
~
e~eFt=rie, effaFeS 'e sEMUe tRe aaee. ~1\Ce 1nei::e etWiie SWFfii!Fi&BEii aRS R9i 8~iUii'I'' pl~lilfj3iilj;fid ~g .;;iiUlfill
13
ell i!!st:1ee. 1-A'e eie a feiflly ~eeel jeb ewer ell seUiA~ 1¥te91 iestfe9 eet1eFeS aAE:f eRE!te8 t:tj!!I II it~
s 14
se11e1el ~e~e!I ef I 1eAfiGPfiff:e1 I e~l"eemeAt9 eBet1t ettf efi'll1e11ee, Btlfl '36FeAtiAfj J3l8R SRS sRil8
~"
15
"tipµor=t. Tl-le Deri 1e3tie Vielenee Pl'eteetief'I Order 11uae, u11MRt1natel), Aet di!!etJ~!ted, Po1)'
16 ettte111e~ tl'let::1gR~ it 'l't'89 e !;Ji'v'el=t 9!3 wwe Ree Ae tiefl ~i~ef1 8A) iAEiieetjeA O:iat_ we
1
e;e Re~ v.reRt a ftfll
17 J!PSfeeUsA eFBBF. 81:-Jt ·nReA eAe a1319Feae!cieel ,0,Rely'a atterA9) aBecit it :Re reFt:-JeeB te ever:i elise1:1sa
18 it. Tl aet nos ii 1 late: duly .
~t) 9 I 9 I fl 6• I I ''I' e1 1's e111e1est 99 ut1 1115 cuo•t

. 19 19iA88 •Me• tiMa 1I l!l• I ~:: I !
20 'Ne nefe 11et able ta reaeR SA)' B!;)Feemeflts eAd ulti_matefy Andy's attorney noted a motion for
-~ 21
presentation of final orders. Judge Castleberry denied his motion and told us to go out in the
" hall and come to terms on our disagreements in the documents. Our attorneys and the GAL
iI~ 22
23
24
met and were able to reach agreements regarding our divorce documents and we were able to
go back into court and get our final divorce documents entered. n toef~ a 111e1~t119 efii ,a,,.,ei, 8118
Ris atteFAey's eBseltJtely ttFIFeeeeReble eJeF1=taRefs eAel er=1 tJf1t111Jeeesser_y' tFif' te eebFt voReM tFte)
25 eo111~letely Beeltee elew1A te get SivereeS;
26 My parents were with us in court that day. Just after the judge pronounced us divorced
27 my parents stepped out in ihe hall. Andy and his attorney left the courtroom while my attorney
28 and I stayed and talked with the GAL When Andy passed my parents· in the hall he made a
29 smart remark to them. calling my sister and me cancers. They have had it with Andy and do not
like him very much and my father responded that Andy should basically bug off. Andy turned
30
Dyer& Primont
503 Ttvel'.fth Atoe. E
Se.a.ttle., WA 98102
(206)343-1528
towards my father and took a fighting stance. He gestured for him to "bring it on" so to speak.
2 My father, realizing what was happening, told Andy that he was not going to fight with him and
3 turned away. At about that time Andy's attorney grabbed him and got him out of the area.
.. I
4
h e attached my prior declarations as well as information I provided to my therapist that details
5
Andy abuse during our marriage, (exhibits 1, 2 and 3). Even after I called the police he came
6
right bac and continued the abuse and always blaming it all on me. He lied to me about his
7
avis and Company and it was not until much later that I learned he had been
8 heir program. I had a very small baby at the time and was totally dependant
9 on Andy. He took II advantage of this and continued his abuse. It all culminated in his being
.10 arrested for violating t Criminal No Contact Order. Our divorce was filed and l sought and
11 ion order, (exhibit 13).
12 Andy was under cou rder by the Municipal Court to be in treatment. In October of
2005 he started treatment with C ck Devore however Mr. Devore's ireatment program was not
13
compliant with the WACS governin V treatment programs and Andy was forced to change
14
treatment programs. He did not like this. He went back to the Municipal Court, without notice to
15
any of us in the dissolution case, and obta ed an order there saying that he should get credit
16 for the time he was working at Mr. Devore's pr ram, even though it was not in compliance with
17 state law. The GAL disagreed and was insisting t Andy be in a compliant program. He did
18 switch to Phoenix Counseling with Dale Todd but re ed to let the issue of credit for his time
) 19 with Mr. Devore go. Ultimately Dale Todd refused to g1 him credit and Andy was removed
from his treatment program, (exhibit 6).
~20
At that point Andy's behavior was really getting bad. s showing up at our visitation
\) 21
exchanges and sitting in his mom's car. He would make faces or y with the instruments on
~ 22
the car to draw attention to himself. It was a violation of the Protection
23
to work out a parenting plan and I was trying to be patient. The GAL w working hard with
24
Andy trying to get him to change his attitude but with apparently no success.
25 In July, just a month or so before our trial, Andy and his mother Wendy
26 District Court, knowing we were next door in superior court, and obtained two Anti
27 Orders; Andy against my mother and Wendy Rife against me. I could not believe the II
28 put in their petitions, (exhibits 1 O and 11 ). We had our full hearing and the judge said they
29
30
Dyer & Primont
503 Twelfth Avt. E
Strattl~,
W.4 951.01
(206) 3'3-1528
1
leii~~iQ.o.2._sand the temporary orders that went along with them, (exhibit 9).
1e1111e<F>t..J~ack to court, me asking that his mother Wendy no longer be
able to act as visitation supervisor, in ligh~Of-FIO>J[..§,S~eeking a protection order against me, and
Andy asking that I be found in eontempt. The court a ime ordered
supervised visitation. I have attached a typed transcript of that hearing at ex(7TTl:m...z_tt
f ~We1~-l!tt!~+.e1'>-Aftd'\>'"~~ffl-e~~~~9e!t~ttM~~~~~~~~__:;:~
7
He started a new DV treatment program at Catholic Community Services in August of
8 2006. He was first ordered into treatment in May of 2005. It is now the end of November of
9 2006 and Andy has still not completed Phase I of any DV treatment program. As required by
10 law, the treatment program has been in touch with me. They have been quite concerned
11 because Andy continues to blame me and seems unable to shift his focus. He also is
12 apparently continuing to argue that he should be given credit for the time he worked with Chuck
Devore. His most recent progress report indicates that they had to have a talk with him about
13
"fighting against doing the program" (exhibit 4). It seems clear that nothing has changed.
14
As I mentioned above, Andy has "therapeutic visitation supervision" with Don Layton.
15
Don has made it quite clear to me that Andy is fixated on blaming me and clearing his name.
16 Mr. Layton notes that Andy needs, "to be mindful of the submerged mass of toxic resentment he
17 harbors towards Jennifer/her mother ... " (Exhibit 5).
18 The reasons for entering a temporary protection order in 2005 and reissuing it until
19 August of 2005 continue to exist today. Andy continues to be a very angry and dangerous
20 person as it relates to me and our daughter. I am fully committed to working with our Case
Manager and through our parenting plan, (exhibit 8) but I feel strongly that I need an order of
21
protection for both Lauren and me. From my perspective Andy is more dangerous now than he
22
was a year ago. He has never at any time taken any responsibility or been accounexhibitle for
23
his physical abuse during our marriage. He has spent the last year trying to get back at me. He
24 is in his fourth treatment program and still has not been able to complete Phase I.
25 Andy has refused to pay child support for November. Our divorce was granted on
26 November 7, 2006. Our final order of child support states that support, under the final order
27 would begin on October 1, 2006 but that is crossed out and December 1, 2006 is written in. I
28 called the Division of Child Support and was told that the temporary orders ended when the final
29 order was entered so technically Andy does not owe support for November. This type of
30
D11cr & Prim on t
503 Tuiclfth A t>c. E
Seattle, IVA 98102
(106) 343·152,9
1 economic terrorism is typical of Andy. He is not worried about Lauren and I having no money
2 he is just thinking about how he can get back at me.
3 I believe we have a very Jong road ahead of us. Who knows if Andy will ever embrace
his treatment and change his way of thinking. He has had_ many opportunities to do so but has
4
not so far. He continues to blame me for everything and I am very concerned for the safety and
5
wellbeing of our daughter if he continues to think and act the way he is now.
6
I am asking that this protection order be effective until 2011, five years from now. Our
7
daughter will be seven by then. Maybe there will be a miracle before then; I hope so but frankly
8 at this point I am not holding my breath.
9 I should not have had to come to court to obtain this order. Every professional in this
10 case has recommended that there be a protection order. All of the evidence points to Andy's
11 abuse; to his refusal to change his way of thinking and be accounexhibitle for his actions. I am
12 on public assistance and am going to school. I have had to borrow all of my attorney fees from
my parents. I did not receive any child support ($562.00) in November from Andy. I am asking
13
the court to order that Andy pay $3,500.00 for my attorney fees and cost in having to bring this
14
petition.
15
I declare under penalty of perjury of the Jaws of the state of Washington that the
16
foregoing is true and correct Signed thir;,2.l_Jtay of November 2006 in Everett, Washington.
17
18
19
20
21
22
Our names are Carol and Steve Holland. We are Jennifer's parents. Portions of this
23
declaration pertain to us. We have read the declaration and assert that information contained in
24
here relative to each of us is based on our own personal knowledge and is true and correct.
25 This declaration is made.under penalty of perjury of the laws of the State of Washington and is
26 signed ';Ind date_~ thi~~ of November 2006 in Everett, Washington.
27
28
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'
STEVE HOLLAND CAROL HOLLAND
29
30
Dyer & Primont
503 Twdft.11 Ave. E
Seattk, \VA 98102
(206) 343-15Z8
.. ···
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4 CL 11996544 ·

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Don Layton's
Jennifer Rae Rife November 20, 2006 Letter
11 Respondent_
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 ff>)( 259 7081
r-
·iihiifoos o:i:oo i'u· 425 252 sois
.,~
BiiiDGiit.LiliWE:J:i.:Y'N ···········
I ,
I
I
I
I
Don Layton, MSW
Child Advocacy Services, Inc.
3114 Oakes, Everett, WA 98201
(425) 252 8056
(425) 252 8561 fax
donlayton 1@verlzon.net
I Monday, November 20, 2006

i
~ Bridgett Uewellyn, Case manager
3114 Oakes Ave
Everett, WA 98201
Re: Rife
Dear Bridgett,
I am thankful that court orders have been finalized on the Rife case; I had an
opportunity to review them last week. To the extent that I have been given an
ongoing therapeutic role relative to parental contact, I would like to make some
suggestions.
It has been my observation that Andrew has demonstrated more than adequate
parenting skills over the three months since I began working with him in a therapeutic
supervision mode. My time and skills would be more effective focused on a different
area of needs. He and I have had several talks along the way about his temper/anger
and domestic violence treatment program. Jennifer, also, has requested my counsel on
several occasions which I have provided; these talks have ranged from parenting advice
to domestic violence concepts to what to expect from children Lauren's age. Andrew
and Jennifer view his anger and the work he is doing differently. Further, Lauren
deserves at least some exploration as to what potential there might be for her parents
to coparent her at some point.
I would like to suggest the following:
That I delegate all of the supervision to Judy.
That I assume a therapeutic role aimed at working with each parent (individually
for the time being) to bring them to a more shared understanding of Andrew's
domestic violence treatment process and progress. These would be individual
sessions at my office, twice a month with each parent - more if necessary.
1
.iikibGiit. l.LliW!il.LiiN .... . ................. ·!ll·o·o111YO.i ..
That Andrew provide me with a release to meet with Sandra Poirier and I meet
with her to set up a collaborative relationship as I engage each parent as
described above.
Therapeutic focus would eventually turn to the trust building and communication
skills necessary to coparenting - and an assessment as to whether or not this is
realistic for Andrew and Jennifer.
Given the language in the court ordered parenting plan, Andrew would be expected to
compensate me for my time.
To summarize:
Andrew's investment in my time would provide greater results if I gave over all
supervision duties to Judy and focused on two therapeutic issues: helping Andrew and
Jennifer to arrive at a common understanding of what Andrew is doing to master his
inappropriate compulsive behaviors and what to expect; offering communication skills
aimed at effective coparenting as divorced parents and assessing their potential for
this. I would do this via individual contact with each parent in my office, giving over
the small supervision role I currently have to Judy Dyer. I would establish an ongoing
working relationship with Sandra Poirier. Andrew would pay for my time.
I would like to make these changes as soon as you can let me know whether or not you
support them as the case manager.
On another note . . . Jennifer has recently made known her desire to return the
transfers to the QFC at each end of the visit, a benefit she can reasonably expect to
have supported by Andrew and the rest of us. Due to traffic Issues, these transfers
seriously cut into the amount of quality time Lauren is able to have with her father
during the residential time that falls during the work week. Andrew is open to adding
an hour to each of the weekday visits in order to address this problem. I would like to
recommend that the weekday times be for three hours (flexed to fit Judy's schedule).
Therapeutic supervisor
1
1
7.00G OCi I9 Pl-1 z: lt 3
pt>,M L. Ot>.N\ELS
2 cou1nY cLERI~
111111111111111111111111111111111111111111111111111111111111
SNOHOMISH CO. WASH.
3 CL 11587486
4

6 In Re the Marriage of:
7 Andrew Scott Rife, No.OS 3 02755 1
Petitioner CALENDAR NOTE
8 and
9 Jennifer Rae Rife,
Respondent
10
TO: CLERK OF THE COURT
11 AND TO: Jennifer Rae Rife
AND TO: Jan Dyer, Attorney for Jennifer Rae Rife
12
13 JUDGE'S CIVIL MOTIONS Date: November 7, 2006

CALENDAR Tuesday - Friday at 9:30 a.m.
14 Nature of Hearing:
Motion to Enforce CR 2A Settlement
15
16
17 WARNING: The moving party MUST CONFIRM by noon two (2) court days prior to the hearing in order for the
matter to be argued. Failure to notify the Court of a continuance or strike may result in sanctions and/or terms.
18 SCLCR 7(b)(2)(E). This form cannot be used for trial settings. SCLMAR 2.1 40(b).
19 Dated: October 18, 2006

20
21
22
23
24
25
26 CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
F\LED
Oo RO'J 21 ~l'\ ii~ 2.5
1 ~~l\(l'-
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5
·I \
6 CL11450468
7
9
In re:
11 and
Respondent.
13
14 TO: THE CLERK OF THE COURT

AND TO: Jennifer Rae Rife nka Lesourd
15 AND TO: Jan Dyer, attorney for Jennifer Rae Rife nka LeSourd
16 PLEASE TAKE NOTICE that Carl J. Gaul, attorney for Andrew Scott Rife, will be
unavailable from December 18, 2006 through January 3, 2007 inclusive. It is
17 requested that motions, depositions and other court hearings not be scheduled to
occur during the time of my absence, and that motions and other hearings be
18 scheduled so that there is sufficient time to prepare for them following the end of
the absence. There is no other attorney available w· sufficient factual knowledge
19 of this case to respond to any substantive reques for re ief du · m ·absence.
,/
20 Dated: November 16, 2006
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 98201
NOTICE OF UNAVAILABILITY OF COUNSEL 425 259-4147 FAX 259 7081
ORIGINAL
1 FILED
2 n5 DEC - 7 P,'i t~: oa
3 -· 01."....~·1·~c ::-'
!'1~1·1:
Cou NT
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll l l l llll llll SNOHO'-'JSH . """
Y CL' ~" .;
4 CL 11459834 " CO. \'.'£1S1t.
5
7
8
9 Petitioner
and CALENDAR NOTE
10 (CDMMISSIONER S
1
DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: January 16, 2007

CA LEN DAR· (Except matters relating to
Nature of Hearing:
Department B or C, As Assigned Motions: To Strike
17 To Dismiss and Disqualify
Counsel
18
19
20
21 WARNING: The moving party MUST CONFIRM by noon two (2) court days prior to the hearing in order
for the matter to be argued. Failure to notify the Court of a continuance or strike may result in sanctions
22 and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for trial settings. SCL AR 2.1 40(b).
23 Dated: December 6, 2006 '

/.
( J •,A....
24 CARLJ.G
Attorney for
25
26
27
28
0RI6'/N CARL J. GAUL
Allomcy ot law
L!J I
}')t:
CALENDAR""'' I
CA~ENDAR) '4 L...
302 Bank of America Building (
Everett WA 98201
(COMMISSIONER'S DOMESTIC MOTION (425) 259-4147 Fax 259-7081
L
•.
7.UOn OC1 11 Pl'\ 3: IS

I\\\\\\\\\\\\\\\\\\\\\11\11 \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\ \\\\ ?"ML Dl>JllELS
2 CL11425866 f'ouuiY CLER\\
sNo\;oMISH co. \~ASH.
3
6
8
In re:
lO Petitioner, INITIAL STATEMENT OF ARBITRABILITY

and AND TRIAL SETTING
Respondent. CLERKS ACTION REQUIRED
12
13 0: THE CLERK OF THE COURT;

NOTO: THE DIRECTOR OF ARBITRATION
14 ND TO: Jan Dyer, Attorney for Jennifer Rae Rife
15 I hereby affirm that this case is at issue; that no affirmative pleading remains unanswered; that
to my knowledge no other parties will be served with summons; and the case in all respects is
16 ready for trial.
17 On November 3, 2006, at 10:00 a.m., this case will be presented to the Court Administrator for
setting of trial date and/or transfer to arbitration.
18
Nature of case: Divorce Estimated trial time: 2 days
19
Is jury demanded: N/A
20 NOTE: Per CR 38, a jury demand and fee must be filed with the Clerk.
22 his case is NOT ARBITRABLE because:
23 This domestic lawsuit presently involves issues other than or in addition to the
establishment, modification or termination of child support or maintenance payments or
24 arrearages; or
25
CARLJ.GAUL
26 Attorney at Law ;/
27 DRJG/NA&TATEMENT OF ARBITRABILITY - I 302 Bank of America Bldg.

1604 Hewitt Ave.
Everett WA 9820 I
425 259·4147 FAX 259 7081 II \
[ . -~
Any response to the Statement of Arbitrability must be filed with the Clerk L~ourt and a
copy served upon the Director of Arbitration with 14 day~SCLMAR 2.l[b]) /
2
3 Dated: October 16, 2006 l/~ - 1
4 CARL J. GAU WSB #8341

Attorney for A drew cott Rife
5
6
I, CARL J. GAUL, declare under penalty of perjury of the laws of the State of Washington, that on
7 October 16, 2006, I deposited in the United States Mail at Everett, First Class Postage prepaid a copy of the
document to which this declaration is affixed, to the following persons, addressed as follows:
8
Jan Dyer
9
Seattle WA 98102
lO
Bridget Llewellyn
11 3114 Oakes
Everett, WA 98201
12
l3
Executed at Everett, October 16, 2006
)
14
15
16 ORIGINAL TO CLERK OF COURT, COPY TO DIRECTOR OF ARBITRATION

17
18
19
20
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Laiv
27 1604 Hewitt Ave.
STATEMENT OF ARBITRABILITY - 2 Everett WA 9820 I
425 259-4147 FAX 259 7081
,
1
.2 20061\0V - 7 PM 3: 25
3
.. ". :_ L:AlllELS
4 COUNTY CLERK
s;~OH0:1:Sff CO ..VIASH.
5
6
Illlllll llllll Ill lllll lllll lllll lllll lllll l l l lllll llll llll
7 CL 11954379
8
12
ANDREW S. RIFE, No. 05-3-02755-1
13 Petitioner,
14 and Order of Child Support
Final Order (ORS)
16 Respondent Clerk's Action Required
17
18 I. Judgment Summary
19
Does not apply because no attorney's fees or back child support has been ordered.
20
21 II. Basis
22 2.1 Type of Proceeding

23
This order is entered under decree of dissolution.
24
25 2.2 Child Support Worksheet
26 The child support worksheet which has been approved by the court is attached to this order
27 and is incorporated by reference or has been initialed and filed separately and is
incorporated by reference.
~
28
U) 2.3 Other: NIA
U) 29
== 30
Order of Child Support (TMORS, ORS) - Page 1
'Jb
Dyer & Primont
WPF DR 01.0500 (6/'2006)-RCW 26.09.175; 26.26.132
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
\\\
1
2
3
4
III. Findings and Order
5
It Is Ordered:
6
7 3.1 Children for Whom Support is Required
8
Name (first/last)
9
10 Lauren Rife 2
11 3.2 Person Paying Support (Obligor)

12
Name (first/last): Andrew Rife
13 Birth date: March 22, 1973
14 Service Address: 2416 5t11 St.
Everett, WA
15
16 The Obligor Parent Must Immediately File With the Court and the Washington State
Child Support Registry, and Update as Necessary, the Confidential Information Form
17 Required by RCW 26.23.050.
18
The Obligor Parent Shall Update the Information Required by Paragraph 3.2 Promptly
19 After any Change in the Information. The Duty to Update the Information Continues
20 as long as any Support Debt Remains due Under Th~er.~
21 Monthly Net Income: $4368.6~ L\-Z"t4.~ ~

22
3.3 Person Receiving Support (Obligee)
23
Name (first/last): Jenn Rife
24
Birth date: August 18, 1974
25 Service Address: 503 Twelfth Ave. East
26 Seattle, Washington 98102
27 The Obligee Must Immediately File With the Court and the Washington State Child
28 Support Registry and Update as Necessary the Confidential Information Form
Required by RCW 26.23.050.
29
30
WPF DR 01.0500 (612006) - RCW 26.09.175; 26.26.132 Dyer & Primont
503 Twelfth Ave. £
Seattle, WA 98102
(206) 343-1528
1 The Obligee Shall Update the Information Required by Paragraph 3.3 Promptly After
·2
any Change in the Information. The Duty to Update the Information Continues as
Long as any Montflly Support Remains Due or any Unpaid Support Debt Remains Due
3 Under This Order.
4
Monthly Net Income:$ 2,113
5
The obliger may be able to seek reimbursement for day care or special child rearing
6
expenses not actually incurred. RCW 26.19.080.
7
3.4 Service of Process
8
9 Service of Process on the Obligor at the Address Required by Paragraph 3.2 or any
10
Updated Address, or on the Obligee at the Address Required by Paragraph 3.3 or any
Updated Address, may Be Allowed or Accepted as Adequate in any Proceeding to
11 Establish, Enforce or Modify a Child Support Order Between the Parties by Delivery of
Written Notice to the Obligor or Obligee at the Last Address Provided.
12
13 3.5 Transfer Payment
14
The obliger parent shall pay the following amounts per month for the following children:
15
Amount
16
~ -:::,<-
17 Lauren Rife $ 5'12:00 2> "'-z. --
18
Total Monthly Transfer Amount $572.00 " t; (o 2. . -s ~z..
19
The Obligor Parent's Privileges to Obtain or Maintain a License, Certificate,
20
Registration, Permit, Approval, or Other Similar Document Issued by a Licensing
21 Entity Evidencing Admission to or Granting Authority to Engage in a Profession,
Occupation, Business, Industry, Recreational Pursuit, or the Operation of a Motor
22
Vehicle may Be Denied or may Be Suspended if the Obligor Parent is not in
23 Compliance With This Support Order as Provided in Chapter 74.20A Revised Code of
Washington.
24
25 3.6 Standard Calculation
.. <;<..< . '!):
26
$~0 per month. (See Worksheet line 15.)
27
3.7 Reasons for Deviation From Standard Calculation
28
29 The child support amount ordered in paragraph 3. 5 does not deviate from the standard
calculation.
30
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1
3.8 Reasons why Request for Deviation Was Denied
2
.3 A deviation was not requested.
4
3.9 Starting Date and Day to Be Paid
5 ~<~...lo.I('
6
Starting Date: Q • J .1 I, 2006
Day(s) of the month support is due: First and Fifteenth
7
8 3.10 Incremental Payments
9 Does not apply.

10
3.11 How Support Payments Shall Be Made
11
12 Select Enforcement and Collection, Payment Services Only, or Direct Payment:
13 [x] Enforcement and collection: The Division of Child Support (DCS) provides
14 support enforcement services for this case because: this is a case in which a
parent has requested services from DCS and a parent has signed the application
15 for services from DCS on the last page of this support order. Support payments
16 shall be made to:
17 Washington State Support Registry

18 P. 0. Box 45868
Olympia, WA 98504
19 Phone: 1-800-922-4306 or
20 1-800-442-5437
21 A party required to make payments to the Washington State Support Registry will not
22 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
23 reasonable cost and, if so, to provide the health insurance policy information.
24
3.12 Wage Withholding Action
25
26 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
27 other state, without further notice to the obligor parent at any time after entry of this order
28 unless an alternative provision is made below:
29
30
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1 3.13 Termination of Support
2
Support shall be paid until the child reaches the age of 18 or as long as the child remains
3 enrolled in high school, whichever occurs last, except as otherwise provided below in
4 Paragraph 3.14.
5 3.14 Post Secondary Educational Support

6
The parents shall pay for the post secondary educational support of the child. Post
7 secondary support provisions will be decided by agreement or by the court.
8
3.15 Payment for Expenses not Included in the Transfer Payment ~
9
..,,.,,,<?., c.,-;:i-"r.. ~
10 The mother shall pay ~% and the father ~lo (each parent's proportional share of income ( ..
from the Child Support Schedule Worksheet, line 6) of the following expenses incurred 1
11 on behalf of the children listed in Paragraph 3 .1 :
12 [x] Work related day care.
[x] Pre school.
13 [x] Camps, lessons, sports, and enrichment programs ..
14
Payments shall be made to the provider of the service when possible or to the
15 parent receiving the transfer payment.
16
Under the parenting plan the mother has sole decision making authority. She shall
17 not obligate the father financially without giving him notice of the planned
18 expense. Ifhe voices no objection within 10 days, the expense will be shared per
line 6 of the worksheets. Ifhe does object within 10 days, the matter will be
19 arbitrated by the Volunteers of America Dispute Resolution Center.
20 3. ~ ('tr~l,......_.,. 6-u "".) "'""'~ \>'"~..,. ... ...O"'-' c.....CJ....a
c.-\.\,,."'""° ~"""--<.. -\::::i.
3.16 Periodic Adjustment <.v-.., ...........\\. ':>..... '"'-" f • ..,,,1..,\.q_ """°_,.. ..+1.-.-
21 ~ ~ .,...,..i. "'-... \p-o.
22 Does not apply.
23 3.17 Income Tax Exemptions

24
Tax exemptions for the children shall be allocated as follows: To the mother in even
25 numbered tax years and the father in odd numbered tax years. The mother shall file as
26 Head of Household every year.
27. The parents shall sign the federal income tax dependency exemption waiver.
28
29
30
WPF DR 01.0500 (612006) - RCW 26.09.175; 26.26. 132 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1 3.18 Medical Insurance for the Children Listed in Paragraph 3.1
2
Unless one or more of the alternatives below are checked, each parent shall maintain or
3 provide health insurance coverage if:
4
[X] Alternative I: The parent below shall maintain or provide health insurance coverage
5 if coverage that can be extended to cover the child(ren) is or becomes available to that
6 parent through employment or is union-related and the cost of such coverage does not
exceed 25 percent of that parent's basic child support obligation on Worksheet line 7.
7
8 Father
9
[X] Alternative 3: The parent below is not obligated to provide health insurance
10 coverage:
11
[x] Mother
12
This parent is not obligated to provide health insurance coverage because:
13
14 The other parent provides insurance coverage.
15
The parent shall maintain health insurance coverage, if available for the children listed in
16 paragraph 3. I, 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
17
continue coverage following termination of employment.
18
19
A parent who is required under this order to provide health insurance coverage is liable
20 for any covered health care costs for which that parent receives direct payment from an
21 msurer.
22 A parent who is required under this order to provide health insurance coverage shall
23 provide proof that such coverage is available or not available within 20 days of the entry
of this order to the physical custodian or the Washington State Support Registry if the
24 parent has been notified or ordered to make payments to the Washington State Support
Registry.·
25
26 If proof that health insurance coverage is available or not available is not provided within
27 20 days, the obligee or the Department of Social and Health Services may seek direct
enforcement of the coverage through the obligor's employer or union without further
28 notice to the obligor as provided under Chapter 26.18 RCW.
29
30
WPF DR 01.0500 (612006) - RCW26.09.175; 26.26.132 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1 3.19 Extraordinary Health Care Expenses
(;'.l{''fo
2
The Obligor shall pay §'lo of extraordinary health care expenses (the obligor's ·<A
3 proportional share of income from the Child Support Schedule Worksheet, line 6), if QI~_)
monthly medical expenses exceed$~ J,?% of the basic support obligation from
4
Worksheet line 5). L\-::\-, - .
5
6 3.20 Back Child Support

8
3.21 Back Interest
9
10 No back interest is owed at this time.
11 3.22 Other: Both parents shall carry life insurance sufficient to cover their remaining child
12 support obligation through the child's 23rd birthday. The policy shall name the child as
the beneficiary with the other parent as the guardian of the child.
13
J4 If either parent sets up a college fund for the child they shall inform the other parent and
give the other parent yearly notification of the amount in any such account. ·
15
16 The father shall pay the remaining GAL fees. The fees of the Case Manager will be paid
by the parents on a pro rata basis according to their income shares as shown on the
17 support worksheet. Visitation supervision shall be paid by the father.
18
19
20
21 Dated: -7~/_,._·~. . . .!/~fJ-b~··

. _
22
23
24
Approved for entry:
25 Notice of presentation
26
'2.7
~8 Atto
29
30
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1 ply for full support enforcement services from the DSHS' Division of Child Support.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
WPF DR 01.0500 (612006)- RCW 26.09.175; 26.26.132 Dyer & Primont
503 Ttvelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Worksheets (CSW)
Mother: Jennifer Rae Rife Father: Andrew Scott Rife
Countv: SNOHOMISH s uperior court Number:
Children and Ages: LER, 1

a. Wages and Salaries $5,704.28 $2,798.00
b. Interest and Dividend Income . .
c. Business Income . .
d. Soousal Maintenance Received . .
e. Other Income . .
(add lines 1a throuqh 1e) $5,704.28 $2,798.00
a. Income Taxes (Federal and State) $1,033.95 $236.75
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes $78.72 $428.10
c. State Industrial Insurance Deductions . .
d. Mandatory Union/Professional Dues . .
e. Pension Plan Pavments $291.74 .
f. Spousal Maintenance Paid . .
q. Normal Business Expenses . .
{add lines 2a throuah 2n\ $1,404.41 $664.85
lline 11 minus 2hl $4,299.87 $2,133.15
(Line 3 amounts combined) $6,433.02
Ill line 4 is less than $600, skio to line 7.)
5. BASIC CHILD SUPPORT OBLIGATION: Combined -7
LER $911.00
. $911.00
-
-
-
Father Mother
(Each parent's net income from line 3 divided by line 4} .668 .332
(If line 4 is less than $600, enter each parent's support
obligation of $25 per child. Number of children: 1
{Skip to line 15a and enter this amount.) $608.55 $302.45
8. Health Care Exnenses
a. Children's Monthlv Health Insurance $47.00 .
b. Children's Uninsured Monthlv Health Care . .
c. Total Monthly Health Care Expenses $47.00 .
(line Ba plus line 8b)
{add father's and mother's totals from line 8cl $47.00
{multiply line 5 times .05) $45.55
(line Bd minus line Be., if "O" or negative, enter "O") $1.45
9. Dav Care and Special Child Rearina Expenses
a. Dav Care Expenses . -
b. Education Expenses . .
c. Lona Distance Transoortation Expenses - -
d. Other Special Expenses {describe)
visitation suoervision . .
- -
- -
e. Total Day Care and Special Expenses - -
{Add lines 9a throuah 9dl
(Combine amounts on line 9e) .
Expenses (line 8f plus line 10) $1.45
12. Each Parent's Obligation for Extraordinary Health Care,
Day Care, and Special Expenses $.97 $.48
13. Gross Child Sunnort Obliaation (line 7 Plus line 12) $609.52 I $302.93
Part IV: Child Support Credits (See Instructions, Page 7)
14. Child Sunnort Credits
a. Monthly Health Care Exoenses Credit $47.00 .
b. Day Care and Special Expenses Credit - -
.
. .-
- .
d. Total Suooort Credits {add lines 14a throuah 14c) $47.00 -
Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 8)
a. Amount from line 7 if line 4 is below
$600. Skio to Part VI.
- -
b. Line 13 minus line 14d, if line 4 is over $562.52 $302.93
$600 (see below if aaol.)
c. Amount on line 15b adjusted to meet 45% - -
net income limitation
d. Amount on line 15b adjusted to meet
need standard limitation
- -
Part VI: Additional Factors for Consideration (See Instructions, Page 8)
(Present estimated value of all maior assets.) Household Household
a. Real Estate - -
b. Stocks and Bonds - -
c. Vehicles - -
d. Boats
e. Pensions/IRAs/Bank Accounts
-
-
--
f. Cash - -
!]. Insurance Plans - -
h. Other: - -
-- -
--
17. Household Debt
-
(List liens against household assets, extraordinary debt.)
a. - -
b. - -
c.
d.
-- -
-
e. -- -
f.
-
a. Income Of Current Spouse
(if not the other oarent of this action)
Name
Name
-- -
-
b. Income of Other Adults in Household
Name - -
Name
c. Income of Children (if considered extraordinarvl
- -
Name - -
Name - -
d. Income from Child Sunnort
Name -- -
Name -
Continue to Next Page
WSCSS-Worksheets (CSW) 9/2000 Page 3 of 5
Father's Mother's
e. Income From Assistance ProQrams
Proo ram . .
Proo ram . .
. .
. .
19. Non-Recurrino Income (describe)
. .
. .
20. Child Sunnort Paid For Other Children
Name/age: . .
Name/age: . .

Husband's income based on payroll report through Jully 31, 2006. Wife's income is based upon her
attorney's representation of her income.

Signature and Dates

Date ,/""""\ City Date City

/I
v / A/
7I\
---
Jud~/Reviewing 0 1cer
-.........
Date
Worksheet certified by the State of Washington Administrator for the Courts.

WSCSS-Worksheets (CSW) 9/2000 Page 5 of 5 SupportCa/c"' 2005

....-------.,..-------------------- -- -- - -
FILED
(.J'i J~i,l 29 PM z: SI
1 r,•ML D!1Ntt:LS
'CClUH.TY CLlR,I\ SH
2 ·;,~lCtiOMISH CO.\;" ·
4 \\l\\l\\ \\\\\\ l\\ \\l\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\\ \\\\ \l\\
5 CL11946958
6

Petitioner,
Respondent. (MTSC)
12
I. MOTION
13
18 entered on November 7, 2006 in Snohomish County Washington.
20 Does not apply.
22 Granting sanctions for contempt, including a forfeiture for each day the contempt of court
23 any other relief, including reasonable attorney fees and costs and make up residential time,
24 Chapter 26.26 RCW, and RCW 26.18.040.
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CAUSE RE CONTEMPT (MTSC) - Page I Everett WA 9820 I
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 7081
1
1.4 OTHER:
2
3
his motion is based upon the declaration which follows.
4
5
CARL J. GAUL WSB
Attorney for Andre
6
7 II. DECLARATION
9
10
Jennifer LeSourd disallowed our child's residential time with me on Saturday, January 20,
11 2007.
12 Our parenting plan was entered on November 7, 2007. That parenting plan calls for our
daughter to have residential time with me on a supervised basis three times per week. One
13 of those times is on Saturdays.
14 Paragraph 3.1 of the parenting plan provides residential time "On Tuesday and Thursdays
for three (3) hours and on Saturdays for eight (8) hours each week." Paragraph 3.11
15 modifies this provision, " ... Exchanges shall be As per recommendation of case manager.
She has authority to lengthen or shorten the visit times." Since entry of the parenting plan
16 on November 7, 2006 the Saturday times have commenced at 11:00 a.m. The visitation
supervisor has been Judy Dyer, Bridget Llewellyn's assistant.
17
Bridget Llewellyn was the guardian ad litem before the divorce was final. She remains on
18 the case, but with the title of Case Manager under the permanent parenting plan. Bridget
has always communicated with me by telephone, occasionally in writing, but not by e-mail,
19 which she discourages. She checks her email infrequently. To my knowledge she
communicates in the same way with Jennifer LeSourd.
20
On January 12, 2007 Jennifer LeSourd sent an email to Judy Dyer at Bridget Llewellyn's
21 email address in which she expresses dissatisfaction with the Saturday schedule, but does
not suggest an alternative. She also announces that she and her attorney and her therapist
22 have decided that she will communicate with Bridget I Judy only by email.
23 On January 16, 2007 Commissioner Stewart heard a petition for an order of protection filed
by my former wife. (Case 07 2 00022 2) He denied the petition and dismissed it with
24 prejudice. My former wife and her attorney were both visibly upset by that ruling. The
very next day, Tuesday, January 17, 2007, she sent an email in which she announces that
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
MOT/DEC ORD SHOW CAUSE RE CONTEMPT (MTSC)- Page 2 Everett WA 9820 I
WPF DR 05.0100 (912000) - RCW 26.09.160 42S 259-4147 FAX 259 7081
1 the visit will be from 2:00 p.m. to 5:00 p.m. There is no reason she would have believed
that her email was actually read by anyone.
2
At 11:00 a.m. on January 20, 2007 I met Judy and we went to the exchange place, the
3 Safeway at Silver Lake. Our daughter was not delivered to the exchange place. Jennifer
LeSourd did not appear. Neither did anyone else who might have our daughter or
4 information about her. Judy called Jennifer LeSourd's cell phone number, leaving a
message. After some discussion with Judy, she and I decided that the visit would not
5 happen, though at that point we did not know why.
6 Nearly two hours later, after I had gone on to do other things, Jennifer LeSourd called Judy
Dyer back. A copy of her email to Bridget Llewellyn after that call is attached.
7
On Monday, January 22, 2007 I had my attorney write to Jan Dyer, Jennifer LeSourd's
B attorney suggesting that make up time be arranged. Copy attached. Ms. Dyer has not
responded to that letter. Since last summer Ms. Dyer has generally not responded to letters
9 from my attorney.
10 I have no alternative but to come to the court for assistance. Jennifer LeSourd had no
reason to believe the case Manager approved of or acquiesced in her choice to change the
11 schedule of residential time. I had no reason to know of her fiat at all. Since she already
knew email was not an effective method of communication, Jennifer LeSourd had no reason
12 to believe her communication had ever even been received by Bridget Llewellyn or Judy
Dyer. I am compelled to come to court or allow my former wife to limit the father-daughter
13 relationship. As a consequence, I am compelled to incur additional attorney fees which
should not be required. I am asking the court to award attorney fees in an amount
14 sufficient to compensate me for the fees incurred, approximately $1500, and also in an
amount sufficient to discourage Jennifer LeSourd from future similar violations.
15
16
Other:
17
18
19 I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
true and correct.
20
21
Signed atZ0~1 Wvl---
[City and State]
~ALMJJ£,f_
Andrew Scott Rife
22
Dated:
23
24
25
CARLJ.GAUL
26 At1orney at Law
27 1604 Hewitt Ave.
WPF DR 05.0100 (912000)- RCW 26.09.160 425 259-4147 FAX 259 7081
· · 14!002 ··········
rage 1 or ..i
From: Jennifer LcSourd

To: bb44@earthlink.net
Cc: dyerjanattorney@qwest.net
Date: 1/20/2007 12:56:20 PM
Subject: FW: visitation for saturdays
Bridget-
1 just checked my cell-phone. I have a message from Judy saying I missed visitation today from 11·2pm. I called
her back. I explained that I am not to talk to either one of you by phone only by e-mail. She became rather
argumentative on the phone and angry. I told her I would not argue with her and she basically hung up on me,
before getting out that your e-mail is down and someone is supposed to fix it. If this is true - you should h•ve let
me or my attorney know. I have sent numerous e-mails to you saying this is how our communication to take
place. After sending the below e-mail, and not hearing from you or Judy, I ~ad every reason to believe that 2-5pm
would be acceptable.
It is now barely 1pm - and Judy never even mentioned calling Andy and seeing if 2pm would be okay. She just
angrily asked me if we were still on for Tuesday and Wednesday. Why wouldn't we be?
These kind of phone calls Bridget (where both you and Judy lose your temper) are the reasons for me wanting
everything documented by e-mail.
Jan-
In light of everything going on with Bridget and Judy- I do almost feel uncomfortable doing any exchanges with
either one of them. Judy claims their e-mail doesn't work - but yet she doesn't return your phone calls either. Is
their office phone broken too? Hopefully you can get a hold of Bridget before the next visitation.
******************
.Jennifer R. LeSourd
Snohomish County Mobile Notary
14200 69th Dr. SE Un.it A-5
Snohum ish, WA 98296
Cellular (425) 345.4456
From• Jennifer L.eSourd [mailto:jennlesourd@comcast.net]

Sent: Wednesday, January 17, 2007 6:57 PM
To: 'bb44@earthlink.net'
Cc: 'dyerjanattorney@qwest.net'
Subject: visitation for saturdays
Importance• High
Bridget and Judy,
I have e-mailed several times about Saturday's visitation time. I agreed to last weeks 11-3pm because it was
short notice, but I do not agree with the following Saturday's being from 11-2pm. She misses her afternoon nap
and this is hard on her. In my previous e-mail, I mentioned how Judy even spoke with me about her being tired
and cranky. So I am going to assume that in the best interest of Lauren that 2-5pm will be agreeable. I need to
hear from you by Spm on Friday, otherwise I will go ahead and take Lauren to the Silver Lake Safeway at 2pm.
Thanks,
Jennifer
******************
file://C:\Documents%20and%20Settingslnick\Loca1%20Settings\Temp\70225B3E·FC2C-... 1/2112007
2
... iiRiDGiit. Li:Ewlii:i:YN .
@Joos
!:'age I OI I
From: Jennifer LeSourd

Date: 1/8/2007 3:22:10 PM
Subject: one last e-mail (for now)
I forgot to say - only if Wendy wants to receive the pictures. If she doesn·~ then I won't forward them to you
anymore.
Part of sending them was for you to see Lauren in her home surroundings and with me. Unlike with Andy, you
don't see me very often or with Lauren. You seemed to intimate in your last lener to Jan that I was putting Lauren
and her well-being at rtsl< by asking Judy Dyer to serve Andy. I honesUy didn't think it was a big deal. I didn't tell
Judy to - I asked her to. She said no, and explained why. I then said I understood and that is was no big deal.
This in no way damaged Lauren. I am a wonderful Mother and wouldn't do anything to risk her well-being as you
suggested.
Since you believe I twist words around as you suggested in your most recent letter to Marian, and in the past to
Jan - I would like ALL of our communication to be by e-mail. And only then if necessary.
At this juncture, I wished I hadn't sent you those e-mails. I really don't have anything to prove. It shows for itself.
Lauren is a happy, healthy little gir1 who charms everyone and anyone.
I know Jan will be getting a hold of you soon as I just talked to her regarding the meeting she wants to have. In
light of many things going on - and being Case Manager, don't you suppose that would be good idea?
Communication is always important. Especially between professionals.
Lastiy, I will be starting school at PIMA Medical Institute for a Phlebotomy course starting Jan. 22nd_ That will be
Mon-Thurs 6-1 Opm for 9 weeks. Then I will have a daytime 8 hour extern ship at a hospital. Then of course - I
start my nursing prerequisites at Shoreline Spring quarter. Sy that time I will be able to work as a phlebotomist
part-time at a clinic or hospital.
So - we will have to come up with a way for Lauren to be picked up from visitation. More than likely I will be able
to dmp her off, but not pick her up.
Jennifer R. LeSourd
14200 69th Dr. SE Unit A-5
Snohomish, WA 98296
Cellular ( 425) 345.4456
file ://C :\Documents%20and%20Settings\nick\Local %20Settings\Temp\799 SD E82-8DFC-... 1/2 I /2007
5
Cc: dyerjanattomey@qwestnet
Date: 1/12/2007 1:54:55 PM
Subject: visitation schedule
., ·-·-··· ... "'' ······--·-----·.. ...-····--··--· .. ·······-···--·--·-····-· - .... ·-·-- .. ···-·
Judy,
Thank you for your message -1 appreciate that you talked with Andy and you guy's found a schedule that suits
you. For now - 3-6pm during the week is fine. Although I have a job interview in Bellevue this week at Overlake
Hospital. so my schedule could very easily change. I will let you know on that I don't agree with Saturday's
schedule. The 11am-2pm that is. Remember we discussed how tired Lauren was being brought back from
visitation without a nap? This was your observation (you said she seemed cranky and tired and asked me about
naps). I think 3-6pm would be a lot easier on Lauren. She's very active and still only 2, so most of the time she
depends on a 1 to 1 °l'> hour nap. Hopefully WE can all get this worked out.
Also, like I've said in previous e-mails, I am responding only by e-mail. This was both mine, my attorney's and my
therapist's idea.
Jennifer
PS - court on Tuesday starts at 1pm. I'm sure ;rs going to be a circus, so we may have to revise the visitation
time. I guess we'll see.
******************
Jennifer R. LeSourd
Snohomish, WA 9S296
Cellular (425) 345 .4456
file:l/C:\Documents and Settings\nick\Local Settings\Temp\49677778-439D-4F6F-AA52-... 1/26/2007
1
iiRiDGET LLEWELLYN ........... ········· ........ @ooa·. ..
Page I ot 1.

Date: 1n12007 9:34:46 AM
Subject: FW: Emailing: 011_9.JPG
******************
Jennifer R LeSourd
Snohomish, WA 98296
Cellular (425) 345.4456
---Original Message-----
From: Jennifer LeSourd [mailto:jeiml.i;:sourd@comcast.n~_t]
Sent: Sunday, January 07, 2007 9:33 AM
To: Jan Dyer (JanPyer@qwesJ.net)
Cc: '.Q:JetjanattQJ:Iley@wi;~.net'
Subject: Emailing: 011_9.JPG
Importance: High
I could send fifty more pictures, but will settle for these.
Perhaps Andy would like to see them as well. He is ALLOWED 14 hours per week
supervised visitation. He has yet to take advantage of that.
ln fact - according to my calender ... It's been more on the average of twice
a week, for two hours.
That is a crazy schedule for Lauren.
Hey Brig,
J have an idea ...
Think of something good for LAUREN. Including nap time.
Bridget - in the beginning ... You thought I was weak. ln the end you thought
Twas over-bearing.
All I care about is Lauren. I would do just about anything for that little
girl.
I look forward to your meeting wi.th Jan. And Don. And perhaps Marian. :-)
Or at the least - her notes.
Jenn
file://C:\Documents and Settings\nick\Local Settings\Temp\ELP38B2.trnp 1/23/2007
3
(oh ... and as far as your last letter goes ... Jan does NOT need to inform me
of anything. "Relax!"
The message is ready to be sent with the following file or link attachments:
011_9.JPG
Note: To protect against computer viruses, e-mail programs may prevent

sending or receiving certain types of file attachments. Check your e-mail
security settings to detennin~ how attachments are handled.
file://C:\Documents and Settings\nick\Local Settings\Temp\ELP38B2.tmp 1/23/2007
4
CARLJ.GAUL Attorney at Law 425 259-4147 fax 425 259-7081
Admitted to practice.in Washington, Oregon and California 302 Bank of America Building
1604 Hewitt A venue
Everett WA 98201
January 22, 2007 Fax only to 206 343 7781

503 Twelfth Ave. East RE: Father's Residential Time
Seattle WA 98102
Dear Ms. Dyer
Today I learned that Ms. LeSourd failed to appear for transfer of Lauren at the
commencement of Mr. Rife's residential time on Saturday. Consequently, Lauren was
deprived of three hours residential time with her father.
Ms. LeSourd should pay Ms. Dyer the $120 cost for the time not used due to her
non-appearance.
We propose that this time should be made up by extending Mr. Rife's time by
three hours this coming Saturday. Mr. Rife would also consider an additional 3 hour
visit on a weekday if Ms. LeSourd prefers.
Please do respond promptly as Mr. Rife wants to have a definite plan in place
before the next weekend. I will be reviewing this matter on Friday, January 26, 2007.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife

Judy Dyer
Bridget Llewellyn
Don Layton
CARLJ.GAUL Attorney at Law 425 259-4147 fax 425 259·7081
1604 Hewitt Avenue
Everett WA 98201

503 Twelfth Ave. East RE: Father's Residential Time
Seattle WA 98102
Dear Ms. Dyer

Today I learned that Ms. LeSourd failed to appear for transfer of Lauren at the
commencement of Mr. Rife's residential time on Saturday. Consequently, Lauren was
deprived of three hours residential time with her father.
Ms. LeSourd should pay Ms. Dyer the $120 cost for the time not used due to her
non-appearance.
We propose that this time should be made up by extending Mr. Rife's time by
three hours this coming Saturday. Mr. Rife would also consider an additional 3 hour
visit on a weekday if Ms. LeSourd prefers.
Please do respond promptly as Mr. Rife wants to have a definite plan in place
before the next weekend. I will be reviewing this matter on Friday, January 26, 2007.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Judy Dyer
Bridget Llewellyn
Don Layton
2007 JAN 30 AM 10: 08
2
1111/lll llllll Ill lllll 1111/ lllll lllll lllll 111111111111111111 PAH L. DANIELS
SNOHOMISH CO. WASH.
4

COUNTY OF SNOHOMISH
7
8
In re:
Andrew Scott Rife
9
and
NOTICE OF CONTINUING REPRESENTATION
10
Jennifer Rae LeSourd, fka Rife
12
O: CLERK OF THE ABOVE ENIDLED COURT
13 NOTO: Jennifer Rae LeSourd
Jan Dyer, Attorney for Jennifer Rae LeSourd
14
YOU AND EACH OF YOU will hereby take notice that Carl J. Gaul continues to
15
represent the above-named Andrew Scott Rife. This representation shall continue until
a notice of withdrawal is filed with the court.
16
Except original process, Andrew Scott Rife requests that all further pleadings, papers
17
and motions be served upon his undersigned attor at the address indicated below.
18
19 Dated January 29, 2007
20
21
22
23
24
25
26
CARLJ.GAUL
27
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
., _... ,
\.·' ~·
"".;"' ,. " r: -••~- \

' , .
I\\\\\\\\\\\\\\\\\\\\\\\\\\\\I\\ \Ill\\\\\\ \II\\ 1\11\ 11\11\\1 1
CL12052582
2001 FEB 20 i1i·i 10: 24
I. . L. ;;; : :1.:LS
c:iu::ry c1..Em1
s:rn.:c-: :ISH C-1. '.'.'ASH.
IN THE SUPERIOR COURT FOR THE STATE OF WASHINGTON

COUNTY OF SNOHOMISH
)
In re: )
Andrew Scott Rife ) No: 05-3-02755-1
Petitioner )
) Case Manager Statement
And ) Time and date of hearing
Jennifer Rae Rife ) 02-).l-DY°
Respondent. )
)
It has always been my understanding that the idea of having a Case Manager
was in part to keep the case from continued litigation. In talking with colleagues
who also provide this service that is also their understanding.
For all intents and purposes this case is finished except for the need of the father
to successfully continue his Domestic Violence Treatment and attend the
specified Parenting Classes as outlined in the agreed Parenting Plan.
I am not going to make much comment on the content of the correspondence

that continues to spew forth in this highly contentious and litigious case. I do not
wish to be a party to this type of rhetoric and abysmal behavior. Nor will I be
drawn into trading insults and or making accusations that are based on half-
truths.
I will say that I do not believe that it would matter who the Case Manager is in
this case, as long as they have an independent thought process they too will find
themselves in the same position.
1
Bridget Llewellyn
Guardian Ad Litem
3114 Oakes Ave.
Everett, WA.9820 I
425-339-2382
tf::I OmGtNAL
!'
•
Quite frankly, given the need of at least one of the Attorneys to control absolutely
everything in this case, I am not sure that a Case Manager is at all effective and
or necessary. What is the point as long as they have no authority to do the job?
Since there is a Case Manager I believe that it is imperative in this case for us to
have a very clearly delineated outline of what authority that Case Manager has or
does not have. Without that determination/clarification this nonsense will
continue.
I have outlined some of the things that I think should apply:
The case manager shall be authorized to contact both parties directly by

telephone mail and e-mail. Because of the nature of these cases and the need to
sometimes make very quick decisions in re: times of visits , sickness,
emergencies etc. Telephonic contact shall be the primary method of
communication.
The Case Manager shall be authorized to contact the child directly if she feels it
is appropriate, or to visit either parent's residence without notice.
The Case Manager shall be authorized to change the days and times of visitation
in keeping, in so far as it is possible, with both parents' schedules and the routine
of the child.
The Case Manager shall be authorized to set where the exchanges will be and
how long the visits shall last.
I am asking the Court for some clear direction in this case so that whether it be
me or someone else we will know the exact scope of our role as directed by the
Court and not by either Attorney.
his 1~of c::_ry 2007
~~~g;w~e~llyn G.A.L.
Bridget Llewellyn
Case Manager
3114 Oakes Ave.
Everett WA. 98201
425-339-2382
/
FILED
2001 MAR 22 AH II: 31
PAH L. DP.NIELS
COUNTY CLERK
SNOHOMISH CO. WASH.
I lllllll l l l Ill lllll lllll 111111111111111111111111111111111
CL 12220111
6
UNSIGNED
7
COUNTY OF SNOHOMISH
ORDER
Andrew Scott Rife
9 Petitioner, NO. OS 3 027S5 1
and
10 PARENTING PLAN
Jennifer Rae Lesourd, fka Rife )1~PROPOSED (PPP}
11 Respondent. [ ] TEMPORARY (PPT}
[ ] FINAL ORDER (PP}
12
13 [ ] the final parenting plan signed by the court pursuant to a decree of dissolution entered
on [Date].
14 [ ] the final parenting plan signed by the court pursuant to an order entered on
" ' " " " - - - - [Date] which modifies a previous parenting plan or custody decree.
15 [ ] a temporary parenting plan signed by the court.
[xxx] proposed by Andrew Scott Rife
16
IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
17
I. GENERAL INFORMATION
18
his parenting plan applies to the following child:
19
Name Age
20
Lauren Emily Rife 2
21
22
11. BASIS FOR RESTRICTIONS
23
contact with the child and the right to make decisions for the child.
24
25
2.1 PARENTAL CONDUCT (RCW 26.09.191(1), (2)).
26 CARLJ.GAUL
Attorney at Law
PARENTING PLAN (PPP. PPT, PP) - Pagel

ORI G'/I~v· /iL I 604 Hewitt Ave.
EverettWA98201
WPF DR 01.0400 (912001) - RCW 26.09.181; .187; .194 ' /'j 425 259-4147 FAX 259 7081
1 Does not apply.
2 2.2 OTHER FACTORS (RCW 26.09.191(3)).
3 Does not apply.
4 III. RESIDENTIAL SCHEDULE

5 The residential schedule must set forth where the child shall reside each day of the year,
6 occasions, and what contad the child shall have with each parent Parents are encouraged to
create a residential schedule that meets the developmental needs of the child and individual
7 needs of their family. Paragraphs 3.1through3.9 are one way to write your residential
schedule. If you do not use these paragraphs, write in your own schedule in Paragraph 3.13.
8
3.1 SCHEDULE FOR CHILD UNDER SCHOOL AGE
9
Prior to enrollment in school, the child shall reside with the mother, except for the
1 o following days and times when the child will reside with or be with the other parent:
11 Every Tuesday from 4:00 p.m. to 7:00 p.m.

Every Thursday from 4:00 p.m. to 7:00 p.m.
12 Every Saturday from 11:00 a.m. to Sunday at 11:00 a.m. for six weeks from the date
this parenting plan is adopted by the court. Thereafter, from Friday at 4:00 p.m.
13 through Sunday at 7:00 p.m. on alternating weeks. The father's first such Friday
pickup shall occur on Friday, - - - - - - - - - - - -
14
3.2 SCHOOL SCHEDULE.
15
16
3.3 SCHEDULE FOR WINTER VACATION.
17
18
3.4 SCHEDULE FOR SPRING VACATION.
19
20
3.S SUMMER SCHEDULE.
21
22
3.6 VACATION WITH PARENTS.
23
24
3.7 SCHEDULE FOR HOLIDAYS.
25
The residential schedule for the child for the holidays listed below is as follows:
26
CARLJ.GAUL
Attorney at law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1
2
Odd/Even/Every) Odd/Even/Every)
4
New Year's Day Odd Even
5
Memorial Day None Every
6
July 4th Even Odd
7 Every None
Labor Day
8 Veterans Day
9 Thanksgiving Day Even Odd
10 Christmas Eve None Every
Christmas Day Every None

11
12 For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
13
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
14
Other: Many legal holidays are not listed in this paragraph. The child's residence on
15 those days is to be governed by other paragraphs of this parenting plan. If an
unlisted legal holiday falls within a parent's scheduled time, that holiday will be
16 spent with that parent.
1 7 3.8 SCHEDULE FOR SPECIAL OCCASIONS.
1s he residential schedule for the child for the following special occasions (for example, birthdays)
is as follows:
19
21
Mother's Day every none
22
Mother's Birthday every none
23
Father's Day none every
24 Father's Birthday none every
25 Child's Birthday even odd
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT. PP)- Page 3 Everett WA 9820 I
WPF DR OI.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1
[l Other: Special Occasions shall be from 10:00 a.m. to 7:00 p.m. on the day of the
2 special occasion only. Exchanges for special occasions shall be as
provided in paragraph 3.11.
3
3.9 PRIORmES UNDER THE RESIDENTIAL SCHEDULE.
4
Does not apply.
5
3.10 RESTRICTIONS.
6
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
7
3.11 TRANSPORTATION ARRANGEMENTS.
8
Transportation costs are included in the Child Support Worksheets and/or the Order of
9 Child Support and should not be included here.
Transportation arrangements for the child, between parents shall be as follows:
10
Exchanges shall occur at the Safeway at Silver Lake.
11
Either or both parent(s) may have an immediate family member present at the
12
exchanges as a moral supporter. The moral supporter shall remain at a distance from
the parent(s) and shall refrain from any negative verbal exchange.
13
Either or both parent(s) may have an immediate family member who is licensed and
14 insured transport the child to and or from the exchange if the parent(s) are unable to do
so themselves. Those persons shall conduct themselves in an appropriate and respectul
15 manner at all times. They shall limit their communication strictly to information
concerning the child and the child's needs.
16
1 7 3.12 DESIGNATION OF CUSTODIAN.
The child named in this parenting plan are scheduled to reside the majority of the time
18
with the mother. This parent is designated the custodian of the child solely for purposes of all
other state and federal statutes which require a designation or determination of custody. This
19
20
3.13 OTHER.
21
1. The father shall successfully complete the DV Dads program and the Respectful
Parenting programs at Family Services in Seattle. This parenting plan shall be subject to
22
modification if recommended by the Case Manager or agreed by the parents upon
father's completion of those two programs.
23
2. Bridget Llewellyn remains appointed as Case Manager.
3. At such time as the Case Manager determines that the residential schedule should be
24
changed, she will write a report and make recommendations. The parties may agree to
those recommendations or modify those recommendations by their agreement. Absent
25
written agreement there shall be no change except by court order. The Case Manager
26
CARLJ.GAUL
27 Attorney at law
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT, PP)- Page 4 Everett WA 9820 I
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 Ff\Y. 259 7081
1 shall remain appointed until such time as all requirements under this section are
completed. She may, from time to time, write interim reports and recommendations.
2 She shall write a final report which shall include a statement of any changes to the
parenting plan she may recommend at that time.
3
4. The Case Manager shall have authority as follows:
4 A. The case Manager shall communicate with all parties and professionals working
with the parents. Each parent shall sign authorizations for release of information
5 to the Case Manager for all information concerning the child from any person
who may possess relevant information concerning the parents and the child.
6 B. The Case Manager is authorized to contact each party directly by telephone, mail
and e-mail. Because there is a need for quick communication and decision
7 making concerning times of exchanges of the child, sickness and emergency or
situational information, the primary method of communication will be by
8 telephone.
C. The Case Manager is authorized to contact the child directly.
9 D. The case Manager is authorized to visit each parent's home without prior notice.
E. The case Manager is authorized to change the days and times of the parents'
10 time with the child to accommodate their work schedules and the routine of the
child.
11 F. The case Manager is authorized to regulate the exchanges of the child, including
the times, places, manners and persons who may be present during those
12 exchanges.
G. The Case Manager is authorized to change the durations of the parents'
13 residential time.
14 3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A CHILD.
15 This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
16 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.
17
If the move is outside the child's school district, the relocating person must give notice
18 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
19 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
20 26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A Child).
21 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
22 to the move but may ask for modification under RCW 26.09.260.
23 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
24 and safety.
25 If information is protected under a court order or the address confidentiality program, it

may be withheld from the notice.
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187: .194 425 259-4147 FAX 259 7081
. '
1 A relocating person may ask the court to waive any notice requirements that may put
2
3
If no objection is filed within 30 days after service of the notice of intended
4 relocation, the relocation will be permitted and the proposed revised residential
5
A person entitled to time with a child under a court order can file an objection to the
6 child's relocation whether or not he or she received proper notice.
7 An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
s Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
9
11 If the objecting person schedules a hearing for a date within 15 days of timely service of
child.
13
IV. DECISION MAKING
14
4.1 DAY-TO-DAY DECISIONS.
15
16 he 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
17 he child.
18 .2 MAJOR DECISIONS.
19 Major decisions regarding each child shall be made as follows:
20 Education decisions joint

Non-emergency health care joint
21 Religious upbringing joint
22 The issue of whether the child will attend public or Catholic schools shall be reviewed by
the parents when the child attains the age of four years. If there is disagreement
23 between the parents, the issue shall be determined as provided in part V of this
parenting plan.
24
4.3 RESTRICTIONS IN DECISION MAKING.
25
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.
26
CARLJ.GAUL
27 Attorney at law
302 Bank of America Bldg,
1604 Hewitt Ave.
WPF DR 01.0400 (912001) - RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
. .'
3 • DISPUTE RESOLUTION
4 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
5 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.
6
Disputes between the parties, other than child support disputes, shall be submitted to
7 (list person or agency):
9 he cost of this process shall be allocated between the parties as follows:
1o based on each party's proportional share of income from line 6 of the child support
worksheets of the most recent order of support.
11
12 he counseling, mediation or arbitration process shall be commenced by notifying the other

party by written request by certified mail.
13
14
resolve disputes relating to implementation of the plan, except those related to financial
16 support.
18 process without good reason, the court shall award attorneys' fees and financial sanctions to the
other parent.
19 (e) The parties have the right of review from the dispute resolution process to the
superior court.
20
[] No dispute resolution process, except court action is ordered.
21
22 I. OTHER PROVISIONS
24 The parents shall communicate with each other by email. The parents shall each strictly
limit their communication in those emails to information concerning the child. If an
25 emergency exists the parents shall try to contact the case Manager and/or her assistant
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 Ff>:!. 259 7081
1 by telephone and one of them shall then attempt to contact the other parent to
communicate the information.
2
3 II. DECLARATION FOR PROPOSED PARENTING PLAN
4 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
5 correct.
6
~ ~ rz~
Andrew Scott Rife
.:i.ltf'v7. c;.,~
DatETan Place of Signature
WW--1
7
8
9 III. ORDER BY THE COURT
10 It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and
approved as an order of this court.
11
WARNING: Violation of residential provisions of this order with actual knowledge of its terms
12 is punishable by contempt of court and may be a criminal offense under RON 9A.040.060(2) or
9A.40.070(2). Violation of this order may subject a violator to arrest.
13
When mutual decision making is designated but cannot be achieved, the parties shall make a
14 good faith effort to resolve the issue through the dispute resolution process.
15 If a parent fails to comply with a provision of this plaAn

plan are not affected. 1) p
the other parent's obligations under the
0
16
17
Dated: 9(_ CJ OS G~~
Judge/ Commission~~
18 Presented by: Copy Received: 'a ~
19 ~
20
CARL J. GAUL WSBA# 8341 JAN DYER WSBA# 20355
21 Attorney for Andrew Scott Rife Attorney for Jennifer Rae LeSourd
22
23
24
25
26
CARLJ.GAUL
27 Attorney at law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181: .187; .194 425 259-4147 FAA 259 7081
FILED
u·1 APR -5 PM 2: 22
SUPERIOR COURT OF 1°Aii L. Df..NIHS
WASHINGTON COUNT"( CLER!\
)NOHOHISH CO. \'{f, SH.

(PETITIONER) PRO TEM COMM: DAVID.T. PATTERSON
AND CLERK: S. HUBER
JENNIFER RAE RIFE NKA LESOURD DATE: 04/05/07 AT 9:00 A.M.
(RESPONDENT)
THIS MATTER CAME ON FOR: MODIFY PARENTING PLAN

CONTINUED DATE/TIME/CALENDAR AND CONTINUANCE CODE:
HEARING DATE SET/TIME/CALENDAR CODE:
ACTION:
DOCUMENTS FILED:
THE COURT FINDS IT APPROPRIATE THAT THE CURRENT PARENTING PLAN SCHEDULE
rs FOLLOWED AND PETITIONER'S VISITATION WITH THE CHILD WILL BE WITHOUT
SUPERVISION FOR 60 DAYS. AFTER THAT, THE PETITIONER rs TO HAVE ONE OVERNIGHT
VISIT A WEEK WITH THE CHILD FOR 60 DAYS.
PETITIONER rs TO VISIT WITH THE CHILD FROM 3 TO 8 P.M. EASTER SUNDAY IN
ADDITION TO HIS SATURDAY VISIT.
THERE rs TO BE A REVIEW HEARING UNLESS PARTIES ARE ABLE TO COME TO AN
AGREEMENT.

-
/SJ
J
'....
,.,.,.1 1.·._.
I~
~
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.. _ l
I
07 APR 27 t~i-110: 27
PAI-\ l. DAt;!ELS
COUNTY CLERK
SNOHOH!SH CO. \!/ t. SH.
\~\~CL~\ 12202537
\ \\~U\\I\~\ \ Il \ \ \ \
\\\\\\\\ \\\ \\\\\\\\\\

CASE NO. 05-3-02755-1
ANDREW RIFE CALENDAR NOTE: (NTC)

Petitioner
FAMILY LAW MOTIONS

vs. than twelve (12) calendar days preceding
motion must be filed five (5) £!!!!!! days before the
JENNIFER RIFE hearing. Replies to responses must be filed three (3)
Respondent court days before the hearing.
FAMILY LAW/DOMESTIC CALENDAR Date Requested May 9. 2007

Daily at 9:00 a.m.
Department B or C as assigned. Nature of Hearing: Child Care Expensesdsf
(Confirm at (425 388-3587)
CHILD SUPPORT MODIFICATIONS Date Requested (mm/dd/yyyy): _ _

Fridays at 9:30 a.m. Department D Nature of Hearing: _ _
(Confirm at (425 388-3587)

Wednesday at 12:30 p.m. only Date Requested (mm/dd/yyyy): _ _
Department C
Court Commissioner here:
S.\Web Forms\Clerks Office\word\DomfamilyLawCalendaTNote doc RRU:07/0l/2003 I of2

.·.....
SCLCR 7(b)(2)(H).
FOR MATTERS NOTED BY COUNSEL:

I hereby cenify that I messengered a copy of this
document
to the attomeys/panies listed below, postage prepaid
on the:
Date April 26, 2007

GEORGIA ROSS D Petitioner/Plaintiff
X Respondent/Defendant

Failure to do so may result in your hearing not
FAMILY LAW/DOMESTIC MOTIONS: Most are heard on a Coun Commissioner's calendar. The exceptions
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar or Coun Commissioner

3000 Rockefeller Ave M/S 605 3000 Rockefeller Ave
s. \Web Fonns\Clcrks Officc\word\DomfamilylawCalcndarNote doc RRU.07/0112003 2 of2

l
1
2
07 f:· 0 h·' 27 f", J'O·• (.."7
• 11 I
3 Pt.i1 !.. DA(!ltLS

(;rJUr'TY CcE~.;
StJOtlCJiiJSH CO. ·rt A SH.
4
5
: Illlllll llllll Ill lllll lllll lllll lllll lllll l/1111111111111111
6 I CL12202538
7
County of Snohomish
9
11 ANDREW S. RIFE, No. 05-3-02755-1

12 Petitioner,
and Motion and Declaration for
13 Order Requiring Obligor to Pay
14 JENNIFER R. RIFE, Education Related Day Care
Respondent Expenses
15 MTAF
16
I. RELIEF REQUESTED
17
The respondent respectfully requests this court to enter an order requiring Andrew Rife to
18
19 pay his proportionate share of day care expenses necessitated by the mother's attendance at
20
school leading to employment, including an unpaid extemship.
21
ll. STATEMENT OF FACTS
22
23 Our order of child support states that we will share proportionately the cost of work
24
related day care expenses for our daughter. During our marriage I had a small business as a
25
Notary Public for escrows. During the divorce process it became clear to me that I would not be
26
27 able to support myself on the income I produced from the notary business. At the urging of my
28
therapist I started looking at schooling. I am hoping to ultimately become a nurse but I realized
29
that I needed a quicker job that I could work in while going to nursing school. Ultimately I
30
MOTION TO DISMISS Dyer & Primont

503 Twelfth Ave. E
Page I _._.. ···-.
Seattle, WA 98102 A\
ORIGINAL (206) 343-1528 5'
·. \
1 decided to attend PIMA Medical Institute and take their Phlebotomy Technician Program. The
2
class work component of the program runs from January 29, 2007 through April 27, 2007 plus
3
200 hours worked in an unpaid externship beginning April 2"d. (See attached Ex. A).
4
5 The classes at PIMA are Monday through Thursday from 6:00 p.m. to 9:50 p.m. which
6
makes finding daycare really difficult. Very few daycares are even open in the evenings. After
7
checking out several options my mother agreed that she would be willing to provide the child
8
9 care for Lauren while I went to school. However, she was not willing to do it for free because it
10 cuts in on the time she can devote to her full time job as a real estate agent.
11
We were in court in mid-February and at that time my attorney told Andy and his attorney
12
13 that I had started school and there were now daycare costs for Lauren. She explained to them
14 that my mother was caring for Lauren because it was in the evenings. Andy was very agreeable
15
to this and stated that he certainly would pay his share of the day care costs. I was quite surprised
16
17 but pleased that it seemed we were finally going to be able to have something happen in this case
18 without having to go to court over it. My happiness was shorted lived.

19
My attorney followed up that conversation with a letter to Andy's attorney, (attached as
20
21 Exhibit B). At that point the total costs for daycare for the first month was $865.00 and Andy's
22 share of that was $579.55. Three weeks later my attorney received a letter back from Andy's
23
attorney (attached as Exhibit C) saying they had essentially changed their minds and now Andy
24
25 was not willing to pay any portion of the daycare costs because it was for school and therefore is
26 not "work related."

27
He asserts in his letter that I am going to night school, "to land a $12.00 per hour job" and
28
since my income is imputed at $16.15 per hour (the Notary Business if it was working at its
29
30
Page 2 503 Twelfth Ave. E
ORIGINAL Seattle, WA 98102

(206) 343-1528
. ·,
1 fullest potential and I was never home with my child) there is no way this is "work related." The
2
truth is 1 am going through this program so that 1 can work in the medical field which will give
3
4 me a much better chance of getting into Nursing School, which is very difficult to get in to.
5 1 don't believe my ex husband has any right to tell me what type of job 1 can hold or more
6
to the point, tell me that he will only pay daycare if I am making a certain amount of money
7
8 doing it. Does he mean by this that when I start working as a Phlebotomist Technician he is only
9 willing to pay for his share of daycare if 1 am making more than $16.55 per hour? Andy has
10
some very serious issues with having power and control over me and it is clear that he has still
11
12 not been able to give that up, despite over two years of Domestic Violence perpetrator programs.
13 Before Andy simply said he would not pay any daycare, he was insisting on only paying if
14
I provided proof to him of actual payment of my share, (Exhibit D). Under Andy's rules 1 would
15
not be able to do something "in kind" for my mother for my share, or pay her in cash or any way
16
17 other than the way Andy wants me to do it, via check with the front and backs copies to prove
18
apparently that my mother actually cashed it. Again, his problem with power control issues. It
19
does not seem like my share or how I pay it is any of his business. For one thing 1 don't even
20
21 have a checking account at this point.
22 My extemship started on April 2"d and now, instead of being gone in the evening I am
23
wo'rking (unpaid extemship) from 7:30 a.m. to 4:30 p.m. While my mother was able to care for
24
25 Lauren in the evenings she could simply not take on the task of watching Lauren all day Monday
26 through Friday; she would simply have to quit selling real estate if she did that. I was able to get
27
Lauren enrolled in a very good daycare close to my home and she just started this week. My
28
29 mom watched her during the day for the first two weeks unti I she got accepted to this daycare.
30
MOTION TO DISMISS
Dyer & Primont
503 Twelfth Ave. E
Page3 Seattle, WA 98102
ORIGINAL (206) 343-1528

1 My mother charged $10.00 per hour for care provided in the evenings. She provided this
2
care at my home so that Lauren was able to be put to sleep in her own bed. She also provided the
3
transportation to and from visitations so that there was no disruption in Andy's time due to my
4
5 school. This would not have been the case had I had to put her in an evening daycare program,
6
even if I could have found one. For the one week that my mother watched Lauren during the day
7
she only charged us $8.00 because it was daytime and did not involve having to be at my home
8
9 or put Lauren to bed. We both looked in the paper and the internet to compare hourly rates.
10
Much of what 1 found is attached as Exhibit E. Most evening nannies charged $14.00 or more
11
per hour.
12
13 My mother created invoices for Andy and I to have to that we can keep track for tax
14 purposes and so that she can as well. She understands that she will have to report this income
15
and file a schedule C with her tax return. The invoices for the hours that she kept Lauren while I
16
17 was at school or my externship are attached as (Exhibit F). The total owed my mother is
18 $2,198.00; Andy's 67% of that is $1,472.66. I would ask that Andy be required to pay this
19
amount quite quickly as it is for work my mother already did in January, February, March and
20
21 April after Andy agreed to her doing it and to paying his share.
22 The cost for the Montessori Day Care is $856.00 per month and Andy's share is $573.52.
23
Tuition is due on the first of the month and considered late after the IO'h (additional 20%). I am
24
25 attaching both the application for admission as well as the policy information I received when
26 enrolling her, (Exhibit G). The cost will not change from month to month and Andy can simply
27
send his check directly to the day care on the first of each month. For April they are pro rating it
28
for only two weeks plus a $150.00 registration fee. April's total is $578.00; Andy's 67% share of
29
30
Page4 503 Twelfth Ave. f
ORIGINAL
Seattle, WA 98102
(206) 343-1528
04/21/2007 00:34 4253041333
that is $387.26 which should be paid directly to the day care center immediately.
Iii. STATEMENT OF ISSUES

1. Is day care, which is necessitated by the mother's educational pursuits aimed at
full time employment work-related?

IV. EVIDENCE RELIED UPON
Exhibits A-G.
V. AUTHORITY
RCW 26.19.080.
Respectfully submitted this -z-<;" day of . A ~, ~ \ , 2007.
I have read the factual portion of this motion and assert that it is based on my personal
knowledge. Under penalty of perjury of the laws of the state of Washington I have signed and
dated this document in Seattle, Washington on April c:flO 'fJ.;2001.
MOTION TO DISMISS
Pages
ORIGINAL
n
_ ____,PIMA
MEDICAL
--=i INSTITUTE 9709 Third Avenue NF., 11400 • Senttlc, Wnshiu~1on 98115
LJ
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JO ANN 1.l:P.n..:F.
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Hlf:llAHI) 1.. 1.f/f.lil..'.l~.Jk
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.\1AHK I'. J.t:•:nt.:I·: March 8, 2007

(.'hil•r 01Mrnti11i1 Ol1K:1:r'
tit:OH.Cii'; IHIHClll(lt!'
(.'.11111pm Ulrn•t111· To Whom It May Concern:
Jennifer Rife-Lesourd is a full-time student in our Phlebotomy Technician

Mr\IN{-\Ml'l'S
,l.\/11111. 1",nant kd.. fll<tll
Program. She began the program on Jnnuary 29, 2007 and i~ projected to
Tut110111, Ari7•111J1 ft~716 complete the program on April 27, 2007. Her current school hours are
hnn •'.~bum
Cu1111111• llln11:111r Monday through Thursday, 6:00 pm to 9:50 pm. Beginning April 2, 2007,
she will be on a full-time cxternship from 7:30 am to 4:30 pm. She must
complete 200 hours of extemship.
AL!UIT!O:S-\1 b(H')TI!!'\;>
Al IUl(}!WICOIJI} I 'AMf!IS
lf you have any questions, please tee! free to contact me.
ZlOI "m• l'll'•h" !"I·; ll·J 111(111
Al11•1111•1"1')Hf, f\M 117110
I hllly 'Yn"ltwr Sincerely,
(:11m11u• Ulnch•r
'>!'i'J.-.:, l),1l1•nn Mol,

C.t.Lb-lt YL1;-6.i.. ·"' ..._q_ · "- •
M~"'•· /\./, ll~:U2
r1irl•lt1ph1•r l.11rhk~
c ........... 1~in..;h1r Carole Mizumori
Associate Director
DfNYl•ll C"AM!'l!S
17111 W.7lndA•1·,lll,lll
n ... ,.H, (.;I) 1111121
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Phone (206) 322-6100 • Fu, (206) 324-1985 • www.pmi.edu EXHIBIT ..-!A~-

t •d
.
Dr'ER & PR/MONT
503 Twelfth Avenue E<lst
Se<1ttle, W<1shington 98102
J~n Dyer, Attorney Amy Pasco, Paralegal

Michael Ptirnont." Attorney Georgia Ross, Legal Assistant
~~:ir.r.,rr
. v.,,w,
. I / 1:- i1 '.I
February 23, 2007

FEB 2 7 liEC'J
CA!<L j. GAUL
Carl Gaul. Attorney at La>:"i
ff"':irr~/Ri
1604 Hewitt Avenue
Everett, Washington 98201 trde, ~ EVi!!fffJ
FEB 2 8 ZOD7
LAW c;=-.::c-= OF
.JAN I\'/, DY~fl
Dear Mr. Gaul:
As I mentioned to you and Andy after court the other day, the fact that Jennifer is now in
school necessitates day care expenses for Lauren. Carol Holland has agreed to provide this service
instead of Jennifer being.force to place Lauren in an unfamiliar daycare setting. I would also note
that most of the care is in the evenings and it would be nearly impossible to find a daycare center
that is open for those hours. I was glad to hear Andy indicate that this too was his preference and ·.
that he did not mind paying for daycare for his child. · ·
I also mentioned that I see no reason that these invoices should have to be passed from Carol
to Jennifer to me and then to you and from you to Andy. We are proposing that Carol send these
invoices directly to Andy on ·a monthly basis and he can send his share of the paymertt directly to
her. Of course I would encourage all parties to send copies of all correspondence to the attorneys
involved but I certainly don't see why we need to be the messengers each month. ·
The total cost for day care· expenses from January 29, 2007 to Feb. 23, 2007 are $865.00 and
Andy's 67% of that amount is $579.55.
Thank you in advance for your prompt attention to this matter.
Best regards,
2061343-1528 206/343-7781 IX www.dyetptimont.com

-=---ll81HX3
From: Car1 Gaul To: jan dyer Date: 311512007 lime: 1:19:16 PM Page 1 of 1
CARLJ. GAUL Attorney at Law 423 239-4147 fax42.S 2'9·7081
Adniitted to practice in Washington, Oregon and Califonlia 302 Bank of America Building
1604 Hewitt Avenue
Everett WA 9820 I
March 15, 2007 Fax Only To 206 343 7781 at 1:30 p.m.

503 Twelfth Ave. East RE: Child Care Costs
Seattle WA 98102
Dear Ms. Dyer
I must apologize for my own negligence. You inquired of Mr. Rife's willingness
to pay day care costs incurred during Ms. LeSourd's educational activities. I
assumed he has responsibili~ for that expense and responded before checking the
order of child support to veri Mr. Rife's habilitv for the cost incurred. I should nave
checked, for he is not liable or the cost asserted.
Paragraph 3.15 of the Order of Child Support speifies that Mr. Rife should pay
67°/o of"Work related day care." The expense charged by Ms. Holland is not work
related. Ms. LeSourd's e-mail reveals she has enrolled in a night school class
designed to qualify Ms. LeSourd to land a $12.00 per hour job. Since the child
support is based on her abilitv to earn $2798.00 per month 1n the mobile notary
trade she already has the abinty to earn $16.15 per hour ($2798.00 I 4.33 I 40 =
$16. i's). There is simply no apparent "work related" nature to the current day care
expense. Consequently, the expense is Ms. LeSourd's alone.
When Ms. LeSourd does commence incurring work related day care expense,
Mr. Rife will need enou£Jh information to know that amounts claimed are actually
"work related day care as the order contemplates. Please be sure to notifv us
where Ms. LeSourd is working, the hours she works, the day care provider ancf the
amounts being charged. ~r. Rife will be sure to fulfill the requirements of the
court's orders.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
Car6l Holland
EXHIBIT b
From: earl 425 259 7081 To: jan dyer Date: 2126/2007 Time: 2:20:54 PM Page 1 of 1
CARLJ. GAUL Attorney at La\v 42.'i :Z.'!9""4147 fax 4zj 2'9·7081
Adtnitted to practice in Washington. Oregon and Culifomia 302 Bank of America Building
1604 Hewitt Avenue
Everett WA 9820 I
February 26, 2007 Fax Only To 206 343 7781 at 2:25 p.m.

Seattle WA 98102
Dear Ms. Dyer

When we were at court on February 21, 2006 you mentioned that Ms. LeSourd has
commenced incurring child care costs payable to her mother, Carol Holland as a
consequence of her current educational program. Mr. Rife responded that he is wif ling to
pay his proportional share of those costs.
He requires only ordinary documentation of the reasonable expense incurred. Please
have Ms. LeSourd submit copies of her invoices to Mr. Rife by e-mail. Mr. Rife's e-mail
address is asrife@snopud.com. Mr. Rife will send a check directly to Mrs. Holland for his
proportional share.
Please have Ms. LeSourd provide to him copies of the fronts and backs of her checks
by which she pays her share. It is fine with us if she obliterates the account numbers and
similar information. He has a legitimate interest in knowing that he is paying his
proportional share and that he is not paying 100% of what is actuany paid while Ms. LeSourd
pays nothing. So long as there is verification sufficient to establish that Ms. LeSourd's
money actually gets to the child care provider this interest will be satisfied. Please
encourage Ms. LeSourd to use checks for this purpose as a statement that she pays with
unverifiallle cash is likely to be less credible than a copy of a cancelled check.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
Don Layton
EXIi\B\T -:p
DROP-IN CHILDCARE AVAILABLE Page 1 of I
seattl~.-t;J,conH crnig_~!ist > $nohQiuis_h ~o > chilqcare > DROP-IN CHILDCARE AV AlLAl3LE
please f\<1g with care : [~ategoriz8~.!l [prohibited;) [ spamQ [!!_~ussionO [best otlJ
email. this postJDg 10 a_foeng
DROP-IN CHILDCARE AVAILABLE
Reply to: eommc28620367)(~Jcra(gslist.org

Date: 2007-02-28, I :04PM PST
I am currently a nanny/sitter for 4 PIT clients and am looking to fill some time during the weekdays-evenings. The
times 1 currently have available are from 9:30am - I :OOpm Monday through Friday, evenings from 6:00pm-
l O:OOpm Monday and Wednesday evenings and can do Friday or Saturday evening, even an occasional ovemight
sitting IN MY HOME. I live in the south end of Lynnwood, bordering on Mountlake Terrace- Edn10nds. l anl 34
years old, single, don't smoke,drink or do drugs. I don't believe TV is responsible for tlle child. l have coloring
books, crayons, play dough, drawing paper, pencils, cards and play inventive games like ba!Joon baseball (yes in
the house!)l give only healthy snacks- no candy/chips/cookies. I charge $10.00 an hour up to 8 hours per week,
.. //,.,----·-. ··-,_;
after 8 hours tile fee becomes$ 12.00 per hour. I prefer children who are ages 4 and above.
-- ---·--·---··-· ·-··-·····-- ··-··· ... ··--·······.-· -
Loe ion: LYNNWOOD

it's OT ok to contact this poster with services or other commercia.l inte~\its
~--·------··
PoslinglD: 286203671
Copyright <O 2007 craig,;lis~ inc. term~ of use privacy p;>J!cy t~edb_a<;:k fornni
EXi-1\Bli £ -
http://st'attle.craigslist.org/sno/kid/286203 671 .html ..... ,_ ·~,.. ~ -
QNl1110H
ll0S89909E is:zz L00Z/S0/E0
L0 3911d
Part-time Position Open- Noon to 5:30pm-3days a week!
Page 1 of I
~!)l)ttk-tac.QUlJI craig~.Jis.J > Sf\9ll9mish cg> cl!Usf_~J!re >Part-time Position Open-- Noon to 5:30pm-3days a week!
Part-time Position Open- Noon to 5:30pm-3days a week!

....... -·---- ........ .._ .. _. _____............,. --·--·- ... ····---- -··--·
··-··-~--·-·--····---·------········-
Reply to: @MltoucJina!lnyservices@veri.zon.ne(

Dare: 2007-03-04, 3:46PM PST
Naru1ies are you looking for a part-time nanny position'!

We are looking for caring nannies for our families. We know that working with the children is the best job you can have. We
care that you have the right family to work with. We want you to be part of the family with your family.
Lynnwood family:
*Has one child \ / -

*Rate up to $15 an houV
*Days are Wed/Thur/Fri *Time 12noon to 5:30pm
*Paid Holidays and Sick days
*Nanny will be paid ifparems are home for any reason that day
*Start ASAP
*Position may change to full-time
Nanny Requirements are:

*Love working with young children
*Clean DMV
*Clean BAckground
*Have worked with young children for 3years or more
*First Aid CPR Certified
*Car with full-coverage
Please submit your resume to angeltouchnannyservic~s@verizon.net or call us at

425-760 6971
Thank you,
Angel Touch Nanny Services
LoCHtion: Lynn\vood WA
it'~ N01' ok to contact lhis poster \¥hh services or ~)thcr commercial interests
PostinglD: 288399993
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Mother/experienced childcare
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Mother/experienced childcare
Reply to: coffil!1c28882}~36@craigslist.Q(g

Date: 2007-03-05, 11 :!SAM PST
I am a loving mother of a 1 1/2 year old little girl and also a student who is looking for a nanny position where l
can bring my litrle girl with me. I have a car, insurance, daycare experience and can provide references upon
request. I can work full time starting ASAP! I can commute ro your home. I will bring my own food for my
~gftt:er.'twncatmirrefisi~~~~ proper learning in children.
~y rates are negotiable anywhere above 12 per hour. __)
Please consilter as for your clrildcme!
Location: Kirkland
it's NOT ok 10 contact this poster with services or other commercial interests
PostingID: 288825536
.... ... ....... .......... .... ..... .............. -...... ...... ........ •..... ..---·---·-· .. . ·-- ·-·-·-- - .............. -. .---- ..·-·· -····--·----- ---·-----·-·· ..
Copyright <Cl 2007 craigslist, Inc. terms of µse pri~acy pqlicy feed_IJ•ck forum
http ://seattle.craigslist.org/est/kid/28 882 553 6 .html 2 JC l.,1\1\_,

!>0 3:llld ONllllOH 1:L0S89909E 1s:1:1: L001:/S0/E0
Nannies: Great Pay! Flexible Hours!
Page I of 1
~ei1ttle-tacoma.craigsli$..t > .seanJe > chilge<a.re >Nannies: Great Pay! Flexible Hours!
please t1ag with care : (_mi~~j] [ prohibltedi] [spam I] (.discusslonO [best otD
Nannies: Great Pay! Flexible Hours!

.. " ......................... -............................... ----·· - . --------·. -- -·········· -
------·-· .-----· ·--------- ·--------·· -·· -----
Reply to: jobie@anihou.s<:!holdst.affing.com
Date: 2007-03-05, 10:39AM PST
Annie's Nannies Household Staffing is looking for great nannies! Being a nanny through Annie's Nannies is a
rewarding and exciting way to earn a great income and take care of children! We are always looking for qualified
nannies to place with our families throughout the Puget Sound Area. Annie's Nannies is Seattle's Original Nanny
Placement Agency, and is considered by families and nannies to be the premier resource for exceptional childcare.
We are currently looking for nannies interested in temporary/on-call work. Jobs are available in Seattle and on the
Eastside. Take work according to your schedule-daytime, evening, and weekend work available. Great for
students, or anyone looking to fill in their schedule and make ex'tra money!
Apply now at www.anihouseholdstaffing.com!

,,,,.----·--·-···"'""··· ..... ····-· ·----~
alary: $13-$17 p!Lls per hour '
-··
Location: Searrlo/Eastside
it's NOT ok lo contact this poster with services or other commercial interests
PostingID:288800725
'<- ........ " " ' ' ' ' ' " . ·····-·····""
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,...
EXHIBIT _G~-
http://seattle.craigslist.org/see/kid/288800725.html ""I I~,.....,, ..,.,,...

E0 3911d QNllllOH C:l0S89909E
Weekend N'111Jly/Childcare
Page I of I
seat1lc-tat:oma cr~i_g~\ist > s.09homish co > childcare> Weekend Nanny/Childcare
~rn4i_l this PP.~ti.ng to a frl~11Q
Weekend Nanny/Childcare
----- ----- -. ·- -- -----·-- ------ .--- -------- -----' . ·--- ------·-- -. . ·-· ·----- -- ... --------·--· ·------·--·-·---· . ·-·--· .. ·-·--.
Reply to: comm-28~857697@craigslist.org
Date: 2007-03-05, 12:03PM PST
Need weekend childcare/nanny for two boys aged 2 and 4 years betweeen the hours of9a d-Tpnron-~un
on a consistent basis. The boys are fun, they like to stay busy and play outdoors, etc. ase email me if~our are""'
interested and tell me about your experience. Background check/references required Pay is between 10-14 per )
hour depending on experience, reliability, and attention to detail. _,...-
Location: ever~tt
it's "NOT ok to co act thls poster with services or other commi!rcial interests
PostinglD: 288857697
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Z:0 3:ll;ld GNl;ITlOH z:L0S89909£ is:z:z: l00Z:/S0/£0

Nanny Looking for Evenings and Weekend Work Page 1 of I
seattle-tacoma craigslist > snohomish co> childcare> Nanny Looking for Evenings and Weekend Work
please flag with care : [~teQOrizeciO [lprohibited0 [lspa.;:;O [~u~O [ibl!St~O
email this postingJQ a friend
Nanny Looking for Evenings and Weekend Work
Reply to: comm-288904598@gfilgslist.org

Date: 2007-03-05, 1:15PM PST
Nanny looking for Evening or weekends to render my childcare services. I am Mom of one 5 yr old girl that I
would bring/ have with me, I have Reliable transportation, Full coverage Insurance, First Aid and CPR trained
and certified. I have lots of Experience in childcare and I am very Reliable. My Policy is to collect one week
non refundable, in the case something happens. I had one bad experience where I watched a kid for a whole
week and the parents ran out on me at the end of the week, after they told me they would pay me. So sorry I
have to cover my self. Pay is negotiable for anything over 14+/hr. It does depend on number of kids, and age,
which we can work out. I have good References. Please email if Interested with what you are looking for,
location, and anything else.
Location: Marysville, Wa
it's NOT ok to contact this poster with services or other commercial interests
PostingID: 288904598
Copyright© 2007 craigslist, inc. terms ofµ_~ privacy_p_olicy_ feedback forum
EXHIBIT£-
http ://seattle. craigs 1ist.org/sno/kid/28 8904 598.htm1 31612007

04/13/2007 10:05 3505585072 HOLLAND PAGE 02
03/05/2007 15:51 4253041333 JENNIFER RIFE PAGE 03/09

Date: 2/27/20ti7Time:10:15:36AM Page Jot ti •
From: c;n i25 259 7081 To: jan dyer
Carol Holland
. 9724 146"' Pl SE .
Snohomish, WA 98296.
206.954.1743
·Re: Childcare for Lauren Emily Rife

Jenni~"' LeSourd
c/o Dyer a.nd Primont
503 12th Aven\le East
8e•Utle, WA 9S 102.
Andrew Rifo
2416 5'" Stred
1;ve1·ctt, w A 9 8 20 8
01/29/2007
· S:OOpm to l0:30pm ·
Ol/30/2007
5:00pm io 10:30pm
01/3112007
.5:00pm to l 0:30pm
02/0l/2007
5:00pm to J 0:30pm
22 hours @ $.10 per hour
$220.00
J>Jcnse make· payable to Ca.rot Holland by the last business day of the .munth.
llwc.>icc. #00 J
EXn\B\1' -~.!.---
04/13/2007 10:05 3606685072 HOLLAND PAGE 03
03/05/2007 15:51 4253041333 ~age 4 or o
Dale: 212712007 Time: 10:\5:36 M1
From: can 425 259 7081 To: ian dyer
Carol Holland ·
. 97:24 146 1b Pl S:E
Snohomish, WA 98296
206.954.1743
Re: Childcare for Lauren Emily Rife
.Jen.oifet LeSourd
c/o Oyer and Primont
503 12°' Avenue East·
Seattk, ·WA 98102
Andrew Rife
2416 s"' Street
EVet'Cl:t, w A 98208
Daycare provided for Lauren Emily Rifa:
02/05/2007
5:00p1~ to 10:3()pm
02/06/2007
5:00pm tD I 0:30pm
02/Q7/20-07 .
S:OOpm to 10:30p1u
02/08/2007
5:00pm to l 0:30pm
:Z:Z hou1·s@ $I 0 per hour

$220.00'
Please make payable to Carol Holland by the last business day of the month.
[nvoiCc #0()2
EXliiBIT f
04/1312007 10:05 3606685072 HOLLAND PAGE 04
4253041333 JENNIF'ER RIFE PAGE 05/09

03/05/2007 15:51
Date: ?12712007 lirne: 10:15:36 PM Page o01 o
From: earl .425 259 70~1 To: jan dyer
· Carol Holland
9724 146th Pl SE
Suohomislt, WA 98296
206.954.1743
· Re: Childcare for Lauren Emily Rife
Jennifer LcSourd
c/o Dyer and Primont
503 12"' Avenue East
Seattle, WA 98102
Andrew Rifo
2416 5<h Street
Everett, WA 98208
Daycare provided fqr Lauren Emily Rife:
02/l 312007
. 5:00pm to 8:00prn
02/1412007
5:00p.m to 10:30pm
02/15/2007
·5:(l0pm to I 0:3Dpm
14 hours @$I 0 per hour ·

$140.00
Plca"e make paya.ble to Carol f!olland by the last business day of the month.
Invoice #003
.. ExHlBIT _k_ __:

04/13/2007 10:05 3606685072 HOLLAND PAGE 05

Date: 212712001 1imd0:15 36 AM Page6of6·
From: earl 425 259 708LTo: ~n dyer
Carol Holland
9 '71.4 146th ri SE
Snohomi~h, \VA 98296
206.954.1743
Re: Childcare for Lauren :Emily !\if~: . . · ·'

.,. "
Jennifer LeSomd
.... clo Dyer and Primont
503 'l2'h Avenue East
Sea\tle. WA 981.02
Andrew Rife
2416 5~' Street
Everett, w A 98208
Daycare provided for Lauren Emily Rife:
02/l 912007
s:OOpm to 10:30pm
02120/2007
S:OOpm to 10:30pr.11
0212112007
S:OOpm to 10:30pm
0212211007
5pm.to 10:30pm ·
0212312007.
1 lam t<l 5:30pm
Coro l Ho Ji and
28.S llollrs@$10.per hour
. Balance d1.rn: $285.00
T'lense mak< pttyab\<! to Carol Hol11111d by the last business day of the month.
Invoice #004
. EXH:SIT . . ~
04/13/2007 10:05 3606685072 HOLLAND PAGE 06
Carol Holland
9724 1461h Pl SE
Snohomish, WA 98296
206.954. l 743
Re: Childcare for .Lauren Emily Rife
Jennifer LeSourd
503 12'h Avenue East
Seattle, WA 98102
Andrew Rife
2416 5th Street
Everett, WA 98208
02/26/2007
5:00pm to 10:30pm
02/27/2007
5:00pm to 10:30pm
02/28/2007
5:00pm to 10:30pm
03/01/2007
5:00pm to 10:30pm
22 hours @ $I 0 per hour
Balance due: $220.00
Invoice #005
EXHIBIT F-
04/13/2007 10:05 3606685072 HOLLAND PAGE 07
Carol Holland
9724 l46th Pl SE
Snohomish, WA 98296
206.954.1743
Jennifer LeSourd
503 12•h Avenue East
Seattle, WA 98102
Andrew Rife
2416 5th Street
Everett, WA 98208
03/05/2007
S:OOpro to 10:30pm
03/06/2007
S:OOpm to 10:30pm
03/07/2007
5:00pm to 10:30pm
03/08/2007
5:00pm to 10:30pm
22 hours @ $10 per hour
lnvoice #006
EX~::BIT _E
04/13/2007 10:05 3606685072 HOLLAND PAGE 08
Carol Holland
9724 1461h Pl SE
Snohomish, WA 98296
206.954.1743
Jennifer LeSourd
c/o Dyer and Prirnont
503 12'h Avenue East
Seattle, WA 98102
Andrew Rife
2416 5th Street
Everett, WA 98208
03/12/2007
5:00pm to 10:30pm
03/13/2007
5:00pm to 10:30pm
03/14/2007
S:OOpm to 10:30pm
03/15/2007
5 :OOpm to I 0:30prn
22 hours@$JO per hour
Invoice #007
EX:-::81T _F
·'---
04/13/2007 10:05 3606685072 HOLLAND PAGE 09
Carol Holland
9724 146th Pl SE
Snohomish, WA 98296
206.954.1743
Jennifer LeSourd
503 12th Avenue East
Seattle, WA 98102
Andrew Rife
2416 5111 Street
Everett, WA 98208
03/19/2007
S:OOpm to 10:30pm
03/20/2007
S:OOpm to 10:30pm
03/21/2007
S:OOpm to 10:30pm
03/22/2007
5 :OOpm to I 0:30pm
22 hours @ $ J0 per hour
PIE:ase make payable to Carol Holland by the last business day of the month.
Invoice #008
EX1·::EJ1T _l::·-~-
04/13/2007 10:05 3606685072 HOLLAND PAGE 10
Carol Holland
9724 1461h Pl SE
Snohomish, WA 98296
206.954.1743
Jennifer LeSourd
Seattle, WA 98102
Andrew Rife
2416 5th Street
Everett, WA 98208
03/26/2007
5:00pm to 10:30pm
03/29/2007
5:00pm to 10:30pm
03/29/2007
5:00pm to \0:30pm
16.5 hours@$\O per hour
Invoice #009
04/13/2007 10:08 3606685072 HOLLAND PAGE 02
Carol Holland
9724146'h Pl SE
Snohomish, WA 98296
206.954.1743
Jc11J1ifer LeSourd
503 121h Avenue East
Seattle, WA 98102
Andrew Rife
2416 s•h Street
Everett, WA 98208
04/12/07
7:30am to 4pm
04/13/07
7:30am to Spm
04/16/07
7:30am to 4pm
04/17/07
7:30 to 5pm
36 hours@ $8.00
Balance due: $288.
Please make payable to Carol Holland hy the last business day of the month.
Invoice #010
EXHIBIT .l=°
04/06/20Q7 14:27 JEHf-!IFER RIFE PAGE 02/08 ,
.. ·.· .,
·.,· . . ·-·· . ·-..,

. .: .
. . ;'
. ·. ·.. . . .... · : .... ·. ·:;. .. ....· .. - .. .' .' - . . i ..... : :. . . . . .. ...... . . ·. .. . . . .. ,- . . . . . . .. . .
. APPLICATION FOR ADMISSION 110 CLEARVIEW· MONTESSORI. INC. •'
, .· .· I .
....
·.. 1 AM ENROLLING MYclfl:Lo FOR THE SCHOOL oi\iti sEss16NoF: ccHEcK ONEY · · ·'.
Kfr,nERGARTEN · . 9:00:11 :30 A.MJ..:;-s315.oo A MoNTH-'--MON.-FRI. ··

. PRE-KINDERGARTEN ... · 9:00-11:30AM.--$3i5.oo AMo:Nrn-~-MoN.-FRI .. ·..
·__J>RESCHOOL · .. 9_:00;.11:30 A.M.-$315.-00 A MONTJ:1---MON.-FRI ... · . -.
I AM ENROLLING MY CHILD FOR THEScHOOL & DAYCARE SESSION OF:. CCHECK ONE) .·
_. School & Flill Time Care .· · KINDERGARTEN; PRE-KINDERGARTEN, AND PRESCHOOL
_School & Part Tnn~ Care . · $;~~~'(~~~ ANJ)CO~CTED HbURLY FEE $6.00!liour
. ($7.00/hotir no!i-contracied).
v'foctdler Sch~~l/Ca;e ··. ·· . $856.00/month ·
_·_rllfant ~are, o- l Year, · $948.00/m~nth ·
ELEMENIARY AGE CHILDREN; •· .. ·. p •• •• ••• • • • ••••• • • • • • • · •••
_._Before
. - . and/ornfter
. .
publk
. .
school .care contracted
.
hourly fee--$6.00/hour
. . .
..· :
' .
·· ·.·. ·-·_.Sinmner: Full Time:-$748:ooiinonth or contracted hourly fee of$6:00!liour.
. · ·..· NA¥£ oF cIDLD lauvw t. R,-Pe, PREFERREP NAME . •.. · . • · ... ·.· ·. ·
·. BIRTHJJAY
. ..
9/,a,~o!f
I . . ..
sTARTINCJAGF..2Yz,; HoMEPHoNE#lfd£ · Ql.;>6'- 5113
. . .. . .. . . . ·.
. HOMEADDRESS . CITY~ZIPCOD~
· ·. FA~'S ~AME/Jr,JtwJ e;[ler. socm SECURITY#~---'---~---~-
FATliER'SH,OME ,WDRESS eftlllr16Y-n iJ-r.$+ cELLPHONE#...___,__ _ _ __
·. CITY 6rzy-ipff: . . z&c~DE qgaoI HOMEPHONE#<t/ei.?:-c969-q¥'aff·
· ·FATHER'sEMI'LoYERimB nTLESno.·co. Puo •F.MPLOYERPHoNE#ct/¥;.?i,?666?·· ·
MOTHER;s NAME~Jennt{k 1.-t~ocIALsEcuRrI'Y~ .· · ... ·. .· . ·....•.. ·. ·. ·•. · · .•·
MOTHE~'SHOME ADORES ~--

- -
.
**--
. --- CELLfHO~...-.:
.C .·ZIPCODE...._HO~PHONE. .
. . . . ~.·· .. ·. EMP~OYERPHONE
'"L..:.....IC-___:_c__~.:..-~
T IF cmLD rs ILL, ~T~.? J enn//lv lt~ovcl /nwtbv-

·. . . . . .. . . THIS CHILD IJVES WITH . · . .• . .. . . ·. . . ... ·· .·
_·_BOTH ]'IA't!JRAL PARENTS;. .:.XM.oTHER ONLY,· _ . _FATHERONL Y.,~Mo:rHER & .·
STEPFATfffiR, -.·. _FATHER & STEPMOTHER,._··_GRANDPARENTS~_:_OTI!ER ..
Ifparents are divorced, who is t~e custodlal p~1·e~t?_·_,_rn.!.·-'-'rd;~h<L•J:e,~··v-_·_··-'··--"----'--'~~--_:.._-

. ·. ··,·
.1
. .-: ,.: . . . . · .· ..
EXHiBfT_I.:;::>_
/' ..· ·.•·
. _,::
.· .:.... ::::
' ' iF PARENT'S ~AN'TB~ REA CHE~. IN CASE ~F EMERGENCY. CALL: • ''
' ' NJu"ffi &YD l ih1La;;g ·. fw.,r@?j J??Jkvml (ivwd~ RELATIONS}ITP
PHoNE#ido-tp 954;.In3 ADDREss91.J'1 1i/k'f 4 el:.SE :Snohorv1:th

•' ' ' ' ' ·.·
' ~.
'
1;.JfT CJtd<f~
' ' ' ' ' ' ' '
. NAME A."<D PHONE NUMBER (WITH AREA CODE). OF PERSONS AUTHORIZED TO TAKE.
· · YOUR CHILD FROM·SCHOOL (lnC!uding emergency contact) ..
i: Caw,·. Hrtai nie c;o&- 95l.f-lrl/3

2. · /Jndt-t<· l t2,fe... ·. ·.. tf.?!i~ j5 9:.. 98'.clrt'.
·4··~~~~~~~~~~'--~~'--~~~~~~~~~~~c--~~'---'--~
(Child Will not be allowed toJeave 'sch.Doi with 'any other person(s) without written authorization from ..·
parentorguardianinadvan~e). · .·..· .· . .· .· ·· .··. · . K't:tfc_/!r:lf"ChfLJlc' ·.·· ·
perti~ular individual with whom you wouid not want your child to. leave schooilAJtiMJ. (,!,'({, JO('.ff ~{'e.
.. · j\DY
Family Doctor QY. k'lo%J6awevAddress /dlOO _8flfhUl-fvt AMj 1 6.1eylj>/- · .

PhoneHJ5J 3/ /O Jo& ·. • ·. ·. . · .· ·...·. .
3/(r' 5/l;,Onateofla~tphysiCalexatn
.· ~edica) lnSt1ranceP~,,gran> 6'vsf eho il' e. Pol~' i1tk8333 r /!Jt/93:.. , ,
Famlly Denilit ~/: S'/'J!nj'/t_/cf: Phone#I lfJ?-63fJ~ 1r1.3 . .
Address. /(t?a:JO &fi.u1-tvf Jk:y ;;.k;,_;rs-o //l/1/d~wfl 9/bl2
Does your child ~ave any laiown allergies?_·__,·L!..l."-'-~--,---,-,:--'---'----,-'-"-----'----~
Please specify: L-,---,----'-'-----,-------'---,----'----'-----'-~-'--_:_---_;_

' 2 . _ ---'--,----'C,,--~---'-~_;_-"'-_~---'~-_..:.--_:_;__-'-----'~
3.·-,----"--,--'---,---"'7---'-"---~..c.,_---~-,-----'---.:c__;_
. ·..
Are there any special sirulitions p~rtllining to yo,; child of which' we ~ho~ld be aware?_·.Ln.l.'o..,'-_·_·- - - -
Broth~rs and sisters ~ Piease !is; all names arid iig~s: .·

. L JV/A .
'2•3-:-..~-,---'-'----'---'---'-;-'-'--'-__;_--,---__:_----'----'~_:_~
'4.-----'---,-,.,-'----:---.-:--'___;__:,___,.__:__:---~~.:,.._-
lfo:!f did-you hear abo~t our s~hool?-;--1/_,n+.+k""'twnu..C-,_,,t_'-·-·-~-----_:_____;__~_:_--;_:_
EXHIBIT. Q
·' - ·.
·-
. ...
.:·.·.
. . . TUITION SCHEilULE .
FOR CHILDREN uNDER 3 YEARS OF AGE .
. ·.·,
INFANT PROGRAM: . I -12 Month~ oM .
The tuitionis $948.00 per month for full~time care. Diapers and wipes for the chtld
are inciuded in this fee. The fu!lctiJ:b.e fee iilso entitles children to be at school duririg.
• any days and hours of operation with ~o restriction on time. N~ monetary refurtds ot ·
credit given fot absences; late emollment,. early V.ithdrawal. or emergency closures .
. due to acts qf nature. Untilyoilr child can adeqriatdy eat our usual lunch, parents are ·
responsible for bnnging Suitable amounts of baby food;. formllia, and b()ttles. All .
food and formula must be labeied with the child's name and date before bringing to . ·. ·
. school. · ·· · · · ·· · · .
TODDiERPROGRAA~S:. I-3)~5 • .
. The tuition ~~ $856.00 per month .. Diapers and wipes for the child arid~i:luded in
this fee. The full~time fee _entitles children to be at school during. any days and hours
. ofoperation with no restriction on time. :No monetar)' refillids or credit.given-for
absences, late enrollment; early withdrawal or emergency closures due to acts :of ...
nature .. The. fee is aJwiiys · tbe same regardl~sS ·Of the. number of ho~rs or days fu~t :
m
.· your child is attendance, Brefilaast, a "cold'~ lunch, and your child's daily. snacks·.
are incllided with your tliition: Our hot lunch options are NOT induded in this fee,
... but a meal ticket may be purchased, or the chiid niay bring "either meal from .hoine ...•
.. .·..· .. · .. · . . ·. .· .•.. ·. ·..··•.

· ·.... ·.. • ..... ·. .... •.
·..·.· · . .··..
: '.
~ .g
SI ATI) . . . :· .:
/,;,,,/lip_
. . .. ·.· .
3/;b/01
DATE . , ...
. 'i
. ,·. .:. -~ . : ·: ......... ·

....
EXHIBIT.· ' ~ .•...•.
--~
04/06/2007. 14;27 4253041333 JENNIFER. RIFE PAGE 05/08.
..
.,.· .. . ·, .;.-
·..~- .
. ,: ..
. .. . .
. · .. . . -·
.·. :• ....
. .' . ·... ' ...
..IMPORTANT POLICY INF0Rt'1ATION

··, ' ,_..
.. .
:-·,·
. Regist~ation/Materi~Is Fee. (Scliool Ye~r only). · ..·. . . .· . . . ·.· :... ·
Tuitjon fees do. riot :coyer the pilrchase and replacement of larger classroom activities,
outdoor. eqllipinent, school improvements; · conStruction costs; . etc: ·• We have · many.•
necessary .•:upkeeps» that need to l:ie addressed on a regillar basis: Clearview Montessori
.
char&es
c.
a Re!!isfraticin/Materials Fee. The fee schedule.is as follows: .. ·.
0 .. . . . . .
. . .-. . . . . • ..
New stiidents · ·. Registrati<iii,$100. · Materiaffee~$50
. R~turning stlldents ~egis~atio~-$50 .

Material
.
fee-$50 '
. . .
·. Siblings' . R~gistration-$50 · ·. M~terial fee-$30
~Any
.
·stud~~i Withdra~ fo~ 3o. d~ -~f
. ... . -
mOrc ~11 nCed
. . to ;e~r~sler:
. .
(Including. re& fi:e-of $50)
Sum~er School (Ollly) · . . . . . . .. ·· . ·.. · ·

Students have the. option of atiendiilg school on a full time or Iifilited. ba5is. "School
Only' or "School and Hourly''. tuition is $3 I5;bQ/Month. Before and after school care is
billed at $6~00/HOUR .for contracted hoi.irs ($7.00 for non"COntracted): Lunch is not
iriC!uded: No ino:rietru:Y re:fUnds given for absences.or eariy with-drawLif a c!liid registers ·
for sumri:i.er session, the
registrationiniaterials foe is: . . . . .
Nm; students ... Reglstration-$50 Material fee~$35 · ·
Returning students • Registration~$0 .. Material fee-$35 ·

.. . .
· ·•· Siblings · ' . Registratibn-$0 . Materlai fee-$35 •·
Meal Service:
... Full tirile students receive breakfast,.a "cold" lunch, .arid yourchild'.s daily snacks as part
· of their fee: ..Qur hot ltinches are not inc!ud.ed in thi.s fee, but a hot meai ticket niay be ·
. purchased
. .
for $40.00;
. .
or
the child. may bring either
... . meal frO!ll horne. For hoi.irly students '·.
' '
"Hot or Cold" lunches can be purchased for $2.00 a. day or '1 20 punch lunch ticket may .
· · be purchased for $40;00. · · · · · .· · · · ·
.' .
Nap Mat:
· A nap .mat is· required for every full,tii:ne child UO:dei: kfudergfil-teti <ig~ a8 well as those .
children who stay di.iring, naptil!le on an occasfonal. basis. The fee for. a new .mat is ·
$17.00.. This fee inu5t be iriCJuded with the first ~onth;s tuitioh: Chiidreii. who are in
· k.iriderg:irtenor above do not need a.mat if they willrtotbe pai1:icipating in naptiine .
. r}m,'fil'J
. SI ATU . . .· .•
~f1,V1d···· ······
...· . · .. ·
... s&.7/pi. ·· · ··
. DATE
···-~- ..
. ,..
4253041333 JENNIFER R~FE . PAGE 05/0.8
·,. '
POLICY.INFORlVIATION(CONT.).
. ···' j
·Time ciock: · · · ....· ·. . ·. . . · . . • . · ·.· ..· . .. . . ...· ·
fudividual student attendffiice is documented by means of claSsrooni roll chaJits and also a
time clock system for recorc;iiilg arrivats and departures. The system is necessary in order · ·
. tci verify DSHS student occupancy loads .and 3.Iso fo verify hours of attendance for billing
. ·purposes.·. · Pai;ents are ro:sponsible for •clocking child in and out arid for signing their
. FULL LEGAL SIGNA.TDRE next to child's name on the sign-in/out sheet. (If yoilr
child's name is not on the sign~iii/out sheet, please write it in and it Will be added.) ...
an
If a child on hourly payschei:IU!e is in attendance during .a partkular day and the child .·
has not been clocked either in and/or out .6ri the time clock, we mtist bill for the .
. maximum hourly charge for that day. In addition, we ·do not accept legal responsibility· .. ·
m
for children Until they are clocked by the time clock: ·. . .
. NSF Checks: ..
I. $35;oo cHi\RGE for any check that is ~eturned to us bythe bank,regardless of

reason. (Ifa check is returned to us for NSF; upon parent request, we will resubniit
·the same check to the bank. Ill.this case the $35.00 NSF fee will still apply as well as
the late fee if applicabk):; .·.· · ·· · . · . .· . . ·.· · · . · ·• · .
2. If the check is returned to us after the 10th of the month, your tUition payment Will ·
be considered late .and a late fee equal to 20% of the tuition bruarice Will be charged...·
·Ifwe receive two NSF.checks from the same parents dtiring·the colirse of a year, all
· further transactiOns Will be iri cash. . ·
ALL TUI~ION p~yl\fENts ARE DUE; IN An~ANCE,

ON THE FIRST DAY.
OF THE MONTH. ·IF TUITION IS NOT RECEIVED BY THE 10th DAY OF TiiE
MONTH; ALATE FEE EQUAL TO 20% OF THE mTION PAYMENT
..· .WILL BE CHARGED.
(Note: If~e 10t11 falls on aweekend; tuition: is due th~ Friday before.) ·.
·... •'
- .
.. ir,,,,;d,,) ~..r,,,;..R 3./c;9fa"f

SIAfyRE!Z ·.· DATE
1":·
8
.. H"B.IT_(,--.,
EX I
1 · • . ·
04/05/2007 14:27 4253041333 JENNIFER RIF!;: PAGE. 07/08
·.•·.
-:·. ·.
··; ... ·
·,,: . . .· · ....
. ·.·•:· . ·"
. ·'.
. ;. POLICY INFORlltATmN (CONT) • ·.· .
. ., . :
•UNDER NO cmcUMSTANCES WILL .MONETARY REFUNDS BE GIVEN.

FOR ANY:ABSENCE·DUE TO ILLNESS, EARLY WITHDRAWAL, OR ANY
EMERGENCY CLOSURE DUE TO .FIRE, FLOOD. LACK· OF .POWER, OR
ACTS OF NATURE~. We resen'e space, teaching time, and materials especially for
yoi.Jr child each day. Since 'hiilher absence does not diinirush our expenses, we cfiluiot
under
.
any
. situation
.. offer·. any
.
adjustllients. . time
.
missed.. for
···After Hours Late Fee:· Our closing tiAi.e is 6:00 _P:M,, and there isa $5.00 charge for each ·
· .5-iriinute segment, or any part thereof, th~t a ·child remains in caie after 6:00 P,M .
.Because our dosillg staffs have families, harries, alld a demanding life away from schooi, ·
.th~late fee is paid directly to the. cicising staff to compen~ate them for the disi:uj:ltion' of ..
their plans alld schedules. If you arrive fate to pick up your child, please have the fate
fee ready for .payment at that time. The lat!= fee applies regardless ofthe reason for the
delay, :>Vhether it is tiiiffic; s~ow, car jm:iblenisi bridge openings, etc. To·awiid the late
. fee you may want hi consider having a backup perso1i who can pkk up vour child
for voidn the event of :in emergeD.'Cy. .
.. . .
Additional Children:
In families _where multiple childr~n atte_nd o~ school,· the yo~gest child's tuition fee will -
be the posted fee for his/her age group. The oider child orchiidren .will receive a 15%
discount oil tuition for their age group
.......
Every Child must have.a Clearvie\V M,ontessori T~shirt and/or sweatshirt, for use~~- field
·. · trips and excursions away from th~ campu5. The. fee foi the T-shirt is $8:00. The
.' sweatshirt cost IS $14.00, and ourlightweight waterproof jacket is $24.00. Due to the
number of field trips the .Kindergarten Class. attends; .Kindergarten children must .
. purchase a F_ield Trip Package; which inciudeS a T-shirt, sweatshirt; and jacket for.· .
$46.00. For the safety and comfort of your children, there can:be no eXC!!ptlons to ..·
this policy; ·· .·: · ·. . .· · · . · ·... · < ·.· . · . · · ·.. · · .· .• · · .·
•.:. ~
... ·. ~futd i]JUd@cf ··.
·.··. ~- ' : . ·.·.
3/Qq:/o-r
. 'SI ATUREt/ · ' .. • . •. . DATE
. . . ' . . . ·. . . . : ... . ... , .
9.
.... ExHiBIT ~(}. .

,,·
·.,. . ':.
'·, ..
. .· .. I ~GREE TO PR0-0nE TOTHEDIRECTORbF CLEARVIEW .

MONTESSORI,, ·A.· _WRITTEN· NOTICE -INDICATING WITHDRAWAL·
INTENTIONS OR CHANGE OF HOURs DURING THE FIRST 10 DAYS OF ..
. THE MONTH PRECEDING Ti:IE MONTH IN WHICH THE PROPOSED
CHANGE WILL TAKE Pl.ACE. IF NOTICE IS NOT GIVEN DURING THE.
FIRST 10 DAYS OF THE MONTH PRECEDING Ti:IE PROPOSED CHANGE,
I AGREE TO PAY MY USUAL TUITiON PAYMENT FOR THE
FOLLOWING. MONTIJ,I ,AL.so .AGREE TO.PAY·ALL COURT. COSTS,·
,. COLLECTION COSTS, OR ATTORNEY FEES THAT MAY BE GE1'1"ERATED ·..
DUETOENFORCEMENT OF'flIIS AGREEMENT~ .. .
PLEASE NOTE; AVERBAL NOTICE \VILLNOTUNDERANY .

. CIRCUMSTAi~CES 'SUBSTITUTE NOR BE . .
. ACCEPTED IN LIEU OF THE TIMELY
. WRITTEN NOTICE .
.··. EX.A....'f\1?LE: . f....~Y- ci:i~e~. in. hqurs.

or D.otic~· to· \vithdra·~~f .]~ th~ NI~nth: ~-f-~ebru-~,. ~i~~ .be ·
received in the office in wri.ting by the 10th ofJanuary. . . · ..
Parents or Guardians, .. · . . ..
. Please un~e~stiihd OUr need for this policy and .also the need toiidh~re'to it.. We plai:i OUr ·,
·.. budget spending a iriorith iil advance depending on avaifable inoney coming in'as iildicated
.. by stildent tuition commitments on file; When a parent withdraws or. changes hours without .....
ample notice, it creates a budget deficit for us which. makes it very difficult meet our to.
financial obligations for the npcoming moiith~ Also, children on our ;,vaiting list nmst give .
ample notice to whatever chi!~ care situation. in which they are presently involved before
leaving and changing to out schooL Therefore, when a parent Withdraws after the deadlille, .··.
· we generally cannot fill. the vacancy created, therefore we do; generally without ~xception, .
adhere to the withdrawal notice above ..·.
' .
._·· · · fl&v~ -,d,C11 µ£. . ·3/<?~/or

· S~ATutt . · · ·.. · . . · DATE
*tf you. _wish a copy. oftliis
. . contract,°
. please
. .. ask .for. one-in
. the office.
10
8 In re:
Andrew Scott Rife
and
10 DECLARATION OF SERVICE
Jennifer Rae Rife
12
I, CARL J. GAUL, declare under penalty of perjury of the laws of the State of
13 Washington, that on May 1, 2007, at 4:47 p.m. I served the following documents
upon the office of Jan Dyer, Attorney at law:
14
Responding Declaration of Andrew Rife
15 Declaration of Jenny Hendry
Declaration of Shelly Pattison
16
17 service was accomplished by faxing the aforementioned documents to Jan

over at 206 343 7781, the fax number listed on her tationerv
18
Executed at Everett, May 1, 2007
19 CA
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
DECLARATION OF SERVICE Everett WA 98201
Page 1 425 259-4147 FAX 259 7081
FILED
07 JUN 15 PH 12= 05
1
P:\H l. Df.dl!ELS
2 COUIH Y CLERK
SNOHOMISH CO. W ,'.SH.
4
3
Ill lllll lllll lllll lllll lllll lllll lllll llll llll

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. OS 3 027SS 1
and
10 DECLARATION
Jennifer Rae Rife
11 Respondent.
1, ANDREW RIFE, declare under penalty of perjury of the laws of the state of
I am the Petitioner in this matter. I make this declaration to support my
motion for an order concerning the summer 2007 residential schedule ..
SCHEDULES
The court's most recent order on this matter was April 5, 2007. Since that
time Ms. Lesourd has enrolled in a college level educational course which will
lead her to a nursing degree and licensing as a Registered Nurse. The course
begins with the summer term, July 2, 2007. Ms. Lesourd has provided a copy
of her summer term schedule. Three days per week she is attending class
until 9:15 p.m. see attached class schedule she provided.
Ms. LeSourd also provided a copy of her fall term class schedule which does
not include such late classes. Assuming that she does not have other
scheduled activities, there would be no particular need for the special
schedule during the fall term.
My proposed schedule for July and August weekdays is
WI Ms. LeSourd W/ Mr. Rife W /Montessori
26 CARLJ.GAUL
27 ORIGINAL Attorney at Law
1604 Hewitt Ave.
Page 1 425 259-4147 FAX 259 7081
•
•
1 until Noon 5:30-10:00 p.m. Noon-5:30

Monday
2 Tuesday until Noon 4:00-10:00 Noon-4:00
3 Wednesday until Noon 5:30-overnight Noon-5:30
4 Thursday until Noon 4:00-overnight Noon-4:00
Friday All Day none none

5
Saturday All Day none none
6
Sunday until 9:00 a.m. 9:00 a.m.-overnight none
7
3. PRIOR ATTEMPTS TO RESOLVE
8
MY attorney wrote to Ms. LeSourd's attorney on May 30 suggesting a special
9 summer schedule. Ms. Dyer responded the very next day saying that Ms.
Lesourd was amenable to adjusting the summer schedule, but the rest of her
10 letter went on to discuss other things. Since then we have not been able to
get the discussion back on track. In order to have the matter determined
11 before the rest of the summer passes, it is necessary to obtain a ruling from
the court.
12
on
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
'•
'·
,',.
LAKE WASHINGTON TECH COL

FRI,, MAY l.S, 2007, l0:57 AM LESOORD JENNIFER R
A78l. - SUMMER 07 STUDENT SCHEDULE BBS-l.5-35142
Day Phone: (425) ~:::::::: Birthdate: Advisor: ANY ADVISOR

.,;
Evening (425) ~ I citizen: y vet status: , ,
Rssidency, Status 'l. l'lE$ID.ENT · Program; 32JA AAS NURSING : " '
Fee Payi~g st~tus · iA1 vqc; ·P.RE,P: H:oyiu.,Y Intent':G OC<;:UP PREP· APPLICANT,
.: . ~ . ,. .
. ..• ·i' '
. •' '' •' .
• ·' ' ' ' : ; .!'; ·~· • : .·' •
'.• ' : .·. ·.·.··:··.,..
•Ii~•' ,. ,
LES,OURD JENNIF_ER R
WA . ,. ' ~· \, .
I ,i' ~ ·. ' .. , .. ' .' ..
. ,. '• ,, .' '..... .... ., .- . ' ' .
qs~.1'..~. ,. '"I'•?•. S'U\R'l' BND START END • lo"!illl: ' c:tJJi.9'
ITEM c:rv NL'M DAYS TIMI: TJPG l».TE DATE INSTROCTOR PAY FEE
---- ----- .... ··- ·-----------------------
Sit•o'iO:.Tirl·'OQ.~~- 0~ .. BASIC' MA±'ff '· '·' '5.0
--· l:AB
---------- --------··
1:219 MW
····-· --~~-~
·diilOP 04:2Di'
····-· ---~- ·-~---~---·-·
xl..ahin111lca~&o.·
·---~----···
72BO PSYC' ~00 01 LIPRSPA.N PSY~OLOGY 5,0 E:AS •:ie 'l"l'h Ol130P. 04iSOI?. Culber.t'.l!llbtl. M'
2$47 n.:i;?~f' ,100 ··~l.- SORVEY Oi' ·.eJ:OLOO''i
TOTAL c:REDITS
•••
is ,.'o
St:aff
TUITION CHARGES .. 709.25 PRIOR PAYMENTS ... ,00

FEE CHARGES . . . . . . 47. 40' COVERED BY FINAID ,oo
.===-=====::::
TOTAL CHARGES .. . 755.65 TOTAL PAYMENTS.:., .00
,QO TOTAL DUE , , , ··" 755.65
~
,.
......
~ .;'.
''''''''''' ~99/ ~Q9. Ill'.

----------------- ---
1
I lll~l~!llHJ~llll 11111111
F!L~D
2 07JUl~22 AMll:Q3
3 P1\H L. D1\:: 1as
COUNTY CLER~
4 SNOHOHISH CO. WA SH.
5
6
7

11 ANDREW S. RIFE, NO. 05-3-02755-1
12 Petitioner,
and DECLARATION OF JENNIER RIFE
13 IN RESPONSE TO MOTION TO
JENNIFER R. RIFE, MODIFY THE PARENTING PLAN
14 Respondent.
15
16 I am the Respondent named above and make this declaration based on my own personal
17 knowledge. I am attaching the declaration I filed with the court in March of 2007, when Mr.
18 Rife was also asking this court to essentially modify our parenting plan. At that time the court
19 denied his motion but we did enter an order regarding his visitation that sets out what his visits
20 will be through early August 2007. At this time the Case Manager is to issue an interim report
21 regarding the father's progress in his DV Treatment. We have a review hearing set for the week
22 of August 13, 2007. There is no basis for this present motion. This issue was decided by the
23 court on April 5, 2007. These repeated attempts to modify the parenting plan are not in good
24 faith and again I am asking that Mr. Rife be ordered to pay my attorney fees for having to
25 respond to these motions. Please see my requests in the prior declaration, incorporated by this
26 reference. This is abuse of the courts and this conflict.
27 The court should note that the April 5, 2007 order states that the expansion of Andrew's
28 time is contingent on his continued successful progress in Phase II of DV Perpetrator's treatment
29 as well as the requirement that he enter and complete DV Dads and Respectful Parenting at
30 Family Services. At the time of the April Order Mr. Rife had just entered Phase II at Evergreen
DECLARATION OF JENNI ER LeSOURD
IN RESPONSE TO MOTION TO
Dyer & Primont
503 Twelfth Ave. E
MODIFY THE PARENTING PLAN
Seattle, WA 981oj
Page I
(206) 343-15~
t(o(o
1 Treatment Center after doing Phase I at Catholic Community Services. He also reported that he
2 had completed his intake for DV Dads at Family Services.
3 Since that time what we have all learned is that his current treatment program is refusing
4 to communicate with anyone, me, his attorney, other treatment programs, or anyone else. Mr.
5 Rife was not eligible to enter into DV Dads because his current treatment program would not
6 communicate with the staff at DV Dads. All of this is a clear violation of the WA Cs governing
7 DV Treatment Programs and from my perspective is just one more piece of evidence in Andy's
8 ongoing saga of not taking his DV treatment seriously. Please see my earlier declaration for
9 more history but the bottom line is Mr. Rife was ordered into DV Treatment by the criminal
10 courts in May of 2005. Today, June 2007 he has yet to complete Phase II and we have zero
11 information about his progress.
12 There is simply no basis to make any changes to the current order, which sets out what
13 his visitation is during the summer. My summer school schedule has no bearing on this issue. I
have taken care of my responsibility for alternate care during the evenings I will be in class.
14
Lauren will be staying with my mother who has agreed to pick her up from day care, facilitate
15
the visitation exchanges, feed Lauren as well as meet me for dinner (between work and class)
16
with Lauren. She is not planning on charging Mr. Rife or I for this time of watching Lauren.
17
There is no basis to change the order of April 5, 2007. This motion is in bad faith. Please
18
award me attorney fees. I am attaching a statement from my mother indicating her willingness to
19
watch Lauren; the May Progress Report from Family Services, a letter from my attorney to Mr.
20
Gaul that Mr. Rife references in his declaration as some indication that I agreed to expand his
21
time this summer. I did not.
22
23
foregoing is true and correct. Signed and dated this 21" day of June 2007 in Seattle,
24
Washington.
25
26
27
28
29
30
DECLARATION OF JENNIER LeSOURD Di;er & Primont
IN RESPONSE TO MOTION TO 503 Twelfth Ave. E
MODIFY THE PARENTING PLAN Seattle, WA 98102
Page 2 (206) 343-1528
cnfGINAL
HOLLAND PAGE 01
06121/2007· 15:59 3606685072
c ...
r
. . ..- '
.... " , ,
~
I._ ll' •' .. , r.,,-
II
~
' ...
~,.
" ,,

ANDREW RIFE,
Petitioner,
N0.05-3-02755-1
v.
DECLARATION OF
JENNIFER LESOURD CAROL HOLLAND
(fka Jennifer Rife), (DCLR)
Respondent.
I Declare that the attached I page declaration was written by me and is based on my own
personal knowledge and is true and correct, under penalty of perjury of the laws of the state
of Washington.
Signed at Snohomish, Washington on June 21, 2007.
tauLY~
CAROL HOLLAND
DECLARATION (OCLR)- PAGE I

BS/20/2007 17:~8 PAGE B2
' ,
June 20, 2007
Dyer and Primont

503 12th Ave East
Seattle, WA 98102
J, Carol Holland am Lauren Rife's maternal grandmother and Jennifer LeSourd's mother.
I have a flexible schedule and am willing to pick Lauren up from Montessori and V>'atch
her unti.I her mother arrives home from college classes. I will also handle the exchange
when Lauren is returned from her father on his visitation evenings. Lauren's Aunt Lisa
and cousins from Florida will be here in ,July and Lisa has also offered to help care for
Lauren for the few hours needed. There is already Montessori School expense and
neither [ or Lisa will charge for the care provided to Lauren.
In addition to caring for Lauren I have also offered to take Lauren to have dinner ~ith her
mother before class on occasion.
. .- .
1
2
3
4
5
SUPERIOR COURT OF THE STA TE OF WASHfNGTON
6
COUNTY OF SNOHOMISH
7
8
In re: ase No.05-3-02755-1
9 ANDREW RlFE,
Petitioner R17 DECLARATION
10 And
11 JENNIFER LESOURD,
(fka Jennifer Rife),
12 Respondent.
13
14
16
18
98102, telephone number 206-343-1528 and fax number 206-343-7781.
20
22
Dated this 21st day of Jun.e, 2007 in Seattle, Was
23
24
25
26
27
28
29
30
Dyer & Primont
503 Twelfth Ave. E

(206) 343-1528
'•
~-=" 'I ,......__ r"""t.

I...,. ii 'I "• •· ~
f\lED
APR u o 2001
II LI ·.--, . ...., , ,,}'
p,\;; L. Oi..;.:i'.:LS
PP.M L. OP.NIELS cou;ny cc"~
SNOHOMISH CO. t. ASH.
COlJN\Y CLER~ ~
~CHOM\Sfi .CO. W.\•H
~

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)
)
and n \" ) NO. 05 - S - ()'l- -=!S) - \
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DEFENDANT/ RES PO ND ENT ) ORDER
)
)
IT IS HEREBY ORDEREDW --("""'<- C..v rr~,_r-\--

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DOtlE II'i OPEI'T COL RT :his date: \..-.--"t_ '"'-- \::..,
Presented By:
~J.;, v
!/
16101 "'"!:Ji
•
Page# 2 <.:.-f?_...
Case Name _\2_'--,"-.C-'--i....-=-+l__,(2_,_.s;"-'--"--------
, Case No. (JS - "3:. ~~?-:f'>~ - I
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' ___,
DONE IN OPEN COURT this date: -~-+----5._,_/--'~'---7"----
<
JUDGE /'COURT COMMISSIONER
6/01 page2c12
Community Violence Prevention Services 'Family Services
Changing lives. Every Doy.
613 -2nd Avenue, Seattle, WA 98104 Phone (206) 826-3044 Fax 1-877-903-0553
Client Progress Report
Program: 0~1en'sJ)omestic Violence Intervention Program: 0Weckly Group

·OLesbian Do1nestic Violence Intervention Program: 0Monthly Group
)8f>v Dads and Their Kids 0Respectful Parenting
To Cg,-/ &,J: fu. ('fzs) 1...S'l- ]08 Month --"!'!1. .~...>.+·--,--~----20 0}

]g" f?yer : .fux- (~) Jlt3 - 7181 Staff__.lli,..,~....,i-'-+Arh~'l'lo,.:.S-----
Jh¥-Lle<uefyo: 2tlll- Ocik~ ~-, E.d 7820 I
Re: Andrew! g.;£ j:i('Pioneer Square
DOB 3- '1-1..- J3 0 Bellevue

Cause No. Q5-3-0215S-J_________. _ __
IN COMPLIANCE REVIEW IN PROGRESS OUT OF COMPLIANCE

0Cumpkted !make on _ _ _ __ 0 (See conm1ents below) 0Did not complete intake process
0Attended first group on _ _ _ __ ODid not attend as required
0Attending Weekly groups OD id not pay fees
Q'\nending l\fo/1thly~p_s OOther _ _ _ _ _ _ _ __
)t')IOther: .. .J)_V. __.._ua.~1-..:1),__ __
_ _ Completed Program Satisfactorily ___J)ismissed from Program (see below)
_LFile Closed (see below)
Dates attended: 5--:13 i _ _ _ 1·_ _ _ ; _ _ _.!_ _.!_ __
Dates missed: I
---'---''- I
--·; ___I --~--
I
C(
0See Attachments .'

. / ..
j
'"'..."'"
.. . '
,....
Client Progress Report Supplementary Page ... '.2 df 2-
Re: bd1£<.J "tde ___ Date: ~kvI "2.(,( l]
6J<:;"-Of98 _________
:{-§(- /./4£ '_?, oC
From: Cari G~ul Zo: Jan Dyer Date: 6/i3/200i i1me: 2:41:46 PM PageBoii
...... o5/:l'i /2'6'61. 'i!l': 2;. f'Ai<'. ...................... · lfi'6o2'/6o3
/)YER & PR/MONT

503 Twelfth Avenue E.:ist
Se;ittle, Washington 98102
Jan Dyer. A:tomcy Amy Pa>co, Pa"llegal

Mlch~ol Prlmont. Attorney Geo~9ia R.oss, Legal As~istant
May 31, 2007
Carl Gaul
1604 Hewitt Avenue
Re: Rife/LeSourd
Dear Mr. Gaul:

I received your letter just as I was drafting one to you regarding some of the same issues.
I agree that there may be a better schedule for the next couple of months and am open to
looking at that issue. Before we get to that point there is another issue that needs to be dealt
with and that is the status of Andy's DV Treatment,
We have no progress reports from Evergreen DV Treatment Center. We know they are
refusing to provide any information to anyone. We all know by now that, by law, they
cannot take that stance. Regardless, that is a fight for another day with other actors. The
only salient point to me is that because of it, Andy cannot get into DV Dads until he has
successfully completed his treatment program at Evergreen.
As I understand it, you suggested to Mark Adams that Andy have an evaluation in lieu of
Family Services communication "'ith Evergreen. Mark suggested two names of evaluators
and seemed to agree that he would accept that. You and I talked on the phone shortly after
and we discussed this very issue. At that time you conveyed that Andy would opt to wait
until he was finished at Evergreen, rather than have an evaluation, and then enter DV Dads.
This was all spoken with the W1derstanding that the overnight visitations would have to be
put off as well.
The last time we were in coun to set the unsupervised residential schedule Andy was
actively in the intake process with Family Services. The order, and our willingness to move
to unsupervised visitation, was based on the fact that Andy was beginning the Family
Services componem of his treatment. The order states clearly, "Expansion of father's time is
contingent on his continued successful progress in Phase II of DV Perpetrator's treatment as
well as the requirement to enter and complete DV Dads and Respectful Parenting at Family
Services." We have no evidence of his successful progress in Phase II because Evergreen
"ill not communicate with anyone. He is not in DV Dads and ,.·"ill
not be for some time,
despite having an alternative that would allow him to get in now.
206/343-1528 206/343-771!1 Ii< www.dyerprimol"/t.com

From ,Carl G~ul ·i o Jan D.y:r Daie: 6/13/2007 Time: 241:46 PM P.age 7of 7
.... ··osh i 12·0·67··rs·:22··l'Ak ....... . .. ..................... ~'663'/6'63 ...... .
P>ge 2
May51. 2007
Absent a court order, we can not agree to begin overnight visitation, or make any other
accommodations or expansions, until we have satisfactory evidence Andy is either in DV
Dads (i.e. he is finished with treatment at Evergreen and started in DV Dads) or has an
appointment to have the assessment done that will allow him to enter DV Dads. When either
one of those things has been accomplished let us know and we can have this discussion.
Best regards,
1
3
4
5
·5
SliPERIOR COURT OF WASHINGTON

9
ANDRE_W S. RIFE,
10 Petitioner,
and DECLARATION OF JEl'iNIER RIFE
JENNIFER R. RIFE, - MODIFY THE PARENTING PL.'-LI\'
12
Respondent.
13 -
1.4 I fu"TI the Respondent named above_ I make this declaration under penalty of perjury and
15 based on my own personal knowledge. I arn over 18 fu"J.d otherwise competent to testify.
' 16 As I understand it, Andrew
-
Rife is asking that the cow-t enter a new parenting olan faat
- -
17 substantia!ly changes the final parenting plan entered in October of 2006. · I do not agree that
18 should be done.
19 Our parenting plan was a plan that was agreed to between all of us. There are rest.-ictions
20
21 of this case in October of 2005 the court has consistently ruled that Andy should only have
- 22 supervised visitation with our daughter.
23 Bridgett qewe!lyn was the GAL during our divorce and is the case manager under our
24 final parenting plan. In her final report to the court the GAL recommended that Andy's
25 visitation, "continue as _is tmtil he lia:s completed the first phase -of his Domestic Violence
_Treatment successfully and the mother has spoken with Dale Todd and he is satisfied tliat the
26
father is progressing. If he is, then tlie visits shall become unsupervised and the hours shall
27
remain the . ' same ... When the father has successfully completed his Domestic Violence
28 -
Perpetrators_ Treatment and provided proof of such then he can move to expand his unsupervised
29
ti.me either by agreement or by further court order." (Page 12 - 13 of GAL report dated June 6,
30
2006).
DECLARATION OF JENNIFER RrFE

_Cfl!GINAL Dyer & Primont
503 Twelfth Ave. E
Seat:le, W.4 98102
(206) 343-1528
Page I
1 It seems to me that our current parenting plan is clear on what has to happen and it has
2 not happened. On page 3, section 3.10 it states that Andy will emoll and successfully complete a
3 -state certified domestic violence perpetrators treatment program. He has not yet done that,
4 despite being first ordered to do that in June of2005. As I understand it he did manage to attend
5 26 weeks at Catholic Community Services but he has yet to "successfully complete" any
6 treatment program. In the nearly 2 years since he was first ordered into treatment he has now
7 only managed to get through the first Phase, which is generally done in six months. He is now
8 allegedly working with Evergreen Treatment Program, his fifth treatment program.
9 As I understood our parenting plan, Don Layton was appointed as a Therapeutic
10 Visitation Supervisor to, "work directly with the father." (Parenting Plan, page 3, line 21 ).. I
11 now see in Ms. Llewellyn's report that she is asserting that I refused to meet with Mr. Layton
12 and that Mr. Layton "soon determined that Mr. Rife did not need help with his parenting skills."
13 I don't believe that is true at all. Mr. Layton did suggest that he meet with Andy and me
14 together. I did not and do not feel comfortable doing that. There is a criminal No Contact Order
15 prohibiting Andy from having any contact with me. My therapist had long advised me against
16
having any "joint" meetings or sessions of any sort with Andy. Both my attorney and my
17 therapist discussed this issue with both Mr. Layton and Ms. Llewellyn .. My therapist made it
clear that from my treatment perspective she did not recommend any joint sessions with Andy.
18
Now Ms. Llewellyn is saying that my attorney, my therapist and I were all mistaken. That is
19
simply not true.
20
I have only received one report from Don Layton and it certainly does not say that Andy
21
does not need help. I notice that no one bothered to attach a copy of that report for this hearing.
22
A copy is attached to this declaration .. It is clear from the first page that Mr. Layton viewed his
23
role as assisting Andy, "with parenting skills" and, "ensuring that his anger issues do not
24
interfere with his parenting tasks." He notes significant anger issues in the ensuing weeks. Mr.
25
Layton noted that, "He [Andy] indeed does have trouble handling his behavior when stressed or
26
·upset." In mid October of 2006 Mr. Layton offered an assessment of how things are going,
27
(page 4 midway down the page). He notes that Andy does have good parenting skills but that he
28
also has a, "submerged mass of toxic resentment he harbors towards Jennifer/her mother - he
29
does pretty well with keeping this from Lauren. He is doing well when I [Mr. Layton] am
30
Dycr & Primont

503 Twelfth Ave. E
Seattle, WA 98102
DECLARATION OF JENNIFER RJFE (206) 343-1528
Page 2
1 present; how well is he doing with this when he is around his family? Or when he is not being
2 watched? The work he is doing in the DV program is important."
3 In his conclusion he states, "The most important issue for Andrew to address is his
4 residual anger. Undoubtedly much ofthis is by virtue of the difficult custody battle that is on the
5 verge of begin resol vec.l; however there is a high likelihood that Andrew harbors a lot of anger
6 from pre Jennifer events in his life also. I am taking opportunities to educate Andrew about
7 anger and what it does to people. I am encouraging him to take full advantage of the DV
8 treatment program that he is in. I also plan to suggest to Bridgett Llewellyn that Aildrew would
.9 benefit from ongoing individual work aimed at exploring what he may carry from his childhood
10 and family or origin." He goes on to say that he thinks he should shift his focus to relational
11 issues rather than parenting skills.
12 It seems to me that Mr: Layton is not saying that there are no issues or problems of
13 concern regarding Andy's parenting. I am not aware that Andy is doing any individual work in
14 any therapy, as Mr. Layton suggested. I have agreed to work with Mr. Layton in conjunction
15 with the advice of my own therapist; just not in any joint sessions with Andy.
16 I do understand and agree that now that Andy has finally completed the first 26 weeks of
17 his treatment program his visitation time should be unsupervised. I have no problem with that.
18 The part· I disagree with is the times and the schedule. I feel that, as recommended by the GAL
19 in her final report to the court, Andy's overall time should not increase until he has completed all
20 of his DV treatment requirements, not simply Phase I. I do not understand why the Case
Manager is now recommending something different than she recommended in her final report as
21
the GAL; it makes no sense to me.
22
We entered into a CR2a agreement last August and at that time started our new parenting
23
arrangement, although the final parenting plan was not signed until later in the fall. Although
24
our parenting plan states visits are to be three hours on Tuesday and Thursday and eight hours on
25
.Saturday, it was not until January' of this year that Andy even began to exercise all the time
26
allotted in the parenting plan. Until January it was three hours three days a week, with many
27
many cancellations having nothing to do with me or our child. I have put together the following
28
to show how often visits have been cancelled just since November.
29
Nov. 1.5 Cancelled, not by me.
30 Nov. 18 Cancelled, not by me.
Nov. 21 Cancelled, not by me .. Dyer & Pn"mont
503 Twelfth Ave. E
Seattle, I-VA 98102
Page3
Nov. 28 Cancelled, not by me.
2
3 Dec. 16 Cancelled, not by me.
Dec. 19 Cancelled, not by me.
4
5 Jan.9 Cancelled, not by me.
Jan 10 Cancelled, not by me.
6
Feb. 10 Cancelled, not by me.
7 Feb. 15 Cancelled, not by me.
8 March22 Cancelled, not by me.
9 March 24 Cancelled, not by me.
March 27 Cancelled, not by me.
10
11 My point here is to make it clear that suggesting that it would be in our two year old
12 daughters best interest to suddenly begin to have not only unsupervised time with Andy but to
13 add in extended overnight time simply makes no sense to me. There is no way.I believe this
14 would be good for her. At our first hearing in the fall of 2005 we provided the court with a copy
15 of the King County Family Court Services Access Guidelines. Commissioner Beadle approved
16 them and based the initial visitation schedule on them. I believe we have been following them
17 ever since. A copy is attached for the court. For toddlers 18 months to 3 years old it states,
,
"When the non-residential parent has been a regular and significant caretaker, ari overnight per
18
week is possible once the child has become accustomed to the other's parent's surroundings.
19
Weekend long access is _still not recommended." In this case, Andy has had supervised
20
visitation for about three hours at a time 2-3 times each week since the fall of2005. During our
21
marriage she was an infant and was never in his care for extended periods of time.
22
The case manager proposed that we continue for another month With the current
23
. schedule, then expand that to include one overnight and follow that for six weeks then expand
24
that to full weekends, Friday through Sunday. Andy believes that the overnight visitation,
25
unsupervised, should start right away.
26
I feel strongly that no overnight should begin until Andy rs actually enrolled and
27
participating in the DV Dads program. Six months ago Andy agreed that there was a history of
28
Domestic Violence and he agreed to our final parenting plan with the restri~tions and the
29
requirement that he complete a DV treatment program, complete DV Dads and complete
30
Respectful Parenting. He has not completed any treatment program yet. He has barelv
. made it
~
Dyer & Primont

503 Twelfth Ave. E
Seattle, WA 98102
DECLARATION OF JENNIFER RlFE
.(206) 343-1528
Page4
1 through Phase I but he certainly has not completed any program and it remains to be seen if he
2 will or can actually openly and accountably complete a full program. The issue here is his ability
3 to parent our child without restrictions. He has agreed to enter _and complete a program aimed
4 specifically at father's who have used abuse in their family relationships. It seems to make sense
5 to me that his time .should not be exparided until he is actually in that program and making
6 satisfactory progress.
7 Andy intimates to the court that he is actually already enrolled in the DV Dad's program.
8 I have been contacted by the program and they have provided all parties with a Client Progress
9 Report dated March 2007. I am attaching a copy of that report. It is clear that he has gone
1o through the intake process but has not finished it and he definitely is not "in" that program right
11 now. They have asked him to provide them with certain information and documentation. Once
12 they receive the requested information they say they will review his file to determine if he is.
13 appropriate for the program.
14 I would love nothing more than for Andy to take his treatment seriously and be
15 accountable for his own actions. Unfortunately it is one thing to talk the talk but it is another to
16 walk the talk. Andy's walk and his talk are not consistent with each other. If he had absorbed
17 the concepts taught in any of his treatment programs he would not still be blaming me for
18 everything and still trying to convince everyone he meets that I am the abuser. In his
19
declarations for this hearing he calls it my, "allegations of abuse." He maintains this position, ·
20 still two years later, despite the fact that he was arrested and charged with assaulting me or
despite the fact that he was arrested again and charged with violating the Criminal No Contact
21
Order. He does not tell us· how he has changed or how he is now accountable or what valuable
22 \
lessons he has learned in treatment. He simply continues to blame me for everything. He

23
attaches declarations that he provided to the court in the fall of 2005. The court's response then
24
was to order that his time be supervised and that he enter into and complete DV Treatment. He
25
provided all of these same declarations to the GAL and her response was that he was an abuser in
26
need of treatment and that his time should be supervised or daytime only until he successfully
27
completes DV treatment.
28
In October of 2006, just six months ago, Don Layton was noting Andy's "toxic rage"
29
against me and my mother. In November of 2006 his progress report from CCS noted that he
30
was having difficulty committing to the program and they had concerns regarding energy being
· Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 5·
spent fighting against doing the program. Then in January they say that he has done his 26
2 sessions but he can no longer be in their treatment program and has to go somewhere else for the_
3 second phase. Although the Case Manager is asserting that he is enrolled at Evergreen
4 Treatment Center, they have not made any contact with me and I have no verification of this.
5 Nothing has changed. Andy is still bouncing froin program to program and still has not managed
6 in almost two years to successfully complete the first of three programs that he has agreed to
·7 participate in, Batterer' s treatment, DV Dads and Respectful Parenting.
8 I also believe that further evidence of that fact that Andy has not changed is his continued
9 abuse of me through the courts. During our divorce Andy filed a motion for a restraining order
10 against me (October 2005) which was denied. In.November he brought a motion for bad faith
11 sanctions, also denied. In December 2005, when my attorney was trying to find out if Andy was
12 in DV treatment, Andy brought a motion to keep us from having access to his file at the
13 treatment program he \vas iii at that time, despite the fact that he had already signed releases to
14 have the treatment provider provide me with the same information he was objecting to. Then in
15 July of 2006 he and his mother snuck over to District Court and obtained two ex parte
16 protections orders keeping my mother and me away from him and his mother. Those petitions
17 were ultimately dismissed at the hearing. The judge made it clear that they had not met their
burden of proof and he believed they had only brought the petitions to attempt to gain some
18
advantage in the family law case. At that same time he brought a motion to have me found in .
19
contempt, also denied. We entered into a CR2a agreement in August 2006 but Andy
20
immediately began backing off on his agreements. We were ultimately forced back into court to
21
get the final orders entered. Since our divorce was finalized in the fall of 2006 Andy has filed a
22
Motion to Disqualify and Dismiss my attorney. This was a completely frivolous motion that his
23
attorney did not confirm and was never heard. Nevertheless I had to incur attorney fees for my
24
attorney to respond to this stupid motion. Then he filed another motion to have me found in .
25
contempt. That motion was also. denied. At the same time, Andy has hired yet another attorney
26
who_ has filed a grievance against my attorney with the Washington State Bar Association. He
27
has also filed a grievance against my attorney's law partner because he stood in for my attorney
28
once last summer. I have read the grievance arid it is based entirely on their assertion that my
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 6
------------
1 attorney never told the truth and Andy and his attorney always told the truth so therefore my
2 attorney was not truthful with the court. We know these grievances will go nowhere anq Andy
3 knows that too. Ii is just another tool to continue to abuse me and anyone that stands by me.
4 Another recent example is his refusal to pay for any daycare for our child while I am in
5 school. He says he does not have to pay for day care unless it is "work" related and since I am
6 going to school so I can work, he says that is not work related. Why would he do this other than
7 to make my life very hard? Why does he still need to beat me up? I will be forced to file a
8 motion on this issue of daycare while I am in school and in an unpaid externship as I believe that
9 is work. If he was a fully supportive father he would want me to get an education and a job and
10 he would be willing to .help with daycare. Instead it is all a game. I only mention it here to show
11 how much he continues to be an abusive person and has not changed and understand the issue of
12 is payment for daycare will be decided at another time.
13 Frankly I am very tired of having to tell this court, once again, that Andy continues to be
14 an abusive person. For once I would love to be able to say, "Hey look, Andy is doing what he is
15 supposed to do and he is being decent about it.';
16 Andy is not only asking that he get more time with our daughter, he is also requesting
17 that the court do away with the restrictions in our final parenting plan, that the court now say that
we have joint decision making and that the case manager's role be substantially expanded to shift
18
the focus away from him to me.' As I iinderstand it froin what my attorney has explained to me,
19
there is no such thing as a "Motion to Modify a Parenting Plan." Our final parenting plan
20
anticipates these changes and there is simply no basis for the changes he is requesting .. I assume
21
his lawyer can read the law, just like mine can. As I understand it RCW 26.09.260 is the only
22
statute that allows a modification of a parenting plan and that statute requires that the court find
23
that there is adequate cause after a Summons and Petition to Modify has been filed. If the court
24
finds that there is adequate cause to proceed then a trial date is set, Andy and his attorney are '
25
apparently asking that the court ignore the law in this regard and modify the parenting plan to
26 '
take away all of the restrictions that Andy and his attorney agreed to last August.
27
This motion is in bad faith and I would ask that I be awarded $3,500.00 in attorney fees
28
and bad faith sanctions for having to respond to this and for his continuing abusive use of this
29
conflict.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 9S102
DECLARA T!ON OF JENNIFER RIFE . (206) 343-1528
Page 7
.. ..
2 foregoing is true and correct. Signed this 28th day of March 2007 in Seanle, Washington.
3
4
5
6
~~d&J
NNIFER LeSOURD ·
7
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Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 8
11
•·=- I"- ED
r111~),'IJ.•!~H .
11
•. ,._
'' '·"I'I: I G
-2 Hf/
SUPERIOR COURT OF ,·~·· · l. D.\i!IELS
WASHINGTON . ,. .~OU~IT 'f CLER~
-- -- -- -- -- "-1Cd0111SH co I'/,'. Sf/
- --- - - - ._,)

(PETITIONER) COMMISSIONER: JACALYN D. BRUDVIK
AND CLERK: HOLLY M. BEAL
JENNIFER RAE RIFE DATE: 07/2/07 AT 9:00 A.M.
(RESPONDENT)
THIS MATTER CAME ON FOR: MOTION REGARDING SUMMER 2007 RESIDENTIAL SCHEDULE (#162)
ACTION:
PETITIONER APPEARED: YES COUNSEL: CARL J. GAUL, I I I
DOCUMENTS FILED:
ORDERS ENTERED: ORDER
PETITIONER'S MOTION THAT THE RESIDENTIAL SCHEDULE BE MODIFIED PURSUANT
TO RESPONDENT'S SCHOOL SCHEDULE IS DENIED.

1
: I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\Ill\\\\\\\\\\\\\\\\\\\\\\\\\
2 CL12434697
7007 JUL 27 AM II: 04
3
PAM L. DANIELS
4 COUNTY CLERK
SNOHOMISH CO .. WASH.
5
8
9 Petitioner
and CALENDAR NOTE
10 (COMMISSIONER'S DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: August 13, 2007
CALENDAR- (Except matters relating to
Nature of Hearing:
Department B or C, As Assigned Motions: motion re
17 residential schedule
18
19
for the matter to be argued. Failure to notify the Court of a continua e or strike may result in sanctions
21 and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for tri ttin . S LM 2. 40(b).
22 Dated: July 26, 2007

23
24
25
26
27
28
CARL J. GAUL
Dl n
CALENDAR NOTE Auorney at Law /'.l,;
302 Bank of America Build'1,g/
Everett WA 98201
1
{COMMl6510NER B DOMESTIC MOTION CALENDAR)
(425) 259-4147 Fax 259·7°181 ~
f ~i=EO
Illllll/ llllll Ill II/I/1/l/l llllllllll lllll111/l lllll /Ill llll
CL 12045310 111111 t"E'O -o \' \-\ '3'.'3S
1 t;.\l\t.LS
Pf>-\'\ L. I) (RI\
2 comni ~b.~1t..s'r\.
s\\Q'r\Or\IS
3
5
7 NO. 05 3 02755 1
Andrew Scott Rife AUAS
and CONTEMPT
9 Respondent.
10
IT IS ORDERED:
11
12
13
Date: February 21, 2007 Time: 9:00 a.m.
14 3000 Rockefeller Commissioner's Department B or C
15
16 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
17 appoint an attorney to represent you.
18 Other:
19 Dated: FEB 0 6 2007 (uJ~

;Jodge f Commissioner
20
Present . by:
21 I
22
23
24
25 CARLJ.GAUL
Attorney at law
26
1604 Hewitt Ave.
27
AUAS ORD TO SHOW CAUSE RE CONTEMPT (ORTSCJ(t::age 1'
WPF DR 05.0150 (9/2001) - RCW 26.09.160 c:
t.,.'iLl8~ tj\j£·:·2_~5 259-4147 F"1. 259 7081
"°'Sf' f1 ~ n Everett WA 9820 l
FILED
I\\\\\\\~\i\\\i\I\\\\\\i\I\i\i\\\\\\\\\\\\\\\l\i\\\\
2007 HAR 22 AM II: 31
I.
1. CL12220108 PAH l. DANIELS
I
" CpUNTY CLER!~
;:i/IOHOMISli CO. \\.'ASH.
4
5
8
9 Petitioner
and CALENDAR NOTE
10 (COMMISSIONER 5
1
DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: April 5, 2007

CALEN DAR- (Except matters relating to
Nature of Hearing:
Department B or C, As Assigned Motions: Modify Parenting Plan
17
18
19
21 and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for'trial settings. SC MAR 2. O(b).
22 Dated: March 20, 2007

23
24
25
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J....~
28
CARLJ.GAUL
CALENDAR NOTE 0 RIG I ' Attorney at law ·;
~~
/VA L
Everett WA 98201
ICCJMMISSICJNER'S DOMESTIC MOTION CACENDARI (425) 259-4147 Fax 259-7081
1
4
CL 11946957
5
7 NO. 05 3 02755 1
Andrew Scott Rife
and CONTEMPT
9 Respondent.
10
IT IS ORDERED:
11
12
13 Date: February 15, 2007 Time: 9:00 a.m.

15
l6 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
17 appoint an attorney to represent you.
18 Other:
19 Dated: JAN 2 9 2007 \ ~-·
20
21
22
23
24
25 CARLJ.GAUL
Attorney al law
26
27
1604 Hewitt Ave.
WPF DR 05.0150 (9/2001) - RCW 26.09.160 425 259-4147 FAX 259 7081
Ftt..E'D
1
I\ \~\ \~\U\ICL~\I12434698
n\ \ \ \ ~Il ~\ \ \~\ \ \ 1\11\\\\ 2001 JUL 21 M" 11: o4
PAHL. DANIELS
2 COUNTY CLERK
SHOHOHISH CO .. WASH.
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 MOTION
Jennifer Rae Rife
16
Andrew Rife moves this Court to enter an Order establishing the
17 residential schedule commencing with the date of hearing of this motion,
18 consistent with the report and recommendation of Bridget Llewellyn dated
uly 26, 2007 as provided in the court's order of April 5, 2007.
19
20 II. Statement of Grounds

21
The court's order of April 5, 2007 established changes of residential time
22
in two 60 day increments, followed by a review hearing in the week of August
23 13, 2007. Ms. Llewellyn has issued a new report and recommendation, which
24 does not mention Christmas time residential schedule. Mr. Rife has proposed
a parenting plan which follows the recommendation of the Case Manager, but
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MOTION Everett WA 98201
PAGE 1 425 259-4147 FAX 259 7081
1 adds a specific provision of Christmas residentail time.
2
III. Evidence Relied Upon
3
4 Declaration of Andrew Rife submitted herewith.

Court's order of April 5, 2007.
5
Case Manager Bridget Llewellyn's repo
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(
8 RL J. GAUL WSf!A
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26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PAGE 2 425 259-4147 FAX 259 7081
•
•

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
11 Respondent.
12 I, ANDREW RIFE, declare under penalty of perjury of the laws of the State of Washington,
hat the following is true and correct.
13
14
I am the former husband of Jennifer LeSourd, and the father of Lauren Rife, who is the
15 subject of the parenting plan in this matter. I make this declaration to support my request
for an adjustment of the parenting plan as recommended by the Case Manager, Bridget
16 Llewellyn.
17 2. ADOPT CASE MANAGER'S RECOMMENDATION, MOSTLY
18 Ms. Llewellyn has filed her five page report. With one exception, I agree with all of Ms.
Llewellyn's recommendations.
19
Ms. Llewellyn does not address the subject of Christmas residential time. I am asking the
20 court to address the subject. The parenting plan already provides for Christmas Eve with
me, and Christmas Day with Ms. LeSourd. I am asking the court to specify that Lauren
21 spend the five days before Christmas Eve with me and the five days following Christmas
Day with Ms. LeSourd. Certainly other suggestions could be made, and I am amenable to
22 working out a different schedule, but the court should address the subject of Christmas
residential time.
23
24 on July 26, 2007 ANDREW RIFE
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 1 425 259-4147 Ft>;/. 259 7081
~-------------------- - -- ----
MAY-01-2007 14:14 FROM-CUSTO~R ENGINEERING 425-783-8650 T-846 P.001/003 F-894
F\l_ED
011'\fi~ -2 M-111: 51
l
ptM l. D/,NIELS
coUtH 'I CLE~ K SH
SNOHOMISH CO. WA .
2
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I11111111111111111111111111111111111111111111111111111111111
s CL12203818
6

COUNTY OF SNOHOMISH
8
9 In re:
Andrew Scott Rife
10 Petitioner, NO. 05 3 02755 1
and
11 SHELLY PATIISON
Jennifer Rae Rife
12 1----------~R~es~p~o~n~d~e~n~t·:..1-------------~
13 I, SHELLY PATTISON, declare under penalty of perjury of the laws of the
14
15
I am Shelly Pattison. I am acquainted with Andrew Rife. I am not
16 acquainted with Jennifer Lesourd.
17 Andrew Rife has asked me to make this declaration to advise the court
of rates I have paid for care of my child cnow age 4l for evening child
18 care.
19 2. NANNY RATES
20 From the time my daughter was 6 months old to the time she was 2 Y2,
I had a nanny come to my home to care for her during work hours. I
21 paid her $7.50 per hour, strictly for the care of my daughter. The
nanny was expected to not be doing housework or anvthing else that
22 did not relate directly to my daughter.
23 3. GRANDMOTHER RATES
24 When my daughter was 2 Y2 my mother began caring for my daughter
on a regular basis during my work hours. I paid her a little under ss.oo
25 per hour for this service. Any time that was outtside of my work hours
26
CARLJ.GAUL
Attorney at Law
27 302 Bank of Arnerica Bldg.
1604 Hewitt Ave.
DECLARATION OF SHELLY PATilSON . Everett WA 98201
Page 1 ~~9-4147 FAX 259 7081
1
a~\\J\~
•
MAY-01-ZOOT 14:14 FROtj-CUSTOt.ER ENGINEERING 425-783-8650 T-846 P.OOZ/003 F-894
1 was considered "grandparenting" time and was not compensated.

2
4
executed at Everett WA
on May 1, 2007
5
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26 CARLJ, GAUL
Attorney 11t Law
1604 Hewitt Ave.
DECLARATION OF SHELLY PAlTISON Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
2
F\LED
01 JUN I '5 Pr\ iz: OS
1
PAHL 01\\~\ELS
cou11TY ct.ERl'ASH
2 SNOHOi~\SH CO. W .
: !i I\\\\\\\ 111111Ill1111111111 \\\\I l\1\11111111111111111111

CL12362386
Ill\
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 MOTION RE SUMMER 2007
Jennifer Rae LeSourd (fka Rife) RESIDENTIAL SCHEDULE
11 Respondent.
12
13 comes now Andrew Rife, Petitioner above named, and moves this court to
enter an Order granting the relief requested in Part I below:
14
I. Relief Requested
15 Andrew Rife moves this court to enter an Order which adopts his proposed
residential schedule for summer 2007.
16
17 Mother's school schedule will cause her to be unavailable for three evenings
per week during July and August 2007. For those two months only, Mr. Rife requests
18 a change of the residential schedule so the child will be with him rather than in
nonparental care.
19
20 Should an available father have residential time with the child during times
the mother is unavailable?
21
IV.
22
23
24
25
26
ORIGIN CARLJ.GAUL
Attorney at Law
27
MOTION RE SUMMER 2007
RESIDENTIAL SCHEDULE
1604 Hewitt Ave.
Everett WA 98201
J_L
Page 1 425 259-4147 FAX 259 7081
\Lo)
' I
I
\\\\\ml\~\\\CL12269315
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Ff L.EO
1 07JUN26PM/2:17
PAM l. DANIELS
2 COUNTY CLERK
SNOHOMISH CO. W /\SH.
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 REPLY DECLARATION OF ANDREW RIFE
Jennifer Rae Rife
12
I, Andrew Rife, declare under penalty of perjury of the laws of the state of
15 I am the Petitioner in this matter. I make this declaration to reply to my

former wife's declaration dated June 21, 2007.
16
2. FACTS NOT PREVIOUSLY KNOWN BY THE COURT
17
MY former wife would have the court believe the present motion is simply a
18 request for reconsideration of the court's decision of April 5, 2007. Nothing
could be further from the truth.
19
In mid·May 2007 Ms. LeSourd enrolled in a program leading to a nursing
20 degree. This information did not exist when we were before the court on
April 5, 2007 and could not have been presented to the court at that time.
21 The court was not even informed that she had any intention of enrolling in
that program'. MY attorney received copies of the enrollment documents
22 soon after her enrollment.
23 ! - - - - - - - - - - -
24 At the time of the court's April 5, 2007 decision, the court was not fully informed of Ms. LeSourd's
educational pursuits. In her declaration of March 28, 2007 (page 7, lines 7-12) she refers to being in school and an
unpaid externship. It was a technical course to become a phlebotomist technician, the classes for which ended the
25 ery next day. She has yet to file any verifiable information about her completion of the externship portion of the
program.
26
CARLJ.GAUL
27
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
c;tL
Reply Declaration of Andrew Rife
CC:/. 259 7081
llol
,.
1 Among the surprises in the educational documents we received was the news
of Ms. Lesourd's class schedule commencing July 2, 2007 which will keep her
2 until 9:1 s p.m. in class in Kirkland three nights each week.
3 Ms. LeSourd provides a declaration of her mother, Carol Holland in which Ms.
Holland volunteers to handle all the exchanges when her daughter will be
4 unavailable due to her educational commitments. The offer belies the simple
fact: Jennifer will be unavailable to care for our daughter during the time I
5 have asked for residential time.
6 3. ULTERIOR MOTIVE
7 My attorney wrote to Ms. Dyer about the summer schedule on May 30, 2007.
In that letter he proposed the same schedule as I am proposing in my present
8 motion. Ms. Dyer responded on May 31, 2007, stating, "I received your letter
just as I was drafting one to you regarding some of the same issues. I agree
9 that there may be a better schedule for the next couple of months and am
open to looking at that issue." The balance of the letter deals with Ms. Dyer's
10 frustration in communicating with Evergreen Manor and the requirements
Family Services has for its participants, not subjects over which 1 have any
11 control.
12 Ms. Dyer has never proposed any alternative residential schedule for the next
couple of months, her letter of May 31 notwithstanding. My attorney wrote
13 on June 1 and June 13 trying to find an agreement concerning summer
residential schedule. No response was received on those issues. There being
14 no progress toward agreement, we had no choice but to file the present
motion so it could be heard before Ms. Lesourd's summer educational term
15 begins on July 2, 2007.
16 Ms. LeSourd and her attorney have set out upon a campaign designed to
prevent a normal father-daughter relationship. Please review the declaration
17 of Bridget Llewellyn dated April 1, 2007 and filed as a sealed Document on
April 2, 2007.
18
Referring to herself, Mr. Layton, and Judy Dyer, Ms. Llewellyn notes:
19
... It was all of our opinions based on many hours of observation that
20 Mr. Rife did not need Therapeutic and/or other supervised visits with
Lauren. His parenting skills are exemplary and she adores him. He
21 is consistent, loving, and assertive when necessary and always
tuned into her needs. No matter if it is a short (2 houn or long (8
22 houn visit. He has had an inordinate amount of visits ... 2
23 (Emphasis addedl.
24
25 2
Page 4, lines 1-3.
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Reply Declaration of Andrew Rife Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
. . .
1 After reviewing the facts of her involvement for several pages, Ms. Llewellyn
notes at page 6, line 6, "Ms. Dyer has made it crystal clear that she is out to
2 seek and destroy this man's relationship with his child and to make his life
miserable as is possible."
3
4. MY OPINIONS
4
There is no reason the summer schedule I have suggested should not be
s implemented.
6 MY former wife will be unavailable to care for our daughter for significant
time through July and August. I have asked for residential time during that
7 period. In September Ms. LeSourd has a more ordinary schedule, and I have
not asked for increased residential time during that time as it is to be
8 determined at a mid-August hearing if we do not have an agreement by then.
9
10
on June 25, 2007
11
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CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Reply Declaration of Andrew Rife Everett WA 98201
Page 3 425 259-4147 FAX 259 7081
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10
11 JENNIFER R. RIFE
(nka Jennifer LeSourd) NO. 05-3-02755-1
12 Petitioner,
And RESPONSE TO ANDREW RIFE'S
13 MOTION TO DISMISS TO
ANDREW S. RIFE, DISQUALIFY COUNSEL, AND;
14 Respondent. MOTION TO STRIKE
15
16
PETITIONER denies that the Motion to Dismiss and to Disqualify Counsel, and Motion to Strike
17
have a basis in fact or in law, and should therefore be denied.
18
The motions should be denied for the following reasons:
19 I. Neither motion meets the requirements of Washington State Superior Court Civil Rules 7 or 11.
20 CR I !(a) states that "Every pleading, motion, and legal memorandum ofa party represented by an
21 attorney shall be dated and signed by at least one attorney ofrecord in the attorney's individual
22 name[ ... ]." CR 7(b)(3) requires that all motions be signed in accordance with CR 11. Neither of the
23 motions is signed by the attorney. Therefore, both motions should both be stricken, and, an award of
24 attorneys fees to Petitioner in the amount of $1,000.00 should be granted for the expenses incurred in
25 responding to the motions.
ORIGINAL
Response to Andrew Rife 's Motion to Dismiss and to Disqualify Dyer & Primon
Counsel 503 Twelfth Ave. E, Seattle, WA 9810
1206) 343-152
1 2. The Motion to Disqualify Jan Dyer from further participation in this case is utterly without merit.
2 Respondent claims "attachment 12 to Jennifer's declaration" is a memo that Ms. Dyer sent to Theresa
3 Fox. (Exhibit A, al/ached and incorporated by reference) In fact, our Exhibit 12 an entirely different
4 document. (Exhibit B, al/ached and incorporated by reference) It is a copy of a Motion to Transfer Case
5 to Superior Court which was filed in the case. The memo which Mr. Rife attaches to his Motion to
6 Disqualify is nowhere contained in the pleadings in this action. Therefore, this action is without any
7 merit. It is not grounded in any fact, and should be dismissed, and sanctions should be issued under CR
8 11 in the amount of $1,000.00.
9 3. The Motion to Strike: Respondent moves to strike parts of my declaration which are matters of
1O fact that are not privileged by any rule, and therefore the Motion should be denied.
11 4. The Motion to Dismiss the Petition: This motion goes to the substance of the underlying petition
12 for a protection order. The facts are presented in the accompanying declaration of Jennifer LeSourd.
13 For all of the above-stated reasons, Petitioner requests that the motions be denied, and that
14 attorneys fees and sanctions in the amount of $2,000.00 be awarded to Petitioner.
15
16 Presented by: DYER & PRIMONT

Attorneys for Jennifer LeSourd
17
18
19
20
21
22
23
24
25
Response to Andrew Rife 's Motion to Dismiss and to Disqualify Dyer & Primon
Counsel 503 Twelflh Ave. E, Seattle, WA 9810
(206) 343-152
/
JAN M. DYER
Atl:or11ey
200/34.3..1526
:206/3'13-7791 rx
MEMO
TO: Theresa Cox

FROM: Jan Dyer
JJATE: May 11, 2006
RE: Andy Rife review/revocation hearing
1 understand that the court is having a hearing to look into

Mr. Rife's treatment status. Since I have been the person l'nost
closely observing his treatment status; from his victbn 's
perspective, I wanted to share some iii.formation with you.
Mr. Rife was initially ordered into treatment in May 2005. He

went to Davis and Company. The records we have from that
time make it clear that their assessment wa,s- that Mr. Rife had
a significant problem with domestic violence. No long after
their assessment came out Mr. Rife quit going to treatment, l
believe that was so1netime inj/'K*l&t of 2005.
Uf!L -
He was arrested again in October of 2005, this time for
violating the no contact order. He was at the house and he
was the person that called the police trying to get Jen a17'ested.
The cops could tell he was lying and arrested hiTn instead.
At about the same time this was filed as a divorce and we

started our process in the family law courts. Wlten he hired
his f a1nily law attorney he was apparently directed to enroll in
8
)AN M. DYER
Attotnt!y
206/~l'i-~-1~20
106/5<>-·7791 r,
treatment with Chuck De Vore, which he .did. Mr. De Vore 's

treatment does not comply with the WAC's and his state
certification is currently under investigation. /have personal
experience with Mr. De Vore and his "treatment" progra.1n. In
n1y opinion it is a useless program, at least for the stated
p1upose. Unfortunately what I have seen is that the offending
parent actual(y gets wotse while in treatment with Mr. De Vore.
11iat certainly seems to be the case with Mr. Rife as lie is still
quite abusive and continues to blame his victim for everything.
Our fa1nily law case is all about him trying to prove what a
bad person she is to deflect this charge of domestic violence.
The issues has been raised by Mr. Rife's attorney several tilnes
and much investigation has been done but Mr. Rife's visitation
with his daughter is still supervised and not overnight.
So now our GAL has insisted that Andy get into a progra1tl
tit at is compliant with the WAC and tliat operates in a group
therapy setting (as mandated by the WA Cs) versus individual
sessions (forbidden by the WACs but what Mr. De Vore does).
He has switched programs but now! understand he wants
advanced ,5tanding because of all the time he has already been
in treatment. I urge you to argue strongly against this. HE
SlIOULD NOT GET CREDIT FOR SOMETEIING FJE llA.S
NOT DONE. A 12 month DVprogram mandates that Phase l
be weekly group sessions. Andy has never done this and
should certainly not be given credit for it now. All he has done
it to try to avoid treatment. Davis and Co. tried to hold hbn
9
)AN M. DYER
Attorney
~06/3•3-1529
206/34.3-7701 f.it
accountable and he quit. Chuck De Vore never tries to hold

anyone accountable and that suited Andy just fine.
Accountability is what tteatment is all about and its time Andy
had to take some. ,
Jen and I have worked very hard to get the matter this far and
us·
we are trusting that you will not let down. Mr. Rife needs to
be in a real WAC compliant treatment progrant. The reality is
he has gone a year and still has not really done treatment.
Been kicked out at Davis and Co, and then went to an
unqualified treatment center. Looks like noncompliance to
me.
.......
Let us know what happens.
10
,.
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'*,. 1
2 .'
3
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7
8 DISTRICT COURT OF WASHING TON
9
NO.· U06-216
10 ANDREW RIFE
11
Petitioner MOTION TO TRANSFER CASE ro
vs. SUPERIOR COURT (HARASSMENT)
12 CAROL HOLLAND (MT).
Respondent
13
14 I. MOTION.
15 Based on the declaration below, on behalf of Carol Holland, we move the court for an order transferring the
~ case to the Snohomish County Superior Court
16
17 Dated: -::/- · Z u - D<.-
18 20355
19
II. DECLARATION I OFFER OF PROOF
20
21 2.1 I am the attorney for Carol Holland and Jennifer Rife. I also represent Jennifer Rife in the
dissolution of her marriage in Snohomish County Superior Court. I am unavailable to be in court this
22
morning as I have a hearing in Mt. Vernon at the Skagit County Superior Court at 9:00 a.m. Michael
.23
Primont is appearing in my absence to present this motion.
24
25 2.2 . The following meritorious reasons exist to transfer the case to Superior Court:
26 Carol Holland is the mother of Jennifer Rife who is the respondent in companion case, U06-215.
27 Andrew Rife is Jeruiifer's husband. Andrew filed for dissolution of his marriage to Jennifer Rife. That
28 matter is scheduled for trial in Snohomish County Superior Court on August 21, 2006. (In re Rife, 05-3-
02755-1). The petitioner in U06-216 is Andrew Rife's mother, Wendy Rife.
29
30
MT TO TRANS CASE TO SUPER COURT (HARASSMENT) (MT)·_ Page l of 3
UH-08.0100 (9/2000) • RCW 10.14.150 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
8 (206) 343-1528
EX1·:rnr
---
1 · Andrew Rife is currently under a stipulated order of continuance out of Everett Municipal Couri
2 relative to a charge of DV Assault and Violation of a Criminal No Contact Ordior. In both, Jennifer Rife is
3 · his victim, (CR 67770 and CR 69259).
4 Jennifer Rife has a Domestic Violence Protection Order, under the dissolution cause number in
5 Superior Court, protecting both she and the parties daugbter from further acts of domestic violence from
Andrew Rife.
6
Wendy Rife, Andrew's mother, has served as the "visitation supervisor" for all visitation between
·7
Andrew Rife and his 22 month old daughter. Mr. Rife has had no unsupervised visitation with his daughter
.8
since his arrest in October of 2005 for Violation of the No Contact Order. To our knowledge and belief,
9
although ordered to enter and successfully complete a state certified domestic violence perpetrators
10 treatment program in the criminal case, Mr. Rife is not currently enrolled in any treatment program. He has
11 been enrolled in at least 3 treatment programs in the last year but has yet to successfully complete any of
12 them.
13 Because of the Protection Order and No Contact Order that Je~nifer Rife has against Andrew Rife,
14 her mother Carol Holland has been helping facilitate the visitation transfers. Both grandmothers, Carol
15 Holland and Wendy Rife, have been the involved persons for the last nine months in all of the visitation
16 transfers. Mr. Rife has obtained a Temporary Order from this court which prevents Carol Holland from
coming near or having any contact with Andrew Rife. That effectively prevents her from facilitating the
17
visitation transfers. It also makes her and any other member of her family completely unwilling to help any
18
further with the visitation transfers. Ms. Holland and Ms. Rife adamantly deny each and evety allegation
19
made by Mr. Rife and his mother and asserts that neither has done anything to intimidate, threaten or harass
20
Mr. Rife or his mother Wendy Rife. It is our belief that a court may find, after hearing all the evidence in
21
this matter that this motion has been brought in bad faith and for improper purposes. We believe there is
22 substantial evidenCf: on that point. At a minimum we believe, these Petitions do not meet their burden of
23 proof and will be denied after a full hearing.
24 Because of the Protection Order and No Contact Order and the histoty of domestic violence
25 committed by Andrew Rife, the Family Law Commissioners who have handled this case have steadfastly
26 ruled that Andrew's time with his child is to be supervised. The supervisor has been his mother, Wendy
27 Rife. Wendy has obtained a Temporary Order from this court which prevents Jennifer Rife from coming
near or having any contact with Wendy Rife, the visitation supervisor. Given that neither Jennifer Rife or
28
Carol Holland can come near Andrew Rife or Wendy Rife, visitation with the child is currently impossible.
29
30
MT TO TRANS CASE TO SUPER COURT (HARASSMENT) (MT)-Page 2 of3
UH,08.0100 (9/2000)- RCW 10.14.150 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
.. 1 On the day that these orders were obtained, July 7, 2005, there was also an ex parte hearing on.the·
2 dissolution case in Superior Court. That hearing was brought at Jennifer Rife's request and on notice to
3 Andrew Rife and his attorney. Yet, Mr. Rife and the same attorney saw fit to come to this court on the same
4 day and with no notice to Jennifer Rife and her attorney, and obtain these Temporary Orders.
5 There. was no emergency, no imminent harm or no immediate threat. Not one of the alleged
inciden.ts in either petition happened less than a month ago and most were allegations of things that
6
happened in 2005. Although Mr. Rife's attorney served Jennifer Rife when they were in Superior Court
7
· lat.er that day, Ms. Holland was not served for another 6 days. She facilitated two more visitations with
8
Andrew Rife willingly in attendance before she learned that he had obtained this order.
9
There are currently two hearings set in the family law case on this very issue (visitation in light of
10
these orders, visitation in light of Andrew Rife's failure to be enrolled in Domestic Violence Treatment, and
11 Mr. Rife's motion for Contempt claiming Jennifer Rife is in contempt due to the fact that these two orders
12 have made visitation with the parties child impossible. Those hearings are set for Monday July 31, 2006 in
13 the Family Law Department of the Snohomish County Courthouse.
14 We are asking to have these two Petitions set over to Superior Court to be heard on July 31, 2006 with
15 the family law motions. They involve the same issues and same parties and each are indispensable to a just
16 and equitable resolution of the issues presented. We respectfully request that this court so order.
We have no objection to a re issuance of the current order through the 31 ~of July 2006. Mr. Primont
17
is authorized to accept service on behalf of Ms. Holland and Ms. Rife. If the court denjes this motion then
18
we would ask that these matters be continued to a time when I can be available to present our case. Mr.
19
Primont has my available dates and times.
20
Respectfully submitted this Zt> of July 2006.
21
22
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25
26
27
28
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MT TO lRANS CASE TO SUPER COURT (HARASSMENT) (MT)- Page 3 of 3
UH-08.0100 (9/2000)-RCW 10.14.150 Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
f\LED
o fEB 21
J PM 3: 29
SUPERIOR COURT OF p/',M L. DANIELS
COUN1 ·1 CLE.~J'..
WASHINGTON SNOHO!-liSH CO. rl .. SH.

(PETITIONER) COMMISSIONER:, ARDEN J. BEDLE
AND CLERK: S. HUBER
JENNIFER RAE RIFE NKA LESOURD DATE: 02/21/07 AT 9:00 A.M.
THIS MATTER CAME ON FOR: ALIAS SHOW CAUSE RE CONTEMPT

ACTION:
GUARDIAN AD LITEM APPEARED: NO
DOCUMENTS FILED:
ORDERS ENTERED: ORDER ON SHOW CAUSE RE CONTEMPT/ JUDGMENT, TO BE FILED BY COUNSEL
DYER.
THE COURT DENIES PETITIONER'S MOTION FOR CONTEMPT FOR RESPONDENT MISSING
ONE VISIT BY WHICH SHE WAS AGREEABLE TO, BUT WAS NOT CLEAR ON THE TIME.
PETITIONER HAS CANCELLED 9 OR 10 VISITS HIMSELF WHICH IS NOT CONTRADICTED BY
HIM. HE HARDLY COMES TO COURT TODAY WITH CLEAN HANDS. THE COURT DOES NOT FIND
CONTEMPT.
PETITIONER IS TO HAVE RESIDENTIAL TIME WITH THE CHILDREN FROM 3 TO 6 P.M.
TUESDAYS AND THURSDAYS, AND 10 A.M. TO 6 P.M. SATURDAYS. PETITIONER IS TO
CONFIRM TWO DAYS PRIOR TO THE VISIT WITH BRIDGET LLEWELLYN THAT HE IS GOING TO
EXERCISE HIS VISITATION, OR THE VISIT WILL NOT OCCUR. THE VISIT TOMORROW WILL
OCCUR.
THE COURT DENIES PETITIONER'S REQUEST FOR A MAKE-UP VISIT.

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10 REPLY DECLARATION -·c i'3 ..,.~
Jennifer Rae Rife OF ANDREW RIFE :"J:;r'.

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11 Respondent. ,>.....: "
~·
12
I, Andrew Rife, declare under penalty of perjury of the laws of the State of Washington, that "
13 the following is true and correct.
14 1. AGREED MATTER: SUPERVISION SHOULD END

15 Jennifer Lesourd's responding declaration (at page 3 lines 16-17) states "I do
understand and agree that now that Andy has finally competed the first 26 weeks of his
16 reatment program his visitation time should be unsupervised. I have no problem with
hat."
17
Jennifer would not agree to discontinue supervision if she were not confident that
18 Lauren is safe with me and that I am a good Daddy. She knows that there is no reason
for Lauren to not spend time with me. I take good care of Lauren. Jennifer knows that
19 there is no reason to keep Lauren from the paternal side of her family. She knows that
there is no reason Lauren should not go to church, and that I will take her. She knows
20 that Lauren's time with me should be expanded.
21 I have not chosen to cancel any visit for personal convenience. In the five months
since entry of the decree, sixteen scheduled visits have not occurred. Four were cancelled
22 due to the lack of a supervisor. Five were cancelled due to my own illnesses. Six were
cancelled when I was called out by my employer for mandatory overtime resulting from
23 storm damage to the electrical system. One was cancelled by Jennifer LeSourd when she
did not deliver the child. If supervision were not required certainly four more visits would
24 have occurred. Perhaps some of the visits missed during the call out could have occurred
also.
25
26
CARLJ.GAUL
Attorney at Law
REPLY DECLARATION OF ANDREW RIFE
Page 1
OR\G\NAL 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
,,
1 Explanation of Cancellation
Date
2 11/15/06 Supervisor Unavailable. Cancelled by Judy Dyer
3 11/18/06 Supervisor Unavailable. Cancelled by Bridget Llewellyn
4 11/21/06 Supervisor Unavailable. Cancelled by Don Layton

11/22/06 Illness (acute bronchitis). Cancelled by me
5
11/28 & 29/06 Mandatory Employment Call Out due to storm. Cancelled by me.
6
12/16/06 Mandatory Employment Call Out due to storm. Cancelled by me.
7
12/20/06 Mandatory Employment Call Out due to storm. Cancelled by me.
8 Mandatory Employment Call Out due to storm. Cancelled by me.
1/9 & 10/07
9 1/20/07 Child not delivered. Cancelled by Jennifer LeSourd.
10 2/10 & 17/07 Illness (Influenza A & B). Cancelled by me
11 3/22 & 24/07 Illness (staph infection). Cancelled by me

3/27/07 Supervisor Unavailable. Cancelled by Don Layton
12
13
2. MODIFICATION OF NOVEMBER 7, 2006 PARENTING PLAN
14
I want the court to be mindful that this is a request to modify the parenting plan
15 entered on November 7, 2006 pursuant to the terms of that order. It is not a request to
modify any temporary parenting plan.
16
The November 7, 2006 parenting plan was entered by agreement of my former wife
17 and myself along with the Guardian ad Litem, Bridget Llewellyn.
18 Jennifer LeSourd's responding declaration often focuses on what was said and done
before the decree, as though those old facts were current facts. Generally speaking, they
19 are not current facts. And she certainly knew the pre-decree facts at the time she signed
the parenting plan on November 7, 2006 and appeared before Judge Castleberry affirming
20 that the parenting plan should be entered. The parenting plan contemplated that it would
be modified as I progressed through my treatment. I committed to a full year treatment
21 program, and I also committed to two additional programs. The parenting plan allows for
increases in my time with our daughter before I have completed all of them.
22
3. NEW SCHEDULE
23
Jennifer LeSourd's responding declaration asserts that my residential time should
24 not be expanded until I have satisfied each and every requirement of the November 7,
2006 parenting plan. She is asking the court to impose a requirement not found in the
25 order. And, she makes no reference to the father daughter relationship nor does she make
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
REPLY DECLARATION OF ANDREW RIFE Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
1 any explanation how Lauren would be benefitted if the court were to follow her
recommendation.
2
A. THE ORDER AND THE RECOMMENDATIONS OF EXPERTS
3
The divorce settled on November 7, 2006 (not on August 7, 2006). The
4 decretal parenting plan provides at paragraph 3.10 3:
5 Visitations will be supervised by Don Layton or his designee. Don Layton is

appointed as a Therapeutic Visitation Supervisor to work directly with the
6 father. Mr. Layton may expand or contract the visit times or durations,
however, there shall be no expansion of time until the father has successfully
7 completed Phase I of his treatment program.
8 (Emphasis added).
9 I have completed Phase I of the domestic violence perpetrator's treatment

program. The Therapeutic Visitation Supervisor Don Layton has recommended that
10 supervision be discontinued. The case manager has recommended that supervision
be discontinued and Lauren's time with me expanded.
11
One of the Case Manager's duties is to make recommendations concerning
12 expanded access. The decretal parenting plan provides at paragraph 3.10 4:
13 Bridget Llewellyn is appointed as Case Manager (she has been the appointed
GAL during the case). She shall communicate with all parties and
14 professionals working with the father and make written recommendations on
future expanded access for the father.
15
(Emphasis added)
16
Ms. Llewellyn has made a written recommendation of expanded access.
17
The decretal parenting plan provides at paragraph 3.10 5 (in part):
18
At such time as the Case Manager determines that the father has progressed
19 and visitation should be expanded, she will write a report and make
recommendations. The parties may agree to those recommendations or
20 modify those recommendations by their a9reement. Absent written
agreement there shall be no change expect (sic) by court order...
21
Ms. Llewellyn has determined that I have progressed. She has determined that
22 visitation should be expanded. She has written a report making recommendations. My
former wife has not agreed to those recommendations, so they have not yet been
23 implemented. Because there is no written agreement a court order is necessary, which is
why I have filed the present motion. Don Layton concurs with Ms. Llewellyn's
24 recommendation. His November 2, 2006 report concludes:
25 I do not believe Andrew needs ongoing parenting work. He does, however, need
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 coaching about dealing with Jennifer and others in the wake of a bitter divorce.
Jennifer, also, has invited my input regarding dealing with the visitation process.
2 I would suggest that my efforts shift from a primary emphasis on parenting skills
to a focus on relational issues. In this I would work with each parent and would
3 partner (dialog with) the professionals involved with them.
4 B. DAUGHTER - FATHER RELATIONSHIP

5 I have provided the court copies of declarations filed in the fall of 2005 to show the
court my involvement as a father at that time. I was highly involved. Since that time I
6 have had supervised residential time. Jennifer's declaration references the King County
ccess Guidelines, with their emphasis on the importance of the child being familiar with
7 he non-custodial parent's home. Lauren is familiar with my home - it is where she lived
until the separation, and it is where she has spent most of the time she has been with me
8 in the last 15 months. She still sleeps in the room she has known all her life.
9 Lauren is consistently happy to see me. The experts, Don Layton and Bridget
Llewellyn, recognize the bond and Lauren's comfort level. They also recognize that I am
10 competent to do the job of parenting my daughter. Neither of them expresses any
concern about my ability to parent.
11
A typical visit has involved pickup, then transportation to where the visit itself will
12 actually occur (my home, a park, etc.). Then I spend my time interacting with Lauren
while being observed by the supervisor, whether Don, Judy or Bridget. This always
13 involves a great deal of play and tasks where she and I help each other do something.
here will typically be time where she will play alone while I am doing something else,
14 often getting a meal prepared. I feed Lauren and I take care of her.
15 3. MY TREATMENT HISTORY
16 Jennifer and her attorney have consistently attempted to mislead the court
concerning my domestic violence perpetrator's treatment1. I have attended:
17
Counseling pursuant to Everett Municipal Court Order:
18
Provider Sessions
19
Davis & Co. 2
20
Summit Counseling (Joint Counseling) 7
21 5
Summit Counseling (Individual Counseling)
22 Charles Devore 25
23 1--~~~~~~~~~
1
24 I want the court to be aware that the Everett Municipal Court did order me
into a DV treatment program. I complied with that requirement. The Municipal Court
25 determined that I had complied with all treatment requirements last Maf. I have no
ongoing or future DV treatment requirements with the Everett Municipa Court.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
1 7
Phoenix Counseling
2 Subtotal 46
3 Counseling pursuant to Superior Court Order:
4 Provider Sessions
Catholic Community Services 26
5
Evergreen Manor 1
6
Subtotal 27
7
Total Sessions 73
8
9 Jennifer never requested any treatment program until July 2006, two months after
I had satisfied the Municipal Court.
10
Jennifer filed case 05 2 01268 2, a petition for an order of protection from domestic
11 violence on October 3, 2005. She did not request that I be ordered to obtain any
counseling or treatment. The court reissued the temporary order of protection nine times,
12 but the petition was eventually dismissed. No permanent order of protection was ever
entered in that matter.
13
On October 19, 2005 I filed the divorce and a show cause hearing was scheduled.
14 ennifer responded to it. But she did not file any motion requesting that I be ordered into
any evaluation or treatment program. Even though she had not filed a motion requesting
1s hat I enter into treatment, she and her attorney frequently expressed to the GAL and to
the Superior Court Commissioners their opinion that I was out of compliance with the
16 orders of the Municipal Court. The Municipal Court did not share that opinion.
17 The divorce was set for trial on August 21, 2006. On July 7, 2006 (sub number 85},
ennifer filed a motion which requested that I be required to enter into DV perpetrators
1s treatment. Commissioner Stewart denied that motion without prejudice. On July 31,
2006, less than a month before our scheduled trial date, Commissioner Waggoner granted
19 the motion. Thereafter I went to Catholic Community Services.
20 Jennifer belittles my treatment history, claiming that I have "barely made it" through
Phase I. She ignores the history. I have recently completed Phase I, on schedule. I have
21 been involved in domestic violence perpetrator's treatment nearly continuously since the
fall of 2005. I have always complied with all requirements of each program I have
22 attended. I have been personally involved in my treatment program on an ongoing basis.
23 Jennifer claims that I am "bouncing from program to program." What a crock!

When the Everett Municipal Court ordered me to participate I did so. When this court
24 ordered me to participate I did so a second time. What should be evident is my
commitment to the process of changing my behavior and the attitudes behind that
25 behavior. I am determined to improve myself by the education. On January 25, 2007 I
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 5 . 425 259-4147 FAX 259 7081
1 was leaving my weekly meeting when I happened to see Jan Dyer at Catholic Community
Services. I said "Hi" and continued on my way. At the time Sandy Poirer was satisfied
2 with my progress. Then I received a letter from Sandy Poirer informing me that Catholic
Community Services is recusing itself from my case and that I must find a new service
3 provider, copy attached. When my attorney and I requested information why this step was
being taken, the response was only to provide the name and telephone number of CCS's
4 attorney. Sandy Poirer would not talk about it. No useful information was learned from
the attorney, either. I was able to enroll in a program at Evergreen Manor. See March 13,
5 2007 letter from Evergreen Manor, attached. Just last week I received a copy of Jan
Dyer's February 2, 2007 letter to Sandy Poirer in which she damned me roundly, copy
6 attached. Notice that her letter does not mention a single thing I have done to justify her
condemnatory statements. Since the provider must treat information received from a
7 victim as confidential, Sandy could not even confront me with whatever Jan Dyer may have
said 2 • She would have been left in an impossible situation. I will continue my
8 participation.
9 4. FALSE ISSUES
10 A. DON LAYTON
11 Again, there is an agreement hidden in the text. Jennifer now agrees to Don
Layton's proposal for therapy.
12
Don Layton, MSW was designated as the Therapeutic Visitation Supervisor. He soon
13 concluded that I did not really need his services and delegated the actual supervision to
others. He did suggest that he work with Jennifer and me individually to work on co-
14 parenting issues. He never suggested to me that Jennifer and I should ever meet
together, merely that we both engage with him in this process. Jennifer declined. I am
15 pleased that she now says (page 3, lines 14-15) "I have agreed to work with Mr. Layton
in conjunction with the advice of my own therapist' just not in any joint sessions with
16 Andy. Nobody ever suggested joint sessions.
17 B. OLD NEWS
18 In the oral ruling of November 1, 2005, Commissioner Bedle ordered supervised
visits because he was aware that there was a statistical risk that with Jennifer unavailable
19 I might "substitute" Lauren as recipient of physical violence. I appreciated then the
caution he was showing.
20
But now, 15 months later, there is no indication of any risk to Lauren. There is
21 instead an indication of benefit.
22 1----------
2
23 It would be a brave attorney who would make a distinction between
information received from Jennifer LeSourd and information received from Jan Dyer. In
24 her December 2, 2005 letter to Bridget Llewellyn Ms. Dyer denied the distinction, saying
'Let me clarify something for r,ou, I stand in the shoes of my client. If I say something,
25 it is the same as if she said it. ' Given that position, CCS could not even confront me
and give me an opportunity to respond to whatever Ms. Dyer may have said.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 6 425 259-4147 FAX 259 7081
1 c. JENNIFER'S LITIGATION COMPLAINTS
2 In an attempt to divert attention from the parenting issues, Jennifer attempts to
claim that my participation in this litigation somehow constitutes abuse of her. She got her
3 facts wrong. If the court wants to review those issues, I have attached a table which lists
her complaints and my responses. She has nothing to complain about. Each of us has
4 on some and lost some. Though she vigorously argued the domestic violence case, in
the end it proved a lost cause. We appeared for 9 (nine) hearings before she abandoned
5 he action. Then she settled the divorce without a domestic violence restraining order.
fter the decree was entered she had me served with a DV petition (simplv. repeating the
6 allegations from her 2005 DV petition) bearing the divorce cause number, then did not
proceed to a hearing. After that she filed a new DV action (again repeating the allegations
7 from her 2005 DV petition) which did proceed to a hearing. After hearing on the merits
Commissioner Stewart dismissed with prejudice.
8
6. BLAMING
9
Jennifer LeSourd claims that "He simply continues to blame me for everything."
10 Hardly. It is interesting that she provides not one single example of something I blame
her for. She does not include in her declaration anything, not one thing I blame her for,
11 but claims I blame her for every thing.
12 I have always acknowledged my own responsibility for my own conduct. I decline

to acknowledge responsibility for things that are beyond my control. I am responsible for
13 my own use of force. I am not responsible for Jennifer LeSourd's alcoholism nor her
temper. I am responsible for my own responses to her.
14
7. DON'T FORGET THE BABY
15
I am asking the court to look at the current facts, including my successful
16 completion of Phase I. I am asking the court to look at the Case Manager's
recommendation. Her recommendation should be implemented.
17
18
19
20
Executed at Everett WA on April 2,
2007
~~
ANDREW RIFE '
21
22 t-----------
3
23 Document 122 in the court's file is her calendar note for hearing on this
petition. The petition itself is not in the court's file, though it was served on me. I am
24 attaching a copy of that petition. It bears the cause number of a Hauenstein divorce,
OS 3 00314 8. I believe the clerk's office returned it to Ms. Dyer as it had the parties
25 reversed and had a cause number for another divorce on it. Please refer to my lawyer's
letters to Ms. Dyer dated December 5, 2006, January 8, 2007 and January 9, 2007.
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 7 425 259-4147 FAX 259 7081
1
2 Attachment
Response to Jennifer LeSourd's Litigation Complaints
3
4
Location Jennifer's Claim Truth
Page/Lin e
5 6/9 Andy filed a motion for I am the petitioner. At the time of
restraining order against me filing an ordinary ex parte restraining
6 (October 2005) which was order I order to show cause was
denied. entered. Ordinary restraints against
7 foolish personal conduct and economic
conduct were requested and granted
8
6/10 In November he brought a She brought the motion and lost it.
9 motion for bad faith sanctions, Ms. Dyer filed a motion for bad faith
also denied. sanctions, which was denied.
10
6/12 Andy brought a motion to keep Ms. Dyer noted a records deposition
11 us from having access to his for the entirety of Charles DeVore's
file ... file. I thought this exceeded the scope
12 of the release I had signed and made
a mockery of my right to
13 confidentiality. I brought a motion for
a protective order. Commissioner
14 Stewart denied that motion.
15
6/15 Unlawful Harassment orders I sought an order of protection from
Unlawful Harassment by carol Holland
(Jennifer's mother) because she was
16
stalking me. My mother sought an
17
order of protection from Unlawful
Harassment a~er Jennifer. At hearing
18
the cases were dismissed. Jennifer's
claim that the judge concluded the UH
19
cases were brought to gain advantage
in the divorce is a false claim. Judge
20
Steve Thomas made no such
statement•.
21
22
23 4 0 ne of the issues in the grievance with the Bar Association is the falsity of one
24 of Ms. Dye r's previous statements attributing to Judge pro tern Steve Thomas
state men ts he did not make. I believe she has the audio CD of that hearing. She does
25 not provid e a transcript of Judge Thomas' actual statements because he did not say
what Jenni fer is now attesting to.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
REPLY DEC LARATION OF ANDREW RIFE Everett WA 98201
Page 8 425 259-4147 FAX 259 7081
·--
1 Her statement is false. The court did
5/24-25 In the fall of 2005 the court
ordered my time supervised order my time to be supervised. But
2 and that I enter into and no order was entered in the superior
complete DV Treatment court in the fall of 2005 requring me to
3 enter into or complete DV Treatment
or any other treatment.
4
6/20 We entered into a CR 2a On November 7, 2006 Judge
5 agreement in August 2006 Castleberry ruled that there was no CR
2A agreement.
6
6/20 Andy immediately began I have no idea what she is talking
7 backing off his agreements about. She provides no detail.
8 6/21 We were forced back into court This statement is literally true and
to get the final orders entered. contextually false. My attorney tried
9 for two months to get Ms. Dyer to sign
and return the closing documents.
10 Finally in frustration my lawyer filed a
motion to enforce a CR 2A agreement.
11 On November 7, 2006, after Judge
Castleberd ruled, the last details were
12 negotiate and agreed final orders
were entered. She and her attorney
13 were forced back to court, because
they refused to complete an apparent
14 settlement. Jennifer's statement is
contextually false because she makes
15 the statement as a criticism of me,
though the fault was hers.
16
6/23 Motions to Dismiss and to Jennifer LeSourd filed two substantially
Disqualify Attorney identical domestic violence getitions in
17 the divorce cause and a 20 7 DV case.
We filed substantially identical motions
18
to dismiss and to disqualify counsel.
The case was heard in the DV file only.
19
Our motion to dismiss the DV petition
was granted. Commissioner Stewart
20 made no ruling at all on the motion to
disqualify counsel.
21
Ms. Dyer had filed her own declaration
22 on the merits of the case, confusing
her role as advocate with a separate
23
role as a witness. There is nothing
abusive about filing a motion to deal
24
with this unusual situation.
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 9 425 259-4147 FAX 259 7081
1 See my lawyer's letter of January 9,
6/23 Motion to dismiss and
disqualify attorney not 2007, attached. He proposed to Ms.
2 Dyer that duplicate motions in Jennifer
confirmed and not heard
LeSourd's new DV case (07-2-00022-2)
3 and the divorce be heard in the DV
case only. The motion to dismiss was
4 granted. Commissioner Stewart made
no ruling on the motion to disqualify.
5 The motions in the domestic case were
never heard.
6
6/35 WSBA Grievance After the decree was final I did engage
7 an attorney to represent me in filing a
grievance against Ms. Dyer. My
8 attorney in that matter is Leland G.
Ripley, formerly Chief Disciplinary
9 Counsel for the Bar Association. The
grievance is based largely upon Ms.
10 Dyer's own false statements to the
court and knowingly offering false
11 evidence. The Bar screened it in,
assigning disciplinary counsel to
12 investigate. The matter is still open. I
have a complete copy of the
13 grieveance related correspondence
and documents and also the
14 documents relating to Ms. Dyer's own
criminal history. I will gladly provide
15 copies if the court cares to review
these issues.
16
The grievance addresses the conduct
17 of the attorney. It really does not
relate to Jennifer and Andrew, nor
18 does it relate to our daughter.
19 7/4 Daycare Costs I owe a percentage of work related
daycare costs. Ms. LeSourd tried to
20 get me to pay non-work-related
daycare costs. I declined. See my
21 lawyer's letter of March 15, 2007. It is
not abuse to refuse to be taken to the
22 cleaners. If she had wanted
maintenance, she should have
23 negotiated it when the divorce was
being finalized.
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 10 425 259-4147 FAX 259 7081
CAJHOLIC
't~r)MMUNITY
SERVICES
nf S11oho1nish Counry
WV.'-NW
March 7, 2007
To: Mr. Andrew Rife
I have fowid it necessary to Recuse myself from this case. You will receive full credit for
tbe groups attended. You wiU:n~ to find another program to finish your treatment.
Re;-pectively ~....,_
/-····~. > ~o{A_q 6<~
C. '{
Sandra L Poirier LMHC
Program Director
TiesThat Bind
Domestic Violence
Batterers Treatment Program
l<>l f.J~\.lTclt A~·c..'111e • l;.ver~~tt. \'(:~shingi<)n 98201 • (425) 257-~t11•1"'oll·Free Hi~R-2'10-8.572 • J-":.\X (-125) :!57 .212!i
1
03/13/2007 17:13 4252124515 EM CASE MGMT PAGE 01/02
FAX COVER SHEET

EVERGREEN MANOR "THE COTTAGE" OFFICE
To:. CM\.. ~~~\... Date: ~-\~-C)"'.:\-
FACILITY: m~~~ ffi \_,ftQ

FAX No. l~s) ~~-\t)~\
SUBJECT: _?t>....>..:.~""""'-.:..:.ia=~=-~-'--'-'·:\~._,_\::..=-:__---'-----~--
FROM: MARIE CURTIS
PHONE #: (425) 259•5842 . FAX: (425) 212-4515

(425) 258·2407 EXT: 1870
•
•
.i
warning
The informaHon in this fax Is considered confidential. It Is lntend!!d only for !hti individuals named above.
Dissemination, dtstnbution or copying of this lnformatlon Is pmhiblted. Please notify us Immediately If you have
received this transmission in error.
2832 Hoyt - Everett, WA 98201 - Phone: (425) 25~5842 • Fax: (425) 259'()243 • tdd u5er 1-l!00-B33-63BB
1
03/13/2007 17:13 4252124515 EM CASE MGMT PAGE 02/02
Alcohol & Suhmnce /\buse Trtatmnrt

A priv;itc n\\1'1-profit ap;cncy ~ince 191~
March 13th, 2007
Carl Gaul
Attorney at Law
1602 Hewitt Ave
Everett, WA. 98201
Dear Mr. Gaul
Re: Andrew S. Rife

DOB: 03-22-1973
This letter is to verify that the above-named client entered domestic violence
classes at Evergreen Manor on March 12111 , 2007 after completing 25 weekly
classes at Catholic Community Services, documentation verified. Mr. Rife will
then enter monthly monitoring group on March 191h, 2007.
If you have any questions, please feel free to contact me at (425) 258 - 2407.
Sincerely,
Marie Curtis
Case Manager
EVERGREEN MANOR
:ll'iOI SUMMIT AVF,Nl!E • EVERITIT. WA 98201 •BUS. (425) 258-2407 •FAX (425) 3:19-26111
2932 HOIT AVENUE • hV'EREIT. WA 93201 • BUS. (425) 259-5842 • FAX (425) 2.~9-0243
www.evercreenmanor.org
2
···· o3hsi2001·2:i:01· F'Ai 425·252 soi6. BRIDGET LLEWELLYN ............................ .
~OOi
03/24/2007 00:19 4253041333 JENNIFER RIF°E PAGE 01/05
OYER & PR/MONT

· 503TwellthAveriue~
Se;ittle, W'IShlrigtori 98102
J<n Dyer, Afumey Amy Pasco, Pa'<leg•I

Michael Ptirnont Attorney Georgia ll.oss, L<g.:tl Assi:;tint
ClfENTCopy
· February 2, 2007 [;r-,·J~- 'f·his w°'.! uf\,+ f-e-,b vi.

Sandy Poier · /Jt/ &/! et .JvJhn a 'I ith, -t>i ct
Catholic Community Services
1918 Everett Ave. e/ rYlrt~ J'ahtfj Jal~ ~hn.tz/tJvaf?
Everett, :Washington 98201
Re: Andrew Rife

Jci11
/ (I
d)dn+t,av..t...
,J.d /) .I I r ' 1 lN 1
t&~)(Jlvv tt·/t
e_,,f-
I l/J._,
DearMs.Poier: lJ. i,jd,f/.'J Cl'f f+;;,~;·1 .W ~ ·...
It was a pleasure to meet with you on Thl.ll"sday and thank you for taking the fune to talk to
me. I had no idea tha1 Andy would be there when I was there and in fact, specifically came there in
the morning because it has always been my belief that he is there in the afternoons. It makes no
difference to me but apparently it upset Andy so much that be had to run right to his attorney who ;
then had to send another crazy letter to me via fax late last night. I am attaching a copy of that letter I
just so you know what is going on. j
I want to express my concern that Andy seems to know wba:t to say in group but he is talking
out of the other side of his mouth in the court case. In addition to this letter I got yesterday l am also
including Andy's recent declaratiQn to the court in opposition to Jelln's request to for a DV
Protection Order. It is clear from this sworn statement that he continues to blame everything on Jenn
1
or anyone else that he can find
You should also be aware that he has filed a motion in court to have me removed from being
Jenn's attorney and has filed a grievam:e against me with the Washington State Bar ,Association. The
motion to have me removed was not confirmed by his attorney and was never argued, although I was
forced to respond. The grievance is not going anywhere either but that is not Andy's goal. His goal 'I
is to punish me by making me work on things that I can not bill a client for. So please understand his ,
assault on Jennifer and on me has been nonstop since this matter started We have certainly seen no'
1
change since he started treatment with CCS and in fact,, it seems that his attacks have become niore
persanal and devious since starting With your agency. Words mean nothing to me when it comes to
abusers; a change in actions is the benchmark. Andy's actions have remained consistem end abusive
the entire time with zero change.
i would think that Andy would expect that I would be checking up on his treatment and j
wanting to see his file, This should be no smprise to anybody and completely within my duties to r
my client, Instead I get crazy ramblings like this from his attorney who consistently reinforces
Andy's belief that it is all Jenn's fault. You should know that Andy's family, his attorneys and the
case worker all enable Andy and all have other agendas to promote that ha.ve nothing to do with
holding Andy accountable for his abusive actions. ,
www.ctyf:rpt'fmont.COM I
I
1
iiiiiiiciit LLEWELLYN ........................... · · · ~002
,.
Page2
Febr.u~ry 2, 2007
My client is the primary parent of a 2 year old little girl. While Jenn, as an adult, can keep
Andy away and protect hersel.4 Jenn also has a duty to protect Lauren. As her attorney that then
· becomes my duty and I fully int.end to see th~ Lauren remains protected to the fullest extent I can.
So long as I see no. change in Andy's actions and attitude I have to assume he still bas not taken
responsibility for his actions towards Jenn.
Please feel free to contact me at any time if you have any questions or would like any further
infonnation.
Best regards,
JanM. Dyer
cc: Jennifer LeSourd.
-----------------
CARLJ. GAUL Attorney at law 425 259-4147 fax 425 259·7081
1604 Hewitt Avenue
Everett WA 9820 I
December 5, 2006 Fax only to 206 343 7781

503 Twelfth Ave. East RE: Hearing Dates
Seattle WA 98102
Dear Ms. Dyer
Yesterday I received a voice message from your assistant Amy. She informed me that
the motion you scheduled for tomorrow was not properly filed and will not be heard and it
will be rescheduled. She also told me that I could either use the copies your office previously
submitted or she would send new copies.
As to the scheduling, you and I have each submitted notices of unavailability covering
the latter portion of this month. Unless time is shortened, the hearing will need to be in
January. am available on any day you may choose between the 10th and 17th of January,
2007.
As to copies, I believe you have a procedural defect which I decline to waive by
communicating that the copies I have are good enough. They are already not good. When
you send a new calendar note, please also send a complete copy of the moving party's
documents.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
CARLJ.GAUL Attorney at law 425 259-4147 fax 425 259-7081
1604 Hewitt A venue
Everett WA 9820 I

503 Twelfth Ave. East RE: Hearing Dates
Seattle WA 98102
Dear Ms. Dyer
Let's see if I got the time lines and files straight yet:
08/07/06 Rife Dissolution appears to settle, but does not.

08/21/06 Rife Domestic Violence Order expires.
10/10/06 Rife Domestic Violence action dismissed.
11/07/06 Rife Dissolution actually settles.
11/21/06 You file a calendar note in the dissolution action relating to an order
for protection, but do not file any other documents in the divorce file.
11/21/06 You file a petition for an order of protection listing Jennifer Rife
LeSourd as petitioner and Andrew Rife as respondent, but list the file
number of the Hauenstein divorce. The clerk's office returns these
documents to you. At the end of the process, you have no motion
filed in any case relating to a domestic violence action for Ms.
LeSourd or Ms. Hauenstein.
11/27/06 I did not notice the erroneous file number, and I filed responding
motions in the divorce file.
12/06/06 Whatever may have been scheduled in the divorce file is not
confirmed and not heard.
12/06/06 I file a calendar note for my motion to dismiss setting hearing for
January 16, 2007 in the divorce action, still unaware that the file
number on your documents did not reference the Rife dissolution, but
rather the Hauenstein matter.
01/02/06 You file a new petition for an order of protection from domestic
violence with a brand new 2007 DV cause number. Mr. Rife is not
served. It appeared that you or Ms. LeSourd had decided to abandon
the action.
01/08/07 Mr. Rife is served the new 2007 DV petition, only four business days
before the date set for hearing.
01/08/06 Referencing the divorce case number, you have reply documents
served on my office in which you ask for terms for responding to my
motion to dismiss an action that was never filed. Even though the
cause number references the divorce, the parties are again reversed.
Perhaps the clerk will send this back to you also.
Since the court cannot rule on untiled matters, my motion to dismiss appears moot,
as does your reply motion served today. It looks to me like you are deliberately filing
Jan Dyer
January 8, 2007
Page 2
pleadings for no legitimate purpose and only to increase the strife and expense of this
protracted litigation. An alternative explanation would be reassuring. Perhaps you can let
me in on something I have been wondering: If you did not know of the errors in your filing
on November 21, 2006, when you realized that there was an error in your filing, why did
you not simply call / fax /write and tell me about the problem and your intention to refile
correctly?
I will try to send you a new responding declaration and motion to dismiss later
today or tomorrow. Mr. Rife's declaration has been revised and improved: It is not merely
a repetition of the prior declaration. It may be faxed tomorrow, dependin~ on when I get
my editing done. Since the DV action was not timely served, I do not think a timeliness
objection from you is appropriate.
Yours truly
Faxed Without Signarure
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
CARLJ.GAUL Attorney at law 425 259""4147 fax 425 259-7081
1604 Hewitt Avenue
Everett WA 9820 I

503 Twelfth Ave. East RE: Responding Documents
Seattle WA 98102
Dear Ms. Dyer

Faxed with this letter you will find Mr. Rife's Motion to Dismiss and to Disqualify
Counsel along with his Motion to Strike with supporting documents. These documents are
being filed in the domestic violence cause number. The documents I produce have been
improved frm what I sent you before, though the attachments have not. If the fax quality
is poor, please refer to the attachments I sent you previously.
Because the docuemnts you filed in the Hauenstein and Rife dissolutions largely
duplicate the most recent domestic violence case, it makes sense to proceed in the 2007
domestic violence cause number. This is not based on any theoretical correctness, but
rather because the 2007 case probably has a complete set of documents and does not
present the procedural hurdles one would find in proceeding in the Rife dissolution file.
Accordingly, I propose to not confirm the domestic motions, and to appear only once, on
the domestic violence calendar. The likelihood is that we get the same commissioner
either way, but that we will be on the 1:00 p.m. calendar rather than the 9:00 a.m.
calendar.
If you prefer to appear at 9:00 a.m., that is fine with me, we can do it that way
also. Please do communicate if you prefer that time.
Yours truly
To Avoid Delay
CARLJ. GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
CARLJ.GAUL Attorney at Law 425 259-4147 fax 425 259-7081
1604 Hewitt A venue
Everett WA 98201
Jan Dyer MATIER: Rife Dissolution

Seattle WA 98102
Dear Ms. Dyer
I must apologize for my own negligence. You inquired of Mr. Rife's
willingness to pay aay care costs incurrea during Ms. LeSourd's educational
activities. I assumed he has responsibility for that expense and responded before
checking the order of child support to venfy Mr. Rife's liability for the cost incurred.
I shoulcf have checked, for he 1s not liable for the cost asserted.
67°/o of "WOrk related day care." The expense charged by Ms. Holland is not work
support is based on her abilitv to earn $2798.00 per month in the mobile notary
trade, she already has the ability to earn $16.15 per hour ($2798.00 I 4.33 I 40 =
$16.15). There is simply no apparent "work related" nature to the current day care
Mr. Rife will need enouiiJh information to know that amounts claimed are actually
where Ms. LeSourd is working, the hours she works, the day care !Jrovider ancf the
amounts being charged. Mr. Rife will be sure to fulfill the requirements of the
court's orders.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
Car61 Holland
CARLJ.GAUL Attorney at law 425 259-4147 fax 425 259-7081
1604 Hewitt Avenue
Everett WA 9820 I

Seattle WA 98102
Dear Ms. Dyer
I must apologize for my own negligence. You inquired of Mr. Rife's
willingness to pay aay care costs incurrea during Ms. LeSourd's educational
activities. I assumed he has responsibili~ for that expense and responded before
checking the order of child support to verify Mr. Rife's liability for the cost incurred.
I should have checked, for he 1s not liable for the cost asserted.
67°/o of "WOrk related day care." The expense charged by Ms. Holland is not work
support is based on her ability to earn $2798.00 per month in the mobile notary
trade, she already has the ability to earn $16.15 per hour ($2798.00 / 4.33 / 40 =
$16.15). There is simply no apparent "work related" nature to the current day care
Mr. Rife will need enou~h information to know that amounts claimed are actually
where Ms. LeSourd is working, the hours she works, the day care provider and the
amounts being charged. Mr. Rife will be sure to fulfill the requirements of the
court's orders.
Yours truly
To Avoid Delay
CARLJ.GAUL
OG/s
cc: Andrew Rife
Bridget Llewellyn
Carol Holland
•
• .. l
·.-- ~-_.·
.-
·•
-·
l SUPERIOR COURT OF WASHh"'IGTON

FOR SNOB:OMlSll COUNTY No .. 05-3-00314-8
JENNIFER R. Ril'E, 8118174
Petition f or Order for Protection
Petitioner (First, Middle, Last Nrune) DOB
v. (PTORPRT)
ANDREWS. RJFE, 3!22173
Respondent (First, Middle, Last Name) DOB
1. XI am the victim of domestic violence committed by 3. My age is:

the respondent as described in the statement below. D Underl6 0!6orl7 Xl8orover
Re~pondent s
1
2. X J live io this county. age js:
D I left my residence because of abuse and this is the D Under 16D16or17X18 or over
- county of my ne'-'' or fonner residence.
4. My relationship with the respondent is: D current or forme r dating Din-law
X spouse or former spouse relationship 0 parent or child
D parent of a common child 0 stepparent or ste pchild 0 blood relation other
D current or fonner cohabitant as D current or fonne r than parent or child
intimate partner cohabitant as roommate
5. Identification of Minors (if applicable) DNo Minors involved.

Name How Related to R~sides
(First. Middle loitial, Last) Age Race Sex Petitioncr Res ondent with
Lauren Rife 2 Cauc F Dau ghter Daughter IPetitioner
6. Other court cases or other restraining, protection or no-contact orders involving me, the minors and
the respondent:
Case Name City of Everett v. Jennifer Rife v. Andrew
Andrew Rife Rife
Case Number CR67770 05-2-01268-2
I
Court/County Municipal Court Snohomish C ounty
Petition for Order for Protection (PTORPRTj - "a;;e ·1

WPF OV-1.015 (6/2006) - RCW 26.50 030
1
Check the box for each type of relief you are requesting, for each type of order you need.
Temp: l Request a Temporary Order for Protection, effective until the hearing, because an
Emergency Exists as descrlbed in the statement below. A temporary p:rotf:ction order should
be issued immediately without notice to the respondent, to avoid irreparable injury.
Full: I Request a "full" Order for Protection, following a hearina
Temp Full
l j
x x 1
Restrain respondent from causing any physical harm, bodily injury, assault,
including sexual assault~ and from molesting harassing, threatening, or stalking
1
X me X the minors named in paragraph 5 above.
(If the court orders this relief, and the respondent is your spouse or former spouse,
the parent of a co1nmon child, or a current or former cohabitant as intimate partner~
the respondent will be prohibited from possessing a firearm or ammunition under
federal law for the duration of this order. An exception exists for law enforcement
officers and military personnel when carrying department/government-issued
firearms. 18 U.S.C. § 925(al(l 1.)
x x ' Restrain respondent from coming near and from having any contact whatsoever,
in person or through others, by phone, mail, or any n1eans, directly or indirectly 1
except for mailing of court documents, with X me X the minors named in paragraph
5 above, subject to any court·ordered visitation.
x x 3
Exclude resp(lndent from X my residence X my workplace X my school; X tlie
day care or school of X the minors named in paragraph 5 above
You have a right to keep your residential address confidential.
0 0 ' Direct respondent to vacate our shared residence and restore it to me.
x x ' Prohibit respondent from knowingly coming within, or knowingly remaining
witl1i11 500 of: X our shared residence FEET of X my residence X my workplace x
my school; X the day care or school of X the minors named in paragraph 5 above
Temp Full Temporary Order, effective until a hearing. Full Order, effective following a hearing.
! j
6
0 0 Grant me possession of essential personal belongings, including the following:
Petition for Order for Protection (PTORPRT) - Page 2

WPF DV-1.015 (612005) • RCW26.S0.030.
2
I
0 0 ' Grant me use of the following vehicle:
Year, Make & Model License ·r--:o. .
D D 'Other:
NIA O qDirectthe respondent to participate in appropriate treatment or counseling

services.
0
NIA X ' Require the respondent to pay the fees and costs of this action.
NIA X 11
Remain Effective longer than one year because respondent is likely to resume
acts of don1~stic violence ai?ainst me if the order exnires in a vear.
·Check the following only if you are reques'tirig protection involving a minor: .
x x 12
Subject to any court-ordered visitation, Grant me the care custody and control uf
1
X the mlnors named in paragraph 5 above X
x x 13
Restrain respondent from interfering with my physical or legal custody t•f'Xthe
1ninors narned in paragraph 5 above.
x x " Restrain the respondent from removing from the state: X the minors named in
paragraph 5 above.
Request for Special Assistance From Law Enforcement Agencies:

Does not npply.
Domestic violence includes physical han11, bodily injury, assault, stalking, Or inflicting fear of
imminent physical harm, bodily injury or assault between family or household members.
Tilis Petition is based on the declaration attached and exhibits attached.

f)oi.~s the re~pondent ov.n or possess fll'eanns? X Yes DNo
Does the rcspond~nr use firearms, weapons or objects to threaten or hann you? No
Jfyou arc requesting that the protection order lasts longer than one year, describe the reason:; why: Sec. declarations
antl exhibits attac:hcd and incorporated by this reference.
Petition for Order for Protection (PTORPRT) - Page 3

WPF DV-1.015 (612006) • RCW 26.50.030
3
Fil-ED
1 07 MAY - 2 AM II: 51
2 PAM L. DAHIELS
. cou11r" CLE
SNc1101·11s1i co. ~1 SH.
3
4
Illlllll l l l Ill lllll lllll 111111111111111111111111111111111
CL 12203820
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 RESPONDING DECLARATION OF
Jennifer Rae LeSourd, fka Rife ANDREW RIFE
11 Respondent.
12 I, ANDREW RIFE, declare under penalty of perjury of the laws of the State of
I am the petitioner in this matter. I make this declaration to respond to my former

wife's request that I pay for educational child care expenses.
SUMMARY OF RESPONSE
I have declined to pay my former wife's claim for child care expenses. She brings
the present motion falsely alleging that she has incurred child care expenses with
her mother. I am not obligated to pay fictional expenses.
If my former wife did incur an educational daycare expense that expense is not
chargeable to me under the November 7, 2006 order of support. As to the
Montessori daycare expense, that is also an educational expense, not a work related
expense, and 1s not my responsibility. If my former wife wishes to assert that I owe
the expenses she now asserts, she must utilize the arbitration clause of the order
of support.
RED HERRING
Ms. LeSourd attempts to divert attention from the baseless nature of her claim by
asserting that my refusal to pay what I do not owe constitutes some sort of control
CARLl.GAUL
Attorney at Law
(
27
RESPONDING DECLARATION OF ANDREW RIFE

Page 1
oo \G\~ ~\_
~
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081 {~
1 issue impacting domestic violence 1 • Balderdash. She pretends that I should
volunteer to pay money not owed, for a responsibility not mine. If there is a control
2 issue, it is hers, not mine. She settled the divorce without mentioning any need for
retraining, without any discussion of maintenance. Now she is attempts to impose
3 on me the cost of her choice to seek employment guaranteed to reduce her income.
Her choice to become a phlebotomist is simply her personal choice which does not
4 impact any obligation of mine.
5 3. FICTIONAL EXPENSES
6 The Declaration of my former wife never states that she has paid her mother a
dime, nor that she ever will pay her a dime for child care.
7
As this subject of child care costs came up through counsel and gradually additional
8 facts were provided, my attorney asked for documentation that child care costs
were actually being incurred. That documentation was never provided. Instead,
9 Ms. LeSourd files the present motion. In it she acknowledges that she cannot
provide proof of payment and argues that I should pay cash regardless of how she
10 may pay her mother with services or whatever. She never does get around to
saying that payment has been made by any method, nor that she has any intention
11 of ever paying her mother.
12 Even if they had been real, the expense claimed is unreasonable. I would have
cared for Lauren with out charge. My mother would have done so also.
13 Furthermore, the amount charged is unreasonable. Ms. LeSourd provides copies
of internet advertisements from people seeking employment, not those seeking
14 employees. I have found other people were able to obtain child care without the
excessive rates claimed by Ms. Holland. WAC 388-165-320 provides a maximum
15 rate for grandparent care of $2.06 per hour. Even doubling that would be less than
half what Ms. LeSourd pretends to owe.
16
4. NOT WORK RELATED
17
The November 7, 2006 order of support does not obligate me to pay any portion
18 of education related daycare.
19 Prior to our separation my then-wife operated a business known as "Snohomish

County Mobile Notary." She continues to Ms. LeSourd has an income of $2798 per
20 month. This works out to be $16.15 per hour. ($2798 / 4.33 / 40 = $16.15). She
seeks training to earn significantly less.
21
Ms. LeSourd now claims that her income of $2798.00 was "imputed" to her. That
22 statement is false. The income amount is what she claimed. In her DECLARATION
OF JENNIFER RIFE IN RESPONSE TO MOTION FOR TEMPORARY ORDERS AND IN
23 SUPPORT OF HER REQUEST FOR A DOMESTIC VIOLENCE PROTECTION ORDER
24
1
She has previously tried to convince the court that I had refused to pay child support for
25 November 2006, even though I had paid it and had sent copies of my paycheck stubs showing the
payment to her attorney.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
RESPONDING DECLARATION OF ANDREW RIFE Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
1 FILED IN OCTOBER 2005, Ms. LeSourd stated at page 8:
2 I am self-employed. I do not believe I make as much as Andy claims I do

on his proposed support worksheet. The only records I have are my
3 invoices. Looking back over the last year, my average gross monthly income
has been $2798.00 ...
4
Ms. LeSourd's current assertion that $16.15 is the wage she could earn if the Mobile
5 Notary business was working at its fullest potential and if she was never home with
our daughter is a new story. In October 2005 (when our daughter was even
6 younger than she is now) she claimed the income based on her invoices.
7 Ms. LeSourd has told a different new story also. On January 2, 2007 she filed a
petition for an order of protection from domestic violence. Attached to that petition
8 is a declaration from Jennifer LeSourd dated November 21 2006 in which she
claims "I am on public assistance and am going to school2." She has never
9 revealed the school she was attending at the time, and she has not explained how
she handled child care. Indeed, if she was truly receiving public assistance
10 payments 3, it seems she would have been eligible for DSHS Children's
Administration Child Care Subsidy Programs, but she does not discuss it.
11
Once I had received Ms. LeSourd's declaration attesting the $2798.00 income, my
12 attorney and I used her number as the true number for her income. Afer all, she
claimed to have the invoices. At the time of settlement, that same number was
13 used. It is an actual income amount she established. It is the amount she certified
to the court when she signed the settlement documents.
14
Ms. LeSourd maintains the Snohomish County Mobile Notary website. She
15 downplays the significance of her self employment now.use the same income
amount
16
6. MONTESSORI SCHOOL
17
I do not question whether the Montessori School charges $856.00. Again, I am not
18 liable for the cost.
19 The Montessori School is a daycare, and is necessitated only by Ms. LeSourd's

educational pursuit. It is not work related child care cost. The documents provided
20 reveal that it cannot be considered a preschool or otherwise come within the terms
21
2
Ms. LeSourd's declaration of November 21, 2006 does not display page numbers. The quoted
22
material is found on the fifth page, at lines 11-12, about three inches above her signature. Commissioner
Stewart dismissed the petition with prejudice.
23
3
I do not believe she was actually on public assistance. I have paid my child support faithfully
24 every single month. Under the temporary orders it was $540 per month. Since December 1, 2006 it has
been $562.50 per month. I believe that I pay more as child support than she would receive as public
25 assistance and that she is therefore ineligible for public assistance. But the story she chose to put into
her declaration is accurately quoted.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 of the order of support.
2 7. FUTURE CHILD CARE
3 I do not share Ms. LeSourd's trepidation about payment of child care costs or what
job she may get. I anticipate that as a newly licensed phlebotomist, she will work
4 odd hours and some cooperation will be necessary to provide child care during her
work hours. Probably some of the time she is working it will be reasonable for our
5 daughter to be in a child care facility. Probably some of the time she is working will
be during our daughter's residential time with me. I am unable to be sure what will
6 happen in the future. I do expect to pay my fair share of reasonable verifiable work
related child care costs once Ms. LeSourd becomes employed, regardless of her rate
7 of pay.
8 7. ARBITRATION CLAUSE
9 The November 7, 2006 Order of Support requires disputes between my former wife
and myself to be arbitrated. She has not invoked it. The court should deny all her
10 requests for relief and require the issues to be arbitrated as the support order
provides.
11
12 ANDREW Rfr
on May 1, 2007 v
13
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CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
.•
~~~~Er:I
2001 FEB -1 AM \O: 30
1
PAM L. 0}\;l\sLS
COUHTY CLERK
2 SliOHOMISH CO .. WASH.
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll /Il /Ill
3 CL 11639693

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae LeSourd, fka Rife
11 Respondent.
12 I DECLARE:
13 1. 1am over the age of 18 years, and I am not a party to this action.
14 2. I served Jennifer Lesourd with the following documents:

15 an alias order to show cause dated February 6, 2007, an order to show
cause dated January 29, 2007, and motion/declaration for an order to
16 show cause re contempt.
17
3. The date, time and place of service were <if by mail refer to Paragraph 4
18 belowl:
l9 Date:. February 6, 2007 Time: 3:53 p.m.

20 Address: 14200 69th Dr. SE, Unit A-5
Snohomish WA 98296
21
22 4. service was made pursuant to Civil Rule 4!dl:

23 by delivery to the person named in paragraph 2 above
24
25
CARLJ. GAUL
26 Attorney at Law
1604 Hewitt Ave.
27 DECLARATION OF SERVICE Everett WA 98201
Page 1 425 259-4147 FAX 259 7081
I
L __ _
• ••
1 s. Other:
2
4 I declare under penalty of perjury under the laws of the state of Washington that
the foregoing is true and correct. ~ ~- -~~---
5
6 Dated: February 6, 2007 ~
BRIAN MARTIN
7
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CARLJ.GAUL
Attorney at Law
26
1604 Hewitt Ave.
Page 2 425 259-4147 FAA 259 7081
-. """'iR'I
•
:~
......->
r;-o
~:....
--
2007 FEB - 7 AM 10: 30

PAM L. [ie..•:JELS
COUNTY CLERK
1 SNOHOMISH CO .. ','/ASf:
2
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Lesourd, fka Rife
11 Respondent.
12 I DECLARE:
13 1_ I am over the age of 18 years, and 1am not a party to this action.
14 2. r served Jennifer Lesourd with the following documents:
1s an alias order to show cause dated February 6, 2007, an order to show

cause dated January 29, 2007, and motion/declaration for an order to
16 show cause re contempt.
17
3. The date, time and place of service were <If by mail refer to Paragraph 4
1s below>:
19 Date: February 6, 2007 Time: 3:53 p.m.

20 Address: 14200 69th Dr. SE, Unit .A.·5
snohomlsh WA 98296
21
22 service was made pursuant to Civil Rule 4(dl:
23 bv delivery to the person named in paragraph 2 above
24
25
CARLJ,GAUL
26 Attomey at Law
1604 Hewitt Ave.
Everett WA 98201
Page 1 425 259-4147 FfVI. 259 7081
1
I
L_
..
.,
•
1 s. Other:
2
3
4 1 declare under penalty of perjury under the laws of the state of Washington that
the foregoing is true and correct. ~ _ /"ft /....
5
6
Dated: FebruaryG,2007 ~~~·
BRIAN MARTIN
7
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CARLl.GAUL
Attorney at Law
26
1604 Hewitt Ave.
27 DECLARATION OF SERVICE Everett WA 98<01
Page 2 425 259-4147 FAX 259 7081
2
Evergreen Manor - Summit: Outpatient
PO Box 12598
Everett, WA 98206
425-258-2407
425-339-2601
2007 JUi'; 20 Pi! l1: 39
Illlllll llllll Ill lllll lllll l l l lllll lllll lllll lllll llll llll
CL 12345771 Pr\f·I L. O · i:: .
DATE, 2007-06-18
.. , EQUi~ry'cU:R1'~
:Or.0.-kMISJi CO ,.,,.SI·
1..:,.
• 1 '•I
TO: Snohomish Superior Court - Family Division
3000 Rockefeller Ave
Everett, WA 98201
RE' Andrew S. RIFE (2007-03-12)

2416, 5th Street
Everett, WA 98201
Case Number' 05-3-02755-1

Intake Date' 2007-03-12
Program: Anticipated Completion Date: 2007-09-03
Report Period, 2007-05-01 to 2007-06-30
Treatment Activity:
Date Duration Attendance Type

2007-05-02 oo,oo Billable Activity Other Non-Billable Activity
2007-05-07 01,29 Present DV Monthly Monintoring - Present
2007-06-04 01,30 Present DV Monthly Monitoring - Present
Urinalysis Results:
Date Result Drug
None to report
.
~ Support Groups attended:
o Verified
Patient is:
[X] in compliance
[ ] not in compliance
Financial Compliance: [X] Yes No
Compliance Criteria Met: [XJ Yes No
Treatment recommendation:
[X] Continue
[ J Completed
[ ] Discharged
Comment:
THIS IS TO ADVISE THE COURT OF THE CONTINUED PROGRESS OF THIS CLIENT IN MRT-DV TREATMENT AT
EVERGREEN MANOR. HIS ATTITUDE, GROUP ATTENDANCE AND PARTICIPATION REMAIN GOOD. PROGNOSIS
REMAINS POSITIVE THIS DATE. ATTENDING MONTHLY MONITORING GROUPS PER WAC 388-60.
Probation/Court assistance requested: [XJ Yes [ ] No

1
-Tim2;;4%:;/.:..--------
Tackels, CDP
2007-06-18
'r
6~ Evergreen Manor - Summit: Outpatient Confidential.

This information has been disclosed to you from records whose confidentiality is
protected by federal law (42 CFR, Part2 ) . Federal regulation prohibits you
from making any further disclosure of this material without the specific written
consent of the person to whom it pertains, or as otherwise permitted by this
regulation. A general authorization for the release of medical or other
information is not sufficient for this purpose.
FIL_ED
i \11~!,•!t!lll
I
07 APR -5 PH 12: 02
p .t.H L. DANIELS
COUNTY CLERK
SflOHOtilSH CO. W .~SH.

~"' I) ll..h~ (2_ '- f"~ )

)
)
and ) NO. OS - ~ - ('.)L. -:iS) - \
e. -+-<--
..)-c.,..., ..., '~ l:JL
DEFEND A NT/ RESPOND ENT
)
) ORDER
)
)
IT IS HEREBY ORDERED.Q r-c..~ \ ._Q_~...),.'- c_,(

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DO~tE 1~1 OPe~J COLT"R:T tRis date:
e."--<;..~ .._. '(.
\_
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Presented By:
10644
Page# 2 '-'-fl___
Case Name ~Q__._(-~'-~\.r-'(2.~,~~~----- Case No. <h - "3' --0"2-=tS~ - I
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DONE IN OPEN COURT this date: ~ 5, ')-d717

Presented By:
~7~
JYEJGE /COURT COMMISSIONER
1084-4
(t..t,..,£We.{_Lj rJ
C~ M ,q;J-fUi'-'7l
8 In re:
Jennifer R. Rife
and
10 MOTION TO STRIKE
Andrews. Rife
11 Respondent.
12 comes now ANDREW SCOTT RIFE, above named, and moves this court to enter
an Order granting the relief requested in Part I below:
13
1. Relief Requested
14 ANDREW SCOTT RIFE moves this court to enter an order which strikes portions
of the declaration of Jennifer R. Rife dated November 21, 2006.
15
11. statement of crounds
16
17 numerous statements concerning the process of negotiation occurring August 7,
2006 through November 7, 2006.
18
19 numerous statements concerning events predating the decree in this matter, now
merged into that decree.
20
111. statement of issues
21
ARE STATEMENTS MADE DURING SETTLEMENT NEGOTIATIONS ADMISSIBLE IN
22 EVIDENCE?
23 DOES A SETTLEMENT READ INTO THE RECORD AND APPROVED BY THE COURT AND
EMBODIED IN A DECREE OF DISSOLUTION OF MARRIAGE RESOLVE ALL ISSUES
24 BETWEEN THE PARTIES?
25 IV. Evidence Relied upon

26
CARLJ.GAUL ~
27 Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
I
';
425 259-4147 FAX 259 7081

1
DECLARATION OF PETITIONER IN SUPPORT OF PROTECTION ORDER
2 A copy of that declaration showing the portions which should be
stricken is attached hereto.
3
v. Legal Authority
4
CR 2A
5 ER 408
6
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
2
3
4
5
6
7
. . rSUPERIOR COURT OF WASHINGTON
8
9 I FOR SNOHOMISH COUNTY NO: 05-3-00314-8.
10 JENNIFER R. RIFE, 8/18/74

11 Petitioner DOB DECLARATION OF PETITIONER IN
'12 v. SUPPORT OF PROTECTION ORDER

13 ANDREWS, RIFE, 3/22/73
'14 Respondent 006
15
16 My name is Jennifer LeSourd. Prior ta my divorce my name was Jennifer Rife, I am the
17 petitioner named above. I am attaching 18 exhibits to this declaration and ask that they be
18 incorporated by their refarance herein. An index to those pleadings is attached. Andy Rife and
I were married and we have a child in common. The divorce essentially started when Andy was
19
arrested for tha sec~nd time in Jess than six .months on .a domestic violence related char<ge. I
~?O
obtained a temporary protection order at that time and Andy filed for a divorca,
21
For reasons that I have never understood the court reissued my temporary protection
22
order month after month, (exhibit 14). There was never any real quesl!On that I would have a
23 prolection order but the way it started ouUt just kept getting reissued. Finally in April we were in
24 court again on the re-issuance of the protection order in front of Commissioner Stewart Our
25 trial was set for mid August. The court gave us the choice of having it issue a full protection
26 . order at that time or reissue to the trial date.
27 I Since we believed that this case was going to tri21 'wa opted to rsi1;1sue the protection
1 order to the trial date so that we could present the evidence all at once and with live testimony.
29
fo trial I don't mean to sound like I was not
When I say that I believed tha case was going to go
29 1
willing to settle, We believed It was going to trial because, although Andy had been arrestee!
30
twice (exhibit 16), although the court had ordered that his visitation with our daughter be
Over &- Pn-~:nont:
5o;i Tr.1;df01 A~·.:. E.
5cattl£. WA. 9·Sl0Z
<206) 34.5-;/,"l::.'j
1 supervised, although he had been dismissed from one DV treatment program (exhibit 17),
2 chose another that did not comply with state law regarding treatment programs and was forced
3 to go to yet anothar program bur was also dismissed from that program for continuing to attempt
to subvert the law regarding Phase I treatment, (exhibit 6) he continued to be in complete denial
4
about his abuse and continued to blame everything. on me. He continued. right up to two weeks
5
before trial. to assert that he should be the primaiy parent of our daughter. This despite the
6
j GAL's
7
8
I supervised
recommendations that she ·live primarily with me and that Andy have "therapeutic"
visitatio~. complete DV treatment at Catholic Family Services, enroll in and complete
DV Dads and Respectful Parenting at Family Se1viceo, he continued to assert that he should be
_? 9 Ithe primary parent I believed we were going to have no choice but to go to trial. In many ways
10 now t wish I had.
~ 11 - - .. .
..
. ... . .. .
·~ ......
., ···-
1;
~
.,.WFA8)1 QFFi1-IQGI Ql=llil 019 Gei.6 lt'f9B ~AeFe 99 oell. 1 l11ateed ef ii.a,iA~ I!! depo,.itioi 1 i1e et'"IC'f ~i•
~12
~ 13
eHe1=1~a) e~aFl!IB ~a eeHle ~Re eaea. J~'e 1uaioa 11~11ia Gt.IFfilFi;eii ;11:1Q Rei s~~iii11;t,l;1 pi:ii1i-:;ai:19i,I •o &siu ..
!!!U i~st:tes. We eid et feirly ttee6 jeh l!'iief ell settiA§ R=tes~ iea~ee ee 11eP:e8 eAB e~eea ct~ niU
-l 14
1
~ ee~eMI pttg"~ ef l1!u1d11~riHe1, ttg1eeme11~$ e~e~! ettF dim ef'ee, St::lfl f!'e!tFeFltiR~ '3~6R e"o iii~ il=i
~
15
~t:IJ:l~Orl. ~lie 9e1 neeitie ltiiliole11ee Prie~eetieA 81de1 ~1se. t1Afel'tl:JAatel), ""e~ di~e~s$ed. f147i
16 eUeP'ne~ U1et:isAt it 11&9 e si;e!"t ft~ ne heel fie.er ~i 1 1eA el'!) iuefieeHeA tRs:~. 1,ire Biel Ae~ •'llf!Ai a ~~!I
17 f3Fetaetie1~ eFBaF. s~t 'IVReA et:ie B~19i;eeel;:iea' ; t1 •-'>'a attetAeY aBe:1;:1t it Ae Fe#t::teeei te e·1a~ eiiseuae
0
18 it. Tl 1t1! ne~ i11 lete: dal'.

~ 19 Si,.l!li!i •lil11A f I • b1 I I ! ; t 9 II I
I I
5
ii •• , " 5 !!L 1ed pgj!l1 !11g \(\HJjl
' i,} \f\'e ne1 e Aet able te 1eael""' S:fll)
'
a~Feaffl&Rte aitid ulti~ately Andy's attorney noted a motion for
20
-~' 21
presentation of final orders. Judge Castleberry denied his motion and told us to go out in the
hall and come to terms on our disagreements in the documents. Our attorneys and the GAL
i ~
f,\
22
23
24
met and were able to reach agreements regarding our divorce documents and we were able to
go back into court and get our final divorce documents en.tared. U ~!:'el~ 9 l'T'IOl'ltlie oF i 0111d7 81'11!i
l,i~ ette•i:te~ 'e e8eeltttel) t:Jf"lresseAaele Be:1,ei11di3 eJ:ei an t1Af'leeessa1•i tFi~ te ee1::ut ;;here tFIO'.f
25 eo1npletel) aaelt68 eJeofl te t;1et eilvereeS;
26 My parents were with us In court that day. Just after the judge pronounced us divorced
27 my parents stepped out in the hall. Andy and his attorney left the courtroom while my attorney
28 and I stayed and talked with the GAL When Andy passed my parents ·;n the hall he made a
29 smart remark to them, calling my Sister and me cancers. They have had it with Andy and do not
30
Ilike him veiy much and my father responded that Andy should basically bug off. Andy turned
Dy,<:iT' c-· PrfJno1~t

50j TwEljthA.f;c. E
S<!.~t-~l..-, lV,{ 9:!101
(20~9 34J-1.62S
towards my father and took a fighting stance. He gestured for him to "'bring it on' so to speak.
2 My father. realizing what was happening, told Andy that he was not going to fight with him and
3 turned away. Al about that time Andy"s attorney grabbed him and got him out of the area.
4
h' a attached my prior declarations as well as lnformg!fon I provided to my thsrapist that details
5
Andy abu~e during our marriage, (exhibits 1, 2 and 3). Even after I called the police he came
6
right bsc and continued the abuse end always blaming it all on me. He lied to me about .his
7
a·vis and Company and it was not until much later that I learned he had been
s discharged fro heir program, I had a very small baby at the time and was totally dependant
9 II advantage of this and continued his abuse. II all culminated in his being
. 10 Criminal No Contact Order. Our divorce was filed and I sough! and
11 obtained a temporary prot !ion order, (exhibit 13).
12 Andy was under cou rder by the Municipal Court to be in treatment In October of
~ 13
2005 he started treatment with C ck Devore however Mr. Devore's treatment program was 110!
~'0 14
compliant with the WACS governin V treatment programs and Andy was forced to change
treatment programs. He did not like this. He want back to the Municipal Court, without notice to
~ 15
any of us in the dissolution case, and obta ed an order there saying that he should get credit
G) 16 for rhe time he was working at Mr. Davore's pr ram, even though it was not if1 compliance VJith
17 state law. The GAL disagreed and was insisting t Andy be In a compliant program. He did
1"'=
' 18 switch to Phoenix Counseling with Dale Todd but re ed to let the issue of credit for his time
".... 19 with Mr. Devore go. Ultimately Dale Todd refused to g1 him credit and Andy was removed
~20 from his treatment program, (exhibit 6).

Al. that point Andy's behavior was really getting bad. s showing up at our visitation
'\l -?1 exchanges and sitting in his n1om's car. He would make faces or y with the instrun1ents on
~ 22 the car to draw attantlon to himself. It was a violation of the Protection
2.3
to work out a parenting plan and I was trying to be patient. The GAL w
24
Andy trying to get him to change his attitude but with apparently no success.
25 lri July, just a month or so before our trial, Andy and hie mother Wendy nuck over to
26 District Court, knowing we were next door in superior court. and obtained two Anti rassment
27 Orders; Andy against my mother and Wendy Rife against me. I could not believe the Ii
28 put in their petitions, (exhibits 10 and 11). We had our full hearing and the judge said they
29
30
Dy•::r & P1·fn1ont·
503 Tu:c{AAA1Jt. r
Si:attle, H·i'!. ~~1.01
(.?Q(i) ;4J.-15~6
both of th>Eew1"p.~Jar~s~a~nd the temporary orders that went along with them, (exhibit 9).
Shortly after that we ack to court, me asking that his mother Wendy no longer be
able to act as visitation supervisor, in ligh seeking a protection order against rne, and
Andy asking that I be found in Contempt. The i;ourt a prof'5~Siona1ry
supervised visitation. I have attached a t)lped transcript of that hearing atee;i(x'TTit>il-Z....!1

~~fl'ee~!te1"-wh<""'""''"°'-eel~~IO<H'91""e.rt.~!ffe-l'>tl!".......__~~~~~--'=-
7 He star1ed a new DV treatment program at Catholic Community Services in August of
6 2006. He was first ordered into treatment in May of 2005. It is now the end oi Noveml,er ot
9 2006 and Andy has still not completed Phase I of any DV treatment program. As required by
10 Jaw, the treatment program has been in touch with me. They have been quite con0ernad
11 because Andy continues to blame rne and seems unable to shift his focus. He also is
12 apparently continuing to argue that Ile should be given credit for the time he worked with Chuck
Devore. His most recent progress report indicates that they had to have a talk with him about
13
"fighting against doing the program" (exhibit 4). It seems clear that nothing has changed.
14
As I mentioned above, Andy has "therapeutic visitation supervision" with Don Layton.
·15
Don has made it quite clear to me that Andy is fixated on blaming me and clearing his name.
1G Mr. Layton notes that Andy needs, "to be mindful of the submerged mass of toxic: resentment he
17 11arbors towards Jennifer/her mother ... " (Exhibit 5).
18 The reasons for entering a temporary protection order In 2005 and reissuing it until
"19 August of 2005 continue to exist tOday. Andy continues to be a very angry and danoerous
20 person as it relates to me and our daughter. I am fully committed to working with our Case
Manager and through our parenting plan, (exhibit B) but I feel strongly that I need an order of
21
protection for both Lauren and me. From my perspective Andy is more dangerous now than he
22
was a year ago. Ha has never at any time taken any responsibility or been accounexhibitle for
23
24 I
his physical abuse during our marriage. He has spent the last year trying to get back at
is in his fourth treatment program and still has not been able to complete Phasg I,
me. He
25 Andy has refused to pay child support for November. our divorce was granted on
26 November 7. 2006. Our final order of child support states that support, under the final order
27 would begin on October 1. 2006 but that is crossed out and December 1, 2006 is written in. I
28 called the Division of Child Support and was told that the temporary orders ended when the final
29 order was entered so technically Andy does not owe support for November. This typ<> of
30
l/o.JCI" & Prinu;1:t
5oJ rw~{ftf1.1\;·<=· r
$i:n:t!t, H·~\ 'J610:!.
(206) :1-hi~1.:;:,~
.. .
1 economic terrorism is typical of Andy. He Is not worried about Lauren and I having no money
2 he is just thinking about how he can get back at me.
3 I believe we have a very long road ahead of us. Who knows if Andy will ever embrace
his treatment and change his way of thinking. He has had. many opportunities to do so but has
4
not so far. He continues to blame me tor everything and I am very concerned for the safety and
5
wellbeing of our daughter ii he continues to think and act the way he is now.
6
I am asking that this protection order be effective until 2011, five years from now. Our
7 daughter will be seven by then. Maybe there will be a miracle before then; I hope so but frankly
8 at this point I am not holding my breath.
9 I should not have had to come to court to obtain this order. Every professional in tllis
10 case has recommended that there be a protection order. All ot the evidence points to Andy's
11 abuse: to his refusal to change his way of thinking and be accounexhibitle tor his actions. I am
·12 Oil public assistance and am going to school. I have had to borrow all of my attorney fees from
my parents. I did not receive any child support ($562.00) in November from Andy. I am asking
13
the court to order that Andy pay $3,500.00 for my attorney fees and cost in having to bring this
14
petition.
15
I declare under penalty of perjury of the laws Of the state of Washington that the
16 foregoing Is true and correct. Signed thi&.2_1_1bay of November 2006 in Everett, Washington.
17
18
19 ~111.,l'/.·I h&t,,2..f
20 NNIFER LeSOUAD
21
22
Our names are Carol and Steve Holland. We are Jennifer's parents. Portions of t11is
23
declaration pertain to us. We have read the declaration and assert that Information contained in
24
here relative to each of us is based on our own personal knoWledge and is true and correct.
25 This declaration is made.under penalty of perjury of the laws of the State of Washington and is
26 signoa .and dat~~ thl~~ of November 2006 in Everett, Washington.
27 --~ // ,- --l(/
, .J L4o•(<-' · - (
;l . i,:, /Vl.i.J
( '.,fi)JJ./:
-I/ .·
I .v ,(
28
STEVE HOLLAND CAROL HOLLAND
29
:30
Over & l~rinti)nf
511.; Tt1:dftl1Aut?. £
S1!11rtle, \VA 9.'3102
('lQ6) S4J-1~18
F~LED
2001 MAR 22 AH II: 31
1
PAM L. DANIELS
COUNTY CLERK
111~~!1~!1 "
1
SNOHOMISH CO. WASH.
\
\
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 MOTION TO MODIFY PARENTING PLAN
Jennifer Rae Rife
12
Comes now Andrew Rife, Petitioner above named, and moves this Court to enter
13 an Order granting the relief requested in Part I below:
15 Andrew Rife moves this Court to enter an Order which adopts the parenting plan
he proposes, a copy of which is attached hereto.
16
II. Statement of Grounds
17
The prior parenting plan entered on November 7, 2006, contemplated increase in
18 the parenting plan upon Mr. Rife completing Phase I of domestic violence perpetrator's
treatment. Mr. Rife has successfully completed that requirement. The Case Manager has
19 submitted a report recommending a change in the parenting plan, the gravamen of which
is to greatly increase the child's residential time with Mr. Rife.
20
III. Evidence Relied Upon
21
Parenting Plan, November 7, 2006
22 Declaration of Andrew Rife
Case Manager Report Update (Sealed) March 16, 2007
23 Declaration of Candace Krischano
Declaration of Janice Hayhurst
24 Declaration of Evelyn Krischano
Declaration of James Rife
25 Declaration of Stacie Rife
26
27 OR {;/~I if,;~
/
,
I
CARLl.GAUL
Attorney at Law
302 Bank of Americ.a Bldg.
1604 Hewitt Ave.
MOTION TO MODIFY PARENTING PLAN I Everett WA 98201
PAGE 1 ·t.... 425 259-4147 FAX 259 7081
" . '•
1 Declaration of Kate Krischano

Declaration of Wendy Rife
2 Declaration of Lance Uhden
Declaration of Vanessa L. Uhden
3 Declaration of Joan Swendson
6
Dated: ~u[~\ c
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MOTION TD MODIFY PARENTING PLAN Everett WA 98201
PAGE 2 425 259-4147 Ff\'/. 259 7081
•
FILED
, I1\\1\\\\\\\\I \\I\\\\\ 11\11\I\\\11111 \1\1\ \Ill\ 1\11\1\\11\\1 2001 JUL 27 AM II: 04
1 . CL 12434699
PAM L. D~.NIELS
2 COUNTY CLERK
oNOHOMISH CO .. WASH.
3
5
UNSIGNED
6
ORDER
Andrew Scott Rife
9 Petitioner, NO. OS 3 02755 1
and
10 PARENTING PLAN
Jennifer Rae Lesourd, fka Rife [ ] PROPOSED {PPP)
11 Respondent. [ ] TEMPORARY {PPT)
[ ] FINAL ORDER {PP)
12
13 [ ] the final parenting plan signed by the court pursuant to a decree of dissolution entered
on [Date].
14 [ ] the final parenting plan signed by the court pursuant to an order entered on
1 = - = - - - - - [Date] which modifies a previous parenting plan or custody decree.
15 [ ] a temporary parenting plan signed by the court.
[xxx] proposed by Andrew Scott Rife
16
17
18
his parenting plan applies to the following child:
19
Name Age
20
Lauren Emily Rife 2
21
22
II. BASIS FOR RESTRICTIONS
23 Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the right to make decisions for the child.
24
25 2.1 PARENTAL CONDUCT (RCW 26.09.191(1), (2)).
26 CARLJ.GAUL
Attorney at law
. . hi! £..; 1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT. PP)- Page I efJ., (b,( f'-''' Everett WA 9820 I
WPF DR 01.0400 (912001)-RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1 Does not apply.
2 2.2 OTHER FACTORS (RCW 26.09.191(3).
3 Does not apply.

6 occasions, and what contact the child shall have with each parent. Parents are encouraged to
create a residential schedule that meets the developmental needs of the child and individual
7 needs of their family. Paragraphs 3.1through3.9 are one way to write your residential
8
3.1 SCHEDULE FOR CHILD UNDER SCHOOL AGE
9
Prior to enrollment in school, the child shall reside with the mother, except for the
1 o following days and times when the child will reside with or be with the other parent:
11 Every Tuesday from after father's work until 7:30 p.m.

Every Thursday from after father's work until 7:30 p.m.
12 Alternating weekends from Friday after father's work until Monday morning,
commencing on Friday, August 17, 2007.
13
14
15
3.3 SCHEDULE FOR WINTER VACATION.
16
Every year, the child shall spend the five days ending December 24 with her father and
1 7 the five days commencing December 25 with her mother. The exchange time shall be at 9:00
p.m. on December 24 in odd numbered years, and at 9:00 a.m. on December 25 in even
18 numbered years.
19 3.4 SCHEDULE FOR SPRING VACATION.
2o Reserved pending Case Manager Recommendation.
21 3.5 SUMMER SCHEDULE.
24 The child shall have a week of uninterrupted time with each of her parents in August
2007. Father shall inform mother of his chosen time for this vacation by July 31, 2007. Mother
2 5 shall inform father of her chosen time for this vacation by August 7, 2007.
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT, PP) - Page 2 Everett WA 9820 I
WPF DR 01.0400 (912001)- RCW 26.09.181; .187: .194 425 259-4147 FAX 259 7081
1 In subsequent years, each parent shall have the right to three weeks of vacation with
he child, to be taken in one two week block and on one week block separated by at least one
2 week. In even numbered years mother shall have first choice, in odd numbered years the
father shall have first choice. The parent having first choice shall inform the other in writing of
3 the chosen vacation periods by May 1 of each year. If that choice is not communicated as
required, the other parent shall have first choice of vacation periods.
4
3.7 SCHEDULE FOR HOLIDAYS.
5
The residential schedule for the child for the holidays listed below is as follows:
6
7 (Specify Year
(Specify Year
8
New Year's Day Odd Even
9
Memorial Day None Every
10
July 4th Even Odd
11 Every None
Labor Day
12 Veterans Day
13 Thanksgiving Day Even Odd
14 Christmas Eve None Every
Christmas Day Every None

15
16 For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
17
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
18
Other: Many legal holidays are not listed in this paragraph. The child's residence on
19 those days is to be governed by other paragraphs of this parenting plan. If an
unlisted legal holiday falls on a Friday or Monday adjacent to a parent's
20 scheduled time, that holiday will be spent with that parent and the exchange of
the child shall be adjusted by one day to accommodate that holiday time.
21
3.8 SCHEDULE FOR SPECIAL OCCASIONS.
22
he residential schedule for the child for the following special occasions (for example, birthdays)
2 3 is as follows:

(Specify Year (Specify Year
25 Odd/Even/Every) Odd/Even/Every)
26 CARLJ.GAUL
Auorney al Law
1604 Hewitt Ave.
WPF DR Ol.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1 none
Mother's Day every
2 Mother's Birthday every none
3 Father's Day none every
4 Father's Birthday none every
Child's Birthday even odd

5
6
[l Other: Special Occasions shall be from 10:00 a.m. to 7:00 p.m. on the day of the
7 special occasion only. Exchanges for special occasions shall be as
provided in paragraph 3.11.
8
9
Does not apply.
10
3.10 RESTRICTIONS.
11
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
12 Notwithstanding a previous finding that limiting factors are present in this case, there is
no longer a need for restrictions based on the circumstances and conditions existing
13 today.
16 Transportation arrangements for the child, between parents shall be as follows:
17 To the extent practical, the exchanges of the child shall be accomplished through
the child's daycare/preschool. If the daycare/preschool is not available as an
18 exchange place, exchanges shall occur at the Safeway at Silver Lake.
19 Either or both parent(s) may have an immediate family member present at the
exchanges as a moral supporter. The moral supporter shall remain at a distance from
20 the parent(s) and shall refrain from any verbal exchange.
21 Either or both parent(s) may have an immediate family member who is licensed and
insured transport the child to and or from the exchange if the parent(s) are unable to do
22 so themselves. Those persons shall conduct themselves in an appropriate and respectul
manner at all times. They shall limit their communication strictly to information
23 concerning the child and the child's needs.
24 3.12 DESIGNATION OF CUSTODIAN.
25 The child 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 child solely for purposes of all
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1 other state and federal statutes which require a designation or determination of custody. This
2
3.13 OTHER.
3
1. The father shall successfully complete the DV Dads program and the Respectful
4 Parenting programs at Family Services in Seattle. This parenting plan shall be subject to
modification if recommended by the Case Manager or agreed by the parents upon
5 father's completion of those two programs.
2. Bridget Llewellyn remains appointed as Case Manager.
6 3. At such time as the Case Manager determines that the residential schedule should be
changed, she will write a report and make recommendations. The parties may agree to
7 those recommendations or modify those recommendations by their agreement. Absent
written agreement there shall be no change except by court order. The Case Manager
8 shall remain appointed until such time as all requirements under this section are
completed. She may, from time to time, write interim reports and recommendations.
9 She shall write a final report which shall include a statement of any changes to the
parenting plan she may recommend at that time.
10
4. The Case Manager shall have authority as follows:
11 A. The Case Manager shall communicate with all parties and professionals working
with the parents. Each parent shall sign authorizations for release of information
12 to the Case Manager for all information concerning the child from any person
who may possess relevant information concerning the parents and the child.
13 B. The Case Manager is authorized to contact each party directly by telephone, mail
and e-mail. Because there is a need for quick communication and decision
14 making concerning times of exchanges of the child, sickness and emergency or
situational information, the primary method of communication will be by
15 telephone.
C. The Case Manager is authorized to contact the child directly.
16 D. The Case Manager is authorized to visit each parent's home without prior notice.
E. The Case Manager is authorized to change the days and times of the parents'
17 time with the child to accommodate their work schedules and the routine of the
child.
18 F. The Case Manager is authorized to regulate the exchanges of the child, including
the times, places, manners and persons who may be present during those
19 exchanges.
G. The Case Manager is authorized to change the durations of the parents'
20 residential time.
21 3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A CHILD.
23 If the person with whom the child resides a majority of the time plans to move, that
24
25 by personal service or by mail requiring a return receipt. This notice must be at least 60
26
CARLJ.GAUL
27 Attorney at law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181: .187; .194 425 259-4147 FAX 259 7081
1 the move in time to give 60 days' notice, that person must give notice within 5 days
2 26.09.440. See also form DRP5CU 07.0500, (Notice of Intended Relocation of A Child).
3 If the move is within the same school district, the relocating person must provide actual
4 to the move but may ask for modification under RCW 26.09.260.
6 and safety.

8
A relocating person may ask the court to waive any notice requirements that may put
9 the health and safety of a person or a child at risk.
1o Failure to give the required notice may be grounds for sanctions, including contempt.
11 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
12 schedule may be confirmed.
13 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.
14
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
15 (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
16 with the child.
17 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.
18
If the objecting person schedules a hearing for a date within 15 days of timely service of
19 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
20 child.
21 IV. DECISION MAKING
22 4.1 DAY-TO-DAY DECISIONS.
2 3 Each parent shall make decisions regarding the day-to-day care and control of each child while
he child is residing with that parent. Regardless of the allocation of decision making in this
24 parenting plan, either parent may make emergency decisions affecting the health or safety of
the child.
25
4.2 MAJOR DECISIONS.
26
CARLJ.GAUL
27 Attorney at law
1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT. PP) - Page 6 Everett WA 98201
WPF DR 01.0400 (912001)-RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
2 Education decisions joint

Non-emergency health care joint
3 Religious upbringing joint
4 The issue of whether the child will attend public or Catholic schools shall be reviewed by
the parents when the child attains the age of four years. If there is disagreement
5 between the parents, the issue shall be determined as provided in part V of this
parenting plan.
6
4.3 RESTRICTIONS IN DECISION MAKING.
7
8
10 . DISPUTE RESOLUTION
11 The purpose of this dispute resolution process is to resolve disagreements about carrying out
13
Disputes between the parties, other than child support disputes, shall be submitted to
14 (list person or agency):
16 he cost of this process shall be allocated between the parties as follows:
17 based on each party's proportional share of income from line 6 of the child support
orksheets of the most recent order of support.
18
19 he counseling, mediation or arbitration process shall be commenced by notifying the other
party by written request by certified mail.
20
21
resolve disputes relating to implementation of the plan, except those related to financial
23 support.
2 5 process without good reason, the court shall award attorneys' fees and financial sanctions to the
other parent.
26
CARLJ.GAUL
Attorney at Law
27
1604 Hewitt Ave.
PARENTING PLAN (PPP. PPT, PP) - Page 7 Everett WA 9820 I
WPF DR 01.0400 (912001)-RCW 26.09.181; .187; .194 425 259·4147 FAX 259 7081
1 ( e) The parties have the right of review from the dispute resolution process to the
superior court.
2
3
4 I. OTHER PROVISIONS
6 The parents shall each strictly limit their communication to information concerning the
child, whether that communication occurs in person, by telephone, or by any written
7 form of communication. If an emergency exists the parents shall try to contact the Case
Manager and/or her assistant by telephone and one of them shall then attempt to
8 contact the other parent to communicate the information.
9
II. DECLARATION FOR PROPOSED PARENTING PLAN
10
I declare under penalty of perjury under the laws of the state of Washington that this
11 plan has been proposed in good faith and that the statements in Part II of this Plan are true and
1123 00-~ s: 1/2 W,o 2 c..,~ uJ,

Af1dreCOttRife Date/andace of Signature
14
15
III. ORDER BY THE COURT
16
1 7 approved as an order of this court.
is punishable by contempt of court and may be a criminal offense under RCW 9A.040.060(2) or
2 0 When mutual decision making is designated but cannot be achieved, the parties shall make a
21
If a parent fails to comply with a provision of this plan, the ~tpE(C, 1¥?'i11*~ons under the
22 plan are not affected. U1v ;)1 (J lY nu
23 Dated: ORDER
Judge I Commissioner
24
25
26 CARLJ.GAUL
Attorney at La~v
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1 Copy Received:
Presented by:
2
3
CARL J. GAUL WSBA# 8341 JAN DYER WSBA# 20355
4 Attorney for Jennifer Rae LeSourd
Attorney for Andrew Scott Rife
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Allorney at Law
1604 Hewitt Ave.
WPF DR 01.0400 (912001)- RCW 26.09.181; .187; .194 425 259-4147 FAX 259 7081
1
2
3
Illlllll l l l Ill lllll lllll lllll l l l lllll l l l lllll llll llll
4 CL 12120574
5
6
7
8
10
11 ANDREW RIFE,
12 Petitioner,
NO. 05-3-02755- I
13 and
14
JENNIFER RIFE (nka Jennifer LeSourd), NOTICE OF CONTINUED
15 Respondent. REPRESENTATION
16
17
18 TO: THE CLERK OF THE COURT;
19 AND TO: Andrew Rife, Petitioner and to
AND TO: Carl Gaul, his attorney of record.
20 AND TO: Bridget Llewellyn, case manager.
21 You and each of you will hereby take notice that Jan M. Dyer continues to represent the
22 respondent Jennifer LeSourd. This representation shall continue until a notice of withdrawal is
filed with the court
23
Except original process, Jennifer LeSourd requests that all further pleadings , papers and
24
motions be served upon her undersigned attorney at the address below.
25 You are not authorized to serve pleadings or papers by use of facsimile unless specifically
26 negotiated with the undersigned. Where authorized, service by facsimile will only be accepted
27 Monday through Friday, 9:00 a.m. through 4:30 p.m .. Pacific Time.
28
DATED this 2"d day of February, 2007.
29
30
Dyer & Primont
503 Twelfth Ave. E )
Seattle, WA 98102
(206) 343-1528
Ff LED
07 JUL -2 AM 10: 37
P/~M L. DA~.JIELS
COUNTY c1 '"RK
SNOHOHISfl CO.\;,\ SH.

)
)
)
'f~~:!Z L_~~J ~11_

i
)
No. aS- ~ - t>z ::i'Ss - \
DEFENDANT/RESPONDENT{- ) ORDER
)
)
IT IS HEREBY ORDERED: -1.?_-{. . =-_\'- -'-'- -~-'-.::,-"',.,,,=---"ti=-'_..,,~'--'('-'~-"l:-~_,,.,._'--"'0'--+-

_--\'--'-\_v-'-''-----'
1' I\ <=> . \ ' .. ...J Y-"L ~ "' ""' ,.._ <e r-t- ~ '- J4_ ~' J ~ c.\r.- " ,,9.. . \:,
p'
DONE IN OPEN COURT this date: _ _ _ _ __:.,+--1-/-~-1-'o=....J:r~

Presented By:
TJ~Uife_
URT COMMISSIONER
(
1064~
~ ' . ..
'
FILED
07 JUN 29 AM IQ: 35
Illlllll llllllCLIll lllll12274514
lllll lllll lllll lllll lllll lllll llll llll PAM l. OANiELS
COUNTY CLERK
SHOHOHISH CO. 'ii f, SH.

ANDREW RIFE,
Petitioner,
N0.05-3-02755-1
v.
ARBITRATION DECISION OF
JENNIFER LESOURD, HARRY SLUSHER DATED
(fka Jennifer Rife), JUNE 12, 2007
Defendants.
I Declare that the attached 4 page arbitration decision was written by me and is a true and
correct copy.
Signed at __:F_.:v_e.:...Q...-=(_2....--=d~,_W=--=-.:A'---._ _ on June 2.. 'S' , 2007 .

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., FAMILVLAW ~
'. ARBITRATION/MEDIATION SERVICE . '."(2_ ~
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I: FREELAND, WA 98249
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COU:: I Y CLErir\
Si~OHO: '.\SilCO. \'.'t>.SH.
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
12
13
I, ANDREW RIFE, declare under penalty of perjury of the laws of the State of Washington,
14 hat the following is true and correct.
15 1. I am the petitioner in this case. I make this declaration to reply to the declaration of my
former wife, Jennifer LeSourd, dated February 14, 2007.
16
2. WHY WE ARE HERE
17
We are here because Jennifer Rife failed to deliver our daughter to the transfer place, and
18 then refused to respond to a simple request for make up time.
19 Jennifer no-showed for visitation on January 20. She does not take responsibility for her
failure to obtain permission to change our daughter's time with me. She sent one (1) email
20 and did not follow up with either the case manager, the supervisor or Don Layton! Then
she simply did not both erto show up. Her excuse -using our daughter's naptime- is not
21 valid. She states that Lauren's naptime is noon to 2:00 p.m. So why in the world would
she wake our little girl in the middle of her nap to get her to the visitation exchange place
22 by 2:00 p.m. !? She is using our daughter as a weapon and it is wrong, wrong, wrong.
23 This should have been resolved by make up time, but she and her lawyer are embroiled in
a dispute with the case manager over what authority the case manager has, and her
24 attorney refuses to even bother to respond to my attorney's letter requesting makeup time.
We should not be here, but I have no other place to turn. She and her lawyer refuse to
25 honor Bridget Llewellyn's decisions as case manager. Instead, Jan Dyer attempts to dictate
.. :v
26
(~\~~ CARLJ.GAUL
27 \)~\'v Attorney at Law
1604 Hewitt Ave.
Page 1 425 259-4147 FAX 259 7081
•
1 to Bridget Llewellyn what she may and may not do. See attached letter, February 2, 2007,
Jan Dyer to Bridget Llewellyn.
2
3. ISSUES BEFORE THE COURT
3
I want the court to remember that this contempt motion is based upon my former wife
4 denying residential time on Saturday, January 20, 2007.
5 The November 7, 2006 Parenting Plan, paragraph 3.1 is clear enough. Lauren is to be with
me "On Tuesday and Thursdays for three (3) hours and on Saturdays for eight (8) hours
6 each week." My time with Lauren has been supervised. The supervisor, Judy Dyer, was
only available for three hours on Saturdays, so that is the amount of time I was able to
7 exercise. (Recently her availability has increased so that commencing February 3, 2007
Lauren has been spending 8 hours with me on Saturdays.)
8
Jennifer knew the time for the January 20 visit was from 11:00 a.m. to 2:00 p.m. Jennifer
9 acknowledges (page 3, lines 20-21) that she was notified that the January 20, 2006 visit
would be from 11:00 a.m. to 2:00 p.m. She unilaterally chose to change that time, did not
10 verify that it was acceptable to anyone else, nor even that the communication was read by
anyone else.
11
Jennifer attempts to miss the point of her knowledge of the time for the visit. Lauren was
12 with me on Saturday, January 6, 2007, from 11:00 to 2:00. Jennifer refers to a Friday
January 12, 2007 e-mail she sent to Bridget Llewellyn. But that e-mail also acknowledges
13 that Bridget Llewellyn has the authority. Her responding declaration ignores the fact that
the Saturday January 13, 2007 visit was also from 11:00 to 2:00, notwithstanding what she
14 had to say the previous day. And she does not provide any explanation why she waited
until Wednesday January 17 at 6:57 p.m. to announce her change for the following
15 Saturday. Neither does she explain why she arrogates to herself the authority to set the
times for others. She knows that Judy Dyer has limited availability and a schedule to
16 maintain.
17 My own opinion is that Jennifer announced her decision to change the visitation time
without bothering to obtain the agreement of anyone else, particularly the supervisor, is
18 that she was still angry about the dismissal of her petition for an order of protection from
domestic violence the day before. If she had simply been concerned about Lauren's nap
19 time, she would have been communicating on Monday, during the day when supervisor
Judy Dyer is in her office.
20
Jennifer acknowledges (page 3, lines 12-16) that on a prior occasion when she initiated a
21 change, she faxed information to the case manager and also that she followed it up with
a phone call to the supervisor. She does not explain why she did not take as much care to
22 assure that her communication was received for the January 20, 2007 visit.
23 Jennifer does not explain why she did not arrange make up time. She does not even
mention the subject. She knows that denial of residential time will result in a contempt
24 filing. I filed three contempt motions on this basis while the divorce was pending. (One
was denied because Jennifer had been following her attorney's advice to disallow the time.
25 One was not served. And one was abandoned when we had an apparent settlement on
26
CARLJ.GAUL
27
Attomey at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
1 August 7, 2006).
2 RED HERRINGS
3 Jennifer spends the first two pages discussing her view of the history of our divorce. Some
of what she has to say is accurate, most is not. All of it is irrelevant. She denied residential
4 time on January 20, 2007 and she did not respond to an invitation to simply provide
alternate time.
5
Jennifer points out that Bridget Llewellyn is our case manager, which is true. She points
6 out that Bridget Llewellyn can adjust visit times, which is inconsistent with Jennifer being
able to change the times unilaterally. Jennifer claims that Bridget Llewellyn cannot change
7 the days of the visits, ignoring the fact that the parenting plan provides for Saturday visits,
and the visit forming the basis for this contempt motion is a Saturday visit.
8
Jennifer claims that the parenting plan was negotiated in July 2006, which is false. It was
9 initially negotiated on August 7, 2006. She claims that it has been an absolute nightmare,
ignoring that she agreed to it before Judge Castleberry on November 7, 2006, three full
10 months after it was negotiated. Whether she finds it nightmarish or not does not affect her
duty to comply with it. If she finds this plan difficult, she could always propose
11 improvements, but she has not done so.
12 Jennifer claims that I have continued to make this case adversarial. That is a false claim,
but even if it were true, would not justify her choice to disallow residential time on January
13 20, 2007. And it does not explain her choice to not respond to an invitation to simply
arrange compensatory time.
14
Visitation has been at various times and various days in the 16 months since the divorce
15 was filed. So what? Jennifer knew that there was a visit scheduled for Saturday January
20, 2007 at 11:00 a.m. and she prevented it from occurring. I work for the Snohomish
16 County PUD. I had mandatory call out last fall due to service interruptions following record
breaking rain storms. I had mandatory call out in December and January due to service
17 interruptions caused by heavy snow and cold. I had to work as much as 40 consecutive
hours without rest. I have been ill, causing a total of three visits to be missed. I have
18 never simply chosen to miss a visit. My visits have all been supervised. The supervisors
have not always been available, or have been available for less than the full time
19 authorized. While disappointed, I have not attacked their competence, honesty or
credibility. It would simply serve no purpose.
20
Jennifer criticizes the supervisor for making "no attempt to salvage" the afternoon time after
21 Jennifer contacted her at 12:56 p.m. We did not have that time because she did not have
it available, which Jennifer would have known if she had communicated reasonably. I went
22 home after Jennifer no-showed. If I had been contacted at that point, I could have
exercised my time in the afternoon. But I had no reason to expect that the afternoon would
23 be available, but no longer had a supervisor available.
24 Jennifer defends herself by claiming she was trying to stop miscommunications and
constant changes to the visitation schedule. She ignores that she is the source of
25 non-communication and change to the visitation schedule.
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 Jennifer pretends that her home address was a secret of some sort. I am attaching a
portion of her web site where she lists the address. Additionally, she has been served at
2 her home address more than once. Her claim that Bridget Llewellyn divulged private and
personal information is false, but also irrelevant. Whether Bridget Llewellyn did or did not
3 err in allowing my attorney access to information in her files really has nothing to do with
Jennifer's contempt for failure to follow the parenting plan.
4
5. SUGGESTION
5
We need for the case manager's job to be defined. The court should enter an order
6 defining that job so everybody can read it and live with it, whether they are happy with it
or not.
7
8
EXECUTED at f."0e_ce,;rC , Washington on 2-/16 /o7
9 ~
4~
r I
,JZ
10 ANDREW RIFE
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
DYER & PR/MONT
Seattle, Washington 98102
Ja:i f'\«t, Al'\omey Amy Pasco, P::ara~egal

.\1!.:.:h3e! Pl'irno:it, Atto~ney G::ol'gia Ross, L.~5.11 As~(s~a:;t
February 2, 2007
Bridgett Llewellyn
3114 Oakes Ave.
Re: Rife/LeSourd
Dear Ms. Llewellyn:

You seem to be under some mistaken impression that you have some authority in this matter
to determine my client's course of action. Make no mistake, you do not. You have only that
authority conferred to you in the parenting plan and that is quite limited. When you were a GAL you
had GAL authority, as you point out in your letter; authority with some root in the law, A case
manager's duties are not defined any where in the law. Your duties spring from .the contract between
Andy and Jehn'and the court's adoption· of that contract. You ·are bound by the four corners of the
parenting plan. That is the .extent of your authority over either Andy or Jenn.
My authority to act in my client's behalf, in this case Jenn, is not confined to the parenting
plan as y\i>urs is. My aurhority to act in Jenn's beqalfis rooted in the Magna Carta and evety law and
cas.e handed down the·centuries since. I do not represent Jenn only for the purposes of adversarial
procc:;edings in the courts; I represent her in every aspect of the implementation of this parenting
plan.· A plan we fought hard for and won: I stand i.n her shoes in any dealings regarding this
parenting plan and that includes communicati0n with you.
You have made your position as to Jenn abundantly clear and you seem to have the same
opinion of me. You have :weighed in on Andy's behalf on issues that do not pertain to you and over
which you have no authority. You have taken a position adverse to jenn.on·Andy's domestic
violence against her, which is really not your place. You are the parenting plan case manager and
that is all. Your opinion on ·wheth'.er or not Jenn should get a protection order certainly carries no
weight yet you insisted on interjecting yourself. It was none of your· business and if yoli had any
desire to maintain a working relationship with Jenn or any objectivity as ihe case manager, then you
really should have stayed. out of it. By taking a side you made yourself adversarial. You were an
ineffective pro dad GAL that had to be forced at every juncture to do the right thing. Your failure to
act on more than one occasion forced us to have to go to court. .Your inability to follow court orders
in the beginning of the case put the case in a posture that had not ·been contemplated when
Conunissioner Beadle ordered you to conduct an interim report, which you never every bothered to
do. Your bias for fathers seems quite apparent. Whether you.a,dmit that or not, that is what it looks ·
like from here.
2061343-1529 206/043-7791 IX www.ctycrprirnont.com

i':i~.:.:
F~::-•:-i,.:~1y :. 20Ci;:
Because you have chosen to take this tact in this case you have put yourself in an adversarial
position when you ·are supposed to be a neutral. For a victim of DV that is an uncomfortable position
and coHnter to where I want Jenn to be right now. While it is time for her to move on and build her
o"·n 1ife it is time for Andy to do. the same. The difference here is he is the abuser that still has not
even made it through Phase I of any accountability based treatment program. To this day he is still
blaming Jenn, even in his recent swom declarations. He is the one you are supposed to be watching
and evaluating· and giving us recommendations for. Instead he just continues to blame Jenn and me
and· everybody else. He does this because he is emboldened by you, his attorneys and his family.
His attorney and his family I can understand but you have a higher duty and it is clear that you have
no intention of carrying that duty out.
Don identified early on, and so did. you and so did JeJUl, that Andy's family has a very harsh
way of talking that is quite abusive. I am curious what you are doing about.that? ls there a plan? .J
think there. is not. You keep plenty busy talking to ei'eryone on the phone and changing the days and
times whenever you 'feel like it or whenever it's convenient for the supervisor or Andy. Jenn has not
been the one that has asked for changes; in fact she and her family have made sure that 110 matter
how late or against what they think is good for Lauren, they have complied when it was possible for
them to do so. Yet week to week the visit times and days change, mostly at Andy's request. Do you
think this is good for Lauren? Do you understand how difficult .it makes Jenn's life and any attempt
to go to school and work? If you don't, Andy does. From my perspective he is using aJI of you to
continue to abuse )elUl and Lauren. You allow him to keep everything changing at bis whim.
A.busers control and Andy is controlling you. If Andy is not doing this then who is?
The parenting plan we agreed to is clear, at least to me. Let me ·review it with you so that we
are all on the same page as to what we expect: . .
l. It is the father, not the mother's, time that is restricted. Jt is the father that your focus as a
case manager is supposed to be on. ,.
2. The 3.2 schedule is Tuesdays and Thursday for 3 hours and Saturday for 8 hours. I run aware
that the visits have been on almost every .day of the week but rarely on Tuesday and
Thursday. I see no authority in the parenting plan for either you or Don to change the day of
the week. Absent the agreement of the parties, changing the days of the week would be a
modification of the parenting plan. We have not agreed to any modification of the
parenting plan. Visitations are 6n Tuesday, Thursday and Saturday.
3. Andy has to successfully complete treatment, including DV Dads at Family Services.
4. His time is not to be ·expanded until he has successfu!ly completed Phase I of DV Treatment.
5. You are to communicate v,.ith all parties anc) professionals working with the father and
make written recommendations on future expended access for the father.
6. Vv'hen and if you think Andy's visitation should be expanded, you are to "Tile a report and
recommendations.
7. Unless we all agree, there shall be no change except by cou.rt order.
8. Under transportation you have authority to set where the exchanges will be and bow long the
visits will last.
It is only under this last section that you have any reason to communicate with my client.
You do not have the authority to change the days as you have in the past. They are Tuesday,
Thursday and Saturday, period. You and 'or Don can change the times. As to that, we are going to
say again, and again if necessary, that Laure.n's nap time is beiween noon ru1d 2:00 p.m. cvei)· day.
When she has visits during that time without getting her nap it is hard on her a.i1d on everyone else.
So, from our perspective weekday visits need to be after 2:00 p.m. on Tuesdays and Thursdays. As
I
L
Pl9' 3
Fd~~t.i.1iy 2, 1007
we understand it visits are currently (as of last week) Tuesdays and Wednesdays, from 3 :00 p.m. to
6:00 p.m. and Saturday from 11 :00 a.m. to 2:00 p.m. As I understand it you now, this week, decided
to expand Andy_' s. time from three hours on Saturdays to the full 8 hours and have set the time to be
I 0:00 a.m. to 6:00 p.m. on Saturdays thereby almost tripling the time 'Lauren. "'ill be with Andy on
Saturdays. While I understand that you have the authority to do that it does seem a bit abrupt and
possibly a lot of change for a little girl. Wouldn'.t a graduated schedule make more sense? It is clear
··to see where all of this ·is going. You believe Andy is just about finished with Phase I of his
.treatment and we all know that as soon as he has completed Phase 1 of treatment you will be
recommending lifting any requirement for supervision. I am just curious though about what your
basis was for tripling the amount of time he has been· spending for the last six months without a .
phase in.
So, let's be clear: There will be .visits on Tuesday and Thursday from 3:00 p.m. to 6:00 p.m.
and· Saturdays from l 0:00 to 6:00 p.m~ Al¢.ough you have authority to change tlie .times of the day
the visits take place, you do·not have the same authority regarding the days of the week. Those are
set in the parenting plan as Tuesday, Thursday and Saturday. Absent agreement, signed by all
parties, or court order, those days do riot change. We will agree to reasonable and verified work or
treatment related changes but only if those changes are coi:tSistent_over a reasonable period of time.
While you have authority to change the time and location of the exchanges, those changes
must be reasonablY. based and confined so as to limit their impact on the child. Consistency is
always in her best interest. In order for Jenn to go to school and work outside the home successfully,
it is imperative that visit times be consistent. .Her family members will continue to provide bai;k up
for the exchanges but it is her primary responsibility and her schedule has to be considered. Frequent
changes to the times make planning or being a new employee very difficult.
We have been operating under this parenting plan for over six months. In that same period of
time, the days, times and places of exchange have rarely stayed the same from week t'o week. Often
the changes have been sudden and without reasonable cause. · This has caused a great deal of
frustration and concern and is really not good.'for Lauren. She is old enough now to understand that
she is going to see her dad. We owe her consistency if nothing else.
From this time on we need to have the "times and places set and' those need ·to not change
absent a verifiable work or treatment related reason. Lauren comes first and everyone else's
convenience comes last. If there is going.to be a change it needs to be communicated and verified in
a timely fashion with enough notice so that the other party can make alternate arrangements. · We
consider three full days notice sufficient. That means if there is· going to be a change on Tuesday it
needs to be communicated by Friday because the weekends don't count. If it is a change for
Thursday, it needs to be communicated by Monday. A change for Saturday needs to be
communicated by Wednesday. And becaU.Se this is very important, we must insist that changes are
in v.Titing. And because this remains. quite adversarial and fraught with difficulties,. we must' insiSt
that all conununication with our client come through our office. We will see that communications
flow efficiently and promptly. It is not our desire to be a cog iii this wheel but rather to be a grease
can that keeps_ it moving.
The other reason why we are insisting that all communication be in writing and to our office
is that you seen] to be quite erratk•~and undependable about communication. On Thursday of last
week my client's mother )'eceived a letter you wrote to Jennifer. You mailed it to Jennifer's parent's
home not Jenni'fer's.' And you mailed it to Jennifer Rife, which is not her name. Her name is
Jennifer LeSciurd 11nd it is hard to imagine why you would not have adjusted to that name change in
six months. Also; no one in our office or in our side of.this case has ·ever been given any notice that
..
P.Jg~ .i
F~t-i~l:;Hy ~- :2007
you do not do business via email. If that is so, it seems odd that you list your email on your
°letterhead and, business car. You seem to want all communication via telephone but often list an
incorrect telephone nwnber on your letterhead. My office speI)t two weeks leaving your voice mail
messages asking you to call us so that we could set up a meeti.ni. You never once bothered to return
my messages. Then when Jenn tells you that she wants communication to go through me you refuse
and tell her that you are demanding that you deal directly with her. You tell her this in a letter you
send to her parent's home. You are way out of your line ·of authority in this regard and your actions
are causing more confusion, which frankly I believe is your goa.L As.a result and in order to avoid
further confusion, all correspondence must be faxed or mailed to my office with enough notiCe
to gi"e us three days notice o·f any changes, not including weekends.
Unless we hear differently from you, in writing directed. to my office, visits ";ill occur
every Tuesday, Thursday from 3:_00 ·p.m. to 6:00 p.m. and Saturday from 10:00 a.m. to 6:00.
p.m. As I understand it, all of the exchanges occur at a Safeway designated by you. ,Jf the
times or locations ·of any of those visits must change, your· office will contact my office in
writing three days in advance.
\\'hen you are ready to write a report and need to talk to Jenn for her input, please contact my
office so that we can arrange for that to happen. Other than that, I do not believe any communication
betwee1i you and my client is necessary· or warranted. If you feel it is, feel free to contact me and we
can discuss the matter: ·
Best.regards,
nn.LcSourd
Don Lfi)1.on
Opposing cqunsel
.'
From: Marianne 425-259-7081 To: earl Date: 2/812007 Time: 8:11:44 AM Page 1 of 1
• · "Snohomish County Mobile Notary - Contact Us Page I of I
Home Areas We Serve 0

Services We Provld4t:J Who We Are Contact Us
Contact us for your notarization needs using the following:
- E-mail us at: jenn@snocomobilenotary.com

- E-mail us using our E-mail web form
- By telephone at: 425-345-4456
- By fax at: 425-316-3676
- Mail address: Snohomish County Mobile Notary
14200 69th Dr SE #A-5
Snohomish, WA 98296
- Fill out an online notarization appointment request form
here
http://www.snocomobilenotary.com/contact_us.html 217/2007
1
......,.
1
~1 1/l II/IIl//l//f111/f111/fI/IllIll/II/I
IIll/I/III/If
CL 12038244
2001 FEB 21 AM IQ: 38
P/.;i•I L. D.i\MIELS
2 cou;:ry CLER:{
S!i'J:-~o; i!SH CO. \'.'ASH.
3

COUNTY OF SNOHOMISH
7
B Andrew Scott Rife Petitioner, NO. 05 3 02755 1
and
9 Jennifer Rae LeSourd, fka Rife ORDER ON SHOW CAUSE RE
Respondent. CONTEMPT/JUDGMENT
10 (ORCN)
Next Hearing Date:
11 [ ] Clerk's Action Required
12 I. JUDGMENT SUMMARY
13 ~ Does not apply.
[] Judgment summary is as follows:
14
15 B. Judgment debtor
C. Principal judgment amount $
16 D. Interest to date of judgment $
E. Attorney's fees $
17 F. Costs $
G. Other recovery amount $
18 H. Principal judgment shall bear interest at 12 °10 per annum
I. Attorney's fees, costs and other recovery amounts shall bear interest at 12 °/o per
19 annum
20 K. Attorney for judgment debtor
L. Other:
21
22
II. FINDINGS AND CONCLUSIONS
23
HIS COURT FINDS:
24
2.1 COMPLIANCE WITH COURT ORDER.
25
26 CARLJ.GAUL
27 C>;#
I<!) I
Allorney at La\v
1604 Hewitt Ave.
1
ORD ON SHOW CAUSE RE CNTMPTIJDGMNT (ORCN) - Page 1 ~( Everett WA 9820 I
WPF DR 05.0200 (912001) - RCW 26.09.160, 7.21.010 425 259-4147 FAX 259 7081
l</-3
. ,_....
1 Jennifer Rife [.fcfi'~

comply [ ] iAte11ti01 ially failed te cam13ly with a lawful order of the court
dated November 7, 2006.
2
2.2 NATURE OF ORDER.
3
The order is related to parenting plan (custody/visitation).
4
2.3 HOW THE ORDER WAS VIOLATED.
5
[1" The order was not violated.
6 ,[ J This aF9eF was vielate9_ii:i the tollowii:i!J FR~FU'lef j 4---
T...__._ ,_,._....._,-f~~ vf- 1"'-~,e~h -k -+',-,,,_ ,_,,.,,.__~-+
7 a- ,Q , " ' - ) Lt. ""'-";> s~ j v' •'> ,1- c.,,J (,,_,__ .f'a.f'i....,,_,_.. /... ,,._,,, ?<-rt ..a.+,,_,,.- <--r.,_., c (
~. 'h~ lc.-0l<.. ,,.,,.._. ~ n-... ~~-,...,,,.._ l>-· r:-~ ~
<MA/"a<A
8
,,,.,,,,.c,.r;,,.__ ~, e.k i.,.-,-,._) '·~r J ~::--. -{.,....___,_ -
9
2.4 PAST ABILITY TO COMPLY WITH ORDER.
Rife[~· []did not have the ability to comply with the order as follows:
10
Jennifer
11
12
13
2.S PRESENT ABILITY AND WILLINGNESS TO COMPLY WITH ORDER.
14
Jennifer Rife [i.(tias [ ] does not have the present ability to comply with the order as
15 follows:
16
17
Jennifer Rife [ ] has [ ] does not have the present willingness to comply with the order as
18 follows:
19
20
2.6 BACK SUPPORT/MAINTENANCE.
21
Back support/maintenance is not addressed in the contempt motion.
22
23 [] Other:
24
25
26 CARLJ.GAUL
Attorney at lalv
1604 Hewitt Ave.
ORD ON SHOW CAUSE RE CNTMPTIJDGMNT(ORCN)-Page 2 Everett WA 98201
WPF DR 05.0200 (912001)-RCW 26.09.160. 7.21.010 425 259-4147 FAX 259 7081
1 2.7 COMPLIANCE WITH PARENTING PLAN.
the residential (visitation · · s of the parenting plan and had the ability to
4 comply with the parenting pa , · resently unwilling to comply. The
noncompliance with the residential prov1s was [ ] was not in bad
5 faith.
Other:
6
9 2.8 ATTORNEY FEES AND COSTS.
10 W
[ ]
Does not apply.
The attorney fees and costs awarded in paragraph 3.7 below have been incurred
11 and are reasonable.
12 III. ORDER AND JUDGMENT

13 IT IS HEREBY ORDERED:
14 3.1 Jennifer Rife []is ~ot in contempt of court.

15
3.2 IMPRISONMENT.
16
Does not apply.
17
[] Other:
18
19
3.3 ADDmONAL RESIDENTIAL TIME.
20
21 Andrew Rife all have additional residential time as follows:
22
23
24
25
3.4 JUDGMENT FOR PAST CHILD SUPPORT.
26 CARLJ.GAUL
Attorney at Laiv
1604 Hewitt Ave.
ORD ON SHOW CAUSE RE CNTMPTIJDGMNT (ORCN)- Page 3 Everett WA 9820 I
WPF DR 05.0200 (912001)- RCW 26.09.160, 7.21.010 425 259-4147 FAX 259 7081
1 Does not apply.
2 3.5 JUDGMENT FOR PAST SPOUSAL MAINTENANCE.
3 Does not apply.
4 3.6 CONDillONS FOR PURGING THE CONTEMPT.
5 [ / Does not apply.

[ ] The contemnor may purge the contempt as follows:
6
10 3.7 ATTORNEYS FEES/COSTS.
11 ~ Does not apply.

[l -~-------------[Name] shall have judgment against
12 Jennifer Rife in the amount of $ _ _ _ _ _ _ for attorney's fees and
$ for costs.
13
3.8 REVIEW DATE.
14
'·,/Does not apply.
15 H' The court shall review this matter on
[Time].
[Date] at ~
16
3.9
,..._.._ ~..,,...,,,_5 tR--- .:0 e-~----·1F'L} ; T "'--"'
OTHER. s-C..e.12f1-,µ '3:c:>,i f""'- '*-"" '-.66 pvv- .5~d"'I vi),9-1 sL..._ijtl, to.._._
''f'-1 ~ --n..._ ....._,,_,J1"'-i cl~·
17 k (,, P~· j:~f7....-..- ,,,t,.(( <-7('.-~ .,,..-.,-r,.). I· I',"'-.._,[.,,._._"'-"";~~
t-.M '/-.> /I'! ~ L( ~ -.ft-ll.... ~ J\r -n..J i / ;-,,,T ~tv-{(.._~ ,,..,,_ ~....._.,.... '
18 3.10 SUMMARY OF RCW i6.09.430 - .480, REGARDING RELOCATION OF A CHILD.
20
21 If the move is outside the child's school district, the relocating person must give notice
22 days before the intended move. If the relocating person could not have known about
23 after learning of the move. The notice must contain the information required in RCW
24
25 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.
26 CARLJ.GAUL
Attorney at Lalv
1604 Hewitt Ave.
ORD ON SHOW CAUSE RE CNTMPTIJDGMNT (ORCN) ·Page 4 Everett WA 9820 I
WPF DR 05.0200 (912001) - RCW 26.09.160, 7.21.010 425 259-4147 FAX 259 7081
2 and safety.
3
If information is protected under a court order or the address confidentiality program, it
4 A relocating person may ask the court to waive any notice requirements that may put
5
6 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
7
confirmed.
9
10
11
with the child.
13 If the objecting person schedules a hearing for a date within 15 days of timely service of
child.
15
WARNING: Violation of residential provisions of this order with actual knowledge of its terms
16 is punishable by contempt of court and may be a criminal offense under RCW 9A.040.060(2) or
17
18
Dated: f EB 2 1 2007
19 Judge / Commissioner
20
21
22
23
24
25
26 CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
ORD ON SHOW CAUSE RE CNTMPTIJDGMNT (ORCN)- Page 5 Everett WA 9820 I
WPF DR 05.0200 (912001)-RCW 26.09.160. 7.21.010 425 259·4147 FAX 259 7081
F~LED
2001 MAR 22 AH II: 31
PAH L. DAMI ELS
COUNTY CLERtl
SHOMOMISH CO. WASH.
Illlllll l\llll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
CL 12220110

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
9 Petitioner, NO. OS 3 027SS 1
and
Jennifer Rae Rife
that the following is true and correct.
I am the Petitioner in this case. I make this declaration to support my motion to adopt a
new parenting plan pursuant to the recommendation of the case manager dated March 16,
2007.
BRIEF HISTORY
My former wife and I have a child, Lauren, now 21/2. Our divorce was pending for roughly
13 months. The temporary parenting plan was driven by the allegations of domestic
violence from my wife. The parenting plan entered with the decree also was largely
dictated by those issues.
I was enrolled in domestic violence perpetrator's treatment. Through an unfortunate series

of events I ended up spending more than a year in the first portion of the treatment
process. I have now competed Phase I and have commenced Phase II. The November 7,
2006 parenting plan specifies that Lauren's residential time with me should not be expanded
until I have completed Phase I.
For 13 months, while the divorce was pending, Lauren's residential time with me was
supervised, principally by my mother, Wendy Rife. In the last 2·3 months it was supervised
by Don Layton, Bridget Llewellyn and Judy Dyer. Since entry of the parenting plan Lauren's
time with me has continued to be supervised. Again the supervisors have been Don Layton,
MSW, Case Manager Bridget Llewellyn and her assistant, Judy Dyer. These impartial
CARLJ.GAUL
Attorney at Law
0 RIGI 302 Bank of America Bldg.
Page 1
NA L 1604 Hewitt Ave.
Everett WA 98201
425 259·4147 FAX 259 7081
.....
,.
. .
1 observers concur that there is no need for ongoing supervision of Lauren's time with me.
2 The parenting plan specifies that I must complete the DV Dads program with Family
Services in Seattle. I have enrolled in that program, which involves two Tuesday meetings
3 per month for five months, beginning in April. I will be taking that course concurrently with
the remainder of the domestic violence perpetrator's program. The parenting plan also
4 specifies that I must complete the Respectful Parenting program. I expect to enroll in that
program to follow the completion of the DV Dads program.
5
3. PROPOSAL
6
With one exception, I concur with the recommendation of the case Manager. She suggests
7 four weeks of Tuesday-Thursday for 3 hours each and Saturday for 8 hours, transitioning
to a second phase of residential time of Tuesday - Thursday for 3 hours each plus 25 hours
8 on Saturday-Sunday. My proposal omits the first phase because that is simply what is
happening currently and has been happening for some time, with the exceptions of days
9 of illness or weather related complications.
10 Throughout the time the case was pending, the Guardian ad Litem knew that I had a good
relationship with my daughter. I am submitting again copies of declarations submitted at
11 the beginning of the divorce to document the relationship that existed then. Ms. Llewellyn
has submitted a recommendation to transition fairly quickly to an ordinary schedule of
12 contact, with no requirement of supervision of my time. It is about time. I was raised
within the Roman Catholic tradition. I want so much to have my daughter in church on
13 Easter Sunday. Since the separation I have had only slight Sunday time.
14 4. INTRANSIGENCE
15 The Case Manager's recommendation was expected by both sides. I had my lawyer write
to Ms. Dyer on March 1, 2007 with a proposal for the new parenting plan. She has not
16 responded. The failure to participate in good faith has caused me to incur additional
attorney fees which should not have been necessary. I am asking the court to enter an
17 award of attorney fees in my favor as a result of the intransigence of the opposition.
18
19
on ?(ttt(tJ 7.
A~Iff' ) ¥=
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAA 259 7081
·---- - ~ ···-
1
2007 MAR 29 PM 2: 05
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll l l llll PAM L. DANIELS
.. CL12156613 COUNTY CLERK
SNOHOMISH CO. WASH .
5
6

9
10 Petitioner,
and DECLARATION OF JENNIER RIFE
12 Respondent.
13
14 I am the Respondent named above. I make this declaration under penalty of perjury and
15 based on my own personal knowledge. I am over I 8 and otherwise competent to testify.
16 As 1 understand it, Andrew Rife is asking that the court enter a new parenting plan that
17 substantially changes the final parenting plan entered in October of 2006. I do not agree that
18 should be done.
19 Our parenting plan was a plan that was agreed to between all of us. There are restrictions
20 in that parenting plan based on Andy's history of acts of domestic violence. Since the beginning
21 of this case in October of 2005 the court has consistently ruled that Andy should only have
22 supervised visitation with our daughter.
23 Bridgett Llewellyn was the GAL during our divorce and is the case manager under our
24 final parenting plan. In her final report to the court the GAL recommended that Andy's
visitation, "continue as is until he has completed the first phase of his Domestic Violence
25
Treatment successfully and the mother has spoken with Dale Todd and he is satisfied that the
26
father is progressing. If he is, then the visits shall become unsupervised and the hours shall
27
remain the same ... When the father has successfully completed his Domestic Violence
28
Perpetrators Treatment and provided proof of such then he can move to expand his unsupervised
29
30
time either by agreement or by further court order." (Page 12 - 13 of GAL report dated June 6, / /J
2006). y
Dyer & Pnmont
503 Twelfth Ave. £
Seattle, WA 98102
(206) 343-1528
Page I
1 It seems to me that our current parenting plan is clear on what has to happen and it has
2 not happened. On page 3, section 3.10 it states that Andy will enroll and successfully complete a
3 state certified domestic violence perpetrators treatment program. He has not yet done that,
4 despite being first ordered to do that in June of2005. As I understand it he did manage to attend
5 26 weeks at Catholic Community Services but he has yet to "successfully complete" any
6 treatment program. In the nearly 2 years since he was first ordered into treatment he has now
7 only managed to get through the first Phase, which is generally done in six months. He is now
8 allegedly working with Evergreen Treatment Program, his fifth treatment program.
9 As I understood our parenting plan, Don Layton was appointed as a Therapeutic
10 Visitation Supervisor to, "work directly with the father." (Parenting Plan, page 3, line 21). I
11 now see in Ms. Llewellyn's report that she is asserting that I refused to meet with Mr. Layton
12 and that Mr. Layton "soon determined that Mr. Rife did not need help with his parenting skills."
13 I don't believe that is true at all. Mr. Layton did suggest that he meet with Andy and me
14 together. I did not and do not feel comfortable doing that. There is a criminal No Contact Order
15 prohibiting Andy from having any contact with me. My therapist had long advised me against
16 having any 'joint" meetings or sessions of any sort with Andy. Both my attorney and my
17 therapist discussed this issue with both Mr. Layton and Ms. Llewellyn. My therapist made it
18 clear that from my treatment perspective she did not recommend any joint sessions with Andy.
19
Now Ms. Llewellyn is saying that my attorney, my therapist and I were all mistaken. That is
simply not true.
20
I have only received one report from Don Layton and it certainly does not say that Andy
21
does not need help. I notice that no one bothered to attach a copy of that report for this hearing.
22
A copy is attached to this declaration .. It is clear from the first page that Mr. Layton viewed his
23
role as assisting Andy, "with parenting skills" and, "ensuring that his anger issues do not
24
interfere with his parenting tasks." He notes significant anger issues in the ensuing weeks. Mr.
25
Layton noted that, "He [Andy] indeed does have trouble handling his behavior when stressed or
26
upset." In mid October of 2006 Mr. Layton offered an assessment of how things are going,
27
(page 4 midway down the page). He notes that Andy does have good parenting skills but that he
28
also has a, "submerged mass of toxic resentment he harbors towards Jennifer/her mother - he
29
does pretty well with keeping this from Lauren. He is doing well when I [Mr. Layton] am
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 2
1 present; how well is he doing with this when he is around his family? Or when he is not being
2 watched? The work he is doing in the DV program is important."
3 In his conclusion he states, "The most important issue for Andrew to address is his
4 residual anger. Undoubtedly much of this is by virtue of the difficult custody battle that is on the
5 verge of begin resolved; however there is a high likelihood that Andrew harbors a lot of anger
6 from pre Jennifer events in his life also. I am taking opportunities to educate Andrew about
7 anger and what it does to people. I am encouraging him to take full advantage of the DV
8 treatment program that he is in. I also plan to suggest to Bridgett Llewellyn that Andrew would
9 benefit from ongoing individual work aimed at exploring what he may carry from his childhood
1o and family or origin." He goes on to say that he thinks he should shift his focus to relational
11 issues rather than parenting skills.
12 It seems to me that Mr. Layton is not saying that there are no issues or problems of
13 concern regarding Andy's parenting. I am not aware that Andy is doing any individual work in
14 any therapy, as Mr. Layton suggested. I have agreed to work with Mr. Layton in conjunction
15 with the advice of my own therapist; just not in any joint sessions with Andy.
16 I do understand and agree that now that Andy has finally completed the first 26 weeks of
17 his treatment program his visitation time should be unsupervised. I have no problem with that.
18 The part I disagree with is the times and the schedule. I feel that, as recommended by the GAL
19
in her final report to the court, Andy's overall time should not increase until he has completed all
of his DV treatment requirements, not simply Phase I. I do not understand why the Case
20
Manager is now recommending something different than she recommended in her final report as
21
the GAL; it makes no sense to me.
22
We entered into a CR2a agreement last August and at that time started our new parenting
23
arrangement, although the final parenting plan was not signed until later in the fall. Although
24
our parenting plan states visits are to be three hours on Tuesday and Thursday and eight hours on
25
Saturday, it was not until January of this year that Andy even began to exercise all the time
26
allotted in the parenting plan. Until January it was three hours three days a week, with many
27
many cancellations having nothing to do with me or our child. I have put together the following
28
to show how often visits have been cancelled just since November.
29
Nov. 21 Cancelled, not by me. Di;er & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 3
2
3 Dec. 16 Cancelled, not by me.
4
5 Jan. 9 Cancelled, not by me.
Jan 10 Cancelled, not by me.
March 27 Cancelled, not by me.
10
11 My point here is to make it clear that suggesting that it would be in our two year old
12 daughters best interest to suddenly begin to have not only unsupervised time with Andy but to
13 add in extended overnight time simply makes no sense to me. There is no way I believe this
14 would be good for her. At our first hearing in the fall of 2005 we provided the court with a copy
15 of the King County Family Court Services Access Guidelines. Commissioner Beadle approved
16 them and based the initial visitation schedule on them. I believe we have been following them
17 ever since. A copy is attached for the court. For toddlers 18 months to 3 years old it states,
"When the non-residential parent has been a regular and significant caretaker, an overnight per
18
week is possible once the child has become accustomed to the other's parent's surroundings.
19
Weekend long access is still not recommended." In this case, Andy has had supervised
20
visitation for about three hours at a time 2-3 times each week since the fall of 2005. During our
21
marriage she was an infant and was never in his care for extended periods of time.
22
The case manager proposed that we continue for another month with the current
23
schedule, then expand that to include one overnight and follow that for six weeks then expand
24
that to full weekends, Friday through Sunday. Andy believes that the overnight visitation,
25
unsupervised, should start right away.
26
I feel strongly that no overnight should begin until Andy is actually enrolled and
27
participating in the DV Dads program. Six months ago Andy agreed that there was a history of
28
Domestic Violence and he agreed to our final parenting plan with the restrictions and the
29
requirement that he complete a DV treatment program, complete DV Dads and complete
30
Respectful Parenting. He has not completed any treatment program yet. He has barely made it
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 4
1 through Phase I but he certainly has not completed any program and it remains to be seen if he
2 will or can actually openly and accountably complete a full program. The issue here is his ability
3 to parent our child without restrictions. He has agreed to enter and complete a program aimed
4 specifically at father's who have used abuse in their family relationships. It seems to make sense
5 to me that his time should not be expanded until he is actually in that program and making
6 satisfactory progress.
7 Andy intimates to the court that he is actually already enrolled in the DV Dad's program.
8 I have been contacted by the program and they have provided all parties with a Client Progress
9 Report dated March 2007. I am attaching a copy of that report. It is clear that he has gone
1o through the intake process but has not finished it and he definitely is not "in" that program right
11 now. They have asked him to provide them with certain information and documentation. Once
12 they receive the requested information they say they will review his file to determine if he is
13 appropriate for the program.
14 I would love nothing more than for Andy to take his treatment seriously and be
15 accountable for his own actions. Unfortunately it is one thing to talk the talk but it is another to
16 walk the talk. Andy's walk and his talk are not consistent with each other. If he had absorbed
17 the concepts taught in any of his treatment programs he would not still be blaming me for
18 everything and still trying to convince everyone he meets that I am the abuser. In his
19 declarations for this hearing he calls it my, "allegations of abuse." He maintains this position,
still two years later, despite the fact that he was arrested and charged with assaulting me or
20
despite the fact that he was arrested again and charged with violating the Criminal No Contact
21
Order. He does not tell us how he has changed or how he is now accountable or what valuable
22
lessons he has learned in treatment. He simply continues to blame me for everything. He
23
attaches declarations that he provided to the court in the fall of 2005. The court's response then
24
was to order that his time be supervised and that he enter into and complete DV Treatment. He
25
provided all of these same declarations to the GAL and her response was that he was an abuser in
26
need of treatment and that his time should be supervised or daytime only until he successfully
27
completes DV treatment.
28
In October of 2006, just six months ago, Don Layton was noting Andy's "toxic rage"
29
against me and my mother. In November of 2006 his progress report from CCS noted that he
30
was having difficulty committing to the program and they had concerns regarding energy being
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 5
1 spent fighting against doing the program. Then in January they say that he has done his 26
2 sessions but he can no longer be in their treatment program and has to go somewhere else for the
3 second phase. Although the Case Manager is asserting that he is enrolled at Evergreen
4 Treatment Center, they have not made any contact with me and I have no verification of this.
5 Nothing has changed. Andy is still bouncing from program to program and still has not managed
6 in almost two years to successfully complete the first of three programs that he has agreed to
7 participate in, Batterer's treatment, DV Dads and Respectful Parenting.
8 I also believe that further evidence of that fact that Andy has not changed is his continued
9 abuse of me through the courts. During our divorce Andy filed a motion for a restraining order
10 against me (October 2005) which was denied. In November he brought a motion for bad faith
11 sanctions, also denied. In December 2005, when my attorney was trying to find out if Andy was
12 in DV treatment, Andy brought a motion to keep us from having access to his file at the
13 treatment program he was in at that time, despite the fact that he had already signed releases to
14 have the treatment provider provide me with the same information he was objecting to. Then in
15 July of 2006 he and his mother snuck over to District Court and obtained two ex parte
16 protections orders keeping my mother and me away from him and his mother. Those petitions
17
were ultimately dismissed at the hearing. The judge made it clear that they had not met their
18
burden of proof and he believed they had only brought the petitions to attempt to gain some
advantage in the family law case. At that same time he brought a motion to have me found in
19
contempt, also denied. We entered into a CR2a agreement in August 2006 but Andy
20
immediately began backing off on his agreements. We were ultimately forced back into court to
21
get the final orders entered. Since our divorce was finalized in the fall of 2006 Andy has filed a
22
Motion to Disqualify and Dismiss my attorney. This was a completely frivolous motion that his
23
attorney did not confirm and was never heard. Nevertheless I had to incur attorney fees for my
24
attorney to respond to this stupid motion. Then he filed another motion to have me found in
25
contempt. That motion was also denied. At the same time, Andy has hired yet another attorney
26
who has filed a grievance against my attorney with the Washington State Bar Association. He
27
has also filed a grievance against my attorney's law partner because he stood in for my attorney
28
once last summer. I have read the grievance and it is based entirely on their assertion that my
29
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 6
1 attorney never told the truth and Andy and his attorney always told the truth so therefore my
2 attorney was not truthful with the court. We know these grievances will go nowhere and Andy
3 knows that too. It is just another tool to continue to abuse me and anyone that stands by me.
4 Another recent example is his refusal to pay for any daycare for our child while I am in
5 school. He says he does not have to pay for day care unless it is "work" related and since I am
6 going to school so I can work, he says that is not work related. Why would he do this other than
7 to make my life very hard? Why does he still need to beat me up? I will be forced to file a
8 motion on this issue of daycare while I am in school and in an unpaid externship as I believe that
9 is work. If he was a fully supportive father he would want me to get an education and a job and
10 he would be willing to help with daycare. Instead it is all a game. I only mention it here to show
11 how much he continues to be an abusive person and has not changed and understand the issue of
12 is payment for daycare will be decided at another time.
13 Frankly I am very tired of having to tell this court, once again, that Andy continues to be
14 an abusive person. For once I would love to be able to say, "Hey look, Andy is doing what he is
15 supposed to do and he is being decent about it."
16 Andy is not only asking that he get more time with our daughter, he is also requesting
17
that the court do away with the restrictions in our final parenting plan, that the court now say that
18
we have joint decision making and that the case manager's role be substantially expanded to shift
the focus away from him to me. As I understand it from what my attorney has explained to me,
19
there is no such thing as a "Motion to Modify a Parenting Plan." Our final parenting plan
20
anticipates these changes and there is simply no basis for the changes he is requesting. I assume
21
his lawyer can read the law, just like mine can. As I understand it RCW 26.09.260 is the only
22
statute that allows a modification of a parenting plan and that statute requires that the court find
23
that there is adequate cause after a Summons and Petition to Modify has been filed. If the court
24
finds that there is adequate cause to proceed then a trial date is set. Andy and his attorney are
25
apparently asking that the court ignore the law in this regard and modify the parenting plan to
26
take away all of the restrictions that Andy and his attorney agreed to last August.
27
This motion is in bad faith and I would ask that I be awarded $3,500.00 in attorney fees
28
and bad faith sanctions for having to respond to this and for his continuing abusive use of this
29
conflict.
30
Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
Page 7
2 foregoing is true and correct. Signed this 281h day of March 2007 in Seattle, Washington.
3
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~idkJL
NNIFER LeSOURD
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Dyer & Primont

503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
Page 8
l of these parents are anywhere near a point where there can ·or should deal ·with each other one on
one and so .it appears that their families may have to remain supportive for some time as we.
2
move slowly forward.
3
Tnis child is too young to tell me what she knows or what she is feeling and my brief interaction
4
and observation of parent/child veil! also not give me a necessa.-ily accurate read into the true
relationship. Anyone can perform for an hour or two, in fact, Domestic Violence perpetrators ar
5 among the best ti'iere are at presenting themselves in a good light. \Vhether or not an indiV:idual
had no prior arrests for Domestic Violence does not mean that what led to their current situation
6 was simply a combination of their ov..11 and their partners personality. which, of course,
translates into "it was the other persons fault". The fact remains that "'-e not only have one arrest
.... 7"
but w.:·bave two in tliiS case: I am not yet convinced that Andy fully understands the iinpact of
his behaviors on his very young and vulnerable daughter and until he does we must proceed
8 . slowly and carefully to try and protect her from any future hann.
9
Andy needs to fully immerse himselfi..-ito his treatment with Mr. Todd a.."1.d truly learn how
10
domestically violent behavior permeates every aspect of one's life, most especially the life of his
child_
.11
Likewise I am not fully convinced that Jennifer will not return to her use of alcohol. Her history
12. would certainly lend itself in that direction and it is imperative that she remain in her therapy and
follow the recom.-nendations of all of her treatment professionals. No o;;ie wants to see her fail
13 and Lauren needs a clean, sober and healthy mom.
Mv recommendations are:
15
l. The Mother should be 1he residential placement for the child.
16
2. · The father must remain in bis Domestic Violence Treatment v>:ith Dale Todd and follow all
17 recommendations of such.
18 3. When he has finished the first phase of Domestic Violence Treatment be should enroll in
the appropriate parenti_ng class through Fa.-nily Services.
19
4. The mother must remain in her therapy until such time.as the therapist deems it no JOnger
20 .necessa.-y.
21
5. .The mother must follow all recommendations of her Drug and Alcohol Evaluation.
22
6. The father's Visitation should continue as is until he has completed foe first phase of his
23 · Domestic Violence Treatment successfully and the mother has spoken with Dale Todd and
he is satisfied that the father is progressing.. ·
24
7. J.fhe is, then the visits shall become u..-i.superV:ised and the hours shall remain the·sa.-ne.
25
RIFE - GAL Report . Bridget Llewellyn
Page - 12 Guardian ad Litem.
3l14 Oakes Avenue
Everett, WA 98201
'17.:; -:;-:;q ?.'.liO
EXHIBIT A
06/07/:;006 03:14 F.U: 425 252 8016 BRi°DGET LLEWELLYN
'I
I
l 8. The father shall provide proof to the mother's attorney that he is enrolled in the appropriate
parenting class.
2 /. 9. Wben the father has successfully completed his Domestic Violence Perpetrators Treatment
3
a.-id provided proof of such then he can move to expand his unsupervised time either by
4
agreemeDt or by further court order.
JO. Tho mother must enroil in and complete an age-appropriate parenting class arid pro-vide
proof of such to father's attorney.
11. Neither parents shall use alcohol at any time.

7
12. The Domestic Violence Protection Order shall stay in full force and effect.
8
13. The Grandparents/family members shall provide transportation to a.'1d from visitation.
9
10 I .
Conclusion · . · .
1 1
IGiven this child's age and her inab1hty to verbally ex-press her. feelings we must proceed very
J.2
13
Icarefully. I know that this father ~ill not be pleased that I have not recommended immediate
unsupervised visits and/or overnights but he must understand that my job is to protect this ohild,
not to give parents what they want or think that they should have and/or are entitled to.
14 This child is entitled to a life free of Domestic Violence and Alcohol Abuse and it is the job of
both her parents to provide that for her. Until recently that has not been the case and so now both
15
slie and they must suffer the consequences of those choices. Change takes time and tremendous
16
effort, let us hope that both parents can s'.and that test of time and move forward successfully and
17
I
with I
give Lauren a life free of Domestic Violence and Alcohol Abuse and that thev become at peace
themselves. . ·
-
. ·
18 Humbly submitted by Bridget Llewellyn on the 6th day of June, 2006 in Everett, Washington.
19
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3114 Oakes Avenue
Everett, WA 98201
4?<; 1, 1,Q ?1!!?
EXHIBIT />r
--- - ------------
I . .· ,_
Don .,_ayconr
Child Advocacy Services,
3.i 14 Oake:;_~ cve1ett 1 WA 9820 i
(425) Z52 8056
(425) 252 8551 fox
d :in laYcon 1 @v-2.~izo ;;.nel
'
I began Superyi.seci visitafiq.n services ·for fa.r1drS!w ?.!7-e's contact with his daUghter-. Lauren, oil August
S; 2006 .. Ws·tjid three vlsit:s (Bf7, 81?, B/9) on .a 11 basic·su?e;vision"' basis, up to t.'1e time a CP2A
agreeme.it y.,~~ re.ached in 1hls C2S9 t.~t cal:2- for ongc;ng the;ar:iet.riic s.u.be;vision. ?ar the cas-e
· rf:a;-:agef, th':= objectiv~s of therapeutic supervisi6n are to ass!S:t Andrew with p2renil09 skills 3l1d
· snsure :his an$e:- fSsLies do ii Of iirterfere wit1i h!-~ pasenting ."fa~~s vvtth .Lau;e.n. ·
In mid Augl'.st1 as ii1Y fhe;ape:ut!c supervis)_on role comtn_enC.ed1 I reviev,1ed th~ _fo1io. .vlnfj docu;;ie, ,:..:,,:
the aat):e;~r fi'l Custo6Y ahd Visitation· DfsPute::;/1 R Lundy

1
1998 ' UndersfaildL'.!9
Ban.Ci.Jft- ail ai'Jc:e orovided .bv Jennifer ~ffe
· 11101105 .Tem.po;arY O;deifo~ P~o1ectioii~
'.:.:: ..
05121/05 Everett. Police l,~::;ident ."1.eport
05125705 .Dome5l1c V!ole.:ice Assessrne:it, KH: Davi3, Devis & CCi.
10102105 Everet± PoiiC.e Incident Reoart
10(30105 PsychoJOgicaI EvaiLl:atio;i ~· A.ndtevf Rffs; ·steve Clancy, Ph, D, ,-ouiiraii)gare
05/15/0B tette1 J1crn Dais Todd •. PttoerilX Counseling, to the part1esjh this case '
:OS/'i 9/05 Guardian ao Lffeiri ~eport, F:L[biiC; 8Jidge:tf Lleweli.Yn .
· 1 h.:!ve also ie~iv~ci ~~ve.~l e-iilails from J.ennif=r Rif= 2no-r11et to·co:lsu!t v1ith her 0:-: two to three
occasions at h-:!1 r-:..-quest to respond to parenting queStions she h2s had about her own pai"S!.i':ti~g
_sfi/is..
3?Sic sup~rvisi~n s~.sio~s inv~/ved monitoring Andrew Rife with h(::; daUgryte-r three times in cJ.o:se
succession~ .817, 818 and 3/9/0$- ~to 7 pfn. Exchang'e=? <?WtJIT'ed at my office. ·.Louien was
del!ve~d by 9ith-e; he1 rfloil}er.oi her ry-::~;;-,:!f gfe.ndmcihei. Jtie visits \'Vera three hours Jeng and
inVoived diiving to And."":?w's home: th ah rehiming· to.m;- office at t:,e ~.hd of th~ tim: fur Lau1ei1's.
~nsfe;
. . to her.rnother Di c-rai1dffiother.
back ~ .
t:ach
. -
visit incit.:ded
.
a file.al for Lauren.2s
.
well 2s
fT~q!-ient di;?~• ch.a:-1g9c::. ,c:-oJiov~ing ar-e highi~hte- frorn th::::.~ t.=ir-e~ Sup-::1-v;s~d residentraf tiifies - ·
i
Lauten d9IivSi-ed by Carof Hoii2;id. Carol indicates Lauren n~eeS 2 diapei ch2ng6'.
ail:
~no'1ew J:iai'lc:Hes f,~I~ weil. S9Vo?;.al of Aildrew's: ~l;it.:v~s ~fo;:>ped '.:>y duiin::; ~au~n':s tirfie ~t h::r
I
Fa~hez-·s house - ·paternal grandr.iot1'ler! brot'iei, sister in /aw, g~at at1nt. ·Th8y stayed approximately
half an houi.' Lauren knov,1s ana' -20joys hs1 fc:thei and.file ;eJ=itfves. /i..ndi=-w fed !...~urs:n. Geneial
uJ2v. · A diaper chaiiae Defore vve i.:;2v.e for the offic~: la:U.'12'1 i;; r..:p.;gt a.t th.g tiansfe;-frcm. he:r fe:th~•
~~~ - .
··. EXrliBIT _3_,,.__ !.

818: LatJr~n delivered by Jen0ifei, T;ansfe; is smooth; GuJen a iiH.ie sleepy. She as":-\s.foi ·
g1ai1drn2 2s we.arrive at And1ew's house. Outside play. Tf1e ;el5tives stopped by·again.f6r about
half ;;.n hour. Lauren :-i~s dl~rrilea .ne~:::sslt.iting th~e dlaper c!lailgeS dLiiiilg ~J:i!:;: v1s:t. !...au..-en
exhib;is sepaiation an>::lsfy as she !s. fr::r.sfeued back to Jennife1 at the end of this visit.
819: Laur.;i;i delivered bv Jeii.nffer. Lsuren eS!e-=:::; ::sm:::cth l:ran:s!tiDiL laUien iT128iS _1uov ·ove·r. ·
Lau1en does seine spitting.' The rel::iivss agaiil d10P by fo; a b;-iefTliile \vfth Lauren. Laufsn~·en]Oys
. thB' attention. Lauren fa.ik3 biisfiy about "tno;nmy/' and "home." .1alked with P.ndie.'.'! about how
Ldt..:i8;""J C0:-1ti0UO'...!sJV ~o;:i~ks hi3 cit~;ition and th~ need to 'tee.ch h'::!; to be moP- self -=ritei!aihina:
EncoU1a.gec' him to~have h-91 heip him witn' t=Sks .. Oesigil. sho;t tasks whe:-e she is focused o~'1 the
.~sk irt$fs2d of hfm. Hav:: something for.hei to do out of his'pi.:cs3ncs fCr- next time. L2u1en .2gali1.
v;2s ups.at .o;.t t.~ci t:-aru;fei b::.ck f::i Jennif.a;- st ff1e end c~ ~::~ v:sit_
On 8/J.:i _wa began doing two hour vfsit> v1heie my ro/s shifted to 2·the12peutic mie. These visit;·
.occufTed Oi)Ce-? :v.reek whiia L<?!.1;-.;;il .;;p.90: :W~ o'tha;- firneS s week wf~h 0n::frev'' sup~,;i;;;;ed by Judy
Dyar. ~ojlowing aie highlights from the t~e2peutic ti;ne3 f have spent wjth Lauien and Aildrew. We
have done· ien of t1':ese visits to date. Most of t,1el"n have oCCuiieC at Andrev/$ ·home, though we
have int~:-rtionariy moved som~ cf ~=>m to othe:- si1\/iioi"J'i'i!ent;: fc;- a b;oader fie!d of beH~yio;:s to
\t/Dik \i.rith°.
. .
8/14: There v.:as nb visitation sch8duled fo; t~is date. HoW-9'v.;i:-, Arid;-ew ..,.....~ the.r-e tai~i:-ig wi'th
Bridgett !...J.evveifyi1 and :ea:o1.Ho11and afrived \vi~;. laui~'l, ifl!st3k-=:1fY sen~ by Jenn ifes·. After sorne
discussion, W-=. did a. visit anyv.-ay. VVediovs tcrAnd;ew's horn:. We d!:scussed th:= pattern that
'visitation vvaS expeCted to tak~ -·arrive at hoi":"\e, .small srBck: piay tme. Suppei, r-8dding·. ~cm.:ao solo .
t;iile at the eild. ·Lauren asks foi h3i mother a.ccu pie of titn=s. l2u.-ei1 t~;ows her food. We talked
through ho\"J to d~ with unv.ranied b~ha.vior. Lauren v.ras picked up· by hei g;andmother; Lauien
e>~hibited :.;Orne separation .$.nYjefy.
8123: Laure.• deiiva;ed·bv arendrnomer. Lau.en ·uaset st the frarisf=; to A-,diew ~'lls ~me. Laureri
is g;ur.:py. Some food trin?Wing. Andrew exei-cised the tecJ1i1iques we discu:sssd last fime. Lau;e:1 ·
doing more ·ind!3.pehdent p/f?y. Some pou5ng. L2uJen. tebefiiot!S dUiing a dfapei change_. Talked
abot.:t WOikiiig on_ dinnei process end fable rtianners (food throwii1g, spitti;;g out food, cfetnands and
yeiUng).
.
Lau1en .alO w21F at s=Jf play .v1fm hei peiis with Andrew c!e3.iled up the
.
kite.hen after
. dihner.
09/0S: Laur.s:n deiivered by jei1nifei W1lo raiates that Lauren has not bsen fseHn.9 wait 'We drive to
J.oys R Lis. Di..:fti1g t11e drive Aildtew 2sks if he can introduce his ne\.v girffiiend to LaU_;en. I asked
,'1ifi1. to v~-ai'r Oil ltiis_ .AJ;;o duiing the drive; L'auJei1 s· consta;fJy demandiilg· And;evi's aftentio;i .furn .
t~-e back seat We talk about how to ffiinimfze Uiis over time. At the toy sfoie, Ana·revv works v,1iti,
Lauren weil - posnrve, 2liows. h-ei to roa:fn. Intervened whe0 she got toys out and W'2s not wiiiing to
put ~sm bacK.•:...;~ rr-.ade ieason2bis pun::hases fo;- her- Sa:ok bag. Eimo.doli~: Petz d0g" .A.ndrew
·wai abls to wort~ W.frl lauien. in a moie baJ2riced wav ih ths field than hs does at his home. Lauren
b2Caii16 c1fr1gy i:J;id a bit moi"e diflicuft· when Andrew iook. a few miilUtes to visit with a '"fri2;id we ran
S~ross ;;:{ t,:..,e Mc=Doiiaids.. ~Uren L~aii"ul, "hold )'Oil,~ When fl Vv'.:s tii7l9 to retuill to step the visit.
09/i 1: !.:..au1e;; deiive1ed by gtandmOthei. Smooth trat'isition to Andre\.<t. La.uren srnacks And;eW 23
he g::ts hor q~t of ~e true:~ at his hct.:5e. We ai-e trylng to ftgure out v1i";at is behfnd her be}1avior.
Lauiei1 helps AildieW ffiake p;~; book.;ead[ng. Soi"i1e: food t1rcv:ing. Meai fogsiher. A;1drew
• < .
oemons~r-aleS goo
d S:t1e;:1dDi1
~ .... ~tO l."tile oenav1or
• ' • ~ '.,. h • . " . .
~anagemeill SKi 13 \.'.'ve·.,ave oeen 01scuss1ng a;i
d d.d·
: an
gx~lientjob O.f\""o;-king wi':h hi:3 datii;h1er during thls Vi:5it
9120: Leurefi de/fve;ed by Jei:iiifer.. She !s taikative. And1ev1 is.ii1ci.s2sing Lauran's i;idep~ndent
p/'?·Y ~ct;v;ti~; ;;:uo::-::is:;fu!ly. H.:: is co:-:si~7ently e;icou..-e~ing and ::Supportive of Lauren. Lauren
continuously deji';ands Ana';ew's attention. VVe tal.~ 2bout several ways for Andrew to teach he; to
be more independent of hi;-n . Andrev1 ;esponds weli to t'ie couple of chaf!enges Lauren presented - .
EXHIBIT _...;;f,.....,._
Den !...2;·'f:::i;;, /\/;SW 420 252'35Si
a1ound din;ier ilfTle - Pra~e t1i0wii-:g, refusal to ec:t. \/Ve talked =bout parent dir:;-ct9d ~eh~vioi vs
chiid directed behavioi, ilD~iilG that Lallien is into something new .eveiV 30 secouds and how Andrew
should !.;.ave- her o;i her cwn ~ith t,~is whf{? providin; h:vo er t11ree p/a,1ned acr!V/tles to do \Vi~h h~i
Lauren at:S! w=ll. Whei'i Laur-en oicked UD t1e ohane to ~ik to aiandina - .A.ild;ev.· aot.h!s mot19r on
··the phoile to taik to Lauren - L~uie;i deiighted_ Andiew uses ;kills \ve discussed i~ rninin11ze
· L..al.i;er.'s S3?a>af1on a~x:efy et the t1e.1o!i~1, "·L~f~ get ready tw see mom .., Good worK.
9/28: Prior to -this Vlsit, Ji.;dy Dyei had infcr,11ed me of 3iidgett Llewellyn's 2ecfsion to sh_ift the
:~~s.fa; /oc.atiotl i:::J a
:-:iDi-? ~ntie/ 0:1~ .. i :!=gic::-:d i.o :;-es:-; this i;-ifc.-i7i~tioil 017 to Andrew anc' ara so
du,-ii)g the usUai reW_ minu~s i speild wffh AOd1e'N 2s he routin9iy arrives '2:srIY bi h!i visits. Aii.dr?W
..did n9t 12spoild \.Yeil to this :iew.S, HiS co;i;;nents and dSii153i1Df sugge~tsd he ii'1de:ed Oo~s have
t-out;Je :-,arrc!If:"lg ;-,:::; ~:;i,ha,Vio;- \Vh~i"l St;.;;:iss:?d Oi u·;sei. A:idrevi' m~de ~eve;-al.int.:?P' ·... ?riate
comments-
"Ab.so! utely ·r:otr
"'3iid:;ie±:t is n_Dt CO;";"';?:;.~ •• :., :do:;;;;. hi;:;t f-.:icw h~:- \-v,:;:,y aro<...:n-:J 'i}:!s offi:;.e"
"r.iil goi0g to have the c.2se rnana:9e1 rep:aced, n
":::> . ' J.l.· 1-. " . ... ' . "
~;icge.l.~ ....eue.r g5-t a iawyer.. .
"Tilis cha;ige \Viii ea{ iiiS ·~y ti:ne\vit, Lc;:u!-g;i_" ·
Ahdfew v;as upset i:o-the poiilt that he v.·anfed fo :::ancei ills schedu/e·d tiiTle with Lau,~n and
Cor:sidefsa· stop;:il;ig the visif3 a!togeth~i~ i en~ouraged him to cai;-;1 down 8i1d Spend ~'le time With
h:S daughter.. I :>ainted ou't that the" visi"ta.tiotiS we:=- r:;'!:end22 fo:- Lau:-'9':-i';; b;ei0efi~ ~;;d 't}-:cot fie wouid
be "!aking a mista.~e to_ deiJy hei the time She ne~ds \~}-it1 hlrri, Three times i exp:ai;ied to-A:id~Sw
that. ff he has 8i1 issue it needed TD be take1i up wifi1 3ddgett Llewellyn and ·that ·r rieed 1'1iril to cease
th!~ fype o,f d!scuss(Oil \•i1ith iil9: It took Aridrew s~v-eiaf miriui-?s 2;-i.:fs:=v::..;1 ;ei':'l:nders to ;g2ch the
.DOiilt Wh9ie he COUid diOD this cor,V::rrsaf:=>f':. We inOVBd af"isad Y1ith the vfsftatiOi) OiOCE!SS once-he
h2d caliTied dci71. i_ encbuicig~-Ahdr8W to prccass the ~·:ay he b=haveQ wrt:h iile :In his DV g.-oup. ·.
We h3d mad~ a decision c;ior to not have AndiewS ie\afiv9s d;-o·o in fr,3 brief vrsitafJc~ ·tiiiles he· Or;
(
no\v hss vlit1 . L9u;-en. Iii n'au of th!s, i invffud And:-ev:r to encbui"Zig~- h·is relatives to s'2f ~Pa famiiy
evsilt 2hd inv;te ;.:s to ft at their.home as cuests. Such ah eve:-rt w<=:s scheduied for tcd2v.· However.
as we left the offiCe, Ar:d1~\:.Y ex6:ained tO-me t~cl his fami/v had not been· ore.oared to ti:;is at theii d0
oWi'i hotn_e aiid so he. had fnvrted them to ~athei at his hor~e - for a bi_ithd~y Party foi LaU1er1.. I.
explained to Ai1df-ew that this v.i~s cci[ifrary tD what he h8d ag:-eeo' to do - atte_ttd as g'ues:S at One of
&le 1elaCTve's homes. A:1d1ew i1'ldicated, uMv n1istake." .~e iildicsted he h2d iiifsu0derst60d \vh:tJ
v.·anted. B~c::use seVeiaf 'i:Jecoie had mad~ o18ns f0r thiS visit, I a/lowed the exlstlno ..v;an to .D!av' oUt.
. . ~ . . -
Tile usual crbv.,tei of relatives wete fr1srs-: With addrtlo;:j Of ~1"~ a drop in Andre\.v'~ grandmoth~1 a,~d
viSit frori'l A1drevls u::icie. 1 obse;vecft":afiiluch of the ta!K bef\veen tne relatives aid A.i1Ciew was.
Pejoialive.. ff aPvea:1ed io ba good na'hl;ed bUt cieail}' sounded. insurring iD ah oufu\de.-. Andrew a;1d
I dis:;-Jssed mis at a 12:rer v!sil - about' how th ls fype of'fnteractio;; cair affect Lau1en. .=-:_e v.ras
·8ceptive, as he has been to ~ii Of my input.: a:nd outfin~d Specific. p!a~s to min1nifz.s these thinf;:s and
shieid h:s Catighter fiOiil them.. ·
L J..' ' ' ·1.., ' • , I - ~ ........... -, . ' - J.. •' -1- ... . •..:..
A~ ~neorw 1oay pai"I)', _aure0 V·la? corn>::>, ~1e ano inLerac'Bve. .~ 11e:re v..re;e· LOO maily g11 :.S.
suggestion, Aidr.eW.v.rithhera severa1 oft~em ta g~vfa!·to Lauren 5t:ft--tu:-.9 CT;11es ..
The farnffy lavishes a !of of .attention on Lauieti who enf91tained thein ail vvhile frequ~ntry checkfng in
wfth hef futhei.
·LBUieil i-? cVeiiY f~scinat=d wi±h bUQSr· the. fiie:s rn the house.
. . .
A;rdy .;i.:::.;:rica~ed !...au;-.:;in nic.gfy from the gioLJ? wher. it w;:::. ti;;;:: to J::::~ve - thOugh he -:vas n.eiVous
· aboUt iea.vi;ig his 'family a.this home as we !~ft.
Dcn'Lay:::ir:, iv'iSV\/ 425 2.52 356"'r
I g2ve A:-:drBW e list of tilings that Lau.~n e11joys th3t was pro\0ded to i!1e by Jennifer. He accsptsd it
without iilcid=nt.
10104: t1ansfef ii1 the·{obby (th= tJa;TsfuJS are usualiy in my ·office); a fJ);ai deciSion Oil V1he1e to
GtOV:= fu;;;? tG11SfaiS· {O is not yet made ...=i.ndrew apologfzes for his a0ge1 i~ tle C?ffice last \V~ek. Piior
-to L.aLJiBi"J'f:. a11lv;;:/, f offs1ed to de::i;ief Wif.l Andrew hi~ behsvior ir: rny office last week. We
discuss=:d comoulsive b9h2vior" ultii/iatt.:;t:s, blaming behavioi, igDoring boundarla:s., the effecf..s·of
Coiifli~ oil otn.efs (on ~aureii). Ahd:=v1 acknow!edgeo'·to me that his off!o=: beh21ii6: l.'VGS a probleiil.
. .
At1d1sw p1epated a fii1e dii1nSr ai!cf L2ui9n ate weif. The'y opeiied a Couple of the ieft ove1 birthday
P.1Ss:ei1ts. f had Andrew set Lau;sin fo independ-:;;t "fask,s vJfliie he fixed dii1;ier- she (a0d h9). did
w2/i di t'-il.s.. J potn:.ad o:.;t fo A:id1ew t~;;f L~n.1;-:;:n was occupying ;-ie;-seff, thou91-i She continu~d t;:;-
de_;""Gand 1'lis ati:ent!cn often; ~..iis :s geed prog:res3.
-'10/1 B: T~e t-a;;s7~r soof is: now 2t tha o:=c in S!/v&; L.dl.~e. Jannrf-e;- d.aiivered l.8~;-en e:id es.~e::' ff
we cOuid ~eet after th~ visft .-'\t:c'ieV1' desc;ibes. some of the other visits (with Judy Dyei") :..... Ch\1diei1S
tv'itiseurn 1 the Jive1. Lou1en ls very tafkativ~: e:s usu31, during the ca1 lide to And;-ew'S home. A'"ldrev.r
has beaun a potty ti'ainino routi1?e witl L.::a!.li~n - doi:ig wefl. Sh:::i is ;:>Uilii'lg up h:;;i:- ov.rn pu11-up3 af!d ·
pants.atthi.s point. A:irffew b;o11Q1~t up a disCLl.sslon about his frustiaiion with superv:sed visitation
·b6unGa1ies:.- \'Ve taik~i;J 2bout the v•:sdorn ·of accepting t1is on a iemporai}' basfs, 02· ciBattve and
!ook 'fC:v:aid. to n0i7Ti.s:~-ed time dov.'11 t\1~ ;cad. ·
I took soii1e tl;ne to ;efiecf Wili1 Andrew on h:ow things are gc:iing -
He ls riot a p;-obiem with Lau1~i1 in ·me ways init:ally wo;ried about- d.1sr2spectful a •• d
ab£Jsf\/-e behi:vior. :-:;e hzs.go:::id parenting S_kms _alr'3ady. ·
H-e dos:S, hov1evei-, ne9d to be iilindfui of th= sUbmeryed mass .of ic~it resef":tfi?gr.;-t he
.hatbo.s. to\'1.-ardS Jennifer/her ;not"1i=c...,.: he does. ptetfy w-eli wit~ k~eping th!s f'io;n· Lauren.
He is QoJ;ig v1eii Wh9N law preseht; now well is he doir1g wfth _this when he is· around r:::s
.family? or v.rhen he !s ilOt beiilg '!-Vatched? The work he is doing ii1·t:.,e DV oro£irarn is
fiffpoJ'~i1t · -
The fat:'lef/Gaught-3-r ;-eiafio'1shiµ ls too L-ifense; too cCnsumi:1g - Laiuren expects:and

aetiJ3iiCS '100% Of his U~t.divided ati9n~oil. We 21-9 work~flg v.1eii on ~h!s '/Vheil WE! are at his
1'1DJ"7le; wfl/ need. to see how this goes in the fie!d.
The -intei"aGifo0s·oe0-veen hls faiilii)- w2mbers aie rud~; they 11:~y bs do;ie wi~ho!J! ma(ice1
but ;i"eed to-not occur around· Laurai.l. Andrew can control his own ex,::;iess·io;:s, estabiish
fuies for his Tamilv :~his ow;i hon1e. and ~stabirsh ey.vect2tions oft'lein
. .
around his dauohter. - .
16125: . Lau1en deHVe;.9q .by grandmC?t~~~-

je.nn.ife; is HJ.. Lauren ls vsry Aildrew u.ses ~ikatfve.
sev_erai off co!Oi ·te;ms when referring tv 'LaUi.S<'i; diugleberry, ifttfe tuid. She a.p;>ea;s ;..:r;a.Jfecte.d by
thl::.7. f.0d1ew L·s~s the piggy. bank for a ieaiilli19 ectivify wfUl Laur~;i. Po"tty trainfilg.· Lauren still
firaklng s\rong bids for Andrev/s undlviqei:i attention .. We taik~d abowt cl!qwing Laurep to do things
h~ o~·ii way i;;stead of.<;::o2_ohing he.:- to do t1in9s t'1e way you: vJo0fd have hei do t.1em.
. .
smooth tonsfei back to 9:-andmoth.et. ·Sepaiation anxiety h:::s ceased over the pEs~ few· visits.
""..
1, 1/01;
r--- -
~.-C f":'-2ns1s:-,
. :. . . • . ·~ . ' . .. ~. . .·,.
Lsu.-en de1:ve1ec D'f Je.<;n;e.~ \Vile 1;-:-;;1c:;;:2s s1 1~ :s liOl :-eelJng weJ/ and v.:l/J tie
. .
sending sister 01 her hUsb,and tci pick up laui'9il. We Wai.1<.ed the maii and ate theie. Uneventful
Vi3ft. Whl!e vvaitiilg for Jennffe.r1 AndrSv.r and r talked about W:1at he needs to vvc1k 9n. Discussed
the banaflt of worki::g tow:<irti; ~vi;;ntu~ny i";avii>S a fri~;-id/y :~i;;:;tionship with J::n.-:if-e;-To; La~ren's
sake. Talked !n general teJiils about what this would take~. including how io~g it might take.
F
Summa);:
Andiew hes good s~ong parsnflng st~ills. He: is r~spolls/v::= io input as to how to fine tune theill and
s::Jccef:sfuilY tries things out. L;;::uren is overiy f6cu:5~d o;; he; fathe1 but Is irnpi'"ovirig, wli:h Aiid;eWs
help, in fnoie :::·nd m9:-:e indep~r:.de;it 3ct\vity. I have obs=:iVed Lau1en with h9r rnot1e; also and ;1ote
that she does not demand ..Jer;ilifer's attet1iio;i with the s3ifle fervoi she does Andiew's.) Th'e ;nost
impo~...a0t ;~iu·e.for A;idr~w t'o ac::r~s·s is hi:=. i~si:::h.:31 a:ige;~ Uo:ciciubtec:Hy iT!UCh of this is by vli(i..le of
the difficult custody b3ttie that is on tSe_verge Of being resojved; hoVvever,. there is a·_hig.h fikeiihood
th2t And;::aw harbors a ·lof·of an9.~r fiorn ;x~ Jennifer events iii' his fi"fs 2!sc. ·I .aii1 3f-ing cppoitu;;ities
io edwc;;!-2 Ar:dr~w:.;;:Oc":.:t ailg..g.r and whs.t if de-~ to ?=o?1-::. I .si"'ry -:;ncOU1a9i;,g hlii1 to t2Ke IUll
· .advaii"tage .o~ the DV treaf;;ient 0;-ogiarn that he is ·ih: i also .p:a:-i tb st:iggest to· Bridgett L/eweiiyn thfit
A~di~W \·..ou!d 6"ei1sf;t fro'.~ ongol;ig indf\(idual \vo;.i\ aim~d a! =xpio:ing he r;-;ay carry rrOrn his
·chiidhc:>d a;id family 01 o;igii1.
I do not be!i~v9 Aildre:w 1Jeeds o;igo:i1g parei1fiiig waif:.. ~9 doe:s,· 1'1ow:ver, need co2Chitig about
de-afirn::I with Jeiliilfe~ ;;ai1::! ofue;s; l:r t'.'1& v.:;;;;ke of a bftte; ciivc:::-ta. j;n;iffe1, a!sci 1 h::;:i invitee ;';IV. i:i1:n;t
1ega1ding deaili}g \vith the.visttatfoli :Drocess. r w6uld suggest that rrry effo;ts shift from a P1imar}t
efi:.vhasis 6~ ;:ia;-e,otlf)g ~kil[s to a fo:;1.:s on reiafioiial iss:ies ... Jn this 1 would· Work with each parent
a·11d woulC partner (dia/Og wf~h) the profe.s:;ic;-~!s.::i_voived 1,.vft.~ tha~. ·
HLl01bJv, .
·,/7, ~-··
. . !lt'x~
· Do:i Layton //
206 920 2929
EXHIBIT "].,..: ~-
- TlES THAT 3it-~p
r-·A:i
0
.H-or1r
:._.__ ----
State C~rt!fied DolilestiC \ticfence.
3atte1e1s Treat!"iieiit ?rogralil
r~Jic. Ar-. ,ru;.f1'1 :m /
.. \.. t'··!r"''
,,__,,__ - -
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t{ -· . ..IL ... - -. ..._ .
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WW-NW
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D.0.3.: J- ~;i..-13
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Pn~se f requires· a minimum of 6 iGonths of week)y ·g10up ineeffngs.
Phase I ____,,.\_,____ of_·__c)__·_c::,_·_ _ ws.skiy sessions compietea, .
Six . fi:lor;fhs of:Pbase _:LJ _wJf/ f0I!ov; Corhofetion of. Phase L _

f. , PhaS9 It°ieqGireS hlfnihlunl~Of·s_ r11o~t!~s :Or ~n~ group pet m·~~th: ·..
a·
Dates Attendea:._/_d~/s__r0_1_r;:;.__
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-t ••·
Program Director Program Counssfor

•
•
' '-~··. . ~ .
Community Violence Prevention Services !'Family Services

Changing live~. Every Doy.
613 -2nd Avenue_. Seattle, WA 98104 Phone (206) 826-3044 . Fax J-877-903-0553
Client Progress Report CL/ENT copy
Program: 0Men 's Dotnestic Violence Intervention Program: 0Weekly Group

0Lesbian Domestic \liolence intervention Progra1n: 0Monthly Group
)8f>v Dads and Their Kids 7QBJ 0Resp~crful Parenting
· r I r r' .,,_, ~re ''I U- ,.,ro_r r.~ .

Month --"-''.i.:::<a'-"o.,""ICJ.1_ _ _ _ _ _ 20
.-:L
0T
· To Cod '?au[ : jZi.J( I 'f2>J ,<-?:f - l < r7/'r
· :&., ryer- = fur: C2!b) 2'+3 - 17-er s1.rr_""'ruq,..,r/::c;.---~&k'-l=.,.,m""'s,______
. &1dpf L/e«>efyo: 11/lf 0,f:Ps /rve_, EV€reft 18Zo I
Re A-ndrec..1 Ri:fu_ ~Pioneer Square
00!3 3- 'L2- 73 0 Bellevue
CauseNo. QS-3-02'}Sr;-J
__IN COMPLIANCE LREYIEW IN PROGRESS __ OUT OF COMPLIANCE

10'completed Inrake on.~! · /lf-C'"+ _}g[ (Sec ~omments below) 0Did nor complere inrake process
UAttended firs! group on _ _ __ 0Did not attend as required ·
0Anending Weekly groups 0Did not pay fees
0Anending Monthly groups OOther _ _ _ _ _ _ _ __
Oother:_ __
_ Completed Program Satisfactorily __ Dismissed from Program (see below)

__ flle Closed (see below)
Dates ottended: I I I I I
Dates missed: I I I I I
~
-hr
rece 111e>
iJs ee Attachn1ents
CLIENT COPY EXHIBIT j )

Client Progress Repo11 Supplementary Page 2 cf '/
Re:. Andres. Kite ~gv5C tf. o~->- ()J_ ?SS- r) Date: mqr>J1 ice 7
..J
-1
I
KING COUNTY FAMILY COURT SERvJCES

1;CCESS Gl!JDELINES
Family Court Visitation Guidelines were first developed in July 1974 in

response to a request by the Family Law Section of the Seattle/King County Bar
Association. The guidelines subsequently have been revised to reflect current
practice knowledge and research findings about th_e best iriterests of children-after
divorce and/or separation, inpaternity cases. and third-party custody actions.
i' .
The iinplementation of the Washington State Parenting Act in 1988 creates
·new models and terminology for families and family law practitioners. The -
guidelines reflect these new concepts and seek to guide families in the development
of a reasonable and child centered residential schedule. As policy, the law
recognizes the fundamentai importance of the parent-child relationship to the
·.;.,eifare of the child and that the relationship between the child and each parent
should be fostered unless inconsistent v.ith the child's best interests. .
Family Court Services' collective experience tells us that families and their
legal advocates need current information which is focused on the-need,s of children .
. · These guidelines are based on child development theory and on research reg~ding
children .of divorce. This guide is offered to help identify the type of residential·
schedule suited to the needs of each child. The guidelines only provide some of the
information that may be needed, but do present some of the possibilities for a
. schedule. Tbey should not, however, be considered r_ules, laws, or be used rigidly.
The guidelines which follow focus on the.child's needs and abilities as

suggested by stages of child development. However. these suggestions should
not be applied without giving: due consideration to a range of other.
factors. including:
the existence of conditions V.'hich may require restriction of access

pursuant to RC\V 26.09.191 ·
the quality of the relationship between the child(ren) a"nd each parent
as well as th·e history of parenting . · ·
the ability of the parents.to cooperate with each other

. !'
the unique cultural and circumstantial needs offa.-nilies
EXHIBIT
·c:..
B-1
·\·
THE CHILD'S NEEDS
Some parents are able to flexibly chailge residential schedules as children

grow and their needs change. These families do not need intervention by the legal
system or other helping professionals. For other farriilies there w-i.11 be conflict and
these guid.elines may be helpful in identifying residential schedules which best suit
the. needs of each child.
It must be recognized that a child is often influenced by the primary

residential parent and!or step parent. It is essential that thes'e' persons support an
ongoing relationship V..ith the other parent. Both parents should help the child
know that it is normal and healthy to feel positively about both parents and to
·enjoy time with each.
In understanding the needs of children at different ages it is useful to

organize the relevant information into age related stages. Howevei: it should be
emphasized th.at stage related plans do not take into account the sometimes
significant individual differences between children of the same age. Specific
problems and exceptions .may require professional consultation. The six .
developmental· stages .used here are: INFANT. TODDLER PRESCHOOLER. .
· · EARLY ELEMENTARY. LATE ELEMENTARY A.ND ADOLESCENT.
DEVELOPMENTAL ASPECTS
INFANTS (Q.- IS.MONTHS)
CBirth to 6 months) For the baby it is essential to have consistency of physical care
and sensitive, cooperative interaction between the infant and caregiver.· The II
I I
pattern of access should not interrupt the ability of the parents to provide smcioth •' II
·! !
child care routines. Access periods should occur frequently enough to facilitate good
bonding between the infant and parents. Daily contact of a few h6U:rs in the ·
• • 1 • •
. primary residence of the infant would be the optimal plan -with b()th p'arents
sharing in feeding, bathing, changing, and otherwise caring for the infa."1.t as well as
playing with the child.
Ideally, both parents are committ~d to the i ..."1.fant developing a good

relationship -with both parents. \Vbi.le parental cooperation is important at any age,
parental cooperation is the crucial fact affecting what plan canbe used during
i."1.fancy. \Vben parents are unable to restrain themselves from engaging in open
conflict, access periods should 'occur somewhere other than in the home of the '" l
residential parent. Special family circumstan·ces may require that access periods
occur in a protected setting or in the office of a mental health professional.
EXHlBJTJ:::--
B-2
During early infancy frequent and predictable contact with the child
is best. Unless Circui:nstances allow several contacts a week, time with the
child away from the residential parent should be limited to one or two
hours.
CE to 18 months) The fanning of secure attachment relationships is the major issue

at this age. The most i.c-nportant features of caregiving are stability and
responsiveness. Young children can quickly lose feelings of attachment to people
they do not frequ·ently see ..
As for younger infants, the more frequent and stable the pattern of access,
the longer it can be. If frequency is less than once or twice a week, access ·
shouid not be more than one to three hours. Children this age need
routine contact with familiar people. Overnights away from the primary
caregiver should be discouraged unless the instability for the child is
outweighed by other factors'.
TODDLERS C18 MONTHS TO 3 YEARSl
The tasks of children durjng this period are developing a sense of

separateness from the parents and learning to master limits. The child should be
given adequate freedom to e"'-plore and permission to resist the parent on
uniniportant issues, but must be required to obey in areas of safety, self control and
social :Ui.teraction.
"While frequency and consistency are stili important, children of this

age can handle a schedule of access which provides less frequent contact.
An 18-month.:.Old child who is w!th the other.parent only on weekends can
handle parts .ofa day. For older toddlers, when the non.-residential parent
.has· bee·n. a retul.ar·.and s~gnifi.Cant careta~er, an overnight per ~~eek· is
. possible o:µ<;e the child has become accustomed to the other parent's
·surroundings. Weekend long access is still not recommended.
PRESCHOOLERS C3 TO 5 'YEARS)
Preschooi children are developing sex role identification and p~er

relationships as well as lear.ning t.o ·m.anage their ~pulses. Parents need to model
clear i:oles and values and to tise effective parenting skills.
The level of conflict between parents appears to be more important than the
schedule of .contact for preschool children: Almost as important is the
PREDICTABILITY OF THE CONTACT. Frequent contact also is indicated.
·Sporadic, infrequent access is clearly contraindicated.
B-3 EXHIBIT . ~""~-

. .'
EM OP Lynnwood
\3810 196th St SW
Lynnwood, WA 98036
'· ... '"" .: -.-... .....,

07APR-9 Pii 4:32 " I-~,~.: .. .... -;1
,\
DATE, 2007-04-02
SNGHCH1Sr1 1.~uu!-t T 'f 07 ~p,~ i 0 P" 3
TO: Snohomish County sup;J~i~f: !£:-OUtfi:O lJ RT . " : 35
PA•· L
3000 Rockefeller Ave MS 502 cdJ,,rPAi':JEf s
SNOHOHJ.rff( CLff/~
Everett, WA 98201-4046
co ·"·~SH.
"' . .
•• 0
RE, Chad A. Rife (1982-09-02)

4628 7Sth St. SW
Mukilteo wn ~e?25
case Nurnber<::os-3- 755-1
Intake Dace, 2007-01-30
Program: '
Anticipated Completion Date: 0000-00-00
Report Period, 2007-03-01 to 2007-04-30
Treatment Activity:

2007-03-12 01'29 A AM/DV-A - Present
' ~\. ~
1 .r - T f-. ·'
Uri'nalysi S Results:
Date Result Drug
None to report
Support Groups attended:

o Verified
Patient is:
[X] in compliance
Ill lllll llllllllll lllll lllllllllllllll llll llll
[X] Continue
[ ] Completed
[ ] Discharged
Comment:
This correspondence is to advise the court of the continued progress of this client in all
areas of qomestic _violence perpetrator treatment. His attendance, attitude and group
Participation remain good. Prognosis remains positive at this time. Is currently attending
once monthly monitoring groups per WAC 388-60.
Probation/Co~rt assistanCe requested: [XJ Yes [ ] No
2007-04-02
Tim Tackels, CDP
. ~ ....
EM OP Lynnwood Confidential.
l.tAY-01-2007 14:15 FROl.4-CUSTOl.l:R ENGINEERING 425-783-8650 T-846 P.003/003 F-894
F\LED
011'\A~ -2 ~!'\ \\: 5 I
PAM L. DANIELS
1 couHTY CLE~K
SNOHOMISH CO.WA SH.
2
5
I Illlllll llllll Ill lllll lllll 111111111111111111111111111111111
CL12203817
6

COUNTY OF SNOHOMISH
8
9 In re:
Andrew Scott Rife
10 Petitioner, NO. 05 3 02755 1
and
11 JENNY HENDRY
Jennifer Rae Rife
13 1. JENNY HENDRY, declare under penalty of perjury of the laws of the

14
15
I am JENNY HENDRY. 1 operate an in-home daycare in Everett WA. I am
16 licensed as a childcare provider for children from birth to age 11.
17 2. MY RATES
18 1talk to other childcare providers from time to time. I am familiar with
the market for services such as mine. The rates I charge are ordinary in
19 this area.
20 I currently charge $30 per day for toddlers. Toddlers are children from
2 to 3 year old.
21
I sometimes care for children outside ordinary work hours. MY after
22 hours rate is $5.00 per hour. 1charge the after hours rate commencing
at 5:30 p.m.
23
on May 1, 2007
25
26
CARLl.GAUL
Attorney at LEW
1604 Hewitt Ave.
DECLARATION OF SHELLY PAmSON Everett WA 98201
Pagel 425 259-'1147 FAX 259 7081
3
a?-\G\~f\\..
EM OP Summit
2601 Summit Ave
Everett, WA 98201
FILED
425-258-2407
425-339-2601 I lllllll l l l Ill lllll lllll 111111111111111111111111111111111 UiMAY-2 AHI0=36
CL 11943653
f'f,M L. DANIELS
coutnY CLERK
DATE: 2007-04-16 ;,NOHOHISH CO. 'ii,', SH.
Everett, WA 98201
RE: Andrew S. RIFE (2007-03-12)

2416, 5th Street
Everett, WA 98201
Case Number: 05-3-02755-1
Intake Date: 2007-03-12
Report Period: 2007-04-01 to 2007-04-30
Treatment Activity:

2007-04-02 01:29 Present DV Monthly Monintoring - Present
2007-04-05 00:14 Case Management .25 hr
Urinalysis Results:- -
Date Result Drug
None to report
Support Groups . at tended :i~ r :.: 1 •
0 Verif i'ed
Patient is:
[X] in compliance
( ] not in compliance
Compliance Criteria Met: [X] Yes No
[X] Continue
[ J Completed
[ J Discharged
Comment:
This is to advise the court and attorney of the continued progress of Mr. Rife in Domestic
Violenc Monitoring phase of one year treatment program. He has attended his final weekly
group~and one moilthlY monitoring group since entrance into EMI DV treatment program.
Prognosis remains positive at this time.
Probatiori/Court assistance requested: [X] Yes [ ] No
~~
Tim Tackels, CDP
2007-04-16
·. ·I;'· ..
EM OP Summit Confidential.
EM OP Summit
PO Box 12598
Everett, WA 98206
425-258-2407
.-
7
425-339-2601 007 flAY -4
DATE, 2007-04-30
Everett, WA 98201
RE, Andrew S. RIFE (2007-03-12)

2416, 5th Street
Everett, WA 98201

Intake Date' 2007-03-12
Report Period, 2007-04-01 to 2007-04-30
Treatment_ Activity:
Date ,,Duration Attendance Type

2007-04-02 01,29 Present DV Monthly Monintoring - Present·
2007-04-05 00,14 Case Management .25 hr
2007-04-16 oo,oo Status Report
Urinalysis Results:
Date Result Drug
None to report

o Verified
Patient is:
[X) in compliance
[ ).L not in compliance
Compliance Criteria Met: [X] Yes No
[X] Continue
[ ] Completed
[ ] Discharged
Comment:
This correspondence,is to advise of the continued progress of the above named client in
domestic .violence PerpetratOr treatment at this facility. The exercises are done in timely
manner. The attitude, attendance and group participation remain good. CURRENTLY ATTENDING
MONTHLY MONITORING GROUPS. Prognosis remains positive at this time.
Probation/Court assistance requested: [X] Yes [ ] No

~/L/) 2007-04-30
Tim Tackels, CDP
EM OP Summit Confidential.
1 Fll_.EO
2 07 JUN 15 PM 12: 05
3
4
~,·I I1\\1\\1111\11\\I11\1\II\\\1111\\Ill\II\\\I\\\\\\\\\\\\\\\\\
I CL 12362388
PAi1 L. DANIELS
COUNTY CLERK
SNOHOMISH CO. l'I A SH.

7
8
9 Petitioner
and CALENDAR NOTE
10 (COMMISSIONER S
1
DOMESTIC
Jennifer Rae Rife MOTION CALENDAR}
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: June 29, 2007

CAL EN DAR- (Except matters relating to
Nature of Hearing:
Department B or C, As Assigned Motions: motion re summer 2007
18
19
21 and/or terms. SCLCR 7(b)(2)(E). This form cannot be used foi>trlal , settings. SCLMAR 2.1 40(b).
22 Dated: June 14, 2007
23
24
25
AL 26
27
28
ORIGINAL §)
CALENDAR NOTE
CARL J. GAUL
Attorney at Law
,,.j
()•)
l-
I
(COMMISSIONER S
1
Everett WA 98201 \
(425) 259-4147 Fax 259-708{lo ,
'-j
: .... ; ' . . .. .
· .. !
' . . ., . . . ·. ..·.
.. . . .·.>i . .· ' ..
·, . . . . . · .·
... ;.:·
: .·. i.: ..· : ·, . . .·
.. '• .. I...,. ·... ·._ ... :··... . '.,·. "
.
'.
. . ;
·.· . · .. •·'FILED····.·
'
·.-·
·...
·..
·. ·.:
' ' ' 2007 AUG 16 Plf I: 16 ' '' '
. •. •.. : 11111111111111 .. 'PAHL DANIELS
· ' COUNTY CLERK .
SNOHOHISH co .. wASH:·.: .. ·
i . CL 12544183
.......
..... · . ' . .
; ..
. ·.·. '
"'
SUPERIOR COURT OF THE STATE OF WASHINGTON .
' . IN AND FOR THE COUNTY OF SNOHOMISH
', .. re rhi; m .. rr1~e i= .·.·.·•· ·'

·. Ario/re~ Sc~#Jf
. . Plain ·
. ·. ·
titioner NO. oS-3-p,..755-/
COVER SHEET.
ATTACHED HERETO IS: ·-r,~~tmenr ·.···~.'(Am.· Re-por±
~ ...
__.. _
. . _ _ _<·• . . f}t
' ''' ·.· \~
• . ·-1..
'
PO Box 12598
Everett, WA 98206
425-258-2407
425-339-2601
DATE: 2007-08-13
Everett, WA 98201

2416 5th Street
Everett, WA 98201

Report Period: 2007-08-01 to 2007-08-31
Treatment Activity:

2007-08-06 01:30 Present DV Monthly Monitoring - Present
Urinalysis Results:
Date Result Drug
--------------------------------------------------------------------------------
None to report

O Verified
Patient is:
(X] in compliance
( ] not in compliance
[X] Continue
[ ] Completed
[ J Discharged
Comment:
THIS CORRESPONDENCE IS TO ADVISE YOU OF THE CONTINUED PROGRESS OF THIS CLIENT IN MRT-DV
TREATMENT SINCE LAST REPORTING. HE MAINTAINS GOOD GROUP ATTENDANCE, ATTITUDE AND
PARTICIPATION. PROGNOSIS REMAINS POSITIVE THIS DATE.
Probation/Court assistance requested: [XJ Yes [ ] No
2007-08-13
Tim Tackels, CDP
...........
-.
Evergreen Manor - Summit: Outpatient Confidential.
I 11111111111111111111111111111111111111111111111111111111 \Ill
1
CL 12536586
2
3
4
5
6
7
9
COUNTY OF SNOHOMISH
11 ANDREW S. RIFE, NO. 05-3-02755-1

Petitioner,
12
-~'
and DECLARATION OF JE1''l'l'IER RIFE
1 ii, Respondent.
15
16 My name is Jennifer LeSourd and I was formerly known as Jennifer Rife. I make
17 this declaration based on my own personal knowledge.
18 As I understand it, Andrew Rife is once again asking that this court modify the
19 parenting plan without bringing a Petition to Modify the Parenting Plan or without asking
20 the court to find that there is adequate cause to modify the parenting plan. This is not the
21 first time he has made this request and this is not the first time I have made this objection.
22 I am attaching the declarations I have previously filed so that I don't have to repeat
23 myself each time.
24 Frankly I have to say that I have been quite alarmed at how negative and
·25 destructive Mr. Rife's behavior has been since we signed the final parenting plan. I was
26 hopeful that things would settle down but they did not. There is always the issue of
27 Andy's refusal to complete a state certified and WAC compliant DV treatment course.
28 He was ordered into treatment because he was arrested and convicted of assaulting me in
29 2005. In over two years he has not managed to finish a one year DV treatment course.
30 DECLARATION OF JENNIER RIFE

IN RESPONSE TO MOTIOl\' TO
Page I
oyer & Primor
503 Twelfth Ave.
Seattle, l-\ 1A 98102
ORIGINAL (206) 343-15-

1 He has been in at least 5 different treatment agencies. The agency he is currently
2 allegedly working with refuses to talk to me, to may attorney or allegedly to Andy's
3 attorney. I have made myself aware of the WAC' s requirements for DV treatment
4 programs and I am aware that their refusal to communicate with me violates the WACS
5 that govern DV treatment programs. I really don't care that they allegedly have talked to
6 Bridget Llewellyn as she was not the victim of Andy extreme abuse and frankly I have
7 Jong ago stopped believing anything she says. I hate to say this but frankly I think Bridget
8 Llewellyn has some unresolved issues that prevent her from being objective in any way.
9 She has become meaningless as a Case Manager and is not useful or helpful in any way.
10 My family and I have grown so concerned over her abusive behavior that we recently
11 hired Jennifer Keilin who is a well known Parenting Evalu'ator and GAL. We provided
12
her with Bridget's complete file and with all the information we had in this case relevant
to the GAL/Case Manager and asked her to give us a second opinion. Her report is
13
attached. I concur fully with her report and it frankly speaks for itself.
14
I also want to note that Andy has abused the conflict here in ways that this court is
15
not even aware of. We entered our final parenting plan in November of 2006. In
16
December he brought a motion seeking to have my attorney disqualified from
17
representing me. His attorney stuck the motion before it was heard but we were forced to
18
respond never the Jess. Right after that he began bringing grievances with the
19
Washington State Bar Association against both my attorney and her Jaw partner· who
20
stood in for her on two occasions in my case.
21
Between January and August of 2007 Andy kept up a relentless barrage of
22
grievances directed at my attorney. He hired an attorney, as Mr. Ripley, who I
23
understand was also Mr. Gaul's attorney when he was suspended from practicing for
24
some short period of time. Andy's grievance was his claim that every word Ms. Dyer
25
ever spoke in court was a lie. Then he apparently hired a private investigator to tear apart
26
Ms. Dyer's life. Everything little thing they could find was brought up. They frankly
27
were not having much luck until they found a lien that Ms. Dyer's office had filed many
28
years ago that was apparently a very small violation of the Jaw governing attorney
29
conduct. Ms. Dyer immediately withdrew the lien. This lien, having nothing to do with
30 DECLARATION OF JENNI ER RIFE
MODIFY THE PARENTING PLAN Dyer & Primont
Page 2 503 Twelfth Ave. E ·
Seattle, WA 98102
(206) 343-1528
ORIGINAL
1 this case, is the only thing the WSBA found that she had even come close to doing
2 wrong. The point is Ms. Dyer and Mr. Primont have had to spend their ovm time and
3 money defending themselves against Andy and his specious and false allegations for over
4 six months. As I now understand the bar is obligated to investigate every complaint, no
5 matter how clear it is that it is just brought to harass an attorney. Every time she would
6 respond, Andy's attorney would find something else and keep the ball rolling. Ms. Dyer
7 estimates that she has spent over $25,000.00 in attorney fees in defending herself against
8 Andy's baseless allegations about her conduct to the bar association.
9 Meanwhile, I went through a medical technology program so that I could have a
10 better paying job and have started school to obtain my nursing degree. This required that
11 our daughter be in preschool or daycare. Andy refused to pay any share of the day care
12 expense. He forced me to arbitrate this issue. I prevailed on the arbitration but Andy has
still not paid his full share of what he was ordered to pay." My point is that he has
13
continued to abuse me and this conflict in any way he can.
14
I have been very concerned because it is clear that Andy and his family are saying
15
very terrible things about me and my family to our daughter. Her statements when she
16
comes back from visitations are very troubling. There is a long history of this. Don
17
Layton noted Andy's "toxic rage" towards me and my family as a problem for Andy in
18
2006. He recommended that Andy get some individual therapy to deal with his anger but
19
Ms. Llewellyn has simply ignored this recommendation, even though she was the one
20
who sought out Mr. Layton's opinion.
21
Andy has simply not changed. He is spiteful and mean any time I see him. When
22
we are here at court he almost always is agitated when we are out in the hall. I see him
23
pacing up and down and several times he has made very rude and hateful comments
24
towards my parents if they are here with me. He has tried to provoke my father into a
25
fight on several occasions. His anger simply spills over, regardless of what I do or say. I
26
have come to believe that this frankly has very little to do with me anymore, it is really
27
all about Andy's uncontrolled anger and his need to get back at me for exposing his
28
abuse.
29
Page3 503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
1 I am attaching a transcript from a hearing we were at in the summer of 2005, right
2 after he and his mother had obtained anti harassment orders against my mother and I.
3 The orders were ultimately dismissed with the judge commenting that there was no
4 evidence at all but it was clear that Mr. Rife and his mother were only using the court
5 system to attempt to gain an advantage in the family law litigation. At that time he was
6 warned by the commissioner that he needed to pay attention to his treatment and stop
7 blaming everyone else. Nothing has changed.
8 Andy is supposed to take a class called DV Dads but he has managed to make it
9 appear that he is in compliance even though he his not in that class. He is not in that
10 class because his treatment provider refused to talk to Family Services treatment
11 program, also a violation of the WACS. So, let me get this straight: Andy is not moving
12 forward with his treatment because his current treatment is refusing to do something they
are required by law to do. And that is all right? It is not.
13
And now, even though he is still not in DV Dads he is asking the court, without a
14
Petition to Modify the Parenting Plan, to just get rid of the RCXW 26.08.191 restrictions
15
in our parenting plan. I want to be clear to the court: His abuse was not just verbal or
16
emotional. Andy is physically abusive as well as emotionally abusive. He is abusing our
17
daughter now by constantly telling her lies about me. Things he has no business telling
18
our child. To say that he is a wonderful parent (as Bridget seems to do) is simply not
19
objective. He is full of anger at our exchanges. Our child comes back to me saying
.20
terrible things to me about me. Things she could only hear from her father.
21
From what I can tell Andy has not changed at all. All he has apparently learned
22
from the five treatment agencies he has been in is how to take his abuse underground.
23
Now he is.using this system to abuse me and anybody that wants to help me, such as my
24
attorney.
25
Andy has forced my attorney and her law partner to waste over $30,000.00 of
26
their time in the last six months with his abusive grievances to the bar association. He
27
has refused to pay his share of day care or pre school expenses without being absolutely
28
forced to do so. He continues to come to this court with illegal motions (i.e, asking to
29
modif)• the parenting plan without bringing a Petition and seeking a finding of adequate
Page 4 503 Twelfth Ave. E
Seattle, WA 98102
ORIGINAL (206) 343-1528
-, -, . -, - 4253041333
.. L. ~ • ..::• =i
cause). This is clear abuse of this conflict. I have made this request in the past but I am.
asking again. Please see this for what it is and stop him by ordering that he pay
$30,000.00 in attorney fees for his abuse of this conflict.
I am not attaching the grievance file to this declaration as it contains much private
information about Ms. Dyer and Mr. Priillont. It is certainly available to the court to
review in private. It is clear from reading it that Andy is willing to spend any amount to
continue to abuse me and anyone that works with me. Please stop him and send him a
message that this abuse will not be tolerated.
I am asking that there be no change in Andy's time with our daughter until he is
enrolled in DV Dads and making satisfactory progress.
foregoing is true and correct. Signed and dated this 20th day of August 2007 in
Snohomish, Washington.
DECLARATION OF JENNIER RIFE

Pages
ORIGINAl
....
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COUNTY OF SNOHOMISH
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In re:
10 ANDREW S.RJFE Case No. 05-3-02755-1
Petitioner, GR! 7 DECLARATION
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and
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JENNIFER R.RIFE
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Respondent,
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20 I have examined the Declaration of Jennifer Rife which consists of 5 pages not
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98102, telephone number 206-343-1528 and fax number 206-343-7781.
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Dated this 20th day of August, 2007 in Seattle, Washington.
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Dyer & Primont
503 Twelfth Ave. E

(206) 343-1528
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·;,;_ suoCHOUNT y CLEllK- I
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COUNTY OF SNOHOMISH
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In re:
11 ANDREW S. RIFE,
NO. 05-3-02755-1
12 Petitioner,
and REPORT OF JENNIFER KEILIN, MSW,
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CCDC REGARDING CASE MANAGER
14 JENNIFER R. RIFE, BRIDGET LLEWELLYN'S MOST
Respondent. RECENT REPORT
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Dyer & Primon1

503 Twelfth Ave.
Seattle, WA 98102
(206) 343-1528
_ _\I\~ _:__
Jennifer Keilin, MSW, CCDC
216FirstAvenueS. Suite#333 Seattle,\l./A 98104
Phone (206) 621-7007 Fax (206) 623-9267
August 16, 2007
Jan Dyer .
Seattle, WA 98102
Re: LeSourd/Rife Matter
Dear Ms. Dyer:
This matter was referred to me by the office of Jan Dyer, the attorney for Ms. LeSourd, on July
26, 2007. Ms. Dyer requested that I review Ms. Llewellyn's Case Manager Report of July 26,
2007 and provide my opinion regarding any concerns I noted about Ms. Llewellyn's process,
opinions and recommendations.
This is my report on my review of Ms. Llewellyn's Case Manager Report. In addition to

reviewing Ms. Llewellyn's report, I also reviewed the following docume_nts:
2006/2007 Bridget Llewellyn GAL file

2007 Invoices from Bridget Llewellyn
GAL reports
GAL questionnaire
Bridget Llewellyn communication
Arbitration notebook
Arbitration decision
Bridget Llewellyn's financial spreadsheet
Bridget Llewellyn's update/completion on Andrew Rife
Dale Todd correspondence
Don Layton correspondence
Edgewood records
Everett Municipal Court docket, Andrew Rife criminal file
Mr. Gaul's contempt motion, 7/31/06
Mr. Gaul's motion for ex parte restraining order and show cause 11/05
Mr. Gaul's motion to dismiss counsel
Mr. Gaul's letters and Andrew Rife declaration on upcoming summer schedule
Ms. Hilfrink's reports/Jennifer
LeSourd/Rife Matter
Page 2 of6
Ms. Hilfrin.k' s report, Residence XII, Dr. Keller correspondence

Incident report, Michael Brunsman
Modify parenting plan notebook
Motion for summer schedule and order
No contact order/police reports
Notebook in support of issuance of protection order
Orders/Finals
Phoenix Counseling correspondence
Protective order hearings file
Correspondence received from Bridget Llewellyn
Sandy Poier correspondence
Summit counseling
Visit reports 2005
My opinion is based solely on my review of Ms. Llewellyn's report and these materials. This
report is intended to be used solely for the current litigation and no other purpose.
Introduction
Ms. Llewellyn was appointed as the case manager for Mr. Rife and Ms. LeSourd, regarding their
child, in November of 2006. Ms. Llewellyn provided her Case Manager Report on July 26,
2007, in advance ofa scheduled hearing on August 13, 2007. In her report, Ms. Llewellyn
provided an update regarding a number of events since the last hearing on April 5, 2007, stated
some opinions and made recommendations.
On page 1, Ms. Llewellyn discusses Mr. Rife's progress in completing his DV Dads program.
On page 1, line 20, she states Mr. Rife is "unable to follow through" with the court ordered
requirement of attending Family Services DV Dads program because his Evergreen Manor
treatment provider refuses to speak with Family Services. Her ·statement that Mr. Rife is unable
to follow through appears to be somewhat misleading. According to the Family Services client
progress report of May 2007, Mr. Rife can be "considered for re-entry to DV Dads once he has
satisfactorily completed the requirements of his primary DV program." On page 4, line 10 of her
report, Ms. Llewellyn stated Mr. Rife is willing to seek entry to the DV Dads program at that
time. It appears that Ms. Llewellyn should have stated "Mr. Rife is unable to follow through at
this time." On page 2, line 1 of her report, Ms. Llewellyn reported Mr. Rife "will finish his
Treatment in September ... " It appears Mr. Rife will soon be eligible to re-enter the DV Dads
program. It is not clear why Ms. Llewellyn believes he is unable to follow through with this
requirement and it appears her conclusion is somewhat inaccurate.
Regarding Evergreen Manor's refusal to .provide information to Family Services, Ms. Llewellyn
should be aware that WAC 388-60-0145(3) requires domestic violence perpetrator program
participants to sign a release "allowing the current domestic violence perpetrator treatment
program access to infonnation held by all prior and concurrent treatment agencies, including
domestic violence perpetrator treatment programs, mental health agencies, and drug and alcohol
treatment programs." Mr. Rife signed a release for Family Services to access his treatment
information from Evergreen Manor, as noted in Family Services client progress report of May
2007. Ms. Llewellyn does not appear to consider that Evergreen Manor's failure to share
LeSourd/Rife Matter
Page 3 of6
information, which prevents Mr. Rife from progressing in his court ordered treatment
requirements and delays expansion of his parenting time, may constitute a form of malpractice
and may be actionable. She appears to conclude that Mr. Rife has no control over Evergreen
Manor's decision, but does not report any steps Mr. Rife took to remedy this situation. She
herself does not appear to inquire as to any steps that may be taken, such as putting an official
request in writing through Mr. Rife's attorney, having Mr. Rife provide a complete copy of his
treatment file to Family Services, speaking with Roy Carson in Olympia, or even lodging a
complaint. There seems to be an emphasis on "not rocking the boat" with Mr. Rife's Evergreen
Manor treatment provider, perhaps at the expense of holding Mr. Rife accountable.
On page I, line 21, Ms. Llewellyn reports that Mr. Rife's Evergreen Manor provider said
" ... when he saw what other providers had been through in this case there was no way that he was
going to put himself in the same position." She does not appear to inquire nor does she report
how communicating with Family Services would create a problem for Evergreen Manor, even
though communication between the programs appears to be expected and provided for by the
WACs. There appears to be an implicit assumption that Mr. Rife's previous domestic violence
perpetrator providers were treated improperly or poorly, although the legal record and Ms.
Llewellyn's previous reports reflect that Mr. Rife changed from two agencies specifically
because of issues surrounding WAC compliance.
Although Ms. Llewellyn previously recommended Mr. Rife engage in treatment that met the
WAC requirements, she now appears to blame Ms. Dyer for Mr. Rife's lack of progress in
treatment. In her Case Manager Statement of April I, 2007, Ms. Llewellyn stated Ms. Dyer "has
gone about sabotaging" Mr. Rife's treatment (page 2, line 18), that Ms. Dyer waited until Mr.
Rife had completed 25 weeks of Phase one before she "made sure ... Mr. Rife should get no
credit for any of his treatment ... " (page 3, line 5), credited Ms. Dyer with an "effective
sabotage" because Mr. Todd "declined to do further treatment because he was going by his
license requirements" (page 3, lines 13 - 14), and stated Mr. Rife's had trouble focusing on his
restarted treatment because of his perception of "constant harassment" (page 3, line 16). Ms.
Llewellyn does not appear to hold Mr. Rife accountable for his actions related to his domestic
violence treatment, including continuing with a provider after learning the provider was
practicing outside of the WAC, insisting another provider give credit for that treatment even
though that was outside the WAC, and having trouble focusing on treatment because he
ultimately had to start over. This appears to continue even now, as stated above, as Ms.
Llewellyn does not seem to think Mr. Rife bears any responsibility for his current provider's
refusal to speak to Family Services despite Mr. Rife's signed authorization. It is a concern that
Ms. Llewellyn's strong negative feelings about Ms. Dyer may be preventing her from holding
Mr. Rife accountable for his choices and behavior as is her duty as case manager.
Ms. Llewellyn discusses Mr. Rife' s voluntary completion of an alternate parenting class. On
page 2, line 3, Ms. Llewellyn states Mr. Rife completed the "seven (7) week S.T.E.P. Parenting
Class through Providence Hospital's Family Resource Center. On page 4, line I 0, Ms.
Llewellyn states Mr. Rife remains willing to go to DV Dads "even though he did the S.T.E.P.
class." Ms. Llewellyn appears to equate the S.T.E.P. Parenting Class with Family Services DV
Dads program. These two programs are very different. Providence Hospital's website describes
their S.T.E.P. parenting class as a program "designed to help you become a better parent. STEP
LeSourd/Rife Matter
Page 4 of6
participants work together in small discussion groups allowing parents to become actively
involved in discussing common concerns and learning specific child-training ideas and skills."
Family Services brochure describes DV Dads as an "innovative group [that] helps men
understand the effect of their domestic violence and abusive behavior on the children who have
been or are in their lives. We cover child development, parenting techniques and communication
skills, all in the context of violence in the child's home." Ms. Llewellyn's apparent acceptance
of Mr. Rife's completion ofa S.T.E.P. Parenting class in lieu of Family Services DV Dads is a
concern and seems inappropriate as it is outside the court order of April 5, 2007. While she does
not specifically recommend that Mr. Rife no longer be required to follow through with DV Dads,
her visitation recommendation on page 5 is no longer contingent on his completion of that
program, as it was in the past.
Ms. Llewellyn describes her impression of Mr. Rife's parenting abilities and relationship with
the child. On page 2, line 6, she makes a very strong, affirmative statement on Mr. Rife's behalf:
"!can assure the court that Lauren is her father's number one priority. Nothing in his life comes
before Lauren and her needs." This brings up two concerns. First, Ms. Llewellyn appears to be
advocating for Mr. Rife and her strong, unqualified statement suggests a lack of objectivity.
Although Ms. Llewellyn's role in this matter is as a case manager, for which there appear to be
no documented rules of conduct, she also continues to identify herself as a Guardian ad Litem by
profession and should be bound by the Guardian ad Litem rules. Washington State Superior
Court Guardian ad Litem Rule 2(b) states, "A guardian ad !item shall maintain independence,
objectivity and the appearance of fairness in dealings with parties and professionals .... " Second,
Ms. Llewellyn appears to now see Mr. Rife's parenting and relationship with the child as
separate from the issue of domestic violence. The domestic violence literature is clear that
domestic violence issues are intertwined in the perpetrator's parenting and relationship with the
children in a number of ways. It is a concern that Ms. Llewellyn would make this statement on
Mr. Rife's behalf before he completed his domestic violence related treatment requirements,
particularly the DV Dads component.
Ms. Llewellyn reports asking Ms. LeSourd to share any concerns she has with Ms. Llewellyn.
On page 2, line 18, Ms. Llewellyn stated Ms. LeSourd provided her with "some thirteen (13)
pages of mostly regurgitated complaints about Andy and his alleged behavior." Ms. Llewellyn's
statement is disrespectful of Ms. LeSourd and trivializes her concerns. This is inconsistent with
Guardian ad Litem Rule 2(f) which states, "A guardian ad !item is an officer of the court and as
such shall at all times treat the parties with respect, courtesy, fairness and good faith." Ms.
Llewellyn goes on to say, " ... for the most part [Ms. LeSourd's concerns] are not things that
could not be worked out if the two were actually talking to each other ... " She appears to hold
Ms. LeSourd primarily accountable for the lack of communication between the two parties,
which may indeed be related to the restraining order Ms. LeSourd obtained subsequent to Mr.
Rife' s assault.
Ms. Llewellyn references nature of the litigation a few times in her case manager report,
describing "continuous hostile litigation in this case (page 2, line 23)" and " ... the litigious
nightmare that is this case (page 4, line 8) ... " Ms. Llewellyn appears to hold Ms. LeSourd and
her attorney primarily responsible for this, as evidenced by her case manager statement of April
I, 2007 in which she openly blames Ms. Dyer. The legal record appears to reflect that Mr. Rife
LeSourd/Rife Matter
Page 5 of6
and his attorney initiated or necessitated a number oflegal actions, including an attempt to
disqualify Ms. Dyer as attorney for Ms. LeSourd, refusing to pay daycare costs, filing a
protection order against Ms. LeSourd and her mother, seeking to expand the visitation schedule
before meeting court ordered requirements, and even pursuing a bar complaint against Ms. Dyer.
It is a concern that Ms. Llewellyn does not appear to consider that the number and nature of Mr.
Rife's multiple legal actions may rise to the level of abusive use of conflict. It would be
reasonable for her to weigh whether Mr. Rife is abusing Ms. LeSourd through the legal system
and if he is failing to effect changed behavior despite progressing through domestic violence
treatment. Ms. Llewellyn's strong, negative feelings towards Ms. Dyer may be preventing her
from holding Mr. Rife accountable and making appropriate recommendations.
A specific example of Ms. Llewellyn seeming to fail to hold Mr. Rife accountable relates to his
proposed parenting plan filed on March 19, 2007. This plan eliminated the RCW 20.09.191
restrictions related to his domestic violence, despite the fact he was currently in a domestic
violence perpetrator's program and had been criminally charged for assaulting Ms. LeSourd.
This should have been a red flag to Ms. Llewellyn regarding Mr. Rife's commitment to taking
responsibility for his behavior. A similar example occurred in June of 2007 when Mr. Rife filed
a motion to expand his time with Lauren based on Ms. LeSourd's school schedule. To support
his motion, Mr. Rife attached statements written by his family members in 2005, at the start of
this action, which spoke highly of his parenting, insisted he would never harm anyone and spoke
negatively of Ms. LeSourd's parenting, character and lifestyle. This, too, should have concerned
Ms. Llewellyn. These actions by Mr. Rife suggest that he may not be taking responsibility for
his behavior, continues to blame his victim, and is not manifesting changed behavior. Ms.
Llewellyn does not comment on this behavior in her reports.
Ms. Llewellyn goes on to discuss her contact with the child's preschool. On page 3, line 16, Ms.
Llewellyn reported speaking with the child's Montessori school director and "advised Felicia to
refuse to discuss anything other than Lauren's welfare with any person dropping off or picking
up." Advising the preschool to take certain actions appears inappropriate as it is outside the
scope of Ms. Llewellyn's court ordered case manager duties.
Ms. Llewellyn describes her impression of the child's needs. On page 4, line 12 of her report,
Ms. Llewellyn states, "Lauren needs a regular, normal pattern of contact with BOTH parents and
regardless of what the prior agreement was, we need to move forward." ... " Her statement is
somewhat unclear, as Lauren currently has regular, unsupervised visitation time with Mr. Rife
each week. Ms. Llewellyn fails to describe any difficulties manifested by the child that support a
need to change the schedule at this time and, in fact, appears to report things are going well for
her (page 2, line 5; page 3, line 19).
Ms. Llewellyn goes on to give her current recommendations. On page 5, Ms. Llewellyn
recommends a substantial increase in Mr. Rife's parenting time. She provides no evidence to
support that this recommendation is in the child's best interests as demonstrated by the child. It
is a concern that Ms. Llewellyn is recommending increased visitation at this time despite the fact
Mr. Rife has not yet completed the requirements necessary to qualif)' for additional time, as
ordered by the court on April 5, 2007.
LeSourd/Rife Maner
Page 6 of6
In summary, there are a number of concerns present in Ms. Llewellyn's report, including the
appearance of a lack of objectivity, a pattern ofleniency in favor of Mr. Rife and of appearing to
attribute greater responsibility and blame to Ms. LeSourd and Ms. Dyer. Ms. Llewellyn's
recommendation for increased time for Mr. Rife does not appear to be supported by the available
facts.
I hope this information has been helpful.
Best regards,

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COUNTY OF SNOHOMISH
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In re: Case No. 05-3-02755-1
10 ANDREWS. RIFE, GRl7 DECLARATION
11 Petitioner,
And
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13 JENNIFER R. RIFE
Respondent,
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I am the attorney for the Respondent in the above-captioned matter and I make the
17 following statements pursuant to GR! 7a(2):
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I have examined the Report Of Jennifer Keil in, MSW, CCDC, which consists of 6
19 pages not including this declaration. The email transmission is complete and accurate.
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The Report was emailed to me at 503 Twelfth Avenue, Seattle, Washington
21 98102, telephone number 206-343-1528 and email addressjan@dyerprimont.com.
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I declare under penalty of perjury under the laws of the State of Washington that
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Dated this 20th day of August, 2007 in Seattle, Washington.
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27 . DYER WSBA#20355
Attorney for Respondent
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Dyer & Primont
503 Twelfth Ave. E
Se•ttle, WA 98102
ORIGINAL (206) 343-1528

..
216 First Avenue S. Suite #333 Seattle, WA 98104
Phone (206) 621-7007 Fax (206) 623-9267
Curriculum Vitae
Areas of Practice
Forensic Examinations
Parenting Examinations
Chemical Dependency Assessment
Counseling
Education
Master's of Social Work, University of Washington, 1998.
Addiction Studies, Pierce College, 1993.
Bachelor's of Social Work, Pacific Lutheran University, 1991.
Internships
Social Worker Intern, Child Welfare Services, DCFS. September 1997 to April 1998.
Social Worker Intern, King County Family Court Services. January 1997 to June 1997.
Chemical Dependency Counselor Intern, Shared Health Services. December 1992 to March
1993.
Employment Experience
Private Practice. Forensic Evaluations and Counseling. April 2003 to present.
Forensic Social Worker, Dr. Stuart Greenberg, PhD. Conducted parenting, personal injury, and
chemical dependency examinations. March 2001 to April 2003.
Foster Parent Recruiter, Division of Children and Family Services. Developed and implemented
a pilot program to recruit foster parents in King County. November 2000 to March 2001.
Social Worker 3, Child Protective Services, DCFS. Performed investigations and assessments,
and provided case management services to children and families. April 1998 to November 2000.
Juvenile Rehabilitation Counselor, Echo Glen Children's Center. Provided assessments,

counseling and case management services to incarcerated youth. July 1994 to April 1998.
Chemical Dependency Counselor, Shared Health Services. Performed substance abuse

evaluations and provided individual and group counseling. March 1993 to July 1994.
Certificates
Certified Chemical Dependency Counselor I, since 1994.
Academy of Certified Social Workers, since 2003.
Jennifer Keilin, MSW, CCDC Page 2 of 3
Post Graduate Training

Changing for Good: Practical Tips for Individual and Population-based Motivational
Interviewing. Dr. Christopher Dunn. Seattle, WA. 11 hours. May 14 & 15, 1999.
Personal Injury Examinations. Stuart Greenberg, PhD. American Academy of Forensic

Psychology. Vancouver, B.C. 7 hours. March 28, 2001.
Comprehensive Child Custody Evaluations. Marsha Hedrick, PhD. American Academy of

Forensic Psychology. Vancouver, B.C. 7 hours. March 30, 2001.
Psychological Testing. Stuart Greenberg, PhD. King County Family Law CASA training.
Seattle, WA. 1.5 hours. September, 2001.
Parenting Evaluation Training Program. Andrew Benjamin, J.D., PhD. University of

Washington School of Psychology. October 2001 to July 2003.
A Survey of Forensic Psychology Practice: Issues & Applications. American Academy of

Forensic Psychology. Seattle, WA. 24 hours. October 18 -21, 2001.
Co-Occurring Disorders. Alcohol and Drug Studies. Bellevue Community College. Bellevue,
WA. 15 hours. November 9-10, 2001.
Suicide: Information to Intervention. Alcohol and Drug Studies. Bellevue Community College.
Bellevue, WA. 15 hours. November 16-17, 200 I.
19•h Annual Conference of the National Organization of Forensic Social Work: Social Work and
the Law. National Organization of Forensic Social Work. St. Louis, MO. 14 hours.
May 6-8, 2002.
The Use & Abuse of Psychological Experts in Family Law Litigation. King County Bar
Association. Seattle, WA. 6.5 hours. October 18, 2002.
Ethical Issues in Forensic Psychology. American Academy of Forensic Psychology. Long

Beach, CA. 7.0 hours. January 15, 2003.
Excusing and the New Excuses. American Academy of Forensic Psychology. Long Beach, CA.
7.0 hours. January 16, 2003.
Forensic Applications of the MMPI-2. American Academy of Forensic Psychology. Long

Beach, CA. 7.0 hours. January 17, 2003.
Assessment of Psychopathy: An Overview of the Hare Scales. American Academy of Forensic

Psychology. Long Beach, CA. 7.0 hours. January 18, 2003.
Forensic Consultation, Expertise & Testimony. American Academy of Forensic Psychology.

Long Beach, CA. 7.0 hours. January 19, 2003.
.. Jennifer Keilin, MSW, CCDC Page 3 of3
Understanding Brain Development and Infant Mental Health. University of Washington School
of Social Work. Sheri Hill, Ph.D. Seattle, WA. 21.0 hours. March 2003.
Increasing Skills in Working with Adolescents. University of Washington School of Social

Work. Carol Barber, MSW. Seattle, WA. 21.0 hours. March 2003.
Title 26 Registry Family Law Guardian ad Litem Training. King County Bar Association.
Seattle, WA. 29.25 CLE hours. February 2004.
The SASSI: Administration and Scoring. Tassi, Inc. Terry Sheneman. Seattle, WA. 3.5 hours.
June 19, 2004.
The SASSI: Clinical Interpretation. Tassi, Inc. Terry Sheneman. Seattle, WA. 3.5 hours. June
19, 2004.
Assessing and Treating Child and Adolescent Mental Health Disorders. University of
Washington School of Social Work. Sheri Hill, Ph.D. Seattle, WA. 21.0 hours. June
2004.
The Challenge of Child and Adolescent Substance Abuse. University of Washington School of
Social Work. Stephen Bogan, MA, CDP, CMHC. Seattle, WA. 21.0 hours. June 2004.
Psychopathology for Addiction Counselors. Bellevue Community College. Paula Frederick,

MEd, MS, CDP, LMHC. Bellevue, WA. 50.0 hours. December 2006.
FAMILY COURT
' 7/31/06
RIFE CASE #05-3-02755-1
.PRESENT:
Tracy Waggoner, Commissioner
·Jan Dyer, Attorney
·Carl Gaul, Attorney
Jennifer Rife
Andrew Rife
JD: Thank you Commissioner. I believe this is my motion. Let me introduce myself for the record.
I am Jan .Dyer. I represent Jennifer Rife who is here on my left. Mr. Gaul is on my right. He
represents Andrew Rife, just for the record. And there's two .motions before the court.
Originally I had filed a motion asking for a change in the supervisor to professional supervision
for this visitation case. I do want to note to the court, I think you know we're 21 days from trial
at this juncture. Mr. Gaul, on behalf of his client, has obtained an _·_ cause and a contempt
motion .. That motion has never been served on my client by personal service. It was faxed to my
office. We do not accept faxed service. Mr. Gaul is aware of that. In addition, we had indicated ·
that we would accept service and we will accept service. My client's address is confidential and
we had hoped to keep that confidential and we've always indicated that we would accept service.
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In my, at least my practice is· acceptance of service means you're sending a form and I sign it and
\ we file it and it says thai: I've accepted service. I've asked Mr. Gaul over and over to provide
that form to me. No form has been forthcoming. I don't really know what to say about that. Mr.
Gauljust personally.served my client on Friday with a new contempt motion to be heard in a few
weeks. So he does understand that the need for personal service is there, but my client has never
been personally served, nor has my office been adequately served with this motion. And I'd ask
at today's hearing for contempt to be stricken. I'd like to move forward with my motion.
TW: Go ahead.
JD·· Thank you. There's a long history with this case. I've tried to provide the court some
background. We can't certainly give the court the whole file on 'everything.
TW: I've got the whole file.
JD: I understand that. I'm not going to try and argue the entire case. In three weeks we're going to
argue that. But this has been a very, very troubling case. The case started out with two DV
arrests. After the second arrest of Mr. Rife, he filed this petition for dissolution of marriage. At
every juncture in this case it's been ordered that he have supervised visitation.· He's been
ordered into domestic violence treatment. And the criminal case, the Guardian Ad Litem in our
case has recommended that he have domestic violence treatment. There has been ... I think vou
see .the letters ... a huge brouhaha with whether or not he has to do the first phase in the gr~up:
The State Certification Agency has said yes, that's how it has to be. The Guardian Ad Litem
recommended finally that he get in to treatment with Dale Todd. He did. But Mr. Todd,
unwilling to buck the W Al:; wanting to do the program the way the WAX tell him to do it, when
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he received an order from the Municipal Court saying he had to accept first phase credits as an
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of treatment' ·he withdrew from the case. And I tl>ink it's interesting to note that the
Municipal Court case says treatment with Dale Todd. Ms. Llewellyn's recommendations are for
Mr. Rife to completely immerse himself into treatment with Dale Todd, a specific treatment
provider, because Mr. Rife has now been through three treatment providers; each time
something, either he quits or he gets removed. i think thi.s is important because we've gone
along with supervised visitation here and today what it is that we are finally asking the court that
the supervision become professionally supervised.
TW: Okay, let me interject a question here. One of the questions that I have is I appreciate the fact
that District Court for purposes of whatever pending criminal action, has taken whatever steps
they want. This is a thick file and I don't want to be operating under an incorrect assumption.
Where is, or what order requires that a DV program be completed?
JD: Well, the Municipal Court order is that.
TW: Okay, there's not a Superior Court order at this point?
JD: No there is not. It's been assumed because it was ordered in Municipal Court the court ... itjust
has to do with what's required in Municipal Court. It's not been specifically ordered in this case
and you are absolutely correct in that. It has been recommended by ...
TW: I just wanted to make sure because as I said ....
JD: No, you're_ absolutely correct. That has not been ordered in this case. Thi.s case sort
of. .. because the Municipal Court case happened first it was just sort of tracking along. Although
it has been recommended. We have the GAL's report and it was clearly a recommendation in
there as well. I just wanted to point out that Municipal Court ordered that he remain in treatment
with Mr. Todd. Ms. Llewellyn also recommended he remain in treatment with Mr. Todd. Mr.
Todd washed his hands of the case and said I'm not going to do it because I'm not going to go
against what I know to be the WAX:. And so there is a problem there. But a more .... and that has
been a problem throughout the case: And I would say that that is sort of a thing that's out there.
The treatment. It's clear that Mr. Rife has tried to avoid treatment at every cost. And the one
assessment we do have has been from Davis & Company. We've had that all along. Mr. Todd
has relied on it. And I think that it's Important for the court to understand that we're not talking
about just sort of maybe a little bit of domestic violence. When they did their assessment at
Davis & Company he was in the dangerous range on control. He was in the problem risk range
on truthfulness. And he was in the problem risk range on violence. And I just ... may harbor a lot
of poorly repressed resentment, anger and even hostility, needs close supervision. When upset,
which I _ he was now also, this person's emotions all too easily interfere with his judgment.
Under perceived stress this individual could be assaultive and potentially dangerous. He was all
those things to my client during their marriage. Our concern now is for this very small child.
I'm going to ta!k about Lauren probably more than might be comfortable because we've lost
track of Lauren, the baby, in this whole case. This case has turned so into getting Jenn that we
just don't talk about Lauren. And we are here today to talk about .Lauren. Initially the
grandmother, Mr. Rife's mother, was the supervisor. My client's mother has been the person to
also do the exchanges. And I also think it's very interesting to note, and that's kind of going
along okay, but you've got people who aren't parties, for example. And that's a problem now.
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After the anti-harassment orders, the complete false allegations that have been made against my
client, no one in the Holland family is willing to step forward.
TW: ·when is that set for hearing?
JD: That is this next Friday, Your Honor. And I have provided you with the petitions and I have
provided you a lot of answers.
TW: I appreciate that. I just wanted to know when it's set for.
JD: We asked that it be joined with this case. The District Court denied that notion and set it over to
a 'date after this hearing, indicating that they hoped that today's hearing would resolve that. I
don't know how that cart happen. But maybe you can be creative in that regard. It has now
gotten to a juncture where it's clear that the supervisor is not supervising anything. She is
basically .... and I'm talking about Wendy Rife at this point who is· the supervisor. She is actually
enabling her son to be a better abuser. She is not supervising. There has been problem after
problem after problem with the exchanges. And I was looking back .in the file. I note that the
GAL actually on May 15, and I've given you a copy of the letter, there's a letter in here dated
May 15 from the GAL which she says very clearly .... this is May 15. This is just after they've
done this exchange on the 6th that's part of.: where Wendy Rife alleged that my client harassed
her at the exchange. And in fact we tell you that Wendy Rife essentially forced herself into Ms.
Holland's home and continued talking about inappropriate things. But it's interesting because
the Guardian Ad Litem at that point recommended that ... here is it, "the grandparents are
operating in the best interest of this child and trust they can work together toward the end. I
would suggest that neither parent be present at the exchanges." Now back in May 15, if Mr. Rife
had taken that suggestion to heart, a lot of problems might have been resolved. And Mr. Rife has
insisted on being in the car at every exchange. My client doesn't go to the exchanges. She may
be at the parent's house when the child is dropped off, but.for the most part she stays out of the
way. There's no protection order against her, but she just feels that it's best to keep distance.
But he comes in the car every time, makes faces, makes comments, makes noises, honks the
horn. And his mother doesn't ever. stop. him. If you say that's not appropriate can you not do
that at exchanges? Oh it's just fun, he's just being a boy. He would never hurt you. He would
never .... he's a good guy. She just defends him. This is not a supervisor. We can't deal with the
family anymore. My client .and family can no longer take the risk that they're going to be
arrested, that they're going to be served with something else, that they're going to be accused of
some other false allegation. They just can't do this any longer. And we're submitting to .the
court that Wendy Rife is an .inappropriate supervisor any longer. She filed an anti-harassment
petition against my client. The supervisor files what we consider very false, very false
allegations. Allegations against my client at a visitation exchange. And then somehow says how
should this not stop visitation. Mr. Rife has done nothing. He's no longer in treatment with Dale
Todd. To our knowledge he's not in treatment. We are three weeks from trial and we have
another contempt motion coming at us on the 11th and we have a hearing on Friday on these anti-
h!lrassment motions. It seems to me more designed to keep us from getting ready for trial and
getting this thing moving forward. The court's not going to have any information for it when we
get to trial about supervision, about visitation. All they're going to have is a self-serving
testimony of Ms .. Rife. We need professional supervisor notes at this point. We need a
professional supervisor in this case. I know the GAL is not recommending this and I know the
GAL is recommending immediate resumption of visitation and I just want to make a note here,
and I would like to reserve a few minutes in rebuttal on this issue. But unfortunately ... we have
3
the GAL recommendations. We agree to them. We would sign a planning plan in a moment that
incorporated them. That does not seem possible. Mr. Rife does not apparently agree with GAL
recommendations. The report is finished. The GAL has now weighed in on this issue without
doing the investigation. Without talking to my client. \Vithout talking to my client's mother.
TW: Okay, I'm going to listen to her first so then you can respond to what she has to say.
JD: Certainly. Thank you Your Honor.
TIV: Go ahead.
BL: This case has taken on a total life of its own. I'm not quite sure what it has to do with this child
and what is just a fight between not only the parties but by the attorneys as well. There's an
order in November that says that the DA also returned visitation and who was supervising. I
asked that it be resumed. That was ignored. I said I would get another letter _ _. Then I said it
will resume and that was followed by threatening phone calls by five-page single-spaced letters
and counsel accused me ofbeirig in __ pocket amongst other things.
TW: Well, the issue to the court is whether or not his mother is any way appropriate at this point to be
a supervisor.
BL: I'm not sure what has happened. I did talk to the client. Ms. Dyer was on vacation. at the last
hearing. I spent most of the time talking with her and her sister trying to resolve this. I have
note pad's .. The last thing was not even between these two. It was allegedly between his brother
and her sister. How that ... I don't know what happened any more than Ms. Dyer knows what
happened. All we have is what these parties are teliing us at those exchanges. I offered to go
and observe an exchange so there wouldn't be any hassle a.-id it was turned down. So I don't
think that this grandmother is going to let anything happen to her gra.-iddaughter any more than I
think that ...
TW: So why is Mr. Rife atthe exchanges?
BL: I don't know that he is at them at this particular time.
TW: \Vell there's no visits at this particular time.
BL: Right I know that. But I'm not sure. I have been told. And apart froni being there I cannot be
sure whether he has been there every visit or not. I asked that he not go and because the child
was being taking back I believe at one point to Clearview, he was then losing half an hour of his
visit if he didn't drive back with them and wasn't willing to give that up.
TW: Do you have a position with regard to the whole issue of in this action, which is a completely
separate action than the Municipal Court criminal action, whether or not he should start DV
treatment over again? And be in group.
BL: Yes. And I've recommended that he does. And it's my understanding there's a signed document
with Catholic Community Services as of the 14'h .
TW: Of August.
4
BL: Of August. And the Municipal Court as far as they're concerned, when I talked to his parole
officer, said they were done with him. As far as they were concerned it was finished. He is just
being monitored. They have reassessed him and they assessed him as not a danger to the
community.
JD: And I'm going to object to that. ___

· (both speaking), Your Honor, and that's ...
BL: And they told me they would not .... excuse me Ms. Dyer. ...
T\V: I appreciate that. This is not entered ... this is entered as a basis for her opinion. That's the only
purpose. Not for the truth of the matter stated.
BL: I'm not disputing court information ihat I received. I asked if it was coming out in writing and
they said no they would not be putting it in writing. I asked can I disclose what you're telling me
to all the parties .. Yes you can. We are done with hiin.
TW: Okay, fine.
CG: Your Honor, Ms. Dyer's office received the order to show cause contempt and I have
accompanying documents on the 19th. Why she wants to assert that Mr. Primont's statement that
he would accept service and then a copy going to their office somehow isn't good enough, I
don't know. I have never had an attorney agree to accept service and I just send it off; and then
have a complaint that you didn't send along a form. I've never. ... when they agree to accept
service you just don't worry about it. Serve it like you would any motion. And that's what you
have in front of you. You'll notice the copy receipt stamp wit.h Mr. Primont's name on it. As to
the present motion, there's no indication that Wendy Rife has' allowed anything inappropriate to
go on. They're complaining that Andrew is present at the exchanges. He is in the car. They
stay out at the end of the driveway. Grandma takes the child to the door. What harm he is doing
by being in the car at the end of the driveway escapes me and I've never really heard why there
would be a problem with him being in the car at the end of the driveway. I've never heard a
statement that he got out ofthe car. I've never heard a statement that he directed any comment to
his estranged wife. I've never even heard that he directed any comment to the mother of his
estranged wife. I appreciate that they have a prejudice against him occupying space on the
planet. But there's no reason that he should not be in the car at the end of the driveway. Maybe
it would be better not to.
TW: Do you find that amusing sir?
·AR: No mam.
TW: Ye<).h, I would hope not.
CG: Now in this matter there is no order for domestic violence treatment. My client was ordered in to
a DV perpetrator's treatment program by the Everett Municipal Court. He has satisfied them.
He has completed the process. Now he has, because he recognizes that he has additional
education to obtain, he has arranged to commence treatment program through Catholic
Community Services and that's corning up on the 141.., of August. From the point of view of
advising him, this court didn't have an order. That court has the power to put him in jail if he
5
doesn't keep that court happy. You keep that court happy. And he's done that. Nciw that that's
accomplished he can turn his attention to whatever other matters he chooses and he chose to find
his way to .Catholic Community Services. As to everything else that you're being told, you're
basically being told the same thing that was in front of the court when the November 1, 2005
order was entered. You're being told that he's taking this domestic violence_·__ counsel was
reading from the computerized report from. Yeah he did. And that pre-dates the 11/01/05 order.
What she had to tell you is certainly no change. The change is that they brought a motion on an
emergency and ex-party basis before Commissioner Stewart. The motion was denied.
Immediately upon denial of the motion, counsel, Mr. Primont, not Ms. Dyer, notifies us that the
visit for the. next day won't happen. And by golly it doesn't. That's when Ms. Llewellyn was
trying to facilitate it. When the court denies an order and I step out intci the hall, I'm not
accustomed to hearing myself or the other side saying basically that they're going to grant
themselves the relief that the court just denied. So when the visit on the 8th didn't occur I
brought the order to show cause contempt. At that time Wendy ... Excuse me, Jennifer Rife had
been served a no contact order. That the grandmother who was doing the visitation exchanges
hadn't been served a no contact order.
TW: But it did exist.
CG: It did exist and it hadn't been served. And I was told she was out of town. The sister and the
brother-in-law were people who had done exchanges before and I don't have any clue why they
were· unavailable. The mother's duty is to deliver it. It's a delivering parent ruk And Mr.
Rife's duty at the other end is to deliver upon the return. He is entitled to 10 hours per week; 2
. th
hours on Monday and Wednesday and 6 hours on Saturday. And since the 7 when
Commissioner Stewart ruled, he has missed three Saturdays and four weekdays. There's an
assertion from the other side that exchanges are impossible. And if you saw what Bridget
'Llewellyn has been doing and the attachments that I have submitted you know we've been trying
to find alternatives, and in fact those letters don't get answered when I send them. Bridget got a
response. Anything is impossible if you want it to be. On the other hand, this child is entitled to
a relationship with her father and we're !Jeing met with a stone wall. And it's a pity that comes
up right in front of trial but I can't ignore it. I have to bring the contempt. I have to do
something to get this process going again. ·
TW: Thank you.
JD: It's true, the __ commissioner in this case was in fact Commissioner Stewart. Why __
Commissioner Stewart and Mr. __ clients. We gave them notice _ _ hearing because it's
important. They were over in District Court the same day getting their asparte(?) restraining
order. They didn't tell anybody that was in court with them that day that that was happening.
They served their client. Now had we known about that before ... they were over next_._ saying
there's an emergency but they weren't telling Commissioner Stewart about that emergency. And
he believed there was no emergency and that this should ... denied it without prejudice .. Said set
it on for a regular hearing. Not. denied flatly. Because there was no emergency. And I mean
they're over in District Court saying emergency, emergency, we need immediate relief. Mr.
Gaul argues that Ms. Holland, the grandmother, wasn't available and it's true. She was out of
town for the weekend and that's why she wasn't served. When she came back into town on
Monday and Wednesday she did the visitations. She didn't know there was a protection order
against her. She went ahead and did the visitations. Mr. Rife showed up, was in the car. He had
just gotten a protection order against her that hadn't been served yet. Yet he came to those
6
v1s1tations. She did those visitations on Monday and Wednesday. He is not frightened. There
was no fright here. But yet they were over in District Court saying there's an emergency here,
Your Honor.
TW: So visits have been cut off since service of the orders?
JD: I'm sorry, what?
T\V: Visits have been cut off since service?
JD: We continued with the visitations when it was only my client, Jennifer, that had been served.
But once Carol Holland got service of her protection order, there was no one to deliver any
longer. There was no in the family. They all stepped back. Brothers, sisters, ·everybody is like
this isn't going to happen. And they continued to come to the visitations. And Mr. Gaul says it's
the __ parent's obligation. It would have been her obligation then to· go violate the order that
Wendy Rife had obtained against her. This child has had that visitation for over eight months.
Grandmothers delivering. It's suddenly three weeks before trial, according to Ms. Llewellyn we
should do the police station, we should do Stacey Rife who is one of the worst offenders in this
whole pot of family. The things she said in the GAL' s report that are contained in the GAL' s
report about my client are sickening to us. Sickening to us. But yet now she's going to be the
supervisor. Or .we're going to go to the police 'station. We're going to go to the jail and we're
going to pick some strangers. We need professional supervision. The entire Rife family is bent
on revenge. These anti-harassment orders got under the cover of secrecy while we're here in
court. We're here. We're standing here. Could have easily gone over and argued them, but no.
We're going to run over there and tell them there's an emergency but. we won't tell
Commissioner Stewart about any emergencies. ·This whole thing is just very, very, very nasty.
And my client can no longer appear at visitations. She's violating order. Carol Holland can no
longer appear at visitations. She's violating order. So there is no one else in this family willing
to do it. We are three weeks from trial. This man is now in his fourth treatment program. If you
look at all the the courtroom and says, and I understand we're not in Municipal Court, but
the order says stay in treatment with Dale Toda and finish treatment with Dale Todd. It doesn't
say go to Catholic Family Services. The GAL's recommendation was just ignore Mr. Rife.
Don't come· to the interviews. Immerse yourself Immerse yourself into treatment with Mr.
Todd and learn something from it. This is about denial, blaming it on Jenn. We are over a year
later, over a year later and he hasn't even finished phase one. This calls for supervised visitation,·
Your Honor. If a case ever called for supervised visitation. We at least need that safety for these
next three weeks so we can get to trial and we can develop all of these issues fully and fairly on
that basis.
· TW: Thank you. Anything else?
CG: Your Honor, I appreciate the fervor of counsel but you want to talk about GAL's orders
ignored ... My client's complied.
TW: Okay. I've heard enough on this. I mean we're three weeks short of trial. There isn't ... there
hasn't been and it's quite frankly an oversight all the way around as far as the court can tell, that
this court did not specifically order that there be ... that M.r. F.ifr be ::: .> DV treatment program.
And I'll remedy that today. Because while it is n0: un~c;u:uoa certainly to adopt the
recommendations of a pending criminal action, clearly •l:" pi..rprise was not to obviate the need
7
for that in any way because of sql!)LJJther court deciding that something was meant that was
clearly not in conformity with the ~ So this court does not accept what has been done .at all.
And they can accept whatever they want. It's an independent court. They can make whatever
rulings they want. This court is not bound by it. So Mr. Rife needs to get in to treatment and
needs to comply ... and that treatment needs to be treatment that compli.es with the wax. .There
have been from the court's perspective if there had been less game playing with that to begin
_with we probably wouldn'.t be here because I can tell you what this looks like to me is somebody
that's got DV issues that hasn't addressed them. Bottom line. There is huge control issues here ..
There is huge blaming the victim here. There is all kinds of issues here. I don't care how you
want to package it. You being in the car. There's been no denial of honking the ·horn, making
faces, creating big disturbance at exchanges. Your child is at .the exchange, sir. That's just
nonsense. At best it's nonsense. That's just ridi.culous. And similarly this whole protection
. order issue ... I mean, if somebody gets a protection order after they':ve gone into someone else's
home uninvited? I just am astonished by that. I have to say, I don't think that the grandma at
this point, Mr. Rife's mother, is in any way capable of being a supervisor in this matter because
she has interjected herse!.f in this way into the proceeding. And if she feels so unsafe by
mom ... I'm not saying that mom's actions .. .I don't know how she .has played into this dynamic
or otherwise. But quite frankly grandma's decided that she can't be around them so she can't be
a supervisor. Period. Because if they can't communicate about this child or if issues come up or
returning the child if there's a problem or anything else then she can't act as a super-Visor.
Period. So whether there's another person that is an appropriate supervisor in this family that
can stay out of the fray and act as a supervisor as opposed to an advocate for the father, I don't
know. I mean, you would be in a better position to know that than the court. Because that's
what the supervisor's role is. Not as an advocate for the father, but as supervisor for the child.
And it's apparently unclear to people here, extended people, what their role is and how to
accomplish that. Whether somebody .. .I don't know. Do you have an idea about that?
BL: These parties are at such odds and the families are at such odds that I don't think there's anybody
on either side who can do that. I just don't think there is. I wasn't suggesting Stacey as a
supervisor. I was just suggesting her as a transportation. But there's bad blood everywhere. I
don't have anybody to recommend. I guess I could do this. I don't know what the court's going
to recommend. And I don't like wearing two hats. But we are only three weeks out from trial. I
tried to be there present so that there was no altercation, but .... I could say that visitation will take
place in my own facility for the next three weeks. Supervised. That takes everybody's family
out of the loop.
JD: We suggested professional supervision.
TW: She has professional supervision. Her office does that.
JD: We won't object to it. We asked for Don Leighton to have another professional in this case that
has other credentials and take a different look at it. Mr. Leighton also I'm sure is a...... ·
BL: I have to say that Don Leighton is in my office building.
JD: That's fine. I mean that would work too. I think .. .I'm actually looking for maybe a male person
that might turn some screw or make something work. Nothing so far has worked. And Mr. Rife
has not followed Ms. Llewellyn's recommendations either. And I'm sort of hoping that ....
8
TW: Well part of the problem is the families have just lost their minds in this case.
BL: And I can tell you that Mr. Leighton is taking big parts of the summer off.
JD: And I can also report that Mr. Leighton is working on a case of mine and he has availability.
TW: Let me hear from Mr. Gaul please.
CG: You Honor, if you 're inclined towards supervision I know Ms. Llewellyn does a good job. I
know that Judy Dier does the job. I know Don Leighton does the job. I have concerns about
Don Leighton's availability because he recently declined a case that I.was looking for help on
but that was as a GAL, not as a supervisor. But I'm perfectly happy if you're inclined to. that,
letting Ms. Llewellyn designate the supervisor and let her continue to designate the terms of the
visitation, which is exactly what the 11/01/05 order does. Visitation supervision designated by
her would be new.
TW: Yeah. I quite frankly ... given that it's three weeks short of trial and that things have just gone
nuclear in this case, I think that it makes sense for everybody's purpose to get things calmed
back down and get it on to a basis where there is some rational thought process that is going
forward here. Whether·... I hesitate also to have Ms. Llewellyn be acting in that capacity, not
because she's not capable or able, but I think that that puts a difficult situation on her. Judy Dier
or Don Leighton are both fine as far as the court is concerned. There's other people that do it as
well.
BL: Judy Dier works for _ __
TW: I appreciate that but it's a separate set of eyes.
BL: Absolutely and I don't... she does 90% of the visitations there.
TW: So I would be less inclined to do it by name than somebody that you can arrange to make it
happen that's available.
BL: I just know that Don ... I just spoke with him ... And Don is, in fact it had occurred to me to ask
Don to do this case. And he's in one week and he's· gone the next week.
TW: Well, and you've got three weeks. So I don't know if he's here or he's not. I have no idea what
his schedule is.
BL: He's not here much this week, he was here last week.
TW: But visits need to recommence upon verification that he is signed up for DV treatment. If that's
already occurred, that verification can occur immediately and visits need to recommence, you
can get supervision set up and it's less quite frankly at this juncture an issue that the court is
necessarily finding that this is a long-term fix to the situation but rather a short-term gap until
trial. Number one. And number two, the court is absolutely finding that because of. the
advocacy ·involvement of your mother, she's no longer an appropriate supervisor. At least at this
juncture. So that being said, with regard to the order to show cause on contempt with regard to
the parenting plan, I think that the mother overstepped by suspending all visits contrary to the
9
direction of the Guardian Ad Litem. I think she was doing that on advice of counsel specifically
and I think that that provides a defense to contempt quite frankly, although questionable I
suppose advice.
CG: \Vould the coun order make-up visits anyway?
TW: What I'm going to do is reserve make-up visits. to the trial court because I don't know if it's
supervised unpaid, I don't know if he can do that between now and then quite frankly.
CG: He can as far as ... he can take care of the finances if we have a supervisor.
TW: Then I don't have a panicular objection to it. Once the letter went out saying that they shall
recommence and they didn't recommence, from that timeframe forward count up the visits that
were missed and there should be make-ups at his expense. But I'm not making a finding of
contempt based on the fact that the v.-1fe was operating on advice of counsel. Okay?
JD: Thank you.
10
Brock Transcription Services, LLC was hired to transcribe from a CD audio tape of a Family Court
hearing of 7/31/06 regarding jennifer Rife, Case #05-3-02755-1. Brock Transcription Services, LLC
has no knowledge of any persons involved in this case. Brock Transcription Services, LLC transcribed
this audio tape to the best of our ability in regards to the sound quality of the CD.
/Jw7f1~ ,b,oc/f_
Anne-Marie Brock, Owner
Brock Transcription Services, LLC
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Community.~,rpi~ce Prevention Services Family Services
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613 - 2nd f,\enuc, Seanle, WA 98104 Phone (206) 826-3044 Fox 1-877-903-0553
Client Progress Report
Program: 0Men's Domestic Violence Intervention Program: 0Weekly Group

0Lesbian Domestic \'iolence Intervention Program: 0Monthly Group
$ v Dads and Their Kids OH.esp~ctful Parenting
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Re: A.1clrec..1Rifu j;5('Pionccr Square
DOB 3- 'J.2- 73 0 Bellevue
Cause No. 05-3-023-SS-/
_ _ IN COMPLIANCE __ REVIEW IN PROGRESS OUT OF COMPLIANCE

0Completed Intake on 0 (See comments below) OD id not complete intake process
0Anended first group 0;1 ____ 0Did not attend as required
0Attcnding \Veekly ,groups 0Did nol pay fees
(1<1.aending Mopthll'.~~P.s OOther - - - - - - - - -
~Other: D \L /..J:i(JS _.. __
_ _ Completed Program Satisfactorily __))ismissed from Program (sec below)
.JL.File Closed (see below)
Dotes attended: s~13 i _ _; _ _ _.l_ _ _i _ _~I_ __
Oates missed: _ _ _.1·_- - - _ _ _ _.!_ _ _ ! _ _~! _ __
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0See Attachments
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- - - -...... - - · -
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll /111 FILED
1 CL 12536584
2007 AUG 20 PH I: 23
2
PAH l. DANIELS
3 s~w~i~'llHYCCOLERK
·WASH.
4
5
6
7
8 ANDREW RIFE,
9 Petitioner,
10 N0.05-3-02755-1
v.
11 LETTER FROM JENNIFER
JENNIFER RIFE (nka Jennifer LeSourd) LESOURD TO BRIDGET
12 Respondent. LLEWELLYN DATED JULY 19,
13 2007
14
15
16
17
18
19
20
21
22
23
24
25
26
27
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29
30
Dt;er & Primon~
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-1528
ORIGINAL \I\~
'•
July 19, 2007
Bridget,
My fall schedule for school is attached to this document. I have Intro to Algebra from
12:00 to 12:50 M-F. I have Anatomy and Physiology I from I :10 to 3:20 M, W & F.
Lastly, I have English Comp from I: I 0 to 3 :30 T & Th. This leaves my evenings free to
be with Lauren (I study at night and at school between classes) and this also allows me
the ability to work part-time as a phlebotomist in the mornings or on days I do not have
Lauren with me. I am currently still working on my resume to get a phlebotomy job and
do not have a job as of yet.
I plan to consistently have my classes in the afternoons only. At least to the best that I
can. In the odd circumstance that something comes up, my Mom or my sister Lisa are
willing to babysit, of course - free of charge.
Lauren has been doing extraordinarily well at her Montessori School. She talks about her
"friends" all the time, and her favorite teacher Toni. She will freely tell you how she
plays outside with her friends, how she takes a nap and what she has to eat for lunch and
snack time. In picking her up or dropping her off, she always wants to take me oµ a
"tour" of her school and point out her favorite toys or show off her friends.
It was hard in the beginning to let Lauren go to daycare/Montessori. She had a!ways ·
spent her time with me or family members. But she has really blossomed from attending
there. I've learned a lot about the Montessori Method in my psych class, and I am
especially glad that I chose the school I did. I truly do not have to worry about her when I
am at school during the day. There has not been one day that I have picked Lauren up
that she has been upset or crying. I will watch her for a few minutes before she notices
me and she is always busy socializing with her friends and playing. Her teachers tell me
that she adapts more and more all the time.
Some of my concerns:
I.) Andy and his Mother's attitude towards Lauren's school. Lauren's teacher has
told me on several occasions Andy will try to question her and some of the other
staff about me and Lauren. When dropping off Lauren one time he holding her
and told the teacher that she would start crying when he left he then asked them if
Lauren cries when her "Mother" leaves her. Now why would he want to know
this? One time when Andy was picking Lauren up he got there and she was
wearing a diaper. He demanded to know why she was in a diaper, insisting that
she was fully p9tty trained. He seemed very agitated by this and upset the
employee he was speaking harshly to. It is my understanding that as a result of
incidents like these the employees, when he tries to ask them anything, are to
direct him to the director of the school. Also, Wendy has made a few uncalled for
remarks that I just ignored. At the doctor's office when we were all there when
Lauren was sick, Wendy said "ugh, that daycare. Those two little boys and their
snotty noses all the time!" I asked Lauren's teacher about the boys (who are
twins) and they have allergies. Toni is a great teacher and keeps all the kids clean.
Then a bit later I made a remark about how Lauren needs to get used to using the
toilet there not just at home or at other family's members houses. Wendy said "I
don't blame Lauren for not using the bathroom there. I wouldn't." Again, this
being said in front of Lauren
2.) Since the supervised visitation has stopped, Lauren has come back home (in the
car) or at home with some really strange and inappropriate things that a 2 year old
just wouldn't say unless someone told them this or they heard it in a conversation.
She has said out of the blue at times, "Mommy you have no friends", "Mommy
you are lazy", "Mommy, you are a bad driver", "Mommy, you are mad at me".
Also I have heard in the car on the way back "I hate Grandma Carol". First of all,
Lauren never calls my Mom Grandma Carol but just "Grandma". Lauren is very
attached to my Mom, as she is my whole family. But lately, right after visitations
or after one of Lauren's overnight visits, Lauren will be very rude and aggressive
towards my Mom if my Mom tries to kiss her or play with her. Again, this is only
for several hours after the visitation with Andy has ended. I religiously kept notes
on this and I have those saved on my computer. I have notes on all the transfers.
Just like today's transfer. My Mom never gets out of the car if we go together to
get Lauren- I do. She's my daughter. It is always Wendy who gets out of the car
while Andy stays inside his truck. Today I took notice while Wendy was talking
to me that Andy was staring with a very nasty lookon his face towards my
Mother. It has been over a month since my Mom has actually gotten out of her car
during the exchanges. In fact she has hardly gone with me to the exchanges in the
last couple of months; I usually go by myself. She just goes as a witness when
she has time. I believe I do need a witness though - and will continue to have my
Mom come with me, or any other family member who can. She doesn't talk to
Andy or even look at him. It is Andy who calls my Mom when Lauren is sick and
when he dislocated her elbow. The previous time Lauren was sick (and I had
cancelled the visit) Wendy and Andy said that they were already on their way to
Lauren's school so they would stop by and see if Lauren was okay. They didn't
just stop by- they accepted my Mom's invitation to come into her home and see
Lauren. Of course Lauren just had a bug as all kids get - but Andy insisted on
taking her to the doctor. At the doctor's office - we all ended up being there
together in a small room. I had to drive from the U-District as I was still at my
externship. Andy was cracking jokes and doing silly things. Like he decided to
taker her underwear off as we were leaving to put a pull-up on her so she
wouldn't have an accident in the car. He held up her underwear for everyone to
see and said "hey look! Skidmarks!" No body laughed. It is not just a "guy thing"
to do that it was crude and embarrassing and way out ofline. If Lauren was older
she would probably have felt humiliated, embarrassed and ashamed. My Mom
was there both times.we had to take Lauren to the doctor during Lauren's
visitations with Andy and everyone seemed to be able to get along. This extreme
resentment (toxic is the word Don Layton used for it) towards my Mom is very
disturbing, unwarranted and frightening to me. Lauren also asks me all the time
(no matter what it is ... a sippy cup she's had for a long time or a small toy I have
picked up for her) "who bought this Mommy?" I i~ll always tell her Mommy did
as it is true and Lauren will always say back "no, Grandma bought it." These are
just very strange things. I can see her "pretending" and trying to say Daddy
bought it, but my Mother??? Lauren and I have also talked about where babies
,
"come from" when she plays in her baby mode. I explained that she came from
Mommy's tummy and that Mommy and Daddy were there when the doctors took
her out of Mommy's tummy. This became a constant conversation as she kept
asking if she could "get back in". I had to laugh and say no, she was too big now!
After a while, she started coming back from Andy and Wendy, and she would
want to talk about "the hospital" again, only this time she won't say"! came from
Mommy's tummy" but instead says "Daddy found me at the hospital!" So now,
whenever she wants to talk about it, she will tell me I'm wrong- that Daddy
found her at the hospital. You'll notice from everything I am writing in this letter
to you - that it really sounds like Andy is trying to alienate Lauren from me
instead of us co-parenting her. I don't talk bad about Andy around Lauren
whatsoever, nor does my family. It would only serve to hurt her; and thus
eventually probably alienate her from me on my own doing if I were to do that.
Kids want to love both their parents and not have to listen to any negativity or bad
words about the other parent. Jan and Marian warned me about not ever doing this
from the very beginning and I have heeded that warning.
3.) There was an incident right before 4th of July where my Dad tried to return a book
to Andy. Andy made a hugely aggressive transfer out of it. I have that
documented extensively as well. If Wendy can sit at a transfer or at the doctor's
office and constantly question me on school, work, Mike and Lisa ... why can't
my Dad return a book to Andy? If Andy truly believed it to not be his book, he
simply could have said no instead of"Maybe it's Jan's'\ "Why don't you get your
balls out of your wife's purse" etc. He just aggressively gets more and more upset
,•
with my parents for no reason. The last time we were in court after his motion
was denied, he walked past my Mom, Amy and myself sitting. on one of the
benches. He walked by and shoved a finger towards my Mom and said "Carol,
you need to get a fucking life". Both Amy and I heard this as well as my Mom.
We just ignored him. Losing a motion makes it okay for him to say such a thing
or act in that way? I can only imagine what is being said to and around Lauren
when she is with him. It's not my parents that have a problem; but it would seem
that Andy has certain unresolved issues ( I think Don Layton suggested he get
individual counseling, which I don't believe he is doing). Also regarding the last
motion which Andy lost he must have been very certain he would win. On a day
that I normally pick her up·from school she was very upset to see me. She said no,
Daddy is picking me up. She remembers every little detail told her at drop-off.
She was crying and very upset. He was certain he was going to win his motion
and that he would be picking her up that evening. That is horrible! His attitude
towards this seems to be selfish and egomaniacal - he put himself first and set
Lauren up to feel insecure. The school told me they heard Andy tell her that he
would be coming for her that day. I have to mention as well - a couple of days
before the motion when I picked Lauren up from Safeway, she said to me "I go
live with Daddy". This surprised me so I told her no, she lives with both Mommy
and Daddy. She said" I go live with Daddy. Daddy said so". This was the
weekend right before the court date June 31 "!July I".
4.) I am also upset because I believe Andy has Lauren sleeping in his bed with him.
Wendy told me this although she said Andy sleeps on the floor next to the bed. I
don't believe this and Lauren blurts out other wise. I told her a couple of weeks
ago when I dropped her off at school that Daddy was going to pick her up and she
was going to sleep at his house. She said "sleep with Daddy in big bed". I said
'
what about your crib Lauren, and she said she sleeps with Daddy in his big bed.
Right when Lauren was born, Andy and I had come to an agreement that we did
not believe in co-sleeping. Especially as children grow older, it becomes a more
disruptive sleep, and sleeping alone helps teach children independence and
confidence. For the whole time Lauren has lived alone with me, she has either
slept in her crib or now, she sleeps in her "big girl bed" a twin size bed that she
has had for a month now and really enjoys. Even ifher crib was still here, she
would still be comfortably sleeping in it. Now in the morning sometimes or
during the night, she will come into my room and want to sleep with me. I take
her back to her bed. This has disrupted the continuity of her sleeping patterns and
is not good for her. Being almost 3 she is too old to be sleeping with Andy in his
bed. It is very inappropriate and disturbing. Recently in trying to get her to_go
back to her bed very early in the morning when she came to my room - she said
no, there are monsters in there. I turned on all the lights and we both looked
around her room. I told Lauren there were no such things as "monsters". She said
Daddy told her there were monsters. This is NOT funny and exactly the
OPPOSITE of what you teach children.
5:) The transfers are starting to upset me. It is a long process when I am trying to get
Lauren back. Andy or Wendy won'tjust simply get her out of the truck and make
it a smooth transition for all; they let Lauren hang out of the sumoof of Andy's
truck, they will let her sit in the front seat and honk the horn, or Andy will put her
in the bed of his truck and let her run up and down while I am standing there
waiting. Don Layton or Judy Dyer never would have let that happen. Sometimes,
I am even left waiting at my car watching Andy run up and do"m with Lauren
inside one of those kids "car grocery carts". Of course because of this, Lauren is
having a great time and does not want to come back to me. When I drop Lauren
off to Andy and Wendy on Sundays, I get Lauren out of the car, kiss her and hand
her to Wendy and say "have fun Lauren, Daddy's here". I'm sure Wendy could
attest to that. Several times Wendy has had to tell Andy that I am waiting and that
Lauren needed to be handed over. One last thing ... Wendy constantly talks about
the time she spends with Lauren and the things they do. Wendy has all but
admitted (inadvertently) that she is ALWAYS around when Andy has visitation.
My concern isn't that I'm worried about Wendy/Lauren's relationship but: Is
Andy willing and or capable of having Lauren for an extended period of time
without others around to take-over or to help?
6.) Lastly, I am concerned over Lauren's bowel movements when she is spending
extended periods of time with Andy. I have noticed for a very long time now that
she will have to have a bowel movement as soon as I get home with her. It is
consistent with her saying her "bottom hurts" and her "tummy hurts". She will
even do this if! take her to a restaurant after the exchange. She has gone
numerous times this way and will ·hide under the table and get very quiet. It is
almost as if she holds it when she is away, to the point where it hurts her. She
doesn't have a problem going at home, in a public place, or even at my parent's

house. I asked Wendy the first time we were all at the doctors office if she had
noticed Lauren having very many bowel movements when she is with them.
Simultaneously Wendy said "no" and Andy said "yes". Andy didn't speak up
again, Wendy did. She said once in a while, small little bowel movements like
maybe she was having trouble or was constipated. In Lauren's almost 3 years -I
have only seen her constipated once and that was when she had the flu when she
was much younger and became dehydrated. Bridget, you have my detailed notes
on Andy's strange (very strange) and peculiar bathroom habits (which Don
Layton even noticed) and it worries me that Lauren is "holding it" for such long
periods of time until she is returned.
So with that said, I think Lauren is doing very well. At least when she is with me. I don't
know about the other side as there is no communication in any which way or form. She
has a wonderful school that she enjoys and is thriving and learning at it. My concerns are
bad mouthing the other parent, family members and parenting skills/techniques and
knowing what is proper and improper. As Lauren gets older some of what I believe is
going on could really damage her and affect her as she is growing. I find it disturbing that
he just finished a 7 week parenting course at Providence Hospital in Everett (I didn't
even know he was going there, we were all told it was a parenting program with Tim
Tackles at Evergreen Manor) and yet all of these issues of parenting/bad mouthing are
still coming up, I am hopeful that the DV Dads and Respectful Parenting programs at
Family Services will help him with these issues. Despite coming from a broken home - I
want her to have every opportunity to grow and love all of her family members without
having to have any hang-ups or psychological distress.
Please let me know if you have any questions. Also, if necessary, I'm sure the director of
the Montessori would give you a tour of Lauren's school with the appropriate
authorization.
,.
PILED
2007 AUG 22 Ml II: ~S
1
PAM L. Dt-.;·iiEI S
, COUNTY CLER~
oNOHOMISH co. WA SH.
2
3
I1\\\\\11\1\11\\I11\1\ 1\\\1 \Ill\ \\\\I 1\1\11\\\1 \\\\\ \\\\ \\\\
4 CL 12528106
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
11 Respondent.
12 1, ANDREW RIFE, declare under penalty of perjury of the laws of the state of
13
14
1 am the petitioner in this matter. I make this declaration to reply to the
15 materials submitted by my former wife, Jennifer Lesourd.
16 2. PARENTING
17 I do not disparrage Ms. Lesourd. She is no longer a sufficient part of my life

to merit more than occasional references at all, and the ones that do occur are not
18 negative. Lauren and I spend time finger and brush painting. we use glitter glue.
Inside my home we spend time building forts with quilts and blankets. She has a
19 small kid's tent and sleeping bag. She and I go to the woodland Park zoo, to the
Stanwood fair, to the Museum of Flight, many parks and the Children's Museum. At
20 home we play soccer in the backyard, run through the sprinkler and play in her
kiddy pool. She gardens with her own tools. She has a kite that she got into the air
21 before my mother and I could. She enjoys helping her father with minor chores.
She enjoys educational activities, such as flash cards and has begun the
22 memorization of letters and numbers.
23 Lauren does not sleep in my bed. When overnights first commenced she
asked to spend the night in my bed. I allowed her to do this, but I slept elsewhere.
24 Since then, she has been sleeping in her own bed. Again, if Jennifer LeSourd would
communicate she might avoid some histrionics.
25
26
CARLl.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 1 ORIGINAL Everett WA 98201
425 259·4147 FAX 259 7081
1 3. JENNIFER LESOURD ASSUMES NEGATIVES
2 MY former wife colors everything she knows or suspects about me in the most
negative possible light. She ignores anything possibly favorable. For example, she
3 complains that I have not completed a domestic violence perpetrator's treatment
program. She ignores that I have one meeting left. I complete at the beginning of
4 September. She complains that I have not "managed" to complete a course, but
does not discuss that I have attended more than twice the requisite number of
5 classes. She ignores that my reports are consistently positive 1 • Ms. Llewellyn has
reported to the court the reasons Evergreen Manor declines to communicate about
6 me with Ms. LeSourd and Ms. Dyer. My former wife proceeds to write about how
Evergreen Manor is not complying with the Washington Administrative Code, but
7 then she never quotes the statute or rule she thinks is being violated. When I
commenced there, I signed releases authorizing communication with Jennifer
8 Lesourd and Ms. Dyer, among others. But I have not asked them to communicate
or refrain from communication with Ms. Lesourd and Ms. Dyer. In fact, last April I did
9 request that Evergreen Manor communicate directly with Family services.
Evergreen Manor declined. I do not make decisions for Evergreen Manor.
10
MY former wife colors what she knows or suspects of Bridget Llewellyn in the
11 most negative possible light. Bridget Llewellyn, Judy Dyer and Don Layton all concur
that I am an excellent father and have excellent parenting skills. They reached their
12 conclusions based upon first hand observations. She hired an MSW to review Bridget
Llewellyn's file. Interestingly, that MSW did not list that she had spoken to Ms.
13 Llewellyn.
14 In August, knowing that my time with Evergreen Manor is nearly completed,
I called Mark Adams of Family services for the specific purpose of again enrolling in
15 that program. Mr. Adams has not returned my calls. Perhaps vacations and the like
have delayed him. 1 intend to resume contact with him and enroll in the DV Dads
16 and Respectful Parenting classes.
17 MY former wife and I have no direct communication. My former wife reaches
·udgments that my behavior has been negative and destructive. She refers to
18 "co parenting" but so long as she declines to communicate constructively we will just
have more of the same.
19
4. VERBIAGE
20
Ms. LeSourd recounts statements she attributes to our daughter. · 1 could
21 respond in kind, but I decline to do so. If I recounted all the things that our
daughter says then drew conclusions from those statements, all I would accomplish
22 is to assure that our daughter bears the emotional burden of the parents'
disagreements. Think how petty and ridiculous this could get! Most such comments
23 are the sorts of things that should be allowed to pass off and be forgotten. If there
is a specific concern, it could be brought up with Bridget Llewellyn or Don Layton.
24
25 1
I attach a copy of the August 13, 2007 report.
26
CARL]. GAUL
27
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
1 If one of them files a declaration about what Lauren says, I will deal with the
statements at that time.
2
One conclusion 1can draw is that if Ms. Lesourd would communicate with me
3 about our daughter, even by email, we might well be able to get on the same page
from time to time. Ms. LeSourd might be less concerned about what I say if she had
4 some idea what I actually do say. At the exchanges of our daughter I generally stay
in my vehicle and have no interaction with her. The exceptions have been when
5 Lauren and I happened to get there first and we might be playing with a grocery
cart or some similar activity. My decision to minimize direct communication at the
6 exchange was encouraged by Ms. Llewellyn and Mr. Layton to avoid argumentation
or conflict at the exchanges.
7
At the Montessori 1have a friendly relationship with the staff. When Lauren
8 was new to that school I was told more than once about the difference between
Lauren's responses to each of her parents. When the Montessori staff wants to talk
9 to me about my daughter I am not going to cut off the conversation. It is a pity that
Ms. Lesourd wants to cast these conversations in a negative light.
10
5. CONFLICT
11
Ms. LeSourd and her parents have come out of court angry. Her parents have
12 both initiated discussions with me using "salty" language, to which I have responded
in kind. It may not speak well of any of the participants in these dust-ups, but it
13 hardly constitutes some kind of abuse. The last time we were at court Ms. LeSourd
herself had some angry words for me which she delivered in an angry voice and her
14 mother made a point of walking directly up to me, so her face was within just
several inches of mine to be sure that I could see her angry expression.
15
The conflict has extended to the exchanges. On July 3 I arrived at the
16 exchange point. Jennifer LeSourd was present but stayed in her car, which I thought
unusual. soon her parents arrived in his truck. Jennifer Lesourd's father, Steve
17 Holland, did approached me with a book in his hand, loudly saying something about
it being something of mine they found around the house. At a glance I could see
18 that it was a book glorifying Adolph Hitler and the Third Reich. It was not mine. I
have never had interest in such books. In an exchange of unpleasantries I informed
19 him of that. That day 1had had outpatient surgery to excise two abcesses low on my
pine. I had no desire to assume a fighting stance, but I can assure the court that I
20 had no ability to do so at the time. I had a very sore posterior.
21 6. DR. VISIT
22 There have been two occasions when I have taken Lauren to a doctor, June
14 and June 28. On both occasions there were adults who were not comfortable
23 together all crowded into the examination room. There was some nervous humor
all round. None of it was inappropriate. on the second occasion I did change
24 Lauren's underwear for a new pull-up. There was no statement about "skid marks."
1made no such statement and neither did anyone else. It is simple fiction.
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 7. CHILD CARE COSTS
2 I have paid my share of child care costs. our parenting plan requires me to
contribute to work related child care costs. My former wife enrolled in an
3 educational program and asked me to contribute to child care costs, partly to her
mother and partly to Clearview Montessori. Because this was educational, not work,
4 related child care, 1did not think this was covered by the order. To resolve the issue
we arbitrated it before commissioner Slusher. He came out in the middle. He
5 directed payment for the amount attributed to Ms. Lesourd's mother, and made
findings that would require me to pay for other months if she was actually
6 participating in her educational program. Ms. Lesourd has not provided any
documentation that she incurred any work or educational related child care cost in
7 the months of April or May. In fact, her arbitration materials were clear that there
were no such costs in those months. Accordingly, there is no payment for me to
8 make.
9 MY former wife does not want to resolve the issue: She wants to complain.
She claims something !unstated> is owing to her and provides no documentation or
10 information from which a person could agree or disagree with her. If I owe, I will
pay my share. But until she communicates about the costs incurred so I can agree
11 or disagree, there is simply no payment to make.
12 As to the Montessori costs in June, July and August, I have paid my share
directly to the Montessori. She has nothing to complain about.
13
8. BAR ASSOCIATION ETHICAL COMPLAINTS
14
1 did file a grievance against Ms. over and also against Mr. Primont. The
15 grievances are pending before a review committee at the Bar. To my knowledge
they are not dismissed.
16
ELC 2.12 2 provides that Ms. over may not bring any action against me for
17 damages based upon filing a grievance with the Bar Association. Ms. over attempts
to avoid this rule by having her client make the same identical request in the divorce
18 file. It is not a very subtle ruse.
19 I understand a fair contest. I also understand the necessity of following a

recognized standard of conduct. In the course of the divorce I came to the opinion
20 that Ms. Dyer was behaving unfairly. I Googled the subject and found my way to the
standards of conduct, the Rules of Professional Conduct. Reading them
21 strengthened my opinion. I believed Ms. Dyer has violated RPC 1.7, 3.1, 3.2, 3.3, 3.4,
22 1 - - - - - - - - - - -
2
23 ELC 2.12(b): Communications to the Association, Board of Governors,
Disciplinary Board, review committee, hearing officer or panel, disciplinary counsel,
24 adjunct investigative counsel, Association staff, or any other individual acting under
authority of these rules, are absolutely privileged, and no lawsuit predicated thereon
25 may be instituted against any grievant, witness, or other person providing information.
(Emphasis added)
26
CARL]. GAUL
Attorney at Law
1604 Hewitt Ave.
Page 4 425 259-4147 FAX 259 7081
1 3.5, 8.1 and 8.4. I held my peace until after the divorce was settled on November 7,
2006. With the divorce resolved, I sought counsel on the RPC issues, ultimately
2 retaining Leland G. Ripley, formerly Chief Disciplinary counsel for the Washington
state Bar Association. I never did hire an investigator or similar person. I did review
3 and obtain copies of public records.
4 1 am not providing the factual details of Ms. Dyer's misconduct because I
doubt that they have much relevance to the parenting issues in this case. If the
5 court wants to investigate the contents of the WSBA grievance against Ms. Dyer, that
is fine with me. Ms. Dyer and 1can file copies of every single document in that file.
6
7
on August 21, 2007
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 5 425 259-4147 FAX 259 7081
~.' ..
. ,,

PO Box 12598
Everett, WA 98206
425-258-2407
425-339-2601
DATE: 2007-08-13
TO: ATTORNEY OF RECORD

CARL GAUL
1602 Hewitt Avenue
Everett, WA 98201

2416 5th Street
Everett, WA 98201

Report Period: 2007-08-01 to 2007-08-31
Treatment Activity:

2007-08-06 01:30 Present DV Monthly Monitoring - Present
Urinalysis Results:
Date Result Drug
None to report

O Verified
Patient is:
[X) in compliance
[ ) not in compliance
Financial Compliance: (X) Yes No
Compliance Criteria Met: (X) Yes No
(XJ Continue
( ) Completed
( ) Discharged
Comment:
THIS CORRESPONDENCE IS TO ADVISE YOU OF THE CONTINUED PROGRESS OF THIS CLIENT IN MRT-DV
TREATMENT SINCE LAST REPORTING. HE MAINTAINS GOOD GROUP ATTENDANCE, ATTITUDE AND
PARTICIPATION. PROGNOSIS REMAINS POSITIVE THIS DATE.
Probation/Court assistance requested: (X] Yes ( ] No
2007-08-13
Tim Tackels, CDP
,,

L
1 F\LED
') 2001 ~UG 28 PH 3: 59
P!l.Vi 1... [J/.,'/<l\ELS
I I lllllll llllll Ill lllll lllll 111111111111111111111111111111111 courn 'I cc6E~11}.sH.
SNOHOMISH ·
CL 12530086

7
8
9 Petitioner
and CALENDAR NOTE
10 (CDMMISSIONER S
1
DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: September 11, 2007
CAL EN DAR- (Except matters relating to
Nature of Hearing:
Department B or C, As Assigned Motions: motion re
18
19 matter, please indicate Court Commissioner
for the matter to be argued. Failure to notify the Court of a conti ance or strike may result in sanctions
21 and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for ri I settings. SC 2.1 40(b).
22 Dated: August 28, 2007
23
24
25
26
27
28
CARLJ.GAUL
CALENDAR NOTE Attorney at Law
(CDMMISSIDNER S
1
c;;:zr 6 I 4/lf
~ 302 Bank of America Building
Everett WA 98201
(425) 259-4147 Fax 259-7081
.. '
FILt:U
-, I I ,. " ~ ...... --,
'
SUPERIOR COURT OF
WASHINGTON
FOR SNOHOMISH COUNTY,

COMMISSIONER: JACALYN D. BRUDVIK
vs. CLERK: HOLLY M. BEAL
JENNIFER RAE RIFE DATE: 9/11/07@ 9:00 A.M.
THIS MATTER CAME ON FOR: MOTION REGARDING RESIDENTIAL SCHEDULE (#172)

CONTINUl!D DATE/TIME/CALENDAR AND CONTINUANCE CODE:
ACTION:
PETITIONER APPEARED: YES COUNSEL: CARL J . GAUL
GUARDIAN AD LITEM APPEARED: YES, BRIDGETT LLEWELLYN
DOCUMENTS FILED:
THE COURT IS NOT WILLING TO ESTABLISH ANY PARENTING PLAN WITHOUT THE
PREVIOUS FACTORS THAT WERE INSTITUTED AT THE TIME OF THE CONCLUSION OF THE
TRIAL. THE COURT IS WILLING TO EXPAND SOME ON THE CURRENT EXISTING SCHEDULE.
THE RESPONDENT SHALL ADDITIONAL TIME ON TUESDAYS AND THURSDAYS FROM AFTER SCHOOL
UNTIL 7:00 P.M. AND ALTERNATING SATURDAYS FROM 10:00 A.M. TO RETURNING THE CHILD
TO DAYCARE ON MONDAY. THERE SHALL BE NO JOINT DECISION MAKING AT THIS TIME.
THE RESPONDENT IS ORDERED TO ENROLL, ATTEND AND COMPLETE ALL EXISTING
FINAL TRIAL ORDERS REGARDING DOMESTIC VIOLENCE TREATMENT AND/OR PROGRAMS.
1 PATERNITY MINUTE ENTRY

. • I""
FILED
2001 SEP I I AM IQ: ~ I
PAM L. DA.NIELS
COUMT Y CLERK
SHOHOMISH CO. I'/ A SH.
111111111111111111111111111111111111111111111111111111111111
CL 12448426

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9\c,,,__, ~1,,,\ur'(.... c.._hc..-i1f\ S\.-,c,_\..\ ~ ~11r:-,...,.,,_..\- ~ %--\~-
DONE IN OPEN COURT this d a t e : - - - - - - - - - -
Presented By:
6101 page1of2 10844
I
Page# _ _ __
Case Name ----'~.__,_.\.-'---'-L:::__ _ _ _ _ _ __ Case No. C§ - ?:> -b ~3-'SS - \
--\\..-..__ h \\.o.v.. ,_Q l) -)\:-..__ "-'1.W rt.~'-J)~,.,~.._J,_ 5<.h...Jl.A._:

..(:""c....~ r ~ -\ '"'-t... ~
DONE IN OPEN COURT this date: _ _ _ _q-=-.,../_1_/.,_)_()_I_,__ __

I I
.---:-,';\
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---=----=-.:=....-A-J~.,J,....L_______
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FILED
• ... • t ,... ,,..
, I . , .; , l:
1 I>;'·: L. D;'\: 1:ELS

c ..1.1:~1 f CLLk:i..
2 -~);'{il·:Ori!Si·~ CV. l~· .•. 1.:i,ll
4 Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
CL 12290877
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 certificate of completion of Domestic
Jennifer Rae Rife Violence Program
11 f--~~~~~~~~--=-:R~es~p~o~n~d~e~n~t~.L-~~~~~~~~~~~~~
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
@@ Everett WA 98201
Page 1 425 259-4147 FP!I. 259 7081
...=
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Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll FILED
CL12447955 2001 SEP 20 PM 3: 02
PAH L. DAf!IELS
COUNTY CLERK
SNOHOMISH CO. WASH

RIFE No. 05-3-02755-1

Plain tiff/Petitioner
vs. COVERSHEET
RIFE
ATTACHED HERETO IS:

Report from Evergreen Manor
PO Box 12598
Everett, WA 98206
425-258-2407
425-339-2601
DATE' 2007-09-17
Everett, WA 98201
RE, Andrew S. RIFE (2007-03-12)

2416 5th Street
Everett, WA 98201

Report Period' 2007-08-13 to 2007-09-30
Treatment Activity:

2007-08-13 oo,oo Status Report
2007-09-10 01,30 Present DV Monthly Monitoring - Present
Urinalysis Results:
Date Result Drug
None to report

O Verified
Patient is:
[X] in compliance
[ J Continue
[X] Completed
[ ] Discharged
Comment:
BE ADVISED OF THE SUCCESSFUL COMPLETION OF THE ONE YEAR TREATMENT PROGRAM OF DOMESTIC
VIOLENCE. MR. RIFE COMPLETED HIS MONTHLY MONITORING GROUPS AT THIS FACILITY 9/10/07. FILE
CLOSED SUCCESSFULLY THIS DATE. PROGNOSIS IS POSITIVE.
Probation/Court assistance requested: [ J Yes [X] No
---- 2'l' ~-----. 2007-09-17

•
·-·
"!'.J,.d' ·-'.
• Tim Tackels, CDP

I
t
'-
FILED
2007 SEP 21 PM 4: 40
PAM L. D1~;·;1ELS
1 COUNTY CLER!<
SNOHOHISH CO. I'/ ASH.
2
3
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
4' CL 12521824
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
11 Respondent.
that the following is true and correct.
I am the former husband of Jennifer LeSourd, and the father of Lauren Rife, who is the
subject of the parenting plan in this matter. I make this declaration to support my motion
for reconsideration.
RESERVE UNDECIDED ISSUES
I am only asking the court to continue to reserve issues that were previously reserved which
were not addressed in the pleadings or the rulings on September 11, 2007. Those issues
were reserved pending case manager's recommendation under the November 7, 2006
parenting plan. The specific language of the September 11, 2007 order might appear to
have decided those issues even though they were not before the court for decision.
The court ruled on September 11, 2007 concerning residential schedule. It established a
residential schedule of Tuesday and Thursday afternoons and alternating weekends
(Saturday 10 a.m. through Monday morning return at Montessori). The court did not rule
on residential time at holidays (especially Thanksgiving and Christmas-New year time), did
not rule upon summer residential schedule, and did not rule upon vacations. Under the
November 7, 2007 these issues are reserved for Ms. Llewellyn's later recommendation. The
court should explicitly continue those items as being reserved for later agreement or
decision following Ms. Llewellyn's recommendation.
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page 1 425 259-4147 FAX 259 7081
-...
•
1 3. LEAVE THE REST ALONE
2 I want to be sure the court understands what I am not requesting. The court made a
specific ruling for the residential schedule. The court ruled that it would make future
3 changes and Ms. Llewellyn would not have authority to make such changes. The court
declined my invitation to change decision making and dispute resolution. I am not asking
4 the court to revisit those issues. I am only asking the court to explicitly reserve the issues
which were not mentioned in argument of counsel and not mentioned in the court's ruling.
s The language of the order is sufficiently broad to create an erroneous impression in the
event of future hearings.
6
Paragraphs 3.2 through 3.6 should be explicitly not changed by the court's order.
7
8
9 on September 21, 2007 ANDREW RIFE
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
I.
F!Lfo
2007S£p 21
1 P!1 4: 40
PAfiL 0
SNoCOLJNr y /.. f :f~L s
HOrffSH /LfRK
: Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll l l llll O. WASH.
CL 12521823
4
5
6
8
9 Petitioner
and CALENDAR NOTE
10 (COMMISSIDNER S
1
DOMESTIC
11 Respondent
13
14 FAMILY LAW / DOMESTIC Date: October 5, 2007

CAL EN DAR- (Except matters relating to Without Oral Argument
15 trial dates, continuances, and revisions)
Daily at 9 a.m.
16 Court Commissioner Nature of Hearing:
Commissioner Brudvik
17 Motions: motion for reconsideration
18
19
for the matter to be argued. Failure to notify the Court of a conti a ce or strike may result in sanctions
21
4----
and/or terms. SCLCR 7(b)(2)(E). This form cannot be used for rial Jettings. S .1 40(b).
22 Dated: September 21, 2007 / - -
23
24
25
26
27
~~
28
CALENDAR NOTE
ICOMMISSIONER S
1
CARL J. GAUL
Attorney at Law
302 Bank or America Buildin
Everett WA 98201
(425) 259-4147 Fax 259-7081
l
I. Relief Requested
16
17 Andrew Rife moves this Court to enter an Order

18 (1) confirming the schedule established in the September 11, 2007 as
being the residential schedule under paragraph 3.1 of the
19
parenting plan of November 7, 2007, and
20 (2) reserving the residential schedule under paragraphs 3.2 through
21 3.6 for later agreement or ruling of the court.
22
II. Statement of Grounds
23
24 The court's order of September 11, 2007 established a regular schedule

of father-daughter contact during ordinary weeks. It also stated that it would
25
26 CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
PAGE 1 425 259-4147 FAX 259 7081
l
I
1 be the final order adjusting schedule under the November 7, 2006 parenting
plan. However, there remain other specific paragraphs relating to residential
2
schedule which remain for decision.
3
4 III. Evidence Relied Upon

5
Declaration of Andrew Rife submitted herewith.
6 Parenting Plan of November 7, 2006
7 Order of September 11, 2007
: Dated:°//~( ( () 7
10 I Attorney for AND
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
MCJTICJN Everett WA 98201
PAGE 2 425 259-4147 FAX 259 7081
. .
..
FILED
2007 OCT -5 PM /O: zz
I\\\\\~~~\~~~\~\\\\\\~\~\~~\\\\~~\\~~~
1
2 PCAOM L. DAN/ELS
UNTY CLERK
CL 12502168 SNOHOMISH CO. IVASH
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Lesourd, fka Rife
11 Respondent.
12 I DECLARE:

14 2. I served Jan Dyer, attorney for Jennifer LeSourd with the following
documents:
15
Calendar Note
16 Motion
Declaration of Andrew Rife
17
3. The date, time and place of service were !if by mail refer to Paragraph 4
18 belOW):
19 Date: September 21, 2007 Time: 4:38 p.m.

20 Address: Jan Dyer
Attorney at Law
21 503 - 12th Ave. E
Seattle, WA 98102-1528
22
23
4 service was made pursuant to Civil Rule 4!dl:
24 ·
25
CARLl.GAUL
26
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
1
Page 1 425 259-4147 FAX 259 7081
!'10
•
i
1 by faxed delivery to the person named in paragraph 2 above, attorney

for Jennifer Lesourd.
2
s. Other:
3
5
I declare under penalty of perjury under the laws of the state of Washington that
6 the foregoing is true and correct.
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CARLJ.GAUL
Attorney at Law
26
27 1604 Hewitt Ave.
Page 2 425 259·4147 FAX 259 7081
Superior Court of the State ofWashitlJtJR
. 07 OCT -""S PM 3: 03
0
\\\\\\\\ \\\\\\\\\I\\\\\\\\\\\\\\\\\\\ \\\Ill\\\\ 1111\ \Ill 1\\1
CL 11680736
f :N~H::~~o:~~u:::~ty to~~ ~ ~J~~~
M/S#502
p T JUDGE
SNOHOMISH <RlbMAS!~.~NNE
3000 Rockefeller Avenue
JAMES H. ALLENDOERFER
Everett, WA 98201-4060 COURT COMMISSIONERS
LARRY E. MC KEEMAN
RONALD L. CASTLEBERRY (425)388-3421 (425)388-3536 ARDEN J, BEDLE
THOMAS J. WYNNE LESTER H. STEWART
ANITA L. FARRIS JACALYN D. BRUDVIK
LINDA C. KRESE TRACY G. WAGGONER
GEORGE N. BOWDEN BRUCE I. WEISS
ELLEN J. FAIR
KENNETH L. COWSERT
MICHAEL T. DOWNES COURT ADMINISTRATOR
ERIC Z. LUCAS SUPERIOR AND
DAVID A. KURTZ JUVENILE COURT
BOB A. TERWILLIGER
October 5, 2007
Carl Gaul
302 Bank of America Bldg. Reviewed by commissioner.
Everett, WA 98201 Please tlle.
Bridget Llewellyn
3114 Oakes Avenue
Everett, WA 98201
Jan Dyer
503 Twelfth Avenue E.
Seattle, WA 98102
Re: In Re the Marriage of And~ew-RifeandJennif!'lr Rife kna LeSourd

Snohomish County Caus'e No. 05-3-02755-1~ .
"--~ I
Dear Counsels and Guardian Ad Litem:
The Motion for Reconsideration filed September 21, 2007, did not have pleadings with
regard to service on the opposing party or Guardian Ad Litem. The Court makes no
decision on the Motion at this time.
Sincerely,
acalyn D. Brudvik
Court Commissioner
FILED
=========u/OCT-5 Fn 2:20
SUPERIOR COURT OF PAHL. Dt.N/ELS
COUNTY CLERK
Illlllll l l l Ill lllll lllll lllll l/11111111111111111111111111 WASHINGTON SNOHOHISH CO. ri .•.SH.
CL 12131610 FOR SNOHOMISH COUNTY

AND CLERK: HOLLY M. BEAL
JENNIFER RAE RIFE DATE: 10/05/07@ 9:00 A.M.
THIS MATTER CAME ON FOR: MOTION FOR RECONSIDERATION (#187)

ACTION:
PETITIONER APPEARED: NO COUNSEL: NOT PRESENT
DOCUMENTS FILED:
ORDERS ENTERED: **NO ORDER ENTERED**
THIS MATTER WAS TAKEN UNDER ADVISEMENT WITHOUT ORAL ARGUMENT.

FILED
1
ZOOl NOV -5 AM IQ: 03
PAM L. DAi~IELS
2 COUNTY CLERK
SNOHOMISH CO.WASH.
3
4
5
6
7
IN THE SUPERlOR COURT OF THE STATE OF WASHINGTON
9
10
11 ANDREW S. RlFE,
12 NO. 05-3-02755-I
Petitioner,
13 and
NOTICE OF ABSENCE OF
14 JENNIFER R. RlFE, COUNSEL
15 Respondent,
16
17
18 TO: CLERK OF COURT
NOTO: All parties and counsel of record.
19
20
PLEASE TAKE NOTICE that Jan M. Dyer will be out of the State or otherwise unavailable
21
from November 19, 2007 through November 29, 2007 and December 2I, 2007 through January 2,
22
23 2008. It is requested that motions and other court hearings not be scheduled to occur during the
24 ime of this absence and that motions and other hearings be scheduled so there is sufficient time to
25 repare for them following the end of the absence. There is no other attorney available with
26 sufficient factual knowledge of this case to respond to any substantive request for relief during my
27
absence.
28
Dated the 2nd of November , 2007
29
30
Dyer & Primont
503 Twelfth Ave.e-(
Seattle, WA 98102
(206) 343-1528
NOTICE OF ABSENCE
!13
FILED
1 7007 DEC I 0 AM 9: 59
2 PAM L. DANIELS
CCUHTY CLERK
SHOHOHISH CO. WASH
3
4
Illlllll llllllCLIlllllll12994656
lllll lllll lllll lllll lllll lllll llll llll
7
9
In re:
11 and
12 Jennifer Rae Lesourd, fka Rife
Respondent.
13

AND TO: Jan Dyer, attorney for Jennifer Rae Lesourd
15 AND TO: Bridget Llewellyn, case Manager
16 PLEASE TAKE NOTICE that Carl J. Gaul, attorney for Andrew Scott Rife, will be
unavailable from December 12, 2007 through January 3, 2008 inclusive. It is
17 requested that motions, depositions and other court hearings not be scheduled to
occur during the time of my absence, and that motions and other hearings be
18 scheduled so that there is sufficient time to prepare for them following the end of
the absence. There is no other attorney available · sufficient factual knowledge
19 of this case to respond to any substantive requ t or relief uri the period of
unavailability.
20
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 98201
1 I~ILFD
k,
2
2008 JAN - 7 PM 2: 44
3 I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\11111 \\\\\Ill\\ 11\11 \\\\ \\\\
4
CL 12730320 SDllYA_J. KRASKI
COUN I y CLERK
SHOrJOHISH CO. WASH.
5
6
7
9
10
ANDREW S. RIFE,
12 NO. 05-3-02755-1
Petitioner,
13
And
15 JENNIFER R. RIFE, COUNSEL
16
Respondent,
17
18
0: CLERK OF COURT
19 OTO: All parties and counsel of record.
20
22 om January 26, 2008 to February 6, 2008. It is requested that motions and other court hearings
23 ot be scheduled to occur during the time of this absence and that motions and other hearings be
24
cheduled so there is sufficient time to prepare for them following the end of the absence. There is
25
o other attorney available with sufficient factual knowledge of this case to respond to any
26
ubstantive request for relief during my absence.
27
Dated this 2nd of January 2008.
28
29
30
JANM. Dyer & Primont
503 Twelfth Ave. E
Seattle, WA 98102
(206) 343-152~
OTICE OF ABSENCE \~
1 FILED
2
·3
111~~1100~111111111~00
CL16234458
2013 NOY 11+ AH IQ: 50
SOHYA KRASKI
4 COUNTY CLERK
SNOHOMISH CO. WASH
5
IN THE SUPERIOR COURT
6 OF THE STATE OF WASHINGTGN
7
8
In re the matter of: NO. 05-3-02755-'l
9
ANDREW RIFE,
10 NOTICE OF INTENT TO WITHDRAW
Petitioner,
11
and
12
JENNIFER RIFE,
13
Respondent.
14
15
TO: THE CLERK OF THE C:OURT; and
16 TO: JENNIFER RIFE; and
TO: CARL GAUL, attorney for Petitioner
17
PLEASE.TAKE NOTICE i:HAT the undersigned intends to withdraw as Attorney
18
19 of Record for the above-named Jennifer Rife, as of the 18th day of October 2013. Said date is.at
20 least ten (10) days after.service oftliis notice. This withdrawal shall be effective without order of
21 the court unless an.objection to the withdrawal.is served.up<iil. Said withdrawing attorney prior to
22
the date set forth in this.notice.
23
There is no scheduled triii.l date. The last known address of Jennifer Rife, the above-
24
named, is 14200 69th Dr. SE #A-5; Snohomish, Washington 98296.
25
DATED this gm day of October 2013,
26
27
28
29
30 /A?fM. />7z~
/IUT""'41_/tAA716. z
.~ wA:mtu:
IZNJ.H.'-V.t:r
NOTICE OF WITHDRAWAL 1
F!LEu
2 2013 NOV 18 AH IQ: 31
3 SONYA KRASKI
COUNTY CLERK
4
SNOHOMISH CO. WASH
6
11m~woo1mm1~~~~
CL16379378
7

10 In re: No. 05-3-02755-1
II ANDREW RIFE, Response to Petition for
Petitioner, Modification/Adjustment of Custody
12
and Decree/Parenting Plan/Residential
13 Schedule
JENNIFER MEHADDI (fka Jennifer Rife),
14
Res ndent.
15
To: Andrew Rife
16
I. Response
17
1.1 Admissions and Denials
18
The allegations of the petition in this matter are admitted or denied as follows (check only one fo
19 each paragraph):
20 Paragraph ofthc Petition
21
I. I Admitted
22 1.2 Admitted
1.3 Admitted
23 2.1 Admitted
2.2 Denied
24 2.3 Denied
2.4 Admitted
25 2.5 Admitted
2.6 Lacks Information
26
2.7 Admitted
27 2.8 Denied
28
Response to Petition for Modification VERONICA FREITAS
Page I of2 V. FREITAS LAW, PLLC.
210 Summit Avenue East
ORIGINP1L Seattle, Washington 98102

(206) 328-7362
v@vfreitaslaw.com
2.9 Denied
2. I 0 Lacks information
2 2.11 Denied
3
Each allegation of the petition that is denied, is denied for the following reasons:
4
2.2 Adequate cause should not be found to move forward with Mr. Rife's petition to modify.
5
2.3 The court should not enter a new order of support based on Mr. Rife's proposals and
6 allegations.
7 2.8 There has been no substantial change in circumstances. The child has not been integrated into
Mr. Rifc's home and modifying the parenting plan in the manner that Mr. Rife is requesting would
8
be detrimental to the child's wellbeing. The environment in Ms. Mehaddi's home is not detrimental
9 to the child.
10 2.11 There are no substantial change in circumstances. Mr. Rife's petition should be denied.
II 1.2 Notice of Further Proceedings

12 Notice of all further proceedings in this matter should be sent to the address below
13
1.3 Other
14
N/a.
15 JI. Requests
16
2.1 Request for Dismissal
17
The nonrcquesting party requests that the petition be dismissed.
18
2.2 Request for Modification or Adjustment
19
Does not apply.
20
21 2.3 Protection Order
22 Does not apply.
23 Dated:_\~\_· _,_o_-_,_s_____
Veron ca Freitas, WSBA# 19405
24
Attorney for Jennifer Mehaddi
25
26
27
28
Response to Petition for Modification VERONICA FREITAS
l'oge 2 of2 V. FREITAS LAW, PLLC.
2IO Summit Avenue East
Seattle, Washington 98l02
(206) 328-7362
v@vfreitaslaw.com
FILED
2 2013 NOV 18 PM 3: 03
3 SONYA KRASKI
COUNTY CLERK
4 SNOHOMISH CO WASH
5

County of Snohomish
8 In re:
9
ANDREW RIFE, No. 05-3-02755-1
10 Petitioner, Notice of Absence
and
II
JENNIFER MEHADDI (fka Jennifer Rife),
12
Res ondent.
13 TO: CLERK OF COURT
AND TO: All parties and counsel of record.
14 PLEASE TAKE NOTICE that VERONICA FREITAS will be out of the State or
otherwise unavailable on the following dates:
15
16 December 20, 2013 through January 6, 2014
17 June 30, 2014 through July 4, 2014
18
August 22, 2014 through September 8, 2014
It is requested that motions and other court hearings not be scheduled to occur during the
19
time ofthis absence and that motions and other hearings be scheduled so there is sufficient time
20 to prepare for them following the end of the absence. There is no other attorney available with
sufficient factual knowledge of this case to respond to any substantive request for relief during
21 my absence.
22
DATED November 7, 2013.
23
24 Respectfully submitted,
25
26
VERONICA FREITAS, WSBA #19405
27
28
VERONICA FREITAS
V. FREITAS LAW, PLLC.
Notice of Absence 2IO Summit Avenue East
Seattle, Washington 98I02
Poge I of I (206) 328-7362
v@vfreitaslaw.com
1
2 '~ ' .

COUNTY OF SNOHOMISH
7
In re:
8 Andrew Scott Rife
9 and
NOTICE OF UNAVAILABILITY OF
10 Jennifer Rae Mehaddi, f/k/a Rife COUNSEL
Respondent.
11
TO: THE CLERK OF THE COURT
12 NOTO: Andrew Scott Rife
NOTO: Veronica Freitas, attorney for Jennifer Rae Mehaddi
13
PLEASE TAKE NOTICE that Carl J. Gaul, attorney for Andrew Scott Rife, will be
14 unavailable during the following time periods:
From Through
15
December 18, 2013 January 3, 2014
16
March 12, 2014 March 19, 2014
17 May 20, 2014
May 14, 2014
18
It is requested that motions, depositions and other court hearings not be scheduled to occur
19 during the time of my absence, and that motions and other hearings be scheduled so that there is
sufficient time to prepare for them following the end of the absence. There is no other attorney
20 available with sufficient factual knowledge of this case to r~ond to any substantive request for
relief during my absence. I_ ' i
21 l/~
22 CARLJ.GAUL
Attorney for And
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
NOTICE OF UNAVAILABILITY OF cou~~~2 \G\' · \ I
"'\ L_
Everett WA 98201
425 259·4147 FAX 259 7081
In re the Marriage of: No. 05-3-02755-1

Andrew Scott Rife Petitioner,
vs. NOTICE OF APPEARANCE
Jennifer Rae Rife

Respondent(s)
TO: THE CLERK OF THE ABOVE-CAPTIONED COURT;

CJ>
z
-~ig;
:::!?
~
0
f'T1
.,,-
~~
AND TO: PETITIONER: ANDREW SCOTT RIFE n
w
r
AND TO: PETITIONER'S COUNSEL: CARL GAUL ~P:
. ,...&>
-a
:x m
AND TO: RESPONDENT: JENNIFER RAE RIFE :fl:x ..
N 0
AND TO: RESPONDENT'S COUNSEL: VERONICA FREITAS "'x N
°'
PLEASE TAKE NOTICE that Elise (Elizabeth) F. Buie is appearing as Guardian
ad Litem on behalf of minor child. We request that all further notices, papers and
pleadings be served on Guardian ad Litem at Elise Buie, Guardian ad Litem, 1037 NE
651h St., #354 Seattle, WA 98115.
DATED this 29™ day of December, 2013.
\11~11~~1111~~
CL16271797
Elise (Elizabeth) F. Buie, GAL, WSBA #44985
CERllFiCATE OF FACSIMILE AND MAiLING
I certify under the penalty of perjwy under .t!Je laws of the State of Washington
thatL111aiied a copy of the attached docwnent to Carl Gaul and Veronica Freitas; ail by"
first clas~ United _States mail, postage prepai_d, on December 29, 20 B.
:signed this 291h day of Dec.ember, 2013 in Seattle, Washington.
Elise (Elizabeth)F. Buie, GAL, #44985

,
1
3
In re Marriage of: No. 05-3-02755-1
4
Andrew Scott Rife NOTICE OF UNAVAILABILITY
5
Petitioner,
vs.
v
-fit-
7
Jennifer Rae Mehaddi, f/k/a Rife, ..., .....
::i:
8 ~
·~
Res ondent s
(")
9
10
TO:
ANDTO:
THE CLERK OF THE ABOVE-CAPTIONED COURT;
PETITIONER: ANDREW SCOTT RIFE
~~ -
:g.1!·=-- ,,
··Jl'.'!O>
w
:z
ANDTO: PETITIONER'S COUNSEL: CARL GAUL ~!:.~
11 AND TO: RESPONDENT: JENNIFER RAE MEHADDI FKA RIFE U>
::r ,..,;s;
12
ANDTO: RESPONDENTS COUNSEL: VERONICA FREITAS en ..
13 Please take notice that Elise (Elizabeth) F. Buie, Guardian ad Litem in the above
matter will be unavailable January 13-17, 2014, January 30-February 5, 2014, February
14
17-21, 2014, March 10-March 18, 2014, April 14-25, 2014, May 1 - May 20, 2014,
15
August 7-12, 2014.
16 The undersigned requests that no hearings, discovery or other matters requiring
17 any response or attention by this office be scheduled between this period or the week
immediately following, to permit sufficient preparation time after the absence. The
18
undersigned will request sanctions if any matters requiring any response or attention
19
are scheduled during the period noted above.
20
Dated this 291h day of December 2013
21
22 Elise F. uie, Guardian ad Litem, WSBA #44985

1037 NE 65111 St. #354
23 Seattle, WA 98115
206-769-7173 Phone
24 888-659-6345 Fax
25
Elise F. Buie
Notice of Unavailability - 1 Guardian ad Litem
111
1037 NE 65 St. #354
Seattle, WA 98115
206-769-7173 Phone
888-659-6345 Fax
., I
1
2
3 CERTIFICATE OF FACSIMILE AND MAILING
4 I certify under the penalty of perjury under the laws of the State of Washington
5 that I mailed a copy of the attached document to Carl Gaul, Attorney at Law, Veronica
6 Freitas, Attorney at Law, all by first class United States mail, postage prepaid, on
7 December 29, 2013.

8
DATED th;, 29th day~~
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ellse F. Buie
Notice of Unavailability - 2 Guardian ad Lltem
1037 NE 55lh St. #354
Seattle. WA 98115
206-769-7173 Phone
888-659-6345 Fax
FILED
201~ HAR -6 AH IQ: 19
SOHYA KRASl'.I
COUNTY CLERK
111111m1111111111
CL16674907
Sl-lQ'lCM!SH CO. YIASH
SUPERIOR COURT OF WASHJNGTON

CASE NO. 05-3-02755-1

--------------
ANDREW RIFE
Petitioncr/Plaintifl{s) NOTE FOR TRIAL SETTING AND INITIAL
STATEMENT OF ARBITRABILITY
vs. (NITSNA OR ST A)
JENNTFER MEHADDI (AKA JENNIFER RIFE)

Respondent/Defendanr(s)
TO: The Clerk or the Court; the Dlre<tor or Arbitration (by separate copy serviced at Room 502,
Superior Court Administration) and the attorneys or parties listed below:
I hereby affirm lhal this case is at issue; thot no offirmotive pleading remains unanswered; that 10 my knowledge no
other parties will be served with summons; and that the case in oil respccl< is ready for trial and/or lransfcr 10
arbitration.
Porenling Plan Modification 2
Type of C a s e : - - - - - - - - - - - - - - - - - - Es1imated Trial Time: _ _da_ys _ _ __
(Check one)
A jury of 0 twelve is requested and a jury demand ond fees have been filed with the Clerk pursuant to CR 38.
Osix
(Check one)
This case 0 is arbiirable.
I!'.] is nol orbiuuble.
Please note that as or 12-19-2003 there ls a mandatory arbitration ree orS220.00 which must be paid at the
time or filing this document with the County Clerk. Documents that indicate the case IS orbltrable that are
submitted without the rec will be returned to the submitting party.
NOTE: Arbitrable, non-jury coses should not be noted for presentation to the Superior Court
03/20/2014
at I 0:00 AM this case will be presented to the Court
Date (mm/dd/yyyy):
----------
Adminislrator's Office for Trial Setting.
IT IS NOT NECESSARY TO APPEAR FOR TRIAL SEITING.
I of3
ZYI
INITIAL STATEMENT OF ARBITRABILITY (SCLMAR 2.1)
This case is ARBITRABLE because: (Check one)

D The sole rclicfsoughl is a money judgment and involves no claim in excess of$50.000 exclusive of
any attorney fees, interest and costs (RCW 7.06.020 SCLMAR 1.2) or
D The sole relief sought. regardless of the number or amount ofpaymenl•, is the cstablishmcnl.
termination or modification of maintenance or child suppon payments or arrearages (RCW 7.06.020
SCLMAR I .2) or
D The undersigned waives any claim in excess of $50,000 in order to have this case arbitrated; or
D This is a Small Claims matter appealed from District Coun.
This case is NOT ARBITRABLE because: (Check one)
D Relief other than or in addition to a money judgment is being sought and/or a claim, counterclaim or
cross claim exceeds $50,000 exclusive of attorney fees. interest and costs; or
[!] This domestic lawsuit presently involves issues other than or in addition to the establishment,
modification or termination of child support or maintenance payments or arrearagcs; or
D This case is an appeal from a Municipal or District Coun decision (which is not a Small Claims
matter); or
D This case is otherwise statutorily cxcmpl from mandalOry arbitration.
RCW:
Civil Cases not subject to MANDATORY Arbitration may be submitted to arbitration pursuant to MAR 8.1 (b),
SCLMAR 8.1 and SCLMA 2.1 (d) by stipulation which must be filed with the Clerk of the Coun and a copy served
upon the Director of Arbitration.
D The undersigned hereby requests that this matter be transferred to arbitration pending formal stipulation
by the panics.
Any Response to this Statement of Arbitrability must be filed with the Clerlc of the Coun and a copy served upon the
DireclOr of Arbitration within 14 days afier this document has been served and filed. (SCLMAR 2.1 (b))
I cenify that I mailed a copy of this document to
!he atlOmeys listed hereon, postage prepaid on the
/1~
(Signature)
Date (mm/dd/yyyy): 03-05-2014
~~~~~~~~~~~~~-
Date (mm/dd/yyyy): 03-05-2014 W SBA#: 19405

~~~~~~~~~- ~~~~~~~~~~~~~~~~~-
NAME:
NOTE: File the original of this document with the
Veronica Freitas
Clerk of the Coun: Serve a copy on the DireclOr of
Arbitralion, Room 502, Superior Coun ADDRESS:
on all panics. 210 Summit Ave East, Seattle, WA 98102
TELEPHONE: 206-328-7362
~~~~~~~~~~~~~~~-

D Pctilioncr/Plaintiff
2 of3
·•
PLEASE LIST THE NAMES, ADDRESSES, ETC. OF ALL OTHER AITORNEYS IN THIS CASE
NAME: WSBA#: 8341

Carl Gaul
-=-='-'-'------------
TELEPHONE: 425-259-4147
0 .Petitioner/PlaintiIT
1604 Hewitt Ave, Everett, WA 98201 D Respondent/Defendant
NAME: WSBA#: _ _ _ _ _ _ _ _ _ _ _ __
Elise Buie TELEPHONE: 206-769-7173
--'-'---------~
1037 NE 65th S1 #354, Seaule, WA 98115 D Respondent/Defendant
NAME: WSBA#: _ _ _ _ _ _ _ _ _ _ _ __
- - - - - - - - - - - - - - - - - - - TELEPHONE: - - - - - - - - - - -
D Rcspondent/Dcfendanl
NAME: WSBA#: _ _ _ _ _ _ _ _ _ _ _~
- - - - - - - - - - - - - - - - - - - TELEPHONE:
NAME: WSBA#: _ _ _ _ _ _ _ _ _ _ __
- - - - - - - - - - - - - - - - - - - TELEPHONE:
ADDRESS: ArroRNEY FOR: (Check one)
D Respondcnt/Defendanl
' ..
1
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CL16491834
3
In re Marriage of: No. 05-3-02755-1
4
Andrew Scott Rife NOTICE OF UNAVAILABILITY
5
Petitioner,
VS. .......
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Jennifer Rae Mehaddi, f/k/a Rife, ;Eco
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Res ondent
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TO: THE CLERK OF THE ABOVE-CAPTIONED COURT; ::e:n~
l>A- -.. 0
10 ANDTO: PETITIONER: ANDREW SCOTT RIFE Vl
AND TO: PETITIONER'S COUNSEL: CARL GAUL ~
11 AND TO: RESPONDENT: JENNIFER RAE MEHADDI FKA RIFE

ANDTO: RESPONDENTS COUNSEL: VERONICA FREITAS
12
13 Please take notice that Elise (Elizabeth) F. Buie, Guardian ad Litem in the above
matter will be unavailable April 14-25, 2014, May 1 - June 1, 2014, June 27-July 7,
14
2014, August 7-12, 2014 October 13-17, 2014.
15
The undersigned requests that no hearings, discovery or other matters requiring
16 any response or attention by this office be scheduled between this period or the week
17 immediately following, to permit sufficient preparation time after the absence. The
undersigned will request sanctions if any matters requiring any response or attention
18
are scheduled during the period noted above.
19
~_, ~ted this 6th day of March 2014.
20
21 ~~
Elise F. Buie, Guardian ad Litem, WSBA #44985
1037 NE 65u; St. #354
22
Seattle, WA 98115
23 206-769-7173 Phone
888-659-6345 Fax
24
25
Elise F. Buie
1037 NE 65th St #354
Seattle, WA 98115
206-769-7173 Phone
888-059-0345 Fax
1
CERTIFICATE OF FACSIMILE AND MAILING
2
3 I certify under the penalty of perjury under the laws of the State of Washington
4 that I mailed a copy of the attached document to Cart Gaul, Attorney at Law, Veronica
5 Freitas, Attorney at Law, all by first class United States mail, postage prepaid, on March
6 6, 2014.
7 DATED this 6th day of March, 2014
~~
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ellse F. Buie
1037 NE 651h St #354
Seattle, WA 98115
206-769-7173 Phone
888.059.0345 Fax
Ff LED
201~HAR25 AHll=09
SONYA l<RASKI
COUHTY CLERK
TO: SNOHOMISH CO. WASH
Elise F. Buie
Guardian Ad Litem
1037 NE 65th St. #354
Seattle, WA 98115
11m~~u~111~~m111~1111
CL16551578
Date: March 24, 2014
Eoht
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
VS
· Jennifer R. Rife
This is to notify you that the above case has been set for Non-Jury trial on July 16, 2014 at 9:00
am, in the Superior Court, Presiding Judge's Department, Courthouse Building.
Court Administrator
Eoht Eoht
IMPORTANT NOTICE: Your attention is directed to SCLCR 40(d), SCLSPR 94.04{c), and CR 41(e) which read
as follows: ·
SCLCR 40(d) TRIALS-CONFIRMATION: It shall be the duty of each attorney of record or

party pro se in a case set for trial to jointly or separately confirm, no sooner than 12 noon of the first court
day of the week [6/3012014) and no later than 12 noon of the last court day of the week [7/312014) two
weeks prior to the trial date, in such written form as approved by the court. The court may strike the trial
date and may impose sanctions and/or terms against the parties or counsel for failure to so confirm.
WARNING: IN FAMILV LAW CASES, PURSUANT TO SCLSPR 94.04(C)(l)(B), FAILURE TO
CONFIRM YOUR TRIAL DATE, APPEAR ON A CONFIRMED TRIAL DATE, OR OBTAIN ORDER GRANTING A
TRIAL CONTINUANCE MAY RESULT IN DISMISSAL OF YOUR CASE.
CR 4l(E): Notice of Settlements. If a case is settled after it has been assigned for trial it shall be
the d)lty of the attorneys or of any party appearing prose to notify the court promptly of the settlement. If
the settlement is made within 5 days before the trial date, the notice shall be made by telephone or in
person .. All notice of settlement shall be confirmed in writing to the clerk.
UTILIZE THE NEXT PAGE OF TlDS LETTER OR A COPY THEREOF

TO:
Carl Joseph Gaul
Attorney at Law
1604 Hewitt Avenue, Suite 302
Everett, WA 98201

~
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
VS
Jennifer R. Rife
Court Administrator
IMPORTANT NOTICE: Your anention is directed to SCLCR40(d), SCLSPR 94.04(c), and CR 41(e) which read
as follows:
SCLCR 40(d) TRIALS - CONFIRMATION: It shall be the duty of each attorney of record or
party prose in a case set for trial to jointly or separately confirm, no sooner than 12 noon of the first court
day of the week [6/3012014) and no later than 12 noon of the last court day of the week (7/312014) two
WARNING: IN FAMILY LAW CASES, PURSUANT TO SCLSPR 94.04(C)(l)(B), FAILURE TO
CR 4l(E): Notice of Senlements. If a case is settled after it has been assigned for trial it shall be
the duty of the attorneys or of any party appearing pro se to notify the court promptly of the settlement. If
person. All notice of settlement shall be confirmed in writing to the clerk.
UI'IUZE THE NEXT PAGE OF THIS LEITER OR A COPY THEREOF

. '
TO:
Veronica Freitas
Attorney at Law
Seattle, WA 98102

EolJI
IN THE SUPERIOR COURT OF THE STATE OF W ASBINGTON
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
vs
Jennifer R. Rife
Court Administrator
Snohomish County Superior Comt
IMPORTANT NOTICE: Your attention is directed to SCLCR 40(d), SCLSPR 94.04(c), and CR 4 l(e} which read
as follows:
SCLCR 40(d) TRIALS- CONFIRMATION: It shall be the duty of each attorney of record or
party pro se in a case set for trial to jointly or separately confinn, no sooner than 12 noon of the first court
day of the week (6130/2014) and no later than 12 noon of the last court day of the week [713/2014) two
weeks prior to the trial date, in such written fonn as approved by the court. The court may strike the trial
date and may impose sanctions and/or terms against the parties or counsel for failure to so confinn.
the duty of the attorneys or of any party appearing prose to notify the court promptly of the settlement. If
person. All notice of settlement shall be confinned in writing to the clerk.
UTIUZE THE NEXT PAGE OF THIS LETTER ORA COPY THEREOF

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11
12 In re the Marriage of I
13 I NO. 05-3-027551
14 Andrew Scott Rife I
15 Petitioner, I REPORT OF
16 and I GUARDIAN AD LITEM
17 I
18 Jellllifer Rae Rife I Public Report
19 Respondent. I
20
21 On October 24, 2013, Elise (Elizabeth) F. Buie was appointed Guardian
22 ad Litem for Lauren Rife. Any information included in the Guardian ad Litem
23 Public Report that has also been filed with the Court is incorporated by refer-
24 ence herein unless the information is contained in this report.
25 I. RECOMMENDATIONS
26 1. Lauren Rife shall be assessed by a mental health professional agreed to
27 by both parties (on their own or in mediation) and parents shall follow any and
28 all recommendations for counseling. Lauren's counselor shall also meet with
29 each parent individually.
30 2. Communication between Parents: Emails should be used as the primary
31 and preferred form of non-emergency information, to communicate information
32 about the child's schedule, medical issues, medical or other appointments,
33 school activities, proposed changes to the parenting time schedule, holiday ac-
REPORT OF
GUARDIAN AD LITEJlll
Ill#""""""''I. Billa 6aallllmdl/laJllJaniaJ
1DIJUllPlll.#IM
(Pabllcl 1181110.11188115
RCW 26.09.260 PAGE 1 Pllllll uom 189-1111. 11111111111 ll5!HIMll
1 tivities, the child's personal property items or clothing, and other parenting-
2 related issues.
3 a. Specify an Email address: One email address should be specified
4 for use between the parents. That email address shall be checked at least once
5 per day. Once an email address is specified for parenting, the other parent
6 shall not send emails to a different email address. If this email address must
7 change, timely notice shall be provided to the other parent.
8 b. Brief and Specific Emails: Keep the emails short. If you have more
9 than one issue to cover, number the issues and then the answering email shall
10 refer to them by number. The emails should be brief and concise. No more
11 than one email shall be sent each day unless there is some particular
12 emergency.
13 c. Subject lines: Use specific subject lines on all emails.
14 d. Future-oriented only: All emails shall relate to future activities on-
15 ly, a request for future action or provide specific information. Emails shall not
16 re-hash past incidents, assign blame or make judgments on past events.
· 17 e. Respectfulness: No name-calling, no nicknames and no abusive
18 language should be used. Each email shall be written in such a way that you
19 would feel comfortable to publish it on the front page of the newspaper.
20 f. Responses: Emails that require a response should be responded to
21 within a timely fashion. In any event, a response shall be forthcoming within
22 24 hours. If an email does not require a substantive response, the receiving
23 parent shall send a responding email that says "received."
24 g. New Spouses/Significant Others: New spouses or sign.ificant oth-
25 ers shall not be involved in email communication. They should not send
26 emails and they should not be copied on emails, which are sent to the other
27 parent.
REPORT OF 111ia """""""'1. fllllA 8llanlllD a ll16t1lllll1ltB

GUARDIAl'l AD LITEM 11111IE115"11. 145'
(Public) lelllll, llA 88115
RCW 26.09.260 PAGE2 l'IDlll 12081111&-nn.J111888165HIQ
1 h. Financial issues: Emails relating to financial issues should be sent
2 separately from emails relat,ing to children issues.
3 i. Text messaging: Text messaging is generally not the preferred
4 method of communication. It should be utilized to convey time-sensitive com-
5 munication only such as being delayed for a residential time exchange.
6 3. Decision Making: Based on the available information including months
7 of emails regarding ongoing problems with decision-making, it is the opinion of
8 the undersigned that the parents do not have a recent satisfactory history of
9 cooperation to share authority in most major decisions regarding the Child.
10 Further, both parents are opposed to mutual decision-making. The under-
11 signed recommends the following:
12 Educational Decisions - Joint subject to arbitration
13 Changing Schools - Joint subject to arbitration
14 Religious upbringing- Joint
15 Extracurricular Participation - Sole -Mother
16 Non-emergency Medical Care - Sole - Mother
17 Non-emergency Dental or Orthodontic Care - Sole - Father
18 Haircuts - Sole -Father
19 Tattoos and Body Piercing - Sole - Father
20 Counselors - Sole - Mother
21
22 Educational Decisions: The child shall attend her current school
23 through the remainder of this school year. The father or mother shall have the
24 authority to annually enroll the child in her current school, select optional
25 classes, authorize educational testing, obtain tutoring and seek education ac-
26. commodations (e.g. Section 504 Accommodations) for the child. If educational
27 testing is done, the results shall be provided to both parents. If one parent en-
REPORT OF 111111,,,,,.,,,,,,,, f. Biiia lllliiltlbai II/ U1m/IJIJlnJ6J

GUARDIAN AD LITEM 10110 BP IL #15'
(Public) 1111118, 111119811li
RCW 26.09.260 PAGE3 l'llllll IJ08l Jll&.1111.1111888185&GU
1 rolls child in school, the other parent shall be listed as such on each and every
2 form including the emergency contact form at the school.
3 Changing schools shall be a joint decision and subject to the dispute
4 resolution process. If a parent wants Lauren to change schools, that must be
5 suggested in writing by May 1, 2014 for the 2014-2015 school year or by No-
6 vember 15, 2014 for the 2015-2016 school year and by November 15th of any
7 future year. The decision to change schools is subject to joint decision-making
8 and the dispute resolution process. That process might need to be on an expe-
9 dited basis in light of various school application deadlines.
10 Any costs or fees associated with the dispute resolution process regard-
11 ing Educational Decisions or to change schools shall be divided according to
12 each party's proportional share of income from Line 6 of the Child Support
13 worksheets. The arbitrator shall have the authority to allocate or re-allocate
14 fees for cause.
15 The arbitrator shall issue his or her final decision in writing and forward
16 a copy to each party. The original decision shall be filed with the court and
17 shall be binding upon the parties unless an action for court review is filed with-
18 in twenty (20) days. The court shall assess costs and reasonable attorneys'
19 fees against a party who seeks court review and fails to improve his or her posi-
20 tion. Unless waived, the court may assess costs and reasonable attorney's fees
21 against a party who unilaterally withdraws a request for court review after
22 costs or fees have been incurred by the opposing party.
23
24
25
REPORT OF llllalllflltetllJ,, Bllla t:adladlll6ltllllllmtl

GUARDIAl'l AD LITEM IDIJ 11115" 11. llUI
(Public) ll8lllD. 1111118111
RCW 26.09.260 PAGE4 PBDll llOBI JBll..1111.111 m881611M1141
1 Extracurricular Participation. Neither party shall independently enroll
·2 the child in any activity that talces place during the other parent's residential
3 time with that child, including weekend activities.
4 For all decisions that impact the other parent's residential time (extra-
5 curricular activities, vacation), either parent shall notify the other parent via
6 email of the pending decision, as soon is reasonably possible, about the issue
7 and the proposed decision/ solution. The other parent has 36 hours to re-
8 spond. No response indicates agreeing with the referring parent's proposed de-
9 cision. If the parties do not agree, the dispute shall be submitted to arbitration
10 by Lee Tinney. The costs of arbitration related to extra-curricular participation
11 shall be borne by Mr. Rife yet the arbitrator shall have the authority to allocate
12 or re-allocate fees for cause. The parties shall abide by the rules of the arbitra-
13 tor insofar as briefing, oral argument and/or fees are concerned.
17 in twenty (20) days. The court shall assess costs and reasonable attorneys'
19 tion. Unless waived, the court may assess costs and reasonable attorney's fees
20 against a party who unilaterally withdraws a request for court review after
21 costs or fees have been incurred by the opposing party.
22 Non-emergency Medical Care. The mother shall have the authority to schedule
23 routine non-emergency health care appointments (e.g. physical exams or check
24 ups) and minor, non-emergency health care for minor illnesses or minor inju-
25 ries and consent to routine treatment thereof. The mother shall notify Mr. Rife
26 by email of all such appointments and treatment, describing any findings,
27 treatments or recommendations. If a healthcare provider recommends ongoing
REPORT OF 11116""""""'11. 111111. 8aanlltID Blll1DllllltJtaBI

GUARDIAN AD LITEM 11111 UllPR.1115'
(Public I lelllle. llll 11811l1
RCW 26.09.260 PAGE& l'llllll 1J081111&-1111. IU 1888185HIU
1 treatment beyond a course of medication (e.g. surgery, multiple appointments,
2 referral to a specialist or further evaluation), the response will be subject to
3 joint decision-making and the dispute resolution process.
4 Non-emergency Dental/Orthodontic Care. The father shall have the authority
5 to schedule routine non-emergency dental care appointments (e.g. dental or or-
6 thodontic exams or check ups or cleanings) and minor, non-emergency dental
7 care for minor dental situations and consent to routine treatment thereof. The
8 father shall notify Ms. Mehaddi by email of all such appointments and treat-
9 ment, describing any findings, treatments or recommendations. If a dental or
10 orthodontic provider recommends ongoing treatment beyond a course ofmedi-
11 cation (e.g. surgery, multiple appointnients, referral to a specialist or further
12 evaluation), the response will be subject to joint decision-making and the dis-
13 pute resolution process.
14 Consultation. All major decisions for the child, including those items, which
15 are subject to sole decision-making, shall be made by the assigned parent only
16 after reasonable and liberal advance notice and an opportunity for consultation
17 by the other parent.
18
19 4. In order to seek a modification of this parenting plan, including· a change
20 in decision-making, excluding a change of primary parent (which is Mother in
21 this matter), without. a substantial change of circumstances or showing of det-
22 riment, the parent must initiate, fully participate in, comply with all recom-
23 mendations and completely pay for a parenting evaluation and report by a
24 Ph.D.-level parenting evaluator mutually agreed upon by both parents or ap-
25 pointed through dispute resolution (also paid for my the initiating parent).
26 Both parents and child shall participate in the parenting evaluation. In the
27 event the initiating parent seeks a modification of this parenting plan under
REPORT OF llllB {BllB/J8111J 1.111111, llDanlllB l/lll1UI/llllJIBll

OUARDIAl'l AD LITEM IOUll 115" 81. 113114
(Public) 1181111, 11188115
RCW 26.09.260 PAOE6 l'llOIJ IJOBJ JBIHIJI. rll18881 UIMllU
1 this section, the complete parenting evaluation report shall be served upon the
2 other parent with the initial pleadings.
3 5. The parents shall work with a Case Manager and/or Parenting Coordina-
4 tor for 2 months in an attempt to help educate them on better communication
5 skills and parallel-parenting skills so that they can reduce their conflict. Any
6 and all fees or costs related to a Case Manager/Parenting Coordinator shall be
7 borne by Mr. Rife.
8 6. Residential Schedule: The undersigned adopts Part III, Residential
9 Schedule, Sections 3.1 - 3.14, that the parties agreed to in their March 25,
10 2011 parenting plan. No other provisions in the 3/25/ 11 parenting plan are
11 adopted unless specifically referred to in these recommendations.
12 7. The "right of first refusal" shall apply only if more than twelve (12) hours
13 of childcare is required.
14 8. The following provisions shall be included in the final parenting plan
15 signed by the parties:
16 Participation in Children's Events. The child shall be accompanied by
17 the parent with whom the child is residing at the time of a given social or ath-
18 letic event. The other parent shall not be limited from attendance at that event,
19 providing said attendance by the non-residential parent is not disruptive to the
20 other participants by a reasonable person standard
21 Notification of Child's Events. Each parent shall be responsible for
22 keeping themselves advised of school, athletic, and social.events in which the
23 child participates.
24 Deviation from Schedule. Acceptance and waiver of any deviations from
25 the provisions of this parenting plan shall not constitute acceptance or waiver
26 of subsequent deviations from this plan. The provisions of this plan shall re-
27 main in effect until modified by an appropriate written order by a court of com-
REPORT OF Biia ,,,,,,,..f/JJI. llll/4 flllBnl/111 ltl lllBI1lllJ1l6lt

GUARDIA11 AD LITEM llll1u85"a 1115'
(Pabllc) 11111111. U 11811li
RCW 26.09.260 PAGE7 l'llDll ll08J J119.1Dl. Ill 18881115HM5
1 petent jurisdiction; provided, that any and all revisions to this plan that are in
2 writing and signed by both parents, and shall be effective immediately.
3 Objectives. Each parent agrees to honor one another's parenting style,
4 privacy and authority. Neither parent shall interfere in the parenting style of
5 the other nor shall either parent make plans or arrangements that would im-
6 pinge upon the other parent's authority or time with the child without the ex-
7 press written agreement of the other. Each parent shall encourage the child to
8 discuss their grievance against a parent directly with the parent in question. It
9 is the intent of both parents to encourage a direct parent-child bond and com-
10 munication.
11 9. Dispute Resolution: Dispute resolution shall be arbitration by Lee Tinney
12 or Retired Judge Castleberry or Lynn Pollock or some other mutually agreed
13 upon arbitrator. If the parties mutually agree, they may use mediation instead
14 of arbitration at the Dispute Resolution Center.
15 To initiate arbitration, the requesting party shall communicate with the
16 office of the arbitrator to select a date for the arbitration hearing; such date to
17 be not less than 14 days from the date notice is mailed to the other parent, ex-
18 cept in exigent circumstances. The requesting party shall deliver a notice of
19 intent to arbitrate to the other parent (with a copy sent to the arbitrator) in-
20 eluding a) the arrangements for arbitration, such as the time, place and the
21 name and phone number of the arbitrator, b) the issues on which arbitration is
22 sought and an explanation thereof, c) a proposed resolution to each issue and .
23 an explanation thereof and d) copies of all documentation the requesting party
24 will ask the arbitrator to consider in making a decision. The responding party
25 shall, within 7 days, deliver a written response to both the requesting parent
26 and the arbitrator, specifying a) any objections to the arrangements for arbitra-
27 tion, with proposed alternative arrangements, b) a response to the issues, ex-
REPORT OF l11IB ,,,,,,,,,,,,,, ,, Bala IJaartlaB llll11161B/1111Bnm

OUARDIAll AD LITEM 11111 D BJ" Bl 1135'
(PubllcJ leallle, llA98m
RCW 26.09.260 PAGES l'llOll IJDBJ 189-lln,IU 1888185!MIMI
1 planations and proposed resolutions of the requesting party, c) any additional
2 parenting issues the responding party wants arbitrated and an explanation
3 thereof, d) a proposed resolution to the responding party's new issues and an
4 explanation thereof and e) copies of all documentation the responding party
5 will ask the arbitrator to consider in making a decision. Other than phone
6 calls limited to scheduling arrangements, the parties shall not contact the arbi-
7 trator except in writing or email with a full copy simultaneously forwarded to
8 the opposing party. The parties shall not discuss the merits or circumstances
9 of the issues with the arbitrator unless the other party is included in the con-
10 versation. Copies of all communication including email, sent to the arbitrator
11 must be sent at the same time to the opposing party and all telephone calls
12 with the arbitrator shall include both parties.
13 The authority of the arbitrator shall include a) ruling on schedule and
14 discovery issues, b) making such findings of fact and conclusions of law as the
15 arbitrator deems necessary to clarify the decision, c) making such decisions as
16 are necessary to effectuate the terms of the plan, including but not limited to
17 making short-term adjustments such as make-up days and temporary changes
18 to the residential schedule and d) re-allocating arbitration and attorneys fees
19 for cause. Either party has the right to seek immediate do novo judicial review
20 of the arbitrator's decision. Except as otherwise specified herein, the provi-
21 sions of the Superior Court Mandatory Arbitration rules shall apply.
25 '
in twenty (20) days. The court shall assess costs and reasonable attorneys'
27 tion. Unless waived, the court may assess costs and reasonable attorneys' fees
REPORT OF DB ll1llOBllJI 1.111111. llllanllaBldlllDJ/llltltBn

GUARDIAN AD LITEM 11111 IE 115" IL 11351
(Public) 11111111. llA 88111
RCW 26.09.260 PAGE9 PRDll IJOBIJll&.1111.fll 18881859 BPI
1 against a party who unilaterally withdraws a request for a court review after·
2 costs or fees have.· bee incurred by the opposing party.
3 In the dispute resolution process:
4 (a) Preference sb.all l:>e given to carrying out this Parenting Plan ..
5 (b) .Unless an emerg~ncy exists, the parents shall use .the designated
6 process to resolve disputes-relating-to implementation of the plan, except those
7 reJa.ted to•finElJ1cial support.
8 '(c) A written ·record shall be prepared of any agreement·reached in
9 counseling or mediation and of each arbitration award and sha:JI be provided to.
10 each pat_ty.
11 (d) If the court finds that a parent has used ·or frustrated the dispute
12 resolution process without goo~ reason, the court sha:JI award attorney~s fees
13 and finan«llil sanctions to the other parerit.
14 (e) The parties.have the.right.of review from ilie dispute resolution
15 process to the Superior Court.
16 10~ Both parents shall see a•counselor to help address the ongoing relation-
17 ship issues.between them that appear to cause barriers in their ability to sue~
18 cessfully parallel parent.

19
20
21
22
23
24
25
26
27
REPORT OF llllll lllllBflllfll1.111111. lll18lrllatl 111lllBlllllllmlU

oUARDIAR .AD LITEM . 1mi11&5"R#3lil . . . . .
(Piabllc) SUllll, UllBlll
RCW 26.09.260 PAGE 10 1'111111 U08I Jll9.JIJI, Rll 18881 &llMllU
1
2
3 D. EVIDENCE RELIED UPON
4 These recommendations were based on the following:
5 1. Snohomish County Superior Court file No. 05-3-027551 .
6 2. Order appointing GAL, 10/24/ 13
7 3. Parent forms of both parents
8 4. Employee Performance Evaluation Review Form - PUD - Mr. Rife
9 5. Agreed Parenting Plan dated 3/25/ 11
10 6. Documents provided on 1/4 / 14 re: Andrew Rife, DV Background include
11 ing timeline and exhibits
12 7. More than 200 Pages of texts, pictures, notes about daily things such as
13 pick up from soccer, hair, showers, etc. from Mr. Rife including calendars of
14 time that he spent with Lauren agreed to by Ms. Mehaddi dating back to
15 10/2009
16 8. Declaration of Ms. Valente from Mr. Rife
17 9. Declaration of Kathleen Krischano, Mr. Rife's aunt
18 10. Declaration of Cindy Taylor from Mr. Rife
19 11. Handwritten Letter from Wendy Rife re: incident at soccer field 11/9/13
20 12. School records of Lauren - reading logs, math homework, IOWA Test Re-
. 21 suits, Poem written by Lauren Rife re: soccer provided by Mr. Rife
22 13. Performance Evaluation Form from Mr. Rife's employer
·23 14. Numerous calendars depicting Lauren's schedule from Mr. Rife
24 15. Emails from the parties regarding Lauren's schedule, school, homework,
25 hair, lunch, soccer, medical situations
26 16. Sentencing Recommendations, City Attorney Office dated 8/25/05
27 17. Proposed Assessment and Report for Andrew Rife dated 5/25/05
· 28 18. Monthly Progress Report, dated 6/ 1/05
29 19. Summit Counseling letter dated 9/29/05
30 20. Petition for Order for Protection filed 10/3/05
31 21. Stay of Proceedings for DV Treatment dated 10/5/05
32 22. NCO, dated 10/5/05
33 23. Summary Evaluation and Report by Charles DeVore dated 12/ 1/05
34 24. Letter from DSHS to DeVore re: complaints with compliance dated
35 6/7/06
36 25. Order on Motion for Review and Clarification of Order, No CR 67770, CR
37 69259
38 26. Transcript of.Telephone Conversation dated August 2013
REPORT OF Eatl IIlllallfJl/JJI. BBi& laan/IBII "'""1111111JJn111

GUARDIAN AD LITEM IDDD85"R#311
(PabllcJ 1811118, WI 118115
RCW 26.09.260 PAGE 11 1'11111112881J&9.JIJl,Ill1888JaHMI
1 27. Letter from Dale Todd closing Mr. Rife File dated 6/21/06
2 28. Domestic Minute Entry by Commissioner Waggoner dated 7 /31/06
3 29. Final Parenting Plan dated 11/7 /06
4 30. Petition for Order for Protection dated 1/2/07
5 31. Order of Dismissal dated 1/ 16/07
6 32. Progress Report- Catholic Community Services dated 3/ 1/07
7 33. Correspondence from CCS rescusing Sandra Poirier dated 3/7 /07
8 34. Case Manager Statement of Bridget Llewellyn dated 4/5/07 (Sealed)
9 35. Correspondence from Providence re: 7 Session parenting class dated
10 7/18/07
11 36. Evergreen Manor Report dated 9/ 17 /07 Discharging Mr. Rife
12 37. Notes from Mr. Rife dated 4/ 16/08, 4/22/08, 4/29/08, 5/5/08,
13 38. Correspondence dated 8/ 13/08 re: Mr. Rife refusal to sign ROI
14 39. Co~spondence dated 9/2/08 from Mr. Rife re: ROI
15 40. Correspondence dated 11/5/08 from Mr. Rife Release of Information
16 41. Correspondence dated 11 /6/09 from Mr. Rife's counsel to Family Ser-
17 vices
18 42. Correspondence dated 11/ 18/08 from Family Services to Mr. Rife
19 43. Correspondence dated 1-1/ 18/08 from Family Services to Mr. Gaul
20 44. Hundred's of emails to and from Mr. Rife and Ms. Mehaddi since October
21 2013 including pictures of texts and copies of emails with outside sources
22 such as teacher, principal, Soccer Coach, family friends, etc.
23 45. Declaration of Colin Hill from Mr. Rife
24 46. Declaration of Christine Desantos from Mr. Rife
25 47. Medical Records, Everett Clinic
26 48. Phone Conversation Transcript, August 13, 2013
27 49. 911 recording provided by Mr. Rife
28 50. Countless hours of thought as to how best to serve Lauren's best inter-
29 ests while not causing more conflict yet addressing the very real concerns
30 about the parties inability to put aside their own war to focus on Lauren yet
31 staying optimistic about the parties ability to move forward constructively.
32
33
34 V. INTERVIEWS WITH PARENTS AND CHILD
35 Interviews with Andrew Rife:
36 Interviews with Jennifer Mehaddi:
37 Interviews with Soufayane Mehadcli:
REPORT OF lllltl llllldBllll I. Bala BllBlll/BJI '"lllBallllllmlBI

GUARDJAlll AD LITEM IOIJUllPR#UI
(Public) 11111111.11111111115
RCW 26.09.260 PAGE 12 l'lllllll l208I 1119-1111, RI 1888185HMll
1 Interviews with Lauren Rife:
2
3 VI •. COLLATERAL INFORMATION
4 Wendy Rife, Paternal Grandmother
5
6 Carol Holland, Steve Holland, Maternal grandparents
7
8 Lisa Holland, Maternal Sister
9 Stacy Rife, Paternal Sister-in-Law
10
11 Bruce Stewart, Principal at St. Mary Magdalen
12 Bernie Houghton, 3d Grade Teacher at St. Mary Magdalen
13
14 Vlll. CONCLUSIONS
15 Mr. Rife and Ms. Mehaddi truly need to bury the hatchet. Lauren de-
16 serves a break from this conflict that has existed almost her entire life. The
17 amount of time, energy and money that is spent fighting would be better spent
18 on counseling for Lauren and what is in Lauren's best interests. True disen-
19 gagement needs to occur between these parents that divorced so long ago to
20 enable successful parallel parenting. The Mehaddi marriage and Mr. Mehad-
21 di's arrival here in the United States seemed to throw the previous level of co-
22 operation into a tail spin. It is hoped that any issues can be addressed by way
23 of counseling so that these two parents can get back to parenting Lauren coop-
24 eratively as they were doing when they agreed to a parenting plan in March
25 2011. The level of cooperation and flexibility they had during that time should
26 be lauded as a success rather than used to create a record of every detail which
27 serves as the basis of this modification. Much trust has been destroyed as a
28 result of this current litigation and it is the undersigned's hope that the par-
REPORT OF DB fll1ndlRIOl I. llllla 611altla Bl IJ1BillllllDtDI

GUARDIAN AD LITBM 1m ow 11. #IM
IPubllcl 1111118. llA 88115
RCW 26.09.260 PAGE 13 l'llUll l208l 189-1111. Ill 188816ll9 AH
1 ents will work to rebuild that trust and focus not on each other but on Lauren
2 and what is best for Lauren. Each parent has great value in Lauren's life and
3 development. Lauren can appreciate the value each offers. Hopefully with
4 time, education, and counseling, the parents can learn to appreciate the value
5 each offers Lauren.
6
7
8 I declare under penalty of perjury under the laws of the State of Wash-
9 ington that the foregoing is true and correct, to the best of my knowledge.
10
11 Signed at Seattle, WA on March 23, 2014.
12
13
14
15
16
17
18 Elise (Elizabeth) F. Buie, WSBA #44985
19 Guardian ad Litem/ Attorney
20 Bachelor of Arts, Psychology, 1990
21 Juris Doctorate Degree, Loyola Law School, 1994
22
REPORT OF llJIB l1lllllll/llllJ1.1111/a lll1BnlJBa Id ll1Blll/IIltlnl

GUARJ>lAR AD LITEM 11181DllPll.#15'
(Pabllcl leallll. llA 88115
RCW 26.09.260 PAGE14 l'llDIE ll08I 189-Jlll. fll 1888185IMllQ
~-··
,;..:
FILED
1 1 1m~1 m1 ~w1n1 1~1 1 1 1 1 1 1 1 1 1 1
1
2
CL 16717199 201~ APR 28 AM II: OI
3
SONYA KRASKI
4 COUNTY CLERK
SllOHOMISH CO. WASH
5
6
7
8
Andrew Scott Rife, NO. 05 3 02755 1
9 Petitioner
and MOTION TO COMPEL DISCOVERY
10 Jennifer Rae Mehaddi, f/k/a Rife
Respondent.
11
COMES NOW Andrew Scott Rife and moves the above entitled Court for an order requiring
12
Jennifer Mehaddi to answer the interrogatories and r est for prod ction served on or about March
13
14
on the subjoined declaration. . 1
10, 2014; and for a reasonable attorney's fee. This m · n is bas on e records and files herein and
15
16
CARL J. GAUL declares under penalty of the laws of the state of Washington that the following
statement is true:
17
18
1. Identity and Purpose. I am the attorney for Andrew Scott Rife herein. I make this
declaration in support of Andrew Scott Rife's motion to compel discovery.
19
2. Discovery Propounded. Interrogatories Propounded to Jennifer Mehaddi on or about
March 10, 2014.
20
21
3. No Proper Response. More than 30 days have elapsed since service on said Jennifer
Mehaddi and no answers to said interrogatories and requests have been returned to my office;
22
4. Discovery Conference. A discovery conference occurred on Thursday, April 17, 2014,
was scheduled in my office at which time Jennifer Mehaddi's attorney said her client had promised to
23 get draft answers to her the next day (Friday, April 18, 2014). Ms. Freitas said she believed she could
get answers delivered on the following Friday, April 25, 2014. She was not able to provide answers
24
to any questions at the time of the discovery conference. No further answers or requests for production
have been provided as of this date. The Court should award terms for the necessity of bringing this
25
action.
26
· 5. Justice Mandates an Order. Discovery will not occur in an orderly manner without
judicial intervention by an Order Comepelling Discovery. Jennifer Mehaddi has had sufficient time and
27
28
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
2-L.f
, ~".
1 opportunity to make a response addressing the fair substance of the discovery propounded and without
justification has not done provided such a response. In this case the failure to fulfill discovery
2 obligations prejudices the justice process because mediation cannot occur until discovery is complete.
3 6. Attorney Fees I Costs. Andrew Scott Rife has incurred reasonable attorney fees and
costs in this matter as follows:
4
Item Amount
5 discovery conference 0.3 hours $75.00
6 preparation and calendaring this motion to $125.00
compel discovery 0.5 hours
7
hearing on motion to compel (anticipated) 1.0 $250.00
8 hours
9 Total $450.00
10 Judgment should be entered in favor of Andrew Scott Rife against Jennifer Mehaddi in the
amount of $450
11
Executed at Everett, Snohomish County Washin
12
13 CARL J. L WSBA# 834
Attorney for Andrew Scott
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 CARLJ. GAUL
Attomey at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
FILED
1 20 I~ APR 28 AH II: 0 I
2 SONYA KRASKI
COUNTY CLERK
3 SNOHOMISH CO. WASH
4
5
7 In Re the Marriage of: No.OS 3 02755 1
8 Andrew Scott Rife, CALENDAR NOTE (NTC)
Petitioner This form must be Hied wtU'I the Cerk not later than twelve
9 and (12) days preceding the date requested. SCI.CR 7(b)(2)(C).
Jennifer Rae Mehactdi, f/k/a Rife, Responses to motion must be filed five (SJ court days before
10 Respondent the hea~ng. ReplleS to responses must be filed three (3)
court days before the hear1ng.
11
12 AND TO: Jennifer Rae Mehaddi
AND TO: Veronica Freitas, Attorney for Jennifer Rae Mehaddi
13
FAMILY LAW / DOMESTIC CALENDAR - Date: May 16, 2014 at 9:00 a.m.
14 to trial dates. continuances, and
(Except matters relating
revisions) Nature of Hearing:
15 Court commissioner compel discovery
Department B or C, As Assigned
16 Matters set before a Court Commissioner will be assigned later to a particular department. The assignment will be
posted the day of the hearing. Extended motions are set by the Court Commissioner, not a party or counsel. If a
17 presentation, or if a particular Court Commissioner has already heard a recent motion on the matter, please indicate
Court Commissioner _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
18
WARNING: The moving party MUST CONFIRM by noon two (2) co ys prior to the hearing in
19 matter to be argued. Failure to notify the Court of a continuance r str· e y result In
SCLCR 7(b)(2)(E). This form cannot be used for trial settings. 2. 40(b)
20
Dated: April 25, 2014
21
22
Declaration of Service
23 I, CARLJ. GAUL, declare under penalty of perjury of the laws of the State of Washington, that on April 25, 2014,
sent via ABC Legal Messengers a copy of Motion and Declaration to Compel Discovery and a copy of the document to
24 hich this declaration is affixed, to the following persons, addressed as
25 Veronica Freitas
26 Seattie WA 98102
Executed at Everett, April 19, 2014
27
28
l'!il '" ~-,,·- ....
.•' .
•Ff LED
-
•
·201~.HAY -'.2 Pl1 2: liS'

1 .
1m~~111~111111~m11~1~1
,SONYA KRASKJ
2 GOUNTY.CLERK
, .SHOH01:1JSH .CO.
- ,WASH·-
3 CL 165~3065 ~ ' ' ' ~
4
5
COUNTY OF SNOHOMISH .
7
8
Andrew Scott Rife NO. 05 3 02-755 1
9 Petitioner,
and MOTION/DECLARATION FOR
10 AN ORDER TO SHOW .CAUSE
Jennifer Rae Mehaddl, f/kia Rife .RE- -
11 Respondent. CONTEMPT
MTSC
12
I. MOTION
15
1..1 FINDING CONTEMPT.
16
Finding contempt for failure to comply with'
17
the parenting plan/custody order
18
Signed by the court on O'ctober 24, 20·13 in Snohomish County WA in this
19 cause.
20 1.2 ESTABLiSHING A JUDGMENT.
21 Does not apply.
·22 1.3 GRANTING SANCTIONS.
23 Granting sanctions for contempt, including a forfeiture for each day the
contempt of court continues, and establishing conditions by which the
24 contempt may be purged and granting any other relief, including reasonable·
attorney fees and costs and make !.!P resiaential time. as may l:)e appropriate
25
CAIµ, J. GAUL
26
27 ·.
ORIGINAL. .
' _,,
Allorney at law.
3.Q2 Bank of America Bldg.
1604 Hewitt Ave.
Mot/Dec;Ord Show Cause re Contempt (MTSC) - Page I ·Everett WA 9820 I
WPF DRPSCU 05,0JOO Mandatory (612008)- RCW26,09.'160 425"259..(147 FAX 259 7001
1 under Chapter 7.21 RCW, Chapter 26.09 RCW, Chapter 26.10 RCW,
2
3 1.4 OTHER:
4 Andrew Scott Rife also requests an order specifically authorizing him to
provide transportation to and from all the child's practices and games without
5 regard to the residential schedule.
6 This motion is based upon the declaration whi , follows.
7
Dated: ~( / / ?_.,() / q ,. . ,. .,. ,. . .!.,<'~:ffrr...:;:~ir..4¥r.h---
8
9
II. DECLARATION
10
11
12
A. The October 24, 2013 parenting plan provides in part VI (page 10)
13
"-tEach parent will get the child to her practices and games
14 during their residential time."
15 Jennifer Mehaddi has refused to comply with this provision of the parenting
16 plan. She intentionally refused to get Lauren to her practices and games occurring
17 during her residential time on March 14, March 16, April 14, April 16, April 21 and
18 pril 28.
19 B. The October 24, 2013 parenting plan provides in part V (page 9)
20 "Disputes between the parties, other than child support disputes, shall be
submitted to (list person or agency):
21
[x] mediation by VOA-Dispute Resolution Center 425-339-1335 ... "
22
Jennifer Mehaddi refused to mediate in good faith. She appeared at the date
23
and time specified, but did not mediate.
24
25
CARLJ.GAUL
26 Allorney al Law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 2 Everett WA 9820 I
WP F DRPSC U 05. 0 I 00 Mandatory (612008) - RCW 26. 09. I 60 425 259-4147 FAX 259 7081
..
•
1 The Temporary Parenting Plan of October 24, 2013 was violated in the
2 following manner:
3 Background:
4 When Lauren began Kindergarten (academic year 2010-2011) Lauren began

5 spending significantly more time with me than she had previously. Jennifer
6 Mehaddi and I agreed she would begin playing organized soccer. She showed both
7 talent and enthusiasm for the sport. In the spring of 2011 Jennifer and I agreed that
8 he 2007 parenting plan simply did not reflect what we had been doing and intended
9 to continue to do as parents for our daughter. We wrote a new parenting plan we
10 both could agree upon.
11 March 25, 2011 the current permanent parenting plan 1 was entered. This
12 parenting plan somewhat documented Lauren's increased time with me. Even
13 en it was entered Lauren was actually spending more time with me than the
14 amount specified in the parenting plan. After entry of the March 25, 2011 parenting
15 plan Lauren's time with me continued to increase.
16 I have been employed by Snohomish County PUD No. 2 since 1999. My
17 ork hours are quite flexible. I can and do take time to be with Lauren and
18 participate in her daytime activities such as school. I can and do pick Lauren up
19 rom school, provide the after school activities such as snacks, homework, play
20 dates and sports and sometimes dinner. Lauren particularly loves soccer and
21 skiing. Especially on days Jennifer works late I have delivered Lauren to Jennifer's
22 home, or sometimes to her parents' home when she gets home, which would be
23 after the afternoon I evening activities..
24 1----------
1
25 Attachment 1
CARLJ.GAUL
26 Allomey at law
27 1604 Hewitt Ave.
WPF DRPSCU 05.0100 Mandatory (612008) - RCW 26.09.160 425 259-4147 FAX 259 7081
1 Lauren began playing league soccer in the fall of 2010. She has always
2 been more than enthusiastic about playing soccer. She is very good at it.
3 Lauren's skill and commitment to her soccer were truly impressive. Jennifer
4 and I learned about a select soccer league, Washington Rush. We discussed it with
5 each other and with Lauren. Part of what we discussed was that participation would
6 not be a single season because a player with advanced skills is unlikely to be happy
7 playing recreational league soccer with unskilled teammates and opponents. All
8 three of us agreed upon this commitment, and that Lauren would try out for this
9 competitive league and if accepted, that she would be participating more than just
10 one season. She tried out, and she qualified for Rush.
11 In the spring of 2013 Lauren was enrolled in the select soccer league,
12 ashington Rush. Jennifer was enthusiastic about Lauren and her involvement in
13 Rush. Lauren is now 9 years old. She plays above her age with 10 and 11 year old
14 players. And her coach praises her as the best player on the team.
15 It is important to remember that Lauren's registration with Washington Rush
16 is for a different duration than the seasons. Lauren's registration runs through
17 ugust, 2014.
18 Washington Rush practices and plays year round, with more practices and
19 games occurring in the spring and the fall and fewer in the winter and summer.
20 Jennifer was a supportive parent at first. See her May 10, 2013 text
21 message2 • Jennifer's work schedule made it difficult for her to attend or provide
22 Lauren's transportation to the practices or games. My work schedule made it
23
24 ,____ _ _ _ _ _ __
2
25 Attachment 2
CARL .J. GAUL
26 Allorney al Law
27 1604 Hewitt Ave.
•
1 convenient for me to attend.and provide Lauren's transportation to the practices and

2 games. I took the lead in .Lauren's soccer involvement.
3 .Until recently, Jennifer has been happy to have me facilitate Lauren's soccer
4 involvement. I did it as needed, at any time, without seeking any reimbursement of
5 cost or other consideration from Jennifer MehaddL I would o~dinarily provide
. 6 Lauren's transportation to and from the practices and games. If the activity was
7 scheduled during time Lauren was residing with her mother, I would pick her up .
8 (from school or Jennifer's home, sometimes at Jennifer's mother's) transport her to
9 the game or practice, then. deliver her to back afterward. Sometimes I would
10 ransport Jennifer. Sometimes I would provide money for gasJor Jennifer to be able
11 to attend the games. It was a successful systern. Lauren attE!nded all her practices
12 and played in all hergames in the 2012-2013 season. Jennifer Mehaddi was able
13 o attend some practices and four of the 11 games.
14 This pattern persisted from the beginning of Lauren's soccer activity until the
15 domestic violence at the end of July I beginning of August 2013. I was concerned
16 about Lauren's safety, and Jennifer's also. When I asked questions about the
17 situation Jennifer was unwilling to provide information about it. I asked if they· were
18 getting counseling or other service to reduce the risk of future similar incidents. I did
19 not try to determine fault or causation of the incident I was careful to not intrude.
20 into her marriag!!!. I was concerned that Lauren should not be in a violent
21 household. Jennifer's response was to tell me she would "back off on La_ureri's
22 soccer" if I petitioned for m_qdification of parenting plan .. I thought it was-curious that
23 she would.be concerned about modification of the parenting plan because it showed
24 hat she considered the domestic violence in her horne to be a prqblem that might
25
CARL J. GAUL
26 A11on;ey at Lmy
302 Bank of Amefica Bldg.
27 1604 Hewitt Ave.
MotiDec Ord Show Cause re Contempt (MTSCJ - Page '5 Everett WA98201
WPF'DRPSCU 05.0100 Mandatory(6/2008) -RCW 26.09.160 '425 259-4147 FAX 259.7081
•
1 ·ustify a modification of the parenting plan. But I did not understand why her threat
2 was against our daughter and the sport she loves.
3 L.auren's Practices and Games
4 I filed the petition for modification October 2, 2013. On October 24, 2013 the
5 court entered a temporary parenting plan. The Commissioner did not rule on
6 anything about transportation to sports events. But in negotiation of details in the
7 hallway Jennifer Mehaddi was arguing that she should transport our daughter for
8 the practices and games occurring during the time the child resides with her, rather
9 han having me provide this service. She and her attorney were quite insistent that
10 she could do the transportation and would do so. I was concerned that she would
11 actually get Lauren to the games and practices as she had previously been unable
12 to do so, due to her work schedules or the expense of transportation.
13 The solution was to include a provision in the court's temporary parenting
14 plan requiring each parent to get Lauren to her games and practices during our
15 respective residential times.
16 Since this action was filed Jennifer Mehaddi wrote that she considered the
17 soccer to be "too much" for our child. I had not noticed any difficulty, so I responded
18 by saying so, and providing some of Lauren's school work in which she expressed
19 her enthusiasm for soccer.
20 Lauren played indoor soccer in January and February 2013. Though indoor
21 is separate from Washington Rush, on October 22, 2013 the Rush coach wrote
22 about the upcoming indoor games4 • In then winter when the weather is worst there
231--~~~~~~~-
3
24 Attachment 3
4
25 Attachment 4
CARL .I. GAUL
26 Allorney al law
27 1604 Hewitt Ave.
WPF DRPSCU 05.0100 Mandatory (612008) - RCW 26.09.160 425 25!H147 FAX 259 7081
1 is indoor soccer. I responded that Lauren would want to participate 5. Jennifer
2 Mehaddi informed him Lauren would not participate6 • Jennifer then announced that
3 I had decided she would participate without her agreement, therefore as Lauren's
4 "primary parent" she had decided Lauren would not be playing indoor soccer7 •
5 At the time I was trying to find a way to reduce tensions between Jennifer and
6 me, so she and I talked about the subject. In the end, I agreed that Lauren would
7 not play indoor last winter, though she did play in the six games she wanted to
8 during the time she was with me. Rush resumed in late January.
9 March 10, 2014 the coach sent an emai18 about the practices being Mondays
10 and Wednesdays for the remainder of March and April. Practices would be 5:30 to
11 7:00 p.m. on March 10, 12, 17, 19, 24, 26 and 31, April 2, 7, 9, 14, 16, 21, 23, 28
12 and 30. Jennifer works at PolyClinic at Northgate until 7:00 p.m. on Wednesdays.
13 State Cup was scheduled for March 16 and March 23 in Olympia. Jennifer's
14 response was to blame me for the schedule set by the league9 .
15
16
17
5
Attachment 5
18
6
Attachment 6
19
7
Attachment 7
20
8
21 Attachment 8
9
22 Attachment 9. Jennifer misstates the facts. I do take Lauren skiing. I did not
ell her she could be on a ski team. She asked to be on a team and I told her she had a
23 lot of learning to do. Lauren's academics and health were not suffering. Jennifer refers
to a "consistent cold and cough" but no such health problem existed. Jennifer asked
24
me to not register her for anything until after mediation. Then Jennifer attended a
25 mediation session, but did not mediate.
CARLJ.GAUL
26 Allorney at Law
27 1604 Hewitt Ave.
WPF DRPSCU 05.0100 Mandatory (612008)-RCW 26.09.160 425 259-4147 FAX 259 7081
1 Jennifer Mehaddi's next complaint was that Lauren was too tired and her
2 school work was suffering as a result of the soccer. She also complained that
3 Lauren has Obstructive Airway Disease which is a very mild form of childhood
4 asthma. Again, I had not noticed any such problem, so I asked the classroom
5 teacher and the team coach who both responded that Lauren is doing fine, has
6 plenty of energy and enthusiasm. I scheduled an examination by Lauren's
7 pediatrician to verify whether there might be a medical reason to limit the soccer
8 participation. The doctor did not find such a reason and also commented that
9 soccer is one of the best forms of exercise for people with asthma 10 • Jennifer
10 agreed to attend the doctor's appointment, but added that Lauren is "so tired all the
11 time. 11 "
12 I wanted to be sure that I was not missing something about Lauren. If she
13 really was tired all the time, or had a persistent cough I had not noticed or if there
14 was some other problem I would want to do whatever might be necessary to
15 remedy the problem. So I also sent emails to the classroom teacher, Mrs.
16
17
18
19
201--~~~~~~~-
10
21 Attachment 10. I was concerned about a multiple subjects. I was and I
continue to be happy to mediate our differences, and I told Jennifer I was starting the
22 mediation process. Another subject was that continuing Lauren's participation in Rush
requires renewing the registration, so I would handle the registration to be sure the
23 opportunity would not be lost. Third was the health claim so I scheduled a medical
24 checkup for Jennifer's next day off, March 13, 2014.
11
25 Attachment 11
CARLJ.GAUL
26 Allomey at law
27 1604 Hewin Ave.
M01/Dec Ord Show Cause re Contempt (MTSC) - Page 8 Everett WA 9820 I
WPF DRPSCU 05.0100 Mandatory (612008) - RCW 26.09.160 425 259-'1147 FAX 259 7081
..
1 Houghton 12 , and to the two coaches, Rich Hansen 13 and Josten Geralde14 • Jennifer
2 and I attended Lauren's physical examination. The doctor did find slight asthma,
3 but recommended sports and being active. She said that soccer is one of the best
4 activities for a child with asthma. She declined to address Jennifer's questions
5 about whether Lauren needed a break from soccer.
6 March 16 Contempt
7 On March 13, 2014 Lauren's Rush coach, Rich Hansen sent Jennifer
8 Mehaddi an email 15 informing her that the State Cup competition would occur on
9 the next two Sundays, March 16 and March 23.
10 The next morning, March 14, 2014 Jennifer Mehaddi responded that Lauren
11 ould not be at the games on March 16 because " ...this Sunday we have family
12 plans and Lauren will not be able to make the state cup in Olympia .. 16" Jennifer
13 Mehaddi sent me a copy of the two emails. Thinking that the location (in Olympia)
14 might be the reason for Lauren not participating, I volunteered to take Lauren to her.
15 My offer was refused. Lauren spent Saturday night at a sleep-over at her cousins'
16 home in Everett.
17
18
19 L - - - - - - - - - - -
12
20 Attachment 12, my email and Mrs. Houghton's response
13
21 Attachment 13, my email and coach Rich Hansen's response
14
22 Attachment 14, my email and coach Josten Geralde's response
15
23 Attachment 15, which repeats the same information as his March 10, 2014
24 email, Attachment 8.
16
25 Attachment 16
CARLJ.GAUL
26 Allomey al Law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MfSC) - Page 9 Everett WA 9820 I
WPF DRPSCU05.0100Manda1ory (612008) - RCW 26.09.160 425 259-4147 FAX 259 7081
•.
1 March 22, 2014 Jennifer Mehaddi, again supportive, sent a text message17
2 "Tell Lauren I said good luck at her game and that I'm thinking about her."
3 Monday, March 31, 2014, Lauren attended practice even though it was on
4 her mother's residential day.
5 April 16 Contempt
6 On Wednesday, April 918 coach Josten Garalde sent an email that for the
7 remainder of April the practices would be on Mondays and Wednesdays for the rest
8 of April. (April 14, 16, 21, 23, 28 and 30).
9 Jennifer Mehaddi responded the same day that "Lauren will not be at practice
10 next week. A decision regarding soccer will be made at the end of the month. Mr.
11 Rife is aware of this as I have not agreed to further practices/games at this point."
12 On Wednesday April 16 I sent an email 19 to Jennifer Mehaddi that there was
13 a practice at 5:30. I knew that Wednesday is her day to work until 7:00, so I
14 reminded her:
15 Also, the parenting plan also requires each parent to get
Lauren to her games and practices. She has a practice this
16 evening at 5:30 at Kasch Park. If there is a need to get Lauren
to practice, before it commences, I am happy to pick her up from
17 wherever she is and get there."
18 She responded 20 :
19 Soccer for the season is over. She will not be going to
practice. See you at mediation.
20
21
17
Attachment 17
22
18
Attachment 18
23
19
24 Attachment 19
20
25 Attachment 20
CARLJ.GAUL
26 Allorney at Law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MI'SC) - Page 10 Everett WA 98201
1 Lauren was not at practice on April 16.
2 April 21 Contempt
3 On April 20, 2014 the entire team was senfa practiee schedule21 . Separate
4 emails went to Lauren at my email address and at her mother's email address.
5 L~uren was\with her mother on·April.21, 2014. She was.notat the scheduled
6 practice,
7 On Wednesday April 23 .Lauren was with me. She was insistent that she
8 ould make itto that pr~ctice, and wanted rne to ta!<e her early so she could get
9 some· additional.soccer time with h·er friends, I took her. She was the happiest kid.
10 Jennifer was angry with me for having taken Lauren to the practice without .her
11 permissicm.
12 April 28 Contempt.
13' Lauren was not at the April 28 practice.. The practice was during time she
14 as si:;heduledto be with her mother.
15 REFUSAL TO MEDIATE
16 Tl'le parenting plan, pa~ V, requires dispute~ between the parents to be
17 mediated. Jennifer Mehaddi refused to mediate in good faith.
18 In. late March I wrote to.Jennifer Mehaddi that we had. a dispute about soccer.
19 The parenting plan requires mediation, so we needed to mediate it. Stie appeared
20 o nave unilaterally decided to remove Lauren from soccer-. Removing her would
21 necessarily· be a joint decision. I did not expect her to accept mediation because
22 st:ie had refused to mediate twiee before, To my surprise she agreed to mediation.
23 It was scheduled for April'24, 2014 at Volunteers of America.
24 1 - - - - - - - - - -
25 'ii Attachment21
CARLJ.GAUL
26 Allomey ai Law
302 Bank o'f America Bldg.
27 1604 Hewitt Ave.
Mot/Dec Ord Show Ciiuse re Contempt (MISC) - Page i I Everett WA 9820 I
WPFDRPSCU 05,0100 Manda!ory (612008) - RCW 26.09.160 425 259-4147 FAX 259 7081 ·
..
1 At the commencement of mediation Jennifer said that soccer was "too much."
2 In response to questions she said that soccer was taking up too much family time,
3 that she was getting home too late and she was too tired.
4 I pointed out that Lauren's pediatrician did not find a health problem and
5 specifically recommended soccer. Then she complained that after soccer Lauren is
6 oo tired to do her homework. I responded that her teacher reports she is doing well
7 academically and that Lauren has time to do her homework between the release
8 rom school in the afternoon and when soccer practice starts. That is when she
9 does her homework when she is with me, and she could do the same when with
10 Jennifer. I do not know when she does homework at her mother's but doing it early
11 might help.
12 I explained that I had requested mediation because we had agreed to
13 Lauren's participation in Rush soccer and there was no agreement between
14 Jennifer and me to withdraw her. Jennifer's response was to angrily state that there
15 ill not be joint decision making after trial, she has decided that Lauren will no
16 longer be in Rush soccer and that she has already signed her up for a different
17 soccer program in Snohomish. I then said that the result of the trial next July is not
18 yet known, and we need to comply with the parenting plan we have. Lauren is still
19 registered with Washington Rush, and her team is still practicing. Jennifer
20 expressed her anger that I took her to practice on April 23.
21 We took a break. After the break, I tried to suggest that I can pick Lauren up
22 rom school on her activity days and get her to soccer, and deliver her to Jennifer
23 Mehaddi's afterward, as I did for three years. She was not willing to consider it and
24 she was not willing to discuss it. I said that Lauren loves this sport, that she
25
CARLJ.GAUL
26 Allorney at law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 12 Everett WA 98201
-.
1 participates at an advanced level. I also said that if.we are both looking for solutions
2 e cari, find one that allows Lauren to continue. I was intending to discuss adjusting
3 he residential schedule so that Lauren would be with me on soccer days and with
4 Jennifer on non-soccer cjays. It might not be a. complete solution but could have
5 been a partial solution.
6 Instead of discussing possible solutic;ms·thatmight facilitate Lauren's soccer
7' participation while preserving residential time with her mother, .Jennifer just sat still
8 and .speechless. Her face became red.and got· redder .. One of the mediators asked
9 her if she wanted to continue the mediation process. She said "No" and she got up
10 and walked out.
11 Jennifer Mehaddi should be found in contempt for her refusal to mediate in
12 good faith. I tried to emphasize that we need to comply with the parenting plan we·
13 t:iave, and that we should look for solutions to our present impasse. She did not
14- make one suggestion looking for middle ground. Her position was that Lauren will
15 not participate at !'Ill, rega_rdless whether Lauren is with Jennifer or with me. Period.
16 Jennifer Mehaddi appeared at Volunteers of America. She did nothing to mediate.
17
. I declare under penalfy of perjury u11der the laws of the state of Washington
18 that the foregoing is true and correct. . .
19
20 Signed a1&eA.Jtif, W/f
21 [C1fy and State]
22 Dated: >jt//<f
23
24
25
CARLJ •. GAUL
26 Allorney at Law
302.Bank ofAmerica Bldg.
27 1604 Hewin Ave.
Mot/Dec Ol:d Show Cause re Contempt (MTS<::)- Page 13 Everen WA 9820 I
WPF DRPSC(J 05.0100 Mandatory (612008) - RCW 26.09.160 425 259-4147 FAX 259 7081.
..
IN~E>C'TO ATTACHME~:TS
1. October 24, 2013 Temporary Parenting'Plan

2' May 10, 2013 text message, Jennifer Mehaddl to Andrew Rife
3. Lauren's."soccer house" writing assignment
A. October 22, 2013 email, from coach Rich Hansen about Indoor soccer
5. Email October 22, 2013, Andrew Rife to Rich Hansen
6. Email October 22, 2013, Jennifer Mehaddi to Rich Hansen
7. Email October 22, 2013, Jer:inifer Mehaddl to Rich .Harsen
8~ Em.ail Marth.10, 20141,Josten Garalde to Jennifer MehadcU
9. Email March 10; 2014, Jennifer Mehaddl to Andrew Rife
10. Email March fl, 2014,.Andrew Rife.to Jennifer Mehaddi
11. Email March 11, 2014, Jennifer Mehaddi to Andrew Rife
12. Email March 11, 2014;.Andrew Rife to Bernie Houghton and response
13. Email March 12, 2014, Andrew Rifeto.Rich.Hansen, and response
14. Email March 12, 2014, Andrew Rife' to Josten Garalde, and response
15. Email, March 13, 2014, Rich Hansen to J~nnifer Mehaddi
16. Email, March 14, 2014,Jennifer Mehaddi to Rich Hansen
17. Text Message, March 22,.2014, Jennifer Mehaddi to Andrew Rife
18. Email, April 9~ 20141 Josten Garalde toTeam, and response.fromJenilifer
Mehaddi
19. Email, April 16, 2014, Andrew Rife to Jennifer Mehaddi [redacted]
20. Email, Aprll 16, 2014, Jennifer Mehaddi to Andrew Rife and response
21. Email, April 20, 2014, Josten Garalde to Team
Attachment 1
.·
Supeiioc COw:t.o.f.. asblngton

· County of S~ohom1 h
No. O? -~ - o '2.'7'=7" S _ )
·Petitioner,
,e·.
. Parenting ·p1an .
oaact..(eee~-
Tlimporai'y (PPn.
[ . lnal Order(PPl
. '
This paremmg plaD is:

·[] thetinalp. · · plaD signed by~ court p\Jl'Sl1811t to a decree of dissolution, legal
separation. 'clcC!araiion concerning validil:fsigiled by tb_e court·on this date or
. [] . . :~-:n-~1-·..-'-i-..-g-p-lan-_-si_gq....ed_b_y"""'ih~ court piriwmt to 811 ol'der signed by the court on
· this date or whicb ~es a previous p8nmiing
.. .pla!i or .
.9 a tcmporazy
.'O' proposed by
-
It Is Ordered, AdJudged·and
!. .
i:>e~reed: ..
L General l!'fonnatlo~
Thisp~plallapplies tot followmg_chil~
.
.·...
. .· ~rsa-c_
· ~/q, ·.
'?'
Parenting Plan (PPP, PPJ'. PP ,·!>age 1 ol 11 . . ~.# .
WPF DR 01.0400 Mandaloty ~ 008) • RCW 26.09.016,. /&~(94,
· Attachment 1
II. ·easls for Restrictions
Under certain circumstanc s, as ouUined below, the court mey limit or prohibit a parenrs
contact with the chl/d(ren) nd the right to make decisions for the child{ren).
2.1 Parental Condu t (RCW 26.09.191 (1 ), (2)) \) . jJ .I~ J

I"
. .·\~~--,·
[] Does not y.
(] The "ti er's [] respondc:nt's residential time the child(ron) Shall bo limited r
:straWie~i!l'~letely, and mutual decision-ni•king and designation of a dispute
'IV""~·othcr than court action shall not be required, because [] this parent
idiiig · this parent has engaged in the conduct which follows:
[] abandonmmit continues for an extendOd periOd of time or substan

to perform parentin ctions (tliis .applies only to parents, not to a
pcrsqn who i'esides with a pare~
[] Pbys cal, sexual or a pattern ofem1ot!lilll81 abuse of a child.
[] A · of&Cts of domestic violence . ed in RCW 26.50.010(1) or an
t or sexual assault which causes grievo · y harm or the fear of
2.2 w26.09. ~ 91(3)) \2....e..s.A.-/'V'..L-J__

[]
[l 's []respondent's invoivemllllt or conduct nia:y have an adverse efii
c.lm~~·s·best intcRBts boc•nso of the existence-ofthit&:Ms which follow:
[l
[]
[]
[1
[l ivc use of conflict by the which crcalcs the danger of serious
damlll8eto tho child's _psychological deve ent
[] ,.-,.--has withheld from the otha parent to the child for a pro1tracte<IJ
wi1hout good-.-· · · '
[l
Pamnting Plan. (PPP. PPT, P - Page 2 of 11

WPF DR 01.0400 Mandatory 8)-RCW26.09.016, .181; .187; .194
'.
'
The residential schedule· ust 'set forth where the chlld(ren) shall raSlde each day of tlie year,
including.Provisions for h '/days,_bl/thdays offamily members, 1tacstioils, and (Jther special
occasions, and.what cont ct the chlld(ren) shall have wjth each pBfT!rit; Parents em encourage<!
tiHwet&.a.tet#t/91itla/ sch ule-lhel-m&et&the developmentsJ.nfied&dlh&thlld(ren) end
individual needs· of their fa fly. paragraphs 3.1 through 3.9 are one way tg write your
residential sched_ule. If yo do nofuse· these paragraphs, Write in your own Schedule In
Paragraph 3.13. · · · · ·
. ..
3.1 · Schedule for ~h ldren Under: School Age · .
. There are no ohildreil lll1dCr school age. .
Prior to eliro . ent in school, the child(ren) s!iall reside with th.e" [ ] petitioner :
[]respond · except for the followjiig.days. lind times when ihe child(ren) will reside
With or be the oilier patent · · ·. · ' ·· ·· .
_ _ _ _ _ _ _ to (day and time)·----'----
[] week [ ] every other week [ ] the first and third week of the month
. [] ·· and'feuR!tweck efth11mondi-[.}o!lli:r: ·
from (day an limll) _ _ _ _ _ _ _ to (day and time) _ _ _ _ ___,_
[] CVf'ltY week [.] t:'if'ltY other week [ ] the first and third week of the ·month
.. ... . [] the imd fourth Week ofthe_month [_]other: ·
3.2 School Schedul'

Upon enrollment in ool, the child(ri:n) shall reside with the [ ] petitioner .
~respondent, Blccept · the fyllowing days and timea when tho child(nm) will reside with or he
with the other parent:
. .,. c..J- -,
..J+-
.
, · . ·
s;.i-1 · io. &r,,r ..,, -4--~cJ.., _..,.,
· I
.. a,,
. ...-.J......
from (day ·and • ) .. to (day and time) · . · ·. · · "''1 ·
.V..-. T\.i.r.r..,., a.l+.1> ~ u.....1· t.. ·cWJ: ;o _Iii' . Q, Wfl ~~&If
[]
"[]
eet-fi(I eveiy other week [] the first and .third week of the month
an~ fourfh ~ ~tho·month [) other. ·. ·
"'=..j _
c..-t .· .q H- ~ t. '-.io I
From (day and •• ) f J Th~"1 ~~ (d8y ~-tiJ!ie) ~JO, ~;:,,
.)rot ·d°" .s c.hoa:\ . · . · . · · . I
[] evmy every other week [].the first and third· wCelC of the month
[l the BP:d fourth week of the month n• ..
Parrmtlng Plan (PPP, PPT. PP) Page 3 Of 11 . . .

WPF DR 01.0400 Mf1tldafory ~ 008) ~ RCW 26.09.0_16; .181; .187; .194
..
. . ·. .
[] · . The school hedule willstart when each child begins [ ] kindergar!Cn [] first grade
[ J otlier: · · ·
· 3.3 Schedule for WI ter Va~tlon
The child(ren) shall ·do with the [.] petitioner [ ] reSpondent during winter vacation, excep
for tho following and times when the child(nm) will reside with or be with the other paren
<&)""".........,..-c. a-.. . ~ :~ 1-z..""5 ( '2.. D l I
"~~~
3.4 · Schedule fOr er School Breaks
'Ibe chilcl(nm) shall · with the [ ] petiliODer [ ] respondent during other school ~
except for the·follo · g clays and times 'Wb'en thrr cbild(renrMJl"reside witlror !Xi with the o er
parent·
q.,.,...,~
3.5 Summer Schedu a
Upon completion of .. school year, the child(ren) shall.reside with the [] petitioner
[ ] respondent; except for the followiiig days and times when the chilcl(ren) will reside with. o be
with the other parent . . · · ·· ·
(14, . Same as sch : I ym.sehedule.

[] Other:. .
3.6
[].
[]
Parenting Plan (PPP, PPT,.PP - Page 4of11 .

WPFDR 01.040f!Mandatory~ . 8) ·RCW28.09.016, .161;.1W; .194
3.7 Schedule for Ho ldays
~;ie..,,...,...2,1 .. ~ ~ . ""3 ( '2JS {-v ( (

· . With Petitioner
'° .
ule for 1he ~ren) ~the holidays listed below is BS fo~ciws:
c ~ •
. .With Respon
·
. , (Speci:fy¥ear.. . (Sp@cify Year· .

· · Qdd/Eyen/EveOO · · Odd/Even/Eyery)
. NewYear'sDay
Martin Luther King ay
f.
Presidents' Day ·
Meuiorial.Day "'
. July4th
Labor Day·
Vetermis' Day
Thanksgiving Day
Christmas Eve
Christmas Day
. .
[] For pU?pOSeS fthis parenting plan, a holiday shall begin·and end BS folio~ (set forth
times): .
II .
[] Holl~. whir fiill on a Fri~ 0r a Mon~~ in!)lude Saiurday an!f Sunday.
·[ ] . Other:. . .
3.8 Schedule for Sp cial Occasions
,:,...~
[] . Other:
·I . :
. ~ ....
Parenting Plan (PPP, PPT. PP ·Paga 5-of 11 . · . .
WPF DR ()1.0400 Mandaiwy. ~ . 008)- RCW 26.0~.016, .181;. 187; .194
. .. I
I
I
' .
3.9 Priorities Unde• ~' Rosldontlol Schodu~

Il 0oes not app~ because·on:e parent has no .visitation or restric:ieci visitation. · ·
Fl., Paragraphs 3p -·3 .8, have priilrity over Jl!ll'8.P~hs 3..l and 32, in .tho fellowing. order:
[·] . RaniJIthe Older of priori~, wi1h 1 being given. the. highest priority:. · .
-'-'-"'·.. _.tervacatio~ (33) 3 holidays (3.7) · · ·

chool breaks (3.4) · Ispecial occasions (3.8)
~:::IJUmm.erscbedule (3.S) .j_VBCl¢ion with parents (3.6) ·
.[] .Olhl
3.10 .Restriction~
I ·1 .
1
';;tf[ DQes not app' because there are no limitiag filctors in para~bs 2.1 or 22.
The (] petiti · er's [] respoadont's residential time with 1he children shall be limited
!Jec:ause 1h are limiting mCtors in paragraphs 2.1 and ~2. ·The following 'rcstrictioas
shall apply en the Children spend time with thili parent
l. . ..
j ..
. . . . .
. - . .· .
[] There are $8 ~ in paragraph 2.2, bat there ere. no restrlctions on the .
[] petitioaer's [] respoadent's residential time with the children for the foll~g
ressons: I . . .. . .
I ..
I
I
3.11 TransportaUcm . ngements
. ...
., .
·included in the Child Siipport Wiuksheets ancl/or the order of Child ·
T~on
. ~~ ~
arranr
suppozi and shoald · be lnclwled here. . · ·
for the child(ron), betWeen piron11 shall be as follows:
~· '3/Z-7/-:u t<
. . ·1·1~'t£L-· .n~
Parenting Ptan (PPP, PPT. PP)- Pag11 of 11 6 '.

WPF DR 01.. 0400 Mandatory ~r008)-R~W:26.09.0.16, .1~1~ .187; .194
."
. ~
3.12
3.:13
. i . .
3.14 Su~mary of Rcvy 26.09.~0 • .480, Regarding Relocation of a Child
., . . . . .
This is a Slllllilllll)' ~-For lhe full text, please see RJ;W 26.09.430 through 26.09.480.
If lhe person with·whE'tb_e child resides a majority ot~e time plans to mov~ ·that ~on shall
· give notice to ev~ . .
If.die move is oulside e child's •i
entitlod to oourt.ordcrcd time.with the child. ·
distii~ the rel~ pei-son ~ust give notice by
pezsonal servi~ o.t. by lni4i1 reqµiring,a rJlfum =ipt. ,This, lllltic=.mnst.be;et least 60:!18Ys biifore
. 1he Intended move.· If~ re!OC!'i"g peniou could not have.kn.own about the move .in time to give
. 60 deys~ notice, that~·· .must give notice within S daya_atter learning. of the move; Tho
notice must contain th. information required in RCW. 26,09.44<>. See also fonn DRPSCU
07.0SOO, (Notice of . ded ReJocatioil ¢A Child): · .. · .
irthe move ia Withh:i f4e same schoOl .~ct, _the·reJocatlng pers0n must provide~ notice by
BDY re&SOnable mlialls.l _,,·per!IGltCDtitled I& tim~-thO"cbilchnat not-ol!jecl, loihO"mave-but· ·
. may ask for modificetibD, llllder RCW 26.09.260. · · · · .
Notice may bo delaycid4lfor 2i. deys if1he relocating pers0n is~ a domestic violence sheltei-
or .is mOV'lng to avoid· ·cleat, lmlliediate and umeaSonable risk to health and safety. · ·
. . ·. . . . . . .
I -
Pa.renting Plan (PPP, PPT, PPJ\· ~ 7 of-11 . ·. . ...

WPF DR01.0400 Mandatory (6(2008) -RCW26.09;016, .181; .187; .194
.
.r
I
I
.. I
Ifinfonnation is prtjteeted unclcr a court order or the addRss confidentiality program, it may be
withheld from the njitice. · ·
A relocating.person ~y~ the court to waive any notice requirements that i;nay put the health .
and safety of a pers~n or a child at risk.
Failwe te-givo.~JtqUiseO-notice may be grounds for sanetio~ inclllllifig eolltempt.
. I , .
Ifno objection Is filed within 30 days after ser,vice oltbe notice of Intended relocation, the
rdocation.'!'riJl be p~tred and tbe proposed revised residential schedule may be
confirmed. , ·
'
A person entitled to tune with a child under a court order can file an objection·to the child's
rolocati011whe:th.er.of DOt be or eho roceived proper notico- .....
An objection may bd filed by using the ~datory Pattem form WPF DRPSCU 07.0700,
'
(Objection to R.cl~OJl/Petition for Modificatjon ofCUstody.~erenting Plan/Residential
Scliedulo). The objTon must be Served on all persons ontitled to timo with tho child. .
The relocating person shall not move the child during the timo for objoction unless: (a) the .
'delayed noti.ce provi¥ons apply; or· (b) a court order allows tho movo. ·
If the objecting penqn schedliles a hearing for a date within 15 days of timely servico of the
objeotiozi. the reloc+g person shall not move the child before the .hearing~. there is a
clear, immtidiale and~le risk to the health or safety of a person or a child. .
IV. Decision Making

4.1 Day-to-Day Decl~ions
Each parent .shall maJfe decisions regarding the day-to-day care and control of~ child while
the' child is residing~ thJit parent Regardless of the alloeation of deeision making in this
pan:nting p!asi, coithcr~may make e:mergoncy cleciJiuns afi'ectingtlnrlrellldronafety of the
children.
4.2 . Major Decisions !'

;
Major decisions regatjling each child shall be made 1111 follows:
. !
Educafion decisionil! (] petitioner [] respondent · ~ joint
. ~~~~ergencyb.:.. h~ care [] . petitioner · [ ] respondent ~ join~ '
ADUglOUS Up nDglllg · . [) petitioner [] · respondont W joint
. ""' [] petitioner · [] respondent [] joint
· [] petitioner [ ] respondent [ ] joint
[] petitioner [ J respondent [] joint
[] petitioner · [] re5ponclent [] joint
[] p¢tioner [ ] respondent [ 1· joint
[ J• • petltlinler rr·· respondliir'" rJ. joint
Parenting Plari{PPP, PPT. PPJ;- Page 8of11

WPF DR 01.0400 Mandatory (&-200B)-RCW26.09.016, .181; .187; .194
. .
4.3 · Restrictions in ~ecision Making
. I
fi Does llOt appJY ~nse tbm ~no l~g factcr.i in piiragraphs.2.1 and 2.2 above.
"1i . Sole ~ioi) making shall be. ordered to the [ ]petitioner [ ] respondeµt for the
· · following te8sons:
...
[] ·A !lljmation mi the other parent's deciSion making Bllthority is mandated by .
R.CW-26.09.191(See'paragi-aph2.1). . .
[J Bot!I parems are oPJlosed to mutaal decision making: .· .
[ J. One parent is opposed to mutual. deCisioiJ. making, and suCh opposition is
reascinably
' based
. OD the following-criteria:
. . .
I . .
(a} ! The BXistmce ofa limitatiO;D unilllr RCW 26.09.191;
(b} \ thO histo~ of partiCipl!tiOB ¢'each parent ~ decision making in each of
· , · the.areas m RCW 26.09.184(4Xa); .
(c) ; ·Whether the puenta have demonstrated ability and desire to cooperate
! · With one another in decifilon mB!cing in each of the areas in·
; RCW 26.09.184(4)(a); and
(d) ! The parents' gecgraphic ProxmmY to one another, tO the extent that it
I --~their ability to make timely inutua1 decisions.
.j
[] There are ~g factcr.i ia_parasraph 2.2, but there are no restrictions· on mutual
decision making for the following ?e11S9DS: ·
. .! . . .
i
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_,;
i. v. Dispute R&sohitlori
. . I .
The purpose of this dlspute/esolution process Is to ~e disagreements about carrying out.
this p81enting plan. ·This di~pute resolution· process _may, and under some local eourt rules or
the provisions Ofth/s plan must be used before_ filing a petit/~ to modify the plan or a mot/on for
contempt for fBHlng ta.fallow the plan. · · · · • · · · · ·.
' . I • '
'I . ' .
l'f:j_ · Disputes between the pmties, other than child support disputeS, shall .be silbmitted ti> (list person
.orageucy}: .\ .. .. : . :
I, . .•
!
[] co1111SOlingby;I ~~---..,~~~~~~-'-~~--'
or
I •
. ot mediation by ! VOA-Dimpte Resglutlon Cente.r425-339-1335, if this box is checked

and isSues of ~c vfolence or Child abuse ere~ thim the court finds that-the
victim rcquestC4 mocllaiion; tbllrme'diafion is appropriite illicrtnat"tlleYl~ is.permitted
to have a·~ person present ch!ring the mediation p:oc-eedingil, or. .
[] ubiiratiouby~~~~~~~~~~~~~-
1
· Parenting.Plan (PPP, PPT,. PP)'- Page 9 of11 .

WPF DR.01.0400 Mimdatory.(812008)-RCW
. '
26.09.016, .181; .187; .194
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The eost of
.
this+. I
shall~ allocated between the parties as follows:
. ,
[] · . I% potitiolllll' % respond.mt
.
~ .based ilD eafb
paity'spro.P<J.ltiOnal shaie of income frOm line 6 of the child silpport
WO!ksheets. ' .. ' ; .
[] as d~~ iD the dispute resolution process. · · · ·.
:. . .
The dispute resol• process shall be commenced by~ the other party by [] written
request [ ] ·certified ijWl [ l. other. · ·
. In the dispute resolujion prQCCSS:

. ; .
(a) Preference s1ialJ lie-given to·~ out this Parenting Plan. . .
(b) Unle.u an ~c:rgency eXis1s, the parents shall ase the desipted p~ss to resoI:ve ·
.disputes .re~ to implementation ·of the plan; except those .related to financi!ll support.
(c) of
A written recloni shall be prepMed any agreement reached in counseling or mediation
and of each ilibitration awaid and shall be provided to each party. .
(d) If the comtfinds thataparmit has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys' fees and finmwilil sanctions to the
"otber parent.'.! .
. . : . . . . ..
(e) The parties ~ve the right of review from the dispute n;solutionpmcess to the superior
court..· i .·. . .....
I' .
. i
! VI.. Other Provisions
[l There are no other ~ons. ·.

M .. ··~are the foilawil)g other )irovisiolis• · · . · · · . · · · _.....,.
C°-t.&p1-- 0 ~1tc:L.-~~ V> :\ ~.~ ~c:l>-v-. J.:
/Lii"
0
1 J,
~-r-T"'1 \I ~
L L .
. {. .
r J"'\ ~
"3 I?...'?. I~" {{' · th":-R
' .
.._.
• -d._L _,,_ef- - . .
". Co~
0
~ ~._·
!
•
- .'
_ r·r-
I
e" J... f J. .1.::\I ,:..r ~' c. ~ J.
to ~- t' "" cA-t t-
-~ -:i.-._jd ..... , ..fh..:r .-.c~'-" ~ h<M.·
•·
... . . .
Parenting Plan (PPP, PPT.-PP).- _Page· 10 of11 _

WPFDR01.0400M!lncletory.(612008)-RCW28:09.~8, .181; .187;·.194
,.
,..
VII. i·oeclaration for Proposed Pare~tfng Plan

'
!
. Fi Does not apply; ,

(Only sign if this is 4proposed panmiing.plan.) I declare under penalty ofp~wy under the laws
of the state of Washington that this plan.has been proposed in good faith and that the statements
in Pmt n ofthiS Plml are tru~ and comx:t. ·· . · . · . . .
Petitioner I
D~ and Place of Signature
'
Date and Place.of Signature .
- · It js,ordered, adjudged line! #:reed that the parenting pJan ~forth above ls adopted and ~ved as an
order "of this court· ' ·
WARNING:. Violation ofn$i~tial proyisions of this~ with 8ctual knowledge qf its tenns is
punishable by contrmpt of co!irt
and may be a criminal Offense .under RCW 9A40.060(2) oi'
9A40.070(2). Violation oftl!is order may subject a violator 'to am.¢.
. I - • •
When muniBI decision m•!cing·is ~gnated but cannot be eclii.evcd, the parties shall make agood faith
effort to resolye the i.ssue.thn:jugh the dispute resoliition ~· . :
I
If a parent fiiils to comply with a provision oftbls:plan, the other parent's obligations under the plan ere
not afrected. ·. J · . .
,,.,. 'licT :2~4[201J (J!jfif?,1~/&vudu.'L

' Commlss oner
. ·.·' .
..:Appro:for/1 .·. . .
~ ciJ'P~·or Lawyer/WSBANo: /W~
V=tN.Uu- -6i:.bia .
PriDtNanio . ·PzintName
.·
·..
Parenting Plan (PPP, PPT, PP),' - Page 11 Of.11

WPF DR 01.04()() M11nd11lory(tf200B) -RCW~6.09.016, .181; .187; .194
. '.
. . . ''
1
~·
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..- ( •
•
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Fl.LED
·- 2011 HAR 25 PH ~1 1:3
SONYA KRASKI
COUHTY CLERK
SNOHOHISH CO. WASH
Superior Cou~ of ashl'19ton

County of
In.~ lhe Paraitilig and of: .
No. ~-02755-1
Lauien Emily Rife Olild(rm)
Parenting Plan
Andrew ScOU Rife Pedlioaer
[ ] Proposed (PPP)
and [ J Temporary. (PPT}
[ X] Flnal Order (PP)
.Jeonlrer LeSoUrd •·
This parenting.plan is:
£I the filial signed by the COllrl puml8Dt IO a judplent and order establisbing
Resi.denlial
dllled......_ _ _+-+-_ _ ling_Plan/Oiild
· _ _ __ signed by the coun on Ibis date or
_ _ _ _Support
[ii I the final an Biped by die court punwmt to.Bil onler signed by, the coun on. !his.elate
or daled _ l whldt modifies a pn:viOllB parenting·
plan or custody Cll;CllllC.
[) a tempmmy g plan signed by tbc eollrt.
n p1oposedby( >----------~
L General lnformatlon
This parenting plan appllels lllefollowing cllildren:
Lainn Emily "fe 6

OR\G\NAL
. I
Pat8nliilg Plan (PPP, P) • Page 1Ot 10
WP/' PS 15.0600Mllndaljirj(&'a10B) • RCW aa&.S7S, 28.09.016, •181:. 187:. 194
11
.. ..
•
11. 88888 ror Res1rlctlona

UndBr CS/tBln cltcunultall~. as outllnsd below, the court may 6nvl orptDhlblt apa1811fs
contsct wtrll the chUcl(o the rigid to make dsdslons for the t:hlld(1811).
2.1 Parental Concl (RCW 26Jl9.191(1), (2))
[XJ Doesnot 'I·

[) The ()mo a [) fadler'siaidelllial lime wllh die child(rcn) shall be llmill:dor
restrained ~llllet~y. and mutual dccislmHnaldng and designalion of a dispute
resolution Olher llum court acdoa sllall DOI be n:quiml bec:ause [ ) lhls parent
()a ding with tbls pamit bu Cugaged in the conduct wh!cb follows:
[) Willful abandonmeDl that COlllillUCS for an cxlellded period of time or substantial

ID pd Ii» m pan:ntiag fUnctiOlll (lhls applies oaly to parents, not to a
who .aides wilh a pamit).
[] PbVljjQJ, &Uual or a pattens of emadOllll abuse of a dlild.
() lhiiUlrtY or acts nf domestic violeiice as defined in RCW 26.S0.010(1) or an
t or sexual assault wbieb c:au&ea grievous bodily harm or the fear of sudl
2.2 cw 26.0S.191(3))
[X) Does not ly.
() The() mQiljer's
I ()father's involvement or conduct may have an adverse~ on lbe
dlild's nterellS because or die exll- or the l'Kun which follow:
(] ~Ject or submmlial nllllpdfonmnce of parenting functions.

() or physical lmpalrmeDt which iutcrfera with the
~*'«rlD ,eie11mnclOll.i110DBI
pf:rf~1111:e of pan:uting fuuetiDDS as defined in RCW 26.09.004.
[] 1ctn.11-taimlmpalrment l'Clllltlng from drug, alcohol, or other 111bstauce abuse
inlal'eaca wltb the pcrfanmsa of parenting funcliona.
[) aJisenre or substmitial impahmellt nf emotional ties between the parent and
() abusive-ofc:oafllct~tbepareat~~--tbed:mgeroflCrious
djinilige i'o die child'• psychological~
() t bas withheld from 11111 otber puent acccsa to Ille child for a jiiUUactted
wltboul gDOd Clllll&
[)
..
.
Ill. Realdantial Schedule

Tha resldentlsl schedule set frJtth whare the t:hlld(ren) shall reside each day of llrB year,
Including ptrJVislons for ys. bltfhdays of famDy membets, vacattons. and other spedal
occasionS. and what COii the ohDd(nm) Shall have wllh aach parent. Parents are encouraged
to craate a resldantlsl sc11•11B that meets the dflvelopmsntBJ nseds of the child(nm) and
Individual needs of their • Paragraphs 3. f through 3.9 are one way to writs your
resldsntial schedu/8. II do not use these paragraphs.. write in your own SChedule in
Paragraph 3. 13.
3.1 ScheduJe for ChD ren Under School ase-
IX ] There m: no cblldzen under school age.
[) Prior to ill llChool, Ibo cbild(ra) llhaJJ reside wilh Ibo [ ) modler [ Jfalber,
except for followina days and limes when Ille child(rm) will reside wilh or be wilb
. dlcodler c
time) to (day and lime) _ _ _ _ _ __
( ] every other week ( Jdie fint .and lhlrd week of the month [ ] die second
of lbe lllOlllb [ ) other:
from (day;±!lime) to (day and lime)

(] every I ] every mba' week () the fine and third week of the monlh [ ] the second
and founh of lbe monlb [ ) Giber:
3.2 School Scheclu!p

Upon cnrollmeul In ~ !Im cbild(R111) sball n:sidO wilh the (x ) mother ( J falller, except for
die followina days lima when 1111: cbiJd(ral) wiU reside with or be wilh the odicr puenc
from (day dme) Tvesday after &ebool ID (day and lime) Wednesday morning,
droppjng child off sci-I. 'Ille f'alber shall have ralclenlial lime every Thursday after school
unlil 7:30PM die cluld ID molhcr'1 home.
[x ) every [ ) every other week [ Jlhe fine and third week of the month [ J lhe
&CCODd mid Ourth week of lbe lllOlllb [ J other:
&om (day lime) Friday after &ebool co (day and time) Sunday at 1:00 PM rc111ming
die child IO mother' home.
[J week [x ] every Ollia' week [ ) tbo fim and lhlrd week of Ille lllOlllh
[1 and fomdl week of the moatb [ Jother:
P1181111ng Plan (PPP, PPT. P) • Page Sal f 0

WPF PS 15.0600 (5'200B) • RCW 2tJ.2fl.37S. H.09.011, .181;. 187;, UH
:.' . .• . I
The school
I~ wiU start when each child begins [it) kinderpnen ( J fust pade
[]
[ Jother: '. J
i
3.3 rVacaUon
·de wilb tbe [ it) lllOlbcr ( Jfalllcr durins wimer vacadon, acep1 for die
when lhe chlld(ra) will reside with or be with the other pan:nc The
lies for wintm' breaks, UDless vacation is n:quesll:d thirty (30) clays in
:I
3A Schedule for r School Breaks
lbe dlild(mn) sbali ·dD wilh Iha [it ] molhcr [ Jfather during odlcr sebool breab, Cl!Cqll for
du: followins days ' limes wben lhD chlld(ren) wiU reside with or be with die other pment
Residential idicdule applies, llllless vacation is n:que&lcd lbirty (30) clays in advance by email.
I
. I
3.5 Summer Sched&,llD
I'
.I
Upon complelion of~ sc:hool year. the ehild(ren) shall reside wilh the [] mother [ J father,
except for 1he fol~ns clays and limes whDn lhe chlld(rea) wiU reside with or be with the other
pan:111: · i
I
[] Same as . year schedule.

[it ] Otller: Raj sehcdule applic:s, wilb die cau:eplion of Tuesday pict up at 7:30am a1
the llllllherl place of work reumlins du: child Wednesday evening at 7:30pm. 'llwnday
pick up of· ild up al the motbcr's place ofwmt al 7:30am. and reiumo io IDOlber's
~817:· PM.
'i
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3.8 Vacation With t.renta
[) Dou Diil ~·)'·
[it ] The scbcdU for vacalion wilb panmll is as follows: Mocher and Falber will each have
lbree (3) ' of vacalion per year. Eacb parait allall submit lbeir vacadon reqw:sl, by
email, . ' (30) claya in advam:e.
I
I
Pllll1llt/ng Plan (PPP, PPT. f P) ~ Pllf1S 4 of 10
WPF PS 15.0600 Mandatolj (Bl'tllXJB)- RCW atal.376, XOS.016, •181;. 1117;. 194
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3.7 Schedule fOr Ho,ldaya
I
The R&idelllial scbecfu!e for tbe cbild(rm) for Ille holidays listed below is as follows:
I WitbMother WilhFalher
II (Specify Year
I
(Specify Year
i Odd@rm/Everyl Qdd/Eyen/l!veryl
New Year's Day i

EVEN ODD
Martin Llllher King ry EVEN ODD
Presidenls' Day EVEN ODD
Memorial Day I EVl!R.Y
July4•
' EVEN
Labor Day EVERY
Veteran1' Day EVEN G1'l ~
Tbanbgivins Day EVEN o\:lO
Quiamas Eve BVERY
OuimnasDay EVERY
(1. ] For pmposeii of this pamiling plan, a holiday llhal1 begin and end as follows (set forth
times): 11lun and Rllll'll lhc child to elm other parent at 7pm tbe same day.
I
[] Holidiy. wbidi fall on a Friday ar a Monday sball include Satun!ay and Sunday.
I
[] Other. I
I
3.8 Schedule for S~lal Occasions

The resida11ial ~n!c for Ille dlild(mi) for die following special occasions (for ex.ample,
birthdays) is as follilws: ·
i WllhMOlhcr WllhFalher
I
Odd/EygnlEyml
EVERY_ _ _ _ __ Odd/Eyen/Eyeryl
Mgthcr'aDay
EVERY_ _ _ __
fath!r'• Dav I
EVERY_ _ __..___
Molber's Blnbday~-- EVERY_ _ _ _ __
Falbcr'1 Binhday~---
[l Oiiier: l
Parenting Plan (PPP, PPT. PP)· Pags Sol 10
WPF PS 15.0800 AfandatOiY (6/2008) • RCW 2626.375. 28.09.011, •181;. 1117;. 194
I
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3.9 Priorities Under ~e ResldenUal Schedule .
() Does not 8PA1Y bff•nse one parent bas no visitation or reslricrcd visitation.
[J Paragraphs 31:-3 • 3.8 bave priority aver paragraphs 3.1 and 3.2 in the followi!IS order:
i
Rani tbe onlerofpriority, wilh 1 being given die tupestpriority:
'
I
_ 4..._winfcr vacalicm (3.3). .....,3_boliclays (3.7).
_s~l lueab (3.4) _6.JPCCW oa:asions (3.8)
-2+•"" ,..,.
ICbcdu1c {3.s) _I.....,.. vacallon wilh paiats·(J.6)
I
[ x) OWir: By llgRlClllalt
3.10 Restrictions
[ll J Does not apply because dlcre ae no limldng factors in parasrapbs 2.1 or 2.2.
(] The [ ] modll:r's [] fiubcr'1 realclenlial dme with lho childR:n shall be limired because
dlcre me liaimns factms in pazagnphs 2.1 and 2.2. 1be following rcslrictions &hall
apply wben the childmi spend limo willl &bis parait:
[) Tbae are Iiquting facuini In paraaraph 2.2. but there me no mtrictions on the
[) mother's [ J fallter's residendal time wilb the children for tile foUnwiog reasons:
i
i
. 3.11 Transportation Arrangements
I
Transportation ~an: Included in the Clild Support Worbheell and/or the Order for Cliid
Support and should jiot be illl:luded here.
Tnmspoztalion ~for du! cbild(rcn) botwwww paienta shall be as follows: By
agr=mcnt of die parties. .
3.12 Designation of Custodian

!
The chlldml ~~· parmdiDg plan me sc"oduled co n:slde tho majority of the lime with
Ille [ x} lllOlhcr ( ] Ii . 1bis pmwt ii cleaipall:d the cnsuxlian of the cbild(ren) solely far
purposes of all ~ slate and fedenll statwes which require 11 deaiptlon or daermlnadon ot
cuslOdy. 1bis desigilalion &ball.not affect eitller parent's ripes and responsibililies under this
paraiting plan.
.,.
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3.13 Other
'
Pal8ltlln(J Plan (PPP. ppr, i!f.J • Page 8 ol 10
WPF PS 16.0600 MantlstotY (B121XJB). RCW 28.2s.37S, 26.09.DJB.. rar; .1111;. 194
;·· . ..
3.14 Summary of RC:W 28.09.430 - 480; Regarding Relocatfon of a Child

This is a SUlllllW)' oji1y. Far the full iexl, please see RCW 26.09.430 ihrough 26.09.480.
'
If die person with wjiom die child resides a majority of die lime plans ID move, that person shall
give llOlice to t:vr:ry person entitled lo court ordcicd lime with lhe child
If the move Is ouiside die child's school clistricl, die relocating person muit give ootice by -
personal service or ti>' mall reqlliring a mum n:ceipl. This nodco must be at leaaa 60 days before
lhc illlalded move. If the relocaliog person could DOC llave known about lhe move in time IO give
60 days' notice, lhat person must give notice wilhin 5 days after lcaroing of Ille move. Tbe
nolice IDUSI conmin die infoniialion requirm in RCW 26.09.440. See also form DRPSCU
07.OSOO. (Notice of irirended Relocalioo of a Child).
If lhc move is widlili Ille same school dislricl, lbe reloealing person must provide actual oolice by
any reasonable ~ A pcnao entilled ID time wilb die child may nor objeca 10 Ille move bur
may ask for modificillioo under RCW 26.09.260.
Nolice may be clela~ fvr 21 days if Ille relocating person is emaing a domeslic _violence lhella"
gr is moving to avoi'1 a clear, illlmec!iaae aod llllRl8SOllable risk IO heallb and safely.
If informalioo is ~ IDlder a court order or die address coofidenliality program, ii may be

withhdd from lbn ~-
A relocating person ,may ask the court to waive 811Y notice requiR:lllelll8 lhat may pua lbe beallh
and safety of a ~ or a child aa risk. · -
Failure to give Ille ~ nocice may be pounds for aanctioos, including coolelnpl.
or
Ir no objection Is IBed Wltldn 30 da11 after senlce Ille notice or lateaded reloeation, the
reloeation will be &iermJlled aod Ille proposed reYlsed resldeoHal sdiedule ma1 be
caoftrmal. \
A pen.on enlilled ro;time wilb a child under a coun order ean filo 811 objcc1ion ao lbc child'•
reloealioo wbelller or
'
oat be er she received proper aotice. '
An objection may bC r.Jcd by usiog lbe mand•amy paaem form WPF DRPSCU rn.rnoo.
(Objocdon IO Ro1ocluion1Pe1111on for Modlficalion of Custody Decree/Parenti119 Plan/Residential
Sc:liecfnle). The ~OD 1111111 be served on all pmoos eotidcd-IO lime ~ilh lhe child.
Parenting Plan (PPP, PPT, fPJ • Pllf197ol10 .
WPF PS 11!1.CltiOO Mandal'Dly (fll2008} • RCW 26.26.815, 26.09.018, .181; .181; .194
·,' . .. .
1be relocating person shall DOl move die dlild dming the lime for objeetion unless: (a) the
delayed notice proviSions apply; or (b) a c:oun order allows Ibo 1110YC.
If die objecting pencin sdlcdulea a hearing for a dale wllhin 1.5 days of limely ~ of die
objccdon, die ieh:in;laa parson lhall acn move die child bcloie tbe bearing unless thac is a
clear, imlllcdlam and:umalO!llble risk to the heallb or safety of a person or a child.
IV. Decision Making
4.1 Day to Day Dec~ona
Each parent shall mab decisions regarding the day~ care and COlllrol of each child while
Ibo child ia residing With that parCllt. Regardless of die allcx:ation of clccisioo making ia t11iJ
parenting plan, eilhci' paient may mab emageuc:y cleclsions affecling the health or safety of the
children. :
P8tfllll/ng Plan (PPP, PPT. PfJ} ·Page B of 10

WPF PS 15.0600 MllndBtoly (&'2008} • RCW 28.2S.376, 26.09.011,. 181;. 181;. 194
: . i .
4.2 Major Decisions,
Major decisions regmding cm:b c:blld abaU be made as follows:
l!dnc:ation ck:ciiioDa [J motha' [·) falher [x) joint

Non-cniergicm:y bealib care [) mother [) fallier [x J joinl
Religious upbringing [J molher (] falher (x) joint
[J molher [] fadlcr [) joint
[) motha' [) falber [) joint
[) mo1hcr [J father [) joint
[) mo1hcr [) father [) joint
[J modler [) father . [) joint
[) mother [) father [) joint
4.3 RestrlcUone In Decision Making
(X) Docs DOI apply because lllcre an: ao limiting fiM:lors in paragraphs 2.1 and 2.2 above.
[) Sole decision making ahalJ be onlaed co the [ ] mother [ ) Cather Cor the Collowing
IQSOllS:
(J A limlwion on.the odlerpuat'1decisionmakinsautbority is mandated by

RCW 26.09.191 (See paragraph 2.1).
[) ~ pi;e!Ull 8111 opposed 10 mutnal decllion making.
[) · One parent la opposed IO mutual decision mating. and such opposition is
reasoua'bly based on lhe rollowinJI cri~:
'
(a) . The existence of a limillllon under RCW 26.09.191;
(b): The history of patlicipalion of each parent in decision making in each of
' the areas in RCW 26Jl9.184(4)(a);
(c) Wlldhcr Ibo pmnta have dc1J10Dlll'lltcd ability and deairc IO eoopcr~
with one allOlhcr in decision -kins in each or tho areas in Rew
26.09.184(4)(8); and
(d) The parenta' gougaap.'llc pniximlty to one anolher, to the extent thal it
affccla lhcir ability IO make llJDe!y mlllllal decisions.
[) There are limiting factors in paragraph 2.2, but lhme me no renictions on mutual
decision making for the followiDB ressom:
Psl9ntfng Plan (PPP, P1'T. f'P) ·Page Sol 10

WPF PS 16.0600 MandalOI)' (S'200B} ·ROW 2Cl26.37S, atallOJB, • rsr;. 1117;. JIU ·
~ . .' .
v. Dispute Reaotutton
The putpOSB ol lhls ~ resolutlan procsss Is to f8SDlve disagreements about carrying Out
thlS parenting ptan. This diSpUte l8SOlutlan procsss mq, snd under SOl1l8 local couJt tu/es or
Ille provisions ol lhls p/Bn must, be used before tmng a pelitlpn to modify the plan or a morion
for contempt for failing ro foJlow ths p/Bn.
'1.f Disp1*s belweell lhC parties, Olber lhan child support disputes, Bhall be submlacd ID Oisl person
r.. or agenqr):
[] coumeliq ~ or
mrdi••ion by' .
\Id
rntt/114. oC 4-wvrieu .if lllls box it checked :md
issues of domestic violeoce or child abuse are pre&e111, lbcn the coun finds llw Iha victim
requested mcdlalion, dUlt medialicm is appropriarc and that Ille victim Is Permitted to
have a~ person present during lhe mediariOn proceedings, or
[J arbltralion by_ _ _ _ _ _ _ _ _ _ _ _ _,
1bc cost of this proc:esa shall bo allocated between die parties as follOWB:
[1 _ _ _,. lllOlher .. fadler.

based on each pmty's pioponional lllare of lnc:ome l\'om line 6 of lhe child support
K worbbcelL
[] u dclermimid in Ille dispute resolution pnxms.
1bc dispute resolulion pnJCCSS sbalJ be 0011u1e11c¢ by notifying the other pany by [ ] wrlacn
request [ ] cenificd mall [ JOlhcr: .
In the dispute reso.IUliOll process:
(a) Prcfamice shall be gjvca ro canyiag out lhis Pan:nting Plan.

(b) Unless an ciacigeucy cxills, the pamnll &hall use the designated pnlCCS& IO iaolvc
dispulel reJadng IO iqil-lalioa of die plan, except those Rlatccllo financial support.
(c) A wri11£11 iec:ard &haU be pn:pared of any agrec:mcnt reached in counseling or mediatiOll
and of cacb arbllntion awud and lllal1 bo provided to eacb pany.
(d) If die court fillds tbat a puen1buusedorfnisaaled11111 disp111e resollllion pnxess
without good reason. the court shall award aaomcy'a fcca and financial sanctions co the
achcr parcnL
(e) The parties have lhe right of Rviow frviia the d1spule molulion pzocess 10 die superior
court.
[] No dispute n:solulion piocesa, ac:ept court aclion Is ordered.
P111811ting Plan (PPP, PPT. PP)· Page 10of 10 •

-- WPF PS 1$.0600 Mlilldatoiy(HrlOB} • RCW2f.a37$, 26.09..016, .1B1; .1B7;. 19'
() . 1beR are no other provisions.

[ 11] · 1beR are the following ocher provisions: Eilhcr pamit may lake the child out of the llall: of
WuhlnglOD for the PIDllOSO ofvacadon. The Modleror Father SHAU. Nar obtain a passpmt
for_lhe cbil# ~_anyJ~ am:l~Jbei:@if'iiiiii4.Mod1c£11WfliawDist njbtOf'id"uiaTif' · 1
-more-lhan-foar.(4).bom'So~Ii~MOtluiiagiieiilo-"NBVBRmllliiilcmsc
in child support from Fallier. Tim Father agrees to pay One roundlrlp airline licket IO Algeria, BOI
10 eJtCCCd $2,000.00 USD. Only onc:e. If Ille Molha' ii uuablo IO llllYCI IO Algeria, lbe l'albcr
aball pay Ille c:baDge dctct fee for Motlier to uaYCI IO anolhcr destinallon. The Oiild aball reside
with the Falber for two (2) wecb wbllc the Mocher'• boyfriend from Algeria is In the COllDlly.
Tim Mother aball have villls with the child on Tuesday's and 'lbunday's from aftl:r school until
7:30PM. This~ (2) weeks_ if on.Jy when MOJber's~ firstJiri.vcs JO Ibis~
l/iis .2 ~ f6 )11UMtl.l / W.Uh-Htrf"'1"pliff""".r~~I tldlj
VIL •Declaration for Proposed Parenting Plant1t111 3p.M ~
(11 ) Does not apply.
[) (Only sign If Ibis Is a pauposed pamitlns plan.) I declaae under penalty of perjury under lhe laws
of the 11a11: ofWasbingtDD lbat this plan bas been pioposed in good faith and lbat the sta'emrllJI
in Part n of Ibis an are 1n111 comc:L
Date and Place (City mid S1111i:) of SignalUl'e

"J}n/u ~~. '4M
J>a'le and Place (City and Sime) of SignatuJe
It is orclcred, adjudged and da:Rcd tbal tho pan:Dlins plan set forth above ill adoplcd and appao.m as an
order of Ibis~
Warning: Violation of residential provisions of Ibis order wltb actual knowledge of ils terms is
punishable by conll:nlpl of court and may be a criminal offense under RCW 9A.40.060(2) or
RCW 9A.40.070(2), Violation of Ibis order may subject a violator IO amst.
When iilUIWl1 clccision making ia designaled but i:annot be acldcwd, the panic:s shall malrz a good fallb
effort ao aesolve Ibo issue lluaugb die dispulD ac:solulion pnx:c:ss. •
Jf a puatl falls ID comply wilh a provision of Ibis plan, the otbcr pmau's obligations llJlder die plan am
not affccta1.
MAR 2 s io"
Dated:--.~~~~~~~~~~
missioner
Approved for entry:
Panmtlng Plan (PPP. PPT. PP) • Page 11 ol 10

WPF PS 15.0600 MandatOf1(6/2008}.RCW:l6.2f.37S,2G.09.01B, .181;. 187; 184 I
·' " . : -~ .
Signatwl: of Party or Lawyerl\YSBA No. Signatuni of Party or 1.awyerJWSBA No.
Print Name
Panmtlng Plan (PPP, PPT. PP)· Page 12 of 10

WPF PS 15.0BOO Alandllloiy (HOOS) • RCW a.a187S, 26.09.01B, .181; .11JT: .194
Oropbox - 2014-03-29 10.47.02.png Page I of l
Attachment 2
11111 Verizon 3G 10:47 AM @ -"f 100°/o Qi
[Very cute!)
May 10~ 2013, 7;38 AM
Laure(l is r~gistered for

· soccef·afid.the .
:·:t()~ma'nie~tfor June 7th.
May 10, 2013) 8:04 A.rv1
That's good. Sure she is

excited! Thanks for doing
that. Happy to see her
tonight - I feel like· l've lost
a lot of time with her and I.
Talk to you later.
Attachment 2
. .. "
4/27/2014
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112 OThe Mailbox•• Daily Jaumsl Prompts• TEC3168

Attachment 3
Attachment 4
On Oct 22, 2013, at 12:41 PM, rich@washingtonrush.com wrote:
Hi Team, we have signed up for the next indoor session, starting weekend of NOV
9th. Indoor is NOT mandatory by no means. If you have other plans during our down
time, great.
Unfortunatly, indoor starts during outdoor play. Like I did last season, I will work with
the indoor people and schedule around our outdoor games. We will NOT play indoor
before an outdoor game. Although we may go straight from outdoor to indoor depends
on schedule.
Azul plays on the Sat the 9th and 16th, and Nero plays on Sat the 9th and 23rd.
Those are the indoor dates I will adjust.
Schedules for indoor usually don't come out until a week before if that.
If you DO NOT plan on playing, please let me know so we can remove you from the
roster.
Thank you, Rich
Attachment 4
Attachment 5
From: Andrew Rife <asrife001@icloud.com>

Date: October 22, 2013, 1:06:13 PM PDT
To: "rich@washingtonrush.com" <rich@washingtonrush.com>
Subject: Re: INDOOR
Lauren will want to play indoor soccer.
Attachment 5
Attachment 6
On Oct 22, ·2013, at-,12:56 PM_, Jenn <jennifermeh~ddi@comcast:net> wrote:
Hi riqh, this. is Jennifer Lauren~s-mom. She will not be playing indoor. Her dad· is
already aware. Thanks!
Attachment6
Attachment 7
From; "jennifermehaddi@comcast.nef' <jennifermehaddi@comcast.net>

Date: October 22, 2013, 10:11:42 PM PDT
To: Washingtonrush <rich@washingtonrush.com>
Cc: Amy Pasco <amy@vfreitaslaw.com>, Andrew Rife <asrife001@icloud.com>
Subject: Re: INDOOR
I am Lauren's primary parent, and I just got your email today. I was not aware of any
indoor soccer coming up prior to this or Andy making arrangements without my
knowledge. Lauren loves her team and playing, however there are things I want to be
able to do with her with the holidays coming up and some "down time" would be nice
since she plays mostly year round. Sorry to have to tell you all this, but he made that
decision without my knowledge or consent. So she will not be playing indoor soccer.
Hope this clarifies everything.
Thanks,
Jennifer
Attachment 7
.·
Attachment 8
From: Josten Garalde <jostengaralde@gmail.com>

Subject: Re: Training/Game This Week
Date: March 10, 2014 9:52:57 PM PDT
To: Jenn <jennifennehaddi@comcast.net>
State Cup will be 2 games this Sunday 3/16 and 2 games 3/23 in Olympia. I'll send out
more details to everybody once we confinn the details.
Practices should stay the same from March-April, Mondays and Wednesdays,
5:30-7pm. Tryouts are in early May.
Josten Keoni Garalde

Washington Rush, Head Coach
c: 425-344-6290
www.washingtonrush.com
Attachment 8
Attachment 9
On Mar 10, 2014, at 10:07 PM, "jennifermehaddi@comcast.nef'

<jennifermehaddi@comcast.net> wrote:
You said that practice was going down to one day a week. Last week was supposed
to be her last game, but she has a game on Saturday in Snohomish and then 2 games
on Sunday in Olympia? Then 2 practices during the week, and two more games the
following sunday in Olympia again, when you take her skiing on the days she isn't
playing soccer? What happened to academics and her health coming first? Loi, I can
hear her coughing right now. Don't tell me a consistent cold and cough is normal for
months in a row. A doctor will never agree with that. This is TOO much for her. Your
pushing her too hard. If she's going to ski in the winter and be on a TEAM for skiing like
you told her, then she needs to not play select soccer for the winter. She needs a break
at some point. I fully agree with being athletic but this is not right. So like I said, please
do not register her for anything at this point until we can mediate something that is best
for Lauren.
Attachment 9
Attachment 1b
On Mar 11, 2014, at~2:18 PM, Andrew Rife <asrifeOQ1@icloud.com> wrote:
Jenn·,
I filled out the application form fa~ mecliation and faxed it back to them .. You should
be getting.something ih the. mail shortly.
To ensure .Lauren's position is held, I will be moving forward with registration.

Hopefully we can move quicl<ly on mediation. ·
Also, to.address some ofyolir health concerns, I have scheduled a well child check
up with Dr. Hastings at the Silver Lake Everett .Clinic on Tht,jrsday at 3:30. Dr. Lester is
not availal;>le on Thursdays but wanted to schec:lule sorrtething on a day you were
available. Hopefully that works~ :
Attachment 1 o
Attachment 11
On Mar 11, 2014, at 7:08 PM, "jennifermehaddi@comcast.ner•

<jennifermehaddi@comcast.net> wrote:
Yes, a doctor's appointment is good. Although I don't see why you refer to it only as
"my health concerns" for Lauren. You are aware she has Reactive Airway Disease and
when she gets ill her illness is exacerbated by this? That is why it is unfair to compare
her "colds" to people you work with and other teammates or school peers. Their health
isn't my concern, just Lauren's. We can mediate Andy as we should per the parenting
plan, but I am holding firm that playing ALL year round soccer with added tournaments,
jamborees and state cups not to mention LATE night practices is too much for a young
9 year old. She is so tired all the time. Unless you are willing to compromise on the
soccer and how much she does then we will end up in court over this. Unfortunately.
She is 9 years old. Other parents may think this schedule is okay but I don't care about
that. I think she is too young and after this whole year of being on a team and not rec or
academy I can see it is too much.
I also want to address with the doctor other concerns that can be discussed with
Lauren outside of the exam room so my mom will come to sit out in the lobby.
Attachment 11
Attachment 12
From: Rife, Andy [mailto:ASRife@SNOPUD.com]

Sent: Tuesday, March 11, 2014 12:01 PM
To: Houghton, Bernie
Subject: Lauren Rife
Mrs. Houghton,
Have you noticed Lauren being excessively tired and having more colds and sniffles
than most kids in her class? Does she appear to have a lack of energy and is she able
to maintain focus? I want to make sure that her grades aren't slipping.
Andrew Rife
Snohomish PUD #1
425-783-8559
From: Houghton, Bernie [mailto:BernieH@stmarym.org]

Sent: Tuesday, March 11, 2014 3:03 PM
To: Rife, Andy
Subject: RE: Lauren Rife
Lauren has a lot of energy and is doing well. Loves school. Mrs. Houghton
Attachment 12
Attachment 13
On Mar 12, 2014, at 5:35 PM, Andrew Rife <asrife001@icloud.com> wrote:
Rich,
Have you noticed Lauren being often sick and excessively tired at practices or
games lately?
From: Washingtonrush <rich@washingtonrush.com>

Date: March 12, 2014, 7:53:24 PM PDT
To: Andrew Rife <asrife001@icloud.com>
Cc: Jenn <jennifermehaddi@comcast.net>
Subject: Re: Lauren
I have not noticed a decline in her play or skill level. All girls have had their bout with
sickness over the season, but not excessive.
Rich
Sent from my iPhone
Attachment 13
Attachment 14
On Mar 12, 2014, at 10:03 AM, Andrew Rife <asrife001@icloud.com> wrote:
Could you tell me if you have notice Lauren being more tired and less enthusiastic
at practices than the other girls?

Date: March 13, 2014, 5:44:07 PM PDT
Subject: Re: Lauren
Hi Andrew, I haven't noticed anything. She is always energetic and is a ton of fun
coaching with her great attitude at trainings and games. Tell her to keep up the
awesome work!
Sent from my iPhone
Attachment 14
Attachment 15
From: rich@washingtonrush.com (mailto:rich@washingtonrush.com]

Sent: Thursday, March 13, 2014 3:00 PM
To: Jennifer Mehaddi
Subject: Rush
Hi Jennifer, the Select season starts every year in May with try-outs for 2014-2015
season, after try-outs players are placed on a team. Season runs from May to April,
with time off during periods of the year.
After league season is over, (Fall and Spring) teams start to prepare for State Cup,
which runs from Mar to mid April, depending on how you do, depends on how long you
practice. Azul's is the next two Sunday's with two games each day. After State Cup,
there will be time off, then teams still get together for practice leading up to try-outs, to
keep the players active and getting touches on the ball.
If you have any further questions, dont hesitate to ask.
Thank you, Rich
Attachment 15
Attachment 16
From: Jennifer Mehaddi

Sent: Friday, March 14, 2014 8:25 AM
To: 'rich@washingtonrush.com'
Cc: 'jostengaralde@gmail.com'
Subject: RE: Rush
Thank you for the information Rich. As Josten recently said Lauren is really learning
and enjoys playing soccer with Rush. Very proud of her! Without causing any problems
or going in to private issues, I just wanted to let you know as you probably already
know ... Andy and I are having some differences of opinion on how much soccer Lauren
plays during the year. I would like her to explore different sports or activities for a
season or two. It is not against the Rush team or coaches at all. Lauren is very
comfortable and enjoys both you and Josten as coaches.
However, this Sunday we have family plans and Lauren will not be able to make the
state cup in Olympia. She will be at the game in Snohomish on Saturday and at the
state cup the following weekend.
Thanks again,
Jennifer Mehaddi
Attachment 16
.1!ll·Verizon 3G 9:22 AM @ -"'( 1 OOo/o c:Ji
, ent 17
.·"'.-....-~
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7
·,"" .· ·· · · i=ci"i"t'' ,·~.,
Mat 22s 2014, 9:08 AA1
. Tell Lauren I said good

I
luck at her game and that
I'm thinking about her.
~·
~·
~-----------------'
Attachment 17
Attachment 18
On Apr 9, 2014, at 10:04 AM, Josten Garside <jostengaralde@gmail.com> wrote:
Hi Rush, I hope you've all had a good break.
We will start training next week, Mondays 4-5:30pm and Wednesdays 5:30-7pm at Kasch for the
rest of April.
If you're free this Saturday, my GU14's have a State Cup game 4:30pm Kasch Park if anybody
wanted to come out and support the team. We have to win against Northwest Nationals to advance.
Also, I wanted to encourage the girts to watch any soccer they can. We live in the information
age and have access directly to watch some great matches such as Champions League, Premiere
League and the World Cup coming up this summer in Brazil.
I remember at 14 years old, we had the World Cup in the States and it was the first time I really
started watching soccer, learning about different styles of play and studying some of my favorite
players. I love the fluidity and creativity of the Brazilian Samba players and it inspired to practice on
my own.
Watching the game is apart of a young soccer players education. Studying it, and imitating
moves of high level professional players Is what kids do around the world. I love the Sounders but I
wanna encourage the girts to see and know whafs out there as well.
Below is a true story video about a group of kids starting a football team in Thailand that lives on
a village on top of the water. Pretty amazing stuff. The second link gives highlights and updates on
the latest pro leagues and players around. Enjoy!
http://funniestvideoalbum.blogspot.jp/2014/03/What-lf-nothlng-is-impossible.html
http://www.footytube.com
Josten Keoni Geralda

c: 425-344-6290
From: "jennifermehaddi@comcast.net" <jennifermehaddi@comcast.net>

Date: April 9, 2014, 11:09:02 PM PDT
To: Josten Garside <jostengaralde@gmail.com>, Washingtonrush <rich@washingtonrush.com>
Cc: Andrew Rife <asrife001@icloud.com>
Subject: Re: Watching Soccer
Hi Josten,
I wanted to let you know that Lauren will not be at practice next week. A decision regarding soccer
will be made at the end of the month. Mr. Rife is aware of this as I have not agreed to further
practices/games at this point.
Thanks,
Jennifer Mehaddi
Attachment 18
• Attachment 19
.,.
Redacted Email Andrew.Rife to Jennifer' Mehaddi
[Material pn ot~er topics redacted]
April 16,2014.
Jenn,
·Also, the parenting plan also requires each parent. to get.Lauren.to her games and.
practices. She has a practice tl)is evening at 5:30. at Kasch Park. If there is a n~d for
transportation to get Lauren to practice, before. it commences, I am happy to pick her up
from wherever she is an~ get there. .
Attachment 19
.• • Attachmerit 20
On.Apr'16, 2014, at3:00 PM, Jenn <jeriniferm-ehadc!i@ce>mcast:net> wrote:
'5occer for the seaso11Js ove_r. She will not be.going to practice. See you at
mediatio11. ·

Date: April 16, 2014,:3:02:56 PM PDT
To: Jenn <jennifenilehaddi@comcast.ne_t>
Subject: Re: Lauren
Soceefis.not.over. She is still registeredwith the team.
Attachment 20
Attachment 21
,

Date: April 20, 2014, 11 :26:33 PM PDT
To: Cece Mejia <abrahamhmejia@msn.com>, Rachel Miller <sbmiller@nwlink.com>,
Lauren Rife <asrife001@icloud.com>, Allie Williams ·
<williamschristy.dan@frontier.com>, Anna Howell <mshowell@yahoo.com>, Zoe
Jackson <katherinebristol.kj@gmail.com>, Ashlyn Mackey
<mike_mackey@comcast.net>, Brittney Beitel <beitel911@yahoo.com>, Cece Mejia
<Mpatriciamejia@msn.com>, Hannah Ochs <ochsdc98@gmail.com>, Sarah De Santos
<christinekd68@gmail.com>, Sarah De Santos <luisad0804@gmail.com>, Lauren
<jennifermehaddi@comcast.net>, Gabrielle Lindow
<Christopher.C.Lindow@boeing.com>, "Lindow, April M"
<april.m.lindow@boeing.com>, Gina Scott <Gina@cojk.com>, Washingtonrush
<rich@washingtonrush.com>
Cc: "<matt@washingtonrush.com>" <matt@washingtonrush.com>, Ben Somoza
<bsomoza@washingtonrush.com>
Subject: Training next two weeks and GU11 Tryouts
Training with Azul team
Monday- 4/21- 4:00-5:30 - Kasch Park
Wednesday 4/23- 5:30-7:00 - Kasch Park
Training with GU11 age group
4/28-5/1 -TBD. Kasch Park
GU11 Tryouts
Friday-5/2- 5:45-7:00pm - Kasch 3
Saturday-5/3-1:00-2:30pm - Kasch 1
Wednesday-5/7-5:30-7:00pm - Kasch 2

c: 425-344-6290
Attachment 21
FILED
ZOl~"AY-Z PH 21 '4i
111~1~\~~l~~il~\\~\
1
SONYA KRASKI
2 COUNTY CLERK
CL16593064 SNOHOMISH CO. WASH
3
4

COUNTY OF SNOHOMISH
NO. 05 3 02755 1
7 Andrew Scott Rife
8 and CONTEMPT
9 Respondent.
Clerk's Action Re uired
10 IT IS ORDERED:
11 Jennifer Rae Rife 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
12 granted.
13 Date: (Vl~ ~ I '"2...J f</ Time: 9:00 a.m.
Place: Snoho~ish County Room/Department:
14 Courthouse Commissioner's Department B or C
3000 Rockefeller As Assigned
15 Everett WA 98201
16 If you fail to appear in person and defend at these P.roceedings the court may
grant all of the relief requested and/or issue a bench warrantlor your arrest
17 without further notice to you.
:tiwt
l8 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.
19 Other:
20
21
Dated: l. l ·
~~~~Ttt:~g~e..,..,..c-::m~m=1~s~s1~o=ne~r=--~-
Copy Received:
22
23
24 Veronica Freitas WSBA# 19405
._ Attorney for Jennifer Rae Rife
25
a·R\G\~~l
CARLJ.GAUL
Allorney al law
26
1604 Hewitt Ave.
27 Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1 Everett WA 9820 I
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160 425 25~147 FAX 259 7081
I
FILED
1
ZOI~ 11AY -1 AH IQ: 55
2 SONYA KRASKI
COUNTY CLERK
4 111m11111111111
CL16591398
5

COUNTY OF SNOHOMISH
8
In re:
9 Andrew Scott Rife
Petitioner, ND. 05 :s 02755 1
10 and
Jennifer Rae Rife
11 Respondent.
12 THE CLERK OF THE COURT
Andrew Scott Rife
13 veronica Frelta~ attorney for Jennifer Rae Rife
Elise Buie, Guarulan ad Lltem
14
PLEASE TAKE NOTICE that earl J. Gaul, attorney for Andrew Scott Rife,
15 Ill be unavailable from the following period:
FROM THROUGH
16 May 5, 2014 May 15, 2014
17 May 27, 2014 May29, 2014
18 June 2, 2014 June 12, 2014
19 June 23, 2014 June 26, 2014

July 14, 2014 July 18, 2014
20
It Is requested that motions~ depositions and other court hearings not be scheduled
21 o occur during the time or my absence, and that motions and other hearings be
scheduled so that there is sufficient time to prepare for them following the end of
22 the absence. There Is no other attorney available wi ufficien ctuar knowledge
of this case to respond to any substantive request o rel f ri g my absence.
23 Dated: May 5, 2014
24
25
CARLJ.GAUL
26 Attomey at Law
27 1604 Hewitt Ave.
Everett WA 98201
ORIGIN,~L 425 259-4147 FAX 259 7081
FILED
11mm1~111~~m~~100~111moo
1
2
CL16717397 201~ PIAY -8 PH 2: 52·
3
SONYA KRASKI
4 COUNTY CLERK
SNOHOMISH CO. WASH
5
7
8 WASHINGTON
ANDREW scan RIFE Cause#: 05-3-02755-1
9

vs. ORDER TO SHOW CAUSE RE CONTEMPT;
JENNIFER RAE RIFE MOTION/DECLARATION FOR AN ORDER TO SHOW
11 DefendanURespondenl CAUSE RE CONTEMPT
12
Hearing Date: May 19 2014
13
14
15 Declaration:
17 therein.
On the date and time of May 3 2014 l 1:02AM at the address of 14200 69TH DR SE UNIT A-5
18 SNOHOMISH, within the County of SNOHOMISH, State of WASHINGTON, the declarant duly served
the above described documents upon JENNIFER MEHADDI by then and there personally delivering I
19 true and correct copy(ies) thereof, by then presenting to and leaving the same with JENNIFER MEHADDI
Who accepted service, with identity confirmed by verbal communication, a white female approx. 45-55 years
20 of age, 5'-5'4" tall, weighing 160-180 lbs with blonde hair..
No information was provided that indicates that the subjects sen•ed are members of the U.S. military.
21
22 and correct.
Dated: May 5, 2014 at Everett, \VA
23
24
25 Service Fee Total: $ 79.50
26
27
28
ABC Legal Services, Inc. 05-~2755-1

206 521-9000 ORIGINAL Gaul, Car1
1604 Hewitt Ave, #302
111rtm~ii
085 PROOF OF SERVICE
Everett, WA 98201
Pogc I of I
425 259-4147
1.
FILED
2 101~ l\~Y -9 Alo\ 9: I 0 .
3
SOHYA KRA$KI
COUllTY CLERK
\11~1111\111\I\~
• SNOHOMISH CO. WASH
5
· CL16589342
6
7
Superior Coort~fWashio~n
8
County of Snohomish
9
In ro:
10
ANDREW RIFB; No. 0§..3:.02755-1
II Petitioner,
end .
12 DECLARATION OF VERONICA
JHNNIFBR. MEHADDI (fka Jennifer Rife), FREITAS IN RESPONSE TO
13 MOTION TO COMPEL .
Respondent•
15 .
.My name is Veronica Freitas. Iain over 18 years old and am competent to.tesiify as
16
witness in this matter. lam. the attomey for the Respondent, Jennif<% Mf:haddj; I have nwi
17
the Motion to COJripel Discovery and em submitting this decbuation in response.
18
19 Cmf Gaul, atliiiney for the Petitioner arid I. participated in a telephone lr37 conferi:ilee
20 April 18, 2014. He _queried me, ~when I ex~ed to be able fu provide .Ms. Mehaddi'
21
~ responses. Mr. Oaul informed me that bis client bad inslructed him to file a motion
22
compel aml that he bad done so. Mr. Gaul acknOwledged that the inotiOn was •inrnw:ssary
23
assured, me that be would strike the motion once he received the interrogatory n:sponses,
24
25 Ms. Mehaddi's interrogatory 1esponses wen: picked up at my offiee by ABC Legal Servi
26 on April 29, 2014 and were received by Mr. Gaul's office ill 1:32 p.m. on April 30, 20i4. See AB
27
Legal_ Service messenger slip attaclJed as F.xhibit A.
VERONICA~rrAB.
·V, FREITAS LAW0 PLLC.
DF.q.ARATION 210SummltAveoue But
"""' lof3 ·Seattle, Wa1blugfim !18102
. (206) 328-7362
v@vfreltulaw.cmil
As soon as my office received the motion to compel, my panilegal, Kelli Gomez, email
2
Mr. Gaul asking him if he was going to.strike the motion and, ifnot, informing him that thebelllrind
J
date will haVe to be moved due to my unavailability. That email is attached es EXhibit B; .Mr. ..
4
, luis fililed ID respond to .thaf. emaiJ.
6 After reviewing Ms. Mehaddi'11 intmoptmy n:spooses. Mr. Gaul emailed and felt that
7 few of Ms. Mehaddi's answers wm: not answered cnmpletely. Upon receiving that email. Ms
8
Gomez again emailed Mr•.Gaul, inquiring BboiJt moving the liearing date. Again, no 1esponse ·
9
w Mr.. Gaul. . in nisponSe
Supplemental ansWers. have been supplli,d to Mr.. Oaill . to his email .ie(jtieStJ
11 These emails~ inchufed as Exhibit C,.
12 Interestingly enough, my office also sent inllmupiloiies for Mr. Rife to answer.
13
responses are overdue. MY, paralegal, Amy Pasco, emailed Mr. Gaul to set up en h'l7 anlfiereni~
14
(Exhibit D). Mr. Gaul Sent a Notice of Unavliilahility in response (F.xhibit H).
., Aa:onting to
Notice ofUmiviillability, Mr. OaµI will be unavailable lillllting the day that Ms. Pasco scheduled
16
17 h'l7 conference through the date of this hearing.
18 Mr. Gaul is acting in bad faidL Ms. Mehaitdi bas eruiwered her interrogatories fully
19
completely; Mr. Gaul has refused to 1dlpmd to eny communication fium iny.offiCe.n1:gar(liol1
20
moving this hearing, striking Ibis hearing (1r setting an lr37 ~ for. bis own c:iieirt's past
2f
22
inteJ1o¢my mrswas, buthas emailed n:questing mDRl infonnation fium Ms. Mehaddi. All of Mr
2J Gaul's requests and comm1mications have been answered promptly. 1bis motion should be.deni
2A and attorney fees should not be ordered.
I declare undei penalty of perjwy pursuant lo the laws of the State o( Washington that
26
'1:1
foregoing is irue and correct to the best of mr knowledge.
28.
VERONICA llREITAB
V•. JIREITAS LAW, PLLC.
DllCLARATION .210 sommU Avenue East
PagOlofJ Seattle, Waslllagtoo 98102.
(lo6) 328-7362
v@vfi'eltaslaw.com
l)ATIIDlllis~Dayof M<j ,2014~ Se~-<.. ,Washington.
3
~IR\
4
10
II,
12
13
14
IS
16
17.
18
·19
20
21
.24
2S
27
2a
VERONICA llllEITAS
v.•FRDTAS·LAW, PI.LC.
Dl!Ci.ARATION 210 Summit Avenue Bast
Page 3 of3 &eatiie. w8sllington·11af02
{'206)328-7362
v@Vfre11as1aw.eom
EXHIBIT A
V.FREITAS LAW, PLLC

I I
210 Summit Avenue Rast, Seattie, WA 98102 tel• (206)328-7362 fax• (206)323-0464
·'
l,\e!.:".Cl"Jtr $~1~lt<.1 ' •

lr·ST Ot.Y
.....
Mehaddl
-
INtERRGAoTRY REsPoNSES
I
CARI.GAUL
1604 HEWrrr AVE
EvERErr, WA 982
APR 302014 @~
2
C LEGALMESSENGEAS
D 0 .D 0
nus FORliil NOT FOR PROCESS
Bulk Charge
EXHIBITB
V. FREITAS LAW, PLLC

I I
210 Slimmlt Avenue l!ast, Seattle, WA,98102 tel• (206)328-7362 Cax• (206)323~04
Amy Pasco
From: Kelli Gomez·

Sent:· Tuesday, AprD 29, 2014 11:05 AM
To:' Carl Gaul
Cc: Veronica Freitas; AinY Pase<>
Subject: MehaddVRife
f'ollow Up Flag: Follow up

Flag Statu5: ComPfeted
,.
Hello; We. have received your motlcin .to ·compel. Our Interrogatory responses were messengered to your office. this
mom_lng.' Wiii you l>e striking the motion oi:ice you receive the documents? Veronica Is Scheduled to bi! In trial oil May
16th, If you aren;tstrlking the hearing we wlll need to discuss new dates; .
Thank you.
Kelll G.omez
Paralegal
V; Freitas l.8W, PUC
.. 210 summ11 Ave. east
Seatt1e,.WA 98102
Phone: (206)328·7362
Fax: (206)3l3-0404
kelll@vtreltaslaw.com
wwyj.vfre!taShiw.com,
This o,mail and any files ti-ansoiiued \vilh i( are intended only fur lbe penon or enlily ID which 11 luddressed and may COnl8in . .
confidential· malerW and/Or material llfl1leCI~ by law; Any retransmission, disseminalion or USC of Ibis lnfuimatloo may be aviohilion
of that law. Ifyou n:celved this e-mail in error, please conlact the ilendei and delete the e-mail 8nd ilS attachmeotl from all computen;
l
EXHIBITC
V. FREITAS .LAW, PLLC

I
210 Summit Avenue Bast, Seattle, WA 98102 tel• (20!>)328-73!>2 !Jax• (206)323-04-04
I . •
1·
2.
3
4
5
6
. . RIOR COURI' OF WAStiIN.GTON
7· COUNlYOF SNOHOMISH ..
8
Inre: · .
g AndrewscottRlfe
Petitioner, NO. OS I 02755 1
10 and NOTICE OF UNAVAILABILITY OF OOUNSEL
Jennifer Rae Rife
11 Respondent.
12 THE CLERK OF THE rouim
Andrew soott Rife ·
13 veronica Frei~ attorney fOr Jennifer Rae Rife
Elise Buie, Ouarulan ad Utem · .
14
._ . . . PLEASE TAKE(NOTICE that earl J. ciau1, attorney for ·Andrew Scott.Rife,
_
15
Ill be unavailable-from the followlng period: ·
.. FROM. THROUOH
16 Mays, 2014 May15,2014
17 May27, 2o14 MaY29, 2o14
18 June 2, 2Q14. June 12. 2014
19 June 23, 2014 June 26, 2o14
Juiy 1_4, ~014 JUIY 18, 2014
24
is
CARLJ.GAUL
26 Attorney st /.JJw
302 Banl(d America Bldg.
XI 1604 Hewitt Aw.
Everett WA98201
NOTICE OF UNAVAILABILITY OF COUNSB. 425 1,59-4_147 FAX 259 7o81
EXHIBITD
V. F-REITl\.S LAW, PLLC

I
210 Summl_tAvenue l!ast,Seattle, WA'98102 t:el• (206)328-7~62 Im• (206)323-0404
Amy Pasco
From:. Amy Pasco

Seilt: MondaY, May 5, 2014 12:54 PM
To: car1gaul@hotmail.com
Cc: veronli:a Freitas; Betli Humphrey;,Kem ~omez; Hye; Tony
Subje~ Rife diseovery ·
H!!l_k> earl,
Andy Rife'~ Interrogatories are overdue;.
Our office will call you tomorrow at 2:00pni fOi' an lr37. mnferenee.
Please let iis know If that-time will not-work for you.
T_hank you, -
Amy Pasco
Paralegal
V. Freitas LaW, PLLC
210 Summit Ave: e,
Seattle, WA 98102
Phone: (206)328-7362
Fax: (zci6)3i3-0404
mallto:ami@vtrellaslaw.com
ww\y.Vfreltaslaw.com
This e-mail and any. files transmitted with ii are intended only for the person or entity to which ii is addressed tind may contairi
confid.cnilal maierlal and/or materliit proiected by'. law. Any retransmission, dlssCminaticiri or ilse orthisJnfomiation ma)' be a violation
.oflhat Jaw. If you received this e-mail in error, please coiltai:t the serider aiid delete the e-mail and iti attachments fi'om _all computers.
I
EXHIBITE

I I
210 SunlmltAvenue East, Seattle, WA 98102 tel• (206)328-7362 fax• (206)323-0404
AinyPasco
.From: Kelli Gomez
Sent: Tues~ay. May 6, 2014 10-AS .AM
To: earl Gaut Amy PaScc>
Cc Veronica Freitas; eliseb(tilmai~treetlawgroup.com
Subject: RE: Rife Notice .of UnavaDabllity
·Follow Up Flag: FoUQ1Nup.

Flag Status: Completed
If Mr, Gaul has a notice of absence through May 15 and Is requesting adequate tlrrie. to prepare a response I am unclear
h!Jw he wlH be pr_epared for a l_learlng on May 161b. it seems that date will not work for him as well. canwe resdiecluie
the motion to comJM!li It would make the most sense to have the motio·n to compel and the contempt heard on the
same day.
Than_kyou.
Kelli Gomez
Paralegal
V. Freitas Law, PLLC
210 Summit AW. East
·Seattle, WA 98102
Phone: (206)328-7362
Faic: (206)323-0404
kelll@vffettaslaw.com•
www.vfreltaslaW.i:om
This e-mail end eny. lifus trmwnittect' With It are intended only for tlio person or entity to which ii is addressed and may contain
eonlidential material andiO.. material protecled by law. Any retransmission, disSCJDi•ation or use ofthb inforiruitlon mily be a violation
oflhal la_w. tryou received this e-mail in error, please COll1act the sender and delete the e-mail and its attachments from all eomputen.
From: cart Gaul [mallto:carlgaul@hotmall.com)

Sent: Monday, May OS, 2014 10:32 PM
To: Kelli Gomez; Amy"Pasco
Cc: Veronica Freitas; eliseb@malnstreetla\vgroup.com
SubJl!Cl: Rife Notice of Unavailability
Kelli and Amy,
Attached please find a Notice of Unavailabllity for Carl Gaul.
Thankyou, ·
Marianne, Paralegal to
I
' '
Amy Pasco
From: KeOIGomez
Sent: Thursday, May 1, 2014 12:44 PM
To: Carl Gaul
Cc: Veronica Freitas; Amy Pasco
Subject: RE: Rife I Mehaddi Discovery
Follow Up Flag: Follow up

I would like to follow up regarding my previous email tPtat veronica Is not avallable the date that you have filed the
motion to compel.
Kelli
From: earl Gaul !mallto:carlgaul@Ptotmall.com)

To: Veronica Freitas
Subject: Rife/ Mehaddl Discovery
Ms. Freitas
I received partial answers to the discovery propounded to Mrs. Mehaddl. I notice that the responses
to Interrogatories 3, 5, 15, and 17 appear to be incomplete. The response to 18 may be erroneous.
There was no response at all to Request for Production 3, an apparent coUatlng error.
The response to RFP 6 Is inconsistent with the corresponding Interrogatory.
Please review the responses and supplement as may be appropriate.
CARLJ.GAUL
Attorney at Lmv
302 Bank of America Bulldlng
1604 Hewitt Avenue
Everett WA 98201-3536
Tel. 425-259-4147
Fax 425-259-7081
carlgaul@botmall.com
I
,_,
F\LED
ZOl~MAY 19 PH 3: 56
1
SOHYI\ KRASKI
2 COUHTY CL.ERK c
~tWHOMlSH CO. W;\ ~H
3 1111m11111111111m1111111
CL1659275S
4
5
6

Petitioner,
10 and MOTION/DECLARATION FOR
AN ORDER TO SHOW CAUSE
11 Jennifer Rae Mehaddl, f/k/a Rife RE CONTEMPT
Res ondent. MTSC)
12
I. MOTION
13
Andrew Scott Rife moves the court for an order directing Jennifer Rae Mehaddi to
14 appear personally before the court and show cause why an order should not be entered:
18 Signed by the court on October 24, 2013 in Snohomish County WA in this cause.
20 Does not apply.
22 Granting sanctions for contempt, including a forfeiture for each day the contempt of
court continues, and establishing conditions by which the contempt may be purged
23 and granting any other relief, including reasonable attorney fees and costs and
make up residential time, as may be appropriate under Chapter 7.21 RCW, Chapter
24 26.09 RCW, Chapter 26.10 RCW, Chapter 26.26 RCW, and RCW 26.18.040.
25
26
27
ORIGINAL
Mot/Dec Ord Show Cause re Con/empt (MISC) - Page I
CARLJ.GAUL
Auomey al Law
Bank of America Bldg.
1604 Hewitt Ave.
Everctt WA 9820 I
WPF DRPSCU 05.0100 Mandalory (612008) - RCW 26.09.160 425 259-4147 FAX 259 7081
•
•
1
1.4 OTHER:
2
Andrew Scott Rife also requests an order specifically requiring Jennifer Rae
3 Mehaddi to keep him advised of all days and hours she is scheduled to wor1<,
including any changes in her schedule and all days and times she is wor1<ing in
4 excess of her ordinary schedule.
5 Andrew Scott Rife also requests an order specifically requiring Jennifer Rae
Mehaddi to keep him advised of all days and times that Lauren Rife requires more
6 than four hours of child care, specifically including child care provided by her mother
and/or her sister.
7
Andrew Scott R!fe also requests an order specifically prohibiting Jennifer Rae
8 Mehaddi making any medical decision without his affirmative agreement or an order
of court.
9
This motion is based upon the declaration wh~ws. 'Kl
:~ Dated: ~ I~, ")_.)l'·-l CARLJ.GAUL~1
12
13 II. DECLARATION
15 Failure to comply with the parenting plan as follows:
16 1 First Right of Refusal
17 The March 25, 2011 parenting plan provides in part VI (page 11)
18 "The Father and Mother shall have first right of refusal if more
than four (4) hours of child care is required."
19
This portion of the March 25, 2011 parenting plan remains in effect because
20
the October 24, 2013 temporary parenting plan provides in part VI (page 10):
21
"Except as modified by this order all provisions of the
22 3/25/2011 order remain in effect."
23 Jennifer Mehaddi has refused to comply with this provision of the parenting plan.
24
25
CARLJ.GAUL
26 Allomey at Law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MI'SC) - Page 2 Everett WA 9820 I
•
•
1 2 The October 24, 2013 parenting plan establishes decision making in part 4.3:
2 Nonemergency Medical Care [x]joint.

3 Jennifer Mehaddi has refused to comply with this provision of the parenting plan.
4 This order was violated in the following manner:
5 Background:
6 At the time the March 25, 2011 parenting plan was entered, Jennifer worked at
7 Everett Clinic. I would get our daughter Lauren Rife from school and take care of her until
8 her mother got home from work, then deliver her to Jennifer's home. Jennifer worked late
9 one day per week. We had our daughter Lauren spend these late day hours nights with
10 me. The same pattern persisted when she went to work at Washington Urology in
11 February 2012. Jennifer was unemployed most of the summer of 2013, but the same
12 pattern of time with me persisted. In August 2013 she found work at Swedish Medical
13 Group's Birth and Family Clinic in Edmonds. She worked Monday, Tuesday, Thursday
14 Friday, with occasional Wednesday or Saturday time. Thursday was her late day. Initially,
15 he midweek extended time became an overnight and moved to Thursdays. I would be
16 responsible to get Lauren to school on Friday.
17 When Lauren was in kindergarten (academic year 2010-2011) Lauren began
18 spending significantly more time with me than she had previously. March 25, 2011 a new
19 agreed parenting plan was entered. This parenting plan documented Lauren's increased
20 ·me with me. Nonetheless, her time with me continued to increase. Lauren had
21 previously been at a Montessori. There is a first right of refusal provision because each of
22 us preferred parental care over any alternative such as a daycare center or babysitter.
23 Before this action was filed in October 2013 the pattern of parenting we had
24 developed between us was that we both were ready to change the days Lauren was in one
25
CARLJ.GAUL
26 Allorney al law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MISC) - Page 3 Everett WA 98201
WPF DRPSCU05.0JOO Mandatory (612008)-RCW 26.09.160 425 259-4147 FAX 259 7081
•
1 home or the other based on consideration of Jennifer's work schedule or Lauren's school
2 and activities and whatever else might be going on. We both knew we were actually
3 ollowing a schedule that differed from the written parenting plan. Neither of us was
4 particularly concerned at that time about the first right of refusal language found in part VI
5 of the parenting plan. We never had need to discuss it.
6 On October 24, 2013 the Commissioner entered a temporary parenting plan. That
7 order preserves most of the March 25, 2011 parenting plan, including Part VI, which
8 establishes a right of first refusal when more than 4 hours of child care is required.
9 Upon entry of this order Jennifer Mehaddi began having her mother, Carol Holland,
10 interfere with the established pattern of parenting. Jennifer was clear that she would not
11 allow any time for Lauren to be with me in excess of the specific written terms of the court's
12 orders. That forced me to again read the orders to review what was in them. This is when
13 he first right of refusal became important.
14 During discovery I obtained information concerning Jennifer Mehaddi's actual work
15 schedule. She has deprived Lauren of time she should have been spending with me.
16 1. Jennifer Mehaddi has prevented exercise of "right of first refusal"

residential time by father during times when more than 4 hours of child
17 care was required.
18 Between March 25, 2011 and October 24, 2013 I continued to frequently have time
19 ith Lauren when her mother was working. Marginally observed holidays like Columbus
20 Day and Veterans Day were examples. I would also have Lauren with me in afternoons
21 after school and I would provide transportation to and from Lauren's activities. She and I
22 did not talk about it particularly in the sense of deciding if a particular part of the parenting
23 plan required me to have this involvement, nor whether Jennifer had to facilitate that
24 involvement. It was just what we did. The actual time I was spending with Lauren
25
CARLJ.GAUL
26 Allorney at Law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cau~e re Contempt (MI'SC) - Page 4 Everett WA 9820 I
1 expanded over time to the point that Lauren was with me significantly more than she was
2 ith Jennifer.
3 When the court's order of October 24, 2013 was entered, Jennifer Mehaddi
4 immediately began trying to restrict Lauren's time and activity with me. Her mother, Carol
5 Holland, had provided some child care and some transportation previously, but suddenly
6 her mother's involvement multiplied, as part of an effort to minimize my involvement. Carol
7 Holland has been confrontational about trying to take Lauren during time she is scheduled
8 o be with me. Jennifer Mehaddi's communications have been confrontational and
9 demanding about the time.
10 The March 25, 2011 parenting plan provides in part VI (page 11)
11 "The Father and Mother shall have first riclit of refusal if more
than four (4) hours of child care is required."
12
This portion of the March 25, 2011 parenting plan remains in effect because
13
the October 24, 2013 temporary parenting plan provides in part VI (page 10):
14
"Except as modified by this order all provisions of the
15 3/25/2011 order remain in effect."
16 At the time this modification action was filed, October 2, 2013, Jennifer Mehaddi
17 as employed at Swedish Medical Group, at the Edmonds WA Birth and Family Clinic. In
18 response to a records deposition subpoena Swedish provided a work history of Jennifer
19 Mehaddi, which included the time clock information for her, day by day. These records
20 reveal that there were many days when the first right of refusal found in Part VI of the
21 parenting plan of September 25, 2011 required Lauren to be with me.
I
22 A. November 11, 2013
23 On Sunday, November 10, 2013 I had a telephone conversation with Jennifer
24 Mehaddi. She told me that our daughter was sick, and that she would take the next day,
25
CARLJ.GAUL
26 Allorney at Law
27 1604 llcwitt Ave.
Mot/Dec Ord Show Cause re Con/empt (Ml'SC) - Page 5 Everett WA 9820 I
WPF DRPSCU 05. OJ 00 Mandatory (612008) - RCW 26. 09.160 425 259-4147 FAX 259 7081
•
1 November 11, off work to be with her. Consequently, I would not be entitled to spend the
2 day with Lauren. I told her that I had the day off because it was a legal holiday, Veteran's
3 Day. There was no school for Lauren on Veteran's Day.
4 I had Lauren with me when she was under the weather several times over the
5 previous few years. Sometimes it happened to be on time that Lauren was scheduled to
6 be with me, other times it happened to be time I could take care of her while Jennifer was
7 atwork.
8 I told her that she need not take the day off, because. and I could provide care for
9 Lauren during the Monday holiday and that I would be happy to pick Lauren up at 6:45 to
10 7:00 the next morning as Jennifer left for work, as I had done many times before. Her
11 response was to tell me that the right of first refusal no longer existed under the temporary
12 parenting plan. I disagreed, and I referred her to the October 24, 2013 parenting plan
13 ich preserved the March 25, 2011 parenting plan's first right of refusal language.
14 Discovery from Swedish documents that Jennifer Mehaddi worked a full day on
15 November 11. She clocked in at 7:25 a.m .. and clocked out for lunch at 12:43 p.m .. 5.3
16 hours. She clocked in after lunch at 1:45 p.m. and clocked out at 5:23 p.m .. 3.63 hours.
17 She was paid for 8.93 hours that day.
18 Lauren was not sick on November 11, 2013. She spent the day with Carol Holland,
19 not with Jennifer. She should have spent it with me. She would have spent it with me if
20 ennifer Mehaddi had not lied to me about her work hours.
21 In an email on November 26, 2013 Jennifer Mehaddi recognized that the first right
22 of refusal continued to exist. She wrote:
23 ...This 4 hour first right of refusal makes everything complicated for everyone
and it needs to go away in the final parenting plan. Lauren is too old for it. In
24
fact - I know it will go away...
25
CARLJ.GAUL
26 At1omey or Law
27 1604 Hewitt Ave.
WPF DRPSCU 05. 0100 Mandatory (612008) - RCW 26. 09. I 60 425 259-4147 FAX 259 7oS!
•
1 B. December10,2013
2 This was a Tuesday, which was then Jennifer's late-day, and Lauren should come
3
· h me when school was out.
4
On December 10, 2013 Lauren was kept home from school. During the day
5
Jennifer texted me that I could not pick Lauren up from school. But she did not tell me that
6
7 Lauren might be ill, and she did not tell me that she was sufficiently ill to see a doctor. At
8 5:00 p.m. Carol Holland took Lauren to Swedish Edmonds where Jennifer was then
9 orking. She was seen by Dr. Fuhrman, the doctor Jennifer worked for'. He saw Lauren.
1O Jennifer told me that Lauren had a sore throat and ear pain, but the doctor's notes do not
11
confirm any portion of her claim. The doctor's notes show that her pulse and temperature
12
ere normal, and no diagnosis was made.
13
Lauren had not been sick at all. The time she spent with Carol Holland should have
14
15 been spent at school, and I should have picked her up at the end of the school day and
16 spent the time with her until her mother got home. If she was too sick to go to school, she
17 should have been home with me, and I would have taken her to Dr. Hastir1gs. Le J t~ r< (
18
I had recess duty the next day, Wednesday, December 11, 2013. Lauren was
19
playing happily. She was not at all sick. In fact, she was energetic as ever.
20
c. February 17, 2014
21
22
23
24
' Lauren's established pediatrician is Dr. Hastings at Everett Clinic Mill Creek,
25 not Swedish.
CARLJ.GAUL
26 Auomey at law
27 1604 Hewin Ave.
Mot/Dec Ord Show Cause re Contempt (MI'Sq - Page 7 Evcren WA 9820 I
1 Jennifer Mehaddi left the Swedish employment on January 20, 2014. F~briJary .3,
2 2014 she was.hired at Polyclinic at Northgate.
3
At Pq_lyclinic Jennifer Mehaddi's Employee ,Actio_n Form when she was hired lists
4
her shift as being from 7:30 a.m. to 5:00 p.m. on Monday, Tuesday and Friday, 9.5 hours
5
each day. Wednesday is her "late day"when she works from 10:30 a.m. to 7:00 p,m., 8.5
6
7 hours. There is no indication of her lunch times, but she ·is scheduled to be at work 38
8 hours per week, compensated for 36 houi:s per Week, with a % hour lunch each day,
9 Jennifer Mehaddi began working regularly on February 17, 2014, President's Day.
10 She clocked in at 7;30 a:m. and clocked out.at 4:30 p.m. Lauren did not have· school as it
11
as a holiday.
12
I had the day off because itwas·a holiday. Jennifer knows I have legal holidays off.
1.3
I have had the same employment.since 1999,. before she. even met me. Jennifer had
14
15 Lauren spend the day with Carol Holland. It· should have been spent with. me.
16 The day before .President's Day was Sunday, February 16. It was Jennifer
17 Mehaddi's residential day. She asked me·to pick up Lauren and take her to soccer that
18 day, which I was glad to do. I delivered Lauren hack to her mother after socceL There
19
as no reason she could not have communicated the need for child care on February 17.
-20
Lauren and I Would ha~e been happy to have the. time together.
21
22
E. February 19, 2014
23 On February 19, 2014 Lauren.should have been with me frorn 1:45 release from
24 school until Jennifer retllmed that evening. Polyclinic records show that Jennifer Mehaddi'
25
CARLJ.GAUL
26 Allorney al Law
302 Bank ofAfi1erica Bldg.
27 1604 Hewitt Ave.
Mo//Dec•OrdShow Cause re Conlempl (MTSC) - Page 8 Everett WA 9.8201
WPFDRPSCU 05. 0100 Mandatqry (612008) - RCW 26. 09.160 425 259-4147 FAX 259 7081
..
1 clocked in at 10:00 a.m. and clocked out at 7:45 p.m .. The afternoon should have been
2 spent with me. not with the grandmother. Instead, Jennifer Mehaddi's mother Carol
3
Holland picked Lauren up from school at 1:45 p.m. She brought Lauren to soccer practice
4
at 5:30 p.m. She left, then returned to pick her up. Jennifer did not appear.
5
F. April 9, 2014
6
7 On April 9 Jennifer simply Mehaddi made plans during the Wednesday afternoon
8 ime Lauren was scheduled to be with me. I questioned her, and she responded that "the
9 hour rule" does not count. I did not want to have a conflict with Carol Holland in front
10 of Lauren. Also, thinking it was a one-time thing I allowed Carol Holland to take Lauren
11
hat afternoon. Lauren spent no time with me after school. Jennifer worked until she
12
clocked out at 7:45 p.m. She would not have been able to get home to be with Lauren until
13
. at least a half hour later. The time should have been spent with me.
14
15 G. April 16, 2014
16 On April 16 the same thing was done again. Jennifer again claimed the 4 hour rule
17 does not apply. Again I allowed Carol Holland to take Lauren rather than have a
18
confrontation in front of Lauren.
19
Thereafter we received discovery from Polyclinic showing the late hours on
20
ednesday are scheduled.
21
2. Jennifer Mehaddi has failed and refused to make a nonemergency
22
medical decision jointly.
23
The Guardian ad Litem has recommended that Lauren should have a counselor.
24
Jennifer and I were each looking into potential counselors. I had narrowed down my list to
25
CARLJ.GAUL
26 Attorney al law
27 1604 Hewitt /\ve.
Mor/Dec Ord Show Cause re Contempt (Ml'SC) - Page 9 Everett WA 9820 I
WPF DRPSCU 05. 0100 Mandatory (612008) - RCW 26. 09.160 425 259-4147 FAX 259 7081
..
1 o, J. Paik and another, both at Everett Clinic Mill Creek. I learned that Dr. Paik is
2 accepting new patients, while the other is not. I received an email from Jennifer Mehaddi
3
hat our daughter has an appointment on May 29 at 2:00 p.m. I thought the notice was
4
abrupt, but I sent back an email that Dr. Paik is one of the people I had in mind. We had a
5
consensus and an agreement to Dr. Paik.
6
7 On May 15, 2014 Jennifer Mehaddi sent me an email that Lauren has an
8 appointment with a different counselor in Marysville. I would not have agreed to this
9 counselor. There was no attempt to reach a joint decision at all. Her action is inconsistent
10 ith the parenting plan.
11
12
Other:
13
14
15 I declare under penalty of perjury under the laws of the state of Washington that the
oregoing is true and correct.
and State]
19
20 Dated: /r o/I 'f.

~
21
22
23
24
25
CARLJ.GAUL
26 Allorney a1 law
27 1604 Hewitt Ave.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page I 0 Everett WA 98201
WPF DRPSCU 05.0100 Mandatory (612008) - RCW 26.09.160 425 259·4147 FAX 259 7081
JENNIFER R. MEHADOI
!Dav Date Punch In Punch In Punch Ou! Punch Out Oepartmen Shift Hour Shift Hou• Total Dallv Total Dally Hours
I Actual Adlusted Actual Adjusted Actual Adjusted Actual Adjusted
410278
Wed 8/14/2013 2:00:00PM 2:00:00PM 5:00:00PM 5:00:00PM 26471932 3 3 3 3
Thu 8/15/2013 1:30:00 PM 1:30:00PM 5:00:00PM 5:00:00PM 26471932 3.5 3.5 3.5 3.5
Fri 8/16/2013 1:4S:OOPM 1:45:00 PM 5:00:00PM 5:00:00PM 26471932 3.25 3.25 3.25 3.25
Mon 8/19/2013 11:40:00AM l1:40:00AM 4:56:00PM 4:56:00PM 26471932 5.27 5.27
Mon 8/19/2013 7:23:00AM 7:23:00AM 10:54:00AM 10:54:00AM 26471932 3.52 352 8.78 8.78
Tue
Thu
8/20/2013 7:59:00AM 1:15:00PM
8/22/2013 7:55:00AM 7:55:00AM
6:31:00PM 6:31:00PM 26471932
6:52:00PM 12:00:00PM 26471932
10.53
10.95
5.27
4.08
10.53 5.27
-:;;
~ti
Thu 8/22/2013 12:30:00 PM 12:30:00PM 6:52:00PM 6:52:00PM 26471932 6.37 6.37 17.32 10.45
Fri 8/23/2013 5:53:00PM 7:30:00AM 5:53:00PM 5:53:00PM 26471932 0 10.38 0 10.38
Mon 8/26/2013 11:42:00AM 11:42:00AM 5:41:00PM 5:41:00PM 26471932 5.98 5.98
Mon 8/26/2013 7:3S:OOAM 7:35:00AM 11:02:00AM 11:02:00AM 26471932 3.45 3.45 9.43 9.43 (
Tue 8/27/2013 8:27:00AM 8:27:00AM 12:19:00PM 12:19:00PM 26471932 3.87 3.87
Tue 8/27/2013 1:17:00PM 1:17:00PM 7:39:00PM 7:39:00PM 26471932 6.37 6.37 10.23 10.23 ...._y
Thu 8/29/2013 8:10:00AM 8:10:00AM 6:20:00PM 6:20:00PM 26471932 10.17 10.17 10.17 10.17
Fri
Fri
8/30/2013 11:35:00AM 11:35:00AM
8/30/2013 7:58:00AM 7:58:00AM
5:39:00PM 5:39:00PM 26471932
11:02:00AM 11:02:00AM 26471932
6.07
3.07
6.07
3.07 9.13 9.13
~J
Mon 9/2/2013 8:44:00AM 8:44:00AM l:lO:OOPM l:lO:OOPM 26471932 4.43 4.43 4.43 4.43
Wed
Wed
9/4/2013 7:42:00AM 7:42:00AM
9/4/2013 11:51:00AM 11:51:00AM
10:46:00AM 10:46:00AM 26471932
5:51:00PM 5:5l:OOPM 26471932
12:04:00PM 12:04:00 PM 26471932
3.07
6
3.07
6 9.07 9.07
j
Thu 9/5/2013 8:29:00AM 8:29:00AM 3.58 3.58
Thu 9/5/2013 12:49:00 PM 12:49:00 PM 6:47:00PM 6:47:00 PM 26471932 5.97 5.97 9.55 9.55 -+-
Fri 9/6/2013 7:15:00AM 7:15:00AM ll:OO:OOAM ll:OO:OOAM 26471932 3.75 3.75
Fri 9/6/2013 12:00:00PM 12:00:00PM 5:13:00PM 5:13:00PM 26471932 5.22 5.22 8.97 8.97 --.$
Mon 9/9/2013 7:31:00AM 7:3l:OllAM 10:32:00AM 10:32:00AM 26471932 3.02 3.fl2 r.
Mon
Tue
9/9/2013 11:20:00AM 11:20:00AM
9/10/2013 8:18:00AM 8:18:00AM
5:30:00PM 5:30:00PM 26471932
12:15:00PM 12:15:00PM 26471932
6.17
3.95
6.17
3.95
9.18 9.18
l
Tue
Thu
9/10/2013 l:lO:OOPM l:lO:OOPM
9/12/2013 12:55:00 PM 12:55:00 PM
8:14:00PM 8:14:00PM 26471932
6:31:00 PM 6:31:00PM 26471932
7.07
5.6
7.07
5.6
11.02 11.02
:r
Thu 9/12/2013 8:39:00AM 8:30:00AM 12:02:00 PM 12:02:00PM 26471932 3.38 3.53 8.98 9.13 'vJ
Fri 9/13/2013 7:40:00AM 7:40:00AM 10:47:00AM 10:47:00AM 26471932 3.12 3.12
'
;.
Fri 9/13/2013 11:47:00AM 11:47:00AM 5:32:00PM 5:32:00PM 26471932 5.75 5.75 8.87 8.87
Mon 9/16/2013 1:30:00PM 1:30:00PM 7:52:00PM 7:52:00 PM 26471932 6.37 6.37
Mon 9/16/2013 7:59:00AM 7:59:00AM 12:28:00PM 12:28:00 PM 26471932 4.48 4.48 10.85 10.85
Tue 9/17/2013 1:2l:OOPM 1:21:00 PM S:Ol:OOPM S:Ol:OOPM 26471932 3.67 3.67
Tue 9/17/2013 8:02:00AM 8:02:00AM 12:43:00PM 12:43:00 PM 26471932 4.68 4.68 8.35 8.35
Thu 9/19/2013 7:57:00AM 7:57:00AM 6:19:00PM 6:19:00PM 26471932 10.37 10.37 10.37 10.37
Fri 9/20/2013 11:24:00AM 11:24:00AM 5:42:00PM 5:42:00PM 26471932 6.3 6.3
Fri 9/20/2013 7:40:00AM 7:40:00AM 10:46:00AM 10:46:00AM 26471932 3.1 3.1 9.4 9.4
Mon 9/23/2013 7:29:00AM 7:29:00AM 11:08:00AM 11:08:00AM 26471932 3.65 3.65
Mon 9/23/2013 11:43:00AM 11:43:00AM 5:37:00 PM 5:37:00PM 26471932 5.9 5.9 9.55 9.55
Tue 9/24/2013 8:26:00AM 8:26:00AM 12:11:00PM 12:ll:OOPM 26471932 3.75 3.75
Tue 9/24/2013 1:06:00 PM 1:06:00PM 8:17:00 PM 8:17:00 PM 26471932 7.18 7.18 10.93 10.93
Mon 9/30/2013 7:23:00AM 7:23:00AM 11:23:00AM 11:23:00AM 26471932 4 4
Mon 9/30/2013 11:53:00AM 11:53:00 AM 6:11:00 PM 6:11:00 PM 26471932 6.3 6.3 10.3 10.3
Tue 10/1/2013 8:2l:OOAM 8:21:00AM 11:59:00AM 11:59:00AM 26471932 3.63 3.63
Tue 10/1/2013 12:56:00 PM 12:56:00 PM 7:56:00PM 7:56:00 PM 26471932 1 7 10.63 10.63
Sat 10/5/2013 8:12:00AM 8:12:00AM 1:49:00PM 1:49:00PM 26471932 5.62 5.62 5.62 5.62
Mon 10/7/2013 7:3l:OOAM 7:31:00 AM 5:55:00PM 5:55:00PM 26471932 10.4 10.4 10.4 10.4
Tue 10/8/2013 1:14:00PM 1:14:00 PM 6:03:00PM 6:03:00PM 26471932 4.82 4.82
Tue 10/8/2013 8:30:00AM 8:30:00AM 12:14:00PM 12:14:00PM 26471932 3.73 3.73 8.55 8.55
Thu 10/10/2013 lO:Sl:OOAM lO:Sl:OOAM 6:32:00PM 6:32:00PM 26471932 7.68 7.68 7.68 7.68
Fri 10/11/2013 12:43:00 PM l2:43:00PM 4:20:00 PM 4:20:00PM 26471932 3.62 3.62
Fri 10/11/2013 7:59:00AM 7:59:00AM 11:44:00AM 11:44:00AM 26471932 3.75 3.75 7.37 7.37
Mon 10/14/2013 7:55:00AM 7:55:00AM 12:20:00PM 12:20:00PM 26471932 4.42 4.42
Mon 10/14/2013 1:23:00 PM 1:23:00 PM 6:05:00PM 6:05:00 PM 26471932 4.7 4.7 9.12 9.12
Tue 10/15/2013 8:20:00AM 8:20:00AM 1:06:00 PM 1:06:00PM 26471932 4.77 4.77
Tue 10/15/2013 1:44:00PM 1:44:00 PM 7:42:00PM 7:42:00 PM 26471932 5.97 5.97 10.73 10.73
Thu 10/17/2013 7:SO:OOAM 7:50:00AM 5:16:00PM 5:16:00PM 26471932 9.43 9.43 9.43 9.43
Fri 10/18/2013 7:34:00AM 7:34:00AM U:35:00AM 11:35:00AM 26471932 4.02 4.02 4.02 4.02
Sat 10/19/2013 8:17:00AM 8:17:00AM 12:47:00PM 12:47:00 PM 26471932 4.5 45 4.5 4.5
Mon 10/21/2013 8:0l:OOAM 8:0l:OOAM 1:09:00 PM 1:09:00PM 26471932 5.13 5.13 5.13 5.13
Tue 10/22/2013 8:0S:OOAM 8:05:00AM 12:03:00PM 12:03:00PM 26471932 3.97 3.97
Tue 10/22/2013 1:03:00PM 1:03:00 PM 6:46:00PM 6:46:00PM 26471932 5.72 5.72 9.68 9.68
Thu 10/24/2013 1:19:00 PM 1:19:00PM 6:25:00PM 6:25:00PM 26471932 5.1 5.1 5.1 5.1
•
Fri 10/25/2013 7:29:00AM 7:29:00AM 12:21:00 PM 12:21:00PM 26471932 4.87 4.87
Fri 10/25/2013 l:OS:OOPM 1:08:00PM 5:32:00PM 5:32:00PM 26471932 4.4 4.4 9.27 9.27
Mon 10/28/2013 7:37:00AM 7:37:00AM 11:13:00AM 11:13:00AM 26471932 3.6 3.6
Mon 10/28/2013 11:46:00AM J1:46:00AM 5:34:00PM 5:34:00PM 26471932 5.8 5.8 9.4 9.4
Tue 10/29/2013 l:lO:OOPM l:lO:OOPM 5:37:00PM 5:37:00PM 26471932 4.45 4.45
Tue 10/29/2013 8:19:00AM 8:19:00AM 12:40:00PM 12:40:00PM 26471932 4.35 4.35 8.8 8.8
Mon 11/4/2013 8:03:00AM 8:03:00AM 8:13:00AM 8:13:00AM 26471932 0.17 0.17 0.17 0.17
,\ Thu 11/7/2013 l:OS:OOPM 1:08:00 PM 6:45:00PM 6:45:00PM 26471932 5.62 5.62
~l>J '),>>1 tJo"~....,._.t.,,,._,,. ~ \

Thu 11/7/2013 7:49:00AM 7:49:00AM 12:08:00PM 12:08:00PM 26471932 4.32 4.32 9.93 9.93
Fri 11/8/2013 7:51:00AM 7:5l:OOAM 10:46:00AM 10:46:00AM 26471932 2.92 2.92
Fri 11/8/2013 11:16:00AM 11:16:00AM 5:15:00PM 5:15:00PM 26471932 5.98 5.98 8.9 8.9
"~I
Mon
Mon
Tue
Tue
11/11/2013
11/11/2013
11/12/2013
11/12/2013
7:25:00AM
1:45:00PM
8:49:00AM
1:18:00PM
7:25:00AM
1:45:00PM
8:49:00AM
1:18:00PM
12:43:00PM
5:23:00PM
12:12:00PM
7:39:00PM
12:43:00PM
5:23:00PM
12:12:00 PM
7:39:00PM
26471932
26471932
26471932
26471932
5.3
3.63
3.38
6.35
5.3
3.63
3.38
6.35
8.93
9.73
8.93
9.73
v
Thu 11/14/2013 9:59:00AM 9:59:00AM 12:02:00PM 12:02:00 PM 26471932 2.05 2.0S
Thu 11/14/2013 12:23:00PM 12:23:00 PM 6:16:00PM 6:16:00PM 26471932 5.88 S.88 7.93 7.93
Fri 11/15/2013 11:18:00AM J1:18:00AM 5:28:00 PM 5:28:00PM 26471932 6.17 6.17
Fri 11/15/2013 7:10:00AM 7:10:00 AM 10:3S:OOAM 10:35:00AM 26471932 3.42 3.42 9.58 9.58
Sat 11/16/2013 8:18:00AM 8:18:00AM 3:33:00PM 3:33:00PM 26471932 7.25 7.25 7.25 7.25
Mon 11/18/2013 lO:JO:OOAM lO:lO:OOAM 5:45:00PM 5:45:00PM 26471932 7.58 7.58 7.58 7.58
Tue 11/19/2013 8:19:00AM 8:19:00AM 12:16:00PM 12:16:00 PM 26471932 3.95 3.95
Tue 11/19/2013 l:Ol:OOPM l:Ol:OOPM 6:04:00PM 6:04:00 PM 26471932 5.05 5.05 9 9
Thu 11/21/2013 9:52:00AM 9:52:00AM 6:21:00PM 6:21:00 PM 26471932 8.48 8.48 8.48 8.48
Fri 11/22/2013 8:08:00AM 8:08:00AM 12:01:00PM 12:01:00 PM 26471932 3.88 3.88
Fri 11/22/2013 12:28:00PM 12:28:00PM 4:21:00PM 4:21:00PM 26471932 3.88 3.88 7.77 7.77
Mon 11/25/2013 ll:JO:OOAM Jl:lO:OOAM 5:33:00PM 5:33:00PM 26471932 6.38 6.38
Mon 11/25/20~.3 7:3l:OOAM 7:31:00AM 10:31:00AM 10:3 UlO AM 26471932 3 3 9.38 9.38
Tue 11/26/2013 8:19:00AM 8:19:00AM 12:22:00PM 12:22:00 PM 26471932 4.05 4.05
Tue 11/26/2013 1:23:00PM 1:23:00PM 8:25:00PM 8:25:00PM 26471932 7.03 7.03 11.08 11.08
Fri 11/29/2013 1:40:00PM 1:40:00PM 3:25:00PM 3:25:00PM 26471932 l.75 1.75
Fri 11/29/2013 8:00:00AM 8:00:00AM l:06:00PM 1:06:00PM 26471932 5.1 5.1 6.85 6.85
Mon 12/2/2013 11:44:00AM J1:44:00AM 5:20:00PM 5:20:00PM 26471932 5.6 5.6
Mon 12/2/2013 7:42:00AM 7:42:00AM ll:OS:OOAM 11:08:00AM 26471932 3.43 3.43 9.03 9.03
Tue 12/3/2013 8:12:00AM 8:12:00AM 12:32:00PM 12:32:00PM 26471932 4.33 4.33
Tue 12/3/2013 1:15:00 PM 1:15:00 PM 12/5/2013 7:28 8:25:00PM 26471932 42.22 7.17 46.55 11.5
Thu 12/5/2013 1:17:00 PM 1:17:00 PM 6:24:00PM 6:24:00PM 26471932 5.12 5.12
Thu 12/5/2013 7:30:00AM 7:30:00AM 12:24:00 PM 12:24:00 PM 26471932 4.9 4.9 10.02 10.02
~ Fri 12/6/2013 11:44:00AM 11:44:00AM 5:13:00PM 5:13:00PM 26471932 5.48 5.48
I
Fri 12/6/2013 7:10:00AM 7:10:00AM 11:04:00AM 11:04:00AM 26471932 3.9 3.9 9.38 9.38
Mon 12/9/2013 7:27:00AM 7:27:00AM 10:47:00AM 10:47:00AM 26471932 3.33 3.33
11:34:00AM 11:34:00AM 5:34:00PM 5:34:00PM 26471932 6 6 9.33 9.33
~:n
12/9/2013
v,;~ I Tue
Thu
12/10/2013
12/10/2013
12/12/2013
12:43:00PM
8:2l:OOAM
7:54:00AM
12:43:00PM
8:21:00AM
7:54:00AM
5:23:00PM 5:23:00PM
12:10:00 PM 12:10:00 PM
6:38:00PM 6:38:00PM
26471932
26471932
26471932
4.67
3.82
10.73
4.67
3.82
10.73
8.48
10.73
8.48
10.73
Fri 12/13/2013 7:24:00AM 7:24:00AM 10:47:00AM 10:47:00AM 26471932 3.38 3.38
Fri 12/13/2013 11:20:00AM 11:20:00AM 4:36:00PM 5:30:00 PM 26471932 5.27 6.17 8.65 9.55
Mon 12/16/2013 11:12:00 AM ll:l2:00AM 5:12:00PM 5:12:00PM 26471932 6 6
Mon 12/16/2013 7:40:00AM 7:40:00AM 10:39:00AM 10:39:00AM 26471932 2.98 2.98 8.98 8.98
Tue 12/17/2013 · 8:02:00AM 8:02:00AM 12:04:00PM 12:04:00 PM 26471932 4.03 4.03
Tue 12/17/2013 12:52:00 PM 12:52:00PM 4:30:00PM 4:30:00 PM 26471932 3.63 3.63 7.67 7.67
Thu 12/19/2013 7:18:00AM 7:18:00AM 6:0l:OOPM 6:01:00 PM 26471932 10.72 10.72 10.72 10.72
Fri 12/20/2013 5:29:00PM 12:00:00PM 5:29:00PM 5:29:00PM 26471932 0 5.48 0 5.48
Sat 12/21/2013 12:29:00PM 8:41:00 AM l2:29:00PM 12:29:00 PM 26471932 0 3.8 0 3.8
Mon 12/23/2013 7:15:00AM 7:15:00AM 4:42:00PM 4:42:00PM 26471932 9.45 9.45 9.45 9.45
Thu 12/26/2013 7:40:00AM 7:40:00AM 8:34:00AM 8:34:00AM 26471932 0.9 0.9
Thu 12/26/2013 10:36:00 AM 10:36:00AM 6:48:00PM 6:48:00PM 26471932 8.2 8.2 9.1 9.1
Fri 12/27/2013 7:54:00AM 7:54:00AM 5:30:00 PM S:30:00PM 26471932 9.6 9.6 9.6 9.6
Sat 12/28/2013 9:00:00AM 9:00:00AM 3:30:00PM 3:30:00 PM 26471932 6.S 6.S 6.5 6.5
Tue 12/31/2013 7:42:00AM 7:42:00AM 3:54:00PM 3:54:00 PM 26471932 8.2 8.2 8.2 8.2
Wed 1/1/2014 8:4S:OOAM 8:45:00AM 1:36:00PM 1:36:00 PM 26471932 4.85 4.85 4.85 4.85
Sat 1/4/2014 8:28:00AM 8:28:00AM 3:30:00 PM 3:30:00PM 26471932 7.03 1~03 7.03 7.03
Employee Last Name: Employee First Name: Effective Date or Action:
Mehaddi Jennifer 2-3-14
REASON FOR ACTION

0 Allocation Change 181 New Employee 0 Performance Evaluation 0 Promotion 0 Rehire Employee
0 Schedule Chan11e 0 Status Change D Termination 0 Transfer n Other:
NEW JOB INFORMATION

New Allocation: New Posltionfl'ltle: Medical Assitant New Base Rate:
% at Cost Center - Location 20.IS
100 % 8134100 -300 Name to Appear on Badge: Jennifer
Differential:
o/o at - Position Title to Appear on Badge: Medical Assistant
%at - New Location:

Physician: Dr. Gugel Click Here to Choose Other:
New Status: NewFfE: New #or Hrs a week: New Direct Supervisor:
D Regular Full-Time (40 hrs) .9 36 Chris Tews
181 Regular Part-Time(< 40 hrs) New Shift (Schedule): New Emp. #: (HR use only)
002570
0Per Diem (I 5% differential) 7:30 to 5:00 181 M 181 T 0 W D Th 181 F 0 S 0 Su
0Temp 10:30 to7:000M OT ~w 0Th OF Os Osu
PERFORMANCE EVALUATION I MERIT INCREASE '\

RN (Clinical Only):
D Annual evaluation 0 90 days evaluaiion 0 6 months evaluation
0 Top Performer
Performance Rating: D Leading Performer
D Strong Perfonner
D Top Perfonner D Leading Performer D Strong Performer D Developing Performer D Developing Performer
0
/o Increase: (HR will do necessary prorating) Notes: New RN Step:
Merit Increase Prorating (HR use only) Next Reviews (HR use only}
Prorated Increase?: ONo 0Yes Days Prorated: Prorated % Increase: Next Performance Review
Date:
Market Adjustment: (HR use only):
New Base Rate After Merit Increase: Next Salary Review Date:
Market Adjusanent?: ONo DY es % If Yes, New Base Rate After Market Increase:
(market adjusanenrs proraied on the same schedule as merit increases)
ADDITIONAL COMPENSATION
0 Referral Bonus Name: 0Commission 0Bonus 0 Other: Amount:
TERMINATION
Last Work Date:
Termination·Type: Termination Reason:
0 Involuntary D Better Opportunil)I 0 Education 0 Job Abandonment
(Submit a Termination Form for all involunlary terms) 0 Job Dissalisfaction 0 Location D Perfonnance
0Voluntary D Personal I Family 0 Retirement 0 Reduction in Force/Layoff
\ D Other (please specify):
..-------'----'---------'
I Comments: Jennifer will be taking 112 hour lunch
Authorized Signature: Chris Tews Date: 1-22-14
HR Review: TM Outside Policy Administrator Authorization:

Date: 213/14 Date:
Employee Punches By Day Report
Run by: EMEODl9SnPC R.unat: 04/15/2014 12:06 EST
Employee: 002570-TPC
Team:
Date Selection: oyo312014 - 04/141201"' .
Team FuP Nome Work Date Hours Productive Overtime Absent P_und! ' ·- . .· :. • -~.. ';.;j:-':: 'f:?~
~ame ' - 0
:··-·
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- . J:!ata ... : ·~I . ~ . •, .,_ ~.<fj,\~""fi-tc··•'
/. -·~ -'.-),'fi:-~:~t..:.'~~:'!
34100 Mehaddl, 02/03/2014 9.00 7.00 GMTOFFSET=·
14:45 ON
Jennifer 28800
02/06/2014 a.so a.oo 09:00 ON
GMTOFFSET=·
28800
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GMTOFFSET=-
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- ---·-·----.
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GMTOFFSET=·
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28800
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08:45 ON
28800
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... •... ...·--·· . ··- - .. ,. ---~-
. -·-- 28800
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-· ·---- .. ----
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28800
.. --.- ··"·-~· • -- _. -- 07:30 •.•ON GMTOFFSET=·
2007 Jnfor. AU rights reserved. www.lnfor.com. Page 1 of 3 Employee Punches By Day Report
•
Employee Punches By Day Report

Run by: EME001987TPC Run at: 04/15/2014 12:06 EST
Employee: 002570-TPC
Teem:
Date Selection: 02/03/2014 - 04/14/2914
04/09/2014 10.75 8.00 I.DO 10:00 ON GMTOFF5ET=·

25200
19:45 OFF GMTOFF5ET=·
25200
04/11/2014 10.00 8.75 0.25 07:30 GMTOFFSET~
ON
25200
•r~•--
04/14/2014 11.25
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7.50
... _.___
17:15
07:15
OFF GMTOFFSET=·
25200
GMTOFFSET=·
ON 25290
17:00 GMTOFFSET=·
OFF 25200
Mohaddl, Jonnlter total: 362.25 280.25 2.00 4.25
34100 total: 362.25 280.25 2.00 4.25
2007 Jnfor. All nghts reserved. www.lnfor.com. Page 3 ot 3 Employee Punches By Day Report
From: Jenn <jennifermehaddi@comcast.net>
Date: April 9, 2014, 8:37:19 AM PDT
Subject: Re: Lauren
Today easier on my mom. She still works. Utilizing this 4 hour rule is ridiculous and
everyone agrees and it's not fair to Lauren. She's a person - not ownership Andy. Do as
you want and take time away from me. This 4 hour rule won't last long.
Sent from my iPhone
On Apr 9, 2014, at 8:32 AM, Andrew Rife <asrife001@icloud.com> wrote:
Why can't she come to your work on Friday after school?
Sent from my iPhone
On Apr 9, 2014, at 8:28 AM, Jenn <jennifermehaddi@comcast.net> wrote:
Always last minute and planned. My mom was going to bring her to my work to
have lunch with me and meet my co workers.
Sent from my iPhone
On Apr 9, 2014, at 7:31 AM, Andrew Rife <asrife001@icloud.com> wrote:
I am volunteering at the school today so I'm going to go ahead and pick

Lauren up and spend the afternoon with her. I'll have to your house by 7:00pm. Dinner
and homework will be done.
•

Date: April 9, 2014, lt41 :29 AM PDT
·To: Andrew Rife <asrife001@icloud.cor:n>
Subject: Re: Lauren
I shouldn't have to answer your questions.on my daywith her - but she gets off
school early and my lunch is at·3pm today. So therefor the 4 hour rule doesn't count.
My mom ..will get her.
Sent from my iPhonl:,!
.On Apr 9, 2014, at 8:32 AM, Andrew.Rife <asrife001@icloud.com> wrote:
Why can't she c:Ome to your work on.Friday after school?'·

..
•
That's not child care. I will be picking her up at 1;45pm. I let it go last week. I have since
confirmed with my attorney that a lunch break does not qualify as child care. Therefore,
I will be exercising my right of first right of refusal. If you find yourself getting off of work
early, let me know and I will bring Lauren to you.
Sent from my iPhone
On Apr 16, 2014, at 7:31 AM, Jenn <jennifermehaddi@comcast.net> wrote:
> No she's coming to my work for lunch and she's already aware of this and excited. So
therefor the 4 hour rule does not apply.
>
> Sent from my iPhone
>
>>On Apr 16, 2014, at 7:06 AM, Andrew Rife <asrife001@icloud.com> wrote:
>>
>> Pursuant to the parenting plan I will be picking Lauren up from school today at 1:45.
Today is your late day and I am available to care for her. Her homework will be done
and she will be fed dinner.
>>
>> Sent from my iPhone
•
•

Date: May 12, 2014, 1:06:14 PM PDT
To: Jenn Mehaddi <-jennifermehaddi@comcast.net>
Cc: Elise Buie <elisebuie@gmail.com>
Subject: Re: Jeanne Paik, LH - Behavioral Health - Mill Creek, WA - The Everett
Clinic
I have a couple of counselors names at the Everett clinic. Jeanne Paik was one of
them and Stephanie garrison was the other. I called the clinic this morning to see which
one was accepting new patients. Jeanne Paik is and Stephanie Garrison is not. Both of
them came highly recommended.
Sent from my iPhone
On May 12, 2014, at 12:58 PM, Jenn Mehaddi <jennifermehaddi@comcast.net>

wrote:
Since I have not heard from Andy from my last email, I have scheduled Lauren to
see Ms. Paik at The Everett Clinic behavioral health in mill creek at 2pm on Thursday
the 29th of this month. Most places are extremely booked or not taking new patients.
I've heard good things about Ms. Paik especially in regards to children. I hope this will
be a good fit for Lauren. I had the scheduler make a note that the therapist will need to
talk to each Andy and I separately to get a brief run down on what is going on and what
Lauren is going through and dealing with.
Thanks,
Jennifer
•
•
From: Jenn Mehaddi <jennifermehaddi@comcast.net>

Date: May 15, 2014, 2:14:01 PM PDT
To: Andy Rife <asrife001@icloud.com>
Subject: Fwd: Welcome & Counseling Forms
I will fill out the paperwork and you can take care if the insurance portion. You will be
reimbursed out of network. If there is a portion I am responsible for than I expect a bill
showing what I owe per the current parenting plan.
Sent from my iPhone
From: "Kerry Kirsch, MA, LMHC" <kerry@ruahcounseling.com>

Date: May 15, 2014at1:51:48 PM PDT
To: jennifermehaddi@comcast.net
Subject: Welcome & Counseling Forms
Hi Jennifer,
I am glad that we were able to talk earlier and set up an appointment for your
daughter for 10:00 AM Thursday, 5/29/14, in Marysville. I want to make sure that you
have all the info to my office there and I find it helpful to have clients fill out my intake
forms prior to the session, so I've attached them for you to fill out.
The address to my office is:
1622 3rd Street

Marysville, WA 98270
My office is located downstairs, so you will want to follow the ramp to the back of
the house and enter the door in the back to go downstairs to the waiting room.
If you have any questions on the attachments, please let me know.
In addition, my website info is www.ruahcounseling.com. My licensure information

is not updated yet on the site, but I am a Licensed Mental Health Counselor currently.
I look forward to meeting with you and being of help to your daughter.
Take care,
Kerry
FILED
ZOI~ 11AY 19 Pl'I 3: 56
1
SONYA KRASKI
2 COUNTY CLERK
l~l~/~///l/~///~/ll~/~11/11~//
~1mHn~ISH co WASH
3
4
CL16592754
5
7 NO. 05 3 02755 1
Andrew Scott Rife
and CONTEMPT
9 Jennifer Rae Rife (ORTSC)
Respondent.
IT IS ORDERED:
11
Jennifer Rae Rife shall appear in person before this court at the place and time below
12 and show cause why the relief requested in the motion should not be granted.
13 Date: June 3, 2014 Time: 9:00 a.m.
15
If you fall to appear in person and defend at these proceedings the court may grant all of the
16 relief requested and/or issue a bench warrant for your arrest without further notice to you.
17 If Imprisonment is requested in the motion and you cannot afford an attorney, you may request
e court to appoint an attorney to represent you.
18
Other:
19 MAY 1 9 2DH
Dated: April 10, 2014
20 Ju ge / Commissioner
21 opy Received:
22
23 Veronica Frei WSBA# 19405

Attorney forJen r Rae Rife
24
25
26
27
ORIGINAL
Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1
CARLJ.GAUL
Allomey at Law
1604 Hewitt Ave.
Everett WA 9820 I
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160 425 259-4147 FAX 259 7081
. ,
3
,,
4
s
6
l~~~I~CL16740554
1~~1111I ~iI Ii~ 1~11~ -m
r
7
;::,;J
8
County of Snohomish
9
In re:
10
II Petitioner,
nod DECLARATION OF JENNIFER
12
JENNIFER MEHADDl (fka Jennifer Rife),

MEHADDI IN RESPONSE TO
13 MOTIONS RE CONTEMPT
Respondent.
14
15 My name is Jennifer Mehaddi. I nm over 18 years old and am competent to testify as

16
witness in this matter. I am the Respondent in this case. l11c Petitioner, Andy Rife and I wcr
17
previously married and have a nine year old daughter together, Lauren. I have read Andy's motio
18
19 nnd am submitting this declaration in response to both of those motions.
20 I am not in contempt. l have not willfully or intentionally violated any com1 orders. In fact.
21
the opposite is tme. I have tried as hard as possible to comply with all of the current orders of th
22
comt even though there are many things going on right now that I believe are very hanuful an
23
damaging lo Lauren.
24
25 I believe that Andy has filed both of these contempt motions because he wnnts to punish me
26 Audy is a very abusive person. Our short mru1·iage was nightmare during which he was incredibl}
27
controlling nnd was both physically and emotionally abusive towards me. He was charged mm
28
VERONICA FREITAS
DECLARATION
Pngelofl7 ORIGINAL 210 Summll Avenue Enst
SenUlc, Wnshlnglon 98102
(206) 328-7362
1·@vfrcllnslnw.co111
•
than one limo for assaulling me. He was ordered to attend domeslic violence batterer's treatmen
2
and he ended up nltending at least four separnte domeslic violence balterer's treatment pmgram
3
before finally being able 10 complete one. The finnl parenting plan from our divorce had Laure1
4
s living wilh me primarily, included restriclions against Andy, gave me sole decision making and ha
6 Andy's time with Lauren professionnlly supervised. I am including that parenting plan as Exhibit A.
7 Andy and I got along alright for quite a while and I was letting him spend extm time wit!
8
Lauren, outside our parenting plan. He 1hen begnn pressuring me to change our parenting plan.
9
declined repeatedly, but we had been gelling along very well for a long time. Lnuren was enjoyin
10
JI
her ti.me with him and we had been able to work out whalever minor issues we had. I agreed I
12 modify the parenting plan so that it would reflect the schedule 1hat we had been following. And
13 wanted to get rid of the sole decision making and prolllised me repeatedly that he had changed hi
14
abusive ways and that we would be able to conlinue getting along. I trnsted him and agreed t
15
change the parenting plan. That was a mistake. I should not have trnsted him.
16
17 Andy has golten more and more obsessive and controlling since thnt parenting plan wa
18 entered. He filed a pelition to modify the parenting plan recenlly seeking to change residentia
19
placement. We are currently in lhe midst of that modificalion case now.
20
Elise Buie was appointed as our GAL in lhe modificnlion case. She completed her repo
21
and concluded that NONE of Andy's outrageous claims were 1111e. She recommended that Lnure1
22
23 remain wilh me the majority of lhe lime nnd for me lo have sole decision making for non emergene
24 heallh care, exlrncurriculm· activilies and counselling for Lauren. She recommended thnt Andy hav
2S
sole decision making for non-emergency denial care and haircuts, which have never been an issue
26
I am providing a copy of the report under a sealed report coversheet
27
28
VERONICA FRRITAS
Dl!CLARATJON 2IO Summll Avenue Ens!
Page 2of17 Seotlle, Woshlnglon 98102
(206) 328-7362
v@vfreltnslnw.com
•
Andy has been even more hostile, ngitnted and aggressive since her report cnme out.
2
believe that these contempt motions are an attempt by Andy to get back at me. I do not believe thn
3
he thinks I am really in contempt, but I know that he really docs want me to be punished. I am
4
s good parent Wld I have a good relationship with our daughter. This legal case and Andy's obsessiv
6 and crazy behaviour are tearing Lauren apart. I am frightened for om· daughter. lam frightened f01
7 myself. I do not know what else Andy is going to do or how far is going to take this.
8
As I mentioned above, l do not believe that I am in contempt. These motions should b
9
dismissed. I will respond to each allegation below.
10
ti
Transporting to Pmcliccs nod Games-
12 I have not intentionally failed to get Lauren to soccer practice. Contrary to Andy's claims,
IJ am very supportive of Lauren's soccer playing. Soccer has become n huge issue over the past fe\\
t4
months, in part because I cannot get any clear communication from anyone including Andy or ti
IS
Rush soccer coaches and staff. It was my nnderstwtding that the soccer season had ended. Laure
16
17 had her last soccer game und her end of the season pruty in March. Th.is is confirmed in an emuil
18 that was sent out to parents on March 23n1 (Exhibit B). Another email was sent out lo parents o
t9
March 23n1 congratulating the girls for " ... ending the season and tourney with some great winslll"
20
That email is attached us Exhibit C. l believed that that meant that the season was over. It turns ou
21
that in select level soccer, the season is never really over. I had no idea that is how it worked when
22
23 agreed to it. I have tried to get a straight answer out of Andy nnd Lauren's coaches for months nbou
24 when the season ends and I never get the same answer twice. I am including some of my emails I
2S
her coaches inquiring about when the season ends etc. as Exhibit D.
26
Lauren does enjoy soccer nnd she is very good at it. However, I am very conccmed abou
27
28
VERONICA FREITAS
V. FREITAS I.AW, PLLC.
DECLARATION llO S11n1n11t Avenue East
Page 3 ofl7 Sentlle, Washington 98l02
(206) 328-7362
v@vfrcltaslnw.com
•
how much soccer she is playing. She hos been playing on the Rush select soccer team. l11is te
2
hns two practices per week that go until 7:00p.m. They also have at least one gW11e per week on th
weekends. In addition to thnt they piny all day toummncnts in locations as fur away as Puyallup an
Olympia. In addition to the regular Rush schedule, it hm1cd out that !here was also a winte1· indom
6 soccer schedule. When the regular winter season was over and 1hey had the end of season pa1ty,
7 was shocked when the email was sent out informing the parents that the practices would continu
8
and that they were expected to participate in the "State Cup" toumament in Olympia and that the
9
would be another toumament the following weekend as well. l11c season was over ru1d I had mad
10
II
plans for Lauren to have a sleepover with her cousins. She was very excited about it and I believ
12 that the soccer season was over. I should not be found in contempt for this.
13 Andy's own declorntion is ve1y confusing. On pages six and seven of his own declaration h
14
writes " ... indoor (soccer) is separate from Washington Rush, on October 22, 2013 the Rush coac
IS
wrote about the upcoming indoor games ... " he then writes " ... I agreed that Lauren would not pla
16
17 indoor lost winter, though she did play in the si:< games she wonted to during the times she was will
18 me. Rush resmned in late January''. So again, was the season over or was it not over? Was indoo1
19
soccer part of the year round season or not? Why was it resuming if it is year round? It doesn'
20
make any sense.
21
In addition to playing soccer and attending school, Andy also takes Lauren skiing on th
22
23 weekends W1d school breaks. I think that skiing is great and I run glad that she gets the opporhmil
24 to do so, but adding that on at the same time soccer is happening is too much.
Lauren was sick and exhausted for almost the entire winter. Andy refuses to acknowledg
26
this. When I first start~d hying to talk to him about Lauren taking a break from soccer, h
27
28
VERONICA FREITAS
DECLARATION 210 Summit Avenue East
Page4ofl7 Sentlle, Wnshlnglnn 98102
(206) 328-7362
'®vfreltnslnw.com
immediately began emailing her teachers and her coaches lo get them to say that she was health
2
and fine. She had brouchilis mulliple times. She has reactive airways disease and was diagnose
3
with asthma earlier this year.
4
Lnnren docs not gel enough down time and she needs more rest. She is nctive and healthy
6 but she needs more time to relax and be a kid. Almost every lime it is time for her to go to soccei
7 practice or a soccer game when she is with me, she complains that she is too tired and that she wan
8
to stay home, but she is always terrified that I will tell Andy. She has expressed numerous tim
9
that there are other sp011s and other activities that she would like to try, but she doesn't want t
10
II
disappoint Andy. There are other times that she just wants to stay home and rest. Select soccer i
12 too much for Lauren right now. Had 1 realized that it was a year round, non-stop activity, I woul
13 have never agreed to it. Contrary to what Andy stales in his declaration, I was not aware that sclcc
soccer meant that she would be playing year round. I agreed that she could try select soccer but Iha
doesn't mean that l agreed that she would play select soccer forever. It appeared that the season ha
16
17 ended when the coaches sent emails talking about how the season had ended. I tried to discuss th
18 next season with Andy and when we didn't agree, I sta11ed the mediation process.
19
Port of the issue with soccer is that Andy never put me doWll as her other parent, emergent}
20
contact, contact person, person Lauren resides with or ns Lauren's primnry residential parent. And
21
inteillionally left me off of all her registration fonns. I hove been lo ulmost nll of Lauren's game
22
23 that have fallen during my residential time and all practices that have fallen during my rcsidcntia
24 time when l have not lmd to work. I have met the coaches many, many times. When I tried to ge
2S
information about Lnuren's registration, I was refused. I had to go all the way up to the CEO o
26
Washington Rush soccer in Colorado lo try and gel info111111tion about my own daughter. I then ha
27
28
VERONICA FREITAS
Y. FREITAS LAW,PLLC.
DECLARATION 210 Summit Avenue Ensl
Page S of 17 Sentllc, Wnshlnglon 98102
(206)328-7362
v@vfrcllaslnw.com
to provide lhe coaches here, who I have met many times wilh Lauren, with a copy of her birt
2
ce11ificatc, our parenting plan and my idenlificalion before !hey would acknowledge me as he1
3
mother. Even then they refused to release Lauren's registration infonnation to me. Had Andy pu
4
my contact info1mation down when he registered her, this wouldn't have been such a big problem
6 I am including many of these emails between myself and Rush Soccer as Exhibit E.
7 While Andy and I did agree thnl Lauren could try select soccer and while I have tried very
8
very hard to reach agreements with him, I would like to point out that our cmrent parenting plan nn
9
temporary order are silent on how extracurricular activities shall be decided. Per our current orders
10
11 cxtmcu11icular activities do not need to be made joinlly. ll is my understanding that this means tha
12 extrncun'iculnr nclivities should be decided by me only as I am Lauren's primary parent. While th

13
cmrenl temporary order does stale that we must get Lauren to her games and practices, that does no
14
mean the she must be re-registered on the same tenm or re-registered at all. The Rush socce1
IS
structure is slill unclear to me. It is still unclear if the "player cw'd" means that she is active!
16
17 registered on lhe team and if it does mean thnt then why would she have tryouts for fell if the playc1
18 card is good through August? Again, I should not be found in contempt on this issue as I have no
19
intentionally refused to take Lauren to her games or practices. I thought the soccer season was oveJ
20
and could get no clear i11fo11nation proving otherwise.
21
22
Andy states in his declaration that I have always been happy to have him take Lauren t
23 practices wtd games dm'ing my lime. This is not tme. There have been times that I have been o
24 with Andy taking Luuren, often times I agreed to this lo avoid w·guing with him. Andy ca1u1ot ta!<
25
no for an answeJ-. Other times I let him take her to out of town toumamenlS because I had to work 01
26
because I could not afford to get her to them es muny of them are for away. Andy has never offere
27
28
VERONICA l'REITAS
V. l'REITAS LAW, PLLC.
DECLARATION 210 Summit Avenue Eosl
Page 6of17 Seollle, Washington 98102
(206) 328-7362
v@vfrcllnslaw.com
to pay for the gas to drive to these events.
2
I have never tlu·eatened to "back olT Lauren's soccer" because Andy threatened to modi
3
our parenting plan. We had never discussed it. My husband, Soufyane, and I had a non violen
s argument that caused me to have a post Iraumatic stress reaction and I called 911. The police cam
6 and left. No one was nn·estcd. I told Andy about this at the time so that he would know what wa
7 going on encl I had him keep Lauren so Soufyanc and I could resolve our dispute. No one was i
8
any clnnger at any time. Once again, l should have not trnsted Andy. I was shocked when Andy file
9
the petition to modify our parenting plan. The first I had heard of it was when I was seived.
IO
II
Just yesterday, I learned that Andy has been taking Lauren to soccer practice on Thursdn
12 and that she is now registered with another team, but Ihrough Rush Soccer. I am including th
13 emails between myself and Niki Allan, whom l believe is the team parent responsible fo1
14
coordinaiing parent communication as Exhibit F. I was shocked again when I learned that Lauren i
IS
now playing on a completely different team. This crumot be considered the same season if she isn'
16
17 even playing on the same team anymore. I nm sm1>rised that Andy isn't trying to have me found ii
18 contempt for not tnl<lng her to the practices for the team I didn't even know she was on. Niki'
19
email from yesterday states that she was just informed by Andy to include me on the team emails
20
This is ridiculous. I believe that Andy didn't want me to know about this until after my contemp
21
response was filed 1111d/or afler the contempt heaiing ilself.
22
23 Mediation·
24 I informed Andy months ago, when it appeared that the season was ending, that I did no
2S
agree that Lauren should continue playing select soccer and that I wanted her to take a break. Eacl
26
time I mentioned this he would become exlremely agitated and aggressive. I nm the one wh
27
28
VERONICA FR~:ITAS
DECLARATION 210 Summll Avenue Easl
Pogo 7of17 Sentlle, Woshlnglon 98102
(206) 328-7362
v@vrrellnslnw.com
repeatedly brought 11p mediating the soccer iss11e. I am the one who contacted Volunteers o
2
America to begin the mediation process. This is why they sent the information to Andy to fill 0111
3
Andy dragged his feet and waited until the last minute to complete his paperwork and send it in.
4
s Andy is not being truthful when he states tlmt I was not willing to mediate. I went to th
6 mediation prepared with ru1icles about children and spmts specialization (Attached as Exhibit G
7 and infommtion about other, less intense recreational soccer teams. I was hopeful that Andy wo11I
8
see that it isn't that I don't want Lauren ever piny soccer again, I mnjust concerned about her healtl
9
and want to scale it back a bit. I was hopeful that with the help of the mediators that we woul
10
II
actually be able Io reach ru1 agreement.
12 When our mediation began, it was Andy, myself, two mediators and two mediators i
13
tmining in our room. Andy refused to speak directly to me and instead kept making sideway
14
coll1Jllents to the mediators. He told them that I just didn't want La11ren to do soccer because I wa
IS
lazy and that if it wasn't for him she would just be sitting m'Otmd inside every day. ll1e mediator
16
17 asked me if I felt comfortable conummicating with him and I said that I did not. He the1
18 corrunented to them that I have comm11nication problems with everyone. Encl! time I tried to sa)
19
anything, he would inte1rupt me and talk over me to the mediators. His altitude and demeanor w
20
upsetting to me and I asked if I co11ld step outside for a moment. ll1ey said that I could but tho
21
Andy would need to leave the room us well in order to prevent ex partc communication wid1 them.
22
23 I left the room and went into the lobby so that r could call my attorney's office. r was ver
24 upset mid was in tears. I was trying to have a private conversation and Andy kept pacing back an
2S
forth across the room from me. While he wns pacing he was talking to himself, but was sayin
26
certain things very loudly. He was clenching ond unclenching his fists as he was pacing. At on
27
28
VERONICA FREITAS
DECLARATION 210 Summll Avenue En&I
Pogc8or11 Sonlllc, Wnshlnglon 98102
(206)328-7362
v@vrrclloslaw.com
point he said that I had borderline personality disorder n few minutes later he said that I f"'•••kin
2
disgusted him. Mis conunents were so loud that my attorney's paralegal, Amy Pasco, whom I wa
3
speaking with on the phone heard him talking and asked me what was going on in the background
4
s Ms. Freitas' office told me that I did not need to stay at the mediation ifit was that upsetting. It wa
6 my understanding that mediation was going to be much more civil and respectful than that.
7 After I ended the call, 1 visited the restroom and tried to collect myself. I did end up goin
8
back in to the mediation to try one more time to reach an agreement with Andy. Andy's onl
9
proposed solution was for me to let him drive her to all of her practices and games. That is not
10
11 acceptable solution by any means as almost all of her practices fell on my residential days. Ifl wer
12 to agree to that then I would hardly sec her at nil. His only solution was for me to lose my time wit
13
her so he could take her to soccer. That is not in Lauren's best interests.
14
One of the many reasons that Andy cites es his reason for wanting to modify our parentin
IS
plan, which we are in the midst of doing right now, is that he says that I do not care about Ln11re1
16
17 and do not support Lauren and that Lauren is wilh him more of the time because in the past I hnv
18 allowed him to trnnsport her to soccer and to tournaments that I could not afford to get her to. Hi
19
offer to provide transportation is just something that he will hy to use against me later.
20
I never agreed lhat Lauren could play select forever. I agreed thnt she could hy selec
21
22
soccer. I have tried lo figure out when the season is over and hove not been given a clear answer.
23 the absence of any clear infonnation, I assumed lhat the season ended when they hod the "end o
24 season paity" and "Inst game of the season". After that I stopped taking her to practices, because_
2S
again, I could not get an answer to the questions "what w-e they practicing for?", "what are th
26
trying out fo1·?" etc. I should not be found in contempt for this.
27
28
VERONICA FREITAS
DECLARATION 210 Summit Avenue Enst
Pnse9of 17 Seattle, Wnshlugton 98102
(206) 328-7362
v@vfrellnslow.com
Andy told me in a text message that he had signed her up for next season. I tried to get th
2
regis1mtion information from him and he would 1101 respond. I tried to get the registmtio
]
infonnation from Wushington Rush and was repeatedly denied because he would not aeknowledg
to them that I am Lauren's mother. I asked Andy again to provide me with the registratim
5
6 infonnation and he then tells me that he hasn't done it yet. That email is attached os Exhibit H
7 Then I learned yesterday that he must have signed her up ru1d that she is now playing on ouothe1
8
team that stm1ed practicing o couple of weeks ago. This is ridiculous and unacceptable.
9
Our parenting plan does not state that extracurricular activities need to decided jointly. I an
10
II
Lauren's prima1y parent and r believe that this means the decisions on this issue fall to me only.
12 have tried and tried to reach agreements on this issue with Andy, even though I don't believe I nee
11 to, and he is not willing to budge even a little bit. I am the one who started the mediation process.
14
came to mediation prep11red, ready and hopeful that we would be able to compromise, but r shoul
have known better. Our mediation was just another opportunity for Andy to be harass and intimidat
16
17 me.
18 Rlgbt ofFit·st Refusal-

19
I have not intentionally violated any pa11 of this provision intentionally. Neither one of u
20
followed this provision for years. There were nmny, mru1y times when Andy or I would be at wor
21
and Lauren would be with my 1110111 or his mo111. We never disc1L'ISed it or brought it up. We just di
22
23 whatever was best for Lauren or was most convenient. Andy acknowledges this in an email that h
24 sent to me on April 16, 2014 (Exhibit I). In this email he writes ''. .. Neither you nor I ever had t
talk about the right of first refi1sal because neither you nor I cvc1· thought of it in those tenns." H
26
goes on to say "I did not think about part VI of our parenting plru1, and neither did you." It wasn'
27
28
VERONICA FREITAS
DECLARJ\TION 210 Summit Avenue Eost
Pogo 10of17 Seatlle, Washlnglon 98102
(206)328-7362
v@vfreltaslnw.eom
•
until Andy filed the petition to modify that he began trying to take Lauren when he thought I woul
2
be unavailable for four hours. It has now gotten lo the point that I feel like he is stalking me. Heh
3
subpoenaed all of my employment records so he could pour over them and find out when I migb
4
s have violated this provision. Since he has received the documents he has continued to harass Ill)
6 place of employment and ask them for my clock in and clock out times each week, because of th
7 subpoena, they have to comply with these demands.
8
Andy's request to the court to order me to provide him of all days and hours Umt I a
9
scheduled to work, including any changes in work schedule and nll days and times I am working ·
10
ti
excess of my ordinary schedule. This is a continuation of the control and abuse that I experience
t2 during our mnnfoge. This should not be ordered.

13 I did not let Andy spend November 11 lh with Lauren when she was sick. This was short!
14
after our temporary orders hearing and I did not realize that th.is ridiculous provision still applied.
IS
U1ought that it went away at our temporary orders hearing. I did work that day and Lauren was wit!
16
17 my mom. I argued with Andy about the right of first refusal because I did not think that it applied
18 My attomey's office later explained to me tlmt the right of first refusal docs still apply. I did no
19
intentionally violate this provision of our pnrcnting plan and have complied witl1 it since that day.
20
The email from me that Andy included in which I acknowledge the four hour rule still applies \
21
sent on November 261h, weeks after day of this incident.
22
23 J do not understand Andy's issue with December JOlh. Lauren was in school that day.
24 including her attendance records from school as Exhibit J. She did not miss any school that week a
all although she did have a cold end didn't feel good. My mom picked her up at school and brough
26
her to me at work at Swedish. Lauren was seen by Dr. Furhmw1, whom I worked for, w1d I clocke
27
28
VERONICA FREITAS
DECLARATION 210 Su mm II Avenue Ensl
Pngc 11 orl7 Sonllle, Washington 98102
(206) 328-7362
v@vfrcltaslew.com
out ot 5:23pm and then Lnuren and I went home together.
2
There was period of time, before Ms. Buie's report was released, that Andy hod backed o
3
of this four hour mle. Everyone but Andy could see that it was bad for Lauren as she hates bein
4
5
shuffled around. I believe that Ms. Buie spoke to Andy or his attomey and requested that he sto
6 enforcing this rule, because he suddenly stopped. At the time, I thought that he had just gone bac
7 to the wny it had been for the post few years and was no longer concemed with it so February 19
8
Andy didn't tnke Lauren. He knew my work schedule and knew that Lauren didn't have school an
9
that I wns working. He is very forceful and demanding when he wants something, but he neve1
10
II
asked about this day. After Ms. Buie's report was released und he saw what she had written abou
12 him and what she had recommended, he began abusively (to Lauren) demanding shict complianc
13
with the right of first refusal again. I should not be held in contempt when it is unclear when And
14
is going to want to follow one port of the order and when he is not going to want to.
15
I work until 7:00pm on Wednesdays nnd I have a one hour lunch break. Wednesday is als
16
17 my dny with Lauren. Lauren loves spending time with me at work. I do not understand why And
18 thinks that Wednesday, April 9th Lnuren would have been scheduled to be with him as I hav
19
Lauren every Wednesday. Nevertheless, my mom was going to pick up Lauren at school w1d brin
20
her to my work so we could nil have dinner together. I was available and Lauren was with m
21
during dinner. There was no four hour period tlrnt I was not with Lauren on this day or on Apri
22
23 16'2'. 111ese were my residential days with Lnuren and I was available to have dim1er with her. Sh
24 was not nway from mc for four hours on either of these days. I should be able to enjoy dim1er wiU
2S
my daughter on my day without having to have a tug of war ove1· her 01· having to worry abou
26
being served with a contempt motion.
27
28
VERONICA FREITAS
DECLARATION 2IO Summit Avenue Ensl
Pase 12ofl7 Sea Ille, Washlnglon 98102
(206) 328-7362
v@vrreiloslnw.com
Since April 16°1, Andy hos gotten more and more aggressive aboul the Wednesdays. Ea
2
week my mom has arrived at school to pick up Lnlll'en nnd Andy has been there. Ench week
3
fight aboul it thl'Ough emails or texting. I hy to hold my ground, but I nm nfraid of how far he wil
s tnke it. Each week my mom has been al lhe school to pick up Lnuren so we can have dim1er togethe1
6 and ench week she leaves without Lauren in order to spare her fl'Om any conflict at school. This i
7 very sad and unncccssmy.
8
It is not only confusing and upsetting to me. Ms. Buie sent an email about his very subjec
9
(Exhibit K). In her email she asks for someone to point out why it is an issue for my mom to brin
ID
II
Lauren to have lunch with me nt work. Andy never responded to her email. There is no real reaso
12 except thnl he wanls lo keep Lauren from spending time wilh me and my family. Wednesday ism
13 day with Lauren. I should be able to enjoy dilmer with her on my dinne1· break. This should not
14
such a big issue and I should not be held in contempt for ii. This issue is also discussed in Ms
IS
Buie's supplemeulal report that wns issued yesterday.
16
17 Nonemergency medical decisions-
18 Lauren needs to be seeing n counsellor. I have tried to get Andy to agree to get Lnuren int
19
counselling for n long time but ii never happens. Andy always says that she doesn't need it or ovoid
20
the subject allogether. I am including and email form (Exhibit L) me to Andy on April 22•d. 111
21
Jasl line of this emnil from me snys "Also, I will be talking with my attomey soon regarding Laure
22
23 seeing n private counsellor on her own". This came on the heels of me once again trying to ge
Lauren in to counselling.
2S
Ms. Buie reconunended lhal Lauren slm-t seeing a counsello1· and asked us to get somethin
26
set up 11s quickly as possible. I emailed Andy again (Exhibit M) on May 8°1• He responded said lhn
27
28
VERONICA FREITAS
V. FREITAS LAW, l'LLC.
DECLARATION 210 Sum mil Avenue Easl
Page 13of17 Senllle, Washington 98102
(206) 328-7J62
v@vfrellnslnw.com
he agreed with coimselling and that he would fonvard me some names. He never proposed an}
2
names to me. An appointment was mode for Lauren with Ms. Paik at the Everett Clinic. After doin
3
more research, I realized that Ms. Paik docs not specialize in any one areu. l would really prefer
4
Lauren to sec someone who specializes in working with children and divorced families. I continue
5
6 doing resenrch. l mode countless phone cnlls and did much research online.
7 Someone told me about Kerry Kirsch and said the! she is great with kids. She specializes i
8
children and families of divorce and also does co parent counselling. I made en appointment an
9
emailed Andy and Ms, Buie on Moy 15th. I am nttnching that email es Exhibit N. At the end of th
10
II
email, I say that l run going lo move forward with this plan unless l hear otherwise from Andy.
12 never heard back from Andy about Kerry Kirsch so I had no way of knowing that he objected
13
should not be found in contempt because Andy refused to respond to my very clear email.
14
Recent Events-
u
Andy's behovio1· is getting scru'ier and scarier. He continues to engage in hostile an
16
17 menacing behaviour towards me. I am terrified to be alone with him. Our daughter is a nervou
18 wreck. She hns so much anxiety lately and is terrified that someone is going to steal her dog ru1d !ha
19
her pe! bird is going to fly away and will never be found. She is very, very clingy to me and neve1
20
wants me to leave her. She knows what is going on here. She has been wettii1g the bed almost eve
21
night al my house and she tells me that this happens ul Andy's house as well, but he denies it
22
23 Lauren confinned with Ms. Buie that she wets !he bed nt both homes.
24 In addition to his behaviour ot mcdialion, he has also been harassing my husband Soufyan
25
and I each time we nre alone with him. Andy earns significantly more money tlmn J do. This ·
26
another reason !hat he cites, in his previous declomlions, for trying to take Lauren away from me.
27
28
VERONICA l'REITAS
Pngc 14of17 Scottie, Wnshlnglon 98102
(206)328-7362
''@vrrclloslow.com
A few weeks ago, Lauren had a doctor's appointment Andy and I met at the Everett Clini
2
for this appointment. I usually try to have someone with me to prevent Andy from being hostil
3
towards me, but I had to go to this appointment alone. When we were in the lobby, Lauren went t
s the restroom and the second she was out of sight, he began yelling at me for not being fmanciall
6 responsible because a bill collector called his home. He yelled at me in front of the reception sta
7 and other patients waiting to be seen. At one point, he yelled "Gel your shit together") lltls wa
8
very embmTnssing and demeaning. It is not Andy's job to publicly shame and chastise me.
9
Last week, Lauren hnd another appointment at the Everett Clinic. Andy brought Lauren an
10
II
Soufyane and I met them there. Soufyane waited in the lobby during her appointment. After th
12 appointment Lauren, Andy and I retumed to the lobby, where Soufynne was waiting. Andy looke
13 at Soufynne and said loudly "Hi Soufyane, you look tired". Soufyane told him that he had bee
14
working n lot lately and hadn't had a chance to shave. Then Andy said even louder, as h
IS
approached the exit door with Lauren "Well I have a razor in my tmck if you can't afford one"
16
17 Then he left with Lauren. I can only imagine the things he continued saying to Lauren after the
18 left the clinic.

19
lltls past Thul'Sday, someone knocked on my door. I answered the door and was served will
20
the second contempt motion. I accepted the papers without incident. A couple of hours later, I wa
21
at my mother's home scruuting the documents lo my allomey's office when someone starte
22
23 pounding on the door and hollering tluough the stonn door for me. My dad asked ltlm who he
24 and he just kept saying that he was a friend of a friend. My mom had to leave for an nppointmen
2S
and when she tried to leave the garage, this person sta11ed banging on the car, pulling on th
26
windshield wipers and trying to open her car door. My dad called the police. They detained the ma
27
VERONICA FREITAS
Ot::CLARATION 210 Sun1mll Avenue Easl
Page IS of 17 Scntlle, Washlnglon 98102
(206) 328-7362
v@vfreltnslnw.com
who told them that he was trying to serve me with documents that I had already been served with.
2
am including a picture of the man with the police as Exhibit 0. This incident was very scary for al
3
of us. I was scared to go home that night. He left foce prints on my parents' storm door and chase
4
and assaulted my mother's cnr. He was very aggressive and agitated and it was all complete!
s
6 unnecessary.
7 The assault at my mother's home was not only unnecessary because I had already beer
8
served, but because my attorney, Ms. Freitas, emailed Mr. Gaul and Ms. Buie weeks before an
9
informed them she would have gladly accepted service on my behalf. Granted Ms. Freitas' emai
10
II
(Exlribit P) is in regards to the first contempt motion, but per that email, Mr. Gaul should hav
12 contact Ms. Freitas' office regarding accepting se1vice. I do not have a histo1y of avoiding servic
t3 and there is no reason that any of this had to happen. This was just one more chance for Andy t
14
harass and intimidate me and my family.
Conclusion-
t6
17 I am not in contempt. I have not intentionally violated any court order. I have tried m
18 hardest to figure out what is happening with soccer and huve never been able to get any clea
19
infonnation. I do not agree that Louren should continue to play select soccer and so after the "e.n
20
of season party" and "last game of the season" I began trying to reach an agreement with Andy
21
When it became clear that we would not be able to reach an agreement I contacted Volunteers o
22
23 America to request mediation. I went to mediation prepared lo mediate and was hopeful that w
24 would be able to compromise.

2S
Andy and I did not follow the right of fu·st refttsal provision of our parenting plan for years
26
Then suddenly and for a short period of time, he wanted to follow it. ·111en, per Ms. Buie'
27
28
VERONICA FREITAS
DECLARATION 210 Summll Avenue Ensl
Pogc 16ofl7 Senlll•, Wnshl11g1011 98102
(206) 328· 7362
\'@vfrellnslaw.com
suggestion (I believe), he stopped. After her rep01t crune out he wanted to follow this provisio
2
again. I did make one mistake on November 11, because I misunderstood the orders after ou
3
hearing, but I believe that I have not violated the right of first refusal since. I am available to bav
4
dinner with Lauren on my Wednesdays. There is no four hoUI' period that I am unavailable on th
6 Wednesdays thnt Lauren comes to hnve dit111e1· with me at work and I should not be found ·
7 contempt fo1· trying to hnvc dinner with my daughter on my residential day.
8
Tmade an appointment with a counsellor 111 the Everett Clinic for Lauren. I later, after muc
9
research, found someone who is much more qualified and experienced to meet Law·en's needs.
10
II
emailed Andy and told him this. I also told him that I would move f01wnrd with this person unless
t2 heard back from him. l never heard back from him and he instead of responding, filed thi
tJ contempt motion. I should not be found in contempt fo1· this either.
14
These motions should be dismissed. l nm not in contempt. If the court finds me in contemp
IS
it will embolden Andy to continue with and increase his antagonistic, harassing and menncin
t6
17 behavior. n1ese motions arc abusive at best. Andy makes more than three times I do. I should no
18 be ordered to pay his attomey fees for these frivolous and costly motions. We hnve trial coming u
19
in eight weeks. These issues could have been addressed at trial. Both of these motions should b
20
denied.
21
I declare under penalty of pe1jury pursuant to the laws of the State of Washington that U1
22
23 foregoing is tme and correct to the best of my knowledge.
DATED this '7.J-\.nay of ~'--'-"'"'>'t--='

2S r
26
27
28
VERONICA FREITAS
Page 17 ofl7 Seatlle, Wnsl1inglon 98102
(206)328-7362
v@vfrcilnslaw.com
•
EXHIBIT A

I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 Ifax• (206)323·0404
.................. ~~~ JEH•UFER RIFE PAGE 81/07
·:-/ ·.· ..
'1
: 1 '.j ·.
: II
'i
4 Superior. Court of W.ashington
s County of Snohomish ·
s. hue .the M.niage ·of: ..
. .
7.
ANDREW~-. Rll'E;· No. ·os-3-02?55-I
8 t Peiitiouer,
9 f and
Psrenting Plan.
.
Final Order (PP):·. ..
10 .
1
·I JBNNIFJ"! ,. R:FE,
..
.·
:•·
•1 I·; ncllmi: ·
·-~----==='--...__-'-----~~----
R
• I - : . . . .. .· .
12 t ~his paf<01t!ng;: '<· · is :he fu'lal parenting plan, r~ed by ~ent~tw~ tho pllrdes, Sl!IJlod by the
13 I tourt puiBunlll r. · nleeree of dissolution. · . .'
.•.
1'1 · 1 Is it' Order~d, Adjudged. .and Decreed:. ' . .
15
.j,. I. "General Information
16
'
This parecllng
. childi'en:
i':' , sp;ilics to tlic following
·17
'
18
,·
~9. ,. ! ;_,.,,,~n·Binily Rife. 2
20 .•
II.· Basis for Restrictions·
.... 21. I ·lI
2~. · 1211 ·Parenta'. Coi1duct (RCW 26.09.19.1 (1 ), "{2))
.. 23_, -:.:-~. TAfl!e.r;s ~esidenf.ia1 ti1ne with the chiid ahe.11 b~_ JhUi~d·Or .rostrainod oompJetelyJ and
I .,,;·.:.:aJ.dee.isiot-mRking nnd'd.Signntio~ ofa ditpu~ ~esolutlon process olhflt tl!an eourt ·
. :24
a:.:hri shall.not be required, beeauso this parent hall engaged In the conduot which '
. 25 rb.~: r;,ws: ·· · /. ·
. - 26 0
l. :· .'· ·xy of aofs o.f domostio vi ole11co as Oefued In RCW 26.SO.OJ 0(1) or an assault
. 27 ::: ..~:1 t".tu1seS·gdevo1Js bodiJyharm Or tl~e fear of such harm . . ·.. . ' :·
28 'j 2.t··:I .. Other F,;,::tm-s (RCW 26.09.191(3))
.
··29
3C
II ·
I
Does n~r. a;.p:y.
..
·
P~;ent1no Plan (!"Pr'. •-PT. PP) - Page 1
I w1c DR OUT40C '~-?o.;s). - RC.W 26.09.181; .187;. 194 Dyer & l'rfina11·
~ l'l;o!ltA Av• l
I I
Sclrfti.,,.WA JIJO!
l . rnJ5)lfS-JS21
I·
JENlilFER RlFE PAGE 02/07
f
Ill. Residential Schedu.le
2
3 3.1 Schedule .for Children Under Sch.ool Age
4 Prior 1<> -::u..-,IJment in scbool,the child shall re~lda witli the mother, exe<>pt f.or the following
5 cays i11:d ·::ncs when tl1e child will
reside with or b_e with tho otlicr pafe!!I:
6 On Tuesday ond Thursdays for thre~ (3) hours and on Saturdays for olght (8) hours each woe!<.
AII vi•:t:- •o ho supervised by_Oo;i Layton or a person designtited by Mr, Layton and'oihOJW~I>
7 ngr""~ :c• i'Y the Caso Maoagor. All visitntlona aro subject to sectlpn 3,10 below.
8
3.2 Schoo! Schedule
9
Resc.f\·oc ;icnding Case l\ljanagor R0C9mm.cndation.
1.0
f1 3.3 Schedule for Wintor Vacation .
12 Reserv(:{l i~r?.nding Case Manager Re.commendation . .
. i3
3.4 SchadoJ!<> for Other Sctiool Braaks
14
. 15
16 3.5 Summr:r Schedule"
1.7 Reserved pending 17.se Manaaer Rceommendaiion
'18
3.6 Vacatio=·· With Parents
20 Reserv.•rl ponding Case Manager Roview.
21 . 3.7. Schedl:!e for Holidays

22 Prior I~ sd1ool, th: residential schedule for the child for the holidays listed below is as follows:
23
Wjth Motj1cr With Father
..
24 Chrisf!Ufl-':: :~vc Every
25
26
27
28
Cl1rjs:1r:-'s J''i?.J•
Memciri::l Jizy
J1~y 4''
.Labo' D•:··
Thant:Sgi-.::n:; Day
Every
~-
Evon
"91& ...i>'
Evon
. '
·'
..
Ever"'
c:idd ..
Odd .
Por pu:po>r-4 oftl1is pareittlng plan; a·J101iday shall begin et\ 1:00 a:m. and.end at 7:00 p.m·. All·
29 holiday Ii;?,· iR subjocl to scc.tion 3. l 0. If !·laliday time' ii mi."lsed du" to the visitation
superv:sN ·, sd1edule • m&K_e up visit may_be anangod. · . ·
30
.,Poi"cnl/flg Pion (F"'-- : ."f'T, PP).- Pai;o.2 .
WPF DR 01.0~.oo :r.-;f)06) -RCW 26.09;18!; .1~7; .194 Dy4r & !'rimont
~OJ 'l'l..ifth Aw. ~
S••HI<. WA Dm02
.I !
" OOS1BIM52B
--....... j""""' JENNIFER RIFE PAGE 03/07
;l
.1
I
1 I " .
3.8 Schedule for SpeC!af Occ11slo11s.
2
3 · Tho r1>S;le1~.Jni schedui: for the er.lid for the followingspeeial occasfons.(fore~ple, birthdays)
a.,
i.9" fol!ov1.:;: -
4 Witb Mo~-------'W!l'..illtuh""P..,at,.h,..or·
:.· ·5 •. Mot.her'• Dn; . Bvory
I Fatbl!lr s j~::iy Eveiy

1
6 Mother·~ Bir:'hdn.y
Pethe:- 1 f: C!h-s:hday :
.7
8· J1or p1trpc-~e1t nf'tJiis pauntlng plnn, r. speeial occa"slon sh.all bbgfn 8.t 1.1 ;60 a.m. and.end ·at 7:00 .f'\.
p.m. Ail •r•cir.I occasion time is subject to seotion 3.10. I(Spcoial Oeaosion time is m!••ad duo ~'\£...
9 to the vis!:acifln supe:vis<>r's schedules m!'kc up visit may be r.rranged · :. . -'·- ~
~~' !-'....,...l.\ ~ ........ ._.~1..""'"~l) ~~ -~~'"-". ~- \.....t.,:.. ... r:.....!..> '.Q. ..... ~,J.~.~ ~
10 3;9 · Prforlti'>" Under the Residentllll Schedule. I>· ...,,._..._,...""'""-'"' ~<> '-1.'-":>I . sJ
11 (.\o..'i'•'\- ~r ...~.0 &. i,......,. ..;.,~s'o· 6
Does nc!. :rnpl y.
1-2
13°13.10
1..: Tbe fat~er's residential tim~ with the ohild shall. be lintltcd ~use tJ1ere are limiting' fac!oill in
par11.3raphs 2. J a.,d 2.2. The following restrictions shall apply when the chll~n spend tirno with
15 thi~ pr.rr.n1.·
16
I. Patl;e.:· :,l\af I enroll in and suocessrully complete a. state eortlfied domestic violence
17 pcrp<~: ..:ors treatment program. Ho is currently eniollod at Catholic ComniunltY Sorvi.oes,
(CCS). Tho father shall sign approprl•te l'Ofeesos so that tho treattuent prpgram can.
16. com:n:micote with tho mother and provide monthly piogress repol'U to .the Case Manager,
19 counsei for mother and counsel for faU1er. · ·
2. . Tu~ futl:c; s!lall enroll in and suceessfutly complot<> the DV Diids program and.ti"'
20 RospectfJI Pru·enting program at Family Se1vice.s in Seattle. •
0
·
21. 3. Visi'"''""" will bo supervis ed by Don Layton or his desigDee. Pon Layton is appolnt.ed as. a
TI1err-1>~u1ic Visitation Supervisor to work direil"Jy with the father. 1',U., La.Yton may expand
. 22 or co11;:;·8"t Uio visit ti.mes or durations, however, there shall be no expansion oftin!e until tlie
father hes successfully completed l'haso·r of bis treatment p~ogran1. · · .
ia 4 .. 13,;.;ge:: Llewelle~·f~ .appointed as Caso Manager\sbo Jias.beon .the appointed GAL durlng ·
:24 the ca••). She .•hall communlcnto witl1 all.parties and professionals woddng with the father
end m;.!m written recormriendatious on future expanded O:ccess for the fath'!J'. ·
26 S. At •u< ii time as the Case Manager date:mines that the father has progressClf lil)d visitation
~hol!l~ he expanded, she will write a report and ma1co rccoitunendations. 'Tiie-parties may.
26 ngru ~' t.hoso recommendations or modify those recommlllidations by their agreement.
27. A!>se;·.' <Yrittcn ogrccinen: the:o shAll be no <lhange expeet by court order. The Case f14aliager'.
shall 1cr.1~in· nppllinted until suoh time a• all oftho fethor~s requirornen~ lUlder this ~ion
'28 "'" o<:"1p!etod. She may, ftmn thn• to tlm~, write. interim report~ and roc:Onuncndatlons. She ~~
29 •hall \\ ro!h .. final repmt witb rCC<lmniendatinns at suoli time .. the father hos completed all rr
of :;,e :•9,irem•.nts set Ol;f above. I.~ ~ .. ~J.. ,. .... ~· r'<' ..., ""-1\ ,;..~\" ..J..4i ..:. ~
30
. . ··
......
<--~ of .,._,;>:, c\...-!f-> ~ -
ParanflngP/sn(PF.~.PPT. PP)--Pflga3, ..,~
6, \.•
,......~\r.. ~ ... D
c..r.Jl .·. . .
- ~-c.t...i,....._ ...-JJ,""~ "'
WFF DR 01.0400 (!i/2006) - FiCW 26.09.181; .187; .~ . <.. . D!µr& Pitnum
. 603. ~lft!o Ao• ;
S111~-., WA. 98!0:
1106/ 84Mli7i
•
... ........ ., ... ~.:1.:J
1
3.11 Transpc;·:c;tlori Arran$e1ne1\ts
2.
3' Transpnrl:ilion COS"..S ar~ :r.cluded fn tho Child s~pport Worksheets and/or tl\o Order of Child
Support tll~ 6houid not.be inclnded here.
.
1·
4 .
Transponntjou arrangements for the child, botv(oon parents shall boas followil: l!x:chonge! shall
:s !> ;....,g;<411D¥1._.e ·e• lSM f&!ci II :a 44 ,, J b so Icing as. !hay are .
suporvi<c.:i. The Catie Mane.ger sh•il make reconun~1datioii.s fo~ 'transportation arrange;noi1ts at. r '
.6 .1 such tim<- •• visitatiQD is no longer·suporvisod. - . · . .
'Pb,~ t-<...a,....-•,;.J...c.Jrr\h.,:. .• C' (~ ~~ ..... (.\...... "-.} c.-.~ ....~ ~ .. .
7 DesignRtion of Custodian 1-~'I>........,. ""'"'"' .... ~ I'""' ct......... · .
3.12 ..,.
8
'9 . 111e cJ;i!d·,on na~cd thi~ p•~•~!ing'plan ar~·soJ1odulcd
in to resi.do tho majori~
.oilh<; time with .' S
the 'l11otl>0r This p•ront is dMignated ,t11e.custodian of the child solely for purposes of all'other
10 state and :'~deral s-.a:utes whicli requi'e a d~ignaJion or dctonnluation o( custody. 'This .
des~atioin shall not &!Teet ".ithor.p11rcnt's rishts and responsibi:i!leti under this parentipg plan.
11.
12 3.13 Other: N/A
·.13 3.14 Sumr'narf of RCW 26.09.430 • .480, Regarding Re1ocatlori of a Chll~

14
This js a •o:i:miary only. Par the full text,'p.loaso see' RCW 26.09.430 throu!ih 26.09.480.
15
If tho prJ"" ·n with whom the r.Jiild resiries a majoricy of the time plans to move, that person shall
16 give notiC<'. tc• evory person entitled to court.onlored time with the child.
17 lf lhe move i~ outside tho cilild's school di•lric~ tbo relocating person milst give notico by
.perso112l .<ervice or by mail l'equb'ing a relllrll rbeeipt. TJils notloo·must be at loast 60 de.ya before
16· t!i•. intended move. lf t~o relocsting perAon could not -have known abo'!! tho move In ti mo to give
60 days• l>oticc, tbat poraon must give notice \jllthin 5 days af\or learnin_g of the move. The .
19.
notice m11'!1 c.outniu tho informn:ion required in RCW 26.09.440. See Riso form DR.PSCU
20 07.0500, ()!o:.ice oflntended Relocation-of A Child). ·
21 Jfthe '"°'·~ is wltl1in the same schocl district; the relocating j>orson mU:.t provide aotuai notice by
• any rca,$0:'-'lbio moans. A por~ou ontitled to tbne with'the child niaynot object to tho move·l!uf
22 mo.y ask for modification wi~or RCW 26:09.260. · ·
23 Notice mo.v be delayed for 21 days if the relocatiugper$0R ls onteri11g "domootio._vlolenoo slieltm"
o~Js moving ~:a avoid. o. cle_ar, ilrin1ec:lia.te a.nd'unrcasonnble 1isk to l~e.alth arid· safety.·
24
lf inforn:u=hn is pro:~oted under~ court·order 01: the address confidentiality program, it may be
~5 withhold ::;.":·.·1:i1 :he notice. .
26 A 'olocatir.,1 person· niay· ask the.eou1fto waive any riotJco reqtfu'<>meuto that m·ay put the health
27' and safe')' of a p•rson or a child at :'isk. · ·
28 Failure lo .i;ive the 1·equir'cd notir~ may be grounds. for oai.1ctions,,inol11di.ng cont~pt, ·
29 Ir no objoction ls flied witMn 30 days iifto~·scrvicd of tho notic.e oflntondod relocation, the
reJocntion wfli be permitted and the proposed revised re;lden!lal acbedule may be
30 confirn1c<l. · ·
IPerenting Plttn (Pr· ·c. PPT. f'P). Pilg• 4 .
j WPF DR.01.04-0G (•V2005) • RCW26.0S.18.1;, 187; .194. Dyar.& Primo11
:i · . 603 't:<wrJIA.M•.;
&11.:tcfo., WA SSIO.
CI06)Sf8·m•
. .•r
•
..
I JENNIFER RIFE PAGE 05/07
1··
1
1 A person •ntiHecl to lime with ocl;ild ";1der a corut order ca.n file e.n objection to the child's
feloC'.a:j~~· '"h!.tl1er or not ba or ~he l'eccived p1·oper noti~. . · · .
2
An o!*" ::(11\ :nny ba filed by using lhc mandttory pntt.ern fonn WP!' DRPSCU 07 .0700,"
3 {Objection ~' R.elocation/Petilion for Mod[fication of Custody Decree/l'arentingPla11/R.esidentiaJ
4 Sehedulcj. The objocticin inust be se1ved o~ all persons entitle<\ to timo with ll1e child. ·
T!ie reioco~ir.£! person Shall !!Of move the child during the time for objeeti.on unless: (a) the
5
delayed Jl(•lic., proyisions ap1>ly; or (b) a court order allows tho move.
6 lfthe nlol~,;rir.g person schedules a hearing for a date within °15 days oftlmely.aervioe of th~
·7 objectio~. ;he relocallng person shat( not inovo tho chtld J:>eforo the hOa~ing wiles& there is a
• c1<;0:·, ;..,,,.~iiote.and unreason ab I& risk to tho health or safet)_' of a·person or a child .
.B
I
g IV. Decision Making
10 14.1 Oay~to-Day Decisions ·
. 11 .
· tlocli·i'nro:·,; .•ha!! mako decisions regarding the. day·to.:day. core and control ofeaeh child. wh!lo
12 the child i• r<.siding yntb that Jlllrc~t. Regardless of the ellocation of decision bieking fo this
·parenting pion, e!thcr parent may make omergcney declsiW.s affec\ing !be health or safety of the
13 cl1ildro11.
14
4.2 Major Decisions
. 15
Major de cir.inns regardi"g ·each chilri sball bomirdc as foll'?ws:
16
17 Educatiail rl.r~ision.s rooth11T•
Non-cmerg<.ncy health care mother
18 ReligioJ:s "!Jl:ringit:g . · . . mother
19·
•Tue i.sue .)(whether the child.win attend public or Catholic ·.;.i.~ois Sh.all be i·ovie~ by the
?o ' parent•"''"'' she reacllcs the.age offour years old; if~1cre is adisagreoinont; ' . .
21 4.3 Restrictions in Decision Making

22
Solo dccis:m1 :r.akb1g shall bo ordeiM to tho mothOJ" for thefol_l~wing ro~~ns:
23
24 A i :.. i'tn!ion· on th~ _other parent's decision Jl1Dkini authority !a }llandll!ed by RCW :
26.!'9.191 (Seeparagrapb2.I). ·· · ·
25
- V. Dlsp!Jte Rasolutlon·
26
.
.. .
27 Disputes betwun r.!1-. porlies, other. than child supp91t disputes, shRIJ bo submitt8<1 to die Volunteers of
IAmerica Dispute R< ,,,;ution Seivlc.• in Everet! W.ShingtOn. · · .·
28
The cost. r.f !hi< process shall be alloc•tell bo>.woen·th~,parties os follows bose"d on each party's.
pr9por!im:.<'. chaco of income from Hue 6 ofU1e child support worksheets o.i· as dotor.nined in"the
dispute res•'J.lutio:-i prOce..E!(. ·
Psnsnling Plan (PPP. PPT, PP) - Peg~ 6 .
WPF DR 01.0400 (o/2005)- RCW26.D9.181;.. 1B7; .194 .DJ#r & Pn'!ntlllt
A••·
.sl!J 1"'t!Jll• B
· Scttffh, WA ISJOJ
('J06J aiJ.uat
I
.i
.•
..
1
The di•e":e resolution process"'"" he cor.frr.enced by notifying the o1her party by written
2 rettue.;i:,
3
Jn the. rJ:~: ·J:-C reso!ution process:
4
(a) i'roforenc~ shall be given to carrying out !his Parenting Plan.
5
(h} 1.hless n11 eroerge,,cy exist•, the pa:·onts shill.use tho designated process to resolve
.s d!<pi:tes relating to implementation' of tho pjao, excopt thos-; re!atod to financial suei>cut. .
(c) A writteu record shall ba prep·ar'!'l ofBny ':8'"~ment reached In counseling or medlatlon
7 . •nd cf each •rhltration ·award and ·shall be provided to each party. . ·
·s.1 (d). If ir.e C()urt finds that a parent.has u•ed or fn:strate"d the diilpute resC>Jution process
without g6cd reason, tho. conrtshall award attorneys' foes And
. financial sanctions
. to· tho·
.
9
I (e)
0:~1e.r parent. . · ·
Thri piutios have .the right of review from the dispute resolution process to the snporlof
10
11 I VI. Other Provisions
12
There a;·e. 1:0 other provisions.
13
14 VII. Declaration for Proposed Parentln!J Pl~n
15 . Doesnot appiy.
16
. VIII.' Order.by the. Co~rt
17
. 16 It is ordered, atijudged and decr;,..d thotllio parenfuJg plan set fortb abovo ·is 9.d~pted and approved a~ an
order of.this court. ·
19
·20 WA:R."'IING: Vio'"tion of r..,ideutial provisions of this order. with actual ·knowledge of Its terms ls
of
. punishable by ccmempt court ai1d moy be a criminal offense.under RCW 9A:.40.060(2) or· .
21 9A.40.070(2). Vi<,!(l:ion of:his order may sllbjoct a.violato~ to iu:rest.
22 When mutuol deois""' making is designAtod but cannot be achieved, the parties sh8.JI m'ake a good fafth ·
23 eff01t to 1-esolv• 'h" issue through tho dispur~ resolution.process.. . · · ·
24 if a pll:ent fails to ·"'''nply with~ provision oftlils plan, the oth•.r pareni·~:obligations un&fr th.e plau ero
not affected; ·
25
26 .Da:e<i: ·7-1-k~~
27
28
29
30
Parenting Plen (PP.'"-. ."PT, PP} - PogB 6
WPF DR 01,0400 tf>·?.·.106)-RCW 26.09:181; .187; .1~1
.. \ . Dyer &.Primon;
S03 :ru.,lfth.11•&.~
S•attle, WA 9!2;(1;:
. (206) U3-l621
,_., .................. ... JENNIFER RIFE
. . PAGE 07/07
1
2
3 Presented l>y: Approved for entry:
•
EXHIBITB

I
210 Summit Avenue !last, Seattle, WA 98102 tel• (206)328-7362 I fux• (206)323-0404
Jennifer Mehaddi
On Mar 30, 2014, al 11 :07 AM, Joslen Gara Ide <joslengamlde@gmail.com>
wrote: · · -- ·- --·
Training
Monday· 3/31 ·5:30·7pm Kasch Park
Wednesday - 4/2 No Training but attend:

Boys Jackson High Varsity vs Lake Stevens 7:30·9pm
@ Everett Memorial $6.00 Adult Admission.
(We can sit with my GU14's group all together)
Spring Break Training Off· April 5th-20th
End of Vear Party

When: Saturday 4/19
Time: S:OOpm Indoor Pool & Food. 7:30pm Sounders game In
Theatre.
location: Avana Apartments Bothell, more Info to come I
Thanks for a great season Ill

c: 425-344-6290
www.washinglonrush.com
EXHIBIT C

I I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 fax• (206)323-0404
.-•
Amy Mlkulsl<y

Sent: Tuesday, April 22, 2014 11:18 PM
-.---To:· - Amy Mikulsky
Subject: Fwd: Spring Break
Josten Keoni Gnrolde

c: 425-344-6290
www.woshingtonrush.com
•••••••••• Forwarded message ••••·••·••

From: !cnnlfermehaddl@comcast.net <jennifem1ehaddi@comcast.net>
Date: Thu, Mar 27, 2014 at I0:55 AM
Subject: Re: Spring Break
To: Josten Garside <jostengaralde@gmnil.com>
Cc: "rich@washingtonrnsh.com" <rich@washingtonrush.com>
Hi Josten,
Could you email me or mail me a copy of the recent registration form Andrew Rife tilled out for Lauren for the
upcoming next soccer season. If you hnve to mail it, my address is 14200 69th Drive SE Unit A-5 Snohomish
98296. Email would be great though at jennifcnnehaddi@comcast.net
I'm sorry· I om only sending this to you as I do not know of onother person to send it to there to get this
information. However, it is very imp011ant and I will need this right owny. Thnnk you very much.
Jennifer Mehaddi
On Mar 23, 2014, nt 9: 14 PM, Josten Gnralde <jostengaralde@gmnil.com> wrote:
Hi Azul,
Con rat t the iris for ending the season and toumc with some reat wins!!! And big thanks
·~
to Coach Brittney for 1cu mg up t 1c team 111 ympial It's been awesome working with the girls
and seeing them improve each practice and competing in games. Win or loss, we all are learning
and growing together and that's most impo11ant.
We will be taking a break this April and regrouping ot the end of the montll in preparation for
May tryouts. Dates ofT arc April 5th-20th. It will be a good time to rest and recuperate.
..
ll1e end of the season party may now be on Sntyrday. At>ril 19th and we will confirm soon with
octails. Expect o 5pm start still with pizza and pool lime.
Also attached is a great documentary for the girls to watch to gain a different perspective of the
game played around the world. With !he World Cup coming up !his summer, it will be a fun
experience for everybody to leam about different cultures.
It's one my favorites as my wife and I have experienced n little bit of this in Germany, Uganda
and Mexico. Enjoyl
http://www.pelada-moyie.com/!railcrs/index.h!ml
Sec you all Wednesday at Kosch.

c: 425-344-6290
2
EXHIBITD

I I
210SummltAvcnuc !last, Seattle, WA 98102 tel• (206)328-7362 fax• (206)323-0404
Amy Mikulsl<y
---~----From:
Josten Garalde <joslcngaralde@gmall.com>
Sent: Tuesday, April 22, 2014 11 :22 PM
To: Amy Mlkulsky
Subject: Fwd: Lauren Rife

c: 425-344-6290
www.washinglonrush.com
•••••••••• Forwardcd messngc -·--------

From: Jennifer Mchaddi <Jennifcr.Mehaddi@polyclinic.com>
Dnte: Wed, Mar 12, 2014 at I :16 PM
Subject: Lauren Rife
To: "jostengnrolde@gmnil.com" <jostengarnldc@gmnil.com>
Hello Josten,
I really need clarification on the upcoming events.
It is my understanding that the regular winter season is done, except for this game in Snohomish on Saturday. Is
this correct?
The State Cup games are not pnrt of the regular winter season. Correct?
March and April practices arc practices for what season?
May try outs arc for the season that begins when?
Please Jet me know as soon as possible,
Thank you.
I
Amy Mikuls!iy
Sent: Tuesday, April 22, 2014 11:23 PM
--.--To: Amy Mikulsky
Subje,t: Fwd: Training/Game This Week

c: 425-344-6290
www.washingtonrusl1.com
------ Forwarded message --·--·--·

From: !e1111!fem1ehaddl@comcast.11el <jennifen11el1addi@comcnst.net>
Date: Sun, Mar9, 2014ot 8:44 PM
Subject: Re: Trnining/Game This Week
To: Josten Gnrnlde <jostengnrnlde@gmnil.com>
Hi Josten,
Just wondering if there is going to be nn email soon regarding practice days nnd what events are coming up. I
thought this past Saturday was the last game but Andy told me there was a Jamboree. So a little confused on
what the near future is. Please let me know, thank you.
Jennifer Melmddi (Lauren's 1110111)
On Mar 7, 2014, at 11 :05 AM, Josten Garaldc <jostengaraldc@gmail.com> wrote:
Hi team, just a heads up on your commute for Satu1·day, the Sounders have their home opeuer at
I2pm so plan on troffic through Seattle on your way to om· game.
Go Rush and Sounders!
Sent from my iPhone
On Mar 3, 2014, at 8:42 AM, Josten Garnlde <jostengarnlde@gmail.com> wrote:
HI Rush,
Great battle last Saturday. The girls are Improving each week and coming
together as a team. We will focus on pressure and cover this week for defense
and recovery runs. Homework Is 200 juggles this week with bounces.
EXHIBITE

I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 Ifax• (206)323-0404
- AmY Mlkulsl<y
From: Jenn <jennilennehaddi@comcast.net>
Sent: Monday, March 31, 2014 1:47 PM
To: Amy Mikulsky; Amy Mikulsky
Subject: Re: Lauren Rile

Flag Status: Flagged
I'm scanning my drivers license and Lauren's birth certificate. Tim suggested If you will not accept this documents as
proof that I am her mother, that I come to you In person showing you this. You arc aware that I am her mother as well
as Rich and Josten do. I will be getting Lauren from practice tonight at 7pm. So Instead of flat out saying no and making
this difficult and adversarial I would like to find a solution and I just provided you with one. This Is absolutely horrible
and ridiculous.
Sent from my IPhone
> On Mar 31, 2014, at 1:40 PM, Amy Mlkulsky <rcl-am@msn.com> wrote:
>
>Thank you for getting those documents to me. As of right now, I don't
> have any proof that you are her mother and therefore you can
> understand why I can't give you any Information. I am happy to speak
>with Tim and/or your attorney. I assure you I am only trying to act
> In the best Interest of our player. We have many famllles that share
>custody of their players and set up separate accounts for both all the
>time. Once we establish you are her mother, we can get your own
>account set up with Lauren as well. ·Amy
>
> --Original Message--
> From: Jenn (mallto:jennlfermehaddl@comcast.net]
>Sent: Monday, March 31, 2014 1:31 PM
>To: Amy Mikulsky
>Subject: Re: Lauren Rife
>
>I'm going to contact nm right now then. I'm currently scanning legal
>documents to you right now that show I am her mother and primary
>parent. You are wrong and opening yourself to legal Issues by denying
>me my daughters records.
>
>Sent from my IPhone
>
»On Mar 31, 2014, at 1:27 PM, Amy Mlkulsky <rcl·am@msn.com> wrote:
»
»HI Jennifer -As a club, we make It our policy to protect our members
» and players privacy and lnfonnatlon. I'm sure you can understand
» that I cannot release a player's Information base on an email request
» from an lndlvldual that I have no record of. I assure you I am only
»protecting our player and not taking sides. We will be happy to
»cooperate with any legal request for Information, but until them my
»hands are tied. You, of course, have every right to discuss this
»policy with the club's Board of Directors. let me know II you would
» like their contact Information. Thank you for your understanding of
- - - - --» my position. - Amy
»
»--·Original Message·-··
»From: jennlfermehaddl@comcast.net
» [mallto:jennlfermehaddl@comcast.net)
»Sent: Monday, March 31, 201411:25AM
»To: Arny Mlkulsky
» Cc: usclubreglstrar@washlngtonrush.com; Washlngtonrush
»Subject: Lauren Rife
»
»Amy and Martine
»
»
» I just Onlshed a phone call with CEO Tim Schulz In Colorado. My
»attorney has encouraged me to gather my daughters records as my right
»as her parent rather than having to Subpoena the Information at rny
»expense and time. He stated verbatim and clarified what I already
» know as WA state law "you as her Mother and primary parent with
»current joint decision making have every right to your daughter's
» records, bar none. Your parenting plan and the fact that she Is a
»minor and your daughter, supersedes the club policy". He In fact
»stated there Is no club policy stating that a parent has no right to
» their own child's records. He told me to scan to you the copy of mine
»and Mr. Rlfe's (Lauren's dad) portion of the parenting plan that
»shows we have joint decision making and that I am primary parent. He
»asked me to allow you
» 48 hours to get this Information to me. Denying me this Information
» Is Illegal. For example as nm stated • what If Andy was not at a
»practice or a game and neither was I. How would you contact me, how
»would Lauren's Injury and medical care be handled appropriately?
» Because of my name not being on those records, and because I am
» refused access to those records or not allowed to have my name added,
»WA Rush would be In hot water and possibly a lawsuit. Mr. Rife left
» me off of our own daughter's records when I trusted him to not do so.
»The team/club should be neutral and that Is certainly not the case here.
»There have been emails back and forth and declaration written from
» parents of the team. t want all correspondence, and all registry
> Information.
»
» I will fax and scan that portion of the parenting plan this afternoon.
»I need your fax number Immediately, and a phone call back from an
»administrative person HERE In WA that I can further discuss and
» confirm this with.
»
»
»Thank you and I'm sorry to have to go this route but I have no choice
»after being denied. I wlll await a phone call very shortly from
»either you or a person who can responsibly handle this situation. If
»not- Mr. Schulz has asked me to call him back and he said he would
2
» personally get Involved. His cell phone number Is 303·638·5672 if you
»want to confirm any of this with him.
>> ...
»
»
»Jennifer Mehaddl (Lauren Rlfe's Mother)
»Cell: 425-330·2503
3
Amy Mlkulsl<y
From: Jenn <jennlfermehaddi@comcast.net>
To: .. tschulz@rushsoccer.com; tschulz@rushsoccer.com
Cc: Amy Mlkulsky; Amy Mikulsky
Subject: Fwd: your legal documents in a pdf
Attachments: Jenn portion of parenting plan.PDF; Untitled attachment 00504.hlm
HI Tim,
Without taking legal action I have offered up every which way to prove I am Lauren's mother and to find a solution. For
some reason it appears amy does not want to disclose any current or past records. So I am sending you all the
documents that I've sent amy. If you would accept these documents by email, why would she not? I don't know what
else to do and I should not have to have to pay for my attorney to subpoena everything. I'm not harassing anyone or
being dlfflcult - I am Lauren's mother and I need her records. let me know If there Is anything else I can do or my last
step wlll be calllng my attorney and I should not have to.
Sent from my !Phone
Begin forwarded message:
From: "Carol Holland" <bolland@premlerl.net>

Date: March 31, 2014 at 1:32:47 PM PDT
To: <lennlfermehaddl@comcast.net>
Subject: your legal documents In a pdl
Amy Mlkulsl<y

Subject: Re: Lauren Rife
My own account Is not what I'm asking for. Tim knows and told me to reinforce that I am asking for Lauren's registrar
Information and correspondence.
Sent from my !Phone
>On Mar 31, 2014, at 1:40 PM, Amy Mlkulsky <rcl-am@msn.com> wrote:
>
>Thank you for getting those documents to me. As of right now, I don't
> have any proof that you are her mother and therefore you can
> understand why I can't give you any Information. I am happy to speak
>with Tim and/or your attorney. I assure you I am only trying to act
> In the best Interest of our player. We have many families that share
>custody of their players and set up separate accounts for both all the
>time. Once we establlsh you are her mother. we can get your own
>account set up with Lauren as well. ·Amy
>
> -···Original Message·····
> From: Jenn (mallto:jennlfermehaddl@comcast.net)
>Sent: Monday, March 31, 2014 1:31 PM
>To: Amy Mlkulsky
>Subject: Re: Lauren Rife
>
> I'm going to contact Tim right now then. I'm currently scanning legal
>documents to you right now that show I am her mother and primary
>parent. You are wrong and opening yourself to legal Issues by denying
> me my daughters records.
>
>Sent from my !Phone
>
»On Mar 31, 2014, at 1:27 PM, l\my Mlkulsky <rcl-am@msn.com> wrote:
»
»HI Jennifer -As a club, we make It our pollcy to protect our members
»and players privacy and Information. I'm sure you can understand
»that I cannot release a player's Information base on an email request
» from an Individual that I have no record of. I assure you I am only
» protecting our player and not taking sides. We wlll be happy to
»cooperate with any legal request for information, but until them my
» hands are tied. You, of course, have every right to discuss this
»policy with the club's Board of Directors. Let me know If you would
»like their contact Information. Thank you for your understanding of
» my position. • Amy
»
»···-Original Message·····
I
•
»From: Jennlfermehaddl@comcast.net
» [mallto:jennlfermehaddl@comcast.net)
»Sent: Monday, March 31, 2014 11:25 AM
»To: Amy Mlkulsky
»Cc: usclubreglstrar@washlngtonrush.com; Washlngtonrush
»Subject: Lauren Rife
»
»Amy and Martine
»
»
» I just finished a phone call with CEO Tim Schulz In Colorado. My
»attorney has encouraged me to gather my daughters records as my right
»as her parent rather than having to Subpoena the Information at my
»expense and time. He stated verbatim and clarified what I already
» know as WA state law "you as her Mother and primary parent with
»current joint decision making have every right to your daughter's
»records, bar none. Your parenting plan and the ract that she Is a
»minor and your daughter, supersedes the club policy". He In fact
»stated there Is no club policy stating that a parent has no right to
»their own child's records. He told me to scan to you the copy of mine
» and Mr. Rlfe's (Lauren's dad) portion of the parenting plan that
»shows we have joint decision making and that I am primary parent. He
»asked me to allow you
» 48 hours to gel this Information to me. Denying me this Information
» Is Illegal. For example as Tim stated - what If Andy was not at a
»practice or a game and neither was I. liow would you contact me, how
»would Lauren's Injury and medical care be handled appropriately?
» Because of my name not being on those records, and because I am
» refused access to those records or not allowed to have my name added,
»WA Rush would be In hot water and possibly a lawsuit. Mr. Rife left
» me off of our own daughter's records when I trusted him to not do so.
»The team/club should be neutral and that Is certainly not the case here.
»There have been emails back and forth and declaration written from
»parents of the team. I want all correspondence, and all registry
> Information.
»
» I wlll fax and scan that portion or the parenting plan this afternoon.
» I need your fax number Immediately, and a phone call back from an
» administrative person HERE Jn WA that I can further discuss and
» confirm this with.
»
»
»Thank you and I'm sorry to have to go this route but I have no choice
»after being denied. I wlll await a phone call very shortly from
»either you or a person who can responsibly handle this situation. If
»not - Mr. Schulz has asked me to call him back and he said he would
»personally get Involved. His cell phone number Is 303-638-5672 If you
»want to confirm any of this with him.
»
»
»
»Jennifer Mehaddl (Lauren Rlfe's Mother)
2
»Cell: 425-330-2503
~-~- 1•- - -
3
Amy Mlkulsl<y
-Fram: - Benjamin Somoza <bsomoza@washlngtonrush.com>
Sent: Thursday, April 17, 2014 4:14 PM
Subject: Lauren Rile
Amy for Lauren's dad Lawyer. Here is what I chatted about with Tim Shullz.
I talked to SP! Rush CEO Tim Shultz regarding Lauren Rife's moms emails ond conversation with him. He told
me that he encouraged her to handle it on o local level with Washington as we would not release any
information about her. I told him that we could not release nny info on players if they ore not on the account and
wished he would connect with us prior to speaking to someone that calls him. He said his mom was pretty upset
and going to press legal if we did not release all the info ond emails we hove had. We talked that this is a good
learning tool for Rush as a whole with divorces and families. We have not had any further conversations about
it.
Benjamin Somoza
Washington Rush, Technical Director
c. 206-779-5571
www.washlngtonrush.com
I
Amy Mikulsl<y
From: jennllermehaddi@comcast.net
Sent: Thursday, March 27, 2014 9:29 PM
'" ----~ · To: Amy Mikulsky; Amy Mikulsky; Amy Mikulsky
Subject: Re: Lauren Rile

Then we will have to subpoena It. I am her Mother and primary parent. Because I am not on the account I don't see how
I am not privy to the Information. There has been many problems with Rich and the parents on the team and
declaratlons written regarding my personal Ille and this llllgatlon that Is highly Inappropriate. I will be forwarding your
response to my attorney. Thank you.
On Mar 27, 2014, at 9:22 PM, Amy Mlkulsky <rcl-am@msn.com> wrote:
> HI Jennifer - I pulled up Lauren's account. Because you are not

>connected or listed on her account, I am not able to give you details regarding her
>registration. I'm sorry I can't help you, but I must follow club policy.
>Thanks -Amy
>
> ··-·-Original Message .....
> From: Jenn (mallto:)ennlfermehaddl@comcast.net)
>Sent: Thursday, March 27, 2014 7:28 PM
>To: rcl-am@msn.com
> Subject: Lauren Rife
>
>HI Amy
>
> I need to find out If Lauren was registered for the upcoming season of
>soccer. Even If It was canceled I need to know and have a copy of It.
> Please see my texts with Rich below. This has to do with mediation and
> Lauren being able to play. It's very Important. Please let me know as soon as possible.
>Thank you.
>
>Jennifer Mehaddl (Lauren's mom)
>
>Sent from my IPhone
- - . - ·-----
EXHIBIT F

I I
210 Summit Avenue llast, Seattle, WA 98102 tel• (206)328-7362 fax• (206)323-0404
Amy Pasco
From: Jenn Mehaddi <jennifennehaddi@comcast.net>

·-~-sent:- - Monday, May 26, 2014 6: 14 PM
To: Amy Pasco; Veronica Freitas
Cc: Elise Buie
Subject: Fwd: Practice Change/Team Info
Sent from my iPhone
~ .. F.-om: Brian and Niki Allan <briannikinllan@msn.com>

Dntc: May 26, 2014 at 6:11: 18 PM PDT
To: Lauren Rife <jennifcrmchaddi@comcnst.net>
Subject: RE: Practice Chnngeffemn Info
Last week was the first week of practices. The team has had two practices since try-outs. I just
received word today from Andrew to add you to our team email group. Mya is very excited to be
playing with Lauren this season.
From: jcnnife1mehaddi@comcast.net
Subject: Re: Practice Changetream Info
Date: Mon, 26 May 2014 17:27: 19 -0700
To: brinnnikiallan@msn.com
This is the first notice I have gotten in probably a month regarding soccer. Can you tell me how
many practices there have been since Lauren had try outs? I'm absolutely shocked.
On May 26, 2014, at 4:45 PM, Brian and Niki Allan <brinnnikiallan@msn.com> wrote:
HI Jennifer! I'm forwarding you the recent emails I sent out to the team.
Niki Allan (Mya's mom)
From: brlanniklallan@msn.com
To: asrife001@lcloud.com; wdr1626@yahoo.com; brlannlklallan@msn.com; bur
gy23@hotmail.com; dale.pesek@gmall.com; easats@gmall.com; toad8610@ms
n.com; jenamcc@hotmall.com; lessnrlley@yahoo.com: kristintemperly@gmall.c
om;goldsgymteresa@yahoo.com; taddyg23@gmall.com: vladlvel@gmall.com
CC: guszadra@gmall.com
Subject: Practice Change/Team Info
Date: Fri, 23 May 2014 20:46:16 -0700
This email contains lots of Information, please read carefully.
Practice change for next week:
Tuesdav. May 27th 6:00pm Olympic View Middle School

Address for Olympic View Middle School: 2602 Mukilteo Speedway
Mukilteo, WA. 98275
Thursday. May 29th 5:30pm Kasch Park
I will have June's schedule soon.
Korrie
Per club request, we will keep Korrie up to date with all team practices and
games. Everyone has a Korrie account, it was used to register for the
season. Please go onto your account and update your alerts and
notifications. This is how you would like to be notified of changes by email,
text, and/or phone call. Several times last season, Sandy needed to
cancel practices last minute due to weather and field situations. Any last
minute changes will come from her and she sends out those alerts
through Korrie. Bryan and I will keep ii updated so please use this sight for
info regarding practices, games and tournaments.
I will still send out a weekly email on Sunday night or Monday morning as
a reminder for the weeks events.
Another great perk of Korrlo, it has a mobile app. I even synced my

Korrio calendar to my smartphone. Check it out and let me know if you
have any questions.
Medical Release Forms
All players must have a signed medical release form. Please print the
attached form and return ASAP.
Birth Certificates
Birth certificates need to be verified for all new players to Washington

Rush (that's a majority of the team). We do not need to keep a copy, only
need to see it to verify DOB. Please bring It to an upcoming practice
for Bryan or I to verify.
Club Volunteer Hours

2
Each family is responsible for serving 4 volunteer hours.
Rush Cup will be a great opportunity to satisfy those hours. (more Info to
come)
Team Representative needed Ill We need a team rep to attend the

club's AGM meeting to represent our team's vote on board elections. It will
be on June 19th. This will satisfy one hour of volunteer time.
We also need another person to help Teresa Wirkkala on the auction and
raffle. Both the auction rep and raffle rep wlll satisfy their 4 volunteer
hours. Please respond ASAP, I need another parent to help out.
Tent shelter: this position of carrying around the team's pop up tent to and
from the games now receives full credit towards their volunteer
hours. Thank you Erika (Jade's mom) for volunteering to do this for the
team.
Raffle
The raffle Is a big fund raiser for the club. The Kick-Off will be In the next
few weeks. Tickets will be $20 each this year. Each player will receive 5
tickets to sell. More Info to come.
Last year's grand prize was a car!
Winner will be drawn at Rush Cup
Recap:
Please note the changes for next weeks practice schedule
Print and sign medical release form
Bring birth certificate for verification
Team Representative needed ASAP for June 19th
2nd auction/raffle rep needed ASAP
This was a lot of information. Please let me know If you have any
questions.
Niki
3
EXHIBIT G

I
210 Summit Avenue Rast, Seattle, WA 98102 tel• (206)328-7362 Ifax• (206)323-0404
- carorHolland
From: )ennllermehaddi@comcasl.net
Soni: Saturday, March 29. 2014 2:27 PM
To: Carol Holland
Subject: Does year-round play put young soccer players al risk?
Please print for me
hIt p://www. pIn yi Inga i11 sport s.com/ne\\'Sid cl ui I/Does-wn r-ro 1111d-P.I ny-nut -yo 11 ng- soccer-p Iayers-at-risk
Does year-round play put young soccer players at risk?
ccording to ~!.!iH::li>v.tJ,<l!!.i.w:k,,•,r.-:, more than 3.5 million

kids under the age of 14 receive medicnl treatment for ~l'O!:I~ injuries each year, ond children between the
ages of 5 and 14 account for nearly 40 percent of all sports-related injuries treated in hospitals.
Many experts sny that overuse is the most common cause of sports-related injuries, since the same
muscles ore used O\'er and over again.
"Playing one sport for 12 months a yem· means a young athlete is either destined to ha\'e great technique,
or they \\rjlljust break down," orthopedic surgeon Dr. Charles Bush-Joseph recently told the Chicago
Tribune.
Today, many kids are playing sports, such as ~!•<'l:.('f, all year long, a practice that many doctors say could
end up injuring them.
"I think the word is getting ont to coaches and parents about the consequences of o\'emse injuries, but we
still have A long wny to go before people understand the severity of these concerns," Dr. ,Joel Brenner,
chairman of the American Academy of Pediatrics Council on Sports Medicine and t_'\1.,,,5,, told the
newspaper.
One way to cut down on yom child's risk of being injured while playing sports is to avoid sports
specialization and ensure he or she is using the proper new or used sports equipment.
.. · - - · -·-B~id-;;s injUl'ics, experts say that sports specialization can lead to bum out and comPJetel)·-ii1iderminc the
reason many kids play sports to begin with - to have fun.
' .
2
------------·-- ·--·-- · - ·-- --·--·--·
-Carol. Holland
From: jennlfermehaddi@comcast.net
Sent: Sunday, March 30, 2014 11:57 AM
To: Carol Holland
Subject: Kids and Sports - How Much is Too Much?
hl11>://spor1smc<licine .nhoul .c•>m/mf /chi ldrcn/n/K ids-A ml-Soorts-1 fow-M uch-1 s-Too-Much. ht Ill
Kids and Sports - Hov, Much is Too Mneh? 1
.. It's not uncommon for kids today to take their play prell)' seriously. Sports practices, personal conching,
drills and detailed workout routines seem to be part of the new normal for any kid ll'ho wants lo plar any
sport. The days of fun, exercise, fresh air and rnndom play haYe given O\"er lo organized, O\'er-scheduled
and sel"ious training. And more kids are becoming specialized at n \'ery young age. In the Sos most kids
who played sports, played multiple sports throughout the year, and had big gaps that included random
outdoor fun. Today, the number of kids who are encouraged (or who chose) to narrow in on one sport, and
try to excel at that just one sport, is large, and still growing. And while some kids thri\'e in this
environment, many are suffering the consequence.~ of too much oft he same activity, for too long, and with
too much intensity. Q,·eruse injmies, burnout and mental fatigue are starting to appear in kids as young as
eleven and twelve.
According to ·>ln11~pvrbi1!.i11;:i"..~·.!.!'.'l~· more than 3.5 million kids under age 14 recei\'e medical treatment fo1·
sports injmies each year nnd high school athletes account for an estimated 2 million injuries, 500,000
,,
doctor ,·isits and 30,000 hospitalizations e\·er.1• yenr. Children between the ages or lh·e and fomteen
account for nearly 40 percent of all spo11s-related injuries treated in hospitals. And e,·r.n more
surprisingly, •".1:! ·•~• · 111.iax;; ·:; are responsible for nearly holf of 1111 sports injuries to middle and high school
students.
One reason that experts gi\'e for this dramatic increase in injuries is a new trend toward sports
\1 '.
specialization in young athletes. This spcciali1.ation, and the year-round training programs that go with it,
also seems to be linked with a dramatic rise in the number of kids showing up in doctor's offices with
chronic O\'eruse injuries including lrti~Jtqjjb, and e\'en :1~1.r.-~.it1•.I {~:_1,:~ ~.J.'h ~_,l.i! • 1\1:n ;iJll.l. And many kids arc
suffering from injul'ies that once were only seen in 1>ro athletes. Joints reconstruction in )'OUng athletes,
unheard of in the 70s and Sos, started emerging in the 90s, and has become a gro\\ing trend in the past
decade.
The recent trend towards sports specialization in young athletes has resulted in kids following year-round
training routines, overnsing muscles, joints and growing bodies In grueling 1·epctition. The idea that
I
-------------·-·-··-·--. - -· . -·. -·-·· ---------
starting young and training early might lead to scholarships, pro careers, success and endorsements can
blind many well-intentioned coaches and parents. Kids bodies arc far more n1lnerable to the stress of
_repetitive mo\•ements, and e\'entually, will break down.
Parents and coaches can avoid many of the harms of,;\:;·.!.!! "'"'"l> in kids by simply helping set the right
environment for healthy sports participation.
• Time off from organized sp01·1s.

Gi\·e kids a break by encouraging them to take a minimum of t\\'o to three months a\\'ay from any
one sport dnring the )'ear.
• Encom·agc kids to piny multiple sports, at diffel'ent times of the year.
Different sports, and different 1110\'ement pattcms help kids stny healthy, and balanced. Using the
same mo\'ements, the same muscles and the same joints none-stop through the year is a set-up for
injmy. Encourage a wide-mnge of activities including swimming, field sports, court sports, biking,
walking and random play.
• Reduce re11etltive motions, like batting 01· pitching.
Any activity, or sport, that required repetitive und systematic range of motion of one or more joints
can wreak havoc on young bodies. Practicing the same motion--pitching, S\\inging, or kicking-·o\·c1·
and over throughont the year isn't ideal fol' gl'owing bodies. It's better to ha,·e kids play sports that
require a wide-rnnge of fluid mo\'cments, or mix up pitching practice, with fielding practice to
allow 111uscles and joints to rest, and recO\·er. Working a rnriety of muscles in different ways also
helps keep a gro\\ing body in balance, and encourages a wide range of skills, coordination, agility
and flexibility. So encourage kids to play a range of positions in their sport and learn the skills drills
for special occasions, not daily practices.
• Play attention to wa1·ning signs of overuse.
Nagging injuries that nrc left untreated can quickly tum into< I,:, ro·, i''"lil .. 1>;-. that rcquil·e a much
longe1· reco\•e1·y time. They mny e\'en 1·esuh in long-term problems that nC\·er henl properly.
• ~r1'l:!l~jJJ.it11:i~.!i iJ11n,_l~c.n.:itr:1r.
Pull kids off the field at the first sign of an injury. Any injury that hwolves pain, swelling, weakness,
or decreased mo\•emcnt needs medical attention. And any injmy that doesn't i111pro\'e in a day or
two warl'ants a \'isit to a physician.
• Take bend inju~ies ve1·y se1·iously.
l;u.11n11-~i1111~
in youth sports can ha\'e very serions long-lenn consequences if ignored. The damage
from e\'en a mild bump on the head can become cumulali\'c, and each successh·e head injmy can
ha,·e more and more serious effects. 1f you suspect a concussion, pull your child immediately nnd
follow the concussion treatment guidelines.
2
----------·---- ..... ·-. -· ------ ----------
Carol Holland
From: Jennllennehaddl@comcast.nel
To: Carol Holland
SubJect: Youth Sports and Overuse and Chronic Injuries - Increasing Overuse and Chronic Injuries in
Youth Sporls
Did I send 1his one?
h11 p://~mwtsmcd ic inc .n hm 11. en mt.id/c I1i Id rcn/;1/<1vc n is~k ids. h 11 n
Youth Sports and Overuse Injuries

The numbers of kids showing up in the doctor's office with ..-..\"'-··;,,, , .... -, suc.h as tendonitis, is climbing
drnmatically, nccoi·ding to Boston Children's Hospital. Nationally renowned orthopedic surgeon, Dr.
Jn mes Andrews, said that he is seeing four times as many o,·cruse iujuries in youth sports than fi\"e rears
ngo and more kids are having surgery for chronic sports injmies.
Bxperts attribute this increase to the fact that more youth today arc specializing in one sport at an early
age and training year-round. All these injmies can be linked to o\'erusc; doing too mnch, too often. Gone
me the days of switching to a new sport each season - the two or three-sport young athlete seems to be a
things of the past as the competition, access and seasons expand to rcnr-round.
This sports specinlization seems to ha\•e come \\ith a price. Playing a \'ariety of different spmts throughout
the year wns a form cross-training that was extremely beneficial to a young body's physical de\·elopment.
Playing multiple spo1ts, at different times of the ~·enr gi\'es some muscles n chance to rest while others a1·e
being worked. Now those same muscles and joints arc used none-stop and ha\"c no recorn1-y time.
Training the same muscles year-round is believed to be the main cause of the rise in m•eruse injuries in
young nthletes. 'l11e repctiti\'e stress can cause young bodies to break down. When you stress the same
body ports m·er and O\'er again, there's a risk of injmy.
Kids Should l'lay a Va1·iety of Sports - Avoid Specializing in One S1101•t

Young athletes need to \'ary their truiningjust like pros do. All pros lm\"e an off-season where they change
their training routine and <•:··L'i"'"''· They still spccinlir.e in one sport, but they adjust their scnsonnl
trninii1g to allow complete reco\°CI)'. No one can go 100 percent in a sport year-round ,,·ithout risking
injury or reduced performance.
Many physician's who treat these injured kids feel that the solution is education for parents and coaches,
so that they con sec the warning signs and pull kids off the field before injuries get serious.
. - - __ _____ .
,,,_ ____
The Americ:m College of Sports Medicine has published 111.!lll''' !~r•;'·~·•i i,;.,\ ~ · ,_:_.1,.i;, .. ·-. '''' \ "'\"'!' .-\11· 1:';;·,
as a reference fo1· kids, parents and coaches seeking to keep kids safe dudng sports.
Rend more about:

f•
~pr JUI! -~l.t:_l liri Iii: 1~.-;1 il~:- .. ~r ( "11 iJi.l "'.:.tJ
t 0'i.•nn11q11 Sp<H:i·.:. t nj1_1_1 r:i .i.n_C I~-~ ldr1•n

=
·r,.,·,1ttn" Iii il11d l'n. ·~·~'.11110111111 'lull\q·n·~- ~-•:)1 •l't:. i ,.1,il.:t i1•..,
.i:il11.'.:\".". F!·.:_1,c.:l111 ,.
-:<•:h ;11,·~.Ji· nd1111ir.i,,
Sources:
:1·hc ~ 1n~~r!t:11?_l,~1!!r:;.~t·_,_!1. ~1_1!'.•rt !-. ~.-1, ., i :~·1_1 ,,.
,-\l;;~J.!aH!.!J.~P-'-'·rt• i\·1r.~ !i+:f.1.1.(·_:_q 1,.! t >r.1 l_111_p! ~=I h t '.c·: 11 · ·:
2
•
-------··-·---·- ....
Carol Holland
From: jennifermehaddi@comcasl.nel
To: Carol Holland
Subjoct: Sports Specialization - What's Safe, Whal's Nol
11 l ln:// ll1 Ill i Iy Ii t ncss. u btl l 1t •~nn1 h.HIlk id ssp1 l rl slnlSP.url s •S 1~c i uIi YU Iin !!:l!.un
Sports Specialization: V\'hat's Safe, vVhal's Not:

With kids clnmoring to join elite trm·el teams at younger and younger ngcs, and mnny coaches and leagues
all too willing to mnke that happen, parents are often stuck in the middle. When nre you :•"J 1,1; : ..... 1
diifd\ 1.:1~111-and when are you pushing too hard for a dream tlmt's unlikely to come trne? When are you
supporting your child's passion, and when me you ca\'ing in to pressure from a coach or fellow parent?
Learn more about the consequences of sports specialization so you and rour athlete can make smart
decisions.
What Is Sports Specialization?
In general, specialization in sports means playing (or trnining for) one spo1·t, exclusi\'ely, year-round. A
2013 study of young athletes used n sports spccinlizatio11 scale to 1-ate kids' le\'el of speciali7d"ltion.
Researchers ga\'C one point for each of the following, for a maximum score of six:
• Tmining more than 75 percent of the time in one sport

• Training to impro\•e skill; or missing time with friends due to training
• Quitting other sp01ts to focus on one sport
• Considering one sport more impo1tant than olhers
• Trm•eling out of state regulnrly
• Training more limn eight months a year, or competing more than six months n year
The Risks of Sports Specialization
In that study, kids who hud suffered sports injuries scored higher on the specialization scnle. (~,. ·.· '""'°
i11i11ri1•:; are one of the biggest concerns when athletes tmin intensively for one sport. Relatedly,
specialization can limit normal motor skill dc\·elopment. If n child is spending all his time on the soccer
field, he won't get a chance to learn or impro,·e the skills needed for swimming or ,·olleyball or bicycling. A
softball pitcher will spend the majority of hc1· time throwing, instencl of running or ernn catching.
- --:i--
-Too much ofa good thing can also lead to a_q::_id_,. and l't" '"'"'.Simply put, specialization can takP. the fun
right out of sports. A 2013 study published in the Journal '!{Sport Helmvior reported that young adults
who had specialized as kids were less likely to participate in spm·ts in adulthood. Kids ll'ho nre \'err busy
with one sport may miss the opportunity to stumble onto a different sport ther might i~!''".- 1: ~~ 1_;,·:c.:::_i1.;
!'\•Jrn:, becnuse they aren't trying lots of different acti\'ities.
Finally, there's no guarnntec that sports specialization will lead to a successful athletic caree1-, despite the
pressui·e some kids and parents feel ("If he doesn't play on this ti·a,·el team now, he won't be able to piny in
high school, and then he won't get a college scholarship ... "). John P. Di Fiori, MD, president of the
American Medical Society for Sports Medicine and team physician for UCLA athletics, discussed this at
the society's annual meeting in April, 2013. "With the exception of select sports such as gymnastics in
which the elite competitors are \'Cry young, the best data we ha\'C would suggest that the odd.~ of achie,·ing
elite le\'els with this method are exceedingly pom-. In fact, some studies indicate that early specialization is
less likely to result in success than participating in se\'eral sports as 11 youth, and then specializing at older
11
ngcs.
The Rewards of Spo1·ts Specialization
Once your child does reach age 11 or 12, specialization is not as risl<y and cnn ernn bring some benefits.
Specialization helps kids develop strong skills in their chosen sport. If they arc successful, the~· can build
good confidence in their abilities. They may be able to trD\·cl to interesting places and learn to get along
with lots of different people. And yes-maybe they'll e\'en earn a sports scholarship or create a career for
themselves in sports. If your child is trnly devoted to her sport, has fun playing it, and takes rr• '''""·I;,_,.,, "'
1\:(I"'''' tlh'.J'i~l, of il_lJl.ll"), then specializing may really be rewarding nflc1· all.
,,
.lu~1111lhl, N, ,.ID; llu~°"' I.. PhD; l'l nl. 1~ .. •.. 1•' ···.• ! : 1 ·, . ' I• •; 1; ~ .... t • • t
1
••• ' •• • .• •• . .... ·
lhLoes..:11, \\'illinm 0.: LimlL". A11hlc,· N. ·1 " ;:........ ·••,• :·.- ·•,·. : \.; ·'i• '• -·· · ';· . ., . ··,1,1. ·-·. 1 ..
2
Carol Holland
-,-.-From: jennlfermehaddl@comcast.net
Sent: Sunday, March 30. 2014 10:61 AM
To: Carol Holland
Subject: Age of Specialization: One Sport Vs. Multiple Sports - Greensboro, NC - Child Sports Injuries
h11p://\\°\\"\\".\.!llil lt111iortho.co1nh1L!C of sncci;i1 i'.l:tl ion.hlll1
Age of Specialization: One Spo1t Vs. I\1llltiple Sports - Grl'cnsboro,

NC - Child Sports lnjuries
Age ofS)lecialization: One Sport Vs. Multis)lorts

Ry Dctavius M11son
•, -,~ ...
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•: . ·.' ·Kobe Bryant, Roger Federer, Tom Brady, l.ebron ,James, Alex
Rodriguez. When these names are brought up, a rew things come lo mind: excellence, transcendent talent,
winning, but the thought of them specializing in one sport should not. Kobe & Federer were soccer playern,
Brady plnycd baseball, Lebron plared football and A-Rod played baskctbnll, footbnll nnd soccer. It's kind
of strange to think that each of these Future Hall of Famcrs in their respective sp01ts didn't spend every
waking moment of I heir life dedicaled lo their chosen profession. Sure you hnvc the story of Tiger Woods
who 11·as placed on the Mike Douglas Show to putt against Bob Hope at the ripe old age of 2. Or tennis
great Andre Agassi who somclimcs prncticed with pro tennis players at the age of 5! But ~·ou ne\'er hear
from the other side of the fence. What aboul the many athletes who spedalize at a young age, only to fall
short of their lofiy ambitions. Wondrous success stories like Tiger Woods and And1·e Agassi are
aber.-ations, but ns long as there are wealth and fame associated with professional nthletes, people will
attempt to make their child the next Tiger Woods. But the question you must ask ~·ourself is "Is it really
worth itr'
Since the sporting 11nh·e1"Sc hns grown in popularity & exposure, the idea of creating the perfect athlete has
Jed to many studies of specialization. l'rom journal mticlcs lo full fledged books, arens of interest
throughout the 20+ years of research include the perfect ngc to specialize in one sport, O\'Cruse injuries in
the young athlete, who should specinlize in a parliculnr sport, and whether or not specialization is needed
for college preparation. They nil hn\•e one centrnl theme, specializing in one sport at a young nge could
have dire consequences on yom body. Youth who m·e coerced into specializing in n sport by family or
coaches are al nn even greater risk. According lo SAflE KIDS USA, children nges 5-13, our ~·outh, account
for nearly 40% of nll sports related injuries.
Many athletes are being faced with the option of specinlizing in one sport or being looked at as not being
dedicated to their particular sport. Gone are the months known as the off-season and just "playing out in
the backyard," now athletes go from theil' school team, to their tra\•eling AAU team, and maybe e\·en on to
a community team. More and more, kids are not gi\'en the option to participate in another sport due to
nothing more then n lack of time. This repetilil'e amount of stress on the mind and body can cnuse
physical & psychological burnouts, injmies related to o\'erusc, O\'ertraining, and maybe e\·en psychological
pl'oblems related to failure. A bumout is defined by sport psychologists as "physical/emotional
exhaustion, sport devaluation, and reduced athletic accomplishment." Injuries related to overnse are n
major concern for younger athletes. Pal'ticipating in the snme spol't stresses the snme bones, joints, and
muscles. With limited rest & reco\•e1y time the body begins to break down, fatigue nnd become more
susceptible to injuries. O\•eruse injmies account for 50% of the amount of total injuries in middle and high
school athletes. O\•ertrnining is the result of the st min & l'epetitious nature of multiple practices \\ithoul
the p1·oper !'est. It could be something that lasts n day or two or something thnt lasts for half the season.
Some psychological problems related to specinli7.ation include loss of focus, loss of interest in a spo1t,
increased amonnt stress that's intertwined in spol't, depression caused by failing and cmotionnl fatigue.
These areas of concern ure becoming the norm for today's athlete which is rniterated in the number of
youth injuries and injuries that were previously only seen in ndults.
What would you do if your son was 6'6 at the age of 13? Would you force them to play a sport that put
them at a disad\'antage 01· in\'oll'e them in n sport that could use their great height to their nd\'antage like
basketball? Or maybe they ha\·e a long torso, a shorter lower body, nnd big feel; they would be best suited
fol' swimming sp01ts. While none of these trnils necessarily menn future success, it would be rensonable
for one to II)' and specialize them in a particuln1· sport. If one chooses the one sport specialization route,
the two most important things for n parent/coach to remember is the safety of the child comes first nnd to
ne\•e1· make the sport feel like a job, always keep it fun. Anothel' significant task in specializing in one sport
is to protect the athlete and theil' hcnlth. According to the Amcricm1 Acndemy of Pediatrics, signs of sport
O\'erload include chronic injuries, illnesses, weight loss, sleep disturbances, nnd foiling gmdes in school.
2
------- ··-- ---
Specialization has been a hot topic of discussion for many years. As with any hot topic, many studies ha\'e
been done to support or refute the practice of specializing in one sport. All of the studies I hu\"C read all
point to one thing: specializing in one spo1t at a young age, e\'en excelling at the sport at a young age, does
not equate to future success. That means a child can master bending it like Beckham at the age of 3, win
e\'eJ)' MVP trophy for each team he's on, and e,·en dominate one of the many 11'8\'eling AAU soccer teams;
it does not mean thnt he will ha\'e fulme success as a soccer player. The only thing that has been
accomplished in that scenario of soccer specialization is that 1.) The child hns lost the opportunity lo
discover other talents 2.) The years of pounding on his body could result in future injuries or 3.) The child
might burnout & tire of the spOl't. It is also of note one study whose conclusion was that kids do not ha\'c
to be one sport specific to compete at the collegiate le\'el. Wow, n study of collegiate athletes that shows
that early specialization is not needed and is no guarantee for future success. Who would ha\'e e\-er
guessed?
So allow your child to participate in multiple sports. That way he or she can become adept to using o
multitude of muscles and puts less stress on lhe muscles and bones they use in their primary sport.
Pnrticipating in multiple sports also allows them to sec if they nrc talented in another spo1·t, less stress on
the body, O\'erall athleticism increases, gain more fiiends & social interaction, nnd there is less pressure to
be perfect.
References:
1. Hccimovich, Mark (2004). SpOl't Specialization iu Youth: A Litcrnturc Re\·iew

,Journal of the American Chiropractic Association, Apr 2004
2. Amcl"ican Academy of Pediatrics Committee on Spo11s Medicine and Fitness.

(2000). Intensive !mining and sports specialization in young athletes. Pediatrics, 106
( 1), 154-157. Retrie\•ed October 16, 2005 from SPORT Discuss database.
3. O'Neill, D. B. & Micheli, L. J. (1988). O\'eruse injuries in the young nthlete. Clinics in
Sports Medicine, 7, 591-610.
4. Pantuosco-Hcnsch, Lynn. (nd). Is Youth Spo1t Specializ.1tio11 Necessaf)· for Future Collegiate
Participation? Retrie\'ed August 26, 2008 from
5. Cassell, Juliet. (nd). Should my chilcl specialize?

l~ct1·ieved August 26 2008 front h• ·J,. '.'" · •.\-·\ .~·~ h1t· .. :~·.r~ p 1rl.-·j · ·u "· •t\I
1
3
- · 6.-Swanson, .lennifer. (,h1ly 2005). A New Youth Epidemic? Relrie\'ed August 27, 2008 from
,, l \p:/ i_\}.\\ \\".1'1~h~,_1ffU1b.1,•1ilH/tcai 11)': ...,, ..... :!(H J.,1/ !~.::1.!-.1 r
EXHIBITH

I I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328·7362 fax• (206)323·0404
Amy Pasco
. Sent: .. Saturday, May 3, 2014 3:39 PM
To: Amy Pasco
Subject: Fwd: Rush

. ·-
Subject: Re: Rush
Date: March 27, 2014 4:09:53 PM PDT
To: "jennifermehaddi@comcast.net" <jennifermehaddi@comcast.net>
· · - ) Hasn't been done yet.
Sent from my iPhone
On Mar 27, 2014, at 3:58 PM, "jennifennehaddi@comcast.net" <jennifennehnddi@comcnst.net>

wrote:
I would appreciate it if you would provide me with a copy of the registration you
filled out for Lauren this upcoming season or if not the user name and password
that you use on the Rush website. Thunk you.
Jennifer
EXHIBIT I

I
On Apr 16, 2014, at 1:47 PM, Andrew Rife
<nsrifeOO l@icloud.com> wrote:
. __ __. ___ - - ..
..., Jenn,
For two consecutive weeks you have

contrived excuses to keep Lauren
from spending time with me.
For the past 3 years you have

acquiesced time with to me for the
benefit of Lauren. The day you
worked late Lauren was with me at
least until you got home, and most
times overnight. Neither you nor I
ever had to talk about the ri ht of
ust re sal because neither ou nor I
.ever t ought of it in those terms. It
was simply time Lauren was
supposed to be with me. I did not
think about part VI of our parenting
plan, and neither did ou. That all
c anged last summer when you
began trying to limit and prevent
Lauren's time with me. I started
talking about the four hour rule and
in November you told 1me that it
does not exist under the temporary
pw-enting plan. I pointed out that it
does still exist.
Now you acknowledge that it exists,

and suddenly you ore having your
mother take Lauren to eat lunch with
you while you are at work. From my
side it looks like a contrived method
of trying to limit Lauren's time with
me, at variance from what we have
been doing for three years ..
1 will allow Carol to pick Louren up
from school today so she con hove
lunch with you - even though it is a
violation of the parenting plllfl.
I want to protect Lauren from

conflict.
Also, the parenting plan also requires
each parent to get Lauren to her
games and practices. She has 11
practice this eyening nt 5 :30 nt Kasch
Park. If there is n need for
transportation to get Lauren to
practice, before it commences, I am
happy to pick her up from wherever
she is and get there.
Andrew
Sent from my iPhone
..
EXHIBIT J

210 Summit Avenue Hast, Seattle, WA 98102 Itel• (206)326-7362 Ifax• (206)323-0404
Meeting Atlendanco bttps://ps.archscapsc.org'admlnlattendance/vlow/meetlng.hlml?&n=OO...
PowerSchool.
-·------.Attendance
Rife, Lauren 3 816923035 SMM
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I of2 S/2312014 2:31 PM

EXHIBITK

I
Amy Pasco
Subject: FW: Lauren Eating lunch with her mother?
From: Elise Buie <elisebuie@gnmil.com>

Date: May 14, 2014 at 5:42:25 AM PDT
... To: "jennifennehnddi@comcast.net" <jennifermehaddi@comcast.net>, Andrew
Rife <asrifeOOl@icloud.com>
Cc: Carl Gaul <earlgnul@hotmail.com>, Amy Pasco
<amv@vfreitnslaw.com>, Veronica Freitas <v@vfreitnslaw.com>
Subject: Lauren Eating Lunch with her mothe1·?
I am so shocked and appalled at the time and negative energy that exists in this
matter.
Can someone explain to me (as I nm cc11ain that I am missing some important

element of this argument) why it is a source ofeonflict for Lauren to eat lunch
with her mother one day per week? or even multiple days per week? Or on no
schedule at nil?
Lauren's heart, soul and body must be so damaged by the tug-of-war that she lives
in the middle of daily - really hourly.
This has to stop.
Js·there not some way to find resolution on this very minute issue to end the battle
once and for all???
Elise F. Buie
Family Law Attorney I Guardian ad Litem
Main Street Law Group
lelephono 208.971.4800
dln!ci 208.380.1623
fax 206.971.4648
oltseb®ma!nslref!Uawgrgup COOl
1001 Fcunh Avenue
44lhfloor
seaure. WashlnjJlon 981154
YNIW ma!nstmeUawgroup com
CONFIDENTIAL COMMUNICATION· Thls communkallon corulltutes an elettfonlc communlcaUon wlthln the meaning of the
Eletltonk: Comtnunlcallon' Prlwcy Acl, 18 U.S.C. Se<lion 2510, and Its dlsclowre l111r1ct1y llmlled to the reclplel\l lnlcnded by
thir sender. n m8Y' conuiln Information lhal ts proprfclory, prlvlleged, and/or conOdcntlaL If you art not the Intended redplent,
EXHIBITL

210 Summit Avenue East, Seattle, WA 98102 Itel• (206)328-7362 Ifax• (206)323-0404
-
~ (
Fwd: Lauren
Sent from my !Phone
No, It's the 2nd time. I want her to see Seth Ellner has he specializes In seeing children. It needs to be
somewhere outside of Everett. If you don't agree I'm going to ask Elise to make a couple of
recommendations.
Sent from my !Phone
On May g, 2014, at 1:48 PM, Andrew Rife <asrl!eOOl@lcloud.com> wrote:
It's only the first time you've asked about counseling for Lauren.
Sent from my !Phone
From: Jennifer Mehaddl <!!lem.!ln!!Ie!l!rw.M~!lhai!!d!!;d!!lil!!.l!!!!lE!.1!11!£.!'211~

Date: April 22, 2014, 11:43:36 AM PDT
To: Andrew Rife <asrlfc001@lcloud.com>
Cc: Amy Pasco <amy@vtreltaslaw,com>, Carol Holland
<holland@premlerl.net> ·
ct: Lauren
Do not get confrontational with my mom. She is helping with

transportation and therefore deserves to not be talked to like that.
Secondly, It was Lauren who did not want to rush and get ready for you
at 10am. Yesterday was my residential day and you offered to bring her
back at 12:30pm. Did I throw a fit and say no, she needed to be home
by lQam? You were working and she was with your Mother. Lauren has
been very traumatized and upset with this litigation and your constant
harassment and obsessive need for the back and forth. Now you are
taking tomorrow off work at the last minute on my residential day with
Lauren so you can Insert yourself. That Is One. I'm not going to play this
game and upset Lauren. But let me tell you - and read the report again
from Elise. Lauren does NOT like the constant back and forth. She
recognizes what you are doing. You need to start putting her wants and
I
•
needs above your own. This Is not a game or a tug of war. Lauren Is 9
years old and I find your behavior and trickiness and being sneaky with
the schedule just plain sad and hurtful to her.
~---.·-·-~
~ Also, I will be talking with my attorney soon regarding Lauren seeing a')
~ private counselor on her own. f
2
• •
EXHIBITM

I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328·7362 Ifax• (206)323-0404
•
Sent from my iPhone

From: ife <asrifeOOl@icloud.com>
Dat : Moy 8, 201 at I :42:31 PM PDT
To: e di <jennifermehaddi@comcasl.net>
Subject: Re: Lauren
I ogree with counseling for Lauren. I got n couple of names of counselors here locally. I can
forward those names to you later. I have their information et home.
Sent from my iPhone
This is now the 2nd time I nm emailing about Lauren getting In lo see a counselor on her own.
I'm concerned about her and how this conflict against me end the litigation is afTecting her. She
needs to have e neutrnl person she can talk to privately without worrying about any
consequences. It's imperative she start counseling right away. I've asked Lauren if she would like
lo do this on her own, end she agreed and seemed happy/relieved by this idea. I have someone in
mind - or we can ask the GAL if she has any reputable counselors she knows of. Let me know
right away please.
Sent from my iPhone

• •
EXHIBITN

I I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 fax• (206)323-0404
. .
Amy Pasco
To: Amy Pasco
Subject: Fwd: Lauren counseling

He NEVER responded to this email. He says I just changed the appointment and it was all so abmpt. Uh, Elise
gave us a deadline. l!'s in an email that was sent to all of us.

.
;...... .
From: "jennifermehaddi@comcast.net" <lennifermehaddi@comcast.net>

Subject: Lauren counseling
Date: May 15, 201411:27:52 AM PDT
Andy,
I still hove not heard bock from you regarding counseling for Lamcn. I initially set up the
appointment for her al the Everett clinic just so we could get an appointment with someone. l
never heard if this was an acceptable date or time. However, since that time l have continued to
research children's therapists and have made many inquiries and phone calls. I have henrd really
great things about Karen Kirsch. She has a good reputation and works with children. She has
offices in Marysville and Seattle. I have gone ahead and mode an appointment for Lauren lo see
her on May 29th in Marysville at 1Oam and will go ahead and cancel the appointment at the
Everel1 Clinic. The Everett clinic is medical bnsed and is really only short term. I think that
Karen Kirsch could be a better fit becnuse she has lots of experience with children of divorced
families nnd can continue to see Lauren for ns long as she needs to be seen. I am going to move
forward with this plan unless I hear otherwise from you.
Jennifer
. .,
EXHIBIT 0

I I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328· 7362 fax• (206)323-0404
. .
EXHIBIT P

I
·-·
___ . Amy Pasco
From: Kelli Gomez

Sent: Friday, May 23, 2014 12:02 PM
To: Amy Pasco
Subject: FW: Scheduling Issues

From: Veronica Freitas

Sent: Friday, May 09, 2014 10:07 PM
• .. · To: ellseB
Cc: Veronica Freitas; Carl Gaul; Kelli Gomez; Amy Pasco
Sub)ect: Re: Scheduling Issues
I am happy with June, but I am in bock to back trinls and I do not have time to bring a motion to continue on
sho1tened time if I do not have to. I have other hearings in King County on the 20th and 21st. I can appear on
the 19th and argue to continue for your availability and mine and seek attorney's fees and sanctions for Mr.
Gaul's unreasonable position refusing to schedule the hearing on a date we ca11 oil be available. Had he checked
in advance offilin the show cause order, we could hove secured a date and I would have acce ted'service n
!> .
Since I can be there on the 19th as I can reschedule my medical appointment, I need to keep that date. I cannot
agree to a elate I am not available.
Sent from my iPhone
On May 9, 2014, at 8:09 PM, "cliseB" <eliscb@mainstreetlnwgroup.com> wrote:
I do not mean to be difficult but I filed a Notice of Unavailability and am in Boston on 19th
I am not understanding how my properly filed NOU can just be ignored on a contempt hearing
involving an issue like this in this mattc1·.
It seems to me that we must work out an agreeable date even if in June?
Elise F. Buie
Family Law Attorney I Guardian ad Litcm

telephone 206.971.4800
direct dial 206.389.1623
fax 206.971.4848
I
...
FILED
2 201~/>IAY 27 PH /: 54
3
E8liJt ,t\RJ\ Stil
S!/O' J0,'11S~ gB_E~~ H
11111~~~11~~m111m1m~
CL16740560
v
1
Supe1·ior Com·t of Washington
8
County of Snohomish
9
In re:
10
II Petitioner,
and DECLARATION OF AMY PASCO
12
13 JENNIFER MEHADDI (!kn Jennifer Rife),

Respondent.
14
15 My name is Amy Pasco and I am over eighteen yeurs of age and um competent to testify i
16
this matter. I am one of Veronica Freitas' pamlegal.
17
On April 24, 2014, while I was at work 111 V. Frcitos Law, PLLC, Kelli Gomez, Ms. Freitas
18
19 other paralegal, infonned me that I had 11 phone call, but that she couldn't understand who wru
20 calling even though she had asked the caller more than one time who it was.
21
When I answered the phone, I too, hncl to ask more thnn one time who wns calling as I coul
22
not understand the person. After a few seconds, I realized that it was Jennifer Mehaddi. She w
23
crying very ha1xl and her breathing sounded like she was abnost hyperventilating. Afler a fe\\
24
25 minutes, I wns able to understand tlmt she wns nt mediation with Andy and was explaining whnt he
26 been going on. As we were talking, I kept hearing a loud otllbtu'St from someone in the background
27
I asked her who that wns and she said thnt is was Andy Rife, pacing back and f011h. At one point
28
VtmONICA FREITAS
DECLARATION
Pogo I or2 ORIGINAL 210 Summit Avenue Eosl
S•nllle, Washington 98102
(206)328-7362
v@vrrcltnslnw.com
-.
heard him say something about a personality disorder followed by muttering. A moment Inter
2
heard him say "f.. king" something and then more muttering. All of this while Jennifer was c1yin
J
and trying to haven conversation with her attorney's office.
4
s I declare under penalty of pc1jmy pursuw1t to the laws of the State of Washington that th
6 foregoing is h·ue wid coJTect to the best of my knowledge.

7 DATED this 't:\ Doy of~_, 2014 at <; -C-~ Washington.
A~
8
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IS
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2S
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27
28
VERONICA FREITAS
rage 2 of2 Senllle, Wnshlnglon 98102
(206) 328-7362
v@vfrellnslaw.com
1
fF~LIED
2 2GI~ JUN -2 AM IQ: 52
3
SONYA KRASKI
COUNTY CLERK
lllm~~l~lll~lil/11~~1
5
6
CL16773267
7
8 WASHINGTON
ANDREW SCOTT RIFE Cause#: 05-3-02755-1
9

vs. ORDER TO SHOW CAUSE RE CONTEMPT;
JENNIFER RAE RIFE MOTION/DECLARATION FOR AN ORDER TO SHOW
11
DefendanURespondent CAUSE RE CONTEMPT
12
Hearing Date:
13
14
15 Declaration:
The undersigned hereby declares: That s(he) is now and at all times herein mentioned, a citizen of rhe Unired
17 therein.
On the dare and time of May 22 2014 4:1 lPM at the address of 14200 691H DR SE UNIT A-5
18
SNOHOMISH, within the County of SNOHOMISH, State of WASHINGTON, the declarant duly served
the above described documents upon JENNIFER MEHADDI by then and there personally delivering 1
19 true and correct copy(ies) thereof, by then presenting to and leaving tbe same with JENNIFER MEHi\DDI
Who accepted service, with identity confirmed by verbal communication, a white female approx. 35-45 years
20 of age, 5'-5'4" tall, weighing 160-1 BO lbs with blonde hair..
21
No information was prm-ided that indicates that the subjects served are members of the U.S. military.
22 and correct.
Dated: May 23, 2014 at Everett, WA
23
24
25 by~~ K. Devoe
Service Fee Total: $ 214.50
26
27
28
ABC Legal Services, Inc. 053027551

206 521-9000 ORIGINAL Gaul, Carl
lffio~mrn~rn~~OSJ
PROOF OF SERVICE 1604 Hewitt Ave, #302
Everett, WA 98201
Pngc I of I
425 259-4147
FILED
1 l'O!~Ht.Y 29 PH 2: 02
2 SO~IYA KRASXI
c , ~O_UllTY
1~~m1~m1111m111~~11~m1
CLERK
3 -SOHud!S~ CO. WASH
4 CL16743491
5
6 OUNTY OF SNOHOMISH
7 In re:
Andrew Scott Rife
and
9 Jennifer Rae Mehaddl f/k/a Rife REPL y DECLARATION OF
Respondent. ANDREW RIFE
hat the following is true and correct.
11
12
I am the petitioner in this matter. I make this declaration to reply to my former wife's
13
declaration concerning her contempt. This case is about whether Jennifer Mehaddi has
14
illfully failed to comply with the court ordered parenting plan.
15
2. THE REAL ISSUES
16
A. EXTRACURRICULAR ACTIVITIES: The temporary parenting plan requires
17
each parent to get Lauren to her games and practices. Jennifer's claim of sole decision
18
making authority on the subject of extracurricular activities is innovative and inconsistent
19
ith the parenting plan. The only games and practices Lauren had at the time the order
20
as signed were her soccer games. Jennifer's "understanding" would erase the provision.
21
Jennifer Mehaddi knew the soccer season. was not over. Please refer to the
22
attachments to my previous declaration. March 10, 2014 the coach sent an email directly
23
o her about games on March 16 locally and March 23 in Olympia. That email also
24
discussed the practice schedule through the remainder of March and April (#8). She sent
25
me an email about it the same day (#9). In that email she also raised concerns about
26
CARLJ.GAUL
27 Attorney at Law
302 Bank of Amenca Bldg. !))\\JLnhV
Page 1
Everett WA 98201
425 259-4147 FAX 259 7081
1 Lauren being tired, her academics suffering and health concerns. I had not noticed such
2 problems, so I wrote her teacher(#12) and both of her coaches (#13 & #14). All three
3 responded that she is full of energy and doing fine. The doctor's chart notes report that
4 here is no medical reason to limit Lauren's soccer. (See Sealed Health Care Records)
5 Lauren's Washington Rush registration is technically through August 2014. There
6 are breaks in the schedule, giving time for rest and other activities. The athletes try out
7 and are assigned to teams that compete outdoors in the fall. In the winter there is indoor
e soccer (though Lauren did not participate indoor during Jennifer's time this year and chose
9 o participate some of the time during my time). In the spring there is more outdoor soccer.
10 hen there is the state cup. There are practices and try outs again after that. Jennifer
11 knew all this as she was included on the emails I received. She had plenty of emails of her
12 own. Attachment 1. The March 13 email from coach Rich (#15) tells her that "After the
13 league season is over, (Fall and Spring) teams start to prepare for the State Cup, which
14 runs from Mar to mid April ... " Part of the program is to divide into new team assignments
15 at this time of year.
16 With the spring tryouts Lauren is assigned to a different team. She must play with
17 he Under 10 players and some of her teammates are moving up one age category. If we
18 ultimately jointly decide, or the court decides, that Lauren should not participate in
19 ashington Rush, sh& can be withdrawn. But if she misses the beginning of a season she
20 cannot be added. Lauren's participation in spring tryouts is part of her current registration
21 and it preserves her options going forward.
22 B. MEDIATION: Jennifer Mehaddi refused to mediate. On March 11 I sent
23 Jennifer Mehaddi an email that I had initiated mediation. Jennifer's story of the
24 occurrences at mediation is fantastic and false. I went to mediation looking for solutions,
25 or middle ground on which we could find agreement. Jennifer was so angry she would
26
CARL]. GAUL
27
Attomey at Law
302 Bank of Amenca Bldg.
1604 Hewitt Ave.
Page 2 425 259-4147 FAX 259 7081
1 barely talk from the beginning. I have known her for over 10 years, and I could see that
2 if I spoke directly to her we would not have a productive mediation. So I directed my

3 discussion to the mediators. For the most part, she did also. Jennifer did mention
4 olleyball. She has been adamant that Lauren should not play soccer at all in her emails.
5 She would not consider it at mediation. When she requested a break I was asked to leave
6 he room where the mediators were to avoid communication during the break, which was
7 reasonable. While out I did not have any communication with Jennifer Mehaddi. She was
8 having a phone call with someone. I kept sufficient distance that I did not know who she
9 as talking to nor what she might be saying. I was not paying attention to her, but I did not
10 notice anything about her indicating she was having difficulty communicating or in a hyper-
11 emotional state. Amy Pasco tells a complete fiction. She even claims she could hear me
12 "pacing." One should keep in mind that she is paid to be a partisan as she is part of Ms.
13 Freitas' office. Jennifer Mehaddi's emotional state was not a product of any bad conduct
14 at the mediation. She was upset before she got there.
15 At mediation Jennifer did not say that most of the practices fall on her residential
16 days. If this subject had been raised I would have asked about rearranging the residential
17 schedule, essentially swapping days with her and days with me to reach a solution. In her
18 declaration, her solution is to deny Lauren the activity she loves.
19 c. RESIDENTIAL TIME: Jennifer refuses to comply with the parenting plan.
20 It is part of her attempt to limit Lauren's involvement with me as she attempts to substitute
21 he step father for the father. She says she "did not let" Lauren spend November 11 with
22 me because Lauren was sick. I knew that sickness was not the reason. After Lauren
23 started spending time with me about 2009, if Lauren felt a little under the weather this was
24 not a reason she should not spend the time with me. She could spend the day resting or
25 do quiet activities with me, just as she has done other times. Swedish records show that
26
CARLJ.GAUL
Attorney at law
1604 Hewitt Ave.
Page 3 425 259-4147 FAX 259 7081
1 Jennifer Mehaddi worked on November 11 from 7:25 a.m. to 5:23 p.m. Attachment 2.
2 She knew I had the day off because I get all legal holidays off. Lauren should have been
3 ith me. The next day I had recess duty. Lauren was at school, and showing no effects
4 of any illness. She was as full of beans as ever.
s Jennifer knows that I can and do exercise time with Lauren. I always have. When
6 ime is scheduled I am able to rearrange my work hours to accommodate it. She misstates
7 hen she claims that I "backed off on the four hour rule." Until a year ago it did not need
8 o be mentioned because Lauren was with me much more than the parenting plan
9 specifies by agreement. I only needed to refer to it when she began her systematic
10 reduction of Lauren's time with me. Now she says the court order is "ridiculous."
11 Lauren loves hertime with me, our activities and our routines. After school she gets
12 some play time, then does her homework. Then there is physical activity or playing with
13 riends or cousin, followed by dinner and delivery to Jennifer's or 8:00 p.m. bedtime. She
14 is a very happy kid during our time. There is no anxiety and she is not shuffled about.
15 Jennifer focuses on Wednesdays. There have been two (2) occasions when she
16 had Lauren with her during this time. She tries to tell the court that Lauren enjoys leaving
17 school, driving to North Seattle for a half hour with her'. followed by a drive back through
18 Seattle's rush hour to spend some time with her grandmother and then be shuttled to pick
19 up Soufyane in Bothell and delivered to her mother's condo to get to bed late. And
20 ennifer says Lauren dislikes being shuttled around! Jennifer points out that Ms. Buie sent
21 an email about the Wednesday time. I responded to Ms. Buie. Attachment 3.
22 D JOINT DECISION MAKING: Jennifer Mehaddi refuses to make joint
23 decisions. She will not make a joint decision about soccer, about medical care, or about
24 ,____ _ _ _ _ _ _ __
1
25 Jennifer daims a one hour lunch, but the documents from her employer show a half hour
lunch. Whether she is being driven back at 3:30 or at 4:00 p.m. makes little difference as the traffic will
be crawling.
26
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
Page4 425 259-4147 FAX 259 7081
1 counseling. She will not participate in mediation. And she claims I am angry and abusive
2 because I want to make joint decisions and I want to use the dispute resolution process
3 specified by our parenting plan.
4 On May 12 we had both settled on Jeanne Paik as counselor. Butthen on May 15
s ennifer emailed that she would move forward with Kerry Kirsch If she did not hear back
6 from me. She sent the email on May 15, 2014 at 11 :27:52 a.m. By 1:51 p.m. Jennifer had
7 the Intake forms from Ms. Kirsch and had scheduled an appointment without giving me an
B opportunity to agree or disagree. Not responding in 94 minutes on a work day is hardly
· 9 evidence that I had not objected and it Is not evidence that I had agreed by acquiescence.
10 But Jennifer has now heard otherwise from me and she has not made any effort to
11 schedule an appointment with a jointly selected counselor. Because she did not respond
12 my lawyer has had to notify Ms. Kirsch of my objection. Attachment 4.
13 3. THE RED HERRINGS

14 All I am asking is that she comply with. the parenting plan. Jennifer's claim of fear
15 is false and has nothing_ to do _with her ability to comply with the parenting p_lan. T~ere Is
16 nothing scary about insisting that we follow the parenting plan. I did not misbehave toward
17 Soufyane, not at the doctor's office nor anywhere else. Nor would I.
18 I have asked the court to require Jennifer Mehaddi to let me know her work
19 schedule because she has not been forthcoming in the past. Her claim of "control and
20 abuse" is ludicrous. She knows I do not care about when she works, but I do care about
21 when Lauren is scheduled to be with me. Parental availability is part of that determination.
22 4. SUMMARY
23 Jennifer Mehaddl does not respect the court's order. She is in contempt of court.
24
25
on May 28, 2014 av
A~~-~
.A :....-:::... s===
26
CARLJ.GAUL
Attorney at Law
27 302 Bank of Amertca Bldg.
1604 Hewitt Ave.
Pages 42525~147 FAX2597081
1

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Jennifer Mehaddl's Emails
Jennifer Rae Mehaddl f/k/a Rife With Washington Rush & coaches
11 Respondent.
12 Please see attached
13
14
15
16
17
18
19
20
21
22
23
24
25 ATTACHMENT 1
26
CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
Jlrom: "iennifermeh!ddi@comc~.net" <iennifenneh•ddi@lComcast.net>
Date: October 24, 20i3, 7:25:3<) PM PDT
To: Andre\v Rifll <:isrifeOOl@ic!omlcom>
Cc: Washingtonrush <tioh@wa•hingtcinrush.com>
"Subject: Re: Lauren
U!uren deserves it !ind rm.sure she will be vary happy to beat this! She is a great player
and loves her team. Rich, can yol! please make sure that you include me in all
correspon.dence when c!i'scus~ing Lauren with Andy. Thank. you.
From: rich@washingtonrush.com
Date: October 24, 2013, 2:5 l:OS pM PDT
:to: Lau~n Rife <AsrifeOOl@ic!OUL[coin>
~bjec;_t: Launn · ·
Hello, Lauren ls.a candldate'for rnovlng up to tlie Nero team

If that"team moves to 9v9 for the Spring season. Her skills
and hustle. !Ire there, we just need to work on t\er
toughness to. compete at this age. My Idea Is to keep Lauren
at !..1-10 pel(t .season, as she shouJd excel by being at her

appropnate age. Ev~ If she does !!Ot move up .thlS season
getting the experience 'at this· level, wlll aide her In belng a'
top piaver next season at u-10.
Thank you, Rid!

From:• tennifeiinelmdiU@aiinCaSt.Jtet.<jeDnifeiinehadai@comcastnel>
Date: Siln, Mar 9, l014at 8.:44 P.M
·$Ubje1;t; Rt!: T.faini.ng/Game·Thi!i Wee~
To: Jqsien Garalde :<j!JStengaralde@gmail.com>
Jlist w~n&ring if there is going tQ 't;e an emrul&oOh i:llgard,lngpi'l\Ct.ice 4ays anci whill evm~ are·comin'g up, l
!hQugh(tJiis JlllSl Saton!;ly W\IS thel~gl!flle l:ll!t Ait4Y iol~-R!-~'li!~ w.as- ~:,famboree."'So a little co,!lfu§ed ~
whauhe·near future is. Please-let·me·know, thank you.·
Jenhifer Mebaddi (Lauml•s:mom)

On Mar 1, 2()~4, at ll :05 A.M,)()St~ Qaralde :<fosten~c!e@gmail.com> WT!)~:
Hi Ulam, wsi ·~he~ lip 1>11-)'.our cODUnl!te for ~Satl!lday; fue -Sounders have their home· opener at
~ so plan on ·iralfu: through Senttl~ on your way fo our gnine,
$ent :fi'Qm ip:y iPhol;le

On Mlll'3, 2014,,at 8:42 AM. Josten:Garalde"<jostmg8J181de@gmail.com> wrote:
Hi Rush,
Great battle last Saturl'.fav. •. Jhe girls 11.re irl)pr9vjng eii.ch weel(and corri,l,ng
together as a team; We will focus on pressure and cover thl$ we~ for defense
11nd recove.ry ~uns. flomework.is 2o0.juggles .tflls week.with bounr;es.
·From: Jemiifer:Mclualdl·<Oennifer.Mehaddi@oo!v"ellni'c,ci:Jill>
Date:Frl.M.r 14, 2ili4at.8!2S-AM
:Subject: .JU;: Aush
To; :"ricJi@wa.,biiurtonrusb.com'' .:ricl!@wasbingtoprush.com!r
Cc: "jostengaralde@gmaiLcom~ <jqg-u:upaldc@gmail.com>
'
Th;m.k·you for tile li:tformatio.n Rieti.)ls JbS_leo rE"CeotlyJl~td. Lauren is-reallylearn,fng and enjpys playing •occef With;~
•'l/ery proud of ilerl Without.cau!inrr•nv pr.oblem• or"SOins ln·to private Issue~, rilJst wanted to let youcknow.·il!l you: ·
P.rolil!lil~ tilready ~w..,A:nQ.V-.~nd .1 are HaVlrlil. S!m\i! dlffe~em:~ of ~inion on how much s~ef ~uri:n pli!~'dyt[l11Hne·
ve.11r. I wouldlf~ ..~rto ~IOJl!".dlif~N 5pom'°r a~tJ.vlt1~iora.'.5eason or~-. It Is nota~il'.!~ttl:nlRusti tearrror
.coaches.at all. U.uren is very:comfurtablio! llnd enjoys botb:>(OU ancf.Jcrsten.,,•·coache>. - - . - .. -
.However, this Sunday we'ha'lt! family plans and U.uren;will not be:able to make the state.cup in Olympia.She Will be at
V\i!game Iii Snotiorrllsh ort.Siturday'iirid a! the ~l;lti:" Cijp~ {otl~inil weekenl't.
TharikS agall'I,
Jennifer Meha&U
From: rld!@WaslJjnqtonMh.com [madto:di:h@washfl!dtpnrusiJ.mml

~11.)ll~y, lwfarch~,20.113:QQ P~
T~: Jenn.lfer Meha!ldl
Sllbjed: R~h
HI Jennifer~ tl}e.Selel::t .$eii1Son star!S. eveiy -year li1 Mil)' Wittl try-<>uts. tor 2014-lul:i season'
after t('f~_Pil.ts
player5 ar"'e placed .on a:team" seasOit. runs from Ma.Y to A.PHI, ·with time off during ·pe11ods of the ysc1
After 'league season Is over, {:'all and Spring) teams start to prepare·tor State CUp, whleh runs from Mar
·t0 _qi)d April, depe!!!llng 1)n :how v<>Q. 4r;>,· deP.e!Uls on .how }png you .P~· Azu~s Is the next two S!!!!~~s
with' twolgame,seachday. After~ate Olp, therewUl.be. tlrne off,- then teams:_stl)I get to(Jether for practice
leadln!!. up to·uy-outs,. to keep the plav.ers attlve:and ·gettJng·touches on the trail. ·
xf'you have anv further questions, dont hesitate to ·ask:
niank you, Ricl'I

··-------Forwarded message-~.
Erom: Jelildfer:Mehaddl <rennifer.Meliaddl@Dolyclinlii.com>
Oate:.We<I, 'Mar 26, 2014 at .11:43 AM
Subject; practice
To; "iosteneara!c!e@gmaj!..c;om• <jmihmgmlde@gmajl.com>.
rm.:at. work so don't have'n'iy awn povate emillI up, but just wanted 19 confirm ih111 thlll'll is pmc:tice todayand'
n.9 CIUJceDation. · · · ·
Tbl!J)k you!
Jennifer Meliaihfi (Lauren's moin)
Front: !erulifennc!h9ddftW9l!!1"ast m:t <fenn!fermehailai@com·AAnep

D!ite: Thu, Mar 27, 2014at10:55 AM
Subject: Re: Spring Break
To: Josten ~de <j9'l1em!ar:ild!G@grmil.com>
Cc: "riCh@washingtonruSb.com" <rich@washinlitonrush.com>
Cquld you eiqa.il me or ml!il ~ ac'(:opy·ofthe l;llCenl re~ion form AnlJreW, Rife lilied ou't for Lau~ll for~
upcoming next soccer season. If you have to mail i1; my address is .14200 69th Drive SE Unit :A-5 Snohmnisb
-98296. Email would be. great tt.ough at jennifennehotldi@comcast.net
I'm sorry • l am·.only sen,ding 1his to you J1S l do'not know of anot)ier'pllfSOn to send it to i!rere tQ get,iiis
infom1ati.<m• However, ii is very imp<>t:tant and .I will need this right away.~ yo.u very much..
Jennifer Mehaddi
On f4ar'il~, 20i4, at~:l4PM, Jl>sten Garlllde-<j0S1engaralde@gmai!:com> wrote:
Hi AZill,
C)ongr$ Jo the girb (or cndigg1hc season.an~.toumcywith:~ome great,~!!! Altd big thanks
lo Coach Brittney for'heading UP. the team in Olympia! It's ~en awesome wcnking wi~ the· girls
and seeing-them irrJrrove each practice and competing in games. Win or loss, we all are learning
and growing logelhet and that's most iinportanl
We. wi)l be ta!ciDg ~break tbii April. l!lld.regrouping.at jh~ Cl!!l of the month in prep~9n for,
-- • •• ...u .. aNll. T4o-.... ;:il &...n ,,. _.,.,...A:.--:_,.. -l:- _ .... -..1 _..____...,..
Ftom:• lenitlfennel!addi@wmeast.net.<;'ennifennehaddi@cmncast.nep
Date:. Thu, AP,t 3, 2014,at l0:3Q AM
11>.ubjcg: R~: Traii:riu:g this Week
To: ,tosten Oaralde <jm!wJgarnlde@gmail.com?
HiJOsten.
'When: doet1 ~ start back up again? I kn<>W. t)le kids ·are off until tile 2(lth but t!Qes practice stliJt up ~.
bll~~ ~ cnrtJ!? W~d ~.nhe trYL!!g oµt f9!'.' Ulo ~ 9r!Jll '?
front: !eDnif'ei'mmad!IJ@lc;O!iic;aSt.Jtet.<iennifennehaddi@cimlcastnel?
Date: Sun, ~[oe'30, 2014 at 7:00 PM
$ubjel't: ~e: T~g this W~k
To: )_ostm ~de "'iostongara!de@gmail.com>
'Cc: ADdrewRife <asrifeOOl@iCJoud.com>
Htiomn.
\Ve biid'l!·b'l#IS~n:jssue. ttim. WB!f·~ R$01~ - ~o liappy 19.s;iY ~n will~ lillltpractjce tQqiQ¢oW;
Jennifer
On.Mar:'3Q, 2014, at'12:04 PM, jcnnifCirtieh«ddi@comoastnet wto~:
Hello, Laui'en will not be able to.ilttend onM0nday fQr1he· thlining"ilorattend the: 00:14 game.
Jerinillir""'Mi:hllildi
On Mlit30, :2014, (It 11:07 AM, JoSten.~dc <josttn!!lli'alde@ginaj!.coi:il>wrote:
Training
Monday - 3/31 .:s:30-7pm Kasch P,.at:k
Wednesday - 4/2 No Tralnln_g but attend:.

Boys Jackson High Varsity Vs Lake stevens 7:30-9prn
'
-.......
Fram: 1Vrry·Mikuls~·<rci-am@msn.com>
Seilt: IhuB"day, Ap"ril 1~ 2014 12:58 PM
T!>= 'l.enn'·
Subject: .RE:-Watching Soocer
HI Je"rinifer- Nothil'ls l)as ~anljeif sir\te v.,e l~tt.Pa~ll- Tl\fouts a~ et the end of /lpril ;ina reglstra!lciiflar nexH.~·
wpµid opl!'n us:raft!lr tl:ll!t 1'ha~lt5 • Arnv - ·
&om: Je"n [mailto:jennifermehaddl@>comc:ast.net]

sent: Thill'.Sdav, APnl 10, 2014 12:43 PM
To;,Amv M11<u);l\.V ·
:Suliject: fWd:•WatchihgSoccer
Qui. u expbifu1hitt19 mll7 I'm:~o)iridea liy<tbls ~mail How llllil taw:en:·b\\ reg"isu:i:ed? Please.lilt me km:iw.
~'hank_ yciu. .
Jennifer Mdiaddi (Lauren's mom).
From: Andrew. Ril'e <asrifeOOl@ic!oudcom:"?

Qii~ APril 10, 2014 'atJ2:.18:3l. PM PDT
To: "iemiif¢i'Jfui!iaddi@ebmCast:.ngt''-<:jennifetnielii!!ldJ@botncl!St:.net>
Cc_: Josfl;n ~ldi:i <insteygl!raldij@&n•llcoml>, WashillgtOntush <ilcb@washin'gton!p!!h.com>
!!nbji!¢, Re; \f.iitclltng•Soccer · · ·
Joll!Cl'.l,andRich,-
1am sOrfy that-yoµ-both. have been Involved-iii this fariiily.matter unilece8silrily. Lauren's mother
!ll1d I agt~d thri:e y_eani agO:"th!it.alii! woµ!d. p.arti.:ip;lte in sOllcer ind oiie yearag_o that ~he W<l.illil
for
play the W.asbington ~ush. We; dq nothJl_ve:an iigr~ent b!llwt;en"llS ~"1'Cl110Ye her;fr9Jll thjs
league and i;l!e·ri:m.~ regis.tered. · ·
Sent:ftom:my iPhOll!:
On Apr.<;!, 2QJ 4; J!t.ll:Q9-PM, "jennifenneliadjJj@comcast.net." <jennifennehaddijQ!comcaBt.neffe
wrote: -· - . . . --
Hi Josten,
i wairttd 10 let.yon'kn<>W that 'Lm!feri will not be at p,riu:tice next. week. A decision
TI:garding'llQQc~wJll be ntiida at: the end cit:tbcmarith. Mr: Jtife is 11\VIU'e' ofthi.S as
.1 h!l.v~.n~~ed to•furtp.c:r ~iceslgl!IJ10ll at·thi!f.poii\t.
Thanks,
,Jennifer Mehaddi.
From: Amy Miklilsky ~-nm@msn;com>
])ate~ Ma}r'.3 1 20l4, (2:5~55 PM l'OT
to: llllrifeOOl@i(;Joud.com
Saibj¢Ct: Registration
HI Andrew~ Here Is the clarificatiOn'.fl!gllrding:reglstiatlon.
Players are registered to .their teams for 12 months, 'SeJitemberl- August 31., The season ends at
tfyoiits When·te•ms ar:e reforlifed. but ~nk:ally th!!'f ~re sbll reglslere!I tci ~r te~m.s untii Aug\)~
3:(st a!!,d ·l!llll continue IX> u$1! their players-(;l~s tflrtiuslt tt:i.e:summet
let.me know ltytiu hltve:any questions. ihari~sf .• /~!!IV

1·
2.
.s
6 SUPERIOR'COURT OF WASHINGTON
COUNTY OF SNOHOMISH . . . .-
7
8 In re:
Afl.drew Scot~.Rlfe
9 Petitioner, NO. 05 3 02755 1.
and
10 .Swedish Employment Record
Jenrilfer Rae.Mehaddl f/k/a Rife November 11,.2013
u Respondent.
13 Exerpt from··discovery
14 Swedish Medicai Group Payroii Record
Jennifer Mehaddi worked November 11, 2013
15 7:25 a.m. thr9ugh s:23
16
17
iB
19
20
21
22
23
24 ATTACHMENT 2
25
26
CARL-J. GAUL
27
Attornerat Law
302 Bank of.America Bldg.
1604 Hewitt Ave.
Everett WA.98201
425 259-4147 FAX 259 7081
Fri 10/25/2013 7:29:00AM 7:29:00AM 12:2l:OOPM 12:21:00PM 26471932 4.87 4.87
Fri 10/25/2013 l:OB:OOPM 1:08:00PM 5:32:00PM 5:32:00PM 26471932 4.4 4.4 9.27 9.27
Mon 10/28/2013 7:37:00AM 7:37:00AM 11:13:00AM 11:13:00AM 26471932 3.6 3.6
Mon 10/28/2013 11:46:00AM 11:46:00AM 5:34:00PM 5:34:00PM 26471932 5.8 5.8 9.4 9.4
Tue W/29/2013 l:lO:OOPM l:lO:OOPM 5:37:00PM 5:37:00PM 26471932 4.45 4.45
Tue 10/29/2013 8:l9:00AM 8:19:00AM 12:40:00PM 12:40:00PM 26471932 4.35 4.35 8.8 8.8
Mon 11/4/2013 8:03:00AM 8:03:00AM 8:13:00AM 8:13:00AM 26471932 0.17 0.17 0.17 0.17
Thu 11/7/2013 1:08:00 PM 1:08:00PM 6:45:00PM 6:45:00PM 26471932 5.62 5.62
Thu 11/7/2013 7:49:00AM 7:49:00AM 12:08:00PM 12:08:00PM 26471932 4.32 4.32 9.93 9.93
Fri 11/8/2013 7:5l:OOAM 7:51:00AM 10:46:00AM 10:46:00AM 26471932 2.92 2.92
~I~Mon
Fri 11/8/2013
11/11/2013
11:16:00AM
7:25:00AM
11:16:00AM
7:25:00AM
5:15:00PM
12:43:00PM
5:15:00PM
12:43:00PM
26471932
26471932
5.98
5.3
5.98
5.3
8.9 8.9
Mon 11/11/2013 1:45:00PM 1:45:00 PM 5:23:00PM 5:23:00PM 26471932 3.63 3.63 8.93 8.93'~
Tue 11/12/2013 8:49:00AM 8:49:00AM 12:12:00PM 12:12:00PM 26471932 3.38 3.38
Tue 11/12/2013 l:18:00PM 1:18:00PM 7:39:00PM 7:39:00PM 26471932 6.35 6.35 9.73 9.73
Thu 11/14/2013 9:59:00AM 9:59:00AM 12:02 :Oil PM 12:02:00 PM 26471932 2.05 2.05
Thu 11/14/2013 12:23:00PM 12:23:00 PM 6:16:00 PM 6:16:00PM 26471932 5.88 5.88 7.93 7.93
Fri 11/15/2013 11:18:00AM 11:18:00AM 5:28:00PM 5:28:00PM 26471932 6.17 6.17
Fri 11/15/2013 7:10:00AM 7:10:00 AM 10:35:00AM 10:35:00AM 26471932 3.42 3.42 9.58 9.58
Sat 11/16/2013 8:18:00AM 8:18:00AM 3:33:00PM 3:33:00PM 26471932 7.25 7.25 7.25 7.25
Mon 11/18/2013 lO:lO:OOAM lO:lO:OOAM 5:45:00PM 5:45:00PM 26471932 7.58 7.58 7.58 7.58
Tue 11/19/2013 8:19:00AM 8:19:00AM 12:16:00PM 12:16:00PM . 26471932 3.95 3.95
Tue 11/19/2013 l:Ol:OOPM l:Ol:OOPM 6:04:00PM 6:04:00PM 26471932 5.05 5.05 9 9
Thu 11/21/2013 9:52:00AM 9:52:00AM 6:2l:OOPM 6:21:00PM 26471932 8.48 8.48 8.48 8.48
Fri 11/22/2013 8:08:00AM 8:08:00AM 12:01:00 PM 12:01:00 PM 26471932 3.88 3.88
Fri 11/22/2013 12:28:00 PM 12:28:00PM 4:21:00PM 4:21:00PM 26471932 3.88 3.88 7.77 7.77
Mon 11/25/2013 ll:lO:OOAM ll:lO:OOAM 5:33:00PM 5:33:00PM 26471932 6.38 6.38
Mon 11/25/2013 7:3l:OOAM 7:31:00AM 10:31:00AM 10:31:00AM 26471932 3 3 9.38 9.38
Tue 11/26/2013 8:19:00AM 8:19:00AM 12:22:00PM 12:22:00 PM 26471932 4.05 4.05
Tue 11/26/2013 1:23:00PM 1:23:00PM 8:25:00PM 8:25:00PM 26471932 7.03 7.03 11.08 11.08
Fri 11/29/2013 1:40:00 PM 1:40:00 PM 3:25:00PM 3:25:00PM 26471932 1.75 1.75
Fri 11/29/2013 8:00:00AM 8:00:00AM 1:06:00PM 1:06:00PM 26471932 5.1 5.1 6.85 6.85
Mon 12/2/2013 11:44:00AM 11:44:00AM 5:20:00PM 5:20:00PM 26471932 5.6 5.6
Mon 12/2/2013 7:42:00AM 7:42:00AM ll:OB:OOAM 11:08:00AM 26471932 3.43 3.43 9.03 9.03
1

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Email to E. Buie re counselor
Jennifer Rae Mehaddl f/k/a Rife
11 Respondent.

13 Email from Andrew Rife to Elise Buie
May 12, 2014
14
15
16
17
18
19
20
21
22
23
ATTACHMENT 3
24
25
26
CARLJ.GAUL
Attomey at U1w
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
Froni: Andrew Rife <asrifeOOI@icloud.com>
Date: May 23, 2014, 4:41:44 PM PDT
To: Elise Buie <elisebuie@gmail.com>
Subject: Re: Lauren
Elise
Your email asks for a comparison of Ms. Paik and Ms. Kirsch. The short answer is that
I did my research on counselors, and found Ms. Paik, and I wanted Lauren to have
counseling with her. Jennifer also did her research and found Ms. Paik and wanted
Lauren to have counseling with her. We had an agreement that Lauren would have
counseling with Ms. Paik.
Then Jennifer unilaterally decided on somebody else. That Is not joint decision
making. That is.not what our parenting plan calls for. Jennifer's recent actions are not
coparenling and not joint decision making. Three limes I have set up mediation. She
refused to participate. Twice she simply walked out. I am more than willing to work with
Jennifer in coparenting, but I am not willing to be summarily excluded.
The decision to use Ms. Paik was a joint decision made on May 12. Jennifer and I both
named the same person: we both agreed on the same counselor. I thought Jennifer's
meth.od of announcing her selection of Ms. Paik and making the appointment was
abrupt, but I decided not to complain about it because I had come to the same
selection. I do not confuse joint decision making with manners. I wish she had made a
joint decision with me before making the appointment, but at least we had an
agreement.
On May 12, 2014, at 12:58 PM, Jenn Mehaddi <jennifennehaddi@ccimcasl.net> wrote:

Since I have not heard from Andy from my last email.. I have scheduled Lauren to see Ms. Paik at
The Everett Clinic behavioral health in mill creek at 2pm on Thursday .the 29th ofthis month.
Afostplaces are extremely booked or not taking new patients. I've heard good things about Ms.
Paik especially in regards to children. 1 hope this will be a good fit for Lauren. I had the
scheduler make a note that' the therapist will need to talk to each Andy and 1 separately to get a
briefrun down on what is going on and what Lauren is going through and dealing with.
Thanks,
Jennifer
http://n\.evercttclinic.com/?url=httpo/o3A%2F%2Fwww.cvereltclinic:com%2FPhysicians%2Fjea
nne-paik.ashx%3 Fp%3J)5 L06%26srchloc%3D22#2670
Eight minutes later at May 12, 2014, 1:06PM I responded:

From: Andrew Rife <asrifeOOl@icloud.com>
Date: May 12, 2014, 1:06:14 PM PDT
To: Jenn Mehaddi <jennifermehaddi@comcast.net>
Subject: Re: Jeanne Paik, LH - Behavioral Health - Mill Creek, WA - The Everett
Clinic
I have a couple of counselors names at the Everett clinic. Jeanne Paik was one of them
and Stephanie garrlson was the other. I called the clinic this morning to see which one
was accepting new patients. Jeanne Palk Is and Stephanie Garrison is not. Both of
them came highly recommended.
Just three days later, on May 15 at 11:27 a.m. she sent me an email claiming she had
not heard from me,cancelling the appointment with the agreed Jeanne Paik, and instead
made an appointment with yet another counselor, excluding me from the process:
Andy,
I still have not heard back from you regarding counseling for Lauren.... I have heard really
great things about Karen Kirsch . ... I have gone ahead and made an appoinrment for Lauren to
see her on !day 29th in !Yfarysvil/e al J Oamand will go ahead and cancel the appointment atthe
Everett Clinic. ... I am going to move fonvard with this plan unless I hear otherwise from you.
Jennifer
She informed me about both actions after the fact in the same email. I was shocked. I
called Everett Clinic to verify the appointment on May 29 and was told it had been
cancelled. I made a new appointment with Ms. Paik for June 12, which holds Lauren's
place with the agreed counselor and gives Jennifer and me time to come to an
agreement on a counselor, if not Ms. Paik then someone else we agree upon.
Jennifer never gave me the chance to evaluate Ms. Kirsch, nor to agree or
disagree. Ms. Kirsch and Ms. Paik have similar educational backgrounds so I might
have agreed to use Ms. Kirsch if she were not "out of network".
Jennifer stated that Everett Clinic offers short term counseling only, though in my
research, I was able to learn Ms. Paik does long term counseling. She also said the
counseling at Everett Clinic is "medical based" which I do not understand since
counselors do not prescrlbe medication. I realize that this may be a simple
misunderstanding. These are topics to discuss when making a joint decision.
I really do want to parent jointly and cooperatively, and this should have been an easy
joint decision, and a success for both of us.
Quite apart from joint decision making, there is a difficulty with insurance coverage. Ms.
Palk is "in network" for my coverage. Ms. Kirsch is "out of network", which would
require greater out of pocket cost. Jennifer's second May 15 at 2:14:01 p.m.stated
I will fill out the paperwork and you can take care if the insurance portion. You will be
reimbursed out of network. If there is a portion I am responsible for than I expect a bill
showing what I owe per the current parenting plan.
The problem here is that in the past several years Jennifer has not paid any uninsured
medical or dental cost, so I have paid all of Lauren's medical and dental bills. It does
not make sense to go out of the Premera Blue Cross Network when there are many
excellent "in network" counselors available to choose from.
If Jennifer has changed her mind about the agreed counselor, I would really like to know
why. Perhaps I might agree and we could find another counselor.
Andrew Rife
1
2.

COUNTY 'c)F-SlllOttOMISH .
7
8 In [e: ..
Anarew:scot~ Rife
9 Petitioner, NO. 053 027551
and.
10 Email to counselor Ker.r:y Kirsch
Jennifer Rae Mehaddl f/k/a Rife.
11 Respondent.
i,_2 . Please see attached

13 Email from Cart J ...Gaul to Kerry Kirsch
May 28, 2014
14
15
16
17
18
19
20
2'1
22
23
. ATTACHMENT 4
24
25
26
6RLJ.GAUL
· Attorney at Law
27 302 Bank ofArrierlca,Bldg.
·· 1604 Hewitt Ave.
Everett .WA 99201
425·259-4147. FAX 259 7081
Oul!OQk.Corn Print Message https:/tr..yl 73.mail.live.com/oVmail.mvc/PrintMessages?mk!=en-us
Lauren Rife
From: Carl Gaul (carlgaul@hotmail.com)

Sent: Wed 5/281145:16 PM
To: kerry@ruahcounseling.com (kerry@ruahcounseling.com)
Cc: Andrew Rife (asrifeOOl@icloud.com); v@vfreitaslaw.com (v@vfreitaslaw.com);
eliseb@mainstreellawgrotip.com (eliseb@mainstreetlawgroup.com)
1 attachment
temp pplan rife.pdf(747.i. KB)
Ms. Kirsch
I am attorney for Andrew Rife. He is the father of 9 year old Lauren Rife. Jennifer Mehaddi is
Lauren's mother.
Part 4.2 of the October 24, 2013 parenting plan (attached) establishes joint decision making.
Mrs. Mehaddi and Mr. Rife had both settled upon a different counselor (through Everett Clinic) for
Lauren, then Mrs. Mehaddi abruptly changed to you without consultation or agreement from Mr.
Rife. There was an appointment at Everett Clinic. Then Mrs. Mehaddi sent an email announcing
that she wanted to consider you as counselor, ending with a statement that if there was no
response she would move ahead. 94 minutes later she had already scheduled an appointment
with you and had your intake materials. She unilaterally cancelled the other appointment.
Mr. Rife was not Included in the decision to select you as counselor for Lauren. He does not
consent to Lauren receiving c.ounseling from you. He objects to you providing service in this
matter. He provides the health insurance for Lauren. He will not cooperate in submission of any
insurance claim for your service. In the event that there is a billing, he will not pay it.
Mrs. Mehaddi is scheduled to appear before the court on June 3, 2014 to show cause why she
should not be held in contempt for a variety of reasons. One of them is her action in disregarding
the parenting plan in her selection of you as counselor for Lauren.
Please understand this is not about you. If the matter had been approached differently and if you
were within his health insurance network of providers, it is possible he might have agreed to your
participation with his daughter. It is about Mrs. Mehaddi's refusal to make a joint decision and her
continuing efforts to assume sole decision making authority in violation of the parenting plan.
Mrs. Mehaddi's attorney Veronica Freitas and the guardian ad litem Elise Buie are receiving
copies of this email.
CARL J. GAUL
I of2 512812014 7:14 PM

Outlook.'Com Print Message https:/lbay 173. meil. livc.oom/ol/meil.mvc/PrintM.:ssages?m kt=en-us
Attorney ar Law
1604 Hewitt Avenue
Tel. 425-259-4147
Fax 425-259-7081
carlgaul@hotmall.com
2of2 5/28/2014 7:14 PM

'FILED
·20 I~ JUN 13 PH I: I 0
SOHYA KRASKI
COUNTY CLERK
SNOHOMISH CO. WASH
1~1 1 1 1CL16781010
I 1Il 1 1 1~\ID\1 1 1 ~I~ ~Il ~Il m1111
Superior.Court of Washington -·
County of Snohomish
Order on Show Cause re

Petitioner, Contempt/Judgment
- and~~
. I
(ORCN)
--l .e....._: Next Hearing Date:
~~:A.Res ondent. Clerk's Action Re uired, 1J 3.10
I. Judgment Summary
0 Does not apply.

0 Applies as follows:
B. Judgment debtor
C. Principal judgment amount (back child support/medical support/other obligations/
maintenance) from (date) through (date) $ _ _ _ _ _ __
D. Interest to date of judgment $-------
E. Attorney fees $ _ _ _ _ _ __
F. Costs $ _ _ _ _ _ __
G. Other recovery amount $-------
H. Principal judgment shall bear interest at % per annum
I. Attorney fees, costs and other recovery amounts shall bear interest at % per annum
L. Other:
Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 1 of 7

WPF DRPSCU 05.0200 Mandatory (0712013) - RCW 26.09.160, 7.21.010
II. Findings and Conclusions
This Court Finds:
2.1 Comp~cew~p.._co~
(Name)J e..-..._.:.k.r ,.0'di;Icomply D intentionally failed to
comply with a lawful order of the court dated on IO/-z.f I I 3 .
2.2 Nature of Order
The order is related to D child support D medical support D child care, educaf al expenses,
transportation expenses, or other special expenses D spousal maintenance parenting plan
(custody/visitation) D a restraining order.
2.3 · How the Order was Violated

~ The order was not violated.
D TI1is order was violated in the following manner (include dates and times, and amounts, if
any):
2.4 Past Ability to Comply With Order
(Name)_.,---.,------------D had D did not have the ability to comply

with the order as follows:
2.5 Present Ability and Willingness to Comply With Order
(Name)-,-,.......,-----,-----,--,,--------D has D does not have the present ability to

comply with the order as follows:
(Name) _ _ _ _ _ _ _ _ _ _...,--_ _ _ D has D does not have the present

willingness to comply with the order as follows:

2.6 Back Child Support/Medical Support/Other Unpaid Obligations/Maintenance
D Back child support/medical support/ child care, educational expenses, transportation

expenses, or other special expenses/maintenance is not addressed in the contempt motion.
D No back child support, medical support, child care, educational expenses, transportation
expenses, or other special expenses, or maintenance is owed.
D (Name) failed to pay the other party the sum of
S for child support and interest to date in the amount of
$ for the period from through
-------
S for medical support and interest to date in the amount of
$ for the period from through_._ _ _ _ __
$ for child care, edueational expenses, transportation expenses, or other
special expenses and interest to date in the amount of$ for the period
from through _ _ _ _ _ __
$ for maintenance and interest to date in the amount of
$ for the period from through-------
D Other:
2.7 Compliance With Parenting Plan
Does not)IPPly. c. J (
(Name) '-l.f..M,.-.l • llA...fa"I,,
1J.J has complied, and is currently willing
to comp~with th~)larentin!J::AL,
(Name)'1.,.t..s........1 f-c-. M, has not complied with
ffie-'l'l:S:idential (visitation) provisions of the parenting plan and had tl1e ability to
comply e parenting plan, and is currently unwilling to comply. The
noncompliance · he residential provisions 0 was 0 was not in bad faith.
D decision making provis10 the parenting plan and had the ability to comply
with the parenting plan, and is curr nwilling to comply.
D dispute resolution provisions of the parenting pian-~d the ability to comply
with tl1e parenting plan, and is currently unwilling to comply_-..........._
D Other:
Ord on Show Cause re Cntmpl/Jdgmnt (ORCN) - Page 3 of 7

2.8 Attorney Fees and Costs
[],..--- Does not apply.

.r:J The attorney fees and costs awarded in paragraph 3.9 below have been incurred and are
reasonable.
Ill. Order and Judgment
It is Ordered:
3.1
3.2
Contem:: Rulinp-
(Namej\.}~h..v
Imprisonment
~l
D is rs not in contempt or court.
Does not apply.

(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ is to be confined in the (name of
county) County Jail.
D 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.
D Confinement is suspended as follows:
D Other:
3.3 Additional Residential Time
Does not apply.

( N a m e ) - - - - - - - - - - - - - - - shall have additional residential
time as follows:·
3.4 Judgment for Past Child Support
Does not apply.

No judgment for past child support was requested.
Ord on Show Cause re Cntmpt/Jdgmnt (ORCNJ - Page 4 of 7

WPF DRPSCU 05.0200 Mandatory (0712013)- RCW 26.09.160, 7.21.010
D (Name) shall have judgment against
(name) in the amount of$
-------
for unpaid child support arrearages and $ interest thereon for the period
from (date) through (date) _ _ _ _ _ _ _ __
3.5 Judgment for Past Medical Support
Po
D
Does not apply.
No judgment for past medical support was requested.
(Name) shall have judgment against
(name) in the amount o f $ - - - - - -
for unpaid medical support arrearages and $ interest thereon for the
period from (date) through (date) _ _ _ _ _ _ _ __
3.6 Judgment for Other Unpaid Obligations
Does not apply.

No judgment for past child care, educational expenses, transportation expenses, or other
special expenses was requested.
(Name) shall have judgment against
(name) in the amount o f $ - - - - - - -
for unpaid child care, educational expenses, transportation expenses, or other special
expenses arrearages and $ interest thereon for the period from
(date) through (date) _ _ _ _ _ _ _ __
3.7 Judgment for Past Maintenance
Does not apply.

No judgment for past maintenance was requested.
(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ shall have ju"dgment against
(name) in the amount of$ _ _ _ _ _ _ for
unpaid maintenance arrearages and $ interest thereon for the period
from (date) through (daie) - - - - - - -
3.8 Conditions for Purging the Contempt
Does not apply.

The contemnor may purge the contempt as follows:
D Does not apply.

WPF DRPSCU 05.0200 Mandatory (0712013) - RCW26.09. 160, 7.21.010
;zJ' (N~•) v't1':'::..,___5 4l2:t':l<
(name) ~, ~_ _
attorney fees and $ Sc e -,. , q fi
""" ··~ '"'""'"""""
in the amount of$
costs.
for
3.10 Review Date
£ D o e s not apply.
0 The court shall review this matter on (date) - - - - - - - - a t (time)------
3.11
3.12
If the person with whom the child resides a majority of the time p_lans to move, that person shall
give notice to every person entitled to court ordered time with the child.
If the move is outside the child's school district, the relocating person must give notice by
the intended move. lfthe relocating person could not have known about the move in time to give
notice must contain the infonnation required in RCW 26.09.440. See also fonn 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
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
withheld from the notice.
A relocating person may ask the court. to. waive any. notice requirements.that.may. put the health
and safety of a person or a child at risk.
If no objection is filed within 30 days after sen'ice of the notice of intended relocation, the
confirmed.
A person entitled to time with a child under a court order can file an objection to the child's

WPF DRPSCU 05.0200 Mandatory (0712013) - RCW 26.09. 160, 7.21.010
.,
(
(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.
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 residential provisions of this order with actual knowledge of its terms is
punishable by contempt of court-and may be a criminatoffenserunderReW 9A.40'.060(2)'or
:ITT~) v~it''i;;;;~~o.,,m-~ -~
Presented by:
r + JMll'!le/Commissioner
d . ffJJ./
Si~f Party or Lawyer/WSBA No. I ' 'fo,S- Signature of Party or
Co...r! .:J • b.c..d
Ord on Show Cause re Cntmpt!Jdgmnt (ORCN) - Page 7 of 7

WPF DRPSCU 05.0200 Mandatory (07/'2013) - RCW 26.09.160, 7.21.010
. -· ~. - . \ Fl ! ,_C(I,
~- .,
I -\~l~M~~\\l\~ll~\\\~~l\I\\~~\\\\ I SUPERIOR COURT OF

Ct16560448 __; WASHINGTON
CAUSE NO.: 05-3-02755-1

ANDREW SCOTT RIFE COMMISSIONER: SUSAN C. GAER
(PETITIONER) CLERK: PATRICIA BUNDY
AND DATE: 06-13-14 @ 9:00 A.M.
JENNIFER RAE RIFE DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: SHOW CAUSE RE CONTEMPT it248; SHOW CAUSE RE CONTEMPT #253
ACTION:
PETITIONER APPEARED: YES COUNSEL: CARL GAUL

RESPONDENT APPEARED: YES COUNSEL: VERONICA FREITAS
GUARDIAN AD LITEM APPEARED: YES
DOCUMENTS FILED:
ORDERS ENTERED: ORDER ON SHOW CAUSE RE CONTEMPT/JUDGMENT ENTERED, TO BE FILED BY

COUNSEL GAUL
THE COURT IS SHOCKED THAT THE FATHER WOULD FILE THESE CONTEMPT ACTIONS IN
LIGHT OF THE GUARDIAN AD LITEM'S REPORT. THAT REPORT CLEARLY STATES THAT
THE CONFLICT IN THIS LITIGATION IS DAMAGING THE CHILD. THE FATHER APPEARS
NOT TO CARE WHAT HIS BEHAVIORS ARE DOING TO THE CHILD. IT APPEARS THAT THE
FATHER IS INTENT ONLY UPON GETTING HIS WAY, NOT THE BEST INTERESTS OF THE
CHILD.
PERHAPS THE FATHER UNDERSTOOD WHAT ALL WAS REQUIRED WHEN SIGNING UP THE
CHILD FOR SOCCER, BUT IT IS CLEAR THAT THE MOTHER DID NOT AND THE COURT ALSO
FOUND THE INFORMATION CONFUSING. THE SCHEDULE IS EXTREMELY INTRUSIVE ON THE
PARENTING SCHEDULE. IF THE PARENTS AGREE THAT IS ONE THING; HOWEVER, THE
COURT TAKES ISSUE WITH THE SCHEDULE AS THE TIME WITH THE PARENTS IS MORE
IMPORTANT THAN SPORTS. THERE IS NOTHING INDICATING WHEN THE CHILD SIGNED UP
THAT THE MOTHER AGREED TO HAVING HER RESIDENTIAL TIME INTERFERED WITH BY
SOCCER. THE COURT DOES NOT FIND THAT THE MOTHER WILLFULLY VIOLATED THE
PROVISION OF THE ORDER.
THE PARTIES HAVE DIFFERING VIEWS OF WHY THE MEDIATION FAILED. THEY
CLEARLY WENT IN TO MEDIATION THINKING THAT TWO COMPLETELY DIFFERENT ISSUES
WERE TO BE MEDIATED. THE MOTHER DID NOT WANT THE CHILD PLAYING SOCCER. THE
1 MINUTE ENTRY
. . .
ANDREW SCOTT RIFE AND JENNIFER RAE RIFE

05-3-02755-1
FATHER THOUGHT THEY WERE GOING TO DEFEAT THE TRANSPORTATION PROBLEMS BECAUSE
THE CHILD WAS PLAYING SOCCER. THE PARTIES DID NOT EVEN AGREE WHAT WAS TO BE
ADDRESSED AT MEDIATION.
THE COURT FINDS THESE MOTIONS ATTEMPTS AT CONTROLLING THE MOTHER. THE
PURGE PROVISION OF GIVING THE FATHER HER SCHEDULE FOR THE ~HOLE YEAR IS
CLEARLY INVASIVE. THE COURT WILL NOT FIND CONTEMPT IN RELATION TO
MEDIATION. THE COURT FINDS THAT BOTH PARTIES HAVE SOME RESPONSIBILITY IN
THE MEDIATION FAILURE.
THE COURT CANNOT UNDERSTAND WHY THERE WAS NO RESPONSE TO THE PSYCHOLOGIST
ISSUE. JOINT DECISION MAKING DOES NOT MEAN THAT ONE PARENT CANNOT SCHEDULE
AN APPOINTMENT BEFORE TELLING THE OTHER PARENT WHO THE PROFESSIONAL IS AND
THEN WAITING FOR AN OBJECTION.
THE COURT WILL SUA SPONTE MODIFY THE RESIDENTIAL SCHEDULE ONLY AS RELATES
TO THE FIRST RIGHT OF REFUSAL. THE FATHER APPEARS SO RIGID THAT EVEN IF THE
MOTHER RUNS OVER THE FOUR HOUR LIMIT BY TEN MINUTES HE SHOULD BE GIVEN THE
RIGHT OF FIRST REFUSAL. THIS PROVISION SHALL BE CHANGED FROM FOUR HOURS TO
TWENTY-FOUR HOURS. TIME MISSED: LINE DRAWN, COMPLY EXACTLY OR I WILL FILE
A CONTEMPT. CHILD IS BROUGHT OUT FOR LUNCH TO BREAK UP THE DAY SO THAT THE
FOUR HOURS REQUIRED FOR RIGHT OF FIRST REFUSAL WOULD BE BROKEN UP.
THE FATHER'S CONTROLLING ISSUE IS OF GREAT CONCERN TO THIS COURT. IT
APPEARS HE IS PUSHING WAY TOO HARD AND THE MOTHER IS OVER REACTING. THERE
HAS BEEN DOMESTIC VIOLENCE IN THIS CASE. THE PARENTS WERE CO-PARENTING WELL
TOGETHER PRIOR TO THE TIME THE MOTHER GOT A NEW SIGNIFICANT OTHER.
THE COURT WILL NOT FIND CONTEMPT. THE COURT WILL AWARD ATTORNEY FEES TO
THE RESPONDENT. COUNSEL SHALL PROVIDE A FEE DECLARATION BY MONDAY. IF THE
PETITIONER HAS OBJECTIONS, SET IT FOR HEARING. IF THERE IS NO OBJECTION
AFTER A WEEK, THE COURT WILL ENTER THE ORDER.
2 MINUTE ENTRY
201~ JUN 16 AH IQ: 20
SONYA.KRASKI
COUNTY CLERK
SNOHOMISH CO . .WASH

IN AND FOR THE COUNTY OF SNOHOMISH.
·Cause No. Q5-3.:02755- l

ANDREW SCOTT RIFE
DECLARATION OF KATHERINE DEVOE
vs. RE: SERVICE OF PROCESS OF:
JEJllNIFER,RAE RIFE ORDER TO SHOW CAUSE RE

CONTEMPT; MOTION/DECLARATION
FORAN ORDER.TO SHOW CAUSE RE
CONTEMPT
1 1. The undersigned hereby declares: That(s)he.is now,·and at all times.herein mentioned~
2 a citizen <if the United.States and resident of the State of Washington, over the age of
3 eighteen, not a party io nor.in.terested in the aboye entitled action, and is competenfto be a
4 witness therein.
5 2. lam an indepenllent contractor process server and wali assigned by ABC Legal to
6 serve the above captioned docu.ments for ABG LegaHracking.n.umber.6942093.
7 3. On or about May 19, 2014, !received. the above captioned documents for service on
8 Jennifer Mehaddi at the address of 14200 69TH DR SE, UNIT A-5, SNOHOMISH, WA
9. 98296.
Page- _I. ABC L.cPI SCrVicis, J_nc.

Reference#_ 053027551 633 Yci;lcr .Way, ScatUc..WA 98104
ABC Tracking# 69420\IJ 206.521.295o-866:S21.2950 - F.. 206.382. 1717
ORIGINAL 2&5
•
4. On May 20, 2014 at 4:44 pm, I attempted service at the address of 14200 69rn DR SE,
2 UNIT A-5, SNOHOMISH, WA 98296 but there was no answer at the door. There was no
3 movement and no noise from inside. There were no lights on. Al 5:25 pm, I returned to the
4 address of 14200 69THDR SE, UNIT A-5, SNOHOMISH, WA 98296 and the screen door
5 was closed but the front door was wide open. The lights were on, a dog was barking, and I
6 could hear someone moving upstairs. I knocked on the door and rang the doorbell multiple
7 times for fifteen minutes and waited but no one came to the door.
8 5. On May 22, 2014, I was provided an alternate address for service on Jennifer
9 Mehaddi, 9724146TH PLACE SE, SNOHOMISH, WA 98296. I was informed that this
10 address belonged to Jennifer Mehaddi's mother and that Jennifer Mehaddi may be at this
11 address on this day.
12 6. On May 22, 2014 at 3:49 pm, I attempted service at the address of 9724 146TH PL SE,
13 SNOHOMISH, WA 98296. A white female approximately 55-65 years of age, 5'4"-5'6"
14 tall, weighing 160-180 lbs with gray hair who refused to provide her name answered the
15 door. When I explained that I had legal documents to deliver for Jennifer Mehaddi, Jane
16 Doe stated that Jennifer Mehaddi does not reside here. When I asked for more information,
17 Jane Doe became angry and demanded that I not return to this address for anymore
18 attempts.
19 7. On May 22, 2014 at 4:11 pm, I returned to the address of 14200 69TH DR SE, UNIT
20 A-5, SNOHOMISH, WA 98296. A white female approximately 35-45 years of age, 5'-5'4"
21 tall, weighing 160-180 lbs. with blonde hair answered the door. I explained that I had legal
22 documents to deliver for Jennifer Mehaddi and the above mentioned female then identified
23 herself as Jennifer Mehaddi. I then and there performed personal service by handing one (1)
24 true and correct copy of the above captioned documents to Jennifer Mehaddi, who accepted
25 service.
Page2 ABC Legal Services, IK-

Ref==: # 05302755 I 633 Ycs.lcr Way, ScatUc, WA98104
ABC Trading# 6942093 206.521.2950-866.521.2950- Fox 206.382.1717
•
1 I declare under penalty of perjury under the laws of the State of Washington that the
2 foregoing is true and correct to the best of my knowledge on the date and time herein noted.
4 Dated this -ti- day of -:;I'°"'fZ-- , 2014
s
6
7 Katherine Devoe
Page3 ARC l..zgal Services, lne.

Rerercnce II 053027551 633 Yesler Way, Scatllc. WA 98104
ABC Tracking# 6942093 206.521.2950- 866.521.2950 - Fu 206.382.1717
...
FILED
201~ JUN 17 AH IQ: 21
~Il ~Il I~\ ~\~Il \Ill\
2
3 \ll\1111 Ill \Ill\\\\\\ \Ill\ 1111\ SONYA KRASKI

5 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR
SNOHOMISH COUNTY
6
In re: )
7
)
ANDREW RIFE, ) NO. 05-3-02755-1
8
Petitioner, )
9 and
) Declaration of Veronica Freitas Re:
) Attorney's Fees Incurred in this Matter.
10 JENNIFER MEHADDI (Orn Jennifer Rife),
Respondent.
)
11 )
)
12
13
Veronica Freitas declares as follows:
14
15 1. I am the attorney of record for the Respondent, Jennifer Mehaddi in the above captioned action. I
16 am over the age of eighteen and am otherwise competent to testify. This declaration is based
17 upon my own personal knowledge.
18 Jn relation to the two contempt motions filed on behalf of the Petitioner, Andy Rife, the attorney's
19 fees and costs have totaled $2,749.23. I charge $275.00 per hour and have expended 6.25
20 hours reviewing the motions, reviewing the file for possible exhibits, drafting the response
21 declaration, communicating with opposing counsel and guardian ad !item regarding hearing
22
dates and appearing for the hearing. My paralegal, Amy Pasco, charges $150.00 per hour and
has expended 4.2 hours reviewing the motions, communicating with the Respondent, revising
23
the response materials and compiling exhibits. My paralegal, Kelli Tyack, charges $100 per
24
hour and she has expended 2.2 hours preparing exhibits, collating sets of pleadings,
25
arranging for filing and service. My office charges twenty cents per copy and 374 copies
26
were made. My office uses ABC Legal Services and the charge for having ABC deliver the
27 filing set, working copy and copy for opposing counsel is $173.00. I am asking the Court
28
Attorney's Fees Declaration VERONICA FREITAS
WPF DRPSCU 07.0200 Mandatory (612008) V. FREITAS LAW, PLLC.
RCW 26.09.260; .270; 26.10.200 210 Summit Avenue East
Page I of2 (206) 328-7362
v@vfreitaslaw.com
to award attorney's fees in an amount sufficient to compensate Ms. Mehaddi for the total costs
2 oflitigating the two contempt motions.
Dated: -~l?~·\~·1"'----\_"_, _
4
5 Veroruca Freitas, WSBA No. 19405

6
IO
11
12
13
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17
18
19
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22
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Page 2 of2 (206) 328-7362
v@vfreitaslaw.com
Andrew Scott Rife objects to the amounts claimed by Veronica Freitas as attorney fees in
13 e above matter based upon an oral ruling of the Honorable Commissioner Susan Gaer on June
14 13, 2014.
15
The fees declaration presents conclusory amounts, without the ability to determine whether
l6 all portions of the fees claimed were reasonable under the circumstances. In the absence of an
17 itemized account statement, the court has no ability to exercise its discretion in a meaningful
manner.
18
19 The amount claimed by Ms. Freitas appears to be in excess of a reasonable fee for the work
20 performed.
21
22
23
°'"" & /z.' / f zv1
24
25
26 ""
CARLl.GAUL
27 Attorney at Law
302 Bank of Amenca Bldg. II
CBJECTICN RE ATTORNEY F'EES
PAGE 1 OF 1
OR/GfNAL 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
11 .If
(/'
/ .," I
FIL.ED
ZOI~ JUN 25 AH II: 11
SO"YA KRASi\I
TO: COUNTY CLERK
SNOHOMISH CO. WASH
Carl Joseph Gaul
Attorney at Law
I\~~111\1CL16878819
1 \\I ~I\ l~\I \~I lml 1 1 1~1\1 1 1 ~I 1\ 1
1604 Hewitt Avenue, Suite 302
Everett, WA 98201 I
Date: June 23, 2014
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
VS
Jennifer R. Rife
This is to notify you that the above case has been set for Non-Jury trial on October I, 2014 at
9:00 am, in the Superior Court, Presiding Judge's Department, Courthouse Building.
Court Administrator
Snohomish County Superior Cowt
IMPORTANT NOTICE: Your attention is directed to SCLCR 40(d), SCLSPR 94.04(c), and CR 41 (e) which read
as follows:
SCLCR 40(d) TRIALS - CONFIRMATION: It shall be the duty of each attorney of record or
party pro se in a case set for trial to jointly or separately confirm, no sooner than 12 noon of the first court
day of the week [9/1512014) and no later than 12 noon of the last court day of the week [9/1912014] two
CR 41(E): Notice of Settlements. If a case is settled after it has been assigned for trial it shall be
the duty of the attorneys or of any party appearing prose to notify the court promptly of the settlement. If
the seulement is made within 5 days before the trial date, the notice shall be made by telephone or in
person. A II notice of settlement shall be confirmed in writing to the clerk.

TO:
Veronica Freitas
Attorney at Law
Seattle, WA 98102
Date: June 23, 2014

Eollt
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
vs
Jennifer R. Rife
This is to notify you that the above case has been set for Non-Jury trial on October 1, 2014 at
Court Administrator
Eollt 00
IMPORTANT NOTICE: Your attention is directed to SCLCR 40(d), SCLSPR 94.04(c), and CR 4 l(e) which read
as follows:
SCLCR 40(d) TRIALS-CONFIRMATION: It shall be the duty of each attorney of record or

party prose in a case set for trial to jointly or separately confinn, no sooner than 12 noon of the first court
day of the week (9/15120141 and no later than 12 noon of the last court day of the week (9/19/20141 two
weeks prior to the trial date, in such written fonn as approved by the court. The court may strike the trial
date and may impose sanctions and/or tenns against the parties or counsel for failure to so confinn.
CONFIRM YOUR TRIAL DATE, APPEAR ON A CON~"IRMED TRIAL DATE, OR OBTAIN ORDER GRANTING A
CR 41(E): Notice of Settlements. lfa case is settled after it has been assigned for trial it shall be
lhc duty of the attorneys or of any party appearing prose to notify the court promptly of the settlement If
person. All notice of settlement shall be confinned in writing to the clerk.
UTILIZE THE NEXT PAGE OF THIS LEITER OR A COPY THEREOF

AS THE FORM FOR CERTIFICATE OF TRJAL CONFIRMA TJON.
TO:
Elise F. Buie
Guardian Ad Litem
I 03 7 NE 65th St. #354
Seattle, WA 98 I 15
Date; June 23, 2014

Eolll l'o!ll
IN mE SUPERIOR COURT OF THE STATE OF WASHINGTON
NOTICE OF TRIAL SETT~G
and
RE: Cause No.: 05-3-02755-1
Andrew S. Rife
vs
Jennifer R. Rife
This is to notify you that the above case has been set for Non-Jury trial on October I, 2014 at
Court Administrator
l'o!<I Esdll
lMPORTANT NOTICE: Your attention is directed to SCLCR 40(d), SCLSPR 94.04(c}, and CR 4 l(e) which read
as follows:
SCLCR 40(d) TRIALS- CONFIRMATION: It shall be the duty of each attorney of record or
party prose in a case set for trial to jointly or separately confirm, no sooner than 12 noon of the first court
day of the week [9/1512014) and no later than 12 noon of the last court day of the week [9/19/2014[ two
the duty of the attorneys or of any party appearing pro se to notify the court promptly of the settlement. If
person. All notice of settlement shall be confirmed in writing to the clerk.
UTIUZE THE NEXT PAGE OF THIS LETTER OR A COPY THEREOF

Fit.ED
20 I~ JUN 25 AH 11: I
SONYA KRASKI
COUNTY CLERK
SNOHOMISH CO. WAS
2
4
~111~11111111~1111~m11111111
1111CL16878818
m
5
7
In re:
8 Andrew Scott Rife
Petitioner, NO. os 3 02755 1
9 and
AGREED ORDER TO RESET TRIAL DATE
10 Jennifer Rae Mehaddl f/k/a Rife
Respondent.
11
Based upon the Agreement of the Parties, The Court Orders
12
1. The trial date of July 16, 2014 ls hereby stricken.
13
Reason for continuance: The parties need additlonal time to complete discovery
14 and conduct mediation.
The case shall be assigned a new trial date by Superior Court Ad~lstratlon.
15
16
2.
Dated:
pt.•"''- 1s u1.-.inu&1tAi l't> Oe...~•-- '•Hn _
17
~ J~ 1 .)t/~ Judge/~
Agre :
18
19 (
20 VERO !CA FREITAS WSBAtJ 19405
Attorney for Jennifer Mehaddl
21
22
23
24 ELISE BUIE
Guardian ad Utem Lo.:iiA -lr"Lf I..\ q 2'5
25
26
-
CARLJ.GAUL
Attorney at Law
27 302 Bank or Aml!rlca Bldg.
QRE'.ED DRDtR TO A!:BltT TRIAL DATE
PAmC 1 ctll" 1
1604 Hewitt Ave.
Everett
~ZS 25'9-4147
WA 98201
FAX 259 7081
f'/\\J
ORIGINAL
,
Dates of Unavailability. Carl Gaul:
August 8 -August 15, 2014
August 19 - August 29, 2014
September 2 - September 5, 2014
Dates of Unavailability. Veronica Freitas:
The following are dates that Veronica Freitas has trials that she expects to proceed
and will be unavailable:
August 6, 2014
August 11, 2014 -August 15, 2014
August 23, 2014 - September 6, 2014
September 12, 2014
Dates of Unavailability. GAL Elise Buie:
October 13 - 27, 2014
November 24 - 28, 2014
December 17, 2014 - January 6, 2015
May 5-11, 2015
May 26 - June 2, 2015

FlLED
201~ JUN 26 P" 3: 11·
SONYA KRASKI
COUNTY CLERK
~tHJHnHISH CO. WASH
I lllWl~/~1~111/~ll~~Wl~I
·.. __ C:L16560810
.
'

A.ti ouu ~,'re

)
)
PLAIN'flf'F/PETITIONER )
~ NO. e;7-3- tJ.;2. 7-s-?- I

)
) ORDER
)
)
DONE IN OPEN COURTthis date:
Presented By:
Copy Received:
8f01 pugo I 012

...... .4-~~: ........ -& ....... ~ "i.~r·"•• a; I' • ,..., •
.·. ' -
.. J.: ......
.. ~ ...... (. ~
(/..AA.s~~
1
JUN 2u 2014 ' . --·---~
.
2
SOlllYA l\MSKI
COUNTY CLERK
--; CJ ""'-..,..;-.,s,~
3 SNOHOMISH CO. WASH. &it>t.....e. v
4
5
co
6 SUPERIOR COURT OF WASHINGTON Cc·
-oz ~
COUNTY OF SNOHOMISH "'c; <-
7 ""--
-~
00
c=
:z:
XJ~
8 In re: "'
c..>
9
Andrew Scott Rife
Petitioner. NO. 05 3 02755 1 "'_.c""
01
c
~·"'
...,,,
:JC
and c ~
10 OBJECTION RE ATIORNEY FEES nz c..>
Gl-~
Jennifer Rae Mehaddi f/kla Rife Ul
11 Respondent. ....
:X-
12
13 the above matter based upon an oral ruling of the Honorable Commissioner Susan Gaer on June
14 13, 2014.
15
16 all portions of the fees claimed were reasonable under the circumstances. In the absence of an
manner.
18
20 performed.
_,. wI~~/2<), t
21
22
CA J. GAULWS
23 Attorney for Andre
24
25
26 CARLJ.GAUL
Atto(Tley at /..iJw
1604 Hewitt Ave.
OBJECTION RE ATTORNEY FEES Everett WA 98201
PAGE 1 CF" 1 425 259-4147 FAX 259 7081
.. C 0'-M~'~ \ \o"'.e..f 'de... ..
r.c·. ~'"'-cyD °"' ~ \1.)~ol'-\
'\ ',<.\() ........
5 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR

SNOHOMISH COUNTY
6
In re: )
7
)
ANDREW RIFE, ) NO. 05-3-02755-1
8
Petitioner, )
9 and ) Declaration of Veronica Freitas Re:
) Attorney's Fees Incurred in this Matter.
10 JENNIFER MEHADDI (fka Jennifer Rife),
Respondent. )
II )
)
12
13
14
15 1. I am the attorney of record for the Respondent, Jennifer Mehaddi in the above captioned action. I
16 am over the age of eighteen and am otherwise competent to testify. This declaration is based
18 In relation to the two contempt motions filed on behalf of the Petitioner, Andy Rife, the attorney's
21 declaration, communicating with opposing counsel and guardiwi ad Iitem regarding hearing
22
dates and appearing for the hearing. My paralegal, Amy Pasco, charges $150.00 per hour and
23
the response materials and compiling exhibits. My paralegal, Kelli Tyack, charges $I 00 per
24
25
26
27
filing set, working copy and copy for opposing counsel is $173.00. I am asking the Court
28
Page I of2 (206) 328-7362
JUDGE'S COPY v@vfreitaslaw.com
'•
4
Dated: _l""'-,,<--.\...,,'1,,__-_\_1...!_\_
5 Veroruca Freitas, WSBA No. 19405
6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Attorney's Fees Declaralion VERONICA FREITAS
WPF DRPSCU 07.0200 Mandatory (6/2008) V. FREITAS LAW, PLLC.
RCW 26.09.260; .270; 26. I0.200 210 Summit Avenue East
Page 2 of2 (206) 328-7362
v@vfreitaslaw.com
~-FILED
. 1009 JUL 23 PM f: ·57

1
SONYA KRASK!
2
4
;\li\!l!!\l'"
~
~··COUNTY CLERK
~NOHOMISH CO. WASH
7
9
In re:
10 Andrew Scott Rife Petitioner, NO. 05 3 02755 1
11 and
12
Jennifer Rae Rife
Respondent.
13

AND TO: Andrew Scott Rife
15 AND TO: Jan Dyer, attorney for Jennifer Rae Rife
AND TO: Bridget Llewellyn, case Manager
16
PLEASE TAKE NOTICE that Carl J. Gaul, attorney for Andrew Scott Rife, will be
17 unavailable from August 12, 2009 through August 24, 2009 inclusive. It is requested
that motions, depositions and other court hearings not be scheduled to occur
18 during the time of my absence, and that motions and other hearings be scheduled
so that there is sufficient time to prepare for them following the end of the
19 absence. There is no other attorney available with sufficient factual knowledge of
this case to respond to any substantive request for relief during my absence.
20 Dated: July 21, 2009 Faxed ~

1tj}out Sigil'rure
21 To Av id42,~ l/
22 CARL J. GAUL WSB
Attorney for And
23
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Everett WA 98201
FILED ORIGINAL
2 201~JUL 11 PM I: 23
3
SONYA KRASKI
4 COUNTY CLERK
SHOHOHISH CO. V/ASH
s
6 11111m 111m111111~~11m
CL16989517
~1 1 1 1 ~1~ 11111111
7
8
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR
9 SNOHOMISH COUNTY
Cause No. 05-3-02755-1

MOTION RE A'ITORNEY FEES

Respondent.
IS
16
COMES NOW, Jennifer Mehaddi, by and through her attorney of record, Veronica
17
Freitas, and hereby requests that this court enter the Respondent's proposed order and judgment
18
re attorney fees relating to the motions re contempt and orders the Petitioner to pay additional
19
fees for having to file this motion. This motion is based upon the subjoined Declaration of
20
Veronica Freitas.
21
22
Respectfully submitted this 9lh Day of July, 2014.
23
24
25
Veronica Freitas, WSBA No. 19405
26
27
28
MOTION RE ATIURNEY FEES-- Pnge I of4 VERONICA FREITAS

(206) 328-7362
.. .-=. .. r--:•--•--·· ---
'·
) DECLARATION
4 My name is Veronica Freitas and I the attorney for the Respondent, Jennifer Mehaddi. I
5 am over eighteen years of age and am competent to testify as a witness in this matter.
6
The Petitioner, Andy Rife, filed two separate motions to have the Respondent, Ms.
7
Mehaddi, found in contempt for violating many provisions on the parties' parenting plan. Both
8
motions were heard before Commissioner Susan Gaer on June 13, 2014. Commissioner Gaer di
9
not find that Ms. Mehaddi had violated the parties' parenting plan in any way and ordered Mr.
10
Rife to pay Ms. Mehaddi attorney fees.
II
Section 3.11 of the Order on Show Cause re Contempt entered by Commissioner Gaer on
12
June 13, 2014 (Exhibit A) states "Veronica Freitas shall provide a declaration regarding fees by
I)
Monday 6/16/2014. lfMr. Rife does not object within 1 week, court will enter judgment in the
14
requested amount. If he does object the court will decide amount on motion ... "
15
16 I submitted my declaration re attorney fees and proposed order re attorney fees and costs
17 to the court and to Mr. Gaul on June 16, 2014. These are attached as Exhibit B. The costs and
18 fees are very reasonable. Mr. Rife's motions were very lengthy. The second Order re Show
19 Cause re Contempt was signed by the court on May 19, 2014 but was not served until the
20 afternoon of Thursday, May 22"d, the Thursday before Memorial Day weekend. The response to
21 both contempt motions was due at noon the Tuesday afler Memorial Day weekend. The
22 response to the motions was drafted over Memorial Day weekend and was filed timely.
23
In order to respond to all of Mr. Rife's outrageous accusations, it was necessary to review
24
literally hundreds of email exchanges between the parties, the child's soccer team administrators,
25
the parties' GAL and medical professionals. It was also necessary to review medical records,
26
previous motions, declarations, correspondence, orders, Ms. Mehaddi's employment records and
27
more. All of this needed to be done in order to draft Ms. Mehaddi's response. Ms. Mehaddi was
28
MOTION RE ATfOR.1'1EY FEES-- Page 2 of 4 VERONICA FREITAS

2t0 Summit Avenue East
Seattle, Washington 98!02
(206) 328-7362
.·
charged for a total of 6.25 hours of my time. That includes appearing for the court hearing. In
2 reality I estimate that I spent more than ten hours on Mr. Rife's contempt motions.
3
Ms. Mehaddi was served with the second contempt motion at her home by a professional
4
process server on May 22nd. She went to her parents' home to scan the documents and email
s
them to my office. While at her parents' home a strange man came to the home and began
6
banging on the door aggressively. When Ms. Mehaddi's mother attempted to leave the home,
7
this man began banging on her vehicle, pulling on the windshield wipers and attempted to open
8
the car doors. He then chased afler Ms. Mehaddi's mother as she drove away. It turned out that
9
this was a former client of Mr. Gaul, the Petitioner's attorney. Mr. Gaul had sent this person out
10
to serve Ms. Mehaddi again even though she had already been served. This was incredibly
11
frightening and upsetting to Ms. Mehaddi and her family and there were many phone calls and
12
emails with my office regarding this incident.
13
My staff also spent significant time getting necessary information from Ms. Mehaddi in
14
order to prepare the response to the motions and then revise and finalize the response. More tim
15
had to be spent arranging for filing and delivery of the response. In order to have the response
16
delivered by noon on Tuesday, the day after Memorial Day, ABC Legal Messengers charged a
17
$173.00 fee for expedited delivery (Exhibit C).
18
19 Mr. Gaul filed an objection to my attorney fee declaration and proposed order (Exhibit
20 D). Commissioner Gaer then ordered that we needed to note a motion (Exhibit E). My fees are
21 more than reasonable. They are not excessive. I am requesting this court to enter the proposed
22 order and judgment re attorney fees that was submitted to this court on June 16, 2014. I am also
23 requesting the court to order Mr. Rife to pay an additional $I 000.00 in fees for forcing Ms.
24 Mehaddi to note this motion.
25 I declare under penalty of perjury pursuant to the laws of the State of Washinb'1on
26
that the following is true and correct to the best of my knowledge.
27
28
MOTION RE ATrORNEY FEES-- Page 3 of 4 VERONICA FREITAS

2IO Summit Avenue East
Seattle, Washington 98l02
(206) 328-7362
--r..'\ •• r __ : .. __ , ____ - - -
DATED this IO!h day of July,2014
'
at Seattle,. WA.
,2
.5 VERONICA FREITAS
10
II
Ii
iJ
14
15
16
17
18
19
20
21
22
23
26
.27
28
MOTION RE ATIORNEY FF.ES-Pogc_4 of4 VERONICA FREITAS

Seattle, Washingion 98102
(206) 328, 7362 . .
.. r-. •• '--=·--·--·· ---
EXHIBIT A

210 Summit Avenue East, Seattle, WA 98102 Itel• (206)328-7362 Ifax• (206)323-0404
Superior .Court of Washir.igton ..
County of Snohomish
No.o~ 3 02:7?5 /
Order on Show Cause re
Petitioner, Contempt/Judgment
and {'\ •• r / /, (ORCN)
::i' .t.-.:k-f~ ' Next Hearing Date:
' -PkA._~:A.
Res ondent.
I. Judgment Summary
D Does not apply.

D Applies as follows:
B. Judgment debtor
C. Principal judgment amount (back child support/medical support/other obligations/
maintenance) from (date) through (date) $----~--
D. Interest to date of judgment $-------
E. Attorney fees $ _ _ _ _ _ __
F. Costs $ _ _ _ _ _ __
G. Other recovery amount $-------
H Principal judgment shall bear interest at % per aru1um
. !. Attorney fees, costs and otlier recovery amounts shall bear interest at % per annum
L. Other: ·
Ord on Show Cause re Cntmpl!Jdgmnt (ORCN) -· Page 1 of 7

II. Findings and Conclusions
This Coult Finds:
2.1 Comp~ce W~tt;,Co;.:t.:.&

(Name) J C.--""-' k- Ja(ii;Icomply 0 intentionally failed to
comply with a lawful order of the court dated on IO/-z.f/ _.
2.2 Nature of Order
The order is related to 0 child suppo11 0 medical support 0 child care, e~al expenses,
transportation expenses, or other special expenses 0 spousal maintenan~parenting plan
(custody/visitation) 0 a restraining order.
2.3 ...
·How the Order was Violated
f f The order was not violated.
0 This order was violated in the following manner (include dates and times, and amounts, if
any): ·
2.4 Past Ability to Comply With Order
(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ O had 0 did not have the ability to comply

with the order as follows:
2.5 Present Ability and Wiiiingness to Comply With Order
(Narne) _ _ _ _ _ _ _ _ _ _ _ _ _ _ O has 0 docs not have the present al;>ility to

comply with the order as follows:
(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ O has 0 does not have the present

willingness to comply with the order as follows:
Ord on Show Cause re Cntmpl/Jdgmnt (ORCN) • Page 2 of 7

WPF DRPSCU 05.0200 Mandatory (0712013) • RCW 26.09.160, °7.21.010
2.6 Back Child Support/Medical Support/Other Unpaid Obligations/Maintenance
D Back child supportlmedical supportl child care, educational expenses, transportation

expenses, or other special expenses/maintenance is not addressed in the contempt motion.
D No back child support, medical support, child care, educational expenses, transportation
expenses, or other special expenses, or maintenance is owed;
$ for child support and interest to date in the amount of
$ for the period from through-------
$ for medical support and interest to date in the amount of
$ for the period from through..:.·------
$ for child care, educational expenses, transportation expenses, or other
special expenses and interest to date in the amount of$ for the period
from through ___...:._ __
$ for maintenance and interest to date in the amount of
$ for the period from through - - - - - - -
D Other:
2.7 Compliance With Parenting Plan
p_,......
~
Does notJ.PPly. ~ J f r
(Name)\J.L_c.._,.Y (d. /Vi.fal,,,~
'! has complied, and is currently willing
to comp~with th~prentin~1
(Name)'1....<-<.......1 ~ M~ has not complied with
idential (visitation) provisions of the parenting plan and had the ability to
comply he parenting plan, and is currently unwilling to comply. The
noncompliance · he residential provisions 0 was 0 was not in bad faith.
D decision making provis10 the parenting plan and had the ability to comply
witl1 the parenting plan, and.is.cu ~·~illing to comply.
D dispute resolution provisions of the pnrentin&Ji1an.llll!!_had the ability to comply
with the parenting.plan, and is currenlly unwilling to comply~
0 Other:

WPF DRPSCU 05.0200 Mandatory (0712013) - RCW 26.09. 160, 7.21.010
[],...-- Does not apply.

{'.) The attomey fees and costs awarded in paragraph 3.9. below have been incurred and are
rcasonnblc.
Ill. Order and Judgment
/I /s Ordered:
3.1 Contem:: Ruli:j" ~'l

(Name)\.\~ k D is r s not in contempt of court.
- 3.2 Imprisonment
Does not apply.

(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ is to be confined in the (name of
county) County Jail.
0 Confiuement shall commence immediately-and-shall continue1mtil-

(date) or until the c0ntempt is purged as set forth in
paragraph 3.6 below, iu which case the contemnor shall be released immediately.
D Confinement is suspended as follows:
D Other:
3.3 Additional Residential Time
Docs not apply.

(Name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ shall have additional residential
time as follows: -
3.4 Judgment for Past Child Support
Does not apply.

No judgment for past child supj)l)rt was requested.
Ord on Show Cause re CntmpVJdgmnl (ORCNJ ·Page 4 of 7

WPF DRPSCU 05.0200 Mandatory (0712013) · RCW 26. 09. 160, 7.21.010
0 {Name) shall have judgment against
(name) in the amount o f $ - - - - - -
for unpaid child support arrcarages and $ interest thereon for the period
from (date) ·thrOugh (date) _ _ _ _ _ _ __
3.5 Judgment for Past Medical Support
Po
D
Does not apply.
No judgment for past medical support was requested.
{Name) shall have judgment against
(name) in the amount of$-,---.,..---
for unpaid medical support arrearages and $ interest thereon for the
period from (date) through (date) _ _ _ _ _ _ __
3.6 Judgment for Other Unpaid Obligations
·~ Does not apply.

No judgment for past child care, educational expenses, transportation expenses, or other
special expenses was requested.
D {Name) shall have judgment against
(name) 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) _ _ _ _ _ _ __
3. 7 Judgment for Past Maintenance
tB
D
Does not apply.
No judgment for past maintenance was requested.
{ N a m e ) _ ' - - - - - - - - - - - - - - shall have judgment against
(name). in the amount of$ for
unpaid maintenance arrearages and $ interest thereon for the period
from (date) through (daie) - - - - - - -
3.8 Conditions for Purging the Contempt
Does not apply.

The contenmor may purge the contempt as follows:
D Does not apply.

Ord on Show Cause "re Cnlmpt/Jdgmnt (ORCN) - Page 5 ol 7
WPF DRPSCU 05.0200 Mandatory (07/'2013) - RCW 26.09: 160, 7.21.010
(Name)*~"<-+-~+~
(name)~ 54t!"V-=]::~ 1
. shall have judgment against
mtheamountof$ _ _ _ _ _ _ for
attorney fees and $ _s;, e -,. , l I ~ r ccists.
3.10 Review Date

. ~Docs not apply.
0 Thecou1t shall review this matter on (date) _ _ _ _ _ _ _ _ at (time) _ _ _ __
3.11
3.12
111is 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 P.lans to move, that person shall
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,~he relocating person·must.pmvide actual notice by
may ask for modification under RCW 26.09 .260.
or is m0\1ing to avoid a clear, immediate and unreasonable risk to health and safety.
A relocating person may ask the court.to waive any. notice requirements..tbat.ma.y. put the health
.IC no objection is filed within 30 days after sen•ice of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule moy be ·
confirmed.
relocation whether or not he or she received proper notice. · ·
Ord on Show Cause re Cntmpl/Jdgmnt (ORCN) - Page 6 of 7

. '
An objection may be filed by using the mandatory pattern fonn WPF ORPSCU 07 .0700,
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
clear, immediate and unreasonable risk to the health or safety of a per.;on or a child.
Warrrlng: Violation ofresidential provisions of this order with actual knowledge of its tem1s is
punishable by contempt·ofcourt·and·moy·be a crimina~offe1mrundcrRE:W 9A.40.060(2)'or
::.O~) ¥~1r·7;:;;wb;~·~•·w~ ~
Presented by:
I + J.wage/Commls~loner
Signature of Party or
Co..,, I J' · t;~ d
Ord on Show Cause re Cntmpl/Jdgmnt (ORCN) • Page 7 of 7

WPF DRPSCU 05.0200 Mandatory (0712013) • RC<W 26.09.160, 7.21.010
EXHIBITB

I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 I fax• (206)323-0404
'
s IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR

SNOHOMISH COUNTY
6
In re: )
7
)
8
ANDREW RIFE, ) NO. 05-3-02755-1
Petitioner, )
9 nnd ) Declaration of Veronica Freitas Re:
) Attorney's Fees Incurred in this Metter.
10 JENNIFER MEHADDI (fl<a Jennifer Rife),
Respondent. )
11 )
)
12
13
IS 1. I am the attorney of record for the Respondent, Jennifer Mehaddi in the above captioned action. l
16 em over the age of eighteen and em otherwise competent to testify. This declaration is based
18 hi relation to the two contempt motions filed on behalf of the Petitioner, Andy Rife, the attorney's
21 declaration, communicating with opposing counsel and guardian ad !item regarding hearing
22 dates and appearing for the hearing. My paralegal, Amy Pasco, charges $150.00 per hour and
23
the response materials and compiling exhibits. My paralegal, Kelli Tyack, charges $I 00 per
24
2S
26
27 filing set, working copy and copy for opposing counsel is $173.00. I am asking the Cou1t
28
Altomey's Fees Declaration VERONICA FREITAS
WPF DRPSCU 07.0200 Mandalory (612008) V. FREITAS LAW, PLLC.
Page I of2 (206) 328-7362
v@vfrclfaslnw.com
•
3
4
Dated: _\.a_J ·~ -\ '-\ ~---- ...
·-
Veroruca Freitas, WSBA No. 19405
s
6
JO
II
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
28
Attorney's fees Declaration VERONICA FREITAS
RCW 26.09.260; .270; 26.10.200 210 Snmmll Avenue Rast
Seattle, Wnshlngton 98102
Pagc2of2 (206) 328-7362
v@,·freltaslnw.com
•
s
6
7
8
County of Snohomish
9
In re:
JO
II Petitioner,
and 01·dcr re: Attorney Fees and Costs
12 Clerk's Acti~n Requirecl
13 JENNIFER MEHADDI (fka Jennifer
Rife),
14 Res ondent.
IS
I. Judgment
16
17 A. Judgment creditor Jennifer Rae Mehaddi

18
B. Judgment debtor Andrew Rife
C. Principal judgment amount $ 2.749.23
19 D. Interest to date of judgment $Q
E. Attorney fees $ 2,568.75
20 F. Costs $ 247.80
21 0.Attomey fees, costs and other recovery amounts shall bear interest at 12 % pe
annum
22 H. Allomey for judgment creditor: Veronica Freitas
I. Attorney for judgment debtor : Carl Gaul
23
24
2S
26
27
28
VERONICA FREITAS
Order - Page I of1 210 Summit Avenue East
Seatlle, Washington 98102
(206) 328-7362
v@\'frcllaslaw.com
.,
II. Order
2
THIS MATIER having come on regularly before the Cow1 upon Petitioner's Motions for
3 Contempt and the Court having reviewed the files end records herein and heard argument
4 of counsel, and deeming itself fully advised, now, therefore,
s IT IS HEREBY ORDERED AS FOLLOWS:
6 I. Respondent shall poy V. Freitas Law, PLLC $2,749.23 for the Respondent's
7 legal fees within ten days. A judgment for said $2,749.23 shall enter in favor of Jennifer Rae
8
Mehaddi.
10 Dated:
Jmlgc/Commissioner
II
12
13 Presented by:
14
IS -·[90~-·-- . . . . . ..
16 Veronica Freitas, WSBA No. 19405
17
18
Approved for Entry
19
20
21
Carl Gaul, WSBA
22
23
2'1
2S
26
27
28
VERONICA FREITAS
Order- Page 2 of2 210 Summit Avenue Ens!
Seattle, Weshlngfon 98t02
(206) 328-7362
v@vfreilnslew.com
EXHIBITC

I
210 Summit Avenue East, Seattle, WA 98102 tel• (206)328-7362 I fax• (206)323-0404
2927 Rockefeller Everell, WA 98201 abclcgal.com
Phone: 425 2584591 l'ax: 206 2529322 Fed Tax ID#: 91-1153514
SPECIAL DELIVERY INVOICE

Firm: V. Freitas Law, PLLC ORDER#: 20781607
~ lrn~~~ollltU~W 1111
210 Summit Ave E
Seattle WA 98102
Account#: 107751 DATE: May 29, 2014

Caller: CLIENT REF: -
Phone: 206 328-7362
AMOUNT DUE: $173.40
Cose: Rife
Couse Number: 05-3-027551
OrderDotc: May27,201411.30AM
Documents: dee.sealed con fo"", sealed, dee or amy
SERVICE DESCRIPTION
Pickup: ABC Everett 2927 Rockefeller Everett
Destination: SNOHOMISH COUNTY SUPERIOR COURT 3000 Rockefeller, Mail St Clerks Office Everett
Destination: SNOHOMISH COUNTY SUPERIOR COURT 3000 Rockefeller, Mail St Judges Mailroom Everett
Destination: Gaul, Car11604 Hewitt Ave, #302 Everett
SERVICE PERFORMED TOTAL

Legal Messenger Delivery $108.45
Miscellaneous Service $ 64.95
Subtotal $ 173.40
Sales Tax $ 0.00
Total $ 173.40
Prepaid Ami
An1ount Due $173.40
CHECK STATUS & ORDER ON-LINE@ABCLEGAL.COM

EXHIBITD

210 Summit Avenue East, Seattle, WA 98102 Itel• (206)328-7362 I fax• (206)323-0404
1

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 OBJECTION RE ATIORNEY FEES
11 Respondent.
12
13 e above matter based upon an oral ruling of the Honorable Commissioner Susan Gaer on June
14 13, 2014.
15
16 all portions of the fees claimed were reasonable under the circumstances. In the absence of an
manner.
18
20 performed.
I
21
22
23
°'"" w/z.) 741 t
24
25
26 CARLJ. GAUL
Attorney at Law
1604 Hewitt Ave.
CBJECTICN RE ATTCRNEY F"EES Everett WA 98201
PAGE 1 CF 1 425 259-4147 FAX 259 7081
EXHIBITE

I I
· 210 Summit Avenue East, Seattle,-WA 98102 tel• (206j328:7362 fax• (206)323-0404
...
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-..,/ ·( •BEFENE>AN:F/RESPONDENT ) ORDER
)
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IT IS.HEREBY ORDERED: "Z/..~;,::f'' .'h j 1\·u ·" { ,·: - _(·_ !•- ( (' .-,,;t, 1
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''DONE IN OPEN COURT this date:

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,
Amy Pasco
From: David fitzgerald <davidt.fitzgerald@hotmail.com>

Sent: Monday, July 7, 2014 6:58 PM
To: Amy Pasco
Subject: RE: Your case
I currently live in a two bedroom unit with my coworker/friend joe sears, his gf katie todd and their 18 mo old
daughter mckenna. this situation will change soon. either renting a larger house with all of us or joe will
purchasing his first home and we will be living there. in the mean time be Ila would share a bedroom with
mckenna. it is a friendly and kid friendly loving enviroment that bella enjoys being at. while i am at work until
bella starts school she will be baby sat by my mother and step father who currently baby sit my wife and our
daughter anna. so she will be with her younger sister and grandparents al day. school schedule will be a
bit different. I am going to first shift at Boeing on august 8th. i am not sure how that will all be worked out yet
but with my full families support getting to and from school will be no problem. i do not have pies of her skin
condition as it is hard to notice in the pies but is very visible and apparent in person. there are doctors
notes and paperwork from when i took her to the dr to be examined, and tia took me to court to for
contempt. so they should already by filed with the courts. nate is getting his dee for me by end of today i
believe he said. he also was giving you permission to use what ever is needed from his case with tia. waiting
on a couple decs from my parents i am getting the tax returns and pay stubs and bank statements gathered
together to email or fax tomorrow if i cant email them tonight.
From: amy@vfreitaslaw.com
To: davidt.fitzgerald@hotmail.com
CC: v@vfreitaslaw.com; beth@vfreitaslaw.com; kelli@vfreitaslaw.com; hye@vfreitaslaw.com
Date: Mon, 30 Jun 2014 16:57:23 -0400
Subject: Your case
Hi David,
Please fill out the attached documents and return them to me as quickly as possible.
If you want to have child support modified along with the parenting plan then I will need you to provide me
with six months of bank statements and six months of statements for all other financial accounts, six months
paystubs and two years of tax returns.
What is your living situation? What type of place do you live in?
Do you have any pictures of Bella's skin situation?
Also please gather up the declarations from your family, friends etc and start sending those to me as soon you
get them.
Thank you!
Amy Pasco
Paralegal
210 Summit Ave. E.
Seattle, WA 98102
Phone: (206)328-7362
Fax: (206)323-0404
mailto:amy@vfreitaslaw.com
1
..
www.vfreitaslaw.com
This e-mail and any files transmined with it are intended only for the person or entity to which it is addressed and may contain
confidential material and/or material protected by law. Any retransmission, dissemination or use of this infonnation may be a violation
of that law. lfyou received this e-mail in error, please contact the sender and delete the e-mail and its anachments !Tom all computers.
2
-.
1\fNf~f l:fO
FILED
201~ JUL II PH I: 23
~11111WIll~111111~111!1~~11111 ~I~ I~ 1111

SONYA KRASKI
I COUNTY CLERK
SNOHOMISH CO. YIASH
CL16989516

CASE NO. 05-3-02755-1
CALENDAR NOTE: (NTC)

ANDREW RIFE
Petitioner(s) FAMILY LAW MOTIONS
vs. Unless otherwise provided by applicable rule or statute, this

form and the motion must be filed with the Oerk not later
than twelve (12) ealendar doy• preceding the date
requested. Responses to motion must be filed five (S) court
JENNIFER MEHADDI (tka Jennifer Rife) days before the heuring. Replies lo responses must be nled
Respondent(s) three (3) court dny• before the hearing.

Date requested: July 24, 2014
FAMILY LAW/DOMESTIC CALENDAR
(mm/dd/yyyy)
Monday through Friday@ 9:00 am. Motion for Attorney Fees
Department B or C as assigned. Nature of h e a r i n g : - - - - - - - - - - - - -
*Depanment assignment will be posted the day of the

hearing (Confirm hearing at 425-388-3587)
CHILD SUPPORT MODIFICATIONS Date requested:

(mm/dd/yyyy)
Mondays@ I:00 p.m.
Department D Nature of h e a r i n g : - - - - - - - - - - - - -
(Confirm hearing at 425-388-3587)
PRO SE DISSOLUTION CALENDAR Dale requested:

(mm/dd/yyyy) ••NO CONFIRMATION REQUIRED ..
Wednesday@ 12:30 p.m. only
Department C
/\)\
Agreed Matters and Default Orders only
••• NO CONTESTED MATIERS •••
If noting a presentation, or ifa panicular Court Commissioner has already heard a recent motion in the matter,
please indicate that Coun Commissioner's name here: Commissioner Gaer
C11GINAL
M:\Mehaddi\Pleadings\Ours\Motion Re Attorney Fees\Note For Motion Family Law.Doc. 7/812014 1of3
WARNING: The moving party MUST CONFIRM by calling 425-388-3587 two (2) coun days prior to the hearing
BEFORE 12:00 noon, in order for the matter to be heard.
Failure to notify the Court ofa continuance or slrikc may result in sanctions and/or terms. SCLCR 7(b)(2)(H).
Sec below for other confirmation and noting information.
CERTIFICATE OF SERVICE BY MAIL:

I hereby ccnify that a copy of this document
and all documents listed on page 3 have been mailed to (Signature) (' \
the attomeyslpanies listed on page 3, postage prepaid
on the: ~<UC\!\ 'L=, XI .. ~-\-cc...)
(Printed name)
\.S ':.\ e:i S'
Date (mmldd/yyyy): _Ju_ly~9,~2_0_14
_ _ _ _ _ __ WSBA#
Attorney for: (CHECK O ?

(Signature) D Petitioner/Plaintiff espondent/Defendant
Veronica Freitas D Pro Sc
(Printed natne)
FOR PARTIES PRO SE: Noted by: D Petitioner D Respondent
If service is required, you must also file a RETURN OF

SERVICE. Failure to do so may result in your hearing not (Petitioner's signature)
being heard.
Please check in the Law Library for more information (Petitioner's printed natne)
regarding service.
(Respondent's signature)
(Respondent's printed natne)
FAMILY LAW/DOMESTIC MOTIONS: Most family law & domestic motions are heard on a Coun
Commissioner's calendar. The exceptions are matters relating to trial settings, lrial continuances, motions for
revision, motions to waive mediation requirement, and motions to enforce CR2A agreements; please refer to the
Civil Motion Calendar Note regarding these motions.
EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Coun Commissioner, not
by a party or by counsel.
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Trial
Continuance Calendar or Coun Commissioner Calendars must be confirmed at 425-388-3587 two (2) coun days
prior to the hearing BEFORE 12:00 noon. All other matters noted before an individual judge must be
confirmed/continued by his/her law clerk. Adoptions, reasonableness hearings and minor settlements arc specially
set and confirmed through the Civil Motions Judge's Law Clerk al 425-388-3421. If you reach voice mail when
Calendar Notes should be tiled at: All Motions Heard At:

Superior Coun Clerk's Office Superior Coun
M:IMehaddilPleadingslOurslMotlon Re Attorney Fees\Nole For Motion Family Law.Doc, 7/812014 2 of 3
Please print the names, addresses etc. of all other attorneys in this case and/or all other parties requiring
notice.
Name: ~\ (!)~\ WSBA#: '%) )!

Address: ~ O 1.... '"1:> C......~ 4, }..~\c.,l:.~ Phone # '--\1.) '1.)"\ · '--\ I'\ I Ext.
\ \.9 0 "\ \ \ \ t> &- .]>. .C.., Attorney for: (CHECK ONE)
lSaJl'etitioner/Plaintiff D Respondent/Defendant
0 Pro Se
Name: WSI3A#:
Address: \b:\ 1 }.?~ l.,,)~ '5~-t\-J,5""1 Phone # <_c)\.. -""7 loS · 1\\a.:> Ext.
Sc:.'*, w~ Attorney for: (CHECK ONE)

D Petitioner/Plaintiff D Respondent/Defendant
D Pro Se ~ ~~L
Name: WSBA#:
Phone# Ext.
Attorney for: (CHECK ONE)
D Pro Se
Name: WSBA#:
Address: ~~~~~~~~~~~~~~-
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pros.
List all documents mailed: Ls\ e ii\~ ....( JY.,..\c , ~~ ~c\. c;.r ~)..,
S> "~{\l\""O I() o?.l,l) c V'-2 '"'( ~ °'~
M:\Mehaddi\PleadingslOu"'IMotlon Re Attorney Fees\Note For MoUon Family Law.Doc, 7/812014 3 of 3

12 I, Carl J. Gaul, declare under penalty of perjury of the laws of the State of
13
14
I am attorney for Andrew Rife. I make this declaration to Respond to Veronica
15
Freitas' motion and declartion for attorney fees. Her request is unreasonable and should
16
be denied. If not denied, the court should award significantly less than she requests. Mr.
17
Rife suggests $1000.
18
BACKGROUND FACTS
19
Mr. Rife brought motions for orders finding Mrs. Mehaddi in contempt for her
20
iolations of parenting plan. His position was simple: Mrs. Mehaddi had refused to comply
21
ith the parenting plan. Mrs. Mehaddi filed a wide ranging response, informing the court
22
about a variety of topics beyond those forming the basis of Mr. Rife's motion. The court
23
denied Mr. Rite's motions, and oraled ruling that there would be an award of attorney fees.
24
Ms. Freitas filed a fees declaration seeking an award of $2749.23. Mr. Rife provided
25
26 CARLJ.GAUL
Attorney at Law
27 DECLARATION 302 Bank of America Bldg.
OPPOSING FEES REQUEST 1604 Hewitt Ave.
Everett WA 98201 ,,-a.
Pag~ 1of5 425 259-4147 FAX 259 7081 ,£..- IJ
1 an objection. The objection noted that the fees declaration presented conclusory amounts,
2 ithout any itemization, and without any l!leaningful ability for the court to exercise its
3 discretion.
4 Ms. Freitas has now filed the motion for fees. Her motion and attachments do not
5 address the objection. She still has not provided any itemization of the time spent nor an
6 xplanation why the fee claimed is reasonable. But she adds $1000 to her request, without
7 explaining why that is reasonable nor why it would be within the court's oral decision.
a 3. FEE FACTORS
9 In determining an award of fees, the courts look to RPC 1.5(a) which states the
10 basic principal that a lawyer may not charge or collect an unreasonable fee nor an
11 unreasonable amount of expenses. It then follows with a listing of eight factors to be
12 nsidered in determining whether a fee is reasonable or not.
13 Those factors and their applicability to this file follow:
14
RPC 1.S(a) Factor Comment
15 1 the time and labor Ms. Feitas states that 6.25 hours of
required, the novelty and her time were invested in these two
16 difficulty of the contempt motions. In her current declaration
questions involved, and the skill she provides no indication what she did
17 requisite to perform the legal during those hours, except to say that the
service property; court hearing was included. In her June 13
18 declaration she lists a variety of activities,
including communicating with opposing
19 counsel and the guardian ad litem regarding
hearing dates. She certainly did a lot of
20 communicating about hearing dates, as
several hearing dates were set, and reset, all
21 at her request.
She does not address the time
22 involved nor the difficulty of the questions.
23
24
25
26 CARLJ.GAUL
Attorney at Law
27 DECLARATION 302 Bank of Amenca Bldg.
Everett WA 98201
Page2 of5 425 259-4147 FAX 259 7081
1 RPC 1.S(a) Factor Comment
2 2 the likelihood, if apparent Not a factor
to the client, that the acceptance
3 of the particular emrcloyment will
preclude other emp oyment by
4 the lawyer;
5 3 the fee customarily Ms. Freitas does not inform the court
charged in the locality for similar of rates charged in Snohomish Coun% for
6 legal services; similar services. Neither does she in orm
the court of her own charges to Mrs.
7 Mehaddi.
8 4 the amount involved and The amount involved is relatively

the results obtained; small: Mr. Rife only sought to compel
9 compliance with the written terms of the
~arenti'Wc plan as he understood them. Mr.
10 ife's e ort was unsuccessful, and Ms.
Freitas did obtain a victory for her client. But
11 there was enough merit to Mr. Rite's position
that the court sua ~onte modified the
12 riarenting plan to e ectively eliminate the
rst right of refusal found in part 3.13 of the
13 March 25, 2010 parenting plan.
5 the time limitations Ms. Freitas had no time limitations.
14 Ms. Freitas makes a false claim of some
imposed by the client or by the
circumstances; urgency. There were two orders to show
15 cause. The first was obtained on May 2,
2014, sub number 249, with a hearing date
16 of May 19, 2014. On May 14 that hearing
was continued by agreement to June 3, a
17
date she requested. See Attachment 1
Ms. Freitas then wants Mr. Rife to pay
18 for her ABC L~al Messengers rush order
cost to file time y for the hearing date she
19 requested!
The second order to show cause was
20 obtained on May 19, and also set for hearing
on June 3. Both hearings were again
21 continued at Ms. Freitas' ~uest to June 13.
Ms. Freitas requeste all those
22 continuances.
23 6 the nature and len~th of Ms. Freitas provides no information.
the professional relations ip with
24 the client;
25
28 CARLJ. GAUL
Attorney at Law
Everett WA 98201
Page 3 of 5 425 259-4147 FAX 259 7081
1
RPC 1.5(a) Factor Comment
2 7 the experience, Ms. Freitas provides no information.
reputation, and ability of the
3 lawyer or lawyers
performing the services;
4
8 whether the fee is fixed or Presumptively not a factor.
5 contingent
6 9 the terms of the fee Ms. Freitas does not reveal the terms of her
agreement between the lawyer fee agreement with Mrs. Mehaddi. Neither
7 and the client, including whether does she reveal the amount, if any, she
the fee agreement or confirming charged her client for the services.
8 writing demonstrates that the
client had received a reasonable
9 and fair disclosure of material
elements of the fee agreement
10 and of the lawyer's billing
practices.
11
RED HERRING
12
Ms. Freitas discusses service of process. Mrs. Mehaddi was avoiding service of
13
process. The Order to Show Cause was issued on May 19, 2014. The very next day, May
14
0, 2014 ABC Legal Messengers reported Mrs. Mehaddi being at her condominium on a
15
arm day, with the door open. In 15 minutes of knocking and ringing the doorbell the
16
process server could not get a response to the front door. The family dog barked, assisting
17
in the notification thatthere was someone atthe door, but Mrs. Mehaddi refused to answer.
18
See Declaration of Katherine DeVoe re: Service of Process, filed with this declaration.
19
When service had not been accomplished by the morning of May 22, 2014 I
20
obtained a second process server. As it turned out, both process servers were successful.
21
he second process server did not know that Mrs. Mehaddi had already been served when
22
he served at Mrs. Mehaddi's parents' location. Neither he nor Mr. Rife are responsible for
23
he histrionic response from Mrs. Mehaddi and her extended family. There is no indication
24
hat any increased cost was involved.
25
26 CARLJ. GAUL
Attorney at Law
Everett WA 98201
Page 4 of 5 425 259-4147 FAX 259 7081
1 Ms. Freitas then complains of complying with the court's rules regarding a timely
2 response. She neglects to discuss that her client contributed to any time difficulty by
3 delaying service of process.
4 Ms. Freitas also neglects to discuss that the hearings were repeatedly reset at her
5 request.
6 5. CONCLUSION
1 Ms. Freitas has not justified the fees she claims. Because it is clear that some fees
a ere incurred in her successful defense of Mr. Rite's claims of Mrs. Mehaddi's contempt,
9 Mr. Rife suggests that the court's purposes will be satisfied by his payment of $1000, which
10 he is prepared to pay promptly.

11
on July 17, 2014
.(
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
Everett WA 98201
Page 5 of 5 425 259-4147 FAX 259 7081
ATTACHMENT'1
. -
Emails re Resetting Hearing Date~
Requested by Ms. Fe~s
To: Carl Gaul, Veronica Freitas
Cc: eliseb@mainstreetlawgroup.com, Amy Pasco
kelli@vfreitaslaw.com
From: Kelli Gomez (kelli@vfreitaslaw.com)
Sent: Thu 5/22/14 4:57 PM
To: Carl Gaul (carlgaul@hotmail.com); Veronica Freitas (v@vfreitaslaw.com)
Cc: eliseb@mainstreetlawgroup.com (eliseb@mainstreetlawgroup.com); Amy Pasco
(amy@vfreitaslaw.com)
We just received your contempt motion. I wish you would have checked Veronica's
schedule first. She is scheduled to begin trial on June 3rd. Can we agree to have both
contempt motions heard the same day?
Kelli Gomez
Paralegal
210 Summit Ave. East
Seattle, WA 98102
Phone: (206)328-7362
Fax: (206)323-0404
www.vfreitaslaw.com
From: C::arl ~aul (carlgaul@tiotmail.com)
Sent:, Thu 5/22/14 5:11 PM
To: Kelli Gomez (kelli@vfreitaslaw.com);-v@vfreitaslalN.C()!TI (v@vfreitaslaw.com)
Cc: . elisebuie@gmail.com (elisebuie@ginail.cclril); arriy@vfreitaslaw.com
(amy@vfreitaslaw.com) . .
Bee: A~drew Rife (asrifeOQ1@icl~ud.eom)
I checked. They are set to.be heard at the same date and time.
CARL ~- GAl.JL.
~ttomey at:La.V''
1604 HewittAvenue
Everett WA 98201-3536·
Tel. 425-259-414.7
Fax 425-259-7081
carlgaul@hotmail.com
FW: TRIAL ASSIGNMENT- Litiu v. Burian (13-3-01750-8 SEA)?
Veronica Freitas
5/29/14
To: Carl Gaul, eliseB

Cc: Amy Pasco, Kelli Gomez
v@vfreitaslaw.com
Hi Carl,
Please see below. My King County trfal has been on standby all week and I was just
sent out for Monday morning. I need to reschedule the Mehaddi contempt hearing. I
am scheduled to be in Sno Co the morning of our mediation on two other matters. We
can put the contempt hearing on that day too, June 13th which is the following Friday. I
am scheduled to get a ruling on a trial at 9:00 am that morning and will be in Family
Law by 9:30 on the other two cases and can do Mehaddi as well.
The King County case has 3 attorneys and an interpreter and is expected to last two
weeks. Please be agreeable. I do not know if Elise is available on Friday the 13th or
not. Please let us know. Thank you and sorry for the timing. I was hoping to complete
this trial before our hearing, but a third attorney and interpreter were added which
doubled the expected length of the case.
Veronica Freitas
210 Summit Ave. E.
Seattle, WA 98102
Phone: (206)328-7362
Fax: (206)323-0404
mailto:v@vfreitaslaw.com
www.vfreitaslaw.com
Re: FW: TRIAL ASSIGNMENT- Litiu v. Burian (13-3-01750-8 SEA)?
Elise Buie
Add to contacts
5/29/14
Cc: Carl Gaul, Amy Pasco, Kelli Gomez
eliseb@mainstreetlawgroup.com
I am good on 6/13. That would be fine. Schedules are quite complicated.
Elise F. Buie

direct 206.389.1623
fax 888.659.6345
1001 Fourth Avenue
44th Floor
www.mainstreetlawgroup.com
•
Sent from my iPhone
On May 30, 2014, at 2:09 PM, "Cart Gaul" <cartgaul@hotmail.com> wrote:
Veronica
This email is to confirm the substance of our telephone conversation of this

afternoon.
In order to accommodate your trial commencing June 2, I agreed to reset the

contempt hearing which has been set for June 3 to June 13 as you requested. We
have reset that hearing with the court administration.
You and I agreed that the mediation will not occur on June 13 and that it must be
reset to a later date, but will remain with Wayne Pellegrini.
And you and I agreed to reset the trial date. We discussed that a late-September
date is likely to be assigned.
The change of trial date will make it possible for the parties to accomplish the things
Ms. Buie recommended.
I will send a form of order for an agreed resetting of the trial. Please sign it and
forward to Elise Buie to return to me for entry. Signing-scanning-and-emailing is fine,
with a listing of your unavailability/conflict dates. Upon return I will sign the order and
get it to court administration.
CARLJ.GAUL
Attorney at Law
1604 Hewitt Avenue
Tel. 425-259-4147
Fax 425-259-7081
From: Veronica Freitas (v@vfreitaslaw.com)

Sent: Fri 5/30/14 2:51 PM
To: Carl Gaul Ccarlgaul@hotmail.com)
Thank you
13
14
I am attorney for Andrew Rife. I make this declaration to Respond to Veronica
15
Freitas' motion and declartion for attorney fees. Her request is unreasonable and should
16
be denied. If not denied, the court should award significantly less than she requests. Mr.
17
Rife suggests $1000.
18
BACKGROUND FACTS
19
Mr. Rife brought motions for orders finding Mrs. Mehaddi in contempt for her
20
iolations of parenting plan. His position was simple: Mrs. Mehaddi had refused to comply
21
ith the parenting plan. Mrs. Mehaddi filed a wide ranging response, informing the court
22
about a variety of topics beyond those forming the basis of Mr. Rife's motion. The court
23
denied Mr. Rite's motions, and oraled ruling that there would be an award of attorney fees.
24
Ms. Freitas filed a fees declaration seeking an award of $2749.23. Mr. Rife provided
25
26 CARLJ.GAUL
Attorney at Law
Everett WA 98201 ,,-a.
Pag~ 1of5 425 259-4147 FAX 259 7081 ,£..- IJ
1 an objection. The objection noted that the fees declaration presented conclusory amounts,
2 ithout any itemization, and without any l!leaningful ability for the court to exercise its
3 discretion.
4 Ms. Freitas has now filed the motion for fees. Her motion and attachments do not
5 address the objection. She still has not provided any itemization of the time spent nor an
6 xplanation why the fee claimed is reasonable. But she adds $1000 to her request, without
7 explaining why that is reasonable nor why it would be within the court's oral decision.
a 3. FEE FACTORS
9 In determining an award of fees, the courts look to RPC 1.5(a) which states the
10 basic principal that a lawyer may not charge or collect an unreasonable fee nor an
11 unreasonable amount of expenses. It then follows with a listing of eight factors to be
12 nsidered in determining whether a fee is reasonable or not.
13 Those factors and their applicability to this file follow:
14
RPC 1.S(a) Factor Comment
15 1 the time and labor Ms. Feitas states that 6.25 hours of
required, the novelty and her time were invested in these two
16 difficulty of the contempt motions. In her current declaration
questions involved, and the skill she provides no indication what she did
17 requisite to perform the legal during those hours, except to say that the
service property; court hearing was included. In her June 13
18 declaration she lists a variety of activities,
including communicating with opposing
19 counsel and the guardian ad litem regarding
hearing dates. She certainly did a lot of
20 communicating about hearing dates, as
several hearing dates were set, and reset, all
21 at her request.
She does not address the time
22 involved nor the difficulty of the questions.
23
24
25
26 CARLJ.GAUL
Attorney at Law
Everett WA 98201
Page2 of5 425 259-4147 FAX 259 7081
1 RPC 1.S(a) Factor Comment
2 2 the likelihood, if apparent Not a factor
to the client, that the acceptance
3 of the particular emrcloyment will
preclude other emp oyment by
4 the lawyer;
5 3 the fee customarily Ms. Freitas does not inform the court
charged in the locality for similar of rates charged in Snohomish Coun% for
6 legal services; similar services. Neither does she in orm
the court of her own charges to Mrs.
7 Mehaddi.
8 4 the amount involved and The amount involved is relatively

the results obtained; small: Mr. Rife only sought to compel
9 compliance with the written terms of the
~arenti'Wc plan as he understood them. Mr.
10 ife's e ort was unsuccessful, and Ms.
Freitas did obtain a victory for her client. But
11 there was enough merit to Mr. Rite's position
that the court sua ~onte modified the
12 riarenting plan to e ectively eliminate the
rst right of refusal found in part 3.13 of the
13 March 25, 2010 parenting plan.
5 the time limitations Ms. Freitas had no time limitations.
14 Ms. Freitas makes a false claim of some
imposed by the client or by the
circumstances; urgency. There were two orders to show
15 cause. The first was obtained on May 2,
2014, sub number 249, with a hearing date
16 of May 19, 2014. On May 14 that hearing
was continued by agreement to June 3, a
17
date she requested. See Attachment 1
Ms. Freitas then wants Mr. Rife to pay
18 for her ABC L~al Messengers rush order
cost to file time y for the hearing date she
19 requested!
The second order to show cause was
20 obtained on May 19, and also set for hearing
on June 3. Both hearings were again
21 continued at Ms. Freitas' ~uest to June 13.
Ms. Freitas requeste all those
22 continuances.
23 6 the nature and len~th of Ms. Freitas provides no information.
the professional relations ip with
24 the client;
25
28 CARLJ. GAUL
Attorney at Law
Everett WA 98201
Page 3 of 5 425 259-4147 FAX 259 7081
1
RPC 1.5(a) Factor Comment
2 7 the experience, Ms. Freitas provides no information.
reputation, and ability of the
3 lawyer or lawyers
performing the services;
4
8 whether the fee is fixed or Presumptively not a factor.
5 contingent
6 9 the terms of the fee Ms. Freitas does not reveal the terms of her
agreement between the lawyer fee agreement with Mrs. Mehaddi. Neither
7 and the client, including whether does she reveal the amount, if any, she
the fee agreement or confirming charged her client for the services.
8 writing demonstrates that the
client had received a reasonable
9 and fair disclosure of material
elements of the fee agreement
10 and of the lawyer's billing
practices.
11
RED HERRING
12
Ms. Freitas discusses service of process. Mrs. Mehaddi was avoiding service of
13
process. The Order to Show Cause was issued on May 19, 2014. The very next day, May
14
0, 2014 ABC Legal Messengers reported Mrs. Mehaddi being at her condominium on a
15
arm day, with the door open. In 15 minutes of knocking and ringing the doorbell the
16
process server could not get a response to the front door. The family dog barked, assisting
17
in the notification thatthere was someone atthe door, but Mrs. Mehaddi refused to answer.
18
See Declaration of Katherine DeVoe re: Service of Process, filed with this declaration.
19
When service had not been accomplished by the morning of May 22, 2014 I
20
obtained a second process server. As it turned out, both process servers were successful.
21
he second process server did not know that Mrs. Mehaddi had already been served when
22
he served at Mrs. Mehaddi's parents' location. Neither he nor Mr. Rife are responsible for
23
he histrionic response from Mrs. Mehaddi and her extended family. There is no indication
24
hat any increased cost was involved.
25
26 CARLJ. GAUL
Attorney at Law
Everett WA 98201
Page 4 of 5 425 259-4147 FAX 259 7081
1 Ms. Freitas then complains of complying with the court's rules regarding a timely
2 response. She neglects to discuss that her client contributed to any time difficulty by
3 delaying service of process.
4 Ms. Freitas also neglects to discuss that the hearings were repeatedly reset at her
5 request.
6 5. CONCLUSION
1 Ms. Freitas has not justified the fees she claims. Because it is clear that some fees
a ere incurred in her successful defense of Mr. Rite's claims of Mrs. Mehaddi's contempt,
9 Mr. Rife suggests that the court's purposes will be satisfied by his payment of $1000, which
10 he is prepared to pay promptly.

11
on July 17, 2014
.(
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
Everett WA 98201
Page 5 of 5 425 259-4147 FAX 259 7081
ATTACHMENT'1
. -
Emails re Resetting Hearing Date~
Requested by Ms. Fe~s
To: Carl Gaul, Veronica Freitas
Cc: eliseb@mainstreetlawgroup.com, Amy Pasco
From: Kelli Gomez (kelli@vfreitaslaw.com)
Sent: Thu 5/22/14 4:57 PM
To: Carl Gaul (carlgaul@hotmail.com); Veronica Freitas (v@vfreitaslaw.com)
Cc: eliseb@mainstreetlawgroup.com (eliseb@mainstreetlawgroup.com); Amy Pasco
(amy@vfreitaslaw.com)
We just received your contempt motion. I wish you would have checked Veronica's
schedule first. She is scheduled to begin trial on June 3rd. Can we agree to have both
contempt motions heard the same day?
Kelli Gomez
Paralegal
210 Summit Ave. East
Seattle, WA 98102
Phone: (206)328-7362
Fax: (206)323-0404
www.vfreitaslaw.com
From: C::arl ~aul (carlgaul@tiotmail.com)
Sent:, Thu 5/22/14 5:11 PM
To: Kelli Gomez (kelli@vfreitaslaw.com);-v@vfreitaslalN.C()!TI (v@vfreitaslaw.com)
Cc: . elisebuie@gmail.com (elisebuie@ginail.cclril); arriy@vfreitaslaw.com
(amy@vfreitaslaw.com) . .
Bee: A~drew Rife (asrifeOQ1@icl~ud.eom)
I checked. They are set to.be heard at the same date and time.
CARL ~- GAl.JL.
~ttomey at:La.V''
1604 HewittAvenue
Everett WA 98201-3536·
Tel. 425-259-414.7
Fax 425-259-7081
FW: TRIAL ASSIGNMENT- Litiu v. Burian (13-3-01750-8 SEA)?
Veronica Freitas
5/29/14
To: Carl Gaul, eliseB

Cc: Amy Pasco, Kelli Gomez
v@vfreitaslaw.com
Hi Carl,
Please see below. My King County trfal has been on standby all week and I was just
sent out for Monday morning. I need to reschedule the Mehaddi contempt hearing. I
am scheduled to be in Sno Co the morning of our mediation on two other matters. We
can put the contempt hearing on that day too, June 13th which is the following Friday. I
am scheduled to get a ruling on a trial at 9:00 am that morning and will be in Family
Law by 9:30 on the other two cases and can do Mehaddi as well.
The King County case has 3 attorneys and an interpreter and is expected to last two
weeks. Please be agreeable. I do not know if Elise is available on Friday the 13th or
not. Please let us know. Thank you and sorry for the timing. I was hoping to complete
this trial before our hearing, but a third attorney and interpreter were added which
doubled the expected length of the case.
Veronica Freitas
210 Summit Ave. E.
Seattle, WA 98102
Phone: (206)328-7362
Fax: (206)323-0404
mailto:v@vfreitaslaw.com
www.vfreitaslaw.com
Re: FW: TRIAL ASSIGNMENT- Litiu v. Burian (13-3-01750-8 SEA)?
Elise Buie
Add to contacts
5/29/14
Cc: Carl Gaul, Amy Pasco, Kelli Gomez
I am good on 6/13. That would be fine. Schedules are quite complicated.
Elise F. Buie

direct 206.389.1623
fax 888.659.6345
1001 Fourth Avenue
44th Floor
www.mainstreetlawgroup.com
•
Sent from my iPhone
On May 30, 2014, at 2:09 PM, "Cart Gaul" <cartgaul@hotmail.com> wrote:
Veronica
This email is to confirm the substance of our telephone conversation of this

afternoon.
In order to accommodate your trial commencing June 2, I agreed to reset the

contempt hearing which has been set for June 3 to June 13 as you requested. We
have reset that hearing with the court administration.
You and I agreed that the mediation will not occur on June 13 and that it must be
reset to a later date, but will remain with Wayne Pellegrini.
And you and I agreed to reset the trial date. We discussed that a late-September
date is likely to be assigned.
The change of trial date will make it possible for the parties to accomplish the things
Ms. Buie recommended.
I will send a form of order for an agreed resetting of the trial. Please sign it and
forward to Elise Buie to return to me for entry. Signing-scanning-and-emailing is fine,
with a listing of your unavailability/conflict dates. Upon return I will sign the order and
get it to court administration.
CARLJ.GAUL
Attorney at Law
1604 Hewitt Avenue
Tel. 425-259-4147
Fax 425-259-7081
From: Veronica Freitas (v@vfreitaslaw.com)

Sent: Fri 5/30/14 2:51 PM
To: Carl Gaul Ccarlgaul@hotmail.com)
Thank you
••
/
·'
FILED
201~ JUL 17 PM 12= 38
\~ll~~ll~~l~~l\11\\\
SONYA KRAS~;I
COUHTY CLERK
S!HJHOHIStl CO. WASH
CL17072555

Cause No. 05-3-02755-1

ANDREW SCO'IT RIFE
DECLARATION OF KATHERINE DEVOE
vs. RE: SERVICE OP PROCESS OF:
JENNIFER RAE RIFE ORDER TO SHOW CAUSE RE

CONTEMPT; MOTION/DECLARATION
FOR AN ORDER TO SHOW CAUSE RE
CONTEMPT
I 1. The undersigned hereby declares: Thal (s)he is now, and at all times herein mentioned,
2 a citizen of the Uniled Slates and resident of the State of Washington, over the age of
3 eighteen, 001 a party to nor interested in !he above enlilled action, and is competent 10 be a
4 witness therein.
s 2. I am an independent contractor process server and was assigned by ABC U:gal 10
6 serve the above captioned documents for ABC U:gal tracking number 6942093.
7 3. On or about May 19, 2014, I received the above captioned documents for service on
8 Jennifer Mehaddi al the address of 14200 69TH DR SE, UNIT A-5, SNOHOMISH, WA
9 98296.
1'91 All(; Lqol ScM- ia<.

6l3 Ycskr Way, Sc:ank, WA 98104
206.521.2!lS0-1166.5212950. Fu20lU82.1717
01<I.6I.NA.L
' .
.
I 4. Oo May 20. 2014 at 4:44 pm. I attempted service at the address of 14200 69™ DR SE,
2 UNIT A-5, SNOHOMISH, WA 98296 but there was oo answer at the door. There was oo
3 movement and DO noise from inside. There were no lights oo. At 5:25 pm. I returned to the
4 address of14200 69™ DR SE, UNIT A-S, SNOHOMISH, WA 98296 and the screen door
S was closed but the front door was wide open. The lights were oo, a dog was barking, and I
6 could hear someone moving upstairs. I knocked on the door and rang the doorbell multiple
7 times for fifteen minutes and waited but no one came to the door.
8. 5. Oo May 22, 2014, I was provided an alternate address for service on Jennifer
9 Mehaddi, 9724146™ PLACE SE, SNOHOMISH, WA 98296. I was informed that this
to address belonged to Jennifer Mehaddi's mother and that Jennifer Mehaddi may be at this
11 · address on this day.

12 6. On May 22, 2014 at 3:49 pm, I auempted service at the address of 9724 146™ PL SE,
13 SNOHOMISH, WA 98296. A white female approximately SS-65 years of age, 5'4"-5'6"

14 tall. weighing 160-180 lbs with giay hair who refused to provide her name answered the
IS door. When I explained that I had legal documents to deliver for Jennifer Mehaddi, Jane
16 Doe stated that Jennifer Mebaddi does not reside here. When I asked for more information,
17 Jane Doe became angry and demanded that I n9t return to this address for anymore
18 attempts.
1.9 7. On May 22, 2014 at 4:11 pui, I returned to the address of 14200 69TH DR SE, UNIT
20 A-5, SNOHOMISH, WA 98296. A white female approximately 35-45 years of age, 5'-5'4"
21 tall, weighing 160-180 lbs. with blonde hair answered the door. I explained that I had legal
22 documents to deliver for Jennifer Mehaddi and the above mentioned female then identified
Z3 herself as Jennifer Mehaddi. I then and there performed personal service by handing one (1)
24 true and correct copy of the above captioned documents to Jennifer Mehaddi, who accepted
25 service.
ABC 1.qal Services. blc.
6llYcskr\\lay.SWtlc,.W/\9Sl04
2116.521.2950- 866.521.Z\150. Fu 206.38l.1717
~_, ..
1 I dedare under pellill!Y'of perjurr under the:laws of the State of Washington tliilt the
2 foregoing is.true and conect to the best of my knowledge on the date an·d time· herein noted.
4 Dated.this .JS_ day of g!.l!\i~ ; 2Dl4

s
'6
7 Katherine Devoe
ABC I.Cpl Scmc<s, I= .

R.r=na: 1 os3airu1 . 633 '\'""" Waj; &anlc0 WA 981o4
ABC Tncklaa t 6\14um 2QU21.2950-8f•!i-,SZl.29SD -..Fu 206.382.1717
FILED
ZOl~JUL21 AHll:32
2
SONYA l\RASKI
3 COUllTY CLERK
SNOHOMISH CO. WASH
\\\\\~~\\~~\~\il\\\\\\\~\I
4
s
CL17074931
6
7
8
County of Snohomish
9
In re:
10
ANDREW RffE, No. 05-3-02755-1
II Petitioner,
and
12
JF.NNWER MEHADDI (!ks Jennifer Rife),
DECLARATION OF VERONICA
13 FREITAS IN REPLY TO MOTION
· Respond en I.
14
RE ATTORNEY FEES
IS
My name is Veronica Freitas and I an1 over eighteen years old and am competent to testify.
16
am the attomey for the Respondent. I have reviewed Carl Gaul's (attorney for Petitioner) respons
17
dcclaralion lo Ms. Mehaddi's motion for attorney fees and I nm submitting this declaration in reply.
18
19 My homly rate is $275.00 per hour and is ve1y reasonable for an attorney with m
20 experience. My paralegals are billed at $150.00 and $100.00 per hour. I do not charge any type o
21
markup on things like messenger se1vice or special delivery fees. I charge twenty cents pe1
22
photocopy and filly cents per facsimile. All of these charges are r.easonnble.
23
Mr. Gaul filed two separate motions fm· contempt against Ms. Mehaddi citing a laundry lis
25 of allegations. In order to adequately respond to Mr. Rife's motions, much time and enerb'Y wa
26 spent reviewing the motio.ns, GAL reports, communicating with Ms. Mehaddi, drafting and revisin
27
the response, reviewing countless emails between the parties etc. All of this was explained in m
28
VERONICA FREITAS .
DECLARATION 210 Summfl Avenue Ens!
Page I of6 Scnttle, Washington 98102
(206)328-7362
v@vrreitaslnw.com
ORIGINAL
Declaration re Attorney fees that was filed on June 16, 2014. This same declaration was als
2
included as Exhibit A to this motion for attorney fees. I do not understand how Mr. Gaul i.
3
continuing to say that he has no idea what the charges represent as it is laid out clearly in th
4
5
attorney fee declaration.
6 The efforts of my office were e!Tective as the com1 did not find Ms. Mehaddi to be i
7 contempt on any of the 1idiculous allegations raised by Mr. Rife and ordered Mr. Rife to pay Ms
8
Mehaddi's attorney fees. Commissioner Gaer did modify the temporary parenting plan sua spont
9
by eliminating the four hour right of first refusal provision. This was done because it was clear tha
10
II
Mr.Rife was abusing this provision with no regard for the pm1ies' child's feelings or well-bein
12 even though he had been asked repeatedly by Ms. Mehaddi and the pa11ies' GAL, Elise Buie, t
13
stop rigidly enforcing this provision as doing so was very damaging to the parties' child. This wa
14
not done because Commissioner Gaer found any merit to Mr. Rife's complaints.
IS
1 will nddress RPC 1.5 (a) and the issues that Mr. Gaul has raised briefly below:
16
17 I. The time and labor required, the novelty and difficulty of the questions involved and th
18 skill and requisite to perform the legal service properly: 1 believe that I covered this i1
19
my motion. In order to refute Mr. Rife's baseless claims, it was necessary to review.
20
compare and annlyze Ms. Mehnddi's employee records, the child's medical records, th
21
child's school records, hundreds of emails between the pru1ies, the child's soccer tca1
22
23 administration, the GAL and more. Once that had been done then the response needed t
be written. Unfortunately, after the initial draft of the response to the first contcmp
25
motion had been dralkd, Ms. Melmddi was served twice with the second eontcmp
26
motion, that contained completely new allegations, thus requiring that even more tim
27
28
VERONICA 111!.l!:ITAS
Y. I/REITAS LAW, PI.LC.
DECl.ARA TION 210 Summit Aveuue Ens!
Page 2 of6 Scnlllc, Wnshington 98102
(206) 328-7362
v@vfrcftnslnw.cn m
be spent preparing and finalizing lhc response.
2
2. Does not apply.
3
3. The fee cuslomarily charged in the locality for similar legal services: 1 do no
•I
understand what Mr. Gaul's issue is with this. I charge the same rates to all of my client
s
6 no matter which county I am appearing in. I have also provided the corn1 with m
7 attorney fee affidavit that explains the fees and charges.

8
4. The amount involved and the results obtained: Mr. Rife was not simply scekin
9
compliance from Ms. Mchadcli. Mr. rufe was proposing that Ms. Mehaddi lose tim
IO
II
with the parties' cltlld and was asking the court to order Ms. Mehadcli to provide hi
12 with her work schedule in advance so he could know exactly when and where she woul
13
be working. He was also asking for her to pay his attorney fee.~ even though he is awar
14
that his income dwarfs hers and that is would he impossible for her to do so. He wa.
IS
seeking to punish Ms. Mchaddi. The comt found that Ms. Mchaddi was already i
16
17 compliance with the parenting plan. There was no medt to Mr. Rife's motion. Ms
18 Mehaddi was not and is not in contempt and Mr. Rife was ordered to pay Ms. Mchaddi'.
19
fees.
20
5. The time limitations imposed by the client or by the circumslances: As I stated above.
21
Ms. Mehaddi was initially served with the first contempt motion. The second motio
22
23 for contempt was sc1ved on Ms. Mebaddi in the afternoon on the 11mrsday befo1
24 Mcmodal Day weekend. Due to the complexity of the allegations, it was not possible t
2S
have the response to both motions completed in time to be delivered to Snohomi
26
County on the regular messenger nm by the end of the day that Friday (the very ncx
27
28
VERONICA FREITAS
V. FREITAS I.AW, PLLC.
DECLARATION 210 Summit Avenue EIL•t
l'ngc 3 or6 Sentllc, Wnshington 98t02
(206) 328-7362
v@vfrcltnslaw.com
dny). The response was due on Tuesday, May 27~', the day after Memorial Day. h
2
order for it lo be delivered on time it was necessary to have it delivered via rush dclivc
3
with ADC Legal Services. "111e invoice for this is included as Exhibit C lo this motion
5
The charge was $173.40. There was no need to request the move the second contcmp
6 heaiing as it was set to be.heard at the same time as the first one. My pai·alegal, Kell"
7 Gomez, did email Mr.Gaul and did request to move the hearing so they could both b
8
heard at the same time without realizing that they were already calendai·ed for the sam
9
date and time.
JO
II
6. The nature and length of the professional relationship with the clienl: I have
12 professional relationship with Ms. Mclmddi. I run her attorney. I have been represcntin
13
Ms. Mebadcli since she was served with Mr. Rife's petition to modify tbe parties'
14
parenting plan.
15
7. The expc1ience, reputation and ability of the lawyer or lawyers pcrfonning the services
16
17 I have been practicing law since 1989 and I believe that .I have a good reputation.
18 8. Docs not apply.

19
9. The terms of the fee agreement between the lawyer and the client, including whether th
20
fee agreement or confirming writing demonstrates that the client had received
21
reasonable end fair disclosure of mate1ial clements of the fee agreement and of th
22
23 lawyer's billing practices: J believe that this was covered in the Declaration re Attome
24 Fees.
25
There is no red herring here. Ms. Mehnddi has never avoided service and she was no
26
avoiding se1vicc of the second motion for contempt. When the process sc1vcr came to the home an
27
28
VERONICA FREITAS
V. FIU>ITAS LAW, PLLC.
DECLARATION 210 Summit Avenue Ens!
Pngc-1 of6 Senllle, Wnshingtou 98102
(206) 328-7362
v@vfreltoslnw.com
Ms. Mchaddi was home, Ms. Mchaddi answered the door and took the papers. Ms. Mehaddi wa
2
not home during the alleged previous sc1vice attempts and was not aware of them until reviewin
3
Mr. Gaul's declaration.
4
Ms. De Voe did not see Ms. Mchaddi in her home on May 20111 • She went to the home an
6 the dog barked but no one came to the door. She did not see or hear anyone speaking or movin
7 around inside the home. Ms. Mehaddi bas a security, dead bolted, sto1m door. On wann days, sh
8
frequently leaves the interior door open and deadbolts the ·security storm door to allow for mo
9
ventilation. Ms. Mehaddi did not answer the door when Ms. DeVoe was there because she was no
10
II home.
12 When the process server came back on May 22nd and knocked on the door, Ms. Mehadd
13
opened the door and took the papers. She then went to her mother's house to scan the documents t
my office. While· she was there, Mr. Scott Romano, another one of Mr. Gaul's clients, came to Ms
15
Holland's (Ms. Mchaddi's mother) home and began yelling and banging on the door. He then bega
16
17 banging on Ms. Holland's car and was trying to open the cm· doors as she was driving away. Thi.
18 was unreasonably aggressive and very frightening for Ms. Holland. Mr. Romano never identific
19.
himself and did not disclose that he was attempting to deliver documents. It was reasonable for Mr
20
Holland to call the police. There was nothing histrionic about Ms. Mehaddi's or the Hollands'
21
response
22
23 Mr. Rife was ordered to pay Ms. Mehaddi 's fees associated with the contempt motions ..
24 Mr. Gaul objected to my fees then the court ordered that the matter would be dctennined on
25
family law motion. I provided my declaration re attorney fees and Mr. Gaul objected so I noted thi
26
motion. My fees responding to the motions rue ve1y rca~onable. The $1,000.00 that Mr. Gaul i.
27
28
VERONICA FREITAS
V. FREITAS LAW, PLl.C.
Page 5 of6 Sentlle, Wnshlngton 98102
(206) 328-7362
v@\'frcitnshnv.con1
offering is not nearly enough to cover the fees and costs associated with responding to the molions
2
I have requested nn additional $1,000.00 lo cover the additional time that is being spent drafting
3
noting, replying and appearing for this motion lo obtain the fees for Ms. Mehaddi that the court ha
already ordered Mr. Rife to pay. Ms. Mehaddi should not have to spend any money in order to gc
5
6 Mr. Rife lo pay the nllomey fees that he was ordered lo pay.
7 I declare under penalty of pe1jury pursuant to the laws of the Stnle of Washington that th
8
contents of the letters nre true and com:ct lo the best of my knowledge.
9
10
DATED this:i,\.,,,_Day of L~4--' 2014 at Sc::.-.vt-c. , Washington.
II
12
13
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VERONICA FREITAS
DECLARATION 210 Summll Avenue Easl
l'ogc 6 of6 Scntllc, Washlnglon 98102
(206) 328· 7362
v@vfrcilaslaw.eom
I r ,._
11111111111111111~1111~11111~"~mm11111~
CL16785440
SUPERIOR COURT OF
WASHINGTON ...
,..•_•
....
, \.
I
FOR SNOHOMISH COUNTY • I j L
CAUSE NO.: 05-3-02755-1

ANDREW RIFE COMMISSIONER: LEE B. TINNEY
(PETITIONER) CLERK: MEGHAN WRIGHT/
MELODY STEWART
AND DATE: 7-24-14 @ 9:00 A.M.
JENNIFER RIFE NKA MEHADDI DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: MOTION FOR ATTORNEY FEES

ACTION:
PETITIONER APPEARED: NOT PRESENT COUNSEL: CARL GAUL
DOCIJMENTS FILED:
ORDERS ENTERED: ORDER RE: ATTORNEY FEES AND COSTS
THE COURT FINDS THE AMOUNT OF ATTORNEY'S FEES AND COSTS OF $2,749.13
TO BE REASONABLE AND ORDERS THAT AMOUNT BE PAID BY RESPONDENT.
1
21lo
MINUTE ENTRY
• I FILEi
2
201~JUL 24 ~:· 11: 2ri
3
SOHY .. :
1~1m1m1~1~m11~~m11~111~~1111
4 '.:c:_,;-iJ Y C.L :.i'. \
. .·~·~.·-;:·: : r.\ \·.-·i' ~
5
CL16785422
6
7
8
County of Snohomish
9
Inre:
IO
11 Petitioner,
Order're: Attorney Fees and Costs
and
13 JENNIFER MEHADDI (flea Jennifer
Rife),
14 Respondent.
15
I. Judgment
16
17 A. Judgment creditor Jennifer Rae Mehaddi

18
B. Judgment debtor Andrew Rife
C. Principal judgment amount $ 3,949.23
19 D. Interest to date of judgment $Q
E. Attorney fees $ 3.568.75
20 F. Costs $ 247.80
21
G.Attorney fees, costs and other recovery amounts shall bear interest at 12 % pe
annum
22 H. Attorney for judgment creditor: Veronica Freitas
I. Attorney for judgment debtor : Carl Gaul
23
24
25
26
27
28
VERONICA FREITAS
Order-Page J of2 210 Summit Avenue East
Seattle, Washiogtoo 98102
(206) 328-7362
v@vfreitaslaw.com
.•
, I
II. Order
2
THIS MATTER having come on regularly before the Court upon Petitioner's Motions for
3 Contempt and the Respondent's Motion re Attorney Fees and the Court having reviewed the files
4 and records herein and heard argwnent of counsel, and deeming itself fully advised, now,
5 therefore,
6 IT IS HEREBY ORDERED AS FOLLOWS: "2. 7 41 >
;2--
7
I. Respondent shall pay V. Freitas Law, PLLC $6,749.2;1 for the Respondent's
legal fees within ten days. A judgment for said $21,719.23 shall enter in favor of Jennifer Rae
r.es.ptt7e!e,J,2 149 · ,_ 1
8
Mehaddi. aM.d ~~ cu.M..sf
9
~
10 '
Dated: -----'--JU.:_L_2_'t_20_14_ __
II
.hldge/Commissioner
12
13
14 Presented by:
15
16
17 vJonica Freitl!S:WS9A No. 19405
18
19
Approved for Entry
20
21
22
23
'
24
25
26
27.
28
VERONICA FREITAS
Order- Page 2 of 2 210 Summit Avenue East
(206) 328-7362
v@vfreitaslaw.com
F~LED
201~ AUG 15 AH 9: 25
smlYA i\RASKI
COUHTY CLERK
SNOHOMISH CO. WASH
IN THE SUPERIOR COURT, IN AND FOR THE COUNTY OF SNOHOMISH, STATE OF WASHINGTON
IN RE: ANDREW SCOTT RIFE Cause No.: 05-3-02755-1

Plaintiff/Petitioner Hearing Date: 08/26/2014
vs.
JENNIFER RAE MEHADDI F/K/A RIFE DECLARATION OF SERVICE OF
Defendant/Respondent NOTICE OF DEPOSITION UPON ORAL EXAMINATION;
SUBPOENA IN A CIVIL CASE
The undersigned hereby declares: That s(he) is now and at all times herein mentioned was a cttizen of
the United States, over the age of eighteen, not an officer of a plaintiff corporation, not a party to nor
interested in the above entitled action, and is competent to be a witness therein.
On the 14th day of August, 2014 at 10:54 AM at the address of 14200 69TH AVE SE #A.S,
SNOHOMISH, Snohomish County, WA 98296; this declarant served the above described documents
upon SOUFYANE MEHADDI by then and there personally delivering 1 true and correct copy(ies) thereof,
by then presenting to and leaving the same wtth SOUFYANE MEHADDI, Who accepted service, with
identity confirmed by verbal communication, a Middle Eastern male approx. 35-45 years of age,
5"10'"-6'0'" tall, weighing 160-180 lbs with black hair ..
No information was provided or discovered that indicates that the subjects served are members of the
United States military.
Service Fee Total: $ 79.50
Declarant hereby states under penalty of perjury under the laws of the State of Washington that the
statement above is true and correct.
DATED this 14th day of August, 2014
Katherine Devoe, Reg.# 2013-39, Snohomish County
ORIGINAL PROOF OF SERVICE

PAGE10F1 Tracking#: 000434J.U3
Illllll lllll lllll lllll lllll 111111111111111111111111111111111

..,
I
FILED
201~ AUG 19 Pff 3: 51f
\\ll~ll\\\i\11\\\111
CL16974221
SONYAJRA~I
· COIJtlT1 C(E J(
SllOllOHISH CO. ASH

IN AN[) FOR THE COUNTY OF SNOHOMISH
In re: /' )
A-"'dr-<-v Scsff {(;+<- ) No. 05-3-02755-1
Petitioner. )
vs. fVkc...A,· ) CERTIFICATE OF COMPLETION
~.1.. ,,..:-fl-v R~Re$po~nt,
... ) OF PARENTING SEMINAR
-P/k/o/ R_ ,-f.<_
THIS CERTIFIES THAT
Andrew Rife
HAS COMPLETE[):
FOR THE KIDS' SAKE: A PARENTING SEMINAR
[)ate: August 16, 2014

FILED
2
·201~ AUG 28 AH 10: I+ I
3 SOHYA KRASKI
COUHTY Cl.ERK
\\~~\\\~~\lll\\~lll~~~\
s
CL16947211
6
7
8
County of Snohomish
9
In re:
10
ANDREW SCOTI RIFE, No. 05-3-02755-1
II
Petitioner,
12 and Respondent's Submissions
Pursuant to ER 904
13 JENNIFER MEHADDI fka RIFE,
14
Resnondent.
IS
Jennifer Mehaddi, by and through his attorney of record, Veronica Freitas, submits the
16
documents set forth in Exhibit A and attached hereto, pursuant to Evidence Rule 904(b).
17
18
Respectfully submitted this 26 August 20 I 4.
19
20
21
22 Veronica Freitas, WSBA No. 19405

23
24
25
26
27
28
Respondent'.< S11hmiS.<ions Pursuant to ER 904 VERONICA FREITAS
Page I ofl V. FREITAS LAW, PLLC.
210 Summit Avenue Eost
Seattle, Washington 98!02
(206) 328-7362
v@vf...,itoslaw.com
Rife/Mehaddi
904 Exhibit A '
:~ii!; r, :·:::.~~~.:r.·~--~\ _::q~cgp~oA::~~:~~~~.. ·: .· .· ::·, -..:·.~~-=-,Q~t-~:{~I-~ :.- ~ . :_ -~-~- ~~---· '_t:'}M.iffli:.:_.:~.~--:~1 ~-: •'-:-. ·::;;i -~{~,!:i::: .·_.- o_ :..M~~.E,?~-:-~~-t!']> ....: '. :-'Teiepii,onf·::
I Mehaddi Psychological Evaluation 18-Aug-14 Daniel J. Rybicki, Psy.D., DABPS Harbor, WA 98335 253-858-8850
2 Sealed GAL Report 23-Mar-13 Elise Buie 98115 206-769-7173
3 Sealed Supplemental Gal Report 26-May-14 Elise Buie 98115 206-769-7173
1106 Columbia Ave, Suite 100,
4 Rife Psychological Evaluation 13-0ct-05 F outaingate Marysville, WA 98270
5 2011 Mehaddi Tax 2011 IRS

Transcription of June 13, 2014 355 SW Alaska St. 2nd Fl, Seattle, 206-682-1427
8 Contempt Hearing I l-Aug-14 Rough and Associates WA98126
Snohomish County Public Utility 2322 California St. Everett, \VA
9 Rife Earnings Statement Varies District 98201 425-258-8213
Snohomish County Public Utility 2320 California St. Everett, WA
IO Rife Employment Offer 4-0ct-99 District 98201 425-258-8211
Snohomish County Public Utility 2321 California St Everett, WA
II Rife Performance Evaluation Review Varies District 98201 425-258-8212
12 Rife Time Reporting 16-May-14 District 98201 425-258-8213
13 Rife W2 Varies District 98201 425-258-8213
3000 Rockefeller Ave. Everett, WA 425-388-3769
14 Incident Report 23-May-14 Snohomish County Sheriffs Office 98201
Mehaddi's Paystub- Swedish Medical
15 Group Varies Swedish Medical Group PO Box 389672 Seatt;e. WA 98138
16 Lauren's Counseling Records Varies The Everett Clinic 3902 Hoyt Ave. Everett, WA 98201 (425) 259--0966
17 Lauren's Medical Records Varies The Everett Clinic 3901 Hoyt Ave. Everett, WA 98201 (425) 259--0966
MD Phone Calls notes TEC Medical
18 Records Varies The Everett Clinic 3903 Hoyt Ave. Everett, WA 9820 I (425) 259--0966
v. Freitas Law
Seattle, WA 98102
.
\
Rife/Mehaddi
;-_
904 Eichibit A ..
19. Meliaddi's Paystub ~PolyCliniC. Varies. The PolyClinic 1(45 Broadway Seattle, WA 98122
Meliaddi's Pay5tub --WashingtOn 11911 ~ l32nd St. Ste 200
20. Urology Associates, Inc Varies ' Wasington urology.Associates, Inc Kirkland, WA 98034 425-453-2827
'!f:-F!eitas Law
Seattle, WA 9S102
0
...
FILED
2tl~ OCT -I AH 11 1 20
2
SONYA KRASKI
3 COUIHY ClERK
SNOHOMISH CD. WASH
4
s lllHllllDllllllllWllmH~
CL16980747
6
7
9 In re: No. 05-3-02755-1
10
ANDREW RIFE, AGREED ORDER STRIKING
II Petitioner, TRIAL DATE AND SETTING OVER
and FOR BINDING ARBITRATION
12
JENNIFER MEHADDI (flea Jennifer Rife),
13
Res ndent.
14
13
ORDER
16
This matter having come before the undersigned Judge in the above entitled court based upon the
17
agreement of the parties; the court having reviewed the files and records herein and being fully advised in
18
the premises, it is no therefore
19
ORDERED ADJUDGED AND DECREED that the current trial date in this case of October I,
20 2014 is hereby stricken based upon the agreement of the parties and, based upon further agreement of the
21
parties, the matter shall be scheduled for binding arbitration with Wayne Pellegrini at a mutually agreed-
22 upon date of November 4, 2014.
L
23
{pi/J.Ja
;()_
24
Done in open court this day of '2014.
25
26
27
28
Agreed Order Striking Trial Date and Setting Over for VERONICA FREITAS
Binding Arbitration V. FREITAS LAW, PLLC.
210 Summit Avenue Eost
Pllj!e I of2 Seattle, Washington 98102
(206) 328-7362
v@vfreitaslaw.tom
.,
I,,
Presented by:
2
3 nC\.A---
4 Attorney for Petitioner
5
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Agreed Order Striking Trial Date and Setting Over for VERONICA FREITAS
Binding Arbitration V. FREITAS LAW, PLLC.
Page 2 of2 Seattle, Washington 98102
(206)328-7362
v@vfreitaslaw.com
FILED
ZOii HAR 23 AH II: 36
SUPERIOR COURT OF SONYA KRASKI
FOR SNOHOMISH COUNTY SNOHOMISH CO. WASH
ANDREW S. RIFE CAUSE NO.: 05-3-02755-1

(PETITIONER) COMMISSIONER: TRACY G. WAGGONER
AND CLERK: L. MORGAN
JENNIFER R. RIFE DATE: 03/23/11 EX PARTE AM
THIS MATTER CAME ON FOR: DISSOLUTION - EX PARTE

ACTION:
PETITIONER APPEARED: YES COUNSEL: PRO SE
DOCUMENTS FILED:
ORDERS ENTERED:
THE PETITIONER IS ADVISED HE NEEDS TO FILE A PETITION FOR MODIFICATION
OF THE PARENTING PLAN; UNTIL HE DOES, THE COURT DOES NOT HAVE JURISDICTION TO
MODIFY THE PARENTING PLAN OF NOVEMBER 7, 2006.
1 MINUTE ENTRY
FILED
2011 HAR 25 PM ~: 13
SONYA KRASKI
COUNTY CLERI~
SNOHOMISH CO. \'/ASH
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll
CL 14677251

County of
No. as - 5 - e::. z. 7 <;;;::; - 1-

Order Re
Petitioner,
Modification/Adjustment
and
Of Custody Decree/Parenting
.Je_,.,..,, t='u ~ L,. S<Jwrcl Plan/Residential Schedule
(Ft.A)- \2· Res ondent. (ORMDD/ORDYMT)
I. Basis
This order is based on:
[l a finding that adequate cause had been established for hearing the petition.
N' an agreement of the parties.

an order of default signed by the court on this date or d a t e d - - - - - - - - - - - - -
II. Findings
The Court Finds:
2.1 Jurisdiction
This court has jurisdiction over this proceeding for the reasons below.
)q 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.
,k This state is the home state of the children because:
the children lived in Washington with a parent or a person acting as a parent for at
least six consecutive months immediately preceding the commencement of this
proceeding. (! F:·' GI NAL
Ord Re Mod/Adj of Parenting Pin (ORMDD, ORDYMT) - Page 1 of 7 ~ ''
WPF DRPSCU 07.0400 Mandatory (612008) - RCW 26.09.260; .270; 26.10.200
,<\!
[] the children are less than six months old and have lived in Washington with a
parent or a person acting as parent since birth.
[] any absences from Washington have been only temporary.
[] Washington was the home state of the children within six months before the
commencement of this proceeding and the children are absent from the state but a
parent or person acting as a parent continues to live in this state.
[] The children and the parents or the children and at least one parent or a person acting as a
parent have significant connection with the state other than mere physical presence, and
substantial evidence is available in this state concerning the children's care, protection,
training and personal relationships, and:
.!>!:' The children have no home state elsewhere.

[] The children's 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.
;M- 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, are 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 state's jurisdiction
over the children shall last until ( d a t e ) _ · - - - - - - - - - - - - - - -
[] 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 26.27.201through26.27.221. 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.
[] Other:
2.2 Modification Under RCW 26.09.260(1 ), (2)
[] Does not apply.
Ord Re Mod/Adj of Parenting Pin (ORMDD, ORDYMT) - Page 2 of 7

[) The custody decree/parenting plan/residential schedule should not be modified because
none of the statutory reasons in RCW 26.09.260(1) and (2) 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
nonmoving party and the modification is in the best interest of the children and is necessary
to serve the best interest of the children. This finding is based on the factors below:
The parties agree to the modification.
The children have been integrated into the moving party's family with the consent
of the other party in substantial deviation from the decree or parenting
plan/residential schedule.
[l The children's environment under the custody decree/parenting plan/residential
schedule is detrimental to the children's 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.
[l The other party has been found in contempt of court at least twice within three
years because the person failed to comply with the residential time provisions in
the court-ordered parenting plan, or the person has been convicted of custodial
interference in the first or second degree under RCW 9A.40.060 or 9A.40.070.
The following facts, supporting the requested modi ft cation, have arisen since the decree or
plan/schedule or were unknown to the court at the time of the decree or plan/schedule:
r. c.-?ra-,J (
_r-o,::./.
,,,(_.._ f<~ n/?/"'c..
2.3 Modification or Adjustment Under RCW 26.09.260(4) or (8)
J>Y Does not apply.
[] The custody decree/parenting plan/residential schedule should not be modified because:

[)none of the statutory reasons in RCW 26.09.260(4) apply.
[ ] none of the statutory reasons in RCW 26.09.260(8) apply.
[] 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 children do not
Ord Re Mod/Adj of Parenting Pin (ORMDD, ORDYMT) ·Page 3 of 7
WPF DRPSCU 07.0400 Mandatory (612008) • RCW 26.09.260; .270; 26.10.200
reside a majority of the time would serve and protect the best interests of the children using
the criteria in RCW 26.09.191. The following facts support the request for modification:
[] 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.
2.4 · Adjustments to Residential Provisions Under RCW 26.09.260(5)(a) and (b)
~ Does not apply.
[] The custody decree/parenting plan/residential schedule should not be adjusted because

none of the statutory reasons in RCW 26.09.260(5)(a) and (b) 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. It is a minor modification in the residential schedule that does
not change the residence at which the children are scheduled to reside the majority of the
time and:
[] is not more than 24 full days in a calendar year.
[] 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 custody decree/parenting plan/residential
schedule impractical to follow.
2.5 Adjustments to Residential Provisions Under RCW 26.09.260(5)(c), (7), (9)
~ Does not apply.
This section only applies to a person with whom the child does not reside a
majority of the time who is seeking to increase residential time.
2.5.1 Parent subject to limitations under RCW 26.09.191(2) or (3)
[l The residential time of ( n a m e ) - - - - - - - - - - - - - - - - - - is not

subject to limitations.
[] The residential time of (name) is subject
to limitations. This parent [ ] has [ ] has not demonstrated a substantial change in
circumstances specifically related to the basis for the limitations.
WPF DRPSCU 07.0400 Mandatory (612008) - RCW 26.09.260; .270; 26. 10.200
2.5.2 Parent Required to Complete Evaluations, Treatment, Parenting or Other Gasses
[] (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.
The following facts show this parent [ ] has [] has not fully complied with such
requirements:
2.5.3 Adjustment to Residential Provision Under RCW 26.09.260(5)(c)
[] ·The custody decree/parenting plan/residential schedule should not be adjusted because

none of the statutory reasons in RCW 26.09.260(5)(c) apply.

substantial change in circumstances of [](parent's name) _ _ _ _ _ _ _ _ _ _ __
[] (child(ren)'s name(s)) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
- - - - - - - - - - - - - - - - h a s 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 at which
the children are scheduled to reside 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.
2.6 Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)

!'( Does not apply.
[] The custody decree/parenting plan/residential schedule should not be adjusted because
none of the statutory reasons set forth in RCW 26.09.260(10) apply.
[] The following nonresidential aspects of the parenting plan/residential schedule 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:
[ ·] Dispute resolution.
[] Decision making.
[] Transportation arrangements.
[] Other:

2.7 Substantial Change in Circumstances
(Complete this part if a modification or adjustment is based on paragraphs 2.2, 2.4,
2.5. 1, 2.5.3 or 2.6)
The following substantial change has occurred in the circumstances of either party or of the
children:
2.8 Protection Order
Does not apply.

The [ ] domestic violence [ ] antiharassment Order for Protection signed by the court on
this date or dated , is approved and incorporated
as part of these findings.
Ill. Order
It is Ordered:
[] The petition to modify/adjust the custody decree or parenting plan/residential schedule is denied.
[] The petition to modify/adjust the custody decree or parenting plan/residential schedule is granted.
The custody decree or parenting plan/residential schedule signed by the court on this dated or
dated , is approved and incorporated as part of this
order. This decree or parenting plan/residential schedule supersedes all previous decrees or
parenting plans/residential schedules.
[] Child support shall be modified in accordance with the custody decree or parenting plan/residential
schedule approved by the court. The order of child support signed by the court on this date or
dated , is approved and incorporated as part of this order.
This order of child support supersedes all previous child support orders.
. . . ,.
[) The parties shall comply with the [ ] domestic violence [ ] antiharassment Order for Protection
signed by the court on this date or dated , in this cause
number. The Order for Protection signed by the court is approved and incorporated as part of this
decree.
[] Other:
Dated: 3 / 2 '3 / / I .~ &: '9 L\l \I

\II~ issioner
Presented by: ~ /(,p--
Signa~orJiLaw;ftf BA No. Signature of Party or Lawyer/WSBA No.

l\NOta-ii'c..v VL-i=::P 3/ z 7 I(/
Print or Type Name {Date I Print or Type Name Date
~,vyj~ lwcuuJ Signature of Party or Lawyer/WSBA No.

Si tjre<;f P!:r L?wyer/WSB;,f<o.
'\./ nn1f14L U/l @Jr0::_
Print or Type Name Date Print or Type Name Date
Signature of Party or Lawyer/WSBA No.
Print or Type Name Date

\
FILED
201 llMR 25 PH ~: 13
SONYA KRASKI
COUHTY CLERK
Illl\lll ll\l\l Ill lllll l\l\l l\lll lllll lllll l\l\l l\l\l llll llll SNOHOMISH CO. WASH
CL 14677249

County of
In re the Parenting and Support of:
No. 05-3-02755-1
Lauren Emily Rife Child(ren)
Parenting Plan
Andrew Scott Rife Petitioner
[ ] Proposed (PPP)
and [ ) Temporary (PPT)
[ x) Final Order (PP)
Jennifer LeSourd "FKA" Jennifer Rife

Res ondent.
This parenting plan is:
[] the final parenting plan signed by the court pursuant to a judgment and order establishing
Residential Schedule/Parenting Plan/Child Support signed by the court on this date or
dated _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
[x ] the final parenting plan signed by the court pursuant to an order signed by the court on this date
or dated 1117/2006 , which modifies a previous parenting
plan or custody decree.
[] a temporary parenting plan signed by the court.
[] proposed by ( n a m e ) - - - - - - - - - - - - -
It is Ordered, Adjudged and Decreed:
Lauren Emily Rife 6

QR\G\NAL
Parenting Plan (PPP, PPT, PP)· Page 1of10
WPF PS 15.0600 Mandatory (612008) · RCW 26.26.375, 26.09.016, .181; .187; .194
II. Bases for Restrictions
2.1 Parental Conduct (RCW 26.09.191 (1 ), (2))
[ X] Does not apply.

[] The [ ) mother's [ ) father's residential time with the child(ren) shall be limited or
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:
[) 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.
2.2 Other Factors (RCW 26.09.191 (3))
[X] Does not apply.

[) The [ ) mother's [ ) father's involvement or conduct may have an adverse effect on the
child'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 child's psychological development.
[) A parent has withheld from the other parent access to the child for a protracted
period without good cause.
[] Other:
Parenting Plan (PPP, PPT, PP) - Page 2 of 10

WPF PS 15.0600 Mandatory (612008) - RCW 26.26.375, 26.09.016, .181; .187; .194
The residential schedule must set forth where the child(ren) shall reside each day of the year,
occasions, and what contact the child(ren) shall have with each parent. Parents are encouraged
individual needs of their family. Paragraphs 3. 1 through 3.9 are one way to write your
Paragraph 3. 13.
3.1 Schedule for Children Under School age.
[X ] There are no children under school age.

[] Prior to enrollment in school, the child(ren) shall reside with the [ ] mother [ ] father,
except for the following days and times when the child(ren) will reside with or be with
the other parent:
from (day and time) to (day and t i m e ) - - - - - - - - -

[ ] every week [ ] every other week [ ) the first and third week of the month [ ] the second
and fourth week of the month [ ] other:
from (day and time) to (day and time) _ _ _ _ _ _ _ __

[ ] every week [ ] every other week [ ] the first and third week of the month [ ] the second
3.2 School Schedule

Upon enrollment in school, the child(ren) shall reside with the [x ] mother [ ] father, except for
the following days and times when the child(ren) will reside with or be with the other parent:
from (day and time) Tuesday after school to (day and time) Wednesday morning,
dropping child off at school. The father shall have residential time every Thursday after school
until 7:30PM returning the child to mother's home.
[x ] every week [ ] every other week [ I the first and third week of the month [ I the
second and fourth week of the month [ ] other:
from (day and time) Friday after school to (day and time) Sunday at 7:00 PM returning
the child to mother's home.
[] every week [x ] every other week [ ] the first and third week of the month
[] the second and fourth week of the month [ ] other:

[) The school schedule will start when each child begins [ x) kindergarten [ ) first grade
[ ) other:
3.3 Schedule for Winter Vacation
The child(ren) shall reside with the [ x) mother [ ] father during winter vacation, except for the
following days and times when the child(ren) will reside with or be with the other parent: The
residential schedule applies for winter breaks, unless vacation is requested thirty (30) days in
advance by email.
The child(ren) shall reside with the [x) mother [)father during other school breaks, except for
Residential schedule applies, unless vacation is requested thirty (30) days in advance by email.
3.5 Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the [ ) mother [ ) father,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
[) Same as school year schedule.

[x) Other: Residential schedule applies, with the exception of Tuesday pick up at 7:30am at
the mother's place of work returning the child Wednesday evening at 7:30pm. Thursday
pick up of child up at the mother's place of work at 7:30am. and retume to mother's
home at 7:30 PM.
[) Does not apply.

[x ) The schedule for vacation with parents is as follows: Mother and Father will each have
three (3) weeks of vacation per year. Each parent shall submit their vacation request, by
email, thirty (30) days in advance.

3.7 Schedule for Holidays
The residential schedule for the child(ren) for the holidays listed below is as follows:

New Year's Day EVEN ODD

Martin Luther King Day EVEN ODD
Presidents' Day EVEN ODD
Memorial Day EVERY
July 4"' EVEN
Labor Day EVERY
Veterans' Day EVEN <i \J I~
Thanksgiving Day EVEN o\JQ
Christmas Eve EVERY
Christmas Day EVERY
[x ] For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times): I lam and return the child to the other parent at 7pm the same day.
[] Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
[] Other:
The residential schedule for the child(ren) for the following special occasions (for example,
birthdays) is as follows:
Mother's Day EVERY_ _ _ _ _ __
Father's Day EVERY- - - - - - -
Mother's Birthday_ _ _ __
Father's Birthday_ _ _ _ __
[] Other:
3.9 Priorities Under the Residential Schedule
[] Does not apply because one parent has no visitation or restricted visitation.
[] Paragraphs 3.3 - 3.8 have priority over paragraphs 3.1 and 3.2 in the following order:
Rank the order of priority, with I being given the highest priority:
_4_winter vacation (3.3) _3_holidays (3.7)

_5_school breaks (3.4) _6_special occasions (3.8)
_2_summer schedule (3.S) _ I _ vacation with parents (3.6)
[ x) Other: By agreement
3.1 O Restrictions
[x ) Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
[) The [ ) mother's [ ) father's residential time with the children shall be limited because
there are limiting factors in paragraphs 2.1 and 2.2. The following restrictions shall
apply when the children spend time with this parent:
[] There are limiting factors in paragraph 2.2, but there are no restrictions on the
[)mother's [)father's residential time with the children for the following reasons:
Transportation costs are included in the Child Support Worksheets and/or the Order for Child
Transportation arrangements for the child(ren) between parents shall be as follows: By
agreement of the parties.
The children named in this parenting plan are scheduled to reside the majority of the time with
the [ x) mother [ I father. 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 parent's rights and responsibilities under this
parenting plan.
3.13 Other
Parenting Plan (PPP, PPT. PP) - Page 6 of 10

3.14 Summary of RCW 26.09.430 - 480, Regarding Relocation of a Child
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
A relocating person may ask the court to waive any notice requirements that may put the health
confirmed.
IV. Decision Making
4.1 Day to Day Decisions
the child is residing with that parent. Regardless of the allocation of decision making in this
children.

4.2 Major Decisions
Education decisions [I mother [I father [x) joint

Non-emergency health care [I mother [I fattier [x) joint
Religious upbringing [I mother [I father [x) joint
[l mother [I father [l joint
[l mother [I father [l joint
[l mother [I father [I joint
[l mother [l father [l joint
[I mother [I father [l joint
[I mother [l father [l joint
4.3 Restrictions in Decision Making
[x ) Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.
[) Sole decision making shall be ordered to the [ ) mother [ ) father for the following
reasons:
[) A limitation on the other parent's decision making authority is mandated by

[) Both parents are opposed to mutual decision making.
[] One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a) The existence of a limitation under RCW 26.09.191;

(b) The history of participation of each parent in decision making in each of
the areas in RCW 26.09.184(4)(a);
(c) Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in RCW
26.09.184(4)(a); and
(d) The parents' geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
[) There are limiting factors in paragraph 2.2, but there are no restrictions on mutual
decision making for the following reasons:

"
V. Dispute Resolution
the provisions of this plan must, be used before filing a petition to modify the plan or a motion
Disputes between the parties, other than child support disputes, shall be submitted to (list person
or agency):
[l counseling by , or
mediation by Vol
11vtUe.vf- o{! 4W\LV'iCµ , if this box is checked and
issues of domestic violence or child abuse are present, then the court finds that the victim
requested mediation, that mediation is appropriate and that the victim is permitted to
have a supporting person present during the mediation proceedings, or
[) arbitration by_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
The cost of this process shall be allocated between the parties as follows:
[l _ _ _ _ _ % mother % father.
based on each party's proportional share of income from line 6 of the child support
:K worksheets.
[l as detennined in the dispute resolution process.
The dispute resolution process shall be commenced by notifying the other party by [ ) written
request [ ) certified mail [ ) other:

(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.
and of each arbitration award and shall be provided to each party.
without good reason, the court shall award attorney's fees and financial sanctions to the
other parent.
(e) The parties have the right of review from the dispute resolution process to the superior
court.
Parenting Plan (PPP, PPT, PP) - Page 10 of 10 .

r ~ · t ·. .
[) There are no other provisions.

[ x) There are the following other provisions: Either parent may take the child out of the state of
Washington for the purpose of vacation. The Mother or Father SHALL NOT obtain a passport
for the child for any foreign travel. The Father and Mother shall have first right of refusal if
more than four (4) hours of childcare is required. The Mother agrees to NEVER seek an increase
in child support from Father. The Father agrees to pay one roundtrip airline ticket to Algeria, not
to exceed $2,000.00 USO. Only once. If the Mother is unable to travel to Algeria, the Father
shall pay the change ticket fee for Mother to travel to another destination. The Child shall reside
with the Father for two (2) weeks while the Mother's boyfriend from Algeria is in the country.
The Mother shall have visits with the child on Tuesday's and Thursday's from after school until
7:30PM. This two (2) weeks is onJy whenJ1ier's.b9JYfriend first Mfives ti this c9unq-y. /,ul
Thts .;2wulu ft; )11f!i«d1 I w nd'jrtJff' pri {}ffL'- SC to/ 'fO w~ ~J
VII. Declaration for Proposed Parenting Planlln I 3pm·yt' ~
[x) Does not apply.
[] (Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under the laws
of the state of Washington that this plan has been proposed in good faith and that the statements
in Part II of this Ian are true nd correct.
Date and Place (City and State) of Signature

"31!7111 2u~. UM
I '
Date and Place (City and State) of Signature

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 order may subject a violator to arrest.
When mutual decision making is designated but cannot be achieved, the parties shall make a good faith
~fa parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
MAR 2 5 ZOll
Dated:__,,'----------------
missioner
Parenting Plan (PPP, PPT, PP) · Page 11 of 10

' ... . "; ..
Signature of Party or Lawyer/WSBA No. Signature of Party or Lawyer/WSBA No.
Print Name Print Name

FILED
•.·
Soohomish !'mlty SUPerior r.oort

FILED SonYa Kraski
!'.culty Clerk
Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll l \11111 ZOii HAR 25 PH I: 40 Everett WA
CL 14761278 SONYA KRASKI 05-3-02755-1
COUNTY CLERK
SNOHGHISH CO. WASH Rait. Date Acct. Date Tile
03125/2011 03/25/2011 12:54 PM
ReceiPt/Item n Tran-l'.ode Docket-!'.OOe
2011-01-<Y/065/0l 1104 m
Cashier: AXD
Paid BY: rife, andrew
County of Snohomish Tr<rlSaetion Amount: $56.00
lnre: ?~~tr~ of~ c,_.,..,fy Off
No.
,[\.~·"Q?vJ S.<.Jlt \'2.\~
f"'Y-U Petitioner,
Summons(Modification/
and Adjustment of Custody
Decree/Parenting Plan/
Respondent. . Residential Schedule)
SM
To:
1. An action has been started in the above court requesting that a custody decree/parenting
plan/residential schedule be modified/adjusted. Additional requests, if any, are stated in the
petition, a copy of which is attached to this notice.
2. You must respond to this notice and petition by serving a copy of your written response on the
person signing this summons and by filing the original with the clerk of the court. If you do not
serve your written response within 20 days (or 60 days if you are served outside of the state of
Washington) after the date this summons was served on you, exclusive of the day of service, the
court may.enter an order of default against you, and the court may, without further notice to you,
enter an order regarding adequate cause and a decree to modify/adjust the custody
decree/parenting plan/residential schedule and providing for other relief requested in the petition.
If you serve a notice of appearance on the undersigned person, you are entitled to notice before
an order of default or a decree may be entered.
3. The court shall deny the petition unless it finds that adequate cause for hearing the petition is
established, in which case it shall set a date for hearing on an order to show cause why the
requested order or modification should not be granted.
[] 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.
Summons Mod/Adj Parenting Plan (SM) - Page 1 of 2

WPF DRPSCU 07.0120 Mandatory (712007)- CR 4.1; RCW26.09.270; 26.10.020
..
4. You may file an opposing declaration to show that there is not adequate cause to hold a full
hearing. If you do not file an opposing declaration or respond and the court finds that adequate
cause exists, the court may enter an adequate cause order and an order modifying/adjusting the
custody decree/parenting plan/residential schedule without notice to you pursuant to RCW
26.09.270.
5. Your written response to the summons and petition must be on form WPF DRPSCU 07.0200,
Response to Petition for Modification/Adjustment of Custody Decree/Parenting Plan/Residential
Schedule. This form may be obtained by contacting the clerk of the court at the address below,
by contacting the Administrative Office of the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
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 of this notice and motion will be void.
7. If you wish to seek the advice of an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time.
8. One method of serving a copy of your response on the petitioner is to send it by certified mail
with return receipt requested.
This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state of Washington.
Dated: 3/2-:>/tr
I (
Print Name
File original of your response with Serve a copy of your response on:
the clerk of the court at:
[ ] 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 Party's Lawyer
Snohomish County Clerk

[Name]
MS 605 3000 Rockefeller
[Address]
Everett. Washington 9820 I
Summons Mod/Adj Parenting Plan (SM) - Page 2 of 2
WPF DRPSCU 07.0120 Mandatory (712007)- CR 4.1; RCW26.09.270; 26.10.020
•

County of
Inre: F'A-r"'--.\i.".'.J i Lcu.ul'(,-.J °V'•·Ltr 1r,r. . . . No. O'S- 3 - o~ I SS-- "'.'.l_
Petition for Modification/

Adjustment of Custody Decree/
Parenting Plan/Residential
Petitioner, Schedule
and (PTMD)
0.i,,<..MtJ. Para. 2.14: check box if petition is

attached for:
[ ] Order for protection DV (PTORPRT)
Respondent. Order for rotection UH PTORAH
1.1 Identification of Requesting Party/Parties
Name (first/last) ffeo(l.<;""1 S.~o /¢ /2 I,:;_ Birth date "J/z-zjt f7.J

Last known residence (county and state only) L-•. .k.>bm~', L, co,_,,. ..y . 44fL-.
Name (first/last) ,.J"''-R......,,iJl'-'=:...t"'-F--'"''-'l'"---V-"-'."'5-"o-"l.<.A=J"-------- Birth date 08/!Et/

I 7
lz ?('
Last known residence (county and state only)--=...J..:...;v.....:<l"'-~=.:C!.'::::':L.=-__,,('..::",,:;Vl>:c"'!...±Jc.+--tv-,4.............:.·_.
1.2 Identification of Other Party/Parties

Name (first/last) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Birth date_ _ _ _ _ __
Last known residence (county and state only)_ _ _ _ _ _ _ _ _ _ _ _ _ .
Name (first/last) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Birth date _ _ _ _ __
Last known residence (county and state o n l y ) - - - - - - - - - - - - - - ·
Name (first/last) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Birth d a t e - - - - - -
Last known residence (county and state o n l y ) - - - - - - - - - - - - -

Pet for MocVAdj Parenting Pin (PTMD) - Page 1 of 11
WPF DRPSCU 07.0100 Mandatory (612008)- CR 4.1; RCW 26.09.181; .260; .270
1.3 Dependent Children
Name (first/last) L~10 ~"·41 \< ... &_ Age
Name (first/last) Age
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 in this matter and approving the proposed parenting plan/residential schedule, which is
fi/ed with this petition.
2.2 Adequate Cause

' ,.
There is adequate cause for hearing the petition for modification.
2.3 Child Support
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.
2.4 Jurisdiction and Venue
The court has proper jurisdiction and venue.
The requesting party/parties reside(s) in (county and state only) - - - - - - - - - - - -
The children reside in (county and state o n l y ) - - - - - - - - - - - - - - - - - -
The other party/parties reside(s) in (county and state o n l y ) - - - - - - - - - - - - - -
Pet for Mod/Adj Parenting Pin (PTMD) - Page 2 of 11

WPF DRPSCU 07.0100 Mandatory(612008) - CR 4.1; RCW 26.09.181; .260; .270
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 made a child
custody, parenting plan, residential schedule or visitation determination in this matter and
retains jurisdiction under RCW 26.27.211.
[l This state is the home state of the children because:
the children lived in Washington with a parent or a person acting as a parent for at
proceeding.
[l the children are less than six months old and have lived in Washington with a
parent or a person acting as parent since birth.
[l any absences from Washington have been only temporary.
[l 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 children's care, protection,
training and personal relationships, and:
~ The children have no home state elsewhere.

[] The children's 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 exe~cise 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 state's 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

WPF DRPSCU 07.0100 Mandatory(612008) - CR4.1; RCW 26.09.181; .260; .270
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.
[] Other:
2.6 Uniform Child Custody Jurisdiction and Enforcement Act Information
Name of Child Parent's Name Parent's Name

L~ £ ..... :I.{ 12'-i=; ~o<-C:V (2 \. fi
in no place other than the state of Washington and with no person other than the requesting
party or the other party.
[l 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:
M 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.):
Involvement in any other proceeding concerning the children:
~ 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):

WPF DRPSCU 07.0100 Mandatory(6/2008)- CR4.1; RCW 26.09.181; .260; .270
Other legal proceedings concerning the children:
)>4' The requesting party does not know of, any other legal proceedings concerning the
children.
[] The requesting party knows of, the following legal proceedings that concern the children
(list the children concerned, the court, the case number, and the kind of proceeding):
2.7 Custody Decree or Parenting Plan/Residential Schedule
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 Modification Under RCW 26.09.260(1), (2)
[] 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.
[l 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.
[l The children's environment under the custody decree/parenting plan/residential

schedule is detrimental to the children's 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.
[l The other party has been found in contempt of court at least twice within three
years because the party failed to comply with the residential time provisions in the
court-ordered parenting plan, or the parent has been convicted of custodial
interference in the first or second degree under RCW 9A.40.060 or 9A.40.070.
2.9 Modification or Adjustment Under RCW 26.09.260(4) or (8)
[] Does not apply.
[] 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
Pet for ModiAdj Parenting Pin (PTMD) - Page 5 of 11
WPF DRPSCU 07.0100 Mandatory(6/2008) - CR4.1; RCW 26.09.181; .260; .270
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.
2.10 Adjustments to Residential Provisions Under RCW 26.09.260(5)(a) and (b)
}?( Does not apply.

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:
[] is not more than 24 full days in a calendar year; or
[] is based on a change of residence of the parent with whom the child does not reside
a majority of the time or an involuntary change in work schedule by a party which
makes the residential schedule in the parenting plan impractical to follow.
2.11 Adjustments to Residential Provisions Under RCW 26.09.260(5)(c), (7), (9)
J( Does not apply.
This section only applies to a person with whom the child does not reside a
majority of the time who is seeking to increase residential time.
2.11.1 Parent subject to limitations under RCW 26.09.191(2) or (3)
[l The residential time of (name) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ is not

subject to limitations.
Pet for Mod/Adj Parenting Pin (PTMD). Page 6 of 11
WPF DRPSCU 07.0100 Mandatory(6/2008)- CR4.1; RCW 26.09.181; .260; .270
[] 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)
[] The Custody Decree/Parenting Plan/Residential Schedule should be adjusted because a

substantial change in circumstances of (parent's n a m e ) - - - - - - - - - - - - -
or (child(ren)'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 non primary residential party.
2.12 Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)
.P( 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:
[] Dispute resolution.
[] Decision making.
[] Transportation arrangements.
[] Other:

WPF DRPSCU 07.0100 Mandatory(612008)- CR4.1; RCW 26.09.181; .260; .270
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 of the custody decree/parenting plan/residential schedule
is based upon the following substantial change in circumstance:
2.14 Protection Order
)<( Does not apply.

[] There is a protection order between the parties filed in case number-------•
court , which expires on ( d a t e ) - - - - - - - - -
[] The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this petition.
[ ] filed separately under [ ] this case number [ ] case number - - - - - - - - - ·
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
2.15 Servicemembers Civil Relief Act Statement
2.15.1 A. Service member status -- (name of other p a r t y ) - - - - - - - - - - - - -

[ ] is not a service member;
[] is on active duty in the U.S. armed forces (excluding National Guard and
reserves);

WPF DRPSCU 07.0100 Mandatory (612008) - CR 4.1; RCW 26.09.181; .260; .270
.. '
[ ] 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;
[] I am unable to determine whether the other party is or is not on active duty in the
U.S. armed forces;
[] I am 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 Defense Man Power Data Center Report obtained from
https://www.dmdc.osd.mil/scra/owa/home.
[ ] 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

National Guard member or a Reservist;
[] 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.
WPF DRPSCU 07.0100 Mandatory(612008)- CR4.1; RCW 26.09.181; .260; .270
2.16 Other
Ill. 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 matter and approving the
proposed parenting plan/residential schedule, which is filed with this petition.
[] The moving party also requests that the court:
[l 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.
[l Enter a domestic violence protection order.
[l Enter an antiharassment protection order.
[l Other:
i l
Date .
Date
3/J.3!11
I
correct.
Signed at (city) ~-RH i f 0,/1-~~- on (date) __3_,_,/~z.=3=+-/~/_(

, (state) __
r I
__
d~? ,/'fl/ 7Cc;-:g
•
Signature of Requesting Party
_h_v~w~df-----,,.,-----' (state)
[l Joinper ~
;r I, 0-lJ'lfl,j UMvJ ,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.

WPF DRPSCU 07.0100 Mandatory (612008)- CR4:1; RCW 26.09.181; .260; .270
•• •
[] 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,

served.
[] I waive notice of entry of the decree.

court clerk.
[] I, , join in the petition. I understand that by joining in the petition,

served.
[] I waive notice of entry of the decree.

court clerk.
Pet for ModiAdj Parenting Pin (PTMD) - Page 11 of 11

WPF DRPSCU 07.0100 Mandatory(6/2008)- CR4.1; RCW 26.09.181; .260; 270
..... El
'-••
I
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2 2r::11:ov-ti Mi 10: 33
1~~~m1~m11~10011111w~1~
3 sc;~y:., K;t/,SKI
COIJHTY CLERK
4 s:;cHOMISH co. WASH
CL17054592
s
6
7
County of Snohomish
8
In re:
9
10 Petitioner,
and Motion and Declaration re
II
Objection to Deposition
12 JENNIFER MEHADDI (flea Jennifer Rife),
13 Respondent.
14
IS I. Motion
16 The respondent, by and through her attorney of record, Veronica Freitas, objects to the
17 deposition of Elizabeth Buie and moves to quash the subpoena duces tecum.
18 II. Declaration
On October 29, 2014 my office was served with a Notice of Deposition (Records Only)
19
for Elizabeth Buie to be produced before November 7, 2014. Please see documents attached as
20
Exhibit 1. This case has settled, please see CR2A agreement attached as Exhibit 2. The parties
21
have settled on a parenting plan and the petitioner's attorney has drafted the agreed order per the
22
CR2A agreement, see Exhibit 3. The only issues remaining to be decided upon is Child Support
23
and any award of attorney's fees. That was agreed to be decided via arbitration. An Agreed
24 Order Striking Trial Date and Setting Over for Binding Arbitration was entered on October 1,
25 2014, see Exhibit 4.
26 Per Snohomish County Local Rule 26. General Provisions Governing Discovery (k) ... /n
27 any case brought under Title 26 R. C. W. discovery will be completed no later than the date of
28
VERONICA FREITAS
OBJECTION AND MOTION 210 Summit Avenue East
TO QUASH SDT Seattle, Washington 98102
(206) 328-7362
Pege I of2 v@vfreltoslaw.com
OR1G1NAL
confirmation required by Rule 40(d)(l). Trial for this case was set for October 1'1, per local rule
2 26, any discovery would have needed to be completed by September 19th. November 7, 2014 is
3 well past the discovery deadline.
4 There is no reason for the petitioner to subpoena these records as the parenting aspect of
s our case has settled. Regardless of settlement the petitioner is well past the discovery deadline
and this subpoena is inappropriate and I ask that this court quash the subpoena.
6
7
Respectfully submitted on November 3, 2014.
8
10
II
00/\----
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
28
VERONICA FREITAS
V. FREITAS LAW, PLL.C.
OBJECTION AND MOTION 210 Summit Avenue East
TO QUASH SDT Seattle, Washington 98102
(206) 328-7362
Page 2 or2 v@vfreltaslaw.com
EXHIBIT 1
V. F_REITAS LAW, PLLC

210 Summlt_)l.'!!!nue East, Seattle, Wf\98102 Itel• (206)328;7362 !tax• (20~)3_23-04.04
2
s
COUNTY OF SNOHOMISH
7
In re:
Petitioner,
9 NOTICE OF DEPOSITION
and
(Records Production Only)
10
JeMlrer Rae Mehaddl f/k/a Rife
11 1--~~~~~~~~--'-'Res=c=on~d~e~nt~• .__~~~~~~~~~~~~
12
EDzabeth "Ellse" Buie
Veronica Freitas, attorney for Jennlrer Rae Mehaddl ffk/a Rife
13 Elizabeth "Elise" Buie, Guardian ad Ut:em for Lauren Emily Rife
14 The deposition for records production only of the following-described person wlll be
taken on the fOllowfng date1 at the fOllowlng time and place, subject to continuance or
15
djournment form lime to tune:
16
WITNESS: Elizabeth "Ellse" Buie
17
DATE: November 7, 2014
18
TIME: 10:00 a.m.
19
PLACE: Law Office of earl J. Gaul
20
1604 Hewitt Avenue, Ste. 302
everett WA 98201
21
Note: This deposition Is for records production only. No pe
22
Dared: October 22, 2014
23 CARL J, GAUL WSBAH
Attorney for Andrew S
24
25
26
27 CARLJ.GAUL
At10n1t)' at Ltnv
302 Bank or Anierlca Bids.
. 1604 Hcwlll Avo.
llve,.H WA 98201
425 259·4147 FAX 259 7081
1
2
3
4
5
6 Issued hll the
7 SUPERIOR COURT FOR THE STATE OF WASHINGTON
SNOHOMISH COUNTY
8 Andrew Scott Rife
Petitioner CAUSE NUMBER: 05 3 02755 1
9 V&
Jennifer Rae Rife SUBPOENA IN A CIVIL CASE
10 Respondent For Records Production
11
12 0: Elizabeth "Elise" Buie
13 CR 45(c)(2)(A) provides:
14 A pemn commanded lo produce and permll lnspecUon and copying of daslgnalad books, papers,
documonls or langlbla things. or lnapecUon of premises need not appear In person al Iha place of
15 producllon or Inspection unless commanded lo appear for deposlllon, hearing or lrlal.
16 YOU ARE COMMANDED to produce and permit Inspection and copying of the
17 ollowlng documents or tangible things al the place, date, and time specllle<I below (llst
ocuments or objects):
18 Your entire file created and maintained as Guardian ad Lltem for Lauren
19 Emlly Rife In the above captioned matter, commencing Aprll 27, 2014
through the present.
20 All emall communlcallon related to the above CSP.lloned matter case,
21 regardless of date from the time of your appointment to the present.
22 An Itemized !Isling of amounts you have been paid, Including payor,

23 An Itemized llsllng of your lime billed, Including dates, lime Invested and
notes of service provlcfed.
24 To the extent these documents may exist In a digits! form especially small
25 and bllllng records, they are to be produced In an unencryp\ed dlgltal format.
26
27
26 CARLJ.GAUL
Altomay at Law
1604 HawHIAvo.
Everall WA 98201
425 259-41~7 FAX 259 7081
,•
1 Documents Y.OU are to produce Include all documents In ·your possession,

regardless whether they may be produced by you or by another lndlvtdual,
2 tnCludlng experts.
3 DATE November 7, 2014
LACE Law Office of Carl J. Gaul
4 1604 Hewitt Avenue, Ste 302 TIME 10:00 a.m.
Everett WA 98201
5
HEREIN FAIL NOT AT YOUR PERIL
6
DATED: October 22, 2014
7
8
9
10 Attorney for An row Scott Rife
11 302 Bank of America Bulldlng
1604 Hewitt Ave.
12 Everett WA 98201
4252594147
13
PROOF OF SERVICE
14
SERVED DATE PLACE
15 SERVED ON (PRINT NAME) MANNER OF SERVICE
16
17 SERVED BY (PRINT NAME) TITLE
18
DECLARATION OF SERVER
19
declare under penally of perjury under the laws of the Stale of Washington that the
20 oregolng Information contained ln the Proof of Service Is true and correct.
21
Executed on /...,...,...,..,_ __
22 ~/PLACE SIGNATURE OF SERVER
23
24
ADDRESS OF SERVER
25
26
27
CARLJ.GAUL
28 Attorney et Lnw
302 Bank or America Bldg.
1604 Hewlll Ave.
Everelt WA 98201
425 259·4147 FAX 259 7081
.. ..
1 CR 46, Sections (c) & (d): upon a requirement lhal lhe subpoenaing parllf l!dvan
(o) Proteallon of Persons Subject lo Iha reasonable cost or producing Iha books, papers
2 Subpoenas. documents, or lenglble !hinge.
3 (1) A parly or an allorney responsible for the (B) If a subpoena

Issuance and service of a subpoena shall lake (I) requires dlsclosura of a trade secrel or Olhs
4 roosanoblo steps lo avoid Imposing undue burden or conQdenllal research, developmenl, or commercial
expanse on a parson subjeol to lhat subpoena. The lnformallon, or
5 court shall enforce Ihle duty and Impose upon lhe (II) requires disclosure of an unralalned oxpert•e oplnlo
party or altorney In breach or Ihle duly en epproprlate or lnformellon nol describing specmo events o
6 asncUon, whlah may Include, bul la nal llmlled lo, losl ooourrsnoes In dlspula and rasulllng from the exparl=
earnings and a reasonable ellorney's fae. sludy made not al Iha roqueel or any party, lhe co
7 may, lo prolecl a person subject to or affeclsd by lh
{2)(A) A parson commanded to produce and permit subpoena, quash or modify Iha subpoena or, If Iha pert
8 lnapecllon and copying of designated books, papars. In whose behalf Iha subpoena Is Issued shows
documents or langlble lhlngs, or lnspecllon of subslanllal need for Iha lasllmony or malsrlel Iha
9 premises need nol eppeer In person al lhe place of cannot be olhsrwlse met wllhoul undue hardship e
producllon or lnspeallon unless commanded to assures lhal the person lo whom lhe subpoena I
10 appear for deposlllon, hearing or ldal. addre98sd wm ba. reasonably compensated, Iha co
may order appearance or producllon ontyupon spaclRs
11 (B) Subj eel to paragraph (d)(2) of lhfa rule, a person condlllons.
commanded lo produce and permll lnapacllon and
12 copying may, wllhln 14 days eRer service of (d) Dultse In Responding to Subpoena.
subpoena or before the lhne specIRed for compliance
13 If such lime ls less lhan 14 days aner service, serve (1) A person responding lo a subpoena lo produc
upon Iha party or altorney designated In lhe documenls shall produce lhsm as lhey are kepi In lh
14 subpoena wrltlen objection lo lnspacllon or copying usual course of business or shall organize and labs
of any or ell of the doslgnaled malerlela or of Iha lhem lo correspond wllh Iha oatugorlas In Iha demand
15 promises. If objacllon la made, Iha pelly serving lhe
subpoena shall not be anllllad lo Inspect end copy (2)(A) When lnformallon subject lo a subpoena I
16 the molorlals or lnapaat Iha pramlaas except wllhhsld on a claim that II Is prlvlleged or aubjeot t
pursuant lo an order or Iha court by which the protscllon as lrlal preparallon maferlale, Iha claim ehal
17 subpoena was Issued. If ob)ecllon has bean made, be made expressly and shall be supported by
lhe party serving Iha subpoena may, upon nollce lo desorlpUon of Iha nature of Iha documanls
16 ll1e p8/son commanded to produce and all other communrcallons, orlhlnga nol produced lhal la sufflclsn
parlles, move el any lime for an order lo compel Iha lo enable Iha demanding party to conlasl lhe claim,
19 production. Such en order lo compel production
shall prolsol ony parson who la nol a party or an (B) If Information produced In response lo a subpoen
20 o!Ocar of a party from slgnlQcanl expanse resulUng Is subject lo a clolm of prMlege or of prolecllon es lrlal
from lho lnspeollon and copying commanded. praparaUon malerlal, Iha person making lhe clelm ma
21 nollfy any party lhal received lhe lnformaUon or lh
(3)(A) On llmely motion, Iha court by which a clalm and Iha basis for II. ARer being noUOed, a part
22 subpoena was l98ued shall quash or modify Iha must promptly relurn, sequester, ordaslroylhespeclfts
subpoena If II: lnrormallon and any copies II hes; must not use
23 (I) rans lo allow reasonable lime for compliance; disclose Iha lnrormallon untn the clalm Is resolved; mus
{II) falls lo comply wllh RCW 5.68.010 or subsscllon teke reasonable alepe lo retrieve Iha lnlormallon If th
24 (e)(2) or this rule; party disclosed II before being noURed; and mo
(IU) requires disclosure of privileged or other promptly present lhe lnformallon In camera to lhe ccu
25 prolecled mallor and no axcapllon or wefver applies; for a dalermlnallon of Iha claim. The person respond In
or lo Iha subpoena must preserve the lnformallon unlll th
26 (Iv) subjects a person lo undue burden, provided clalm Is resolved.
lhal, lhe court may condlllon denlal of tho mollon
27
28 CARLJ.GAUL
Allomey al Law
302 Bank or America Bldg.
1604 Hewnt Ave.
Everall WA ge201
425 259-4147 FAX 259 7081
EXHIBIT 2 ' - . .

. 210 S~mmit Avenue .East, Seattle.-WA 98102 ·I tel• (206)328-7362 Ifax• (206)323-0404
-
"
1•.;
s
6
Superior Com·t of Wnshlngton
8 In re:
9 ANDREW RIPE, No. 05·3·02755·1
Petllioner,
10 STIPULATED AGREEMENT
and
PURSUANT TO CR2(A)
II
JBNNIFBR MBHADDI (tka Jennifer Rife),
12 Res ondent.
13 THE FOLLOWING IS A PULL AND COMPLETB SEITLEMBNT STIPULATION

14 AND AORBBMBNT OP THE PARTIBS PURSUANT TO CR2A. UNLESS OTHERWISB
IS
AGRBBD ELSEWHERE IN THIS DOCUMENT, THB STIPULATIONS, TERMS AND
16
AGREEMENTS SHALL COMMENCE AND BB BNPORCBABLB UPON THB DATE THIS
17
18 INSTRUMENT IS SIGNED BY ALL PARTIBS.
19 STIPULATIONS
20
21 A. Each party agrees and stipuloles this is o liill ond completo agreement between the
22 pm11es and is enforceablo in com1. &oh party understands that even though final documents yet
23 need to be prepared this stip11latlcn and agreement is offectlve and binding upon execution and
24 enforceable in court. The pa1·1ies stipulate and ocknowledge THE TERMS SBT FORTH BELOW
2s HAVE BEEN KNOWINGLY AND VOLUNTARILY ENTERED INTO AND PURTHBR THB
CR2A STIPULATION AND AOREHMENT IYAYNB P. PBLL!!OR!NI

THIRDSTREHTNEDlATIDM
Page- I 1038 THIRD STREET
,.,.,. _Jjk- dtrJIPY MAllYSVIUE, WASHINOTON 1111210

(no}B~O• FACSIMILE (UO)BU0102
.:~
TERMS AND PARBNTINO PLAN SBT FORTH HERBIN ARE IN THE BEST INTEREST OP
2 THBCHILD.
3 8. Any disputes in tho drafting oflhe final documents sholl be submillcd to Wayne P.
4 Pellegrini for binding arbitmlion. (RCW 7.04A)
s I. CHILD SUPPORT
6 Not resolved through mediation.
1 ll PARENTING ISSUES/PROVISIONS
8 The parenting plan signed by lhe parties and the GAL, which is atlacbed hereto is fully
9 incorporoted into this CR2A es if set fo11b fully hereln. Tho pa11ies agree the tenns set forth in
10 parenting plan altached hereto sholl be fully incorporated into the final pa1'Cnting plan and
II entered with this com1.
12 III FEES
13 (\',)J rlf-« ,J.-
0 Altomey Fees fo1· Dlm!!uffon; Not resolved through mediation.
14
IS IV OTHER
16 • Flnftl 01·ders: TI1e Pelltloner's attorney will prepare the final pnrenting plan, and
submit to Respondent's altomey for signoture. 111ereafter tho Petitioner's atlmnoy shall
17 enter nnd provide confo1mcd copies to the other side.
18
19
Dated: _ _ __
20
21
22
23
ANDRHW RIFE, Petitioner
24
2S
CR2A STIPULATION AND AORllllMENT WAYNE P. PELL~QRIN!

Peg,..2 THIRD Sllll!ST MEDIATION
11138 THIAOSlREET
lnlllnls:~ ¥. MARYSVnlE, WASHINGTON 88270

(360)8Sll-8SIO • FACSU.ULE (380) 861-6182
.-
v
2
s
6
7
8
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
2S
CR2A STIPULATION AND AGREBMHNT l\IAYNI! P. PBUJ!G!llNI

TlllRDSTRll6Tl.IEDIA11DH
Pnge-3 11138 lHIRD STREET
Initials:~ ~
MARVSVIUE, WASHINGTON 98210
(180) 85M680 • FACSllAILE (38UJ851-8762
\
-~ 3
s
6
8
S11pe1·io1· Com·f of Washington
County of Snohomish
9
In ro:
10
ANDRBW RIFB, No. OS-3·02755·1
II
Pelilioner,
12 ond AGREED/MEDIATED
PARENTING PLAN PURSUANT
13 JENNIFER MBHADDI (flea Jennifer Rife), TOCR2(A)
14
Respondent.
IS I. General Information
16
This parenting plan applies to the followlng chlld:
17
18
19
Lauren Emlly Rife
20 II. Basis for Restrictions
21 Under certain circumstances, as outlined below, the court may limit or prohibit a
22 parent's contact with the children and the right lo make decisions for the children.
23 2.1 Parental Conduct (RCW 26.09.191(1), (2))
24 Does not apply.
2S
26 2.2 Other Factors (RCW 28.09.191 (3))

27
Does not apply.
28
!&[/J.
f BlliA L
Pn.-e111/11g Pinn (PPP, PP7; PP) - Pnge.
·COPY
IYPF DR 01.0400 Afn11tfnto1y (6't'.J'f<
26.09.016,.181;.181;.194
2
Ill. Realdentlal Schedule
3
The res/den/la/ schedule must set forth where the chl/dren shall reside each day of the
4 year, Including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the chl/dren shall have With each parent.
5
Parents are encouraged to create a resident/al schedule that meets the developmental
6 needs of the chl/dren and lndlvlclua/ needs of their faml/y. Paragraphs 3.1 through 3. 9
are one way to write yaur res/den/la/ schedule. If you do not use these paragraphs,
7 write In your own schedule In Paragraph 3.13.
8
3.1 Schedule for Children Under School Age
9
Does not apply es there are no chlldren under school age.
JO
II 3.2 School Schedule
J2 The chlld shall reside with the mother except for the following days and limes
when the chlld shall be with the other parent:
J3
14
Every other weekend commencing Thursday at 8:30 a.m. to Monday morning
return to school (8:30 am If there Is no school on Monday).
JS
Every other week (following the weekend Indicated above) the father wtn have
16 Wednesday commencing at 8:30 a.m. to Friday morning return to school (8:30a
17 If there Is no school on Friday).
JS When there Is no school the pick-up and drop off will be at the
mother's residence.
J9
2J The child shall reside with the mother during winter vacation except for the
followlng days and times that the chlld shall reside with or be with the other
22
parent. ·
23
Same as school schedule.
24
25
26
I
The chlld sliall reside with the mother during other school breaks except for the
followlng days and times when the chlld shall reside or be with the other parent.
27
28
IYAXN!l P. PEJ.LEQRJNI
TH!RDSTRE61'MElnA1K»f
1838 THIRD STREF.T
Pm't!lllh1g Pla11 (PPP, PPT. PP) - Page 2 of I I MARY8VlllE, WASlnNOTOHG82 ~~:
ll'PF DR OJ.0400 Mm1dnto1)' (612008) - RCll' 1
(380J--· FACSIMll.E (380)vn2
26.09.016, .181; .187; .194
Spring break shall be alternated with the mother receiving spring break In even
years and the father receiving spring break In odd years.
2
3 Spring break shall begin at 9:00am on the first weekday of the break after school
lets out and shall end at 6:00pm on the last weekday of spring break In order to
4 continue the regular weekend rotation.
s Midwinter break shall be alternated with the mother receiving midwinter break In
6 odd years and the father receiving midwinter break In even years. Midwinter
break shall begin at 9:00am on the first weekday after school lets out and shall
7 end at 6:00pm on the last weekday before school resumes.
8
3.5 Summer Schedule
9
The chlld shall reside with the mother during summer break except for the
10 following days and times when the child shall be with the other parent.
II
The Summer Schedule Is defined as beginning on the first Sunday after the last
12 day of school at 6:00pm and ending at 6:00pm on the last Sunday before school
resumes.
13
14 Each parent shall have resldentlal time on a week on/week off schedule with the
exchanges happening at 6:00pm on Sundays. The mother shall have the first full
IS week of summer break In odd years and the father shall have the first full week o
summer break In even years.
16
17 The parents will be responsible for choosing camps/childcare during their weeks.
18 Vacations should be scheduled during that parent's respective weeks.

19
20 3.6 Vacation With Parents

21 Vacations with parents shall be taken during the summer break and shall be
scheduled on each parents' own weeks.
22
23
24
2S
26
27
28
WAVN!lP, PELL!!OR!NI
TIJIRD ST~BBT M&OlATIOH
1630 THIRD STREET
Ptu't11ll11g P/a11 (PPP, PPT. PP) • Page J of JJ MARYSVILlE, WASHIHC!TON M270
ll'PF DR OJ.0~00 Ma11dnlol)• (612008) - RCIJ' (390)858-6580 • FACSIMll.E (3e0)8Sl<l762
26.09.016, .JBJ; .JB1; .194
I 3.7 Schedule for Holidays
2
The resfdentlal schedule for the children for the holidays listed below Is es
J follows:
(Specify Veer (Specify Veer
s Odd/Even/Every) Odd/Even/Everv) ,.,()
6 Martin Luther Day Every f/t/,,.
7 President's Day <=-t I 1&
Thanksgiving Day Even Odd ~JIJ'
8 Christmas Eve Every v ~)
Christmas Day Every
9 Even Odd
New Year's Day
10 July 4lh Per3.6
Memorial Day Every
II Labor Day Every
12
For purposes of this parenting plan, a hollday shell begin and end as follows:
13
Unless specified otherwise below, holidays shall begin at 10:00am and end at
14 7:00pm the same day.
IS
Chrlatmas Eve shall commence on 12123 at noon and conclude on
16 12/24 at 9:00 p.m.
17
Thanksgiving shall begin at 10:00am on Thanksgiving Day and end et noon the
18 day aner Thanksgiving.
19 Memorlal Day, Labor Day shall Include the adjoining weekend and shall
20 commence Friday after sohool and conclude Tuesday drop off at school.
21 Other holldays not llsted above that fall on a Friday or a Monday shall be spent
with the parent who has the adjoining weekend.
22
23 3.8 Schedule for Speclal Occasions
24 The resldentlal schedule for the children for the followlng speclel occasions Is as
follows:
Odd/Even/Everv) Odd/Eyen/Everv)
27 Mother's Day Every
28
IYAXNll P. PBU.EORINI
THIRD STRBBT MEDIA1IOH
10!8 THIRD STREET "!":
Pnra11//ng P/n11 (PPP, PP1; PP) - Page 4 of 11 MAR'ISVltLE. WASHINO'TON 118270/\,/'t
WPP DR 01.0400 Mm1dntol)' (611008) · RCIY (3BO)e58-6580• FACSU.ULE (3ll0)851't)'U.
26.09.016, .181; .187; .194
Father's Day Every
2
Special occasions shall begin at 1O:OOam and end at 7:00pm on the day or the
3 special occasion.
4 3.9 Priorities Under the Reeldentlal Schedule
Paragraphs 3.3 • 3.8, have priority over paragraphs 3.1 and 3.2, In the rollowlng
6 order:
7 Renk the order of priority, with 1 being given the highest priority:
8
3 winter vacation (3.3) 1 holidays (3. 7)
9 4 school breaks (3.4) 2 special occasions (3.8)
5 summer schedule (3.6)
10
II
3.1 o Restrictions
12
Nellher parent shall utilize physical or corporal punishment as a disciplinary tool
13 or allow a third party to do the same.
14
15
Transportation costs are Included In the Child Support Worksheets end/or the
16
Order of Chlld Support and should not be Included here.
17 Transportation arrangements for the children, between parents shall be as
follows:
18
19 Receiving parent shall provide transportation, except as otherwise Indicated In

3.2 above.
20
21 3.12 Designation of Custodian
22 The children named In this parenting plan are scheduled to reside the majority of
the time wllh the mother. This parent Is designated the custodian of the children
23 solely for purposes of all other state end federal statutes which require a
24
designation or determination of custody. This deslgnaHon shall not affect ellher
parent's rights and responsibilities under this parenting plan.
2S
3.13 Other
26
27
28
WAYN6 P, PE!,LEOR!NI~
TillRD Sn&ET Ml!DJA'TfOH
1638 TIURD BTRE ET
Pore11tl11g P/a11 (PPP, PPT, PP) - Paga j of I l MARV9V11.LE, WABHINOTON 08210
ll'PF DR 01.0/00 Mm11Jnto1y (612008) - RCIJ' !380) 6&8-8610 • FACSIMILE (380)661-9782
16.09.016, .181; .181; ./94
Ch!ld's Counselor: Jeanne Palk wlll continue as the chlld's therapist. The
2
parents shall not communicate with the therapist unless speclflcally requested by
the therapist. The therapist shall communicate with the "case manager" when
l there Is an Issue addressing the needs, activities and/or best Interest to the chlid.
The therapist may contact the parent(s) If the therapist deems it appropriate
4 and/or necessary to address Issues related to the chlld. Both parents wlll
s cooperate In scheduling and transporting the child to the therapy sessions
through the case manager.
Case Manager/Parenting Coordinator: The parents shall direct all

7 communication regarding Lauren through a case manager for the next 6 months.
8
The case manager Is authorized to hear the concerns/dispute of each parent
and/or chlld. The case manager Is further authorized to communicate directly
9 with the child's therapist. The case manager Is authorized to make or render a
decision. Unless reallocated by the case manager, all costs end fees associated
10 with the case manager shell be paid by each parent proportionate to each
11 parent's respective Income (line 6 of Chlld Support Worksheets- current order).
12 • After 6 months, the parties may contact the other parent via email
regarding a decision, dispute or concern that has arisen. Either parent, at
13
any time, may seek Input and a decision from the case manager regarding
14 any subsequent dispute or concern after the lnltlal 6 months set forth
above. ~ ., .,.lo I
IS
16
• The case manager, ().1,,... ~I , Is appointed and agreed upon
by both parties.
17
• Should either party object to the decision of the Case Manager, the matter
18
shall heard de-novo by motion upon the famlly court motions calendar.
19
20 Communication: After the lnlllal 6 months Indicated above, all communication

thereafter shall be In the form of a writing. Emelle should be used as the primary
21 and preferred form of non-emergency Information, to communicate Information
about the chlld's school, medical Issues, medical or other appointments school
22 activities. Proposed changes to the parenting time schedule, holiday activities,
23 chlld's activities and all other parenting related Issues. (emali
24 Anger Management Assessment and Parenting Classes: The parties agree

the Respondent's now husband, Soufayene Mehaddl wlll complete an anger
25
assessment wilh 'DIL\G- 'e:>'OU. The parties agree the assessment report wlll
26 be provided to the attorney of the father. Mr. Msheddl agrees to follow any
ecommendatlons Indicated In the assessment end provide verification to the
ether's attorney that he has successfully completed such recommendations.\
p iLI, a.J2- Ii;, "\ ""'IZ.. . \I\ e-\4 11. ~ ~ • M 12.- W\ E:'H ,:.. o.o\ ~\ 'v
.
f>.-0..,.11 RJe &...
. re-cor.\- ~
""'-0\1\.~\'\ C.OV\llf>\\~f!EP,Pl!UllQ'mNI
,,.,,v,,/
~ °'$ 0--V\,bll TIOADSTRBBTMCDIATION
!638 lMIRD STREET
1/111g P/011 (PPP, ppr, PP) - Pngo 6 of I I MARVSVD.lE. WA6HlllGTON9827
I~ DR 01.(HOO Mn11dnto1)' (611008) • RCIY l3IOIB58'8580 • FACSIMB.E (389)811·8702
26.09.016,.181; .181; .194 ~
Failure for Mr. Mahaddl to complete this process Is grounds for modlRcatlon
pursuant to RCW 26.09.260. Mr. Mehaddl will also complete the For Kid's Sake
2
Parenting Seminar and provide a copy of his certificate of completlon to the
3 father's attorney and the court. Both parents Wiii complete the JIS form end
Include Mr. Mehaddl and any other adult that hes significant contact with the
4 minor child (not grandparents).
Father's Evaluation: The father will provlde t? le mp,har attorney a copy of his
s psychologlcal e~aluatlon prevfpusly requlcedc0 ~ 11..,..._, ~ · In.... f-
6 ~~..... l _.., f''"'";..... tw~ ""'f.,:{,. p ""'ff'dV -
3.14 Summary of RCW 26.09.430 • .460, Regard.Ing Relocatlon of a Chlld
7
This ls a summary only. For the full text, please see RCW 26.09.430 through
8
26.09.480.
9 If the person with whom the chfld resides a majority of the time plans to move,
10 that person shall give notice to every person entltled to court ordered time with
the child.
II
If the move Is outside the chlld's school district, the relocating person must give
12 notice by personal service or by mall requiring a return receipt. This notice must
be at least 60 daye before the Intended move. If the relocetlng person could not
13 have known about the move In time to give 60 days' notice, that person must
14 give notice within 5 days after !earning of tho move. The notice must contain the
Information required In RCW 26.09.440. See also form ORPSCU 07.0600,
IS (Notice of Intended Refocatlon of A Chfld).
16 If the move Is within the same school district, the ralocatlng person must provide
actual notice by any reasonable means. A person entltled to time with the chlld
17 may not object to the move but may ask for modification under RCW 26.09.260.
18 Notice may be delayed for 21 days ff the relocatlng person Is entering a domestic
violence shelter or Is moving to avoid a clear, Immediate and unreasonable risk
19
to health and safety.
20 If Information Is protected under a court order or the address confldentlaflly
21 program, It may be wlthhald from the notice.
A relocating person may ask the court to waive any notice requirements that may
22
put the health and safely of a person or a chfld at risk.
23 Fallure to give the required notice may be grounds for sanctions, Including
24 contempt.
25
If no objection Is fllad within 30 days after service of the notice of Intended
relocalton, the relocation will be permitted and the proposed revised
26 resldenttal schedule may be confirmed.
27
28
Part11tlng Pln11 (PPP, PPT. PP} - Paga 7of11

WAYNE P. rl!LL!lOR!N!
TlllRDSTREETfl.ffDJATIOM
1&30 THlllD STREET Ci tii
MARYSllD.lE. WASHINOTON98270
WPF DR 01.0400 Mn11tlatory (612008) - RCll' IS80)6$8-- • FACSIMILE 13G0)8$1-8181
16.09.016, .181; .187; .194
A person entllled to time with a chlld under a court order can flla an objection to
the child's relocation whether or not he or she received proper notice.
2
An objection may be flied by using the mandatory pattern form WPF DRPSCU
l 07.0700, (Objection to Relocation/Petition for Modmcatlon of Custody
4 Decree/Parenting Plan/Resldenllal Schedule). The objection must be served on
all persons entltled to time with the chlld.
s The relocating person shall not move the chlld during the time for objection
6 unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.
7
If the objecting person schedules a hearing for a date within 15 days of timely
8 service of the objection, the relocating person shall not move the chlld before the
hearing unless there le a clear, Immediate and unreasonable risk to the health or
9
safety of a person or a chlld.
10
11
12
IV. Decision Making
13
4.1 Day·to·Day Decisions
14
Each parent shall make decisions regarding the day-to-day care and control of
IS
each chlld whlle the chlld Is residing with that parent. Regardless of Iha allocation
16 of decision making In this parenting plan, either parent may make emergency
decisions affecting the health or safety of the children.
17
18
19 4.2 Major Daclalona

21
Education decisions Joint
22 Nonemergency health care Joint
Counselllng Joint
23
Extracurrlcular activities Joint
24 Nonemergency dental care Joint
Orthodontia Joint
25 HalrcutsltatteeelhadV plarGlng Joint
26
Saa also attached excerpt& for Iha process for decision making
27 as recommended by the GAL Report, which excerpts are
28
.IY.Anl.B P. P!!LL!lG11!NI
TillRDSTREETMEblATION
1838lHIRDSTREET ':::;/
Pt11Ymlh1g P/m1 (PPP, PPT. PP) • Page 8of11 MARYSVIUE, WASHINGTON 98210 ~')
ll'PF DR OUHOO Mm1da1ory (611008) • RCll' (380)668-8$80 •FACSIMILE (380)851-llTBZ
26.09.016, ./Bl; .181; .19.f
attached hereto and Included In this agreement as If set forth
2 fully herein.
3 4.3 Restrictions In Decision Making
4
Does not apply, there are no limitations
s
6
1
Tha purpose of this dispute resolution process Is to raso/va dlsagreamanls about
carrying out this parenting plan. This dispute resolullon process may, and under soma
1 local court rules or Iha provisions of this plan must ba usad before fl/Ing a pal/lion to
modify Iha plan or a motion for contempt for falling to follow the plan.
9
10 Disputes between the parties, other than chlld support disputes, shall be
submitted as follows:
11
• For the nrst 2 years (24 months) from the execution of this agreement all
12
disputes shall be submitted to the case manager to be decided.
13
• After 24 months the parties shall submit their disputes to an agreed upon
14 mediator with famlly law experience. If the parties can't agree upon a
mediator the mailer shall be submitted lo Wayne P. Pellagrlnl for
IS
mediation.
16
17
18
Proportionate to Income (per line 6 of the child support worksheets).
19 The counseling, mediation or arbitration process shall be commenced by notifying the

other party by written request and/or a-mall:
20
21 In the dispute resolutlon process:

22
23 (b) Unless an emergency exists, Iha parents shall use the designated process
to resolve disputes relating to Implementation of the Plan, except those
24 related to flnanclal support.
(c) A wrlllan record shall be prepared of any agreement reached In
counseling or mediation and of each arbitration award and shall be
26 provided to each party.
21
28
\VAYN!! P. P!!LLEQRINI
TlllRDSTRElrrMFDJATtoN ~'
1838 THUID STREET
Pare/ll/11g Plan (PPP, PP1; PP) • Pag• 9 of I I MARYSVIUE, WASHINOTON llHIO
lYPF DR 01.MOO Mn111falOFJ' (611008) - RCW (380) 1158-8580 • FACSIMILE (380)851-8782
16.09.016•• 181; .181: .194
(d) If the Court finds that a parent has used or frustrated the dispute
2
resolution process without good reason, the court shall award attorneys'
fees and financial sanctions to the other parent.
3 (e) The parties have the right of review from the dispute resolution process to
the Superior Court.
4
s VI. Other Provisions
6 Telephone Access. When the child of the parties Is not residing with a given
parent, that parent shell be permitted unimpeded and unmonitored telephone
7 access or Internet web chat with the child so long as contact Is Initiated by the
8 child.
9 Activities. Each parent shall have the right and responslblllty to ensure that the
child attends school end other agreed upon scheduled activities while In that
10 parent's care. Parents shell attend school and extracurricular activities and
II events that fall on their resldentlal days only.
12 Change of Address. Each parent shall provide the other with the address and
phone number of his or her residence and shall update such Information promptl
13
whenever It changes. Each parent shall provide the name and blrthdates of all
14 lndlvlduals who reside In the same home as the child.
IS Affections. Each parent agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the child and the
16
other parent, and to promote the emotions of affection, love and respect between
17 the child and the other parent. Each parent agrees to refrain from words or
conduct, and further agrees to discourage other persons from uttering words or
18 engaging In conduct, which would have e tendency to estrange the child from the
other parent, to damage the opinion of the child es lo the other parent, or which
19
would Impair the natural development of the child's love and respect for the other
20 parent.
21 Enrichment ActM!les. The parents may participate In school activities for the
22
child while the child Is In their care. Each parent shell Inform the other parent of
all Information regarding activities.
23
Child's Welfare. Each parent shall provide the other parent promptly with receipt
24 of any significant Information regarding the welfare of the child, Including physical
2S
and mental health, performance In school, extracurricular activities, etc.
26 Children's Involvement. Neither parent shall ask the child to make decisions or
requests Involving the residential schedule. Neither parent shall discuss the
27 residential schedule with the child except for plans, which have already been
28
.l'M_~B P. PBLLgORINI
THIRD ST1lBBT MEDIA'JIOJrf ..,~
1638 THIRD STREET (' ){
Pnn'1lll11g Plnll (PPP, PPT, PP) - Paga 10 of I I MARVSVlllE, WASHlNBrON 118270 ~ \)
ll'PF DR 0/.0400 Mm1da101)' (612008) - RCIY (380)8'8-8580 • FACSIMllC (3B0)8!t-41762
26.09.016, .181; .181: .194
agreed to by both parents In advance. Neither parent shall advise the chlld of the
2
status of child support payments or other legal matters regarding the parents'
relatlonshlp. Neither parent shall use the child, directly or Indirectly, to gather
3 Information about the other parent or take verbal messages to the other parent.
4 Derogatorv Comments. Neither parent shall make derogatory comments about
5
the other parent or allow anyone else to do the same In the child's presence.
Neither parent shall allow or encourage the child to make derogatory comments
6 about the other parent.
7 DEVIATION FROM RESIQENTIAL SCHEDULE: Acceptance and waiver of any
8
deviations from provisions of this Parenting Plan shall not constitute acceptance
or waiver of subsequent devlstlons from this plan. The provisions of this plan
9 shell remain In effect until modified by an appropriate written order by a court of
competent jurisdiction; provided, that any and all revisions to this plan are In
10 writing and signed by both parents, and shall be effective lmmedlately
II
NOTIFICATION OF CHILD'S EVENTS: Each parent Is to keep themselves
12 apprised and Informed regarding Information concemlng the wsll-belng of the
chlldren, Including, but not llmlted to, copies of report cards, school meeting
13
notices, vacation schedules, class programe, requests for conferences, results of
14 standardized or diagnostic tests, notices or activities lnvolvlng the children,
samples of school work, order forms for school pictures, all communications from
15 health care providers, the names, addresses and telephone numbers of all
16
schools, health care providers, regular daycare providers, and counselors, as ..A<i-
well es mental health records accumulated by said counselors. , ~-"H'----
17 ~ "°»' """T> ;hi= f~~ {P'\\\ C.OOf>~-\(.. \V\ 0~
18 ~ f°'"&~fa-1\- ~ L<UA.Ve.111.. 'Ti-. f'~&Sf>D"t"t- \A\\l \g,...,.. ~W
~ ~~' ~ e~~ ~ fv.c.ci.l'1 -tvo.»iz-1 to ~I
\-'\.t.~T U> ~ ~e.v e>-.~V'~ lo_Co.f..;~.:;;;11\'\.'S.~7...· ~~:::::::==j
19
20 -:
CA~UL,
~ llr341 ANDREW RIFB, Petitioner
21 AU n .
22
23
24
n~-
VERONICA FREITAS, WSBAql9405
25
AUomey for Res]Jondenl "/ / 11} I '/
26
27
28
WAYNR P. PEilEQRINI
1HIRD.STRF.ErMEOIATlON
1838 THIRD STREET
Pnl'c111/11g P/011 (PPP, PP1; PP)· Paga I I of I I MARY81111.LE, WASHINGTOH 98270
WPF DR 01.0400 Mn11dnlo1J• (612008) - RCW (390) aee.esao. FACSIMILE !3001 Bel-8782
16.09.016, ,/81: .181; .194
•
:I . - 1
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20 11 • a, ,, * r •
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21 Gii t a • ?' 3 I ti .. IL~
22 Educational Declal2ns: The child shall attend her current school/f A''-
1o
23 Hno1>gh the 1 emal::dR ef tltle eeksel ,cat·. The father or mother ehall have th
24 authorlt.y to annually enroll the child In her current school, select optional
25 classes, authorize ed\lcatlonal leatlng, obtain tutoring and seek education ac-
26 commodatlons (e.g. Section 504 Accommodations) for the child. If educatlonnl
27 testing la done, the results shall be provided to both parents. If one parent en
\ R&PORTOI> 11110(IJ/t8bDlb11.Bvlo. OVSfd/811 odl/tsnlfAllDml1

GUARDIAN AD LITEM IDllHUl'ILUIUI
IBBALJID)
RCW 116.0IMIGO PAOoa
111m..v1aaaun
ll!ON111081188-10UllllUllOlll-031D~
/~ ,,tft. -
1 1·0Jls child In school, the other parent shall be listed as auch on eaoh and eve1y
2 form Including the emergency contact fo1·m at tho school.
3 Changing schools shall be a joint deolalon and subject to the dispute
4 1"Caolutlon process. If a parent wants Lauren to change schools, that must be
5 suggested In writing by Ma,y 1, 2014 for the 2014-2015 school year or by No-
6 vember 15, 2014 for the 2015-2016 school yeat• and by November 15th of any
7 futu1·e year. The decision to change schools Is subject to joint deolalon-!"aklng
8 and the dispute resolution process. That process might need to be on an expe-
9 dited basis In light of various school application deadlines.
10 Any coats 01· fees associated with the dispute resolution process regru'd-
11 lng Educational Decisions or to chango schools shall bo divided according to
12 each party's proportional share of Income from Line 6 of the Child Support
13 worksheets. The arbitrator shall have the authol'ity to allocate or re-allocate
I
14 fees for cause.
15 'rhe arbitrator shnll leeue hie or her final decision In writing and forwnrd
16 a copy to each party. 'rhe original decision shall be flied with the court and
17 shall be binding upon the parties unless an action for court review IA flied with-
18 in twenty (20) days, The court shall aaacss costs and reasonable attorneys'
19 fees against a pa1•ty who seeks court review and fails to lmpt'Ove hie or her poal-
20 Uon. Unless waived, the court ma,y assess coats and reasonable attorney's fees
21 against a party who unllatcrally withdraws a request fo1• court 1·evlew after
22 costs 01· fees have been lncuri·ed by the opposing party.
23
24
25
~-., RllPORT O"

QllllROIAH AD LlTBM
II/lo 11moTJB1b1 i BIITa aus/IJ/sn su1118l/l/m1010011
1011Hl81'8Lflllf4
(BlilALEDI 11Dlllt.W188110
now aG.09,260 PAOlll4 Pllllll111881!88·lD3.IAllf8BIH&Bl4D
.,. .
A;.!--~
~ 1'4\.. t,.....J ""
""-<. .,,.....__
1 Extracunl ula ·t cl atlon. Neither party shall l11depl!ndentl,y enroll
°f:L'<>'vow-
2 the ohlld,, n a1 activity that talrea place during fhe-ofll91• parent's residential ~
3 time with that chlld,JnclmllRg wcelceud acthllles,
4 For all decisions that Impact the other parent'e residential time (extt·a-
5 currlculal' actlvltles,_vacatlq,J?) 1plther parent shall notify the other parent viii
•f"" ~ "°'"O'"· • c rCJJ ~~
tf... C<>-4"- ~.,,
6 emal~o~ the ponding decision, as soon Is 1·eaeonabl,y possible, about the Issue
7 a11d the proposed declslon/solutlon. The othe1· parent has 36 hours to re-
8 spond. No response Indicates agreeing with tho referring parent'e p~posed de-
9 cision. If tho 1111rlles do not agree, the dispute shall be submitted to arbitration
.... ,~.,-\)&'Y",.,
10 by :r- y. The costa of arbltratlon,rrlrtlld to extt·a-.curulcular partlclpatlon
.,._,,..,,.,.., ~ 1.4\..t...., C-•S·<.J~.>
11 shall be borne by MP.-Rlfe yet the a1·bltrat r shall have the authority to allocate
12 or re-allocate fees for cause. 1'he parties shall abide by the rules of the arbitra-
13 tor Insofar as briefing, oral argument and/ or fees are concerned.
( 14 The arbitrator shall Issue his or her final decision In wrlUng and forward
15 a copy to each party. The original declelon shell be flied with tho court and
16 shall be binding upon the parties unless ail action for com•t review le filed with·
17 In twenty (20) days. The court shall assess costs and reasonable attorneys'
18 fees against a party who seeks court review and falls to Improve his or her posi-
19 tion. Unless waived, the court may assess costs and reasonable attorney's feea
20 against a party who unllaterally withdraws a request for cou1t t'evlew after
21 tz
costs or fees have been Incurred ~ ';e~ parly.
2 Non-em01·gency Medico.I Cat'e. The mother shall have the authority to schedule
23 routine non-emerg011cy health care appointments (e.g. physical exams 01· check
24 upe) and mlnol', non-emergency health ca1'C for minor Illnesses or mlno!' lr\)u-
...,....,~ """"'- ~
25 rles o.nd consent to routine treatment thereof. The l!l9l'we s~ltll netl~· MF Rife
26 by email of all such appointments and treatment, describing any findings,
I.._
..
27
*'
treatments or recommendalfons. If a healthcare provider recommends ongoing
Nol'\-~~ ~ ~~ ~r,o~ s~\ ~ ..... .4. ~

RBPORT OP' -C{..\¥.....v
GUARDIAN AD LITBM
f0.XW...~
Cv.1.<11..+e
o.,.wl ~~IOU/~flJ~Ulg~d~"t;«i~y O~I fl>
1-Wi- c.t:i.A1q
II\. CA.\ !IA. e\-\VllfOH~ 10llHll5'1L#lll4 ~
0
(8BALBD) llltU,WAB8118 I
,.ll,,Row2e.ow:~f~~ ~~~ ~e;~~8le:;~ ~

rv ~ o.. 1ti~.,\.1-fi~"*- ~\CA.It av~..\.....\ \~.SW- 1k ~~
Vl\\\ C..Olf'.&v..tf w'i+L.1'\..t.. ~ ~~ o"'- ~.ti: ...·\<;,.~ 'i-f i'1uz.ve
·, !> "- Cov\..-A.id-,
)_
1 treatment beyond a course or medication (o.g. surgery, multiple appointments, 7(~
2 l'eferral to a specialist or furthe1· evaluation), the response w111 be subject to b
joint decision-making and the dispute rcsolutlo~s. ~J,":fi."1 ~ .J 1,, (.,,...
1
3
on-emergency Dontal/Orthodontlc Ca1-e. Thelftrttlet shall havo the authority µJ.v.
11,.,t.....
5 to schedule routine non-emergency dental care appolnhnents (e.g. dental 01· or-
0~
6 thodontlc exams or check ups or cleanings) and minor, non-emergency dental 4' . . . _; -
7 care fo1· minor dental situations and consent to 1·out1no troatmont thereof, The
8 father shall notify Me. Mehaddl by email of all such appointments and treat-
9 ment, describing any findings, treatments or recommendations. If a dental or
10 orthodontic provider recommends ongoing treatmont beyond a course of medi-
11 cation (e,g, surgery, multiple appointments, referral to a specialist or t\Jrthe1·
l?.
13 pule resolution process. ~ ~ \...,.JJ. ~
(
14 Consultation. AU meJ01· decfs~rni,~lng those Items, which
15 are subject to solo declelon-maklng, shall be made by the assigned parent only
16 after reasonable and llbe1·al advance notice and an opportunlt;y for coneultatlon
18
19 4. . 1nno;ii1~::tl!!::<sell!!£.I ng plan, Including a change
20
23
24 Ph.D.-lcval parenting ev~t«o
25 pointed through di
26 d child shall participate Jn the parenting evalua
27 event the ltlatlng parent seeks a modification of Ihle parenting plan under
~- .. R&PORTOI"
GUARDIAN AD I.ITEM 11!81NIB5'1Lft38'
(BB.Ill.EDI hall~WIB8118
ROW U.09,260 PAOBG PHOHlltOBllBD·m!.IAXl8881B59-BllO
. . ·'
J
::;;~:~
~:=;:i;:;~alttallen report ehall he ee1 vcd t1pen U1e
2
The parents shall WQrk with a Case Manager S1Rdfe1 l'drenting coOidina-
3
4.
5.
.I..,
tor for ~...months Jn an attempt to help educate them on better communication
5 sldlle and parallel-parentlng akllla eo that they can reduce their conlllot:-Jltfty
rl
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6 - . - .
7 lie LU bj Ilia IUIL.
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12 7. .. .
13
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14 8. The followlng provielone shall be Included In the final parenting plan

15
6
signed by the parties:
.. . . . .. . . ... /'
.
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I'
1 I
TA I I
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191 ~
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7 \ / . .
20 ........
21 r:!otlncatlQn of Child's Events, Eaoh parent shall bo reeponelble for
22 keeping themselves advised of school, athlellc, and social events In which the
23 child partlclpates.
24 Devlatlo11 fl'Om Schedu_ls_., Acceptance and waiver of any deviations from
25 the provisions of this parenting plan shall not constitute acceptanoe or waiver
26 of subsequent deviations from this plan. The provisions of this plan shall re-
27 main In effect until modified by an appropriate written order by a court of oom-
RBPOR'l'OV
OVARDIAll AD Ll'l'BM
(8DllLBD)
RCIV 26.09.260 PAOD7
llllOtnl/S/JD/Dlf.Buto.OU61tl1BllBlllU1mlll10IDOY
103101a'8Ltl1DI
llllllo,Wl08110 A
~
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PRORillOBllOD·lll3.1dl8881089·03H W \ J
r
EXHIBIT 3

2io summit Avenue East,.Seattle,WA 98102-I tel• (206)328-7362 I fax• (206)323-o404.
. '
2
' Superior Court of Washington

6
County of Snohomish
7
In re:
8
9 Petitioner,
and AGREED/MEDIATED
10
II JENNIFER MEHADDI (flea Jennifer Rife). TOCR2(A)
Respondent.
12 ··-~~~~~~~~~~~~~~~.__~~~~~~~~~~~~--
13 I. General Information
14
This parenting plan applies to the following child:
IS
16
Lauren Emily Rife 9
17
18 II. Basia for Restrictions
19 Under certain circumstances, as outlined below, the court may limit or prohibit
parenrs contact with. the children and the right to make decisions for the children.
20
21 2.1 Parental Conduct(RCW 26.09.191(1), (2))

22 Does not apply.
23
2.2 Other Factors (RCW 28.09.191(3))
24
Does not apply.
25
26 Ill. Realdentlal Schedule
27
28
CARL I. GAUL
AlloraGJ at I.aw
1111)4 HowlllAYenutf302
Parenting Plan (PPP, PPT. PP) - Page I of 14 EYerattWA88201
WPF DR 01.0400 Mo11datory (612008) - RCW (42&) 259-4147•FACSIMILE1425) 2611-7081
26.09.016, .181; .187; .l'N
The resident/al schedule must sat forlh where the children shall reside each day of th
2
year, Including provisions for holidays, birthdays of family members, vacations, an
other special occasions, and what contact the children shall have with each parent.
3 Parents are encouraged to create a residential schedule that meats the developments
needs of the children and individual needs of their famlly. Paragraphs 3. 1 through 3.
4 are one way to write your residential schedule. If you do not use thasa paragraphs,
5
write in your own schedule In Paragraph 3.13.
Schedule for Children Under School Age
Does not apply as there are no children under school age.
School Schedule
The child shall reside with the mother except for the following days and time
when the child shall be with the other par!'lnt:
Every other weekend commencing Thursday at 8:30 a.m. to Monday momln

return to school (8:30_ am if there Is no school on Monday).
Every other week (followlng the weekend indicated above) the father will hav
· Wednesday commencing at 8:30 a.m. to Friday morning return to school (8:30a
If there is no school on Friday).
When there Is no school the pick-up and drop off wlll be at the mother'
residence.
Schedule for Winter Vacation
The child shall reside with the mother during winter vacation except for th
following days and times that the child shall reside with or be with the othe
parent.
Schedule for Other School Breaks
The child shall reside with the mother during other school breaks except for th
following days and times when the child shall reside or be with the other parent.
Spring break shall be alternated with the mother receiving spring break In eve
years and the father receiving spring break In odd years.
CARLI.GAUL
AUorucy al Law
1804 Hawllt AY9Ml8 0302
Parenllng Plan (PPP, PPT, PP) - Page 2o/14 Everett WA 08201
WPF DR 01.0400 Mandatory (612008) - RCW (426) 269-<1147 • FACSIMILE (425) 289-7081
26.09.016, ,181; .187; .194
Spring break shall begin at 9:00ain on the first weekday of the·break after schoo
lets out and shall end at 6:00pm on the last weekday of spring break in order t
continue the regular wee.kend rotation.
Midwinter break shall be alternated with the mother receiving midwinter break i
odd years and the father receiving midwinter break in even years. Mldwlnte
break shall begin at 9:00am on the first weekday after school lets out and shal
end at 6:00pm on the last weekday before school resumes.
Summer Schedule
The child shall reside with the mother during summer break except for th
following days and times when the child stiall be with the other parent.
The Summer Schedule Is defined as beginning on the first Sunday after the las
day of school at 6:00pm and ending at 6:00pm on the lest Sunday before schoo
resumes.
Each parent shall have residential time on a week .on/week off schedule with th
exchanges happening at 6:00pm on Sundays. The mother shall have the first ful
week of summer break In odd years and the father shall have the first full week o
The par1?nts will be responsible for choosing camps/childcare during their weeks.
Vacations should be scheduled during that parent's respective weeks.
Vacation With Parents
Vacations with parents shall be· taken during the summer break and shall b
Schedule for Holldaya
The residential schedule fOr the children for the holidays listed belQW is a
follows: ·

Odd/EvenlEvervl Odd/Even/Every)
Martin Luther King Day Every
Presidenrs Day Every
. Christmas Eve Every
CMLJ.OAVL
Allomoylll.aw
1004 H~ Avanua "302
Parenting Plan (PPP. PPT, PP) - Page 3of14 EV8retl WA 98201
WPF DR 01.0400 Mandatory (612008) - RCll' (428) 2&Ml47 • FACSIMILE (4211) 260-7081
26.09.016. .181; .181; .194
Christmas Day Every
2
New Year's Day Even Odd
July 4th Per 3.5
3 Memorial Day Every
Labor Day Every
4
;
s For purposes of this parenting plan, a holiday shall begin and end as follows:
6 Unless specified otherwise below, holidays shall begin at 10:00am and end a
7:00pm the same day.
7
8 Christmas Eve shall commence on 12/23 at noon and conclude on 12/24 at 9:0
p.m.
9 I
Thanksgiving shall begin at 10:00am on· Thanksgiving Day and end at noon th
10 day after Thanksgiving.
II
Memorial Day, Labor Day shall include the adjoining weekend and shel
11 commence Friday after school and conclude Tuesday drop .off at school.
13
Other holldeys not llsted above that fall on a Friday or a Monday shell be span
14 with the parent who has the adjoining weekend.
IS 3.8 Schedule for Special Occasions

,16
The residential schedule for the children for the following special occasions Is a
17 follows:
Odd/EveniEverv> Odd/Even/Eyeryl
19
Mother's Day Every
20 Father's Day Every
21 ·Special occasions shall begin at 10:00am and end at 7:00pm on the day of th
22
special occasion.
23 3.9 Priorities Under the Reeldentlal Schedule

24 Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, In the followin
1S
order:
26 Rank the order of priority, with 1 being given the highest priority:
17 3 winter vacation (3.3) 1 holldays (3. 7)
18
CARLI.GAUL
Altaruy .. Law ·-
1804 H8"AU Avenuo l302
Parenting Plan (PPP, PPT, PP) - Page 4of14 EvemtWA~I
WPF DR 01.0400 Mandatory (612008) - RCW ('2&) 2BMl47 • FAC81MllE (428) 288·7081
26.09.016, .181; .187; .194
4 school breaks (3.4) 2 special occasions (3.8) ·
2
3 3.10 Restrictions
4 Neither parent shall utilize physlcal or corporal punishment as a disciplinary too
or allow a third party to do the same.
6 3.11 Transportation Arrangements

7 Transportation costs are included In the Child Support Worksheets and/or th
8
Order of Child Support and should not be Included here.
.Transportation arrangements for the children, between parents shall be a
9
follows: ·
10
Receiving parent shall provide transportation, except as otherwise Indicated I
11 3.2 above.
12
13
The children named In this parenting plan are scheduled to reside the majority
14 the time with the mother. This parent is designated the custodian of the childre
solely for purposes of ell olher state and federal statutes which require
designation or determination of custody. This designation shell not effect elthe
16 perenfs rights end responsibilities under this parenting plan.
17 3.13 'Other
18
Child's Counselor: Jeanne Paik will continue as the child's therapist. The paren
19 shall n~t communicate with the therapist unless _speclflcelly requested by th
therapist. The therapist shall communicate with the "case manager" when the
20 Is an issue addressing the needs, activities and/or best interest to the child.
21
The therapist may contact the parent(s) if the therapist deems it approprlat
and/or necessary to address _Issues related to the child. Both parents wil
22 cooperate In scheduling and transporting the child to the therapy session
through the case manager.
23
24 Case Manager/Parenting Coordinator: The parents shall direct all communlcatlo

regarding Lauren through a case manager for the next 6 months. The ces
25 manager is authorized to hear the concerns/dispute of each parent and/or child
The case manager Is further authorized to communicate dlrectly with the child'
26
therapist. Unless reallocated by the case manager, _all costs and fees associate
27
28
CAR!. J, GAVL
AHomeyldl.aw
11S04 Hewlll AY811UO AD2
Parenting Pla11 (PPP, PPT, PP) - Page j of14 Evorotl WA 88201
WPF DR 01.0400 Mandalory (611008) - RCW (4~ 2li9.. 147o FACSIMILE (4211) 259-7Cl1
26.09.0/6,.181; .187; .194
with the case manager shall be paid by each parent proportionate to ea
2
parent's respective Income (line 6 of Child Support Worksheets - current order).
3 ·The parties may change the specific tenns of the parenting plan by agreement or
through the judicial process. The Case Manager shall have no authority to
4 change the terms of the parenting plan.
The Case Manager shall .assist In Implementation of this parenting plan
and shall have the following responslblllty:
6
A. To assure that communication between the parents concerning
7 the chlld occurs In a civil and respectful manner.
8 B. To facilitate negotiation between the parents to assist them in
reaching joint decisions.
9 c. To hear any disputes between the parents and between the
child and one or both parents concerning Implementation of
10
this parenting plan.
II D. To decide disputes between the parents relating to the child's
needs and activities that may Impact the parent's residential time.
12 E. To educate the parents concerning communication skills and
parallel parenting skills designed to reduce lnterparental conflict.
13
14 • After 6 months, the parties may contact the other parent via emal
regarding a decision, dispute or concern that has arisen. Either parent, a
15 · any time, may seek Input and a decision from the case manager regardln
any subsequent dispute or concern after the initial 6 ·months set fort
16
above. · ·
17
• The case manager, Debra Riehl, Is appointed and agreed upon by bot
18 parties. The parents shall work with the Case Manager for 24 months i
19
en attempt to help educate them on better communication skills an
parallel-parenting skills so that they can reduce their conflict.
20
• Should either party object to the decision of the Case Manager, the matte
21
shall heard de-novo by motion upon the family court motions calendar.
22
Communication: After the :fnitlal 6 months Indicated above, all communlcatlo
23 thereafter shell be in the fonn of a writing. Emalia should be used as the prims
and preferred fonn of non-emergency lnfonnatlon, to communicate ioformatio
24
about the child's school, medical Issues, medical or other appointments achoo
activities, proposed changes to the parenting time schedule, holiday activities,
child's activities end-ell other parenting related issues. (email
26
Anger Management Assessment and Parentjng Classes: The parties agree th
27
Respondent's new husband, Soufayane Meheddl will complete an ange
28
CMLJ,GAYL
Anomey at Law
1804HBWlftAvenua1302
PCl1'flnlfng /'Ian (PPP, PPT, PP) • Page 6of14 E¥8reRWA08201
WPF DR 01.0400 Mandatory (611008) - RCW (420) 2!M147•FACSIMILE1420) 2!&·7081
26.09.016, .181; .187; .194
assessment with Dale Todd. The parties agree the assessment report will b
provided to the attorney of the father, paid by Mr. Mehaddi. Mr. Mehaddl wil
2
provide monthly compliance report to father's attorney. Mr. Mehaddi agrees t
3 follow any recommendations Indicated In the assessment and provide verificatio
to the father's attorney that he has successfully completed sue
4 recommendations. Failure for Mr. Mahaddl to complete this process Is ground
s for modification pursuant to RCW 26.09.260. Mr. Mehaddi will also complete th
For Kid's Sake Parenting Seminar and provide a copy of his certificate o
6 completion to the father's attorney and the court. Both parents will complete th
JIS form and Include Mr. Mehaddl and any other adult that has significant coniac
7 with the minor child (not grandparents).
8
.. Fathe(s Evaluation: The father will provide to the mother attorney a copy of hi
9 psychological evaluation previously required and follow any treatmen
recommendations and provide montly reports to mother's attorney.
10
II
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
28
CAALJ.GAUL
-all.aw
180• Hewlll Avenue ll302
Parenting Plan (PPP, PPT, PP) - Page 7 of U Evereft WA 118201
WPF DR 01.0400 Mandatory (612008) - RCW ("26) 2BM1•7 • FACSIMILE. (•26) 269-7081
26.09.016, .181; .187; .194
'2 3.14 Summary of RCW 26.09.430 • .480, Regarding Relocation of a Child
3 This is a summary only. For the full text, please see RCW 26.09.430 throug
26.09.480. .
4
If the person with whom the child resides a majority of the time plans to move
s that person shall give notice to every person entitled to court ordered time wit
the child.
6
If the move Is· outside the child's school district, the relocating person must glv
7 notice by personal service or by mall requiring a return receipt. This notice mus
8 be at least 60 daya before the Intended move. If the relocating person could n
have known about the move in time to give 60 days' notice, that person mus
9 give notice within 5 days after learning of the move: The notice must contain th
information required in Rew. 26.09.440. See also form DRPSCU 07.0500
10
(Notice of Intended Relocatlon of A Child).
II If the move Is within the same school district, the relocating person must provld
12
actual notice by any reasonable means. A person entitled to time with the chll
may not object to the move but may ask for modification under RCW 26.09.260.
13
Notice may be delayed for 21 days If the relocating person Is entering a domesti
14 vlolence shelter or Is moving to avoid a clear, immediate and unreasonable ri
IS
If Information Is protected under a court order or the address confldentlallt
16 program, It may be withheld from the notice. ·
17 A relocating person may ask the court to waive any nQtice reguirements that ma
put the health and safety of a person or a child at risk.
IR
Failure to give the required notice may be grounds for sanctions, lncludln
19 contempt. ·
20 If no objection la flied within 30 days after service of the notice of lntende
relocation, ~e relocation Wiii be permitted and the proposed revise
21 realdenOal schedule may be confirmed.
22 A ·person entitled to time with a child under a court order can file an objection t
the child's relocation whether or no1 he.or she received proper notice.
23
An objection may be filed by using the mandatory pattern form WPF DRPSC
24 07.0700, (Objection to Relocation/Petition for Modification of Custocl
2S Decree/Parenting,Plan/Resldentlal Schedule). The objection must be seived o
· all persons ·entitled to time with the child.
26
27
28
GARLJ.QAUL
AttonleJ •It.,...
1804 HawutA"enual302
Parenting Pion (PPP, PPT, PP) - Page 8 of U E-WA9m1
WPF DR 01.0400 Mandatory (612008) - RCW (425) 2&o...t47 •FACSIMILE (426) 269-7081
26.09.016, .181: .187: .194
The relocating person shell not move the child during the time for objectlo
2
unless: (a) the delayed notice provisions apply; or (b) a court order allows th
move.
3
If the objecting person schedules a hearing for a date within 15 days of tlr:nel
4 service of the objection, the relocating person shall not move the child before th
hearing unless there is a clear, immediate and unreasonable risk to the health o
safety of a person or a child.
6
IV. Decision Making ·
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control o
each chlld while the child Is residing with that parent. Regardless of the allocallo
of decision making in this parenting plan, either parent may make emergenc
Major Decisions
Major decisions** regarding each chlld shall be made as follows:

Nonef"!lergency health care Joint
Counselling Joint
Extracurricular activities · Joint
Nonemergency dental care Joint
Orthodontia Joint
Haircuts Joint
•• For decision making see also part VI
Restrictions In Decision Making
Does not apply, there are no limitations.
22 V. Dispute Resolution
23
The purpose of this dispute resolution process is to resolve disagreements abou
24 carrying out this parenting plan. This dispute resolution process may, and under som
local court rules or the provisions of this plan must be used before filing a petition t
2s modify the plan or a motion for contempt for failing to follow the plan.
26
Disputes between the parties, other than child support disputes, shall b
27 submitted as follows:
28
CARLl.GAUL
Al.....,.a!Uw
1804 HnlttAvenut"302
Parenting Plan (PPP, PPT. PP) - Paga 9of14 EVerell WA 08201
WPF DR 01.0400 Mandatory (611008) - RCW (425) 2BMt47 •FACSIMILE (42B) U0.70Bf
26.09.016, .181; .187; .194
2
• For the first 2 years (24 months) from the execution of this agreement al
3
• After 24 months the parties shall submit their disputes to an agreed upo
4
mediator with family law experience. If the parties can't agree upon
mediator the matter shall be submitted to Wayne P. Pellegrini fo
mediation.
6
The cost of this process shall be allocated between the parties as foliows:
7
8 Proportionate to Income (per line 6 of the child support worksheets).
9 The counseling, mediation or arbitration process shall be commenced by notifying th

other party by written request and/or e-mail:
10
II
12
(b) Unless an emergency exists, the parents shall use the designated proces
13 to resolve disputes relating to implementation of the Plan, except thos
related to financial support.
14 (c) A written record shall be prepared of any agreement reached I
counsellng or mediation and of each arbitration award and shall b
provided to each party.
16 (d) If the Court finds that a parent has used or frustrated the disput
resolution process without good reason, the court shall award attorneys
17
18 {e) The parties have the right of review from the dispute resolution process t
the Superior Court.
19
20
21 Teleohone Access. When the child of the parties Is not residing with a give
parent, that parent shall be permitted unimpeded and unmonitored telephon
22 access or Internet web chat with the child so long as contact Is Initiated by th
child.
23
24 Activities. Each parent shall have the right and responsibility to ensure that th
child attends school and other agreed upon scheduled activities while In the
2S parent's care. Parents shall attend school and extracurricular activities an
events that ·fall on their residential days only. Each parent sliall be responsibl
26
for keeping themselves adVised of school, athletic and social events In which th
27 child participates.. '
28
CARJ.l GAU!.
Atlmmy al law
1804Hlll'olttAvenue1302
Parenting Pion (PPP, PPT, PP) - Pogs 10of14 E-ttWA 88201
Jl'PF DR 01.0400 Mandatory (612008) - RCW (426) 2119-4147 •FACSIMILE (42512511-1081
26.09.016, .181; .187; ./94
I
Change of Address. Each parent shall provide the other with the address. an
2
phone number of his or her l'esldenCj3 and shall update such Information pr<impll
3 whenever It changes. Each parent shall provide the name and birthdates of al
Individuals Who reside in tl)e same home as tl)e child.
s· Affections.. Each parent agrees to exert every r,easonallle effor,t to maintain fre
access and unhampered contact and communication between the child and th
. 6 other parent, and to pr_o1T1ote the emotions of affection, love and respeet betwee
the child and the other parent. Each parent agrees to refrain from words o
7 conduct, and further agrees to discourage other persons fronr uttering words o
8 engaging in conduct, which would have a tendency to estrange the child from th
other parent, to damage the opinion of t~e child as to the other parent, or whlc
9 would Impair the natural development of tlie child's love and respect for the othe
pai:ent.
10.
II Enrichment Activities. . The parents may participate In school activities for th

child while the child is in their care. Each parent shall Inform the.other parent o
. 12 all Information regarding activities .
13
Child's Welfare. Each parent shall prov!de the other parent promptly with recelp
14 of any significant information regarding the welfare of the child,· 1ncllidlng physica
and mental.health,_performance in scho9I, extracurricular activities, etc.
Chljdren's lnyolyeinent Neither parent shall ask the child to make .dE!cisions o
16
requests involving the residential schedule. Neither parent shall discuss. th
17 residential schedule wllh. the child excep_t for plans, which have already bee
agreed to by both parents in advance. Neither parent shall advise the child of th
18 stat.us of child support pay~ent& or other' legal matters regarcling the p_areots
relatlonshlp. Neither parent shall use the. child, directly or Indirectly, to gathe
i9
information about.the other parent or take ve[bal messages to the othE!r parent.
20
Derogatory Com·ments. Neither parent shall make derogatory comments·abou
21 the other parent or allow anyone else to do the same In the child's presence
22
Neither parent shall allow or erjcoui'age the child to make derogatory comment
about the other parent.
23
Deviation from Ressldentlal Schedule: Acceptance and waiver of any deviation
24 ·from· provislohs of this Parenting Plan shall not.constitute acceptance qr wai~er o
25
subsequent deviations from this plan. The·provlsions of this plan shall remain f
effect until modified ,by an appropriate written order by a court of competen
26 jurisdiction; provided, that any and all revisions to this plan are in. writing an
signed.by both parents, and shall be effective Immediately
27
28
CARLJ,OAUL
Auorae)' at LlrPr
1804 HaWmA'9iruo l302
·Paranitng Plan (PPP, PPT, PP) - Page 11 ofU EVe,.tt WA 118201 ; •
WPF DR 01.0400 Mandatory (611008) RCW (426) 269-4147• FACSIMILE (428) 289-7081
26.09.016, .181_; .187; .194
Notification of Child's Events: Each parent Is to keep themselves apprised an
informed regarding Information concerning the well-being of the children
2
Including, but not limited to, copies of report cards, school meeting notices
3 vacation schedules, class programs, requests for confer.ences, results · o
standardized or diagnostic tests, notices or activities Involving the children
4 samples of school work, order forms for school pictures, all communications fro
s health care providers, the names, addresses and telephone numbers of al
schools, health care providers, regular daycare providers, and counselors, a
6 well as mental health records accumulated by said counselors.
7 passport: The parents will cooperate In obtaining a passport for Lauren. Th
8
passport will be kept with the father. Both parents may freely travel to Canada
Mexico and other agreed locations.
9
Educational Decisions: The child shall attend her current school and atten
10 Archbishop Murphy so long as the father continues to pay 100% o fthe tultlo
II and costs. The father or mother shall have the authority to annually enroll th
child In her current school, select optional classes, authorize educational testing,
12 obtain tutoring arid seek education accommodations (e.g. Section 5
Accommodations) for the child. If educational testirtg la done, the results shall b
13
provided to 'both parents. If one parent enrolls the child In school, the othe
14 parent shall be listed as such on each and every form Including the emergenc
contact form at the school.
Changing schools shall be a joint decision and subject to the dlsput
resolution process. If a parent wants Lauren to change schools, that must b
16
suggested In wrHlng by November 15, 2014 for the 2015-2016 school year an
17 by November 15th of any future year. The decision to change schools Is subje
lo joint decision-making and the dispute resolution process. That process mlg
18 need to be on an expedited basis in light of various school appllcatlori deadlines.
Any costs or fees aBBoclated with the dispute resolution process regardln
19
Educational Decisions or to change schools shall be divided according tcf eac
20 party's proportional share of income from Line 6 of the Child Suppa
worksheets. The arbitrator shall ahve the authority to allocate or reallocate fee
21 for cause.
The arbitrator shall issue his or her final decision in writing and fo~ard
22
copy to each party. The original decision shall be filed with the court and shall b
23 binding upon the parties unless an action for court review Is filed within twen
(20) days. The court shall assess coats and reasonable attorneys' fees against
24 party who seeks court review and fella to Improve hie or her position. Unles
25
waived, the court may assess costs and reasonable attorney's fees against
party who unilaterally withdraws a request for court review after costs or fee
26 have been incurred by the opposing party.
27
28
CARLJ,OAVL
Allorney •I Law
11UM Hew!ll Avenue '302
Parontf1rg Pion (PPP, PPT, PP) - Page 12 of 14 Everott WA 88201
WPF DR 01.0-IOIJ Mandatory (611008) - RCW (425) 2SMt47 •FACSIMILE (426) 269·708t
16.09.016, .181; .187; .194
·.
Extracurricular Participation. Neither party shall be n:1quired to have th

· child participate In any activity that takes place during their own parenr
2
residential time with that child.
3 For all decisions that Impact the other parenrs residential time (extra
curricular activities, vacation), either parent s~all notify the other parent via th
case manager, or email after the case manager is released, of the pendln
decision, as soon as is reasonably possible, about the Issue and the propose
decision I solutlori. The other parent has 36 hours to respond. No respons
6 indicates agreeing with the referring parenrs proposed dec!slon. If the parties d
not agree, the dispute shall be submitted to arbitration by Wayne Pellegrini. Th
7 costs of arbitration related to extra-curricular participation shall be borne by th
8 parties per llne 6 of the child support worksheets. The arbitrator shall have th
aut~ority to allo~te or reallocate· fees for cause. The parties shall abide by th
9 rules of the arbitrator insofar as briefing, oral argument and/or fees a
concerned. ·
10
· · The arbitrator shall Issue his or her final decision In writing and forward
II copy to each party. The original decision shall be flied with the court and shall b
binding upon the parties unless an action for court review la filed within !wen
12 (20) days. The court shall assess costs a.nd reasonable attomeys''fees against
party who seeks court review and fails to Improve his or her position. Unles
13
waived; the court may assess costs and .reasonable attorney's fees against
14 party· who unilaterally withdraws a request for court review afte rcosts or fee
have been Incurred by the opposing party.
u· Non-ememency Medical Care. Each parent shall have authority t
schedule routine non-emergency health care appointments (e.g. physical exam
16
or check ups).and minor non-emergency health care fof minor Illnesses or mlno
17 Injuries er.id consent to routine treatment thereOf. The pa~rit shall notify th
other by email of all such appointments and treatment, describing any findings
18 treatments · oi' recommendations. If the health care proilider recomrnend
ongoing. treatment beyond a course of medicailon (e.g. surgery, mullipl
19
appintnients, referral to a specialist or further evaluation), the response will b
subject to joint decision making and the dispute resolution process.
· Non-emeraencv Dental Care. Each parent shall have the authority t
21 schedule routine non-emergency dental care app9intmel')te (eg dental o
orthodontic exams or ch~ck ups or cleanings) and minor, non-emergency denta
22
care for minor dental situations and consent to routine treatment thereof. Th
23 parent shall notify the totier parent by email of al! such appointments an
treatment, describing any findings, tre;nmenta or recommendations. If a denta
or orthodon.tlc provider recommends Ol)golng treatment beyond a course o
25
medication (e.g. surgery, multiple appointments, referral to a specialist or futhe .
evaluation), the resp9nse will be subject to joint decision.making and the dlsput
26 resolution process. Each party may attend dental appointments.
Non-emergency medical and dental appolntmimts sh.all be made by eithe
27 parenf and attended by one parent in order to create a calm environment
. . for th
28
CABLJ;GAlJL
AltomoyatLow
1~ Hewll!AY9nUa aM
Parenting Plnn(PPP, PP'f. PPl-Page 13 of ~4 evareu WA 88201 . _ . .
WPF DR 01.0400 Mandatory (612008) - .RCW (4211) 26M147 •FACSIMILE (425) 259-7081
'26.09.016, .. 181; .187; .194
child. Both parents may attend appointments when dealing with a significan
medlcal or dental issue. The parties will consult with the case manager on thee
2
Issues If there Is a conflict.
3 Deviation from Schedule. Acceptance and waiver of any deviations fro
the provisions of this parenting plan shall not constitute acceptance or waiver o
4 subsequent deviations from this plan. The provisions of this plan shall remain i
effect uritil modified by an appropriate written order by a court ..
7
Dated:
8
9
10
CARL GAUL, WSBA#8341 ANDREW RIFE, Petitioner
II Attorney for Petitioner
12
13 VERONICA FREITAS, WSBA#l9405 JENNIFER MEHADDI, Respondent

14
u
Elise Buie WSBA# 44985
16 Guardian ed Lltem
17
18
19
20
21
22
23
24
2S
26
27
28
CARLJ.OAUL
Altcmcy al law
1804 HowlnAvenuef302
Parenting Plan (PPP, PPT. PP) - Page 14 of 14 E-WA8'201
WPF DR 01.0400 Mandatory (612008) RCW (426) 269-4147 • FACSIMlLE (426) 269·1081
.•
16.09.016, .181; .187; .194
EXHIBIT4
·V. FREITAS LAW, PLLC

210 Summit Avenue East.Seattle~ WA98102 ·I tel• !206)328,7362 Ifax• (206)323-0404
. '•
FILE-D
2
•
'
6
1
Superior Court or Washington
a Counly ofSnobomlsb
9 In ro: No. 0'·3·027SS- I
10
ANDREW RIPn, AGREEDORD!RSTRIKING
II Pellllonor, TRIAL DATE AND 81!.'rl'ING OVER
and FOR BINDING ARBITRATION
12
JENNIFER MEHADDI (flea leMllllr Rift),
IS
ORbER
16 This maner having come befble tho tmdenlgncd Judgo In 1he alloYe entlllcd court based upon lhe
17
agn:cmen1 oflho parties; lhe cowt llavlna reviewed !he mos and records herein and betna fblly advircd In
11 lhe premises, Illa no lhorelbro
·IP ORDERBDADJUDOED AND DECRSED that thecunenl lrlaldnlll In lhlscmeofOctoller I,
20 2014 ls hmby 11rfcken based upon lhe agreement of lite pullcs and, baaed UJIOn f\lnher agreemenl of 1he
21 parlles, lhe mancr shall be scheduled !'or binding arbl11111lon wllh W•JM Pellearfnl Bl B mulually aweed-
22 UJ10ndoicofNovember4,2014.
: Done In open CllW1 lhls L day of ~i/iJo 1 2014,
3'
16 Dal<d: _ _ _ _ _ _ _ __
27 .
Judgr/QM1!11gsh1ner
18
Agrml Order Slrildna Tdal Doto ond Souloa OYcr for VERONICA FREITAS
Blndlna Mllnltlon v. FREITAS LAw Pl.LC.
I
210 Su111111l1 Awn•• £1111

Paa< 1aU S.Ottlo, Wa1bla&1on 98101
(106) J21-7J6l
v@.rrcllmfaw.com
l'ftsented by:
1·
,
4
1 ~0__.~A'""'.
Veronica
~A.,,,....,.,;;,•;.:-~-'"'-...,-~~
Freitas; WSBA No. 19405
Anomiji for Petitioner ·
s
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10
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28
Aarm!OrdcrSiril<Jna Trld Dali: and ScttinaOviil'or . VERONICA FREITAS
Dln4Jna Arbliia1Jon . · . 'y, FRRITAS.LAW,PU.C;
:. 210 Summit ,\qaue f!1d
Plge1ol1 . Stattlr, Wuhlngton 9810!
(206)')18-1361
-~1181~~.com
'·
..... -.. · · - - · - - - - - - - . ' . .

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?~I~ NOV-~ AH IQ: 23
11111~m~~~1m1~11~~~1111~1
CL17054590
m~11 SONYA KRASK/
COUNTY CLERK
SNOHOMISH CO. IVASH

IN AND FOR SNOHOMJSH COUNTY
CASE NO. 05-3-02755-1

ANDREW RIFE
PlaintifT/Petitioner(s) CIVIL MOTIONS -
COMMISSIONER CALENDARS
vs. Unless olherwise provided by applicable rule or stlllute. !his
fonn ond !he motion must be filed wilh !he Clerk not llllcr lhan
JENNIFER MEHADDI (FKA JENNIFER five (S) oourt days preceding the date requested.
RIFE)
Defendwit/Respondent(s)
.. SEE "WHERE TO NOTE VARIOUS MATTERS"ON PAGE 2, to determine where matters are to be set.

November 13, 2014
COURT COMMISSIONER Dote requested:
CIVIL CALENDAR (mm/dd/yyyy)
Motion re Objection to
Tuesday through Friday@ I 0:30 am.
Department A - I" Floor Nature of bearing: _D::.. :;e,;:;.p. :.os"'i"'ti;.:o""n_________
(Confirm hearing at 425-388-3587 or online el

www.snohomishcountvwa.gov/Confinnations)
COURT COMMISSIONER Dale requested:

GUARDIANSHIP/PROBATE CALENDAR (mm/dd/yyyy)
Thursday@ 9:00 a.m. OR Friday@ 9:30 a.m. Nature of b e a r i n g : - - - - - - - - - - - - -

Department D - 1• Floor
(Confirm hearing et 425-388-3587 or online at

www.snohomishcountvwa.gov/Confirmations)
Please nOle llml these colcndarsarc limited 10 14 maum per calendar. Parties for cases noted on the calendar in excess of the 14 maner limit will he
nolificd Dl the time ofcmlirmatim Md v.ill be requin:d lO ~note lhe motiCD'1orsubmi110 an agreed cont.inuan~ date.
lfnoting a presentation, or ifa particular Court Commissioner has already heard a recent motion in the matter, please
indicnte that Coun Commissioner's name here: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
l:IMehaddi\Pleedings\OurB\Objeetlon To OlscooCR.nl"G'lNAl[r Clvil_201410100859577247 (3).Docx 111312014 1of3 2 8y

''
WARNING! CONFIRMATION REQUIRED: In order for the matter lo be heard, the moving party MUST CONFIRM
their motion two (2) court days prior lo the hearing BEFORE 12:00 noon by calling 425-388-3587 or online at
www.snohomishcountvwa.gov/Confinnations
Failure IO notify the Court of a continuance or strike may result in sanctions and/or tenns. SCLCR 7.
This form cannot be used ror trial settings. SCLMAR 2. I SCLCR 40(b).
CERTIFICATE OF SERVICE BY ME:SSENGER AND Noted by: A

EMAIL: _,,/1,~......:::~~-==-----------
1 hereby certify that a copy of this document (Signature)
and all documents listed on page 3 have been mcs<engered Veronica Freitas
and emailed IO lhe attorney listed on page 3:
(Printed name)
19405
Date (mm/dd/yyyy): -'l-"l/~3/2=01'-'4'------- WSBA#
~\j,0 Anomey for: (CHECK ONE)

(Signature) 0 Petitioner/PlainlilT 1:81 Respondent/Defendant
!·lye Kim 0PmSe
(Printed name)

For the most current information on where to calendar various matters see Administrative Order 11-12 which can be found
online al \1Jww.snohomishcountywa.gov/l 3S4/Administrative-Orders
COMMISSIONER CIYIL MOTIONS: The following are heard on the Court Commissioner's Civil Motion Calendar:
Defaults, Discovery Motions and enforcement thereof; Supplemental Proceedings; Unlawful Detainer or Eviction &
Receiver actions; Motions to Amend Pleadings and Petitions for Restoration of the Right to Possess Firearms. Probate and
Guardianship matters are set on the Probate/Guardianship calendar.
PRESIDING JUDGE'S MOTION CALENDAR: The following motions are heard on Presiding Judge's Motion
Calendar: trial continuance, pre-assignment, expedited trial date, jury trial (untimely demand), and motion IO waive
mediation requirement.
RALJ HEARINGS: RAW hearings are noted on the Wednesday morning criminal hearings calendar@ 10:30 a.m. in
room C304 .
.. All other civil motions are heard before lhc Civil Motions Judge••
EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Court Commissioner only, not
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Molion Calendar
or Court Commissioner Calendars must be confirmed two (2) court davs prior to the hearing BEFORE 12:00 noon by calling
425-388-3587 or online at www.snohomishcountvwa.sov/Confirmations.
All matter.; specially set on a Judge's personal calendar must be seliconfirmed/continued/stricken through the Judge's law
clerk. Adoptions, reasonableness hearings and minor settlements are specially set on the Judge's Civil Motions calendar
each Monday and are confirmed through the Civil Motions Judge's law clerk. Judge's calendar rotations and law clerk
contact information is available online al www.snohomishcountywn.gov/DocumenlCenler/Home/View/7655 or by calling
Court Administration at 425-388-3421.
Calendar Nnln 111hould be filed at: All l\lotion!I Heard Al;

Snohoml~h County Snohoml!h County
Superior Court Clrrk'!I Office Superior Court
EvereU, WA 98201 Even:tt, WA 9820 I
l:\Mehaddl\Pleadlnga\Oum\Objectlon To Dlscovery\Calendar Note-Commlsaloner Clvl1_2014101008595n247 (3).Docx 11/312014 2 of 3

Please print the names, addresses etc. of all other attorneys in this case and/or all other parties requiring notice.
Carl Gaul
Name: WSBA#:
302 Bank of America Building 425-259-4147
Address: Phone# Ext
1604 Hewill Ave
Allorney for: (CHECK ONE)
Everett, WA 98201 181 Petitioner/Plaintiff D Respondent/Defendant
D ProSe
Name: WSBA#:
Address: Phone# Ext.
Allorney for: (CHECK ONE)
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
Name: WSBA#:
Address: ~~~~~~~~~~~~~~~
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
List all documents Calendar Note, Motion/Dec with Exhibits, and proposed order
mailed/messengered:
l:IMehaddl\PleedlngslClurslObjedlon To Discovery\Calendar Nole-Commissioner Civ11_2014101008595m47 (3).Docx 11/312014 3 of 3

• • •
FILED
1 2014Nov ~s PH .
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11111~~~Ill~~ II~ II~ ~lllffl ~~~II
3 ' . "o. YIASH
4
00
CL17049604
5

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife NO. 05 3 02755 1
9 Petitioner,
and
10 Motion for Entry of
Jennifer Rae Mehaddi f/kla Rife Order re Modification
11 Res ondent. Parentin Plan Pursuant to Cr 2A
12
Comes now Andrew Rife, Petitioner above named, and moves this Court to enter
13 an Order granting the relief requested in Part I below:
Andrew Rife moves this Court to enter
15 Order re Modification of Parenting Plan and
Agreed/Mediated Parenting Plan Pursuant to CR 2A.
16
II. 'statement of Grounds
17 The parties have reached an agreed modification of parenting plan.

Should the court enter an Order re Modification of Parenting Plan and an Agreed
19 Mediated Parenting Plan?

Agreed/Mediated Parenting Plan Pursuant to CR2(A). Copy attached.
21
Legal Authority
22 RCW 26.09.181(4): "The parents may make a ent parenting plan."
23 Dated: November 4, 2014

24
25
26
CARLJ. GAUL
Attorney at Law
MDT1aN F"DR ENTRY Ct:' 1604 Hewitt Ave. (;
PARENTING PLAN PURSUANT TD CA 2A Everett WA 98201 /'}<),
PAGIE 1 OF" 1 425 259-4147 FAX 259 7081 ,LO
•
...
7
K
County of Snohomish
9
In re:
10
II Petitioner,
and AGREED/MEDIATED
12
13 JENNIFER MEHADDI (fko Jennifer Rife), TOCR2(A)
Respondent.
14 11-~~~~~~~~~~~~~~~.....l-f.~~~~~~~~~~~~~
IS I. General Info aUon

16
17
IR
Lauren Emily Rife 9
IV
II. Basis for Res
21 Under certain circumstances, as outlined below, e court may limit or prohibit a

parent's contact with the children and the right to ake decisions for the children.
22
2~ 2.1 Parental Conduct (RCW 26.09.191(1), (2)
24 Does not apply.
25
2& 2.2 Other Factors (RCW 28.09.191(3))
27 Does not apply.

28
w
ll!IRD Sl"llEET Ml!OIA
~~~1
Parenting Plan (PPP. PPl: PP) - Page~ 11
WPF' DR 01.0400 Mandatory (dt:'.rR f f'l1Jk I A v ,-~-6762
(360)6S8-6SllO•FA
16.09.016.. 181; .181; .194 0 I 'I
2
Ill. Resldentlal S hedule
3
The residential schedule must set forth where th children shall reside each day of the
4 year, including provisions for holidays, birthdays f faml/y members, vacations, and
other special occasions, and what contact the chi ren shall have with each parent.
5
Parents are encouraged to create a resident/al edu/e that meets the developmental
6 needs of the children and individual needs ofthei family. Paragraphs 3.1through3.9
are one way to write your residential schedule. If ou do not use these paragraphs,
7 write in your own schedule in Paragraph 3. 13.
~
3.1 Schedule for Children Under School Ag
9
Does not apply as there are no c:t1ildren un er school age.
10
11 3.2 School Schedule
12 The child shall reside with the mother exce t for the following days and times
when the child shall be with the other pare
I)
14
Every other weekend commencing Thursd at 8:30 a.m. to Monday morning
return to school (8:30 am if there is no sch I on Monday).
15
Every other week (following the weekend in iceted above) the father will have
16
Wednesday commencing at 8:30 a.m. to F ay morning return to school (8:30a
17 if there is no school on Friday).
18 When there Is no school the p k-up and drop off will be at the
mother's residence.
I 'l

21 The child shall reside with the mother durtn winter vacation except tor the
. following days and times that the child shall ide with or be with the other
22
parent.
23
24
25
26 The child shall reside with the mother during ther school breaks except for the
following days and times when the child shal reside or be with the other parent.
27
28
WAYNE P. PELLEGRINI
TIURD STREF.TMF.DIATION
1636 THIRD STREET
Pa1Tnting Plan (PPP. PPT. PP) • Page 2of11 UARYSVIU.E. WASHINGTON 98~fa:
WPF DR 01.0./00 Mandarory (6n008) • RCH' (J6o) ~o. FACSIMILE (36ll)v1 ,.
16.09.016•. 181; ./117; ./94
· Spring break shall be altemated with the her receiving spring break In even
years and the father receiving spring brea In odd years.
2
3 Spring break shall begin at 9:00am on the rs! weekday of the break after school
lets out and shall end at 6:00pm on the las weekday of spring break In order to
4 continue the regular weekend rotation.
s Midwinter break shall be alternated with th mother receiving midwinter break in
6 odd years and the father receiving mldwinl r break in even years. Midwinter
break shall begin at 9:00am on the first we kday after school lets out and shall
7 end at 6:00pm on the last weekday before ool resumes.
8
3.5 Summer Schedule
9
The child shall reside with the mother durin summer break except for the
10
following days and times when the child sh II be with the other parent
II
The Summer Schedule is defined as begin Ing on the first Sunday after the last
12 day of school at 6:00pm and ending at 6:00 m on the last Sunday before school
resumes.
13
14
Each parent shall have residential time on week on/week off schedule with the
exchanges happening at 6:00pm on Sunda . The mother shall have the first full
IS week of summer break in odd years and th father shall have the first full week o
16
17 The parents will be responsible for choosin camps/childcare during their weeks.
18 Vacations should be scheduled during that arent's respective weeks.

19
20 3.6 Vacation With Parents
21 Vacations with parents shall be taken during the summer break and shall be
22
23
24
2S
26
27
28
WAYNE P. PEU EGRINI
TllllU>STll££T Ml!DlATION
16311 TH1RD STREET
Parcnrlug Plan (PPP, PPT. PP) - Page J of I I MAR'ISVIUJ;. WASHMJTON 98270
WPF DR 01.0400 Mnrulatory <611008) - RCll' (380) 65MSBO •FACSIMILE (380)651-6162
26.09.016•. 181; .187; .194
•
-
3.7 Schedule for Holldays
2
The residential schedule for the children fo the holidays listed below is as
3 follows:
4 With Methe With Father

(Specify Ye r (Specify Year
s Odd/Even/Evety)
Odd/Even/E e )
h Martin Luther Day Every
7 President's Day e"""'f
8 Christmas Eve Every
Christmas Day Every
9
New Year's Day Even Odd
10 July 4lh Per3.5
Memorial Day Every
11 Labor Day Every
12
For purposes of this parenting plan, a holld y shall begin and end as follows:
13
Unless specified otherwise below. holidays hall begin at 10:00am and end at
14 7:00pm the same day.
15
Christmas Eve shall commence on 2123 at noon and conclude on
16 12124·at 9:00 p.m.
17
· Thanksgiving shall begin at 10:00om on Th nksgiving Day ond ond ot noon tho
19
Memorial Day, Labor Day shall include the djoining weekend and shall
20 commence Friday after school and conclud Tuesday drop off.at school.
21 Other holidays not listed above that fall on a

with the parent who has the adjoining week
:?2
23 3.8 Schedule for Special Occasions
24 The residential schedule for the children for e following special occasions is as
follows:
25
Odd/Even/Ev Odd/Even/Evetyl
27 Mother's Day Every
28
WAYNE P PELLEGRINI
THIRD STREET MEDIATION
1638 nnRO STREET ~
Parentipg Plan (PP/1, PPT. PP) - Page 4 of 11 MARYSVILLE, WASHINGTON 98270{'..;.(\
WPF DR 01.0400 Mandatory• (612008) - RCW (360)65U5&1 •FACSIMILE (360)6,;f"tJB2>
1ti.09.0/6, .181: .187: ./94
'
Father's Day Every

2
Special occasions.shall begin at 10:00am nd end at 7:00pm on the day of the
J special occasion.
4 3.9 Priorities Under the Resldentlal Schedu e

5
Paragraphs 3.3 - 3.8, have pr1or1ty over pa graphs 3. 1 and 3.2, In the following
6 order:
7 Rank the order ot priority, with 1 being glv the highest priority:
8
3 winter vacation (3.3) 1 holidays (3. 7)
9 4 school breaks (3.4) 2 special occasions (3.8)
I I)
11
3.10 Restrictions
12
Neither parent shall utilize physical or corp ral punishment as a disciplinary tool
13
14
15
Transportation costs are Included in the Chi d Support Wori<shoets and/or the
16
Order of Child Support and should not be in luded here.
17 Transportation arrangements for the childre , between parents shall be as
18
follows:
19 Receiving parent shall provide transportatio , except as otherwise indicated in

3.2 above.
20
21
The children named in this parenting plan ar scheduled to reside the majority of
the time with the mother. This parent Is des nated the custodian of the children
23 solely for purposes of all other state and fed ral statutes which require a
24 designation or determination of custody. Th designation shall not affect either
parent's rights and responsibilities under thi parenting plan.
25
3.13 Other
26
~7
WAYNE P PELLEGRINI~("
THIRD STREET MEDlA TTON ,"\
163& THIRD STREET
Par'rmting Pla11 (PPP, PPT. PP) • Pa~ 5 of I I MARYSV/UE, WASHINGTON 98270
WPF DR 01.0400 Mandatory (6!]008) - RCW ('60) 85M580 • FA~lllltE (leo) 8!11 .. 762
16.09.016, .//JI; .187; ./94
\
· Child's Counselor: Jeanne Paik will con nue as the child's therapist. The
parents shall not communicate with the th rapist unless specifically requested by
2
the therapist. The therapist shall commun le with the "case manager" when
3 there is an issue addressing the needs, a 'vities and/or best interest to the child.
The therapist may contact the parenl(s) if e therapist deems It appropriate
and/or necessary to address Issues. relate to the child. Both parents will
cooperate in scheduling and transporting· e child to the therapy sessions
s through the case manager.
b
Case Manager/Parenting Coordinator: he parents shall directall
7
communication regarding Lauren through case manager for the next 6 months.
8
The case manager Is authorized to hear th concerns/dispute of each parent
and/or child. ·The case manager is further uthorized to communicate directly
9 with the child's therapist. The case manag ris authorized to make or render a
decision. Unless reallocated by the case ri1 nager, ali costs and fees associated
f(i
with the case manager shall be paid by ea parent proportionate to each
II parenrs respective income (line 6 of Child upport Worksheets - current order).
12 • After 6 months, the parties may cont ct the other parent Via email
regarding a decision, dispute or con m that has arisen, Either parent, at
13
any lime, may seek input and a decl ion from the case manager regarding
14 any subsequent dispute or concern r the initial 6 months set forth
abOve. ~·,.,.I.)
15
16
• The case !llanager; OJ...- ~I , Is appointed and agreed upon
by both parties.
17
• .Should ellller party object to the dee! ton of the Case Manager, the' matter
18 shall heard de-novo by motion upon e family court motions calendar.
19
20 Communication: After the initial 6 months ndlcated;above, all communication

thereafter shall be in the form of a writing. ails should be usecfas the primary
21 ·and preferred form of non-emergency Infor tlon, to communicate Information
about the child's school, medical issues, m teal or other appointments school
22
activities. Proposed changes to the parentin time schedule, holiday activities,
23 child's activities and all other parenting relat issues. (email
24 An er Mana ement Assessme t and Pa ntln Classes: The parties agree

the Respondent's new husband, Soufayane ehaddl will complete an anger
2S
assessment With:J)4,..1.:... ~b~ . The pa es agree the assessment report will
21> · be provided to the attorney of the father. Mr Mehaddl' agrees to follow any
....,.,...,,rrimendations Indicated in the assessme t and provide·verification to the
ether's attorney that he has successfully co plated such recommen!lations. \
p ~c,A.. Ii;,'\ ""CZ... \I\~"'- 04 4 • fVHz.. YV\E'\oll ~DO\ ~ lw
. · ,, .~ , ,._ · ,_·.. r-e-ccr+- .\.-a /1
f'l"C>.,..\•-'00 e.... hA.a'A...--\"\ '-""~ l...-lf6f/EP,Pm.t.EGRIN! f.h. ·
·~"50....~ TIURD STREET MEDIATION
1836 THIRD STREET
rting Pion (PPP. Pl'T..PP) • Pog~ 6 ofl I / MARVSVIW!, WASHINGTON
WP DR 01.0400 Mantlutory (612008) • RCW (360)~ •FACSIMILE (360)651-8782
.. . ··~
16.09.016, .181~· .187: .194
<
•
Failure for Mr. Mahaddi to complete this p cess is grounds for modification
pursuant to RCW 26.09.260. Mr. Mehed will also complete the For Kid's Sake
2
Parenting Seminar and provide a copy of is certificate of completion to the
J father's attorney and the court. Both paren swill complete the JIS form and
Include Mr. Mehaddi end any other adult t t has significant contact with the
4 minor child (not grandparents).
Father's Evaluation: The father will provl e to the mplher attorney a copy of his
s
psychological evaluation previously req --1 :f.l' /
l'f"'""' <r1... tv--...h-. f-1,,_::..J..-r:ir:
6 /'<W t • [)~~ -.d f""V;J.,.... ~ 14.(....,.. P ""'~J -
3.14 Summary of RCW 26.09.430 • .480, Reg ing Relocation of a Child
7
8
This is a summary only. For the full text, pl ase see RCW 26.09.430 through
26.09.480.
9
If the person with whom the child resides a ajority of the time plans to move,
IO that person shall give notice to every perso entitled to court ordered time with
the child.
II
If the move is outside the child's school dis ict. the relocating person must give
12 notice by personal service nr by mail requi o a retum receipt. This nntice must
be at least 60 days before the Intended mo e. If the relocating person could not
13
have known about the move in time to give 0 days' notice, that person must
14 give notice within 5 days after leaming of th move. The notice must contain the
Information required in RCW 26.09.440. S also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
·~
16 If the move is within the same school disbi , the relocating person must provide
actual notice by any reasonable means. A arson entitled to time with the child
17 · may not object to the move but may ask for odification under RCW 26.09.260.
18 Notice may be delayed for 21 days ff the rel eating person is entering a domestic
violence shelter or Is moving to avoid a clea , immediate and unreasonable risk
19
20
If information Is protected under a court ord r or the address confidentiality
21 program, it may be withheld from the notice.
A relocating person may ask the court to wa e any notice requirements that may
22
put the health and safety of a person or a c Id at risk.
23
Failure to give the required notice may beg unds for sanctions, including
24 contempt.
25
If no objection is filed within 30 days afte service of the notice of intended
relocation, the relocation will be permltte and the proposed revised
26 residential schedule may be confirmed.
27
28
WAYNE P PELLEGRINI
;.,
TIQRDS1K£ETlol£DIATION ~·
Parcniing Plan (PPP, PPT, PP) • Pag<' 7uf11
1638 THIRD STREET C,
MARY!MU.E, WASHINGTON SB270
WPF DR 01.0lOO Mandatory (612008) - RCW (360) B5M580, FACSIMILE (360) B51-67B2
26.0~.016•• 181: .187: .194
•
A person entitled to time with a child unde a court order can file an objection to
the child's relocation whether or not he or he received proper notice.
2
An objection may be filed by using the ma datory pattern fonn WPF DRPSCU
3
07 .0700, (Objection to Relocation/Petition r Modification of Custody
4 Decree/Parenting Plan/Residential Schad e). The objection must be served on
all perso_ns entitled to time with the child.
5
The relocating person shall not move the lld during the time for objection
6 unless: (a) the delayed notice provisions a ply; or (b) a court order allows the
move.
7
If the objecting person schedules a hearin for a date within 15 days of timely
R service of the objection, the relocating pe n shall not move the child before the
hearing unless there is a clear, immediate nd unreasonable risk to the health or
9
10
II
12
13
4.1 Day-to-Day Decisions
14
15 Each parent shall make decisions regardin the day-to-day care and control of
each child while the child is residing with th t parent. Regardless of the allocation
16 of decision making in this parenting plan, e· er parent may make emergency
decisions affecting the health or safety of th children.
17
18
19 4.2 Major Decisions

20
Major decisions regarding each child shall b made as follows:
21
22 . Nonemergency health care Joint
Counselling Joint
23
Extracurricular activities Joint
2~ Nonemergency dental care Joint
Orthodontia Joint
25 Haircuts/tatteastbady pleFGlng Joint
26
See also attached excerpts for the rocess for decision making
27
as recommended by the GAL Report which excerpts are
28
Pt1rrnting Plan (l'l'I'. Pl'T. PP) - Page 8 of 11

WAYNE P, PELLEGRINI
THIRD STREET MEDIATION
1636 THIRD STREET
WARVSVD.1£. WASHINGTON 98270 ~
<
~
WPF /JR 01.0400 Mt1ndatary (611008) - RCW (380) 658-6580 • FACSIMU.E (380)651-8762
16.119.016, .181: .187: .194
attached hereto and Included In s agreement as If set forth
2 fully herein.
3 4.3 Restrictions In Decision Making
4
Does not apply, there are no llmltations
s
V. Dispute Res
6
7 The purpose of this dispute resolution process is resolve disagreements about

carrying out this parenting plan. This dispute res utlon process may, and under some
8 local court rules or the provisions of this plan mus be used before filing a petition to
modify the plan or a motion for contempt for fail/n to follow the plan.
9
JO Disputes between the parties, other than c ild support disputes, shall be
11
• For the first 2 years (24 months) fro the execution of this agreement all
12
disputes shall be submmed to the manager to be decided.
13
• After 24 months the parties shall su it their disputes to an agreed upon
14
mediator with family law experience. If the parties can't agree upon a
15
mediator the matter shall be submitt to Wayne P. Pellegrini for
mediation.
16
The cost of this process shall be allocated betwee the parties as follows:
17
18 Proportionate to Income (per line 6 o the child support worksheets).
19 The counseling, mediation or arbitration process s all be r.ommenced by notifying the

20
21 In the dispute resolution process:

22
(a) Preference shall be given to carrying ut this Parenting Plan.
23 (b) Unless an emergency exists, the pa nts shall use the designated process
to resolve disputes relating to lmplem ntation of the Plan, except those
24 related to financial support.
25
(c) A written record shall be prepared of ny agreement reached in
counseling or mediation and of each rbitration award and shall be
26 provided to each party.
27
28
WAYNE P. PELLEGRINI
TiflRD SlRE.n MEDIATION ~·
1638 TlilRD STREET
Pa...:nting Plan (PPP, PPT. PPJ - Page 9 of 11 MARVSVl.Lf. WASHINGTON 118270
ll'PF DR 01.0400 ManJaJory (612008) - RCW (3801 Ma.6580 • FACSllAllf (3801651-6762
]6.09.016.. 181; .187; .194
•
(d) If the Court finds that a parent has sed or frustrated the dispute
resolution process without good rea n, the court shall award attorneys'
2
fees and financial sanctions to the her parent.
J (e) The parties have the right of review rom the dispute resolution process to
the Superior Court.
5
VI. Other Provi Ions
6 Telephone Access. When the child of the arties is not residing with a given
parent, that parent shall be permitted unim ed and unmonitored telephone
7
· access or internet web chat with the child long as contact is initiated by the
child.
9 Activities. Each parent shall have the right nd responsibility to ensure that the
child attends school and other agreed upo scheduled activities while In that
10
parent's care. Parents shall attend school nd extracurricular activities and
11 events that fall on their residential days onl .
I~ Chance of Address. Each parent shall pro ide the other with the address and
phone number of his or her residence and all update such information promptl
LI
whenever it changes. Each parent shall p vide the name and birthdates of all
14 individuals who reside in the same home a the child.
15 Affections. Each parent agrees to exert ev reasonable effort to maintain free

access and unhampered contact and com nication between the child and the
16
other parent, and to promote the emotions affection, love and respect between
17 the child and the other parent. Each parent grees to refrain from words or
conduct, and further agrees to discourage o er persons from uttering words or
18 engaging in conduct, which would have a te dency to estrange the child from the
other parent, to damage the opinion of the c ild as to the other parent, or which
19
would impair the natural development or the child's love and respect for the other
parent.
21 Enrichment Activities. The parents may pa cipate in school activities for the
child while the child is in their care. nt shall inform the other parent of
22
all information regarding activltles.
23
Child's Welfare. Each parent shall provide I e other parent promptly with receipt
24 of any significant Information regarding the elfare of the child, including physical
25
and mental health, performance in school, e racurricular activities, etc.
26 Children's Involvement. Neither parent shall sk the child to make decisions or

requests involving the residential schedule. either parent shall discuss the
27 residential schedule with the child except for lans, which have already been
28
WAYNE P, PELLEGRINI
THIRD STRl!ET MEDIATION ... ~
1838 THIRD STREET { )\'
P<lrenting Plan (PPP. PPT. PP)· Pai;< 10 of II MARYSVILLE. WASHINGTON 98270 - lJ
WPF DR 01.0400 Manda100· (612n08i • RCW (!80) 6!18-6511Q •FACSIMILE (360) 651-6762
26.09.016.. 181:. 187: .194
I.
. '
agreed to by both parents In advance. Ne er parent shall advise the child of th

status of child support payments or other I al matters regarding the parents'
relationship. Neither parent shall use the hild, directly or indirectly, to gather
3 information about the other parent or take erbal messages to the other parent.
4 Derogatorv Comments. Neither parent sh II make derogatory comments about

5
the other parent or allow anyone else to d the same in the child's presence.
Neither parent shall allow or encourage th child to make derogatory comments
6 about the other parent.
1
DEVIATION FROM RESIDENTIAL SC E' ULE: Acceptance and waiver of any
8
deviations from provisions of this Parentln Plan shall not constitute acceptance
or waiver of subsequent deviations from th plan. The provisions of this plan
Q shall remain in effect until modified by an a propriate written order by a court of
competent jurisdiction; provided, that any a d all revisions to this plan are in
10
writing and signed by both parents. and sh II be effective immediately
II
NOTIFICATION OF CHILD'S EVENTS: E h parent is to keep themselves
1.2 apprised and informed regimling lnformati r.onceming the well-being of the
children, including, but not limited to, copie of report cards, school meeting
IJ
notices, vacation schedules, class program , requests for conferences, results of
14 standardized or diagnostic tests, notices or ctivities involving the children,
samples of school work, order forms for sc ol pictures, all communications from
15 health care providers, the names, addres and telephone numbers of all
schools, health care providers, regular da ro providers, and counselors, as ~
16
well as mental health records accumulated y said counselors. • ~--r-t---
17 ?11-»( .,i'-T> ~ fDwV~ 11'>1\ c.oopeNO.-tc.. \V\ o~
18 I),, ~">~ ~ LQJ.A.Ye.~. 'TN. f>tA..SSfDk 1Ai1\ \o..a... ~ w
~ ~..\-k.c..r. ~ e~~ fvw'1 -fvo..Ne.I to
t-\L~i c..o o.._,,,...;.. ~ r:A.~v..c.c.a \.o Co:h~ ·
19
__,.~~~=---i
~I
~*1fr'41 ANDREW RIFE.POiliooo
22
23
24
n~-----
VERONICA FREITAS, WSBA1f19405
25 Attorney for Respondent "J / 11/ 1 '/
27
WAYNE P, PELLEGRINI
THIRD STil.F.llT MEDIA no~
1638 TtilRD STREET
P<1r<ntiug Plan (PPP. PPT. PPj • Pag
26.09.016, .181; .187; ./94
.
• Ytr..V-eiA+; ~. '?to.. I\. A~l---VV\~
.
l
L
-1
,./
I .
. - I -. ~'- fld be se nt
---- ..
2 ' ••• I
--- es. ' ,
3 I. - I . ~ . .
. d
.. I - ~
-
4 . .. shou11 beu to COnVf'Y
. . . •.. .- .. - .. .. .
5
6 3. - .
.
-. ~'
-. -'-
.
.... . - .. . . .. nths
- .. . .
·-
. -
7
.. . . ._. - ...
-~· • ·-·-- .-
0f
8
.· - - -
·-f
9
. -L-~
. I I - .- -.
- .. L J.L. - \ v •.
.. l. -
10
-• I - -
11
12
1
. .. • 1 •1
; .. - ·•
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,......_ -
. 13
-
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;• aro1
14 - .
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.15
l6 - \ . ;.-~
·- - --
-,
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17 -- .•. - -- -~
- . I
l~ er
. .. - . .
19 I
,. a., -r I \
20 I
. -
If ft
- ' 1
' ~
:.! J
·' -~ "/!.~
22 Educational Decisio1i's: The child 'shalla'·tend her current schooVt 9'
23 tJcqaglt tlzc i?ZJLqd:Jdcs er Uti8 aul:ucil ;caµ. The father·or mother shall have th
24 o.u.thoriiy to annually enroll .the child in. her cur 'ent school, select optional
25 das3c3,
. .
authorize educational tc ..ting,. obtain h; toring·and scckcducation ac-
'
26 COIJU1lodatio~ le.g; Section,5_04 Accom1Jlodatio LS) for the child, If edµcational

27 teetmgis.done, the results aha.II be provided to >o.th po.rents. If one. pnrent en
-~ REPORT OJ.I'
",.·,,.;
GUARDL\R AD LITBM
' (SBALBDJ
1 .PARB3
Rmi1 28.09;260
1 rolls child in school, the other parent shall be ted as such on each and eveiy
2 form including the emergency contact form at
3 Changing schools shall be a joint decl and subject to the dispute
4 resolution process. If a parent wants Lauren t change schools, that must be
5 suggested in writing by May 1, 2014 for the 2 4-2015 school year or by No-
6 vember 15, 2014 for the 2015-2016 school and by November 15th of any
7 ~ture year. The decision to change schools is ubject lo joint decision-making
8 and the dispute resolution process. That proc es might need to be on an expe-
9 dited basis in light of various school applicatio
10 Any costs or fees associated with the dis ute resolution process regard-
11 ing Educational Decisions or to change achoo shall be divided according to
12 each party's proportional share of Income from Line 6 of the Clu1d Support
.~ 13 worksheets. The arbitrator shall have the au rity to allocate or re-allocate
14 fees for cause.
16 a copy to each party. The original decision sh I be filed with the court and
17 shall be binding upon the parties unless an ac on for court review is filed with·
18 in twenty (20) days. The court shall assess cos and reasonable attorneys'
19 fees against a party who seeks cowt review an fails to improve his or her posi-
20 tion. Unless waived, the court may assess cost and reasonable attorney's fees
:.11 against a party who unilaterally withdraws a uest for court review after
22 cqsts or fees have been incurred by the opposi party.
23
24
25
RBPORTOP fllJl6l1ll/JJ I. BDJa f1l11mJllD fllll/alI1/ll/DrlJ

GUAllDIA!f AD UTGM 1llU 111115" a. #DI
(BBALEDI lmllt.191 &BID
RCW 215.Clll.260 PAOE4 NOlll 12Dll JU.'llll ID lllll B5MIO
,,, ,/J
(bV--K;
\:u_ ,~~ ... 1,...J "" Iv...... .,.,.,____
1 Extracurricular Participation. Neither p ty shall indep~ndently enroll
~"""
'r~
2 the childiln an)! activity that takes piece duri fa';;tl1er part!nt's residential
3 time with that child, .iJ'llcll.l&Ht!irmeel1ten:thictii'ritit!s
4 For all decisions that impact the other p t's residential time (extra-
5 cuniC1.1lar activities,_vacati<?,n),,either parents 1notify the other parent via )-1... c o.o-<- ~ ,,,_..
.f..., &.e-c. n-:tr. • s. r J:*
6 ~ ,
email of the pending decision, as soon is rcaso bly possible, about the issue
7 and the proposed decision/ solution. The othe
8 spond. No response indicates agreeing with th refening parent's proposed de-
9 cision. If the i:i.arties do not agree, the dispute hall be submitted to arbitration
"'·~""4-:U ~-1, <Lt;Y"r'l
10 by be::'f'fu:i.i. The cost'!,, of arbitration related o extra-.cu~ular participation
,,_,. •...., .••• ,.....,. ~ o1 <'.-'S w>J<..y.,...,._
11 shall be borne by Mi', Rife yenhe arbitratdr s have the authority to allocate
12 or re-allocate fees for cause. The parties shall bide by the rules of the arbitra-
13 tor insofar as briefing, oral argument and/ or fe s are concerned.
14 The arbitrator shall issue his or her final ecision in writing and forward c:}';)\
15 a copy to each party. The original decision sha be filed with the court and
16 shall be binding upon the parties unless an ac n for court review is filed with-
!7 in twenty (20) days. The court shall assess cos and reasonable attorneys'
19 tion. Unless waived, the court may assess cost and reasonable attorney's fees
20 against a party who unilaterally withdraws a re uest for court review after
21 costs or fees have been Incurred by the opposln party.
b-"" .
2 Non-emergency Medical Care. Tftt: modJer shal have the authority to schedule
23 routine non-emergency health care appointmcn (e.g. physical exams or check
24 ups) and minor, non-emergency health care for 'nor illnesses or minor inju-
25 ries and consent to rout~nc treatment thereof. c men:;:;;>J&U~~rc
26 by email of all such appointments and treatmen , describing any findings,
!l7 treatments or recommendations. If a healthcar provider recommends ongoing
,
)
I treatment beyond a course of medication (e.g. urgery, multiple appointments, . .,,.r(/'
~ referml to a specialist or further evaluation), e response will be subject to ·· f7
3 joint decision-making and the dispute resolut' ~s. ~.J,"J:i-tl ~ .J 11,. (w-·
on-emergency Dental/ Orthodontic Catt. 'l'h ~ !<hall hRve the authority -[...r'-cr
. J.-t.-
5 to schedule routine non-emergency dental ca appointments (e.g. dental or or- 0~
6 thodontic exams or check ups or cleanings) minor, non-emergency dental Q.' ,..._,; -
7 care for minor dental situations and consent t routine treatment thereof. The
8 father shall notify Ms. Mehaddi by email of all
9 ment, describing any findings, treatments or commendations. If a dental or
IO orthodontic provider recommends ongoing tre ent beyond a course of medi-
11 cation (e.g. surgery, multiple appointments, re rral to a specialist or·further
12 evaluation), the response will be subject to jot decision-making and the dis-
t::..____i_ I 'I J.-1.,,l o-.J.. ..,:. +.,,..- ,_ ~\.y-
........ 13 pUle resolution process. ~ ~ -~:J·~~- ,
14 Consultation. All major decfsfo'i;'; ~ruld ing those items, which c~~
15 are subject to sole decision-making, shall be de by the assigned parent only
16 after reasonable and liberal advance notice an an opportunity for consultation
18
19 4. In o ate¢.ng plan, including a change
20 ~iary parent (which is Mother in
24
25
26
27 event the · 'tiating parent seeks a modification of this parenting plan under
REPORT OF
GUARDIAN AD IJTBlll
fSBAl.BDI
RCW 26.0V.260 PAOB6
'
2 WI gs.
3 5. The parents shall .work with a Case M er &All/ex PW"entmg COOrdma-
.L •J
4 tor for li?~months in an attempt to help educate them on better communication
~A
5 skills and parallel-parenting skills so that they can reduce their conflict~
6
7 Ila I a bj I h hilt.
8 6.
9
10
11
12 7.
·~
13
14 8. The following provisions shall be include in the final parenting plan
15 signed by the parties:
~-,•.l - ·
21 Notificaliun ur Chiltl'>1 Evcnl11. Each p l shall be responsible for

22 keeping themselves advised of school, athletic, d social events in which the
24 Deviation from Schedule. Acceptance an waiver of any deviations from
25 th"e provisions of this parenting plan shall not c netitute ncccptance or waiver
26 of subsequent deviations from this plan. The p ovisions of this plan shall re-
?.7 mRin in effect until modified by an appropriate "tten order by a court of com-
REPORT OF
OUARDIAB AD I.ITEM
(BBAJ.BDI
RCW 26.09.260 PAOB7
•
2
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Order Re Modification/Adjustment
Jennifer Rae Mehaddi f/k/a Rife Of Custody Decree/Parenting
11 Respondent. Plan/Residential Schedule
(ORMDD/ORDYMT)
12 !--~~~~~~~~~~~~~--'-~~~~~~~~~~~~~~
13 I. Basis
14 is order is based on:
15 a finding that adequate cause had been established for hearing the petition.
an agreement of the parties, embodied in an AGREED/MEDIATED PARENTING PLAN
16 PURSUANT TO CR2(A).
11 II. Findings
18 The Court Finds.
19 2.1 Jurisdiction
20 This court has jurisdiction over this proceeding for the reasons below.
21 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
22 "urisdiction under RON 26.27.211.
23 This state is the home state of the children because:
24 the children lived in Washington with a parent or a person acting as a parent for at
25
CARLJ. GAUL
26 Attomey at Law
Order Re Modification/Adjustment 302 Bank of Amenca Bldg.
27 Of Custody Decree/Parenting Pian/Residential Schedule 1604 Hewitt Ave.
(ORMDD/OROYMT) Everett WA 98201
Page 1 · 425 259-4147 FAX 259 7081
. . .
1 proceeding.
2 No othe_r state has jurisdiction.
3 2.2 Modification Under RCW 26.09.260(1), (2)

4 The custody decree/parenting plan/residential .schedule should be, modified becaus_e a
ubstantial change ·of clrcum$!nces has occurred in_ the circumstances of the .children or the
s nonmoving party and the modification is in the best interest of the children and is necessary to
_r\ie the~ lnterest·of the children. This finding is based.on the factors below:
6
The parties agree to the .moclification, hay_ing reachedan agreement, embt>died in ·an
7 GREED/MEDIATED PARENTING PL:AN PURSUANT TO CR2(A).
8 The following facts, .supporting the requested mt>dificatjon, have _arisen since the decree
to
or plan/schedule or were Linkrfown the court at the time of the decree or plan/schedule:
9
The parties have agreed upon modification of parenting plan as embodied.ih the parenting
10 plan of even d11te here.with. '
11 2.3 Modification or Adjusbnent Under RCW 26.0,.260(~) or (8)

12 Does notapply.
13 2.4 Adjusbnents to Residential Provisions Under RCW 26.09.260(5)(a) and(b)

11 D6e5 riot.apply,
is 2.5 AdjusbnentS to Re5idential Provisions'~n_der R,CW 26.09.260(5)(c), (7),

(9) ' .
16
Does notapply.
17
2.5.3 Adjusbnentto Residential Provision Under RcW 26.09.260(S)(c)
18
Does.not apply.
19
2.6 Adjusbnents to Nonre5idential_ Provisions Under RCW 26.09.260(10)
20
"Does not apply.
21
2.7 Su~stantia.I Change in Circumstances _ . ' · ·_ _ .
22 (Complete this part
if airi'~ific:ation or adjustment is based on /Nlragraphs 2.2, 2.4,_
2.5.1, 2.5.3 or 2.6)
23
_ The following substantial change has occurred i(l the circumstances of either party or of the
24 children: The parties have.agreed upon modification.
25
CARLJ.GAUL
26 _ _ _ .Attomey at /.JJw
rder R.e. Modific'ation/Adjustment '302 flank of America Bldg.
27 bf Custody oetree/Parentlng '.Pian/Residential Schedule 1604 Hewitt Ave.
(ORM.DD/0RDYMT) Everett WA 98201
Page 2 425 259-4147 FAX 259 7081
•
1
2.8 ·Protection Order
2
Does not apply.
3
III. Order
4
It is Ordered:
5
The petition to modify/adjust the custody decree or parenting plan/residential schedule is
6 granted. The custody decree or parenting plan/residential schedule signed by the court on
this date or dated is approved and Incorporated as part of this order. This
7 decree or parenting plan/residential schedule supersedes all previous decrees or parenting
plans/residential schedules.
8
Other: Financial issues are reserved for separate determination.
9
10 Dated:
11 Presented by: Copy Received:
12
13
CARL J. GAUL WSBA# 8341 VERONICA FREITAS WSBA# 19405
14 Attorney for Andrew Rife Attorney for Jennifer Mehaddi
15 Copy Received
16
17
ELISE BUIE WSBA# 44985
18 Guardian ad Litem
19
20
21
22
23
24
25
26
CARLl. GAUL
Attorney at Law
Order Re Modification/Adjustment 302 Bank of Amenca Bldg.
27 Of Custody Decree/Parenting Plan/Residential Schedule 1604 Hewitt Ave.
(ORMDD/ORDYMT) Everett WA 98201
Page3 425 259-4147 FAX 259 7081
•
5
6
County of Snohomish
7
in re:
8
9 Petitioner,
and AGREED/MEDIATED
IO
II JENNIFER MEHADDI (!Ka Jennifer Rife), TOCR2(A)
Respondent.
12
14
15
Name
16
Lauren Emily Rife 9
17
18 II. Basis for Restrictions
19 Under certain circumstances, as outlined below, the court may limit or prohibit
parent's contact with the children and the right to make decisions for the children.
20
21 2.1 Parental Conduct (RCW 26.09.191(1), (2))
22 Does not apply.

23
2.2 Other Factors (RCW 26.09.191(3))
24
Does not apply.
25
26 Ill. Residential Schedule
27
28
CARLJ.GAUL
Arulmey at Law
1604 Hewitt Avenue #302
Parenting Plan (PPP. PPT. PP)· Page I of 13 Everett WA 88201
WPF DR 01.0400 Mandatory (612008) - RCW (425) 259"'147 •FACSIMILE (425) 259-7081
26.09.016, .181; .187; .194
'
The residential schedule must set forth where the children shall reside each day of th
year, including provisions for holidays, birthdays of family members, vacations, an
2
other special occasions, and what contact the children shall have with each parent.
3 Parents are encouraged to create a residential schedule that meets the developmenta
needs of the children and individual needs of their family. Paragraphs 3. 1 through 3.
4 are one way to write your residential schedule. If you do not use these paragraphs,
5
write in your own schedule in Paragraph 3. 13.
·Schedule for Children Under School Age
Does not apply as there are no children under school age.
School Schedule
The child shall reside with the mother except for the following days and time
when the child shall be with the other parent:
Every other weekend commencing Thursday at 8:30 a.m. to Monday mornin

return to school (8:30 am if there is no school on Monday).
Every other week (following the weekend indicated above) the father will hav
Wednesday commencing at 8:30 a.m. to Friday morning return to school (8:30a
if there is no school on Friday).
When there is no school the pick-up and drop off will be at the mother'
residence .
.Schedule for Winter Vacation
The child shall reside with the mother during winter vacation except for th
following days and times that the child shall reside with or be with the othe
parent.
Schedule for Other School Breaks
The child shall reside with the mother during other school breaks except for th
following days and times when the child shall reside or be with the other parent.
Spring break shall be alternated with the mother receiving spring break in eve
years and the father receiving spring break in odd years.
CARLI. GAUL
Anorncy UI I.aw
1604 Hewitt Avenue 0302
ParenJing Plan (PPP. PPT, PP) - Page 2of13 Everett WA 68201
WPF DR 0/.0400 Mandatory (612008) • RCW (425) 259-4147 •FACSIMILE (425) 259-7081
26.09.016, .181; .187; .194
·. Spring b~eak shall begin at 9:00am on the first weekday of the break after schoo
lets out and shall end at 6:00pm on the last weekday of spring break in order t
2
continue ·tt:ie regular weeken_d rotation.
3
Midwinter break shall be alternated with the mother receiving midwinter break i
4 odd years and the father receiving midwinter break in even year,;. l\AidwJn_te
5
break shall begin at 9:00am on the first weekday after school lets out and shal
end at6:00pm on the last week.day before school resumes.
6
3.5 Summer Schedule
7
8
The child shall reside with tile mother during summer break except for th
following clays and times·wiien the child shall be with the other parent.
9
'The Summer Schedule. is defined as beginning on the first Sunday after the las
IO
day of school at 6:00pm and ending 'at-6:00j:>m on the last. Sunday before sc;hoo
11 resumes.
12 Each parent shall have residential time on a week on/week off schedule with th
exchanges happening at 6:00pm on Sundays. The mother shall have the first ful
13
week of summer break·in odd years and the fattier shall have the fi_rstfull week o
14 summer brea~ in evel) years.
15 The parents will be responsible for choosing camps/childcare· during their weeks.
i6
Vacations should be. scheduled during that parei:irs respective weeks.
i7
3;6 Vacation With Parents
18
Vacations with parents shall be taken during the summer break and sha!I b
19
schedul.ed on each parents' own weeks.
20
3:7 Schedule.for Holidays
21
The residential schedule for the children for the h.olidays listed below is a
22
follows:
23
Wrth Mother With Father
)4 (Specify Year (SpecifyYear
·25 Odd/Even/Every) Odd/Eveh/Everyl
Marti("! Luther King Day Eve,.Y
26 President;s Day · Every
Thanksgiving Day· Even Odd
21' Christmas Eve Every
28
CARLl GAUL
A11amcy'a1 Uw
1604 Hewltt'Avenue #302
ParentingP/an (PPP. PPT. PP)-Page Jo/ 13 Everett WA 88201
WPF DR 01.0400 Mandaiory {612008) - RCW (425) 259-4147 •FACSIMILE (425) 259-7081
·26.p9.016. .[81; .187; ./94
. .
Christmas Day Every
"New Year's Day Even Odd
2
July 4th Per 3.5
3 Memorial Day Every
Labor Day Every
4
5
For purposes of this parenting plan, a holiday shall begin and end as follows:
6 Unless specified otherwise below, holidays shall begin at 10:00am and end a
7:00pm the same day.
7
8 Christmas Eve shall commence on 12123 at noon and conclude on 12/24 at 9:0
p.m.
9
Thanksgiving shall begin at 1O:OOam on Thanksgiving Day and end at noon th
11
Memorial Day, Labor Day shall include the adjoining weekend and shal
12 commence Friday after school and conclude Tuesday drop off at school.
13
-Other holidays not listed above that fall on a Friday or a Monday shall be spen
15 3.8 Schedule for Special Occasions

16
The residential schedule for the children for the following special occasions is a
17 follows:
19
Mother's Day Every
20 Father's Day Every
21 Special occasions shall begin at 1O:OOam and end at 7:00pm on the day of th
special occasion.
22
23 3.9 Priorities Under the Residential Schedule
24 Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the followin
25 order:
26 Rank the order of priority, with 1 being given the highest priority:
27 3 winter vacation (3.3) 1 holidays (3. 7)
28
CARLJ. GAUL
Atlorney 111 Law
1804 HewittAvenue#3D2
Parenting Plan (PPP. PPT, PP) - Page 4of13 Everett WA 98201
WPF DR 01.0400 Mandatory (612008) - RCW (425) 25S..147 •FACSIMILE (425) 259-7081
26.09.016, .181; .187; .194
' .
4 school breaks (3.4) 2 special occasions (3.8)
2
3 3.10 Restrictions
4 Neither parent shall utilize physical or corporal punishment as a disciplinary too
5

7 Transportation costs are included in the Child Support Worksheets and/or th
8
Order of Child Support and should not be included here.
Transportation arrangements for the children, between parents shall be a
9
follows:
IO
Receiving parent shall provide transportation, except as otherwise indicated i
II 3.2 above.
12
13
The children named in this parenting plan are scheduled to reside the majority o
14 the time with the mother. This parent is designated the custodian of the childre
solely for purposes of all other state and federal statutes which require
15
designation or determination of custody. This designation shall not affect eithe
16 parent's rights and responsibilities under this parenting plan.
17 3.13 'Other
18
Children's Involvement. Neither parent shall ask the child to make decisions o
19 requests involving the residential schedule. Neither parent shall discuss th
residential schedule with the child except for plans, which have already bee
20 agreed to by both parents in advance. Neither parent shall advise the child of th
21
status of child support payments or other legal matters regarding the parents
relationship. Neither parent shall use the child, directly or indirectly, to gathe
22 information about the other parent or take verbal messages to the other parent.
23 Child's Counselor: Jeanne Paik will continue as the child's therapist. The parent
24 shall not communicate with the therapist unless specifically requested by th
therapist. The therapist shall communicate with the "case manager" when ther
25 is an issue addressing the needs, activities and/or best interest to the child. Th
therapist may contact the parent(s) if the therapist deems it appropriate and/o
26
necessary to address issues related to the child. Both parents will cooperate i
27
28
CARLJ, GAUL
Anorney at Law
Parenting Plan (PPP, PPT. PP) - Page 5of13 Everett WA 98201
WPF DR 01.0400 Mandatory (612008) - RCW (425) 259-4147 •FACSIMILE (425) 2511-7081
26.09.016, .181; .187; .194
scheduling and transporting the child to the therapy sessions through the cas
manager.
2
3 Case Manager/Parenting Coordinator: The case manager, Debra Riehl, i

appointed and agreed upon by both parties. The parents shall work with th
4 Case Manager for 24 months in an attempt to help educate them on bette
5
communication skills and parallel-parenting skills so that they can reduce thei
conflict. The case manager is further authorized to communicate directly with th
6 child's therapist. Unless reallocated by the case manager, all costs and fee
associated with the case manager shall be paid by each parent proportionate t
7 each parent's respective income (line 6 of Child Support Worksheets - curren
8
order).
9 • The parents shall direct all communication regarding Lauren through

case manager for the next 6 months. Either parent, at any time, may see
10
input and a decision from the case manager regarding any subsequen
11 dispute or concern after the initial 6 months set forth above. The cas
manager is authorized to hear the concerns/dispute of each parent and/o
12 child. The case manager is authorized to make or render a decision
After 6 months, the parties may contact the other parent via emai
13
regarding a decision, dispute or concern that has arisen.
14
• Should either party object to the decision of the Case Manager, the matte
15 shall heard de-novo by motion upon the family court motions calendar.
16
Communication: After the initial 6 months indicated above, all communicatio
17 thereafter shall be in the form of a writing. Emails should be used as the prima
and preferred form of non-emergency information, to communicate informatio
18 about the child's school, medical issues, medical or other appointments schoo
19
activities, proposed changes to the parenting time schedule, holiday activities,
child's activities and all other parenting related issues.
20
.Anger Management Assessment and Parenting Classes: The parties agree th
21 Respondent's new husband, Soufayane Mehaddi will complete an ange
22 assessment with Dale Todd. The parties agree the assessment report will b
provided to the attorney of the father, paid by Mr. Mehaddi. Mr. Mehaddi wil
23 provide monthly compliance report to father's attorney. Mr. Mehaddi agrees t
follow any recommendations indicated in the assessment and provide verificatio
24 to the father's attorney that he has successfully completed sue
25 recommendations. Failure for Mr. Mahaddi to complete this process is ground
for modification pursuant to RCW 26.09.260. Mr. Mehaddi will also complete th
26 For Kid's Sake Parenting Seminar and provide a copy of his certificate o
completion to the father's attorney and the court. Both parents will complete th
27
28
CARLJ.GAUL
Anomcym Law
1804 Hewitt Avenue "302
Parenting Plan (PPP, PPT, PP) - Page 6of13 Everett WA 98201
WPF DR 0/.0400 Mandatory (612008) - RCW (425) 259-4147 •FACSIMILE (425) 2511-7081
26.09.016.. 181: .187: .194
. ' .
JIS form and include Mr. Mehaddi and any other adult that has significant conta
with the minor child (not grandparents).
2
3 Father's Evaluation: The father will provide to the mother attorney a copy of hi
psychological evaluation previously required and follow any treatmen
4 recommendations and provide monthly reports to mother's attorney.
5
3.14 Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child
6
This is a summary only. For the full text, please see RCW 26.09.430 throug
7 26.09.480.
8 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 wit
9
the child.
IO
If the move is outside the child's school district, the relocating person must giv
II notice by personal service or by mail requiring a return receipt. This notice mus
be at least 60 days before the intended move. If the relocating person could no
12 .have known about the move in time to give 60 days' notice, that person mus
give notice within 5 days after learning of the move. The notice must contain th
13
information required in RCW 26.09.440. See also form DRPSCU 07.0500
14 (Notice of Intended Relocation of A Child).
15
If the move is within the same school district, the relocating person must provid
actual notice by any reasonable means. A person entitled to time with the chil
16 may not object to the move but may ask for modification under RCW 26.09.260.
17 Notice may be delayed for 21 days if the relocating person is entering a domesti
violence shelter or is moving to avoid a clear, immediate and unreasonable ris
18 to health and safety.
19 If information is protected under a court order or the address confidentiali
program, it may be withheld from the notice.
20
A relocating person may ask the court to waive any notice requirements that ma
21 put the health and safety of a person or a child at risk.
22 Failure to give the required notice may be grounds for sanctions, includin
contempt.
23
If no objection is filed within 30 days after service of the notice of intende
24 'relocation, the relocation will be permitted and the proposed revise
25 residential schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection t
26
the child's relocation whether or not he or she received proper notice.
27
28
CARLI.GAUL
AUOl'IIC)' aS Law
Parenting Plan (PPP. PPT. PP) - Page 7 of 13 Everett WA 98201
26.09.016, .181; .187; .194
An objection may be filed by using the mandatory pattern form WPF DRPSC
07.0700, (Objection to Relocation/Petition for Modification of Custod
2
Decree/Parenting Plan/Residential Schedule). The objection must be served o
3 all persons entitled to time with the child.
4 The relocating person shall not move the child during the time for objectio
unless: (a) the delayed notice provisions apply; or (b) a court order allows th
5 move.
6 If the objecting person schedules a hearing for a date within 15 days of time!
service of the objection, the relocating person shall not move the child before th
7 hearing unless there is a clear, immediate and unreasonable risk to the health o
8
9 IV. Decision Making
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control o
each child while the child is residing with that parent. Regardless of the allocatio
of decision making in this parenting plan, either parent may make emergenc
Major Decisions
Major decisions** regarding each child shall be made as follows:

"Nonemergency health care Joint
Counselling Joint
Extracurricular activities Joint
Orthodontia Joint
Haircuts Joint
** For decision making see also part VI
Restrictions in Decision Making
Does not apply, there are no limitations.

24
25 V. Dispute Resolution
26 The purpose of this dispute resolution process is to resolve disagreements abou

carrying out this parenting plan. This dispute resolution process may, and under som
27
28
CARLJ.GAUL
Allomcy DI Law
Paren1ing Plan (PPP, PPT. PP) - Page 8of13 Everett WA 88201
26.09.016, .181; .187; .194
local court rules or the provisions of this plan must be used before filing a petition t
modify the plan or a motion for contempt for failing to follow the plan.
2
3 Disputes between the parties, other than child support disputes, shall b
4
5
• For the first 2 years (24 months) from the execution of this agreement al
6
• After 24 months the parties shall submit their disputes to an agreed upo
7
mediator with family law experience. If the parties can't agree upon
8 mediator the matter shall be submitted to Wayne P. Pellegrini fo
mediation.
9
10
II Proportionate to income (per line 6 of the child support worksheets).
12 The counseling, mediation or arbitration process shall be commenced by notifying th

13
14
15
(b) Unless an emergency exists, the parents shall use the designated proces
16 to resolve disputes relating to implementation of the Plan, except thos
related to financial support.
17
(c) A written record shall be prepared of any agreement reached i
18 counseling or mediation and of each arbitration award and shall b
provided to each party.
19 (d) If the Court finds that a parent has used, or frustrated the disput
20
21 (e) The parties have the right of review from the dispute resolution process t
the Superior Court.
22
23
24 Telephone Access. When the child of the parties is not residing with a give
25 access or internet web chat with the child so long as contact is initiated by th
child.
26
27
28
CARLJ,GAUL
Anomcy al Law
1804 Hewtn Avenue #302
Parenting Plan (PPP, PPT, PP) - Page 9 of I 3 Everett WA 98201
26.09.016, .181; ,/87; .194
! •
Activities. Each parent shall have the right and responsibility to ensure that th
child attends school and other agreed upon scheduled activities while in tha
2
parent's care. Parents shall attend school and extracurricular activities an
3 .events·that fall on their residential days only. Each parent shall be responsibl
for keeping themselves advised of school, athletic and social ev:ents in whic~ th
5
Extracurricular Participation. Neither party shall be required to have the chil
6 participate in any activity that takes place during their own parent's residentia
time with that child.
7 For all decisions that impact the other parent's residential time (extra
8
curricular activities, vacation), either parent shall notify the other parent via th
case manager, or email after the case manager is released, of the pendin
9 decision, as soon as is reasonably possible, about the issue and the propos
decision I solution. The other parent has 36 hours to respond_. No respons
10
indicates agreeing with the referring parent's proposed decision. If the parties d
11
not agree, the dispute shall be submitted to arbitration by Wayne Pellegrini. Th
costs of arbitration related to extra-curricular participation shall be borne by th
12 parties per line. 6 of the child support worksheets. The arbitrator shall have .th
authority to allocate or reallocate fees for cause. The parties shall abide by th
13
rules of the arbitrator insofar as briefing, oral argument and/or fees ar
14 concerned.
The arbitrator shall issue his or her final decision in writing and forward
15 ·copy to each party. The original decision shall be filed with the court and shall b
binding upon the parties ·unless an action for court review is filed within twen
16
(20) days. The court shall assess costs and reasonable attorneys' fees against
17 party who seeks court review and fails to improve his or her position. Unles
waived, the court may assess costs and reasonable :attorney's fees against
18 party who unilaterally withdraws a request for court review afte rcosts or fee
have been incurred by the opposing party.
19
20 Notification of Child's Events: Each parent is to keep themselves apprised an

informed regarding information concerning the well-being of the children
21 including, but not limited to, copies of report cards, school meeting notices
vacation schedules, class programs, requests for conferences, results o
22
standardized or diagnostic tests, notices or activities involving the _children
health care providers, the names, addresses and telephone numbers of al
24 schools; health care providers, regular daycare providers, and counselors, a
25"
well as mental health records accumulated by said counselors.
26 Enrichment Activities. The parents may participate in school activities for th

·child while the child is in their care. Each parent shall inform the other parent o
27 all information regarding activities.
28
CARLI GAUL
AUomcy al Law
Parenting Plan (PPP, PPT, PP)- Page JO of 13 Everett WA 98201
WPF DR 01.0400 Mandatory (612008) - RCW (425) 259-4l47 •FACSIMILE (425)259-7081
2_6,09.016, .181; .187; .194
.. .
Change of Address. Each parent shall provide the other with the address an
2
phone number of his or her residence and shall update such information promptl
3 whenever it changes. Each parent shall provide the name and birthdates of al
individuals who reside in the same home as the child.
4
5
Affections. Each parent agrees to exert every reasonable effort to maintain fre
access and unhampered contact and communication between the child and th
6 other parent, and to promote the emotions of affection, love and respect betwee
the child and the other parent. Each parent agrees to refrain from words o
7 .conduct, and further agrees to discourage other persons from uttering words o
8
engaging in conduct, which would have a tendency to estrange the child from th
other parent, to damage the opinion of the child as to the other parent, or whic
9 would impair the natural development of the child's love and respect for the othe
parent.
10
II Derogatorv Comments. Neither parent shall make derogatory comments abou

the other parent or allow anyone else to do the same in the child's presence
12 Neither parent shall allow or encourage the child to make derogatory comment
13
14 Child's Welfare. Each parent shall provide the other parent promptly with receip
of any significant information regarding the welfare of the child, including physica
15 and mental health, performance in school, extracurricular activities, etc.
16
Deviation from Residential Schedule: Acceptance and waiver of any deviation
17 from provisions of this Parenting Plan shall not constitute acceptance or waiver o
subsequent deviations from this plan. The provisions of this plan shall remain i
18 effect until modified by an appropriate written order by a court of competen
jurisdiction; provided, that any and all revisions to this plan are in writing an
19
·signed by both parents, and shall be effective immediately
20
Passport: The parents will cooperate in obtaining a passport for Lauren. Th
21 passport will be kept with the father. Both parents may freely travel to Canada
Mexico and other agreed locations.
22
23 Educational Decisions: The child shall attend her current school and atten
Archbishop Murphy so long as the father continues to pay 100% of the tuitio
24 and costs. The father or mother shall have the authority to annually enroll th
25
child in her current school, select optional classes, authorize educational testing
obtain tutoring and seek education accommodations (e.g. Section 5
26 Accommodations) for the child. If educational testing is done, the results shall b
provided to both parents. If one parent enrolls the child in school, the othe
27
28
CARLJ. GAUL
Attmncy Ill Law
1804 HSINltt Avenue 1302
Pareniing Plan (PPP. PPT. PP) - Page 11 of I 3 Everett WA 98201
WPF DR 01.0400 Mandatory (612008) - RCW (425) 259-4147 o FACSIMILE (425) 259-7081
26.09.0L6, .181; .187; .194
. . ..
parent shall be listed as such on each and every form including the emergenc
contact form at the school.
2.
Changing schools shall be a joint decision and subject to the disput
3 resolution process. If a parent wants Lauren to change schools, that must b
suggested in writing by· November 15, 2014 for the 2015~2016 school year an
4 by November 15th of any future year. The decision to change schools is subje
to joint decision-making and the dispute resolution process. That process migh
need to be on an expedited basis in light of various school application deadlines.
6 Any costs or fees associated with the dispute resolution process regardin
Educational Decisions or to change schools shall be divided according to eac
7 party's proportional share of income from Line 6 of the Child Suppo
8
worksheets. The arbitrator shall have the authority to allocate or reallqcate fee
for cause.,
copy to each party. The original decision shall be filed with the court and shall b
10
binding upon the parties unless an action for court review is filed within. twen
II (20) days. The court shall assess costs and reasonable attorneys' fees against
party who seeks court review and fails to improve his or her position. Unles
12 waived, the court may assess costs and reasonable attorney's fees against
·party who unilaterally withdraws a request for court review after costs or fee
13
have been incurred by the opposing party.
14
Non-emergency Medical Care. Each parent shall have authority to schedul
15 routine non-emergency health care appointments (e.g. physical exams or chec
ups) and minor non-emergency health care for minor illnesses or minor injurie
16
and consent to routine treatment thereof. The parent shall notify the other b
17 email of all such appointments and treatment, describing any findings, treatment
or recommendations. If the health care provider recommends ongoing treatmen
ls beyond a course of medication (e.g. surgery, multiple appintments, referral to
specialist or further evaluation), the response will be subject to joint decisio
19
making and the dispute resolution process.
20
Non-emergency Dental Care. Each parent shall have the authority to schedul
21 routine non-emergency dental care appointments (eg dental or orthodonti
exams or check ups or cleanings) and minor, non-emergency dental care fo
22
minor dental situations and consent to routine treatment thereof. The paren
23 shall notify the toht:1r parent by email of all ·such appointments and treatment,
describing any findings, treatments or recommendations. If a dental o
24 ·orthodontic provider recommends ongoing treatment beyond a course o
25
medication (e.g. surgery, multiple appointments, referral to a SJ:1ecialist or futhe
evaluation), the· response will be subject to joint decision~making .and the disput
26 resolution process. Each party may atte.nd dental appointments.
Non-emergency medical and dental appointments shall be made by eithe
27 parent and attended by one parent in order to create a calm environment for th
28
CARL J. GAUi.
AltOmcy a! Law
1604 H8wltt Avenue #302
Parentingf'/ari (P('P, PPT. PP)~ Page 12of13 Everett WA 98201
26.09.016, ,181; .187; ./94
....
medical or dental issue. The parties will consult with the case manager on thes
2
issues if there is a conflict.
3
Deviation from Schedule. Acceptance and waiver of any deviations from th
4 provisions of this parenting plan shall not constitute acceptance or waiver o
s subsequent deviations from this plan. The provisions of this plan shall remain i
·effect until modified by an appropriate written order by a court.
ANDREW RIFE, Petitioner
JENNIFER MEHADDI, Respondent
CARLI.GAUL
Anorncy 01 Law
Everett WA 98201
(425) 259-4147 •FACSIMILE (425) 259-7081
... ...
..
medical or dental issue. The parties will consult with the case manager on thes
2
issues if there is a conflict.
3
Deviation from Schedule. Acceptance and waiver of any deviations from th
4 provisions of this parenting plan shall not constitute acceptance or waiver o
5
subsequent deviations from this plan. The provisions of this plan shall remain i
effect until modified by an appropriate written order by a court.
6
7 Dated:
8 Judge I Commissioner
9
10 CARL GAUL, WSBA#8341 ANDREW RIFE, Petitioner

II
Attorney for Petitioner
12
VERONICA FREITAS, WSBA#19405 JENNIFER MEHADDI, Respondent
13 Attorney for Respondent
14
15 ELISE BUIE, WSBA# 44985

Guardian ad Litem
16
17
18
19
20
21
22
23
24
25
26
27
28
CARL J. GAUi.
Anamcy Bl Law
Parenting Plan (PPP, PPT. PP) - Page 13af13 Everett WA 98201
WPF DR 01.0400 Manda1ory (612008) - RCW (425) 2594147 •FACSIMILE (425) 259-7081
26.09.016,. 181;. 187; .194
Fl LED
1
2 SO~YA K~ASKI
COUH 1Y CLE~i'i
3 c.1,· 1t1nt~15H CO. \'/ASH
~ "'
4
5
7 In Re the Marriage of: No.OS 3 02755 1
Andrew Scott Rife,
8 Petitioner CALENDAR NOTE (NTC)
and . llUs form must be filed with the Oerk not later than twelve
9 Jennifer Rae Mehaddi, f/k/a Rife, (12) days preadlng the date requested. 5CLCR 7(b)(2)(C).
Respondent Responses to motion mu.I be Hied five ( S) court days before
10 1!1e heanng. Replies ID responses must be Hied 1!1ree (3)
court days before 1!1e heanng.
11
12 AND TO: Veronica Freitas, Attornev. for Jennifer Rae Mehaddi
AND TO: Elise Buie, Guardian ad Litem
13
FAMILY LAW / DOME5nC CALENDAR- Date: November 17, 2014 at 9:00 a.m.
14
Court Commissioner Nature of Hearing:
15 Department B or c, As Assigned Presentation of Parenting Plan a.
Order re Modification pursuant to
16 CR2A Mediated Settlement
17 Matters set before a Court Commissioner will be assigned later to a particular department The assignment be will
posted the day of the hearing. Extended motions are set by the Court Commissioner, not a party or counsel. If a
presentation, or if a particular Court Commissioner has already heard a recent motion on the matter, please indicate
18 Court Commissioner _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
19 WARNING: The moving party MUST CONFIRM by noon two (2) court days prior to the hearing In order for the
matter to be argued. Failure to notify the Court of a continuance or strike may result in sanctions and/or terms.
20
- -- ----r-
SUCR 7(b)(2)(E). This fonn cannot be used for trial settings. 50,M'AR 2.1 40(b).
21
22
Dated: November 4, 2014 ~
=CA~RL~l.~G=A~U~L.....,..±~~~~~~~
7
Attorney for An
23 Declaration of Service
I, CARL J. GAUL, declare under penalty of perjury of the laws of the State of WashlngtDn, that on November S,
24 2014, I sent by email a copy of Motion for Entry of Parenting Plan Pursuantto CR2Aand a copy of the document to which
is dedaratlon is affixed, to the following persons, addressed as follows:
25
Veronica Freitas Elizabeth Buie
26 Attorney at Law Guardian ad Utem
v@vfreltaslaw.com "'el!E!ise5!b~~E!!!..!~!!!llll!!!l~!!.!J
27 Executed at Everett, November 5, 2014
28
-
.... p i -1..: •
"; .... ' .
'l"!~ NOV -G M'\ [Q: 34
\\~~\~~\\l~\\~\ll\1\11
CL17048398
SOHYA KRASKI
COUHTY CLERK
SNOHOMISH CO. WASH

CASE NO. 05-3-02755-1

ANDREW RIFE
Petitionei{s) FAMILY LAW MOTIONS
Unless otherwise provided by applicable rule or statute, this

vs. form and the motion must be filed with the Clerk not later
than twelve (12) calendar days preceding the date
JENNIFER MEHADDI (FKA JENNIFER requested. Responses to motion must be filed live (5) £2!!.!1
days before the bearing. Replies to responses must be filed
RIFE)
three (3) court day• before the hearing.
Respondent(s)
TO: The Clerk of Coun:

Date requested: November 24, 2014
FAMILY LAW/DOMESTIC CALENDAR
(nun/dd/yyyy)
Monday through Friday@ 9:00 a.m. Motion re Objection to
Department B or C as assigned. Nature of hearing: _D_e~p_os_i_ti_o_n_________
•Department assignment will be posted the day of the

hearing (Confirm hearing at 425-388-3587)
CHILD SUPPORT MODIFICATIONS Date requested:

(mm/dd/yyyy)
Mondays@ 1:00 p.m.
Department D Nature of h e a r i n g : - - - - - - - - - - - - -
(Confirm hearing at 425-388-3587)
PRO SE DISSOLUTION CALENDAR Date requested:

(mm/dd/yyyy) ••NO CONFIRMATION REQUIRED**
Wednesday@ 12:30 p.m. only
Department C
Agreed Matters and Default Orders only

***NO CONTESTED MATTERS***
If noting a presentation, or ifa particular Court Commissioner has already heard a recent motion in the matter,
please indicate that Court Commissioner's name here: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
l:\Mehaddl\Pleadlngs\Ours\Objection To Discovery'°• 8..LGJ ~ALoac, 1114/2014 1of3

-
WARNING: The moving party MUST CONFIRM by calling 425-388-3587 two (2) court days prior to the hearing
BEFORE 12:00 noon, in order for the matter to be heard.
Failure to notify the Coun of a continuance or strike may result in sanctions and/orterms. SCLCR 7(b)(2)(H).
See below for other confirmation and noting information.
CERTIFICATE OF SERVICE BV MESSENGER AND Notedby:..t

EMAIL: ..L(}.,~...,./~
.J.-<::::=._ _ _ _ _ _ _ _ __
I hereby cenify that a copy of this document (Signature)
and all documents listed on page 3 have been messengered Veronica Freitas
and emailed to the attorney listed on page 3: -------------------
(Printed name)
19405
Date (mm/dd/yyyy): 11/04/2014 WSBA#
--=-o.~-------
~\)10 Attorney for: (CHECK ONE)

(Signature) D Petitioner/Plaintiff 181 Respondent/Defendant
H'<E: lCIN OProSe
(Printed name)
FOR PARTIES PRO SE: Noted by: D Petitioner D Respondent
lfservice is required, you must also file a RETURN OF

SERVICE. Failure to do so may result in your hearing not (Petitioner's signature)
being heard.
Please check in the Law Library for more information (Petitioner's printed name)
regarding service.
(Respondent's signature)
(Respondent's printed name)
FAMILY LAW/DOMESTIC MOTIONS: Most family law & domestic motions are heard on a Coun
Commissioner's calendar. The exceptions are matters relating to trial settings, trial continuances, motions for
revision, motions to waive mediation requirement, and motions to enforce CR2A agreements; please refer to the
Civil Motion Calendar Note regarding these motions.
EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Court Commissioner, not
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Trial
Continuance Calendar or Court Commissioner Calendars must be confirmed at 425-388-3587 two (2) coun days
prior to the hearing BEFORE 12:00 noon. All other matters noted before an individual judge must be
set and confirmed through the Civil Motions Judge's Law Clerk at 425-388-3421. If you reach voice mail when
Calendar Notes should be filed nt: All Motions Heard At:

Everett, WA 9820 I Everett, WA 98201
l:\MehaddilPleadings\Ours\Objection To Discovery\Note For Motion Family Law.Doc, 1114/2014 2 of 3
' '
Please print the names, addresses etc. of all other attorneys in this case and/or all other parties requiring
notice.
Carl Gaul
Name: WSBA#:
302 Bank of America Building 425-259-4147
---------------
1604 Hewitt Ave
Everett, WA 9820 I r8J Petitioner/Plaintiff D Respondent!Dcfendant
D Pro Se
Name: WSBA#:
Address: - - - - - - - - - - - - - - - Phone# Ext.

0ProSe
Name: WSBA#:
Address: - - - - - - - - - - - - - - - Phone# Ext.

D Petitioner/Plaintiff D Respondent!Dcfendant
D Pro Se
Name: WSBA#:
---------------
D Pro Se
Name: WSBA#:
---------------
D Pro Se
Calendar Note (Motion/Dec with Exhibits, and proposed order

List all documents mailed: delivered previously 1 I /4/2014)
l:\Mehaddi\Pleadings\Ours\Objection To Discovery\Note For Motion Family Law.Doc, 1114/2014 3 of 3

r:1L E[':
f • •"
2
zn1~NOV 10 AHll: 15
3
SONY/>. KR/>.SKI
4
5
l~~IW~IWllH~~lll~I~~~
CL16806305
COUNTY CLERK
SNOHOMISH CO. WASH
7
In re:
9
IO Petitioner,
II
and Notice of Absence
Res ndent.
13
TO: CLERK OF COURT
15 PLEASE TAKE NOTICE that VERONICA FREITAS will be out of the State or
otherwise unavailable on the following dates:
16
17 November 24, 2014 through November 28, 2014

December 22, 2014 through January 2, 2015
18
February 16, 2015 through February 20, 2015
19 April 13, 2015 through April 17, 2015
20
It is requested that motions and other court hearings not be scheduled to occur during the
21 time of this absence and that motions and other hearings be scheduled so there is sufficient time
to prepare for them following the end of the absence. There is no other attorney available with
22 sufficient factual knowledge ofthis case to respond lo any substantive request for relief during
23
my absence.
DATED October 15, 2014.
24
Respectfully submitted,
25
26
27 VERONICA FREITAS, WSBA #19405

28
VERONICA FREITAS
Notice of Absence 2IO Summil Avenue Eost
Page 1 of I (206) 328-7362
v@vfreitaslaw.com
FILEt1
20l~NOV 17 PH I: 51+
1
2
SONYA KRASKI
~CL16808657
~ ~1111111111~111~~11111111
COUNTY CLERK
SNOHOMISH CO. WASH
3 11m11
4

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
10 Declaration of Counsel Opposing Motion
Jennifer Rae Mehaddi f/k/a Rife to Quash Subpoena Duces Tecum
11 Res ondent.
ashington, that the following is true and correct. ·
13
14
I am attorney for Andrew Rife. I make this declaration to oppose Ms. Freitas' Motion
15
to Quash Subpoena.
16
FACTS
17
Andrew Rife brought a petition for modification of parenting plan. That matter has
18
been resolved with entry of a new permanent parenting plan on November 17, 2014.
19
The entry of a new parenting plan did not resolve all issues. The parties have
20
agreed that child support and attorney fees issues are to be resolved by binding arbitration
21
before Wayne Pellegrini. The arbitration is presently pending.
22
Mrs. Mehaddi has alleged that the petition was brought in bad faith, without
23
reasonable cause.
24
This action was filed in 2013 after an incident of domestic violence during which
25
26 CARLJ. GAUL
Attorney at Law
DECLARATION CF COUNSEL 0PPCISING
~:;~c~ ~~ ~UASH SuBPCENA DucEs TEcuMQ RIGINA L 1604 Hewitt Ave.

Everett WA 98201
425 259-4147 FAX 259 7081
1 Soufyane Mehaddi threatened to hit then the eight year old daughter. Mrs. Mehaddi called
2 911 for assistance at the time, and placed the daughter with her father, Andrew Rife, "until
3 urther notice."
4 Guardian ad Litem Elise Buie determined that the allegations of domestic violence
5 ere a "red herring" (her term) and that there was no domestic violence in the Mehaddi
6 home. Andrew Rife did not share her opinion.
7 Pursuant to Andrew Rife's request, on April 28, 2014 GAL Elise Buie allowed review
8 of her file and provided over 1200 pages of material from that file. Mr. Rife paid the
9 copying charges for the copies he received.
10 In August 2014 there was another incident of domestic violence between Jennifer
11 Mehaddi and Soufyane Mehaddi. The police report shows that he spit in her face twice and
12 hit her. He was arrested for Assault 4 DV, but the prosecutor did not charge him with any
13 offense.
14 On September 11, 2014 the parties mediated pursuant to Snohomish County Local
15 Special Proceedings Rule 94.04. The mediation was partly successful, resulting in the
16 permanent parenting plan entered on November 17, 2014.
17 The GAL's file from April 27 to current has been requested three times by email.
18 Mrs. Buie claimed to be too busy to respond timely to the first request. At the second
19 request she had the flu and promised to be out of the office for at least a week. At the third
20 request she claimed her file had no relevance, and was beyond any sort of discovery time
21 rame. Thereafter she was served a subpoena for production of documents on November
22 7, 2014. She responded on November 6, 2014 by refusing to provide any documents

23 ithout a court order.
24 3. NEED FOR GUARDIAN AD LITEM FILE
25 To respond to the allegations that this is bad faith litigation Andrew Rife needs to
26
CARLJ.GAUL
Attorney at Law
DECLARATION CF' COUNSEL OPPOSING 1604 Hewitt Ave.
MOTION TC QUASH SUBPOENA 0UCES TECUM Everett WA 98201
PAGE 2 CF" 3 425 259-4147 FAX 259 7081
..
1 review the Guardian ad Litem's file concerning the 2013 domestic violence incident(s) to
2 help establish the good faith basis of his petition for modification.
3 To explain the reasons Andrew Rife was unable to accept the Guardian ad Litem's
4 refusal to address the issue even after the August 2014 domestic violence incident, Mr.
s Rife needs access to the material in the GAL's file.
6 4. GUARDIAN AD LITEM RULES REQUIRE PRODUCTION OF THE FILE
1 Guardian ad Litem Rule 2 provides in part
8 (p) Maintain documentation. A guardian ad litem shall maintain
documentation to substantiate recommendations and conclusions and
9 shall keep records of actions taken by the guardian ad litem. Except as
prohibited or protected by law, and consistent with rule 2(n), this
10 information shall be made available for review on written request of a
party or the court on request. Costs may be imposed for such
11 requests.
12
GALR 2(p) provides a right to the file material, just because the party wants it.
13
ndrew Rife has volunteered to pay copying costs. The GAL has no legal basis for
14
declining to produce the file as requested.
15
16 (
17
on November 17, 2014
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorney at Law
DECLARATION CF" COUNSEL CPPCSING 1604 Hewitt Ave.
MOTION TC QUASH SUBPOENA OUCES TECUM Everett WA 98201
PAGE 3 OF' 3 425 259-4147 FAX 259 7081
,
fui!
.. p~
~... r I.
.• 1-.. ;,._,
..
ZOI~ NOY 17 1111 IO: 48
1
.. ·2 . SONYA KRASKI
COUNTY CLERK
·4 CL16808470

(
I
COUNTY OF SNOHOMISH \I
7
a In re:
Andrew Scott Rife
9 · Petitioner, NO. 05 3 02755 1
and
10 Order Re Modification/ Adjust
Jennifer Rae Mehaddl f/k/a Rife Of CUstOdy Decree/Parenting
11 Respondent. Plan/Reslilentlal Schedule
(ORMDD/ORDYMT)
12 t--~~~~~~~~~~~~_._~~~~~~~~~~~~~
13 I. Basis
14 Is order Is based on:
15 a finding that adequate cause had been established for·hearing the petition.
an agreement of the parties, embodied In an AGREED/MEDIATED PARENTING PLAN
16 PURSUANT TO'CR2(A).
11 u. Findings
1a The Court Finds.
19 2.1 Jurisdiction
20 This court has jurisdiction over this p_roceedlng for the reasons below.
21 This court has exduslve continuing j11rlsdlctlon. The court has previously made a child
custody;. parenting plan; residential schedule or visitation determination In this matter and retains
22 "urlsdlctlon under.Rew 26.27.211.
23 This state is the home state of the chiidren because:

24 the chUdren lived In Washington with a parentor a person acting as a parent for at
least six consecutive months Immediately preceding the commencement of .this
25
26 CARLJ;GAUL
Attomey at I.aw
Order Re Modification/Adjustment . 302 Bank of America Bldg.
· 27 Of custody Deaee/Parenllng Plan/Resldentfal Schedule 1604 Hewitt Ave.
(ORMDD/ORDYMT)
Page 1 · 0 RIGINAL 425
EverettWA 98201
25~-4147 FAX 259 7081
1 proceeding.
2 No other state has jurisdiction.
3 2.2 Modification Under RCW 26.09.260(1), (2)
4 The custody decree/parenting plan/resldentlal schedule should be modified because a
substantial change of circumstances has occurred In the circumstances of the children or the
s nonmoving party and the modification Is In the best Interest of the children and Is necessary to
erve the best interest of the chlldren. This finding Is based on the factors below:
6
The parties agree to the modification, having reachedan agreement, embodied In an
7 GREED/MEDIATED PARENTING PLAN PURSUANT TO CR2(A).
e The following facts, supporting the requested modification, have arisen since the decree
· or plan/schedule or were unknown to the court at the time of the decree or plan/schedule:
9
The parties have agreed upon modification of parenting plan as embodied in the parenting
10 plan of even date herewith.
11 2.3 Modification or Adjustment Under RCW 26.09.260(4) or (8)
12 Does not apply.
13 2.4 Adjusbnentsto Residential Provisions Under RCW 26,09.260(5)(a) and (b)
14 Does not apply.
15 2.5 ·Adjustments to Residential Provisions Under RCW 26.09.260(5)(c), (7),
(9) .
16
Does not apply.
17
2.5.3 Adjustment to Residential Provision Under RCW 26.09.260(S)(c)
18
Does not apply.
19
2.6 Adjusbnents to Nonresidential Provisions Under RCW 26.09.260(10)
20
"Does not apply.
21
2.7 Substantial Change In Circumstances
22 {Complete this part If a mad/Rcatlan or at(Justment Is based an paragraphs 2.2, 2.4,
2.5.l, 2.5.3 or 2.6)
23
. The following substantial change has occurred In the circumstances of either party or of the
24 hlldren: The parties have agreed upon modification.
25
CARLJ.GAUL
26 Attomeyat law
Order Re Modification/Adiustment 302 Bank of America Bldg.
27 Of custodv Decree/Pareniing Plan/Residential Schedule 1604 Hewitt Ave.
(ORMDD/ORDYMT) Everett WA 98201
Page2 425 259-4147 FAX 259 7081
. -.
~
1
2.a ·Protection Order
2
Does not apply.
3
III. Order
4
ItisOidered:
5
The petltlon:to ll)Odlfy/adjustthe clist<idy decree or parenting planiresldentlal schedulels
6 granted. The custody decree or parenting plan/residential 5chedule signed by the court on
this date or dated . ls.approved and 111corporated as part of tlils order. This
·7 decree or parenting plan/residential sched1,1!e supersedes all prevloll!? decrees or parenting
plans/residential schedules.
8
Other: Financial Issues are rese.rved for separate determination. 'JI..
A •• £)~
9
r ,
Dated: . ~ · Yl,.<11~
10 · ...Mtge I Commission ~1-
12
13
14'
-VE~AS WSBA# 19405 .
Attorney for Jennifer Mehaddl
15 Copy Received
16
17
ELISE BUIE.WSBA#449BS
18 Guardian ad Utem ·
19
20
21
22
23
24
25
CARL J. GAUL .
26 Altomey at Law
Order Re Modification/Adjustment . 302 sank Of. Anienca
Bldg.
27 Of Custodv Decree/Parenting Plan/Residential Schedule 1604 Hewitt Ave;
(ORMOD/ORDYMT) . Everett WA 98201
Page3 425 259-4147 F~ 259 7081
. ~· •j '
...
2 20l~NOV 17 f1H IQ: '48

3
4
~\I\CL16808471
\\II\\\\ II\ \\1\11\\1\ \I\\\ 11\1\ \I\\\ 1\1\\\Ill\\\I\\II\ SONYA KRASKI
COUHTY CLERK
SNOHOMISH CO. WASH
·S
Superior Court of Wasbi1tgton
. 6
County of Snohomish
·7
Inre: I
8
ANDRBW RIFE, No. 05·3-02755~1
9 Petitioner,
and AGREED/MEDIATED
10 PARENTING. PLAN PURSUANT I.
II .JBNNIFaR MBHl\DDI (fka Jennifer Rlfo),. TOCR2(A)

RcspQJldcnt.
12
14 1'.hls parenting plan,applles to the following chllit:
IS
Name
16
Lauren Emily ~lfe
17
18 II. Basia for Restrictions

19 Under certain otroumst8naes, as outlined below, the oourt may· 'limit. or prohibit
. p818nl's oontaot with the. children and the tfght to flleke decisions for the children.
20
21 2.1 Parental CO!\duot (RCW 28.09.191 (1 ), .(2))
22 Does not apply.

23
2.2 Other Factors (RCW 28.'09•191(3))
24
Does not apply.
2S
26
m! Residential schedule
27
28
¢ARLJ.CWJL
M\orBfiJ' "tt.\Y
1804 K8\lll!Ave11110#$o2
PtJrt1J1tlngPlan(PPP, PPT. PP)-Pilgo ioJIJ .EVerott WA 08101
WPF DR 01;0400 Mt111dtifory (6/JOOB) • RCW (4211) 2&9r4147 •FACSIMILE. (426) 269~ _
26.09.016•• 1s1: .181: .• 194 ·OR.I GIN AL. I ~"\ _iq\

11
1 The res/dant/81 schedule must satforth where the children shali reside each day of th
year, Including provisions for holidays, b~rthdays. of family members, vacations, an.·.
2
othai: spec/sf occasions, and what contact the chlldre11 shall have with each parent.
3 Psmnts em encouraged to create a re~ldantlsl schedule that meats the developments
nasds of.the· children and lndlvldual neee!s of-the/; family. Psragmphs.:$.1 throt:jgh 3.
4 am otie way to write your resldenUsl schedule. ff yau do not use these parsg~phs,
s write In your own schedule fri Parsgraph 3.13. ·
6 3.1 ·Schedule for Cl_tlldren Under School Age

7 Does not apply as· there are no children under school age.
8
3;2 Scl_tool Schedule •.
~
The ohlld shall reside with the mother .except for the fol!owlng days and tl~e
10 when the child shall be with the other parent:
II
Every other weekend commen~lng Thursday at 8:30 a.m. to Monday mornln ~
12 return to school (8:30 am If there Is no school on Monday). ~tG<-Mf IN! . 1;1 '"-7.' i(i.c{ ·
. . . S'vb,-e1e+- ~ ~~-
13
Every other week (followlng the weekend Indicated above) the father wlll hav
. 14 Wednesday commencing at 8:30 a.m. to Friday morning-return to school (8:30a
If there fa no school on Friday).. s .t'Ct r+t'"'q t\. t1 •i.lf
IS
16
When -there Is no schooi the pick-up and drop off wlll be at the mother'
residence. · ·
17
3.3 r
Schedule for Winter Vacation .
- - . -
18
The c~llC! shall reside with the. mother during winter vacation except for th
19
following days and times that the chlld shall reside with or. be with the othe
20 _parent. ·
21 Sarne as school schedule.
22
3.4 · Schedule for Other School Breaks
23
The chlld shall reside with the mother dµrlng .other school breaks except for th·
24 followlng days and times when the chlld shall reside or b!I with' th~ other.parent.
2S
Spring break shall be altemated with the molher receiving spring break In eve
26 years and 'Iha father receiving spring break In odd years,
27
28
CABLJ. OAUL \('
Pnrentl1igPln11 (PPP, 'PPT, PP)-Page2 ojJJ

~;;:r~~..nuq~D2
l!VervttWA88201 . ·
WPP DR 01.(HOO Montlntory (611008) RC.IY . (425)_269-4147 •FACSIMILE (426) 2611-7081
26.09.016. .181; .187; .194
Spring break.shall.begin at 9:00am on.the flrsiwe.ekday of the break after schoo
lets 0ut and. shall end at 6:00pm· on the. last weekday of -spring break In order t
2
continue the regular weekend rotat_lon.
3 . . .
Midwinter break shall be alter;,ated wit~ the.mother receiving !Jildwlnter b~k I
4 odd years and the father receiving midwinter break In even years. Mldwlnte
· . break shall begin at 9:00am on the first weekday after school lets out and ahal
end at 6:00pm o~ the last weekday.before ilcho~I resumes.
6
3.6 · Summar Schedule
7
8
, The chl!d shall reside with the mother during sunm:ier break except for th ·
following daye:and times when the child shall be with the other parent. ·
'The Summer Sehedule la. defined aa. beginning on the first Sunday after the las
day of school at 6:00pm and. ending at 6:00pm on the last Sunday bef6re achoo
resumes.
Each parent shall have ~~l~entlal tiJne .on aweek oh/week ()ff schedule with th
exch~ngee happer:ilng at 6:00pm .on.Sundays, The mother shell have the first ful
week of summer breal< In odd years and the father shalthave the first full week.o
The.parents
. wlll l>e responsible for choosing camps/childcare during their weeks.
· Vacations should be scheduled ~urlog that parent's r9!1Peotlv9 .weeks~
Vacation With Parent$
· Vacations with parents shal) be taken during the summer break and shall .b
scheduled on each parents' e>wn weeks.
Schedulafor·Holldaya
The resldentlal schedule for the children· for the holidays llste"d below Is a
follows:

(SP!iclfVYear (Spe_clfy Year
OddlEvBh/Every)_ Odd/Eyen/EveOO
Martin Luther King Day Every
President's Day Every
Than~glvlrig Day· Even Odd
:r·
Christmas Eve Every
CARLJ, GAUL
Allom6y~l1 Law • . .
1804 K8'111n twenuo 0302 ·
ParenJtng Plan (PPP, PPT, PP) - Page J af 13 EvarottWA8ml .
.WPF DR 01.0400 Mnndn/ol'y (612008) - RCll' (426) 25Ml47 •FACSIMILE (428) 2$7 i
26.09.016, .• 181; .187; .194 .
.. Christmas pay Every
'New Year's Day Even Odd
2
July41h Per 3.$
J Memorial Day Every
Labor Day Every
4
For purposes of this parenting plan! a hol!day shall begin and Eind as.follows:
s
6 Unless specified .otherwise below, holidays shall beglrt at 10:00E1m arid end a ·
7:00pm the:same 9ay.
7
8
Christmas Eve shall commence:on 12123 at noon and rionclude on 12124 atQ:O
p.1J1. C..\n('\<;,.\WI"" \;) u~ s'-'ci,;\\ <...o\fVIV\M.,v\c.c_ '\·\. C\'.CX'.l?'"" .
9 \~I?.'!.\ GW\.~ C,.cN\,"-\u.k. · o.;\- q!<>Of"" ~v- \l/'l.5 • · ·
Thanksgiving shall begln·at 10:00am on Thanksgiving Day and·end at.noon th
to day afterThanksglvlng.
II
Memorial Day, Labor Day shall Include the adjoining Weekend .and. shal
12 .commence Friday after school and co.nclude Tuesday drop off at school.
13 ·Other holidays not Hilted above that fall on a Friday or a Monday shall be spen
u 3.8 Schedule. for Speolal Occasions
16 The resldenUal achedule for the children for the following special occasions Is a
17 follows: ·
18 (Spec1ryvear (Specify Year
Odd/Even/Everv> OddfEimn/Everv)
19
.Mother's Day Every · ·
20 Father's.Day Every
21 Special occasions shall begin at 10:00am and end·at 7:00pm on the day of th
special occasion. ·
22
23 3;9 Priorities Under the Reslderitlal Sche.~~!8
24 Paragraphs 3.3 - 3.8, have priority over paragraphs 3;1 and 3.2, In the fcillowl
25
order:
2(j Rank the order ofprlority, with 1 belng,glven the highest priority:
27 3 winter vacaU_on (3,3) 1 hoUdays (3.7)
28
Parenting P/im.(PPP. PPT. Pl') - Paga., of 13

WPF DR 01.0400 Mtilulatm;y (6120.08) - RCW
26.09.016, ,/81; ,/81; .194
4 school breaks (3.4) 2 special oecaslons (3.8)
2
3 3.10 ReatrloOona
4 Neither parent shall utilize physical or corporal punishment as a dlsclpllnary too
s or allow a third party to do the sa~e. ·

7 Transportation costs are Included In the Child .Support Worksheets and/or th
8
Order of Child Support and should not be Included here.
Transportation arrangements for the chlldren, between parents shall be a
9
follows:
10
Receiving parent shall provide transportation, except as otherwise Indicated I
11 3.2 above.
3.12 Designation ofCua~dlan

12
13
The children named In this parenting plan are scheduled to reside the majority o
14 the time with the mother. This parent Is designated the custodian of the chlldre
15
s.olely for purposes of all other state and federal statutes which require
deslgnatton or determination of custody. This designation shall not affect elthe
16 parent'I! rights and responslbUitlea under this parenting plan.
11 3.13 'Other
18
Children's Involvement. Neither parent shall.ask the child to make decisions o
19 requests· Involving the residential schedule. Neither parent shall discuss th
residential schedule with the child except for plans, which have already bee
20 agreed to by both parents In advance. Neither parent shall advise the chlld of th
21
status of child support payments or other legal matters regarding the parents
relatlonshlp. Neither parent shall use the child, directly or lndlreclly, to gathe
22 Information about Y,e other parent or take verbal messages to the other paren~.
23 Child's Counselor: Jeanne Palk will continue as the child's theraplsl The parent
24 shall not communicate with the therapist unlesa spec!flcally requested by th
therapist. The therapist s11all communicate with the •case manager" when the~
2S Is an Issue addressing the needs, activities and/or best Interest to the child. Th
therapist may contllct the parent(a) If fl!e therapist deems It appropriate and/o
necessary to address Issues related to the chlld. Both parents will cooperate
27
28
CARLl.OA!JL
Attomv at Law
1804 Hev.lft Avanua 11302
Pnnnt/ngP/OJ1 (PPP, PPT. PP)-PagoJ of/3 l!vMltl WA 88201
WPP DR 0/.04~0 Ma11datory (612008) - RCW (42SJ m-4147 • FACSIMILE (425) 269-7081 '
26.09.016. .181; .181; .194
scheduling and transporting the child to the therapy; sessions ~hrough the cas
manager.
2
3 Case Manager/Parenting Coordinator: The case manage~. Debra Riehl, l

appointed and agree~ upon by both parties. The parents shall work with th
Case Manager for 24 months In an attempt.to help educate.. them on bette
communication skllls and parallel-parenting skills so that they can reduce thel
· confllcl ·The case manager Is further authorized to communicate dlreclly wlth·th
6 child's therapist. Uni.ass reallocated· by .the case manager; all C08ts and ~e
associated with the case manager shell .be paid by each parent proportionate t
7 each.parenfs respective Income (lfne 6 of-Child SUpport Worksheets.:. curren
8
order); ·
9 • The parents shall dl~ct all communication regarding Lauren through

oase.managerJor the next 6 months. Elther·parent, at any time, may se
10
Input and a decision from the case llltlnager regarding any subs!iquen
II dispute or concern after the lnltlal 6 months set forth above. The oas
manager Is author~d to hear the concerns/dispute of each parent ancl/o
12 child. The case manager Is authorlzecJ to. make or render a decision
After 6 months; the parties ·may contact the other parent via emal
13
regarding a decision, dispute or coni:em that has arisen.
14
• Should elthlilr party object to the decision of the Case Manager, the matte
IS shall heard de-novo ~Y motion upon the·famlly court motions calendar.
IG
Con'!mynlcajlon: After the lnfllal 6 months Indicated above, all communlcatlo
17 thereafter shall be In the form of a writing. emails should be used as the prime
and preferred form of non-emergency lnfol'ITlatlon, to communtcate lnformatlo
18 about the ohlld'~ school, medical (ss1,1es, medlcal or other appointments achoo
19
actlvltles, proposed changes to the p~rentlng time schedule, holiday activities
child's actlvltlee·and
. all other
. parenting related Issues. . ·
20
,AngerManagement A!sess1nent and Parenting Classes: The parties agree th
21 Respondenfs new. husbSJld, Soufayane Mehaddi wm complete . an ange
2l assessment with ~~.\-\ • . The.pai:tles agree the asse8sni81'!t report will b
provide.cl to 'the a.ttomey of ·the fet~er, paid by Mr. Mehaddl. Mr. Mehaddl wll
23 provide monthly compliance report to fathet's attorney. Mr. Mehaddl agree~
follow any. recommendations Indicated In the li!lsessmeilt and provide vei'lflcatlo
24 ·10 the father's attorney ·that he has. successfully · completed sue
2S recommendations. Fallure for Mr. Mahaddl to complete this process Is ground
for modification pursuant to RCW·26~09;260. Mr. Mehaddl wtu also complete th
26 For Kid's Sake Parenting Seminar and provide a copy of. his certfflcate o
completlon to the father's attorn13y and the c~urt. Both parents wlfl tomplete .th
27
* Associated Behavioral Health 800-858-6702
28 "
~.
CARLJ.OAYL
M'-Jaii:..,
1804 HwiltlAY8nua AOl
Pllllllllirg P/(111 (PPP, Pl'T, PP) • Page 6 ofJ3 "EYlllOllWA98201
WPF DR 0/,0400 Mn111intory (6/2.00J) • /K:W (426) 2&Ml47 • FAC81Mll.E (426) 2&9-7081
26.09.016, .181; ./87; .194
.•
JIS form and Include Mr. Mehaddl and any other adult that has significant contao
with the minor chlld (not grandparents).
2
3 Father's Evalygtlgp: The ~ther wlll provide to the mother attorney a copy of hi
psycho1og1cat eva1uat1on prev1ouary requ1rea ana follow any treatmen
4 recommendations and provide monthly reports to mother's a~orney. ·
5
3.14 Summary of RCW 28.09.430 • ABO, Regarding Relocation of a Child
6
This la a summary only. For the full text, please see RCW 26.09.430 throug
7 26.09.480.
8 If the per8on 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 wit
9
the child. ·
10 If the move la outside the child's school district, the relocating person must glv
II
notice by personal service or by mall requiring a return receipt. ,Thia notice mus
. be at least 60 days before the Intended move. If the relocating person could no
12 .have ~nown about the move In time to give 60 days' notice, that person mus
give notice within 6 days after learning of the move. The notice must c.ontaln th
13 Information required In RCW 26.09.440. See also .form DRPSCU 07.0600
(Notice of Intended Relocation of A Child).
.,
14
If the move la within the same school district, the relocating person must provld
actual notice by any reasonable means. ·A person entitled to time with the chit
16 may·not object"to the move but may ask for modification under RCW 26.09.26Q.
Notice may be delayed for 21 days If the relocating person la entering a domeatl
17
a
violence shelter or la moving to avoid clear, Immediate and unreasonable rls
18 to heallh_and safety.
19 If lnfonnatlon la protected under a court order or the address confldentlalil
program, It may be withheld from the n<?tlce.
20
A relocating person may ask the court to waive any notice requirements that ma
21 put the health and safety of a person or a child at risk.
22 Failure to give the required notice may be grounds for sanctions, lncludln
contempt.
23
If no· objection la filed within 30 days after service of the notice of lnt.ende
24 'relocatlon, the relooatlon wlll be permitted and the proposed revise
25 resldentlal
.
.
A person entitled to time with a child under a cou.rt order can file an objection t
26
the chlld's relocation whether or not he or ahe received proper notice.
cr-
27
28
CARL.L QMJL
. . AUon>Ol'lllA\"I
1804H81'o111AV8ml81302
Paren/J1ig Plan (PPP, PPT, PP)· Pago 1af13 EVetett WA 88201
WPP DR 01.0400 Mandatory (612008) • RCW (4i&) 269-4141 •FACSIMILE (428) 269-7081
26.09.016•• 181; .181; .194
Ail objection may be filed by using the mandatory pattern form WPF PRPSCU
07.0700, (Objection to R"elooatlon/Petltlon for Modification of Cueto
2
Decree/Parenting Plari/Resldentlal Schedule). The objection must be served o
3 - all persona-entitled to time with 'he:chlld. ·
The relocaUng person shall not move the Phlld during. the time for objeotlo
unless: (a) the delayed .not!~ provisions apply; or (b) a court order allows th
s move.
6 If the objecting parson schedules a hearing for a data within 15 days of tlinel
service of the objectlori, the relocating parson shall no~ move the child before th
7 heaHng.unles!l there ls a clear, Immediate and unreasonable i'lakto the hesllh o .
8
safety of a parson oi' a child. ·
9 IV. Decision Making ·

10 4.1 Day-to-Day Decisions
II
..
Each parent shall make decisions regarding, the day-to~ay care and control o
12 each- child whDa the child Is residing with that parent. Regardless of the allocatlo
of decision m11klng In this .parenting plan, .either parent may make emergen
13 decisions affecting .the health or safety of the children. .
14
4.2 Major Deblalona
IS
Major decisions** regarding each child.shall be made as follows:
16
17 Education decisions Joint

'Nonemergency health care Joint
18 Counselling · · Joint
ExtraourrloulEir activities Joint·
19
20 Orthodontia Joint
Haircuts Joint
21 .. For decltilon making see also part VI
22
4.3 Reati'lotlona In o,clal.on Making
23
Does not apply, there are no limitations .
.24
25 V. Dispute Re~olutlon
. .
u . The purpose of this dispute resolution process 18. to f!18o/ve d/sagr&ements abou .
carrying Ol!t this parenting plan. This dispute resolution process may, and under ·s.om
27
28
.CARL 1. GAUL
/1110mqr11taw
1804 Hav.flt Avenue ISCl2 . ~
·
Parenthig Pion (PPP, PPT, PP).· Pags·s qfJJ EwratlWA9NOI ·
WPF DR OJ.0~00 Mandatory (611008) • RCW (420) 209..Sl47 • PACSIMllE (426) 20D 81
26.09.016, .JBJ; ./87; .• 194
1 local court rules or the provisions of this plan must be used before filing a petition t
modify the plan or a motion for contempt for faf/lng to follow the {)Ian.
2
3 Disputes between the parties, other than child support disputes, shall b
4
• For the first 2 years (24 months). from the execution of this agreement al
disputes shall be submitted to the case.managerto be decided.
6
• After 24 months the parties shall su~mlt their disputes to an agreed upo
7 mediator with family law experience. If the parties can't agree upon
8 mediator the matter shall be submitted to Wayne P. Pellegrlnl fo
mediation. ·
9
JO •
11 Proportionate to lncdme (per llne 6 of the child support worksheets).

12 The-counseUng, mediation or arbitration process shall be commenced by notifying th
13
In the dispute resolutl.on proceS&:
14
IS (a) Preference shall be given to carrying out this Parenting Plan.

(b) Unless an.emergency exists, the parents shall use the designated proce
16 to resolve disputes relating to Implementation of the Plan, except thos
. related to flnanclal support. .
17
(c)" A written record shell ·be prepared of any ·agreement reached I
18
counseling or mediation end of each arbitration award and shall b
provided to each party. .
19 (d) If the .Court finds that a parent has used or frustrated the dlsput
20 fees and: financial sanctions to the other parent.
21 (e) The parties have the right of review from the dispute resolutlon process t
the Superior Court. ·
22
VI. Other Provisions .
23
24 Telilphone Access. When the ·child of the parties Is riot residing with a give
25 access or lntemet web chat with the chlld so long as contact Is Initiated by th
chlld: ·
26
27
28
=a.AUL Avonua 0302

~r>l'"""
Parenting Plan(PPP, PP'J', PP) -Pag119tJf 13 EVelllft WA 88201
IYPF DR 01.0400 Mandllt01)' (612008) • RCW (426) 259-4147 •FACSIMILE (428) 269·7081
26.09.016, .181; .187; .194
ActMt!es. Each parent shall have the right and responslbnlty to ensure that th
child .attends school and other agreed upon scheduled acttvltle$ while In the
2
parent's care. Parents shall attend school and extracurricular activities an
3 ,events that faU on their residential days only. Each parent shall be responslbl
for keeping themselves advised of school, athletic and social events In which th
4 child participates. I
5
Extmcyrrlcylar participation. Neliher party shall be required to have the chll
participate In any activity that takes place during their own parent's resldentla
time with that child. ·
7 For all decisions that Impact the other parent's .resld.entlal time (extra
8
curricular activities, vacation), either parent shall notify the other parent via th
case manager, or emall after the case manager le released, of the pendln
9 decision, as soon as Is reasonably possible, about the Issue and the propose
decision I solution. The other parent has 36 hours lo respond. No respons
10 Indicates agreeing with the referring parent's proposed decision. If the parties d
II not agree, the dispute shall be submitted to arbitration by Wayne Pellegrini. Th
costs of arbitration related to extra-curricular participation shall be bome by th
12 parties per line 6 of the child support worksheets. The arbitrator shall have th
authority to allocate or reanocate fees .for cause. The parties shall abide by th
13 rules· of the arbitrator Insofar as briefing, oral argument and/or fees a
14 concerned. ··
-The arbitrator shall Issue his or her final. deolslon In writing and forward
15 'copy.to each party. The original decision shall be flied with the court and shall b
binding upon the parties unless an action for court review Is flied within twen
16
(20) days. The court shall assess costs and reasonable attorneys' fees against
17 party who seeks court review and falls to Improve his or her position. Unles
waived, the court may assess costs and reasonable attorney's fees against
18 party who unilaterally withdraws a request for court review afte rcosts or fee
have been Incurred by the opposing party.
19
20 Notification of Child's Eyents: Each parent Is to keep themselves apprised an

Informed regarding Information concerning the well-being of the children
21 Including, but n6t limited to, copies of report cards, school meeting notices
22
vacation schedules, class programs, requests for conferences, results o
standardized or diagnostic tests, notices or activities Involving the chlldre11
health care providers, the· names, addresses and telephone numbers of al
schools, health. care providers, regular daycare providers, and counselors, a
25
well as mental health records accumulated by said counselors.
26 . Ehrlchment Activities. The parents may participate in school activities for th ·

·child while the ·child Is In their care. Each parent shall Inform the other parent o
27 all Information regarding activities.
28
CA!l!.LOAVL
AltOHIOfllla\Y
~
,.,.
1804 H..ntAvenuo lil02
Parenting Pinn (PPP, PPT, PP)· Pi1811 JO of /3 EvetoUWA8820t
WPF DR 01.0400 Mn11rla!OYY (612008) • RCW (426) 260-4147 • FACSIMR.E (425) 260.l'G&I
26.09.016, ./81; .181; .194
Change of Address. Each pa~nt shall P.rovlde the other with the address an
2
phone number Qf his or her reslden.ce and shall updatE1 such Information prompt
3 whenever It changes. Eacih parent shall provide the name and blrthdates of al
Individuals who reside In the same hom& aa the child.
Affections. Each parent agrees to exert .every reasonable effort to maintain fre
access and unhampered CO!llact and communication· between the child and th
6 otherparent, and to promote the emotions of affection, love and respect betwee
the child and the other parent, Each parent agrees to refrain from words o
7 .conduct, and further agrees to ~ls~urage othe( pe~ons from uttering words· o
8
engaging In conduct, which would have a tendency to: estrange the.child from lh
other parent, to damage the opinion of the child as to the other parent, or whlc
9 would Impair the natural development o~ the chlld's love arid tespE1ct for the othe
parent: ·
10
II DerOqato1Y Comments, Neither parent &hall make derogatory comments abou

the other parent or allow anyone else to do the same In the chlld!s presei1ce
12 Nellher parent shall. allow or encourage the child to makEi derogatory comment
13
14 Chl!d's Welfare. Each par:ent shall provide the other pare11t promptly with recelp
of ~ny significant Information regarding the welfare of the child, Including phy,slca •
JS and mental health, performance In school, extracurricular activities, Eitc.
16
DevJatloofrom Residential Schedule: Acceptance and waiver cf any delilatlon
17 from provJslons of thl& Patentfng . Plan shall not constitute.acceptance orwalver o
subsequent deviations from this plan. The provisions of this plan shall re1T1aln I
18 effect until modified by an appropriate written order by a court of competen
jurisdiction; provided, that any and all_ revisions to this ·plan are In writing an .
19
·signed by bpth parents, .and shall be effective Immediately
20
Pas9port: The parents wlll cooperate In obtaining a passport for Lauren. Th
21 paBSport will be kept with the father. Both parents may freely travel to Canada
22
Mexico and other agreed loc_atlons.
23 Edycetlonal Decisions: The chlld ahell attend her current aohool and atten
Archbishop Murphy so long as the fat~er coi:ttlnues to pay 100%_ ~ the turtle
24 a.nd coats. The f1;1ther or mother shall have the authority to ann(Jally enroll th
25
child In her current school, select ·optlonal classes, authorize educational testing
obtain · tutoring and seek education accommodations (e.g. Section 60
26 Accommodations) for the child.. If Eiducatlonal testing Is done, lhe results shall
provided to both parents. If one parent enrolls the child In school, the othe
21
28
CAfil,J, Gt\U!. ~
Al"""">'BllMw
0
1804 Hav.lllAVfllllO Ho2
ParenthrgPlan(l'PP, PPT. PP). Page II of/3 EW'"H WA 88201'' .
WPP DR 01.0400 Mm1dt1tory (612008) • RCW (4H) :119-4147 • FACSIMILE (42a) 259- I
26.09.0IA .181; .187; .194
•
parent shall be Hated as such on each and every form lnoludlng the emergeno
. contact form at the school. · . .
2
Changing schools shall be a joint decision ar:id subject to the dlsput
3 resolution process. If a parent wants Lauren to change schools, that must b
suggested in writing by November 16, 2014 for the 2016-2016 school year an
4 by November 16th of any future year. The decision to change schools ls subjeo
5
to Joint decision-making and the dispute resolution process. That process mlgh
need to be on an expedited basis In llght of various school application deadlines.
6 Any coats or fees associated with the dispute resolutlon process regardln
Educational Decisions or to change schools shall be divided according to eac
7 party's proportlonal share of Income from Line 6 of the Chlld Suppo
8 worksheets. The arbitrator shall have the authority to allocate or reallocate fee
for cause. .
The arbllratOr shall issue his ,or her final decision In writing and forward
copy to each party. The original decision shall be flied with the court and shall b
10
binding upon the parties unless an action for court review la filed within twent
11 (20) days. The court shall assess coats and reasonable attorneys' fees agalns~
party who· seeks court review and falls to Improve his or her position. Unles
12 waived, the court may assess costs and reasonable attorney's fees against
·party who unllateral!Y withdraws a request for court· review after coats or fee
13 have been incurred by the opposing party.
Non-emergency Medlcal Care. Each parent shall have authority to schedul

1$ routine non-emergency health care appointments (e.g. physical exams or chec
ups) and minor non-emergency health care for minor Illnesses or minor lnJurle
·16
and consent to routine treatment thereof. The parent shall notify the other b
17 emall of all such appointments and treatment, describing any findings, treatment
or recommendations. If the health oare provider recommends ongoing treatmen
18 beyond a course of medication (e.g. surgery, multiple applntments, referral to
19
speclallst or· further evaluation), the response will be subject to Jofnt decfslo
making and the dispute resolutlon.. process. .
20
Non-ememenoy Dental Care. Eaoh parent shall have the authority to schedul
21 routine non-emergency dental care appointments (eg dental or orthodontl
22 exams or check ups or oleanlnge) and· minor, non-emergency dental care fo
minor dental situations and consent to routine treatment thereof. The pa(en
23 shall notify the toher parent by small of all such appointments and treatment
describing any findings, treatments or recommendaUons. . If a dental o
24 . ·orthodontic provider recommends ongoing treatment beyond a course o
as medication (e.g. surgery, multiple appointments, referr~I to a speclallst or futhe
evaluation), the response will be.aubJeot to Joint decision-making and the dlsput
26 resolutlon process. Each party may attend dental appointments.
Non-emergency medical and dental appointments shall be made by eithe
27 parent and a~ended by one parent In order to create a calm environment for th
Pare111t11g Plan (PPP, PPT. PP)~ Pago 12of13

WPP DR 01.<UOQ Mm1dotory (612008) • RCW
f!'!!;~e.AUL
1804 HGl>l!IAYe!Wa l302
everettWA08201
r
(428) 268-4141 •FACSIMILE (426) 24 081
16.09.016, .181; .181; .194
chlld. Both parents may attend appoi.ntment& when deallng with .a slgnlflQah
medical or dental Issue. The parties wllJ conei.lltwlth the case manager Qn thee
2
·issues If there Is a conflict.
3
·. ·Devlatlorj from Schedule. Acceptance and waiver of any d~vlallons from th
4 provisions of this parenting plan &hall not conlitltute acceptance or waiver o
s subsequent deviations from this plan. ThEi provisions of this plan shall remain I
·effect until modified by an appropriate written order by a court. ·
~~
6
NOV 17 201it
1 Dated:
8 1*18\i I Commissiqne1·
9
10 OAUL,W A 8341 ANDRBW RIFE, Petitioner

11
Attomey for Petitioner
12
V . ONICA FRBITAS, WSBA#19405
13 Attorney for.Respondent
14
15 mJSB BUIB, WSBAI# 44985

Glµlltlian ad ·Litem
16
17
18
19
20
21
22
23
24
25
26
27
28
CARLJ,OAUL
Ateoml)'al Lclw"
1eo• llt¥.iaAvonuo 1302
PmnllngPlan(PPP, PPT, PP)-Poga JJ of/J ' E'IOlcU WA N201 .. . . .
lf'PF DR 0/;0400 Mandatory (6/'JOOB) RCIJI (428) 269·4147 • _FAOSIM!I.£ (426) 2511-7081
26.09.016,.·.181;.• /87; .194
•
F\LED
10111 NOV I9 AH II: I3
2
3
SONYA KRASKI
~I ~ ~II ~Il ~11111111111~1 l~I ~I

4 COUtlTY CLERK
SHOHOHISH CO. WASH
s 11111111 Ill ml
CL16813335
6
7
8
County of Snohomish
9
In re:
10
11
Petitioner,
12 and Reply Declaration of Veronica
Freitas
13 JENNIFER MEHADDI (flea Jennifer Rife),
14
Res ondent.
IS My name is Veronica Freitas and I am over eighteen years of age and competent to testi
16
in this matter. I am the attorney for the Respondent, Jennifer Mehaddi. I have reviewed the
17
response declaration of the Petitioner, Andrew Rife's attorney, Carl Gaul and am submitting this
18
declaration in reply.
19
20 The parties attended mediation and agreed on a final parenting plan. Mr. Gaul entered
21 the Final Parenting Plan and Order on Modification with the court on November 17, 2014. These
22
orders are attached as Exhibit A.
23
The parties agreed to submit the remaining issues (child support and attorney fees) to
24
binding arbitration by Wayne Pelligrini. Final submissions have already been submitted by both
25
26 parties and we are waiting for Mr. Pelligrini to issue his decision. There is no opportunity to
27 submit additional information to the arbiter and therefore, the subpoena is moot.
28
VERONICA FREITAS
Page I of2 V. FREITAS LAW, PLLC.
ORIGINAL Seattle, Washington 98102

(206) 328-7362
v@vfreitaslaw.com
..
The subpoena for Ms. Buie's file was served after the discovery cutoff date. The trial date
2
has been stricken. The Final Parenting Plan and Order on Modification have been entered with
3
the court. Ms. Buie's file has no relevance to calculating child support or attorney fees. The
4
5
Subpoena Duces Tecum should be quashed.
6 I declare under penalty of perjury pursuant to the laws of the State of Washington that the
7 contents of the letter are true and correct to the best of my knowledge.
8
DATED this I 8 Day of November, 2014. Signed in Seattle, WA.
9
IO
II
Veronica Freitas, WSBA# 19405
12 Attorney for Respondent
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VERONICA FREITAS
Page 2 of2 V. FREITAS LAW, PLLC.
(206) 328-7362
v@vfreitaslaw.com
EXHIBIT A

' 210 Su1T1mit Aven.u~ East, ·I I
Se_a~le, WA 98102 te1•:(206)328,7362 fax• (206)323-0404
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I
~\1\ 1~1\1CL16854656
1 m~\1\ \1 \1\~1\ 1 1 -\ 1
\11\11\1\1"\1\1\
j
I
SUPERIOR COURT OF
WASHINGTON
201~ NOV 17 PH 3= 04
\_ ... - -- FOR SNOHOMISH COUNTY
;: >1'1WI '11 SH r.o. WA SH
CAUSE NO.: 05-3-02755-1
(PETITIONER) CLERK: M. STEWART
AND DATE: 11-17-2014 @ 9:00 A.M.
JENNIFER RIFE DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME: ON FOR: PRESENTATION OF ORDERS AND CR2A AGREEMENT

ACTION:
PETITIONER APPEARED: NOT PRESENT COUNSEL: CARL GAUL I I I
RESPONDENT APPEARED: NOT PRESENT COUNSEL: NOT PRESENT
DOCUMENTS FILED: COVER SHEET FOR JIS BACKGROUND CHECK (PERMANENT PARENTING PLAN)
ORDERS ENTERED: AGREED/MEDIATED PARENTING PLAN PURSUANT TO CR2 (A); ORDER RE
MODIFICATION/ADJUSTMENT OF CUSTODY DECREE/PARENTING
PLAN/RESIDENTIAL SCHEDULE, TO BE FILED BY COUNSEL GAUL
PROCEEDINGS/COIJRT'S FINDINGS:
THE COURT ADOPTS THE AGREED ORDERS AS PRESENTED.
THE COURT NOTES THAT THE GUARDIAN AD LITEM PARTICIPATED IN THE
FORMATION OF THE PARENTING PLAN DURING MEDIATION.
1 MINUTE ENTRY 2~3

FILEr··
~m111111111111111mm ~1 1 1
1 201~ NOV 26 A~ II : Lifl
SUPERIOR COURT OF
111m1 m111
WASHINGTON SONYA KRASKI
CL16854863 COUHTY CLERK
' FOR SNOHOMISH COUNTY cu .. -···i:.u rn WA~~
CAUSE NO.: 05-3-02755-1

(PETITIONER) CLERK: MEGHAN WRIGHT
AND DATE: 11-26-2014 @ 9:00 A.M.
JENNIFER RIFE NKA MEHADDI DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: MOTION RE OBJECTION TO DEPOSITION

CONTINUED DATE/TIME/CALENDAR AND CONTINOANCE CODE :
REARmG DATE SET /TIME/CALENDAR CODE:

ACTION:
HEARmG STRICKEN/CODE:
PETITIONER APPEARED: NOT PRESENT COONSEL: CARL GAUL, III
RESPONDENT APPEARED: NOT PRESENT COONSEL: VERONICA FREITAS
GUARDIAN AD LITEM APPEARED: YES, ELIZABETH BUIE, ADDRESSED THE COURT
DOClJMENTS FILED:
ORDERS ENTERED: ORDER RE OBJECTION FOR DEPOSITION, TO BE FILED BY COUNSEL

FREITAS
PROCEEDINGS/COIJRT'S FINDINGS:
THE COURT ORDERS THE SUBPOENA SHALL BE QUASHED AS THERE IS NO PENDING
ACTION SUCH THAT A DISCOVER VEHICLE SUCH AS A SUBPOENA IS APPROPRIATE. THE
ORDER IS WITHOUT PREJUDICE TO THE PARTIES TO BRING A SEPARATE ACTION.
1 MINUTE ENTRY
FILEL:
2
201~ NOV 26 AH IQ: 03
3
SONYA KRASKI
1111~~m11m11~11~~11~
4 COUNTY CLERK
SNOHOMISH CO. WASH
5
CL16863144
6
7
8
County of Snohomish
9
In re:
10
II Petitioner,
and Order re Objection for Deposition
12
13
Respondent.
14
15
I. Basis
16
A motion for an objection to the deposition ofEli711beth Buie was presented to this court by Veronica
17 Freitas and the court, after reviewing the motion and declaration finds reasonable cause to issue the order.
18
ID.Order
19
It is Ordered:
20
The notice of deposition served on J;lise Buie seeking docum~by Novembpr 7, 2014 is hereby
21 quashed.w ~r....:;t- h~'~.!c;..c.__
G- $-e-f'~Y-c. ~ y.:;- ,.f.. .e.e
'lfM-ol\ ~(<.;._• 'i ,,~~IA-+- <(.:.:, &av->"---'\
'~ p'-#' <:. .......' (. J ( "- c. o.>-1'"cL :l )
~
22
Dated: NOV 2 6 2014 •
23 .Jmliit'Commissioner
24
Presented by:
25
26 ~
{r eronica Freitas, WSBA No. 19405
"" 11/2,
Date
{Jy
Car Gaul, WSBA No. 8 Date
27 Attorney for Respondent L A Attorney for Petitioner
28 ~~ VERONICA FREITAS
(206) 328-7362
v@vfreitaslaw.com
011 ~o
• 1----
2 2U~ OEC -9 PM 2: 28
3 ll~~l~Dlll~lll~~l~ll~I
CL16899032
SONYA KRASKI
COUNTY CLERK
4 SNOHCtl!SH CO. WASH
7 In re:
8 ANDREW RIFE, No. 05-3-02755-1

Petitioner,
9 and ARBITRATION AWARD
10'
PURSUANT TO RCW 7.04A
11 Respondent.
12
13 ARBJRTATJON AWARD
14 Authori;r.ation: Based upon the Terms and Agreement for Binding Arbitration signed by the
15
parties on or about October 23rd and/or their respective counsel.
16
Considerations:
17
18 My award is based upon the written submissions and evidence presented by counsel, the
19 Stipulated Agreement Pursuant to CR2(A), the GAL Report of Mach 23, 2014, Supplemental
20 GAL Report of May 26, 2014 and upon relevant case law and statutes including but not limited
21
to: RCW 26.19.071, RCW 26.19.080, RCW 26.19 Appendix - Child Support Schedule; Jn re
22
Marriage ofDauber/ 124 Wn. App. 226; Jn re CustodyofBJB 146 Wash. App. I (2008); State
23
ex rel. Sigler v. Sigler, 85 Wn. App. 329, 932 p.2d 710 (1997); In re Marriage of Williams, 84
24
Wn. App. 263; Jn re of In re Marriage o/Crosetto 82 Wn. App. 545; In re the Marriage of
25
ARBITRATION AWARD I.AW OFFICES

Page- I HANSEN McCONNELL & PELLEGRINI
Pl.LC
1638 THIRD STREET
MARYSVILLE. WASHINGTON 98270
ORIGINAL (380) 658-6580 •FACSIMILE (380) 651-11762

Matison, 95 Wash App. 592 (1997); RCW 26.09.140; In re Marriage of Shellenberger, 80 Wash
2 App 71, ( 1995) and other case law as set forth in the body of this award.
3
Facts:
4
Andrew Rife (hereinafter referred to as petitioner) and Jennifer Mehaddi (hereinafter
5
6 referred to as respondent) divorced by Decree entered in Snohomish County Superior Court on
7 November 7th 2006. The parties have one child, Lauren Rife (age 9). On October 3rd 2013,
8 petitioner filed for a parenting plan modification. As part of his petition he requested an order
9
establishing child support in conjunction with the entry of a parenting plan. 1 A Response was
IO
timely filed.
11
Andrew Rife: is single. He has no children, except for Lauren, at issues in this matter.
12
13 Pursuant to the 2006 Final Order of Child Support, the following pertinent information is noted:
14 I. Petitioner is paying $562.52 monthly (wage assignment through DCS).

2. There was no deviation requested or sought by either parent
15
3. The father is required to pay 67% and the mother 33% of the following expenses:
16 Work related day care; pre-school and Camps, lessons, sports and enrichment
programs.
17 4. The father provides medical insurance on behalf of Lauren.
5. The parties agreed upon a life insurance provision. 2
18
Petitioner is currently employed with Snohomish County PUD. He reports a monthly
19
20 gross income of $9,061.38. 3 He reports monthly expenses of $3,612 inclusive of Lauren's tuition
21 expense of $579.00.4 Andrew has prayed for the following relief: (I) Determine child support
22 for Lauren based upon his reported income and imputed income to Jennifer (her current hourly
23
24 1
See Petition for Modification/Adjustment of Custody Decree/Parenting Plan/residential Schedule.
2
See Final Order of Child Suppon entered November 71h 2006.
25 ' See Declaration of Andrew Rife dated October 21•2014.
4
See Financial Declaration of Petitioner filed October 3, 2013.
ARBITRATION AW ARD ~!.A~W~O=F~Fl=C=E~S_ _ _ _ _ __
Page- 2 HANSEN McCONNELL & PELLEGRINI
PLLC
1836 TI<IRD STREET
MARYSVILLE, WASHINGTON 98270
(380) BSs.eSSO •FACSIMILE (360) 651-8782
wage imputed to full time - 40 hours per week); (2) Deviate from the determined basic child
2 support calculation, based upon the amount oftime he spends with Lauren under the terms of the
3
mediated parenting plan; yet to be entered with this court. (3) Petitioner proposes a child support
4
transfer payment of$274.33 (deviated pursuant to his proposed incomes and residential credit).
5
6
Jennifer Mebaddi is married. She has no children, except for Lauren, at issue in this
7 matter. She is currently employed with The Polyclinic as a medical assistant. She reports an
8 hourly rate of$20.15 and a work week consistent of35 hours 5. She is paid bi-weekly. Her
9
proposed child support worksheets suggest a gross income of$3,1 I0.68 (slightly more than her
10
reported hourly wage income). She reports monthly expenses of$2,934.69. 6 Respondent prays
11
for the following relief: (I) The determination of child support based upon her reported gross
12
incomes (as identified on her proposed child support worksheets); (2) Attorney fees in the
13
14 amount of $15,000; based upon need and ability to pay and for intransigence on the side of the
15 petitioner; (3) Denial of a downward deviation as proposed by the petitioner.

16
Other Pertinent Facts: (I) The parties reached an agreement as to each parent's
17
respective residential time with Lauren. At this time, those agreed upon terms are set forth in the
18
Stipulation Agreement Pursuant to CR2(A) executed by the parties on September I llh 2014. (2)
. 19
20 The parties agreed Lauren would continue to attend Arch Bishop Murphy (Catholic School) "as
21 long as the father continues to pay 100% of the tuition costs".7
22
23
'See Declaration of Jennifer Mehaddi dated October 21" 2014.
6
24 See Financial Declaration of Respondent dated October 21" 2014.
7
25 See Stipulation Agreement Pursuant to CR2(A). The tenns of the residential schedule pursuant to this agreement
are not separately set forth in this award. However; the allocated residential times for each parent has been noted
and is articulated below.
ARBITRATION AWARD ~LA~W~O~F~l'l=C=E~S_ _ _ _ _ __
Page- 3 HANSEN McCONNELL Ill. PELLEGRINI
PLLC
1838 TMIRD STREET
(380) 858-8580 •FACSIMILE (380) 861-8782
ISSUE: Child Support
2
Issue: Determination of each party's child support obligation based upon the following:
3
4 !. An assignment of their respective incomes, deductions and credits;
5 2. Whether or not to impute income to the respondent as requested by the petitioner;
6 3. Whether or not to award the petitioner a deviation pursuant to the amount oftime he
7
spends with Lauren under the terms of the residential schedule.
8
Award: Child Support Transfer Payment - Payment made to - Date of Commencement:
9
10 • The respondent/father will pay the mother monthly child support in the amount of
II $830.90
12
• The father is denied a deviation without prejudice. The father is deserving of a
13 deviation of child support based upon the significant time he spends with Lauren.
However; to provide a deviation at this time would leave the mother without the financial
14 ability to meet the basic necessities of the child in her home.
15 • Payments to commence October l ' 1 2014 (Date submitted to Arbitration);

16
• Child support shall be payable pursuant to the same terms as set forth in the 2006 Final
17
order o Child Support through the Washington State Support Registry.
18
• Child support will be paid on 1'1 pay date of the month.
19
20 Findings: 1 find the father's income, deductions and credits for determining child support to
21
be as follows:
22
• Monthly gross income of$9,061.38
23 • Other Income: No other income was reported or verified.
24 • The father received a deduction of $425.05 for his mandatory retirement
contributions pursuant to RCW 26.19.071(5)(c);
25 • No other deductions were verified. The father's request for a deduction for
voluntary retirement contributions is denied • see RCW 26. I 9.071(5)(g);
ARBITRATION AWARD LAW OFFICES
Page· 4 HANSEN McCONNELL & PF.LLEGRINI
PLLC
1838 THIRD STREET
MARYSVIUE, WASHINGTON 98270
(360) 85~580 •FACSIMILE (360) 651-4782
.• A credit of$253.32 for medical ·insurance premiums paid for inediCal·irisurance
2
on behalf of the child.
• The father's monthly income taxes were formulated utilizing single (I) - See
·3 Child.Support Worksheets. ·
• Net income= $6,211,42
4
• Proportional share of income: 70°/o
5
6 I find ·the mother's income, deductions and credits for determining child support· to be as
7
follows:
8
·• Monthly gross income is~imputed.at $3,492.66 pursuant to RCW 26.19.071 (6)
(a) .. Said income is based upon the "Full time.ear:nings 1a1 the.current rate of
~~ .
10
• No other income was utilized for child support purposes;
11 • The mother does notxeport or demonstrate retirement .deduetions or other. credits.
• The mother's monthly income taxes and other·deductions were based upon
12 married filing separately (I)• See Child,Suppoii Worksheets.
• Net monthly income = $2,990.13
13
• Proportionate share of income: 30°/o
14
PetitionerfFather's1ncome: The father pre~ented accurate pay stub inform~tion through
15
September 15th 2014·and accurate historical taxable income for·2·o 13. Utilizing the year to date
16
inc.ome·r~ported on his·pay stubs·W!!S an accurate representation of his monthly i!lcome for'2014.
17
18 Rcspondent/Mother•s· Income: The mother presented accurate pay sub informatfon
19 through August 23rd 1014 and accurate earnings for 2013. However; I find the mother to.. be
20 ''vohintarlly underemployed;' pursuant to RCW.26.19:071 (6)(a). Respondent reports she is

'21
making a full time wage af 35 hours. Neverth.eless, .she provides no.substantiation.or. evidence
22.
p~sented to support.her position that.she can't work more.hours. "Full time"' can.be determined
23
by the employer-ifitis'less than 40·hollrS·per'week and so stated by policy. In this:case there
25
.was no representation to that fact. Therefore; "ihe court is required to impute income fo a
ARBITRATIONAWARD I.AW OFFICES

Page- 5 HANSEN McCONNEl.L & PELLEGRINI
PLLC
16Je THIRD STREET
MARYSVlUE; WASHINGTON 96270
(380) 8sa:eseo. FACSIMILE (380) esi-e162
voluntarily underemployed parent for purposes of calculating child support In re Cus1ody ofB.JB
2 146 Wash. App. 1 (2008).

3
Deviation from the Standard Child Support Calculation: It is undisputed the court
4
has discretion to deviate based upon the significant residential time the father spends with
5
Lauren. 8 The father's residential time with Lauren is greater than 40%, which justifiably meets
6
7 any standard for "significant residential time". Under the Residential Credit Formula,
8 respondent would receive a significant reduction in the petitioner's child support obligation.
9 Unfortunately, respondent's "significant time" must be weighed against the determination of

10
whether or not the deviation provided to respondent would result in insufficient funds in the
11
household of the parent receiving support- "lo mee/ /he basic need~ oflhe child"? The analysis
12
for a deviation would be more in line with a mathematical review of the evidence. Specifically,
13
the$ reduction of expenses in the mother's household v. the increase$ expenses in the father's
14
15 household. The respondent mentions Slate ex rel. Sigler v. Sigler, 85 Wn. App. 329, 932 p.2d
16 710 (1997). Although the case is more noted for "not allowing the residential credit to noncustodial
17 parents whose children receive AFDC, there was a significant point articulated by the court:
18
In 1he rei•ised order of child supporl !he ,·our/ s1a1ed /he reason for !he devialion was
19 Iha! 1he.fc11her had 1he child 40.5 percenl of/he time. The evidence does suppor/ a finding
Iha! /he child spenl Iha! amounl of lime wilh thefalher. The S/a/e argues Iha/ !he co111·1
20 did nol lisl any fuels which indica/e how much /he fa/her .1pends on the child when she is
in his care which would juslifY the reduction in support. The cour/ does fail 10 enter such
21
22
8
RCW 26. t 9.075( I )(d) Residential schedule. The coun may deviate from the standard calculation if the child
23 spends a significant amount of time with the parent who is obligated to make a support transfer payment. The coun
may not deviate on that basis if the deviation will result in insufficient funds in the household receiving the support
24 to meet the basic needs of the child or ifthe child is receiving temporary assistance for needy families. When
detennining the amount of the deviation. the court shall consider evidence concerning the increased expenses to a
25 parent making support transfer payments resulting from the significant amount of time spent with that parent and
shall consider the decreased expenses, if any, to the party receiving the support resulting from the significant amount
of time the child spends with the parent making the support transfer payment.
ARBITRATION A WARD =LA~W~O~l·~·F=IC=E=S~-------
Pagc- 6 HANSEN McCONNELL & PELLEGRINI
PLLC
1836 llilRO STREET
(360) 6SM580 •FACSIMILE (360) 651-8762
findings, and gives no indications how the decrease was calculated. Although Mr. Sigler
.wales how much money he spends on Kristina while she is in his care, the findings and
2 conclusions entered hy the judge do not reflect this. Thus, the devialionfailsfor this
3
reason, as well as/or noncompliance with RCW 26.19.075(/)(d). 9
4
In the instant case, the mother's actual net income is approximately $2,700.00 (without imputing
5
income). Her reported expenses are approximately $3,000. The respondent is married, however;
6
7 there is no evidence of income reported to the new husband. In fact, the joint tax return, for
8 2013, indicates a community "adjusted gross income" of$36,000. When considering the
9 financial welfare of the child, I felt it important to also consider the number of parties in
10
respondent's household that she is responsible for; as well as her own financial circumstances.
11
Second, there is no evidence (even after thoroughly considering her financial declaration) the
12
reduced hours that Lauren spends with her will reduce her overall expenses. On the other hand,
13
the father's net income is approximately $6,900. His reported expenses of approximately
14
15 $3,600.00; include Lauren's tuition. Using the same analysis, I could not reasonably find the
16 increased time with Lauren resulted in an increase in his reported expenses. When examining his
17 financial declaration, I see no significant increase to his "Food and Supplies", the "Children"
18
category or the more basic expenses such as his mortgage and utility payments. Clearly, the
19
greatest "child" expense is Lauren's tuition, which he agreed to cover 100%; provided Lauren
20
continued to attend the school of his choice. Because the father purposefully agreed to pay
21
100% of this cost, I was compelled to eliminate that expense as a justification for a deviation. In
22
23 final analysis, a trial court is required to enter written findings of fact supported by the evidence,
24
25
' See State ex rel. Sigler v. Sigler, 85 Wn. App. 329, 932 p2d 710 (1997).

Page- 7 HANSEN McCONNELL&. PELLEGRINI
PLLC
1638 THIRD STREET
(380) 85&-6580 •FACSIMILE (380) 651-8782
when it enters an amount for suppon, which deviates from the standard calculation. RCW
2 26.19.035(2); In re Marriage o/Sacco, 114 Wn.2d 1, 4, 784 P.2d 1266 (1990). The failure to
3
enter findings is an abuse of discretion and subject to reversal. Jn re Marriage ofGlass, 67 Wn.
4
App. 378, 384, 835 P.2d 1054 (1992). In this case, I cannot award a deviation to the father
5
without leaving the mother's household insufficient to provide for the child's basic needs.
6
7 Other Child Support Related Issues
8
3.15 Payment for Expenses not
9 Included in the Transfer Payment
10
Issue: Determine whether or not to allocate or apportion to each parent a responsibility to pay
Il
for educational costs, sports and other extracurricular expenses for the child?
12
13 Award: The father will pay for 100% of the tuition cost associated with Lauren attending Arch
14
Bishop Murphy.
15
The parties will continue to pay for "other expenses" not included in the transfer payment
16
pursuant to the terms set fonh below:
17
The petitioner/father shall pay 70% and the respondent/mother 30% (each parent's
18
proponional share of income from the Child Suppon Schedule Worksheet, line 6) for the
19
following costs incurred on behalf of Lauren.
20
• Educational: Those expenses generally required by the school, which include,
21
graduation expenses, ASB dues, mandatory field trips, necessary equipment
22 (calculators, etc.) school spon fees;
23 • Soorts (outside school) and Other Activitv Expenses: These expenses must be
agreed to in writing (email/phone texting) before either party is obligated
24 financially to pay his/her proportional share.
25
Payments shall be made to the provider of the service. If one parent pays the other

Page- 8 HANSEN McCONNELL&. PELLEGRINI
PLLC
1838 THIRD STREET
(380) 858-8580 •FACSIMILE (380) 851-8782
parent's share, the other parent shall reimburse the paying parent within 1.0 days
from receiving verification.of payment.
2
3
Findings: Extracurricular Activity Expenses: The court favors agreements of the parties.
4
5
Lauren'.is currenily in sports and outside.school activities. It is incumbent, upon the parents to
6 commimicate about Laureri' s best interest, which may include her participation in these
7 sports/events. Both parents should be willing to advance their.child's experiences through

8 extraordinary act,ivities, ho:wever; it should.b~ done by agre~m~nt.
9
3.19 Uninsured Medical Expenses
10
Award: The parties will continue to each pay their proportionate share(70% to
11
12 petitioner/father and 30% to the respondent/mother) of the uriinsured medical ei1:"penses incurred
13 on behalfof Lauren. Such expenses will include copays, deductibles, orthodontia and all other
14. medic.al and/or dental _expenses .. Each parent shall provide/exchange.medical information
15
·(medfoal coverage card) to allow the child to obtain medical/dental serviCes. The parents will
16
provide receipts of payment and other verification (EOB's, etc.) to the other parent. If a.paying
17
parent fails'to provide verification ofpaymertt to the other parent'on or before 65 days from the
18
19 service, the request for payment is deemed waived and.the. paying.pareni shall not be.reimbursed.
20 Should a receipt or:verification ofpayment:°be presented to the other party within 65 days from
21 service, the other party shall reimburse the paying parent within.15 days from·receiving such
22
receipt-or verification.
23
Attorney Fees:
24
25 Issue: Whether·or. not.to. award attorney fees as requested by the respondent:
ARBrrRA TION Aw ARD LAWOfl'ICES

f>age- '! HANSEN McCONNELL & PELLEGRINI
PLLC
1836 THIRD STREET
MARYsviLLE, WASHINGTON 98270
(380) 6sM580 •FACSIMILE (360) 651-8762
Award: The petitioner s}iall pay attorney fees_ incurred by the re~ndent in the amount of
$5,000.00. Said.fees shall be paid within 30 days from the.filing date·ofthis a~ard. Any
3
remaining amount not otherwise· paid will accrue.at judgment interest until fuily satisfied.
4
5 Findings: I make no· finding.for intransigence. It.is well settle.d that•"a trial court may
6.
consider whether additional legal fees were:cause_dby one party's iniransigence and award
7
attor:neyfees·on that basts." In re.Marriage ofGreenlee, 65 Wash.App. 703,708, 829·P.2d
8
1120. "When intransigence is established. fhe financial resources ofthe ,spouse ·seeking the
9
award are irrelevant." lnre Marriage ofMorrow, 53 Wash.App. 579, 590, 770 P.2d 197
10
II
{ 1989). Intransigence includes foot.dragging and obstruction, filing repeated unnecessary
12 motions, or making .the trial unduly· difficuit and costly by cine's actions. In re the Marriage of
13 Bobitt 135Wn. App. 8 (2006). The·parties in this case have attempted to resolve these difficult.
14
matters in good-.faith. Cleary, there is no indication of intransigence by previous court orders,.
15
the report of the. guardian or. Iitem, or by the evidence provided lei this arbitrator. I reViewed the
16
GAL report, the provided moti_ons of counsel and suggested3~vidence earlier provided for
17
mediation. When comparing the·petitioner's actions, the effect of his actions lipori the
18
19 respondent, the expenses of the case·v. the dozens of cases 10, which establish the identification
20 arid clarification of intransigence, lfeel strongly,that no ihtrarisigence can be found. This case
21 initially began as a high conflict and highly. complex parenting matter - based·upon the: assertions
.
22
of the respondent pertaining to Past actions o(the petitioner. As.a.result of the nature of this
23
case, .both parties have incurred attorney fees and costs well beyond their financial capabilities.
24
25
••·see case notes_ under ''Consideration"· in Arbitration ·!\.want
Page· 10 HANSEN McCONN!'LL & PELLEGRINI
PLLC
1838 THIRD STREET
esa.aseo·.
(389J FACSIMiL¢ (3B0f 8S1_-67B2
It appears both parties have filed appropriate motions when necessary. Moreover; I cannot see
2
where the petitioner failed to timely cooperate with the request of the GAL and/orders of this
3
court (no evidence to support). The matter may not have moved as quickly as the respondent
4
would have liked, but the question goes to "whether or not the actions of the petitioner resulted
5
in the necessity of incurring additional legal fees". In re Marriage of Wallace 111 Wn. App.
6
7 697. For this I can find no basis for intransigence.
8 Attorney fees based upon RCW 26.09.140 11 , I find the respondent to be in financial need
9 for assistance. The respondent's reported net income, even after receiving child support of
10
$830.90, is still significantly less than that of the petitioner. The evidence suggests respondent's
11
husband is currently unemployed. Her financial declaration shows monthly expenses of
12
approximately $3,000.00. Second, I considered the ability of the petitioner to pay or assist with
13
the payment of the respondent's fees. I look at his financial resources. In this case I looked
14
15 primarily at his income and expenses. I find the petitioner has a resulting net income of
16 approximately $6,902.64. From this income he is required to pay respondent $830.90 for child
17 support. Additionally, he has personal monthly expenses that exceed $3,600 (including tuition of
18
$579.00). Based upon his financial declaration, he is left with monthly net disposable funds of
19
approximately $2,500. His financial declaration does indicate other resources including $35,000
20
on deposit in banks as well as other funds. Third, I reviewed respondent's fee verification.
21
22
11
23 RCW 26.09.140 The coun from time to time after considering the financial resources of both panies may order a
pany to pay a reasonable amount for the cost to the other pany of maintaining or defending any proceeding under
24 this chapter and for reasonable attorneys' fees or other professional fees in connection therewith, including sums for
legal services rendered and costs incurred prior to the commencement of the proceeding or enforcement or
25 modification proceedings after entry of judgment

Page- 11 HANSEN McCONNELL& PELLEGRINI
PLLC
1838 THIRD STREET
(380) 858-8580 • FACSIMILE (380) 851-8782
Quite honestly, without more infonnation regarding the nature of the fees as they pertain to the
2 actual expenses related to the modification matter, the source of the fees and the fees paid to
3
date, I can only assume the fee verification appears to be in line with the nature of this case and
4
the litigation that has taken place since October 2013. Based upon my review of the financial
5
infonnation provided, I find the petitioner with the ability to contribute $5,000.00 toward
6
7 respondent's attorney fees incurred in this matter.
9 ARBITRATION FEES:
10 AW ARD: The fees for arbitration are to be paid equally (50/50).
11
12
Submission: I will submit my award to the court within 10 business days. Either party may
13
request reconsideration for mistakes, clerical errors or a clear misrepresentation of the facts.
14
Such reconsideration must be submitted to this arbitrator and all parties within I 0 days of receipt
15
of this award. All reconsiderations shall be in the form of a written submission. The arbitrator
16
reserves the right to award attorney fees subject to the reconsideration only.
17
Respectfully Submitted,
18
Wa:YNY P. Pelleflrtru/
19
HANSEN, McCONNEU & PEUEGRINI
1636 Third Street I Marysville, WA 98270
20 8 (360) 658-6580JFax: (360) 651-6762
wayne@thirdstreetlaw.com Iwww.thirdstreetlaw.com
21
22
23
24
25

PLLC
1838 THIRD STREET
MARYSVIUE. WASHINGTON 98270
(380) BSUS80 •FACSIMILE (380) 851-8782
WORKSHEET SYNOPSIS
FATHER MOTHER COMBINED
1. Montiily Net income Tax Year: Manual $6.904.62 $2.990.13 $9,894.75
2. Proportional Share of Income .698 .302
3 ..Basic Support:
l.A\JREN sfaoo.oo
4. TOTAL $1,300.00
5. Basic Support Obllgatlon with Income Limitations

6. Obligation for Healih Care, Day Care, and Special Exp.
7. TOTAL OBLIGATION
8. CREDIT for Medlcal

9. CREDIT for Day Care and Speclal Eilp.
10. CREDIT for Ordinary Expenses
11. TOTAL CREDITS
·12. Father Pays Mother
Calculated Using Sell Supp0rt Reserve: 2014
File Name:.ARBIIRAT.ION -.RIFE V MEHADDl.SCP
Page was Pri.nted 01111/24.12014 at 01,01 PM
CASE ALERT
Obllgor's· Proportional .Share of Medical lmiurance Exceeds

25% of Basic.Support Obligation.
SupportCa/c"' 2014
C~fl!~lSJ:il:ly".LrilU"P_M?~<~"',~.J"O\IP~
Washington State Child Support Schedule Worksheets
( I Proposed by ( I ( I State of WA ( I Other (CSWP)
Or. ( ) Signed by the Judicial/Reviewing Officer. (CSW)
Mother JENNIFER Father ANDREW

County SNOHOMISH COUNTY Case No. 05-3-02755-1
Chlldlrenl and Aaelel: LAUREN. 9

Part I: Income (see Instructions. naoe 6)
~- !3· yv~ges and Sala~es $9,061.38 $3,492.66
b. Interest and Dividend Income - -
c. Business Income - -
I----
d. Maintenance Received - -
e.Other Income - -
f. lmouted Income
!I. Total Gross Monthly Income (add lines 1a throu11h 1f)
-
$9,061.38 $3,492.86
-
:~=~:~~
a. Income _""[axes (Federal and State) Tax Year. Manual __!!,731.71
___b.FICA (Soc.Sec,+_M!ldicare)/Self-Emj:1IO)l'.ment Taxes
- -
--·
d. Mandatory Union/Professional Dues
-
$425.05
$8.79
-
e. Mandatory Pensiol} Plan Pa)'.ments - -
f. Volun_tary Retirement Contributions -- - -
__g.Maintenance Paid -
- i.h. Total
Normal Business Expenses
Deductions from Gross Income
- --
(add lines 2a through 2h) $2.158.76 $502.53
3. Monthly Net Income (line 111 minus 2i) $8 904.62 $2.990.13
4. Combined Monthly Net Income $9,894.75
Cline 3 amounts combined\
5. Basic Child Support Obligation (Combined amounts --+)
LAUREN $1300.00
- $1,300.00
-
-
-
(each parenrs net income from line 3 divided by line 4) .698 .302
WSCSS-Worlfsheets - Mandatory (CSWICSWP) 0712013 Page 1 of 5
Part II: Basic Child Sunnort Obllaatlon <see Instructions. oaae 71
7. Each Parenrs Basic Child Support Obligation withaut consideration
of low income limitations (Each oarenrs Line 6 times Line 5.) $907.40 $392.60
B. Calculatino low income limitations: Fill in onlv those that armlv.
Self-Suooort Reserve: ( 125% of the Federal Povertv Guideline.) $1.216.00
a. Is combined Ne! Income !.e!i!i !ban :i1 OQO'.l H yes, for each
~11arent enter the 11resum11tive $50 oer chlld. - -
b. l!i Monthl~ Nel ln"2rne Less Tban Self-Su11ggt1 Re~erve'.l If yes,
for that parent enter the presum11tive $50 per child.
c. l!i Montlll~ ~el I0"2Dle !lQYi!l II! Q[ DJQre lb!!O Self-SUllllQ!:I
- -
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 child support obligation after calculating
- -
applicable limitations. For each parent, enter the lowest amount
from line 7, Ba - Be, but not less than the presumptive $50 per $907.40 $392.60
child.
Part Ill: Health Care, Day Care, and Speclal Chlld Rearing Expenses (see Instructions, page 8)
10. Health Care Exoenses Father Mother

a. Month I)" Health Insurance Paid for Child(ren) $253.32 -
b. Uninsured Monthl~ Health Care Exeenses Paid for Child(ren)
- -
<line 10a olus line 10bl $253.32 -
/line 10c amounts combined\ $253.32
11. Dav Care and Soecial Exoenses
a. Da)" Care Exoenses
b. Education Expenses
-- --
c. Long Distance Transportation Expenses
d.Other Seecial Ex11enses (describe)
- -
- --
--
-
- -
/Add lines 11 a throuah 11 di
- -
12. Combined Monthly Total Day Care and Special Expenses '
(line 11 e amounts Combined) -
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12) $253.32
14. Each Parenrs Obligation for Health Care. Day Care, and Special
Expenses (multiply each number on line 6 by line 13) $176.82 $76.50
Part IV: Gross Chlld Support Obllgatlon
15. Gross Child Sunnort Obliaation Cline 9 olus line 14) $1.084.22 $469.10
Part V: Child Support Credits (see Instructions, page 9)
16. Child Suooort Credits
a. Monthl)" Health Care Expenses Credit $253.32 -
b. Day Care and Special Expenses Credit
WSCSS-Worksheets - Mandatory (CSWICSWP) 0112013 Paga 2 of 5
- -
·.
- -
- -
- -
d.Total SunnnrtCredits ladd lines 16a throuah 16cl $253.32 -
Part VI: Standard Calculation/Presumptive Transfer Payment (see Instructions, page 9)
17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is areaterl $830.90 $469.10
Part VII: Additional Informational Calculations
18. 45% of each parenrs net income from line 3 (.45 x amount from
line 3 for each oarentl $3.107.08 $1.345.56
19. 25% of each parenfs basic support obligation from line 9 (.25 x
amount from line 9 for each oarentl $226.85 $98.15
Part VIII: Additional Factors for Consideration (see Instructions, page 9)
(List the estimated value of all major household assets.) Household Household
a. Real Estate - -
b. Investments - --
c. Vehicles and Boats -
d. Bank Accounts and Cash - -
e. Retirement Accounts -- -
f. Other: -I describe I
-
--
- -
21. Household Debt
- -
(List liens against household assets, extraordinary debl)
a.
b.
-
-
--
c. - -
d. - -
e. - -
f.
- -
a. Income Of Current Spouse or Domestic Partner
(if not the other 11arent 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 8 - -
d. Income Of Childlrenl lif considered extraordinarul
Name - -
Name
WSCSS-Worllsheets - Mandatoty (CSWICSWP) 0712013 Page 3 of 5
- -
-~·
e. Income From Child Suooort

Name . .
Name ~ .
f. Income From Assistance Proorams
Program .. .
Prnnram . .
g. Other Income (describe) .
. .
~ .
23. Non-Recurrina lncome.ldescribel
. .
. .
24. Child Support Owed, Monthly, for Biological or Legal Child(ren) Father's iyiother's
Household Household
Name/age: Paid [ ] Yes [ 1 No . .
Name/age' Paid []Yes []No . .
Name/age: Paid [ 1 Yes [ 1 No . .
25. Other Child(ren).Living In Each Household
(Firstname(s) and age(s))
WSCSS-Worlrsheets • Mandatory(CSW/CSWP) 0712013.Page 4 of 5

Other f[actors For Consideration (continued) (attach additional pages as.neceissary)
Sianature and Dates

I declare, under penalfy. of perjury under the laws of the State of Washington, the information
c0ntained ·in these Worksheets is complete, tnle, and correct.
Mothei's Signature Fathei's,Signature
Date Cify Dale City
Judicial/Reviewing Officer Date
Worksheet certified by the· State of Washington Administrative Office of the Courts.

WSCSS-Worlrsheets - Mandatory (CSWICSWP) 0712013 Pagri 5 (Jf.5 SupportCalc" 2014
f:.).arbltration. rife v ~'\a.rbltration-- rife v mehaddi.SC? 1112412014 10:32. am
FILED
201~DEC I.I PH I= OB
1
111~~I~~CL16898736
~ll/11111111~~ 1 1 1 1 ~1 1 1 1 1
SOHYA KRASKI
2 COUNT'( CLERK
StWHOHISH CO. WASH
3
7
9
In re:
11 and
NOTICE OF UNAVAILABILITY OF
12 Jennifer Rae Mehaddi f/k/a Rife COUNSEL
Respondent.
13
14 0: THE CLERK OF THE COURT

NOTO: Andrew Scott Rife
15 NOTO: Veronica Freitas, attorney for Jennifer Rae Mehaddi f/k/a Rife
NOTO: Deborah Riehl, Case Manager
16
PLEASE TAKE NOTICE that Cart J. Gaul, attorney for Andrew Scott Rife, will be
17 unavailable from December 23, 2014 through January 5, 2015 inclusive. It is requested that
motions, depositions and other court hearings not be scheduled to occur during the time of my
18 absence, and that motions and other hearings be scheduled so that there is sufficient time to
prepare for them following the end of the absence. There is no other attorney available with
sufficient factual knowledge of this case to respond to anL(ibstantit request for relief during my
19
absence. L.
Date~:
20
December 8, 2014 A.-v (
21 CARL J. GAUL WSB 341
22
23
24
25
CARLJ. GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
NOTICE OF UNAVAILABILITY OF COUNSEt.O RIGINAL Everett WA 98201

425 259-4147 FAX 259 7081
.. - ,,
' ..
:
-. '
Ill/I/II~lllll/lll~lnlWlll///lllillnll
2
0
1 1
>.Lil 5 ._IA'1 -9 Pli
I z: 28
3 CL16956496 SOil"(.~ :,fiil.Si:i
COUtHY CLERK
4 s~:uliO~llSH CO. WASH
s Superior Court of Washington

7 In re:
8 ANDREW RIFE, No. 05-3-02755-1

Petitioner,
ON RECONSIDERATION
10
II Respondent.
12
13
CONSIDERATION
14
My Reconsideration is based upon the written submissions and evidence presented by
IS
counsel received in my office up to and through December 22"d 2014.
16
17 FACTS ERRONEOUSLY ASSUMED
18
In the Arbitration Award previously filed with this court, this arbitrator was under the
19
impression the respondent's husband, Soufyane Mehaddi, was unemployed. Therefore, it was
20
assumed the respondent, through her employment (with occasional gifts from her family) was
21
supporting the "household" including herself, the party's minor daughter, Lauren, and her
22
23 husband. As a result of the additional materials received as part of this reconsideration, it is now
24 clear respondent's husband is employed and contributing to the respondent's household. These
25 facts are critical and legally required to render a just determination.

PLLC:
1636 THIRD STREET
(380) 658-6580 •FACSIMILE (360) 651-6762
LEGAL MERRITS
2
First, the petitioner and.respondent are represented by t~o seasoned_ and excellent family
3
·1aw attorneys. Each attorney has vigorously defended their ciient's legal and equitable positions.
4
5
Unfortunately, this·arbitrator missed a key fact in this case regarding the,em_ployment of!he
6 respondent's hus!>and, As a result, my award was skewed.: For this I apologize. to both counsels
7 and their, respective clients.

8 Second, in determining the residential credit requested by the petitioner and the a:ward of
9
attorney fees, it was:necessary for me to consider the entirety of the income and expenses_ of both
fo
households. It is-apparent "now" the respondent's household income-is incre_ased by
11
approximately $1,122 per month (ltusband;s purported net income).
12
i3 Third, the legal. issues-are· well established and clearly-identified in my prior award. The
14 only difference is .the consideration of the.additional income to the respondenfs household.
AWARD
16
ISSUE: Child supp~;t
17
18 Award: Child SupportTranlifer Payment::

19
• The pi;titioner will pay the mother monthly child support in the amount of$400;00
20
• The father is awarded a deviation based upon RcW 26.19.075(l)(d). The father is
21
desel"Ving of a deviation of child support based upon the significant time he spends with
22
23 Lauren. Afte~ further cons_ideration of the _husband's inc!)me, I ·find a deviation would not
24 leave 'the mother in a financial hardship;· s6 as to be unable to meet the basic necessities
25 of the child.in'.her home. The respondent's netincome is approximately $2;700.00

Page-2 HANSEN McCONNELL & PELLEGRINI'
PLLC
1636 THIRD STREET
MARYSVILLE, WASHINGT,ON 96270_ . .
(360) 6511--8560 •FACSIMILE (360) 651-3762
(without imputing income). Her reported expenses are approximately $3,000. The
2
respondent husband's purported net income is $1, 122 per month. The husband's income
3
is not used to determine child support, however; it is used to determine the actual income
4
received in the respondent's household. The net household income, without
5
consideration of the parental gifts, is approximately $3,800. Based upon the respondent's
6
7 own financial declaration, she has sufficient household income to meet her monthly
8 expenses and the financial needs of her minor daughter.
9
Issue: Attorney Fees:
IO
II Issue: Whether or not to reconsider the prior award of attorney fees?
I2
Award: The petitioner shall pay attorney fees incurred by the respondent in the amount of
I3
$2,500.00 instead of the $5,000 earlier awarded. Said fees shall be paid within 30 days from
I4
the filing date of this award. Any remaining amount not otherwise paid will accrue at judgment
I5
16 interest until fully satisfied.
I7 Findings: My reconsideration of this issue is based upon the respondent husband's purported
18
income. In my prior award I indicated the husband was unemployed. Cleary that was erroneous.
I9
His income does require reconsideration of the respondent's household expenses and therefore
20
her "need" for purposes of attorney fees. My earlier findings are still appropriate, however; it is
2I
22 clear the respondent's financial needs are less than earlier determined. For that reason, a
23 reduction in the award of attorney fees is appropriate as well.
24
Other:
25

rLLC
1636 llilRD STREET
(360) 658-6580 •FACSIMILE (360) 651-6762
All other issues and.awards, unless specifically revised and set forth above,
2 shall remain as stated in the Arbitration Award of November 4th 2014.
3
ARBITRATION. FEES:
5
6' AW ARD: No fees are assessed· for this.reconsideration.

7
8 Submission: This reconslderatioil·Will be filed .With the court.Within three business dl)ys.
9
10 Respectfully Submitted,
11 Wayne-P. PelleflrU'W
12 HANSEN; McCONNEU & PEUEGRINI
1636 Third Str.,;,tl Marysville. WA 98270
13 V (360) 658-65801Fax: (360) 651-6762
Way.ne@thlrdstreetlaw.com I ~.thl~~!eetlaw.. ~o!JI.
14
15
16
17
18
19
20
21
22
23
24
25
ARBITRATION, A WARD LAW OFFICES

Page-4 HANSEN McCONl'lELL &'PELLEGRINI
PLLC .
1838 TMIRD STREET
,(380) 858-6580 o FACSIMILE (380) 8S1-6782
' ,1 f
~- 1,
i".5 JAtJ 12 AH 10: 35

1
2 SGH YA K!\/.>.SKI
COUNTY CLERt{
I~\ \ \I~~\~\\\\~\~\\\m\\\\\\~~\I~\\~
SNOHOMISH CO. WASH
3
4
CL16956569
5

7
COUNTY OF SNOHOMISH
8 In re:
9
Petitioner, PR 01°05 ~D
10
and ORDER CONFIRMING
ARBITRATION AWARD
11 Jennifer Rae Mehaddi f/k/a Rife
· Res ondent.
12
13 This matter came on for hearing on January 23, 2015 on motion of Petitioner
ndrew Rife, pursuant to RCW 7.04A.220 for an Order confirming the Arbitration
14 ward and Arbitration Award on Reconsideration and entering an order of support
thereon.
15
16 The Court now Confirms the Arbitration Award.

The petition for modification of child support is granted. The Order of Child
17 Support signed by the court on this date or dated , and
he child support worksheet, which has been approved by the court, are incorporated
10 by reference as part of this order.
19
Dated:
22
23
CARL J. GAUL WSBA# 8341 VERONICA FREITAS WSBA# 19405
24 Attorney for Andrew Rife Attorney for Jennifer Mehaddi
-~\~?';v
25
26
CARLJ.GAUL
o\\J' Attorney at Law
27
ORDER CONFIRMING \.)\'' 302 Bank of America Bldg.
1604 Hewitt Ave.
ARBITRATION AWARD Everett WA 98201 , , r()
PAGE 1 OF l 425 259-4147 FAX 259 7081 ·-::;-r-
1
~ .. . ...... -.,I
2
- .... 12- r,:; 10: 35
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3 ('I.~, • ••• I C'{I
4 1111m111111111111m , ...
":'Ci
I
:1 v
~ • . ; , \ ... 1
C... Er~K
·-· : '- ··"'J::u. Vr'AS:I
CL16956568
5

County of SNOHOMISH
7
In re the Marriage of: tiq. 05 3 02755 1
8 r.'~1v.::>os 6-tfl
ANDREW RIFE oriterdf Child Supp&rt
9 Petitioner,
and Final Order (ORS)
10
JENNIFER MEHADDI Clerk's Action Required
11 Respondent.
12
I. Judgment Summary
13
1.1 Judgment Summary for Non-Medical Expenses
14
Does not apply.
15
1.2 Judgment Summary for Medical Support
16
17 Does not apply.

II. Basis
18
2.1 Type of Proceeding
19
·This order is entered under a petition for dissolution of marriage or domestic partnership,
20 legal separation, or declaration concerning validity:
21 order for modification of a custody decree or parenting plan.
23 The child support worksheet which has been approved by the court is attached to this
order and is incorporated by reference or has been initialed and filed separately and is
. 24 incorporated by reference .
25 ORDER DF" CHILD SUPPORT CTMORS, DRS) • PAGE 1 DF" 1 1 CARLJ. GAUL
WPF' DR C 1 .CSCC MANDATORY (6/20 1 4) • ACW 26.09.1 ~;
Attorney at Law
26 26.26.132 ~~\_, 1604 Hewitt Ave., Suite 302
\\J\~
Everett WA 98201
425 259 4147
\)~
1
3 2.3 Other
4
Ill. Findings and Order
5
It Is Ordered:
6
7
3.1 Child(ren) for Whom Support is Required

8
Lauren Emily Rife 10
9
10 3.2 Person Paying Support (Obligor)
11 Name (first/last): andrew rife

Birth date: 3/22173
12 Service Address:
13 The Obligor Parent Must Immediately File With the Court and the
Washington State Child Support Registry, and Update as Necessary, the
14 Confidential Information Form Required by RCW 26.23.050.
15 The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Promptly After any Change in the Information. The Duty to Update the
16 Information Continues as long as any Support Debt Remains due Under
This Order.
17
For purposes of this Order of Child Support, the support obligation is based upon the
18 following income:
19 A. Actual Monthly Net Income: $ 6,905.
20 3.3 Person Receiving Support (Obligee)

21 Name (first/last): jennifer mehaddi
Birth date: 8/18174
22 Service Address:
23
24
25 ORDER DF' CHILD SUPPORT_ CTMCRS, ORS)· PAGE 2 DF' 1 1

WPF" DR 01 .OSCO MANDATORY (6/20 1 4) • RCW 26.09.1 75;
CARLJ.GAUL
Attorney at Law
26 26.26.132
1604 Hewitt Ave., Suite 302
Everett WA 98201
425 259 4147
1
2
3 The Obligee Must Immediately File With the Courl and the Washington
State Child Supporl Registry and Update as Necessary the Confidential
4
Information Form Required by RCW 26.23.050.
5
·The Obligee Shall Update the Information Required by Paragraph 3.3
6 Promptly After any Change in the Information~ The Duty to Update the
Information Continues as Long as any Monthly Supporl Remains Due or
7 any Unpaid Supporl Debt Remains Due Under This Order.
8 For purposes of this Order of Child Support, the support obligation is based upon the
following income:
9
C. The net income of the obligee is imputed at $2990.13 because:
.10
the obligee is voluntarily underemployed.
11
The amount of imputed income is based on the following information in order of
12 priority. The court has used the first option for which there is information:
13 current rate of pay.
14 The obliger may be able to seek reimbursement for day care or special child rearing
15
3.4 .Service of Process
16
Service of Process on the Obligor at the Address Required by Paragraph
17 3.2 or any Updated Address, or on the Obligee at the Address Required by
Paragraph 3.3 or any Updated Address, may Be Allowed or Accepted as
18
Adequate in any Proceeding to Establish, Enforce or Modify a Child
19 Supporl Order Between the Patties by Delivery of Written Notice to the
Obligor or Obligee at the Last Address Provided.
20
3.5 Transfer Payment
21
The obliger parent shall pay the following amounts per month for the following child:
22
Name Amount
23
Lauren Emily Rife $400
24 Total Monthly Transfer Amount $400
25 CADER CF' CHILD SUPPORT (TMCRS, CR6) • PAGE 3 DF' 1 1 CARL J. GAUL
WPF' DR 0 1 .OSCO MANDATORY (6/201 4) • RCW 26.09.1 75;
Attorney at Law
26 26.26.. 132
Everett WA 98201
425 259 4147
1
3 This is a downward modification that has caused an overpayment of $650.00. This

amount shall be repaid or credited as follows:
4
The new child support amount of $400.00 per month is effective from
5 October 1, 2014. The previous child support order required payment of
$562.50 per month, which the obliger paid in October, November and
6
December 2014 and January 2015, resulting in an overpayment of
7 $650.00. The Division of Child Support shall apply a credit of $65.00 per
month for ten months reducing the obliger's actual payment to $335.00 per
8 month. When the overpayment has been fully credited against the
obliger's support obligation the actual transfer payment shall increase to
9 $400.00 per month.
10 The Obligor Parent's Privileges to Obtain or Maintain a License, Certificate,

Registration, Permit, Approval, or Other Similar Document Issued by a
11 Licensing Entity Evidencing Admission to or Granting Authority to Engage
in a Profession, Occupation, Business, Industry, Recreational Pursuit, or
12 the Operation of a Motor Vehicle may Be Denied or may Be Suspended if
the Obligor Parent is not in Compliance With This Support Order as
13
Provided in Chapter 74.20A Revised Code of Washington.
·14
3.6 Standard Calculation
15
$831 per month. (See Worksheet line 17.)
16
17
The child support amount ordered in paragraph 3.5 deviates from the standard
18 calculation for the following reasons:
19 The child 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
20 funds in the receiving parent's household to meet the basic needs of the child.
The child does not receive public assistance;
21
The factual basis for these reasons is as follows:
22
See Arbitration Award and Arbitration Award on Reconsideration
23
24
Does not apply. A deviation was ordered.
25 CADER CF CHILD SUPPORT (TMORB, ORSI - PAGE 4 DF' 1 1
CARLJ. GAUL
WPF" CR 0 1 .0500 MANDATORY (6/20 1 41 - RCW 26.09. 1 75;
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
2
3
4
Starting Date: October 1, 2014
5
Day(s) of the month
6 support is due: First

8 Does not apply.
9 3.11 Making Support Payments
10
Select Enforcement and Collection, Payment Services Only, or Direct Payment:
11
Enforcement and collection: The Division of Child Support (DCS) provides support
·enforcement services for this case because: a parent has signed the application for
12 services from DCS on the last page of this support order. Support payments shall be
made to:
13
Washington State Support Registry
14
P.O. Box 45868
Olympia, WA 98504
15
Phone: 1-800-922-4306
or 1-800-442-5437
16
A party required to make payments to the Washington State Support Registry will not
17
receive credit for a payment made to any other party or entity. The obliger parent shall
keep the registry informed whether he or she has access to health insurance coverage
18
at reasonable cost and, if so, to provide the health insurance policy information.
19
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
20
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
21 support, is being spent to benefit the child.
22
3.12 .wage Withholding Action
23
enforced against real and personal property under the child support statutes of this or
24
any other state, without further notice to the obliger parent at any time after entry of this
order unless an alternative provision is made below:
25 ORDER CF" CHILD SUPPORT <TMORS, ORS) - PAGE 5
WPF" DR C 1 .OSCO MANDATORY (6/ZO 1 4) - RCW 26.09. 1 75;
CF" 1 1
CARLJ.GAUL
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
2
3
(If the court orders immediate wage withholding in a case where Division of Child
4 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
5 Support Registry.)
6 3.13 Termination of Support

7 Support shall be paid:
8 until the child reaches the age of 18, or as long as the child remain(s) enrolled in high
school, whichever occurs last, except as otherwise provided below in Paragraph 3.14.
9
3.14 Post Secondary Educational Support
10
The right to request post secondary support is reserved, provided that the right is
11 exercised before support terminates as set forth in paragraph 3.13.
12 3.15 Payment for Expenses not Included in the Transfer Payment
13
Does not apply because all payments, except medical, are included in the transfer
payment.
14
3.16 Periodic Adjustment
15
Does not apply.
16
17 3.17 Income Tax Exemptions
18 Tax exemptions for the children shall be allocated as follows:

To the mother in even numbered tax years and the father in odd numbered tax years.
19 The mother shall file as Head of Household every year.
.20 3.18 Medical Support- Health Insurance
21 Each parent shall provide health insurance coverage for the child listed in paragraph 3.1,
as follows:
22 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.)
23
A. Evidence
24
25 ORDER OF CHILD SUPPORT (TMCRS, ORS)· PAGE 6 OF' 1 l CARLJ. GAUL

WPF' DR a 1 .a sea MANDATORY (6/20 1 4). RCW 26.09.1 75;
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
3 (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
4 B and C below.
5 B. Findings about insurance:
6
Andrew Rife Jennifer Mehaddi Check at least one of the following findings
7 (Parent's Name) <Parent's Name\ for each oarent
Insurance coverage for the child is available and
8 [X] accessible to this parent at $253.32 cost (child's
portion of the premium, onlv\.
9 Insurance coverage for the child is available and
II accessible to this parent at $ cost (child's
10 oortion of the oremium. onlvl.
Insurance coverage for the child is available but
11 II not accessible to this parent at $ cost (child's
Portion of the premium, onlv\.
12 Insurance coverage for the child is available but
II not accessible to this parent at $ cost (child's
.13 portion of the premium, onlv\ .
Neither parent has available or accessible
14 II insurance through an employer or union: but this
parent is able to provide private coverage at a cost
15 not to exceed 25% of this parent's basic support
obliaation.
16 Neither parent has available or accessible
II insurance through an employer or union: but this
17 parent is able to provide private coverage at a cost
not to exceed 25% of this parent's basic support
18 obliaation.
(Check only one parent) Both parties have
19 II [I available and accessible coverage for the child.
The court finds that this parent has better coverage
20 considering the needs of the child, the cost and
extent of each parent's coverage, and the
21 accessibilitv of the coveraoe.
Other:
22 II II
23 C. Parties' obligations:
24 The court makes the following orders:
25 CADER CF" CHILD SUPPCRT CTMCAS, CRSJ - PAl3E 7 CF" 1 1 CARLJ. GAUL
WPF DR c 1 .DSCC MANDATORY (E;/20 1 41 • RCW 2e.c9.1 75;
Attomeyat Law
26 2e.2e.1 32
1604 Hewitt Ave .. Suite 302
Everett WA 98201
425 259 4147
1
2
3 Check at least one of the following options for
Andrew Rife Jennifer Mehaddi
each parenl
4 (Parent's Name) (Parent's Namel
This parent shall provide health insurance
5 [1 [1 coverage for the child that is available through
employment or is union-related as long as the
·6 cost of such coverage does not exceed 25% of
this parent's basic suooort obligation.
7 This parent shall provide health insurance
[X] [1 coverage for the child that is available through
8 employment or is union-related even though
the cost of such coverage exceeds 25% of this
9 parenfs basic support obligation. It is in the best
interests of the child to provide such coverage
10 despite the cost because:
11 This parent shall provide private health insurance

. II II coverage for the child as long as the cost of such
12 coverage does not exceed 25% of this parent's
basic suooort obligation.
II II coverage for the child even though the cost of
14 such coverage exceeds 25% of this parent's basic
support obligation. It is in the best interests of the
15 child(ren) to provide such covera~e despite the
cost because:
16
This parent shall pay $ towards the health
17 II II insurance premium being paid by the other
parent. This amount is this parent's proportionate
18 share of the premium or 25% of this parent's basic
support obligation, whichever is less. This
19 payment is only required if this parent is not
providing insurance as described above.
20
This parent's contribution to the health insurance
21
II II premium is calculated in the Worksheet and
included in the transfer payment.
22 This parent shall be excused from the
II IxI responsibility to provide health insurance
23 coverage and from the responsibility to provide
monthly payment towards the premium because:
24
25 ORDER OF" CHIL..D SUPPORT (TMCRS, ORS) • PAGE 8 CF" 1 1

WPF' DR 0 1 .0500 MANDATORY (6/20 1 4) - RCW 26.09.1 75;
CARLJ.GAUL
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
3 I (Only one parent may be excused.)

4 D. Both parties' obligation:
5 If the childare receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parent's monthly premium.
6
The parent(s) shall maintain health insurance coverage, if available for the child
7 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
8 privileges exist to continue coverage following termination of employment.
9 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
10 payment from an insurer.
A parent who is required under this order to provide health insurance coverage
11
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
12
Registry if the parent has been notified or ordered to make payments to the
Washington State Support Registry.
13
If proof that health insurance coverage is available or not available is not
14 provided within 20 days, the parent seeking enforcement or the Department of
Social and Health Services may seek direct enforcement of the coverage through
15 the other parent's employer or union without further notice to the other parent as
provided under Chapter 26.18 RCW.
16
You may have separate obligations to provide health insurance coverage for the
17 child(ren) under federal law.
18 3.18.2 Change of Circumstances and Enforcement
19 A parent required to provide health insurance coverage must notify both the Division of
Child Support and the other parent when coverage terminates.
20
If the parents' circumstances change, or if the court has not specified how medical
21 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
22 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:
23
Providing or maintaining health insurance coverage through the parent's employment
24 or union at a cost not to exceed 25% of that parent's basic support obligation;
25 ORDER Cf" CHILD SUPPORT (TMORS, ORS)· PAGE 9

WPF' OR C 1 .OSCO MANDATORY (6/20 1 4J • RCW 26.09. 1 75;
Cf" 1 1
CARLJ.GAUL
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
3 Contributing the parent's proportionate share of a monthly premium being paid by the
other parent for health insurance coverage for the child(ren) listed in paragraph
4 3.1 of this order, not to exceed 25% of the obligated parent's basic support
obligation; or
5 Contributing the parent's proportionate share of a monthly premium paid by the state
if the child(ren) receives state-financed medical coverage through DSHS under
6 RCW 74.09 for which there is an assignment.
7 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
8 for contempt (use form WPF DRPSCU 05.0100, Motion/Declaration for an Order to
Show Cause re Contempt); or file a petition.
9
3.19 .Uninsured Medical Expenses
10
Both parents have an obligation to pay their share of uninsured medical
11 expenses.
12 The petitioner shall pay 69.8% of uninsured medical expenses (unless stated
otherwise, the petitioner's proportional share of income from the Worksheet, line
13 6) and the respondent shall pay 30.2% of uninsured medical expenses (unless
stated otherwise, the respondent's proportional share of income from the
14 Worksheet, line 6).

17 3.21 Past Due Unpaid Medical Support

18 No past due unpaid medical support is owed at this time.
19 3.22 Other Unpaid Obligations

20 .Other obligations that may be owed are not affected by this order.
21 3.23 Other
22
23
Dated: - - - - - - - - - - - - -
Judge/Commissioner
24
25 ORDER Cf" CHILO SUPPORT (TM ORB, ORS) • PAGE 1 0 CF 1 1 CARL J. GAUL
WPF" OR 01 .0500 MANDATORY (6/20 1 4) · RCW 26.09.1 7Sj
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
1
3 Notice· of presentation.waived:
5
8341 19405
6 CARLJ.GAUL VERONICA FREITAS
7
8 I apply for full support enforcement servicesfroin.the DSHS' Division of Child Support '(DCS).3
(Note: _If you never received TANF, tribal TANF, or AFDC, an a_nnual $25fee applies if
9 over $500 is disbursed on a case, unless the fee.is waived by DCS:)
10
11 Signature of Party
12
13
14
1.5
16
17
18.
·19
20
21
22
23
24
25 ·OACEA: CJF' ·CHILD SUPPORT rrMoR·s, o'RsJ - PADE ·1 1 CF' 1 -1 CARLJ.GAUL

WPF DR 01 .OSCO MANDATORY (6/20 1 41 • RCW 26.09• 1 7Sf
Attorney at Law
26 26.26.1.32
Everett WA 98201
425 259 4147
Mother: jennifer mehaddi Father: andrew rife
County: SNOHOMISH Superior Court Cause Number: 05 3 02755 1
RESIDENTIAL SCHEDULE CREDIT USING FORMULA

Lauren
16. NAMES OF CHILDREN
17. BASIC SUPPORT $1,300.00 - - - -
(From Table)
18. ORDINARY-EXPENSES - - - - -
19. ADJUSTED BASIC SUPPORT $1,300.00 - - - -

20. OVERNIGHTS WITH MOTHER 191
21. % OVERNIGHTS WITH MOTHER 52.3 - - - -
(Line 20 divided by 365)
22. OVERNIGHTS WITH FATHER 174
23. %OVERNIGHTS-FATHER
47.7 - - - -
24. MOTHER'S CREDIT PROP .550 - - - -

25. FATHER'S CREDIT PROP .450 - - - -
26. MOTHER'S CREDIT
(Line 19 times Line 24)
$715.00 - - - -
27. FATHER'S CREDIT
$585.00 - - - -
28. OVERNIGHT THRESHOLD SELECTED: 91 NIGHTS
29. TRANSFER PAYMENT BEFORE CREDIT: $830.90

30. RESIDENTIAL CREDIT TO Father IS: $585.00
31. TRANSFER PAYMENT AFTER CREDIT: $245.90
Client c:\program files (xBB)\legalplus\rife andrew\life endrew(B).scp 01/0712015 05:59 pm
....
SupportCa/c" 2011 (Rev. 10/2009)
'. - - '·~ :_ .. · -'• .~ .
[ J Proposed by [ ] [ ] State of WA [ ] Other (CSWP)
Or, J ] Signed by the Judicial/Reviewing Officer. (CSW)
County: SNOHOMISH Case No.: 05 3 02755 1
Child Support Order Summary Report
This section must be completed for all Worksheets signed by the

judicial/reviewing officer.
A. The order [ ] does [ ] 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:
C. The Transfer Amount ordered by the Court from the Order of Child Support is:
- to be paid by [ J mother [ J father.
D. The Court deviated (changed) from the Standard Calculation for the following reasons:
[ J Does not apply
[ ] Nonrecurring income ( ] Sources of income and tax planning
[ I Split custody [ ] Residential schedule (including shared custody)
[ t Child(ren) 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. lncomeforthe.Fatheris_(_]_im_p_u-te_d_[_]_ac-t-ua-1-in_co_m_e_.- - - - - - - - - - - - -·
Income for the Mother is [ ] imputed [ ] actual income.
Income was imputed for the following reasons:
F.Ifapplieable: [ I All health care, day care and special child rearing expenses are"iiicluded-Trlthe--
worksheets in Part 111.
WSCSS-Worlfsheets - Mandatory (CSWICSWP) 612010 Page f of 5
Worksheets
Chlldlrenl and Aaelsl: Lauren Emilv Rife. 10
Part I: Income (see Instructions. paQe 6)
a. Wages and Salaries {lm~uted_ for Mother) - - $9,061.38 -
-
b. Interest and Dividend
c. Business Income
. - Income -
--
-- -- --
.. - - --
-
-
d. Maintenance Received
-- -
- - - -e.-Other Income - - -
f. Imputed Income
g. Total Gross Monthly Income (add lines 1a through 11)
-
$9,061.38
$3.492.66
$3,492.66
a,_lll~r:ne Taxes (Federal and S_!ate) _ Tax Year: Manual - -·- !!,731.71 $226.56
b. FICA (Soc.Sec. +Medi!:!i~)/Self-Employment Taxes - - $267.18
- - State Industrial
c. - ---
Insurance Deductions -- - - -- $8.79
d. Mandato!}'. Union/Profes_sional Dues
__e.M~~datO_l)'Pt:lnsion Plan Pa~ments
-- -- -
- -
$425.05
--
f. Volu~tal)' Retirement Contributions ___ .. -- - --
__g. Maintenance Paid ____ -- -- - ----
__ h. fljormal Busi_ness Ex~nses
i. Total Deductions from Gross Income
. - -- - - - . -
. (add lines 2a through 2h) $2,156.76 $502.53
3. Monthly Net Income (line 1g minus 2i) $6,904.62 $2.990.13
(line 3 amounts combined)
5. Basic Child Support Obligation (Combined amounts ~)
Lauren Emily Rife $1300.00
- $1,300.00
-
-
-
Part II: Basic Child Sunnort Obllaatlon Csee Instructions. paae 71
7. Each Parenrs Basic Child Support Obligation without consideration
of low income limitations (Each parenrs Line 6 times Line 5.) $907.40 $392.60
B. Calculatin!l low income limitations: Fill in onlv those that aoolv.
Self-Suooort Reserve: (125% of the Federal Poverty Guideline.) I $1.134.00 I
a. I~ t;Q!'.DbiO!lQ t'.!l!l! lnc;orne !,,ess Than U QQQ2 If yes, for each
_ p_arent enter the presumptlv~ $5Q_per child.
b. I~ M!mlbl~ !:'.!!el locome Less Itl!!o S!llM.il.!llllQr:l Bei;grve? If yes,
- - - ..
for that parent enter th_e presumptive $50 per child.

c. Is Moalbl~ Net ln~me G~;iter Illii!ll Self-Su1mor:t Beseoo:'.l If
-- - -
yes, 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 Qreater.
9. Each parenrs basic child support obligation after calculating
- -
from line 7. Ba - Be, but not less than the presumptive $50 per $907.40 $392.60
child.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 612010 Page 2 of 5
Part Ill: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Exoenses Father Mother
__ __a. Monthly l:l~i!lth_l_n_surance Pai~_ to_r_ C_h~d(ren) $253.32 -
. p_b. U_ni~sured Monthl)' Health Care Expenses Paid for Child(renl _
-- - . - - - -
· !line 10a olus line 10bl
$253.32 -
!line 10c amounts combined\ $253.32
11. Dav Care and s~cial Exoenses
__ac Di!)' Care Expenses - -.- - -- - - -
b. Education Expenses -- -
-
- _ . c. Lorig. Dista~c~ Tran~i:>ortation Ex~nses - -----
d. Other Si:iecial Expenses (describe)
- --- ·- ------
-- - - - --
-- - - -·- -
--
-
- - - -- -
e. Total Day Care and Special Expenses -
IAdd lines 11a throuah 11dl
lline 11 e amounts Combinedl -
13. Total Heallh Care, Day Care, and Special Expenses (line 10d
plus line 12) $253.32
14. Each Parent's Obligation for Health Care, Day Care. and Special
Exoenses lmultiolv each number on line 6 bv line 13) $176.82 $76.50
Part IV: Gross Chlld Support Obligation
15. Gross Child Sunnort Obliaation /line 9 olus line 141 $1.084.22 $469.10
Part V: Chlld Support Credits (see Instructions, page 9)
16. Child SU""Or! Credits
. __ a. Mon~hly _H~al!I!_ Care Expenses Credit
b. Da)' Care and Special Expenses Credit
~2~3.32
-
-
-
-
- -
-
-
--
- -
d. Total Sunnort Credits I add lines 16a ihrouah 16cl $253.32 -
whichever is nreaterl $830.90 $469.10
Part VII: Addltional Informational Calculatlons
18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each oarentl $3.107.08 $1.345.56
19. 25% of each parent's basic support obligation from line 9 (.25 x
WSCSS-Worl!sheets ·Mandatory (CSW/CSWP) 612010 Page 3 of 5
a. Real Estate
b. Investments
-
-
--
c. Vehicles and Boats - -
d. Bank Accounts and Cash - --
e. Retirement Accounts
f. Other: (describe)
-- -
- -
- -
21 Household Debt
- -
a. - -
b. -- -
c. -
d. - --
e.
f.
-- -
(if not the other ~arent of this action)
Name Souf}'.ane - $1,122.00
Name - -
b. Income Of Olher Adults in Household
Name - -
Name
c. Gross Income from overtime or from second jobs th·e party
- -
--
d. Income Of Child(ren) (if considered extraordinary)
- -·
Name
Name
-- -
-
e. Income From Child Suooort
Name - -
Name - -
f. Income From Assistance Programs
Program -- -
Program -
_ _ g. Other Income (describe)
- -
23. Non-Recurrin11 Income (describe)
- -
- --
WSCSS-Worlrsheets - Mandatory (CSW!CSWP) 612010 Page 4 of 5
-
24. Child Support Owed, Monthly, for Biological or Legal Child(ren) Father's Mother's
Household Household
Name/age: Paid []Yes ll No - -
Name/age: Paid [J Yes l1 No - --
Name/aoe: Paid nYes I l No
25. Other Child(ren) Living In Each Household
-
(First name(s) and age(s))
26. Other Factors For Consideration (attach additional pages as necessary)

Child Support ordered deviates from the standard calculation pursuant to RCW 26.19.075(1)(d),
based upon significant time the child spends with the obligated parent, based upon the Arbitration
Award and the Arbitration Award on Reconsideration. Though the "formula" deviation would result in
a transfer payment of $245.90, the Arbitrator exercised discretion to determine that the transfer
payment should be $400 per month.
Sianature and Dates

Date· City Date City
Worksheet certified by the State of Washington Administrative Office of the Courts.

WSCSS-Worksheets - Mandatory (CSWICSWP) 612010 Page 5 of 5 SupportCa/c" 2011
c: .. \slate temptates\wawOrksheetdtf c:\program files (x88)\legalplus\lite andrew'lrife andrew(6).scp 01/0912015 09:54 am
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CL16956570
4

COUNTY OF SNOHOMISH
7
8 In re:
9 Petitioner,
and Motion for Judgment
10 on Arbitration Award
Jennifer Rae Mehaddi f/kla Rife
11 Res ondent.
12
Comes now Andrew Scott Rife, Petitioner above named, and moves this Court
13 to enter an Order granting the relief requested in Part I below:
15 Andrew Scott Rife moves this Court to enter an Order of Support consistent
ith the Arbitration Award and Arbitration Award on Reconsideration.
16
II. ·Statement of Grounds
17
This matter arises out of a contested action for major modification of parenting
18 plan filed by Andrew Rife. He requested modification of child support as part of that
petition. At mediation with attorney Wayne Pellegrini the parties agreed upon a new
19 permanent parenting plan. On November 17, 2014 the court entered an Order on
Modification and a Parenting Plan (Final Order). These documents concerned the
20 parenting plan only, and dicf not address any issues of support or attorney fees.
21 The parties agreed to binding arbitration of child support and attorney fees.
Wayne Pellegrini was agreed to be the sole arbitrator. Mr. Pellegrini issued an
22 rb1tration Award and lafer issued an Arbitration Award on Reconsideration. The
time for further reconsideration has expired.
23
The arbitrator determined that the child support transfer payment should be
24 $400 per month payable by Mr. Rife to Mrs. Mehaddi. He also determined that Mr.
Rife should pay $2500 toward Mrs. Mehaddi's attorney fees.
25 . \v
26
0~~ CARLJ.GAUL
Attorney at Law
\)~
MOTION F'OR JUOGMENT
1604 Hewitt Ave.
ON ARBITRATION AWARD
Everett WA 98201
PAGE 1 OF' 2 425 259-4147 FAX 259 7081
2 Should the court enter an Order of Support based upon the Arbitration Award?
4 Arbitration Award
Arbitration Award on Reconsideration
s Copies Attached.
5 Legal Authority
7 RCW7.04A
8
Dated: January 8, 2015 (
9
10
11
12
13
14
15
16
17
18
19
20
21
22
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25
26
CARLJ.GAUL
Attorney at Law
MOTION F"OR JUDGMENT
1604 Hewitt Ave.
ON ARBITRATION AWARD
Everett WA 98201
PAGE 2 OF" 2 425 259-4147 FAX 259 7081
2

In re:
)
7
8 ANDREW RIFE, No. 05-3-02755-1

Petitioner,
10'
PURSUANT TO RCW 7.04A
JENNIFER MEl-IADDI (flea Jennifer Rife),
11 Respondent.
12
13 ARBIRTATIONAWARD
14 Authorization: Based upon the Tem1s and Agreement for Binding Arbitration signed by the
15
parties on or about October 23rd and/or their respective counsel.
16
Considerations:
17
18
My award is based upon the written submissions and evidence presented by counsel, the
19 Stipulated Agreement Pursuant to CR2(A), the GAL Report of Mach 23, 2014, Supplemental
20 GAL Report of May 26, 2014 and upon relevant case law and statutes including bul not limited
21
to: RCW 26.19.071, RCW 26.19.080, RCW 26.19 Appendix - Child Support Schedule; In re
22
Marriage of Daubert 124 Wn. App. 226; In re Custodyof BJB 146 Wash. App. I (2008); State
23
ex rel. Sigler v. Sigler, 85 Wn. App. 329, 932 p.2d 710 (1997); ln re Marriage of Williams, 84
24
Wn. App. 263; In re of Jn re Marriage ofCrosetto 82 Wn. App. 545; Jn re the Marriage of
25

PLLC
1638 THIRD STREET
(380) 658-8580 •FACSIMILE (380) 631-11762
Mal/son, 95 Wash App. 592 (1997); RCW 26.09.140; In re Marriage of Shellenberger, 80 Wash
2
App 71, (I 995) and other case law as set forth in the body of this award.
3
Facts:
4
·Andrew Rife (hereinafter referred to es petitioner) and Jennifer Mehaddi (hereinafter
5
6 referred to as respondent) divorced by Decree entered in Snohomish County Superior Court on
7 November 7lh 2006. The parties have one child, Lauren Rife (age 9). On October 3«1 2013,
8 petitioner filed for a parenting plan modification. As pan of his petition he requested an order
9 1
establishing child support in conjunction with the entry of a parenting plan. A Response was
10
timely filed.
11
Andrew Rife: is single. He hes no children, except for Lauren, at issues in this matter.
12
13 Pursuant to the 2006 Final Order of Child Support, the following pertinent information is noted:
14 I. Petitioner is paying $562.52 monthly (wage assignment through DCS).

2. There was no deviation requested or sought by either parent
IS
3. The father is required to pay 67% and the mother 33% of the following expenses:
16 Work related day care; pre-school and Camps, lessons, sports and enrichment
programs.
17 4. The father provides medical insurance on behalf of Lauren.
2
5. The parties agreed upon a life insurance provision.
18
Petitioner is currently employed with Snohomish County PUD. He reports a monthly
19
20 gross income of$9,06J.38. 3 He reports monthly expenses of$3,612 inclusive ofLauren's tuition
21 expense of $579.00.4 Andrew has prayed for the following relief: (1) Determine child support
22 for Lauren based upon his reported income and imputed income to Jennifer (her cunent hourly
23
24 1
See Petition for Modification/Adjusbnent of Custody Decree/Parenting Plan/residential Schedule.
l See Final Order of Child Support entered November 7" 2006.
25 3
See Declaration of Andrew Rife dated October 21" 2014.
' See Financial Declwation of Petitioner filed October 3, 2013.
ARBITRATION Aw ARD o:LA~W:':':"o.,,F~Fl=C=E..
s, - - - - , - - - - - -
l'age· 2 , HANSEN Mc-CONNELL & PEl.l.EGRINI
PLl.C
1838 THIRD STREET
MARYSVILl.E. WASHINGTON 911270
(360) ~580 •FACSIMILE (360) 851-8782
wage imputed to full time - 40 hours per week); (2) Deviate from the determined basic child
2
support calculation, based upon the amount of time he spends with Lauren under the terms of the
3
mediated parenting plan; yet to be entered with this court. (3) Petitioner proposes a child support
4
transfer payment of$274.33 (deviated pursuant to his proposed incomes and residential credit).
5
6
Jennifer Mehaddi is married. She has no children, except for Lauren, at issue in this
7 matter. She is currently employed with The Polyclinic as a medical assistant. She reports an
8 hourly rate of$20.15 and a work week consistent of35 hours 5 . She is paid bi-weekly. Her
9
proposed child support worksheets suggest a gross income of $3,110.68 (slightly more than her
10
reported hourly wage income). She reports monthly expenses of$2,934.69. 6 Respondent prays
II
for the following relief: (I) The determination of child support based upon her reported gross
12
13
incomes (as identified on her proposed child support worksheet~); (2) Attorney fees in the
14 amount of$15,000; based upon need and ability to pay and for intransigence on the side of the
15 petitioner; (3) Denial of a downward deviation as proposed by the petitioner.

16
Other Pertinent Facts: (I) 1be parties reached an agreement as to each parent's
17
respective residential time with Lauren. At this time, those agreed upon terms are set forth in the
18
S1ipula(ion Agreement Pursuant to .CR2(A) executed by the parties on September l l 1h 2014. (2)
19
20 The parties agreed Lauren would continue to attend Arch Bishop Murphy (Catholic School) "as
21 lung as the father continues to pay 100% ofthe tuition costs".1
23
' See Declaration of Jennifer Mehaddi dated October 21" 2014.
6
24 See finoncial Declaration of Respondent dated October 21 • 2014.
7
25 See Stipulation Agreement Pursuant to CR2(A). The terms of the residential schedule pursuant to this agreement
are not separately set forth in this award. However, the allocated residential times for each parent has been noted
and is aniculated below.
ARBITRATION AW ARD ..
LA..,_W"--"O"-F..._F...
1c..ES,,__ _ _ _ _ __
Page- 3 HANSEN McCONNELL & PEl.l.EGRJNI
PLLC
1838 THIRD STREET
(360) 658-6580 •FACSIMILE (380) 651-6762
2
Issue: Determination of each party's child support obligation based upon the following:
3
4 I. An assignment of their respective incomes, deductions and credits;
5 2. Whether or not to impute income to the respondent as requested by the petitioner;
6 3. Whether or not lo award the petitioner a deviation pursuant to the amount of time he
7
spends with Lauren under the terms of the residential schedule.
8
Award: Child Support Transfer Payment - Payment made to - Date of Commencement:
9
10 • The respondent/father will pay the mother monthly child support in the amount of
11 $830.90
12
• The father is denied a deviation without prejudice. The father is deserving of a
13
deviation of child support based upon the significant time he spends with Lauren.
However; to provide a deviation at this time would leave the mother without the financial
14 ability to meet the basic necessities of the child in her home.
15 • Payments to commence October 111 2014 (Date submitted to Arbitration);

16
• Child support shall be payable pursuant to the same terms as set forth in the 2006 Final
17
order o Child Support through the Washington State Support Registry.
18
• Child support will be paid on 1•1 pay date of the month.
19
20 Findings: I find the father's income, deductions and credits for determining child support to
21
be as follows:
22
• Monthly gross income of$9,061.38
23 • Other Income: No other income was reported or verified.
24 • The father received a deduction of$42S.OS for his mandatory retirement
contributions pursuant to RCW 26.19.07l(S)(c);
25 • No other deductions were verified. The father's request for a deduction for
voluntary retirement contributions is denied - see RCW 26.19.071(S)(g);
ARBITRATION A WARD uLA~W"--"0'"'-f.wfl.,.C,,.ES.,___ _ _ _ _ __
Page· 4 HANSEN McCONNELL & PELLEGRINI
Pl.l.C
1636 THIRD STREET
(380) 658-6580, FACSIMILE (360) 651-6782
• A credit of $253.32 for medical insurance premiums paid for medical insurance
2
on behalf of the child.
• The father's monthly income taxes were formulated utilizing single (l) - Sec
3 Child Support Worksheets.
• Net income= $6,211,42
4
• Proportional share of income: 70%
5
6 I find the mother's income, deductions and crediL~ for determining child support to be as
7
follows:
8
• Monthly gross income is imputed at $3,492.66 pursuant to RCW 26.19.071 (6)
9 (a). Said income is based upon the "Full time earnings al lhe currenl ra/e of
pay".
10
• No other income was utilized for child support purposes;
11 • The mother does not rcpon or demonstrate retirement deductions or other credits.
• The mother's monthly income taxes and other deductions were based upon
12 married filing separately (1) - See Child Suppon Worksheets.
• Net monthly income= $2,990.13
13
• Proportionate share of income: 30o/o
14
Petitioner/Father's fncome: The father presented accurate pay stub information through
15
September 15 1h 2014 and accurate historical taxable income for 2013. Utilizing the year lo date
16
income reponed on his pay stubs was an accurate representation of his monthly income for 2014.
17
18 Respondent/Mother's Income: The mother presented accurate pay sub infonnation
19 through August 23n1 2014 and accurate earnings for 2013. However; I find the mother to be
20 "voluntarily underemployed" pursuant to RCW 26.19.071 (6)(a). Respondent reports she is

21
making a full time wage at 35 hours. Nevertheless, she provides no substantiation or evidence
22
presented to support her position that she can't work more hours. "Full time" can be determined
by the employer - if it is less than 40 hours per week and so stated by policy. In this case there
24
was no representation to that fact. Therefore, the court is required to impute income to a
25
ARBITRATION AWARD LAWOFFICF$

Page- 5 HANSEN McCOl'INELL & PEl.LWRINI
PLLC
1636 THIRD STREET
(380) 6511-8560 •FACSIMILE (360) 651~762
volwitarily underemployed parent for purposes of calculating child support In re Custody of BJB
2
146 Wash. App. I (2008).
3
Deviation from the Standard Child Support Calculation: It is undisputed the court
4
has discretion to deviate based upon the significant residential time the father spends with
5
8
Lauren. The father's residential time with Lauren is greater than 40%, which justifiably meets
6
7 any standard for "significant residential time". Under the Residential Credit Formula,
8 respondent would receive a significant reduction in the petitioner's child support obligation.
9 Unfortunately, respondent's "significant time" must be weighed against the determination of

10
whether or not the deviation provided to respondent would result in insufficient funds in the
II
household of the parent receiving support - "ta meet the basic needs of the child"? The analysis
12
for a deviation would be more in line with a mathematical review of the evidence. SpecificaUy,
13
the $ reduction of expenses in the mother's household v. the increase $ expenses in the father's
14
15 household. The respondent mentions State ex rel. Sigler v. Sigler, 85 Wn. App. 329, 932 p.2d
t6 710 ( 1997). Although the case is more noted for "not allowing the residential credit lo noncustodial
17 parents whose children receive AFDC, there was a significant point articulated by the court:
18
·111 the revised order of child support the court stated the reason far the deviation was
19 that the.father had the child 40.5 percent of the time. The evidence does support a finding
rhat the child spent that amount of time with the father. The State argues that the court
20 did not list any facts which indicate haw much the father spends an the child when she is
in his care which would justify the reduction in support. The court does fail to enter such
21
22
8
RCW 26.19.075(1)(d) Residential schedule. The coun may deviate from the standard calculation if the child
23 spends a significant amount of time with the parent who is obligated to make a suppon transfer payment. The coun
may not deviate on that basis iflhc deviation will result in insufficient funds in the household receiving the support
24 to meet the basic needs of the child or if the child is receiving temporary assistance for needy families. When
determining the amount of the deviation, the coun shall consider evidence concerning the increased expenses to a
25 parent making suppon transfer payments re.suiting from the significant amount of time spent with that parent and
shall consider the decreased expenses, if any, to the party receiving the support resulting from the significant amount
of time the child spends with the parent making the support transfer payment.
ARBlTRATION Aw AKD .,LA=W_,o,,.F_._f_.,1c..E,.S.___ _ _ _ _ __
Page- 6 HANSEN McCONNELL & ~ELLEGR!NI
PLLC
1836 TlilRO STREET
~O) 658-8580 •FACSIMILE (380) 851-8762
findings. and gives no indications how the decrease was calcu/a!ed. Although Mr. Sigler
s!Cl/es how much money he spends on Kristina while she is in his care, the .findings and
2
conclusions emered by the judge do no/ reflect this. Thus, the deviation.fai/sfi1r this
3
rea.wn, as well as/or noncompliance with RCW 26.19.075(/)(d). 9
4
In the instant case, the mother's actual net income is approximately $2,700.00 (without imputing
5
income). Her reported expenses are approximately $3,000. The respondent is married, however;
6
7
there is no evidence of income reported to the new husband. In fact, the joint tax return, for
8 2013, indicates a community "adjusted gross income" of $36,000. When considering the
9 financial welfare of the child, I felt it important to also consider the number of parties in
10
respondent's household that she is responsible for; as well as her own financial circumstances.
11
Second, there is no evidence (even after thoroughly considering her financial declaration) the
12
reduced hours that Lauren spends with her will reduce her overall expenses. On the other hand,
13
the father's net income is approximately $6,900. His reported expenses of approximately
14
15 $3,600.00; include Lauren's tuition. Using the same analysis, I could not reasonably fmd the
16 increased time with Lauren resulted in an increase in his reported expenses. When examining his
17 linancial declaration, I see no significant increase to his "Food and Supplies'', the "Children"
18
category or the more basic expenses such as his mortgage and utility payments. Clearly, the
19
greatest "child" expense is Lauren's tuition, which he agreed to cover 100%; provided Lauren
20
continued to attend the school of his choice. Because the father purposefully agreed to pay
21
I 00% Qf this cost, I was compelled to eliminate that expense as a justification for a deviation. In
22
23 final analysis, a trial court is required to enter written findings of fact supported by the evidence,
24
25
' Sec SJ are ex rel. Sigler \'. Sigler, 85 Wn. App. 329, 932 p.2d 710 ( 1997).
ARBITRATION AWARD I II W OFFICES

Page· 7 HANSEN McCONNELL&. PF.Ll.EGRINI
PLLC
18J6 THIRD STREET
(350) 85S-65BO •FACSIMILE (380) 651-6762
when it enters an amount for support, which deviates from the standard calculation. RCW
2 26.19.035(2); In re Marriage ofSacco, 114 Wn.2d I, 4, 784 P.2d 1266 ( 1990). The failure to
3
enter findings is an abuse of discretion and subject to reversal. In re Marriage of Glass, 67 Wn.
4
App. 378, 384, 835 P.2d 1054 ( t992). In this case, I cannot award a deviation to the father
5
without leaving the mother's household insufficient to provide for the child's basic needs.
6
7 Other Child Support Related Issues
8
3.15 Payment for F...xpenses not
9 Included in the Transfer Payment
10
Issue: Dctcnnine whether or not to allocate or apportion to each parent a responsibility to pay
11
for educational costs, sports and other extracurricular expenses for the child?
12
13 Award: The father will pay for 100% of the tuition cost associated with Lauren attending Arch
14 Bishop.Murphy.
IS
The parties will continue to pay for "other expenses" not included in the transfer payment
16
pursuant to the terms set forth below:
17
The petitioner/father shall pay 70% and the respondent/mother 30% (each parent's
18
proportional share of income from the Child Support Schedule Worksheet, line 6) for the
19
following costs incurred on behalf of Lauren.
20
• Educational: Those expenses generally required by the school, which include,
21
graduation expenses, ASB dues, mandatory field trips, necessary equipment
22 (calculators, etc.) school &JlOrt fees;
23 • Soorts (outside school) and Other Activity Expenses: These expenses must be
agreed to in writing (email/phone texting) before either party is obligated
24 financially to pay his/her proportional share.
25
Payments shall be made to the provider of the service. If one parent pays the other
ARBITRATION AWARD 1..AWOFFICES

Pagc-8 HANSEN McCONNELL & PEl.LF.GRINI
PLLC
1838 THIRD STREET
(380) 658-8580 •FACSIMILE (380) 651-6782
parent's share, the other parent shall reimburse the paying parent within I 0 days
from receiving verification of payment.
2
3
Findings: Extracurricular Activity Expenses: The court favors agreements of the parties.
4
Lauren is currently in sports and ouL~ide school activities. It is incumbent upon the parents to
5
6 communicate about Lauren's best interest, which may include her participation in these
7 sports/events. Both parents should be willing to advance their child's experiences through
g
extraordinary activities, however; it should be done by agreement.
9
3.19 Uninsured Medical Expenses
10
Award: The parties will continue to each pay their proportionate share (70% to
11
12 petitioner/father and 30% to the respondent/mother) of the uninsured medical expenses incurred
13 (Ill behalf of Lauren. Such expenses will include copays, deductibles, orthodontia and all other
14
medical and/or dental expenses. Each parent shall provide/exchange medical information
15
(medical coverage card) to allow the child to obtain medical/dental services. The parents will
16
provide receipts or payment and other verification (EOB' s, etc.) to the other parent. If a paying
17
parent fails to provide verification of payment to the other parent on or before 65 days from the
18
19 service; the request for payment is deemed waived and the paying parent shall not be reimbursed.
20 Should a receipt or verification of payment be presented to the other party within 65 days from
21 service, the other party shall reimburse the paying parent within 15 days from receiving such
22
receipt or verification.
23
Attorney Fees:
24
25 Issue: Whether or not to award attorney fees as requested by the respondent.

Page· 9 HANSEN McCONNELL & PELLEGRINI
PLLC
1636 TlilRD STREET
(380) 658-6580 •FACSIMILE (380) 651-8762
2
SS,000.00. Said fees shall be paid within 30 days from the filing date of this award. Any
3
remaining amount not otherwise paid will accrue at judgment interest unti 1 fully satisfied.
4
5 Findings: 1 make no finding for intransigence. It is well settled that "a trial court may
6 consider whether additional legal fees were caused by one party's intransigence and award
7
attorney fees on that basis." In re Marriage ofGreenlee, 65 Wash.App. 703, 708, 829 P.2d
8
1120. "When intransigence is established, the financial resources of the spouse seeking the
9
award are irrelevant. " In re Marriage of Morrow, 53 Wash.App. 579, 590, 770 P.2d 197
10
lI
( 1989). Intransigence includes foot dragging and obstruction, filing repeated unnecessary
12 motions, or making the trial unduly difficult end costly by one's actions. In re the Marriage of
13 Bobill I 35Wn. App. 8 (2006). The parties in this case have attempted to resolve these difficult
14
matters in good faith. Cleary, there is no indication of intransigence by previous court orders,
15
the report of the guardian or litem, or by the evidence provided to this arbitrator. I reviewed the
16
GAL report, the provided motions of counsel and suggested evidence earlier provided for
17
mediation. When comparing the petitioner's actions, the effect of his actions upon the
18
19
respondent, the expenses of the case v. the dozens of cases 10, which establish the identification
20 and clarification of intransigence, I feel strongly that no intransigence can be found This case
21 initially began as a high conflict and highly complex parenting matter - based upon the assertions
22
of the respondent pertaining to past actions of the petitioner. As a result of the nature of this
23
case, both parties have incurred attorney fees and costs well beyond their financial capabilities.
24
25
0
' See case notes under "Consideration" in Arbitration Award.

PLLC
1836 THIRD STREET
(360) 658-6580 • FACSIMILE (380) 851-0762
It nppcars both parties have·filcd appropriate motions when.nee~. Moreover; I cannot sci:
2
where the petitioner failed to timely cooperate with the request of the GAL and/orden; of this
3
C(1un lno evidence to support). The matter may not have moved as quickly as the respondent
4
wnuld hu,•c liked, but the question goes to "whether or not the aclions oflhe pelilioner resulled
5
in 1he iiecessity of incu"ing additional legal fees". In re Marriage of Wallace 111 Wn. App.
6
7 697. For this I can find no basis for intransigence.
8 Attorney fees based upon RCW 26.09.140 11 , I find the respondent to be in financial need
9 for assistance. The respondent's reported net income, even after receiving child support of
10
$830.90, is still significwllly less than that of the petitioner. The evidence suggests respondent's
II
husband is currently unemployed. Her financial declaration shows monthly expenses of
12
approximately $3,000.00. Second, I considered the ability of the petitioner to pay or assist with
13
the payment of the respondent's fees. I look at his financial resources. In this case I looked
14
15 primarily at his income and expenses. I find the petitioner has a resulting net income of
16 approximately $6,902.64. From this income he is required to pay respondent $830.90 for child
17 support. Additionally, he has personal monthly expenses that exceed $3,600 (including tuition of
18
$579.00)_ Based upon his financial declaration, he is left with monthly net disposable funds of
19
approximately $2,500. His fiilancial declaration does indicate other resources including $35,000
20
on deposit in banks as well as other funds. Third, I reviewed respondent's fee verification.
21
22
11
23 RCW 26.09.140 The coun from time to time after considering the financial resources of both panies may order a
pany to pay a reasonable amount for the cost to tbe other party of maintaining or defending any proceeding under
24 !his chapter and for reasonable attorneys' fees or other professional fees in connection therewith, including sums for
legal services rendered and costs incurred prior to the commencement of the proceeding or enforcement or
25
modification proceedings after entry of judgment.
ARBITRATION AWARD ~!'FICES

Poge- 11 llANSl;N McCONNELL & PELLEGRINI
PLLC
1636 THIRD STREET
(380) 658-6580 •FACSIMILE {380) 651-6762
Quite honestly, without more information regarding the nature of the fees as they pertain to the
2 actual expenses related to the modification matter, the source of the fees and the fees paid to
3
date, I can only assume the fee verification appears to be in line with the nature of this case and
4
the litigation that has taken place since October 2013. Based upon my review of the financial
5
information provided, I find the petitioner with the ability to contribute $5,000.00 toward
6
7
respondent's attorney fees incurred in this matter.
9 ARBITRATION FEES:
10 ·A WARD: The fees for arbitration arc to be paid equally (50/50).
11
12
Submission: I will submit my award to the court within 10 business days. Either party may
13
request reconsideration for mistakes, clerical errors or a clear misrepresentation of the facts.
14
Such reconsideration must be submitted to this arbitrator and all parties within 10 days of receipt
15
of this award. All reconsiderations shall be in the form of a written submission. The arbitrator
16
reserves the right to award attorney fees subject to the reconsideration only.
17
Respectfully Submitted,
18
W~P.P~
19 HANSEN, McCONNELL & PELLEGRINI
1636 Third Street) Marysville, WA 98270
20 • (360) 658-6580JFax: (360) 651~762
wavne@thlrdstreetlaw.comIwww.thirdstreetlaw.com
21
22
23
24
25
ARBITRATION AWARD LAWOPFICES

Page- 12 HANSEN McCONNHLL & Pl!LL~GRINI
PLLC
1638 THIRD STREET
MARYSVll.LE, WASHINGTON 88270
(360) 858-6580 • FACSIMILE (360) 851-6782
WORKSHEET SYNOPSIS
FATHER MOTHER COMBINED
1. Monthly Net Income Tax Year: Manual $6,904.62 $2,990.13 $9,894.75
2. Proportional Share of Income .698 .302
3. Basic Support:
LAUREN $1300.00
4. TOTAL $1.300.00
5. Basic Support Obligation with Income Limitations $907.40 $392.60

6. Obligation for Health Care, Day Care, and Special Exp. $176.82 $76.50 $253.32
7. TOTAL OBLIGATION $1,084.22 $469.10
8. CREDIT for Medical $253.32

9. CREDIT for Day Care and Speclal Exp.
10. CREDIT for Ordinary Expenses
11. TOTAL CREDITS $253.32
12. Father Pays Mother $830.90
Calculated Using Sell Suppa" Reserve: 2014
File Name: ARB)TRA TION - RIFE V MEHADDl.SCP
Page was printed on 1112412014 at 01:01 PM
CASE ALERT
Obligor's Proportional Share of Medlcal Insurance Exceeds

25% of Basic Support Obligation.
SupportCa/c" 2014
[ ] Proposed by [ ] [ ] State of WA [ ] Other (CSWP)
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
Mother JENNIFER Father ANDREW

County SNOHOMISH COUNTY Case No. 05-3-02755-1
Chlldlrenl and Aaelsl: LAUREN. 9

Part I: Income (see Instructions, paqe 6)
-~]lg_es and Salaries -- $9,061.38 uA92.66
b. Interest and Dividend Income - --
c. Business Income
-- -- -
d. Maintenance Received
e.Other Income
-- -
-
--- -
f. Imputed Income
g. Total Gross Monthlv Income !add lines 1a throuah 1fl
-
$9,061.38
-
$3A92.66
a.ln~ome_Taxes {Federal and State) TaxYear,_"!l!'.nual $1.731.71 -
$226.56
b. FICA {Soc.Sec. +Medicare)/Self-Em~loyment Taxes . $267.18
__cl, ~a!ldatory Union/Pr:_ofessional Dues
-
$425.05
-~
$8.79
. --
.
e. Mandato~ension Plan Payments . . .
f. Volunta!Y. Retirement Contributions - - ..
.
. ___g_. Malnt~!:!!!nce Pais!__ -- --·--. .. .
.
__ ~.Nof"l'!1_al Busin.ess Eig>_e_!l_ses . ---- - -
(add lines 2a through 2h) $2.156.76 $502.53
3. Monthly Net Income (line 111 minus 21) $6.904.62 $2,990.13
4 Combined Monthly Net Income $9,894.75
(line 3 amounts combined!
5. Basic Child Support Obligation (Combined amounts--+)
LAUREN $1300.00
. $1,300.00
-
-
-
(each parenrs net income from line 3 divided by line 4) .698 .302
WSCSS-Worl!sheers ·Mandatory (CSW/CSWP) 0712013 Page 1 of 5
Part II: Basic Chlld Sunnort Obligation (see Instructions, oaae 71
7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations tEach parenfs Line 6 times Line 5.l $907.40 $392.60
B. Calculatina low income limitations: Fill in only those that "nnlv.
Sell-Sunnort Reserve: 1125% of the Federal Povertv Guideline.) $1.216.00 I
a. Is combine.d Net Income Less Than $1 000? If yes, for each
_~ent e.11_ter the_presumptive $50 per child. -~---1------·- --------1
b. Is Monthly Net Income Less Than Self-Supoort Reserv.!l1 If yes,
__ _!Qr_\!!_filJ~arent enter the presumpJi.ve 550 per chlld. ___________- -· _____-_
1
c. Is Monthly Net Income egyal to or more than Self-Supoort
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_~esumptive $50 oar child, whichever is areater.
child.
Part Ill: HeaHh Care, Day Care, and Speclal Child Rearing Expenses (see Instructions, page 8)
10. Health Care Ex""nses Father Mother

__ a ..Monthly ti_'¥'1th Insurance _Paid for Child(ren)_ ____ ,__~$c253~~--~~-i-------
.... _...b., Unir1~u.r~.'Y'.fl.!!~.!1'...Health Care Expenses Paid for Child(r!!:l)_f------_______- _
(line 10a plus line 10b) ! 253.32
(line 1Oc amounts combined) $263.32
11. Day Care and Special Exoenses
_a:_ Day Care Expenses _ - -
·-· ..
__ b. Edu.~~-QD Expenses_....,.....,,----;-·-
____ c. Long Distance_Transportati~ Expenses
-- --
-- -
_ d.Oth!!r_§pecial ~p~_nses (describe) ··-----------1--- ··-·
- - -
- -
- -
- -
IAdd lines 11a lhrouah 11 ni
- -
12. Combined Monthly Total Day Care and Special Expenses I
(line 11e amounts Combinedl - -
13. Total Health Care. Day Care, and Special Expenses (line 10d
plus line 12) - $263.32
14. Each Parent's Obligation for Health Care, Day Care, end Special
Expenses (multiply each number on line 6 by line 131 $176.82 $76.50
Part IV: Gross Child Support Obllgatlon
15. Gross Child Suooort Obllciation (line 9 plus line 14) $1.084.22 $469.10
16. Child Sunoort Credits
_ _a. MorithlY. Health_ Care E-~~~ses Credit -·-------·-1---s~2.~!R ___ ,, __:_
b. Dav Care and Soecial Exoenses Credit
WSCSS-Worlrsheets ·Mandatory (CSWICSWP) 0712013 Page 2 of 5
- -
- -
- -
d. Total Suooort Credits (add lines 16a throu11h 16c) $253.32 -
whichever is oreaterl $830.90 $469.10
Part VII: AddlUonal Informational Calculations
line 3 for each parentl $3.107.08 $1.345.56
19. 25% of each parenrs basic support obligation from line 9 (.25 x
Part VIII: Addltional Factors for Consideration (see Instructions. page 9)
_ _(':;isl the e_:;_!i;nated value of all .':':~or ho~~hold assets.) Household Household
a. Real Estate
b. Investments
--
--·- - - - - ---
-
.. -- -
- - c . vehicles-aiiCi-Boats - - - · - -
·---d. BarlkAccounts amfCash
e.Retirement Accounts
- -
-
--
· - - -
- ·-f. oilier: (de~crTbe) ---- -- ---- -
-·-- .- - - . -
.
---- - --- .
-
21. Household Debt
--- a. . -- -----
. -- -- -----
b. -
--
--
-
. -------
-··-----
----
c.
d.
--- -
. -
-
-- ·- - -
-----
- ··----·-------
.
---·- e. ------ ---------· - -- -- --------- -·-
f. - -
(if not the other parent of this ac;!ioaj
Name
Name
-
--
-
.---
--- -
Name
------ - --
Name
-
-·
_ _ .Q.;_!n_col!l~.Of Child(ren) (if considered extraordinaiy)
- ··--·-
------- Name - -
Name
WSCSS-Worlrsheets ·Mandatory (CSWICSWP) 0712013 Page 3 of 5
- -
___e,_ln~rne From q~ild SupP-Qrt
-------· -
L__ ~ame
- - - -
.-
Name
----· -·· -·- -
___Uncome From Assistance PrQ91:ams
Prog_ram ... .
----- ·--
--~r:ggram . -· -
_ _ g._Other lncomE!_(descrlbe)
-
--·---- -- --- -- . -----·-·-
. .
23. Non-Recurrina Income (describe)
- . .
. -
24. Child Support Owed, Monthly, for Biological or Legal Child(ren) Father's Mother's
Household Household
.___ ~~etage~-- Paid 11 Yes I J No -· - .
Nam~ag~:..
- Paid (]_ '.f!!S [] No____
·----.- .
Name/ane: Paid Ti Yes r 1 No .
--
.....___ ___
·--· -
-- ----·-·---
WSCSS-Wo1*sheets ·Mandatory (CSWICSWP) 07/2013 Page 4 of 5

Other Factors For Consideration (continued) (attach additional pages as necessary)
Sianature and Dates

I declare, under penalty of perjury under lhe laws of the State of Washinglon, the informatlon
contained in these Worksheets is complete, true, and correct
Date City Date City

Wortsheet certified by the State of Washington Administrative Office of the Courts.
Photocopying of the wori<sheet 18 permitted.
WSCSS-Worlrsheets - Mandatory (CSW/CSWP) 0712013 Page 5 of 5 SupportCa/ce 2014
f: ..\arbltratlon. rife v metiaddl'arbltration - rife v rnehaddi.scp 11/2412014 10:32 am
2

7 In re:
8 ANDREW RIFE, No. 05-3-02755-1

Petitioner,
ON RECONSIDERATION
10
11 Respondent.
12
13
CONSIDERATION
14
My Reconsideration is based upon the written submissions and evidence presented by
15
counsel received in my office up to and through December 22"d 2014.
16
17 FACTS ERRONEOUSLY ASSUMED
18
In the Arbitration Award previously filed with this court, this arbitrator was under the
19
impression the respondent's husband, Soufyane Mehaddi, was unemployed. Therefore, it was
20
assumed the respondent, through her employment (with occasional gifts from her family) was
21
supporting the "household" including herself, the party's minor daughter, Lauren, and her
22
23 husband. As a result of the additional materials received as part of this reconsideration, it is now
24 clear respondent's husband is employed and contributing to the respondent's household. These
25 facts are critical and legally required to render a just determination.
ARBITRATION AW ARD LAW OFFICES

PU.C
11138 THIRD STREET
MARYSVILJ.E, WASHINGTON 98270
(380) 1158-e5BO •FACSIMILE (380) B~1-ll762
LEGAL MERRITS
2
First, the petitioner and respondent are represented by two seasoned and excellent family
3
law attorneys. Each attorney has vigorously defended their client's legal and equitable positions.
4
s Unfortunately, this arbitrator missed a key fact in this case regarding the employment of the
6 respondent's husband. As a result, my award was skewed. For this J apologize to both counsels
7 and their respective clients.

8
Second, in determining the residential credit requested by the petitioner and the award of
9
attorney fees, it was necessary for me to consider the entirety of the income and expenses of both
10
households. It is apparent "now" the respondent's household income is increased by
11
approximately $1,122 per month (husband's purported net income).
12
13 Third, the legal issues are well established and clearly identified in my prior award. The
14 only difference is the consideration of the additional income to the respondent's household.
IS AWARD
16
17
18 Award: Child Support Transfer Payment:

19
• The petitioner will pay the mother monthly child support in the amount ofS400.00
20
• The father is awarded a deviation based upon RCW 26.19.075(1)(d). The father is
21
deserving of a deviation of child support based upon the significant time he spends with
22
23 Lauren. After further consideration of the husband's income, I find a deviation would not
24 leave the mother in a financial hardship; so as to be unable to meet the basic necessities
25 of the child in her home. The respondent's net income is approximately $2,700.00

Page-2 HANSEN McCONNELL & PELLEGRINI
PU.C
1838 THIRD STREET
(380) 858-6580 •FACSIMILE (380) 851-8792
(without imputing income). Her reported expenses are approximately $3,000. The
2
re~"Pondcnt husband's purported net income is $1,122 per month. The husband's income
3
is not used to determine child support, however; it is used to determine the actual income
4
received in the respondent's household. The net household income, without
5
consideration of the parental gifts, is approximately $3,800. Based upon the respondent's
6
7 own financial declaration, she has sufficient household income to meet her monthly
8 expenses and the financial needs of her minor daughter.
9
Issue: Attorney Fees:
10
11 Issue: Whether or not to reconsider the prior award of attorney fees?
12
13
Sl,500.00 instead of the $5,000 earlier awarded. Said fees shall be paid within 30 days from
14
the filing date of this award. Any remaining amount not otherwise paid will accrue at judgment
15
16 interest until fully satisfied.
17 Findings: My reconsideration of this issue is based upon the respondent husband's purported
18
income. In my prior award I indicated the husband was unemployed. Cleary that was erroneous.
19
His income does require reconsideration of the respondent's household expenses and therefore
20
her "need" for purposes of attorney fees. My earlier findings are still appropriate, however; it is
21
22 clear the respondent's financial needs are less than earlier determined. For that reason, a
23 reduction in the award of attorney fees is appropriate as well.
24
Other:
25
ARBITRATION A WARD [.AW OFFICES

Page- 3 llANSEN McCONNELL & PllLLHGRINI
PLLC
1638 THIRD STREET
(380) fl58.6580 •FACSIMILE (380) 651-87112
•
All other issues and awards, unless specifically revised and set forth above,
2 shall remain as stated io the Arbitration Award of November 4th 2014.
3
4
ARBITRATION FEES:
s
6 A WARD: No fees are assessed for this reconsideration.
7
8 Submission: This reconsideration will be filed with the court within three business days.
9
10 Respectfully Submitted,
11 Wty1118-P. p~
12 HANSEN, MtCONNRL a PELLEGRINI

1636 Third Street I Marysville, WA 98270
13 • (360) 658-65801Fax: (360) 651-6762
wayne@thlrdstreetlaw.comIwww.thlrdstreetlaw.com
14
15
16
17
18
19
20
21
22
23
24
25
ARBITRATION AWARD J,A W OFFICES

rage· 4 HANSEN McCONNELL & PELLEGRINI
PLL.C
1838 THIRD STREET
(:!80) 65s.e580 • FACSIMILE (380) 8~1-11782
.... ~, ! I
70'.5 JAN 12 AM IQ: 35

~I~~ 11111111111111~1111~ ~ 1 1 1
1
2 1lmll111 SOIJY,\ i\RA.SKI


6
In Re the Marriage of: No.OS 3 02755 1
7
Andrew Scott Rife, CALENDAR NOTE (NTC)
8 Petitioner lhlS fonn must be flied with the Oerk not later than twerve
and (12) days preceding the date requested. SO.CR 7(b)(2)(q.
9 Jennifer Rae Mehaddi, f/k/a Rife, Responses to motton must be filed five (5) court days before
Respondent the hearing. Replies ID responses must be filed 111... (3)
10 court days before the hearing.

AND TO: Veronica Freitas, Attorney for Jennifer Rae Mehaddi
12
FAMILY LAW/ DOMESTIC CALENDAR- Date: January 26, 2015 at 9:00 a.m.
13
Court Commissioner Nature of Hearing:
14 Department B or C, As Assigned Motion for Judgment on Arbitration
Award and Presentation of Order of
15 Support
16 posted the day of the hearing. Extended motions are set by the Court Commissioner. not a party or counsel. If a
presentation, or if a particular Court Commissioner has already heard a recent motion on the matter, please indicate
17 Court Commissioner _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
18 WARNING: The moving party MUST CONFIRM by noon two (2) court days prior to the hearing in order for the
19 SCLCR 7(b](2)(E). This form cannot be used for trial setti_ngs. SCL i
matter to be a.rgued. Failure to notify the Court of a continuance or strike may result in sanctions and/or terms.
2.1 40(b).
20 Dated: January 9, 2015 . ·

21 CARL: J. GAUL
Attorney for An
22 Declaration of Service
I, CARL J. GAUL, declare under penalty of perjury of the laws of the State of Washington, that on January 9,
23 2015, I sent by ABC Legal Messengers email a copy of Motion for Judgment on Arbitration Award and Presntation of Order
of Support and a copy of the document to which this declaration is affixed to the following persons, addressed as follows:
24
Veronica Freitas
25 Attorney at Law
26 Seattle WA 98102
Executed at Everett, January 9, 2015
27
28
..-
" , . ,,
r" I
... ,
....
J'
I",.•
2 ?] 15 JAi~ I 3 AH 11: 17
~lCL16963061
l /l l /1 1 ~II IIl ~l /1 /~fIW
3 SON YA f(RASKI
4
1111/l l COUrffY CLERK
SNOHOMISH CO. \'/ASH
5

COUNTY OF SNOHOMISH
-· '· 7
In re:
8 Andrew Scott Rife
9
and
SATISFACTION OF JUDGMENT
Respondent.
11
The judgment against Andrew Scott Rife, entered and docketed herein on
12 Pr., .,.,\- I , 2014, in favor of Veronica Freitas/ Jennifer Mehaddi for the sum of
$2750, in payment of the sum due is hereby acknowledged to be fully paid and satisfied. The
13 clerk is hereby authorized to remove the judgment from the record.
14
15 V~Fre~nifer
,~.,~
Mehaddi
16
17 tate of Washington )
,)ss
18 County of King )
19 On A-VS''-?-+ r f, Wt 'I before me v ""

a Notary Public in and for the State of Washington, personally appeared Veronica Freitas ennifer
20 Mehaddi, known to me to be the person who executed the within Full Satisfaction of Judgment, and
·: acknowledged to me that she executed the same for the purposes therein stated.
21
22
Notary Public residing at:
23
SEAL My commission expires: q; UJ,. Wl (p
24
25
26
27
CARLJ.GAUL
A11or1rey at lmv
1604 Hewin Ave.
Everen WA 98201
425 259-4147 FAX 259 7081
jO"f
'\
.......
.. \,•':,,
_1:i.•IillliI:r~'f~llfl1•Mlil!l1_i....,
.\. . .
. -· . C.
. Mount~m re~t :;. _;.1.~ ~dwily '
. EVERETT BRANCH
'
. . 08/11/2014 0222709·
...
~-.. _. . creif11 ~~i~!·:;~~S~>s~00 '
. 00 00222709
•• -· • c ,,_
: PAY ~TWDTBOUsANDSB\IEN~~FDTrDaLWIBANDOOciiNTs- $2.750.00
1 ·... ·. . .,: ~~<> ~r~ s2,1so,oo CASHIER CHECK
ffi~ER
I 8~ ·
VERONI.. CA FREITAS l,AVt OFFICE
RE: ANDREW RIFE . . ,
. ..
• ,
'.
• . i•
·...
I.. ' ~ .
Il uonn , , , ~-
11•00 2 c 2?o'i11•
·
- - - -
1; :t cs ~ao s i; i;1: s 2000 3 i;? i; ~0011•
-
Tl!n\S!Q••TifAfSejigjDeejfiiiove ,....., )
I
•
-. - .. .
FILED
2015 JAN 20 PH 3: 13
1
SONYA KRASKI
COUNTY CLERK
~\I\ ~1\1~1\1~Ill~\
2 S~IGHOMISH CO. WASH
3
\\11\l\\ II\ \\I\\ \Ill\ 1\11\ \I\\\II\
CL17122348
4

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife N& . 05 3 02755 1
9 Petitioner, - 1ia1 £:Jct D
and ORDER CONFIRMING
10
ARBITRATION AWARD
11 Jennifer Rae Mehaddi flkla Rife
Res ondent.
12
13 This matter came on for hearing on January 23, 2015 on motion of Petitioner
drew Rife, pursuant to RCW 7.04A.220 for an Order confirming the Arbitration
14 ward and Arbitration Award on Reconsideration and entering an order of support
hereon.
15
16
The Court now Confirms the Arbitration Award.
The petition for modification of child support is granted. The Order of Child
17 Support signed by the court on this date or dated , and
he child support worksheet, which has been approved by the court, are incorporated
18 by reference as part of this order.
19
Dated:
20
21
Copy Received:
22
23
VERONICA FREITAS WSBA# 19405
a:: 24 Attorney for Jennifer Mehaddi
en
en 25
3: 26
CARLJ. GAUL
Attorney at Law
CROER CCNF"IRMING
1604 Hewitt Ave.
ARBITRATICN AWARD Everett WA 98201
PAGE 1 CF" 1 425 259-4147 FAX 259 7081
.•
1
l l~l 1~1CL16789823
I 1 1 ~1 1 1 ~ l ~l 1 ~1 1 1 1 1 1 1 1 1 1
lllll
.3
5
6
County of SNOHOMISH
7
8
ANDREW RIFE
9
Petitioner,
and Final Order (ORS)
10
JENNIFER MEHADDI Clerk's Action Required
11 Respondent.
12
I. Judgment Summary
13
1.1 Judgment Summary for Non-Medical Expenses
14
Does not apply.
15
1.2 Judgment Summary for Medical Support
16
17 Does not apply.

II. Basis
18
2.1 Type of Proceeding
19
·This order is entered under a petition for dissolution of marriage or domestic partnership,
20 legal separation, or declaration concerning validity:
21 order for modification of a custody decree or parenting plan.
23 The child support worksheet which has been approved by the court is attached to this
order and is incorporated by reference or has been initialed and filed separately and is
. 24 incorporated by reference .
~ 25 ORDER DF CHILD SUPPORT ITMORS, ORB) • PACJE 1 OF' 1 1

CARLJ. GAUL
WPF' DR C 1 .OSCO MANDATORY 16/20 1 4) • RC:W 26.09.1 75;
ff) 26 26.26.1 32
Attorney at Law
~
Everett WA 98201
425 259 4147
.•
..
1·
3 2.3 Other
4
Ill. Findings and Order
5
It Is Ordered:
6
3.1 Child(ren) for Whom Support is Required
7
8
Lauren Emily Rife 10
9
3.2 Person Paying Support (Obligor)
10
Name (first/last): andrew rife
11
Birth date: 3122173
Service Address:
12
The Obligor Parent Must Immediately File With the Court and the
13
Washington State Child Support Registry, and Update as Necessary, the
14 Confidential lnfonnation Fonn Required by RCW 26.23.050.
15 The Obligor Parent Shall Update the lnfonnatlon Required by Paragraph 3.2
Promptly After any Change in the lnfonnation. The Duty to Update the
16 lnfonnation Continues as long as any Support Debt Remains due Under
This Order.
.17
For purposes of this Order of Child Support, the support obligation is based upon the
18 following income:
19 A. Actual Monthly Net Income: $ 6,905.
20 3.3 Person Receiving Support (Obligee)

21 Name (first/last): jennifer mehaddi
Birth date: 8/18174
22 Service Address:
23
24
25 ORDER CJF" CHILD BUPPCJAT_ rTMORS, OAS) • PAGE 2 CF 1 1 CARLJ. GAUL

WPF DR 0 1 .OSCO MANDATCJRY C6/20 1 4J • ACW 26.09.1 75; Attorney at Law
26 26.26. 1 32 \ . 1604 Hewitt Ave., sune 302
Everett WA 98201
425 259 4147
1
2
3 The Ob/igee Must Immediately File With the Court and the Washington
State Child Support Registry and Update as Necessary the Confident/al
4 /nfonnation Fonn Required by RCW 26.23.050.
5 ·The Ob/igee Shall Update the lnfonnation Required by Paragraph 3.3
Promptly After any Change in the lnfonnation. The Duty to Update the
6
lnfonnation Continues as Long as any Monthly Support Remains Due or
7 any Unpaid Support Debt Remains Due Under This Order.
8 For purposes of this Order of Child Support, the support obligation is based upon the
following income:
9
C. The net income of the obligee is imputed at $2990.13 because:
.10
the obligee is voluntarily underemployed.
11
The amount of imputed income is based on the following information in order of
12 priority. The court has used the first option for which there is information:
13 current rate of pay.
14 The obligor may be able to seek reimbursement for day care or special child rearing
15
3.4 .Service of Process
16
Service of Process on the Obligor at the Address Required by Paragraph
17 3.2 or any Updated Address, or on the Obi/gee at the Address Required by
Paragraph 3.3 or any Updated Address, may Se Allowed or Accepted as
18
Adequate in any Proceeding to Establish, Enforce or Modify a Child
19
Support Order Between the Parties by Delivery of Written Notice to the
Obligor or Ob/igee at the Last Address Provided.
20
3.5 Transfer Payment
21
The obligor parent shall pay the following amounts per month for the following child:
22
Name Amount
23
Lauren Emily Rife $400
24 Total Monthly Transfer Amount $400
25 CADER CF' CHILD SUPPORT fTMCRS, CRS) • PAGE 3 CF' 1 1 CARLJ. GAUL
WPF" DR 0 1 .OSCO MANDATORY (6/2014) " ACW Z6.C9.1 75; Attorney at Law
26 26.26.. 1 32
1604 Hewitt Ave., Su~e 302
Everett WA 98201
425 259 4147
..
..
3 This is a downward modification that has caused an overpayment of $650.00. This

amount shall be repaid or credited as follows:
4
The new child support amount of $400.00 per month is effective from
5 October 1, 2014. The previous child support order required payment of
$562.50 per month, which the obligor paid in October, November and
6 December 2014 and January 2015, resulting in an overpayment of
$650.00. The Division of Child Support shall apply a credit of $65.00 per
7
month for ten months reducing the obligor's actual payment to $335.00 per
8 month. When the overpayment has been fully credited against the
obligor's support obligation the actual transfer payment shall increase to
9 $400.00 per month.
10 The Obllgor Parent's Privileges to Obtain or Maintain a License, Certificate,

Registration, Permit, Approval, or Other Similar Document Issued by a
11 Licensing Entity Evidencing Admission to or Granting Authority to Engage
in a Profession, Occupation, Business, Industry, Recreational Pursuit, or
12 the Operation of a Motor Vehicle may Se Denied or may Be Suspended if
the Obligor Parent is not in Compliance With This Support Order as
13
Provided in Chapter 74.20A Revised Code of Washington.
'14
3.6 Standard Calculation
15
$831 per month. (See Worksheet line 17.)
16
17
The child support amount ordered in paragraph 3.5 deviates from the standard
18 calculation for the following reasons:
19 The child 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
20 funds in the receiving parenrs household to meet the basic needs of the child.
The child does not receive public assistance;
21
The factual basis for these reasons is as follows:
22
See Arbitration Award and Arbitration Award on Reconsideration
23
24
Does not apply. A deviation was ordered.
25 ORDER DF CHILD SUPPORT CTMDRB, DRS) • PAGE 4 DF" 1 1
CARLJ.GAUL
WPF' DR a 1 .osoa MANDATORY C6/2D 1 41 • ACW 26.09.1 75;
Attorney at Law
26 26.26.1 32
Everett WA 98201
425 259 4147
..
2
3
4
Starting Date: October 1, 2014
·5
Day(s) of the month
6 support is due: First
8 Does not apply.
9 3.11 Making Support Payments

10 Select Enforcement and Collection, Payment Services Only, or Direct Payment:
11 Enforcement and collection: The Division of Child Support (DCS) provides support
-enforcement services for this case because: a parent has signed the application for
12 services from DCS on the last page of this support order. Support payments shall be
made to:
13
Washington State Support Registry
14 P.O. Box 45868
Olympia, WA 98504
15 Phone: 1-800-922-4306
or 1-800-442-5437
16
A party required to make payments to the Washington State Support Registry will not
17 receive credit for a payment made to any other party or entity. The obliger parent shall
keep the registry informed whether he or she has access to health insurance coverage
18 at reasonable cost and. if so, to provide the health insurance policy information.
19 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
20 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
21 support, is being spent to benefit the child.
22 3.12 -Wage Withholding Action
23
24 enforced against real and personal property under the child support statutes of this or
any other state, without further notice to the obliger parent at any time after entry of this
order unless an altemative provision is made below:
25 CADER DF CHILD SUPPORT rTMORS, CAB) • PADE 5
WPF' DR a 1 .osoo MANDATcAv 1&120 1 4>
DF" 1 1
Rew 2&.09.1 75;
CARLJ.GAUL
26
a
Attorney et Law
26.26.1 32
Everett WA 98201
425 259 4147
1
3
(If the court orders immediate wage withholding in a case where Division of Child
4 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
5 Support Registry.)
6 3.13 Tennination of Support
7 Support shall be paid:
8 until the child reaches the age of 18, or as long as the child remain(s) enrolled in high
school, whichever occurs last, except as otherwise provided below in Paragraph 3.14.
9
3.14 Post Secondary Educational Support
10
The right to request post secondary support is reserved, provided that the right is
11 exercised before support tenninates as set forth in paragraph 3.13.
12 3.15 Payment for Expenses not Included In the Transfer Payment
13 Does not apply because all payments, except medical, are included in the transfer
payment.
14
3.16 Periodic Adjustment
15
Does not apply.
16
17
3.17 Income Tax Exemptions
Tax exemptions for the children shall be allocated as follows:

18 To the mother in even numbered tax years and the father in odd numbered tax years.
The mother shall file as Head of Household every year.
19
.20 3.1 B Medical Support - Health Insurance

Each parent shall provide health insurance coverage for the child listed in paragraph 3.1,
21
as follows:
3.18.1 Health Insurance (either check box A(1) or check box A(2) and complete ·
22
sections B and C. Section D applies In all cases.)
23 Evidence
A.
24
25 ORDER DF' CHILD SUPPORT CTMCRS, ORS) • PADE 6 DF' 1 1 CARLJ.GAUL

WPF' DR 0 1 .0500 MANDATORY (6/20 1 4) • ACW 26.09.1 75; Attorney at Law
26 26.26. 1 :32' 1604 Hewilt Ave., Suite 302
Everett WA 98201
425 259 4147
.'
2
3 (2) There is sufficient evidence for the court to detennine which parent must
provide coverage and which parent must contribute a sum certain. Fill in
4 B and C below.
5 B. Findings about insurance:
6
Andrew Rife Jennifer Mehaddi Check at least one of the followlng findings
7 IParenfs Namel IParenfs Namel for each narenl
Insurance coverage for the child is available and
8 [X] 0
accessible to this parent at $253.32 cost (child's
nnrtion of the oremium. onlvl.
9 Insurance coverage for the child is available and
CI accessible to this parent at $ cost (child's
10 oortion of the oremium, onlvl.
.. Insurance coverage for the child is available but
11 II not accessible to this parent at $ cost (child's
oortion of the oremium, onlvl.
12 Insurance coverage for the child is available but
CI not accessible to this parent at $ cost (child's
.13 nnrtion of the oremium, onlvl .
. Neither parent has available or accessible
14 CI insurance through an employer or union; but this
parent is able to provide private coverage at a cost
15 not to exceed 25% of this parent's basic support
obliaation.
16 Neither parent has available or accessible
II insurance through an employer or union; but this
17 parent is able to provide private coverage at a cost
not to exceed 25% of this parent's basic support
18 obliaation.
(Check only one parent) Both parties have
19 II CI available and accessible coverage for the child.
The court finds that this parent has better coverage
20 considering the needs of the child, the cost and
extent of each parenfs coverage, and the
21 accessibilitv of the coveraae.
Other:
22 [I CI
23 C. Parties' obligations:
24 The court makes the following orders:
25 CADER CF' CHIL.D SUPPORT ITMDRS, DAS)• PADE 7 DF" 1 1

CARLJ. GAUL
WPF' DR C 1 .OSCO MANDATORY (6/20 1 4) • ACW 26.09.1 75;
26 Attomeya tLaw
26.26.1 32
Everett WA 98201
425 259 4147
1
2
3 Check at least one of the following options for
Andrew Rife Jennifer Mehaddi
each parent
4 (Parent's Name) (Parent's Name)
This parent shall provide health insurance
5 II II coverage for the child that is available through
employment or is union-related as long as the
•6 cost of such coverage does not exceed 25% of
this parent's basic suooort obligation.
7 This parent shall provide health insurance
[X] II coverage for the child that is available through
8 employment or is union-related even though
the cost of such coverage exceeds 25% of this
9 parenrs basic support obligation. It is in the best
interests of the child to provide such coverage
10 despite the cost because:

.II II coverage for the child as long as the cost of such
12 coverage does not exceed 25% of this parent's
basic sunnort oblioation.
II II coverage for the child even though the cost of
14 such coverage exceeds 25% of this parenrs basic
support obligation. It is in the best interests of the
15 child(ren) to provide such covera!le despite the
cost because:
16
This parent shall pay $ towards the health
17 II II insurance premium being paid by the other
parent. This amount is this parenrs proportionate
18 share of the premium or 25% of this parenrs basic
support obligation, whichever is less. This
19 payment is only required if this parent is not
providing insurance as described above.
20 This parenrs contribution to the health insurance
21 II II premium is calculated in the Worksheet and
included in the transfer payment.
22 This parent shall be excused from the
II Ix I responsibility to provide health .insurance
23 coverage and from the responsibility to provide
monthly payment towards the premium because:
24
25 CADER DF CHILD SUPPORT (TMDRS, CAB) - PADE S CIF 1 l CARLJ. GAUL

WPF OR D 1 .OSDD MANDATDAY 16/ZD 1 4) • ACW 26.09.1 7SJ
Attorney at Law
26 26.26.1 32
1604 Hewitt Ave .. Suite 302
Everett WA 98201
425 259 4147
..
3 I (Only one parent may be excused.)

4 D. Both parties' obligation:
5 If the childare receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parent's monthly premium.
6
The parent(s) shall maintain health insurance coverage, if available for the child
7 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
8 privileges exist to continue coverage following termination of employment.
9 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
10 payment from an insurer.
A parent who is required under this order to provide health insurance coverage
11 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
12 Registry if the parent has been notified or ordered to make payments to the
Washington State Support Registry.
13
If proof that health insurance coverage is available or not available is not
14 provided within 20 days, the parent seeking enforcement or the Department of
Social and Health Services may seek direct enforcement of the coverage through
15 the other parent's·employer or union without further notice to the other parent as
provided under Chapter 26.18 RCW.
16
You may have separate obligations to provide health insurance coverage for the
17 child(ren) under federal law.
18 3.18.2 Change of Circumstances and Enforcement
19 A parent required to provide health insurance coverage must notify both the Division of
Child Support and the other parent when coverage terminates.
20
If the parents' circumstances change, or if the court has not specified how medical
21 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
22 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:
23
Providing or maintaining health insurance coverage through the parent's employment
24 or union at a cost not to exceed 25% of that parent's basic support obligation;
25 ORDER CF" CHILD SUPPORT (TMDRS, DRS) • PAGE 9 DF" 1 1

CARLJ. GAUL
WPF DA D 1 .OSCO MANDATORY (6/20 1 4) • RCW 26.09.1 75;
26 Attorney at Law
26.26.132
Everett WA 98201
425 259 4147
1
3 Contributing the parent's proportionate share of a monthly premium being paid by the
other parent for health insurance coverage for the child(ren) listed in paragraph
4 3.1 of this order, not to exceed 25% of the obligated parent's basic support
obligation; or
5 Contributing the parent's proportionate share of a monthly premium paid by the state
if the child(ren) receives state-financed medical coverage through DSHS under
6 RCW 74.09 for which there is an assignment.
7 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
8 for contempt (use form WPF DRPSCU 05.0100, Motion/Declaration for an Order to
Show Cause re Contempt); or file a petition.
9
3.19 .Uninsured Medical Expenses
10
Both parents have an obligation to pay their share of uninsured medical
11 expenses.
12 The petitioner shall pay 69.8% of uninsured medical expenses (unless stated
otherwise, the petitioner's proportional share of income from the Worksheet, line
13 6) and the respondent shall pay 30.2% of uninsured medical expenses (unless
stated otherwise, the respondent's proportional share of income from the
14 Worksheet, line 6).

17 3.21 Past Due Unpaid Medical Support

18 No past due unpaid medical support is owed at this time.
19 3.22 Other Unpaid Obligations
20 .Other obligations that may be owed are not affected by this order.
21 3.23 Other
22
23
Dated: -----.J~Arlll-N....i:2~0i-.2w0.i;J15--
24
Presented by:
25 ORDER CF' CHILD SUPPORT CTMCRS, ORS)· PAGE 1 D CF' 1 1
CARLJ. GAUL
WPF" DR C 1 .DSDD MANDATORY (6/20 1 41 • RCW 26.09.1 75;
26 26.26. 1 32
Attorney et Law
Everett WA 98201
425 259 4147
..
2
3 Notice of presentation waived:
8 I apply for full support enforcement services from the DSHS' Division of Child Support (DCS).3
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if
9 over $500 is disbursed on a case, unless the fee is waived by DCS.)
10
.-
11
12
13
14
15
16
17
18
·19
20
21
22
23
24
25 ORDER OF" CHILD SUPPORT CTMDAS, CAB) • PAGE 1 1 DF'" 1 1 CARLJ. GAUL
WPF' DR 0 1 .OSCO MANDATORY (6/2014) • RCW 26.09.1 75;
26 Attorney at Law
26.26.132
Everett WA 98201
425 259 4147
..
. . Mother: jennifer mehaddi Father: an drew rife
County: SNOHOMISH Superior Court Cause Number. 05 3 02755 1
RESIDENTIAL SCHEDULE CREDIT USING FORMULA

Lauren
16. NAMES OF CHILDREN
17. BASIC SUPPORT
(From Table)
$1,300.00 - - - -
18. ORDINARY-EXPENSES - - - - -
19. ADJUSTED BASIC SUPPORT $1,300.00 - - - -

20. OVERNIGHTS WITH MOTHER 191
21. % OVERNIGHTS WITH MOTHER 52.3 - - - -
22. OVERNIGHTS WITHtATHER 174
23. %OVERNIGHTS-FATHER
47.7 - - - -
24. MOTHER'S CREDIT PROP .550 - - - -
25. FATHER'S CREDIT PROP .450 - - - -
26. MOTHER'S CREDIT
$715.00 - - - -
27. FATHER'S.CREDIT
$585.00 - - - -
28. OVERNIGHT THRESHOLD SELECTED: 91 NIGHTS
29. TRANSFER PAYMENT BEFORE CREDIT: $830.90

30. RESIDENTIAL CREDIT TO Father IS: $585.00
31. TRANSFER PAYMENT AFTER CREDIT: $245.90
Client c:\pl'Ogram files (x86)\legalptus\rlfe andrew\rlte arl:lraw{SJ.ecp 01I07l2015 05:5S pm

SupportCalc"2011 (Rov.10/20091
~•'""'"~"' ,, :,111 r\' _.,(,rlltl'!..~ ;:;.,r· ...1.·G1cup 1,,~
•

[ ) Proposed by [ ] [ ] State of WA [ ) Other (CSWP)
Or, J ) Signed by the Judicial/Reviewing Officer. (CSW)
Chlld Support Order Summary Report

A. The order [ ) does ( ) does not replace a prior court or administrative order.
.
-------- ·------ -----·
- to be paid by [ ] mother [ ] !Sther.
-D.-The
- Court ---
- - deviated (changed) from the Standard Calculation for the following reasons:
[ I Does not apply
[ ) Nonrecurring income [ ) Sources of income and tax planning
[ ] Split custody [ ) Residential schedule (including shared custody)
( TChild(ren) from other relationships for whom the parent owes support
[ ) High debt not voluntarily incurred and high expenses for the child(ren)
-E. Income for the Father is [ ) imputed [ ] actual income.

Income for the Mother is [ ) imputed [ ) actual income.
--·-·
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the
worksheets in Part Ill.
WSCSS-Worlrsheets • Mandatory (CSW/CSWP) 6/2010 Page 1 of 5
•
Wortlsheets
Chlld!renl and Aanfsl: Lauren Emllv Rife, 10
Part I: Income !see Instructions. oaoe 61
1. Gross Monthlv Income Father Mother
a. Wages and Salaries (Imputed for Mother) $9.081.38 .
b. Interest and Dividend Income . .
.- -- c . Business Income . .
- d. Maintenance Received . .
e. Other Income . .
f. lmouted Income . $3.492.88
g.Total Gross Monthlv Income ladd lines 1a throuah 1fl $9,081.38 $3,492.88
a. Income Taxes (Federal and StateI Tax Year: Manual $1.731.71 $228.56
b. FICA (Soc. Sec. +Medicarel/Self-Emplovment Taxes . $287.18
c. State Industrial Insurance Deductions . $8.79
d. Mandatorv Union/Professional Dues . .
e. Mandatorv Pension Plan Pavments $425.05 .
f. Volunta~ Retirement Contributions . .
_g.Maintenance Paid . .
h. Normal Business Exoenses . .
. (add lines 2a through 2h) $2,156.78 $502.53
3. Monthlv Net Income Oine 111 minus 2il $8904.82 $2.990.13
Cline 3 amounts combinRdl
5. Basic Child Support Obligation (Combined amounts-+)
. $1,300.00
.
.
.
(each parenfs net income from line 3 divided by line 4) .898 .302
Part II: Basic Chlld Sun""rt Obllaatlon Isee Instructions """e 7)
7. Each Parenrs Basic Child Support Obligation without consideration
of low income limitations !Each oarenfs Line 6 times Line 5.) $907.40 $392.80
8. Calculatina low income limitations: Fill in onlv those that anniv.
Self-Sunnnrt Reserve: 1125% of the Federal Povenv Guideline. I I $1.134.00 I
a. Ii. ~mt!ioed tlet lo!<!!me L.i::;:; Ibao U QQQ? tr yes, for each
oarent enter the oresummive $50 ...,r c hlld. . .
b. I!! MQO!bb'. tlet lo~ml! 61!55 Itlao Self-SUJlllQ!l Bl!lil!!lll!:Z "yes,
for that oarent enter the oresumotive $50 ner child. . .
c. lli Moal!ll~ tl11t la1:2me Grl!S!l!lr Illi!D S11!!-§u111l!!ct Bl!!i!l!lle:Z tr
If that amount is less than line 7, then enter that amaunt or the
oresumntive $50 ""r child, whichever is areater. . .
9. Each parenfs basic child support obligation after calculating
child.
WSCSS-Worlrsheets • Mandatory (CSWICSWP) 612010 Page 2 of S
·•
•
'
Part Ill: Health Care, Day Care, and Spacial Child Rearing Expanses (see Instructions, page 8)
10. Health Care Ex~nses Father Mother
a. Monthly Health Insurance Paid for Childlrenl $263.32 .
b. Uninsured Monthlv Health Care Ex1>enses Paid for Childlrenl . .
· /line 10a olus line 10bl $253.32 .
I line 1Oc amounts combined I $253.32
11. Dav Care and SN>cial Exoenses
a. Da~ Care Exn..nses . .
b. Education Exoenses . .
c. Lono Distance Transnnrtation Exoenses . .
d.Other S""cial Exoenses ldescribel
. .
. .
-- . .
e. Total Day Care and Special Expenses . .
1Add lines 11 a throunh 11 dl
•line 11e amounts Combined\ .
13. Total Health Care, Day Care. and Special Expenses (line 10d
plus line 12) $253.32
14. Each Parenrs Obligation for Health Care, Day Care, and Special
Ex~nses tmultinh; each number on line 6 bv line 131 $176.82 $76.50
Part IV: Gross Child Support ObllgaUon
15. Gross Child Sunnnrt Oblioalion lline 9 olus line 141 I $1.084.22 $469.10
Part V: Child Support Credit& (see Instructions. page 9)
16. Child Su""Drt Credits
a. MonlhiV Health Care Ex .....nses Cred~ $253.32 .
b. Dav Care and SoeciaO=vnenses Cred~ . .
. .
. .
. .
d. Total Sunnnrt Credils ladd lines 16a throuoh 16cl $253.32 .
Part VI: Standard CalculaUon/PresumpUve Transfer Payment (see Instructions, page 9)
whichever is oreaterl $830.90 $469.10
Part VII: AddlUonal lnformaUonal CalculaUons
18. 45% of each parenrs net income from line 3 (.45 x amount from
line 3 for each Mrentl $3.107.08 $1.346.66
19. 25% of each parenrs basic support obligation from line 9 (.25 x
amount from line 9 for each n::irenll $226.85 $98.15
WSCSS-Worlfsheets • Mandlltoty (CSWICSWP) 6/2010 Page 3 of S
..
• •' •

a. Real Estate - -
--
b. Investments -
c. Vehicles and Boats -
d. Bank Accounts and Cash - --
e. Retirement Accounts -
f. Other: (describe l
-- --
-
-- --
21 Household Debi
a.
b.
-- --
c.
d.
-- --
e. - -
f.
- -
(if not the other oarenl of this action l
Name Soutvane
Name
-- $1.122.00
-
b. Income Of Other Adults in Household
-- -
Name
Name
-
is asking the court to exclude per Instructions, page 1O - -
d. Income or Child{ren) (if considered extraordina!}'l
--
Name -
Name -
e. Income From Child Sunaort
Name -- -
Name -
f. Income From Assistance Proarams
P~ram - -
Pr:Qgram - -
a.Other Income (describe)
-- -
23. Non-Recurrina Income (describe!
-
-
-
--
WSCSS-Worlrsheets - Mandatory (CSW!CSWP) 612010 Page 4 of 5
·~
.·
24. Child Support Owed, Monthly, for Biological or Legal Child(ren) Fathers Mothers
Household Household
Name/age:
Name/age:
Paid
Paid
Yes
Yes
No
No
' -
-
--
Name/a11e: ' Paid
Yes No - -

Child Support ordered deviates from the standard calculation pursuant to RCW 26.19.075(1)(d),
based upon significant time the child spends with the obligated parent, based upon the Arbitration
Award and the Arbitration Award on Reconsideration. Though the "formula" deviation would result In
a transfer payment of $245.90, the Arbitrator exercised discretion to determine that the transfer
payment should be $400 per month.
Sianature and Dates

Mothers Signature Fathers Signature
Date· City Date City
~.A:. P1Ax1 1'7.MM-'"'- JAN 2 0 2015

Judicial/Reviewing Offic~ j Date
Worksheet certified by the State of Washington Admlnletrative Office of the Courts.

Photocopying of the worksheet Is permitted.
WSCSS-Worlrsheets - Mandatory (CSW/CSWP) 612010 Page 5 of 5 SupportCalc" 2011
c: ..\slate templatea\waworkaheeldtf c:'iprogram rues (x88)\legalplus11ife andrew\l'lfe andrew(S}.acp 01/09J2015 09:54 em
1 1 1 1 1 1CL16798076
~1 1 1 1 1~1 1 1 1 1 1 1 ~m1111111~1111
2015 FEB 12 PH 3: 40
1
2
SON.YA KilASKI
COUNTY CLERK
SllOHOHISH CO. WASH
3

COUNTY OF SNOHOMISH
7
s In re:
Andrew Scott Rife
9 Petitioner, NO. os 3 02755 1
and
10 Receipt for Payment
Jennifer Rae Mehaddi, f/k/a Rife
11 Respondent.
12
13 Veronica Freitas hereby acknowledges receipt of $2500.00 from Andrew Rife in full
14 satisfaction of the amount awarded by Arbitrator Wayne Pellegrini in the Arbitration Award
15 on Reconsideration in this matter issued on December 23, 2014.
16
17
18
19
4w
VERONICA FREITAS
. 20
21
22
23
24
25
26
CARLl.GAUL
Attorney at Law
?}J( \
RECEIPT FOR PAYMENT
PAGE 1 Of"' 1
ORIGINAL . 1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
FILED
\\\\~~IU\ICL16444758
I~II\~U~I\I~~\\I\\\~\\ 20130CT-3 PH
SIN.YA KRASKI
~: 00
. ett!Hl.Y !KERK .
SNOHfl'ilSH'co. WASH
CASE TYPES 3 - 6
0 '5 - 3 0 2 7 5 s- I
A
__S_N_O_H_O_M_I_S_H_ _ _ _ COUNTY SUPERIOR COURT

CASE INFORMATION COVER SHEET
case Title Marriage of Andrew Rife and Jennifer Mehaddi f/k/a/ Rife
Attorney Name CARL J. GAUL Bar Membership Number _8=3_,_4_,_1____
Please check one category that best describes this case for Indexing purposes. Accurate case Indexing not
only saves lime in docketing new cases, but helps in forecasting needed judicial resources. Cause of action
definitions are listed on the back of this form. Thank you for your cooperation.
DOMESTIC RELATIONS ADOPTION/PATERNITY

__ Adoption (ADP 5)
__ AnnullmenVlnvalidity (INV 3)
__ Confidential Intermediary (MSC 5)
__ Child Custody (CUS3)
__ Initial Pre-Placement Report (PPR 5)
__ Dissolution with Children (DIC 3)
__ Modification (MOD 5)
__ Dissolution with no Children (DIN 3)
__ Paternity/URESNUIFSA (PUR 5)
__ Foreign Judgment (FJU 3)
__ Relinquishment (REL 5)
__ Legal Separation (SEP 3)
__ (Title 26) Termination of Parent-Child Relationship
__ Mandatory Wage Assignment (MWA 3)
(TER 5)
_xxx_ Modification (MOD 3)
PROBATE/GUARDIANSHIP
__ Modification: Support Only (MOS 3)
__ Absentee (ABS 4)
__ Out-of-State Custody (OSC3)
__ Disclaimer (DSC4)
__ Reciprocal, Respondent in County (RIC 3)
__ Estate (EST4)
__ Reciprocal, Respondent Out of County (ROC 3)
__ Foreign Will (FNW 4)
DOMESTIC VIOLENCEIANTIHARASSMENT
__ Guardianship/Estate (G/E 4)
__ Confidential Name Change (CHN 5)
__ Limited Guardianship (LGD 4)
MENTAL ILLNESS
__ Minor Settlement (With guardianship) (MST 4)
__ Alcoholic/Drug Treatment (ALT 6)
__ Non-Probate Notice to Creditors (NNC 4)
__ Mental Illness-Adult (Ml 6)
__ Will Only (WLL 4)
__ Mental lllness_Juvenile (MIJ 6)
If you cannot determine the appropriate category, please describe the cause of action below.
FILED
~
Snohoni.sh County Supolr· em.rt

I FILED Sonya Kraski
County Clem
1~~~1~1~11111m1~
CL16444756
2813 OCT -3 PH If: 00
Everett UA
05-3-02755-1
2 SINYA KRASKI
&IUN~Y GLERK Rcpt. Date Acct. Date T~
SNOHIM SH CCI. WASH 10/03/2013 10/04/2013 04:05 Pt!
3
Rece.ipt/Itei ti Tran-Code !locket-Cotle
4 2013-01-25020/01 1104 tFFR
Cashier: EJ<li
5
SUPERIOR COURT OF Paid By: CA.'ll GAUL, ATIORID AT l.A'.l
6 COUNTY OF SNOHOMIS Transact.ion IL"IJUl'lt: e56.lllJ
1 In re:
NO. 05 3 02755 1
8 Andrew Scott Rife
Petitioner, SUMMONS
9 and (MODIFICATION/ADJUSTMENT OF
I CUSTODY DECREE/PARENTING
PLAN/ RESIDENTIAL SCHEDULE)
I Res ndent SM
11 TO: Jennifer Rae Meha di
12 1. An action has ~n started In the above court requesting that a ~
decree/parentinp plan/residential schedule be modified/adjusted. Additional requests, if
13 any, are stated in the petition, a copy of which Is attached to this notice.
14
2. L
You must respond this notice and petition by serving a copy of your written response
on the person signl;;'g this summons and by filing the original with the derk of the court.
If you do not serve your written response within 20 days (or 60 days If you are served
15 outside of the sta~ of Washington) after the date this summons was served on you,
exdusive of the da of service, the court may enter an order of default against you, and
16 the court may, wi out further notice to you, enter an order regarding adequate cause
and a deaee to rjlodify/adjust the custody deaee/parenting plan/residential schedule
17 and providing forl other relief requested in the petition. If you serve a notice of
appearance on th~ undersigned person, you are entitled to notice before an order of
18 default or a d~may be entered.
3. The court shall d ny the petition unless it finds that adequate cause for hearing the
19 petition Is establis ed, In which case it shall set a date for hearing on an order to show
cause why the reqpested order or modification should not be granfed.
20
Temporaryjresidential placement or custody Is being sought. If adequate cause is
21 found, the, court may proceed immediately to hear the motion for temporary
placement/lstody or may continue the matter to a later time.
22 4. You may file an opposing dedaration to show that there is not adequate cause to hold a
full hearing. If y~'
u do not file an opposing dedaration or respond and the court finds
23 that adequate ca exists, the court may enter an adequate cause order and an order
modifying/adjusti the custody decree/parenting plan/residential schedule without
24 notice to you purspant to RCW 26.09.270.
25 5. Your written respqnse to the summons and petition must be on form WPF DR 07.0200,
Response to Petition for Modification/Adjustment of Custody Decree/Parenting
26 Plan/Residential redule. This form may be obtained by contacting the derk of the
CARLJ.GAUL
Anomeyatlaw
SUMMONS MODI. PARENTING PLAN (SM) - Page I E~~Hw';.'.~8\oei
WPF DR 07.0120 t I
001) - CR 4.1; RCW 26.09.270; 26.10.020 425 259-4147 FAX 259 7081
'
•
•
oourt at the addres5 below, by oontacting the Office of the Administrator for the Courts
at (360) 705-5328, pr from the Internet at the Washington State Courts homepage:
2
http://wvkl.courts.wa.gov/forms
3 6. If this action hasn~been filed with the court, you may demand that the petitioner file
this action with th oourt. If you do so, the demand must be in writing and must be
4 served upon the p n signln!j 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
s motion will be void.'
I
7. If you wish to seek the advice of an attorney in this matter, you should do so promptly
6 so that your writte ' response, if any, may be served on time.
7 8. One method of se Ing a oopy of your response on the petitioner Is to send it by certified
mail with return ipt requested.
8 This summons is issued p rsuant to Superior Court Ovil Rule f Washington.
9

CARLJ. 1
11 Attorney for Andrew Rife
FILE ORIGINAL OF YOUJ RESPONSE WITH SERVE A COPY OF Y UR RESPONSE ON:
12 THE CLERK OF THE COf
TAT:
CARLJ.GAUL
13 Snohomish County Cou ouse AttDmey at Lilw
3000 Rockefeller 302 Bank of America Building
14 Everett WA 98201 1604 Hewitt Ave.
Everett WA 98201
IS
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
Attorner at Law
27 302 Banlc of Amenca Bldg.
I
SUMMONS MOD/AW PARENTING PLAN {SM) - Page 2 1604 Hewitt Ave.

Everett WA 98201
WPF DR 07.0120 (91,001) - CR 4.1; RCW 26.09.270; 26.10.020 425 259-4147 FAX 259 7081
2
5
7
In re:
8 Andrew Scott Rife
NO. 05 3 02755 1
9 Petitioner,
and PETITION FOR
10 MODIFICATION/ADJUSTMENT OF
Jennifer Rae Rife CUSTODY DECREE/PARENTING
11 Respondent. PLAN/RESIDENTIAL SCHEDULE
PTMD)
12
1.1 IDENTIFICATION OF MOVING PARTY.
13
Name (first/last) Andrew Scott Rife
14
Birth Date
15
Last known residence Snohomish County WA
16
1.2 IDENTIFICATION OF NON-MOVING PARTY.
17
Name (first/last) Jennifer Rae Mehaddi, f/k/a Rife

18
Birth Date
19
Last known residence Snohomish County WA
20
1.3 DEPENDENT CHILDREN.
21
22 Child's Name Child's Age

Lauren Emily Rife 9
23
24 II. BASIS
25 2.1 PETITION FOR AN ORDER MODIFYING CUSTODY DECREE/PARENTING

PLAN/RESIDENTIAL SCHEDULE.
26 CARLJ.GAUL
27 ORIGINAL Alforney at lal'r'
1604 Hcwin Ave.
PET FOR MOD/ADJ PARENTING PLN (PTMD) - Page I Everell WA 9820 l
WPF DR 07.0100 (912001) - CR 4.1: RCW 26.09.181: .260; .270 425 259-4147 FAX 259 7081
This is a petition for an order modifying the prior custody decree/parenting plan/residential
schedule in this matter and approving the proposed parenting plan/residential schedule,
2 which is filed with this petition.
3 2.2 ADEQUATE CAUSE.
4
There is adequate cause for hearing the petition for modification.
2.3 CHILD SUPPORT.
5
An order establishing child support in conjunction with the proposed parenting plan should
6 be entered. A child support worksheet and financial declaration have been filed with this
action. (No separate petition for modification of child support needs to be filed.)
7
2.4 JURISDICTION AND VENUE.
8
The court has proper jurisdiction and venue.
9
The moving party resides in Snohomish County WA.
10
The children reside in Snohomish County WA.
11 The other party resides in Snohomish County WA.
12 2.5 JURISDICTION OVER PROCEEDING.
13 This court has jurisdiction over this proceeding for the reasons below.
14 This court has exclusive continuing jurisdiction. The court has previously made a child
custody, parenting plan, residential schedule or visitation determination in this
15 matter and retains jurisdiction under RCW 26.27.211.
16 This state is the home state of the children because
17
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.
18 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
19 presence; and substantial evidence is available in this state concerning the
children's care, protection, training and personal relationships and:
20
The children have no home state elsewhere.
21
22
2.6 UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT INFORMATION.
23
Name of Child Mother's Name Father's Name
24
Lauren Emily Rife Jennifer Rae Mehaddi f/k/a Rife Andrew Scott Rife
25
26
CARLJ.GAUL
Allorney al Law
27 302 Bank of America Dldg.
1604 Hewin Ave.
PET FOR MOD/ADJ PARENTING PLN (PTMD) - Page 2 Everett WA 9820 I
WPF DR 07.0100 (912001) - CR 4.1; RCW 26.09.181; .260: .270 425 259-4147 FAA 259 7081
in no place other than the state of Washington and with no person other than the moving
party or the other party.
Claims to custody or visitation.
The moving 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.
Involvement in any other proceeding concerning the children:
The moving 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):
05-2-01268-2: Jennifer Rife vs. Andrew Rife: Dismissed Without Prejudice by Judge
Wynne,Octoberl0,2006
07-2-00022-2: Jennifer LeSourd vs. Andrew Rife: Dismissed With Prejudice by
Commissioner Stewart, January 16, 2007
Other legal proceedings concerning the children.
The moving party does not know of, any other legal proceedings concerning the
chffdren.
CUSTODY DECREE OR PARENTING PLAN/RESIDENTIAL SCHEDULE.
The Custody Decree/Parenting Plan/Residential Schedule was entered on March 25, 2011
at Snohomish County WA. 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.
MODIFICATION PURSUANT TO RCW 26.09.260(1), (2).
The custody decree/parenting plan/residential schedule should be modified because a
substantial change of circumstances has occurred in the circumstances of the
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 children have been integrated into my family with the consent of the other
parent in substantial deviation from the decree/parenting plan/residential
schedule.
The children's environment under the custody decree/parenting plan/residential
schedule is detrimental to the children's 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.
ADJUSTMENTS TO RESIDENTIAL PROVISIONS PURSUANT TO RCW 26.09.260(5),(8).
Does not apply.
CARLJ.GAUL
A llorney at lmv
1604 Hewitt Ave.
PET FOR MOD/ADJ PARENTING PLN (PTMD) - Page 3 Evereu W /\ 9820 I
WPF DR 07.0100 (912001) - CR 4.1: RCW 26.09.181; .260; .270 425 259-4147 FAX 259 7081
2.10 ADJUSTMENTS TO NONRESIDENTIAL PROVISIONS PURSUANT TO RON 26.09.260(10).
2 The following nonresidential provisions of the parenting plan should be adjusted because
there is a substantial change of circumstances of either parent or of the child and
3 the adjustment is in the best interest of the child:
4
Dispute resolution.
Decision making.
Transportation arrangements.
5 Other:
6 2.11 SUBSTANTIAL CHANGE IN CIRCUMSTANCE.
7 The requested modification or adjustment of the custody decree/parenting plan/residential
schedule is based upon the following substantial change in circumstance:
8
9 See narrative declaration of Andrew Rife submitted herewith.
10
2.12 OTHER.
11
12
13 III. REUEF REQUESTED

14 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/parentin9 plan/residential
15 schedule in this matter and approving the proposed parenting plan/residential schedule,
which is filed with this petition.
16
The moving party also requests that the court:
17
Enter an order establishing child support in conjunction with the proposed parenting
plan/residential schedule. The child support worksheet and financial
18 declaration are filed with this petition.
{l
19 Other:
20
21
Dated: 10(-z,( IJ>
(
22
23 I declare under penalty of perjury under the laws of the sta of Washington that the foregoing is
true and correct.
24 Signed at Evereett WA
on
25
26
CARLJ.GAUL
Auorney at I.aw
1604 Hewiu Ave.
PET FOR MOD/ADJ PARENTING PLN (PTMD) - Page 4 Everen WA 9820 I
WPF DR 07.0100 (912001) - CR 4.1; RCW 26.09.181: .260: .270 425 259-4147 FAX 259 7081
2 JOIN DER.
3 The nonmoving party joins in the petition. By joining in the petition, the nonmoving
party agrees to the enby of a decree in accordance with the petition, without further
4 notice.
Dated:
5 Signature of Jennifer Rae Mehaddi f/k/a Rife
6
10
11
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15
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CARLJ.GAUL
Attorney al la1t1
1604 Hcwiu Ave.
PET FOR MOD/ADJ PARENTING PLN (PTMD) - Page 5 Evercll WA 9820 I
WPF DR 07.0100 (912001) - CR 4.1; RCW 26.09.181; .260; .270 425 259-4147 FAX 259 7081
'
1 FILED
2
3
\11~11\111\\\111
CL16444766
2013 OCT -3 PH
S&NYA KRASKI
~: 00
Clt.INTY CLERK
4 SNOHIHISH CGI. WASH

County of SNOHOMISH
8
In re:
9
ANDREW RIFE No. 05 3 02755 1
10 Petitioner, Financial Declaration
And [X]Petitioner
11 [ ]Respondent
JENNIFER MEHADDI (FNDCLR)
12 Res ndent.
13
Name: andrew rife Date of Birth: 3122173
14 I. Summary of Basic Information
Declarant's Total Monthly Net Income (from§ 3.3 below) $7,141.00
15 Declarant's Total Monthly Household Expenses (from§ 5.9 below) $3,612.00
Declarant's Total Monthly Debt Expenses (from§ 5.11 below)
16 Declaranfs Total Monthly Expenses (from§ 5.12 below) $3,612.00
Estimate of the other party's gross monthly income (from § 3.1g below) [X) $2,693.00
17 [I Unknown
18 II. Personal Information

2.1 Occupation: Engineer
19 2.2 The highest year of education completed: 16
2.3 Are you presently employed? [ ) Yes [ ) No
20 a. If yes: (1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
21 (2) When did you start work there? (month/year) 09/1998
22 b. lfno: (1) When did you last work? (month/year)
23 (2) What were your gross monthly earnings?
(3) Why are you presently unemployed?

24
25
Financial Declaration (FNDCLR) - Page 1 of 6 CARLJ. GAUL
(.'\., I .\ I
Everett WA 98201
425 259 4147 fax 245 259 7081
0 RI
1'
\ 1_
'lD~
SupportCBlclFO 2011
--- --------------
2 Ill. Income lnfonnatlon
3 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 end child support is Not an
4 issue this entire section should be completed. (Estimate of other party's Income information is
optional.)
5
3.1 Gross Monthly Income
6 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
7 you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that
amount below.
8 andrew rife jennlfer mehaddi
a. Imputed Income $2,693.00
9 b. Wages and Salaries $7,141.00
c. Interest and Dividend Income
d. Business Income
10
e. Spousal Maintenance Received
From
11 f. Other Income
g. Total Gross Monthly Income $7,141.00 $2,693.00
12 (add lines 3.1a through 3.1e)
h. Actual Gross Income (Year-t<Hlate) $74,003.83
13
14 3.2 Monthly Deductions From Gross Income

andrew rife Jennifer mehaddi
15 a. Income Taxes
b. FICNSelf-i!mployment Taxes
16 d. Mandatory Union/Professional Dues
e. Pension Plan Payments
17 f. Spousal Maintenance Paid
g. Normal Business Expenses
18 h. Total Deductions from Gross Income
(add lines 3.2a through 3.2g)
19
20 3.3 Monthly Net Income (Line 3.1f minus line 32h $7,141.00 $2,693.00
llLline 3 from the Child Support Worksheet(s).)
21
22
23
24
25
Financial Declaration (FNDCLR) - Page 2 of 6 CARL J. GAUL:
WPF DRPSCU 01.1550 (6/2006) • RCW 26.18.220 (1) Attorney at Law
Everett WA 98201
425 259 414 7 fax 245 259 7081
SupportCe/clFO 2011
1
3.4 Miscellaneous Income andrew rife jennifer mehaddi
a. Child support received from other relationships
2 Name:
Name:
3 b. Other miscellaneous income
(Ust source and amounts)
4 Income of current spouse
Name: Soufyane
5 Name:
Income of children
Name:
6 Name:
Income from assistance programs
7 Name:
Name:
8 Non-recurring income
Name:
9 Name:
Other Income:
10
11
c. Total Miscellaneous Income
12 (add lines 3.4a through 3.4b)
13 3.5 Income of Other Adults in Household

Name:
14 Name:
3.6 If the income of either party is disputed, state monthly income you believe is correct and
15 explain below:
16
IV. Available Assets
4.1 Cash on hand $1,000.00
17 4.2 On deposit in banks $35,000.00
4.3 Stocks and bonds $350,000.00
18 Cash value of life insurance
19
V. Monthly Expense Information
20 Monthly expenses for myself and 1 dependents are: (Expenses should be calculated for the Mure, after
separation, based on the anticipated residential schedule for the children.)
21
5.1 Housing
Rent, 1st mortgage or contract payments $900.00
22
Installment payments for other mortgages or
encumbrances
23 Taxes & insurance (if not in monthly payment)
Total Housing $900.00
24
25
Everett WA 98201
425 259 4147 fax 245 259 7081
SupportCalc'FO 2011
1
5.8 Miscellaneous Expenses
Life insurance (if n.Q1 deducted from income) $31.00
2
Other:
Other:
3 Total Mlscellaneous Expenses $31.00
4 5.9 Total Household Expenses $3,612.00
(The total of Paragraphs 5.1 through 5.8)
5 5.10 Installment Debts Included in Paragraphs 5.1 Through 5.8
Credjtor/Descriolion of Debt Balance Month of Last payment
6
10
11 5.11 Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Month of Amount of
Credjtor/Qescriplion of Debt Balance Last payment Monthly payment
12
13
14
15
16
17
18
19
20
21
22
23
24
25
WPF DRPSCU 01.1550 (612006)- RCW 26.18.220 (1) Attorney at Law
Everett WA 98201
425 259 4147 fax 245 259 7081
SuppottCalclFD 2011
1
Total Monthly Payments for Other Debts and Monthly
Expenses
2
5.12 Total Expenses (Add Paragraphs 5.9 and 5.11) $3,612.00
3
VI. Attorney Fees
4
6.1 Amount paid for attorney fees and costs to date: $750.00
5
6.2 The source of this money was:
6
6.3 Fees and costs incurred to date:
7
6.4 Arrangements for attorney fees and costs are: Savings
8 6.5 Other:
9
10 correct
11
Signedat ~~ , [City] ?t.J/-rstate] on.__./~{J,_/"'.J?!t"""'!-'-~- [Date].
12
rt
13
andrew rife
14 Signature of Declarant
15 The following financial records are being provided to the other party and filed separately with the court.
16 Financial records pertaining to myself:
17 [] Individual []Partnership or Corporate Income Tax returns for

the years: including all W-2s and schedules;
18
[x) Pay stubs for the dates of 9/15/2013.
19 I I Other:
20 Do not attach these financial records to the financial declaratlon. These financial records should
be served on the other party and filed with the court separately using the sealed financial source
21 documents cover sheet (WPF DRPSCU 09.0220). If filed separately using the cover sheet, the
records wlll be sealed to protect your privacy (although they wlll be available to all parties In the
22 case, their attorneys, court personnel and certain state agencies and boards.) See GR 22 (c)(2).
23
24
25
Financial Declaration (FNDCLR) - Page 6 of 6 CARLJ.GAUL
1604 Hewitt Ave., Sutte 302
Everett WA 98201
Template: c:\program files (><86)\legalplus\rile endrewlfd ediled.dtl
Client c:\plogram files ("88)\legelpluslrife andruwlrlfa andrew.scp 1Dro3/2013 11:58 em 425 259 4147 fax 245 259 7081
SupponCS/O'FD 2011
[ ) Proposed by [ ) [ ] State of WA [ ] Other (CSWP)
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
Child Support Order Summary Report

A. The order [ ] does [ ) does not replace a prior court or administrative order.
$353.46.
$353.46 to be paid by [X] mother [ ] father.
D. The Court deviated (changed) from the Standard Calculation for the following reasons:
[ ] Does not apply
[ ] Nonrecurring income [ ] Sources of income and tax planning
[ ] Split custody [ ] Residential schedule (including shared custody)
[ ] Child(ren) from other relationships for whom the parent owes support
[ ] High debt not voluntarily incurred and high expenses for the child(ren)
- -- -- --
E. Income for the Father is [ ] imputed [X] actual income.
Income for the Mother is [X] imputed [ ] actual income.
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the
worksheets in Part Ill.
WSCSS-Worksheets ·Mandatory (CSWICSWP) 612010 Page 1 of 5
Worksheets
Childlrenl and Age(s): Lauren Emily Rife, 9
Part I: Income (see Instructions, oaae 6)
_ ~Wages a_ri.g ~~aries (l_rTlputed f'!' ~-ot!Jer)_
- - - _$_?,1_41.!ll!_ -- - - -.-
.
b. Interest and Dividend Income .
c. Business Income ---- - . -- -- ---
. .
d.Maintenance Received - . -- -
.
- ----
.
e. Other Income . .
f. _!_ni_l!uted Income - ..
. $2,693.00
a. Total Gross Monthiv Income fadd lines 1a ihrouah 1fl $7,141.00 $2,693.00
a. Income Taxes (Federal and State) Tax Year: Manual . .
_!:>._FICA (Soc.Sec_.+Medicare)/Self-E~P.lC>Y_ni_ent Taxes
--- - . .
c. State Industrial Insurance Deductions - - - -
.- -
.
d. Mandatory Union/Professional Dues . .
f?.Mand~t()[Y_Pen~i,<?n__Plan Paymen_l§_ ___ -----· -- - -
. .
f. Voluntary_ 13_etirement Contribu_!io~ __
-- -- - -
. .
g.Maintenance Paid
- .
. .
h. Norm.al Business Expenses . --
.
(add lines 2a through 2h) . .
3. Monthly Net Income (line lg minus 2i) $7141.00 $2,693.00
(line 3 amounts combined)
5. Basic Child Support Obligation (Combined amounts ~)
- $1,290.00
.
.
.
Part II: Basic Child Suooort Obligation (see Instructions, oa<1e 7)
7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.) $936.54 $353.46
B. Calculatina low income limitations: Fill in only those that aooly.
Self-Suooort Reserve: (125% of the Federal Poverty Guideline.) I $1 134.00 I
a. ls !::!lm!lioed Ne! lni;;omi: Less Ib<!n S1 QQQ? If yes, for each
parent enter the presun.iptive $50 per c_hild. . .
b. I§ MQO!bl~ t!le! lni;ome Lg§S Ibi!D Self-Sy11112!:1 B!:S!:IY!!'.2 If yes,
__ for that 11.a~e_nt enter the Jlresump!ive $50_11er child,_
"--- ---
. .
----
c. Is MQ!l!bl~ t!!el lm;omg Grg!!!!l[ Ib!!D Self·Su111m!:l B!:S!:O!!:? If
If that amount is less than line 7, then enter that amount or the
presumptive $50 per child, whichever is greater. . "
----
.
child.
WSCSS-Worksheets ·Mandatory (CSW!CSWP) 612010 Page 2 of S
Part Ill: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Expenses Father Mother

a.Monthly Health Insurance Paid for Child(ren)_ - - -
b. Uni_nsured Monthly Health Care Expenses Paid for Child(ren)
-
- - - -
(line 1Oa plus line 1Ob)

- -
iline 10c amounts combined) -
11. Dav Care and Special Expenses
a. Day Care Expenses - -
b. Educa_tiQ_n !'2<Jlenses - - -
__ E· Long Distance Transportation Expenses -
d.Other Special Expenses (describe)
- - -
- - -
- - - - ----- - - - -
---------- -------- - - - - - -- - -
-
--
(Add lines 11 a throuQh 11 d)
- -
(line 11 e amounts Combined) -
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 Child Support Obligation
15. Gross Child Suooort Obligation (line 9 plus line 14) $936.54 $353.46
16. Child Suooort Credits
a. Monthly Health Care Expenses Credit - -
-
b_. Day Care and ~pecial Expenses Credit
-- - - - -
-- -
-
- - - - --
d.Total Suooori Credits(add lines 16a through 16c) - -
whichever is areaterl $936.54 $353.46
Part VII: Additional Informational Calculations
line 3 for each parent) $3,213.45 $1,211.85
19. 25% at each parent's basic support obligation fram line 9 (.25 x
amount fram line 9 for each parent) $234.14 $88.37
WSCSS-Worksheets - Mandatory (CSW/CSWP) 612010 Page 3 of 5
--
a.Real Estate - -
b.lnvestments - - _$~5(),000_,0Q. - --
-c. Vehicles
- - -
and Boats
- - --- - - - -
-
d.
-- ---· Bank Accounts and-Cash
- -- -- - - _ S_!,000.00
-
-
-
-
--
e.Retirement Accounts - --
- -f.-Other:
- -(describe) -- - - --
-----·-
-
- - --
- -
21 Household Debt
- -
(List liens against household assets. extraordinary debt.)
-- - - - - - - - - - - - ---- - --- - -
- - a.
- -
------------- - - - -------- - - - .- -
- -
-··
b.
c. - - - -
d.
----- ---- --- - - - - - - - - - - -
-- - e. - -- - - - - - - -- - -
f.
- -
(if not the other parent of this actio!I) _
--- --
Name Soufyane - -
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 conside!EI~ EIJ5.t@ordinary)

Name - -
Name
-· -- - - - - -
. - - - - --- - - - - - --- -- - - - -
-- e.lncome From Child Suf?p~-- -
- -
-
Name -
Name - -- - -
--
f. Income From Assistance Programs - --------
Program - -
Program - - - ----~--
-
g.Other Income (describe)
-- -
23. Non-Recurrin11 Income (describe)
-
- .
WSCSS-Worksheets ·Mandatory (CSW/CSWP) 612010 Page 4 of 5
- -
24. Child Support Owed, Monthly, for Biological or Legal Father's Mother's
Child(ren) Household Household
---
__ Name/age~_
-- Paid [] --
---- Yes [] No .
-- .
---
__l'lame/age: _
--- P~[J Yes_[]
---
N_o_
--
. ---- .
Name/aae: Paid I l Yes -11 No . .
-
-- - - -- -
---- - ---
Sianature and Dates

Date City Date City
Worksheet certified by the State of Washington Administrative Office of the Courts.

WSCSS-Worl!sheets ·Mandatory (CSW/CSWP) 6/2010 Page 5 of 5 SupportCa/~ 2011
c: ..\state template6\waworksheet.dtf c:\program files (x86)\legalplus\rlfe andrew\rife andrew.scp 10/03/2013 12:08 pm
FIL Eb
2013 OCT -3 PH ~1 00
1
S8NYA KRASKI
2 CllUNTY CLERK
SNBHGHISH'CO. WASH
3
6

In re the Domestic Partnership of:
Petitioner,
10 and PARENTING PLAN
[xxx] PROPOSED (PPP)
11 Jennifer Rae Mehaddi f/k/a Rife [ ] TEMPORARY (PPT)
Respondent. [ ] FINAL ORDER PP
12
13 [] the final parenting plan signed by the court pursuant to an order entered on
_ _ _ _ _ [Date] which modifies a previous parenting plan or custody decree.
14 [] a temporary parenting plan signed by the court.
[XXX] proposed by Andrew Scott Rife
15
16
17
18
Name Age
19
Lauren Emily Rife 9
20
21
II. BASIS FOR RESTRICTIONS
22 Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contad with the child and the right to make decisions for the child.
23
24
25
26
27
ORIGINAL CARLJ.GAUL
Allorney at Lmv
1604 Hewitt Ave.
PARENTING PUN (PPP. PPT. PP) - Page I Everett WA 9820 I /I f)\J
WPF DR 0/.0400 (612008) - RCW 16.09.016.. 181 .. 187.. 194 425 259-4147 FAX 259 7081 - V
l
2 2.1 PARENTAL CONDUCT (RCW 26.09.191(1), (2)).
3 The respondent's residential time with the child shall be limited or restrained completely,
and mutual decision-making and designation of a dispute resolution process other than court
4 action shall not be required, because this parent has engaged in the conduct which follows.
5 Willful abandonment that continues for an extended period of time or substantial refusal
to perform parenting functions
6
The respondent's residential time with the child shall be limited or restrained completely,
7 and mutual decision-making and designation of a dispute resolution process other than court
action shall not be required, because a person residing with this parent has engaged in the
a conduct which follows.
9 A history of acts of domestic violence as defined in RCW 26.S0.010(1) or an assault or

sexual assault which causes grievous bodily harm or the fear of such harm.
10
2.2 OTHER FACTORS (RCW 26.09.191(3)).
11
The respondent's involvement or conduct may have an adverse effect on the child's best
12 interests because of the existence of the factors which follow:
13 Neglect or substantial nonperformance of parenting functions.

The absence or substantial impairment of emotional ties between the parent and child.
14 [] Other:

l 7 occasions, and what contad the child shall have with each parent. Parents are encouraged to
create a residential schedule that meets the developmentiJI needs of the child and individual
18 needs of their family. Paragraphs 3.1 through 3. 9 are one way to write your residential
19
3.1 SCHEDULE FOR CHILDREN UNDER SCHOOL AGE
20
There are no children under school age.
21
22
Upon enrollment in school, the child shall reside with the petitioner except for the
23 following days and times when the child will reside with or be with the other parent:
24 from 10:00 a.m. to 4:00 p.m. on Saturday and on Sunday

every other week, commencing - - - - - - - - - - -
25
The school schedule will start upon entry of this parenting plan by the court.
26
CARLJ. GAUL
Altorney al Unv
27
1604 Hcwill Ave.
PARENTING PLAN (PPP. PPT. PP) - Page 2 Evcrcll WA 9820 I
WPF DR 01.0400 (612008) - RCW 26.09.016.. 181 .. 187, .194 425 259-4147 FAX 259 7081
1 3.3 SCHEDULE FOR WINTER VACATION.
2 Same as 3.2
3 3.4 SCHEDULE FOR OTHER SCHOOL BREAKS
4 The child shall reside with the petitioner during other school breaks, except for the
following days and times when the child will reside with or be with the other parent:
5
Same as 3.2
6
3.5 SUMMER SCHEDULE.
7
Upon completion of the school year, the child shall reside with the petitioner, except for
a the following days and times when the child will reside with or be with the other parent:
9 Same as school year schedule.
10 [l Other:
12 Does not apply.
13 3.7 SCHEDULE FOR HOLIDAYS.
14 The residential schedule for the child for the holidays listed below is as follows:
15 With Petitioner With Respondent

16 Odd/Even/Every) Odd/Even/Every)
17 New Year's Day odd even
18 Memorial Day none every
19 July 4th odd even
Labor Day every none

20
Thanksgiving Day even odd
21
Christmas Eve even odd
22
Christmas Day odd even
23
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
24 times):
25 10 a.m. to 4 p.m.
26 CARLJ.GAUL
A11orney at law
27
1604 llewin Avc.
WPF DR 0/.0400 (612008) - RCW 26.09.016.. 181 .. 187.. 194 425 259-4147 FAX 259 7081
1
3.8 SCHEDULE FOR SPEOAL OCCASIONS.
2
The residential schedule for the child for the following special occasions (for example, birthdays)
3 is as follows:
4 With Father
With Mother
5 Odd[Even[Evety) Odd[Even[Evety)
6 Mother's Day every none
7 Mother's Birthday every none
8 Father's Day none every

Father's Birthday none every
9
Child's Birthday odd even
10
For purposes of this parenting plan, a special occasion shall begin and end as follows
11
(set forth times):
12
10 a.m. to 4 p.m.
13
[] Other:
14
15
Does not apply.
16
17 1 winter vacation (3.3) 4 holidays (3. 7)

2 school breaks (3 .4) 5 special occasions (3.8)
18 3 summer schedule (3.5) 6 vacation with parents (3.6)
19
3.10 RESTRICTIONS.
20
The respondent's residential time with the children shall be limited because there are
21 limiting factors in paragraphs 2.1 and 2.2. The following restrictions shall apply when the
children spend time with this parent:
22
The respondent must be within both sight and hearing of the child at all times.
23 The respondent is responsible to assure that Sufayane Mehaddi is never in a position of
authority or opportunity to discipline the child.
24 There shall be no physical discipline of the child by anyone.
25
26 CARLJ.GAUL
Attorney at Laiv
27
302 Bank of America Oldg.
1604 Jlewiu Ave.
WPF DR 01.11400 (612008) - RCW 26.09.0/6.. 181 .. 187.. 194 425 259-4147 FAX 259 7081
3
Transportation arrangements for the child, between parents shall be as follows:
4
The child shall be delivered to the residential parent at the parent's home unless the
parties otherwise agree.
5
3.12 DESIGNATION OF CUSTODIAN.
6
The children named in this parenting plan are scheduled to reside the majority of the
7
time with the petitioner. This parent is designated the custodian of the child solely for purposes
of all other state and federal statutes which require a designation or determination of custody.
8
This designation shall not affect either parent's rights and responsibilities under this parenting
plan.
9
3.13 OTHER.
10
11
12
13
14
15
16
3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A CHILD.
17
18
19
20
21
22
23
24
to the move but may ask for modification under RCW 26.09.260.
25
26
CARLJ.GAUL
27 Auorney at Law
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT. PP) - Page 5 Everett WA 98201
WPF DR 01.0400 (611008)-RCW 26.09.016.. 181, .187.. 194 425 259-'1!47 FAX 259 708!
·1 Notice may be delayed for 21 days if the relocating person is entering a domestic
2 and safety.

4
A relocating person may ask the court to waive any notice requirements that may put
5 the health and safety of a person or a child at risk.
6 Failure to give the required notice may be grounds for sanctions, including contempt.
7 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
B schedule may be confirmed.
10
11 (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
12 with the child.
13 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.
14
If the objecting person schedules a hearing for a date within 15 days of timely service of
15 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
16 child.
17 IV. DECISION MAKING

18 4.1 DAY-TO-DAY DEOSIONS.
19 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
2o this parenting plan, either parent may make emergency decisions affecting the health or safety
of the children.
21
4.2 MAJOR DEOSIONS.
22
23
Education decisions father
24 Non-emergency health care father
Religious upbringing father
25
4.3 RESTRICTIONS IN DEOSION MAKING.
26
CARLJ.GAUL
Attorney at Lmv
27
1604 Hewill Ave.
PARENTING PLAN (PPP. PPT. PP) - Page 6 Everen WA 9820 I
WPF DR 01.0400 (611008) - RCW !6.09.016.. 181 . . 187. , 194 425 259-4147 FAX 259 7081
1 Sole decision making shall be ordered to the petitioner for the following reasons:
2 A limitation on the other parent's decision making authority is mandated by RCW

26.09.191 (See paragraph 2.1).
3 One parent is opposed to mutual decision making, and such opposition is reasonably
based on the following criteria:
4
(a) The existence of a limitation under RCW 26.09.191;
5 (b) The history of participation of each parent in decision making in each of
the areas in RCW 26.09.184(4)(a);
6 (c) Whether the parents have demonstrated ability and desire to cooperate
7 26.09.184(4)(a); and
8 affects their ability to make timely mutual decisions.
9 V. DISPUTE RESOLUTION
1o The purpose of this dispute resolution process is to resolve disagreements about carrying out
12
13 No dispute resolution process, except court action is ordered.
14 VI. OTHER PROVISIONS

15 [l There are no other provisions.
[l There are the following other provisions:
16
17
18
19
20 VII. DECLARATION FOR PROPOSED PARENTING PLAN

21 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.
~
22
23
24
25
VIII. ORDER BY THE COURT
26
CARLJ.GAUL
27 A1torne;1 at ltni 1
302 Bank of America Dldg.
1604 Hewitt Ave.
PARENTING PLAN (PPP, PPT. PP) - Page 7 Evcrcn WA 98201
WPF DR 01.0400 (6/Z008) - RCW 26.09.016.. 181 .. 187, .194 425 259-4147 FAA 259 7081
•
1
2 approved as an order of this court.
is punishable by contempt of court and may be a criminal offense under RON 9A.040.060(2) or
s When mutual decision making is designated but cannot be achieved, the parties shall make a
6
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
7 plan are not affected.
B
Dated:
Judge / Commissioner
9
10
11 {
12 CARL: . GAUL WSBA
Attorney for Andrew
13
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26 CARLJ_GAUL
Auorney at Law
27
1604 Hewitt /\vc.
PARENTING PLAN (PPP. PPT. PP) - Page 8 Evcren WA 98201
WPF DR 01.0400 (612008) - RCW 26.09.016.. 181 .. 187, .194 425 259-4147 FAX 259 7081
'
FILED
1 11~~11~~CL16444762
Ill~~ 11!1m00 I~ ~I~ I~ ~I ZD/3 OCT -3 PH ~ 1 OO
2 SONYA KRASK/
~lj,HTY CLERK
SNOH HISH CO. IVASH
3
4
5
COUNTY OF SNOHOMISH
7
8 Andrew Scott Rife
9 and
Jennifer Rae Rife MOTION/DECLARATION FOR EX
10 Respondent. PARTE RESTRAINING ORDER AND
FOR ORDER TO SHOW CAUSE
11 (MTAF
12 I. MOTION
13 Based upon the declaration below, the undersigned moves the court for a temporary order and
order to show cause.
14
1.1 EX PARTE RESTRAINING ORDER.
15
A temporary restraining order should be granted without written or oral notice to the
16 other party or the other party's lawyer because immediate and irreparable injury, loss, or
damage will result before other party or the other party's lawyer can be heard in opposition.
17 This order should restrain or enjoin:
18 each of the parties from molesting or disturbing the peace of the other party or of any
child.
19 each of the parties from removing any of the children from the state of Washington.
20 The other party should be required to appear and show cause why these restraints
should not be continued in full force and effect pending final determination of this action.
21
CARLJ.GAUL
Al/orney al lmv
1604 Hewitt Ave.
MT'NIDECL FOR EX PA RTE RESTRAINING ORD (MFAF) - Page I Everett WA 9820 I
WPF DR 04.0150 Mandatory (612008)- CR 65 (h); RCW 26.09.060. 425 259-4147 FAX 259 7081
i
1 1.4 OTHER TEMPORARY RELIEF.
2 The respondent should also be required to appear and show cause why the court should
not enter a temporary order which:
3
orders child support as determined pursuant to the Washington State Child
4 Support Schedule.
approves the parenting plan which is proposed by the @@ petitioner @@
5 respondent.
appoints a guardian ad Iitem on behalf of the minor children.
6
1.5 OTHER.
7
8
9
10 II. DECLARATION
11 Please refer to separate declaration of Andrew Rife filed herewith.
12 I declare under penalty of perjury under the laws of the state of Washington that the foregoing
is true and correct. ~
~
13
Dated:
14 dreWSCottlfe
15
Do not attach financial records, personal health care records or confidential reports
16 to this declaration. Such records should be served on the other party and filed with
the court using one of these cover sheets:
17 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
18 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
19 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).
20
21 III. EFFORTS TO GIVE OTHER PARTY NOTICE.

22 The following efforts have been made to give the other party or other party's lawyer notice and
the following reasons exist why notice should not be required:
23
No immediate relief is requested.
24
25
26 CARLJ.GAUL
A llorney at Law
1604 Hewitt Ave.
MTNIDECL FOR EX PART£ RESTRAIN/NG ORD (MTAF) - Page 2 Everett WA 98201
WPF DR 04.0150 Mandatory (612008) - CR 65 (b): RCW 26.09.060. 425 259-4147 FAX 259 7081
,.. :
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26 CARLJ.GAUL
Attorney at Law
1604 Hewiu Ave.
MTNIDECL FOR EX PART£ RESTRAIN/NG ORD (MTAF) - Page 3 Everen WA 9820 I
WPF DR 04.0150 Mandatory (6120118) -CR 65 (b): RCW 26.09.060. 425 259-4147 FAX 259 7081
FILED
~:
1~111~1~\\1~1m~~1m~t~\~~~~~~
1 2013 OCT -3 PH 00
2 SONYA KRASKI
SNOH6HISH CO. WASH
3

COUNTY OF SNOHOMISH
7
In re:
s Andrew Scou Rife
Petitioner, NO. 05 3 02755 I
g and
Jennifer Rae Mehaddi, li'k/a Rife Declaration of Andrew Rife
1o Res ondenl.
11 TABLE OF CONTENTS
IDENTITY AND PURPOSE ............................................. 2
DIVORCE, NOVEMBER 7, 2006 ......................................... 3

MARCH 25, 2011 AGREED MODIFICATION .............................. 3
2011 MODIFICATION IN PRACTICE- - MORE CHANGES ................. 4
AGREEMENT & INTEGRATION ........................................ 5
DETRIMENT AL CHANGES
LAUREN SHOULD OFFICIALLY RESIDE WITH ME ......... 6
A. Medical Neglect ............................................ 6
B. Domestic Violence .......................................... 7
I. First Inkling of Domestic Violence ....................... 8
2. First Known Domestic Violence Event ................... 8
3. Second Known Domestic Violence Event ................. 8
JENNIFER MEHADDI FIRST REQUESTS MEDIATION
AND THEN REFUSES TO PARTICIPATE IN MEDIATION ..... 9
RECENT PARENTING ................................................ 10
ADEQUATE CAUSE I LIMITING FACTORS ............................. 10
A. Domestic Violence ....................................... I0
B. Medical Neglect ........................................... I0
C. Failure to Perform Parenting Functions ....................... 11
1. Jennifer Mehaddi Does Not Maintain a Loving, Stable,
Consistent, and Nurturing Relationship with Lauren ....... 11
\\' \ j-\l\\_ CARL J. GAUL
(\ D \
\ ) \-'\ G\ •
~ Attorney at Law
1604 Hewitt Ave.
~
PAGE 1 425 259·4147 Fp;t. 259 7081
1 2. Jennifer Mehaddi Does Not Attend to the Daily
Needs of the Child, Such as Feeding, Clothing,
2 Physical Care and Grooming, Supervision,
Health Care, and Day Care, and Engaging in
3 Other Activities Which Are Appropriate to the
Child ................................... 11
4 • Feeding ................................ 11
• Clothing. . .............................. 12
5 • Physical Ca re . ........................... 12
• Grooming .............................. 12
6 • Supervision. . ........................... I 2
• Health Care . ............................ 12
7 • Daycare. . .............................. 12
• Other Activities: Education . ............... 12
8 • Other Activities: Sporting Activities ........ 12
• Other Activities: Religious Upbringing ...... 13
9 • Other Activities: Social Involvement. ....... 14
10 8. PROPOSED PARENTING PLAt'I ........................................ 14
A. Substantial Refusal to Perform Parenting Functions I Neglect or
11 Substantial Nonperformance of Parenting Functions............. 14
8. Absence or substantial impairment of emotional ties between the
12 parent and child. . ......................................... 14
C. Substantial Refusal to Perform Parenting Functions............. 14
13
9. LIMITING FACTORS ................................................. 15
14 A. Willful Abandonment That Continues for an Extended Period of Time or
Substantial Refusal to Perform Parenting Functions ................... 15
15 8. .Jennifer Mehaddi Does Not Assist Lauren in Developing and Maintaining
Appropriate Interpersonal Relationships............................. 16
16 C. Jennifer Mehaddi Does Not Exercise Appropriate Judgment
Regarding the Lauren's Welfare, Consistent with the Child's
17 Developmental Level and the Family's Social and Economic
Circumstances............................................. 16
18 D. Jennifer Mehaddi Does Not Provide for the Financial Support of
Lauren ................................................... 16
19
10. BENEFIT OF NE\V PARENTING PLAN ................................. 18
20
I 1. SUMMARY .......................................................... 18
21
DECLARATION
22
I, Andrew Rife, declare under penalty of perjury of the laws of the State of Washington, that
23 the following is true and correct.
24 I. IDENTITY AND PURPOSE
25 I am the petitioner in this action for modification of parenting plan. I make this declaration
26 to inform the coun of the facts and circumstances which have changed since the most recent coun
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION CF" ANDREW RIF"E Everett WA 98201
PAGE 2 425 259-4147 FAX 259 7081
order.
2 I am asking for a modification of the March 25, 2011 parenting plan, sub 199, to place
3 the child Lauren Rife in my primary residential care. (See Allachment I)
4 Since our divorce I have supported Jennifer in a variety of ways. I invest my interest, time
5 and money in our daughter. When Jenni fer or Lauren needed my personal involvement I have been
6 there, happily participating. When Jennifer has been irresponsible I filled the void so my daughter
7 would not suffer or go without. When they needed money beyond the child support, I have given
8 or loaned it. Recent facts show that life under the current parenting plan is detrimental to Lauren's
9 physical, mental and emotional development. Jennifer is neglectful with Lauren.
1O Lauren already lives wilh me a majority oflhe time by agreements between Jennifer Mehaddi
11 and me. As time has gone by the actual residential schedule has evolved to the present situation
12 where Lauren lives with me most of the time. Lauren has come to refer to my home as being "home"
13 in conversation. I participate in Lauren's life a great deal more than Jennifer does.
14 2. DIVORCE, NOVEMBER 7, 2006
15 Jennifer Mehaddi and I were married from April 10, 2004 until !he decree was entered on
16 November 7, 2006. Our divorce settled. The agreed parenting plan established primary residential
17 placement of our daughter with Jennifer.
18 3. MARCH 25, 2011 AGREED MODIFICATION
19 After Lauren started Kindergarten in 2009 the time Lauren spent with me began increasing
20 significantly. Lauren would be with me whenever Jennifer had olher things to do, generally at
21 Jennifer's request. At the time, both Jennifer and I were happy with !his arrangement. I also helped
22 her out financially beyond the child support. By the end of 20 I 0 Lauren had started Kindergarten
23 at St. Mary Magdalen and we had settled into a changed residential schedule which bore scant
24 resemblance to the parenting plan entered with the decree.
25 In early 2011 (midway through Lauren's first grade year) Jennifer approached me about
26 changing our parenting plan. The new parenting plan was her idea. She wanted to change the
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION OF" ANDREW RIF"E Evere!IWA98201
PAGE 3 425 259-4147 FAX 259 7081
1 parenting plan to more nearly reflect the time Lauren was spending with each of us. I agreed that
2 the previous plan bore no resemblance to what we were doing, so we agreed upon a modification
3 of the parenting plan. We each knew the parenting plan was changing in a way that we both wanted.
4 And there was something more she wanted from me also, money.
5 Part VI of the March 25, 2011 parenting plan reflects additional concerns in Jennifer's life.
6 She had developed an on line friendship with Soufyane Mchaddi, an Algerian man. Her relationship
7 with him was very important to her. Jennifer was determined to go there to meet him. She asked
8 me for the money to go to Algeria. I knew she would find a way to get there, and I wanted to protect
9 our daughter from the risks of accompanying Jenni for to Algeria to spend time with a man her
1O mother had never met. So I agreed to pay for Jennifer's trip upon the condition that Lauren would
11 stay with me.
12 The new parenting plan was entered by agreement on March 25, 2011. Under the parenting
13 plan, part 3.2 1, during the school year Lauren resides with me
14 Alternating weekends Friday afler school to Sunday at 7:00 p.m.

Every Tuesday after school overnight to Wednesday morning return to school.
15 Every Thursday aflernoon after school to 7:30 p.m.
Alternating major holidays
16
This schedule would have Lauren spending overnight with me 4 times in a 14 day cycle, plus
17
an additional 5 hours on Thursdays. 4/14 is 28.6%, (disregards overnights resulting from vacations
18
and alternating major holidays) which represents substantial time for the non-primary parent. The
19
actual practice has been for Lauren to be with me much more time than is specified by the 2011
20
parenting plan. She actually resides with me a majority of the time.
21
4. 2011 MODIFICATION IN PRACTICE - - MORE CHANGES
22
The 2011 agreed modification merely reflected the residential schedule changes that Jennifer
23
and I had already implemented. Jennifer and I agreed that Lauren would be brought up in the
24
1
25 Part 3.2 governs the school year. The times of day for exchanges expand during the
summer under part 3.5 by changing the times of the pickups and returns, but the number of
26 overnights does not change during the summer.
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAC31E 4 425 259-4147 FAX 259 7081
1 Roman Catholic faith and that she would attend St. Mary Magdalen Roman Catholic grade school.
2 It is the only grade school she has ever known, attending Kindergarten, first grade, second grade
3 and now third grade at St. Mary Magdalen. She earns good grades. She gets near-perfect spelling
4 tests and enjoys arithmetic. Her close friends are there.
5 Lauren has extra-curricular activities. She developed an interest in track and soccer. She
6 loves in soccer. Some of her classmates play on her teams, strengthening their bonds. She plays
7 year round. My work schedule allows me to be available in the allernoons, which allows me to
8 coach Lauren's school team. She excels, playing Washington Rush Soccer, on a select soccer team
9 above her age. She competes as an equal and she loves it.
10 5. AGREEMENT & INTEGRATION
11 Lauren spends 73% of her waking hours with me. Sec Attachment 2: a copy of calendars
12 showing the pattern of Lauren spending significant time with me over the course of2013. Through
13 the end of August 2013 Lauren has spent overnight in my care 51 % of the time. Additionally, she
14 has been with me on 55 other days in the allernoons and evenings. I pick her up from school and she
15 spends 51 % of the overnights with me. She spends an additional 22% of the afternoons with me,
16 on days she sleeps at her mother's home'. I pick Lauren up from school, then she has dinner with
17 me and I deliver her to Jennifer's home about 7:30 p.m.
18
2
19
Extra Extra
20 Overnights Afternoons Overnights Afternoons
21 Jan 15 9 Jun 13 6
Feb 12 8 Jul 13 9
22
Mar 19 4 Aug 17 6
23
Apr 18 3 TOTAL 124 55
24
May 17 10 Percentages 51.24% 22.73%
25 (242 days)
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION OF" ANDREW RIFE Everett WA 98201
PAGE 5 425 259-4147 FAA 259 7081
1 The overnights represent simply where Lauren slept. One key here is in the Extra
2 Afternoons. Lauren loves soccer. 1take her. Lauren has homework. She does it at my house. The
3 second grade teacher knew by her homework which parent she was with the night before. The other
4 key is that the time with me did not diminish in the summer months. Jennifer was unemployed
5 during those months, but her extr.i free time did not increase her time with Lauren.
6 Lauren is integrated into my home, as she is accustomed to her routines at my house. She
7 has her own bedroom, she knows the neighborhood and has friends here. She has extended family
8 nearby here as my mother, my father, my aunt, my brother and I all reside in Everett. She calls my
9 house "home." She has other tern1s for her mother's condo. She says "with Mom ... " or similar ways
10 of referring to her mother's home. When Jennifer wants time with Lauren she calls to arrange it
11 with me, even if it is during days the parenting plan would have Lauren be with her.
12 6. DETRIMENTAL CHANGES
LAUREN SHOULD OFFICIALLY RESIDE WITH ME
13
Recently, things have changed detrimentally at her mother's home. It is harmful to her.
14
am very worried about my daughter. Jennifer Mehaddi has neglected our daughter's medical needs,
15
discussed immediately below. There has also been domestic violence in Jennifer's home 1. Things
16
have changed so badly that Lauren should no longer reside primarily with Jenn lier. I should be the
17
custodial parent.
18
A. Medical Neglect
19
For the past several years I have taken Lauren to most of her doctor's appointments and to
20
all of her dental appointments. The custom became that I take care of the routine medical needs.
21
On June 23 Lauren injured her wrist when she ran her scooter into a tree. It is just one of the
22
things that happens occasionally when kids play. The problem arises from the response to it.
23
Jennifer took Lauren to a walk-in clinic for a doctor to diagnose and prescribe suitable care. After
24
checking in, Jennifer became impatient and decided to leave the clinic rather than wait for Lauren
25
3
26 The domestic violence is discussed below, beginning at page 7.
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION OF" ANDREW RIF"E Everett WA 98201
PAGE 6 425 259-4147 FAX 259 7081
1 to be seen. She just got up and left! There was no good reason to leave before Lauren had a chance
2 to be seen by a doctor.
3 When I next had Lauren she told me of her accident. Lauren told me that she had not seen
4 a doctor and that they had walked out of the walk in clinic. And she told me her wrist still hurt. So
5 I took her to the walk-in clinic. They took an X-Ray which showed a broken bone in her wrist,
6 treated with a soft cast/splint. Sec Scaled Health Care Record. I told Jennifer about the diagnosis
7 and asked why she had left the clinic. She responded that at the time Lauren's wrist seemed to hurt
8 a little less than when they went to the clinic, so she decided lo leave. When Lauren needs medical
9 attention she should gel it. That is why she is on my insurance with no co-pay.
10 When I complained to Jennifer she was angry with me that I had obtained medical attention
11 for our daughter. Jennifer then criticized me for taking Lauren to a doctor without her permission
12 because we have joint decision making. I was not going to leave my daughter in pain. Yet Jennifer
13 had the audacity to say that I could not obtain medical care without discussing it with her. She was
14 concerned that she might be criticized, but not concerned about our daughter. Belter Lauren should
15 sec a doctor when she might not need lo than to not see a doctor when she does need to. Jennifer
16 got this decision precisely wrong.
17 B. Domestic Violence
18 Jennifer Mehaddi resides with her husband, Soufyane Mehaddi'. They have only been
19 residing together since he immigrated in April 2013. The process of Americanization has had its
20 di mculties. It is scary that domestic violence is one of the difficulties. In just four months there
21 have already been multiple incidents of domestic violence in their home. Residing in that
22 environment is harmful to Lauren. I am concerned about two issues relating to Lauren. One is the
23
4
24 I want the court to know that I am not motivated by Jennifer's choice of a husband or
her relationship with him. It is no surprise that there may be frustrations and even anger settling
25 into a new country and that may be the source of Soufyane Mehaddi's behavior. In my limited
interaction with him I have found him to be a pleasant person and respectful to those he comes in
26 contact with. My concern is only with my daughter's environment.
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 7 425 259-4147 FAX 259 7081
risk that she may be assaulted. Nearly as frightening is that she has witnessed and likely will again
2 witness domestic violence. Domestic violence is a cycle that must not be passed on to Lauren.
3 Being a witness to domestic violence is detriment to her. Becoming a victim is worse.
4 1. First Inkling of Domestic Violence
5 Jn July Lauren made some comments making me wonder whether there might be domestic
6 violence and a lot of yelling in her mother's home. I asked Jennifer, and she told me there is no
7 domestic violence in her home.
B 2. First Known Domestic Violence Event
9 On Wednesday July 31, 2013 Jennifer dropped Lauren off to me, and discussed a recent
1O incident where Soufyane had become upset with Jenni fer and hit or pushed her forehead hard with
11 the heel of his hand. She said she was trying to get Soufyane to leave voluntarily, and she asked
12 me to take Lauren full time "until further no/ice." or course I agreed. I would not leave Lauren
13 into a violent situation. I asked about safety at her home. Even though we are divorced I was
14 concerned that Jennifer would be in a violent situation also.
15 3. Second Known Domestic Violence Event
16 On August 7 there was another incident between Jennifer and Soufyane. Jennifer called
17 911. I was worried, and obtained a CD copy of the call and had a transcript typed. See Attachment
16 3. Soufyanc Mchaddi threatened my eight year old daughter when he raised his ann at her in anger.
19 I learned of the incident because Jennifer called me and asked me to take Lauren until further notice
20 for her safety. Of course I took her.
21 "Until further notice" turned out to be only three days. Lauren stayed with me until 9:00
22 p.m. on Saturday August 3 when Jennifer and Jennifer's 11 year old niece Alexa came to pick up
23 Lauren. Alexa told me about the same July 31 incident. I took Jennifer aside and expressed concern
24 about Lauren being in that home with Soufyane having anger problems. She responded by telling
25 me that Souryane would never do anything with other people present. She told me that Soufyane
26 would not act up in front of the kids. Jennifer wanted to have a sleep over with Alexa and Lauren.
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION CF" ANDREW RIF"E EverettWA9B201
PAGE B 425 259-4147 FAX 259 7081
With misgivings I allowed Lauren to go. Jennifer dropped her off at my home at 7: 15 a.m. the very
2 next morning, Sunday, August 4.
3 On August 7, 2013 Jennifer called me and asked me lo take Lauren on days I had not
4 anticipated she would be with me. She did not want to talk about it much, but she did say she had
5 called the police over an incident of domestic violence and she wanted to have Lauren out of the
6 situation. Of course I agreed to lake Lauren again. Lauren stayed with me until August 16. I
7 obtained a copy of her 911 call.
8 There have been a series of communications. Jennifer now claims to have no concern at all
9 about domestic violence and she denies the significance of being hit herself and the threatening
10 gesture toward our daughter.
11 The substance of what Jenni fer has communicated is that there is violence in her home, she
12 knows the patterns of behavior, that he will not do it in front of outsiders. For whatever reason, she
13 has chosen to remain in a violent environment and to keep our daughter in it.
14 7. JENNIFER MEHADDI FlRST REQUESTS MEDIATION

AND THEN REFUSES TO PARTICIPATE IN MEDIATION
15
In early summer 2013 Jennifer and I had several telephone calls to discuss residential
16
schedule because we had not been following the schedule in the 2011 parenting plan and we talked
17
about mediating a new schedule.
18
In the early summer 2013 I received a notice that Jennifer wanted to mediate. The notice did
19
not specify what topic she wanted to address, but the staff at VOA told me that she wanted to
20
mediate about the residential schedule. I wanted to address the parenting plan also. I believe
21
Jennifer actually wanted to talk about what I might be able to do to encourage Lauren to be more
22
respectful ofSoufyane in their home. Sec Attachment 4, text messages. I did talk to Lauren about
23
being more respectful and how lo treat adults, specifically Soufyane. I agreed also to mediate.
24
Then VOA Dispute Resolution Center closed its file because Jennifer's check bounced.
25
After I learned of the DV incidents at the beginning of August, I tried to talk to Jennifer
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DECLARATION OF" ANDREW RIFE Everett WA 98201
PAGE 9 425 259-4147 FAA 259 7081
about it. I told her that I do not want to interfere in her relationship with her husband, but that I do
2 want to be sure that our daughter is not being introduced to domestic violence, essentially being
3 groomed to be a victim. I wanted lo talk to Jennifer about what our daughter is experiencing. She
4 did not want lo talk about it at all just between us sol requested mediation.
5 On August 20 I received the copy of her 911 call. I immediately requested mediation and
6 paid my portion of the cost for mediation. Jennifer has not responded. I wanted to assure that when
7 our daughter needs medical care she will gel it. The insurance will cover the cost, all we need to do
8 is invest our time and concern. I also wanted to reach agreements about who would be supervising
9 our daughter. I had hopes that some counseling might occur for the domestic violence, and I had
10 hopes that we might assure that Lauren is with me during times Jennifer is not present. Jennifer has
11 still not responded to the August 20 request for mediation. See Attachment 5.
12 8. RECENT PARENTING
13 As discussed below, there has been a substantial change of circumstances since 2011 such
14 that a new parenting plan should be entered. The new parenting plan should establish that Lauren
15 will reside primarily with me.
16 Additionally, I believe the environment at Jennifer Mchaddi's home is detrimental to
17 Lauren's physical mental and emotional development. There would be no traumatic harm to her in
18 moving to my home full time and there would be benefit from that move. Lauren is fully integrated
19 into my home and accustomed to the structure and routines I provide. She is peaceful, busy and
20 happy with me.
21 9. ADEQUATE CAUSE I LIMITING FACTORS
22 In this case many of the same facts that establish that there is adequate cause for modification
23 of the parenting plan also establish the basis for limiting factors in the parenting plan.
24 A. Domestic Violence
25 Please see material above at page 6.
26 B. Medical Neglect
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
CECL.ARATIDN CF" ANCREW RIFE Everett WA 98201
PADE 1 0 425 259-4147 FAX 259 7081
1 Please see material above at page 7. Also:
2 I have taken Lauren to every dental appointment she has ever had. I have invited Jennifer
3 to come also. Jennifer has attended one (I), and on that occasion Lauren insisted that I go with her
4 when she was actually with the dentist. Since Kindergarten started almost four years ago I have also
5 taken Lauren to all her routine physical exams and assured that she has all her immunizations. I am
6 happy to be the parent who attends to our daughter's routine medical needs.
7 c. Failure to Perform Parenting Functions
8 Jennifer Mehaddi does not consistently perform parenting functions. Over time, Jennifer has
9 taken less and less interest in our daughter. Jennifer Mehaddi has been withdrawing from Lauren's
10 life. Lauren expects that her mother will not attend school plays and school activities, to not be at
11 soccer games, to not auend her baptism, confirmation and first communion. To fill that void I have
12 stepped in to be the hands on parent. Sometimes, her First Communion for example, another mother
13 will step in to help Lauren by adjusting her veil.
14 I. Jennifer Mehaddi Does Not Maintain a Loving, Stable, Consistent, and

Nurturing Relationship with Lauren.
15
Jennifer Mehaddi's financial instability makes Lauren's home unstable. When she works
16
as a medical assistant she makes decenl wages. But Jennifer has not been able to maintain stable
17
employment. This contributes to her financial difficulties. She was fired from her last job when she
18
walked out to go interview for another job she did not get. She has asked her mother, my mother
19
and me to take Lauren when she could not provide for her. I have helped with my time, interest and
20
involvement as well as helping her financially with her car, trips, PUD bill, and groceries so my
21
daughter would not go without.
22
2. Jennifer Mehaddi Does Not Attend to the Daily Needs of the Child, Such
23 as Feeding, Clothing, Physical Care and Grooming, Supervision, Health
Care, and Day Care, and Engaging in Other Activities Which Are
24 Appropriate to the Child.
25 • Feeding: St. Mary Magdalen provides hot lunches on Wednesdays and

Fridays. I pay for these lunches. On the other three days of a week the
26 parents must provide the lunches. I have been called repeated Iyon Jennifer's
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 1 1 425 259-4147 FAX 259 7081
1 days to take food to Lauren because Jennifer forgot. My boss is supportive,
and he allows me to take time off to do this because he knows I will make up
2 the time promptly. A hungry child cannot learn. I have never failed to send
lunch or have a hot lunch- available for Lauren when she is in my care.
3 • Most days that Lauren returns to Jennifer's home for the night I deliver her
about 7:30 p.m.,just before bed. I make sure she has dinner before going to
4 her mother's.
• Another example, that Lauren does not know what to expect from her
5 mother. Jennifer was to pick up our daughter on Saturday, September 14,
2013. She called in the afternoon and told me to feed Lauren a snack. I
6 offered to feed her dinner, but she insisted she would take care of dinner.
Then she called at dinner time and told me to go ahead and feed Lauren.
7 Then she came late to get our daughter.
• Clothing. Jennifer rarely provides clothing for Lauren. I buy most clothes.
8 I buy the school uniforms (my aunt and mother enjoy helping with this). I
buy the soccer T-shirts and cleats. On the first day of school this September,
9 Lauren called me to bring her a coat. It was a cool day. I did. Evidently
Jenni fer had forgotten.
10 • Physical Care. Jennifer causes Lauren to live with domestic violence and
is in denial about it. Lauren often is poorly groomed and unkempt after being
11 at her mothers, sometimes unbathed.
• Grooming. Lauren will not allow her mother to comb her hair. I ·do not
12 know why. I do not ask. Lauren has me comb her hair, and she lets my
mother do it.
13 • Supervision. Please refer to domestic violence at page 7.
• Health Care. Please refer again to Medical Neglect, at page 6 above .
14 Jennifer provides no regular health care for Lauren. I take her to all her
regular appointments. I have taken her to every dental appointment.
15 • Daycare. Not a factor.
• Other Activities: Education. Jennifer Mchaddi does not attend to Lauren's
16 education. September 19, 2013 was "curriculum night," from 7:00 to 8:30
p.m. Jennifer did not attend.
17 • She has never taken the classes required to volunteer at Lauren's school. It
only takes two evenings to fulfill the requirement. I have taken the classes.
18 • She has never prepared Lauren for a spelling test.
• She has never helped Lauren with a book report .
19 • She has never attended a field trip.
• Other Activities: Sporting Activities Sports are imporant to Lauren. She
20 is an athletic little girl. Soccer is especially important to her. She is quite
talented. The court should consider Lauren's sporting activities. Jennifer
21 does not significantly contribute. Jennifer does not take Lauren or watched
her events. At soccer camps last summer Lauren felt peculiar because she
22 was the only girl whose mother never once picked her up or dropped her orP.
23 • She has missed every one of Lauren's track meets and most of the soccer
games.
24
5
25 I provide the most of Lauren's transportation for practices and games. Both
grandmothers provide transportation for her also, mostly to and from practices. Jennifer does
26 not, even on days she is not working.
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 1 2 425 259-4147 FAX 259 7081
1 • She has rarely taken Lauren to practices.
• She goes to few of Lauren's soccer games. She lacks interest in the activity
2 her daughter loves.
• May 6, 2013, Lauren's soccer team this year had its I st team meeting at 5:30
3 in Marysville. Her mom has informed me that she will not be going. She
asked me to keep Lauren the night.
4 • May 31 Lauren was bal I girl for the Sounders Women's Pro Soccer team. I
attended. Jennifer did not.
5 • She missed 2 of the 3 2012 year end soccer parties. She attended in 2013
because I drove her there.
6 • June 22, 2013, Lauren had two soccer games on Jennifer's weekend. Jennifer
brought Lauren to the I st game but left Lauren with me for game 2 because
7 she had to leave and take Soufyane to work and she did not come back.
• On July 20, 2013 Lauren had soccer games on her mother's weekend. I
8 picked Lauren up at Jennifer's condo for the game. Jennifer was not working
and was home when I picked up our daughter, but she did not go watch our
9 daughter play.
• On August 2 through 5, 2013, Lauren had soccer games on her mother's
10 weekend. Jennifer did not bother to attend. Lauren stayed with me Friday
night through Saturday at 9:00 p.m. Saturday, Lauren and I went to the first
11 day of the soccer tournament. Jennifer picked her up at my house at 9:00
p.m. Saturday, then dropped her off again at my house at 6:00 a.m. on
12 Sunday short on sleep. I took Lauren to the rest of the tournament. Jennifer
again did not attend her game, even though she did not work that day.
13 • Another soccer tournament August 23-25, 2013. Jennifer did not attend any
of her games.
14 • Other Activities: Religious Upbringing. A familiar pattern of
15 non-involvement: For all the many events of the process of initiating Lauren
16 into full membership in the church Jenni fer was not involved in the
17 preparations, she provided none of the transportation, and she did not attend
18 most of the ceremonies.
19 • In February 2013 my mother invited Jennifer Mehaddi to participate in

picking out Lauren's communion dress. Jennifer declined. She said she
20 trusted my mom to do it. My mom and I took Lauren to be fitted.
• In March Lauren put a great deal of work into her communion banner. It was
21 turned in on the 18th of March to hang in the church. Jennifer never saw it.
• She failed to help in any way with Lauren's communion banner or picking
22 out her dresses or shoes.
• May 5, 2013, a Sunday, Lauren had her art displayed the Archbishop Murphy
23 Art Show on Sunday. Lauren's mom knew that the viewing started at I pm
but failed to show up to see her daughter's work, even though it was only
24 about three miles from her home.
• She missed First Communion rehearsal on her own weekend. I had to get
25 Lauren and take her from her mother's home.
• At Lauren's communion confirmation and baptism on Easter Vigil, she
26 walked out before seeing her daughter go through any of the rituals.
CARLJ. GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 1 3 425 259-4147 FAX 259 7081
1 • She missed St. James Cathedral night for Lauren's confirmation ceremony
mass for acceptance into the church.
2 • Jennifer missed the parent-child retreat for the communion with her second
grade class. Lauren was the only child there with no Mom.
3
• Other Acth'ities: Social Involvement. Again, this is the familiar pattern
4
of non-involvement.
5
• Jennifer does not arrange play dates with her friends, although she does with
6 her sister's children who are older than Lauren.
7 8. PROPOSED PARENTING PLAN
8 The facts concerning detriment to Lauren in her mother's home also establish limiting factors
9 for the new parenting plan. Much of the same evidence provides support for each legal issue. In
1o establishing the new parenting plan I believe that the following limiting factors arc present:
11 A. Substantial Refusal to Perform Parenting Functions I Neglect or Substantial

Nonperformance of Parenting Functions.
12
Please refer to the listing of Jennifer Mehaddi's nonperformance of parenting functions
13
beginning at page 11.
14
Jenni fer does not perform educational, medical, social or structured activites parenting
15
functions. Jfl did not perform them, where would our daughter be?
16
Lauren's homework is done at my home. Includes math reading and spelling. All permission
17
slips for field trips are signed by me. The school calls me directly if there are any issues.
18
B. Absence or substantial impairment of emotional ties between the parent and
19 child.
20 Lauren docs not use the term "home" to refer to her mother's place. It refers to my home.
21 Lauren makes comments showing that she would prefer to simply stay in my home. My own
22 opinion is that she gets more positive attention in my home than in her mother's.
23 c. Substantial Refusal to Perform Parenting Functions.
24 Again, please refer to the listing of Jennifer Mehaddi's nonperformance of parenting
25 functions beginning at page 11.

26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
DEC::LARATICN CF" ANDREW RIFE Everett WA 98201
PAGE 1 4 425 259-4147 FAX 259 7081
The list of things Jennifer does not do is stunning. She simply will not do the job. She
2 chooses to do other things than parent. As she has been withdrawing from parenting Lauren has
3 been spending more and more time with me. And I have been doing more and more of the
4 parenting. I have been performing the functions of a custodial parent.

5 Jennifer has her dog groomed regularly and pays the bill. But then may not have money for
6 groceries when Lauren was with her. I have given her grocery money repeatedly so Lauren will not
7 go without.
8 I began keeping a record ol"what has been happening. The residential schedule has been that
9 Lauren stays with me half or more of the overnights, and that she spends most of the rest of her
10 waking hours with me.
11 Last April Soufayane Mehaddi was able to immigrate. When he arrived Jennifer had Lauren
12 spend the first two weeks with me while she and her husband settled in together. The changes of
13 Lauren's schedule have been accompanied by Jennifer's near complete disinterest in our daughter.
14 I have taken over the parenting of our daughter.
15 It reached the point that I thought the parenting plan should be modified again. I believed
16 that we should again modify the parenting plan to reflect the parenting that we have actually been
17 doing. When I suggested a modification to Jennifer. She flatly refused to consider it. Of course she
18 accused me ofjust wanting to modify the child support despite the money I have willingly given and
19 loaned to her over the years. She knows she can count on me to help her out when she makes poor
20 choices that impact Lauren.
21 9. LIMITING FACTORS
22 A. \Villful Abandonment That Continues for an Extended Period of Time or
Substantial Refusal to Perform Parenting Functions
23
Jennifer has not abandoned our daughter, but she basically refuses to perform parenting
24
functions. Again, please refer to the listing of Jennifer Mehaddi's nonperformance of parenting
25
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 1 S 425 259-4147 FAX 259 7081
functions beginning at page 11. The listing is so significant that it goes beyond neglect, it reaches
2 the level of refusal to perform parenting functions.
3 She did not allend the fitting for the special dress for Lauren's baptism. Then she skipped
4 the baptism because her dog was sick. She attended Lauren's First Communion, but left halfway
5 through, not even waiting to witness Lauren receiving Communion. My extended family attended.
6 Jennifer's mother attended and stayed through the entire ceremony. Jennifer had something more
7 important to do. I could understand her disinterest if Jennifer had simply announced that she is not
8 Catholic and did not want to participate and stayed away. But we agreed that Lauren would be
9 raised as a Catholic. We put Lauren in a Catholic school by agreement. Baptism is a crucial part
10 of being a Roman Catholic. So is First Communion. The two sacraments together establish that she
11 is fully a member of the church. To be at our daughter's First Communion and walk out of it sends
12 a terrible and sad message to Lauren.

13 B. .lennifer Mehaddi Does Not Assist Lauren in Developing and Maintaining
Appropriate lntcrnersonal Relationships.
14
Lauren needs to learn how to have friends just because they like each other. Lauren needs
15
to learn how to be part of a team. Jennifer docs not teach or encourage it. I teach friendship,
16
Jennifer does not. Lauren needs to have a religion. I teach it. Jennifer does not.
17
18
c. .lennifer Mehaddi Does Not Exercise Appropriate .ludgment Regarding the
Lauren's \.Velfare , Consistent with the Child's Developmental Level and the
Family's Social and Economic Circumstances.
19
There is too much bad judgment here. Jennifer has no understanding of the damage to
20
Lauren that comes from poor choices, such as losingjobs, financial difficulty and domestic violence.
21
Of all the little girls in her soccer teams, soccer camps, school and church, Lauren is the only one
22
whose mother is consistently absent.
23
24
D. .lennifer Mehaddi Does Not Provide for the Financial Support of Lauren.
I have given or loaned money to Jennifer over the course of the last several years. Often it
25
is a mailer of rescuing Lauren from the consequences of Jennifer's financial irresponsibility. I
26
27
CARLJ.GAUL
Attorney at Law
1604 Hewitt Ave.
DECLARATION OF' ANDREW RIF'E Everett WA 98201
PAGE 16 425 259-4147 FAX 259 7081
believe that our daughter Lauren does not benefit from being in a cash-starved home. I have chosen
2 to provide money when the lack of it might adversely impact our daughter.
3 I have paid for a variety of things. I am far from rich, but I do make enough money to pay
4 my bills and put some aside.
5 • My child support, $562 per month, has always been current.

• I pay all Lauren's health insurance
6 • I pay all Lauren's uninsured health care costs.
• I pay I00% of the cost of Lauren's tuition and fees at St. Mary Magdalen school.
7 • I pay all the costs related to Lauren's soccer.
• I arranged to Lauren's Baptism, Confirmation and First Communion and their
8 attendant costs.
• I gave Jennifer $500 for spending money when she went to Florida where her sister
9 then lived.
• I paid for Jennifer's dog to have a knee replacement, $1300 .
10 • I paid $!000 for Jennifer's dog's verterinary bill when he fell sick, and I paid $167
to have him euthanized.
11 • I paid Jennifer's PUD bill to keep eleclricily in her home .
• I pledged my savings account to cover a secured loan to help her get a new BMW
12 because her parents took away her previous BMW and sold it to her sister's
boyfriend.
13 • I loaned Jennifer $150 for groceries early in the year, before her husband arrived .
• I loaned Jennifer and Soulyane another $150, again for groceries .
14 • I have taken Jennifer shopping for lunch items for Lauren because she had no money
because she lost her job.
15 • I have paid the cost of Jennifer's travel to Algeria to visit her then-boyfriend, now
husband.
16
There were times when she asked me for loans to cover her expenses until her next payday.
17
provided those loans. They were informal arrangements between us, and there was no
18
documentation of the loans.
19
I am not concerned with receiving child support from Jennifer. I am submitting a financial
20
declaration and a child support worksheet because the court rules require it. I can afford to support
21
my daughter. I am asking the court to eliminate my child support obligation because there is no
22
reason for me to pay child support to the other parent for a child who resides in my home. I have
23
always paid my child support, and I have voluntarily paid a good deal more than is required because
24
I have chosen to for Lauren's benefit.
25
26
CARLJ. GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 17 425 259-4147 FAX 259 7081
10. BENEFIT OF NEW PARENTING PLAN
2 With me Lauren has a full life with the parent who is involved in all aspects of that full life.
3 Like most third graders, she goes to school providing both academic and religious education, she
4 does homework, she plays, she participates in organized sports, she has friends. I am with her. She
5 relies upon me. I provide her with the love and support and encouragement she needs. With me she
6 is a happy and fully involved child.
7 She has a loving, stable, consistent and nurturing relationship with me. I attend to her daily
8 needs and to her other interests. I help her maintain and develop friendships with her peers.
9 Her opportunities to develop into a productive and happy adult are more certain residing with
10 me than with her mother. The parenting plan should change.

11 11. SUMMARY
12 The sum of this history is that Jennifer Mehaddi is an irresponsible parent. Her
13 irresponsibility is demonstrated a number of ways. I have chosen to rescue Lauren from Jennifer's
14 irresponsible ways.
15 Her irresponsibility is demonstrated by her choices.
16 Jennifer Mehaddi chose to not participate in her daughter's routine medical care and again
17 by her choice to not even stick around for her daughter to get medical care.
18 Jennifer Mehaddi chose to overlook her husband's violence.
19 Jennifer Mchaddi chose to send Lauren to school without lunches.
20 Jennifer Mehaddi chose to have a big screen television and to have her dog groomed, and
21 an expensive car, but to not have money for groceries or gasoline.
22 Jennifer Mehaddi chose to not be attentive to Lauren's clothing, sending her to school on
23
cold days without a coat.
24 Jennifer Mehaddi chose to be uninvolved in Lauren's education.
25 Jennifer Mehaddi chose to be uninvolved in Lauren's sporting activities.
26
CARLJ. GAUL
27 Attorney at Law
1604 Hewitt Ave.
PA13E 1 B 425 259-4147 FAX 259 7081
1 Jennifer Mehaddi chose lo l:ie uninvolved in her daughter's religion.
2 Jennifer Mehaddi chose to leave the special ceremonyofbaptism, arriving but leaving before
3 il was her tum.
4 Jennifer Mehaddi's choices that detrimentally affect our daughter could fill a much longer
5 list. The point is not to detail her failings, rather to demonstrate that it is time to give Lauren a better
6 life.
7
8
on September 30, 2013
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
PAGE 1 9 425 259-4147 FAX 259 7081
ATTACHMENT 1
March 25, 2011 Parenting Plan
.'
FILED
2011 HAR 25 PH ~: 13
SONYA KRASKI
COU~lTYCLERK
I. SNOHOMISH CO. WASH
_/

County of
In re the Parenting and Support of:
No. 05-3-02755·1
Lauren Emily Rife Child(ren)
Parenting Plan
[ ] Proposed (PPP)
Andrew Scott Rife Petitioner
and [ ) Temporary (PPT)
[ x) Final Order (PP)
Jennifer LeSourd "FKA'' Jennifer Rife

Res ondent.
[] the final parenting plan signed by the eourt pursuant to a judgment and order establishing
Residential Schedule/Parenting Plan/Child Support signed by the court on this date or
dated _ _ _ _ _ _ _ _ _ _ _ _ _ __
[x) the final parenting plan signed by the court pursuant to an order signed by the court on this date
or dated __ 11n/2006 , which modifies a previous parenting
[] a temporary parenting plan signed by the court.
[] proposed by (name) _ _ _ _ _ _ _ _ _ _ __
It is Ordered, Adjudged and Decreed:
Lauren Emily Rife 6

QR\G\NAL
Parenting Plan (PPP, PPT. PP)· Page 1 of 10
.•
II. Bases for Restrictions

Under csrtsfn cfrr:umstancss, ss outlined below, the court msy limit or prohibit a parent's
contact with the chiid(ren) snd the right to mske decisions for the chlld(ren).
2.1 Parental Conduct (RCW 26.09.191(1), (2))
[ X) Does not apply.

[] The []mother's [) father's residential time with the child(ren) shall be limited or
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:
[I 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.
[I A history of acts of domestic violence as defined in RCW 26.50.010(1) or an
assault or sexual assault which causes grievous bodily harm or the fear of such
harm.
2.2 Other Factors (RCW 26.09.191 (3))
[X J Does not apply.

[] The []mother's []father's involvement or conduct may have an adverse effect on the
child's best interests because of the existence of the factors which follow:
(] Neglect or substantinl nonperformance of parenting functions.

(] A Jong-term emotional or physical impairment which interferes with the
performance of parenting functions as defined in RCW 26.09.004.
(] A Jong-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 connict by the parent which creates the danger of serious
damage to the child's psychological development.
(] A parent has withheld from the other parent access to the child for a protracted
period without good cause.
[] Other:
Pamntlng P/sn (PPP, PPT, PP) - Page 2 of 10

WPF PS 15.0600 Mandatory (6/2008) - RCW 26.26.375, 26.09.018, .181; .187; .194
Ill. Resldentlal Schedule
The residential schedule must set forth where the chfld(ren) shell reside each day of the year,
Including provisions for holidays, birthdays of family members, vacations, and other spec/a/
Individual needs of their family. Paragraphs 3. 1 through 3.9 are one way to write your
resident/al schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3. 13.
3.1 Schedule for Children Under School age.
[X ] There are no children under school age.

[] Prior 10 enrollment in school, the child(ren) shall reside with lhe [ J mother [ ) father,
cxcepl for the following days and times when the child(ren) will reside with or be with
the other parent:
from (day and lime) to (day and l i m e ) - - - - - - - -

[ J every week [ ] every other week ( ] the first and lhird week of the month [ ] the second
from (day and lime) 10 (day and t i m e ) - - - - - - - -

( ) every week ( ] every olher week [ ] lhc first and lhird week of the monlh [ ] lhe second
and fourth week of the monlh ( ] olher:
3.2 School Schedule

Upon enrollment in school. the child(ren) shall reside wi1h lhe [x I rnolher I J father, except for
the following clays and times when the child(ren) will reside wilh or be with the olher paren1:
from (day and time) Tuesday afler school to (day end lime) Wednesday morning,
dropping child off a1 school. The father shall have residential time every Thursday after school
until 7:30PM returning the child 10 molher's home.
[x ] every week [ ] every other week [ ] lhe firs! and third week of lhe monlh [ ] the
second and fourth week of the monlh [ ] other:
from (day and time) Friday afler school to (day and time) Sunday at 7:00 PM returning
lhe child 10 mother's home.
[] every week [x ] every other week ( ] !he first and lhird week of the month
[] the second and fourth week of the month [ ] other.
Parenting Plan (PPP, PPT, PP) • Page 3 of 10

WPF PS 15.0600 Mandatoty (612008) • RCW 26.26.375, 26.09.016, .181; .187;. 194
: . .
[] The school schedule will Slart when each child begins [ x] kinderganen ( ) first grade
[ J other:
The child(ren) shall reside with the [ x] mother [ J father during winter vacation, except for the
following days and limes when the child(ren) will reside with or be with the other parent: The
residential schedule applies for winter breaks, unless vacation is requested thirty (30) days in
advance by email.
The child(ren) shall reside with the [x ] mother [ ) father during other school breaks, except for
Residential schedule applies, unless vacation is requested thirty (30) days in advance by email.
3.5 Summer Schedule
Upon completion of the school year. the child(ren) shall reside with the [] mother [] father,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
[I Same as school year schedule.

[x I Other: Residential schedule applies, with the exception of Tuesday pick up at 7:30am at
the mother's place of work returning the child Wednesday evening at 7:30pm. Thursday
pick up of child up at the mother's place of work at 7:30am. and retume to mother's
home nt 7:30 PM.
[I Does not apply.

[x ] The schedule for vacation with parents is as follows: Mother and Father will each have
three (3) weeks of vacation per year. Each parent shall submit their vacation request, by
email, thirty (30) days in advance.
Parenting Plan (PPP, PPT, PP)· Page 4 of 10

WPF PS I 5.0600 Mandatoiy (6!2008) • RCW 26.26.375, 26.09.016• . 181;. 187;. 194
The residential schedule for the child(ren) for the holidays listed below is as follows:

Odd/Even/Every) ()dd/Even{Everyl
New Year's Day EVEN ODD

Martin Luther King Day EVEN ODD
Presidents' Day EVEN ODD
Memorial Day EVERY
July 4'" EVEN
Labor Day EVERY
Veterans' Day EVEN <l 1:l 1:::i
Thanksgiving Day EVEN o\)0
Christmas Eve EVERY
Christmas Day EVERY
[x ] For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times): I lam and return the child to the other parent at 7pm the same day.
[] Other:
The residential schedule for the child(ren) for the following special occasions (for example,
birthdays) is as follows:
Odd/Even/Every) ()dd/Even/Everyl
Mo!her's Day EVERY_'-----~
Father's Day
Mother's Birthday_ _ _ __ EVERY_~~~~-
Father's Birthday,_ _ _ __
[] Other:
Parenting Plan (PPP, PPT, PP) • Paga 5 of 10
WPF PS 15.0600 Mandatory (612008) • RCW 28.28.375, 28.09.018, . 181;. 187; .194
3.9 Priorities Under the Resldentlal Schedule
[I Docs not apply because one parent has no visitation or resbicted visitation.
[I Paragraphs 3.3 - 3.8 have priority over paragraphs 3.1 and 3.2 in the following order:
Rnnk the order of priority, with I being given the highest priority:
_ 4_winter vacation (3.3) · _3_holidays (3.7)

_s_school breaks (3.4) _6_special occasions (3.8)
_2_summer schedule (3.S) _ I _ vacation with parents (3.6)
[ x] Other: By agreement
3.1 O Restrictions
[x] Docs not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
[] The []mother's []father's residential time with the children shall be limited because
!here are limiting factors in paragraphs 2.1 and 2.2. The following resbictions shall
apply when the children spend time wilh this parent:
[] There are limiting factors in paragraph 2.2, but there are no resbictions on the
[] mother's [ ] father's residential time with the children for the following reasons:
Transportation costs are included in the Child Suppon Worksheets and/or the Order for Child
Suppon and should not be included here.
Transponation arrangements for the child(ren) between parents shall be as follows: By
agreement of the panies.
The children named in this parenting plan are scheduled to reside the majority of the time with
the [ x] mother [ ] father. This parent is designated the custodian of the child(ren) solely for
purposes of all other state and federal statutes which require a designation or determination of
custody. This designa1ion shall not affect either parent's rights and responsibilities under this
parenting plan.
3.13 Other
ParrmUng Plan (PPP, PPT, PP) - Paga 6 of 10
WPF PS 15.0600 Mandatory (6/2008) - RCW 26.26.375, 26.09.016, .181; .187; .194
3.14 Summary of RCW 26.09.430- 480; Regarding Relocation of a Child
give notice to every person entitled to coun ordered time with the child.
notice must contain the information required in RCW 26.09.440. See also fonn DRPSCU
07.0500, (Notice of Intended Relocation of a Child).
If the move is within the same school disaict, the relocating person must provide actual notice by
If no objection Is ftled within 30 days after service or the notice or Intended relocation, the
relocation will be permitted and the proposed revised resldenUal schedule may be
conflnoed.
A person entitled to time with a child under a coun order can file an objection to the child's
An objection may be filed by using the mandatory pattern fonn WPF DRPSCU 07.0700,
Schedule). The objection must be served on all persons entitled to time ~ilh the child.
Parenting Plan (PPP, PPT. PP) • Paga 7 of 10
WPF PS 15.0600 Mandatory (612008) • RCW 26.28.375, 26.09.016, .181; .187;. 194
If the objecting person schedules a hearing for a date within IS days of timely service of the
IV. Decision Making
4.1 Day to Day Decisions
children.
Parenting Plan (PPP, PPT. PP) - Paga 8 of 10

WPF PS 15.0600 Mandatory (612008) - RCW 26.26.375, 26.09.016, .181; .187;. 194
4.2 Ma)or Decisions
Education decisions CI mother CI father (x ] joint

Nonoi:mergcncy health care CI mother [) fatlier Cx I joinl
Religious upbringing CI mother CI father [x I joint
CI mother [I fa1her CI joint
[] mother CI father CI joint
CI mother CI father CI joint
II mother [) father [J joint
CI mother CI father [I joint
CI mother [] father [J joint
4.3 Restrictions In Decision Making
Ix I Does not apply because there are no limiling factors in paragraphs 2.1 and 2.2 above.
[] Sole decision making shall be ordered to the [ I mother [ ) father for lhe following
reasons:
[) A Ii mi ration on the other parent's decision making authority is mandated by

RCW 26.09.191 {See paragraph 2.1).
(J Both parents are opposed to mutual decision making.
(J One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following crileria:
{a) The existence ofa limitation under RCW 26.09.191;

{b) The history of participation of each parent in decision making in each of
the areas in RCW 26.09.184{4)(a);
{c) Whether the parents have demonstrated ability and desire to cooperate
26.09.184{4)(a); and
{d) The parents" geographic proximity to one anolher. to the ex1ent that it
affecls their ability to make timely mutual decisions.
[] There are limiting factors in paragraph 2.2. but there are no restrictions on mutual

WPF PS 15.0600 Mandatory (612008) • RCW 26.26.375, 26.09.016, .161; .167; .194
·. ." .
V. Dispute Resolutlon
The purpose of this dispute resolution process Is to resolve disagreements about canying out
this parenting plan. This dispute resolution process may, and under some local coutt rules or
the provisions of this plan must, be used before filing a petit(on to modify the plan or a motion
Dispules between lhe panics, other lhan child support dispules, shall be submined 10 (lisl person
or agency):
[l counseling by , or
media1ion by \jd11J11vr. oC 4@.neµ ,iflhis box is checked and

issues or domestic violence or child abuse are present, lhcn lhc court finds lhat the victim
requested mediation, lhat mediation is approprialc and lhal lhc victim is permined 10
have a supporting person present during the mediation proceedings, or
[] arbitration by_ _ _ _ _ _ _ _ _ _ _ _ _ _ __
The cost of this process shall be allocated between lhe parties as follows:
[l _ _ _ _ % molher % father.
based on each party's proportional share of income from line 6 of lhe child support
:K worksheets.
[] as detennined in the dispute resolution process.
The dispute resolution process shall be commenced by notifying lhe other pany by [ ] written
rcquesl [ ] certified mail [ ] 01her:
In lhe dispute resolution process:
(a) Preference shall be given 10 carrying oul lhis Parenting Plan.

(b) Unless an emergency exists, lhe parents shall use the designated process IO resolve
dispuies relating 10 implementa1ion of lhe plan, except those related 10 financial supporl.
and of each arbitra1ion award and shall be provided to each party.
(d) If lhe court finds lhat a paren1 has used or frustraled lhe dispute resolu1ion process
wilhout good reason, lhe court shall award anomey's fees and financial sanctions 10 the
other parent
(e) The parties have 1he righl of review from the dispute resolu1ion process 10 the superior
court.
[] No dispute resolulion process, cxcepl court action is ordered.
Pan1ntlng Plan (PPP, PPT. PP) - Page 10 of 10 ·

WPF PS 15.0600 Mandatory (612008) • RCW 2626.375, 26.09.016, .181; .187; .194
r • . I ...
[] . There are no other provisions.

[ x) There are the following other provisions: Either parent may take the child out of the state of
Washington for the purpose of vacation. The Mother or Father SHALL NOT obtain a passpon
for the child for any foreign travel. The Fallier and Mother shall have first right of refusal if
more than four (4) hours of childcare is required. The Mother agrees to NEVER seek an increase
in child suppon from Father. The Father agrees to pay one roundtrip airline ticket to Algeria, not
to exceed $2,000.00 USO. Only once. If the Mother is unable to travel 10 Algeria, the Father
shall pay the change ticket fee for Mother 10 a-avel to another destination. The Child shall reside
with the Father for two (2) weeks while the Mother's boyfriend from Algeria is in the couna-y.
The Mother shall have visits with the child on Tuesday's and Thursday's from after school until
7:30PM. This two (2) weeks_ iJ onJy when,l~~er's.Jl91Yfriend f!rst 9/jriv?J'), this c9un!!Y . .;,u
s
/}ii .:i AAJ,kJ to )11/!MA a.t /w. n"' ftom p1 o~ 1~01 'fO s:g~ ~J
VII. Declaration for Proposed Parenting Planf//1fl'/ 3pM·iy ~
[x ] Does not apply.
[] (Only sign if this is a proposed parenting plan.) I declare under penal!}' of perjury under the laws
of the stale of Washington that this plan has been proposed in good faith and that the statements
in Part II of this Ian are b'ue nd correct.
Date and Place (City Md State) of Signature

"3/17/11 C'v~. W..
0£a.id Place (City Md S1n1c) of Signature
order of this coun.
Warning: Violation of ri:sidential provisions of this order with actual knowledge of its terms is
RCW 9A.40.070(2). Violation of this order may subject a violator to arrest.
effort to resolve the issue through the dispute resolution process. ·
~fa parent fails 10 comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
MAR 2 5 2011
Dated:~~------------
missioner
Presented by: Approved for ena-y:
Parenting Plan (PPP, PPT, PP) • Paga 11 of 10

WPF PS 15.0600 Mandatory (6/2008) • RCW 26.26.375, 26.09.016, .181; .187; .194
' . . ".; .
Prini Name Print Name

WPF PS 15.0600 Mandatory (6/2008) - RCW 2626.375, 26.09.016, .181; .187;. l!U
ATTACHMENT 2
2013 Residential Time History Calendars
Page I of I
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Andrew Scott Rife and Jennifer Rae Mehaddi f/k/a Rife
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ATTACHMENT 3
Transcript of 911 Call for Domestic Violence
•,
RE: 14200 59th Dr SE, AS, Snohomish

With First call received at 18:S3 HOURS
INCIDENT NUMBER: SL13-134S1S
DISPATCHER: 911 what is your emergency?
CALLER: Um, my husband's violent.
DISPATCHER: What address is this at?
CALLER: 14200 (inaudible) Dr SE, Unit AS, Snohomish 98296.
DISPATCHER: Ok, so that was 14200 five-nine Drive Southeast, Number A as

in Adam-?
CALLER: No, six-nine, six-nine, 59th , six-nine.
DISPATCHER: Okay, and that was A as in Adam Five?
CALLER: Yes.
DISPATCHER: Okay, and so has he been physical with you?
CALLER: He has been in the past and just a bit ago he raised his arm
when he got mad at my eight year old daughter.
DISPATCHER: Okay, but did he make contact or just threaten?
CALLER: No, he didn't actually hit her but I am worried he is going to.
DISPATCHER: Does he have any weapons on him?
CALLER: I'm sorry?
DISPATCHER: Does he have any weapons?
CALLER: No.
DISPATCHER: Okay, is anybody injured at this time?
1
CALLER: No.
DISPATCHER: Can you give me his last name?
CALLER: Meh ... Mehaddi
DISPATCHER: What's his first name?
CALLER: Soufyane.
DISPATCHER: How old is he?
CALLER: 28.
DISPATCHER: Where is he at in the house right now?
CALLER: He's inside in the entry way.
DISPATCHER: Okay, is he white, Black, Hispanic, Asian?
CALLER: He's white.
DISPATCHER: What's he wearing, what color shirt he have on?
CALLER: White pants and a white shirt.
DISPATCHER: Is he going to be combative with officers when they arrive?
CALLER: I don't know.
DISPATCHER: Has he been drinking or doing any drugs, tonight?
CALLER: No.
DISPATCHER: Who is else is in the house right now?
CALLER: Myself, my eight year old daughter, and my dog?
DISPATCHER: Okay, are you and your daughter safe to stay there.
CALLER: At the time being, yeah, I don't know.
DISPATCHER: And he hasn't left or anything?
2
CALLER: I'm sorry?
DISPATCHER: He hasn't left the house?
CALLER: No.
DISPATCHER: Okay what's your last name?
CALLER: Same last name.
DISPATCHER: What's your first name?
CALLER: Jennifer.
DISPATCHER: What's your phone number, Jennifer?
CALLER: 425-330-2503.
DISPATCHER: Okay, alright we have officers advised that you need some
assistance out there and if anything changes or escalates,
before they arrive you need to give us a call back, okay?
CALLER: Alright, thank you.
DISPATCHER: Okay, thanks, bye bye.
3
ATTACHMENT 4
Text Messages
•••-.: Verizor. 3G 2~50 PM @ 59°/o ~
[Ok, we are at my moms )
[And she's in big trouble)

_ ___ :::Z -Ar ----
(For what}.
For her disrespect for

adults (mostly Soufyane)
and for her smart mouth
and language.
~ra~at-,m:akes me mad -
--
d) ( iMcssage
------ ....
~ - ,. - I
) ' ..- '
.
• •
- . J~
It,.~ -- - -- ------ --- -- -- ---~-~',,_' • '', :• _;' -- ~~-'--", ~ - - ' ' I

•••-"Verizon 3G 2:51 PM @ 59°/o ~
It's to the point she isn't

listening. So I've warned
her the next smart or rude
l or disrespectful thing f~om
, her mouth she will be
I standing facing a corner
I
for 10 min
· 1 wiU .§et her straight when

she· comes tonight
She gets worse and worse

I and it's embarrassing and
. shitty. He doesn't act like
her parent but she's
horrible and I've had it.
__ -·- _____ · - _ __.._(_I-will deal w~~h__!_~\_

·~.:::~(t'~!'CS'r.- ..
) S£,nd
J
•••-~ Verizon 3G 2:51 PM @ 59°/o ~
~.,.;ilt~2"i'). ..'t"r'-<:a;- ?' ·A:-:~- '"'"''«11~.(~:=-o" . ~~
.- , Mes.sages '·- ,, e·n·ni ·er' f:eso·~·. ~· . . . Edit =
---- - - - -
She gets worse and worse

and it's embarrassing and
shitty. He doesn't act like
her parent but she's
horrible and I've had it.
l I ·wi·H d:eal with it
You can say what you

, want but she isn't listening
I
or giving him a chance.
j He's nothing but nice to
her. She's going to get
time out and lost privileges
because she isn't
listening.
~.
~-~
"°'' 'nrl..J
'i'_ , ~ I • •.
L -~ - - - - --- --- -- - _,j

I
ATTACHMENT 5
No Response Report from VOA
.· •
•
==========·~===========
Volunteers of America•
WESTERN WASHINGTON
Dispute Resolution Center of Snohomish, Island and Skagit Counties

P.0 Box 839; Everett WA 98206-0839
Everett Office: 425-339-1335 ToU Free: 1-800-280-4770 Fax: 425-259-2110
Skagit Office: 360-542-8488
MEDIATION SCHEDULlNG REPORT
REPORTED BY: RJ
DATE OF REPORT: 0911312013

CASE NUMBER: 1308044
CASE TYPE: Parenting Plan
PARTY ONE: Andrew Rife
PARTY TWO: Jennifer Mehaddi
DATE CASE OPENED WITH SERVICE FEE: 0811312013
DATE AGREED TO MEDIATE

PARTY ONE: 0811312013
PARTY TWO: 0812712013
LAST DATE OF CONTACT

PARTY ONE: 0911312013
PARTYTWO: 0912712013
DATE FEES RECEIVED

PARTY ONE: NIA
PARTYTWO: NIA
SCHEDULED DATE OF MEDIATION: NIA
DATE MEDIATION HELD: NIA
DATE CLOSED: NIA
0 AGENCY DECLINES 0 MEDIATION I NO SETTLEMENT

0 PARTY TWO DECLINES 0 MEDIATION I PARTIAL SETTLEMENT
0 PARTY ONE WITHDRAWS 0 MEDIATION I SETTLEMENT
0 UNABLE TO CONTACT PARTY TWO 0 ADDITIONAL SESSION SCHEDULED
0 FEESUNPAIDBYPARTYONE D CONCILIATED
181 FEES UNPAID BY PARTY TWO 0 RESCHEDULED
D OTHER:
CURRENT STATUS: Open CC: Pany Two

j '
FILED
\lll~Ulllllll~
CL16444763
2Dl30CT-3 PH 4100
::u~trKRASKI
SHIFllMISH ~~~SH

County of
lnre:
fh..,01 ~..., S.....si:t J2,~
Petitioner(s),
and
Declaration of /
O'"'ei ~"'
[Name)
R . l.'ir..eg o ... l
(Optional Use) ·
DCLR
This declaration is made by:
Name: JoM'-'~R.tr/:t~r' - DS/'1

R.
'Age: !j'_'f____________
__
Relationship to the parties in this action: -~"-v"-"p""e::;.;l"_.k'"'"IS"".o"""'------------
I Declare:
Anelj .fr,,.~verilfJ vegoesf.s fo /4 ~ hi's ., tvork
Declaration (DCLR) - Paga 1 o f _

WPF DRPSCU 01.0100 (612006)
,,,• L~'
•
(Anach Additional Pages if Necessary and Number Them.)
correct.
Signed at f'oerer.f' ,[City] WA [State] on 1-1- I~ [Date].
- /JS///
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
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
privacy (although they will be available to all parties In the case, their attorneys,
Declaration (DCLR) - Page 2 of __

WPF DRPSCU 01.0100 (612006)
•,

County of
In re:
fJ, uo(2.~..,, S.....r tt J2, f# 'J - o<- ?<;;S- ~
No. OS"-
Petitioner{s),
and
Declaration of
Respondent( s). [Name]

(Optional Use)
DCLR
Name: JoH"' R &:iR. r;4~V - DS/'1

Age: _ _b_q
____________~
Relationship to the parties in this action: _~_
.....""p~e~r=t.1~rs~o~r
_ _ _ _ _ _ _ _ _ _ _ __
I Declare:
AnJJ Vr!'Dl/er?ffJ Yfgee5f:s fo fle-.r hi5 s- work
) """
Declaration (DCLR) • Page 1 o f _

WPF DRPSCU 01.0100 (612006)
,.
FILED
ZOil OCT -3 PH ~: 00
SSMYA KRASKI
etUlflY 'Ct;El!K
SNCHIHISH CG.·\VASH

County of
No. 05- -r- o-z 7 > >- ".l-

Petitioner(s),
and
Declaration Pl La •
S~l l<i ,.,..,.-t'"""M"
Respondent(s). [Name]
(Optional Use)
DCLR
Name: ___Shelley Pattison_ _ _ _ _ _ _ _ _ _ _ _ _ __

Age: ___43 _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~
Relationship to the parties in this action: Friend_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
I Declare:
1 have known Andrew Rife and his family for over 25 years. I have also had the pleasure of working with
Andy at Snohomish Countv PUD for over 5 years. Andy has always proven to be hard working.
accountable and committed to his family.
Going on 15 years as an employee of PUD. Andy has earned the respect and trust of his manager and
peers. This has allowed him the flexibility to use PTO (personal time offi on short notice. or last minute
notice. to meet the needs of his daughter. Lauren. Andy is willing. able and has proven to respond
quickly when needed.

WPF DRPSCU 01.0100 (612006)
,,
Andy is the parent that makes ·sure general 'maintenance' issues are scheduled and addressed. He
ensures Lauren gets .to the doctor for-well~hild checkups and to the dentist for cleanings and necessarr
1J11••· 111 ,.,. f •• '.J'..l·J.
work. Andy is the parent that volunteers at school and attends school events during and after school
,r
hours. He is the parent that is visible, "He knows the teachers. the school parents and Lauren's friends.
. , .. , I"
He coordinates play dates. and"holts. play dates. allowing Lauren to build friendships and socialize
outside of school. Andy is the parent that drops everything to deliver a lunch when. for one reason or
another. Lauren gets to school without one. There is no doubt that Lauren's needs come first.
Andy is a loving and committed father. He has created a home environment where. in mv opinion.
Lauren feels safe and secure. There is a schedule. there are boundaries and there are expectations.
Lauren knows what comes next and what to expect when she is with her father. Andy provides for
Lauren emotionally and physically. He reads to her. does homework and projects with her. and most
imoortantly. he nurtures her. Andy ensures that Lauren has the proper school supplies. the proper school
attire and is registered and active in activities outside of school. Andy lets Lauren be a kid.
• VC •: 0 ,I, ;•,\ 1 ;_,,.:1,~,
As parents. we are our children's most influential teachers. Andy sets an example for Lauren. He is
financiallv resoonsible and personally accountable. He recognizes the important things in life.:. family.
Andy has the emotional means and the monetary means to provide for his daughter. He has proven. time
and time again, that he understands his biggest responsibility and most important job in life is to raise a
happv. secure child with love.
I am open and available for further questions.

WPF DRPSCU 01.0100 (61'2006)
'
Andy is the parent that makes sure general 'maintenance' issues are scheduled and addressed. He
ensures Lauren gets to the doctor for well-child checkups and to the dentist for cleanings and necessary
work. Andy is the parent that volunteers at school and attends school events during and after school
hours. He is the parent that is visible. He knows the teachers. the school parents and Lauren's friends.
He coordinates play dates. and hosts play dates. allowing Lauren to build friendships and sociali:ze
outside of school. Andy is the parent that drops evervthing to deliver a lunch when. for one reason or
another. Lauren gets to school without one. There is no doubt that Lauren's needs come first.
Andy is a loving and committed father. He has created a home environment where. in my opinion.
Lauren feels safe and secure. There js a schedule. there are boundaries and there are expectations.
Lauren knows what comes next and what to expect when she is with her father. Andv provides for
Lauren emotionally and physically. He reads to her. does homework and projects with her. and most
imoortantly. he nurtures her. Andy ensures that Lauren has the proper school supplies. the prooer school
attire and is re .and active in
'
, ~
. ' ."vities
' '
.-...
outside o
I .
school. An lets Lauren be a ki
As parents. we are our children's most influential teachers. Andy sets an example for Lauren. He is
financially resoonsible and oer50nally accountable. He recogni:zes the imoortant things in life..:. family.
Andy bas the emotional means and the monetary means to provide for his daughter. He has proven. time
and time again, that he understands his biggest resoonsibility and most imoortant job in life is to raise a
happy. secure child with love.
I am open and available for further questions.

WPF DRPSCU 01.0100 (612006)
.·
(Attach Additional Pages if Necessary and Number Them.)
correct.
__ [State) on -~,_/._:i._~+:1_1_3~-- [Date).

__lv_A-
£"Atll-t v L ?;,_.µ.,-sol')
Print or Typ/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
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
privacy (although they will be available to all parties in the. case, their attorneys,
Declaration (DCLR) - Page 3 of _ _

WPF DRPSCU 01.0100 (612006)
f,
FILED
2013 OCT -3 PH ~: 00
1
SONYA. KR ASKI
2 CIUNfY CLERK
SNOlilMISH C9. WASH
3
4
5
6
COUNTY OF SNOHOMISH
8
NO. 05 3 02755 1
9 Andrew Scott Rife
Petitioner, EX PARTE RESTRAINING
10 and ORDER/ORDER TO SHOW CAUSE
(TPROTSC}
12 Res ondent. Law Enforcement Notification, ~ 4.5
Restraining Order Summary:
13
Restraining Order Summary is set forth below:
14
Name of person(s) restrained: Jennifer Mehaddi, Andrew Rife
15 Name of person(s) protected: Lauren Rife, Andrew Rife, Jennifer Mehaddi
16 See paragraph 4.1.
17
KNOWLEDGE OF ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50
.
18 RCW AND WILL SUBJECT THE VIOLATOR TO ARREST. RCW 26.09.060.
19 I. SHOW CAUSE ORDER.
20
It is ordered that the respondent Jennifer Mehaddi 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 relief1 if any, requested in the motion should not be granted. A hearing
21 has been set for the following aate, time and place:
22
23
Date:
'"(~{ty Time: 9:00 a.m.
Place: Snohomish County Courthouse Room/Depanmcnl:
3000 Rockefeller As Assigned
24 Everett WA 98201 Commissione(s Department B or C
25
26 CARLJ.GAUL
27
OR\G\NI. Attorney at Law
1604 Hewitt Ave.
EX PARTE RESTRAINING ORD {TPROTSC) - Page 1 Everett WA 9820 I
WPF DR 04.0170 Mandatory (6/2008) - CR 65 (b); RCW 26.09.060 425 259·4147 FAX 259 7081
1.11
'
1 If you disagree with any part of the motion, you must respond to the motion in writing hcfore the
hearing and by the deadline for your county. At the hearing, the court will consider WRITTEN
2 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
3 commissioner's staff; (3) serve the other party's attorney with copies of your documents (or have the
other party served if that party docs not have an attorney); und (4) complete your filing und service of
document~ within the time period required by the locul court rules in effect in your county. If you
4 need more information, you are advised to consult an attorney or a courthouse facilitator.
5
FAILURE TO APPEAR MAY RESULT IN A TEMPORARY ORDER BEING ENTERED BY THE COURT
6 THAT GRANTS THE REUEF REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE.
7 II. BASIS
8 A motion for a temporary restrainin~ order without written or oral notice to the respondent or that
party's lawyer has been made to this court.
9
III. FINDINGS
10 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
11 as follows:
12 [] Further, the court finds that the nonrequestin11 party is absent and a) is on active duty as a
National Guard member or Reservist residing 1n Washington, or b) is a dependent of a
13 National Guard member or Reservist residing in Washington on active duty. Despite the
service member's or dependent's absence, failure to enter the temporary orders below
14 would result in manifest injustice to the other interested parties.
15
IV. ORDER
16 It is ORDERED that:
17 4.1
18 VIOLATION OFA RESTRAINING ORDER IN PARAGRAPH 4.1 WITH ACTUAL NOTICE

OF ITS TERMS IS A CRIMINAL OFFENSE UNDER CHAPTER 26.50 RCW AND WILL SUBJECT
19 THE VIOLATOR TO ARREST. RCW 26.09.060.
20 The petitioner and the respondent are each restrained and enjoined from molesting or
disturbing the peace of the other party or of any child.
21
Service
22 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
23 agency listed above.
24 Full Faith and Credit
25 Pursuant to 18 U.S.C. § 2265, a court in any of the 50 states, the District of Columbia,
26 CARLJ. GAUL
A llorney at law
1604 Hewitt Ave.
WPF DR 04.0170 Mandatory (6/2008) - CR 65 {b); RCW 26.09.060 425 259-4147 FAX 259 7081
•
'
1
2
3 4.2 OTHER RESTRAINING ORDERS.
4 The petitioner and the respondent are each restrained and enjoined from removing
any of the children from the state of Washington.
6 Does not apply.
7 4.4 EXPIRATION DATE.
8 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.
9
The Court hereby extends duration of this order to the date for hearing set forth in Part I of
this order.
10
11
4.5 WAIVER OF BOND.
12
The filing of a bond or the posting of security is waived.
13
4.6 Other:
14
The Petitioner's Motion for Temporary Orders shall also be heard at the date and time
15 established in Part I of this Order.
16
18
19
20 CARL J. GAUL WSBA

Attorney for Andrew
21
22
23
24
25
26 CARLJ.GAUL
Auorney at law
1604 Hewitt Ave.
WPF DR 04.0170 Mandatory (6/2008) - CR 65 (b); RCW 26.09.060 425 259-4147 FAX 259 7081
FILED
2113 OCT -3 PH Ii: 00
· SSH.YA KftASKI ·
2 . 11,llY.J.Y 'CLEftK
SNOHIHISH CO. WASH
3
5
6 COUNTY OF SNOHOMISH ·
7 In re:
9 Petitioner, NOTICE OF HEARING FOR

and ADEQUATE CAUSE DETERMINATION
OPTIONAL USE)
~
10
Jennifer Rae Mehaddi f/k/a Rife NTHG)
Res ondent. lerk's Action Required
II
TO THE CLERK OF COURT AND TO:
12
Please note that the court will be asked to determine if adequate cause exists to
modify/adjust the custody decree/parenting plan/residential schedule as requested in
the petition filed in this case.
A hearing has been set for the following date, time and place.
ID /-z.j /~of 3 Time: 9:00 a.m.

Snohomish County Courthouse Room / Department
3000 Rockefeller 301 Or 305, As Assigned
Everett WA 98201
This request is based on the declaration in the Petition for Modification/Adjustment of

Custody Decree/Parenting Plan/Residential Schedule and on the additional declarations
served on the nonmoving party.
You may serve and file a response and opposing declarations prior to the hearing date.
If the court determines that adequate cause for hearing the petition is established by the
declarations, it will set a date for hearing on an order to show cause why the petition
should not be granted.
5. If you do not file a response to the petition, opposin .declarations, or a notice of
23 appearance, an order may be entered without furtzotice o you fi ding you in default
and granting the relief requested in the petition.
24
25 Dated: October 3, 2013 .,..,.,~~-~?':,-,.,.,:,==-1:t~1-----

CARL! . GAUL WSBA
Attorney for Andrew S
0 RIG' IN f--'I\ I
26
CARLJ.GAUL
Attorney al Lai~
27 1 · 302 Bank of America Bldg.
NOT OF HRNG (ADEQUATE CA USE) (NTHG) - Page 1 E~~~:t~\~~ 1~:2~ej

WPF DR 07.0250 (912001) - RCW 26.09.260: .270; 26.10.200 425 259-4147 FAX 2591os1
::. ·
"
FILED
1
\l\~l\~ll~l\l~~~\11\\\~~
CL16347780
13 OCT I 0 PH I: 55
SOHYA J. t(RASKI
2 COUNTY CLERK
SNOHOMISH CO. WASH.
3

COUNTY OF SNOHOMISH
7
8 In re:
Andrew Scott Rife
and
Jennifer Rae Rife
11 Res ondent.
12 I DECLARE:
14 2. I served Jennifer Rae Mehaddi (formerly known as Rife) with the following
documents:
15
• a summons and a petition in this action
16 • a parenting plan
• an order to show cause dated October 3, 2013
17 • a notice of hearing for adequate cause determination
• a motion/declaration for ex parte restraining order and for order to show
18 cause
• a declaration of Andrew Rife
19 • a declaration of John Gregory
• a declaration of Shelley Pattison
20 • sealed personal health care records
• sealed financial source documents
21 • financial declaration
• child support worksheets
22 other:
23 3. The date, time and place of service were (if by mail refer to Paragraph 4 below):
24
25
CARLJ.GAUL
26 Attorney at Law
27 1604 Hewitt Ave.
Page 1
ORIGINAL 425 259-4147 FAX 259 7081
.•
,
•ur= ~
1
Date: J-
Time: -+.--=-.;7...w•.z_"°---- a.m ·"\.5'
2 Address:
3
4
4. Service was made pursuant to Civil Rule 4(d):
5
.){- by delivery to the person named in paragraph 2 above
6
7 by deliver to a person of
suitable age and discretion then resident at the address listed in
8 paragraph 3 above.
9
10 5. Other:
11
12
I declare under penalty of perjury under the laws of the state of Washington that the
13 foregoing is true and correct.
14
15 Seo . Romano
16
17
18
19
20
21
22
23
24
25
CARLJ.GAUL
26 Attorney at Lew
1604 Hewitt Ave.
Page 2 425 259-4147 Ff>:Y. 259 7081
F ~ ~~ F:D
13 OCT 11+ AH IQ: 53
2
SONYA J. :;HASKI
3 coUtHY CLERK
SNOl-'i~~'.ISH Cfl. VIASH.
4
s
G

9 In re:
10
II Petitioner,
and Notice of Appearance
12
IBNNIFER MEHADDI
13
(flea Jennifer Rife).
14 Res ondent.
IS
TO: Clerk of the above-entitled Court and
16 TO: Carl Rife, Attorney for Petitioner;
17
YOU AND EACH OF YOU please take notice that Veronica Freitas hereby appears in
18
the above-captioned cause, requesting that all fm1her papers and pleadings herein, except
19 original process, be se1ved upon the undersigned attorney at the address stated below.
20
21 DATED October 10, 2013.

22 Respectfully submitted,
23
24
VERONICA FREITAS, WSBA # 19405
2S Counsel for Jennifer Mehaddi, Respondent.
26
27
28
VERONICA FREITAS
Notice of Appearance 210 Summit Avenue East
Sealtle, Washlngtou 98102
Page I ofl (206) 328-7362
ORIGINAL v@vfrelleslaw.com
..
10/16/2013 14:14 3606685072 HCl.LAND PAGE 04
FILED
2013 OCT 17 PH 2: 51+
2
SONYA KRASKI
3 COUNTY CLERK
SNOHOMISH CO. WASH
11~11~~111m1111moo
4
5
CL16313729
6
7
8
County of Snohomish
9
Inro:
10 No. 05-3-02755-1
AND:REW RIFE,
11
Petitioner,
and Financial Declaration
12
R.espondent
JENNIFER ME.UADDI (lka Jennifer Rite), (FNDCLR)
13 Ro ondcnt.
14 Namo: Jmmifer Mehaddi

IS
L Summary of Basic Infom1at1011
16
Dcolarant's Total Monthly Net Jncomo (from§ 3.3 below) sd.@oc{.I~
17 Dec:la1&nt'a Total Monlbly H0119Chold ExpenReS (A-om § S.9 below)
Dcclanmt's Total Mcntbly Debt &penses (fi'Om § 5.1 I bcloW)
ssOi?la'iJ.
___"&§_ ~
18 Dcclarant'~ Total Monthly Expenses (from § s.12 below) s 3., ooo, ()0
Eatlmaro of the olhcr party's gl'OAR monthly income (from§ 3.lf below) [ l $ /,/JJ, l!i
19 •
20 Il. Personal Information
2.1 Occupation:
21 2.2 The high~ year of educa1lon ccmpletccl:
22 2.3 Are you l?leae!lllY omployod.7 Yes
23 o. Ifyvs: (I) Where do you work. Empl.ayer's namo and address must be listed on rho
Conildendal Inll>nnation FOJJl'I.
24
(1) When did you start work there (monlh/ycar)?
25
26
27
28
VERONlCA FREITAS
V. FREITASJ..AW,l'LLC.
Flnoncil11 Ded0ration (FNDCLR) • Pop I ofJ :uo Summit Avenue Ea•I
WPF DRPSCUOJ.1550 (612006) ·R.CJ'l 26.18.120(1) Seattle, Wathlngtnn 98102
(206) 318-7362
v@vfrtlt•Slaw.com
H!l.LAHD PAGE 05
• 10116/2013 14: 14 3606685072
ffi, Income lnformaClon

2 If o.bild tolpport Is at issuo, complote tl1e Washington Stalo Child Support Worbhoet(s), lklp Paragraphs 3.1 nod 3.2
If malntcnanca, ~ea, costs or debts are at il'SUO and ohild support l• Not an Issue thf• entire section should
3 completed. (Estimate <1f Olhor pal1)''a income lnfimnotion ls optional.)
Otoss Monthly {ncomo
If you are pald oo a wi:ckly "8$is, multiply yuur weekly gross pay by 4.3 to do1Cm1ine your monthly wog
and ~leg, I( yau are pald every two woe~ multiply your gross pay by 2.15. If )'Q1l aro paid tw:i
monlbly, multiply your gross pay by 2. Ifyou are paid ooco a month, li•t that t1111ount below.
Nome
lcnni!!J:.Mehadl ..IbJ/P'filmd 1tt·
a. Wages ond Selaries s:i1 h94011 $ _ _ __
s ____
b. Interest and DMdond [ncomc ss ___
' _ s ____
c. Bu.<incss Income
d. SpoUlllll MotnlellaDcc Received
From $ _ _ __ s ____
$ _ _ __
e. Other Income S _ _ __
c Total Gross Monthly Income (add 110., 3. loihrouah l. Io) $ ~t; m:oD s ____
Actual Gross Income (VeoM0odnlo) S ~~'1,"l;q#J
s ____
g.
Mon1l1ly Deductions From Gtoss lncomc $ _ __
a. Income Thxc• ss.!J!JJ,.fll_
____ $ _ _ __
b. FICNSel!tcmplo)'Tllent Tuxes s ____
$ _ _ __
c. State lodustrlal lnsumnce Deductions $ _ _ __
$ _ _ __
d. Mandatory Union/Professional Dues s ____ $ _ _ __
e. PC11Sfon Plan Payments
$ _ _ __ $ _ _ __
£ Spousal Mnlntcnance l'aid s ____ s ____
g. Nonna! Business Expe11SCS
s ____
h. Total Deductions from Oros.• lnco.mo s l/9l"'
(add lines Ua lfmnish Us)
Monlhly Net lnC01110 (Linc 3.1 f minus lino 3.2h w: $2.Jkdt/,/h s____
line 3 .&om the Child Support Work!<heet(s).)
Miscellaneous Income
a. Child supporl recolvcd from ollter relatlonshlp•
s ____ $ _ _ __
b. Other 111lscellaneous in.coma (Us1 IOlllCG .... amount&)
s____
- - - - - - - - - - - - - - - s ____ s ____
- - - - - - - - - - - - - - - - $ _ _ __ s ___
----------------
_______________ s $____
_ ___ s ____
$ _ _ __
o. Total Mlsccllanooll$ Income (ndd Im H• lhrouth 3.4b) $ _ _ __
s ____ s 11 JAA.15"
Income of Other Adults in Household
If tho Income of either por(y Is dlsputod. <tile =olhly lncomc you believe le correcc and explain below:
VERONICA l'RBITAS
V.FR:EITASLAW,PLLC.
Financial Dedal'Dlton (FNDCLR). P""" 2 ofS 210 Summit Aven11c East
WPP DRl'SCU 01.1550 (612006)-RCW 26./8.220(1) Seattle, Washington 98102
(206) 328-7362
v@vtfellatlaw.com
3606685072 HU.LAND PAGE 06
10/16/2013 14:14
IV. Available Assets

$ _ _ __
2 4.1 Cash on hand
l./(JO. OD
4.2 On dcpO.Ut in bank• sS___ _
J 4.J Stocks and bonds, cash vuluo oflifb insuranco
4.4 Other llquid aaseta:
s ____
4
V, Monthly Expense Information
Monthly c.'penses for m)'!<elhnd .:J.. dependent• ero: (Expcn8e!< •hould bo calcula!£d fbr the tbtu
after separation, based on the anticipoled residential scbedulo for the children..)
7
5.1 Housing
8
Rent, J81 mortgage or con Iracl payments s boo/IJ. oo
9 Installment paymcntf l)Jr other mortgages or encumhranco.• s
Taxes & Insurance (lfnol in monthlypaymont) s
10 Total HoYslng s ~ooo.oo
II
5.2 Utllltles
Heat (gas & oil) $
12
Electricity s L-:3. r;_,o.a
13 Waler, ...wer, garbage s
Telephone $ 15.a. aa
14 Cable S .ilfJ.D· oO
Od!er $
u Total Utllltlos ll ':l..~~.Q!)
16
5.3 Food and Supplle'
17 Food for person• s 3(}0r00
Supplies (paper, tobocco, pets) s ,u;,(J()
18
Meals eaten. out $
19 Olher s
Total Food SUppllcs s ..1;£,oll
20
21
5.4 Children
Day Care/Babysitting s
22 Clothing $
Tu!Uon (ifany) s
23 Other child-related expenses s
Total Bxpcn•es Children s
24
25 5.5 Transportation
Vehicle payments or lea ... s f'JK/11
26 Vehlclo Insurance & Ucenso s ytl.00
Vehicle gas, oil, ordinary mointennnce s ,?(}(), 01'
27 s
l'oddng
28
VERONICA FREITAS
V. FREITAS LAW, PJ~t.C.
Financial Dedannlon (FNDCLR)-Paga S of5 210 Summit A\'lllllle East
WPF DJIPSCU OJ. I SSO (612001J) - RCIY 26.J8.220(/) Seattle, Washington 98102
(206) 328-736:1
v@lfreiUalaw.com
• 10/16/2013 14: 14 3606685072 HDLLllND PAGE 07
Other ln!n"PQrlation expenses $

Total Ttansportation s ....1?,...,~,r.=,"""t""t.-
Health CaTe (Omit If fully covered)
Insurance
Uninsured dental, orlhodontic, medlMI, eye care cxpcn(lef
ss ___
/11(),1()
_
Oahu U11i11&11Rd health expenses $
Total Health Caro s -1=q=f)--=.i""o""
Personal Expenses (Not 1.uducllng chlldTell)
Clotldns $ 5/J,()()
Hair care/personal caro speases s ~.OQ
Clubs and recreation $ _ _ __
Education s____
Books, newspapen, magazines, photos
s ____
Gifts
s ____
Other $
Total Personal Expense. $ --..1.-:!i~,~()(j=
Miscellaneous Expenses
LiJe infUl'anco Qf~ deducted from Income)
s ____
Other _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ $ _ _ __
Otl\cr _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ s ____
$ _ _ __
Total MiscellancouA Expen~
Total Household .EJ<penses (Tho'""" or Pomgroplu s.t tlrough s.BJ
Installment Debts Included In Paragraphs 5.1 Through 5.8

Dcaoription Month of
rJnwmm=t;<>._,,$&¥~1;ep-~~
.....°:_..~.....
oa......,,,V\_ _ B_a1Rn_"_ ~
Other Debts and Monthly Expenses not Included fn Paragraphs S. t Through S.8
Desorlptlon Month of Amannt o

Creditor ill2l!ll Balance Las! Pavment Monthly
sPayment
__--1
s__--1
$ _ _--1
s __--i
s __--1
s__--1
$ _ _--i
VERONICA FREITAS
V. FREITASLAW,PLLC.
Financial Dccfartlllon (FNDCLR) - Page .t of' :no Summit Avenue En st
WPF DRPSCUOJ.JSSO (612006) • RCW 26.18.220(1) Seattle, Waohlngtoo 98102
(206) 328-7362
~vfrelta11a,v.coui
"10/16/2013 14:14 3606685072 HOLLAND PAGE 08
Total Monthly Payments lbr Other Debi~ and Monthly Expense.• s

l
5.12 Total Expenses (Add P11ragraphs S.!l and 5,11) $
3
4 VI. Attomey Fees

s 6.1 Amount paid fbr attorney fees and costs to date: s 3.tQ0{),00
6.2 'Ille source of this money was: ~ ( / 1Ja.n
6
6.3 Fees and costs lnaurred to date: S _g,I fl.d_{J I 00
7 G.4 Arrangemenl81br auomey fees and cosl8 arc:
6.5 Other:
8
I declare Under penaltyo!pcrjucy under tho laws of' the gtate ofWoshlngton that tho fb?egoing Is truo and cmn:cl
9
II
, [City] [State] on JO /!Jr:RIJl.3 [Date].
12
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14
IS
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VERONICA FREITAS
F'fnant:lal Dac/ar()f(Oll (FNDCLRJ •Pase S ofS 210 Swnmlt Avenue East
IYPF DRPSCU 01.JJJO (IJ/2006) • RCW 26.18.220(1) Seacde, Washington 98102
(206) !llS-7362
v@¥freila.'1)aw.com
Fi1·-
1 E~
L,1
2013 OCT 17 PH 2: 53
2
SONYA KRASKI
3 COUNTY CLERK
11!~~!!\l'"
SltOHOMISH CO. WASH
4
s
6
7
8
County of Snohomish
9
Inre:
10
ANDREW RIFE, No. 05·3-02755·1
II Petitioner,
end
12
DECLARATION OF JENNIFER
JENNIFER MEHADDI (fies Jennifer Rife),
13
Respondent.
RTFE IN RESPONSE TO MOTION
FOR ADEQUATE CAUSE AND
14
TEMPORARY ORDER
IS
My name is Jennifer Mehaddi and I am the respondent in this case. I am over 18 years ol
16
17
and am competent to testify as a witness in this matter. I was previously manied to the petitioner
18 Andy Rife end we have one child together, Lauren Emily. I married my husband Soufyan
19 Mehaddi in June of201 l and he moved here in April of this year.
20
I have read Andy's motion and declarations end am very troubled at how he is twisting th
21
tmth and is flat out lying in many areas. Andy would like this court to believe that I simply don'
22
23 care about our daughter anymore and that I would prefer to not spend wiy time with our daughter
24 That is not true. He would also like the court to believe that I have bad judgment and make terribl
2S
decisions for Law'CJl when she is in my care. That is not tme either.
26
Andy is taking advantage of one very stressful day where I called the police and he
27
28
VERONICA FREITAS
Page I ofl7 Senltle, Washington 98102
(206) 328-7362
v@vfreltaslaw.eom
tu med it into two sepw11te incidents of "DV". There was one incident. I dropped Lauren off a
2
Andy's house once, not twice as be claims. There was no "violence". The police came an
3
investigated and no one was arrested because it was just a verbal dispute. I am very sensitive t
4
s DV, probably too sensitive because of being a victim of domestic violence during my marriage wi
6 Andy. I will discuss the DV allegation in detail below.
7 The only legitim11le issue that Andy raised is that we have not been following the curren
8
parent plan. That may support a minor modification. The calendars that Andy provided are not
9
accurate picture of what we have been doing as he has exaggerated many of the days and times Iha
10
11 he ha.~ had her. Andy has badgered me to change the parenting plan since the day we original!
12 entered it. He wore me down over time and I agreed to the first modification. Since then I hav
13
given up minimally more time with Lauren, nowhere near the amount of time Andy claim
14
however. I regret modifying our original parenting and believe that what needs to happen is for us t
go back and actually follow the parenting plan that is currently in place.
16
17 Andy kepi pushing and I finally agreed to adjust tl1e schedule to allow Andy to have on
18 midweek overnight and Thursday to Sunday morning every other weekend. Currently, Andy h
19
Laure11 eve1y other Wednesday to Sunday and Wednesday and Thursday overnight in the off week
20
Andy has really been pressuring me to agree to a 50/50 parenting plan and I have strenuous!>
21
22
resisted because I believe that it is not in Lauren's best interest to reside with Andy any more th
23 she currently does. Andy has Lauren sleep with him in his bed every night she is with him and h
24 requires her to wear "pull ups" at night. He treats her like she is three, not nine.
25
Andy has threatened me over and over and over again that if I don't agree to a 50/50 pla
26
that he will try to take Lauren away from me. I do not believe that it would be in Lauren's bes
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VERONICA FREITAS
Pagc2ofl7 Seattle, Washington 98102
(206) 328-7362
v@•·freltnslnw.com
interest and have lherefore not agreed. He is now following through on lhose threats. TI1ere is n
2
adequate cause lo modify our parenting plan and his pelitio11 and his motion should be denied an
3
lhat we should actually follow our cummt parenting plan.
4
s Background
6 Our divorce was finalized in 2006 after a very lengthy and contenlious period of litigalion
1 During our divorce, Andy was forced to complete Domestic Batterer's Treatment Program. Ou
8
Final Parenling Plan had oul' daughler Lauren residing with me the maj01ity of the lime, include
9
191 rcslriclions against Andy and gave me sole decision making. I think thal it is important for thi
10
II court to be aware of that history. It is inlel'esling that Andy left thal part oul. This motion an
12 petition is a continuation of Andy's abuse.

13
As soon as our divorce case was finalized, Andy began pressuring me about adjusting o
14
parenting plan. I repeatedly told him no, that I did nol wanl to. It was really important to me tha
IS
we have a good working relalionship, so I tried to be flexible with the schedule occasio11ally. Whe
16
17 I did agree to lei Andy have more time, he would make is seem like he was doing me a favor b
18 picking Lauren up or dropping her off. This has become a huge issue because when he does "do m
19
a favor" by picking up Lauren he keeps her way too long. Instead of bringing her back to me, h
20
will make her dinner and do her homework wilh her. That isn't doing me a favor, that is And
21
encroaching into my time wilh her and then trying to say lhat I am not involved.
22
23 Things had been going prelty smoothly between us and he started bringing up modifying ou
24 parenting plan again. I was very resislant to this and said no over and OVCI' again. He continue
25
asking me and told me that we should just enter a new plan lhat reflected the schedule that we h
26
been following. I sought out advice and everyone I asked told me that I should say no to ·
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VERONICA FREITAS
V. FREITAS LAW,PLLC.
Page 3 ofl7 Seattle, Washington 98102
(206) 328-7362
v@vfrellaslow.com
because he really hadn't changed. I was very leery of entering a new pal'enting plan that remove
2
the . I 91 reslrictions against Andy. He promised that things would continue to go smoothly and
3
eventually acquiesced to his constant pl'essuring.
4
I had met my husband online in 201 land was plaruling on going to Algeria to visit him.
6 did not want Andy to try and say that he had more time with Lauren because I was going away fo
1 two weeks so we added the language under section IV of the agreed parenting plan. I also wanted I
8
ensure Lauren's safety while Soufyane was visiting here the first time so I made BJTBngements wit
9
Andy for her to stay with him. It was my suggestion that she stay with Andy for this time. Sectio
10
II IV is very clear that that arrangement only applied during that one two week period when Soufuan
12 was visiting that first time. Andy is now tl'ying to make it look like I was bargaining time with o
13
child for a plane ticket to Algeria. That is preposterous and the thought of that makes me ill.
14
thought that adding that language would protect me. I never considered taking Lauren to Algeri
with me. I didn't use an attorney when we modified our parenting plan. I now wish I had.
16
17 Allegations
18 There is no substnntial change in cireurnstances that result in a detrimental environment ·

19
my home to WBITBnl moving forwal'd with modifying our parenting plan. I am a good parent
20
LaW"en is safe with me. We have a wonderful relationship. I have not "lost interest'' in our daughter
21
1 am a ve1y active participant in her life. Andy is not being truthful and he is only presenting
22
23 portion ofthe facts here. What he doesn't see doesn't exist to him.
24 It is trne that Andy has devoted time, energy and money in our daughter. That is wha
25
parents do. It is not true that I have not done the same. We both do this. Andy is incredibly push
26
and never lets things go. Andy's family is Catholic. Mine is not. It was ve1y impo11ant to Andy tha
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28
VERONICA FREITAS
Pngc4 ofl7 Seallle, Washington 98102
(206) 328-7362
v@vlh!llaslaw.com
Lauren attend Catholic school. It is so important that he offered to pay the entire cost. It i
2
inappropriate for Andy to push for Catholic school, volunteer to pay the costs so that I will agre
3
and then try to besmirch my parenting because I don't pay the Catholic school! That is the thinkin
4
5
of a controlling and abusive person. This should not be used against me.
6 It was also very important to Andy that Lauren participate in the Catholic religion. Again
7 my family isn't Catholic. I have no religious preference. He kept pushing and I finally agreed Iha
8
she could pru1icipate. I had no idea that there was so much involved with being Catholic. I did no
9
know that there would be so many events, practices, classes, ceremonies etc. or I would not hav
10
II agreed. The Catholic Chmch has never felt that welcoming to me and I do not feel comfortabl
12 there. This should not be held against me. Nonetheless, I do attend many of the ceremonies to
13
supportive of Lauren. I did attend her First Commwtlon. Soufyane and I both attended. It was hi
14
first social event in the U.S. as he had arrived just a few days before. Andy is not being truthfu
15
when he says that I have not participated.
16
17 Lauren started playing soccer a few years ago. Andy has always been a soccer fanatic. H
18 went to college on a soccer scholarship and continued to play soccer recreationally until he hurt ltl
19
knee recently. It was realty important to Andy that Lauren play "select" soccer. Select soccer i
20
very expensive, is year round and is a huge time conunitment. I know that Lauren is good at soccer
21
22
but year round soccer is just too much for our nine year old. I do participate with Lauren in soccer
23 but it is not possible for me to pa11icipate as much as Andy does. My work schedule is not
24 flexible as ltls. I was Ullemployed for pm1 of the summer mid I honestly could not afford the gas t
25
drive her to all of the tournaments. This cannot be held against me and is no reflection of Ill}
26
pm·cnting. Lauren does e1tjoy soccer, but she also wants to pursue other interests as well. She
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VEIWNICA FREITAS
DECLARATION 210 Summit Avenue Eost
Page S of 17 Seattle, Washington 98102
(206) 328-7362
v@vfreltaslnw.com
expressed interest in participating in gymnastics, swimming, basketball etc. Each time she is told n
2
because she is in year round select soccer. There are times when she doesn't want to go to socce1
3
practice and weekends that she doesn't want to participate in soccer games. She does have so
4
s friends that do select soccer as well, but there are many others that do not. There are times whe
6 site would like to do things with her non-soccer friends loo. She does not want Andy to know whe
7 she doesn't want to attend soccer. She is afraid that he will be angry and disappointed with her
8
This is another situation where Andy pushes and pushes for something he wants, offers to pay t
9
costs until I finally agree and then wants to punish me for it. This is coercive and controllin
IO
II behavior.
12 Contrwy to Andy's statements, Lauren does not live with him the majmity of the time.
13 is with me the majority of the time. Andy does frequently offer to pick Lauren up for me becnus
14
he gets off of work earlier than me and he wants to take her to her soccer practice. He does he1
IS
homework with her after school and before practice. I do not need Andy to do Lauren's homcwo
16
17 with her during my residential time nor do I need or want him to cook her dinner. He does i
18 because he insists upon encroaching into my residential time wither her. I enjoy cooking and ea ·
19
meals with Lauren and I also enjoy doing homework with Lauren. Andy feeding Law-en and doi
20
homework with her on my days without my permission should not be held against me.
21
I hate to tell Andy this, but when Lauren is with me she refers to my place as "home" an
22
23 she 1'Cfers to Andy's place as "my dad's". This is what many children of split families do. Laure1
24 has two homes. They are both her homes. She feels comfol1able and loved in both homes. She h
2S
her own bedroom at my place. Lauren has friends near my home and she also enjoys clo
26
relationships with my parents, sister and her cousins. She has playdates with friends and neighbo1
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VERONICA FREITAS
DECLARATION 210 Summll Avenue East
Pagc6of 17 Senttle, Washington 98102
(206) 328-7362
v@vfrellastaw.com
when she is with me. Both of our homes hnve value to Lauren. She has roulines at my home that sh
2
is accustomed to. We both have been able to provide Law-en with appropriate housing.
3
I have not been neglcctfi1l of Lauren's medical care. Andy would like this court to believ
4
s that I simply ca!Ulot and have not been able to CBl'e for Lauren. This, again, is not trne. I at
6 including Law-en's medical records under a sealed medical cover sheet. You can see from th
7 medical records that I have gone to mos I of Lauren's medical appointments with her and Ihat I hav
8
been the one to make most of her medical appointments. Andy slates that I hnve gone to none o
9
them. This is auother lie. There is no "custom" that has Andy taking care of ell of Lauren's medica
10
II needs. Andy has taken Lauren to her dentist more often that I have but thnt is because he schedule
12 the next appointment when he is at the dentist and he schedules it in the middle of tl1e day when
13
am not available and he is. Andy works for the PUD as a supervisor. He spends his day drivin
14
around in the area where we live and where Lauren attends school. He is able to lake time o
IS
during the day for appointments when I am working. That doesn't mean that he is a more fit paren
16
11 than me.
18 On June 23n1 of this year Lauren did i1tjurc her wrist when she ran her scooter into a tree
19
She said that her wrist hu1t and I put ice on it. After a little while it still hwt, but there was n
20
swelling or bruising. l decided to take her to the walk in clinic. While we were waiting Lauren
21
22
fine and began behaving very rambw1ctiously. She was having no problem using her wiist whil
23 she was playing in the waiting room. I felt that it was ok to leave the doctor's office. You CBll se
24 ftom the visit notes that the doctor notes that Andy provided 1hnt Law-en was able to use the affcctc
25
area, that there was no weakness, numbness or pnrelyscs of the affected area, but that it had no
26
improved over time.
27
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VERONICA FREITAS
Page 7of 17 Seattle, Wnshlnglon 98102
(206) 328-7362
\'@vfreltaslnw.com
The second page of this medical record reflects that there was no gross deformit}
2
(bruising/swelling), no bony tenderness and nonnal range of motion. When I left the walk in clinic
3
told the front desk person that we would come back if her wrist did not improve. I told Andy abou
4
s the injury when I dropped Lauren off to him. She was with him for a day or two before he took he
6 to the doctor without infomting me. She had been on the trampoline at his house and played socce
7 before he took her to the doctor. I was not ang1y with Andy for seeking medical attention fo
8
Lauren's wrist. I didn't go to that appointment because I was not informed that he had made th
9
appointment. That is ridiculous. I wns in no way neglectftd.
10
ll DV Allegation
12 I nm very sensitive to domestic violence. Any hint of ii and I react. That is because And
13
was very, very abusive to me dw'ing our short marriage. Andy is right that I know about domesti
14
violence and I learned about domestic violence from living with him. He was both physically an
IS
emotionally abusive. There were many times that the police were called and many more times wh
16
17 he would become enraged and would physically assault me that the police weren't called. And}
18 was charged two separate times for being abusive towards me. It was a miserable and volatil
19
relation.ship and I would never put myself in that situation again.
20
My husband Soufyane is not a violent man. He moved to the U.S. to reside with me i
21
22
April, 2013. We have been learning to live together and build our lives together. I lost my job an
23 was unemployed over the summer at the same time as Soufyane was looking for work. Laure
24 really likes Soufyane and enjoys spending time with ltim one on one, but when the three of us
25
together, sometimes she acts out. It is my understanding that this is pretty common when famili
26
are first "blending". Lauren is used to having me to herself. She was being disrespectful Iowa
27
28
VERONICA FREITAS
DECLARATION 2IO Summit Avenue Ensl
Poge8ofl7 Seattle, Wnshlngton 98102
(206) 328-7362
v@vfrellaslaw.com
Soufyane and making sma11 remarks to him.
2
August 7111, the day I called 911, was the last day of Ramadan. Soufyane could not eat
3
smoke cigarettes or even drink waler from sun up to sun down. We had been arguing over !inane
4
s for the past week on and off and we argued about money that day too. Soufyane was not able t
6 look for work during Ramadan which caused him to feel conflicted. This was the first time he ha
7 been through Ramadan alone, with no one else practising with him and eating a meal with him afte
8
sundown. It was a very hard time. I should not have called 911, but I am very sensitive and ma}
9
even be suffering from PTSD from my experience with Andy. I would never permit anyone t
10
II
harm me or Lauren. The police came to the house, but no one was arrested because we were jus
12 having a verbal disagreement.

13
I took Lauren to Andy's to give everyone space. I went to my mother's for a while. Laure
was only with Andy for a day when I picked her up to visit her cousin. I brought Lauren and het
15
cousin back to Andy's because they wanted to spend time together and it was Andy's time to hav
16
17 Lauren. Andy claimed that I dropped Lauren off to him twice after two separate incidents. That i
18 another lie. The incident he describes as the 'first incident' was ao argument that I had wi
19
Soufyane, about finances in the garage. Lauren's cousin was there and saw Soufyane put his hand ·
20
my face. There was not hitting or "bopping" or whatever word Andy used. My niece Alexa tot
21
Andy something and Andy is again ttying lo twist it to his advantage. I never told Andy about Iha
22
23 argument and I never bmught Lauren over afterward and asked him to keep her. That is another lie.
24 Things have gotten much better at home. Soufyane and I have a great relationship and he i
25
great with Laruen. Lauren is not in danger in my home. There have been no incidents of domesti
26
violence in my home. It is difficult to come to a new country and assimilate. It has not gon
27
28
VERONICA FREITAS
DECLARATION 210 Summit Avenue Easl
Page9orl7 Sentlle, Weshlnglon 98102
(206) 328-7362
v@vfreileslaw.com
perfectly, but no domestic violence is occurring. Andy is twisting and manipulating the facts. If h
2
was so concerned about my household in early August, then why did he wait until October to fil
3
his petition to modify and this motion?
4
s Andy is a racist and hates foreigners, especially if they are non-English speaking. This i
6 something that we fought about when we were married. Soufyane is from Algeria and English i
7 his second language. We have been man·ied for two years, and I have been very careful integratin
8
him into my home with Lauren. TI1ey rarely spend any time alone together and when they do it i
9
only for short periods of time. Soufyane works weekends so dming my weekends Lauren and
10
II spend most of our time togetl1er, unless soccer interferes. Soufym1e and Lauren enjoy one another'
12 company. The play sports and video games together.

13
TI1e text messages that Andy provided prove that Lauren can be sassy and disrespectful a
14
times. They also show that I acted appropriately to her behaviour by giving her a timeout. Over th
15
years Andy and I have worked together to parent Lauren. If he was having an issue with her
16
17 would dib'CUSS it and address the issue in both homes for consistency. I would do the same. I wa
18 not aware that Andy was gathering infonnation to use against me so, as we have done many othe
19
times over the years, I infonned Andy that Lauren was behaving disrespectfully to Soufyane.
20
emails show that notlung concerning was going on.
21
22
Andy is right, I do know that pattern of domestic violence. I learned it fonn him. I hav
23 taken steps to make sure that on the rnre occasion that Soufyane and I have argued that Lauren '
24 shielded and protected from that. That should not be held against me. My home is safe and I am i
25
a good relationship.
26
I make less money that Andy does. That does not mean that I am less of a parent. I am
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VF.RONICA FREITAS
Page 10ofl7 Seatlle, Washlnglon 98102
(206) 328-7362
v@vfreltaslaw.com ·
medical assistant working almost full time. I have been unemployed briefly over the past few y
2
and there have been a couple of times that Andy ha~ loaned me small amounts of money. I hav
3
nlways paid him back. It is inconceivable to me that Andy actually puts on paper that he is a bette
4
parent because he can afford more things than I can. I have addressed the Catholic school costs an
6 the select soccer fees above. Public school and recreational league soccer are perfectly fine and ·
7 Andy is going to try and use the fact that these things are so important to him that he is willing t
8
pay the entire costs against me then I suggest we move her to public school and recreational leagu
9
soccer.
10
II I paiticipate Lauren's life and activities. I have not been withdrawing from Lauren's life, bu
12 I am sure that Andy would like me to. Andy doesn't see the things that I do with Lauren when sh
13
is with me. He doesn't think that my time with her is important because we do things that he isn'
14
interested in. I arranged to not work on the first day of school so that I could attend the first day o
IS
school with her this year. Andy suggests Iha! I wn a bad parent because Lauren didn't have a coa
16
17 with her. I would like lo point out that it was September 3111 and it was seventy degrees that doy
18 Not only was a coat not needed, but if it was needed, the coat was with Andy at his house. This is
19
ridiculous allegation.
20
Andy also suggests that I am a bad parent because I frequently forget to make lunch fo
21
22
Lauren. Titls is another lie. I understand that a hungry child cannot leam. That is why I alway
23 make her a lunch. There have been two times that I have made Lauren's lunch and then Laurer
24 forgot to put it in her backpack. Andy is available during the day to swing by the school. I call
2S
him and asked him to do so. I went in to the school to ask them about Andy's allegations that
26
frequently send her to school unprepared, unfed or unkempt mid they didn't know what I wa
27
28
VERONICA FREITAS
DECURATION 210 Summit Avenue East
Page II ofl7 Sent!le, Washington 98102
(206) 328-7362
v@1·frcltnslaw.com
talking about. There have not been repealed caUs to bring Lauren a lunch unless ii has been And
2
that has been forgetting her lunch.
3
Lauren wears a uniform to school. Andy and his family provide the wlifonns. Andy sai
4
that he would pay ell the costs associated with private school that includes the uniforms. I purches
5
6 lots of non-school clothing. I was going to purchase Lauren's first communion dress online, but the
7 Andy's mom decided that she would take her shopping and buy the dress herself. This is anothe1
8
ridiculous allegation and has nothing to do with parenting.
9
Our daughter is a very intelligent, independent and active nine year old who I encoul'8ge t
10
II
start being more self-reliant. Nine year olds are old enough to comb their own hair. Lauren ha
12 beautiful long, thick hair. It is hard for her to wash it and comb it herself. I help her rinse out h
13 hairs during bath/shower time and I help her comb and brush the back of her hair as well. It is t
14
Iha! I don't "give her a bath". She is nine years old now. I send her to take a bath and then I check i
IS
on her and help her with her hair. She practices good hygiene in my home and is always clean an
16
17 presentable. Once at a soccer game, Lauren wanted Andy's mother to put her hair in a ponytail an
18 not me, because she puts the ponytail up higher on her head than I do. The notion that that make
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me less of a parent is again, ridiculous.
20
One of the issues that I have with Andy's parenting style is that he infantilizes our nine yew
21
old daughter.' He still treats her like she is a baby and he does everything for her. She still slee
22
23 with him in his bed when she is at his house. He also makes her wear a "pull up" to bed at his house
24 Titls is very demeaning and insulting to her. She hates it and doesn't ll.llderstnnd why he can't s
2S
that she is a big girl now. Lauren does not have a bed wetting problem anymore and she is ol
26
enough to be sleeping in her own room in her own bed and without a diaper. Andy has told m
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VERONICA FREITAS
Page 12or17 Seattle, Washington 98102
(206) 328-7362
v@vfreltaslaw.com
previously that J am a bad mother because I don't let her sleep with me anymore. Nine year old
2
shouldn't be sleeping with their parents every night.
3
The idea that I have willfully abandoned ow· daughter is so offensive and again, ridiculous
4
s I love Lauren more than anything. I am very involved in her life. I agreed to the Catholic school
6 Catholic religion and select soccer because they were important to Andy and now he is trying to us
7 those activities to try and push me out of Lauren's life. It is not physically possible for me t
8
participate in all of the events that go along with these choices. On my evenings with Lauren
9
soccer doesn't end until 7:30p.m. It is not possible for me to get off of work and get Lauren fed an
IO
II to prnctiee in time so Andy volimtcers to pick her up. I do attend most of Lauren's soccer games.
12 would rather Lauren not do soccer and instead pursue some other interest that doesn't involve
13
many days per week and that has actual seasons. These activities do not mean that I l1av
14
abandoned our child. IL means that she has too many activities. The statement about Lauren bein
IS
the only little girl whose mother doesn't participate is ridiculous. I do participate. I am just no
16
17 obsessive about it.
18 Some of Andy's statements are truly ridiculous. On page sixteen of his declaration at !in
19
16, he states "I teach fiiendship, Jennifer does not." That is ridiculous and l don't even know what i
20
means. I don't know how one would even respond to such a statement. Lauren has friends
21
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school, friends at bis home, friends al my home, friends in soccer and is friends with her cousins
23 She has playdates mid attends events with friends all the time and not just when she is with Andy.
24 Page sixteen, section C of Andy's declarntion shows Andy's true colors. He suggests Iha
2S
losing a job and not making a lot of money are "bad choices". I make less money than Andy, but
26
am not homeless wtd I am not a bad parent because J earn Jess money. He is so critical an
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VERONICA FREITAS
Page 13 ofl7 Seetlle, Washington 98102
(206) 328-7362
••@vfrellnslaw.eom
judgmental. Again, Andy is the one who taught me about domestic violence, not Soufyane.
2
As far as not picking out the first communion dress or attending nil of the church rehearsals
3
practices, ceremonies etc. goes. This is not true. I have not gone to every single thing, but I do go
4
s many of them. Again, I am not Catholic. I agreed that she could be raised Catholic because And
6 kept pressing the issue, but I never agreed to be Catholic myself. This shouldn't be held against me.
7 I am not financially irresponsible. It really is wonderful that Andy hasn't had to wony abou
8
any financial matters, but unfortunately many other people in the world do. Andy does pay chil
9
support and her health insurance premiums. He is court ordered to do so within our child suppo1
10
II
order. He voluntarily pays for Lauren's private school costs and select soccer costs. Andy did pa
12 for my dog's leg surgery and it was about $1,300.00. My dog Remy stayed with Andy when Laure
13 and I were in Disney World. While we were gone Andy caused Remy to tear his ACL and neede
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the expensive surgery. Andy paid for it because he was the one who caused my dog to be irtjured
IS
He did loan me money for groceries while I was briefly unemployed and I paid him back. He
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17 never paid my PUD bill and he has ne\'Cr met me in a grocery store. If I had known that Andy
18 going lo try and punish me for not making as much money as he does, I would have never discusse
19
it with him. My lower income doesn't mean thntl am less ofa parent.
20
Andy is delusional about his relationship with Lauren. We both have value as her parent
21
and she loves both of us. Contrary to what Andy states, she loves spending time in both of ou
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23 homes. She has many complaints about Andy and Andy's home, as all children do. I alway
24 encourage her to try and discuss them with him. Sometimes I offer to help her talk to him and sh
2S
patties and starts begging me to not tell him she told me anytlting. She doesn't like him coachin
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her soccer team, but is terrified that I might tell him. I am hesitant to write this now, for fear that h
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VERONICA FREITAS
DECLARATION 210 Summll Avenue Eesl
Page 14of17 Seallle, Wasl1lngtoo 98102
(206) 328·7362
v@vfrelleslew.com
will get angry with her for divulging anything negative about him. She does not want to play socce
2
so much, but is afraid to tell him. Andy is the parent you sec on the sidelines yelling at their chil
3
the entire game. His yelling upset Lauren. She told him that her coach said that she did not have t
4
s listen to him. She has hem'd him yelling at me on the phone many times and has asked me why h
6 is mean to me.
7 Andy apparently told Lauren that he \WS filing something end that "people are going to b
8
very sad". She has also heard him yelling at me on the phone. Lauren came to me and was vc1
9
upset and worried about the things he was yelling at me. l told her that we both love her ve
10
II much, but that sometimes we disagree on what is best for her. She immediately told me he palm
12 were all sweaty and she became very flushed. She has been very nervous and clingy with me eve
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since.
14
I am including an email that I sent to Andy in September as Exhibit A In this email I a
IS
calling Andy on making agreements and then not keeping his end of the bm'!lain. He did not lik
16
17 having Lauren on Wednesday night and then returning her to me in the morning and then picki.o
18 her up again for his mid-week di1U1er visit. He kept pushing me to get me to agree that he coul
19
keep her on Wednesday night. I eventually agreed, but only because he agreed to return her to me i
20
the morning 011 Sundays so that l wouldn't lose any time with her. We did this for years and the
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right before filing this modification case, he changed his mind to make it look like he has her more
23 That is not the case. It is just Andy bending the truth again.
24 This past Satm'day, Lauren was having a playdate with my sister's children Chase who i
2S
thirteen years old and Alexa who is ten years old while l was gathering up the nece
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documentation to prepare my response to this hearing. My sister Lisa told the children that the
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VERONICA FREITAS
Pago IS of 17 Sentlle, Wnshlngton 98102
(206) 328-7362
v@vfrclteslew.com
..
could.go to.the 7-ll·to purchase.a snack. The 7-11 is three blocks away from her home. Chase an
'
Alexa are good kids. 'It is perfectly safc·for·a tliirteen year olci boy,. an.eleven year old girl and
3
nine year old girl to walk three blocks down the street. While they were wal!dng to~l'Cls the store
4
s Andy pulled up in bis.PUD truck with the-emergency lights on _!llld stru1ed yelling at Lauren fo
6 beirig there: There wa.s notl_1ing wrong with this s_ilualion..Andy's behaviour was .very upsetting t
7 Lauren l!n<! she called me i_n hysterics. I know tlll!i Andy will bring.this up in his shict reply an
8
will twist ii and spin it info one more m;farious story.
9
The court·should not find adequate cause to modify .this parenting :plan. There is ifothin
10
II dangerous or ala1ming going on fu my home. Lauren is in iio more danger at my home than sbe i~ a •
12 Andy's. I havernot wfllfully abandoned otir child and she ha~ not been integrated into Andfs home
13
Andy has filed tliis petition and. this motion_ to punish me for not.agreeing lo a 50150 parenting plan ·
14
Andy'~ O\Yll ~.talemeJ1ls show whai he tliinks of me. I am.Jess·of a parent because I earn less money
IS
.The lasi line of his declaration makes his' opinion pretty Clear. He thinks that Lauren's life.would
16
17 better without me in'il Thatis in no way in Lauren's best itltcrest.. L!iureri l11ves u_s both and w
IS both have much to offer her. We each provide her with _different things. Different but equall}
19
important.
20
Andy's_ proposed parenting plan is ridiculous and should not: even be considered. 'I reques
21
22
that the court deny his motion. We should go back to following:our current pareniing.plan. Tfth
23 colll1 finds there is adequate cause to.move forward-with a modifieation, t~en i_t.should only IJe
24 minor modification so that oilr new parenting plan rellc:ct~ what \ve have .been doing and keeps m
2s
as the primary residential parent. I request that the parenting plan stays as is while .the modil'icatio
is :pe11ding. My borne is safe, nurturing and appropriate for Lauren and she should contintie t
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VERONICA FREITAS
DECLARATION 2io Summit Avenue Ellsl
Page 16of1·7 · · Seattle, Wesi1ing10,n 98102
(206}'328·7362
v@vfrcllnslaw.com
reside with me the majority of the time. I propose that Catherine Nelles Anderson or Christin
2
Wakefield Nichols conduct the evaluation if the court feels it is necessary and that Andy advanc
3
the fees for this. I have included my necessary financial information under seal. Child suppo1
4
should not change at this time.
6 I declare under penalty of perjury pursuant to !he laws of the State of Washington that th
7 contents of the letters are hue and correct to the best of my knowledge
8
9
DATED this 16"' Day of October, 2013 at Everett, Washington.
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VERONICA FREITAS
DECLARATION 2IO Summll Avenue East
Poge 17of 17 Seattle, Washington 98102
(206) 328-7362
\'@vfrellaslaw.com
.,
'••'
EXHIBIT A
,
'
V. FREITAS LAW; PLLC

I I
210SummltAveinie:llast;Seattle, WA.98102' tel• (206)328-7362 fax• (206):32_3-0404
•
•
Amy Pasco
From: jennifermehaddl@comcaslnet
Sent: Sunday, October 13, 2013 10:14 PM
To: Amy Pasco
Subject: Fwd: Lauren exchanges
An email I sent a while back when he refused to bring her back to be at noon, saying 4pm instead when that has
not been our agreement or what we have been following.
Begin fo1warded message:
From: "jennifermehaddi@comcast.net" <jennifermehaddi@comcast.net>

Subject: Lauren exchanges
Date: September 8, 201312:01:46 PM PDT
We agreed a long time ago that you would keep Lauren an extra night dnring the week because
of transportation and her school. I would never have agreed if you weren't bringing her back
earlier on Sunday like we agreed. I remember it very clearly. I said yes to the extra night, BUT I
said only if you bring her back early on Sunday so I don't lose extra time with her. So for the last
several years, we have been doing that. Now you are saying its a lie? You told Lauren without
my consent that she could stay longer and play there? That is not how co parenting works. T
talked with my mom also and she knows and remembers that we had an agreement about Lanren
coming home early.
You are so dead set on getting 50/50 custody and not paying child support that you are jerking
me around and taking control and changing things on a whim to suit you without following our
agreement or even the parenting plan. Do NOT talk to me about soccer, her school fees or the car
loan. That has NOTHING to do with child support or getting more custody.
Since you refuse to bring her back early on Sunday and you are being abusing the conflict and
making your own rules, Thave no choice but to follow the parenting plan as it states exactly. You
will get her I night a week and we can talk about it further in mediation when I can afford to pay
the fee. You will not continue doing this to me, or her.
Also from now on, we will be signing something about what time she is picked up and dropped
off. You have an agenda and it has nothing to do with Lauren.
In a separate issue - the car loan down payment you loaned me nt the credit union will be caught
up in full by mid October. I can only do it in increments. Again, this is a separate issue and has
nothing to do with lauren, the exchanges, custody or child support.
I
16 to testify in this matter. I wrolo the attached letter and I declare under penally of perjury
17
pursuant to the laws of the State of Washington that the contents of tho letter are true and correct
18
to the best of my knowledge
19
20
21 DATBDthill /6#Dayof{Ji~ ,2013.
22
2l
24
!'a ML~ '{f.u{41f
Sign and Printame
25 &r!J I t. f/o//LJltR..
26
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VERONICA FREITAS
Pagelofl V. FREITAS LAW, PLLC.
Seatlle, Wasblnglon 98102
(206) 328-7362
>@vfreltaslaw.com
My name Is Carol Holland and I am Jennifer Mehaddl's mother. Lauren Rife Is very well care by her
mother, Jennifer Mehaddl and her father Andrew Rife. She also enjoys a good relallonshlp with her step
dad Soufyane Mehaddl. I think Lauren Is a very bright and well adjusted little girl that has grown up
living with her mother full time and visiting her father part time.
As a parent and grandparent with three grandchildren I know that people have different parenting
styles. Jennifer Is nurturing and loving with her daughter Lauren. She's a certified medical assistant and
I see how careful she Is with Lauren's health. Over the years I have attended medical appts with Jennifer
and Lauren and also, on occasion taken care of Lauren when she has been home from school sick.
Lauren does not go to daycare during the summer or after school. She alternates with different sides of
the family during summer break. Our next door neighbor has an In ground swimming pool that Lauren
has been Invited to swim In with their granddaughter and our other grandchildren many times. She's
even shown off her swimming ability to Andrew one day when he picked her up from my house. I take
her to school several times a week or her paternal grandmother does. When I pick her up or she Is
dropped off at my house for school she always Is dean and has her school supplies/lunch. On school
picture day this fall she had a fresh bath and her hair blow dried and straightened special by her mother
early In the morning. After school she Is ellher picked up by me, her paternal grandmother, her father
on his residential days or soccer practice days, her Aunt Lisa or her mother. ••Note: over the 3+ years
that Lauren has attended private school she has had a few tardies. I do not know the dates but If that Is
the case and I am responsible on those days the tardy would only be by a few minutes after the last bell.
Many times I have had to drop my other grandchildren off at publlc school on the way to Lauren's
school. Weather, road construction & traffic can cause delays.
From my observation the last few years Jennifer and Andrew have maintained a congenial attitude
regarding Lauren. Just before Lauren's 'If' birthday Jennifer's dog Remy became suddenly ill and taken
to the vet on an emergency. Andy loved Remy and rushed over to the vet's office. Remy was In Jennifer
and Andrew's life before Lauren was born. The dog did not survive and Jennifer and Andy chose to tell
Lauren together at my home. It was a horrible time and the vet bill a $1000+. Andy offered to pay It
though he was refunded the amount because the vet made some errors In treatment. On Lauren's e••
birthday they gave Lauren a big birthday party with her soccer friends. Andy rented a blow-up jump
house and Jennifer provided cake and pizza. My husband and I live on an acre with a huge yard and they
asked to have Lauren's party at our home. We were present at the party.
Andrew has a good Income and can be very generous. He grew up playing soccer and went to college on
a soccer scholarship and I can see that he provides Lauren everything she needs to play soccer. I have
seen him be over focused on her ability to play and calling out to her on the field, yelling at her for her
performance. I have often wondered if he Is look Ing et Lauren like a mini version of him and living his
soccer years again.
I believe Andrew Is not happy that Jennifer Is remarried and Lauren has a step-father as he has
mentioned many times to me and my husband that he does not think It will last. This past summer In a
\
discussion on my front porch about different cultures, religions and how men treat women Andy.told
·me It took him five different tries and five different schools to complete his DV course before he finally
got It 1told Andy that yes, I remember when he went to multiple DV programs. I told Andy that we· as
people cannot discriminate against a religion ..
Jennifer's husband.has been a guest in· our home many, m·any times since he arrived here. He Is always
pollte and helpful. Soufyane comes fr.om a very large family with 10 slblllngs and has dozens of nephews
and nieces. He"s an active guy. and Is good ~t playing sports &)(box with not on_iy Lauren but our other
·two grandchlldreri. I've never seen him be rude or mean to anyone.
On Ftlday, October 11'" I stopped in at Lauren's school to pick up documents In a sealed envelope for
Jennifer at her request. Whlle waiting for the envelope AndreW's father Jim Rife came In and stood
behind me In llne at.the reception window. Jim told me that he wanted my husband and I to know that
he was not happy \YI.th \Yhat Andrew was doing and said he told his son he would not be Involved. He
wanted to see Lauren's parents Bel along. When the envelope.was handed to me·Jlm said he was at the
school to pick up the same thing.
This has been Lauren's weekend with h_er mother Jennifer, I've seen them together several times In the
last couple of days and Lauren has been particularly attache_d to her mother.· She usually Is sharing a
chair wlth'her mom or hanging on her but this weekend she was sticking to her like glue. She senses the.
stress. I love my daughter and my granddaughter very much arid I kriow Lauren loves her mother ~~d
her fat!Jer both very much •.
Tod_ay Is Monday, October 141• and Jennifer's residential day. I plcked Lauren up from sch()ol and also
my othe.r gra~ddaughter and on our way home Lauren says guess what? I, and I said what?, then. Laur!m
says she was busy doing her math ·in class when she looked up and saw her Dad lookIng at her through
the door to her classroom. I tho11shi she was pretending so I sald,-.''Leuren what would your Dad be
doing afschool" end she said he d11es It a lo.t just comes to the school to look at her''. She said when
.she looked up at him he looked back and left. This Is weird, If he wanted to know If she was In school all
·he has to do Is make ii call. The school yard a.nd bulJdlng !Ire secured so there are no safety Issues;
The sudden declaration of Anllrew Rife thai)enrilfer Is unfit and neglectful as a parent IS not only
.Inaccurate It Is uncalled for. Andy. has been pushing and pushing Jennifer to agree to:glve him more time
with. Lauren. His pushing hes turned In-to.threats to Jennifer that he wlll irv and take.Lauren away from
her. That seems to be ex_e_ctly :what he Is doing. He didn't g_et his way and now he Is punishing her.
As I'mentioned above, Andy makes a good IMng and can bevervgenerous financially. He wanted
Laurent to _go to private sChool end agreed to pay all of the costs associated with that. He also wanted
Lauren to play select soccer which Is very expensive and time consum.lng. He.also agreed to pay all the
costs associated with that too. That doesn't mean that he Is a better or a more flt parent. It just means
that he has more money, I have.read his deciaratlon and the things that he.wrote are cr!Jel. e~d untr.ue
and they show that Andy reallv ha~ no respect for Jennifer as Lauren's mother. His statements also
·Show that he has'no real understanding ofY'!hat Is In Lauren's best Interest. Jennlrer·ls a wonderful,
.attentive and Involved.mother.
'
1a/16/20i~ 13:~8 .3606685072, PAGE 01
...
F ll_'E D
"
2013 OCT I 7 PM 2: 54
'SO!'YA KRASKi
COUNTY CLERK
SNOHOHISH'CO:'VIASH
II ANDREW RIFE; No. 05"3-017SS-l

Petitioner,
12 and D.J,clara,t1on of
13 ~t!Jlkfi.t thl.. f&.h1.lj ,'
JENNIFER MEHADDI (:ftca Jennifer Rife),
14 Res onderit.
ts My name is .:i!J.,.fymte M !fi . lam over 18yearsold and ameompetent

16
to testi(Y in this matter. I wrote the attached letter end I declare under penalty of P,erjury
17
pursuaolfo the laws oftbe State of.Washington that the contents oftbe letter are true and correct
18
to, the, best of rny,knowicdge
19
20
21 DATBD;this ~Day of oc/ofw, 2013.
2l
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Sign and Print Name
lS
~u+w-~
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27
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VERONICA FREITAS
Pagel nfl V, FREITAS LAW, PLLC.
2fl>'Summlt AVllnuo East,
Seattle, W'!Shington98t02
(206) 328-7362
v@vfl'cltaslaw.co111,
• 10/16/2013 13:28 3606685072 HU.LAND PAGE 02
My name is Soufyane Mehaddi. I am Jennifer Mehaddi's husband. Jerutifer and I

have been married since 2011. I have known since before I came to live here that
Andrew Rife is not a kind person. He loves Lauren very much but doesn't see how
he hurts her by the things he does. He is not nice to Jennifer and is rude and
threatens her that he will take away Lauren from her.
One time in the middle of July this year Jennifer and I went to pick up Lauren from
Andy. He wasn't there yet and he texted Jenn to come back at 4:00pm. When we
came back he had his mom there and he started arguing with Jenn. I asked him to
stop and calm down and he said that I should stay out of it because I have no
business. He was yelling that he wants 50/50 time with Lauren and that Jenn
should sit and nicely agree with him but if not then she will be sorry. Andy's mom
then was saying"No not now. Not now." l asked Jenn to get in the car so we could
go. He said that Jenn's parents should get out their checkbooks because he was
going to take her to court if she didn't agree. That is what he is doing now.
When I first came to America Jenn and I had a hard time. It is difficult to come to a
new country. We have worked very hard on our relationship and are able to work
through problems. When we were arguing the time that Jenn called 911, I would
not have ever hurt her or Lauren. We do not argue in front of Lauren at all
anymore. After this fight I apologized to Lauren and told her that I care very much
about her and that I wouldn't do anything to hurt or upset her.
Andy is too obsessed with Lauren playing soccer. She is a nine year old child but
he acts like she should be professional. He take the fun out of it for her and gets
angry if she doesn't pay attention at the game or if she doesn't play as good as he
thinks she should.
My wife is a good mother. She cooks for Lauren and spends tirne with her. She
gives her baths and combs her hair. She makes her lunches and dinners makes
sure that Lauren is always is presentable. Andy loves Lauren but his opinion of
Jenn is not good for Lauren at all. She loves both her parents very much.
I have a good relationship with Lauren too. We play basketball and soccer together
and we challenge each other on the Xbox playing games together. There are times
where Lauren can be rude to me and irritable, but I am patient with her as I know
moving here and living here as been a change for her. She is used to a lot of time
alone with JeJUl and gets jealous. I see Jenn spend a lot ofprivate time with Lauren
and do her best to reassure Lauren that she loves her and tell her how important
their relationship is and how it will not change.
There is nothing wrong with Jenn and there is nothing wrong with our home. We
don't h~~/ch money as Andy does but Jenn is still a good mom.
Soufy~ehaddi
HCLLAND PAGE 01
10/1&/2013 14:14 360&685072
FILED
ZOil OCT 17 PH 2: 5~
2
SONYA KRASKI
3
4
11~~~11~~~1111~~
CL16313731
COUNTY CLERK
SllOHOHISH CO. WASH
7
Superlol' Court of Washington
8
County of Snohomish
9
In re:
10
ANDREW R.IFE, No. 05-3-02755-1
11
Petitioner,
12 and
13 JBNNIFER MEHADDI (flea Jennifer Rife),
14
R· ondent.
lS My name is : l.A' (a J./ollMol . I am over 18 years old and am competent

16 to testify in this matter. I wrote the ettaohcd letter aod I declare under penalty of perjury
17
pursuant to the laws ofthe State ofWashington that the contents of the letter are true and com:ot
18
to the best of my knowledge
19
20
21 DATED this .ili!!:.oay of Qt./o/v.r., 2013.

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VERONICA FREITAS
Page I of I V. IIREITAS L~W, PLLC.
210 SnmndtAvenue East
Seattle, WashlngtDtt 98102
(206) 328-7361
v@vfrcltaslaw.com
i'B/16/2013 14:14 3606605072 HClllAND PAGE 02
Declaration of Lisa Holland
My name is Lisa Holland and Jellllifer Mehaddi is my sister. Lauren Rife Is my niece. I am
writing this declaration in regards to the current custody dispute between my sister and her ex
husb1111d, Andrew Rife.
When J learned that Andrew filed this motion to take primary custody away from my sister, I
was shocked aud disturbed. I've read the paperwork and his reasons fur wanting to change the
parenting plan arc not only false, but completely bizarre. Jennifer and Andy have effectively co-
p8Ill11ted for years and I believe this attempt to Chllf.18e things is another bullying tactic that's
reminiscent of their divorce. He's taking advantage of her financial situation and the :fitct that he
lllakes more money. I do not believe for a single second that his reasons for doing tbls are
genuine or sensible.
Andy is vr:ry effective at manipulating people and garnering infullll8tion to later on twist the
facts and use it against people. His previous DV coul'Ses and participation speak volumes. Our
family had slowly begun trusting Andy again for Lauren's sake and this recont filing on his part
is both saddening and scary. Jennifer and Andy have effectively co-parented for many years and
there is absolutely no need fot this custody battle. It's simply Andy fighting fur oontrol again.
I spend ample time around my niece, my sister, and her husband, Soufyane Mehaddi Law:en Is
a very happy and well adjusted child. Her every day needs are fulfilled and she receives all the
support and love she needs from her Mother and Stepfhther. Lauren bas always had a vezy close
bond with her Mother. Telclng Leuten away from her Mother would damage this bond and be
devaatating to both mother and daughter.
It's taken some 1bne to get to know Soufyane, Jennifer's husband, but it's happening and he's
proving to be a kind p61'Son with a good work ethic and 11 true fondness ibr Lauren. When he
firsl moved here, It seemed to be a little stressful for hlm and Jennifer as he was adjusting to a
new culture and new home. Thbigs are only getting better and he's becoming a regular part of
the famlly. He participates In and contnl>utes to family events. Blll.llding families is a difficult
lask for any0ne. Jennifer has been making this happen with care and patience.
Over the years, Jennifer has taken Lalll'Cl1 on a couple of trips to visit my kids and [ when I lived
in Florida, taken her on several weekend trips to Lake Chelan and participated in school and
sporting events. At times, her work schedule has interfered in some oflhese activities, but that is
to be expected. Andrew seems to have a much more flexible schedule than Jeonifilr and it's
ftustrating that he is tuming that fact around to try and use against her. Jennifer is working hard
to support herself and her film.ily.
Lauren is not abused or neglected in any way by her Mother. The accusation on Andy's part is
absurd. The only abuse here is Andy going after Jennifer, yet 11gain, with over the top
accusal ions.
.., 10/16/2013 14:14 360_6~85072 HCl..LAHD PAGE_ 03
I believe it-is ii) Lauren~s best.lnforcilt to kec:p primary custody.with my Sister.
IM!t!M~
Lisa Holiand
("
FILED
2013 OCT 24 NI II: 52
SUPERIOR COURT OF SONYA KRASK!
WASHINGTON ~ COUNTY CU'RK
FOR SNOHOMISH COUNTY ·'1'0Hll.'11Sii co~·l'/..'.S~
ANDREW S. RIFE CAUSE NO. 05-3-02755-1

AND CLERK: LISA WHITE
DATE: 10-24-13 @ 9:00 AM
JENNIFER R. RIFE NKA MEHADDI DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: SHOW CAUSE; ADEQUATE CAUSE

HEARING DATE SET/TIMF./CALF.NDAR CODE: 11-13-13 @ 10:30 AM/ (CG)
ACTION: COMPLIANCE HEARING
PETITIONER APPEARED: YES COUNSEL: CARL J. GAUL, I I I
RESPONDENT APPEARED: YES COUNSEL: VERONICA A. FREITAS
DOCUMENTS FILED:
ORDERS ENTERED: ORDER APPOINTING GUARDIAN AD LITEM ON BEHALF OF MINOR; PARENTING

PLAN TEMPORARY; ORDER RE ADEQUATE CAUSE {MODIFICATION/ADJUSTMENT
OF CUSTODY DECREE/PARENTING PLAN/RESIDENTIAL SCHEDULE);
SUPPLEMENT ORDER APPOINTING GUARDIAN AD LITEM AND SETTING
COMPLIANCE HEARING TO BE FILED BY COUNSEL GAUL
RESPONDENT ACKNOWLEDGES SERVICE OF THE PETITION AS WELL AS THE OTHER

DOCUMENTS FILED FOR THIS HEARING.
THE COURT FINDS THAT A SUBSTANTIAL CHANGE OF CIRCUMSTANCES HAS OCCURRED. THE
PETITIONER SHALL HAVE ONE OVERNIGHT EVERY WEEK AND ALTERNATING WEEKENDS FROM
WEDNESDAY TO SUNDAY. THE CHILD SHALL RESIDE PRIMARILY WITH RESPONDENT. THERE
SHALL BE NO .CORPORAL PUNISHMENT USED ON THE MINOR CHILD BY EITHER PARENT.
THE COURT SHALL APPOINT A GUARDIAN AD LITEM ON BEHALF OF THE MINOR. THE ISSUE
OF A DETRIMENTAL ENVIRONMENT IS RESERVED. THE GUARDIAN AD LITEM FEES SHALL BE
PAID PURSUANT TO THE PERCENTAGES IN THE LAST ORDER OF CHILD SUPPORT SUBJECT CJq
TO LATER REALLOCATION.
f.11T
1 MINUTE ENTRY
2.20
..f
FILED·
130CT2li AHll:lt2
SOHYA J. KRASKI
COUHTY CLERK
1,1,m11~m1~II1111///~~
CL16311597
11/111~~1//I SHOHOHISH CO. WASH.

County of Snohomish
Order re Adequate Cause

(Modification/Adjusbnent of
Petitioner,
Custody Decree/Parenting
Plan/Residential Schedule)
[ ]' Denied (ORRACD)
':1:1( Granted (ORRACG)
Respondent. [}-Hearing set (CRH)
Clerk's Action Re uired
I. Basis
I.I A petition requesting the modification/adjustment of the custody decree/parenting

plan/residential schedule in this matter has been presented to the court.
1.2 A hearing was held on h) { """2. f {Z.O I 3 [Date].
II. Findings
The Court Finds:
2.1 Jurisdiction
This court has jurisdiction over the proceeding and the parties.
2.2 Service on Nonmoving Party
The nonmoving party was served with a copy'·!lfthc petition for modification/adjustment of
custody decree/parenting plan/residential che' ule.iisummons, a proposed parenting plan, and
child support worksheet, if any, on ID ""/ r~i:'.)'I ;:. [Date].
. <, d{/lJ
J,,,_') /1/:l
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 1 ef43 /•;1 fl
WPF DRPSCU 07.0300 Mandatory (712007) - RCW 26.09.260; .27(1, ~~';~?'ifJ
'>
2.3 Time Elapsed Since Service on the Nonmoving Party
l'1 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 h_as not responded and is in default.
2.5 Adequate Cause Finding
[] Adequate cause for hearing the petition has not been established.
H. Adequate cause for hearing the petition has been established.
[] The parties stipulate that there is adequate cause for hearing the petition.
2.6 Servicemembers Civil Relief Act Statement
2.6. I Service member status -- It appears the nonmoving party:
Ii(( 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.
2.6.2 Dependent of a service member status -- It appears the nonmoving party:
M is not a dependent of a resident of Washington who is on active duty and is a

[] is a dependent ofa resident of Washington who is on active duty and is a National
Guard member or a Reservist;
[] is presumed not a dependent of a resident of Washington who is on active duty and is
a National Guard member or a Reservist.
Ill. Order
It is Ordered:
[] The petition is denied .
.{ci The matter is set for hearing or trial at the date or time established or to be established.
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 2 of 3

_,
.
. . '
.
[] The matter is set for hearing or trial at:
Date: Time: _ _ _ _ _ _ _ _ _ _a.m./p.m.

Place: Room/Department: - - - - - - - -
[] The ·nonmoving party is in default.
[] Other:
(
Signature of Party or L Signature of Party or Lawyer/WSBA No.
~( ~ . &,a_.._._l
Print Name Print Name Date
/\/\ A--:=
Signature of PartY or Lawyer/WSBA No. I'\ <t".S- Signature of Party or Lawyer/WSBA No.
\bro NJ;,,
•
-f"~ I 0{2yl1!.
Print Name Date Print Name Date
Signature of Party or Lawyer/WSBA No.
Print Name Date
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 3 of 3

FrLE'D
130CT21+ AHll:l+2
SONYA J. KRASKI
COUNTY CLERK
I'11Wlll~Wll~~I~iil~I~IIf~l l lI~I
SNOHOMISH CO. WASH ..
CL 16311596
Superior Court.at.Washington
County of Snohomish
(4 In re the Marriage of:
[ ] In re the Domestic Partners~ of:
~4<.U <i'~ \C.~-1-tL No. o~-::i -02r ' i 5- J
Petitioner, Parenting Plan
;~:~~~
roposed (PPP.).
emporary (PPT)
~t..._ R":- k Res ondent.
inal Order (PP)
[] the final parenting plan signed by the court pursuant to a decree of dissolution, legal
separation, or declaration concerning validity signed by the court on this date or
datecr
--------~·
[l the final parenting plan signed by the court pursuant to an order signed by tbe court on
this date or dated which modifies a previous parenting
a temporary parenting plan signed by the court.
proposed by (name) _ _ _ _ _ _ _ _ _ _ __
It Is Ordered, Adjudged and Decreed:
Lo..~ ~ ~~!L- \Ui~

-L ,~·.k
? (_f~'?J]
!;.) .!/A
Parenting Plan (PPP, PPT, PP) - Page 1 of 11 ' ( '/ :.~9
WPF DR 01.0400 Mandatory (612008)- RCW 26.09.016, .1Bt')Blj .~94
"'~:·' /
t,,,/,/;
<'
~
II. Basis for Restrictions
2.1 Parental Conduct (RCW 26.09.191(1), (2)) ~c;, L.(.1-e_ J

[] Does not apply. ~~
[] The etitioner's [] respondent's residential time ~e child(ren) shall be limited r
restrained pletely, and mutual decision-making and designation of a dispute
resolution proc other than court action shall not be required, because [] this parent
[] a person residing · h this parent has engaged in the conduct which follows:
[] continues for an extended period of time or substant

refusal to perform parentin nctions (this applies only to parents, not to a
person who resides with a pare
[] Physical, sexual or a pattern of emo
[] A history of acts of domestic violence as fined in RCW 26.50.0 I 0( I) or an
assault or sexual assault which causes grieve
harm.
2.2 Other Factors (RCW 26.09.191(3)) \:?...e..s-Lt"./..L--J_

[] Does not·apply.
[] The [] peti "oner's []respondent's involvement or conduct may have an adverse effi
on the child(r 's best interests because of the existence-ofthe·facturs"which follow:
[l Neglect ors tantial nonperformance of parenting functions. /)~6

[l A long.term em · nal· o~ physicaJ ..impairment.which-interferes-with the '-"/'
performance of pare · g functions as defined in RCW 26.09.004.
[l A long-term impairment ulting from drug, alcohol, or other substance abuse
that interferes with the perfo ance of parenting functions.
[l The absence or substantial impa ent of emotional ties between the parent an
child.
[] The abusive use of conflict by the pare which creates the danger of serious
damage to the child's psychological deve ment.
[] A parent has withheld from the other parent a ess to the child for a protracted
period without good cause.···
[] Other:

WPF DR 01.0400 Mandatory (612008) - RCW 26.09.016, .181; .187; .194
'
The residential schedule must set forth where the child(ren) shall reside each day of the year,
to create--a-residential schedule ..that·meeis the developmental-needs-of lh~ child(ren) and
individual needs of their family. Paragraphs 3.1 through 3.9 are one way to write your
Paragraph 3. 13.
3.1 Schedule for Children Under School Age
There are no children under school age.

Prior to enrollment in school, the child(ren) shall reside with the [] petitioner
[] respondent, except for the following days and times when the child(ren) will reside
with or be with the other parent:
from (day and time) _ _ _ _ _ _ _ _ to (day and time) _ _ _ _ _ _ __
[] every week []every other week []the first and third week of the month
[] the second and ·fourth·week of the month· [ ]'other:
from (day and time) _ _ _ _ _ _ _ _ _ to (day and time) _ _ _ _ _ __
[] every week [ ] every other week [ ] the first and third week of the month
3.2 School Schedule
Upon enrollment in school, the child(ren) shall reside with the [ ] petitioner
'14_respondent, except for the following days and times when the child(ren) will reside with or be
with the other pare~\Jc....l "f ...p~ S ._!-.,a I io &ror o/J .d- -l: .;..,/ ..... Fl,,•..'!' .,,.:Z
from (day and time) to (day and time) '"'"1 ·
.... .. ~- ........,,. • ,.., """""' s u.. •• 1 h &.,;. ;u CJ s;:. lk.1 -i'....'t/&If
[] every weekii<J every other week [] the first and third week of the month ~.... j _
c-..i. q Her s. .. '-.io I

From (clay and time) J Th .,.. .,?'1 4'•to (day and time)
-=t!' f'r\otv J "7 t'Y\Y,.,,._;,,
)r.:.f ~ .U- s c.ho.,[ · I
[] every wee~every other week [ ] the first and third week of the month

WPF DR 01. 0400 Mandatory (512008) - RCW 25. 09. 015, . 181; . 187; . 194
[] The school schedule will stan when each child begins [] kinderganen [] first grade
[ ] other:
The child(ren) shall reside with the [ ] petitioner [ ] respondent during winter vacation, excep
for the following days and times when the child(ren) will reside with or be with the other paren ·
s~ ~ ~ ~ (-z-..., f '2...011
~~~
The child(ren) shall reside with the [] petitioner [] respondent during other school breaks,
except for the following days and times when the child(ren) wilt reside with. or be with the ot er
parent:
3.5 Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the []petitioner
[ ] respondent, except for the following days and times when the child(ren) will reside with o be
with the other parent:
~ Sarne as school year schedule.

[] Other:
[l Docs not apply.

[l The schedule for vacation with parents is as follows:
s~ ~ ~ ~j"Z-t?(L.oll
,~~~
WPF DR 01. 0400 Mandatory (612008) - RCW 26. 09. 016, . 181; . 187; . 194
The residential schedule for the child(ren) fo~ the holidays listed below is as fo~lows:
~~ 0.....,, 't......... ~ ( v=;,(-z.l>(( 4..... ~
With Petitioner r With Respon t
(Specify ;year • (Specify Year
Odd/Even/Every) Odd/Even/Everv)
New Year's Day

Martin Luther King Day
Presidents' Day
Memorial Day .
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
[] For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
[] Other:
The residential schedule for the childzr n) for the following special occasions (fi~r
e pie,
birthdays) is as follows: _ ""3 ~ l-z_u[( , Q.__.
~ ~ ~ ilh Petttioner With Res dent
(Specify Year (Specify ear
Odd/Even/Every) Odd/Even/Every) _
Mother's Day
Father's Day
[) Other:

3.9 Priorities Under the Residential Schedule
Does not apply because one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
[] Rank the order of priority, with 1 being given the highest priority:
J winter vacation (3.3) 3 holidays (3.7)

:£:school breaks (3.4) Ispecial occasions (3.8)
~mmer schedule (3.5) _J_vacation with parents (3.6)
[] Other:
3.10 Restrictions
':;rf Does not apply because there are no limiting factors in paragraphs 2. I or 2.2.
[] The []petitioner's [] respondent's residential time with the children shall be limited
because there are limiting factors in paragraphs 2.1 and 2.2. The following restrictions
shall apply when the children spend time with this parent:
[] There are limiting factors in paragraph 2.2, but there are no restrictions on the
[ ] petitioner's [] respondent's residential time with the children for the following
reasons:
Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Transportation arrangements for the child(ren), between pareni shall be as follows:
<$"~ ~ i.:..... ~/-z-? LQ ( '
1~f£2-
___ Cf'1;,.,
The children na~din this parenting plan are scheduled to reside the majority of the time with
the []petitioner espondent. This parent is designated the custodian of the child(ren) solely
for purposes of.a I other state.and federal statutes which require a·designation·or·determination of.
custody. This designation shall not affect either parent's rights and responsibilities under this
parenting plan.
3.13
3.14 Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child
If the person with whom the child resides a majority of the time plans to move~ that person shall
personal service or by mail reqµiring.a return receipt. This notice. must.be.at.least 60 days before
07.0500, (Notice oflntended Relocation of A Child).
lfthe move is within the same school district, the relocating person must provide actual notice by
any reasonable means. A person·emitled to time·with·lhe·child·may·not·objectto·the-move but
Notice may be delayed for 21 days ifthe relocating person is entering a domestic violence shelter

WPF DR 01.0400 Mandatory (612008)- RCW 26.09.016, .181;. 187; .194
If infonnation is protected under a court order or the address confidentiality program, it may be
withheld from the notice. ·
Failure to.give-the required.. notice may be grounds for sanctions; including contempt.
confirmed.
A person entitled to time with a child under a court order can file an objection· to the child's
relocation whether or. not he or she received proper notice ..
An objection may be filed by using the mandatory pattern fonn WPF DRPSCU 07.0700,
IV. Decision Making

4.1 Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control ofeach child while
parenting plan, either parent may make emergency decisrons affectingthe·heatth·or safety of the
children.
4.2 Major Decisions
Education decisions [] petitioner [] respondent ~ jo~nt

Non-emergency health care [] petitioner [) respondent ~ JOtnt
Religious upbringing [l petitioner [) respondent W joint
[l petitioner [) respondent [] joint
[] petitioner [] respondent [] joint
[l petitioner [] respondent [] joint
[l petitioner [] respondent [] joint
[] petitioner [] respondent [] joint
.. - [ l .. petitioner rr .. respondent" [J joint

WPF DR 01.0400 Mandatory (6i.W08) -RCW 26.09.016,. 181; .187; .194
4.3 Restrictions in Decision Making
Sole decision making shall be ordered to the [ ] petitioner [] responde,nt for the
following reasons:
[] A limitation on the other parent's decision making authority is mandated by

[] Both parents are opposed to mutual decision making.
[] One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a) The existence ofa limitation under RCW 26.09.191;

(b) The history of participation of each parent in decision making in each of
the areas in RC\V 26.09.184(4)(a);
(c) Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in
RC\V 26.09.184(4)(a); and
affects their ability to make timely mutual decisions.
[] There are limiting factors in paragraph 2.2, but there are no restrictions on mutual
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.
lf4. Disputes between the parties, other than child support disputes, shall be submitted to (list person
or agency):
[] counseling by
mediation by VOA-Dispute Resolution Center 425-339-1335, if this box is checked

and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation·, that mediation is appropriate aii<ftliat Ifie vfotim is pennitted
to have a supporting person present during the mediation proceedings, or
[l arbitration by

[l _ _ _ _% petitioner % respondent.
/J4- based on each party's proportional share of income from line 6 of the child support
worksheets.
[l as determined in the dispute resolution process.
The dispute resolution process shall be commenced by notifying the other party by [] written
request [] certified mail [] other:

(b) Unless an emergency exists, the parents shall use the designated process to resolve
disputes relating 10 implementation of the plan, except those related lo financial support.
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.
(e) The parties have the right of review from the dispute resolution process to the superior
court.
[l There are no other provisions.

M There are the following other provisiori?:, · 1 \n ~
c pt-
-,L 62.. Q'-") 1'\A. ~ cl.-t-- '..__c' :\ t-'-\.. ~ trV' . ~
a...vt ~-rnr-;\,'-""'-s .![ ~ "3 I 2
'7 f "'":>-o tl t>--Y
r~~ """- -1~\f-

ec. c.L.. 'f ~+ ...-;\\ ~ 1-k c.. l.:t J. '"'°
"'-<,... If' ,.. " .A< ~
°"'""' ':I ......... ,) ••.:;... ' t" ~ ,..,,..:: •d-t> ~ h '"-c..

WPF DR 01.0400 Mandatory (612008) - RCW 26.09.016, .181; .187;. 194
VII. Declaration for Proposed Parenting Plan
Does not apply.

(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under the laws
of the state of Washington that this plan has been proposed in good faith and that the statements
in Part II of this Plan are true and correct.
Petitioner Date and Place of Signature
Respondent Date and Place of Signature
order ·of this court.
WARNING: Violation ofresidential provisions of this order with actual knowledge of its terms is
lfa parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
Dated: ---·~o=CT,_-_2_4_20_13_·_ __
Appro:for e~---
~ture itrParty or Lawyer/WSBA No.

VQ.J&tr- ~
Print Name Print Name
Parenting Plan (PPP, PPT, PP) - Paga 11 of 11

FILED
13 OCT 24 AH 11: 43
SOHYA J. KRASKI
COUNTY CLERK
SHOHOHISH CO. WASH.
RECEIVED
I~\~~1~11~~ ~ \ \
CL16311599
\ \ \ I \ ~ \ \ ~ \ \ \ ~ \ OCT 24 2013
Snohom~h County Famity Court

County of Snohomish
~n re the Marriage of:
[) Jn re the Domestic Partners~ of::,
No. O~ - 3 -D "'2... "7~<- l
~ . . . ~ ~c-Jf"ffG+<-.
Petitioner, Order Appointing Guardian ad
and Litem on Behalf of Minor
.:GV'lV\~ ~ ~· (ORAPGL). .
+ka.... -A. Res ondent.
I. Ba·srs
1.1 · -Basis for the Appointment
This appointment is being made pursuant to
~ - RCW 26.09 Dissolution

[] RCW 26.26 Parentage Act
[] RCW 26.50 Domestic Violence
1.2 Children to Whom the Ord~r Applies

The'M°petitioner []respondent []court moved for appointment ofa guardian ad litem for the
following minor child(ren) in this action:
Name--
L a.vr~eJ
(})~?
IJY'/F0!./ (/ t', -" I/
(iy6 i:ff,{;7 /)
Ord Appointing Gal (ORAPGL) - Page 1 of 4 <i-tjJ
WPF DR 04.0200 Mandatory (712009)-RCW 26.09.110; .140; .220. ~
,
II. Findings
After reviewing the case record to date and the basis for the motion, the court finds that the motion
should be granted because appointment ofa guardian ad !item is in the best interest of the
child(ren).
111.- Order--
It Is Ordered:
3.1 Appointment of Guardian ad Litem
Sf,'za..{gA [ ~"'-'...< is appointed as guardian ad !item for

the·abm•e--named minor child(ren) of the parties and shall re"ceive copies of all"pfoadings and notice
of all court proceedings regarding the child(ren).
3.2 Duties of the Guardian ad Litem

TI1e guardian ad Iitem shall investigate and report factual.information regarding the issues ordered
to be reported or investigated to the court. The guardian ad !item shall always represent the
child(ren)'s best interests. The guardian ad !item may make recommendations based upon his or
her investigation. The guardian ad !item shall report the child(ren)'s expressed preferences
regarding the parenting plan to the court, together with the facts relative ·ro whctlier any preferences
are being expressed voluntarily and the degree of the child(ren)'s understanding.
The guardian ad !item shall make a full and complete written report to the court and counsel/parties
on or before(date)- and at least 6CY'cfays liefore trial provided that
an extension may be granted by the court. This report shall include recommendations and bases for
those recomme-ndations.
Issues ordered to· investigate and report:

~ !_1]1 issues relating.to development of a parenting plan •...
[ ] substance abuse of [ ] mother [ ] father [ ] o t h e r - - - - - - - -
[] domestic violence of [] mother []father [] other _ _ _ _ _ _ __
[ ] mental health issues of [ ] mother ('] father [ ] o t h e r - - - - - - - -
[] physical health issues of [] mother []father [] other _ _ _ _ _ _ __
[] sexual abuse allegations of [] mother []father []other _ _ _ _ _ _ _ __
[] criminal history of [] mother []father []other _ _ _ _ _ _ __
[ ] abandonment or neglect by [ ] mother [ ] father
[] integration into the non-primary parent's home
[] other:_.
B( The guardian ad !item shall also report to the court on any other issues discovered that could
affect the safety of the child(ren).
3.3 Other Duties

Other duties of the guardian ad !item include appearing at all court hearings and pretrial
conferences within the scope of appointment unless excused by the court and assisting the parties
and counsel in reaching a resolution of the matters involving said child(ren).
Ord Appointing Gal (ORAPGL) - Paga 2 of 4
WPF DR 04.0200 Mandatory (712009) - RCW 26.09.110; .140; .220.
,
3.4 Guardian ad Litem Access to Child(ren), Records and Information

To facilitate reasonable investigation ofinfonnation penaining to the best interest of the child(ren),
the guardian ad !item shall have access lo the child(ren) and lo all records and infonnation,
including authorization to speak with interested persons, from the following sources: law
enforcement agencies; Child Protective Services (or the.equivalent out-of-state.agency); health care.
providers; mental heald1 care providers; child care providers; the Department of Social and Health
Services (or the equivalent agency in another state); and educational institutions.
These agencies may withhold or blackout portions ofrequested infonnation as warranted by law or
by court order. The guardian ad litem shall maintain the confidentiality of infonnation except as
necessary to fulfill his or her duties as guardian ad Iitem.
Within the scope of appointment, the guardian ad Iitem shall have access to all Superior Court and
Juvenile Court files, including any sealed/confidential portions thereof, other than records sealed
pursuant to RCW 13.50.050(7). All inforination obtained from sealed or confidenrial files shall
remain sealed or confidential, and the guardian ad Iitem shall infonn the court if the guardian ad
litem report contains sealed or confidential infonnation.
The court clerk shall provide certified copies of this order to the guardian ad litem upon request and
without charge.
Upon good cause shown, the guardian ad litem or the parties may move that the court make
confidential any reports or documents placed in the court file by the guardian ad litem.
3.5 · Payment of Fees and Costs

The guardian ad litem fee·is srz_..7 per hour up to$ 2.:x;.uthe maximum the· guardian ad
Iitem may charge without additional court review and approval. ·
The fees and costs of the guardian ad litem shall be paid as follows:
bt % by petitioner and _ _ _ % by respondent

~> % by other: QAc 0 1 ;-<,±>~ a-r.de--<C 4 ( l.. Jj r;'y'o-,fl,..;/
[l Other: r ' / ( TV
If the guardian ad Iitem has been appointed at public expense, the court may assess this cost against
the parties if there is a change in financial circumstances.
The total amount awarded shall be at the discretion of the court up to the maximum amount allowed
after the guardian ad Iitem files an itemized statement of time with the court, along with a specific
request for fees and a proposed Order. Guardians ad litem who are not volunteers shall provide the
parties with an itemized accounting of their time and billing for services each month.
3.6 Consent of Children Over Twelve to Investigation

"3 Does not apply.
[l
has/have reached the age of twelve. Written consent for the guardian ad litem to consult
with and obtain infonnation from medical, psychiatric, or other experts who have served
the child(ren) in the past[] has [] has not been given by the child.
Ord Appointing Gal (ORAPGL) - Page 3 of 4
WPF DR 04.0200 Mandatory (712009) - RCW 26.09.110; .140; .220.
3.7 Authorization for Release of Information
Does not apply.
Each party's signature hereunder constitutes an authorization for release of information by
that party to the agencies listed in paragraph 3.4, above.
3.8 Termination of Appointment

The appoinnnent terminates:
<k£ Upon entry of the final parenting plan or residential schedule.

[] Other:
3.9 Other
'OCT ·2 4: 2013
Dated: _ _ _ _ _ _ _ _ _ _ _ _ __
Approved for entry:
I Notice of presentation waived:
(\/\ !\-:-:- l , 'I•<!>

Signature of Party or er/WSBA No. Signature of Party or Lawyer/WSBA No.
G,c=tJ, G:h -- I
Print or Type Name
v <.r,;"' ' '~ -p..:.;..._.,
Print or Type Name
Accepted upon approval by

the court
Guardian Ad Litem
Signatures of the Parties:
Petitioner's Signature
Child's Signature Child's Signature

(See Paragraph j.6) (See Paragraph 3.6)
Ord Appointing Gal (ORAPGL) - Page 4 of 4
WPF DR 04.0200 Mandatory (712009)- RCW 26.09.110; .140; .220.
,.
FILED
13 OCT 2It AH 11: It 2
SONYA J. KRASKI
COUNTY CLERK RECEIVED
SNOHOKISH CO. WASH.
OCT 24 2013
ll~~~ll~l~~l~ll~lll~~~~l~l~i~
3nonomioh Counry Family Court
CL16311598
IN THE SUPERIOR COURT OF THE ST ATE OF WASHING TON

IN AND FOR THE COUNTY OF SNOHOI\USH
A4,""'4'> .S._.IH R~ NO.

Petitioner/Plaintiff(s)
SUPPLEMENTAL ORDER
vs. APPOINTING GUARDIAN AD LITEM AND
~e_"'" ";k. e~ /v\,_J."ul:! .·

SEITING COMPLIANCE HEAJUNG
Q, -k
ORAPE [CLER.K'S ACTION REQUIRED]
Respondent/Defendan$/(...._ ORCNT [CLER.K'S ACTION REQUIRED]
ORAPGL [CLERK'S ACTION REQUIRED]
This mnuer, having come on before the undersigned Judge or Court Commissioner of the above-entitled court, and
appearing that an investigation and report by a Guardian ad Litem is necessary to aid the court in making a decision,
the Court further deems necessary the following [ns nuthorized under Administrative Order 36-10]:
1. Both parties shall immediately report in person to the "Superior Court Programs" office, I" floor.of
the Courthouse, Room #C140 by ~ ... o,._,
am/pm on / of :2..'{ / 1~ .
2. Both paities shall obtain the Guardian ad Litem (GAL) Personal Information Form from the Programs
Office, complete these forms, and return to the GAL within 48 hours iifter receiving copy of this
order (or no later than ,.., I .2-Jr} 1 l b'lt
Yptrl . .
3. In the event that multiple GALs are named in the Order, the GAL Prograni staff will contact the
GALs and determine who will be appointed. Jn the event the GALs named in the Order are not
available, GAL Program staff will assign and notify the parties prior to the deadline stated in #2.
4. Both parties shall obtain any other supplemental materials, including additionitl questionnaire and
release forms, from the GAL and return to the GAL at the deadline determined by the GAL.
5. Both paities shall pay tllit;Jlojlion of the retainer (see section 3.5, page 3 of Order Appointing GAL)
by 1 I _I' {13 , . The GAL will report compliance to Programs staff..
6. The.GAL shall inform the court of any failure to comply with any of the above requirements on the
Friday prior to Compliance Hearing. Parties must attend the Compliance Hearing if retainer is
not paid & rcqu'ired papenvorl< is not completed & returned. The Court may strike pleadings of
the non-complying I non-attending party. These hearings are typically held on the 3"' Wednesday
following the date of this order. Uyou are in compliance your attendance is not required.
COMPLIANCE HEARING JS SE'T!,OR: DEPT. D, WED.NESDAY, 10:30AM on
. JI / (3 l~ I (date) CQ!J~T .cQ.NFfB,'\1EQ
- r I I ' --
~The guardian ad !item is authorized to ~equirt. tiu\t,parti<:f comply with an evaluation, assessment, or
othertestin for issues desi ated'in se~ti 3'.2, ri! fOrder A ointin GAL.
·-.
The following infonnation must be provided in full for the persons named below who appear to the
Court to be involved in this matter. (Court ordered services may not be initiated unless the requested'
information is provided in full.)
Petitioner ·Rcsnondcnt
Nam~: AN~~i-~ 1~ !!:usl?-~1<- Name: ~;::_~.•na~:-,,,,~ •JJ l.

Address: ho-'\.th.. w.,.
</Klf,
Home Phone: ~zn ;1..e.9 - f_cf.2.ll Home Phone: !_'f.)S) 3 3Z -l:IJ :.Z..
'Vork Phone: \~Z.S) 7YJ- /rSS 'I \Vorl< Phone: c.-u,I \....</l.s) 3.!D ·J.S 03
G· "fi2:r) 2 &9· ~2JO
Dote ofBinh: ;3 · 22- • I'? 3 Date or Birth: ET· H·· 7'1
j</,,_.,_ r
Other nnmes used: Other names used: CS'.t. '4IN1--'u- 1"*'11 o.,J / :r~+
.. Petitioner's Attorney . Re.soondent's Attorney
r-,.,J.-
~.'4-.,
Name: C..o.r I Gou I Name: V(rUJ1r...__ £.r~+. ~ -r-...~/.,
Address: 11. o Y 1+-G-\.u i -tt- ;;jj: 3oZ.. Address: .9. Io .S.v,...,..,1+ A..... e l...c.-" 0 ,,,.. J
-G.v~tt- W"-1: 'JS- .).o I ~..,tt-f.t. /µf- 7it"O f./'/uZ..
Phone: ;;is'- y1y7 -;,_<1.1.s-2 Phone: I ::J.De ~ ~2. tr· 7'3' 2...
Fax: Fax: ~ ;J.vb) 32 '5- O'lo</
.. .. .. .
.
f\ilinor·children '
Nan1c: Name: L.. q ur-c,.. Gm.I~ ~.·f<-.

'l · " '"" . 'I
Date of birth:
Address:
Dote of birth:
Address: J y;. uo
0
l. ,,.z o, ~6. A-5"'
~v.il.,,,..7rh wJ- !.. ~~f'
Phone: Phone:
Name: Name:
Dale of birth: Dale of birth:
Address: Address:
Phone: Phone:
The following are other cases involving these parties that are now or in the past been before this court of other
courts:~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-.,-~~~
Commissioner
esented by: ~
I ""'o ,- v"""'~· ,.. +.-.. ~
WSBA#~-'--'~7~~~~~~~~~~-
Attomey for: f&t.....l.p..1-
A~~d;
5:\Supariol'"Cou!1\GAL\2010 GAl.\S'JPP Cl'dcr1cc GAL Revise~ 11 08 10 ooc.. 111Bf20'IO

'
..
•'
F'IL£o
zo11ac121
5
7 In re:
8 Petitioner,
and REPLY DECIARATION OF ANDREW RIFE
Res ndent.
10
I, ANDREW RIFE, declare wider penalty of perjury of the laws of the State of Washington,
11 t the following is true and correct

13 I lim the petitioner in this matter. I make this declaration to reply to the material submitted
14 y Jennifer Mehaddi. The court should find ai:lequate cause and order my proposed parenting plan
'
15 the temporary parenting plan in this matter.
16 FUNDAMENTAL ISSUES
17 Lauren Rife resides with me. I do the things custodial parents do. Jennifer has withdrawn
from parenting, and has a new DV relationship.
18 Jennifer asked me to care for our daughter while she has gone halfway around the world for
extended stays four times. Why on earth would she have me take .over parenting if she
19 actually believed any of her current criticisms1 to be true?
C. Jennifer Mehaddi does not propose a parenting plan. She wants to maintain the 2011
20 Parenting Plan she admits we never followed, and does not describe the residential schedule
she believes we have been following. I have described it accurately. I began keeping a
21 calendar in January 2013.
22 RELATIONSHIP WITH LAUREN
23
24
25 1
Lauren often sleeps in my bed. eonse(iuent!y, I sleep on the couch. Lauren wore pull ups to
bed until she out grew the problem. · .
26
CARLl.GAUL
27 AttDmey at law
1604 Hewitt Ave.
REPLY DEO.ARATION OF ANDREW RIFE Everett WA 98201
Page 1
ORIGINAL 425 259-4147 FAX 259 7081
'
•
1 Jennifer claims "We have a wonderful relalionship2" without explanation. Our daughter is
2 extrovert. She likes to GO. She likes to DO. She wants to be active. She likes being around lots
3 f people. She wants excitement and stimulation. With me she gets an active, social and stimulating
4 · e. I also see to it that she is fed properly, gets her homework done and a good night's sleep. The
5 arenting plan should change.
6 DOMESTIC VIOLENCE
7 Jennifer attempts to raise negative innuendos. In 2005 and again in 2007 Jennifer filed
8 omestic violence restraining order actions against me. She lost. Both were dismissed. Years ago
9 I recognized my own problems and got cowiseling and the classes for domestic violence and also
10 ook parenting classes. Jennifer has yet to recognize her own problems, and has yet to remedy them.
11 Jennifer has plenty of experience with domestic violence:
12 Jennifer's first marriage was to lngo Klenner, a German immigrant. He returned to Germany
with domestic violence assault charges pending. See Attachment I, Bothell Municipal Court
13 docket.
In Januaiy 2003 her then-brother in law Mike Bnmsman and sister Lisa and Jennifer ended
14 up in a brawl. Police were called. Mike got arrested. Lisa and Jennifer were in a fist fight
but not arrested.
15 C. Jennifer's third marriage is with Soufyane Mehaddi. They argue a Jot. They have enough
domestic violence that she acknowledges his hand in her face and he threatened to hit Lauren
16 by raising his hand to hit her, causing Jennifer to call 911 to protect Lauren.
17 Chronic conflict with her parents, her husband and others is detrimental to Lauren.
18 JUDICIAL INTERVENTION IS NEEDED. MEDIATION WAS REFUSED.

19 I filed this action to protect our daughier Lauren. I had no other choice. Jennifer does not
20 explain why she refused to participate in mediation in the summer of2013. She requested mediation
21 t VOA to reach agreement on changes to the parenting plan. I agreed to mediate. Then the first DV
22 · ncident with her husband occurred. Then her check to VOA bounced. I paid for mediation. I still
23 ted to mediate about changes to the parenting plan, and I wanted to discuss the DV incident and
24
25 2
See Declaration of Jennifer Rife In Response to Motion for Adequate cause and Temporary
Order at page 4 line 20.
26
CARLl.GAUL
27 Attorney at Law
1604 Hewitt Ave.
REPLY DECl.ARATION OF ANDREW RIFE Everett WA 98201
Page2 425 259-4147 FAX 259 7081
1 hat counseling or other services would red~ce the risk of any future similar incidents. Jennifer
2 ever responded. But Soufyane responded to call me a snake, showing his aggressive side to me,
3 otjust to Jennifer and Lauren. Attachment 2. VOA closed its file. Jennifer would not participate
4 · a nonjudicial process.
5 6. DYSFUNCTIONAL RELATIONSHIPS
6 Jennifer lauds her conflict laden family as a resource. In reality, the conflict on the maternal
7 ide of Lauren's family are additional detriment to Lauren. Jennifer complains to me about their
8 ngoing bickering, arguing, and even physical fighting. Here just a few of the many examples:
9 Mother. July 22, 2010 when her mother wanted to be paid the rent and would not provide
money for Jennifer to visit her sister (then living in Florida) Jennifer refers to her mother as
10 a "f"••uo B.. *H." Attachment 3. She and her parents complain about money to each
other. March 26, 2013 she texts concerning her mother, "She's a bitch. Don't even argue
11 with me on that one." Attachment 4.
Brother. March 7, 2011, when she returned from Algeria after marrying Soufyane, Jennifer's
12 brother Jeff sent an email that Soufyane would never be accepted in the farmly. Attachment
5. Jeff was right. Jennifer was not even welcome at her parent's home at Christmas 2012
13 over this issue. I took Christmas dinner to her at her condo. Attachment 6.
c. Father. February I0, 2013 Jennifer's father, Steve Holland, refers to Jennifer as a "dick head"
14 and "stupid." He kicked her out of the Holland house for the third time in two months.
Attachment 7.
15
THE GREEN HERRING : MONEY
16
I have been throwing good money after bad, to protect Lauren from Jennifer's
17
limesno:nsibility. Jennifer's conflicted relationships relate to her own irresponsibility. One way she
18
is irresponsible is about money3. She paid the dog groomer then I gave her for money for groceries.
19
e conflict with her mother4 was over money. Jennifer lives in a condo her parents rent to her for
20
$800 per month, less than a market rate. Jennifer fell behind on the rent, but had money to take a
21
22
23 3
Jennifer makes $18.00 per hour at SWedlsh Hospital/ Edmonds. At 8 hour days, 4.33 weeks In
24 month, she earns $3117 per month. She Jives tn a nice condo and drives a BMW. Poverty has nothing
to do with It.
25
4
See part 6.A. above.
26
CARLJ.GAUL
27 Attorney at Law
1604 Hewitt Ave.
Page3 425 259-4147 FAX 259 7081
1 "p to Algeria. Her mother rightly felt used. The conflict with her father also concerned money'.
2 She had been arguing with Soufyane for a week about money when she called 911 for domestic
4 RED FLAGS : JENNIFER MEHADDI SLINGS INNUENDOS

5 Even though she has been happy to have Lauren with me most of the time, Jennifer Mehaddi
6 ·es to impugn my parenting. Her attitude changed only because of this action.
7 Snorts. Lauren does not belong in Parks Department recreational soccer. She belongs in
8 lect competitive soccer. Lauren's schoolwork shows her enthusiasm for soccer. Recen~y she
9 te an assignment at school about her sparkly fantasy house shaped like a soccer ball and with an
10 · door soccer pitch. Attachment 8. Nobody is forcing this girl into soccer. Like all the parents, I
11 cheer our daughter on. Lauren is in the Washington Rush team picture. See Attachment 9. She
12 loves the sport and the activity. She is proud of her accomplishments.
13 At School. Lauren's classroom door is ordinarily kept open. Parents doing their volunteer
14 ours often wave at their kids if they happen to see each other. I do. Lauren happily waves back.
15 9. JENNIFER IS AN UNINVOLVED PARENT

16 Jennifer's attempt to claim involvement with our daughter fails. Jennifer signed up to be a
17 arent at the 2013 Halloween Carnival at St.. Mary Magdalen, her very first attempt lo serve as a
18 olunteer. She was disallowed from participation because she has never taken the 3 hour Safe
19 nvironment class required for all volunteer parent participation. She told me she cannot take the
20 lass because she is too busy.
21 Jennifer is not so involved in academics, either. In her declaration Jennifer complains that
22 tend to Lauren's homework. But then on October 9, 2013, Jennifer dropped Lauren off with me
23 t--~~~~~~~~~
5
24 See part 6.C. above.
6
25 See Declaration of Jennifer Rife In Response to Motion for Adequate cause and Temporary
Order at page 9, line 3: "We had been arguing over finances for the past week on and off and we argued
bout money that day too.•
26
CARLJ.GAUL
27 Attorney at l.i1W
1604 Hewitt Ave.
REPLY DEa.ARATION OF ANDREW RIFE Everett WA 98201
age4 425 259-4147 FAX 259 7081
•
1 or soccer. She told me she and Lauren had done the math homework, but after soccer I would need
2 o do the spelling, the reading and !ht: science. Now she complains that Lauren does her homework
3 'th me. Jennifer never complained before. Lauren is accustomed to doing it with me, as that has
· 4 been the norm.
5 Jennifer complains in her declaration about all the events and ceremonies. But there have
6 een a grand total of two (2) special events for Lauren (Baptism and First Commwiion) she was
7 pecially invited to attend. These are big events to Lauren. Jennifer no-showed one and left early
8 on the second. All she had to do was be there and watch. Jennifer is not supporting Lauren when
9 she simply is not there or simply cannot stay there. The point is the disappointment for Lauren. She
10 says she has attended or participated in other ceremonies, without identifying any. There have not
11 eenany.
12 Jennifer is not involved in our daughter's health care. The medical records show we were
13 both involved in times gone by. But she has become less and less involved. The dentist confirms
14 ppointments with me. Jennifer complains that the appointments are made when she has to work.
15 cnnifer was off work from May 28 when she was fired witil she found new employment August 12.
16 he knew about the appointment for Lauren's cast removal on July 23, when she was home on
17 nemployment Insurance Compensation, but she did not attend.
18 10. GUARDIAN AD LITEM
19 Jennifer nominates two people to make an evaluation. One is not on the Snohomish County
20 GAL list. The other has no background on this case. It does not make sense to have to educate a
21 ew GAL. Bridget Llewellyn was the Guardian ad Litem in the original divorce. I think she is the
22 est choice for GAL if one is needed.
23 Executed at Everett WA Electronically approved by Andrew Rife

24 on October 20, 2013 ANDREW RIFE
25
26
CARLJ.GAUL
27 Attomey at Law
1604 Hewitt Ave.
Paaes ·-- --· ..
ATTACHMENT 1
Rife vs. Mehaddi Bothell vs. Klenner
No. 05 3 02755 1 Docket
DD7020SX MPH BOTHELL MUNICIPAL COURT PAGE: 1
10/17/~013 3:57 PM - DOCKET
CASE: 8421 BOP
DEFENDANT Criminal Non-Traffic
KLENNER, INGO GUNTHER Agency No.
22714 20TH DR SE #G-305
BOTHELL WA 98021 Home Phone: 4254817107
AKA No aliases· on file.
OFFICER
00183 BOP BROOKS, LESLIE D
09891 BOP WHITE, ERIC 'M
CHARGES
Violation Date: 10/24/2000 DV Plea . Finding
l 9A.36.041 ASSAULT 4TH DEGREE v Not Guilty Dismissed
TEXT . ·-
S 10/25/2000 Case Filed on 10/25/2000 GSM
Charge 1 is DV-related
OFF l BROOKS, L~SLIE D Added as Participant
U DEF BOOKED ON CHARGES. ARR SET FROM JAIL. TRANSPORT ARRANGED.
S OFF 2 WHITE, ERIC MAdded as Participant
OTH ICNN Set for 10/25/2000 10:30 AM
in Room l l"ith J'udge JWR
OTH ICNN: Not Held. Hearing Canceled EJR
ARR NN: Held
Proceedings Recorded on Tape No. 00-135
Beginning Count 695 End count 1055
U JOHN RUSDEN, JUDGE
DEF. PRESENT IN CUSTODY PRO· SE
BEGIN--0695
DEFENDANT ARRAIGNED.
JURY DEMAND
DEFENDANT RELEASED ON PERSONAL RECOGNIZANCE.
s Defendant Arra~gned on. Cha.rge 1
Plea/Response of Not Guilty Entered on Charge 1
U VICTIM PRESENT AND DOES NOT WANT A NCO ENTERED
NCO DEEMED NOT NECESSARY AT THIS TIME
S 10/26/2000 PTR NN Set for 11/07/2000 10:00 AM
in Room 1 with Judge JWR
JTR NN Set for 12/06/2000 08:30 AM
in Room l with Judge JWR
U 10/27/2000 DEF DOES NOT QUALIFY FOR THE PUBLIC DEFENDER. GSM
S 11/07 /2000 PTR NN: Held . EJR
Proceedings Recorded on Tape No. 00-143
Beginning Count 1 End count 3500
U JOHN RUSDEN; JUDGE
ATP: L EDWARDS
DEF. PRESENT WITH ATD FEtDMAN
BEGIN--0001 ,
DEF. MOTIONF OR CONT. FOR INTERPRETER TO BE PRESENT
S 11/08/2000 PTR NN Set for 11/28/2000 10:0~ AM
Docket continued on next pa~
10/17/2013 3:57 PM D 0 C IC E T
CASE: 8421 BOP
DEFENDANT Criminal Non-Traffic
KLENNER, IHGO GUNTHER Agency No.
TEXT - continued
S 01/14/2001 OTH REVNN Set for 12/26/2001 01:31 PM EJR
in .Room l with Judge JWR
OTH.REVNN Set for 04/30/2001 01:31 PM
OTH REVNN Rescheduled to 04/30/2002 01:31 PM
u 01/17/2001 REQ FOR REV FROM PA OFFICE FILED. NOTICE MLD ro DEF AND ATTY. GSM
s REV NN Set for 01/30/2001 01:30 PM
01/30/2001 REV NN: Not Held, Wt/FTA Ol'dered· EJR
Proceeciings Recorded" on Tape No •.01-012/13
u JOHN RUSDEN,· JUDGE .
ATP: L EDWARDS
DEF. FAILS 10 APPEAR FOR REVIEW HEARING
BEGIN--0001
CITY MOTION FOR BENCH WARRANT
CR/ B/W ORDERED FOR $500 CSH OR BOND
s BENCH Warrant Ordered
P.rint on or after 01/30/2001
warrant expires on 01/30/2004
OTH REVNN on 04/24/2001 01:31 PM
in Room 1 with Judge JWR canceled
OTH REVNN on 08/28/2001 01:31 PM
in Room 1 with Judge JWR Canceled
OTH REVNN on 12/26/2001 01:31. PM
in Room 1 with Judge JWR Canceled
OTH REVNN on 04/30/2002 01:31 PM
in Room i with Judge JWR Canceled
u ATTY PHONED AT 1:40P. TO ADVISE CRT DEF IS IN GERl'IANY.· ATTY GSM
WAS HOME W/A SICK CHILD AND COULD NOT BE HERE. ATTY TO PROVID
PROOF DEF IS IN. GERMANY. .
s 01/31/2001 BENCH Warrant Issued·. for SYS
Fail To ·Appear.F.or Hearing
Cash Bail Only
Bail: 500.00·+ so:oo Warrant Fee; Total Bail 550.00
02/20/2001 1052100047 Time Payment Received 30.00 EJR
U 03/12/2001 PROOF OF AIRLINE TICKETS FILEO:·GIVEN TO JUDGE RUSDEN FOR GSM
· REVIEW. . '
03/15/2001 PER JUDGE RUSDEN WRT TO BE QUASHED.
s 03/20/2001 1000100005 Time Payment Received 170.00
03/21/2001 Warrant Quashed
03/22/2001 Warrant Returned
07/25/2001 1206100025 Time Payment Received 100.00 AHN
case Paid in Full and Removed from Time Pay
OTH REVNN Set for 11/27/2001 01:31.PM
U CAROL HOLLAND APPEARED TO PAY BALANCE ON FINES. CK #7777
S 10/24/2001 OTH REVNN Rescheduled to 02/26/2002 01:31 PM JHB
Docket continued on next page
10/17/2013 3:57 PM D0 C KE T
CASE: 8421 BOP
DEFENDANT <::riminal Non-Traffic
KLENNER, INGO GUNTHER Agency No.
TEXT - Continued
U 02/01/2002 CASE REVIEWED. DEF. NON-COMPLIANT DUE TO NO AMT. REVIEWED JHB
BY JUDGE RUSDEN. DISMISS AND CLOSE CASE AS ·DEF. HAS MOVED
TO GERMANY. .
s Charge l Dismissed: Oth-Defrl Co~pl
Defendant Complied with·No contact with Victim
Defendant ~cused/Waived. fo.r Anger .Management Treatment·
Defendant Complied with Stipulated On:lr of Continuance
OTH REVNN on 02/26/2002 01:31 PM
in Room l, with Judge JWR Canc!!led
·Case· Disposition of CL En.tared
u 11/14/2005 FILED--FAXED REoutsT FOR PUBLIC INFORMATION. COPY OF EJR
11/18/2005 PUBLIC DOCKET MAILED TO M SCHOONOVER AT 3101 OflKES AVE
· ', EVERETT, WA 98201
ACCOUNTING SUMMARY '
Total Due Paid credit Balance
Timepay: N 300.00 30CJ.00
ADDITIONAL CASE DATA
Case Disposition
Disposition: Closed Date: 02/01/2002
Parties
.Attorney JOHN,SON, MARTINUS L. JR
Personal Description
Sex: M Race: W DOB:·07/25/l962
Dr.Lie.No.: State: E>cpi res:
Employer:
Height: 5 10 Wei~ht: 180 _Eyes: BL\.( Hair: BRO
Hearing Summary
Held ON 10/25/2000 AT 10:30 AM IN ROOM 1 w:nH JWR
Held PRETRIAL CONFERENCE ·oN 11/07/2000 AT 10:00 AM IN ROOM'l WITH JWR
Held PRETRIAL CONFERENCE ON 11/28/2000 AT 10:00 AM IN ROOM 1 WITH JWR
Held 'ON 01/99/2001 AT 10:00-AM IN ROOM 1. WITH JWR
End of docket report for this case
ATIACHMENT2
Rife vs. Mehaddi Text:Message August 13, 2013
No. 05 3 02755 1 Soufyane Mehaddi to Andrew Rife
teKLO
From: soufyane Mehaddi
Date: August 13, 2013
To: Andrew Rife
Andy you better focus on your self and your life and don't bother me anymore, I will
never trust a SNAKE like· you, sorry I gave you a credit
before but not anymore. You are a snake with a couple of face. Then you can say go
to work soufvane go get a job, ¥OU don't like me being here
you don't like it and you are wishing me ?O back to Algeria, go back home? I am home
here. sorry you are 40 but for me you don t sound like it.
Goodnight and yeah I have ·all the right to ask you to stop your blah blah with my
wife cause you do like to talk so much. And it's bother me
so simple.
Page 1
ATIACHMENT3
Rife vs. Mehaddi Email July 22, 2010
No. 05 3 02755 1 Jennifer LeSourde (Mehaddi) to Andy Rife
From: Jenn LeSourde [mailto:jennlesourd@comcast.net]
Sent: Thursday, July 22, 2010 9:41 PM
To: Rife, Andy
Subject: Florida
I've got a favor to ask. .. and it's humiliating. So that is why I am e-mailing you. I get my
paycheck tomorrow, and my Mom is insisting that she get her $800 in rent this pay period, plus
what I was behind in $100 for June rent and $200 in May rent. r got behind with some extra bills
and missing couple of days of work when I was sick and when Lisa was here .. .[ didn't have
enough PTO. Yes, she is a F* .... G s•••H. She knew this trip was coming up and with the
amount of money I make and paying rent and all my bills it is virtually impossible to save
money. Hence, why I never take trips. She won't work with me on this and that is why I'm so
freaking tired and stressed out Lauren and I cannot go to Florida and have a good time without
money, and you know Mike and Lisa don't have much either. So, if r paid you back $100 out of
each paycheck coming up, would you be willing (if you could) to loan me $500 for this trip? I
know.. .I'm sorry, I hate asking. I'm not Zack though, and this is a really tough spot to be in. I'm
so mad at my Mom right now I can't see straight She could have given me a break, for at least
this month. Or let me pay her back like I suggested to you. She is infinitely selfish and refuses to
see the situation from my point of view. I think she is also mad that Lauren and rare going and
she was never invited. To hell with her. Really. I'm so mad.
If you can't or feel uncomfortable, don't worry I will understand. Asking you was kind of my last
step. So, think about it and let me know. You know I wouldn't screw you over. Bye the way, tell
your Mom thanks for watching lauren and for buying her some new clothes. Boy or not! It helps,
really.
Jenn
ATIACHMENT4
Rife vs. Mehaddi Text Message March 26, 2013
No. 05 3 02755 1 Jennifer Mehaddi to Andy Rife
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ATTACHMENT 5
Rife vs. Mehaddi Email March 7, 2011
No. 05 3 02755 1 Jeff Holland to Jenn Lesourde (Mehaddi)
From: Jeff Holland <jeff@hollandemall.net>
Date:· Mar 7, 2011 7:32 AM
Subject: Re: HI
To: Jenn LeSourde <jennlesourd@comcast.net>
Jenn-
Glad you are back home without incident.
rve been thinking about all this for a while. While I don't approve of what you're
doing, ifs ultimately your decision and your life to live as you see fit However,
you have a child and that is and should be your primary focus.
Do reali7.e your decision to move forward with marrying and/or legally bringing
this pe!liOn to the U.S. will have consequences_.
- He will not be accepted by the family, including me and Debi. No one wants to
meet him, he won't be welcome in any one's home, and we won't want to come to
yo\D'S with him there.
- It will change the way the family interacts with you in a profoundly negative
manner.
- It will affect Lauren and how she grows up with a person in the family that all
but you have ostracized. The resentment and distancing between you and family
will undoubtably affect Lauren in a negative manner.
-Andy will more than likely challenge you for custody ofLallRlll given your
irrational behavior. Given what I've seen and heard, I have to say that I think he
has a good position if you move forward with your plans.
That's it I hope you consider your options and place your child first before your
own needs.
-Jeff
ATIACHMENT6
Rife vs. Mehaddi Text Message December 24, 2012
No. 05 3 02755 1 Jennifer Mehaddi to Andrew Rife
iMessage
'
ATTACHMENT 7
Rife vs. Mehaddi Email February 10, 2013
No. 05 3 02755 1 Jennifer Mehaddi to Carol Holland & Steve Holland
•
From: '1ennifermehaddi@comcast.net" <jennifermehaddi@comcast.net>

Subject: no more
Date: February 10, 20131:39:56 AM PST
To: Carol Holland <holland@premier1.net>, steve holland
<sholland_construction@yahoo.com>
We seem to have had a hard time the last couple of years. Mostly about money. I have admitted
wrong many times regarding rent and the car. Yet, the both of you let years go by where you did
not make a big deal about the car payment or car insurance. We both know this. So I am getting
my own car, and insurance. My going to Algeria has nothing to do with that and affects it by no
way. Youjwnped to a conclusion that I had decided to travel to see Soufyane and not get a new
car. How can we get along and have an adult conversation when you go to asswnption?
This is now the 3rd time in 2 months where you Dad, have yelled and gotten in my personal
space and kicked me out of your house. You called me "stupid", you called me "dickhead" and
you know what? I said nothing back. I did not yell. I defended myself, but I kept my temper.
Mom, you are wrong. You said you heard "raised voices". The raised voice you heard was Dad.
Sure, Chase and Alexa and Lisa heard it. Every word.
So Dad. I am not "sponging" off you. In fact, I have taken great lengths to be more responsible
and be fully independent. A couple of times, I have borrowed money from you lately. I paid you
back as I said I would. That is not sponging. Also, to talk about the money from my divorce from
Andy is not fair. You helped, above and beyond and I said thank you many times. I am a good
person with a good conscience. I have made mistakes, but I will not accept for you to call me
stupid or a dickhead or to kick me out of your house in front of children and every one else.
I am going to visit my husband after almost l year apart. Rent will still be paid, and I will have
my own car. If for some reason I don't by the time I leave, then it is fine. I will understand you
taking back the BMW. I will find a way to work somehow. We all get just one life - and I am not
going to leave Soufyane. I love him, and we have a future. You have tried in so many ways to
prevent that and I can't understand why really.
Like I said, we have had some really hard times. Nothing makes what happened earlier tonight
okay. You threatened me with the condo AGAIN - when I am consistently paying rent. Why? It's
as if - I don't comply or do what you want me to do even in my own personal life, you try to
bend me or break me until I capitulate to what you think my life should be. I am a good person, a
good Mom, and I work hard. I am making things better. Yet, none of it seems to make a
difference with the two of you. You don't even seem to know me anymore.
Jenn
ATTACHMENT 8
Rife vs. Mehaddi 3rd Grade Writing Assignment
No. 05 3 02755 1 Lauren Rife
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112 CIThe Mallbox• • Dally Joumsl Prompts• TEC3168

•
ATIACHMENT9
Rife vs. Mehaddi Washington Rush Team Photo
No. 05 3 02755 1
Lauren Rife
'I
'.(:/; '•_& U fr I
. --
FILED
1 I 3 OCT 25 AH to: 31
2 SONYA J. KRASKI
COUNTY CLERK
SHOHOHlSH CO. WASH.
111~111111111
3
4
CL16311867
s
6
Andrew Scott Rife NO. OS 3 02755 1
9 Petitioner,
and MOTION FOR REVISION OF
10 Jennifer Rae Rife COMMISSIONER'S RULING
Res ondent.
11
12 COMES NOW Andrew Scott Rife, and moves this Court to enter an Order granting the
relief requested in Part I below:
13
14
I. Relief Requested
Andrew Scott Rife moves this Court to enter an Order which revises the Temporary
15 Parenting Plan entered by Commissioner Brudvik on October 24, 2013.
16 II. Statement of Grounds

17 The commissioner found adequate cause for major modification of parenting
plan but did not enter a temporary parenting plan which would protect the child
18 from the detriment in the mother's home.
19 III. Statement of Issues

20 IN AN ACTION FOR MODIFICATION OF PARENTING PLAN, SHOULD THE COURT ENTER
A PARENTING PLAN WHICH PROTECTS THE CHILD FROM THE DETRIMENT IN THE
21 MOTHER'S HOME?

23 The records and files herein.
24 v. Legal Authority
25 RCW 2.24.050
26 CARL]. GAUL
Attomey at Law
1604 Hewitt Ave.
Everett WA 98201
MOTION FOR REVISION OF C::OMMISSIONER'S RULING - 1 425259-4147FAX2597081
2-81
•
1 RCW 26.09.191
RCW 26.09.260
2
3 VI. SCLCR7 Compliance
4 As required by SCLCR 7 Andrew Scott Rife submits:
5 Commissioner's Erroneous Rulings Correct Rulings the Commissioner

Should Have Made
6
In part 3.2 of parenting plan left child in Should have adopted residential schedule
7 residential care of mother 8 days in a 14 day proposed by father, child residing with him
cycle, notwithstanding domestic violence in and having residential time with mother
8 the mother's home. daytime o weekend d
10
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12
13
14
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26 CARL], GAUL
Attorney at Law
1604 Hewitt Ave.
Everett WA 98201
MOTION F'OR REVISION OF' COMMISSIONER'S RUL.ING - Z 425259-4147FAX2597081
-
F\LED
I 3 OCT 25 MHO= 3 I
1
2 SOH'<A J. KRASKI
COUHT'< CLERK
SHOHOHISH CO. WASH.
3
4

7
B
Andrew Scott Rife, No.OS 3 02755 1
9 Petitioner
and CALENDAR NOTE
10
Jennifer Rae Mehaddi, f/k/a Rife,
11 Respondent
AND TO: Jennifer Rae Mehaddi f/k/a Rife
13 AND TO: Veronica Freitas, Attorney for Jennifer Rae Mehaddi f/k/a Rife
14
CIVIL CALENDAR . Defaults, Date: November 1, 2013
15 Discovery Motions & enforrement thereof, Tuesday - Friday at 9:30 a.m.
Supplemental Proceedings, Unlawful Detainer, Nature of Hearing:
16 Probate, Guardianship & Receivership actions, Revision of Commissioner's Ruling
Motions to Amend Pleadings
17
Matters set before a Court Commissioner will be assigned later to a particular department. The assignment will
18
be posted the day of the hearing. Extended motions are set by the Court Commissioner, not a party or counsel.
If a presentation, or If a particular Court Commissioner has already hard a recent motion on the matter, please
19 Indicate Court Commissioner _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
20 WARNING: The moving party MUST CONARM by noon two (2) court days prior to the hearing in order for the
matter to be argued. Failure to notify the Court of a continuance or strike may result In sanctions and/or terms.
21 SCLCR 7(b)(2)(E). This form cannot be used for trial settings. SCLM .1 40 ).

23
24
25
26 CARL]. GAUL
Attomey at lilw
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
1 I, CARL J. GAUL, declare under penalty of perjury of the laws of the State of Washington, that on October
24, 2013, I emailed prepaid a copy of the motion for revision of commissioner's ruling and the document to which
2 this declaration Is affixed, to the following persons, addressed as follows:
3 Veronica Freitas Elizabeth Buie

Attorney at Law GAL
4 v@freitaslaw.com elisebuie@gmail.com
5
6
7 Executed at Everett, October 24, 2013

CARL J. GAUL WS
8
9
10
11
12
13
14
15
16
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26 CARL]. GAUL
Attomey at Law
1604 Hewitt Ave.
Everett WA 98201
425 259-4147 FAX 259 7081
F\LED
jf1~~1~~~~11111~1m11~111il
\ ___
CL 16220192 _,,
SUPERIOR COURT OF
WASHINGTON
ANDREW SCOTT RIFE CAUSE NO. 05-3-02755-1

(PETITIONER) JUDGE: GEORGE N. BOWDEN
AND REPORTER: NOT REPORTED
CLERK: DEBBIE J. HORNER
JENNIFER RAE RIFE DATE: 11-1-13 A.M.
(RESPONDENT)
'!'HIS HA'l"l'ER CAME ON FOR: REVISION OF COMMISSIONER'S RULING

CONTINUED DA'I'E/'I'IME/CALENDAR AND CONTINUANCE CODE:
HEARING DA'l'E SE'I'/'I'IME/CALENDAR CODE:

ACTION:
PE'l'I'l'IONER APPEARED: YES COUNSEL: CARL J. GAUL III
GUARDIAN AD LI'l'EM APPEARED: NO
DOCUMENTS FILED:
ORDERS ENTERED: ORDER ON MOTION FOR REVISION
PROCEEDINGS/COOR'l''S FINDINGS:
PETITIONER'S MOTION FOR REVISION OF COMMISSIONER JACALYN D. BRUDVIK'S RULING

OF OCTOBER 24, 2013: DENIED.
1 MINUTE ENTRY
FlLED
2013 NOV - I PH 3: 41
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CL11169189
CASE TYPES 3 - 6
__S_N_O_H_O_M_I_S_H_ _ _ _ COUNTY SUPERIOR COURT
CASE INFORMATION COVER SH{:"\J;. 3 0 27
Case Title _ _,M=a,_,rr'-'ia,,_g,.e,,,_,o,,_f_,A"'n"'d"'r..,e,_,w"--"S"'c"'o"'tt~R"'ii..,e'"'a"'n"'d,,_,,l"'e"'n"'n"'ii..,e,,_r_,R"'a"'e,,_,_Jf:o:ii,_,Pl._____ 55 1
Attorney Name CARL J. GAUL Bar Membership Number --=8-=3_4~1,_____
Please check one category that best describes this case for indexing purposes. Accurate case Indexing not
only saves time In docketing new cases, but helps in forecasting needed judicial resources. Cause of action
definitions are listed on the back of this form. Thank you for your cooperation.
DOMESTIC RELATIONS ADOPTION/PATERNITY

__ Adoption (ADP 5)
__ Annullment/lnvalidity (INV 3)
__ Confidential Intermediary (MSC 5)
__ Child Custody (CUS3}
__ Initial Pre-Placement Report (PPR 5)
xxxx Dissolution with Children (DIC 3)
__ Dissolution with no Children (DIN 3)
__ Paternity/URESA/UIFSA (PUR 5)
__ Foreign Judgment (FJU 3)
__ Relinquishment (REL 5)
__ Legal Separation (SEP 3)
__ (Title 26) Termination of Parent-Child Relationship
__ Mandatory Wage Assignment (MWA 3)
(TER 5)
PROBATE/GUARDIANSHIP
__ Modification: Support Only (MOS 3)
__ Absentee (ABS 4}
__ Out-of-State Custody (OSC3)
__ Disclaimer (DSC4}
__ Reciprocal, Respondent in County (RIC 3)
__ Estate (EST4)
__ Reciprocal, Respondent Out of County (ROC 3)
__ Foreign Will (FNW 4)
DOMESTIC VIOLENCE/ANTIHARASSMENT
__ Guardianship/Estate (G/E 4)
__ Confidential Name Change (CHN 5)
__ Limited Guardianship (LGD 4)
MENTAL ILLNESS
__ Minor Settlement (With guardianship) (MST 4)
__ Alcoholic/Drug Treatment (ALT 6)
__ Non-Probate Notice to Creditors (NNC 4)
__ Mental Illness-Adult (Ml 6)
__ Will Only (WLL 4)
__ Mental lllness_Juvenile (MIJ 6)
If you cannot determine the appropriate category, please describe the cause of action below.

No. 05-3-02755-1 Andrew Rife v. Jennifer Rife Aka Lesourd Nka Mehaddi

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No. 05-3-02755-1 Andrew Rife v. Jennifer Rife Aka Lesourd Nka Mehaddi

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FILED

s In re the Marriage of:

14 IT IS HEREBY ORDERED, ADJUDGED AND DECREED:

2 0 II. BASIS FOR RESTRICTIONS

1 7 III. RESIDENTIAL SCHEDULE

22 3.1 SCHEDULE FOR CHILDREN UNDER SCHOOL AGE

23 There are no children under school age.

1 3.2 SCHOOL SCHEDULE.

2 Does not apply

3 3.3 SCHEDULE FOR WINTER VACATION.

4 Does not apply

5 3.4 SCHEDULE FOR SPRING VACATION.

6 Does not apply

7 3.S SUMMER SCHEDULE.

8 Does not apply

9 3.6 VACATION WITH PARENTS.

10 Does not apply.

11 3.7 SCHEDULE FOR HOLIDAYS.

13 Does not apply

14 3.8 SCHEDULE FOR SPECIAL OCCASIONS.

Does not apply.

3 3.11 TRANSPORTATION ARRANGEMENTS.

7 4.3 RESTRICTIONS IN DECISION MAKING.

11 [ ] A limitation on the other parent's decision making authority is mandated

14 (a) The existence of a limitation under RON 26.09.191;

1 mediation by Volunteers of America Dispute Resolution Service in Everett WA ,or

3 50% mother 50% father.

4 The counseling, mediation or arbitration process shall be commenced by notifying the

13 Jan Dyer WSBA# 20355

Washington State Child Support Schedule

Part I: Basic Child Support Obligation (See Instructions, Page 5)

Part V: Standard Calculation/Presumptive Transfer Payment {See Instructions, Page 8)

22. Other Factors For Consideration

WSCSS-Worksheets (CSW) 912000 Page 4 of 5 Continue to Next Page

Signature and Dates

Mother's Signature Father's Signature

Date City Date City

Judge/Reviewing Officer Date

Worksheet certified by the State of Washington Administrator for the Courts.

WSCSS-Worksheets (CSW) 9/2000 Page 5 of 5 SupportCalc® 2005

S!DiOHI9l COUNTY SUPER! IJ1T

13 FILE ORIGINAL OF YOUR RESPONSE SERVE A COPY!o~

PETITION FOR DISSOLUTION

Andrew Scott Rife

1317 McDougall Ave.

Jennifer Rae Rife

2416 - 5th St.

ALLEGATION REGARDING MARRIAGE.

This marriage is irretrievably broken.

DATE AND PLACE OF MARRIAGE.

Husband and wife separated on October 2, 2005.

This court has jurisdiction over the marriage.

The division of property should be determined by the court at a later date.

DEBTS AND LIABILITIES.

9 1.13 JURISDICTION OVER THE CHILDREN.

20 Name Mother's Name Father's Name

7 SUPERIOR COURT OF WASHINGTON

13 Name: Andrew Scott Rife Date of Birth: 03/22/73

14 I. SUMMARY OF BASIC INFORMATION

18 II. PERSONAL INFORMATION

22 b. If no: 1. When did you last work? (month/year)

23 2. What were your gross monthly earnings?

24 (3) Why are you presently unemployed?

2 Ill. INCOME INFORMATION