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lS
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BARRY
VAN
SICKLE -
BAR
NO.
986451079
Sunrise
Avenue
Suite
B-315
CA
95661
Telephone:
(916)
549-8784
E-Mail:bvansickle@surewest.net
AttorneyIn
Pro
Per
FILED
LOS
ANGELES
SUPERIOR CO
JAN
21
2009
J~~K.
ay
MAIIIJA
Iii.
L.rfoN,
lJt:pu
SUPERIOR
COURTOF
THE
STATE
OF
CALIFORNIA
COUNTY
OF LOS
ANGELES
DEBORAH
A.S.
VAN
SICKLE,
Petitioner,vs.
BARRY
L.
VAN
SICKLE
CASE NO.
8D0003554
EX
PARTE
NOTICE
OFMOTION
AND
MOTION FOR
RELEASE
OF
DRIVERSLICENSE
AND
MODIFICATION
OFORDER RE
PAYMENT
OF
ARREARAGESj OR, ALTERNATIVELY
FOR
ORDBR
SHORTENING TIME
TO
HEAR
SAID MOTION; DECLARATION
OF
BARRY VAN
SICKLE
DATE:
January
21,
2009
TIME:
B:
30
am
20 PLEASE
TAKE
NOTICE
that
on
January
21,
2009,
21
5,
2009
at
8:30am,
or
as
soon
thereafter
as
party
22
may
be
heard,
Barry
L.
Ban
Sickle
will
move
this
23
court
ex
parte,
for
modification
of
the
court's
orner
u
that
he
pay
per
month
towards
arrearages
on
child
support
25
for
the
parties'
now
adult
,
Heather
Smillie,
for
an
26
order
the
release
of
s
Driver
License
,or,
27
in
the
alternative for
an
order
this
motion
28
1
EX
P~~TE
NOTICE
OFMOTION
AND
MOTION FOR
RELEASE
OF
DRIVERS
LICENSE
AND
MODIFICATION
OF
ORDERRE
PAYMENT
OF
ARREARAGES
 
1
for
a
hearing
on
shortened
time and
allowing
Respondent
to
2
appear
telephonically
as
he
resides in
the
Sacramento
area.
3
This
motion
is to
be
submitted
ex
partein
Department
2G
of
4
this
court located
at
Central
Civil
West,
600
S.
Commonwealth,
5
Los
Angeles,
CA
90005.
6
This
motion
is
brought
on
the
grounds
that
moving
party,
7
Respondent
Barry
Van
Sickle,
has
suffered
extreme
and
unexpected
8
financial
hardships,
has
been
essentially
insolvent,
and
has
9
been
unable
to
pay monthly
bills
as necessary
to
support
his
10
wife
and
two
minor
children,
or
the
$500
per
month
payment
on
11
arrearages.
This
situation
will
hopefully
be
temporary
but
12
respondent
needs
additional
time
and
a
driver's
license
to
13
generate
the
income
necessary
to
support
his
family
and
make
l4
payments
on
the
arrearages.
Respondent's
business suffered
a
15
severe
cash
flow and
collection
problem
for
the
last
six
months
l6
of
2008.
Utilities
andphones
have been
disconnected,
the
house
17
is
on
the
vergeof
foreclosure
and Respondent
has
closed
his
18
office
to
save
rent.
The
details
of
this
are
explained
in
the
19
supporting Declaration
of
Barry
Van
Sickle. Basically,
20
Respondent's
clients
have
been
hit
hard
by
the
current
recession
2l
and
are
unwilling
or
unable
to
pay
their
legal
bills.
22
Respondent
has
been
left
with over
$35,000
in
uncollectible
23
accounts
receivable,
and
had
almost
no
realized
income
during
24
the
latter
part
of
2008.
The
potential
loss
of
a
driver's
25
license will
only
worsen
the
situation.
Moving
party
cannot
2627
28
make
paymentson
any
debt
if
he
cannot
get
to
hearings,
depositions
and
business
meetings.
2
EX
PARTB
NOTICE
OF
MOTION
AND
MOTION
FOR
RELEASE
OF DRIVERS
LICENSE
AND
MODIFICATION
OF ORDER
RE
PAYMENT
OF
ARR&ARAGES
 
1
Moving
party
has
been
working
diligently
to
change
the
2
nature ofhis
practice
and
find
new
and
different
work.
3
Respondenthas
secured
part
time
contract
work,
has
broadened
4
the
practice
to
include
additional
areas,
and
has
taken
on
a
5
major
wage
and
hour
case
that
has
considerable merit
and
6
financial
potential:lt
will
takeseveral
months
to
recover
from
7
the
financial
damage
caused
by
the
business
failures
and change
B
of
business
that
Respondeut
experienced during the
last
six
9
months
of
2008.
What
Respondent
seeks
is
additional
to
pay
down
10
the arrearages,
a
lower monthly
payment
such as
$250
a
month
at
11
least
for
the next
6
mouths and
a
basic
tool
needed
to
generate
12
income,
a
driver's
license.
13
Respectively
submitted,
14
~5
1617
18
19
2021
22
23
24
25
26
27
2B
EX
3
BARRY
VAN
SICKLE
Attorney In
Pro
Per
PARTE
NOTICE
OF MOTION
AND
MOTION FOR
RELEASE
OF
DRIVERS
LICENSE
AND
MODIFICATION
OF ORDER
RE
PAYMENT
OF ARREARAGES
of 00

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