17-3-02497-31 Sally Jo Price Vs Charles Allen Price Jr.

2
17-3-02497-31 2U l1 DEC - l PM 12: 0 I ·

3 MTFR 37
Motion for Revision
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7
Superior Court of Washington
8 County of Snohomish
9
Inre:
10
SALLY JO PRICE, No. 17-3-02497-31
11 Petitioner,
and Motion for Revision.
12
CHARLES ALLEN PRICE, JR.,
13 Res ondent.
14
I. Motion for Revision
15
Comes now the Respondent, by and through his attorney of record, Veronica Freitas, and
16
moves this court to revise Commissioner Jacalyn D. Brudvik's Temporary Order and Temporary
17
18 Parenting dated November 21st, 2017. Please see Temporary Order attached hereto as Exhibit A.
19 II. Relief Requested

20
Mr. Price is seeking revision of Commissioner Brudvik's Order pursuant to the errors
21
claimed in Section III below.
22
III. Claimed Errors
23
24 Commissioner Brudvik made the following errors:
25 1. Prohibiting the parents from taking the children out of Washington State.
26
27
28
Motion for Revision VERONICA FREITAS

Page 1 of7 V. FREITAS LAW, PLLC
544 291h Avenue
Seattle, Washington 98122
(206) 328-7362
2. Ordering $12,000 per month in undifferentiated family support, an amount which
2
exceeds the Respondent's net income.
3
3. Failing to consider the additional $2037 in income given to the wife from both
4
5
rental properties when setting maintenance.
6 4. Ordering the Respondent to pay all premiums (medical, dental, optical,
7 orthodontia, and automobile).

8
OUT OF STATE TRAVEL
9
Mr. Price asks that either parent be allowed to travel with the children out of state for
10
11 vacations with at least two weeks' notice. The parents shall provide an itinerary, address, and
12 phone number where the children can be reached.

13
FAMILY SUPPORT AND MAINTENENECE
14
Mr. Price has a base salary of $7 ,000 per month plus commission. Historically, he was
15
worked 6+ days a week. Prior to 2017, Mr. Price earned a great deal from commissions which
16
17 were a direct result working over 60 hours a week and being "on-call" via telephone 24 hours a
18 day. The mother averaged Mr. Price's income for 2012 -2016 and asked the court to impute him
19
at $416,402 per year (over $30,000 per month). Their argument centered on Mr. Price's
20
"ownership" of this company but he is a producing loan officer and subject to the Consumer
21
Financial Protection Bureau (Title XIV of the Dodd Frank Wall Street Reform and Consumer
22
23 Protection Act). By law, Mr. Price cannot dictate his income and it cannot be based on the
24 amount (terms) of any loans he originates. See Exhibit B, excerpt from Regulation Z, Section
25
1026.36(d). Mr. Price's holding is approximately 2% of the company and his only earnings are
26
salary and commissions as explained below.
27
28

544 29th A venue
(206) 328-7362
In April of this year, Mr. Price had a severe heart attack and spent a week in the hospital.
2
He was lucky to survive and has two stents as a result. The Petitioner acknowledges in her
3
pleadings that as a result of this health event, Mr. Price had to drastically reduced his work hours.
4
Mr. Price had another heart event in October of 2017, which caused his work hours to drop to
5
6 forty hours per week. Mr. Price submitted evidence that his physician has now limited him to
7 working no more than 40 hours a week due to his heart condition. Please note, on his October
8
paycheck, he earned no commission that month as a result of missing work due to health issues.
9
Mr. Price's heart attack has had a tangible impact on his earning potential. In the first ten months
IO
11
of the year, Mr. Price earned $140,000. This averages $14,000 per month.
12 When setting the family support at $12,000, the court apparently adopted the mother's
13
proposed income for Mr. Price which was based off an average of five years earnings. For all of
14
those years averaged, Mr. Price was working the aforementioned 60+ hours and "on-call" which
15
significantly increased his commission earnings. Due to Mr. Price's documented health issues it
16
17 is not realistic to impute him at over $30,000 per month. The court should use his actual year-to-
18 date income of $14,000 per month when setting support.

19
The Petitioner has a bachelor's degree and is able to work. She has worked as recently as
20
2009 and when she worked full-time she earned around $57,000. She should have her income
21
imputed per the net median income table. Mr. Price submitted proof that the Stanwood apartmen
22
23 assigned to the Petitioner produced a net income of $1, 739 .89 per month and that the Marysville
24 rental produces a net income of $190 per month. This totals $1,929.89 in rental income to the
25
Petitioner each month. Her total income should be $4,622.89.
26
27
28

544 291h A venue
(206) 328-7362
For illustrative purposes, the Respondent submits two child support worksheets. Both
2
worksheets include the health insurance premiums paid by Mr. Price. The monthly total for the
3
family is $1485.10. The children's proportional share is $891. The first worksheet, submitted as
4
5
Exhibit C, imputes Petitioner's income per the median net table ($2,696) and includes the
6 income from the rental homes ($1929). After drafting the worksheets and brief counsel realized
7 that the actual net income from the rentals is higher at $2,037 but we have left the original
8
number of $1929 rather than recalculating worksheets and deductions. The tax deductions were
9
determined for 2017 as married filing jointly. The difference in their net incomes prior to
10
11 maintenance is $6,109.78. To equalize the parties through maintenance, Mr. Price would pay
12 $3,054.89. This would result in a child support transfer payment of$1,310.56. Using this
13
worksheet, the Petitioner would have a total of $6,295.34 per month (maintenance+ child
14
support+ rental income) to support her household. Mr. Price would have around $6,386.77.
15
The second worksheet, submitted as Exhibit D, shows the Petitioner's rental income but
16
17 does not impute per the median net table. The income differential is $8,596.67 and Mr. Price
18 should pay $4,298.38 in maintenance. His transfer payment for support would then be $1330.80.
19
The Petitioner would have a total of $7,557.38 to support her household each month. Mr. Price
20
would have around $5,000 per month after paying the health insurance premiums for the
21
22
children. This is not an equitable result and would leave Mr. Price unable to support his
23 household as his rental costs are significantly higher than the $985.90 per month the mother is
24 paying for the mortgage and tax on the family home.

25
It is clear error that the court has ordered support in a level than exceeds Mr. Price's
26
entire net income. This divorce was only filed recently. Mr. Price did not intentionally reduce his
27
28

Page4 of7 V. FREITAS LAW, PLLC
544 291h Avenue
(206) 328-7362
work hours or desire to suffer from a severe health condition to lower maintenance or child
2
support. The parties are left with the reality of Mr. Price earning $14,000 per month. Mr. Price
3
suggests the court equalize the parties with a $6,000 per month payment in undifferentiated
4
family support to the mother and allowing her to retain 100% of the income from the rental
5
6 properties. This raises the mother's total income to $7929 per month gross and lowers Mr.
7 Price's gross income to approximately $8,000 per month. Mr. Price will additionally cover 100%
8
of the cost of medical insurance premiums for the children. All other costs for the children,
9
including uninsured medical expenses, necessary education expenses and extracurricular
10
11
activities should be split 50/50.
12 IfMr. Price's request for a transfer of $6,000 is granted, he would agree that any bonuses
13
received or commissions that exceed an income of $14,000 per month should be placed in trust
14
at one of counsel's offices. Those funds may be disbursed by agreement of the parties or by
15
further court order. Mr. Price cannot agree to this provision if the support transfer is not lowered
16
17 to $6,000 because he would need any additional bonuses or commissions just to meet his
18 obligation to the mother as it already exceeds his net income.

19
PAYMENT OF INSURANCE PREMIUMS
20
Having equalized the parties, the Petitioner should be responsible for all of her expenses
21
including her auto insurance premium of $123 per month and her share of her own medical
22
23 insurance premiums which is $297.02 per month.
24
25
IV.Evidence Submitted
26 All records and files herein submitted to the court for the Motion on Temporary Orders
27 on November 21 5\ 2017.
28

544 291h Avenue
(206) 328-7362
No other evidence may be submitted as pursuant to LCR 7(b)(8)(B)(iii): "All motions fo
2
revision of a Commissioner's order shall be based on the written materials and evidenc
3
submitted to the Commissioner, including documents and pleadings in the court file.
4
Pursuant to LCR 7(b)(8)(B)(iii), ''the moving party shall provide the assigned Court ... a
5
6 copy of the electronic record, ifthe motion before the Commissioner was recorded."A copy of
7 the CD of the hearing will be provided to the court with the working papers.
8
9
V. Legal Authority
10
11
This Motion is based upon RCW 26.09, RCW 26.09.060(6), RCW 2.24.050. LFLR
12 5(c)(4)(G), and LR 7(b)(5).

13
The Court shall review the case de nova and revise any decisions within its judgment and
14
discretion.
15
16 A "hearing de novo" is defined as "trying matter anew the same as if it had not been
17 heard before and as if no decision had been previously rendered." Black's Law Dictionary,
18
Sixth Ed., West Publishing Co., 1990.
19
20 Under RCW 2.24.050, a party may request a revision of a superior court commissioner's
21 order "upon demand made by written motion, filed with the clerk of the superior court,
22
within ten days after ... entry." LCR 7(b)(8)(A) and (B) require certain timing (10-6-21),
23
such as the "motion ... shall be served and filed within 10 days of entry of the written
24
order. .. ," any set hearing must be at least with "six days notice of the time, date and place of
25
26 the hearing on the motion for revision," and "a hearing on a motion for revision ... shall be
27
28

544 29th Avenue
(206) 328-7362
scheduled within 21 days of entry of the commissioner's order." LCR 7(b)(8)(A) and (B)
2
(emphasis added).
3
When considering a commissioner's ruling on revision, the superior court reviews the
4
5
commissioner's findings of fact and conclusions of law de nova on the record. State v.
6 Ramer, 151Wn.2d106, 113, 86 P.3d 132 (2004); RCW 2.24.050. It also applies the de nova
7 standard and does not apply any deference to the commissioner's reasoning, findings,
8
rulings, or eventual orders. The revision court has full jurisdiction over the case and is
9
authorized to determine its own facts based on the record before the court. In re Marriage of
10
11 Dodd, 120 Wn.App. 638, 644, 86 P.3d 801 (2004).
12
13
VI. Conclusion
14
For the foregoing reasons, Mr. Price is requesting that this court revise Commissioner
15
Brudvik's Order dated November 21, 2017.
16
17 Respectfully submitted on this 30th day of November 2017,
18
19
20
Veronica Freitas, WSBA No. 19405
21
22
23
24
25
26
27
28

544 29th Avenue
(206) 328-7362
EXHIBIT A
V. FREITAS LAW, PLLC

I
544 29th Ave Seattle, Washington 98122 tel• (206)328-7362 Ifax• {206)323-0404
2
FILED
NOV 2 t 2017
3 SONYA KRAS.Kl
COUNTY CLERK
4 SNOHOMISH CO. WASH.
5 IN THE SUPERIOR COURT OF THE S.JAIJLQF :WA.SHINGTDN ___ ~-----· --- ---
- - - - - -------------IN AND FOR THECOUNTY OF SNOHOMISH
6
In re the M~age of: Case No.: 17-3-02497-31
7
SALLY JO PRICE, TEMPORARY FAMILY LAW ORDER
8
Petitioner,
9
and
10
CHARLES A. PRICE~ JR.,
11
Respondent.
12
13 Temporary Family Law Order

14 1. Money Judgment Summary
15 DNo moneyjudgment is ordered.
16 O Summarize any money judgments in the table below.
17
I Judgment for D~btor's name I Creditor's____!Amount l Interes
i
(person w~~ must ! name (per.b'Son
' ' !
J J
I
j!
1
pay money/ _ _, wh~ mu.st e I
11
18 ..
-.·_·_·- ~- -_ _ -I-~-~~-
1•
/. La\V)'er's fee_s__
- _ _ _ __
·. . -·.--·iE.azd,). .· l
~--p,,-~-.r~---~e...~~JS:,.~ao_j_~----~
19 1
1Ot -~~------ . --·-··--·L--.-~?-1-~--_._:_·--~---~~~~
20
21
lfliiiL:_
'. ..¥
ea.!ft Interest Rate:
l
_o 1~% unless otherwise listed) ·-··-·------·-
_I ---·--~---J~~-_J
$
~
j]:._~!_VYer (nameh ---·-··· ________ representU.1?_ame2_:__,__ ,_ __.______ _i
22. l_!:a~! (nam!!)__~-.,-.___,____ ·--'- . represents (nal!l.!!l.~---·--- --~--J
23 ,t vvli BREWE LAYMAN P.S.

wneys at law
l~}~~{l. kiox488
fr~ Washington 98206-0488 ___._ _
24 ·~\:::::? (425)°252-5167 Phone
l'iGMfiflRARY FAMILY LAW ORDER - 1 (425 252-9055 Fax
www.brewelaw.com
I 2. Findings
2 The Petitioner made a Motion for Temporary Family Law Order (form FL Divorce 223) or
a Motion for Immediate Restraining Order (form FL Divorce 221) and the court finds there
3 is reason to approve this order.
4 3. Active duty military
5
(I'hefederal Servicemembers Civ!l Relief1:ct covers: ________ ·- ____________ . _ _
------- ---------.-----Army, Navy, 71.ir Force, Marine Corps, and Coast Guard members on active duty,'
• National Guard members under a call to active service for more than 30 days in a
6
row; and
• commissioned corps of the Public Health Service and NOAA.
7
The state Service Members' Civil ReliefAct covers Washington state residents who are
National Guard or Reserve members under a call to active service for more than 30 days in
8
a row, and their dependents.)
9 None of the parties are covered by the state or federal Service Members Civil Relief Act,
OR no party covered by the Acts has asked for a stay.
10
~ The Court Orders
11
4. Care of children
12
This order includes these children:
13
14
15
16 The court signed the temporary Parenting Plan filed separately.
17 Neither party shall take or permanently remove the children out of Washington
state.
18
Petitioner and Respondent shall be and hereby are restrained and enjoined from
19 making derogatory, hostile, or disparaging comments or remarks to the parties'
children whose actual or intended effect is to cause ill feelings or alienation
20 between the parent and the children.
21
discussing the pending legal proceedings with the parties' minor children except as
authorized by the court.
22
23 I BREWE LAYMAN P.S.

Attorneys at Law
P.O. Box488
Everett, Washington 98206-0488
24 (425j 252-5167 Phone
mM:f;QRARY FAMILY LAW ORDER~ 2 (425 252-9055 Fax
www.brewelaw.com
I 5. Pro\'ide support
2 The eol:lrt signed the temporary Child Support O,·~t· and W4:Jrk£heets filed sepm:ately.
l.M'l.A1~""'-~A
3 The Respondent must pay~nsal support to his spouse.
_J.l t>C.
11,_,0/),D - .
Amount: $ _ _ per month. 'b.! £:~ _;:1 ) 2° I J
::t;ti
4 .
Jii2': ·; , . : I ' ;Ce t? i/ I -k.... '
5 --- -··-- ... -- .
Datel st PC!Y1ll~~1 _is dl!t! _ _ ,__ Qay_ qfthe _mon_th_e.a~h_p_aym_entis_ due . ?- _Ai.. ·- ___ -- _- -; --
1/ 2 ~ 3 fl_ .
6 Make all payments to: _ .
Jkthe other spouse/domestic partner. ~~/JS/ f ~
7 [] Washington State Child Support Registry (available if..c · ~ort is
paid through the Registry).
8 {)Vt--{~ :{5V\.lc
6. Family home -
w 1,....-f ~ 1. ..... ·f)
VI,,./) t-G ~
i
lllLC..-"-<.I
9
Stay in the home - The Petitioner may stay in the family homfud r~ii-us~he
10 furnishings, furniture, and adornments located therein.
h£<-_y VV'l.J-V€.>f K-+-
11
.i
12 7. Use of property
13 Petitioner will possess and use:
14 property in possession now.
15 vehicle/s: 2010 Mercedes GL550
16 Respondent will possess and use:
18 vehicle/s: 2012 Audi Q5.
19 Petitioner and Respondent shall be and hereby are restrained and enjoined from
interfering with the use and enjoyment of the other party's automobile.
20
8. Protect property
21
The Petitioner and Respondent must not move, take, hide, damage, borrow against, sell or
try to sell, or get rid of any property, unless it is a usual business practice or to pay for basic
22 needs. Both parties must notify the other about any expenses that are out of the ordinary.
Attorneys at Law
P.O. Box488
24 Everett, Washington 98206-0488
(425) 252-5167 Phone
-mMfQ.RARY FAMILY LAW ORDER~ 3 (425) 252-9055 Fax
www.brewelaw.com
1
2 entering any safe deposit box containing records and/or property belonging to
either or both parties in the absence of a court order or the other party's written
3 consent.
4 The Petitioner and Respondent must not move, talce, hide, damage, borrow against,
sell or try to sell, or get rid of any property, unless it is a usual business practice or
5 to pay for basic needs. Both spouses/domestic partners mu_s_! I1Qti_fy_!h~_~ther a~oii.t__.
... -· -·. ··- ·-- ··---·--····----·
-an_y: expense-Sthafare-61.it of the-ordinary~ ·- -- -- - -- -- ·-- ·-·
6
7 destroying or alienating the community credit of the parties, or from further
incurring community obligations or obligating each other or the community in
8 any way, except in the usual course of business or for the necessities of life.
transferring, removing, encumbering, concealing, selling, damaging, conveying,
10 mortgaging, giving away, destroying, moving, hiding, disposing of, or otherwise
alienating any of the community or separate property of the parties, including but
11 not limited to IRA, Keogh,401-K, retirement, pension, and/or profit sharing
accounts.
12
13 withdrawing any money from any bank, savings and loan association, brokerage,
insurance company, credit union, or other financial institution account of any kind
14 or nature whatsoever, except in the ordinary course of business or the necessities
of life.
15
16 altering, hiding or deleting the text and/or directory identifications and/or drive
path and/or program accessing system of any personal, family, or business
17 documents of any kind or nature whatsoever stored on a computer hard drive,
floppy disc, USB drive or other electronic memory storage system.
18
19 deleting the other party from his or her status as a signer on any account or credit
care of either or both of the parties.
20
dissolving and/or changing the ownership of any corporation, partnership or other
21 business entity, or disposing, selling, pledging, transferring, mortgaging, conveying,
secreting or encumbering the major assets of any corporation, partnership or
22 business entity in which either party has an interest.
BREW E LAYMAN P. s.
23 I Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
l~~;QRARY FAMILY LAW ORDER - 4 (425 252-9055 Fax
www.brewelaw.com
1
2 secreting or tampering with the other party's mail, PROVIDED that each party may
change the mailing address for mail addressed to them individually.
3
9. Household expenses ~,,,
....~~?{
' ., J -:i
,,,_
I l / 11
4
Household expenses must be paid as follows:
5
10
Each party shall be responsible for their own household expenses except for any
11 r_ specific designati9ns set forth_ above. ·-r, }1-h)·,.A.P. .l f si--vill ..A-t...~VLc:ve- i-v........ '-
f>~ rs O\JVL \2..e.~ , .....~~ (-'Ve......_ • \2d+t> ~.-c:..;_-f- 'G ~el..Ll. c:. 00~<---k.. -te ..,,._.~~:
12 10. Divide debts .e:ir.-.......,t p~ 11'\-t..t...""'~""'"-'- · ''P.t..---ti-l-1,-v'-"-tll.- ~ ~ p~+
A'bl \ NL-ttl,' IC, b\/'l..1..-f--N ~·
13 The Petitioner and Respondent must: _,- c ,. \ .D
c.~ _ .c,~ ...-.....t • , ~ ........~~r
.J ~n • c:~~-
LV \~ ..f--t.."'-.....Y·
14 Each be responsible for his/her own futilre debts, including debt from credit cards,
loans, security interest, and mortgages, unless ordered differently.
15
Pay debts as follows:
16 f - --------
~~_ebt (descriq_ej_____,_______ _ _ --~=~-~~=~Iivho should pay -----------···
17 L1. Julie Lang_abeer _____________ _! Pet!_!~o_n_e_r_ __
18 Petitioner and Respondent shall be and hereby are immediately responsible for their
own debts incurred since the date of separation.
19
Petitioner and Respondent shall be and hereby are restrained and enjoined from not
20 incurring any debt for which the party incurring the same will not agree to be solely
liable.
21
22 incurring any extraordinary debts without providing the other party thirty (30) days
prior written notification of intention to incur the same.
23 I
BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
l'~Mf;QRARY FAMILY LAW ORDER - 5 (425) 252-9055 Fax
www.brewelaw.com
1
11. Do not change insurance
2
The Respondent must not make changes to any medical, dental, health, life, property, or
3 auto insurance policy that covers either spouse/domestic partner or any child named in
section 4 above. That means s/he must not transfer, cancel, borrow against, let expire, or
4 change the beneficiary of any policy.
5 J~ay premiums ~s follows:
[_POI~~-~:~==-====-=~~~~~:==~=~
II Who pays--~~==-==~-=~=
6
I 1. Medical --------··--·- Responde~!________________
7 [_2. Q~~ta1~- _______________ 1Respgp.d~nt
_____________ _
i 3. Q_p!~~al . ·-·-----·-·---·-- l Respondent_____________ _
8 j 4. Orthodontia ___________________ LRespondeJ.!L______________ _
[?.Aut~~~}J~--=~--- ------·---·-·--·--·------_J Responden!__ _____________ _
9
12. Pay fees and costs
IO
. [] Request r e s -
c:; t
c-0
{)£)(:)-
I
I? _J
l
/~o }l
11
·g:., The Respondent must pay the other party's lawyer fees. Amount: $ . Make
12 payments to _ _(11r:mie) by _ _ (date).
~-.r~e- ~~ '>
Money Judgment
--r.s.
13
14 {] Tue :ameHflt's listed abo•1e must be paid, bttt the court is not enterffig a i;1wney_
judgment at this rune.
15
'fJ.-Thc amollllt/s listed above shall be entered as a money judgment. (Summarize
the money judgment in section 1 above). The interest rate is 12% 1.illless anGther
16
amount is listed here [] Tho interest rate is % because ~t /
17 [] Other: T VL.fl-.
18 Each party shall bear their own legal fees.
19 13. Restraining order
\.I_./
. ~······
20 No request made.
21 14. Other temporary orders (if any)

22
23 I BR EWE LAYMAN P.S.

Attorneys at Law
P.O. Box488
24 (425} 252-5167 Phone
~Mf:Q.RARY FAMILY LAW ORDER - 6 (425) 252-9055 Fax
www.brewelaw.com
Petitioner and Respondent shall be and hereby are restrained and enjoined from bothering,
intimidating, assaulting or disturbing the peace of the other party in any manner.
2
The Petitioner shall be awarded the income from the following investment or income-
3 producing property commencing immediately:
4 A. Marysville rental property on 66th Dr. N.E. - to Petitioner/Wife

B. Stanwood rental property on 271 st St. N.W. -to Petitioner/Wife
s . 0~~~;""~~;:,::~d. -lo QAJ.Lf .. ~. ,,..~,'c'.,,.,,, .« ~ ,,,~.;,,.,,
6
DONE IN OPEN COURT this'4 ~y of November, 2017. t1~.
7
9 This order: This order:

is presented by Petitioner's attorney is presented by Petitioner's attorney
10 may be signed by the court without notice to may be signed by the court without notice to
Petitioner Respondent
11
12 BREWE LAYMAN P.S.

Attorneys at Law
13
14
Robert Mar, WSBA 27735
na A. Layman, WSBA 25260 Attorney for Respondent
15 ttomey for Petitioner

is presented by my attorney is presented by Petitioner's attorney
17 may be signed by the court without notice to me may be signed by the court without notice to me
~
19~Pri~
18
Cha.des A. Price, Jr,./

Petitioner "
Respondent
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
l'~M\1;QRARY FAMILY LAW ORDER - 7 !425) 252-5167 Phone

425) 252-9055 Fax
www.brewelaw.com
EXHIBITB

I
544 29th Ave Seattle, Washington 98122 tel• (206)328-7362 Ifax• (206)323-0404
1. PAYMENTS BASED ON A TERM OF A TRANSACTION.
ii. i. Except as provided in paragraph (d)(1)(iii) or (iv) of this section, in connection vd.th
a consumer credit transaction secured by a dwelling, no loan originator shall receive and
no person shall pay to a loan originator, directly or indirectly, compensation in an
amount that is based on a term of a transaction, the terms of multiple transactions by
an individual loan originator, or the terms of multiple transactions by
multiple individual loan originators. If a loan originator's compensation is based in
whole or in part on a factor that is a proxy for a term of a transaction, the loan
originator's compensation is based on a term of a transaction. A factor that is not itself a
term of a transaction is a proxy for a term of the transaction if the factor consistently
varies with that term over a significant number of transactions, and the loan
originator has the ability, directly or indirectly, to add, drop, or change the factor in
originating the transaction.
m. Ii. Single of multiple transactions.
The prohibition on payment and receipt of compensation under
§ 1026.36(d)(1)(i) encompasses compensation that directly or indirectly is based on the
terms of a single transaction of a single individual loan originator, the terms of multiple
transactions by that single individual loan originator, or the terms of multiple
transactions by multiple individual loan originators. Compensation to an individual loan
originator that is based upon profits determined with reference to a mortgage-related
business is considered compensation that is based on the terms of multiple transactions
by multiple individual loan originators. For clarification about the exceptions permitting
compensation based upon profits determined with reference to mortgage-related
business pursuant to either a designated tax-advantaged plan or a non-deferred profits-
based compensation plan, see comment 36(d)(1)-3. For clarification about "mortgage-
related business," see comments 36(d)(1)-3.v.B and-3.v.E.
A. A. Assume that a creditor pays a bonus to an individual loan originator out of a bonus
pool established with reference to the creditor's profits and the profits are determined
with reference to the creditor's revenue from origination of closed-end consumer
credit transactions secured by a dwelling. In such instance, the bonus is considered
compensation that is based on the terms of multiple transactions by multiple individual
loan originators. Therefore, the bonus is prohibited under§ 1026.36(d)(1)(i), unless it is
otherwise permitted under§ 1026.36(d)(1)Civ).
B. B. Assume that an individual loan originator's employment contract with

a creditor guarantees a quarterly bonus in a specified amount conditioned upon
the individual loan originator meeting certain performance benchmarks (e.g., volume of
originations monthly). A bonus paid following the satisfaction of those contractual
conditions is not directly or indirectly based on the terms of a transaction by
an individual loan originator, the terms of multiple transactions by that individual loan
originator, or the terms of multiple transactions by multiple individual loan
originators under§ 1026.36(d)(1)(i) as clarified by this comment 36(d)(1)-i.ii, because
the creditor is obligated to pay the bonus, in the specified amount, regardless of the
terms of transactions of the individual loan originator or multiple individual loan
originators and the effect of those terms of multiple transactions on the creditor's
profits. Because this type of bonus is not directly or indirectly based on the terms of
multiple transactions by multiple individual loan originators, as described in
§ 1026.36(d)(1)(i) (as clarified by this comment 36(d)(1)-1.ii), it is not subject to the 10-
percent total compensation limit described in§ 1026.36(d)(1)(iv)(B)(1).
iv. iii. An individual loan originator may receive, and a person may pay to an individual
loan originator, compensation in the form of a contribution to a defined contribution
plan that is a designated tax-advantaged plan or a benefit under a defined benefit plan
that is a designated tax-advantaged plan. In the case of a contribution to a defined
contribution plan, the contribution shall not be directly or indirectly based on the terms
of that individual loan originator's transactions. As used in this paragraph (d)(1)(iii),
"designated tax-advantaged plan" means any plan that meets the requirements of
Internal Revenue Code section 401(a), 26 U.S.C. 401(a); employee annuity plan
described in Internal Revenue Code section 403(a), 26 U.S.C. 403(a); simple retirement
account, as defined in Internal Revenue Code section 408(p), 26 U.S.C. 408(p);
simplified employee pension described in Internal Revenue Code section 408(k), 26
U.S.C. 408(k); annuity contract described in Internal Revenue Code section 403(b), 26
U.S.C. 403(b); or eligible deferred compensation plan, as defined in Internal Revenue
Code section 457(b), 26 U.S.C. 457(b).
v. iv. An individual loan originator may receive, and a person may pay to an individual
loan originator, compensation under a non-deferred profits-based compensation plan
(i.e., any arrangement for the payment of non-deferred compensation that is
determined with reference to the profits of the person from mortgage-related business),
provided that:
A. A. The compensation paid to an individual loan originator pursuant to this

paragraph (d)(1)(iv) is not directly or indirectly based on the terms of that individual
loan originator's transactions that are subject to this paragraph@; and
B. B. At least one of.the following conditions is satisfied:
1. 1. The compensation paid to an individual loan originator pursuant to this

paragraph (d)(1)(iv) does not, in the aggregate, exceed 10 percent of the individual loan
originator's total compensation corresponding to the time period for which the
compensation under the non-deferred profits-based compensation plan is paid; or
2. 2. The individual loan originator was a loan originator for ten or fewer transactions
subject to this paragraph @consummated during the 12-month period preceding the
date of the compensation determination.
EXHIBIT C

I
Washington State Child Support Schedule Worksheets
[X] Proposed by [X] Charles Price [ ] State of WA [ ] Other (CSWP)
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
County Snohomish Case No. 17-3-02497-31
Child/ren and Age/s: Alex Price, 14; Colby Price, 11; Madison Price, 5
Parents' Names: Charles A. Price, Jr. (Column 1) Sally Jo Price (Column 2)
Charles Sally Jo
Part I: Income (see Instructions, paqe 6)
1. Gross Monthly Income
a. Waqes and Salaries Imputed for Sallv Jo $14016.78 -
b. Interest and Dividend Income - -
c. Business Income - $1,929.89
d. Maintenance Received - $3,054.89
. e. Other Income - -
f. Imputed Income
a.Total Gross Monthly Income (add lines 1a throuqh 1f)
-
$14016.78
$2,693.00
$7,677.78
2. Monthly Deductions from Gross Income
a. Income Taxes (Federal and State) Tax Year: 2017 $1,596.93 $412.09
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes $860.44 $478.71
c. State Industrial Insurance Deductions - -
d. Mandatory Union/Professional Dues - -
e. Mandatory Pension Plan Payments - -
f. Voluntary Retirement Contributions $416.67 -
Q. Maintenance Paid $3,054.89 -
h. Normal Business Expenses
i. Total Deductions from Gross Income
- -
{add lines 2a through 2h} $5,928.93 $890.80
3. Monthly Net Income (line 1Q minus 2i) $8,087.85 $6,786.98
4. Combined Monthly Net Income $14,874.83
(add both oarents' monthlv net incomes from line 3) ...• ;/.
5. Basic Child Support Obligation (Combined amounts ---+)
Alex Price $1206.00
Colby Price $975.00 $3,156.00
Madison Price $975.00
-
- .
6. Proportional Share of Income (divide line 3 by line 4 for each parent) .544 .456
WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 1 of 5
Charles Sally Jo
Part II: Basic Child Support Obligation (see Instructions, page 7)

7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.) $1,716.86 $1,439.14
B. Calculating low income limitations: Fill in only those that apply.
Self-Support Reserve: (125% of the Federal Poverty Guideline.) $1,256.00
a. Is combined Net Income Less Than ~1,000? If yes, for each
parent enter the presumptive $50 per child. - -
b. Is Monthly Net Income Less Than Self-Sui;mort Reserve? If yes,
for that parent enter the presumptive $50 per child.
c. Is Monthly Net Income egual to or more than Self-Sui;mort
- -
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 child. $1,716.86 $1,439.14
Part Ill: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page B)
10. Health Care Expenses
a.Monthly Health Insurance Premiums Paid for Child(ren) $891.00 -
b. Uninsured Monthly Health Care Expenses Paid for Child(ren) - -
c. Total Monthly Health Care Expenses (line 1Oa plus line 1Ob) $891.00 -
I~~,~~ :1,i~~'
d.Combined Monthly Health Care Expenses
(add both parent's totals from line 1Oc} $891.00
11 . Dav Care and Special Expenses
a. Day Care Expenses - -
b. Education Expenses - -
c. Long Distance Transportation Expenses - -
d.Other Special Expenses (describe)
- -
- -
- -
- -
e. Total Day Care and Special Expenses
(Add lines 11 a through 11 d)
- -
i
12. Combined Monthly Total Day Care and Special Expenses (add
-
=
both parents' day care and special expenses from line 11 e}
13. Total Health Care, Day Care, and Special Expenses (line 1Od
plus line 12) ' $891.00 ..
14. Each Parent's Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13) $484.70 $406.30
Part IV: Gross Child Support Obligation

15. Gross Child Support Obligation (line 9 plus line 14) $2,201.56 $1,845.44
Charles Sally Jo
Part V: Child Support Credits (see Instructions, page 9)

16. Child Support Credits
a. Monthly Health Care Expenses Credit $891.00 -
b. Dav Care and Special Expenses Credit - -
c. Other Ordinary Expenses Credit (describe)
- -
- -
- -
d.Total Support Credits (add lines 16a throuqh 16c) $891.00 -
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 qreater) $1,310.56 $1,845.44
Part VII: Additional Informational Calculations
18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent) $3,639.53 $3,054.14
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent) $429.22 $359.79
Part VIII: Additional Factors for Consideration (see Instructions, page 9)
20. Household Assets
(List the estimated value of all major household assets.)
a. Real Estate - -
b. Investments - -
c. Vehicles and Boats - -
d. Bank Accounts and Cash - -
e. Retirement Accounts - -
f. Other: (describe) - -
- -
- -
- -
21. Household Debt
(List liens against household assets, extraordinary debt.)
a. - -
b. - -
c. - -
d. - -
e. - -
f.
22. Other Household Income
- -
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name - -
Name - -
b. Income Of Other Adults in Household
Name - -
Name - -
Charles Sally Jo
c. Gross Income from overtime or from second jobs the party
is asking the court to exclude per Instructions, page 8 - -
d. Income Of Child(ren) (if considered extraordinary)
Name - -
Name - -
e. Income From Child Support
Name - -
Name - -
f. Income From Assistance Proqrams
Program - -
Proqram - -
Q.Other Income (describe)
- -
23. Non-Recurrinq Income (describe)
- -
- -
- -
24. Child Support Owed, Monthly, for Bioloqical or Leoal Child(ren)
Name/age: Paid f l Yes f l No - -
Name/age: Paid []Yes [] No - -
Name/aqe: Paid fl Yes fl No
25. Other Child{ren) Living In Each Household
- -
(First name(s) and age(s))
26.0ther Factors For Consideration

Other Factors For Consideration (continued) (attach additional pages as necessary)
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.
Parent's Signature (Column 1) Parent's Signature (Column 2)
Date City Date City
Judicial/Reviewing Officer Date
This Worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 5 of 5 SupportCalc® 2017

c: .. \state templates\waworksheet.dtf y:\family soft\price, c\price, c.scp 11 /29/2017 11 :19 am
EXHIBITD

I
[ ] Proposed by [ ] [ ] State of WA [ ] Other (CSWP)
Parents' Names: Charles A. Price, Jr. (Column 1) 3lly Jo Price (Column 2)
Charles Sally Jo
a. Waqes and Salaries $14016.78 $1,929.89
c. Business Income - -
e.Other Income - -
f. lmouted Income - -
q. Total Gross Monthly Income (add lines 1a throuqh 1f) $14016.78 $6,228.27
b. FICA (Soc.Sec. +Medicare)/Self-Employment Taxes $860.44 $147.63
d.Mandatory Union/Professional Dues - -
f. Voluntarv Retirement Contributions $416.67 -
q. Maintenance Paid $4,298.38 -
- -
{add lines 2a through 2h) $6,861.55 $342.30
3. Monthly Net Income (line 1g minus 2i) $7,155.23 $5,885.97
(add both parents' monthly net incomes from line 3)
5. Basic Child Support Obligation (Combined amounts~)
Alex Price $1206.00
Colby Price $975.00 $3,156.00 ,_.

-
-
6. Proportional Share of Income (divide line 3 by line 4 for each .549 .451
parent)
Charles Sally Jo

8. Calculatinq low income limitations: Fill in only those that aooly.
parent enter the presumptive $50 per child.
b. Is Monthly: Net Income Less Than Self-SuQQOrt Reserve? If yes,
- -
for that parent enter the presumptive $50 per child. - -
c. Is Monthly: Net Income egual to or more than Self-SuQQOrt
amount or the presumptive $50 per child, whichever is greater.
- -
from line 7, 8a - 8c, but not less than the presumptive $50 per child. $1,732.64 $1,423.36
Part Ill: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
a. Monthly Health Insurance Premiums Paid for Child(ren) $891.00 -
b.Uninsured Monthly Health Care Expenses Paid for Child(ren) - -
c.Total Monthly Health Care Expenses (line 10a plus line 10b) $891.00 -
(add both parent's totals from line 1Oc) $891.00
11 . Day Care and Special Expenses
- -
- -
- -
- -
a.Total Day Care and Special Expenses
(Add lines 11 a throuqh 11 d)
- -
both parents' day care and special expenses from line 11 e) -
plus line 12) $891.00

Charles Sally Jo

b. Day Care and Special Expenses Credit
- -
- -
-- -
-
d.Total Support Credits (add lines 16a through 16c) $891.00 -
whichever is greater) $1,330.80 $1,825.20
a. Real Estate - -
b. Investments - -
- -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f. - -
Name - -
Name - -
Name - -
Name - -
Charles Sally Jo
Name - -
Name - -
Name - -
Name
f. Income From Assistance Programs
- -
Proqram - -
ProQram
g.Other Income (describe)
- -
- -
23. Non-RecurrinQ Income (describe)
- -
- -
- -
24. Child Support Owed, Monthly, for BioloQical or LeQal Child(ren)
Name/age: Paid [ ] Yes [ ] No
Paid r l Yes r l No
- -
Name/aQe: - -
Name/aQe: Paid r1Yes r l No - -
25. Other Child(ren) Living In Each Household
WSCSS-Worksheets - Mandatory (CSWICSWP) 0512016 Page 4 of 5

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
WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 5 of 5 SupportCa/c® 2017

c: .. \state templates\waworksheet.dtf y:\family soft\price, c\price, c.scp 11129/2017 11 :18 am
17-3-02497-31
r=1L.ED
RPY
Reply
42
2,011 DEC I _I AH II: 55
2
2~35~09
~~ONYA t'\l~ASKI
3 cornnY CLERK
Il flllllllllllllllllllllllllllllllll Ill SNOHOMISH CO. WASH
4
7
9
In re:
10
11 Petitioner,
and Reply on Revision.
12
13 Res ondent.
14
15
Comes now, Charles A. Price, by and through his attorney of record, Veronica Freitas,
16
and submits this Reply to Petitioner's Response on Revision:
17
18 The W2 opposing counsel references for $17,002 is income from Mr. Price's role as
19 guarantor on a line of credit that he signed for the company. He was removed as guarantor in
20
March of 2016 and has received no income from that date forward. The year prior, tax records
21
show that he received $60,000 due to his role as guarantor. The 1099 showing $26,000 is for
22
Board of Director's compensation. This is given in stock, not dollars. That 1099 was for TWO
23
24 YEARS of payment. Mr. Price anticipates receiving $13,000 for his role on the board in 2017.
25 The parties retain this stock and will be able to divide it as part of the final decree but it is not
26
liquid income. If the court wants to count this as income, then Mr. Price should be allowed to
27
28
Reply on Revision VERONICA FREITAS

Page 1 of4 544 29th Avenue
(206) 328-7362
liquidate this year's stock award. The K-1 form shows income from Sound Pacific Holdings, a
2
real estate investment company which was sold last year. Opposing counsel is grossly
3
overestimating Mr. Price's income. Mr. Price has been operating on the same base-salary for at
4
5
least five years. Opposing counsel notes that there is no evidence of Mr. Price's 2% holdings.
6 Likewise, there is no evidence supporting her contention that Mr. Price dictates his pay and, in
7
fact, the law submitted in the revision motion show the opposite.
8
The rental income on tax returns show a loss due to all of the prior renovations on these
9
properties. At the hearing before the commissioner, a declaration as submitted from the
10
11 contractor, Keith King, stating that all renovations are finished. As such, there will no longer be
12 loss. The actual fixed expenses of maintaining these rentals was addressed in Mr. Price's original
13
declaration with a spreadsheet and was not challenged by opposing counsel. This is in fact the
14
spreadsheet used with Sally's mother, Julia Langabeer, and was akin to a contract. The numbers
15
on the amortization sheet are exact and accurate. Mr. Price is happy to take over the rentals and
16
17 the income produced by them and increase his payment to Mrs. Price to $7,000 per month. This
18 will reduce any uncertainty in Mrs. Price's budget. Mr. Price is not attempting to exaggerate this
19
income in hopes of somehow harming Mrs. Price.
20
In section 6 of the Response brief, opposing counsel attempts to introduce new evidence.
21
22
The $10,479 deposited in Mr. Price's account was due to his expense report. See Exhibit A. This
23 is not income. He is reimbursed for certain expenses according to contract. These covered four
24 months of expenses and included Mr. Price's cell phone, two business flights to Kansas, hotel
25
stays, meetings with realtors, and mileage. To reply to this new evidence, Mr. Price has
26
27
28

Page 2 of 4 544 291h Avenue
(206) 328-7362
submitted the expenses payments and his latest paystub which shows that he is in line to earn
2
under $200,000 this year.
3
Mr. Price has been left in a difficult position. He moved out of the family home and
4
rented at market-rate a three-bedroom home with space for him and his children. This family has
5
6 never "lived large" as Ms. Layman claims. The mother pays $1,000 per month to live in the
7 family home and about an additional $600 in utilities on that home. Their bank statements
8
submitted by opposing counsel do not show frivolous spending. This couple has invested in
9
paying down their mortgage (from $700,000 down to about $120,000), buying rental properties,
10
11 and in rebuilding a recreational vehicle. Mr. Price has already been ordered to pay the health
12 insurance and automobile premiums. With Mrs. Price's expenses, she will have no problem
13
living off $7,000 a month in guaranteed income.
14
Mr. Price is suggesting a revision order that leaves the parties in equitable positions and
15
does not base his income on prior figures that he has not attained in 2017 and will not attain in
16
17 2018 due to his reduction in work hours. Under our proposal, Mrs. Price will receive 50% of the
18 husband's earnings even if those earnings are higher than his estimated $14,000 per month. Any
19
deposits over $14,000 will be disclosed to opposing counsel and the funds split 50/50. If the
20
court does not significantly lower the amount of support, Mr. Price cannot afford to split any
21
additional income as he will need every dollar to cover his own bills.
22
23 Mr. Price is seven months out of a heart attack and surgery. He does not feel well and
24 cannot continue to work the hours he did prior to his health deteriorating. Mr. Price has
25
introduced year-to-date information on his income which shows that he is earning around
26
$14,000 per month. This is the figure the court should use when setting support amounts.
27
28

Page3of4 544 29th Avenue
(206) 328-7362
Respectfully submitted on this 11th day of December, 2017
2
4 L]~
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

(206) 328-7362
EXHIBIT A

I
LeaderOne Financial Corporation Bank:ANB Holding Account Check Number:
Date Document No. Description Amount
11/21/2017 11052017 Expense Report 3,948.54

11/21/2017 08082017 Expense Report 921.29
11/21/2017 09162017 Expense Report 4,180.44
11/21/2017 11072017 Expense Report 1,429.11
. ;;
. ·.:·..'·<.;.:·\_:···. : _:·. ·. '
Paid To: Ch~rles Pri~e~ .· . ·

.··P~te:. Ng~~rnb~V~2. 2o 1
11 SALLY JO PRICE, No. 17-3-02497-31
Petitioner,
12 and Declaration of Charles Price in
Support of Motion to Appoint
13 Parenting Evaluator or GAL
CHARLES A. PRICE, JR.
14 Res ondent.
15 My name is Charles Price and I am the Petitioner in this case. I am over the age of 18
16 and am competent to testify as a witness in this matter. The Respondent, Sally Price and I are in
17 the process of getting divorced. We have three children together, Alex, age 15, Colby age 11
18 and Madison, age 5.
19 A temporary orders hearing was conducted on November 21, 2017. This court entered
20 an agreed temporary parenting plan which granted me residential time with our children every
21 other Thursday to Monday morning and a visit on Wednesdays from after school to 7:30 pm in
22 the off week. It has become apparent to me that this residential schedule is not in our children's
23 best interests. All of the children are struggling with this arrangement. Alex is having the most
24 trouble. It has gotten to the point where Alex refuses to speak to Sally. I am very concerned
25
about the children's emotional stability.
26
When Sally and I were married, Sally made dinner for the children every night and was
generally present for them. I understand that circumstances with Sally have changed
27
28
V. FREITAS LAW, PLLC.

Declaration in Support 544 29th Ave
of Motion to Appoint PE Seattle, WA 98122
Page 1 of4 (206) 328-7362
ORIGINAL v@vfreitaslaw.com
substantially since we separated. Sally is out frequently on nights that she has the children,
2 leaving them to fend for themselves. She has also taken an interest in witchcraft and spirits
3 which takes up a lot of her time and is confusing for the children when they witness her new
4 rituals. I know that Sally may do whatever sh.e wishes and I only mention this behavior because
5 the children are very upset by the seemingly sudden and drastic changes in their mother.
6 I recently learned that Sally was using marijuana and that Alex was aware of it. Alex's
7 adult cousin contacted me after Alex confided in her. This was the first that I had heard that
8 Sally was using marijuana currently or that Alex might also be using marijuana. I immediately
9 contacted Sally and told her what I had heard. She acknowledged having a marijuana pen and
10 said that she was not aware that Alex had taken it. She did not seem surprised that Alex was
1I
aware she had a marijuana pen. We agreed to talk to Alex together and give him a drug test. I
12
was surprised by Alex's demeanor when we met with him. I have not been present with Sally
and the children for several months. Alex was very angry and disrespectful toward Sally during
13
the discussion.
14
Alex had told his cousin that he felt like he did not want to live anymore and that he did
15
not want to live with Sally. I asked Alex about those comments. He said he wanted to live
16
with me, but denied saying anything about not wanting to live. I pointed out that he just made a
17
similar comment earlier in our conversation. He then admitted that he had been depressed
18
lately.
19
The children do not understand the changes in their mother and their home environment.
20
Alex is struggling. I have tried to discuss these issues with Sally but she is defensive and
21
refuses to hear about the children's upset and worry. What is very clear to me after trying to
22
discuss parenting with Sally is that we will not be able to agree on a final parenting plan without
23
the assistance of a parenting evaluator or GAL.
24
My attorney has asked Sally's attorney if Sally would agree to appoint a parenting
25
evaluator or GAL, more than once, and each time Sally has refused. Please see Exhibit A. Her
26
attorney argues that there are not any RCW .191 allegations against either parent, so a parenting
27
evaluator or GAL are not necessary. I do not understand that position. I hope to have a neutral
28

Page 2 of4 (206) 328-7362
v@vfreitaslaw.com
person who can evaluate our situation and speak to our children so their voices can be
2 considered in the final parenting plan decision.
3 Her attorney claims that I am only seeking an evaluation to hurt Sally by questioning her
4 role as primary parent and that I am trying to bully Sally or control her by seeking an
5 evaluation. I did tell Sally that I would seek an evaluator if we could not agree on parenting. I
6 was not trying to bully Sally, I was merely stating a fact about how I understood we would
7 have to proceed short of agreement on parenting. Sally has increasingly been identifying as a
8 victim since we separated. That is another bizarre change in Sally that I do not understand.
9 Sally and I were partners during our marriage. She was very capable. The person her attorney
10 describes in emails, etc. is a total stranger from the person I was married to.
11
I know that there is no way that either Sally or I will move from our positions without an
12
evaluation, which virtually guarantees that we will end up in trial over the final parenting plan.
A parenting evaluator will interview collateral witnesses, the children's teachers, etc. and
13
summarize their statements in their report. If nothing else, the evaluation should shorten a trial
14
by eliminating the need to call many of the witnesses whose statements are contained in the
15
parenting evaluator's report.
16
I do not understand Sally's resistance to agreeing to an evaluation. I am offering to pay
17
for 100% of the evaluator's initial retainer. If additional funds are required to complete the
18
report, I propose that we share those costs 50/50. I am paying Sally $9,000 per month in
19
undifferentiated support, which is more than half of my monthly net income. ·
20
I agreed to the current temporary parenting plan because Sally had been a stay at home
21
mother during the majority of our marriage and I worked outside the home. Sally was proposing
22
less residential time for me in her proposed temporary parenting and she was requesting
23
limitations against me. I have always been very involved in our children's lives. I coached all
24
of their sports teams and attended their school events, assisted with home work and spent
25
quality time with them. I had been trying to negotiate a final parenting plan before I was aware
26
of the extent of the dysfunction at Sally's home. I was not able to predict that Sally would
27
change so drastically so quickly.
28

Page 3 of4 (206) 328-7362
v@vfreitaslaw.com
I do not know if this court believes that a GAL or a parenting evaluator would be most
2 appropriate under these circumstances. I am fine with either so long as the children have an
3 opportunity to be heard.
4 I declare under penalty of perjury under the laws of the state of Washington that the
5 foregoing is true and correct.
6 Signed at Seattle, Washington this 24th day of April, 2018.
Cha~rice
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
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Page 4 of4 (206) 328-7362
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EXHIBIT A

From: Veronica Freitas
To: "Sabrina A. Layman"; Katie Miller
Cc: Amy Pasco; Stevie Craig
Subject: FW: Price W2, Etc.
Date: Monday, April 16, 2018 S:40:00 PM
Hi Sabrina,
Welcome back. I am following up my email message below re: the GAL/PE question. Have you heard
back from your client, or do I need to file a motion?
Mr. Price asked your client to please send him copies of things she receives from the school that are
sent home with the children such as field trip sign ups, etc. Those should be scanned to him
immediately. He has done what he can to have things sent directly to him from the school but there
are some things that are only sent home with the children.
He also requested copies of the children's homework so that he can be sure they are doing
assignments when they are at his residence. Finally, he would like to share in receiving the
children's art projects, etc. that are sent home. He would like to have some for keepsakes.
Your client indicated that she did not intend to respond to his message, so I am sending it to you.
Thank you.
From: Sabrina A. Layman [mailto:sabrinal@brewelaw.com]

Sent: Friday, April 6, 2018 8:22 AM
To: Veronica Freitas <veronica@vfreitaslaw.com>
Cc: Stevie Craig <stevie@vfreitaslaw.com>; Amy Pasco <amy@vfreitaslaw.com>
Subject: RE: Price W2, Etc.
Veronica
I sent to my client. I am out of the office until April 16 but will monitor
my emails to respond timely with what I get from her.
Thanks
Sabrina
From: Veronica Freitas [mailto:veronica@vfreitaslaw.com]

Sent: Thursday, April 5, 2018 3:45 PM
To: Sabrina A. Layman
Cc: Stevie Craig; Amy Pasco
Subject: Price W2, Etc.
Hi Sabrina,
Please see Mr. Price's 2017 W2 attached. Mr. Price is waiting for your client to provide him
with the tax return so he can complete his part of the return. When will she be getting that to
him?
Will you agree to a Parenting Evaluator or a GAL to complete a parenting investigation?

These parties will not be able to agree on a final parenting plan and we will be in trial unless
we have a 3rd party evaluation. Please let me know as soon as possible.
I was hoping we could agree on parenting. Your client's reasons for not sharing the summers
moving forward do not make sense as she will be returning to the workforce and she claims
she will not be teaching in the futures so will work summers presumably. Mr. Price has been
very involved with the children. Your client initially agreed to a 50/50 residential schedule
which is what Mr. Price believes is in the children's best interest and what he will be pursuing.
Mr. Price does need to inventory property in your client's bedroom. There is substantial
property in the closet and pictures or artwork in that room. Your client can be present when
this is accomplished.
-----Original Message-----
Sent: Tuesday, April 3, 2018 4:03 PM
To: Veronica Freitas <yeronica@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>;
Amy Pasco <amy@vfreitaslaw.com>
Cc: Katie Miller <katiem@brewelaw.com>
Subject: FOR SETTLEMENT ONLY - ER 408 PRICE
SEE ATTACHED.
From: ricohscanner@brewelaw.local [mailto:ricohscanner@brewelaw.local]
Subject: Message from "RNP0026738A6D95"
This E-mail was sent from "RNP0026738A6D95" (MP C401SR).
Scan Date: 04.03.2018 15:55:01 (-0700)

Queries to: ricohscanner@brewelaw.local
2
17-3-02497-31
3 AFRSP 57 SGl-i'rA r;Kli.SKi
Affidavit of Defendant Respondent
COUIHY CLEi<K
!1\~ l l l\l l l\l \l l l \l l\l II

4 SNOH8MJSH CO. WASH
7
County of Snohomish
8
In re:
9

10
Petitioner,
Response to Motion for Attorney's
12 Fees and Communication
13 Res ondent.
14
My name is Charles Price and I am the Petitioner in this case. I am over the age of 18
15
16 and am competent to testify as a witness in this matter. I am writing this declaration in response
17 to Sally's motion seeking an order regarding how we communicate about the children and an
18
additional award of attorney's fees.
19
There was no need for Sally to file a motion regarding communication. I am happy to
20
agree to use whatever form of communication Sally prefers. I would appreciate having clear
21
22 boundaries around communication with Sally to protect me from the types of allegations she is
23 making in this motion. I began communicating through attorneys because Sally ignored my
24
email or text messages about some issues and instructed me to go through attorneys on other
25
issues, or her attorney accused me of threatening Sally when I was not being threatening.
26
27
28

Declaration in Response to Motion 544 29th Ave
for Attorney's Fees I Communication Seattle, WA 98122
Page 1 of9 (206) 328-7362
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Meanwhile Sally would call, email or text me about issues and ask me why I am was going
2
through attorneys when we can resolve issues between us.
3
With respect to attorney's fees, Sally has been awarded $9,000 per month in family
4
support, which is more than half of my monthly income (the $9,000 does not include $2,000 per
5
6 month that Sally receives from in rental income monthly). Sally's monthly expenses for the
7 family home are under $1,000 per month. Please see temporary order dated November 21, 2017
8
and order on revision (which reduced Sally's support from $12,000 to $9,000 per month) dated
9
December 12, 2017 attached hereto as Exhibit A. Sally acknowledged that my monthly income
10
11 was $17 ,821 in her declaration in support of her motion, however, in her financial declaration
12 she continue·s to falsely list my income at $34,700 per month. Sally has more available income
13
to use to pay her attorney's fees than I have available to pay mine. I do not understand, given
14
the income division, why she believes I have a greater ability to pay her attorney's fees.
15
Sally stated that I have access to funds via stock in my company and that I receiv
16
17 dividend income in addition to my income. I last received a dividend in 201 7 while Sally and
18 were still residing together. That dividend was $2,770. Please see 1099 attached at Exhibit B.
19
The Leader One Financial stock we own is not a source of funds for us. Leader One is a closel
20
held company, the stock is not publicly traded and can only be transferred to a certain group o
21
individuals. I do not receive any income besides my monthly income which was divided in th
22
23 temporary order.
24 We do have community property cash and investment accounts that can be accessed for
25
attorney's fees. We have $75,000 in a Key Bank account. I propose that we each receive a pre-
26
distribution from that account of $20,000 to use for our attorney's fees, or, alternatively, that we
27
28

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equally divide that account as a pre-distribution to each of us. Sally had withdrawn over
2
$10,500 from our community accounts prior to our temporary orders hearing, I presume for
3
attorney's fees. She was awarded an additional $5,000 for her attorney's fees at the temporary
4
5
orders hearing.
6 Response to Sally's Background Summary
7 I disagree with Sally's contention that I am pursuing a parenting investigation because I

8
am angry about financial aspects of this case. That is a false narrative her attorney has created to
9
prejudice me before this court and it does not make sense. We have a temporary support order
10
11
in place. I know that my child support obligation will not change regardless of the residential
12 schedule and custody will not impact the division of our assets and liabilities.
13
Sally claims that she has had to expend additional fees to engage in ordinary discovery.
14
I have-provided all of the financial documentation that Sally has requested from me in that
15
process. I have no idea what documents Sally is referring to when she states that she is still
16
17 waiting for additional items from me. I believe that Sally is wasting her own funds by hiring a
18 valuation expert to value a business that I do not own. I am a very minority shareholder in
19
Leader One Financial, I own less than 3.5% of the company's stock. I only receive W2 income
20
from the company. My attorney has conveyed this information to Sally's attorney several times
21
but Sally persists in seeking to value the business instead of valuing the stock we own. The
22
23 value of the stock is easily determined by looking at recent sales of stock.
24 There have been changes with respect to the children's situation since the temporary
25
orders were entered despite Sally's assertion otherwise. Please see my motion asking this court
26
to appoint a parenting evaluator or GAL that I filed several weeks before Sally filed this motion.
27
28

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My declaration describes the changes that have occurred since the temporary orders were
2
entered, specifically Alex's struggles and all three children's confusion with Sally.'s
3
significantly changed demeanor toward parenting the children. This court is hearing my motion
4
to appoint a GAL at the same time as this motion. I incorporate my declaration in support of
5
6 that motion into this response by reference.
7 Response to Sallv 's False Narrative re Parenting

8
I am not seeking a GAL to hurt Sally. I always hoped to have an equal residential
9
schedule with the children. Sally and I were discussing a 50/50 residential schedule when we
10
11
discussed separating. I was initially going to buy a house in the same neighborhood as our
12 family home. I needed to make the purchase before Sally filed for this dissolution so that I could
13
qualify for a loan. I planned to live close by Sally's home and be equally involved in parenting.
14
Please see a note that Sally wrote where she summarizes my proposed purchase of a house in
15
our neighborhood and she notes 50150 parenting? at Exhibit C. When Sally and I told the boys
16
17 about the divorce, Alex said he wanted to spend equal time with both of us. See Sally's notes
18 summarizing that meeting attached at Exhibit D. I do not agree with Sally's description of me
19
screaming that she was a liar during that conversation, however, she did accurately record
20
Alex's comments.
21
I agreed to the temporary residential schedule at the temporary orders hearing on the
22
23 advice of my attorney at that time and with the expectation that it was a temporary residential
24 schedule. I hoped that Sally and I would be able to be reasonable about parenting once we had
25
physically separated and were operating separately. I expected that we would be able to agree
26
to me having significantly more residential time than I currently do in the temporary parenting
27
28

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plan. Now that I have seen what has been happening with the children since we separated, I am
2
confident that an equal residential schedule is in the children's best interests. I am not motivated
3
at all by financial matters.
4
5
I never made any demands of Sally. I tried to reach agreements with Sally regarding
6 parenting. When we reached an impasse, I asked Sally to agree to a parenting evaluator. When
7 Sally told me that her attorney was working on a proposed parenting plan, I told Sally that was a
8
not willing to move from the proposal that my attorney sent over and that if she was not willing
9
to agree to that proposal, we should just proceed with the parenting evaluation. I was not
10
11 threatening when I made that statement. I was just talking about my position. Sally attributes a
12 comment to me in her declaration. Here is what I actually said to Sally about her pending
13
proposal, "I don't know about the time, but I would put the offer on the table. I don't think it
14
will be worked out anyway so not sure how much money you want to put into the details at this
15
point."
16
17 Sally's current narrative about my "new" interest in parenting is not accurate or fair.
18 have always been very involved in our children's lives. I coached football at Arlington Boys an
19
Girls Club, and at Lakewood Youth Football for seven years; I attended all of the children'
20
school events and extracurricular activities. I attended the children's parent teacher conferences
21
transported them to tutoring and events, and I assisted with their home work. I also spent qualit
22
23 time with them. I did this despite my working long hours every week. The one thing Sally di
24 that I did not do was take the children to their routine medical appointments because she wa
25
home during the day while I worked. Please see the letter Sally wrote to me in September 201
26
where she describes my involvement with the children attached at Exhibit E.
27
28

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What Sally ignores in her narrative is that I had a massive heart attack on April 19, 2017
2
which profoundly changed my work life. Before my heart attack, I had been working 6 days
3
week, up to 12 hours a day and I was on call 7 days a week. After my heart attack, I put m
4
5
health and parenting as my number one priority. I now work a regular 40-hour week. My wor
6 schedule is flexible so I now have time to volunteer at my daughter's school. See note Sall
7 wrote confirming that I asked about volunteering in Maddie's school in October, 2017, attache
8
at Exhibit F.
9
Sally talks about our settlement negotiations, which I understood were not proper t
10
11 discuss in court pleadings, and she references my request to have the children 50/50 during th
12 summer months. Sally asserts that I am acting in bad faith because she has summers off. This i
13
another unfair example from Sally because Sally stated in her interrogatory responses that sh
14
was not planning to return to teaching and was going to pursue a different career, which
15
assumed meant she would be working during the summers herself. Sally has since changed he
16
17 response to her interrogatory answers and now states that she intends to return to teaching. Sh
18 only did that after her attorney argued that Sally had summers off and my attorney pointed ou
19
Sally's interrogatory responses saying that Sally would not be returning to teaching.
20
Either way, I have the ability to work from home, which is what I intend to do in th
21
22
summers. I do not believe that seeking a 50/50 residential schedule during the summer is ba
23 faith even if Sally had a job where she has summers off. I know that the children need more tim
24 with me. I _thought Sally might find it more palatable to have an equal residential schedul
25
during the summer than the school year given her other comments on the subject.
26
Response to Sally's allegations that I have misused her funds by increasing her attorney's fees.
27
28

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Sally accuses me of increasing her attorney's fees because I have asked her to inform me
2
of the children's medical appointments, etc. Sally argues that she always took the children to
3
routine medical appointments during the marriage. Sally ignores that things have changed since
4
5
Sally and I separated. Yes, she did take the children to their medical appointments when were
6 married, but she also told me about everything that happened with the children when I came
7 home after work and she consulted me about decisions during the day. Now, she tells me
8
nothing and informs me about nothing. All I have asked for from Sally is notice so that I may
9
attend if I am able and so I know what is happening. Sally refused to acknowledge my request
10
11 and continued to fail provide notice so I was forced to have my attorney follow up with Sally's
12 attorney. If Sally would have communicated simple information there would not have been any
13
need for me to involve my attorney. Sally's lack of communication required me to incur
14
unnecessary attorney's fees. It is clear that Sally does not believe I need to be informed or
15
involved in the children's medical issues.
16
17 Sally complains that I have requested a walk through of the family home. I was
18 permitted to take exactly 58 items from the home when I left. Please see letter from Sally's
19
attorney stating that I was not permitted to remove items absent an agreement in writing,
20
attached at Exhibit G. Sally's interrogatories required me to make a very detailed list of
21
property items that I took from the home. I spent a lot of time on that response and worked very
22
23 hard on my interrogatory responses in general. I was looking forward to Sally's interrogatory
24 responses and detailed list of our community property so that I could use her list to determine
25
what items I wanted from the home. Sally did not spend time making a detailed list, which was
26
disappointing and it did not feel fair given how hard I had worked on my response to her
27
28

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interrogatories. Sally failed to include many of our community property items in her list. That
2
is why I requested a walk through.
3
I never demanded that Sally scan me the children's homework, etc. on a daily basis. I
4
5
intended to simply request that Sally provide me with copies of documents re field trips, etc.
6 that are only sent home with the children and not communicated in any other way, when she
7 receives such information. I thought she could send it over once a week. I also mentioned that it
8
would be nice if she would send me some of Maddie's work for me to display at my house. My
9
information is on file with the children's schools and I receive everything that is mailed home,
10
11 but there is a significant amount of information that is communicated to parents only by sending
12 papers home with the children. Sally responded to that my request by saying she was not going
13
to respond, so my attorney needed to follow up with her attorney. Sally could have responded
14
to me with her thoughts, etc. I had to expend attorney's fees to address this issue through
15
counsel.
16
17 Sally did not provide me the necessary information for me to submit our income
18 information for our tax return~ This was frustrating because we heed to have accurate, current
19
income information for this court and for mediation so we can resolve this case. Sally
20
represented to this court that she managed the rental property, which was not accurate. I had
21
historically handled all of the financial matters related to the rental properties. Sally's false
22
23 representations to the court resulted in us not being able to file our income taxes on time. I was
24 trying to make that point when I made the comment about her receiving the rental income.
25
Sally's excuse for not providing the income information is that she is too busy. She said the
26
same thing about her incomplete interrogatory responses, but I am expected to provide detailed
27
28

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information to her attorney on demand and I am working full time. I feel that there is a double
2
standard being applied to me by Sally's attorney.
3
I am pursuing a parenting investigation for what I believe are legitimate reasons which I
4
5
described in my motion seeking the appointment of a GAL. I do not agree that I am making
6 threats to Sally to get her acquiesce to my demands. I am pursuing what I believe is appropriate
7 in this dissolution. Sally and I have different communication styles. I have tried to work with
8
her directly and I have tried to work with her through attorneys. I agree to use a communication
9
tool. It feels to me like the problem is not my communication but the fact that Sally does not
10
11
want to have to include me in decisions about the children and she does not want to have to
12 provide timely responses to appropriate inquires or requests for documentation.

13
I have had to expend attorney's fees for basic communication with Sally. I was forced to
14
expend attorney's fees to schedule my summer vacation with the boys because Sally is non-
15
responsive and because she did not recall the current orders which required several exchanges
16
17 with attorneys for both summers.
19
foregoing is true and correct.
20
Signed at Seattle, Washington this 28th day of May, 2018.
21
22
23
24
25
26
27
28

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EXHIBIT A

I
1
2
FILED
NOV 2 r 2017
3 SONYA KRASKI
COUNTY ClERfi(
5 IN THE SUPERIOR COURT OF THE S.I.t\IE_OF WASHThlGION._ --·---- ··-- -··-

-- --------·-·-------JN AND FOR THE COUNTY OF SNOHOMISH
6
In re the Marriage of: Case No.: 17-3-02497-Jl
7
SALLY JOPRlCE, TEMPORARY FAMILY LAW ORDER
8
Petitioner,
9
and
10
CHARLES A. PRICE, JR.,
11
Respondent.
12

15 0 No money judgment is ordered.

17
l Judgment for Debtor's name-T Credito~-;·5-1 Amount -, 1;.t~res - I
j . (person who must l name (person ! Ji I
~=-~-t:~::Jf~~-~J
18
19
20 ~- _____l_ ~·y--.-~1~-=j
21 l.
Yea!!f Int~-~~!t Rate:
Lawyer (n'!!lle)_:
o 12%unl~.§. otherwiselisted) ··----·-·-----
re resents (name): • .--~------__:)
I
22. l_1awye!.(name)~--- - __-.______ ·-.--' represents (namel_~----~-~-- . __J

___
BREWE LAYMAN P.S.
23 ttwneys at Law
iox488
24 . ffit~ Washington 98206-0488 ___..,_
(425)252-5167 Phone
l'~Mf~Y FAMILY LAW ORDER - 1 (425) 252-9055 Fax
www.brewelaw.com
1 2. Findings
5
(!'he federal Servicemembers Civil ReliefAct covers: ______________________ ... _
· ·----- -------------.----Army, Navy, 7ffrForce, Marine Corps, and Coast Guard members on active duty,'
6
row; and
• commissioned corps ofthe Public Health Service and NOAA.
7
8
10
);;> The Court Orders
11
4. Care of children
12
13
14
15
state.
18
Petitioner and Respondent shall be and hereby are restrained and eajoined from
21
22

Attorneys at Law
P.O. Box488
24 Everette. Washington 98206-0488
(425) 2:J2-5167 Phone
liMf:QRARY FAMILY LAW ORDER - 2 (425) 252-9055 Fax
www.brewelaw.com
1 5. Provide support
2 The eetll't sigtted the temporary Child Sttppm'f 0,·-der and W~rk&heets aled separaool~
l.M'\Mfr~A~A
3 The Respondent must pay4o.usal support to his spouse.
-"" t>C.
~ 11-, bl>D ._...
4 Amount: $ _ _ per month. 'b~ c=~ ..1 } 2° I '"J _
~ )tt: I I. &tot?
I i I -h.... \
5 Date 1st Pl!Yl11~f!1 _i~ dµ~_____ ,__Qa.y Q.fth~_:m_m1th_ e.a.c.h_p_aymenJ:js_ due _ '!- -~·- ·- .___ ~. _ _ .; --
112 IV\ :?J fl- .
Jkthe other spouse/domestic partner. ~ ~oslf ~
7 [] Washington State Child Support Registry (available if_c · ~ort is
8 {)}IL.{ M/ ;{1vJc..
6. Family home u:ii.,......{~ wit!<:: 'buu............
9
Stay in the home - The Petitioner may stay in the family homfud r~~us~he
ha,y \fV'l.NLA ~+.
11
/
18 vehicle/s: 2012 Audi QS.
20
8. Protect property
21
Attorneys at Law
P.O. Box488
24 {425) 252-5167 Phone
m~~y FAMILY LAW ORDER- 3 {425) 252-9055 Fax
www.brewelaw.com
1
3 consent.
to pay for basic needs. Both spouses/domestic partners must notify the other about
5
of
-any-expenses thafare«:>tit the-ordinary. -- --- - - - --- -- - ---- -- -- - - --- - --- ---- --
6
10- mortgaging, giving away, destroying, moving, hiding, disposing of, or otherwise
accounts.
12
of life.
15
18
20
21
business entity, or disposing, selling, pledging, transferring, mortgaging, conveying,
23 I BREWE LAYMAN
Attorneys at Law
P.O. Box488
P.S.

(425! 252-5167 Phone
I~~~y FAMILY LAW ORDER - 4 (425 252-9055 Fax
www.brewelaw.com
I
3
9. Household expenses '"P~2s7 J?-h /
11
4
5
-[~xp-;nse-=:~~-=- -·- ~--=~~-~~~-~:~~::_::~~=-=-'.~~--=::--=:_-::·=:=~~-=:~~~
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.
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6 ! First Mo~g~~g~ on family home ---···-..H·-···-- .L Petitiol!~~--··----------------·~----1 -.. . . . .

l Mortgage and utilities on _r.~!?-!~_lpropef!Y in !v!__~il!~------.JR~!itiop.er._____________ J
i Mort_g~_g_~--~d_ utilit~s on rental prope!!J_i!!__~-!~w~od ______ ! Pet!_tio~_!______________,_____ I _
7
l Utiliti~s on family hol!!~----··-·----------------J_P~!i!ioner A-~1---~-- ;1 OL-l CL ·
\ Child Care l Proportionate share
=.,.,...+ ~Lls
8 I Other: Petitioner shali be responsible fur-hlsfh~r own___ TI>etitioner________________ --------L ~ t, l
l_house}_!_old exp_~nses not above specifie4.:__________________J__,_________________,____ . .1,"'-"-"'-V
9 I Other: Respondent shall be responsible for his/her own i Respondent
I househol4~~P~!1_Se§ not above specifie~..:____________________J ____,
10
11 r~ specific designati9ns set forth_ above. ·-p-e,,+l-ho-v~ s~ill ..A-e_~V\.A/e.... ~........ <... ,\
phuY\£... t--Jf1vut. (le.~ '"'--"UL~ (.'Ve......_ • ~ ~-l- 'S ~et..V.. .c.'-'~<-k -{t:l ~ - te p lP'\.SC
12 10. Divide debts ~<A...;-t p~ lf\..L"-""'~'... · ·-p~-tl-l--'\IY'-"--dl- ~ ~ p..-L..+ ve..
A'bl, Ni.-ftl\'K-, b\t'e.t.--f--N ~h ~
13 The Petitioner and Respondent must: c.r, t=-a....vt c ~\. • , ~ .,,.__.~....:.-}- -h\ c.-·iL--"-,.,.._....,...
LO \ ~ ·-l...--L"\--<-&-- ·
15
16
I~eht (describe)________________=:==~~~=~=~=-~=-~-=-~1 Who-silouidpai__________
17 LL. Juli~ L~gabeer ·-·-----··· I Petit!on~~------------- ______ _
19
liable.
21
P. s.
23 IBREW E LAYMAN
Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
l'~Mf~RY FAMILY LAW ORDER - 5 (425 252-9055 Fax
www.brewelaw.com
1
2
5 Pay premiums
.. ··- ·--
.
as follows:
--
-·· .. ·-·· ...... .. .
[i>oli~L--=====~-=-=:·-·-·----- -----·-·-----------J ----------------=~=

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6
'. 1. Medical ------..·--·---------·-----------..:.IJ.~~~ond.5?_nt _________________
7 i 2~-D~_g_!~L___ -----------..-------·------ LRespo1_1~~~L_______________
! 3. Optical _________________..__ ____. ________ . ______ ! Respondent___________________..___
8 L4.:9rthodontia -·---------------· ____ LB~-~p_Q_~ent ________
[J. AutOB!Q~g~----------- __________, ________ _j__Respond~_!lj__________________ _
9
10
. [] Reql1estres~ b
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11
·g:, The Respondent must pay the other party's lawyer fees. Amount: $ . Make
12 payments to _ _(name) by _ _(date).
v;.,-,;v.J\.f e_ ~ ~ ~ "f'. S.
13 Money Judgment
14 {] The amel:lfltls listed abo 1e must be paid; bnt the cocu't is not enteriftg a a:ioney_
1
judgment at tms tim~

15
'fJ/--Tue amount/s listed above shall be entered as a money judgment. (Summarize
the money judgment in section 1 above). The interest rate is 12% wliess angther
16
amount j5 listed here [] Tho interest rate is % because ~t /
17 OOOcr: ~ ~~
20 No request made.
22

Attorneys at Law
P.O. Box488
24 (425} 252-5167 Phone
1jb!f;QRARY FAMILY LAW ORDER - 6 (425) 252-9055 Fax ·
www.brewelaw.com
------ -----------------
2

s o~~lJ:,....~k.c"';:~~°' --le> ~if ~ .,.~,..,_..rs ,,,- ~ ,,,~.;,.,,
6
DONE IN OPEN COURT this~f 4y ofNovember, 2017. (IJ)
7

11

Attorneys at Law
13
14

~
J.Pri~
18
19 Chru;les
...,, A. Price, Jr.,./
20
21
22

Attorneys at Law
P.O. Box488
l'!GM.f;QRARY FAMILY LAW ORDER - 7 !

425j 252-S167 Phone
425 252-9055 Fax
www.brewelaw.com
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF SNOHOMISH
PLAINTIFF I PETITIONER
and
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DONE IN OPEN COURT this date: _ _ _ _ _ _ _ _ _ __
Presented By:
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DONE IN OPEN COURT this date:

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FDWA1102L 04i11117 CORRECTED (if checked) f-
PAYER'S name, street address, city or town, state or province, country, ZIP or 1a Total ordinary dividends OMB No. 1545-0110 l
foreign postal code, and telephone no.
I
Leader ·one Financial Corporation I
$ 2770.20 Dividends and I
1b Qualified dividends 2017 Distributions I
7500 College Blvd. Suite 1150 I
Overland Park, KS 66210 I
I
913.-747-4000 $ 2770. 20 Form 1099-DIV
I
2a Total capital gain distributions 2b Unrecap. Sec. 1250 gain I
CopyB I
For Recipient I
$ $ I
PAYER'S federal identification number RECIPIENTS identification number 2c Section 1202 gain 2d Collectibles (28%) gain I
I
I
I
48-1148159 533-86-7767 $ $
I
RECIPIENTS name, street address, city or town, state or province, country, and ZIP 3 Nondividend distributions Federal income tax withh d I
or foreign postal code
$ I
Charles Price This is important I
Investment expenses tax information I
$ and is being
1604 Hewitt Avenue, Ste 401
7
furnished to the
6 Foreign tax paid Foreign country or U.S. Internal Revenue
possession
Service. If you
Everett WA 98201
$
are required to
file a return, a
9 ~i~rrrgi3l101hiuidation negligence
8 ~fr7~1l,~~;tion penalty or other
$ $ sanction may be
FATCA filing 1 O Exempt-interest dividends 11 Specified private activity imposed on you ii
requirement bond interest dividends this income is
taxable and the
$ $ IRS determines
that it has not
Account number (see instructions) 12 State 13 State ident~icat1or. no. 14 State tax withheld been reported.
$
------- ------------
$
Form 1099-DIV (keep for your records) Department of Treasury - Internal Revenue Service
EXHIBIT C

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I
544 29th Ave Seattle, Washington 98122 tel• {206)328-7362 lfax• (206)323-0404
EXHIBITG

544 29th Ave Seattle, Washington 981221 tel• {206)328-7362 Ifax• {206)323-0404
Kenneth E. BreWe
BREW E LAY MA l\l P.S. Sabrina A. Laymall
Karen D. Moore
Attorneys at Law Rebecca J. Torgerson
Robert J.Miller
Kent R. Goodrich
Sara M. Epler
l<en Evans
November 8, 2017 Mediation Services
COPY VIA EMAIL & ORIGINAL MAILED
Robert Mal'
Goldberg & Jones PLLC
1200 Westlake Ave. N, Ste. 700
Seattle~ WA 98109
Re: Price Dissolution
Deru•·Robe1t
It is our understanding that Mr. Pl'ice is moving out of the family home this upcoming weekend
and is demanding he have access to certain furnishings, community personal pl'operty items, and
tools. Absent written agre.ement any disputed items need to remain in the family home pending
further agreement or comt order.
Additionally, please advise Mr. Price that Ms. Price does not agree to close any community
accounts associated with the family home at this time and we request that he refrain from
harassment.
Thank you.
Sincerely,
BREWE LAYMAN P.S.

Attorneys at La
Sabrina A. Layman
Attorney at Law
SAL/km
cc: Sally Price

P.O. Box 488
Everett, Washington 96206·0488
425.252.5167 EvereU
206.971.5555 Seattle
360.419.9191 MountVernon
425.252.9055 Fax:
brewelaw.com
ekOB2h1253
17-3-02497-31
PTDSS 1 .
Petition for Dissolution
2011 OCT 26 AM 11= 18
1
2 '. \~iiill\l~\l,\l\\IU (10HYA rrnASKI

COUNTY CLERK
SHOHOHISH CO. W.ASH
3
5 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

6
In re the Marriage of: .CaseN17' 3 024.97 31
7
SALLY JO PRICE, PETITION FOR DIVORCE
8 (DISSOLUTION)
Petitioner, (PTDSS)
9
and
10
11
Respondent.
12
13 Petition for Divorce (Dissolution)

14 1. Information about the parties
15 Petitioner lives in Snohomish County, WA.
Respondent lives in Snohomish County, WA.
16
2. Information about the marriage
17
We were married on October 7, 2000 at Everett, WA.
18
We currently live in the same household.
19
3. Request for divorce
20
This marriage is irretrievably broken. I ask the court to dissolve our marriage and find
21 that our marital community ended on:
22
23
the date this Petition is filed. OR'G' NAL I
BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
425) 252-5167 Phone
1425) 252-9055 Fax
www.brewelaw.com
1 4. Jurisdiction over the spouses
2 The court has jurisdiction over the marriage because at least one of the spouses lives in
Washington State, or is stationed in this state as a member of the armed forces.
3
The court has personal jurisdiction over the Respondent because:
4
The Respondent lives in Washington State.
5
The Petitioner and Respondent may have conceived a child together in this state.
6
5. Is one of the spouses pregnant?
7
No.
8
6. Children of the marriage
9
My spouse and I have the following children together who are still dependent (only list
10 children you and your spouse have together, not childrenfrom other relationships):
11 Child's name
1. Alexander 14
12
13
a. Children's home/s
14
During the past 5 years have any of the children lived:
15 • on an Indian reservation,
• outside Washington state,
16 • in a foreign country, or
• with anyone who is not a party to this case?
17
No. (Skip to b.)
18
b. Other people with a legal right to spend time with a child
19
Do you know of anyone besides you and your spouse who has (or claims to have)
20 a legal right to spend time with any of the children?
21 No. (Skip to c.)
22
BREWE LAYMAN P.S.
P.O. Box488
24 (4251252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
1 c. Other court cases involving a child
2 Do you know of any court cases involving any of the children?
3 No. (Skip to 7.)
4 7. Jurisdiction over the children (RCW 26.27.201 - .221, .231, .261, .271)
5 The court can approve a Parenting Plan for the children my spouse and I have together
because (check all that apply; if a box applies to all of the children, you may write "the
6 children" instead of listing names):
7 Home state jurisdiction- Washington is the children's home state because:
Alexander, Colby, and Madison Price lived in Washington with a parent or

8 someone acting as a parent for at least the 6 months just before this case was
filed, or if the children are less than 6 months old, they have lived in
9 Washington with a parent or someone acting as a parent since birth.
10 8. Parenting Plan
11 I ask the court to order a Parenting Plan for the children my spouse and I have together. I
will file and serve my proposed Parenting Plan (form FL All Family 140)
12
at the same time as this Petition.
13
9. Child Support
14
Court Order - I ask the court to order child support (including medical support)
15 according to state law for the children my spouse and I have together. (You may ask for a
court order of child support even if there is already an administrative order. The court
16 order will replace the administrative order to the extent the court order is different.)
17 I ask the court to order my spouse to pay his/her proportionate share of:
18 work-related day care expenses

education expenses
19 other child-related expenses: sports and extra-curricular activities
20 10. Children from other relationships
21 Neither spouse has children from other relationships who are still dependent.
22
BREWE LAYMAN P.S.
P.O. Box488
24
!425l 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 11. Written Agreements
2 Have you and your spouse signed a prenuptial agreement, separation contract or
community property agreement?
3
Yes.
4
Type of written agreement: Community Property Agreement contained in Last Will
5 and Testament
Date of written agreement: December 22, 2003
6 Should the court enforce this agreement? Yes
7 12. Real Property (land or home)
8 I ask the court to divide the real property according to the written agreement described in
11 above.
9
13. Personal Property (possessions, assets or business interests of any kind)
10
I ask the court to divide the personal property according to the written agreement
11 described in 11 above.
12 14. Debts
13 I ask the court to order each spouse to be responsible for debts s/he incurred (made) after
the date of separation.
14
Divide the debts fairly (equitably) as the court decides.
15
15. Spousal Support (maintenance/alimony)
16
Spousal support is needed. The Respondent has the ability to pay and should pay support:
17
as decided by the court.
18
16. Fees and Costs
19
Order my spouse to pay my lawyer's fees, other professional fees, and costs for this case.
20
17. Protection Order
21
Do you want the court to issue an Order for Protection as part ofthe final orders in this
22 case?
BREWE LAYMAN P.S.
P.O. Box488
!
42Sj 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 No. I do not want an Order for Protection.
2 18. Restraining Order
3 Do you want the court to issue a Restraining Order as part of the final orders in this
case?
4
No. (Skip to 19.)
5
19. Name Change
6
No request.
7
20. Other requests, if any
8
The Petitioner Requests the court to enter a decree of dissolution and to grant the relief below.
9
A. Provide spousal support for Petitioner in a reasonable amount for an appropriate
duration as authorized by RCW 26.09.090.
10
B. Approve the Petitioner's proposed parenting plan, filed herewith, for the dependent
11
children listed in section 6.
12
C. Determine support for the dependent children listed in section 6 pursuant to the
Washington State child support statutes including provisions for post high school
13
education.
14
D. Fairly and equitably dispose of parties' community and separate property.
15 E. A ward the Petitioner legal fees, professional fees and costs as authorized by RCW
26.09.070.
16
F. Equitably divide the tax exemptions for the dependent children.
17
G. Award such other relief as is just and equitable.
18
Petitioner fills out below:
19
I declare under penalty of perjury under the laws of the state of Washington that the facts I have
20 provided on this form are true.
21 Signedat(cityandstate): ~V~ (WA Date: 10/d-3/ 17

22 ~ Printn~m~tl'O Pq·c~ BREWE LAYMAN P.S.
P.O. Box488
(4251252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
BREWE LAYMAN P.S.
Attorneys at Law
By ~ ---
&1'6rina A. Layman, WSBA 25260
Attorney for Petitioner
BREWE LAYMAN P.S.

I Attorneys at Law
P.O. Box488
!425j 252-5167 Phone

425 252-9055 Fax
www.brewelaw.com
FILED
1
17-3-02497-31 ZO I7OCT 26 AM 11 : 18
SM 2
Summons
SONYA KRASKi
·~im1imim1~1mm~
2 cou~nY CLEf~K
SNOHOMISH CO. WASH
3
\
5 IN THE SUPERIOR COURT OF THE STAT-E OF WASHINGTON

3 024 97 Jl
6
In re the Marriage of: CaseNo.:17
7
SALLY
,..
JO PRICE, SUMMONS: NOTICE ABOUT A
8 ', MARRIAGE OR DOMESTIC
Petitioner, . -,. PARTNERSHIP
9 (SM)
and
10
11
Respondent.
12
13 Summons:
14
Notice about a Marriage or Domestic Partnership
To the Respondent:
15
1. The Petitioner has started a case asking the court:
16
to end your marriage.
17
Additional requests, if any, are stated in the petition, a copy of which is attached to this
18 summons.
19 2. You must respond to this summons and petition by servicing a copy of your written
response on the person signing this summons and by filing the original with the clerk of the
20 court.
21 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,
22 exclusive of the day of service, the court may enter an order of default against you, and the

Attorneys at Law
24
~JJM~NS-1
ORIGINAL P.O. Box488
!
425l 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 court may, without further notice to you, enter a decree and approve or provide for the
relief requested in the petition.
2
In the case of a dissolution of marriage or domestic partnership, the court will not enter the
3 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
4 or a decree may be entered.
3. Your written response to the summons and petition must be on one of these forms:
5 11 Response to Petition about a Marriage (FL Divorce 211) if you are married, or
• Response to Petition about a Registered Domestic Partnership (FL Divorce 212) if
6
you are a domestic partner.
7 4. You can get the Response and other forms at:
• The Washington State Courts' website: www.courts.wa.gov/forms
8 • The Administrative Office of the Courts - call: (360) 705-5328
• Washington LawHelp: www.washingtonlawhelp.org, or
9 • The Superior Court Clerk's office or county law library (for a fee).
10 5. If this action has not been filed with the court, you may demand that the petitioner file this
action with the court. If you do so, the demand must be in writing and must be served upon
11 the person signing this summons. Within 14 days after you serve the demand, the petitioner
must file this action with the court, or the service on you of this summons and petition will
12 be void.
13 6. If you wish to seek the advice of any attorney in this matter, you should do so promptly so
'that your written response, if any, may be served on time.
14
7. One method of serving a copy of your response on the petitioner is to send it by certified
15 mail with return receipt requested.
16 This summons is issued pursuant to RCW 4.28.180 and Superior Court Civil Rule 4.1 of the state
of Washington.
17
Dated this 2u day of October, 2017.
Attorneys at Law
19
20 By~~--:--=-__::==~~==--=-=
rina A. Layman, WSB 5260
21 Attorney for Petitioner
22
BREWE LAYMAN P.S.
P.O. Box488
(425! 252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
17-3-02497-31
CICS 3 2017 OCT 26 AH 11 : 19
Case Information Cover Sheet
1977607
SONYA KRASKI
COUNTY CLERK
· 1111111111111111111111111111111111111111 SNOHOMISH CO. W.ASH
. FAMILY
S Y\DVlo MI~ COUNTY SUPERIOR COURT
Case Information
..,, Cover Sheet (CICS)
Case NU11b1 ~ Q24, 97 31case Title,-:J:V\f.€ lliJ /v!£1m'C<~ af-&' {..0

Attorney ~ame k\}zv) \/Vi\_. L~V\M,.Vl.- Bar Membership Number"Z0Zleo
Please check one category that best d~ es 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.
D ADP Adoption D osc Out-of-State Child Custody

D ARY At-Risk Youth D PAT Parentage - Parental Determination
D CHN Confidential Name Change D PPR Initial Pre-Placement Report
D CIR Committed Intimate Relationship D PPS Parenting Plan I Child Support
D CNS Child in Need of Services D PUR Parentage (URESA/UIFSA)
D cus Child Custody D REL Relinquishment
D DDP Developmental Disability D RIC Reciprocal, Respondent In-County
D DEP Dependency D ROC Reciprocal, Respondent Out-of-County
_:S-DIC Dissolution of Marriage with Children D RPR Reinstatement of Parental Rights
D DIN Dissolution of Marriage with No Children D RVS Relative Visitation
D DPC Dissolution of Dom. Partnership-w/Children D SEP Legal Separation
D DPN Dissolution of Dom. Partnership-No Children D SPD Legal Separation - Domestic Partnership
D EFC Extended Foster Care Services D TER 5 Termination of Parental Rights-Parentage
D FJU Foreign Judgment - Domestic D TER 7 Termination of Parental Rights-Dependency
D GFC Guardianship Foster Care D TRU Truancy
D INP Invalidity- Domestic Partnership
D INV Annulment- Invalidity
D MDS Modification - Support Only
D MOD3 Domestic Modification
D MODS Parentage Modification
D MSC3 Miscellaneous Domestic
D MSCS Miscellaneous -Adoption
D MWA Mandatory Wage Assignment
IF YOU CANNOT DETERMINE THE APPROPRIATE CATEGORY, PLEASE DESCRIBE THE CAUSE OF ACTION BELOW.
Please Note: Public information in court files and pleadings may be posted on a public Web site.
FILED
2017 OCT 26 IU111: 18
17-3-02497-31
SONYA KHASKI
AC 4 COUNTY CLERK
Acknowledgment SNOHOMISH CO. WASH
1977610
Ill I111111111111111111111111111111111111
I SUPERIORCOURTOFWASffiNGTON.
IN ANil FOR SNOHOMISH COUNTY
2
4 Petitioner,
5 vs.
Acknowledgement of Receipt o(
6 Family Law Handbook(s)
·(Insert Respondent's Name Above)
7 · . Respondent
· (insert your name) am tlie:
9 ·D Petitioner D Respondent D Attom~y for Petitioner/Respondent ·

(circle one)
10
r::ti:egal Messenger hir~d by the Attorney for Petitmner/Respondent
ll (circle one) ·
12
13 ~ fu£1her ackno:wledge th~t: ·
14 D I am filing aj9int petition signed by both the Petitioner an~ the Respondent and I have been
provided wiili ..a copy of the Family Law Handbook for the 9tlier party and )"ill deliver the same
15 to him/her. · · · ·
16 ~oes No~ Apply - The p~tition. is not a joint petition:

17 Verification
18 I certify under penalty of perjury under the Laws of the State of Washington, that I havetead the above
statements, know their contents and believ_e them to be true and ~orrect I acknowledge receipt of the
19 Family Law Handbook as provided by the.Snohomish County Clerks· Office effective today.
20
21
Signed in Everett, WA on
· (Date)
\()·2lo·t?r 1~
--·-·~7:r. ~--(.
22 -.. ,-.~..7 .._::.
S:\FORMS\FCOURTSER VICES\FAMIL Y LA W\DOMESTIC\Family· Law Handbook Acknowledgment.DOC
2
17-3-02497-31 'FILED
TMRO 5
~\~~~ii~ii~il1111~
3 Z0170CT 26 AM 11: 18
4 SONYA KRASKI
COUNTY CLERK
5 SNOHOMISH CO. WASH
6 SUPERIOR COURT OF WASHINGTON
7
COUNTY OF SNOHOMISH
9
In Re the Marriage of: NO.
10
Sally Jo Price
11
12 and
Petitioner,
3 31
TEMPORARY RESTRAINING ORDER
13 Charles A Price, Jr (TMRO)
Respondent
14
15
16 I. NOTICE TOPARTIES
17
1. This order shall apply to the following types of cases filed after May 1, 2010:
18
A. All family law petitions seeking dissolution of marriage, legal separation, parentage,
19
or declaration of invalidity.
20 B. Actions brought by parties to non-marital relationships involving parenting or
distribution of assets/liabilities.
21
22 II. ORDER
23 IT IS ORDERED:
24
2.1 TEMPORARY ORDERS FOR ALL PARTIES TO DISSOLUTION, LEGAL SEPARATION,
25 INVALIDITY, COMMITTED INTIMATE RELATIONSHIP, OR STATE REGISTERED
DOMESTIC PARTNERSHIP ACTIONS.
26
27
(a) Both parties are restrained from transferring, removing, encumbering, concealing, damaging or in any
way disposing of any property except in the usual course of business or for the necessities of life or as
28 agreed in writing by the parties. Each party shall notify the other of any extraordinary expenditure
made after this order is issued.
29 (b) Both parties are restrained from assigning, transferring, borrowing, lapsing, surrendering or changing
30 entitlement of any insurance policies of either or both parties, or of any dependent children whether
medical, health, life or auto insurance, except as agreed in writing by the parties.
31
32 TEMPORARY RESTRAINING ORDER

SPR 94.04 (effective 5/1/2010, Revised 01127/11)
Page 1 of2
(c) Each party is responsible for his or her own future debts whether incurred by credit card, loan,
2 security interest, or mortgage, except as agreed in writing by the parties.
(d) Both parties shall have access to all tax, financial, legal, and household records. Reasonable access to
3
records shall not be denied. This provision does not apply to documents protected by the attomey-
4 client or attorney work product privilege.
5 2.2 TEMPORARY ORDERS FOR PARTIES IN ACTIONS INVOLVING MINOR CHILD(REN).

6
(a) Under this order, the term "parent" is limited to only those persons listed on a valid birth certificate or
7 a presumed father under RCW 26.26.116.
(b) Each parent shall be restrained from changing the residence of the child(ren) until further court order,
8 except as agreed in writing by the parties. Subsequent orders regarding parenting issues supersede
9
previously issued orders to the extent that the orders may be inconsistent.
(c) Each parent shall have full access to the child(ren)'s educational and medical records.
10 (d) Each parent shall ensure that the child(ren) are not exposed to negative comments about the other
parent. Neither parent shall make negative comments about the other parent in the presence of the
11
child(ren).
12
2.3 IT IS THE RESPONSIBILITY OF THE PETITIONER TO SERVE A COPY OF THE
13 AUTOMATIC TEMPORARY ORDER ON THE RESPONDENT.
14
The Petitioner shall serve a copy of this Order on the Respondent and file a declaration of
15 service in the court file
16 2.4 EFFECTIVE DATE OF ORDER

17
The Petitioner is subject to this order from the time of filing the Petition. The Respondent is subject to
18 this order from the time that the order is served. This order shall remain in effect until further court order.
19
20 Dated: October 26. 2017

SUPERIOR COURT COMMISSIONER
21
22
23
24
25
26
27
28
29
30
31
32 TEMPORARY RESTRAINING ORDER

SPR 94.04 (effective 5/1/2010, Revised 01127/11)
Page 2 of2
' 17-3-02497-31
\MTTMO 6
20170CT 26 AHIJ: 19
1 Motion for Temporary Family Law Order and RE
SONYA KR.ASK!
2
3
~iiij\llll~~l~~ll~llllllI! COUNTY CLERK
S~WHOM!SH CO. WASH

6
7
In re the Marriage of: CaseNo.: t7 3 021f. 97
SALLY JO PRICE, MOTION FOR TEMPORARY FAMILY
8 LAW ORDERS
Petitioner,
9
and
10
11
Respondent.
12
13 Motion for Temporary Family Law Order

14 Use this form in marriage/domestic partnership cases only. For parentage cases, use form FL
Parentage 323. For non-parent custody cases, use form FL Non-Parent 423.
15
1····T<>1J<>tllp~rties:·············
16
i Deadline! Your papers must be filed and served by the deadline in your county's Local Court
17 i Rules, or by the State Court Rules if there is no local rule. Court Rules and forms are online at
i www.courts.wa.gov.
18
I If you want the court to consider your side, you must:
19
• File your original documents with the Superior Court Clerk; AND
20 • Give the Judge/Commissioner a copy of your papers (ifrequired by your county's Local
Court Rules); AND
21 • Have a copy of your papers served on all other parties or their lawyers; AND
• Go to the hearing.
22

Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
watifi.1.Qi'J FOR TEMPORARY FAMILY LAW ORDERS - 1 (425 252-9055 Fax
www.brewelaw.com
1 The court may not allow you to testify at the motion hearing. Read your county's Local Court
Rules, if any.
2
Bring proposed orders to the hearing.
3
To the person filing this motion:
4
You must schedule a hearing on this motion. You may use the Notice of Hearing (form FL All
5 Family 185) unless your county's Local Court Rules require a different form. Contact the court
for scheduling information.
6
To the person receiving this motion:
7
If you do not agree with the requests in this motion, file a statement (using form FL All Family
8 13 5, Declaration) explaining why the court should not approve those requests. You may file
other written proof supporting your side, and propose your own Parenting Plan or Child Support
9 Worksheets.
10 1. My name is Sally J. Price. I ask the court for temporary orders approving the requests
listed below.
11
2. Children
12
I want my children under 18 listed below to be included in the court's orders:
13
14
15
17 (I'he federal Servicemembers Civil ReliefAct covers:

• Army, Navy, Air Force, Marine Corps, and Coast Guard members on active duty;
18 • National Guard members under a call to active service for more than 30 days in a
row; and
19 • commissioned corps of the Public Health Service and NOAA.
20 National Guard or Reserve members under a call to active service for more than 30 days in
21
My spouse/domestic partner is not covered by the state or federal Service Members Civil
Relief Acts.
22
BREWE LAYMAN P.S.
P.O. Box488
(425j 252-5167 Phone
~il.Q~FOR TEMPORARY FAMILY LAW ORDERS-2 (425 252-9055 Fax
www.brewelaw.com
1 4. Care of children
2 Approve the parenting plan proposed by me.
3 Order both parties not to take or permanently remove the children listed in 2 out of
Washington State.
4
Order both parties from making derogatory, hostile, or disparaging comments or
remarks to the parties' child(ren) whose actual or intended effect is to cause ill
5
feelings or alienation between the parent and the child(ren).
6 Order both parties from discussing the pending legal proceedings with the parties'
minor child(ren) except as authorized by the court.
7
5. Provide support
8
Order child support according to the Washington state child support schedule.
9
Order my spouse to pay spousal support (maintenance/alimony) in the amount of: $15,000
10 every month pending further agreement or court order.
11 6. Family home
12 Stay in the home.
13 I want to continue living in the family home.
14 Move out. Order my spouse/domestic partner to move out of the family home within one
week of entry of the Temporary Family Law Order.
15
7. Use of property
16 Order that I can possess and use
17 property in my possession now.
18 Vehicle: 2010 Mercedes GL550
19 Other:
20 the furnishings, furniture, and adornments located in the family home

located at 11423 4th Ave. N.E.,
21
the above listed vehicle and for my spouse to not interfere with my use and
22 enjoyment of the their vehicle.
23 I BREWE LAYMAN P.5.

Attorneys at Law
P.O. Box488
(425l 252-5167 Phone
~m~FOR TEMPORARYFAMILYLAW ORDERS-3 (425 252-9055 Fax
www.brewelaw.com
1
Order that my spouse/domestic partner can possess and use
2
property in his possession now.
3
vehicle: 2012 Audi Q5.
4
8. Protect property
5
Order both parties not to move, take, hide, damage, borrow against, sell or try to sell, or get
6 rid of any property, unless it is a usual business practice or to pay for basic necessities. (If
the court makes this order, both spouses/domestic partners must notify each other about
any expenses that are out of the ordinary).
7
9. Household expenses
8
Order household expenses to be paid as follows so long as sufficient family support is paid
9 to wife:
10
[~!Ii~~~~·:: . -···· · · · · · · · · · · · · · · · · ·:•-. ...••-. -. . ··-- ··:::.:] W~~~~~~!~.P.?.!••······
Lfit~!.M2~g~g~_2P.:J~gyh.2~~- . . . . . .-.. . ;. 1?~!!!!2P.:er
11
I M2~g~g~ . ~4~!i.H!~~~.2P.:!.~P.:!~l.P.!.9.P.~~jP.:M~~Y.i.!!~ . . . . . . . . . !. Petitioner
[ M2~g~g~-~4~!i.H!!~~. .9P.:..!.~P.:!~l.P.!.9.P.~rtY . !P.:§!~~99.4. ···-······!. Petitioner
12 i 1!!i.H!!~~9.P.:J~l.Y.h.9~~-- .. . . . . . . . . . . . Lf>etitioner
13 l····§~~~:~~1i1ionersliai1···heresponsibie·rc;J= his!herown-·····i·····~~i~~~~~~!~~h.~~---····
i ~iii~~?-~~s~~~d~~i~sii~\t~<?~~~~~~~~~ rorhis!herown
4
14 \·Respondent
I. P.g~~~h.2!.4.~~P.~P.:~~~P.:2!_~!?.2Y~~P~~!t.1~4.: ... ... .... ... L. . . . ·--·· ·
15
10. Divide debts
16
Order my spouse/domestic partner and me to:
17
Each be responsible for his/her own debts, including debt from credit cards, loans,
18 security interest, and mortgages.
19 Divide the debts as follows (list debts and who should pay each one):
······················•¥""""'"'""" ....................................................................................
20 ['-?.~.~! . C4.~~e:Jk<!l . . . . . . . . . . . . . . j W~~-~-~~~!~ P?.Y

!. . . !. ~ . . l~l.~~---~~g~!?.~~!.. . . . .. .... . Jpetitioner
21
22

Attorneys at Law
P.O. Box488
(4251252-5167 Phone
~il.Qi'J FOR TEMPORARY FAMILY LAW ORDERS - 4 (425 252-9055 Fax
www.brewelaw.com
1
2
Order both parties not to make changes to any medical, health, life, or auto insurance policy
3 that covers either spouse/domestic partner or any child listed in 2. That means s/he must not
transfer, cancel, borrow against, let expire, or change the beneficiary of any policy.
4
Pay insurance premiums as follows (list policies and who should pay each one):
5
9
10
Order my spouse/domestic partner to
11
pay my lawyer's fees for this case. Amount: $15,000.00.
12 13. Restraining Order
13 No request.
14 14. Other temporary orders
15 Investment/Income Producing Property - Order awarding the parties the income from
the following investments or income-producing property commencing immediately:
16
A. Marysville rental property on 66th Dr. N.E. - to Petitioner/Wife
17 B. Stanwood rental property on 271 st St. N.W. - to Petitioner/Wife
18 Safety Deposit Box - Order both parties from entering any safe deposit box containing
records and/or property belonging to either or both of the parties in the absence of a court
19 order or the other party's written consent.
20 Disturb the Peace - Order both parties to not bother, intimidate, assault or disturb the
peace of the other party in any manner.
21 Protect Property -
22
BREWE LAYMAN P.S.
P.O. Box488
24
~AfJ~ FOR TEMPORARY FAMILY LAW ORDERS - 5 !425j 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 Order both parties from destroying or alienating the community credit card of the
parties, or from further incurring community obligations or obligating each other or
2 the community in any way, except in the usual course of business or for the
necessities of life.
3
Order both parties from transferring, removing, encumbering, concealing, selling,
4 damaging, conveying, mortgaging, giving away, destroying, moving, hiding,
disposing of, or otherwise alienating any of the community or separate property of
the parties, including but not limited to IRA, KEOGH, 401-k, retirement, pension
5
and/or profit sharing accounts.
6 Order both parties from altering, hiding or deleting the text and/or directory
identifications and/or drive path and/or program accessing system of any personal,
7 family, or business documents of any kind or nature whatsoever stored on a
computer hard drive, floppy disc, USB drive or other electronic memory storage
8 system.
9 Order both parties from withdrawing any money from any bank, savings and loan
association, brokerage, insurance company, credit union, or other financial
10 institution account of any kind or nature whatsoever, except in the ordinary course
of business or for the necessities of life.
11
Order both parties from deleting the other party from his or her status as a signer on
12 any account or credit care of either or both of the parties.
Order both parties from dissolving and/or changing the ownership of any
13
corporation, partnership or other business entity, or disposing, selling, pledging,
transferring, mortgaging, conveying, secreting or encumbering the major assets of
14 any corporation, partnership or business entity in which either party has an interest.
15 Order both parties from secreting or tampering with the other party's mail,
PROVIDED that each party may change the mailing address for mail addressed to
16 them individually.
17 Divide debts -
18 Order both parties to not incur any debt for which the party incurring the same will
not agree to be solely liable.
19
Order both parties to not incur any extraordinary debts without providing the other
20 party thirty (30) days prior written notification of intention to incur the same.
21 ~ Reasons/or my requests
22 15. Why are you asking the court for the orders above checked?
BREWE LAYMAN P.S.
P.O. Box488
24 (425! 252-5167 Phone
~il.Q~ FOR TEMPORARY FAMILY LAW ORDERS - 6 (425 252-9055 Fax
www.brewelaw.com
1 • If you need additional space use the Declaration form FL All Family 135.
• If you are asking for a parenting plan, also fill out the Information for Temporary
2 Parenting Plan, form FL All Family 139, and a proposed Parenting Plan, form
FL All Family 140.
3 • If you are asking for child support, also fill out the Child Support Worksheets. If
you have received public assistance for any child in this case, also fill out the
4 Public Assistance Declaration, form FL All Family 132.
• If you are asking for any order involving money (including child support), also fill
5 out the Financial Declaration, form FL All Family 131, and file the required
financial records.
6 • If you are asking to prohibit weapons or order surrender, give your reasons at the
end of this section.
7 • If you are asking to change an earlier temporary order, give the date of the earlier
order and explain how circumstances have changed since then.
8
Dated this 2k_ day of October, 2017.
9
BREWE LAYMAN P.S.
10
11
abrina A. Layman, WSBA 25260
13
Lawyer's address
14 Brewe Layman, P.S.
P.O. Box488
15 Everett, WA 98206
(425) 252-5167
16
Email (attorney/paralegal): sabrinal@brewelaw.com and katiem@brewelaw.com
17
Warning! Documents filed with the court are available for anyone to see unless they are sealed.
18 Financial, medical, and confidential reports, as described in General Rule 22, must be sealed so
they can only be seen by the court, the other party, and the lawyers in your case. Seal those
19 documents by filing them separately, using a Sealed cover sheet (form FL All Family 011, 012,
or 013). You may ask for an order to seal other documents.
20
21
22

Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
~il.Qt-J FOR TEMPORARY FAMILY LAW ORDERS - 7 (425 252-9055 Fax
www.brewelaw.com
_, .
1
2
17- 3 - 0"497-31
..
1
FNDCLRP ation ot petitioner
3 1
5
.\i~\\\\\1\\\1\\
6
Superior Court of Washington, County of Snohomish
7 In re:
17 3 024·97 j\,
Petitioner:
8 No.
SALLY PRICE
9 Financial Declaration of
And Respondent: Name: Sally Price
10 (FNDCLR)
CHARLES PRICE, JR.
11
12 Financial Declaration
13 1. Your personal information
14 Name: Sally Price
The highest year of education completed: 16
15 Your job/profession is: Stay-at-home mom
Are you working now?
16 [ ] Yes. List the date you were hired (month I year): 2009
[X] No. List the last date you worked (month I year):
17 What was your monthly pay before taxes:
Why are you not working now?:
18
19 2. Summary of your financial information
20 (f2of7JR/ete this section after filling out the rest of this form.)
r1. Total Monthly Net Income (copy from section 3, line C. 3.) $2,§..93.00
21 I 2. Total MonthlEx enses After Se aration co from section 7, line I. $15,852.36
IT-Total Monthly Payments for Other Debts (copy from section 9) I $166.67
22 I 4. Total Mont~ Expenses+ Payments for Other Debts (add line 2 and line 3) UJ~Q_'!_9.o3_
23 LGross Monthly Income of Other Party ~._;;..c_.op'"'-y_~_;_ro_;,.;_m'--s'-'"e_;;_ct'-'io'-'n_;;;_3_.A__J.)_ _ _ _ _ _-'-----'-$_34__,,_70_0_.2-"'0___,

24
RCW 26.18.220(1) Financial Declaration Brewe Layman PS

Mandatory Form (0512016)
FL All Family 131 3525 Colby Avenue, Suite 333
Everett, WA 98208
FamilySoft FormPAK PL 2017

ORiG\NAL 425.252.5167
------------------- -
1 3. Income
2 List monthly income and deductions below for you and the other person in your case. If your case
involves child support, this same information is required on your Child Support Worksheets. If you do not
know the other person's financial information, give an estimate.
3
Tip: If you do not get paid once a month, calculate your monthly income like this:
4 Monthly income = Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
5 I A. Gross Monthlv Income (before taxes deductions or retirement contributions) Ii

! Sally Charles I
6
I 1m~uted income $2,693.00 - I
7 I Monthly waQe I salarv - $34, 700.20 I
ir-:---
Income from Interest and dividend Income - - J
---,
8
I Income from business - - I
9 I Spousal support I maintenance received - -
I (Paid by: )
10 I Othe~ Income - -
11 I Total Gross Monthly Income (add all lines above) $2.693.00 $34.700.20
I Total gross income for this year before deductions - -
12 I (starting January 1 of this year until now) I
I
13 ~Monthly Deductions
- n--·--
Sally ! Charles
14
Income taxes (federal and state) - $9,893.04 I
15 FICA (Soc.Sec.+ Medicare) or self-employment taxes - $1,322.65 I
· State Industrial Insurance (Workers' Comp.) - -
16
Mandatorv union or professional dues - -
17 Mandatorv pension plan payments - -
Voluntary retirement contributions (up to the limit in RCW - $416.67
18 C-·
26.19.071 (5)(q))
19
Spousal suooort I maintenance paid - -
Normal busine_ss expenses - -
20 Total Monthly Deductions (add all lines above) - $11,632.36
21 i
C. Monthly Net Income Sally Charles
22 1. Total Gross Monthly Income (from A above) $2,693.00 \ $34. 100.20 I
23
2. Total Monthly Deductions (from B above) - $11.632.36
3. Net Monthly Income (Line 1 minus Line 2) s2.693.oo I $23.067.84
24

FL All Family 131 p. 2 of6 3525 Colby Avenue, Suite 333
Everett, WA 98208
425.252.5167

1 4. Other Income and Household Income
2 Tip: If this income is not once a month, calculate the monthly amount like this:
Monthly income= Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
3
4
~..:. __ _Qther !!.come (Do nqt repeatj[lcome yoy_ a readv listed on PJHJ!!Ll.:1_--,-__. .______________ _
5 Sally Charles
Child support received from other relationships
6
_Other Income From: ( )
7 _Qther Income From: ( )
8 Total Other Income (add all lines above)
9
B. Household Income (Monthlv income of other adults livina in the home) --
10
,_. Sallts Home ! Charles's HC?m~
i'
11 Other adult's gross income - -
re( _}_
Name: ( )
12
Other adult's gross income - - I
13
14
otal Household Income of other adults in the home
add all lines above}
- -
15 5. Disputed Income - If you disagree with the other party's statements about anyone's
income, explain why the other party's statements are not correct, and your statements are
16 correct:
17
6. Available Assets
18 ---··---
19
List vour liauid assets. like cash, stocks, bonds, that can be easilv cashed. I
Cash on hand and money in all checking & savings accounts -
20 Stocks, bonds, CDs and other liQuid financial accounts -
21 Cash value of life insurance -
Other liQuid assets -
22
Total Available Assets (add all lines above) -
23
24

FL All Family 131 p. 3 of 6 3525 Colby Avenue, Suite 333
Everett, WA 98208
425.252.5167

.. )
1
7. Monthly Expenses After Separation
2 Tell the court what your monthly expenses are (or will be) after separation. If you have dependent
children, your expenses must be based on the parenting plan or schedule you expect to have for the
3 children.
A. Housina Expenses F. Transportation Expenses
4 Rent I Mortgage Payment (Family home = $5,975.00 Automobile payment (loan or lease) -
$500.00. Stanwood rental - $5475.00)
5 Property Tax (Family home= $485.91. $1,269.99 Auto insurance, license, registration $1,000.00
Marysville rental= $190.70. Stanwood
6 rental= $550.57. Cabins= $42.82.)
Homeowner's Insurance (Family home) $140.33 Gas and auto maintenance $456.00
7 Other mortgage (Marysville rental) $1, 100.00 Parking, tolls, public transportation -
Homeowner's Association dues or fees $67.00 Other transportation expenses -
8 (Family home)
Total Housing Expenses $8 552.32 Total Transportation Expenses $1,456.00
9
~.
-·
B. Utilities Expenses G. Personal Expenses (not children's)
10 Electricity/heating (Family home= $332.00l $332.00 Clothes $150.00
Water, sewer, garbage (Family home= $971.29 Hair care, personal care $260.00
11 $256.00. Marysville rental = $110.32.
Stanwood rental= $604.97)
12 Telephone(s) - Recreation, clubs, gifts $210.00
Cable, Internet $450.00 Education, books, magazines $117.00
13
Other (specify): Pest control $55.00 Other Personal Expenses -
14 Total Utilities Expenses $1 808.29 Total Personal Expenses $737.00
15 c. H. Other Ex enses
$800.00 Life insurance not deducted from pa
16
17
$1 410.00 Total Personal Expenses
18
D. Children's Ex~enses List all Total Expenses from above:
19 Childcare, babysitting $150.00 A. Total Housing Expenses $8,552.32
Clothes, diapers $200.00 B. Total Utilities Expenses $1_,808.29
20 Tuition, after-school programs, lessons - C. Total Food and Household Expenses $1,410.00
Other expenses for children $150.00 D. Total Children's Expenses $500.00
21
Total Children's Expenses $500.00 E. Total Health Care Expenses $475.42
22 F. Total Transportation Expenses $1,456.00
E. Health Care Expenses G. Total Personal Expenses $737.00
23 Insurance premium (health, vision, dental) - H. Total Other Expenses $913.33
Health, vision, dental, orthodontia, mental
24 health expense not covered by insurance $137.92 I. All Total Expenses (add A- H above) $15,852.3E
Other health expenses not covered by $337.50 Use section 11 below to explain any unusual expenses,
Everett, WA 98208
425.252.5167

1 8. Debts included in Monthly Expenses listed in section 7 above
-
Debt for what expense Who do you owe Amount you owe Last Monthly
2 Ii (mortgage, car loan, etc.) (Name of creditor) this creditor now Payment made
3
I Familv home LOC -
I Marvsville rental -
I Stanwood rental -
4 I -
5
9. Monthly payments for other debts (not
6 l Describe Debt _J. Who do you owe
- included in expenses listed in section 7)
Amount you owe !
_Jf!..f!_d.it card, loan, etcj_ _____j_Name 9f q_edito_r_ _ this creditor now I
Last Monthly Payment
J.Qate and Amou!!.L.____
7 rPersonal loan i Julie Langabeer - $100,000.00 ! October I $166.67
--·-----~
---
8
9
f=====-i_ -
1--- '
-
-
-
-
-
-
1--- -
- -
10 I Total Monthly Payments for Debts $166.67
11 1 O. Explanation of expenses or debts (if any needed):

12
13 11. Lawyer Fees

List your total lawyer fees and costs for this case as of today.
14
I
· Amount paid $s.ooo.oo I Source of the money you used to pay these fees and costs:
15
Describe your agreement with your lawyer to pay your fees and
Amount still owed -
16 costs:
i
I
17 I Total Fees/Costs ss,000.00 I
18
I declare under penalty of perjury under the laws of the state of Washington that the facts I
19 have provided on this form are true.
20 Signed at~ f II~ f vVA Date: to/a3/ 11
21 ~ ,. Sall Pr1·ce
~ere Print name Q
22
23
24
Financial Records - You must provide financial records as required by statute and state and
local court rules. These records may include:
FL All Family 131 p.Eof~
3525 Colby Avenue, Suite 333
Everett, WA 98208
425.252.5167

....."
2
3 local court rules. These records may include:
• Personal Income Tax Returns • Partnership or Corporate Income Tax Returns
4 • Pay stubs • Other financial records
5 Important! Do not attach financial records to this form. Financial records should be served on the other party and
filed with the court separately using the Sealed Financial Source Documents cover sheet (FL All Family 011 ). If filed
6 separately using the cover sheet, the records will be sealed to protect your privacy (although they will be available to
all parties and lawyers in this case, court personnel and certain state agencies and boards.) See GR 22(c)(2).
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
RCW 26.18.220(1) Financial Declaration

Brewe Layman PS
Everett, WA 98208
425.252.5167

17-3-02497-31
PPP 8
Proposed Parenting Plan
20170CT 26 AH 11: 19
1 1977620
SOriYA KR.A.SKI
2 COUNTY CL(RI\
: 1111111111111111111111111111111111111111 SNOHOMISH CO. Vi.ASH
3

6
In re the Marriage of:
7 t7 3 024°9 7 JJI
Case No.: '
SALLY JO PRICE, PROPOSED PARENTING PLAN .
8 (PPP I PPT I PP)
Petitioner,
9
and
10
11
Respondent.
12
13 Parenting Plan
14 1. This parenting plan is a
15 Proposal (request) by a parent Petitioner, Sally J. Price. It is not a signed court order.
(PPP)
16
2. Children - This parenting plan is for the following children:
17
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .c. . . . m
. . . .·.1. .d. . 's name mm··································· !.\g~ I
18 Alexander 14
11
19 3. Madison 5
20 3. Reasons for putting limitations on a parent (under RCW 26.09.191)
21 a. Abandonment, neglect, child abuse, domestic violence, assault, or sex offense.

(If a parent has any of these problems, the court must limit that parent's contact
22
BREWE LAYMAN P.S.
I
23
24
ORIGINAL Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
~~~ED PARENTING PLAN - 1 (425) 252-9055 Fax
www.brewelaw.com
1 with the children, the right to make decisions for the children, and may not
require dispute resolution other than court.)
2
A parent has one or more of these problems as follows:
3
Child Abuse-Charles A. Price, Jr. abused or threatened to abuse a child.
4 The abuse was physical and emotional abuse.
5 Domestic Violence - Charles A. Prince, Jr. has a history of domestic

violence as defined in RCW 26.50.010(1).
6
b. Other problems that may harm the children's best interests. (If a parent has any
of these problems, the court may limit that parent's contact with the children and
7
right to make decisions for the children.)
8
Neither parent has any of these problems. (Skip to 4.)
9 4. Limitations on a parent
10 The following limits or conditions apply to Charles A. Prince, Jr.:
11 Other limitations or conditions during parenting time: No corporal punishment of

the children, no physical discipline of the children.
12
5. Decision-making
13
When the children are with you, you are responsible for them. You can make day-to-day
14 decisions for the children when they are with you, including decisions about safety and
emergency health care. Major decisions must be made as follows.
15
a. Who can make major decisions about the children?
16 !"··· ........................................................................... ,........................................
b. Type of Major Joint Limited

17 Decision (parents make these ! (only the parent named below has authority
de_F.!~!.<!.f}~!<zgt?:.!l.!.<!!LJ . . -··---··-·--t2!!Jqf£e._r.~t?:.~e.__eft?:.F.i.~.!.<!.!!~l . . . .
18 i §.~h22~L.§4.~~!=1:!~9.P.:~I . ~- -···--- . . .L
! Health care (not Sally Price
19 l. .
~!P.:~!.g~P:~Y).... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
! Other: Work related x
20 L~hH4.~~~ . P!.<?Y.!4.~!.~ ..................... ,,,,_ .......
i Other: Counselors or lly Price
21 L.~c:l:l:!P.:~~!~~ . P!.<?Y.!4.~!..s_.................;········--···········--···--·····················································--··----·--··!······--·········································--··················································································································································li
ther; Marriage prio x
e 18
22 Other: into the x
Attorneys at Law
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1 Armed Forces prior to
a e 18 ••••••••••••••••••••••••n•••••••••-MM•••••••••••••••-•••••••••••••••••••--·----·•••••••••••••••••••••••••••••••••••••---•••••••••••••••••••••••••••••••••••••••-•••
2
c. Reasons for limits on major decision-making, if any:
3
There are no reasons to limit major decision-making.
4
6. Dispute Resolution - If you and the other parent disagree:
5
From time to time, the parents may have disagreements about shared decisions or about
6 what parts of this parenting plan mean. To solve disagreements about this parenting plan,
the parents will go to a dispute resolution provider or court. The court may only require a
7 dispute resolution provider ifthere are no limitations in 3a.
a. The parents will go to

8
the dispute resolution provider below (before they may go to court):
9
Mediation - by an agreed upon family law mediator
10
If a dispute resolution provider is not named above, or if the named provider
11 is no longer available, the parents may agree on a provider or ask the court
to name one.
12
Important! Unless there is an emergency, the parents must participate in the
13 dispute resolution process listed above in good faith, before going to court.
This section does not apply to disagreements about money or support.
14
b. If mediation, arbitration, or counseling is required, one parent must notify the
15 other parent by written request.
16 The parents will pay for the mediation, arbitration, or counseling services as follows
17 based on each parents' Proportional Share of Income (percentage) from line 6 of the
Child Support Worksheet.
18 What to expect in the dispute resolution process:
11
Preference shall be given to carrying out the parenting plan.
19
• If you reach an agreement, it must be put into writing, signed, and both
parents must get a copy.
20 • If the court finds that you have used or frustrated the dispute resolution
process without a good reason, the court can order you to pay financial
21 sanctions (penalties) including the other parent's legal fees.
• You may go back to court if the dispute resolution process doesn't solve the
22 disagreement or if you disagree with the arbitrator's decision.
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1
7. Custodian
2
The custodian is Sally J. Price solely for the purpose of all state and federal statutes which
3 require a designation or determination of custody. Even though one parent is called the
custodian, this does not change the parenting rights and responsibilities described in this
4 plan.
5 (Washington law generally refers to parenting time and decision-making, rather than
custody. However, some state and federal laws require that one person be named the
6 custodian. The custodian is the person with whom the children are scheduled to spend
more of their time.)
7
~ Parenting Time Schedule (Residential Provisions)
8
The children live with Petitioner/Mother, Sally J. Price except as described in section 4.
9
8. School Schedule
10
a. Children under School-Age
11
Does not apply. All children are school-age.
12
b. School-Age Children
13 This schedule will apply when the oldest child begins Kindergarten:
14 The children are scheduled to live with Sally J. Price, except when they are
scheduled to live with Charles A. Price, Jr. on:
15
WEEKENDS: every other week from Friday at 6:00 p.m. until Sunday at
16 7:00p.m.
17 9. Summer Schedule
18 Summer begins and ends according to the school calendar.
19 The Summer Schedule is the same as the School Schedule except that each parent shall
spend one (1) week of uninterrupted vacation time with the children each summer.
20
The parties shall notify each other of their intended vacation dates by May 1st of each year.
If the parties cannot agree, then Petitioner's selected vacation dates shall take precedence in
21
even-numbered years, and Respondent's selected vacation dates shall take precedence in
odd-numbered years.
22

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1 10. Holiday Schedule (includes school breaks)
2 This is the Holiday Schedule for all children:
3 I Holiday I Children with Petitioner/Mother I Children with Respondent/Father I

4 **In the event the lather is working, on his designated holidaf-l the children shall remain with
the mother
5
6 Begin Friday of the holiday Begin Friday of the holiday

day/time: weekend after school day/time: weekend after school
7
or 3:00 p.m. or3:00 p.m.
Martin (whichever is (whichever is
8
Luther King
applicable) applicable)
Jr. Day
9 End Monday of the End Monday of the
day/time: holiday weekend at day/time: holiday weekend at
10
7:00 p.m. 7:00 p.m.
11 With the parent that has the attached weekend.
12

14 or3:00 p.m. or 3:00 p.m.
Presidents' (whichever is (whichever is
15 Day applicable) applicable)
17 7:00 p.m. 7:00 p.m.
With the parent that has the attached weekend.
18
19 Even Years Odd Years

Begin Friday of the holiday Begin Friday of the holiday
20 Mid-winter day/time: weekend after school day/time: weekend after school
Break or 3:00 p.m. or 3:00 p.m.
21
(whichever is (whichever is
22 applicable) applicable)
23
I BREWE LAYMAN
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2
7:00 p.m. 7:00 p.m.
4 Odd Years Even Years

Begin Friday after school or Begin Friday after school or
5
day/time: at 3:00 p.m. day/time: at 3:00 p.m.
Spring Break
6 End Wednesday at 7:00 End Wednesday at 7:00
day/time: p.m. day/time: p.m.
7
8
Every Yr.
9 Begin 9:00 a.m. the day of Begin
day/time: the holiday day/time:
10 Mother's
Day End 7:00 p.m. the End
11 day/time: evening of the day/time:
holiday
12
13
Even Years Odd Years
15 or3:00 p.m. or 3:00 p.m.
Memorial (whichever is (whichever is
16
Day applicable) applicable)
18 7:00 p.m. 7:00 p.m.
19
20 Every Yr.
Begin Begin 9:00 a.m. the day of
21 Father's Day
day/time: day/time: the holiday
22 End End 7:00 p.m. the evening
23
I BREWE LAYMAN P.S.
Attorneys at Law
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I day/time:
l
1
I day/time: of the holiday
2 :

Begin 9:00 a.m. the Begin 9:00 a.m. the
4
day/time: morning of the day/time: morning of the
5 Fourth of holiday holiday
July End 9:00 a.m. the End 9:00 a.m. the
6 day/time: morning following day/time: morning following
the holiday the holiday
7
8
9 Friday of the holiday Begin
Begin Friday of the holiday
10
or 3:00 p.m. or 3:00 p.m.
11 (whichever is (whichever is
Labor Day
12 Monday of the
End End Monday of the
13
7:00 p.m. 7:00 p.m.
14
15
16 Begin 10:00 a.m. Begin 10:00 a.m.
Thanks- day/time: Thanksgiving Day day/time: Thanksgiving Day
17 giving Day End 7:00 p.m. End 7:00 p.m.
day/time: Thanksgiving Day day/time: Thanksgiving Day
18
19
20
21
22
23
I BREWE LAYMAN P.S.
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1 Winter In odd-numbered years the children shall spend from after school or at 3:00 p.m.
Break/Christ the day school is out until Christmas Day at 12:00 p.m. with the
2 mas Petitioner/Mother and from 12:00 p.m. Christmas Day until 7:00 p.m. the day
Eve/Christm
3 prior to return to school with the Respondent/Father. The schedule shall be
as Day/New
Years reversed for even-numbered years.
4 Eve/New
Years Day
5

Begin 9:00 a.m. the day of Begin 9:00 a.m. the day of
7 Children's day/time: the birthday day/time: the birthday
Birthdays End 7:00 p.m. the day of End 7:00 p.m. the day of
8
day/time: the birthday day/time: the birthday
9
10 The children shall spend any unspecified holiday or non-school day with the
All three-day parent who has them for the attached weekend. The weekend shall commence
11 weekends not Thursday (if holiday/in-service day is a Friday) or Friday (if the holiday/in-
listed service day is a Monday) after school or 3:00 p.m. (whichever is applicable)
12 elsewhere until 7:00 p.m. Sunday (if the holiday/in-service day is a Friday) or Monday (if
the holiday/in-service is a Monday) of the holiday weekend.
13
Odd Years Even Years
14
Other Begin 9:00 a.m. the Begin 9:00 a.m. the
15 occasion day/time: morning of the day/time: morning of the
important to holiday holiday
16 the family: End 7:00 p.m. the End 7:00 p.m. the evening
17 day/time: evening of the day/time: of the holiday
Easter
holiday
18
19 Every Year
Other
occasion Begin 9:00 a.m. the
20
important to day/time: morning of the
21 the family: holiday
End 7:00 p.m. the
22 Halloween
day/time: evening of the
23
I Attorneys
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at Law
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1 holiday

4 day/time: morning of the day/time: morning of the
Other holiday holiday
5
occasion End 7:00 p.m. the End 7:00 p.m. the evening
6 important to day/time: evening of the day/time: of the holiday
the family: holiday
7 If the holiday falls on a Friday or Monday, the above schedule shall be
Veterans Day
replaced as follows: Thursday (if holiday is a Friday) or Friday (if the
8
holiday is a Monday) after school or 3:00 p.m. (whichever is applicable)
9 until 7:00 p.m. Sunday (if the holiday is a Friday) or Monday (if the holiday
is a Monday) of the holiday weekend.
10
Other Every Year
11 occas10n Begin 9:00 a.m. the day of Begin
important to
day/time: the birthday day/time:
12 the family:
End 7 :00 p.m. the day of End
13 Mother's day/time: the birthday day/time:
Birthday
14
Other Every Year
occasion Begin 9:00 a.m. the day of Begin
15
important to
the family:
16 End 7:00 p.m. the day of End
Father's day/time: the birthday day/time:
17
Birthday
18
11. Conflicts in Scheduling
19
The Holiday Schedule must be observed over all other schedules. Ifthere are conflicts
20 within the Holiday Schedule:
21 If the residential schedule results in a conflict where the child(ren) is/are scheduled
to be with both parents at the same time, the following shall have priority over
section 8, in the following order (1 being the highest priority and 6 being the lowest
22 priority):
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P.O. Box488
~~~ED PARENTING PLAN - 9 !

425) 252-5167 Phone
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1
1 - Section 10: Martin Luther King Jr. Day, Presidents' Day, Easter, Memorial
2 Day, Fourth of July, Labor Day, Halloween, Thanksgiving Day/Break, New
Year's Eve/New Year's Day, All three-day weekends not listed elsewhere.
3 2- Section 10: Mother's Day, Father's Day, Children's Birthdays, Mother's
Birthday, Father's Birthday.
4 3 - Section 10: Vacation with Parents
4-Section 9: Summer Schedule
5 5 - Section 10: Winter Break, Christmas Eve, Christmas Day
6 - Section 10: Mid-winter Break, Spring Break
6
12. Transportation Arrangements
7
The children will be exchanged for parenting time (picked up and dropped oft) at:
8 each parent's home
school or day care when in session
9
Who is responsible for arranging transportation?
10
The picking up parent - The parent who is about to start parenting time with the
11 children must arrange to have the children picked up.
12 Other details:
13 Transportation costs are included in the Child Support Worksheet and/or the Child
Support Order.
14
The child(ren) shall be picked up and returned at the designated times or within
fifteen (15) minutes thereof in the event of an unforeseen delay. Should a delay
15
become necessary, the receiving parent shall be notified immediately.
16 13. Moving with the Children (Relocation)
17 If the person with whom the children are scheduled to reside a majority of their time plans
to move (relocating person), s/he must notify every person who has court-ordered time
18 with the children
19 Move to a different school district
20 If the move is to a different school district, the relocating person must complete the form
Notice ofIntent to Move with Children (FL Relocate 701) and deliver it at least 60 days
21 before the intended move.
22 Exceptions:
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1 a If the relocating person could not reasonably have known enough information to
complete the form in time to give 60 days' notice, s/he must give notice within 5
2 days after learning the information.
• If the relocating person is relocating to a domestic violence shelter or moving to
3 avoid a clear, immediate and unreasonable risk to health or safety, notice may be
delayed 21 days.
4 • If information is protected under a court order or the address confidentiality
program, it may be withheld from the notice.
5 • A relocating person who believes that giving notice would put her/himself or a
child at unreasonable risk of harm, may ask the court for permission to leave things
6 out of the notice or to be allowed to move without giving notice. Use form Motion
to Limit Notice ofIntent to Move with Children (Ex Parte) (FL Relocate 702).
7
The Notice ofIntent to Move with Children can be delivered by having someone personally
8 serve the other party or by any form of mail that requires a return receipt.
9 If the relocating parent wants to change the Parenting Plan because of the move, s/he must
deliver a proposed Parenting Plan together with the Notice.
10
Move within the same school district
11
If the move is within the same school district, the relocating parent still has to let the other
parent know. However, the notice does not have to be served personally or by mail with a
12 return receipt. Notice to the other party can be made in any reasonable way. No specific
form is required.
13
Warning! Ifyou do not notify ...
14
A relocating parent who does not give the required notice may be found in contempt of
15 court. If that happens the court can impose sanctions. Sanctions can include requiring the
relocating person to bring the children back if the move has already happened, and ordering
16 the relocating person to pay the other side's costs and lawyer's fees.
17 Right to object
18 A person who has court-ordered time with the children can object to a move to a different
school district and/or to the relocating person's proposed Parenting Plan. If the move is
19 within the same school district, the other party doesn't have the right to object to the move,
but s/he may ask to change the Parenting Plan if there are adequate reasons under the
modification law (RCW 26.09.260).
20
An objection is made by filing the Objection about Moving with Children and Petition
21 about Changing a Parenting/Custody Order (Relocation) (form FL Relocate 721). File
your Objection with the court and serve a copy on the custodian and anyone else who has
22 court-ordered time with the children. Service of the Objection must be by personal service
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1 or by mailing a copy to each person by any form of mail that requires a return receipt. The
Objection must be filed and served no later than 30 days after the Notice ofIntent to Move
2 with Children was received.
3 Right to move
4 During the 30 days after the Notice was served, the relocating person may not move to a
different school district with the children unless s/he has a court order allowing the move.
5
After the 30 days, if no Objection is filed, the relocating person may move with the
children without getting a court order allowing the move.
6
After the 30 days, if an Objection has been filed, the relocating person may move with the
7 children pending the final hearing on the Objection unless:
• The other party gets a court order saying the children cannot move, or
8 • The other party has scheduled a hearing to take place no more than 15 days after the
date the Objection was served on the relocating person. (However, the relocating
9 person may ask the court for an order allowing the move even though a hearing is
pending if the relocating person believes that s/he or a child is at unreasonable risk
10 of harm.)
11 The court may make a different decision about the move at a final hearing on the
Objection.
12
Parenting Plan after move
13
If the custodian served a proposed Parenting Plan with the Notice, and if no Objection is
14 filed within 30 days after the Notice was served (or if the parties agree):
• Both parties may follow that proposed plan without being held in contempt of the
15 Parenting Plan that was in place before the move. However, the proposed plan
cannot be enforced by contempt unless it has been approved by a court.
16 11
Either party may ask the court to approve the proposed plan. Use form Ex Parte
Motion for Final Order Changing Parenting Plan -No Objection to Moving with
17 Children (FL Relocate 706).
18 Forms
19 You can find forms about moving with children at:

• The Washington State Courts' website: www.courts.wa.gov/(orms,
20 • The Administrative Office of the Courts - call: (360) 705-5328,
22 (I'his is a summary ofthe law. The complete law is in RCW 26.09.430 through 26.09.480.)

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1 14. Other Provisions
2 a. Records. Each parent shall have equal and independent authority to confer with
physicians, counselors, schools, daycare and other programs with regard to the
3 progress of the child(ren) and each shall have free access to counseling, medical,
school, daycare, and other records. Each parent shall have authority to give parental
4 consent or permission as may be required concerning school, daycare or other
programs for the child(ren) while the child(ren) is/are in his or her residential care.
5
b. Telephone Access (Children). The child(ren) shall have liberal telephone
privileges with the parent with whom the child(ren) is/are not then residing without
6 the interference of the residential parent.
7 c. Telephone Access (Parents). The non-residential parent may contact the
child(ren) telephonically at any reasonable time.
8
d. Participation in Child(ren)'s Events. The child(ren) shall be accompanied by the
9 parent with whom the child(ren) is/are residing at the time of a given social event.
The other parent shall not be limited from attendance at that event, providing said
10 attendance by the non-residential parent is not disruptive to the other participants.
11 e. Notification of Child(ren)'s Events. Each parent shall be responsible for keeping

themselves advised of school, athletic, and social events in which the child(ren)
12 participate(s). Both parents may participate in school activities for the child(ren)
such as open house, attendance at an athletic event, etc.
13
f. Disparaging Remarks. Neither parent shall make disparaging remarks about the
other parent to or in front of the child(ren) and both parents shall cooperate in
14
fostering a good and loving relationship between the child(ren) and the other parent.
15 g. Minimizing Impact on Child(ren). The primary objective of the parents is to
minimize the negative impact that their separation shall have on the child(ren).
16 Each parent seeks a full and active role in providing the child(ren) with a sound
moral, social, economic and educational environment for the child(ren). To this
17 end, the parents are committed to cooperative and mutual involvement in the lives
of their child(ren).
18
h. Considering Child(ren)'s Schedules. Both parents shall consider the needs and
19 interests of the child(ren), and the child(ren)'s schedule of school and other regular
planned activities, when arranging visitation.
20
i. Alcohol/Drugs. Neither parent shall consume alcohol in excess nor consume drugs
21 other than over-the-counter or prescribed medication while the child(ren) is/are
under their care.
22

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1 j. Consistency of Routine and Discipline. The residential arrangements are provided
for in the best interest of the child(ren). The child(ren)'s interests is/are best served
2 by responsiveness and cooperation by both parents, involvement by both parents in
all aspects of the child(ren)'s needs, and a reasonable consistent routine of
3 activities, values, and discipline throughout both homes. Inconsistency and conflict
are opposed to the best interest of the child(ren).
4
k. Good Faith of Parents. Both parents freely and wholly commit themselves to this
parenting plan with the expectation that it will provide a stable and lasting
5
residential schedule for the child(ren) and the parents. Each parent is aware that
violations of this parenting plan, abusive use of conflict, false reports to authorities,
6 or bad-faith use of dispute resolution (including court action) could lead to a
reduction ofresidential time with the child(ren).
7
I. Child(ren)'s Clothing/Possessions. The parents shall not interfere with the right of
8 the child(ren) to transport his/her clothing and possessions to each parent's home.
Neither parent shall stockpile the child(ren)'s clothing or possessions. Both Parents
9 shall cooperate in providing and returning the clothing and possessions of the
child(ren).
10
m. Deviation from Schedule. Acceptance and waiver of any deviations from the
11 provisions of this parenting plan shall not constitute acceptance or waiver of
subsequent deviations from this plan. The provisions of this plan shall remain in
12 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 writing and
signed by both parents, and shall be effective immediately.
13
n. Change of Address/Telephone. Each of the parties shall keep the other parent, and
14 the Washington State Support Registry (if applicable), informed as to their current
residential address and telephone number at all times.
15
o. Notification of Change in Schedule. Each parent shall notify the other at least
16 forty-eight (48) hours in advance if he/she is unable to comply with the regular
residential schedule. Both parents acknowledge that from time to time
17 unpredictable situations may arise in their lives, and in the child(ren)'s life/lives,
which makes strict adherence to the above residential plan impractical.
18
p. Piercing/Tattoos. Neither parent shall allow the child(ren) to be tattooed/pierced
19 without the consent of the other parent.
20 q. Compliance with Plan. If a parent failed to comply with a provision of this

Parenting Plan, the other parent's obligations under the plan are not affected.
21
r. Development of the child(ren). Each parent desires to remain responsible and
active in the growth of the child(ren) and development consistent with the best
22 interest of the child(ren). The parents will make a mutual effort to maintain an open,
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1 ongoing communication concerning the development, needs and interests of the
child(ren) and will discuss together any major decision which has been made about
2 or for the child(ren).
3 s. Emergency care for the child(ren). Each parent shall be empowered to obtain
emergency health and dental care for the child(ren) without the consent of the other
4 parent. Each parent is to notify the other parent as soon as reasonably possible of
any illness or injury requiring medical attention, or any emergency involving the
child(ren).
5
t. Routine care for the child(ren). Each parent shall have equal and independent
6 authority to provide routine medical and dental services for the child(ren) while the
child(ren) is/are in his or her care and residence.
7
u. Religious upbringing. Each parent shall have an equal right to include the
8 child(ren) in his or her religious activities and expressions. The child(ren) shall
have the right to make his/her own religious choice as the child(ren) mature(s).
9
v. Day-to-day care. Each parent may make decisions regarding day-to-day care and
10 control of the child(ren) while the child(ren) reside(s) with that parent.
11 w. Major decisions. In the event of an irreconcilable difference between the parents as

to the joint major decision set forth above
12
The matter shall be resolved via the dispute resolution process set forth hereinafter
in section 6.
13
15. Proposal
14
This is a proposed (requested) parenting plan. (The parent/s requesting this plan must read
15 and sign below.)
16 I declare under penalty of perjury under the laws of the state of Washington that this plan
was proposed in good faith and that the information in section 3 above is true.
17
18 ~ .~o~
. l . h Signed at (city and state)
19 16. Court Order
20 Does not apply. This is a proposal.
21
22

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17-3-02497-31
DCLR 9
0 I,~l i il1~ i i 1 1 1 1 1 1 1 1 1
3

IN AKD FORTHE COUNTY OF SNOHOMISH
Case1oi 3 024•9 7 3.li .

·,
DJ(<:,laration of
u-tvt!1 Fe~e,-e I [Name]
Petitioner, l (Optional Use)
9
and I (DCLR)
:~ __0etr1fs Pn 'u_ ,Jr. J
Respondent. I
12
~-~- ---------··---··· ...... ------···--j c.a rt~ fedfrSpt I
13 Declaration of (11an1e)
14 J. 6
I am (age): \years old and I am the [ ] Petitioner !'.)(I Respondent
[ ] Other _ _ (relationship to the people in this case) ----~------
15
16 2. l_ aro - ~o+ h ().. Yl ! ~1b}n( () r(l._&L.6r.1l11'.:l.f-&--_
I declare:
17 fia!l~ a11d. bave rniwn bw tVr abcut J.Sw.11(5 lh mc1

18 e11p{t1tae ani ohsw vatinruit.j)a!lu ~ a. ve~---i ·ri'i
19
ct:Htnbv~t~rnctlslf_;__ad 1Ji h0ol i · '~:a:_t_!::nL!:Lt__ '
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Ct:rd h&VJ pothcA r:zi ;eJ Vn
1 R~
22
C~?Q{~ .i.\f'J.cLftlb:...,.(f\~,l_____
I.
\
BREWE LA.YMAN P.S. j I
Attorneys at Law J .
24
.Optional Form ((i5:]0!6i
FL All Family 135
vo. rRIGINAL
Declaration P.O. Box 488
Everett,
{425) wash_1ngron
252-5167 Phone9&20s-04ss
(425) 252-9055 Fax
· www.brewelaw.com
1
.lt\lLJ~a(tJo p~tra1 laJ bo~1/1Sol~r.YL~_ bn1L__ j
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·--------------------------------- ·-
-~------~ --------------·-·---~-·"·-----· . . ·!
13 (.,\!umber any pages you attach 10 thi.s Declaration. Page limits may apply)
14 I declare under penalty of perjury under the laws of the state of Washington that the facts I have
provided on this form (and any attachments) are true. [ ] I ha,ie attached _ _(nun1ber) pages.
15
Signed at (ciryands1a1e/: \Vlf:.t'f1-'b,-- \;1f)f V\Ni, Date: loluth "t- j
16 \.; r- J
17 ·~~g(.:
~,
_A {,·tL0tJ_a:p~uL__________~---· (~11
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Print name '
18 . . ~ . .- . .--- .............._ ........................... _. . . ._............
l
.. . . . . . . . . . )
Warning! Documents filed with . the court are available for anyone to see unless they are
19 ' sealed. FinancjaL medical, and confidential reports. as described in General Rule 32, must be ·
sealed so they can only be seen by the court the other party, and the lawyers in your case.
20 . ; Seal those documents by filing them separately, using a Sealed cover sheet (form FL All '
. Fa111i! )' . 91) . 0 l~~ ()! 91, ~J~ X()l1 J:'l~~y ac;;k for an ()T~(!! t() ~~! ?t~i;:r <!0.5?l1J:'l}SI11S '
21
22
.,.,,
I.BR EWE LAYMAN P.S .
___
• Attorneys at Law
Optional Form ((J5i:J() l 6j Dt:clantrion
24 FL All ramily 135 p.2of_
P.O. Box488
Everett, Wa-;hington 98206-048&
{425) 252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
. ~·
~it . ..,)..Ei_,
FILED
17-3 024
DCLR - 97-31
2017 OCT .2 6 AM 11: 19
Declaration Aff';o . SONYA KRASKI
1 COUNTY CLERK
2
iii1uuii111111 SNOHOMISH CO. WASH j
II
9
and
j}yj(AN s ~Yiu ,\lv-

10
.l
11
Respondent. I
12
I
--~---'i
13
14 l. I am (age):.fl;. years old and I am the L ] Petitioner [ ] Respm ~

fXl Other _ _(]·elations hip to the peopie in this cqse) 1:--~..w....L~~~('---._
15
2.
. -t~!-lUi~r +6 .f\\~ ctYt
l declare: ______________, _________, . _______. _____________. __ . ___, , _____ -"------------
16
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I BREWE LAYMAN ?.S.
Attorneys at Law
24
Optional Fonn (05/1016i
FL All Family 135
ORtSINAL P.O. Box 488 .
(425! 252-5167 Phone
\425 252-9055 Fax
www.brewelaw.com
I
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10
11
12 _
- · .. ~·-------'------ ---- ._........ ____ __ ____ . ..,
13 (Number a~y pages you aitach to this Declaration. Page limits may apply)
14 1 declare under penalty of perjury under the laws of the state· of Washin&.rton that the facts I have
provided on this fonn (and any attachments) are true. [ ] I have attached__;j~_Jnumber) pages.
!fl~~l~~...., 1-.z.
15
1! Signed a1 (city and state): .JV1rn(¥s vr'ltt; VVA Date:.
16 i l!\ / . ,!
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18 ••<•-•---·-""""-"-•• •••••••••••••·---·--·~··-••-.•••~•• ,.~.. .. ··-~-·~.- •.. ~--••H•Y• •ll-•o••v-•••••-·-· •••"""'·---··• •••••••~ "
[ Waming! Documents filed with the court are available for anyone to see unless they are
19 ; sealed. Financial, medical, and confidential reports, as described in General Rule 22, must be !
. seated so they can only be seen by the court, the other party. and the law-yers in your case. !
20 ' Seal those documents by filing them separately. using a Sealed cover sheet (form FL All J
. "~"'"'"''"'"""•-•i••~·~••••~····'··"'•""'"---~
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for an order to seal other ·-~.~>Y'•
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22
23 iI ") . · I BREWE LAYMAN P.S .
24 !
I
1 c.puona1 F.orm.,
. i(j"'
FL All Family 135
'>fiJ6
_,;k,1 · 1! Declaration
p.~or3
Attorneys at Law
P.O. Box488
Everett, Washington 98206 .. 0488
(425) 252-5167 Phone
l·
,1
(425) 252-9055 Fax
www.brewelaw.com
I 20170CT26AHll:19
-
i)
17-3-02497-31
DCLR 11 SONYA KK.A.SKI
Declaration Affidavit
1977629
COUNTY CLERK
SNOHOMISH CO. WA.SH
· 1111111111111111111111111111111111111111
2
3
4
IN THE SUPERIOR COURT OF THE STATE QF WA,.§l!JN.(JTON

7
· lnre ----~- CaseNo.:17 3 024.97
Declaration of
8 J e~s i if1..; CfA \I a_.e) ()J('I_ [Name]
Petitioner, (Optional Use)
(DCLR)
Respondent.
-~..._____J
]e 5 slcc.t
13
Cu.\ l O.G\ CU"-'
Declaration of -...--(n'dme)
14 1. I am (qge): 4Z years old and I am the [ ] Petitioner [ ] R~spondent .
1-5 [ t,J-Other _ _ (relarionship to the people in this case) .fu..:C'X\ d
~..:...a....--~--
16 2. 1 declare: :X'- -Bet~ ~Dl\1_-Sa II~

'JY\ (C -fur_l___._
17 ~ 11ih~.re. 1Me, m1boJl15 wid lliw. -. 1
18
1llA1 OU\dve..vi's s:c,\l\oo l 1±!,,e · v 5v1 . _ · -
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"F-d1; c a::b_ov1 :POJl_ el'sh'. . --~oclv\~e s± 7 IAJhOW\. .
20 b \D / a-.Yrl .he N SA'.C,Qf_\d C~L\ t--whn \$_____\\} k~~i
21 bef)!) \ V\ --the SQ\'V\f. c~\e&SS ~d-he£ S\V\e;e_, '
22 L\v0, fLpdw 1 <Aw:l -IY r)V\!\ >e 0) VJ? CO rod£ ocl W-f2 I
__
?"'1
I B.REWE LAYMAN P.S.
Attorneys at Law
omGINAL
Optional Fonn.(05/20161
241 rL All Famify l35 P.O. Box 488
)425l 252-5167 Phone
t425 252-9055 Fax
I www.brewelaw.com
- - - --~-----
,. _u
l lt\_LW_e' ~a1 \i;t tl,e SCUM£ \-\ \(JtW ~~s CL-t . . _ .

2 ?m:e.iJJemcl ~ak'.~._ Sll!3 ~'I k®e__ \,y)'{Jr,J
3 u~ ~£. _ c\os:s1e:;:m-1___~df'd -\\e__\d -\r·,ps ~
4 S\ne ctv\d l_ ~L_kreCOl/\t\£ \/YlDYe 'i\tl\Olvc:d. 'lts,~e,
s ~ahO!'\ o-f '\1e sc;,hcel oo Cl vo lYV\-k-i:~\s
6
1 ~ __P1J. h(\c '""£'£--\0--hons 1 ci&sht tii:e_. ______
1 ~ QkW i~fiSQVI . •_frs <>wr- ck ldvrn be~L- I
& Ji',£l'lds 1\/Jf :Tixi ~C(),Yt'lt'. -\(1 ~ 1t kuie Ll!_-ev~ I
9 ~oo ~e:n') ~ a.s well as 01.~~
10 25ke___hct5 __ Qlwo.~S \oeeri Ct\11 \V\\K)lve d_____ ~y£Atcl~· a
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12 I~'niltg at ~ DW\dvu1 a --fu.:::.....:;;..·
_,V\.\._,'--. l~. :. .+-·. - - - 1
.....,-;:-t
13 (Number any pages you attach to this !)edaration. Page limits may apply.)
14 1 declare under penalty of perjury under the laws of the state of Washint,.iton that the facts I have
provided on this fonn (and any attachments) are true. [ ] I have attached __ rx'_(number) pages.
15 -'t""·
16
I Signed at (dty and ""ate)• ~sv-,\ \f_ , VJ y'.\ I0
.·Dme- __ fBfu------ _
11 L-- ;JJ/!C<t 0 °Jessi c_o.__ Cc .. \\~ _
i here Print name 3'(e.\ cy ~
.... ~-- 1-~~ ~· ,,
l8 ~vs'A.R\\ %\i."~-e. rn·t:-. · Lj
. . ----··---~---------, ·---·--------- ...... _ctlL(3WO);i2l-::.OEil~.
Wanii11g! Documents filed with the cow:t are available for anyone to see unJes.s they are :
19 sealed. Financial, medical, and confidential. reports, as described in General Rule 22, must be i
· ' sealed so they can only be seen by the court; the other party, and the lawyers in your case. i
20 ! Seal those documents by filing them separately. using a Sealed covet sheet (form FL All '
.•
Family 01 J; 012,
21 ·-------- ........_or
··-~--
013).
.................. You may ask
__________ for an order to seal other documents
........................ . · '
..
------------···--········--················-·--·--··~·-··"--···-·····-·---->---·~-·-················-•-·
I
i·
22
23 .
Optional F6rm (05120 J6,; · Declaration
IBR EWE LAYMAN
Attorneys at Law
P,S.
241 FL All Family 135 . p.2of'_

P:O, Box488
EvE!rett, Washington 98206-0488
(425l 252-S167 Phone
(425 252-9055 Fax
www.brewelaw.com
FILED
17-3-02497-31
20170CT 26 AM 11: 19
1
I
!
DCLR 12
1977632
SONYA KHA.SKI
COUNTY CLERK
'11m11w1m1111~1m11~
SNOHOMISH CO~WASH
2
,..,
.J

6
!j In re ____..~--- Case No.: I
l· .~~/ly Pn'U/
.Dkl~r.io.f /l 0 2Jt.9 7 ~f ·
1rst-en3t?Y...e~Namef•
?
8
9 (DCLR)
and
~[{/VU s Pvfu 1 (fl".
10
_
11
Respondent.
12
I
13 l Declaration of - -(11a11te)
14 l. I am (age) :..51
years old and I am the t J Petitioner [ ] Respondent
[ JOther _._(relationship to thepeople in this l"ase) · - - - - - - - - - -
15
16
2. 1 d.eclare: :r C\.~ __ °'-- 1-e.ar.h-e.r '\ '<'\ :±JLe=··-----·
17
---1Y\t1£y,Sv\\\~ S0huo'\ c\0\:~:-c± fA-nd,
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20 Pco ~ c-~ , _Sa \\ y JJ '../ &$ eR s ~-ro u.\> s of cb ·~, &e..x~ .
21
-_..;...·'-'-- . s e,e n e)Cr \=H~(j-+-£_._____________,_
22 -~-~-~~-~--1
I
23
Optional Form ((J5i20l6) Declaration
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box 488
~lblNAL
24 FL All Family 135 Everett, Washington 98206-0488
(425) 252-5.167 Phone
{425) 252-9055 Fax
www.brewelaw.com
i ~D \J\Jbor<) Tt M<t.\i Cc1ncexo)
I ·T T
21~~~~~...._--1h~a~v~e--~\:;~nuouv~u~o--+-~$~·~c~A~\l~y¥-~p~.~r~\~c~P----~
3 i S \nee,, 2.Qll. She, b t:ts ·b .ee/Q q_ ~ q ren± 1
4 Vo I v.. n teec i n ov..- coo p.:s a__+\ v e f <"'o 5c&Lro ·, o j
5 1-h e. 1'l\ li\.:r "} 5 v ~ \1 t- Sc~ oli\ \) ~S-b-~ d-, 5 (\, \\y h tLS
6 f!b-lL~' \\etl b e-r . ob\··\) tt.:t··~ o,,, S . ~ n a 1.A r \') r o :9 c 0..10\ •
7 '"Tl\'~s \nvo\·ves Vo\\&:_ntee\t.l°j e'\fe_ry \AJee_\S. '\n I
8 +be c\ ass Cl! 0 m Q\'Y){)r:.9 otb t,y- +b ~-t;,~S, - s q,,j \'I !
9 bets. (\_.\so b e.\d tht?. ·pas~\+~ 60 0£ Cc"f - cb~
w lb ow-=_\dn::,3r1MY1 wh>c.b ce'll..l.1res wee..Kly I
11 me.-e_l~n55 .. T o..m a. :::\.ett&her .tt.c-\- ±bis Sc-boo\
12 SJL h et v e... \/\J ~~+n es5 e cl S C\.H 1 '$ ~· n v o \ v .€-VY'\ e..i-1t~,
13 (Plumber arzv pages you attach to this Declaration. Page limits may applv.)
14 l declare under penalty of pe.rjury under the Jaws of the state of Washington that the facts I have
provided on this form (and any attachment<>) are true. [ JI have attached _ _(number) pages.
15
l6 I
Signed at (city a1ui sf ate): M 0.. '"7 s v· 'j \\ e / \JJA Date: \ DrI ::2 -7-
4 ! l.!-..j7'---
l
. ~Q,~ ~lcsl:en
1
11 !.rs1gn here name

Print
A. G.-e-eri 1
1
18
. Warning! Documents the court <;re available for anyone to see unless they are 1
19 i sealed. Financial, medical, and confidential reports, as described in General Rule 22, must be I
i sealed so they can only be seen by the court, the other party, and the lawyers in your case.
.20 Seal those documents by filing them separately; using a Sealed cover sheet (form FL All
.J~!Y-~l 1, 0 l] 1 9tQ; .3-):...'Y9~-~~..:. i\.~~-f~~-~~<:>.~"'.E!.<:>.c..~<=:~t?~~Ldoc~~~!.1!~.---·-··· ··--···-- --·· · · · · · · · ·
21
22
1 Optional form 105/2016j Dccianrtion

IBREWE LAYMAN
Attorneys at Law
P.O. Box488
P.S.
14 FL All hmily 13' p.2nt_2 Everett, Washington 98206-0488

(425\ 252-5167 Phone
{425 252-9055 Fax
1 www.brewelaw.com
F aLro·. §
•
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ZOl70CT26 AMII: 19
17-3-02497-31
DCLR 13
Declaration Affidavit SONYA K2ASKI
1977637 COUNTY CLERK
SNOHOMISH CO. WASH
1111111111111111111111111111111111111111
IN 'fHE SUPERIOR COlJR<f OF TllG STATE. OF \VASHINGTON

IN AND FORTHECOUNJ'Y OFSNQHOMJSH
Ca~eNo.: '1 3 024.97

Jt .
:r'
Respon.d¢:nt
Br
1A I
Declaration of_.,...__.,..._
. {1u11ne)
rH [
is
-+ l. I am (age)_' lQ.. year::; old an(i l am the L JPetitioner [ ], Respondent
]Other:..c--._Jreh1iionship tq the.JJeopfe in 1his cdse)w$Lt~'.;;;._J:ni;:.f,l.:l~-·'··-·-
-16 1.
!,
2. I dedare:
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' -· " r /''.,..,' > .,., C' tl b ' "" ~ ' - ::::: _() 0 H ·.· jl
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:
22 /- ~~Qc~' - . . ." t £~---S~ -~s,__~~--------j

23 I I
"
BREWE LAYMAN ?.s.
l Attorneys at Law .
24
Op1iqnal 'F<Jrm ((}5.:?016)
jj'L All f>mHY 135 6ftiGINAL P.O. Box 438
Everett Vvashington 98206-04.88
(425)252-5167 Phone
(425) 252-9055 Fax
\VWW.brewelaw.com
................... ______ ..............

,, ___ •••'-••••••·--· -.-•-~··•--•c·• '"'"''""""""""•••••••••-nno•~·-···--··-•·•--••¥¥'"''""'"''"''"
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SREWE LAYMAN ?.s.

11 Optie>nal J-'()~1n ({i5 ?016! Dc·clarmion
I
A;ttorheys at Law
24 11 :Fl AH Famil~' 135

P.O. Box 488
fl· 2of_3" Everet~, Washington 98206-0488
(42S\ 252,5167 Phone
11I (.425) 252-9055. Fax
ww.w.breweraw.com
................ ,,......... ,,,,,,_~~ .................................. .,.,. .,,.~

night at bedtime,
Sally is a wonderful.cook! She learned to appreciate French cooking when she was a
student in France, and enjoys preparing delicious meals for her family and guests~
Most of the day-'to~day chores of tunningthe household have been her

responsibility. She pays th:ebills, does most of the shopping, schedulesTepairmen1
and transports the children to their medicai appointments and activities. In
addition, she's the family trave1 agent, planning itineraries, and booking flights and
accommodations.
Sally also does much of the work of managing their rental properties. She deals with
tenants, collects rents, pays bills and calls repairmen,
Altogether, Sally has put a lot of time, energy, love and talent into her role as wife
and mother. ·
p. 3 of3
..
··············································~---
..
-FIL i= n
' ' ' " - i!;J
2011 OCT 26 AH II: 19

17-3-02497-31
DCLR 14
SONYA KRASKI
1977641 COUNTY CLERr\
SNOHOMISH CO. WASH
.., II I IIll II III II II II lllllll II IIII I II I\1111

6
7
Declaration of
8 Chr1Shne- l<ojm[NameJ
9 (DCLR)
and
10
1 (;VIV! VU-.{ Priµ_..t \Tr.
11
Respondent.
12
13 Declaration of _ _(name)
14 1. I am (age): Y3years old and I am the ( ] Petitioner I)<] Respondent
[ ] Other _ _(relationship lo rhe people in this case) EAMlL\./ PR.IE.ND
15
2. I declare: \ \-\f\\lE" ~NO't-lN SALLY FoRJ O\J?& \0 \IEJ\RS
16
17
19
20
\\JE" SPENT I\ c.,gt.AT DE. Ak OF" 1'\t-'\£. W rlli St\ LL'/ -
\N \\Erl t\1)~ ~ , A'T 5Gt\OOL , 'Oro A LL\I , AND ONE 00
21
22
ON~. \\JE. ALWB\1'5 GO~\QE£EO '2MLL'{ f\~ A LO)'f\L
-
FR\E:ND l CAN DEPEl'JD ON.
23
Optional Fonn f(JJ:20/6) Declaratillll
IBR EWE LAYMAN
Attorneys at Law
P.O. Box488
P.S.
24 fL All Family 135

ORIGINAL Everett, Wa!".hington 98206·0488
4251252-5167 Phone
1425 252-9055 Fax
www.brewelaw.com
SHE AAS J\\..\NPNCO JRE\'\TED OlliERS wrili &E.NUlNE
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13 (Number any page.I\ you attach to this Dec/aralion. Page limits may apply.)
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Signed at {city and stale): Srf\EPO&b I YA Date: lQ /1..o/ 200
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Warning! Documents fiierWith.tilO.;nurtare8Valiab1e for -.;nyODe to see-Un1eSS _iliCY _are ;
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19
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23 IBR EWE LAYMAN P.S

Attorneys at Law
Optional Fonn 10512016> Oedaration
P.O. Box488
24 FL All Family 13!i ..5..
p. 2 or Everett, Washi:fton 98206--0488
!425l 252-5167 hone
425 252-9055 Fax
www .brewelaw.com
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·FIL:ED
ZOl10CT 26 AH II: 19
17-3-02497-31
DCLR 15 SOHYA KRASKI
Declaration Affidavit COUNTY CLERK
1977644 SNOHOMISH CO WASH
Ill I 111111111111111111111111111111111111
5 IN-THE SIJPERIOR-COURT OF-THE STATE OF WASHINGTON

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•. ::ptnridedo1t.·1his.fonn.(andany attachments) aremie.11·1nave attached __(numbe1fpages.
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.· .•. Sigoedat (cityaniJSlaJe): Ju\a\, n ~1
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20 '.>Seal thQse d®uments by filing them separately;. using a Sealed OO't'er sheet. (form Ft All r ..
·.•. Lf~i.~l:.~1!L~I~d!f.~!3~~Y~.~_y-~-~-~~-~~~~ ~-- -------·-·- -·-··-·---·"·-·: ..J
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JB_REW_E lAYMAN
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J Atmmeys at law
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24 ·' :F,1. Mtfffi'li\Y•IJS . p.281_ :£v$'ett,W~~
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~------------ -
17-3-02497-31
DCLR 16
1 ' Declaration Affidavit 20170CT26 AMII: 19
~i~1i11111m1111~11~1111111 SONYA KRASKI

COUNTY CLERK
SNOHOMISH CO. WASH
3
IN THE SUPERIOR COURT OF THE STATF.OF WASHINGTON

•CT\ AND FOR THE COUNTY Of SNOHOt\AlSH
•Jn re (".ase No.~
~ltvV1Pfr~- Dtt1.Jln))~ Q24_ '9 7 . 31

7
s 72:uv~ ~ [Name]
Petitioner.. {Optional Use}
9 (IJClR)
10
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13 Declaration of ______(lu1111e)
14 J. lam (age); .i'h·eafs:. old aild lam th~ [ ] Petitioner [.f) ResptH1de1it
( JOther _(refmionship ro the pEmple itt thr.s (.·w;ej -------~-
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IIBREWE LAYMAN
Attorneys at L.w.r
. Optional l'orm (fJJ'l.!fJ16.i
24 . f'LAU Famliy m~ OOJGINAL iP·.O. b4!8
!Everett. 'i\fas:i\Jngtoo ~206-0488
(425t -~S4-S1i7 ~ooe
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18
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i Warning! Oocuments filed °"1th the .court a.re available for anyon~ 10 :see
-- -----
unless mcy arc
t9 sealed. Financial. mcdk!i!l, ~ml ~i}rdidenHat repons. as described in General Rule 22.. must be '
scaled so :they can only be seen by the court: the ul.ber part)\ and the h1'''Y~rs in your c;ase,
20 I Seai dlose doct.mlrnts by filing them separi.'itely. using a Sealed L"-OVet slleet (form FL All
21
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I BR. EWE.at ..l A. YMAN
Attorl't!Y.S taw
iP.5.
P.O. Box. 488

24 if'L ADI hm!Jy u~ p.~<·f~ E\li!'rett. W.ashinEt1;1n 9!206·0488
(42S) 2!:.:!-5167 Ptione
(423) Z5ZJ.IOSS Fi11t
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14 I Q(.,"4;~are uade~ penalty ofperj11.uy und~r the··· law.s oft~ p.~ate of Waihington t:hat. the facts I h.·ave
pr()\1 1d~d on ilus fom1 (and an}' a:ttat'.h_menls) are true_ .Vtl have attach~ 4rn-u1nbcr} pages.
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20 ! 'Seal _umse documcnls Mby fitmg thetn :separaiely. usmg a .";e,clfed oovet slleet (form .f L All
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I BREWE lA. YMAN ;F.5.

I Ai:t'ori"teys at t:aw
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P.O. Box.4BB
24 !FL ADI Ja~IJ:r :ll~ Everett. WasliinRt1;1n fJE206·04!S
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17-3-02497-31
AFPT 17
Affidavit of Plaintiff Petitioner
20170CT 26 AM II: 19
1
1977654
SONYA KKASKI
2 COUNTY CLERK
Ill Illlllllllllllllllllllllllllllll II Ill SHOHOMISH CO. WA.SH
3

6
In re the Marriage of: CaseNo.: t7 3 024 97 Jli 1
,
"
7
SALLY JO PRICE, DECLARATION OF PETITIONER,
8 SALLY PRICE, IN SUPPORT OF
Petitioner, MOTION FOR TEMPORARY ORDERS
9
and
10
11
Respondent.
12
13 I, SALLY PRICE, declare under penalty of perjury, under the laws of the State of
14 Washington, that the following is true and correct to the best of my knowledge.
15 1. That I am the Petitioner herein and make this declaration in support of my Motion
16 for Temporary Family Law Orders.
17 2. Background. Charles and I were married on October 7, 2000. We lived together
18 prior to marriage for two and a half years. To date we have not physically separated and our date of
19 separation should be deemed the date of my filing the Petition for Divorce.
20 We have three children of our marriage, Alexander (age 14), Colby (age 11), and Madison
21 (age 5). Alexander and Colby have both been diagnosed with ADHD and take medication to
22 control their symptoms. Colby has sleep apnea which is controlled through a CPAP machine.
23
OR\G\NAL I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
24 DECLARATION OF PETITIONER, SALLY PRICE, IN Everett, Washington 98206-0488
~~fl~.T OF MOTION FOR TEMPORARY ORDERS - 1 !

425j 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 3. Petitioner's Situation. I am 44 years of age and in good health. I have an ear
2 condition which has required surgery in the past and I am having surgery in November to remove a
3 growth from my middle ear. I also am schedule to have a laser iridotomy to treat narrow angles. I
4 have appointments scheduled for October 24th and October 31st.
5 I have a Bachelor's Degree in French from Western Washington University. I also received
6 my teaching certificate from WWU. I last worked part-time as a substitute teacher in 2009, but
7 since then have not worked outside the home except to manage the rental properties that we have.
8 I am a stay-at-home mom and manage all aspects of our household and our children's lives. Until
9 recently, Respondent worked 10-12+ hours per day 5 to 6 days per week. He now works 50 hours
10 a week which is "cutting back" because of health concerns.
11 4. Respondent's Situation. Charles is 49 years of age. He had two stents put in after
12 suffering from a heart attack on April 19, 2017. He now takes medication regularly to prevent any
13 further issues. He was supposed to reduce his work hours to 50 hours per week. He now works
14 Monday through Friday from 8 to 4 p.m. and is seemingly doing fine with an episode on Ocrober
15 17, 2017, in which the thought he was having another heart attack. It turned out to be anxiety.
16 Charles is part-owner of Leader One Financial and works as a Mortgage Broker. His
17 income can fluctuate so I have done an average over the last five (5) years (2012-2016):
18 2012 $481,980
2013 $263,908
19 2014 $155,403
2015 $488,660
20 2016 $692,061.22
Total $2,082,012.22
21
22
BREWE LAYMAN P.S.
P.O. Box488
(425! 252-5167 Phone
~}JEifi'lm..T OF MOTION FOR TEMPORARY ORDERS - 2 (425 252-9055 Fax
www.brewelaw.com
1 $2,082,012.22 + 5 = $416,402.44 + 12 = $34,700.20 gross per month. Our tax returns and
2 Charles' pay stubs are filed under seal herewith.
3 5. Parenting/Physical, Verbal & Emotional Abuse. I have always been the children's
4 primary residential parent and Charles has been the breadwinner of the family. Charles has an
5 anger management problem. We never really knew how to handle Charles when he got angry and
6 would walk on eggshells when he got home to see if he was "happy" or "mad". Since I have asked
7 for a separation, he has been demanding and threatening to me and I cannot live with him any
8 further. He has told me he will make sure I have nothing, then present me with child support
9 worksheets and tell me he is buying me a house or himself a house before separate since we won't
10 be able to qualify afterwards. He told me ifl don't accept his proposal, we will "go to war." I am
11 living day to day worried about the Charles factor.
12 I am requesting the court require Charles to move out of the house immediately. I am
13 requesting the court adopt my Proposed Parenting Plan filed herewith which sets forth a residential
14 schedule for Charles with the children every other weekend from Friday until Sunday. I am asking
15 that the court order no corporal punishment of any kind.
16 Charles' mood is always very unpredictable when he gets home from work. He has hit our
17 kids on occasion and is verbally and emotionally hard on them. As recently as September 23, 2017,
18 Madison was sitting with Charles on the couch. When Madison wanted to talk with Charles and
19 change the channel on the television, he pushed her off of him and she fell on the floor. She came
20 to me upset and said he hurt her. He said she was distracting him and needed to go away. She's
21 only 5 years old. There have also been occasions when Colby was not listening and Charles has
22 Smacked him in the face, pushed him, and grabbed him by the back of the neck when he was

Attorneys at Law
P.O. Box488
~~fi~T OF MOTION FOR TEMPORARY ORDERS - 3 !

425l 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 frustrated with Colby. He cannot handle the children's needs during the school week. I am the
2 parent that handles all of their schooling, homework, IEP, doctors' appointments, and mandatory
3 volunteer time at our daughter's school (as well as the boys' when they attended there), etc. I do all
4 the clothes shopping, the grocery shopping, cooking, the running around and coordinating
5 birthdays and events. All of it. Until April of this year, Charles was gone most of all the days.
6 6. Financial Support. My proposed child support worksheets are attached as Exhibit
7 "i.l_." I am requesting the court adopt the same. I have imputed my income based on age and
8 averaged Charles' income from 2012 through 2016.
9 I am additionally requesting Charles be ordered to pay me $15,000.00 per month in
10 maintenance so I can maintain the family home mortgage and costs, and the costs of our rental
11 properties which I have detailed below. My Financial Declaration is filed herewith.
12 7. Family Home/Rental Properties. Our family home is located in Tulalip/Marysville.
13 As I am the children's primary residential parent, I am requesting the court enter an order that
14 requires Charles to move from the residence into his own home within seven (7) days of entry of
15 the Temporary Family Law Orders. Our monthly mortgage payment is interest only and fluctuates
16 between $400 and $600 per month.
17 We have two rental properties:
18 Marysville Rental. This rental property belonged to my family member and we bought it
19 for an investment. We currently have renters on a month-to-month basis. We receive $1,600.00 per
20 month in rent and the mortgage payment is $1,100.00 per month. The extra is deposited into our
21 rental account that I manage.
22
23
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
~fJEfi~T OF MOTION FOR TEMPORARY ORDERS - 4 !

425j 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 Stanwood Rental. We own two parcels of land in Stanwood which contains an 8-plex
2 apartment. The mortgage payment is $5,475.00 per month. We have seven (7) units rented at
3 $700.00 per month and one (1) unit rented at $575.00 per month.
4 I manage the rental properties and will continue to manage the rental properties. All of the
5 monthly obligations for the rental properties are contained on my Financial Declaration filed
6 herewith.
7 8. Debts/Attorney Fees. We have a personal loan from my mom. We pay her $166.67
8 permonth.
9 I have paid my attorney $5,000.00 to date; however, based on Charles' business which
10 needs a value and our properties, I will likely expend several thousands of dollars obtaining values
11 on our assets. I am requesting Charles be required to pay my attorney $15,000.00.
12
13 Executed at Everett WA., this 23rd day of October, 2017.
14
15
sany J. Price
16 Petitioner
17
18
19
20
21
22
BREWE LAYMAN P.S.
23
I Attorneys at Law
P.O. Box488
(4251252-5167 Phone
~~g~.T OF MOTION FOR TEMPORARY ORDERS - 5 (425 252-9055 Fax
www.brewelaw.com
PARENT RESPONSIBILITIES
MOTHER/FATHER
(Ind"1cate "M" fior Mother or "F" fior Fath er un der th e aooropnate co umn
Type Always Occasionally Seldom Never
Enforce Rules/Discipline
M y
Bathe
fv'\ F
Wake Up
/\/\ '
·M r,.l 'l/M. f~C.O~~
. ,..,
Put to bed '{"
(/
Dress (if applicable) i
M F
Change Diapers (if applicable)
/\/\ tf{ F
Prepare Breakfast
M p
Prepare Lunch
Prepare Dinner
.M
.M f'
Grocery Shop
/\A F
Shopping for Kids
M I-
Laundry
IV\ F tnl!
\)
Schedule Appointments
M
Take to Doctor and Dentist
J~
Take for Haircuts
N\ i==
Take to School
.M
Pick up from School {\/\
Help with Homework
/\A
. .
Go to School Conference
j
(\/\y •
F
Attend School Functions
M F
Volunteer at School
M
Coach/Volunteer Sports
F N\ f;
.-
Attend Sporting Events
t:: (M
• -
'-(M? ~
Take to Social Events
/\/\
Vacation With Kids
f\/\ .c
Planning Gifts/Birthdays/Parties
M
•
Care for Children when Ill
M
Other
WORKSHEET SYNOPSIS
Sally Charles COMBINED

1. Monthly Net Income Tax Year: Manual $2,693.00 $23,067.84 $25,760.84
2. Proportional Share of Income .105 .895
3. Basic Support:
Alexander $1206.00
Colby $975.00
Madison $975.00
4. TOTAL $3,156.00
5. Basic Support Obligation with Income Limitations $331.38 $2,824.62

6. Obligation for Health Care, Day Care, and Special Exp.
7. TOTAL OBLIGATION $331.38 $2,824.62
8. CREDIT for Medical

9. CREDIT for Day Care and Special Exp.
10. CREDIT for Ordinary Expenses
11. TOTAL CREDITS
12. Charles Pr Pays Sally Pric $2824.62 I

Calculated Using Self Support Reserve: 2016
File Name: Prices.SCP

Page was printed on 10/18/2017 at 02:33 PM
SupportCa/c® 2017
Copyright© 2017 by Legal+Plus Software Group Inc.
A
County Snohomish Case No.
Child/ren and Age/s: Alexander, 14; Colby, 11; Madison, 5
Parents' Names: Sally Price (Column 1) Charles Price, Jr. (Column 2)
Sally Charles
Part I: Income see Instructions a e6
1. Gross Monthl Income
a. Wa es and Salaries Imputed for Sall $34700.20
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e. Other Income
$2 693.00
$2 693.00 $34700.20
$9 893.04
$1 322.65
c. State Industrial Insurance Deductions
d. Mandato Union/Professional Dues
$416.67
. Maintenance Paid
h. Normal Business Ex enses
(add lines 2a through 2h)
3. Monthl Net Income line 1 minus 2i
4. Combined Monthly Net Income
add both arents' monthl net incomes from line 3
5. Basic Child Support Obligation (Combined amounts---+)
Alexander $1206.00
Colby $975.00 $3,156.00
Madison $975.00
.105
WSCSS-Worksheets- Mandatory (CSW/CSWP) 0512016 Page 1 of 5
Sally Charles
Part II: Basic Child Support Obligation see Instructions, page 7)

of low income limitations Each arent's Line 6 times Line 5. $331.38 $2 824.62
$1 238.00
b.
c.
$331.38 $2 824.62
10. Health Care Ex enses
a. Monthly Health Insurance Premiums Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Month I Health Care Ex enses line 1Oa lus line 1Ob
d. Combined Monthly Health Care Expenses
add both arent's totals from line 1Oc
b. Education Expenses
c. Long Distance Transportation Expenses

Add lines 11 a throu h 11 d
both arents' da care and s ecial ex enses from line 11 e
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
Expenses (multiply each number on line 6 by line 13)

15. Gross Child Support Obligation (line 9 plus line 14) $331.38 $2,824.62
WSCSS-Worksheets- Mandatory (CSWICSWP) 0512016 Page 2 of 5
Sally Charles

16. Child Suooort Credits
a. MontbJY. Health Care Ex~enses Credit - -
b. Dav Care and Soecial Exoenses Credit - -
- -
- -
-
--·------- -
----- d. Total SuooortCredits (add lines 16a throuqh f6c) ···----------
- ------~~-·-·
-
whichever is Qreater) $331.38 $2,824.62
a. Real Estate - -
b. Investments - -
- -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f. - -
(if not the other oarent of this action)
.
Name - -
Name - -
Name - -
Name - -
Sally Charles
Name - -
Name - -
Name - -
Name - -
Program - -
Program - -
- -
- -
23. Non-Recurring Income (describe)
- -
- -
24. Child Suooort Owed, Monthly, for Biological or Legal Child(ren)
Name/age: Paid [ l Yes [ l No - -
Name/age: Paid []Yes []No - -
--
26. Other Factors For Consideration

Signature and Dates

Date City Date City
WSCSS-Worksheets - Mandatory (CSWICSWP) 0512016 Page 5 of 5 SupportCa/c® 2017

c: .. lstate templateslwaworksheet.dtf 1110.0.0.11 lclientsarchive\forms~egalpluslpriceslprices.scp 10/18/2017 02:35 pm
17-3-02497-31 ZOl70CT26 AMII: 19
1 NTC 18
Note for Calendar r·n~•\l~ /4~, ~K
;)1...1~ 1/"\ 1ri.i.i) 1
1977658
2 COUNTY CLERK
SNOHOMISH CO. WASH
II IIIll II III IIII II lllllll II II III Illll Ill
3

6
7 Case1f7 3 024
SALLY JO PRICE, CALENDAR NOTE: (NTC) • 9} . Jlf
8 FAMILY LAW MOTIONS
Petitioner,
9
and
10
11
Respondent.
12
13
Unless otherwise provided by applicable rule or statute, this form and the motion must be filed with the Clerk not less than
twelve (12) calendar days preceding the date requested. Responses to motion must be filed five (5) court days before the
14 hearing. Replies to responses must be filed three (3) court days before the hearing.
15
FAMILY LAW/DOMESTIC CALENDAR
Date Requested: (mmldd/yyyy): 1110912017
Monday through Friday @ 9:00 a.m.
16 Department B or C as assigned.
Nature of Hearing: Motion for Temporary Orders
17 *Department assignment will be posted the day of the

(Confinn hearing at 425-388-3587 or online at
hearing
www.snohomishcountywa.gov/Confirmations)
18
PRO SE DISSOLUTION CALENDAR
Date Requested: (mmldd/yyyy)
Wednesday at 12:30 p.m. only
19 Department C
**No confirmation required**
20 Agreed Matters and Default Orders only
***NO CONTESTED MATTERS***
21
INTERPRETER CALENDAR
Date Requested: (mmlddlyyyy)
Tuesday at 9:00 a.m. in Department D
22 Friday @ I :00 p.m. in Department D
Nature of Hearing:
23 f?tt~r~:~t~eYMAN P.S.
24
~pARNOTE-1
OR'G'NAL P.O. Box488
(425! 252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
1
If appearing Pro Se, interpreters are arranged through (Confirm hearing at 425-388-3587 or online at
Court Administration. Please call 425-388-3421. www.snohomishcountywa.gov/Confirmations)
2
Language needed: _ _ _ _ _ _ _ _ _ _ __
3
NOTE: When picking a hearing date, DO NOT schedule your hearing for a court holiday. A list of court holidays can be
4 found at http://www.snohomishcountywa.gov/354/County-Holidays
If noting a presentation, or if a particular Court Commissioner has already heard a recent motion in the matter, please
5 indicate that Court Commissioner's name here: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
WARNING! CONFIRMATION REQUIRED: In order for the matter to be heard, the moving party MUST CONFIRM
6 their motion two (2) court days prior to the hearing BEFORE 12:00 noon by calling 425-388-3587 or online at
www.snohomishcountywa.gov/Confirmations For additional information see confirmations notes on page 2.
7 Failure to notify the Court of a continuance or strike may result in sanctions and/or terms. SCLCR 7.
This form cannot be used for trial settings. SCLMAR 2.1 SCLCR 40(b ).
8
CERTIFICATE OF SERVICE BY MAIL: Noted by:
9 I hereby certify that a copy of this document and all BREWE LAYMAN, ATTORNEYS AT LAW
other documents listed on page 3 have been mailed to A Professional Services Corporation
the attorneys/parties listed on page 3, postage prepaid on
10
the ;2/p~7· -
11
~ame: Sabrina A. Layman ~a A. Layman, WSBA 25260
12
WHERE TO NOTE VARIOUS MATTERS:
13
For the most current information on where to calendar various matters see Administrative Order 11-12 which can be found
online at www.snohomishcountywa.gov/1354/Administrative-Orders
14
FAMILY LAW/DOMESTIC MOTIONS: Most family law & domestic motions are heard on a Court Commissioner's
calendar. The exceptions are matters relating to trial settings, trial continuances, motions for revision, motions to waive
15 mediation requirement, and motions to enforce CR2A agreements; please refer to the Civil Motion Calendar Note regarding
these motions.
16 EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Court Commissioner only,
not by a party or by counsel.
17 CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Motion Calendar or
Court Commissioner Calendars must be confirmed not later than 12:00 noon two (2) court days prior to the hearing.
18 Confirmations are accepted for a 24 hour period beginning at 12:01 p.m. three court days prior to the calendar hearing date.
When determining your confirmation deadline, do not count weekends or holidays. Confirmations can be made by calling
425-388-3587 or online at www.snohomishcountywa.gov/Confirrnations.
19
All matters specially set on a Judge's personal calendar must be set/confirmed/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
20 Monday and are confirmed through the Civil Motions Judge's law clerk. Judge's calendar rotations and law clerk contact
information is available online at http://wa-snohomishcounty.civicplus.com/1338/Calendars-and-Schedules or by calling
21 Court Administration at 425-388-3421.
Calendar Notes should be filed at: All Motions Heard At:
22 Snohomish County Snohomish County
Superior Court Clerk's Office Superior Court B L
REWE AYMAN P.S.
23 1 Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
~pARNOTE-2 (425 252-9055 Fax
www.brewelaw.com
1 3000 Rockefeller Ave MIS 605 3000 Rockefeller Ave
Everett, WA 98201 Everett, WA 9820 I
2 Please print the names, addresses etc. of all other attorneys in this case and/or all other parties requiring notice.
3 Charles Price
Name: WSBA#:
4 Address: Phone# Ext.
Attorney for:
5
Respondent, Pro Se
7 Name: WSBA#:
Address: Phone# Ext.
8
Attorney for:
9 **
10
List all documents personal
11 served:
Summons, Petition for Divorce, Calendar Note, Motion for Temporary Orders, Declaration of Sally Price,
12 Proposed Parenting Plan, Witness Declarations, Financial Declaration, and Sealed Financial Source
Documents
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
(425! 252-5167 Phone
~pARNOTE-3 (425 252-9055 Fax
www.brewelaw.com
-----
17-3-02497-31
NTAPR 22
Notice of Appearance 20nNOV-2 PM 1: ~o
2 ~i1\111111~1~11111111111m11111 )
SOHYf, KRAS!\!
COU~ffY CLERK
SNOHOMISH CO WASH
4
8
County of Snohomish
10
12 No. 17-3-02497-31
SALLY JO PRICE,
14 Petitioner, Notice of Appearance
and
16
18
Respondent.
20
TO: CLERK OF THE COURT
22 AND TO: Sabrina Layman, Attorney for Petitioner
24
PLEASE TAKE NOTICE that ROBERT MAR hereby appears in the above-
26
entitled action for the Respondent, CHARLES ALLEN PRICE, and requests that all
28
further papers, pleadings and notices, except original process, be served upon the
30
undersigned attorney at the following address: 1200 Westlake Ave. N., Suite 700,
32
Seattle, WA 98109.
34
Dated this 31 51 day of October, 2017.
36
38
ROBERT MAR, WSBA #27735
40 Attorney for Respondent
NOTICE OF APPEARANCE Goldberg Jones, PLLC

Attorneys at Law
[1 0 RIGIi\' .''. L 1200 Westlake Ave. N. Suite 700
Seattle, WA 98109
(206)448-1010
>'· ~·- .; . - ., ••
17-3-02497-31
FILED
RSP ~~24
Response
2082781 1011 NOV 14 PH 12: 04
2
' 1 1 1 1 1 1 1 1 ~1 1 1 1 1 1 1 1 1 1 1
4
6
10 In re:
12 SALLY JO PRICE, No. 17-3-02497-31

Petitioner,
14 and Response Declaration of
Charles Allen Price
16 CHARLES ALLEN PRICE, JR.,
Respondent.
18
20
I, CHARLES ALLEN PRICE, make the following declaration from my personal
22
knowledge:
24
HEALTH ISSUES HAVE IMPACTED MY JOB AND INCOME. I am a loan

26
officer sourcing loan transactions and I put loan transactions together. I then pass it
28
off to a processor and they work it to closing. I also visit realtors to develop business
30
relations.
32
My other responsibility is that I sit on the board of directors for Leader One
34
Financial.
36
After my heart attack on April 19, 2017, I immediately cut my working hours
38
down from 6 days a week, 12+ hours per day (and on call 24 hours a day) to 5 days
40
RESPONSE DECLARATION OF CHARLES ALLEN PRICE Goldberg Jones PLLC

Page 1 Attorneys at Law
1200 Westlake Ave. N. Suite 700
Seattle, WA 98109
(206)448-1010
r
2 a week, 8 hours per day (while on call all the time). My doctor had limited me to 50
4
hours per week. See enclosed Sealed Health Care Records.
6
On October 17, 2017, I was admitted into the hospital with chest pains. My
8
doctor is now limiting me to 40 hours per week, and says that I should be allowed
iO
"stress free personal time, such as not being on-call after hours and on weekends."
12
See enclosed Sealed Health Care Records.
14
I have now reduced my work week to 40 hours per week and am no longer
16
taking after hours calls.
18
My compensation consists of a base salary of $7,000 per month ($3,500 per
20
pay period). I receive commissions monthly that can vary greatly from month to
22
month. Mortgage rates have increased since the election last year, decreasing my
24
commissions; since the bulk of my commissions are based on my ability to drive
26
business through the door, my commissions have been significantly reduced during
28
that time period. Coupled with the fact that I cannot physically contribute the hours
30
that led to my success in the past, I believe it is appropriate to calculate my income
32
based on my year to date for 2017 for purposes of calculating temporary child
34
support and spousal support.
36
38
HER FINANCIAL DECLARATION. Her financial declaration mixed in the
40
costs of maintaining our rental properties (Stanwood apartments and Marysville
rental home), but forgot to include the income in her financial declaration. In fact,
Seattle, WA 98109
(206)448-1010
2
our rental properties more than cover the mortgages/expenses and have a monthly
4
profit.
6
Managing our 2 rental properties is very minimal work---it has consisted of
8
only a few phone calls each month and making sure the bills are paid on it. So if she
10
takes over the management of our rental properties, it will be a very small time
12
commitment on her part. She should have time to work a full-time job.
14
And if she takes over the management of the rental properties, she can have
16
the net income and be responsible for those.
18
I have segregated her personal expenses from the rental property expenses
20
in the attached EXHIBIT A spreadsheet. The spreadsheet also shows what her net
22 income would be if she collected the profit from the rentals, we imputed net median
24
income to her, and took out her living expenses.
26
HER ABILITY TO WORK. She has a bachelor's degree and has full
28 credentials (and is fully certified) to teach high school right now (she teaches French
30
and social studies and history). She was employed previously (as late as 2009) as a
32
teacher with the Marysville school district earning approximately $57,000 annually.
34
There is no doubt in my mind that she can be and should be employed as quickly as
36
she starts applying for work.
38
Her income from working should at least be imputed at the net median for her
40
age which is $2,693 net per month which is what she had on her proposed child
support worksheets.
Seattle, WA 98109
(206)448-1010
2
STANWOOD RENTAL APARTMENT BUILDING. We own an 8 unit
4
apartment building in Stanwood that we rent out. There is little to no work involved
6
with maintaining this asset as it has been a couple of phone calls at most each
8
month dealing with it.
10
The mortgage on the Stanwood apartment building is $2,134, not $5,475 as is
12
incorrectly stated on her Financial Declaration. See my attached EXHIBIT B, the
14
amortized payment schedule.
16
The property tax of $550 per month is paid for 2017 already. The yard
18
maintenance ($550) listed in paragraph 7(H) of her financial declaration is for the
20
apartment as well.
22
Total income of rents and laundry income from the Stanwood apartment
24
building is $5,500. Subtracting the expenses from that, she will have a net of
26
$1,739.89 per month income from the Stanwood apartment building.
28
If she lists these expenses for the rental building she should be listing the
30
income from it as well.
32
MARYSVILLE RENTAL PROPERTY. The mortgage on this asset $1,068
34
per month and taxes are $190 per month. Our rental income on this asset is $1,600.
36
Thus, this is an income producing asset earning her approximately $297.11 per
38
month in income. See the payment schedule attached as EXHIBIT C.
40

Seattle, WA 98109
(206)448-1010
2
RENTAL PROPERTY EXTRAORDINARY EXPENSES. I do not anticipate
4
any extraordinary expenses for our rental properties since the properties have been
6 extensively renovated over the last couple of years. Therefore, I agree to be
8
responsible for any extraordinary expenses (such as repairs) for our rental
10
properties so long as I am involved in the decision making for that and provided all
12
information related to the expense. This means that all of the net income mentioned
14
above would be hers to keep while the temporary orders are in effect.
16
I have been the general contractor and repair man and remodeled all of these
18 units. We also contract out Keith King (see enclosed declaration) who has also
20 assists us in remodel and repairs, but since all the units are currently up to date,
22
there are really no major costs coming down the pipeline.
24
MARYSVILLE FAMILY HOME. I have no objection to her residing in the
26 family home on a temporary basis. The mortgage is only $492.76 per month and the
28 property tax is only $485.89 per month; this means it will only cost her a total of only
30
$978.65 per month for her to be responsible for it. With the temporary spousal
32 maintenance I am proposing below, she will be more than able to take responsibility
34
for that. I have remodeled our home and there is nothing needed in way of repairs.
36
AUTO INSURANCE. Her 2010 Mercedes is only $123 permonth for
38 insurance, not $1,000 per month.
40

Seattle, WA 98109
(206)448-IO IO
2
SPOUSAL SUPPORT I CHILD SUPPORT. SEE THE ATTACHED
4
SPREADSHEET IN EXHIBIT A which shows her total income and expenses if she
6
received the income from the rental properties and imputation for working.
8
You can see from the spreadsheet that her needs would be about $1,893 per
10 1 month. However, my ability to pay that much is severely hampered by my basic
12
living expenses and child support (which is over $2,000 per month).
14
The obvious difference between her calculation of my income and my
16
calculation is that she includes the income I was able to earn in past years when I
18
was healthy. Those kinds of hours are impossible unless we put my life at risk.
20 Even calculating my income using the year to date average (the way I
22
calculated it) is high considering my hours have been cut back to 40 hours per week
24
per doctor's orders.
26 Therefore, I am proposing that my spousal maintenance be $1,000 per
28
month. I have included the $1,000 per month in the enclosed child support
30
worksheets and that leads to child support of about $2,010 per month.
32
34
FINANCIAL RESOURCES. She already withdrew $5,000 from our
36
community funds on October 16 and another $5,500 on October 26. See atttached
38
EXHIBIT D. Given this and the fact that I will be paying her spousal support and
40 child support, we each should be responsible for our own attorney fees.

Seattle, WA 98109
(206)448-1010
2
OTHER FINANCIAL/PROPERTY REQUESTS. Since I will be paying her
4
maintenance, she should be responsible for the all of the debts related to her
6
residence. I am requesting that the court order the following:
8 1. require her to remove herself from my cell phone account and obtain
her own service (I cannot do so for her);
10
2. require her to change the billing on ADT and Netflix to remove from
charging on my American Express card (in my name);
12
3. require her to have her Direct TV billed directly to the home and not to
my AT&T bill;
14
4. require her to have all the family house bills be moved to her name;
5. that I be permitted to take possession of the personal property listed in
16
Exhibit F.
18
PARENTING PLAN
20
I HAVE BEEN AN ACTIVE PARENT DESPITE IN THE PAST WORKING
22
MANY HOURS. My proposed parenting plan is enclosed. During our marriage, it is
24
true that I did not get to spend as much time with our children as she did because of
26
my job. But this year, since my job has been reduced to 50 hours per week (now 40
28
hours per week), I have been able to spend significantly more time with the kids than
30
ever.
32
I did coach football with them and was involved with all of their extracurricular
34
activities. I went to the children's school conferences and spent almost all of the
36
time that I was not working with the children. She did take them to all of their
38
doctor's appointments, but outside of that, I was always involved with my children
40
and I have a strong emotional bond with our children. I have been very involved and

Seattle, WA 98109
(206)448-1010
2
very active with my children: from attending teacher meetings; picking up Alex from
4
his tutor that he had when struggling in school; and picking up and dropping off at
6
Montessori, Catholic school and daycare daily when our children attended. I have
8
been the coach for my son's youth football since he started playing.
10
My new temporary residence will be in Marysville (where we currently live)
12
and close enough for me to get them to school on time as well as big enough to
14
house me and the three kids during my residential time.
16
HER FALSE ALLEGATIONS OF ANGER ISSUES. Her allegation about me
18
having an anger management problem is false. Her allegations about me being
20 physical with the children are also false and her claim about Madison is false. The
22
only allegation that is even part way true is when our son Colby was playing football.
24 Colby was turned the other way and was not listening to me. I grabbed the back of
26 his neck and turned him around. He said, "you're choking me" and I immediately let
28 go as I did not realize I had grabbed part of his jersey by his neck. Colby mentioned
30
this to his counselor, which in turn led to a CPS investigation. CPS evaluated it as
32
"unfounded".
34
There has never been any child abuse of any kind in this family. Sally has
36
never abused these kids nor have I. The declaration made by Sally is purely to
38
limit my time with my children. I have passed all the background checks for
40 school participation and am able to help in the classroom with my children.

Seattle, WA 98109
(206)448-1010
,---
2 Bottom line is that my wife is clearly trying to bring up anything she can to
4 ensure that she is the primary parent and collects child support. You can see her
6 Declaration that she drafted in support of her motion CLEARLY conflicts with her
g letter dated September 11, 2017. See the 9/11/2017 letter she wrote to me in
10 attached EXHIBIT E, where she acknowledges I have been an excellent parent.
12 MY PROPOSED SCHEDULE. I have no problem with her being the primary
14 parent and collecting child support---! just am asking that the court that I receive
16 Thursday afternoon through Monday morning every other week (4 overnights every
18 14 days), once a week dinner (on Wednesday), and equal time during the holidays
20 and vacations. The 2 overnights in her proposed parenting plan every 14 days is not
22 representative of the time that I have had with the children in the past. My proposed
24
parenting plan more closely resembles the time I actually have had.
26 Therefore, I am asking that my proposed parenting plan be adopted as the
28
temporary parenting plan.
30
32
I declare under penalty of perjury under the laws of the State of Washington that the
36 Signed at Seattle, Washington on November 3, 2017.
38
40
RESPONSE DECLARATION OF CHARLES ALLEN PRICE

~PRICE Goldberg Jones PLLC
Page9 Attorneys at Law
Seattle, WA 98 I 09
(206)448-1010
. .
EXHIBIT A
;
WIFE'S PERSONAL
INCOME I EXPENSES
MARYSVILLE STANWOOD (MARYSVILLE FAMILY
RENTAL APARTMENTS HOME)
(imputed
INCOME $1,600.00 $5,400.00 $2,693.00 net)
Coin Op Laundry $100.00
Mortgage ($1,068.53) ($2, 134.05) ($492.76)
Property Tax ($190.70) ($550.57) ($485.89)
Insurance ($43.66) ($243.83) ($88.41)
Umbrella Ins. ($33.16)
Earthquake Ins. on
Family home ($62.50)
Water/Sewer/Garbage ($604.97) ($229.28)
Stanwood P.U.D. ($110.32)
1waste Management
Garbage ($116.37)
PUD/PSE gas and
electric utilities ($230.61)
Cabin taxes ($42.82)
Homeowner's
association dues/fees ($67.00)
Telephone (Cell) ($43.27)
Telephone (Frontier) ($59.93)
Cable/interneUDirect tv,
Broadband ($267.92)
Pest Control ($55.00)
Groceries ($800.00)
Household Supplies ($180.00)
Eating Out ($250.00)
Other : school lunches ($180.00)
Childcare/babysitting ($150.00)
Clothes ($200.00)
Other Expenses for
children ($150.00)
HealthNision Dental
Expenses ($137.92)
Health Expenses not
covered ($337.50)
Auto insurance ($123.00)
Gas/Auto maintenance ($456.00)
Clothes ($150.00)
Haircare, personal care ($260.00)
Recreation, clubs, gifts ($210.00)
Education, books,
magazines ($117.00)
House cleaner ($303.33)
Yard Maintenance ($400.00)
ADT ($60.00)
NET INCOME $297.11 $1,739.89 ($3,930.30)

'
TOTAL (rentals +
personal) ($1,893.30)
. .
EXHIBIT B
Amortization Schedule - Complete
Borrower(s): Date: 01122/2016
Loan Number: 1600079404 Loan Amount: 110,000.00
Broker/Lender: LeaderOne Financial Corporation Interest Rate; 3.125
1802 Pacific A.ve Term: 120
Everett, WA. 98201
Pmt. # Year Pmt. Date Payment Principal Interest PMI Balance

1
2
1 03101/2016
04/0112016
1,068.53
1,068.53
782.07
784.11
286A6
284.42
0.00
0.00
109,217.93
108,433.82
11 ;; 1 f.'; ; 'l z
3 05101/2016 1,068.53 786.15 282.38 0.00 107,647.67.
4 06101/2016 1,068.53 788.20 280.33 0.00 106,859.47
5 07/0112016 1,068.53 790.25 278.28 0.00 106,069.22
6 08/01/2016 1,068.53 792.31 276.22 o.oo 105,276.91
7 09/01/2016 1,068.53 794.37 274.16 0.00 104,482.54
8 10101/2016 1,068.53 796.44 272.09 0.00 103,686.10
9 11101/2016 1,068.53 798.51 270.02 0.00 102,887.59
10 12101/2016 1,068.53 800.59 267.94 0.00 102,087.00
11 01/0112017 1,068.53 802.68 265.85 o.oo 101,284.32
12 02101/2017 1,068.53 804.77 263.76 0.00 100,479.55
13 2 03101/2017 1,068.53 806.86 261.67 o.oo 99,672.69

14 2 04/01/2017 1,068.53 808.97 259.56 0.00 98,863.72
15 2 05101/2017 1,068.53 811.07 257A6 0.00 98,052.65
16 2 06/01/2017 1,068.53 813.18 255.35 0.00 97,239.47
17 ~ ow:11211~1 'i,068.53 815.30 253.23 0.00 96,424.'ii'
18 2 08/01/2017 1,068.53 817A3 251.10 o.oo 95,606.74
19 2 09/01/2017 1,068.53 819.55 248.98 0.00 94,787.19
20 2 10/01/2017 1,068.53 821.69 246.84 0.00 93,965.50
21 2 11/01/2017 1,068.53 823.83 244.70 0.00 93,141.67
22 2 12101/2017 1,068.53 825.97 242.56 0.00 92,315.70
23 2 01/01/2018 1,068.53 828.12 240A1 0.00 91,487.58
24 2 02101/2018 1,068.53 830.28 238.25 0.00 90,657.30
25 3 03/0112018 1,068.53 832.44 236.09 0.00 89,824.86

26 3 04/0112018 1,068.53 834.61 233.92 0.00 88,990.25
27 3 05101/2018 1,068.53 836.78 231.75 0.00 88,153.47
28 3 0610112018 1.068.53 838.96 229.57 0.00 87,314.51
29 3 07/0112018 1,068.53 841.15 227.38 0.00 86,473.36
30 3 08/0112018 1,068.53 843.34 225.19 0.00 85,630.02
31 3 09101/2018 1,068.53 845.54 222.99 0.00 84,784A8
32 3 10/01/2018 1,068.53 847.74 220.79 0.00 83,936.74
33 3 11/01/2018 1,068.53 849.94 218.59 0.00 83,086.80
34 3 1210112018 1,068.53 852.16 216.37 0.00 82,234.64
35 3 01/01/2019 1,068.53 854.38 214.15 0.00 81,380.26
36 3 02101/2019 1,068.53 856.60 211.93 0.00 80,523.66
37 4 03101/2019 1,068.53 858.83 209.70 o.oo 79,664.83

38 4 04/01/2019 1,068.53 861.07 207A6 o.oo 78,803.76
39 4 0510112019 1,068.53 863.31 205.22 0.00 77,940A5
40 4 06101/2019 1,068.53 865.56 202.97 0.00 77,074.89
41 4 07/01/2019 1,068.53 867.81 200.72 0.00 76,207.08
42 4 08/01/2019 1,06&:53 870.07 198A6 0.00 75,337.01
43 4 09/01/2019 1,068.53 872.34 196.19 0.00 74,464.67
44 4 10/01/2019 1,068.53 874.61 193.92 0.00 73,590.06
45 4 11/01/2019 1,068.53 876.89 191.64 0.00 72,713.17
46 4 12101/2019 1,068.53 879.17 189.36 0.00 71,834.00
47 4 01/01/2020 1,068.53 881A6 187.07 o.oo 70,952.54
48 4 02/01/2020 1,068.53 883.76 184.77 0.00 70,068.78
49 5 03101/2020 1,068.53 886.06 182.47 0.00 69,182.72

50 5 04/01/2020 1,068.53 888.37 180.16 0.00 68,294.35
51 5 05/01/2020 1,068.53 890.68 177.85 0.00 67,403.67
52 5 06101/2020 1,068.53 893.00 175.53 0.00 66,510.67
53 5 07/01/2020 1,068.53 895.33 173.20 0.00 65,615.34
54 5 08/01/2020 1,068.53 897.66 170.87 0.00 64;717.68
55 5 09/01/2020 1,068.53 899.99 168.54 0.00 63,817.69
56 5 10/01/2020 1,068.53 902.34 166.19 o.oo 62,915.35
57 5 11/01/2020 1,068.53 904.69 163.84 0.00 62,010.66
58 5 1210112020 1,068.53 907.04 161.49 o.oo 61,103.62
59 5 01/01/2021 1,068.53 909.41 159.12 0.00 60,194.21
60 5 02/01/2021 1,068.53 911.77 156.76 o.oo· 59,282A4
61 6 03/01/2021 1,068.53 914.15 154.38 0.00 58,368.29

62 6 04/01/2021 1,068.53 916.53 152.00 o.oo 57,451.76
63 6 05101/2021 1,068.53 918.92 14.9.61 0.00 56,532.84
64 6 06101/2021 1,068.53 921.31 147.22 0.00 55,611.53
65 6 07/01/2021 1,068.53 923.71 144.82 0.00 54,687.82
Amort. Schedule Complete 03/04 - Enoompass"' from Ellie Mae - www.elliemae.com

Amortization Schedule - Complete
Borrower(s): Date: 01/22/2016
Broker/lender: LeaderOne Financial Corporation Interest Rate: 3.125
1802 Pacific Ave Term: 120
Everett, WA 98201
Pmt.# Year Pmt. Date Payment Principal Interest PMI Balance

66 6 08/01/2021 1,068.53 926.11 142.42 0.00 53,761.71
67 6 09/01/2021 1,068.53 928.53 140.00 o.oo 52,833.18
68 6 10/01/2021 1,068.53 930.94 137.59 o.oo 51,902.24
69 6 11/01/2021 1,068.53 933.37 135.16 o.oo 50,968.87
70 6 12/0112021 1,068.53 935.80 132.73 0.00 50,033.07
71 6 01/01/2022 1,068.53 938.24 130.29 0.00 49,094.83
72 6 02101/2022 1,068.53 940.68 127.85 o.oo 48,154.15
73 7 03101/2022 1,068.53 943.13 125.40 0.00 47,211.02

74 7 04101/2022 1,068.53 945.58 122.95 0.00 46,265.44
75 7 0510112022 1,068.53 948.05. 120.48 0.00 45,317.39
76 7 06/01/2022 1,068.53 950.52 118.01 o.oo 44,366.87
77 7 07/01/2022 1,068.53 952.99 115.54 o.oo 43,413.88
78 7 08/0112022 1,068.53 955.47 113.06 0.00 42,458.41
79 7 09/01/2022 1,068.53 957.96 110.57 0.00 41,500.45
80 7 1010112022 1,068.53 960.46 108.07 0.00 40,539.99
81 7 11fC112022 1,068.53 962.96 105.57 0.00 39,571.03
8:l: 7 f:zl0~12G2:2 'f,368.SJ 965.46 • 103.07 ii.GO 38,6H.SI
83 7 01/0112023 1,068.53 967.98 100.55 o.oo 37,643.59
84 7 0210112023 1,068.53 970.50 98.03 0.00 36,673.09
85 8 03101/2023 1,068.53 973.03 95.50 o.oo 35,700.06

86 8 04101/2023 1,068.53 975.56 92.97 0.00 34,724.50
87 8 05101/2023 1,068.53 978.10 90.43 0.00 33,746.40
88 8 06/0112023 1,068.53 980.65 87.88 0.00 32,765.75
89 8 07/0112023 1,068.53 983.20 85.33 o.oo 31,782.55
90 8 08/01/2023 1,068.53 985.76 82.77 0.00 30,796.79
91 8 0910112023 1,068.53 988.33 80.20 0.00 29,808.46
92 8 1010112023 1,068.53 990.90 77.63 0.00 28,817.56
93 8 11/01/2023 1,068.53 993.48 75.05 0.00 27,824.08
94 8 1210112023 1,068.53 996.07 72.46 o.oo 26,828.01
95 8 01/0112024 1,068.53 998.67 69.86 0.00 25,829.34
96 8 0210112024 1,068.53 1,001.27 67.26 0.00 24,828.07
97 9 03101/2024 1,068.53 1,003.87 64.66 o.oo 23,824.20

98 9 04/01/2024 1,068.53 1,006.49 62.04 0.00 22,817.71
99 9 05101/2024 1,068.53 1,009.11 59.42 o.oo 21,808.60
100 9 06101/2024 1,068.53 1,011.74 56.79 o.oo 20,796.86
101 9 07/01/2024 1,068.53 1,014.37 54.16 0.00 19,782.49
102 9 08101/2024 1,068.53 1,017.01 51.52 o.oo 18,765.48
103 9 09101/2024 1,068.53 1,019.66 48.87 0.00 17,745.82
104 9 .10/01/2024 1,068.53 1,022.32 46.21 0.00 16,723.50
105 9 11101/2024 1,068.53 1,024.98 43.55 0.00 15,698.52
106 9 12/01/2024 1,068.53 1,027.65 40.88 o.oo 14,670.87
107 9 01101/2025 1,068.53 1,030.32 38.21 o.oo 13,640.55
108 9 02/0112025 1,068.53 1,033.01 35.52 0.00 12,607.54
109 10 03101/2025 1,068.53 1,035.70 32.83 0.00 11,571.84

110 10 04101/2025 1,068.53 1,038.39 30.14 0.00 10,533.45
111 10 05101/2025 1,068.53 1,041.10 27.43 0.00 9,492.35
112 10 06/01/2025 1,068.53 1,043.81 24.72 o.oo 8,448.54
113 10 07/0112025 1,068.53 1,046.53 22.00 0.00 7,402.01
114 10 0810112025 1,068.53 1,049.25 19.28 0.00 6,352.76
115 1o 09/0112025 1,068.53 1,051.99 16.54 0.00 5;300.77
116 10 10101/2025 1,068.53 1,054.73 13.80 0.00 4,246.04
117 10 1110112025 1,068.53 1,057.47 11.06 0.00 3,188.57
118 10 12/01/2025 1,068.53 1,060.23 8.30 0.00 2,128.34
119 10 01101/2026 1,068.53 1,062.99 5.54 o.oo 1,065.35
120 10 02/01/2026 1,068.12 1,065.35 2.77 0.00 0.00
Amert. Schedule Complete 03/04 - Encompass"' from Ellie Mae -www.elliemae.com

Amortization Schedule - Yearly Summary
Borrower(s): Date: 0112212016
Broker/Lender: LeaderOne Financial Corporation Interest Rate: 3.125
1802 Pacific Ave Term: 120
Everett, WA 98201
Pmt# Year Pmt Date Payment Principal Interest PMI Balance

12 02/01/2017 1,068.53 804.77 263.76 0.00
Yearly
Totals 12,822.36 9,520AS 3,301.91 0.00 100,479.55
24 2 02/01/2018 1,068.53 830.28 238.25 0.00

Yearly
Totals 12,822.36 9,822.25 3,000.11 0.00 90,657.30
36 3 02/01/2019 1,068.53 856.60 211.93 0.00

Yearly - =
= 12,822.36 -=:::;_-==-= =-==- -
Totals 10,133.64 2,688.72 CJ.00 80,523.66
48 4 0210112020 1,068.53 883.76 184.77 0.00

Yearly
Totals 12,822.36 10,454.88 2,367.48 0.00 70,068.78
6(1 5 02/0t.'202! 1,0SS.53 !l~1.n 156.76 0.00

Yca•llf = ,
Totals 12,822.36 10,786.34 2,036.02 0.00 59,282.44
72 6 02/0112022 1,068.53 940.68 127.85 0.00

Yearly
Totals 12,822.36
==11,128.29
=
1,694.07 o.oo 48,154.15
84
Yearly
7 02/01/2023
. 1,068.53 970.50 98.03 0.00
Totals 12,822.36 11,481.06 1,341.30 0.00 36,673.09
96 8 02/0112024 1,068.53 1,001.27 67.26 0.00

Yearly
Totals 12,822.36 11,845.02 977.34 o.oo 24,828.07
108 9 02/01/2025 1,068.53 1,033.01 35.52 0.00

Yearly =
Totals 12,822.36 12,220.53 601.83 o.oo 12,607.54
120 10 02/01/2026 1,068.12 1,065.35 2.77 0.00

Yearly
Totals 12,821.95 12,607.54 214.41 0.00 0.00
Amort. Schedule -Yearly Sunvnary 03/04 - Encompass"' from Ellie Mae -www.elfiemae.com
Amortization Schedule - Ending Summary
Borrower(s): Date: 01 /22/2016

1600079404
Loan Number: LeaderOne Financial Corporation
Broker/Lender: 1802 Pacific Ave
Everett, WA 98201
Loan Amount: $ 110,000.00

Interest Rate: 3.125%
Term: 120Months
Total Interest Paid: . $ 18,223.19

Total Payments: $ 128,223.19
Amort. Schedule - Ending Summary 04111 - Encompass"'

EXHIBIT C
LeaderOne Financial Corpomtlon, LIC# 266464, NMLS# 266464
'
,:-·.:) . ";'" i ~- ;/ (/!I·'\
Amortization Schedule
Amortization Schedule For.· Charles Allen Price, Sally Price
Property Address: 10030 271ST SR NW Stanwood, WA 98292
Prepared For:
Provided By: LeaderOne Financial Corporation

1802 Pacific Ave Everett, WA 98201
(P) 425·265·9100/ (F} 425-265-9300
Loan Program: 30 yr Fixed Conventional
Loan Amount $447,000 Buydown: Rate Term
Interest Rate 4.000%
Term/Due In 360/360 months
1st PMT Date 02/15/2009
Qual Rate 4.000%
APR 4.087%
Rate Adjustment Payment Adjustment

First Adj. Cap Initial Payment Rate % for months
First Change First Adj. Cap
Adjust Cap First Change
Adjust Period Recast Period
Life Cap Recast Stop
Margin Max Balance
Index Interest Only
Rounding GPM
Summary
No Pmt Date Int Rate Monthly Payment Principal Paid Interest Paid Mtg Insurance Balance
12 02/15/2009 3.000 1,884.57 9,332.47 13,282.37 437,667.53
107 02/15/2010 4.000 2,134.05 86,632.13 141,711.22 351,035.40
1 01/15/2019 4.000 352,205.52 351,035.40 1,170.12 0.00
TOTAL 603,163.71 447,000.00 156,163.71 0.00
CALYX Form Amortz.frm 10198

LeaderOne Financial Corporation, LIC# 266464, NMLS# 266464
Yearly Schedule
No Pmt Date Int Rate Monthly Payment Principal Paid Interest Paid Mtg Insurance Balance
12 02115/2009 3.000 1,884.57 9,332.47 13,282.37 437,667.53
12 02115/2010 4.000 2,134.05 8,252.10 17,356.50 429,415.43
12 02115/2011 4.000 2,134.05 8,588.31 17,020.29 420,827.12
12 02115/2012 4.000 2,134.05 8,938.20 16,670.40 411,888.92
12 02115/2013 4.000 2,134.05 9,302.36 16,306.24 402,586.56
12 02115/2014 4.000 2,134.05 9,681.35 15,927.25 392,905.21
12 02115/2015 4.000 2,134.05 10,075.78 15,532.82 382,829.43
12 02115/2016 4.000 2,134.05 10,486.28 15,122.32 372,343.15
12 02115/2017 4.000 2,134.05 10,913.52 14,695.08 361,429.63
11 02115/2018 4.000 2,134.05 10,394.23 13,080.32 351,035.40
1 01/15/2019 4.000 352,205.52 351,035.40 1,170.12 0.00
TOTAL 603,163.71 447,000.00 156,163.71

1..eaaervne r-mancial corparalion, LIC# 266464. NMLS# 266464
Monthly Payment
No PmtDate Int Rate Monthly Schedule Principal Paid Interest Paid Mtg Insurance Balance
1 0211512009 3.000 1,884.57 767.07 1,117.50 446,232.93
2 0311512009 3.000 1,884.57 768.99 1, 115.58 445,463.94
3 04/1512009 3.000 1,884.57 770.91 1,113.66 444,693.03
4 0511512009 3.000 1,884.57 772.84 1,111.73 443,920.19
5 06/1512009 3.000 1,884.57 774.77 1,109.80 443,145.42
6 07115/2009 3.000 1,884.57 776.71 1,107.86 442,368.71
7 0811512009 3.000 1,884.57 778.65 1,105.92 441,590.06
8 09/15/2009 3.000 1,884.57 780.59 1, 103.98 440,809.47
9 10/15/2009 3.000 1,884.57 782.55 1, 102.02 440,026.92
10 11/15/2009 3.000 1,884.57 784.50 1, 100.07 439,242.42
11 12115/2009 3.000 1,884.57 786.46 1,098.11 438,455.96
Sub Total 20,730.27 8,544.04 12,186.23
12 0111512010 3.000 1,884.57 788.43 1,096.14 437,667.53

13 02/15/2010 4.000 2,134.05 675,16 1,458.89 436,992.37
14 03/15/2010 4.000 2,134.05 677.41 1,456.64 436,314.96
15 04/15/2010 4.000 2,134.05 679.67 1,454.38 435,635.29
16 05115/2010 4.000 2,134.05 681.93 1,452.12 434,953.36
17 06/1512010 4.000 2.134.05 684.21 1,449.84 434,269.15
18 07/1512010 4.000 2,134.05 686.49 1,447.56 433,582.66
19 08/15/2010 4.000 2,134.05 688.77 1,445.28 432,893.89
20 09115/2010 4.000 2,134.05 691.07 1,442.98 432,202.82
21 1011512010 4.000 2,134.05 693.37 1,440.68 431,509.45
22 11/15/2010 4.000 2,134.05 695.69 1,438.36 430,813.76
23 12115/2010 4.0QO 2,134.05 698.00 1,436.05 430, 115.76
Sub Total 25,359.12 8,340.20 17,018.92
24 01115/2011 4.000 2,134.05 700.33 1,433.72 429,415.43

25 02115/2011 4.000 2,134.05 702.67 1,431.38 428,712.76
26 03/15/2011 4.000 2,134.05 705.01 1,429.04 428,007.75
27 04115/2011 4.000 2,134.05 707.36 1,426.69 427,300.39
28 05115/2011 4.000 2,134.05 709.72 1,424.33 426,590.67
29 06/15/2011 4.000 2,134.05 712.08 1,421.97 425,878.59
30 07/15/2011 4.000 2,134.05 714.45 1,419.60 425, 164.14
31 08/1512011 4.000 2,134.05 716.84 1,417.21 424,447.30
32 09/1512011 4.000 2,134.05 719.23 1,414.82 423,728.07
33 10115/2011 4.000 2,134.05 721.62 1,412.43 423,006.45
34 11/1512011 4.000 2,134.05 724.03 1,410.02 422,282.42
35 12115/2011 4.000 2,134.05 726.44 1,407.61 421,555.98
Sub Total 25,608.60 8,559.78 17,048.82
36 01/15/2012 4.000 2,134.05 728.86 1,405.19 420,827.12

37 0211512012 4.000 2,134.05 731.29 1,402.76 420,095.83
38 03/15/2012 4.000 2,134.05 733.73 1,400.32 419,362.10
39 0411512012 4.000 2,134.05 736.18 1,397.87 418,625.92
40 05/15/2012 4.000 2.134.05 738.63 1,395.42 417,887.29
41 06115/2012 4.000 2,134.05 741.09 1,392.96 417,146.20
42 07/1512012 4.000 2,134.05 743.56 1,390.49 416,402.64
43 08115/2012 4.000 2,134.05 746.04 1,388.01 415,656.60
44 09/15/2012 4.000 2,134.05 748.53 1,385.52 414,908.07
45 1011512012 4.000 2,134.05 751.02 1,383.03 414,157.05
46 11/15/2012 4.000 2,134.05 753.53 1,380.52 413,403.52
47 12115/2012 4.000 2,134.05 756.04 1,378.01 412,647.48
Sub Total 25,608.60 8,908.50 16,700.10
Page 1
""""u"' vm: rma11c1a1 i.;orporauon, LIC# 266464, NMLS# 266464
No Pmt Date Int Rate Monthly Schedule Principal Paid Interest Paid Mtg Insurance Balance
48 01/15/2013 4.000 2.134.05 758.56 1,375.49 411,888.92
49 02/15/2013 4.000 2,134.05 761.09 1,372.96 411,127.83
50 03/15/2013 4.000 2,134.05 763.62 1,370.43 410,364.21
. 51 04/15/2013 4.000 2,134.05 766.17 1,367.88 409,598.04
52 05/15/2013 4.000 2,134.05 768.72 1,365.33 408,829.32
53 06/15/2013 4.000 2,134.05 77129 1,362.76 ~08,058.03
54 07115/2013 4.000 2,134.05 773.86 1,360.19 407,284.17
55 08/15/2013 4.000 2,134.05 776.44 1,357.61 406,507.73
56 09/15/2013 4.000 2,134.05 779.02 1,355.03 405,728.71
57 10/15/2013 4.000 2,134.05 781.62 1,352.43 404,947.09
58 11/15/2013 4.000 2,134.05 784.23 1,349.82 404,162.86
59 12/15/2013 4.000 2.134.05 786.84 1,347.21 403,376.02
Sub Total 25,608.60 9,271.46 16,337.14
60 01/15/2014 4.000 2,134.05 789.46 1,344.59 4C2!52S.S6

61 G2/15i2014 4.000 2,'l34.05 792.09 1,341.96 401,794.47
62 03/15/2014 4.000 2,134.05 794.74 1,339.31 400,999.73
63 04/15/2014 4.000 2,134.05 797.38 1,336.67 400,202.35
64 05/15/2014 4.000 2,134.05 800.04. 1,334.01 399,402.31
65 06/15/2014 4.000 2,134.05 802.71 1,331.34 398,599.60
66 07/15/2014 4.000 2,134.05 805.38 1,328.67 397,794.22
67 08/15/2014 4.000 2,134.05 808.Q? 1,325.98 396,986.15
68 09/15/2014 4.000 2,134.05 810.76 1,323.29 396,175.39
69 10/15/2014 4.000 2,134.05 813.47 1,320.58 395,361.92
70 11/15/2014 4.000 2,134.05 816.18 1,317.87 394,545.74
71 12115/2014 4.000 2,134.05 818.90 1,315.15 393,726.84
Sub Total 25,608.60 9,649.18 15,959.42
72 01/15/2015 4.000 2,134.05 821.63 1,312.42 392,905.21

73 02115/2015 4.000 2,134.05 824.37 1,309.68 392,080.84
74 03/15/2015 4.000 2,134.05 827.11 1,306.94 391,253.73
75 04/15/2015 4.000 2,134.05 829.87 1,304.18 390,423.86
76 05/15/2015 4.000 2,134.05 832.64 1,301.41 389,591.22
77 06/15/2015 4.000 2,134.05 835.41 1,298.64 388,755.81
78 07/15/2015 4.000 2,134.05 838.20 1,295.85 387,917.61
79 08/15/2015 4.000 2,134.05 840.99 1,293.06 387,076.62
80 09/15/2015 4.000 2, 134.05 843.79 1,290.26 386,232.83
81 10/15/2015 4.000 2,134.05 846.61 1,287.44 385,386.22
82 11/15/2015 4.000 2,134.05 849.43 1,284.62 384,536.79
83 12115/2015 4.000 2,134.05 852.26 1,281.79 383,684.53
Sub Total 25,608.60 10,042.31 15,566.29
84 01/15/2016 4.000 2,134.05 855.10 1,278.95 382,829.43

85 02115/2016 4.000 2,134.05 857.95 1,276.10 381,971.48
86 03/15/2016 4.000 2,134.05 860.81 1,273.24 . 381, 110.67
87 04/15/2016 4.000 2,134.05 863.68 1,270.37 380,246.99
88 05/15/2016 4.000 2,134.05 866.56 1,267.49 379,380.43
89 06/15/2016 4.000 2.134.05 869.45 1,264.60 378,510.98
90 07/15/2016 4.000 2,134.05 872.35 1,261.70 377,638.63
91 08/15/2016 4.000 2,134.05 875.25 1,258.80 376,763.38
92 09/15/2016 4.000 2,134.05 878.17 1,255.88 375,885.21
93 10/15/2016 4.000 2,134.05 881.10 1,252.95 375,004.11
94 11/15/2016 4.000 2,134.05 884.04 1,250.01 374,120.07
95 12/15/2016 4.000 2,134.05 886.98 1,247.07 373,233.09
Sub Total 25,608.60 10,451.44 15,157.16
Page 2
Leaaerune t-manc1a1 i.;orporation, LIC# 266464, NMLS# 266464
No Pmt Date Int Rate Monthly Schedule Principal Paid Interest Paid Mtg Insurance Balance
96 01/15/2017 4.000 2,134.05 889.94 1,244.11 372,343.15
97 02115/2017 4.000 2,134.05 892.91 1,241.14 371,450.24
98 03/15/2017 4.000 2,134.05 895.88 1,238.17 370,554.36
99 04/15/2017 4.000 2,134.05 898.87 1,235.18 369,655.49
100 05/15/2017 4.000 2,134.05 901.87 1,232.18 368,753.62
101 06/15/2017 4.000 2,134.05 904.87 1,229.18 367,848.75
102 07/15/2017 4.000 2,134.05 907.89 1,226.16 366,940.86
103 08/15/2017 4.000 2,134.05 910.91 1,223.14 366,029.95
104 09/15/2017 4.000 2,134.05 913.95 1,220.10 365,116.00
105 10/15/2017 4.000 2,134.05 917.00 1,217.05 364,199.00
106 11/15/2017 4.000 2,134.05 920.05 1,214.00 363,278.95
107 12115/2017 4.000 2,134.05 923.12 1,210.93 362,355.83
Sub Total 25,608.60 10,877.26 14,731.34
108 01/15/2018 4.000 2,134.05 926.20 1,207.85 361,429.63

109 02/'! Si2018 4.000 2,134.05 929.28 1,204.77 360,500.35
110 03/15/2018 4.000 2,134.05 932.38 1,201.67 359,567.97
111 04/15/2018 4.000 2,134.05 935.49 1,198.56 358,632.48
112 05/15/2018 4.000 2,134.05 938.61 1, 195.44 357,693.87
113 06/15/2018 4.000 2,134.05 941.74 1,192.31 356,752.13
114 07/15/2018 4.000 2,134.05 944.88 1,189.17 355,807.25
115 08/15/2018 4.000 2,134.05 948.03 1,186.02 354,859.22
116 09/15/2018 4.000 2,134.05 951.19 1,182.86 353,908.03
117 10/15/2018 4.000 2,134.05 954.36 1,179.69 352,953.67
118 11/15/2018 4.000 2,134.05 957.54 1,176.51 351,996.13
119 12115/2018 4.000 2,134.05 960.73 1,173.32 351,035.40
Sub Total 25,608.60 11,320.43 14,288.17
120 01/15/2019 4.000 352,205.52 351,035.40 1,170.12 0.00

Sub Total 352,205.52 351,035.40 1,170.12
TOTAL 603,163.71 447,000.00 156,163.71
Pages
. .
EXHIBIT D
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71458178 810355 000037225663 10126/2017 $5,500.00
. . .
EXHIBIT E
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EXHIBIT F
• L•• p,
Tools acquired before marriage

Bed mattress and bedroom set
Couch sectional upstairs in bonus room
TV that was downstairs
Entertainment center upstairs that in in the bonus room
Surround sound upstairs
FILED.
17-3-02497-31
PPP 25
Proposed Parenting Plan
2082783
.11111~II1111llllWII11111~IIII1111111
4

8
10
No. 17-3-02497-31
Petitioner:
12 SALLY JO PRICE, Parenting Plan
(PPP I PPT I PP)
14 And Respondent:
CHARLES ALLEN PRICE, JR. 0 Clerk's action required: 1.
16
18
Parenting Plan
20
1. This parenting plan is a:
22
~ Proposal (request) by a parent: CHARLES ALLEN PRICE.
It is not a signed court order. (PPP)
24
D Court order signed by a judge or commissioner. This is a:
26 D Temporary order. (PPT)
28 2. Children - This parenting plan is for the following children:
·························································································-···---··················································--············,··········································-·········--·-
30 I Child's name Ag~ _J
11. Alexander 14 __ j
32 i 2. Colby 11 .J
i 3. Madis. . .o
. . . .n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . L .................. 5 ,
34
3. Reasons for putting limitations on a parent (under RCW 26.09.191)
36
a. Abandonment, neglect, child abuse, domestic violence, assault, or sex
38 offense. (If a parent has any of these problems, the court must limit that
parent's contact with the children and right to make decisions for the children.)
40
Neither parent has any of these problems. (Skip to 3.b.)
Goldberg Jones, PLLC

RCW 26.09.016, .181, .187, .194
Mandatory Form (05/2016)
~·
'
'
•,
' :_·
I .. 1·

I 1 .? ~ ~....... ~ ~.. .. \ ;_
FL All Family 140 p. 1 Seattle, WA 98109
(206)448-1010
2 b. Other problems that may harm the children's best interests. (If a parent has
any of these problems, the court may limit that parent's contact with the children
4
and right to make decisions for the children.)
6 Neither parent has any of these problems. (Skip to 4.)
8 4. Limitations on a parent
IO Does not apply. There are no reasons for limitations checked in 3.a. or 3.b. above.
(Skip to 5)
12
5. Decision-making
14
When the children are with you, you are responsible for them. You can make day-
16 to-day decisions for the children when they are with you, including decisions about
safety and emergency health care. Major decisions must be made as follows.
18
20
Type of Major Decision Joint
(parents make these
22
decisions to ether
i School I Educational I Cou
24
l-~~9.l!b. .~9..r..~.{~2.!~r.!.!~rn~~~Yt ················································-··········································-········-·························································j
26 b. Reasons for limits on major decision-making, if any:
28
6. Dispute Resolution - If you and the other parent disagree ...
30
From time to time, the parents may have disagreements about shared decisions or
32 about what parts of this parenting plan mean.
34 a. To solve disagreements about this parenting plan, the parents will go to:
36
Mediation (mediator or agency name): Aaron Shields or James Shipman
If there
are domestic violence issues, you may only use mediation if the victim asks for
38 mediation, mediation is a good fit for the situation, and the victim can bring a support person
to mediation.
40
RCW 26.09.016, .181, .187, .194 Goldberg Jones, PLLC

Mandatory Form (05/2016) 1200 Westlake Ave. N. Suite 700
FL All Family 140 p.2 Seattle, WA 98109
(206)448-1010
to name one.
4
8
I
othei parent by: E-MAIL
10
The parents will pay for the mediation, arbitration, or counseling services as
12 follows:
14 (Name): SALLY PRICE will pay 50%,

(Name): CHARLES PRICE will pay 50%.
16
What to expect in the dispute resolution process:
18
• Preference shall be given to carrying out the parenting plan.
• If you reach an agreement, it must be put into writing, signed, and both
20
• If the court finds that you have used or frustrated the dispute resolution
22 process without a good reason, the court can order you to pay financial
sanctions (penalties) including the other parent's legal fees.
24 • You may go back to court if the dispute resolution process doesn't solve
the disagreement or if you disagree with the arbitrator's decision.
26
7. Custodian
28
The custodian is SALLY JO PRICE solely for the purpose of all state and federal
30 statutes which require a designation or determination of custody. Even though one
parent is called the custodian, this does not change the parenting rights and
responsibilities described in this plan.
32
(Washington law generally refers to parenting time and decision-making, rather than custody.
34 However, some state and federal laws require that one person be named the custodian. The custodian
is the person with whom the children are scheduled to spend more of their time.)
36
38
40
RCW26.09.016, .181, .187, .194 Goldberg Jones, PLLC

(206)448-1010
2 .,... Parenting Time Schedule (Residential Provisions)
4 8. School Schedule
6 a. Children under School-Age

8
10
The children are scheduled to live with SALLY JO PRICE, except when they are
12 scheduled to live with CHARLES ALLEN PRICE on:
14 WEEKENDS: every other week from Thursday pick up after school (or if
no school 5:00 p.m.) to Monday drop off at school (or if no school
16 9:00 a.m.).
18 WEEKDAYS: every week on Wednesday from 4:00 p.m. to 8:00 p.m.
20 9. Summer Schedule
22 Summer begins and ends according to the school calendar.
The Summer Schedule is the same as the School Schedule except that each parent
24
shall be permitted up to 15 days of uninterrupted vacation time with the children
each summer. The parents shall confirm their vacation schedules in writing by May
26
151 of each year. (Skip to 10.)
28
10. Holiday Schedule (includes school breaks)
32 Children with (name): Children with (name):

Holiday
MOTHER FATHER
34 D Odd Years ~Even Years D Every Yr. D Even Years D Every Yr.
~Odd Years
36 Martin Luther
Begin day/time: 9:30 a.m. Begin day/time: _______
9:30 a.m. ___,
King Jr. Day End day/time: 7:30 p.m. End day/time: 7:30 p.m.
38
D With the parent who has the children for the attached weekend
D Other plan:
40

(206)448-1010
Holiday Children with (name): Children with (name):
2
MOTHER FATHER
[gl Odd Years D Even Years D Every Yr. D Odd Years [gl Even Years D Every Yr.
4
Begin day/time: 9:30 a.m. Begin day/time: 9:30 a.m.
Presidents'
6 End day/time: 7:30 p.m. End day/time: 7:30 p.m.
Day
8 D Other plan:
! D Odd Years ~Even Years D Every Yr. [gl Odd Years D Even Years D Every Yr.
10 Begin day/time: from 3:00 p.m. the day Begin day/time: from 3:00 p.m. the day
school lets out school lets out
12 Mid-winter End day/time: 7:30 p.m. on the day End day/time: 7:30 p.m. on the day
Break before school resumes before school resumes
14 D Each parent has the children for the half of break attached to his/her weekend. The
children must be exchanged on Wednesday at (time):
16 D Other plan:
[gl Odd Years D Even Years D Every Yr. D Odd Years [gl Even Years D Every Yr.
18 Begin day/time: from 3:00 p.m. the day Begin day/time: from 3:00 p.m. the day
school lets out school lets out
20 End day/time: 7:30 p.m. on the day End day/time: 7:30 p.m. on the day
Spring Break
before school resumes before school resumes
22 D Each parent has the children for the half of break attached to his/her weekend. The
children must be exchanged on Wednesday at (time):
24
D Other plan:
D Odd Years D Even Years [gl Every Yr. D Odd Years D Even Years D Every Yr.
26 Begin day/time: 9:30 a.m. Begin day/time:
Mother's Day
End day/time: 7:30 p.m. End day/time:
28 D Other plan:
D Odd Years [gl Even Years D Every Yr. [gl Odd Years D Even Years D Every Yr.
30 Begin day/time: 9:30 a.m. Begin day/time: 9:30 a.m.
Memorial
Day
End day/time: 7:30 p.m. End day/time: 7:30 p.m.
32
D Other plan:
34 D Odd Years D Even Years D Every Yr. D Odd Years D Even Years [gl Every Yr.
Begin day/time: Begin day/time: 9:30 a.m.
36 Father's Day
End day/time: End day/time: 7:30 p.m.
38
D Other plan:
40

(206)448-1010
2
MOTHER FATHER
4
[8J Odd Years 0
Even Years 0 Every Yr. 0 Odd Years [8J Even Years 0 Every Yr.
Begin day/time: 9:00 a.m. July 4 Begin day/time: 9:00 a.m. July 4
Fourth of
6 July
End day/time: 9:00 a.m. July 5 End day/time: 9:00 a.m. July 5
D Follow the Summer Schedule in section 9.
8 D Other plan:
11 I0 Odd Years [8J Even Years 0 Every Yr. [8J Odd Years 0 Even Years 0 Every Yr.
10 Begin day/time: 9:30 a.m. Begin day/time: 9:30 a.m.
Labor Day End day/time: 7:30 p.m. End day/time: 7:30 p.m.
12 D With the parent who has the children for the attached weekend
D Other plan:
14 0 Odd Years [8J Even Years 0 Every Yr. [8J Odd Years 0
Even Years 0 Every Yr.
Begin day/time: after school on the Begin day/time: after school on the
16 Wednesday before Wednesday before
Thanksgiving Thanksgiving Thanksgiving
Day I Break
18 End day/time: Sunday after End day/time: Sunday after Thanksgiving
Thanksgiving at 7:30 p.m. at 7:30 p.m.
20 D Other plan:
0 Odd Years 0 Even Years 0 Every Yr. 0 Odd Years 0 Even Years 0 Every Yr.
22 Begin day/time: Begin day/time:
End day/time: End day/time:
24
~ Other plan: During the first half of winter vacation, the child shall reside with Father in
even numbered years and with mother in odd numbered years. During the second half of
26 winter vacation, the child shall reside with Father in odd numbered years and with Mother in
Winter Break
even numbered years.
28
The first half of winter vacation shall be defined as 3:00 p.m. on the day school lets out for
30 winter vacation to noon (12:00 p.m.) on December 25. The second half of winter vacation shall
be defined as noon on December 25 to 7:30 p.m. on the day before school resumes.
32
[8J Odd Years 0 Even Years 0 Every Yr. 0 Odd Years [8J Even Years 0 Every Yr.
Christmas
Eve
36 ~ Follow the Winter Break schedule above.
D Other plan:
38
40

(206)448-1010
2
MOTHER FATHER
4
D Odd Years ~Even Years D Every Yr. ~Odd Years D Even Years D Every Yr.
Begin day/time: Begin day/time:
Christmas
6 End day/time: End day/time:
Day
cg] Follow the Winter Break schedule above.
8 D Other plan:
New Year's IZI Odd Years D Even Years D Every Yr. D Odd Years ~ Even Years D Every Yr.
IO Eve I New Begin day/time: Begin day/time:
Year's Day End day/time: End day/time:
(odd/even is
12 cg] Follow the Winter Break schedule above.
based on New
Year's Day) D Other plan:
14
D Odd Years ~Even Years D Every Yr. ~Odd Years D Even Years D Every Yr.
Children's Begin day/time: 10:00 a.m. Begin day/time: 10:00 a.m.
16
Birthdays End day/time: 8:00 p.m. End day/time: 8:00 p.m.
18 D Other plan:
20 All three-day (Federal holidays, school in-service days, etc.)

weekends cg] The children shall spend any unspecified holiday or non-school day with the parent who
22 not listed has them for the attached weekend.
elsewhere D Other plan:
24
Other D Odd Years D Even Years D Every Yr. D Odd Years D Even Years D Every Yr.
occasion Begin day/time: Begin day/time:
26
important to End day/time: End day/time:
the family:
28 Parents' D Other plan: The children shall be with the parent on that parent's birthday from 10:00 a.m.
Birthdays the day of the birthday to 8:00 p.m. the day of the birthday.
30
11. Conflicts in Scheduling

32
The Holiday Schedule must be observed over all other schedules. If there are
34 conflicts within the Holiday Schedule:
36 Named holidays shall be followed before school breaks.
38 12. Transportation Arrangements
40 The children will be exchanged for parenting time (picked up and dropped off) at:

(206)448-1010
2 each parent's home
school or day care when in session
4
6
The picking up parent - The parent who is about to start parenting time with
8
the children must arrange to have the children picked up.
10
13. Moving with the Children (Relocation)
If the custodian plans to move, s/he must notify every person who has court-
12
ordered time with the children.

If the move is to a different school district, the custodian must complete the form
16 Notice of Intent to Move with Children (FL Relocate 701) and deliver it at least 60
days before the intended move.
18
Exceptions:
20
• If the custodian could not reasonably have known enough information to
complete the form in time to give 60 days' notice, the custodian must give
22
notice within 5 days after learning the information.
• If the custodian is relocating to a domestic violence shelter or moving to
24 avoid a clear, immediate and unreasonable risk to health or safety, notice
may be delayed 21 days.
26 • If information is protected under a court order or the address confidentiality
28 • A custodian who believes that giving notice would put her/himself or a child at
unreasonable risk of harm, may ask the court for permission to leave things
30
out of the notice or to be allowed to move without giving notice. Use form
Motion to Limit Notice of Intent to Move with Children (Ex Parle) (FL Relocate
702).
32
•
The Notice of Intent to Move with Children can be delivered by having someone
34 personally serve the other party or by any form of mail that requires a return receipt.
If the custodian wants to change the Parenting Plan because of the move, s/he must
36 deliver a proposed Parenting Plan together with the Notice.
38 Move within the same school district

If the move is within the same school district, the custodian still has to let the other
parent know. However, the notice does not have to be served personally or by mail
40

(206)448-1010
with a return receipt. Notice to the other party can be made in any reasonable way.
2 No specific form is required.
4 Warning! If you do not notify...

A custodian who does not give the required notice may be found in contempt of
6 court. If that happens the court can impose sanctions. Sanctions can include
requiring the custodian to bring the children back if the move has already happened,
8 and ordering the custodian to pay the other side's costs and lawyer's fees.
10
Right to object
A person who has court-ordered time with the children can object to a move to a
different school district and/or to the custodian's proposed Parenting Plan. If the
12
move is within the same school district, the other party doesn't have the right to
object to the move, but s/he may ask to change the Parenting Plan if there are
14 adequate reasons under the modification law (RCW 26.09.260).
16 about Changing a Parenting/Custody Order (Relocation) (form FL Relocate 721).
File your Objection with the court and serve a copy on the custodian and anyone
18 else who has court-ordered time with the children. Service of the Objection must be
by personal service or by mailing a copy to each person by any form of mail that
requires a return receipt. The Objection must be filed and served no later than 30
20
days after the Notice of Intent to Move with Children was received.
22 Right to move
During the 30 days after the Notice was served, the custodian may not move to a
24 different school district with the children unless s/he has a court order allowing the
move.
26
After the 30 days, if no Objection is filed, the custodian may move with the children
28 without getting a court order allowing the move.
After the 30 days, if an Objection has been filed, the custodian may move with the
30
children pending the final hearing on the Objection unless:
32 • The other party gets a court order saying the children cannot move, or
• The other party has scheduled a hearing to take place no more than 15 days
34 after the date the Objection was served on the custodian. (However, the
custodian may ask the court for an order allowing the move even though a
36 hearing is pending if the custodian believes that s/he or a child is at
unreasonable risk of harm.)
38
The court may make a different decision about the move at a final hearing on the
Objection.
40

(206)448- l 0 l 0
Parenting Plan after move
2 If the custodian served a proposed Parenting Plan with the Notice, and if no
Objection is filed within 30 days after the Notice was served (or if the parties agree):
4
• Both parties may follow that proposed plan without being held in contempt of
6 the Parenting Plan that was in place before the move. However, the
proposed plan cannot be enforced by contempt unless it has been approved
8 by a court.
• Eithei party may ask the court to approve the proposed plan. Use form Ex
to
Parle Motion for Final Order Changing Parenting Plan - No Objection to
Moving with Children {FL Relocate 706).
12
Forms
16 • The Washington State Courts' website: www.courts.wa.gov/forms,
• . The Administrative Office of the Courts - call: (360). 705~5328,
18 • Washington LawHelp: www.washingtonlawhelp.org, or
• The Superior Court Clerk's office or county law library (for a fee).
20 (This is a summary of the Jaw. The complete law is in RCW 26.09.430 through
26.09.480.)
22
14. Other
24
14.1 Neither parent shall be permitted to take the children out of school for a
26 vacation and miss any school days unless it is agreed in writing by both
parents.
28
15. Proposal
30
D Does not apply. This is a court order.
~ This is a proposed (requested) parenting plan. (The parentls requesting this
32
plan must read and sign below.)
I declare under penalty of perjury under the laws of the state of Washington that
34 this plan was proposed in good faith and that the information in section 3 above
is true.
36
38 IJV-tv / V'1 J ~Jf JIwv.J ll-.J'

Parent requesting plan signs here Signed at (cit/and state)
40

(206)448-1010
2 16. Court Order
4
IZI Does not apply. This is a proposal.
D This is a court order (if signed by a judge or commissioner below).
6
Findings of Fact - Based on the pleadings and any other evidence considered:
8
Conclusions of Law - This Parenting Plan is in the best interest of the children.
10
Order - The parties must follow this Parenting Plan.
12
14
16
Date Judge or Commissioner signs here
18
Warning! If you don't follow this Parenting Plan, the court may find you in contempt (RCW
20
26.09.160). You still have to follow this Parenting Plan even if the other parent doesn't.
Violation of residential provisions of this order with actual knowledge of its terms is punishable
by contempt of court and may be a criminal offense under RCW 9A.40.060(2) or 9A.40.070(2).
22 Violation of this order may subject a violator to arrest.
24
26
If this is a court order, the parties and/or their lawyers {and any GAL) sign below.
28
This order (check any that apply): This order (check any that apply):
D is an agreement of the parties. D is an agreement of the parties.
30 D is presented by me. . [gl is presented by me.
D may be signed by the court without notice to me. D may be signed by the court without notice to me.
32
34
36
38 SABRINA LAYMAN, WSBA #25260 ROBERT MAR, WSBA #27735

Attorney for Petitioner Attorney for Respondent
40

(206)448-1010
2
4
This order (check any that apply): This order (check any that apply):
6 D is an agreement of the parties. D is an agreement of the parties.
D is presented by me. D is presented by me.
D may be signed by the court without notice to me. D may be signed by the court without notice to me.
8
IO
12 SALLY JO PRICE CHARLES ALLEN PRICE

14
16
18
20
22
24
26
28
30
32
34
36
38
40

(206)448-1010
1 F·ttED~
lll\1 NOV \ 4 p~ \2: 04
17-3-02497-31
2 FNDCLRR 26
Financial Declaration of Respondent
2082786
3
4 · ~11~mm11~~111111m1111111m
5
6
Superior Court of Washington, County of SNOHOMISH
7 In re:
Petitioner:
8 No. 17-3-02497-31
SALLY JO PRICE
And Respondent: Name: CHARLES ALLEN PRICE
10 (FNDCLR)
CHARLES ALLEN PRICE
11
14 Name: CHARLES ALLEN PRICE
The highest year of education completed:
15 Your job/profession is:
16 [X] Yes. List the date you were hired (month/year):
[ ] No. List the last date you worked (month I year):
18
20 Com /ete this section after filling__o_u_t_th_e_re_s_t_o_f _th_is_fo_rm__,.)_ _ _ _ _~-------.

1. ~otal Mont!!_ly Net Income (QQf!Y from section 3, line C. 3.) ____ $9,016.99
21 2. Total Monthl Ex enses After Se aration co from section 7, line I. $8,722.01
_3. T.Qtal Monthly Pa_yments for Other Debts (copy from sectiof!J!L ___________~_ $553.00
22 4. Total Monthl Expenses+ Payments for Other Debts (add line 2 and line 3)_ __L_ $9,275.01
. . . . ____- - -_- - - - _- - - - - _- - - - _- - - _- - - ----'$_1_6~;7_9_3_.o_o_······~]

I Gross Monthly Income of Other Party (copy,__fro_m_s_ec_t_io_n_3_:_A_:,_j_
23
24
RCW 26.18.220(1) Financial Declaration Goldberg & Jones, P.L.L.C.

Mandatory Form (0512016) Attorneys at Law
FL All Family 131 p. 1of6 1200 Westlake Ave N. Suite 700
Seattle, WA 98109
(206)448-1010

1 3. Income
3
4 Monthly income= Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
5 A. Gross Monthl~ Income (before taxes, deductions, or retirement contributions)

CHARLES SALLY JO PRICE
6
ALLEN PRICE
7 Imputed income - $2,693.00
Monthly wage I salal)' $14,016.7f!J________ --
I
8 Income from Interest and dividend Income - i ·-·-· -
------- -·-----r---
9
Income from business - - - · · -
I
-----1--------------
$7, 100.00
Spousal support I maintenance received - ' $1,000.00
10 (Paid by: )
Other Income - -
11
Total Gross Monthly Income (add all lines above) $14,016.78 $10,793.00
12 Total gross income for this year before deductions - I -
(starting January 1 of this vear until now) I I
13
B. Monthl~ Deductions
14 CHARLES I SALLy JO PRICE
ALLEN PRICE
15
ln~Q!!le~xe_~(federal and state) $2,122.68 I $716.98
··----· ·---·----------r---------------
16 FICA (Soc.Sec.+ Medicare) or self-emplo~ment taxes $860.44 I $507.96
State Industrial Insurance (Workers' Comp.) - I -
17
Mandatory union or professional dues - I -
18 Mandatory__Qension plan ~~ments $416.67 -
Voluntary retirement contributions (up to the limit in RCW - -
19 26.19.071 (5)(Q))
20
Spousal suooort I maintenance paid $1,000.00 -
Normal business expenses l - $4,963.00
21 Total Monthly Deductions (add all lines above) $4,999.79 $6,187.94
22 C. Monthly Net Income I CHARLES I SALLy JO PRICE
ALLEN PRICE
23
1. Total Gross MonthJy Income _{from A above) $141016.18 I $10,793.00
I
24 2. Total Monthly Deductions (from B above) $4,999.79 I $6,187.94
3. Net Monthly Income (Line 1 minus Line 2) I $9.016.99 I $4,605.06
FL All Family 131 p. 2 of 6 1200 Westlake Ave N. Suite 700
Seattle, WA 98109
(206)448-1010

Monthly income = Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
3
4
A. Other Income (Do not repeat income you already listed on page 2.)
5 CHARLES I SALLy JO PRICE
ALLEN PRICE
6 Chil~~J:IP2..Q!L!:~ce_i_'{ed frqm ot~er relatiQ_i:!~~f>S ______ !_____________-___J____________:_
Other Income From: ( - l -
7 l --
Other Income From: ( ) ! - I -

8
Total Other Income (add all lines above) I ~
I ~
10 B. Household Income (Monthly income of other adults living in the homel

CHARLES Ii SALLY JO
11 ALLEN PRICE's PRICE's Home
Home 1·
12
Other adult's gross income - -
13 Name: ( ) I
14
Name: ( )
15 Total Household Income of other adults in the home - -
(add all lines above)
16
5. Disputed Income - If you disagree with the other party's statements about anyone's
17 income, explain why the other party's statements are not correct, and your statements are
correct:
18
19 6. Available Assets
20 List your liquid assets, like cash, stocks, bonds, that can be easily cashed.
21 Cash on hand and money in all checking & savings accounts I $399.51
Stocks, bonds, CDs and other liquid financial accounts -
22
Cash value of life insurance -
23 Other liquid assets -
Total Available Assets (add all lines above) $399.51
24

Seattle, WA 98109
(206)448-10 I 0

...
1
3 children.
A. Housing Expenses IF. Transportation Expenses
4 Rent I Mortgage Payment $2,300.00IAutomobile payment (loan or lease) -
Property Tax (if not in monthly payment) - !Auto insurance, license, registration $148.10
5 Homeowner's or Rental Insurance $25.00IGas and auto maintenance $550.00
'
Other mortgage, contract, or debt - IParking, tolls, public transportation -
6 payments based on e~ in your home i
Homeowner's Association dues or fees ' - IOther transportation expenses -
7 Total Housing Expenses I $2,325.00I Total Transportation Expenses $698.10
8 ~~ Utilities Expenses !G. Personal Expenses {not children's)

!
_Electricity and heating Jg as and oil) $230.61 [Ciothes - -----·---~
$150.00
9 Water, sewer, QarbaQe $210.83IHair care, personal care $50.00
Telephone~) $155.?0iRecreation, clubs, gifts ~ ___$200.00_
10 Cable, Internet
-----~--·----
$295.95IEducation, books, magazi·ne-s------··- $50.00

Other (specifyl: Home ~hone Frontier I $59.93IOther Personal Expenses $200.00
11
Total Utilities Expenses I $953.021 Total Personal Expenses $650.00
12
H. Other Ex enses
13 $600.00 Life insurance (not deducted from pay)
$113.33
14 Eating out $59.58
$280.00
15 Total Food and Household Expenses $950.00 Total Personal Expenses $452.91
16 D. Children's Expenses !List all Total Expenses from above:

Childcare, babysittinQ - IA. Total HousinQ Expenses $2,325.00
17 Clothes, diapers ------·····-------·-J _ _!~g~Q_QJ B. To~_Utilities t~en~~~ __________ J__ l~53:_9..?
Tuition, after-school programs, lessons , - IC. Total Food and Household Expenses $950.00
18 Other expenses for children ' $50.00ID. Total Children's Expenses $250.00
Total Children's Expenses $250.00IE. Total Health Care Expenses $2,442.98
19
IF. Total Transportation Expenses I $698.10
E. Health Care Expenses IG. Total Personal Expenses $650.00
20
Insurance premium (health, vision, dental) I $1,485.1 OIH. Total Other Expenses $452.91
21 Health, vision, dental, orthodontia, mental
$807.8811. All Total Expenses (add A- H above) $8,722.01
health expense not covered by insurance
22 Other health expenses not covered by $150. 00 I Use section 11 below to explain any unusual expenses,
1-in_s_ur_a_nc_e_______________--; or attach additional pages.
23 Total Health Care Expenses $2,442.981
~---·--
24

Seattle, WA 98109
(206)448-10 I 0

1 8. Debts Included in Monthly Expenses listed in section 7 above
2
Debt for what expense I Who do you owe Amount you owe Last Monthly
mort a e, car loan, etc.) 1 (Name of creditor) this creditor now Pa ment made
3
5
9. Monthly payments for other debts (.!!Q! included in expenses fisted in section 7)
6 Describe Debt Who do you owe I Amount you owe Last Monthly Payment
!
credit card, loan, etc. Name of creditor i this creditor now ! Date and Amount
7 ! $1495.02 i $80.00
$20,810.27 I $438.00
8 _CreEit car9______~_~nk of America Sandals ~3,103.07 $35.00
9
- I
10 Total Monthly Payments for Debts $553.00
11 10. Explanation of.expenses or debts (if any needed):

12
13 11. Lawyer Fees

List your total lawyer fees and costs for this case as of today.
14
Amount paid $4 ooo.oo I Sour~e of the money you used to pay these fees and costs:
15 ' Credit Card
Amount still owed I Describe your agreement with your lawyer to pay your fees and
16 1 costs:
17 Total Fees/Costs $4,ooo.oo I

i
18
19
20 Date: I I I '?I J :r
21 tf'l(,r/g BILA l?-1&e TfL
Print name
22
23
24
local court rules. These records may include:
RCW 26.18.220(1) Financlal Declaration Goldberg & Jones, P.L.L.C.
Mandatory Form (0512016) Ailorneys al law
FL All Family 131 p. s of6 1200 Westlake Ave N. Suite 700
Seattle, WA 98109
(206)448·1010
FamllySoft FormPAK PL 2017

1 • Personal Income Tax Returns • Partnership or Corporate Income Tax Returns
• Pay stubs • Other financial records
2
Important! Do not attach financial records to this form. Financial records should be served on the other party and
3 filed with the court separately using the Sealed Financial Source Documents cover sheet (FL All Family 011 ). If filed
separately using the cover sheet, the records will be sealed to protect your privacy (although they will be available to
4 all parties and lawyers in this case, court personnel and certain state agencies and boards.) See GR 22(c)(2).
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Seattle, WA 98109
(206)448-1010

17-3-02497-31
CSWP 27
Child Sup rt W
2082788 po orksheet Proposed
· 1111 mmm111111111111~11111111111
[X] Proposed by [X] Charles Allen Price [ ] State of WA [ ] Other (CSWP)
Or, [ ) Signed by the Judicial/Reviewing Officer. (CSW)
County SNOHOMISH Case No. 17-3-02497-31
Child/ren and Age/s: Alexander Price, 14; Colby Price, 11; Madison Price, 5
Parents' Names: CHARLES ALLEN PRICE (Column 1) SALLY JO PRICE (Column 2)
CHARLES
SALLY JO
ALLEN
PRICE
PRICE
Part I: Income (see Instructions, page 6)
a. Wages and Salaries Imputed for SALLY JO PRI $14016.78 -
b. Interest and Dividend Income -··-- - - - - - -
e. Other Income - -
f. Imputed Income - $2,693.00
g. Total Gross Monthly Income (add lines 1a throuqh 1f) $14016.78 $10793.00
a. lnCOf!:!~_'I§lxe~ (Fed~ral and State) Tax Year: 2017 -- - -$2,722.68
$860._44_
$716.98
b. FICA (Soc.Sec.+Medicare)/Self-Emoloyment Taxes --- $507.96-
e. Mandato!)'. Pension Plan Payments $416.67 -
f. Voluntary Retirement Contributions - -
_ _g. Maintenance Paid $1,000.00 -
h. Normal Business Ex~enses - $4,963.00
(add lines 2a through 2h) $4,999.79 $6,187.94
5. Basic Child Support Obligation (Combined amounts--+)
Alexander Price $1206.00
Colby Price $975.00 $3,156.00
-
-
. ,_
J l ·. i ~.._ . ._.
CHARLES
SALLY JO
ALLEN
PRICE
PRICE
b. Is Monthly Net Income Less Than Self-Su1212ort Reserve? If yes,
c. Is Monthly Net Income egual to or more than Self-Su1212ort
reserve from line 3. !f that amount is less than line 7, enter that
' amount or the presumptive $50 per child, whichever is greater. - -
(add both parent's totals from line 10c) $233.50
11. Day Care and Special Expenses
_ _ E_:_~~~-~!!_o_!!_~xpenses - -
··--
- -
- -
- -
- -
e. Total Day Care and Special Expenses - -
(Add lines 11 a throuoh 11 d)
both parents' day care and special expenses from line 11e) -
plus line 12) $233.50
CHARLES
SALLY JO
ALLEN
PRICE
PRICE
- -
- -
- -
d. Total Support Credits (add lines 16a through 16c) $233.50 -
i i7. Standard Ca!cuiation (iine ·i 5 minus iine i 6d or $50 per child
a. Real Estate - -
b. Investments - -
c. Vehicles and
- -Boats
--------- - -
-·----------·---·- ------·----••-•••---·•www -------· - -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f. - -
-
{if not the other ~arent of this action} -------··
Name - -
Name - -
Name - -
Name - -
CHARLES
SALLY JO
ALLEN
PRICE
PRICE
d. Income Of Child(ren) (if considered extraordinarv)
Name - -
Name - -
e. Income From Child Su~port
Name - -
Name - -
Program - -
Program - -
- -
- -
23. Non-Recurring Income (describe)
- -
- -
24. Child Su~~ort Owed, Month!~. for Biological or Legal Child(ren)

Father's income is based on his year to date on his October 31, 2017 paystub.
Mother's income is based on her collecting the income for the two rental properties
and imputed income on her age.

Signature and Dates

Date City Date City

FIL.ED
17-3-02497-31
2011 NOV 14 PH 12: Ot.
DCLR 28
~iiil~llll~~Hl!llllll 1 1
In re:
Petitioner/s (personls who started this case): No.17~02497-31.
SALLY JOPRICE Declaration of
(name): Tyson Steen._ _ _ _ _ _ __
And Respondent/s (other party/parties): (DCLR)
CHARLES ALLEN PRICE, Jft
Pecla~tioQ of ('11~111e): :Tyso•l Steen.·_~-------. . . . . . .

1. 1- I am (age): 3 (e years old and I am the (check one): D Petitioner ~ Respondent
~ Other (relationship to the people in this case):Head Coach For Lakewood Football
Assoc.
I am writing this declaration for Allen Price. I have known Allen Price for the last 3 years. I coached his
oldest son Alex's football team when he was in 7"-" Grade and gth Grade. Allen was at every practice rain
or shine. He always showed encouraging words to his son and was respectful to the coaching staff. I
have had the please to coach this year with Allen in Lakewood. His son Colby plays on our team. These
boys are 9-11 yrs. old's. Allen has shown patience and has worked well with the entire group of roaches.
He has been willing to help the boys in whatever way they needed. We are not just coaches in football it
is important to teach these young men about perseverance, disappointment, courage and leadership.
Allen has provided all this to all the boys on this team. He is a great asset to our program.
.. . ;.·.;
.. ·.. :;......... ···.····· ·········
01>tlona1 i=onli (05!2<ffiii · Declaration
FL All Family 135 . "\ I
I 1
,p.• I1 of 4.
_ I I - 1. , '
• I - • if -
(Number any pages you attach to fhiS Declaration. Page limits may apply.)
I dedare under penalty of perjury under the laws of the state of Washington that the tacts I have
provided on this form (and any attachments) are true. D I have attached (number): ~ pages.
°f.Signed atJ£!~anc;fstateJ:/lrt'tif.&~, ~1"4m. 11//1 1

.· .... w==n
Date:}(
':~~.-.
~~
Optional Form (0512016) Declaration

FLAii Family 135 p.2 ofZ..
17-3-02497-31
DCLR
29
~illlillll/lllH
In re:
Petitioner/s (personls who started this case): No. 17-3-02497-31.
SALLY JO PRICE Declaration of
(name): Christi Miller_ _...,....,,......._...__~
And Respondentfs (other party/parlies): (DCLR)
CHARLES ALLEN PRICE. JR.
Declaration of (name): Christi l\lliller_ _ _~~-

1. / I am (agef_!/L years old and I am the (check one): 0 Petitioner ,2Sl Respondent
gf Other (relationship to the people in this case):;< 11.L> ~~
2. I declare:~~'.'."."'."'.".........~~,...__,_-,-~~~..,.._~......,._~-----"'""';;;_,;...........~.;;......;.~_,_-
I have known AHen Price f'Or 17 years I have worked with him for 14 of those 17 years. fn aD of those
years of working With Allen, he was working about 12+ hours a day.
Allen was always in the office before I arrived in the morning. He was often s1il wmting when I left in
the evening and alway$ scheduled appointments with Realtors on the weekend. I have recently
returned to the mmpany Allen works for. Since his Heartatt.act in mid-20171 have noti::ed that he
made lfe changes and arriws for work later in the mornins and leaves by 4pm.
fn tf-ie time that I have known Allen he has coached youth football with mv husband. He coaches his
son, Colby and my son, Easton. He Is very patient caring a,m gRat at teaching the leadership skllJs that
young hap need. He never missed a game or prattke and was atwavs1here for each child When they
had questions or just needed someone to talk to.
A1len has been lib a familY member to me for many years I see how hfs kids adore him. He Is a great
father and role model. He wauJd do anything for his family.
Optional Form (O!Yi016) Declaration ' ·

FL All Family 135 p.1of_
' "'- f
_,j
~"' ' ' I
' '--
•
IL-
(Number any pages you attach to this Declaration. P.rtge ltmits may apply.}·
I declare under penalty of perjury under the Jaws of the state Of Washington that the facts I have
provided on this form (and any attachments) are true. ~ have attached (number): 0 pages.
f
f ~
. . . .t~:.:.<~atxi*'>'' ~' {/)ti..
~.~~ . . ...· Christi MOier
~ °"":J/-1-17
t1Jr1s6 fahl/cr
Sign here Print name
IWarning/ Documents filed With !he court ~ available for anyone to see unless they are sealed. Fmanoial, I
confidential reports, as described in General Rule 22, must be sealed so they can only be seen by ;
1 meaioal, and
I the court, the other party, and the lawyers in your case. Seal those documents by fiftng them separately, using aI
I Seale<! cover sheEH (form FL AllFamily 011, 91~. or 013)•. You may ask for an order to ~al olh~r docul1lents ·. . 1
Optional Form (05/'l016) · · Deolaration

FLAii Family 135 p.2of_
17-3-02497-31
DCLR 30
2082800
.· 111111mm1111111mm1111 SONYA !'\RA;:: Kl

COUNTY CLERK
SNOHOMISH CO. WASH.

In re:
Petitioner/s (personls who started this case): No. 17-3-02497-31
SALLY JO PRICE
Declaration of
(name): Keith King _ _ _ _ _ _ _ __
Declaration of (name): -'"__,,e-.. /_'f/t

. . ___Jt_;VVJ-'-+------
"f 1. I am (age): S'O years old and I am the (check one): D Petitioner 1)5{ Respondent
© Other (relationship to the people in this case): I do most all the repairs to the Prices
properties. I have a business relationship with both Sally and Allen Price_ _ _ _ __
2. I declare: That I have been in all the units at Camwood apts. I have owned my own
contracting company and I am still in the contracting business since closing my company. I have
worked for Sally and Allen for the past 1Oyears of various things from all their rental properties,
I completely remodeled their cabin in the mountains, the family home and Commercial bui!ding
they had owned in downtown Everett. Allen and myself over the fast 7-8 years have remodeled
and brought all these units up to date. There is no real maintenance needed besides a small
weather stripping item or something very minor. The only time there is any items on these is
when someone departs an apt. At that point there may be some minor painting, carpet cleaning
and possibly a blind. The other property the I repaired for them in the last year is the Marysville
home. I put a new roof gutters downspout on it. I painted it and they put new insulation under
the home. I put a new sump pump under it and this home has never had any real need for

FL All Family 135 p.1 of J_
\ s' -
'
repairs besides these items I just repaired. Allen has always kept up on the maintenance of all
their properties and they are all in great shape. Neither of these properties should have any
repairs needed for some time to come
(Number any pages you attach to this Declaration. Page limits may apply.)
provided on this form (and any attachments) are true. DI have attached (number):_ pages.
f:. Signed at (city and state): .......4"--"-,_,.r;("'-"'-~"""£c"""'zl"-"'-?--""""l&..><...L.ff-"-- _ ___,'f. Date: /(Z - C - / Z

(- ~ ~ ?' ,/~, -& :L/£'ncy
)i6nh~// Printname _/
I Warning! Documents filed with the court are available for anyone to see unless they are sealed. Financial,
\ medical, and confidential reports, as described in General Rule 22, must be sealed so they can only be seen by
! the court, the other party, and the lawyers in your case. Seal those documents by filing them separately, using a
i Sealed cover sheet (form FL All Family 011, 012, or 013). You may ask for an order to seal other documents

FL All Family 135 p. 2 of ..2-
17-3-02497-31
RPY 32
FILED
Reply
2099750 2011 NOV 16 AM II: 09
1
Ill I111111111111111111111111111111111111 SONY/.; !-'..J,\SKI
2
cown y CLERK
S:~~1HOMlSH CO. W,\SH
3

IN AND FOR THE COUNTY Of' SNOHOMISH
6
Jn re the Marriage of: CaseNo.: 17-3-02497-31
7
SALLY JO PRICE, REPLY DECLARATION OF PETITIONER
8
Petitioner,
9
and
10
11
Respondent.
12
13 1. I am the Petitioner herein and make this declaration in reply to Respondent's materials.
14 2. farerrfing Plan. I agree that Respondent's alternating weekend schedule of
15 Thursday to Monday is fine; however, we will need to deal with Colby's CPAP machine. I
16 propose that Respondent get a CPAP for his own home. Until he gets his own, he will need to pick
17 it up from my house on Thursday. I agree with the mid-week visit on Wednesday from 4 to 8 p.m.
18 (so long as he takes the children to/from their activities on those days/times). I believe my holiday
19 schedule should be adopted as I apply the long weekends to school holidays which dovetails with
20 the extended weekends Respond~11t proposes. l also believe I should remain the decision maker
21 when it comes to health care and coun~ling as I have always been the one to make those decisions
22
23 I
BREWE LAYMAN P.S.
Attorneys at Law
24 OR\G\NAL P.O. Box488

(425) 2.52-5167 Phone
REPLY DECLARATION OF PETITIONER - t (425} 252-9055 Fax
www.brewelaw.com
1 and Respondent acknowledges the same. Our children do not have a long mid-winter break so the
2 President's Day break should be alternated (it's Friday to Monday).
3 3. Finances. The Respondent's earnings as I proposed take into consideration market
4 fluctuations and fluctuations in returns. By using a 5 year average. I believe that is fair. What is
5 hot fair is to assume an imputed income for me that is unattainable on a temporary basis and add in
6 additional incomt;: for our rentals. As Respondent ~1ates in his declaration, until very recently he
7 was working 6 days pet week, 12+ hours per day. I was 100% responsible for the children and our
8 rental properties. There was no extra time to work additional locations. I realize that moving
9 forward I will need a plan for financial independence, but on a temporary basis there is no ability
10 for me to earn what Respondent is imputing. I did use an imputed amount to calculate child
11 support because I thought that was fair but it does not me-an that I actually "have'' that amount of
12 money to cover expenses, Add to my lack of work history the fact that I have had three surgeries
13 in the last 4 weeks (one on each of my eyes and one on my ears) which were emergent. I am sti.11
14 recovering from bqth and am in need of assistance.
15 4. It appears that Respondent agrees that I will have the income from the rental
16 properties. The total income is 7,000 for both the apartment building and rental house total. The
17 expenses are $6; 128 per month total. That is income to me of $871.00 pet month so long as we
18 have :fully occupied rentals. This is not sufficient for any consideration of substantial income and
19 could possibly result in liability. I agree that he should cover the costs of the
20 repairs/damage/serious maintenance, etc. and I agree to continue to do what I have been doing to
21 keep the rentals going.
22
BREWE LAYMAN P.S.
P.O.Box488
Everett, Washington 9~20.6-0488
24 (425) 25. 2-5167 Phone
REPLY DECLARATION OF PETITIONER - 2 {425) 252·9055 Fax
www.brewelaw.com
I 5. ~pondent proposals for child support and maintenance are not.sufficient for us to
2 survive. Respondent does not take into consideration the enormous amount of income Respondent
3 controls. He obviously thought he would continue to 1naf(e substantial income based on the fact
4 that his monthly expenses for himself are $9,275.01 per month. It's without.reason that he would
5 suggest the expenses for me and our three children should be l/3 of the expenses for himself
6 UNLESS he expects to continue to earn the income that we have enjoyed for years and years.
7 6. I believe that i:ny proposal is fair given our lifestyle, lefl8th of marriage, reasonable
8 approach to the earnings, Respondent's control over his income received, my need and his ability
9 to pay. Tue court should order that Respondent must take all receipts and income from his
IO employment so he cannot defer receipt ofany commissions or dividends or earnings that would
11 come from his employment or ownership status.
12 7. Conclusion. It c:tppears that we are in agreement on virtually everything regarding
13 parenting our children which is great. The financial situation is untenable as proposed by
14 Respondent. As stated above and .in my initial materials, he has significant earning which he must
15 feel will continue to be ~oming in since he moved put to 4 bedroom/plus office rental home and is
16 apparently planning to .cover his own .$9,200 per month in expenses. lam asking the court to order
17 the support that I have sought.
18
19
20
21
22
BR EWE LAY M AN P. s .
23 I Attorneys at law
P.O ..Box488
24 {425) 252-5167 Phone
REPLY DECLARATION OF PETITIONER - 3 (425) 252-9055 Fax
www.brewelaw.com
1
. ,-f(
2 Executed this _I.L:?day of November, 2017 at Everett, Wa.
10
11
12
13
14
15
16
17
18
19
20
21
22
BR EW E l AV MAN I>. s.
23 I
Attorneys at Law
P.O.Box488
24 (425) 252-5167 Phone
REPLY DECLARATION OF PETITIONER - 4 (425) 252-9055 Fax
www.brewelaw.com
17-3-02497-31
20!1 NOV 2 I ''". .. ~

MTHRG 33
Motion Hearing t :,. r' 11
. : .::::
1
~J
i1\\i1~11111111~m1~11n111111 SUPERIOR COURT OF

WASHINGTON
FOR SNOHOMISH COUNTY
CAUSE NO.: 17-3-02497-31

SALLY JO PRICE COMMISSIONER: JACALYN D. BRUDVIK
(PETITIONER) CLERK: L. ELLIS
AND DATE: 11/21/17 @ 9:00 A.M.
CHARLES PRICE DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: TEMPORARY ORDERS

CONTINUED DATE/TIME/SESSION NAME/CONTINUANCE CODE:
HEARING DATE SET/TIME/SESSION NAME:
ACTION:
HEARING STRICKEN/CODE:
PETITIONER APPEARED: YES COUNSEL: SABRINA LAYMAN
RESPONDENT APPEARED: YES COUNSEL: ROBERT MAR
GUARDIAN AD LITEM APPEARED: NO
DOCUMENTS FILED:
ORDERS ENTERED: AGREED TEMPORARY PARENTING PLAN; TEMPORARY FAMILY LAW ORDER, TO
BE FILED BY COUNSEL LAYMAN
PROCEEDINGS/COURT'S FINDINGS:
THE COURT AWARDS UNDIFFERENTIATED SUPPORT OF $12,000 PER MONTH FOR CHILD
SUPPORT AND SPOUSAL MAINTENANCE TO THE PETITIONER.
THE PETITIONER IS TO MOVE FORWARD WITH BECOMING GAINFULLY EMPLOYED.
ONCE THE PETITONER IS EMPLOYED, SHE IS TO PROVIDE THE NAME OF HER EMPLOYER
AND HOURS EMPLOYED TO THE RESPONDENT WITHIN 48 HOURS.
THE PETITIONER IS AWARDED $5000.00 IN ATTORNEY FEES.
1 MINUTE ENTRY
17-3-02497-31
PPT 34
1 Parenting Plan Temporary 2011 NOV 21 AM IO: 57
2127465
2
1111111111111111111111111111111111111111

IN AND FOR THE COUNTY OF SNOHOMISH _ _ • "'
6
InretheMarriageof: Case No.: 17-3-02497-31 ~-
7
SALLY JO PRICE, TEMPORARY PARENTING PLAN
8 (PPP I PPT I PP)
Petitioner,
9
and
10
11
Respondent.
12
13 Parenting Plan
14 1. This parenting plan is a
15 Court order signed by a judge or commissioner. This is a
16 Temporary order.
18 Child's name
1. Alexander
19 f=2:.:' .. ====L........ ----················· ---·-----··················•·--·····==·········
3. Madison
20
21
a. Abandonment, neglect, child abuse, domestic violence, assault, or sex offense.
22 (If a parent has any of these problems, the court must limit that parent's contact
BREWE LAYMAN P.S.
24
I NA A~·.
~{,.;
Pi qj
~~J · U
.;
-;.
u·P.O.Box488
· 4251252-5167 Phone
· 425 252-9055 Fax
· · · ww.brewelaw.com
1 with the children, the right to make decisions for the children, and may not
require dispute resolution other than court.)
2
Neither parent has any of these problems.
3
b. Other problems that may harm the children's best interests. (If a parent has any
4 of these problems, the court may limit that parent's contact with the children and
right to make decisions for the children.)
5
Neither parent has any of these problems. (Skip to 4.)
6
4. Limitations on a parent ·-pr\
7
8
The following limits or conditions apply to Charles A. ;sf: Jr.:
Other limitations or conditions during parenting time: No corporal punishment of

the children, no physical discipline of the children.
9
5. Decision-making
10
12
13
IJ: Type.ofMa]orT·- ·- Joint Limited
14 Decision j (parents make these I (only the parent named below has authority
-----··---------······· decisionsXtqg_f!.!f!f!_!:L)_..... J<?.1!.1_q¥.:_ _ _~h'!_~~---4__~q_!~!<?.f!~)_
15 School I Educational
Health care (not
16 .~!P.:.~rn~P.:~.Y) ·--·· -·-· · -· · · · · · · · '· · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · :.. _____
5f~;:[ =·~~~~~-·····
17
18
Other; Marriage prior to . x
-~g~_!_~ . . .. . . . . . . . .\ --------- . I
. . . . . . +. . . .
19
Other: Entry into the X
20
21
~~t F:~ :~-~ °.~ ~- · · ·-· · · ' . . . . _____ J_ _ _
c. Reasons for limits on major decision-making, if any:
22 There are no reasons to limit major decision-making.
BREWE LA
P.O. Box488
24
TiGMEQllAflY PARENTING PLAN - 2 !
425! 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1
2
the parents will go to a dispute resolution provider or court. The court may only require a
4 dispute resolution provider ifthere are no limitations in 3a.
5 a. The parents will go to

6
Mediation - by an agreed upon family law mediator
7
to name one.
9
11
12 other parent by written request.
13 The parents will pay for the mediation, arbitration, or counseling services as follows
14 based on each parents' Proportional Share of Income (percentage) from line 6 of the
Child Support Worlrsheet.
15
What to expect in the dispute resolution process:
• Preference shall be given to carrying out the parenting plan.
16 • If you reach an agreement, it must be put into writing, signed, and both
17
• If the court finds that you have used or frustrated the dispute resolution
process without a good reason, the court can order you to pay financial
18 sanctions (penalties) including the other parent's legal fees.
19 • You may go back to court ifthe dispute resolution process doesn't solve the
disagreement or if you disagree with the arbitrator's decision.
20
7. Custodian
21 The custodian is Sally J. Price solely for the purpose of all state and federal statutes which
require a designation or determination of custody. Even though one parent is called the
22
BREWE LAYMAN P.S.
P.O. Box488
24 (425! 252-5167 Phone
l'!GMEQ~Y PARENTING PLAN - 3 (425 252-9055 Fax
www.brewelaw.com
1 custodian, this does not change the parenting rights and responsibilities described in this
plan.
2
(Washington law generally refers to parenting time and decision-making, rather than
3 custody. However, some state and federal laws require that one person be named the
custodian. The custodian is the person with whom the children are scheduled to spend
4 more of their time.)
5 ~ Parenting Time Schedule (Residential Provisions)

6 The children live with Petitioner/Mother, Sally J. Price except as described in section 4.
7 8. School Schedule
8 a. Children under School-Age

9
10
This schedule will apply when the oldest child begins Kindergarten:
11
The children are scheduled to live with Sally J. Price, except when they are
12 scheduled to live with Charles A. Price, Jr. on:
.... ,· l< \(\
13 ~ ~ ' J.-\ ~ WEEKENDS: every other week from Thursday pick-up after school or at
"1>.JV~ 5 :00 p.m. until Monday morning return to school or at 9:00 a.m.
14
WEEKDAYS: eve~ Wednesday from 4:00 p.m. until 7:30 P·rr_1· . D&£J +l>
15 .fr--~~()~t- ~HA~ -i-P/~ -liA._d ,r ..t..L.---h, lA f7 t.. \. D
ummer Schedule w~~ ~ c;. ,
16
Summer begins and ends according to the school calendar.
17
The Summer Schedule is the same as the School Schedule except that each parent shall
18 spend one (1) week of uninterrupted vacation time with the children each summer.
The parties shall notify each other of their intended vacation dates by May 1st of each year.
19
If the parties cannot agree, then Petitioner's selected vacation dates shall take precedence in
even-numbered years, and Respondent's selected vacation dates shall take precedence in
20 odd-numbered years.
21 10. Holiday Schedule (includes school breaks)

BREWE LAYMAN P.S.
P.O. Box488
-___....,

24 425j 252-5167 Phone
l~MEQMR.Y PARENTING PLAN - 4 l
425 252-9055 Fax
www.brewelaw.com
1
I Holiday I Children with Petitioner/Mother I Children with Respondent/Father
2
**In the event the father is working on his designated holiday. the children shall remain with
3 the mother

5
6 or3:00 p.m. or3:00 p.m.
Martin
7 Luther King
Jr. Day
End Monday of the End Monday of the
8
9 7:30 p.m. 7:30 p.m.
With the parent that has the attached weekend.
10
11
12 day/time: weekend after school day/time: weekend after school
or 3:00 p.m. or3:00 p.m.
13 President's (whichever is (whichever is
Day weekend applicable) applicable)
14
15 day/time: holiday weekend at day/time: holiday weekend at
7:30 p.m. 7:30 p.m.
17
18 Begin Friday after school or Begin Friday after school or
day/time: at 3:00 p.m. day/time: at 3:00 p.m.
19 Spring Break
End ~at7:30 End &·~at 7:30
20 day/time: If\ <f,.m. day/time: A p.m.
21
22

Attorneys at Law
P.O. Box 488 ----i--

(425) 252-5167 Phone
~B:Qp~ED PARENTING PLAN - 5 (425) 252-9055 Fax
www.brewelaw.com
------- --------------------
1 Every Yr.
Begin 9:00 a.m. the day of Begin
2
day/time: the holiday day/time:
Mother's
3 End 7:30 p.m. the End
Day
day/time: evening of the day/time:
4 holiday
5

7
day/time: . weekend after school day/time: weekend after school
8 or3:00 p.m. or 3:00 p.m.
Memorial (whichever is (whichever is
9 Day applicable) applicable)
IO
11 7:30 p.m. 7:30 p.m.
12
Every Yr.
13
Begin Begin 9:00 a.m. the day of
14 day/time: day/time: the holiday
Father's Day
End End 7:30 p.m. the evening
15
day/time: day/time: of the holiday
16

18
19 Fourth of holiday holiday
July End 9:00 a.m. the End 9:00 a.m. the
20 day/time: morning following day/time: morning following
21
22
23
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
24 !425! 252-5167 Phone
l'!G~Qll.ARY PARENTING PLAN - 6 425 252-9055 Fax
www.brewelaw.com
3 or3:00 p.m. or 3:00 p.m.
4 Labor Day

6 7:30 p.m. 7:30 p.m.

Begin Pick up from school Begin Pick up from school
9 Thanks- day/time: Wednesday day/time: Wednesday
giving Day End 7:30 p.m. Sunday End 7:30 p.m. Sunday after
10
day/time: after Thanksgiving day/time: Thanksgiving
11
12 Winter In odd-numbered years the children shall spend from after school or at 3:00 p.m.
Break/Christ the day school is out until Christmas Day at 12:00 p.m. with the
13 mas
Petitioner/Mother and from 12:00 p.m. Christmas Day until 7:00 p.m. the day
Eve/Christm
14 as Day/New prior to return to school with the Respondent/Father. The schedule shall be
Years reversed for even-numbered years.
15 Eve/New
Years Day
16

Begin 9:00 a.m. the day of Begin 9:00 a.m. the day of
18 Children's day/time: the birthday day/time: the birthday
Birthdays End 7:30 p.m. the day of End 7:30 p.m. the day of
19
day/time: the birthday day/time: the birthday
20
21
22
23
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
f
4251252-5167 Phone
Ii&MRQ~Y PARENTING PLAN - 7 425 252-9055 Fax
www.brewelaw.com
1 The children shall spend any unspecified holiday or non-school day with the
All three-day parent who has them for the attached weekend. The weekend shall commence
2 weekends not Thursday (if holiday/in-service day is a Friday) or Friday (if the holiday/in-
listed service day is a Monday) after school or 3:00 p.m. (whichever is applicable)
3 elsewhere until 7:30 p.m. Sunday (if the holiday/in-service day is a Friday) or Monday (if
the holiday/in-service is a Monday) of the holiday weekend.
4
5
Other
6 occas10n day/time: morning of the day/time: morning of the
important to holiday holiday
7 the family: End 7:30 p.m. the End 7:30 p.m. the evening
day/time: evening of the day/time: of the holiday
8 Easter
holiday
9
10
Other '61~ q~0
occas10n Begin
11 "'2 ".OD
important to day/time: ~ -
the family: End
12
day/time:
Halloween
13

Begin 9:00 a.m. the Begin
15
16 Other holiday holiday
occasion End 7:30 p.m. the End 7:30 p.m. the evening
17 important to day/time: evening of the day/time: of the holiday
the family: holiday
18
If the holiday falls on a Friday or Monday, the above schedule shall be
Veterans Day
19 replaced as follows: Thursday (if holiday is a Friday) or Friday (if the
holiday is a Monday) after school or 3:00 p.m. (whichever is applicable)
20 until 7:00 p.m. Sunday (if the holiday is a Friday) or Monday (if the ho ·day
is a Monday) of the holiday weekend.
21
22

Attorneys at Law
P.O. Box488
(425l 252-5167 Phone
l~MRQMR_Y PARENTING PLAN - 8 (425 252-9055 Fax
www.brewelaw.com
1 Other Every Year
occasion Begin 9:00 a.m. the day of Begin
2 important to
the family:
Mother's day/time: the birthday day/time:
4 Birthday
5 Other Every Year

occas10n Begin 9:00 a.m. the day of Begin
6 important to
the family:
Father's day/time: the birthday day/time:
8 Birthday
9 11. Conflicts in Scheduling
10 The Holiday Schedule must be observed over all other schedules. If there are conflicts
within the Holiday Schedule:
11
If the residential schedule results in a conflict where the children is/are scheduled to
12 be with both parents at the same time, the following shall have priority over section
8, in the following order (1 being the highest priority and 6 being the lowest
13 priority):
14 1 - Section 10: Martin Luther King Jr. Day, Presidents' Day, Easter, Memorial
Day, Fourth of July, Labor Day, Halloween, Thanksgiving Day/Break, New
15 Year's Eve/New Year's Day, All three-day weekends not listed elsewhere.
2 - Section 10: Mother's Day, Father's Day, Children's Birthdays, Mother's
16 Birthday, Father's Birthday.
3 - Section 10: Vacation with Parents
17 4 - Section 9: Summer Schedule
5 - Section 10: Winter Break, Christmas Eve, Christmas Day
6 - Section 10: Mid-winter Break, Spring Break
18
12. Transportation Arrangements
19
The children will be exchanged for parenting time (picked up and dropped off) at:
20
each parent's home
21 school or day care when in session
22 Who is responsible for arranging transportation?

Attorneys at Law
P.O. Box488
(425l 252-5167 Phone
www.brewelaw.com
1
The picking up parent - The parent who is about to start parenting time with the
2 children must arrange to have the children picked up.
3 Other details:
4 Transportation costs are included in the Child Support Worksheet and/or the Child
Support Order.
5
The children shall be picked up and returned at the designated times or within
fifteen ( 15) minutes thereof in the event of an unforeseen delay. Should a delay
6 become necessary, the receiving parent shall be notified immediately.
9 with the children
11 If the move is to a different school district, the relocating person must complete the form
Notice ofIntent to Move with Children (FL Relocate 701) and deliver it at least 60 days
12 before the intended move.
13
Exceptions:
• If the relocating person could not reasonably have known enough information to
complete the form in time to give 60 days' notice, s/he must give notice within 5
14
days after learning the information.
• If the relocating person is relocating to a domestic violence shelter or moving to
15
avoid a clear, immediate and unreasonable risk to health or safety, notice may be
delayed 21 days.
16
• If information is protected under a court order or the address confidentiality
17
• A relocating person who believes that giving notice would put her/himself or a
child at unreasonable risk of harm, may ask the court for permission to leave things
18
out of the notice or to be allowed to move without giving notice. Use form Motion
19
to Limit Notice ofIntent to Move with Children (Ex Parte) (FL Relocate 702).
The Notice ofIntent to Move with Children can be delivered by having someone personally
20
serve the other party or by any form of mail that requires a return receipt.
21 If the relocating parent wants to change the Parenting Plan because of the move, s/he must
deliver a proposed Parenting Plan together with the Notice.
22

Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
l'~MRQ~YPARENTINGPLAN-10 (425) 252-9055 Fax
www.brewelaw.com
1 Move within the~ school district
2 If the move is within the same school district, the relocating parent still has to let the other
parent know. However, the notice does not have to be served personally or by mail with a
3 return receipt. Notice to the other party can be made in any reasonable way. No specific
form is required.
4
Warning! Ifyou do not notify ...
5
A relocating parent who does not give the required notice may be found in contempt of
court. If that happens the court can impose sanctions. Sanctions can include requiring the
6 relocating person to bring the children back if the move has already happened, and ordering
the relocating person to pay the other side's costs and lawyer's fees.
7
Right to object
8
A person who has court-ordered time with the children can object to a move to a different
9 school district and/or to the relocating person's proposed Parenting Plan. If the move is
within the same school district, the other party doesn't have the right to object to the move,
1O but s/he may ask to change the Parenting Plan if there are adequate reasons under the
modification law (RCW 26.09.260).
11
12 about Changing a Parenting/Custody Order (Relocation) (form FL Relocate 721). File
your Objection with the court and serve a copy on the custodian and anyone else who has
court-ordered time with the children. Service of the Objection must be by personal service
13
or by mailing a copy to each person by any form of mail that requires a return receipt. The
Objection must be filed and served no later than 30 days after the Notice ofIntent to Move
14 with Children was received.
15 Right to move
16 During the 30 days after the Notice was served, the relocating person may not move to a
different school district with the children unless s/he has a court order allowing the move.
17
After the 30 days, if no Objection is filed, the relocating person may move with the
18 children without getting a court order allowing the move.
19 After the 30 days, if an Objection has been filed, the relocating person may move with the
children pending the final hearing on the Objection unless:
• The other party has scheduled a hearing to take place no more than 15 days after the
21 date the Objection was served on the relocating person. (However, the relocating
person may ask the court for an order allowing the move even though a hearing is
22 pending if the relocating person believes that s/he or a child is at unreasonable risk
of harm.)
Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
l'iGMfiQllAR.Y PARENTING PLAN - 11 (425 252-9055 Fax
www.brewelaw.com
1
The court may make a different decision about the move at a final hearing on the
2 Objection.
3 Parenting Plan after move
4 If the custodian served a proposed Parenting Plan with the Notice, and if no Objection is
filed within 30 days after the Notice was served (or ifthe parties agree):
• Both parties may follow that proposed plan without being held in contempt of the
5
Parenting Plan that was in place before the move. However, the proposed plan
cannot be enforced by contempt unless it has been approved by a court.
6
• Either party may ask the court to approve the proposed plan. Use form Ex Parte
Motion for Final Order Changing Parenting Plan -No Objection to Moving with
7
Children (FL Relocate 706).
8
Forms
9
You can find forms about moving with children at:
• The Washington State Courts' website: www.courts.wa.gov/{Orms,
10 • The Administrative Office of the Courts - call: (360) 705-5328,
12 (J'his is a summary ofthe law. The complete law is in RCW 26.09.430 through 26.09.480.)
13 14. Other Provisions
14 a. Records. Each parent shall have equal and independent authority to confer with
physicians, counselors, schools, daycare and other programs with regard to the
15 progress of the children and each shall have free access to counseling, medical,
school, daycare, and other records. Each parent shall have authority to give parental
16 consent or permission as may be required concerning school, daycare or other
programs for the children while the children is/are in his or her residential care.
17
b. Telephone Access (Children). The children shall have liberal telephone privileges
18 with the parent with whom the children is/are not then residing without the /""+/j 4.
interference of the residential parent. '-1"' fi16
19
c. Telephone Access (Parents). The non-residential parent may contact the children
telephonically at any reasonable time.
20 --rr-,t_,tA.C,. r 4\...w I
d. Participation in Children's Events. The children shall be/accompanied by the
21 parent with whom the children is/are residing at the time of a given sgsial @v@nf:
The other parent shall not be limited from attendance at that event, providing said
23 I BREWE LAYMAN P . .
Attorneys at Law
P.O. Box488
Everett, Washington 98206-0488 .
24 {425l 252-5167 Phone
l!GMRQ~YPARENTINGPLAN-12 (425 252-9055 Fax
www.brewelaw.com
1
e. Notification of Children's Events. Each parent shall be responsible for keeping
2 themselves advised of school, athletic, and social events in which the children
participate(s). Both parents may participate in school activities for the children such
3 as open house, attendance at an athletic event, etc.
4 f. Disparaging Remarks. Neither parent shall make disparaging remarks about the
other parent to or in front of the children and both parents shall cooperate in
fostering a good and loving relationship between the children and the other parent.
5
g. Minimizing Impact on Children. The primary objective of the parents is to
6 minimize the negative impact that their separation shall have on the children. Each
parent seeks a full and active role in providing the children with a sound moral,
7 social, economic and educational environment for the children. To this end, the
parents are committed to cooperative and mutual involvement in the lives of their
8 children.
9 h. Considering Children's Schedules. Both parents shall consider the needs and
interests of the children, and the children's schedule of school and other regular
10 planned activities, when arranging visitation.
11 i. Alcohol/Drugs. Neither parent shall consume alcohol in excess nor consume drugs
other than over-the-counter or prescribed medication while the children is/are under
12 their care.
j. Consistency of Routine and Discipline. The residential arrangements are provided

13
for in the best interest of the children. The children's interests is/are best served by
responsiveness and cooperation by both parents, involvement by both parents in all
14 aspects of the children's needs, and a reasonable consistent routine of activities,
values, and discipline throughout both homes. Inconsistency and conflict are
15 opposed to the best interest of the children.
16 k. Good Faith of Parents. Both parents freely and wholly commit themselves to this
parenting plan with the expectation that it will provide a stable and lasting
17 residential schedule for the children and the parents. Each parent is aware that
violations of this parenting plan, abusive use of conflict, false reports to authorities,
18 or bad-faith use of dispute resolution (including court action) could lead to a
reduction of residential time with the children.
19
I. Children's Clothing/Possessions. The parents shall not interfere with the right of
20 the children to transport his/her clothing and possessions to each parent's home.
Neither parent shall stockpile the children's clothing or possessions. Both Parents
21 shall cooperate in providing and returning the clothing and possessions of the
children.
22
BREWE LAYMAN P.S.
P.O. Box488
425j 252-5167 Phone
l'!GMRQµRY PARENTING PLAN - 13 l
425 252-9055 Fax
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1 m. Deviation from Schedule. Acceptance and waiver of any deviations from the
provisions of this parenting plan shall not constitute acceptance or waiver of
2 subsequent deviations from this plan. The provisions of this plan shall remain in
effect until modified by an appropriate written order by a court of competent
3 jurisdiction; provided, that any and all revisions to this plan are in writing and
signed by both parents, and shall be effective immediately.
4
n. Change of Addressffelephone. Each of the parties shall keep the other parent, and
the Washington State Support Registry (if applicable), informed as to their current
5
residential address and telephone number at all times.
6 o. Notification of Change in Schedule. Each parent shall notify the other at least
forty-eight (48) hours in advance if he/she is unable to comply with the regular
7 residential schedule. Both parents acknowledge that from time to time
unpredictable situations may arise in their lives, and in the children's life/lives,
8 which makes strict adherence to the above residential plan impractical.
9 p. Piercingffattoos. Neither parent shall allow the children to be tattooed/pierced

without the consent of the other parent.
10
q. Compliance with Plan. If a parent failed to comply with a provision of this
11 Parenting Plan, the other parent's obligations under the plan are not affected.
12 r. Development of the children. Each parent desires to remain responsible and

active in the growth of the children and development consistent with the best
interest of the children. The parents will make a mutual effort to maintain an open,
13
ongoing communication concerning the development, needs and interests of the
children and will discuss together any major decision which has been made about
14 or for the children.
15 s. Emergency care for the children. Each parent shall be empowered to obtain
emergency health and dental care for the children without the consent of the other
17 children.
18 t. Routine care for the children. Each parent shall have equal and independent
authority to provide routine medical and dental services for the children while the
19 children is/are in his or her care and residence.
20 u. Religious upbringing. Each parent shall have an equal right to include the children
in his or her religious activities and expressions. The children shall have the right to
make his/her own religious choice as the children mature(s).
21
v. Day-to-day care. Each parent may make decisions regarding day-to-day care and
22 control of the children while the children reside(s) with that parent.

Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
l'iGMEQllARY PARENTING PLAN - 14 (425 252-9055 Fax
www.brewelaw.com
1
w. Major decisions. In the event of an irreconcilable difference between the parents as
2 to the joint major decision set forth above
3 The matter shall be resolved via the dispute resolution process set forth hereinafter
in section 6.
4
15. Proposal
5
Does not apply.
6
16. Court Order
7 This is a court order (if signed by a judge or commissioner below).
8 Findings of Fact - Based on the pleadings and any other evidence considered:
9 The Court adopts the statements in section 3 (Reasons for putting limitations on a
parent) as its findings.
10
Conclusions of Law-This Parenting Plan is in the best interest of the children.
11
Order - The parties must follow this Parenting Plan.
12 t:\)+
DONE IN OPEN COURT thic!li_ day of November, 2017.
13
14
15 iwarntng! If you do t foll this P~~~nttngPlan, tiiecolirt-may find you in contempt-,

I (RCW 26.09.160). Yo Ill have to follow this Parenting Plan even ifthe other parent
16 i doesn't.
17 ! Violation of residential provisions of this order with actual knowledge of its terms is i
1 punishable by contempt of court and may be a criminal offense under RCW !
18 i. ?.A:4.Q'.Q~QQ12~?.A_:~9.:_Q?QG2:..Yig!~!i.2~2f !~~2.~4-~~!!?:':lY ~~!?J~9.!~Y.i.2!~!2.t!2. l:l!!.~~!: ___J
21
BREWE LAYMAN P.S.
22 Attorneys at Law
BREWE LAYMAN P.S.
P.O. Box488
24 (425! 252-5167 Phone
l'!GMEQMRY PARENTING PLAN - 15 (425 252-9055 Fax
www.brewelaw.com
1
2
3 rina A. Layman, WSBA 25260 Attorney for Respondent
4
This order: This order:
6
/......,/~
7~ Y ,· /
.
·-. - /
7'"""":;.JI""-··-..,,,......_. ~.--.:;>
_..··
S'iily J. Price {/Charles A. Price, Jr.

8 Petitioner Respondent
10
11
12
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
24 (425l 252-5167 Phone
www.brewelaw.com
FILED
2017 HOV 21 AM IQ: 57
SONYA Kt{t\St{I
COlJ"tTY CLEf~h
S:IC;r'JMiSH CO. WASH

6
In re the Marriage of: Case No.: 17-3-02497-31
' -
7
8
Petitioner,
9
and
10
11
Respondent.
12

15 []No money judgment is ordered.
16 [] Summarize any money judgments in the table below.
17 Judgment for Debtor's name Creditor's Amount

(person who must name (person
pay money) who must be
18
aid
19 L~~~!.~~f.~'?~------·-·-···--······· ... ;---- J?.~~-- $5 Ol>D

ther fees and costs J_
····················-···--·----+····-·-·····-·····-····-···-·---.......
\'>.si $
ther 1$
20
. . . . . . . . . . . . . . . . . . . . . . ., , __,__,___,. . 1. .---·· ·-·-· ·--·----·-- . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . .- · · · · · · ·-· · · -· -· ·--·. t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
21 ~~~~~~~~~~~~~~~~------- .. - - - ,
22
t. ·t-~ii;·~-f.~:~~~-~ =~:.:.:: ~: ...
~ ~~ii~~~~~~~~?;~~t:~~~-~.. . .:. . . : . . . . . . . .:. . . . . . . . . . .. . . . . . :J
~ iiiOOT~?JIN ~:~h::,::o:_:_·----
8
23
24 ~ ~ "'- - !425l 252-5167 Phone

liGMfJiiRARY FAMILY LAW ORDER - 1 ~~.t~~;~~~~;;m
1 2. Findings
5 (I'he federal Servicemembers Civil ReliefAct covers:

• Army, Navy, Air Force, Marine Corps, and Coast Guard members on active duty;
6
row; and
7
8
10
~ The Court Orders
11
4. Care of children
12
13 .............................................................------···-·····-····················-"':'··-·--·········
14 h.Mex~-hil~-=--= -~
r~·;·:<;2D?.i__ ---·---·-·---·············-··································································+··························!
15 i 3. Madison
state.
18
22

Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
'I~Mf;QRARY FAMILY LAW ORDER - 2 (425 252-9055 Fax
www.brewelaw.com
Provide support
:rfte eettrt sigtted the tcnrpomry Child Stt;ppm t Otvkt· aBe WTJ1'k8heets filee sefJafately.
. U--k~~.e...-k'..f .I
The Respondent must payhpousal support to his spouse. \\

~ t>6
12., D!J.t:> - ..i 2 I - i
Amount: $ per month. 'bi! c::.~ ) tJ J \
-- ..._ /il!Jt I 1 l>&t?
Date 1st payment is due _ _ . Day of the month each payment is due YZ ~
1
·
\I
-1/2 ~ \
Make all payments to: .
Jkthe other spouse/domestic partner. ~ ~osif ~
.
I
[] Washington State Child Support Registry (available if_c · ~ort is
.::I! l
\
Family home
{)vu M/ ;f)vJ:.,.
wl,,..-{~ Lui~ ~,,,I.£<_.._.,
~l
Stay in the home - The Petitioner may stay in the family homfud r :us~he I
furnishings, furniture, and adornments located therein.
--.+.
Use of property
~ VVLVvi..A
J
Petitioner will possess and use:
property in possession now.
vehicle/s: 2010 Mercedes GL550
Respondent will possess and use:
property in possession now.
vehicle/s: 2012 Audi Q5.
Protect property
needs. Both parties must notify the other about any expenses that are out of the ordinary.
I BREWE LAYMAN P.S.

Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
l'iGWWl.ARY FAMILY LAW ORDER - 3 (425 252-9055 Fax
www.brewelaw.com
1
3 consent.
4 The Petitioner and Respondent must not move, take, hide, damage, borrow against,
5 to pay for basic needs. Both spouses/domestic partners must notify the other about
any expenses that are out of the ordinary.
6
8 any way, except in the usual course of business or for the necessities oflife.
11 not limited to IRA, Keogh, 401-K, retirement, pension, and/or profit sharing
accounts.
12
oflife.
15
18
20
23 I BREWE LAYMAN
Attorneys at Law
P.O. Box488
P.5.

(425! 252-5167 Phone
l'!G~gRARY FAMILY LAW ORDER - 4 (425 252-9055 Fax
www.brewelaw.com
1
3
9. Householdexpenses ~~ J;;..h/,
4 1
5
10
11 _ specific designati<;ms set forth above. '"P.e..--h-h~ slrv<.....U ~iv\.cve... ~......... L
0
p~ T""'"VA- ~/\A-~ P~· \2L.1--p~+ '$~ ~.o~ -ft:>. ·
12 10. Dividedebts ~ p~ ~··\>.!---h-l-i~ -~ ~ p~+
A'bl, 1VL-tft,·~, br-e.. . J-N ~·
13 The Petitioner and Respondent must: ,. .... c _1 • • L --}..) 1'1£~;i..4-f""<--
~- c.. ......... - ~ • ~ ~ ......... ~
'-.A)\~~·
14 Each be responsible for his/her own futi.ire debts, including debt from credit cards,
15
16 ............................................... - ........................--·-···----·-·· .. ···
[_:f.!~~!Il.t~~P.!:!~~1 . ..... . ... -. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . o sh_Q!J:!~P?.Y

17 LJ'.I.~H5?_~~g~!?.~~!____ __ ___ .................._ Petitioner
19
liable.
21
incurring any extraordinary debts without providing the other party thirty (30) days
22
23 I BREWE LAYMAN P.5.
Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
l'~~;QRARY FAMILY LAW ORDER - 5 (425 252-9055 Fax
www.brewelaw.com
1
2
5 Pay premiums as follows:
6 Who
1. Medical
7 2. Dental
3.
8 4. Orthodontia
9
10
11
f0d.>DO~ b5 t /?:,o} l
'ft, The Respondent must pay the other party's lawyer fees. Amount: $_ _ . Make
payments to ~<};1~e) ~ ~-) ~. S.
12
@)
13 Money Judgment
14 [] The ~eliftt/s listed aboYc must be paid, but the court is not entering a nwney_
judgment at this time.
15
~The amount/s listed above shall be entered as a money judgment. (Summarize
the money judgment in section 1 above). The interest rate is 12% wliess another
16
~ount is listed here [] The interest rate is % because -
17 [] Other: ( l -{- V\.51-
20 No request made.
22

Attorneys at Law
P.O. Box488
(4251252-5167 Phone
l'i&~:Q.RARY FAMILY LAW ORDER - 6 (425 252-9055 Fax
www.brewelaw.com
~-------------
1 Petitioner and Respondent shall be and hereby are restrained and enjoined from bothering,
2
4 A. Marysville rental property on 66th Dr. N.E. -to Petitioner/Wife

B. Stanwood rental property on 271 st St. N.W. - to Petitioner/Wife
5 lZRs.ptAA~ ~ ~.d. -Jo CA.I~ ~ Y"'~~·v-s
Ordered. h'l~~ u__ ,
6 .,+
DONE IN OPEN COURT this$Lf ~of November, 2017.
7

11

Attorneys at Law
13
14
a A. Layman, WSBA 25260 Attorney for Respondent
15 ttorney for Petitioner

/ ./
~ "7'
,, !
\C/
7 /
19~ri~
18 k/
~~~-{/')'.....__
Cflades A. Price, Jt:/ ,,·-·~, . __
v
20
21
22

Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
l'~Mi':Q.RARY FAMILY LAW ORDER- 7 (425 252-9055 Fax
www.brewelaw.com
17-3-02497-31
2 NlWSUB 36
Notice Withdraw and Substitution of Counsel
: i1im1\\i\llllll\l\l\llll\lllll\llIll
5
7 Superior Court of Washington

County of Snohomish
8
9 In re:
10 SALLY JO PRICE,
Petitioner, No. 17-3-02497-31
11
and
12 Notice of Withdrawal and Substitution
13 CHARLES A. PRICE, JR.

14
Respondent.
15 TO: Clerk of the above -entitled Court and

TO: Robert Mar, Attorney for Respondent;
16 AND TO: Sabrina Layman, Attorney for Petitioner;
17
PLEASE TAKE NOTICE that, Robert Mar, hereby withdraws as attorney of record fo
18 the Respondent in the above entitled matter and substituting as counsel is Veronica Freitas, of V.
Freitas Law, PLLC, who hereby appears and requests that all future papers in this proceeding b
19
directed to her.
20
DATED November 28, 2017.
21
Respectfully submitted,
~
22
23
24 Robert Mar, WSBA#27735

WITHDRAWING COUNSEL
25
26
a_A.-=--
Veronica Freitas, WSBA # 19405
27 SUBSTITUTING COUNSEL
28
VERONICA FREITAS
Notice of Withdrawal and Substitution 544 291h Avenue
Seattle, WA 98122
Page 1of1 (206) 328-7362
v@vfreitaslaw.com
2
17-3-02497-31 2U l1 DEC - l PM 12: 0 I ·
3 MTFR 37
Motion for Revision
2186156 ·SQ ~i 'r' :\ Ki\ ;, S~ !
\':lU~ r Y C~Ei:~..;
111~1mm1~11111~111~m
4
S~J;;.:;~·~iSH CO. W,\SH
5
7
9
Inre:
10
11 Petitioner,
and Motion for Revision.
12
13 Res ondent.
14
I. Motion for Revision
15
Comes now the Respondent, by and through his attorney of record, Veronica Freitas, and
16
moves this court to revise Commissioner Jacalyn D. Brudvik's Temporary Order and Temporary
17
18 Parenting dated November 21st, 2017. Please see Temporary Order attached hereto as Exhibit A.
19 II. Relief Requested

20
Mr. Price is seeking revision of Commissioner Brudvik's Order pursuant to the errors
21
claimed in Section III below.
22
III. Claimed Errors
23
24 Commissioner Brudvik made the following errors:
25 1. Prohibiting the parents from taking the children out of Washington State.
26
27
28

544 291h Avenue
(206) 328-7362
2. Ordering $12,000 per month in undifferentiated family support, an amount which
2
exceeds the Respondent's net income.
3
3. Failing to consider the additional $2037 in income given to the wife from both
4
5
rental properties when setting maintenance.
6 4. Ordering the Respondent to pay all premiums (medical, dental, optical,
7 orthodontia, and automobile).

8
OUT OF STATE TRAVEL
9
Mr. Price asks that either parent be allowed to travel with the children out of state for
10
11 vacations with at least two weeks' notice. The parents shall provide an itinerary, address, and
12 phone number where the children can be reached.

13
FAMILY SUPPORT AND MAINTENENECE
14
Mr. Price has a base salary of $7 ,000 per month plus commission. Historically, he was
15
worked 6+ days a week. Prior to 2017, Mr. Price earned a great deal from commissions which
16
17 were a direct result working over 60 hours a week and being "on-call" via telephone 24 hours a
18 day. The mother averaged Mr. Price's income for 2012 -2016 and asked the court to impute him
19
at $416,402 per year (over $30,000 per month). Their argument centered on Mr. Price's
20
"ownership" of this company but he is a producing loan officer and subject to the Consumer
21
Financial Protection Bureau (Title XIV of the Dodd Frank Wall Street Reform and Consumer
22
23 Protection Act). By law, Mr. Price cannot dictate his income and it cannot be based on the
24 amount (terms) of any loans he originates. See Exhibit B, excerpt from Regulation Z, Section
25
1026.36(d). Mr. Price's holding is approximately 2% of the company and his only earnings are
26
salary and commissions as explained below.
27
28

544 29th A venue
(206) 328-7362
In April of this year, Mr. Price had a severe heart attack and spent a week in the hospital.
2
He was lucky to survive and has two stents as a result. The Petitioner acknowledges in her
3
pleadings that as a result of this health event, Mr. Price had to drastically reduced his work hours.
4
Mr. Price had another heart event in October of 2017, which caused his work hours to drop to
5
6 forty hours per week. Mr. Price submitted evidence that his physician has now limited him to
7 working no more than 40 hours a week due to his heart condition. Please note, on his October
8
paycheck, he earned no commission that month as a result of missing work due to health issues.
9
Mr. Price's heart attack has had a tangible impact on his earning potential. In the first ten months
IO
11
of the year, Mr. Price earned $140,000. This averages $14,000 per month.
12 When setting the family support at $12,000, the court apparently adopted the mother's
13
proposed income for Mr. Price which was based off an average of five years earnings. For all of
14
those years averaged, Mr. Price was working the aforementioned 60+ hours and "on-call" which
15
significantly increased his commission earnings. Due to Mr. Price's documented health issues it
16
17 is not realistic to impute him at over $30,000 per month. The court should use his actual year-to-
18 date income of $14,000 per month when setting support.

19
The Petitioner has a bachelor's degree and is able to work. She has worked as recently as
20
2009 and when she worked full-time she earned around $57,000. She should have her income
21
imputed per the net median income table. Mr. Price submitted proof that the Stanwood apartmen
22
23 assigned to the Petitioner produced a net income of $1, 739 .89 per month and that the Marysville
24 rental produces a net income of $190 per month. This totals $1,929.89 in rental income to the
25
Petitioner each month. Her total income should be $4,622.89.
26
27
28

544 291h A venue
(206) 328-7362
For illustrative purposes, the Respondent submits two child support worksheets. Both
2
worksheets include the health insurance premiums paid by Mr. Price. The monthly total for the
3
family is $1485.10. The children's proportional share is $891. The first worksheet, submitted as
4
5
Exhibit C, imputes Petitioner's income per the median net table ($2,696) and includes the
6 income from the rental homes ($1929). After drafting the worksheets and brief counsel realized
7 that the actual net income from the rentals is higher at $2,037 but we have left the original
8
number of $1929 rather than recalculating worksheets and deductions. The tax deductions were
9
determined for 2017 as married filing jointly. The difference in their net incomes prior to
10
11 maintenance is $6,109.78. To equalize the parties through maintenance, Mr. Price would pay
12 $3,054.89. This would result in a child support transfer payment of$1,310.56. Using this
13
worksheet, the Petitioner would have a total of $6,295.34 per month (maintenance+ child
14
support+ rental income) to support her household. Mr. Price would have around $6,386.77.
15
The second worksheet, submitted as Exhibit D, shows the Petitioner's rental income but
16
17 does not impute per the median net table. The income differential is $8,596.67 and Mr. Price
18 should pay $4,298.38 in maintenance. His transfer payment for support would then be $1330.80.
19
The Petitioner would have a total of $7,557.38 to support her household each month. Mr. Price
20
would have around $5,000 per month after paying the health insurance premiums for the
21
22
children. This is not an equitable result and would leave Mr. Price unable to support his
23 household as his rental costs are significantly higher than the $985.90 per month the mother is
24 paying for the mortgage and tax on the family home.

25
It is clear error that the court has ordered support in a level than exceeds Mr. Price's
26
entire net income. This divorce was only filed recently. Mr. Price did not intentionally reduce his
27
28

Page4 of7 V. FREITAS LAW, PLLC
544 291h Avenue
(206) 328-7362
work hours or desire to suffer from a severe health condition to lower maintenance or child
2
support. The parties are left with the reality of Mr. Price earning $14,000 per month. Mr. Price
3
suggests the court equalize the parties with a $6,000 per month payment in undifferentiated
4
family support to the mother and allowing her to retain 100% of the income from the rental
5
6 properties. This raises the mother's total income to $7929 per month gross and lowers Mr.
7 Price's gross income to approximately $8,000 per month. Mr. Price will additionally cover 100%
8
of the cost of medical insurance premiums for the children. All other costs for the children,
9
including uninsured medical expenses, necessary education expenses and extracurricular
10
11
activities should be split 50/50.
12 IfMr. Price's request for a transfer of $6,000 is granted, he would agree that any bonuses
13
received or commissions that exceed an income of $14,000 per month should be placed in trust
14
at one of counsel's offices. Those funds may be disbursed by agreement of the parties or by
15
further court order. Mr. Price cannot agree to this provision if the support transfer is not lowered
16
17 to $6,000 because he would need any additional bonuses or commissions just to meet his
18 obligation to the mother as it already exceeds his net income.

19
PAYMENT OF INSURANCE PREMIUMS
20
Having equalized the parties, the Petitioner should be responsible for all of her expenses
21
including her auto insurance premium of $123 per month and her share of her own medical
22
23 insurance premiums which is $297.02 per month.
24
25
IV.Evidence Submitted
26 All records and files herein submitted to the court for the Motion on Temporary Orders
27 on November 21 5\ 2017.
28

544 291h Avenue
(206) 328-7362
No other evidence may be submitted as pursuant to LCR 7(b)(8)(B)(iii): "All motions fo
2
revision of a Commissioner's order shall be based on the written materials and evidenc
3
submitted to the Commissioner, including documents and pleadings in the court file.
4
Pursuant to LCR 7(b)(8)(B)(iii), ''the moving party shall provide the assigned Court ... a
5
6 copy of the electronic record, ifthe motion before the Commissioner was recorded."A copy of
7 the CD of the hearing will be provided to the court with the working papers.
8
9
V. Legal Authority
10
11
This Motion is based upon RCW 26.09, RCW 26.09.060(6), RCW 2.24.050. LFLR
12 5(c)(4)(G), and LR 7(b)(5).

13
The Court shall review the case de nova and revise any decisions within its judgment and
14
discretion.
15
16 A "hearing de novo" is defined as "trying matter anew the same as if it had not been
17 heard before and as if no decision had been previously rendered." Black's Law Dictionary,
18
Sixth Ed., West Publishing Co., 1990.
19
20 Under RCW 2.24.050, a party may request a revision of a superior court commissioner's
21 order "upon demand made by written motion, filed with the clerk of the superior court,
22
within ten days after ... entry." LCR 7(b)(8)(A) and (B) require certain timing (10-6-21),
23
such as the "motion ... shall be served and filed within 10 days of entry of the written
24
order. .. ," any set hearing must be at least with "six days notice of the time, date and place of
25
26 the hearing on the motion for revision," and "a hearing on a motion for revision ... shall be
27
28

544 29th Avenue
(206) 328-7362
scheduled within 21 days of entry of the commissioner's order." LCR 7(b)(8)(A) and (B)
2
(emphasis added).
3
When considering a commissioner's ruling on revision, the superior court reviews the
4
5
commissioner's findings of fact and conclusions of law de nova on the record. State v.
6 Ramer, 151Wn.2d106, 113, 86 P.3d 132 (2004); RCW 2.24.050. It also applies the de nova
7 standard and does not apply any deference to the commissioner's reasoning, findings,
8
rulings, or eventual orders. The revision court has full jurisdiction over the case and is
9
authorized to determine its own facts based on the record before the court. In re Marriage of
10
11 Dodd, 120 Wn.App. 638, 644, 86 P.3d 801 (2004).
12
13
VI. Conclusion
14
For the foregoing reasons, Mr. Price is requesting that this court revise Commissioner
15
Brudvik's Order dated November 21, 2017.
16
17 Respectfully submitted on this 30th day of November 2017,
18
19
20
21
22
23
24
25
26
27
28

544 29th Avenue
(206) 328-7362
EXHIBIT A

I
2
FILED
NOV 2 t 2017
3 SONYA KRAS.Kl
COUNTY CLERK
5 IN THE SUPERIOR COURT OF THE S.JAIJLQF :WA.SHINGTDN ___ ~-----· --- ---
- - - - - -------------IN AND FOR THECOUNTY OF SNOHOMISH
6
In re the M~age of: Case No.: 17-3-02497-31
7
8
Petitioner,
9
and
10
CHARLES A. PRICE~ JR.,
11
Respondent.
12

15 DNo moneyjudgment is ordered.
17
I Judgment for D~btor's name I Creditor's____!Amount l Interes
i
(person w~~ must ! name (per.b'Son
' ' !
J J
I
j!
1
pay money/ _ _, wh~ mu.st e I
11
18 ..
-.·_·_·- ~- -_ _ -I-~-~~-
1•
/. La\V)'er's fee_s__
- _ _ _ __
·. . -·.--·iE.azd,). .· l
~--p,,-~-.r~---~e...~~JS:,.~ao_j_~----~
19 1
1Ot -~~------ . --·-··--·L--.-~?-1-~--_._:_·--~---~~~~
20
21
lfliiiL:_
'. ..¥
ea.!ft Interest Rate:
l
_o 1~% unless otherwise listed) ·-··-·------·-
_I ---·--~---J~~-_J
$
~
j]:._~!_VYer (nameh ---·-··· ________ representU.1?_ame2_:__,__ ,_ __.______ _i
22. l_!:a~! (nam!!)__~-.,-.___,____ ·--'- . represents (nal!l.!!l.~---·--- --~--J
23 ,t vvli BREWE LAYMAN P.S.

wneys at law
l~}~~{l. kiox488
fr~ Washington 98206-0488 ___._ _
24 ·~\:::::? (425)°252-5167 Phone
l'iGMfiflRARY FAMILY LAW ORDER - 1 (425 252-9055 Fax
www.brewelaw.com
I 2. Findings
5
(I'hefederal Servicemembers Civ!l Relief1:ct covers: ________ ·- ____________ . _ _
------- ---------.-----Army, Navy, 71.ir Force, Marine Corps, and Coast Guard members on active duty,'
6
row; and
7
8
10
~ The Court Orders
11
4. Care of children
12
13
14
15
state.
18
21
22

Attorneys at Law
P.O. Box488
24 (425j 252-5167 Phone
mM:f;QRARY FAMILY LAW ORDER~ 2 (425 252-9055 Fax
www.brewelaw.com
I 5. Pro\'ide support
2 The eol:lrt signed the temporary Child Support O,·~t· and W4:Jrk£heets filed sepm:ately.
l.M'l.A1~""'-~A
3 The Respondent must pay~nsal support to his spouse.
_J.l t>C.
11,_,0/),D - .
Amount: $ _ _ per month. 'b.! £:~ _;:1 ) 2° I J
::t;ti
4 .
Jii2': ·; , . : I ' ;Ce t? i/ I -k.... '
5 --- -··-- ... -- .
Datel st PC!Y1ll~~1 _is dl!t! _ _ ,__ Qay_ qfthe _mon_th_e.a~h_p_aym_entis_ due . ?- _Ai.. ·- ___ -- _- -; --
1/ 2 ~ 3 fl_ .
Jkthe other spouse/domestic partner. ~~/JS/ f ~
7 [] Washington State Child Support Registry (available if..c · ~ort is
8 {)Vt--{~ :{5V\.lc
6. Family home -
w 1,....-f ~ 1. ..... ·f)
VI,,./) t-G ~
i
lllLC..-"-<.I
9
Stay in the home - The Petitioner may stay in the family homfud r~ii-us~he
h£<-_y VV'l.J-V€.>f K-+-
11
.i
18 vehicle/s: 2012 Audi Q5.
20
8. Protect property
21
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
-mMfQ.RARY FAMILY LAW ORDER~ 3 (425) 252-9055 Fax
www.brewelaw.com
1
3 consent.
5 to pay for basic needs. Both spouses/domestic partners mu_s_! I1Qti_fy_!h~_~ther a~oii.t__.
... -· -·. ··- ·-- ··---·--····----·
-an_y: expense-Sthafare-61.it of the-ordinary~ ·- -- -- - -- -- ·-- ·-·
6
accounts.
12
of life.
15
18
20
BREW E LAYMAN P. s.
P.O. Box488
(425j 252-5167 Phone
l~~;QRARY FAMILY LAW ORDER - 4 (425 252-9055 Fax
www.brewelaw.com
1
3
9. Household expenses ~,,,
....~~?{
' ., J -:i
,,,_
I l / 11
4
5
10
11 r_ specific designati9ns set forth_ above. ·-r, }1-h)·,.A.P. .l f si--vill ..A-t...~VLc:ve- i-v........ '-
f>~ rs O\JVL \2..e.~ , .....~~ (-'Ve......_ • \2d+t> ~.-c:..;_-f- 'G ~el..Ll. c:. 00~<---k.. -te ..,,._.~~:
12 10. Divide debts .e:ir.-.......,t p~ 11'\-t..t...""'~""'"-'- · ''P.t..---ti-l-1,-v'-"-tll.- ~ ~ p~+
A'bl \ NL-ttl,' IC, b\/'l..1..-f--N ~·
13 The Petitioner and Respondent must: _,- c ,. \ .D
c.~ _ .c,~ ...-.....t • , ~ ........~~r
.J ~n • c:~~-
LV \~ ..f--t.."'-.....Y·
15
16 f - --------
~~_ebt (descriq_ej_____,_______ _ _ --~=~-~~=~Iivho should pay -----------···
17 L1. Julie Lang_abeer _____________ _! Pet!_!~o_n_e_r_ __
19
liable.
21
23 I
BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
l'~Mf;QRARY FAMILY LAW ORDER - 5 (425) 252-9055 Fax
www.brewelaw.com
1
2
5 J~ay premiums ~s follows:
[_POI~~-~:~==-====-=~~~~~:==~=~
II Who pays--~~==-==~-=~=
6
I 1. Medical --------··--·- Responde~!________________
7 [_2. Q~~ta1~- _______________ 1Respgp.d~nt
_____________ _
i 3. Q_p!~~al . ·-·-----·-·---·-- l Respondent_____________ _
8 j 4. Orthodontia ___________________ LRespondeJ.!L______________ _
[?.Aut~~~}J~--=~--- ------·---·-·--·--·------_J Responden!__ _____________ _
9
IO
. [] Request r e s -
c:; t
c-0
{)£)(:)-
I
I? _J
l
/~o }l
11
·g:., The Respondent must pay the other party's lawyer fees. Amount: $ . Make
12 payments to _ _(11r:mie) by _ _ (date).
~-.r~e- ~~ '>
Money Judgment
--r.s.
13
14 {] Tue :ameHflt's listed abo•1e must be paid, bttt the court is not enterffig a i;1wney_
judgment at this rune.
15
'fJ.-Thc amollllt/s listed above shall be entered as a money judgment. (Summarize
the money judgment in section 1 above). The interest rate is 12% 1.illless anGther
16
amount is listed here [] Tho interest rate is % because ~t /
17 [] Other: T VL.fl-.
\.I_./
. ~······
20 No request made.

22
23 I BR EWE LAYMAN P.S.

Attorneys at Law
P.O. Box488
24 (425} 252-5167 Phone
~Mf:Q.RARY FAMILY LAW ORDER - 6 (425) 252-9055 Fax
www.brewelaw.com
2

s . 0~~~;""~~;:,::~d. -lo QAJ.Lf .. ~. ,,..~,'c'.,,.,,, .« ~ ,,,~.;,,.,,
6
DONE IN OPEN COURT this'4 ~y of November, 2017. t1~.
7

11

Attorneys at Law
13
14

~
19~Pri~
18
Cha.des A. Price, Jr,./

Petitioner "
Respondent
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
l'~M\1;QRARY FAMILY LAW ORDER - 7 !425) 252-5167 Phone

425) 252-9055 Fax
www.brewelaw.com
EXHIBITB

I
1. PAYMENTS BASED ON A TERM OF A TRANSACTION.
ii. i. Except as provided in paragraph (d)(1)(iii) or (iv) of this section, in connection vd.th
a consumer credit transaction secured by a dwelling, no loan originator shall receive and
no person shall pay to a loan originator, directly or indirectly, compensation in an
amount that is based on a term of a transaction, the terms of multiple transactions by
an individual loan originator, or the terms of multiple transactions by
multiple individual loan originators. If a loan originator's compensation is based in
whole or in part on a factor that is a proxy for a term of a transaction, the loan
originator's compensation is based on a term of a transaction. A factor that is not itself a
term of a transaction is a proxy for a term of the transaction if the factor consistently
varies with that term over a significant number of transactions, and the loan
originator has the ability, directly or indirectly, to add, drop, or change the factor in
originating the transaction.
m. Ii. Single of multiple transactions.
The prohibition on payment and receipt of compensation under
§ 1026.36(d)(1)(i) encompasses compensation that directly or indirectly is based on the
terms of a single transaction of a single individual loan originator, the terms of multiple
transactions by that single individual loan originator, or the terms of multiple
transactions by multiple individual loan originators. Compensation to an individual loan
originator that is based upon profits determined with reference to a mortgage-related
business is considered compensation that is based on the terms of multiple transactions
by multiple individual loan originators. For clarification about the exceptions permitting
compensation based upon profits determined with reference to mortgage-related
business pursuant to either a designated tax-advantaged plan or a non-deferred profits-
based compensation plan, see comment 36(d)(1)-3. For clarification about "mortgage-
related business," see comments 36(d)(1)-3.v.B and-3.v.E.
A. A. Assume that a creditor pays a bonus to an individual loan originator out of a bonus
pool established with reference to the creditor's profits and the profits are determined
with reference to the creditor's revenue from origination of closed-end consumer
credit transactions secured by a dwelling. In such instance, the bonus is considered
compensation that is based on the terms of multiple transactions by multiple individual
loan originators. Therefore, the bonus is prohibited under§ 1026.36(d)(1)(i), unless it is
otherwise permitted under§ 1026.36(d)(1)Civ).
B. B. Assume that an individual loan originator's employment contract with

a creditor guarantees a quarterly bonus in a specified amount conditioned upon
the individual loan originator meeting certain performance benchmarks (e.g., volume of
originations monthly). A bonus paid following the satisfaction of those contractual
conditions is not directly or indirectly based on the terms of a transaction by
an individual loan originator, the terms of multiple transactions by that individual loan
originator, or the terms of multiple transactions by multiple individual loan
originators under§ 1026.36(d)(1)(i) as clarified by this comment 36(d)(1)-i.ii, because
the creditor is obligated to pay the bonus, in the specified amount, regardless of the
terms of transactions of the individual loan originator or multiple individual loan
originators and the effect of those terms of multiple transactions on the creditor's
profits. Because this type of bonus is not directly or indirectly based on the terms of
multiple transactions by multiple individual loan originators, as described in
§ 1026.36(d)(1)(i) (as clarified by this comment 36(d)(1)-1.ii), it is not subject to the 10-
percent total compensation limit described in§ 1026.36(d)(1)(iv)(B)(1).
iv. iii. An individual loan originator may receive, and a person may pay to an individual
loan originator, compensation in the form of a contribution to a defined contribution
plan that is a designated tax-advantaged plan or a benefit under a defined benefit plan
that is a designated tax-advantaged plan. In the case of a contribution to a defined
contribution plan, the contribution shall not be directly or indirectly based on the terms
of that individual loan originator's transactions. As used in this paragraph (d)(1)(iii),
"designated tax-advantaged plan" means any plan that meets the requirements of
Internal Revenue Code section 401(a), 26 U.S.C. 401(a); employee annuity plan
described in Internal Revenue Code section 403(a), 26 U.S.C. 403(a); simple retirement
account, as defined in Internal Revenue Code section 408(p), 26 U.S.C. 408(p);
simplified employee pension described in Internal Revenue Code section 408(k), 26
U.S.C. 408(k); annuity contract described in Internal Revenue Code section 403(b), 26
U.S.C. 403(b); or eligible deferred compensation plan, as defined in Internal Revenue
Code section 457(b), 26 U.S.C. 457(b).
v. iv. An individual loan originator may receive, and a person may pay to an individual
loan originator, compensation under a non-deferred profits-based compensation plan
(i.e., any arrangement for the payment of non-deferred compensation that is
determined with reference to the profits of the person from mortgage-related business),
provided that:
A. A. The compensation paid to an individual loan originator pursuant to this

paragraph (d)(1)(iv) is not directly or indirectly based on the terms of that individual
loan originator's transactions that are subject to this paragraph@; and
B. B. At least one of.the following conditions is satisfied:
1. 1. The compensation paid to an individual loan originator pursuant to this

paragraph (d)(1)(iv) does not, in the aggregate, exceed 10 percent of the individual loan
originator's total compensation corresponding to the time period for which the
compensation under the non-deferred profits-based compensation plan is paid; or
2. 2. The individual loan originator was a loan originator for ten or fewer transactions
subject to this paragraph @consummated during the 12-month period preceding the
date of the compensation determination.
EXHIBIT C

I
[X] Proposed by [X] Charles Price [ ] State of WA [ ] Other (CSWP)
Parents' Names: Charles A. Price, Jr. (Column 1) Sally Jo Price (Column 2)
Charles Sally Jo
a. Waqes and Salaries Imputed for Sallv Jo $14016.78 -
. e. Other Income - -
f. Imputed Income
a.Total Gross Monthly Income (add lines 1a throuqh 1f)
-
$14016.78
$2,693.00
$7,677.78
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes $860.44 $478.71
Q. Maintenance Paid $3,054.89 -
- -
{add lines 2a through 2h} $5,928.93 $890.80
3. Monthly Net Income (line 1Q minus 2i) $8,087.85 $6,786.98
(add both oarents' monthlv net incomes from line 3) ...• ;/.
5. Basic Child Support Obligation (Combined amounts ---+)
Alex Price $1206.00
Colby Price $975.00 $3,156.00
-
- .
Charles Sally Jo

b. Is Monthly Net Income Less Than Self-Sui;mort Reserve? If yes,
for that parent enter the presumptive $50 per child.
c. Is Monthly Net Income egual to or more than Self-Sui;mort
- -
amount or the presumptive $50 per child, whichever is greater. - -
a.Monthly Health Insurance Premiums Paid for Child(ren) $891.00 -
c. Total Monthly Health Care Expenses (line 1Oa plus line 1Ob) $891.00 -
I~~,~~ :1,i~~'
(add both parent's totals from line 1Oc} $891.00
11 . Dav Care and Special Expenses
- -
- -
- -
- -
- -
i
-
=
both parents' day care and special expenses from line 11 e}
plus line 12) ' $891.00 ..

Charles Sally Jo

- -
- -
- -
d.Total Support Credits (add lines 16a throuqh 16c) $891.00 -
whichever is qreater) $1,310.56 $1,845.44
a. Real Estate - -
b. Investments - -
- -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f.
- -
Name - -
Name - -
Name - -
Name - -
Charles Sally Jo
Name - -
Name - -
Name - -
Name - -
f. Income From Assistance Proqrams
Program - -
Proqram - -
Q.Other Income (describe)
- -
- -
- -
- -
24. Child Support Owed, Monthly, for Bioloqical or Leoal Child(ren)
Name/age: Paid f l Yes f l No - -
Name/aqe: Paid fl Yes fl No
25. Other Child{ren) Living In Each Household
- -

Signature and Dates

Date City Date City
WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 5 of 5 SupportCalc® 2017

c: .. \state templates\waworksheet.dtf y:\family soft\price, c\price, c.scp 11 /29/2017 11 :19 am
EXHIBITD

I
Charles Sally Jo
a. Waqes and Salaries $14016.78 $1,929.89
c. Business Income - -
e.Other Income - -
f. lmouted Income - -
q. Total Gross Monthly Income (add lines 1a throuqh 1f) $14016.78 $6,228.27
b. FICA (Soc.Sec. +Medicare)/Self-Employment Taxes $860.44 $147.63
d.Mandatory Union/Professional Dues - -
f. Voluntarv Retirement Contributions $416.67 -
q. Maintenance Paid $4,298.38 -
- -
5. Basic Child Support Obligation (Combined amounts~)
Alex Price $1206.00
Colby Price $975.00 $3,156.00 ,_.

-
-
parent)
Charles Sally Jo

parent enter the presumptive $50 per child.
b. Is Monthly: Net Income Less Than Self-SuQQOrt Reserve? If yes,
- -
c. Is Monthly: Net Income egual to or more than Self-SuQQOrt
amount or the presumptive $50 per child, whichever is greater.
- -
from line 7, 8a - 8c, but not less than the presumptive $50 per child. $1,732.64 $1,423.36
b.Uninsured Monthly Health Care Expenses Paid for Child(ren) - -
(add both parent's totals from line 1Oc) $891.00
11 . Day Care and Special Expenses
- -
- -
- -
- -
a.Total Day Care and Special Expenses
(Add lines 11 a throuqh 11 d)
- -
both parents' day care and special expenses from line 11 e) -
plus line 12) $891.00

Charles Sally Jo

b. Day Care and Special Expenses Credit
- -
- -
-- -
-
d.Total Support Credits (add lines 16a through 16c) $891.00 -
a. Real Estate - -
b. Investments - -
- -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f. - -
Name - -
Name - -
Name - -
Name - -
Charles Sally Jo
Name - -
Name - -
Name - -
Name
- -
Proqram - -
ProQram
- -
- -
23. Non-RecurrinQ Income (describe)
- -
- -
- -
24. Child Support Owed, Monthly, for BioloQical or LeQal Child(ren)
Name/age: Paid [ ] Yes [ ] No
Paid r l Yes r l No
- -
Name/aQe: - -
Name/aQe: Paid r1Yes r l No - -

Signature and Dates

Date City Date City

c: .. \state templates\waworksheet.dtf y:\family soft\price, c\price, c.scp 11129/2017 11 :18 am
17-3-02497-31
NTC 38
Note for Calendar
2186160
FILED
111m1111111m1111m11mm ~ 2011 DEC - I PH 12: 0 I

County of Snohomish
SALLY JO PRICE Case No. 17-3-02497-31
CALENDAR NOTE: (NTC)
Plaintiff/Petitioner( s)
vs. CIVIL MOTIONS - JUDGES' CALENDARS
Unless otherwise provided by applicable rule or statute, this
form and the motion must be filed with the Clerk not later than
CHARLES A. PRICE, JR. five (5) court days preceding the date requested.
Defendant/Respondent(s)
**SEE "WHERE TO NOTE VARIOUS MATTERS" ON PAGE 2, TO DETERMINE WHAT MOTIONS ARE TO
BE SET BEFORE THE CML MOTIONS JUDGE VERSUS THE CML MOTIONS COMMISSIONER VERSUS THE
PRESIDING JUDGE.
TO: The Clerk of Court:

A. PRESIDING JUDGE'S CALENDAR Date Requested (mm/dd/yyyy):
NatureofHearing: ------------~
Monday- Friday@ 9:00 a.m.
Department as assigned **Confirm court hearing by noon two (2) court days prior to the
requested date by calling (425) 388-3587
B. JUDGE'S CIVIL MOTIONS CALENDAR Date Requested (mm/dd/yyyy): 12/12117

Nature of Hearing: REVISION OF
Tuesday through Friday @ 9:30 a.m. COMMISSIONER'S ORDER
Department as assigned
**Confirm court hearing by noon two (2) court days prior to the
requested date by calling (425) 388-3587
C. JUDGE'S PERSONAL CALENDAR Date Requested (mm/dd/yyyy): _ _ _ _ _ _ _ __

(Special set hearings to be heard by a specific Judge) Judge: _ _ _ _ _ _ _ Dept: _ _ _ _ _ _ _ __
Hearing date and time must be scheduled through the Natureofhearing: _ _ _ _ _ _ _ _ _ _ _ _ __
Judge's law clerk
**Confirm court hearing by noon two (2) court days prior to the
Judge's calendar/contact information can be found at: requested date by calling the Judge's law clerk
http://www.snohomishcountvwa.gov/DocumentCenter/Ho
meNiew/7657
NOTE: DO NOT schedule your hearing for a court holiday. Please check with the Clerk if you are uncertain when
court holidays occur. This calendar note must be filed with the Clerk not later than five (5) court days preceding the
hearing date requested.
Y:\Price, Charles Jr\Pleadings\Ours\Revision\Hearing Note Civil Judges.Doc 11/30/2017

Page 1of3
WARNING CONFIRMATION REQUIRED:
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) court days prior to the hearing BEFORE 12:00
noon.
Any hearings such as adoptions, reasonableness hearings and minor settlements which are specially set in front of a
specific Judge on the Judge's Personal Calendar must be confirmed two (2) court days in advance through the Judge's
law clerk. For more information on the Judge's schedules, you may call Court Administration at 425-388-3421 or
information can be found on the internet at: http://www.snohomishcountywa.11:ov/DocumentCenter/HomeNiew/7657
Failure to notify the Court of a continuance or strike of a confirmed matter may result in sanctions and/or terms. SCLCR
7(b)(2)(H).
TIBS FORM CANNOT BE USED FOR TRIAL SETTINGS. SC R2.l AND SCLCR40(b).
CERTIFICATE OF SERVICE BY MAIL:
I hereby certify that a copy of this document
and all documents listed on page 3 have been mailed to (Signature)
the attorneys/parties listed on page 3, postage prepaid Kirstyn Palmisano
on the:
(Printed name)
41386
Date (mm/dd/yyyy): 12/1/17
~~~~~~~~~~~
WSBA#
senger. Affidavit of service to be

Attorney for: (CHECK ONE)
D Petitioner/Plaintiff [gl Respondent/Defendant
D Pro Se
(Printed name)

COMMISSIONER CIVIL 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 CALENDAR:
The following motions are heard on Presiding Judge's Calendar: trial continuance, pre-assignment, expedited trial
date, jury trial (untimely demand), motion to waive mediation requirement.
RALJ HEARINGS
RALJ hearings are noted on the Wednesday morning criminal hearings calendar@ 10:30 a.m. in room C304.
**All other civil motions are heard on the Judge's Civil Motions Calendar**
EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Court Commissioner, not
by a party or by counsel.

Snohomish County Snohomish County
Superior Court Clerk's Office Superior Court
3000 Rockefeller Ave M/S 605 3000 Rockefeller Ave
Everett, WA 98201 Everett, WA 98201
Please print the names, addresses etc. of all other attorneys in this case and/or all other parties requiring notice.
Y:\Price, Charles Jr\Pleadings\Ours\Revision\Hearing Note Civil Judges.Doc 11/30/2017

Page 2 of 3
__ ,,.:. ..
Sabrina Layman 25260

Name: WSBA#:
PO Box 488 Everett, WA 98206 425-252-9055
~ Petitioner/Plaintiff D Respondent/Defendant
D Pro Se
Name: WSBA#:
D Petitioner/Plaintiff D Respondent/Defendant
D Pro Se
Name: WSBA#:
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
List all documents mailed: Note, Motion with Exhibits A - D, Proposed Order on Revision, all prior
pleadings
Y:\Price, Charles Jr\Pleadings\Ours\Revision\Hearing Note Civil Judges.Doc I 1130/2017

Page 3 of 3
' ,,
....
.. \
t=\\._ED
'
I.
2 17-3-02497-31
STP 39
Stipulation
3 2205785
·-·-·------.L. ·-- Ill I111111111111111111111111111111111111

5
7.
8
Supedor Coqrt ofWashingtop
County of Snohomish ·
In.re: .
II
SALLY
.. . JO
..
. PRICE
., .·. . .... , ' .), .No. 17-3-02497-31
Petitioner,
and STIPULATION REGARDING
SERVICE BY EMA.IL
13: CHARLES A. PRICE, JR..
14
Res ondent
1.5 The patties to the !ibove~ca,ptioP.ed.. action;. through the undersigp,eg cognsel ofrecord, stipulate
i;inq agree asJollows:
16
17 A. Counsel for both.parties agree to acc.ept service of all future papers wia_pleadjngs, e~cept
original process,via emall to the following addr-esses: . _ . . ... · _ ~ ·. . · d-ivi:<\.,.:t-cl
L-,r~ .e.*..t21't- V"l~'f'4'A-">e.S fv· clt SC OY'"'~Lf LUIL s~ c~ '11.A. ~.J_\k:tYI((!. l
1) Pka.dings shall,be deemed. ~erved by email to V. Freitas Law, PLLC when sent to the
19 · following:: · c..
20 Veronica Freitas: Veronica@vfreitaslaw.con1,
Kirstyn Palmisano: Kirstyn@vfreitasla.w:com
21 Amy Pasco: Amy@vrreitasla,w.cpm,
Stevie Craig: Stevie@vfreitaslaw;com
22
23 2) Pleadings shall be deemed served by email to Bre.We Layman, when sent tp the
following addresses: ~
24
...·: Sabrinal@br.ewelaw.coi;n. A.·NO c:·.:.
Sabriria.Laytn·an.
\Lt{f\tmS,,t;>r.ew-e lttw. ())VY1 ·. ·
25
3) Letters to 'be delivered via email only unless otherwise requested.
26
4) Documents are deemed served atthe time ofsending if sentto.all ofthe foregoing
27 email addresses. between the hours of 9 a.:rn.. ctnd 5 p:m, during ~ no1111aJ. business day .
.28
VE~O~I(:A F.RE;IT AS
STIPULATION REGARDING SERVICE BY EMAIL v; FR:EITAS LAW, PLLC.
S44 29th Ave
Page I of2 w
.Seattle, A. 9St22
. (206)..328.7362
v@vfreita.sl~w.eom
,. ' .• -.
If the document is sent before business hours on a business day, it shall be deemed
2
received as of 9 a.m. on the same day. If the document is sent after S p.m. on a
business day, it shall be deemed received at 9 a.m. on the next business day. A
3 document which is received on a weekend or holiday day shall be deemed received at
9 a.m. on the next business day .
...... 4.
5
5) Documents not sent in a readable format will not be deemed accepted.
6 6) If documents are sent by email and the sender receives a return message that the
user's mailbox is full or that delivery has failed, the server shall immediately contact
7
the receiving party and either arrange for alternate service or timely send the
8 documents at such time as the user's mailbox is accepting email so that the receiving
party actually receives the documents. In the event that a document is successfully
9 received by one of the identified email addresses for a party's attorney but some or all
of the other email address(es) do not receive the document due to technical problems,
10
the receiving attorney at his/her option may choose to waive the need to retransmit to
11 the remaining email address on a case by case basis but is not required to do so.
12 7) If the receiving party receives a document that is illegible, the receiving party shall
contact the sending party, and the sending party shall arrange to email or messenger
13
legible replacement pages.
14
B. The terms of this stipulation may be modified only in writing signed by counsel for
15 Petitioner and counsel for Respondent but the terms of stipulation may be fully
terminated by either party upon ~ea ' ritten notice.
16
\ LI
17 SO STIPULATED BY:
18
19
rina Layman, WSBA #25260 Veronica Freitas, WSBA # 19405
20 Attorney for Petitioner Attorney for Respondent
21
22
23
24
25
26
27
28
VERONICA FREITAS
STIPULATION REGARDING SERVICE BY EMAIL V. FREITAS LAW, PLLC.
544 29th Ave
Page 2 of2 Seattle, WA 98122
(206) 328-7362
v@vfreitaslaw.com
17-3-02497-31
RSP 40
Response
2228643
1 11 /Wllll/llllfllflllllll
2

6
7
SALLY JO PRICE, RESPONSE TO MOTION FOR REVISION
8
Petitioner,
9
and
10
11
Respondent.
12
13 COMES NOW Petitioner, by and through counsel undersigned and responds to Motion for
14 Revision filed by Respondent.
15
1. The parties have agreed on a modification to the parenting plan as follows:
16
Paragraph 9 of the Temporary Parenting Plan shall be modified to say -
17
"Each parent shall have 14 days of vacation time which can be taken consecutively or in parts with
18 the children each summer. If traveling out of state, the traveling parent shall provide information
about locations of travel and remain available via cell phone. If traveling out of country, both
19 parents must agree in advance to the travel outside of the US and shall provide detailed itinerary"
The balance of the paragraph shall remain intact.

20
21
2. The remaining provisions of the court's Temporary Orders should remain in full
22
force without modification. The information and facts that were presented to the court at the time
BREWE LAYMAN P.S.
23 I
Attorneys at Law
24
0R 1G'NAL . .
P.O. Box488
(425j 252-5167 Phone
~oo_~SE TO MOTION FOR REVISION - 1 (425 252-9055 Fax
www.brewelaw.com
1 of the hearing support the orders, the court considered the length of the marriage, the historic
2 earnings, the ownership of the company and continued commissions/earnings AFTER Mr. Price
3 reduced his work hours in addition to the base salary, as well as the parties financial declarations.
4 3. There is no information in the record that Mr. Price only owns 2% of the company;
5 however, the record does contain substantial proof of his historic earnings as well as his year to
6 date earnings, during a year where he both had medical issues as well as separated from his Wife.
7 4. Mr. Price only submitted one paystub from October for the range of October 16-
8 31st. He submitted no other information to contradict the financial materials submitted by Ms.
9 Price. The 2016 Federal Tax Return filed by Ms. Price outlines their 2016 earnings of $648,061.00
10 which are the W-2 earnings that Mr. Price discusses in his reference to the commission and
11 earnings. In ADDITION, Mr. Price received $26,000.00 from Leader One Financial and
12 $23,205.00 on a K-1. And the rental properties that Mr. Price alleges generate "$2,037 in
13 additional income" are a loss each year. Even when you add back in the minimal depreciation
14 listed on Schedule E, the rental do not generate income. Ms. Price estimates that they are positive
15 in the amount of $871 per month if they are fully leased and there are no maintenance or repairs.
16 The Federal Tax returns support that. Mr. Price did not provide any "proof' of rental income - he
17 provided self-created tables and amortizations run by his company.
18 5. Mr. Price's own Financial Declaration contradicts his statements of lower earnings.
19 Knowing that this matter was pending (after being served with the Petition and Motion), Mr. Price
20 relocated to a rental home which has a monthly expense of $2,325.00 per month. He included the
21 health insurance premiums in his Financial Declaration as well as personal expenses which he
22 must have believed he could pay. He states to the court that he has monthly expenses of $9,275.01.
BREWE LAYMAN P.S.
P.O. Box488
24 (425j 252-5167 Phone
~rag~SE TO MOTION FOR REVISION - 2 (425 252-9055 Fax
www.brewelaw.com
1 Knowing that his Wife and children were remaining in the family home and are at this point 100%
2 financially dependent on him, Mr. Price must have felt confident enough in his historic earnings to
3 undertake expenses of nearly $10,000.00 per month prior to a hearing where Ms. Price was seeking
4 financial support of $15,000.00 per month. Frankly, he knows he has the financial capacity to
5 support both households at that level even with his reduced work hours.
6 6. The day after the hearing (11/22/17), he received a deposit from Leader One in the
7 amount of $10,479.50. That's not his regular pay period (he's paid twice a month on the 15th and
8 30th), so he clearly has more control that he alleges over the income that he receives. The deposit
9 accidentally went into the joint account and was pulled back out. See Ex A.
10 7. Ms. Price last worked EIGHT years ago as a part time substitute teacher in 2009.
11 She stopped work to care for the parties children who were 3 and 6 at that time. The parties have
12 since had another child who is now 5 years old. We did in fact use an imputed income amount to
13 calculate child support, but imputed income does not actually pay for groceries or mortgages. And,
14 in high earning cases, like this case, standard of living and monthly expenses well outweigh the
15 concept of imputed income.
16 8. Mr. Price has control over his income and clearly can direct additional funds into
17 his pocket when necessary. The calculation of income that was used was an averaging of earnings
18 and it also took into consideration the continued large sums of money that were earned by Mr.
19 Price well after his April hospitalization.
20 9. The court should deny the motion for revision.
21
22
23 I BREWE LAYMAN
Attorneys at Law
P.O. Box488
P.S.

24 (42Sj 252-5167 Phone
~rrQ_~SE TO MOTION FOR REVISION - 3 (425 252-9055 Fax
www.brewelaw.com
1 Dated this~ day of December, 2017.
2 BREWE LAYMAN P.S.

Attorneys at L
3
By~:,__~~~~~~~~~
4 abrina A. Layman, WSBA 25260
5
10
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12
13
14
15
16
17
18
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20
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22
BREWE LAYMAN P.S.
P.O. Box488
24 (425! 252-5167 Phone
~~~SE TO MOTION FOR REVISION - 4 (425 252-9055 Fax
www.brewelaw.com
EXHIBIT_A
r - - - - - - - - - - - - - - - - - - - - - - --
Filter/Sort _
NEWEST FIRST, LAST 30 'DAYS
.. <> . ,
SERVICE CHARGE W/ • $8.01

29 ONLINE STATEMENT s19.s
NOV DIRECT DEPOSIT $1-01

2 DISCOUNT $27,9'
Leader One, Finan ACH -$479.3:

Collec PPD ***********4374 $26·9
: Nov Leader One Finan ACH

Collec PPD ***********3407
Leader One Finan Payroll $10,479~ 3l

PPD ***********3017 0,506· 3
NOV CLUB SYSTEMS DUES PPD

2
17-3-02497-31
r=1L.ED
RPY
Reply
42
2,011 DEC I _I AH II: 55
2
2~35~09
~~ONYA t'\l~ASKI
3 cornnY CLERK
Il flllllllllllllllllllllllllllllllll Ill SNOHOMISH CO. WASH
4
7
9
In re:
10
11 Petitioner,
and Reply on Revision.
12
13 Res ondent.
14
15
Comes now, Charles A. Price, by and through his attorney of record, Veronica Freitas,
16
and submits this Reply to Petitioner's Response on Revision:
17
18 The W2 opposing counsel references for $17,002 is income from Mr. Price's role as
19 guarantor on a line of credit that he signed for the company. He was removed as guarantor in
20
March of 2016 and has received no income from that date forward. The year prior, tax records
21
show that he received $60,000 due to his role as guarantor. The 1099 showing $26,000 is for
22
Board of Director's compensation. This is given in stock, not dollars. That 1099 was for TWO
23
24 YEARS of payment. Mr. Price anticipates receiving $13,000 for his role on the board in 2017.
25 The parties retain this stock and will be able to divide it as part of the final decree but it is not
26
liquid income. If the court wants to count this as income, then Mr. Price should be allowed to
27
28

Page 1 of4 544 29th Avenue
(206) 328-7362
liquidate this year's stock award. The K-1 form shows income from Sound Pacific Holdings, a
2
real estate investment company which was sold last year. Opposing counsel is grossly
3
overestimating Mr. Price's income. Mr. Price has been operating on the same base-salary for at
4
5
least five years. Opposing counsel notes that there is no evidence of Mr. Price's 2% holdings.
6 Likewise, there is no evidence supporting her contention that Mr. Price dictates his pay and, in
7
fact, the law submitted in the revision motion show the opposite.
8
The rental income on tax returns show a loss due to all of the prior renovations on these
9
properties. At the hearing before the commissioner, a declaration as submitted from the
10
11 contractor, Keith King, stating that all renovations are finished. As such, there will no longer be
12 loss. The actual fixed expenses of maintaining these rentals was addressed in Mr. Price's original
13
declaration with a spreadsheet and was not challenged by opposing counsel. This is in fact the
14
spreadsheet used with Sally's mother, Julia Langabeer, and was akin to a contract. The numbers
15
on the amortization sheet are exact and accurate. Mr. Price is happy to take over the rentals and
16
17 the income produced by them and increase his payment to Mrs. Price to $7,000 per month. This
18 will reduce any uncertainty in Mrs. Price's budget. Mr. Price is not attempting to exaggerate this
19
income in hopes of somehow harming Mrs. Price.
20
In section 6 of the Response brief, opposing counsel attempts to introduce new evidence.
21
22
The $10,479 deposited in Mr. Price's account was due to his expense report. See Exhibit A. This
23 is not income. He is reimbursed for certain expenses according to contract. These covered four
24 months of expenses and included Mr. Price's cell phone, two business flights to Kansas, hotel
25
stays, meetings with realtors, and mileage. To reply to this new evidence, Mr. Price has
26
27
28

(206) 328-7362
submitted the expenses payments and his latest paystub which shows that he is in line to earn
2
under $200,000 this year.
3
Mr. Price has been left in a difficult position. He moved out of the family home and
4
rented at market-rate a three-bedroom home with space for him and his children. This family has
5
6 never "lived large" as Ms. Layman claims. The mother pays $1,000 per month to live in the
7 family home and about an additional $600 in utilities on that home. Their bank statements
8
submitted by opposing counsel do not show frivolous spending. This couple has invested in
9
paying down their mortgage (from $700,000 down to about $120,000), buying rental properties,
10
11 and in rebuilding a recreational vehicle. Mr. Price has already been ordered to pay the health
12 insurance and automobile premiums. With Mrs. Price's expenses, she will have no problem
13
living off $7,000 a month in guaranteed income.
14
Mr. Price is suggesting a revision order that leaves the parties in equitable positions and
15
does not base his income on prior figures that he has not attained in 2017 and will not attain in
16
17 2018 due to his reduction in work hours. Under our proposal, Mrs. Price will receive 50% of the
18 husband's earnings even if those earnings are higher than his estimated $14,000 per month. Any
19
deposits over $14,000 will be disclosed to opposing counsel and the funds split 50/50. If the
20
court does not significantly lower the amount of support, Mr. Price cannot afford to split any
21
additional income as he will need every dollar to cover his own bills.
22
23 Mr. Price is seven months out of a heart attack and surgery. He does not feel well and
24 cannot continue to work the hours he did prior to his health deteriorating. Mr. Price has
25
introduced year-to-date information on his income which shows that he is earning around
26
$14,000 per month. This is the figure the court should use when setting support amounts.
27
28

Page3of4 544 29th Avenue
(206) 328-7362
Respectfully submitted on this 11th day of December, 2017
2
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(206) 328-7362
EXHIBIT A

I
LeaderOne Financial Corporation Bank:ANB Holding Account Check Number:
Date Document No. Description Amount
11/21/2017 11052017 Expense Report 3,948.54

11/21/2017 08082017 Expense Report 921.29
11/21/2017 09162017 Expense Report 4,180.44
11/21/2017 11072017 Expense Report 1,429.11
. ;;
. ·.:·..'·<.;.:·\_:···. : _:·. ·. '
Paid To: Ch~rles Pri~e~ .· . ·

.··P~te:. Ng~~rnb~V~2. 2o 1
Ffl~ED
11:... 3-.:. 02497-31 ZD 17 DEC 12 PM 2: I O
l fim\1~ i"m1 1 1 1 1H J
I
I
SUPERIOR COURT OF
WASHINGTON
FOR SNOHOMISH COUNTY
CAUSE NO.:
~GNYA KRASI'\!
COUNTY CLERK
SNOHOMISH CO. WASH
17-3-02497-31
SALLY JO PRICE JUDGE: JOSEPH P. WILSON
(PETITIONER) REPORTER: NOT REPORTED
AND CLERK: MICHELLE STROHRMANN
CHARLES ALLEN PRICE JR. DATE: 12-12-2017 @ 9:30 AM
(RESPONDENT)
THIS MATTER CAME ON FOR: REVISION

ACTION:
PETITIONER APPEARED: YES . COUNSEL: SABRINA LAYMAN
RESPONDENT APPEARED: NO COUNSEL: KIRSTYN PALMISANO
DOCUMENTS FILED:
ORDERS ENTERED: ORDER ON REVISION
RESPONDENT'S MOTION FOR REVISION OF COMMISSIONER BRUDVIK'S ORDER OF
11-21-2017: GRANTED IN PART. THE COURT REDUCES UNDIFFERENTIATED FAMILY
SUPPORT DOWN TO $9,000 A MONTH. THE COURT WILL ALLOW DISCOVERY TO CONTINUE
WITHOUT PREJUDICE FOR REVIEW SHOULD EXCESSIVE INCOME BECOME AVAILABLE TO THE
RESPONDENT. PETITIONER SHALL RETAIN CONTROL OF RENTAL PROPERTY AND THE
INCOME FROM THAT. RESPONDENT SHALL CONTINUE TO PAY THE MEDICAL PREMIUMS AS
ORDERED~ THE PARTIES HAVE AN AGREEMENT ON SOME CHANGES TO THE PARENTING
PLAN AND THE COURT ENTERS THOSE AS PROPOSED.
1 MINUTE ENTRY
FILED
,- 17 :3--:02497- 31 · - - - - - - - - - - - . . ZO I7DEC I2 PH 2: I O
! ORFR 44 l
Order on Motion for Revision of Court Commiss1
~iOWrA HRASKI
J~i1 1 1 1 1 1 1 1 1m1 1 1 1 1 j COUNTY CLERK

SNOHOMISH CO. WASH

IN AND FORTHE COUNTY OF SNOHOMISH
SQ\\,I & \Jr·\ c..Q_ .)

)
PLAINTIFF I PETITIONER )
and ~ No.\1-3-0l_L\C{f~?J\
Ch~~S A\V0f'I -:\)f\'CL
DEFENDANT/RESPONDENT ~ ORDER <;>f\ Ysvv~ 'Q\C)tJ
)
)
'•
ITISHEREBYORDERED: Jo-1\\.1\i. ~\J??o~:·,;>~Jo~c\ ~ ~C(,CCO ?-er · ·.

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coua-\-r()1bo& yorea..\-s in\'ct ac.eree '" c0,iQlf\Q:? .-to :\lrp,~\ ~ck_
DONE IN OPEN COURT this date:---,,---,......,..,,---~--=----
Presented By:
...IR
JUDGE I COURT COMMISSIONER
:.-. 1084-4
'J Vi Page# 2
Case Name :\(\ C0 ,.., \J" () c.Q__ . Case No. \'1-~ - e:52. L\ Q:Z - °3 (
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At.r,.._ (_,)di a ct- be_ trn.~11 n ~ £ ktz. ha') evet1 DV'€
I 1a M'f oF h;b clCt3Sf3
DONE IN OPEN COURT this date: -~J.~2.-!i_,_,_-_l-.,__,/,.__.J

~,;-1-
r . _. _ · _ _ _
Presented By:
~ '-'l 11J<(o -
~~c
! .
\
17-3-02497-31
1 PORO 45
Protective Order
2578397
2
1111111111111111111111111111111111111111 )
3

6
11
7
SALLY JO PRICE, STIPULATION AND AGREED ORDER
8 OF PROTECTION OF BUSINESS
Petitioner, RECORDS
9
and
10
11
Respondent.
12
13 STIPULATION
14 The parties hereto, by and through their undersigned counsel of record, recognizing that
15 they and others possess confidential business documents and information which will be revealed in
16 the course of discovery during the pendency of the above-captioned proceeding, and desiring to
17 protect such documents and information from disclosure to the public generally, stipulate as
18 follows:
19 A Protective Order is necessary to protect confidential information of LeaderOne
20 Corporation in which the Respondent holds direct or indirect ownership interests. There is no
21 significant public interest in disclosing the confidential information of LeaderOne. Unauthorized
22 disclosure of the confidential information may irreparably harm the parties and company. The
ORIGINAL I
BREWE LAYMAN P.S.
23 Attorneys at Law
P.O. Box488
STIPULATION AND AGREED ORDER OF PROTECTION OF (425j 252-5167 Phone
i~~ss RECORDS - 1 (425 252-9055 Fax
www.brewelaw.com
1 Order below does not prevent disclosure of information that is already in the public domain. Entry
2 of the Order below will facilitate discovery in this matter and will provide the parties access to
3 such documents and information, subject to certain protective provisions set forth below.
6 Bv /2
- SJJrillaLaYman, WSBA 25260
Uilvt-----
By~~~~~~~~~~~
7 Attorney for Petitioner Kirstyn Palmisano, WSBA
Attorney for Respondent
8
9 PROTECTIVE ORDER
10 Based on the stipulation above, the parties agree pursuant to CR 26( c) and CR 29 as
follows:
11
1. Confidential Information Defined. The Respondent has ownership interests in
12
13 LeaderOne Corporation, hereinafter referred to as the company. During the course of the instant
14 action and after its conclusion, the attorneys for the parties may be provided with
15 information/documents containing confidential information relating to the company. 'Confidential
16 Information' means (1) any written or recorded document containing information relating to the
17 company that is not readily available in the public domain (provided that it did not become
18 publicly available as a result of any conduct of the parties or their representatives), and the
19 information contained in such documents; and (2) declarations, interrogatory responses, testimony
20 adduced at deposition, expert reports, responses to requests for admission, production of things
21 pursuant to CR 34, and other similar materials containing information relating to the company that
is not readily available in the public domain.

22
23
I BREWE LAYMAN
Attorneys at Law
P.S.
P.O. Box488
24 STIPULATION AND AGREED ORDER OF PROTECTION OF Everett, Washington 98206-0488
(425j 252-5167 Phone
~~~SSRECORDS-2 (425 252-9055 Fax
www.brewelaw.com
1 2. Use of Confidential Information. All documents and information produced at any
2 time during the course of these proceedings by any party or by third parties, informally, by
3 agreement or formally, regarding the parties' business income, personal income, and financial
4 affairs shall be treated as confidential information. In addition any documents marked
5 "Confidential" by any non-party (including LeaderOne) shall be treated as confidential information
6 under this order. Confidential information shall only be used in preparation for, and conduct of,
7 proceedings in this case, including proceedings necessary to effectuate the division of marital
8 property. Confidential information shall not be disclosed except as permitted by this Order.
9 3. Permissible Disclosure. Confidential information may be disclosed to the Court,
10 court personnel, court reporters, and similar personnel. Confidential information may be disclosed
11 to the following other persons, and disclosure may not be made to such persons until after he/she
12 has signed an Agreement to be Bound by Protective Order, attached hereto:
13 A. Petitioner and Respondent herein;
14 B. Counsel for the parties and counsels' partners, associates, staff or other
15 employees or agents of counsel of record;
16 C. Authors, addressees, or other persons who are indicated on a designated
17 document as having previously received access to said document during the
18 ordinary course of business. Disclosure to such persons shall be limited to the
19 documents previously seen;
20 D. Litigation support services, such as copying services;
21 E. Mediators, arbitrators or others retained to assist in resolving any aspect of
22 the case;

Attorneys at Law
P.O. Box488
24 STIPULATION AND AGREED ORDER OF PROTECTION OF (425) 252-5167 Phone
~~~SSRECORDS-3 (425) 252-9055 Fax
www.brewelaw.com
1 F. Experts and consultants pursuant to CR 26, testifying or otherwise, retained
2 for purposes of this litigation. Such experts will be advised by the person disclosing
3 the confidential information that (a) the confidential information is being disclosed
4 pursuant to this Order and said information may not be disclosed other than by the
5 terms of this Order; and (b) violation of the terms of this Order may constitute
6 contempt of court.
7 4. Additional Persons. Either party may seek an order of this Court to allow persons
8 lil addition to those identified in Paragraph 3 above to have access to such confidential
9 information. Until the Court enters a further order quashing the designation or providing additional
10 access, however, this Stipulation and Order shall control.
11 5. Confidential Information in Pretrial Matters. Nothing herein shall preclude the
12 use of confidential information in motions or pretrial matter, either by reference or as an exhibit.
13 Any document filed with the court is presumed to be a public document. Consistent with court
14 rules and relevant case law (CR 26(c); GR 15; Seattle Times Co. v. Ishikawa, 97 Wn.2d 30, 640
15 P.2d 716 (1982); Dreiling v. Jain, 151 Wn.2d 900, 93 P.3d 861 (2004); Rufer v. Abbott Labs., 154
16 Wn.2d 530, 114 P.3d 1182 (2005)), the court must make particular fmdingsjustifying the limits on
17 the public's access. The court must: (1) require the proponent of sealing or redaction to make a
18 showing of the need to seal or redact; (2) give anyone present when the motion is made the
19 opportunity to object; (3) analyze whether the requested limitation on access is the least restrictive
20 means available and effective in protecting the threatened interest; (4) show that the court weighed
21 the competing interests of the parties and the public, and considered alternative or less restrictive
22 methods; (5) enter an order no broader in its application or duration than necessary to serve its

Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
~~~SSRECORDS-4 (425) 252-9055 Fax
www.brewelaw.com
1 purpose. If the order involves sealing of records, it shall apply for a specific time period with a
2 burden on the proponent to come before the court at a time specified to justify continued sealing.
3 Therefore, if the parties wish to keep a previously filed document confidential, the parties must file
4 an appropriate motion to do so. The burden is on the proponent of sealing to provide the necessary
5 information so the court can determine if all, a portion, or none of a document is to be sealed.
6 Court findings and conclusions reflecting the same and authorizing sealing or redaction must also
7 be filed. Notwithstanding the foregoing, the parties agree that any document marked
8 "Confidential" by LeaderOne shall not be filed in the public court record but (to the extent the
9 party needs to use the document in the proceedings), such document shall be filed and presented to
10 the Court under seal.
11 6. Confidential Information in Depositions. During depositions, any party or
12 deponent may designate exhibits or portions of deposition testimony as confidential by so advising
13 the court reporter on the record. The reporter shall separately transcribe the testimony designated
14 confidential and mark said pages as confidential. After transcription of the deposition testimony,
15 either party may designate exhibits or portions of deposition testimony as confidential by so
16 advising opposing counsel and the court reporter of the exhibits or deposition testimony to be
17 designated confidential within ten (10) days ofreceiving the transcript.
18 7. Confidential Information at Trial. Confidential information may be used at trial
19 only if appropriate steps are taken to maintain the confidential nature of the information. Either
20 party or the company may move the court for an order that confidential information used at trial be
21 received in camera or under such conditions to prevent unauthorized disclosure.
22

Attorneys at Law
P.O. Box488
~~~SSRECORDS-5 l
425l 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 8. Additional Scope. Either party may object to the characterization of testimony,
2 documents, or information as confidential. To the extent a party objects to the characterization of
3 testimony, documents, or information as confidential, that party shall provide written notice of no
4 less than six (6) court days to the person or entity producing the information, as well as to all
5 parties.
6 9. Disposition of Confidential Information. The provisions of this Stipulation and
7 Order shall not terminate during the pendency of this action, including any appeal taken from any
8 decision in this action and the wind-up of the asset division. Further, the provisions of this
9 Stipulation and Order shall not terminate until all materials (other than exhibits of record) are
10 returned to the producing party, which shall occur if requested in writing within 45 days of after
11 final orders enter, or the time for appeal ends, or the asset division is wound-up. However, this
12 provision may be amended by mutual agreement or in the final decree or final order if either party
13 needs or requests copies of historical documents or financial data relevant to property awarded to
14 that party.
15 10. Jurisdiction. The Snohomish Superior Court shall have sole jurisdiction to
16 interpret and enforce this Order.

FEB 0 9 2018
17 DONE IN OPEN COURT this __ d~ ofJanttary, 2Ql~
21
22

Attorneys at Law
P.O. Box488
24 STIPULATION AND AGREED ORDER OF PROTECTION OF (425j 252-5167 Phone
~~~SSRECORDS-6 (425 252-9055 Fax
www.brewelaw.com
. '
l Presented by:
2 BREWE LAYMAN P.S.
4
By-~
S'abrina A. Layman,
WSBA25260
7 Copy Received, Approved for Entry,

Notice of Presentation Waived:
8 /~
9 By kJ/ Vt-----
Kristyn Palmisano, WSBA 41386
11 AGREEMENT TO BE BOUND BY PROTECTIVE ORDER
12 The undersigned herein has received and reviewed the Stipulation and Agreed Order Regarding
Confidentiality and Disclosure of Documents and Information :filed with the
13
County Superior Court on ~. +- ,
20 I~ and agrees to abide by the_term
__s_th_e_re_in___
14 DATED this )4?aay of @'fVu.v-"£ , 201.$.
15
16
17
18
19
20
21
22
23 IBREWE LAYMAN
Attorneys at Law
P.O. Bo>c488
P.S.

f425j 252-S167 Phone
i~SS RECORDS - 7 (425 252-9055 Fa>c
www.brewelaw.com
s
17-3-02497-3.1
1 COPC 46
FILED
2SIB MAR 21 PM a: i.a
· Confirmation of Parenting Class
I
I
I
illlll/1111111111111111111111 Ill j i.f!~tJ'ii'l

,i\Jn1 'i ,~ n•·<OA
Gi'.HJN T'f CU~·RK
StH'.JfWM'!Stl CG.WASH··
"!l
n A bn I .

. IN AND FOR THE COUNTY OF SNOHOMISH
In re: )
SC{ ily fn le_ ) No. 17-3-02497-31
Petitioner, )
vs. ) CERTIFICATE OF COMPLETION
CVrCAYU .t Pn ~ Respondent, ) OF PARENTING SEMINAR
THIS CERTIFIES THAT

Sally Price
HAS COMPLETED:
FOR THE KIOS' SAKE: A PARENTING SEMINAR.
Date: February 17th, 2017 Location: Everett, WA
~~LP!~
· sen:\j;ar
l;;f·~
~ Staff
ORIGINAL
2 17-3-02497-31
NTAB 47
Notice of_Absence Unavailability
2018 MAR 30 AM 10: ~ ~
3
5
ii~\\~\~\\\\\~\\\\~~
6
7
In re:
9
10
Petitioner,
11 and Notice of Availability for Trial
Setting
12 CHARLES A. PRICE, JR.,
13
Res ondent.
TO: CLERK OF COURT
14 ANDTO: All parties and counsel of record.
15 PLEASE TAKE NOTICE that VERONICA FREITAS is available for trial on th

16
following dates, with November 13th_ 15th being the prefeffed choice:
17 November 7th - 9th, 2018

November 13t1i_16th, 2018
18
November 19111-2!5t 2018
'
19
20 PLEASE TAKE NOTICE that VERONICA FREITAS will be out of the State or otherwis
wiavailable on the following dates:
21
22 April 9th_ 13 111 , 2018

June 18th_ July ll 1h, 2018
23
DATED March 29, 2018.
24
25 Respectfully submitted,
26
27
VERONICA FREITAS, WSBA #19405
28
VERONICA FREITAS
V. FREITAS LAW,PLLC.
Notice of Availability 544 291h Avenue
For Trial Setting Seattle, Washington 98122
(206) 328-7362
Page I of I v@vfreitaslaw.com
..
URfGlNAL
,/
F 1
JL' F'f""l
_ . ..,I
17-3-02497-31
NTTSNA 48 . ..
Note for Trial and Statement of NonArb1trab1hty
~i 1i1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 /
SUPERIOR COURT OF WASHINGTON

IN AND FOR SNOHOMISH COUNTY
CASE NO. 17-3-02497-31
SALLY JO PRICE
Petitioner/Plaintiff\s) NOTE FOR TRIAL SETTING AND JNITIAL
STATEMENT OF ARBITRABILITY
vs. (NTTSNA OR STA)

Respondent/Defendant(s)
TO: The Clerk of the Court; the Director of Arbitration (by separate copy serviced at Room 502,
Superior Court Administration) and the attorneys or parties listed below:
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
arbitration. ·
Dissolution ofMaiTiage 3 days
Type of Case: Estimated Trial Time:
(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.
Dsix
(Check one)
This case D is arbitrable.
~ not arbitrable. .
Please note that as of 12-19-2003 there is a mandato•'Y arbih'ation fee of$220.00 which must be paid at the
time of filing this document with the County Cle1·k. Documents that indicate the case IS arbitrable that are
submitted without the fee will be retul'ned to the submitting party.
NOTE: A1·bitrnble, non-jul'y 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)
Date (mm/dd/yyyy): 04/16/2018 · at I0 :00 AM this case will be presented to the Court
Administrator's Office for Trial Setting.
IT IS NOT NECESSARY TO APPEAR FOR TRIAL SETTING.
S:\Systems, Technology & Equipment\Web\SC\Cumnl wcbp38• fomis\C2CivilTria1SettingNole 2.doc 1 of3

INITIAL STATEMENT OF ARBITRABILITY (SCLMAR 2.1)
This case is ARBITRABLE because: (Check one)

D The sole relief sought 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 l.2) or
D The sole relief sought, regm·dless of the number or.amount of payments, is the establishment,
termination or modification of maintenance or child suppo1i payments or arrearages (RCW 7.06.020
SCLMAR 1.2) 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 Court.
This case is NOT ARBJTRABLE 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
J4This 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
D This case is an appeal from a Municipal or District Court decision (which is not a Small Claims
. matter); or
~-This case is otherwise statutorily exempt from mandatory 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 Couii 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 paiiies. ·
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. (SCLMAR 2.1 (b))
CERTIFICATE OF MAILING
J certify that I mailed a copy of this document to
(Signature)
LhA__,,_
the attorneys listed hereon, postage prepaid on the
Date (mn}/dd/yyyy): _3_12_9_12_0_18_ _ _ _ _ _ _ __
Date (mm/dd/yyyy): 3/29/2018 ~~~~~~~~~-
WSBA #:. 19405 --'--~~~~~~~~~~~~~~~~
NAME:
NOTE: File the original of this document with the
Veronica Freitas
Clerk of the Court: Serve a copy on the Director of
Arbitration, Room 502, Superior Coutt ADDRESS:
Administration & a copy
on all parties. 544 29th Avenue, Seattle, WA 98122
TELEPHONE: (206) 328-7362
ATTORNEY FOR: (Check one)

0 Petitioner!Plaintiff
0 Respondent/Defendant
S:\Systems, 1'tchnology & f.quipmcn1\Wcb\SC\Curr<n1 wcbpago fonns\C2CivilTriolSouingNolo 2.doc 2 of3
:I
,)• -
PLEASE LIST THE NAMES, ADDRESSES, ETC. OF ALL OTHER ATTORNEYS JN THIS CASE
AND/OR ALL OTHER PARTIES REQUIRING NOTICE.
NAME: WSBA #: 25260

~~~~~~~~~~~~~
Sabrina Layman TELEPHONE: (425) 252·5167

ADDRESS: ATTORNEY FOR: (Check one)
0 Petitioner/Plaintiff
3252 Colby Ave#333, Everett, WA 98201 D Respondent/Defendant
NAME: WSBA#:~--------~~
TELEPHONE: ~~~~~~~~~~~

D Petitioner/Plaintiff
D Respondent/Defendant
NAME: WSBA#: ~~~~~~~~~~-'-~~
~~~~~~~~~~~~~~~~~~~ TELEPHONE: ~~~~~~~~~~~

,D Respondent/Defendant
NAME: WSBA#:~-~----~~~~
~~~~~~~~~~~~~~~~~~~ TELEPHONE: ~~~~~~~~~~~
.D Respondent/Defendant
NAME: WSBA#: ~~~~~~~~~~~~~
TELEPHONE: - - - - - - - - - -
0 Respondent/Defendant
S:ISyslems, Te<hnology & Hq11ipmen1\Web\SOCurrent webpage l'orms\C2CivilTrio1SeuingNole 2.doc 3 of3

; ~·; ...
11-3-02497-31
N1'~8 1 Absen~e Unavailability
i\1\\\\l\\\\\\ll\\\\\~
1

6
7
SALLY JO PRICE, NOTICE OF CONFLICT DATES FOR
8 PETITIONER'S COUNSEL
Petitioner,
9
and
10
11
Respondent.
12
13 TO: THE CLERK OF THE SUPERIOR COURT
14 AND TO: Victoria Freitas, Attorney for Respondent
15 This action has been noted for trial assignment on April 16, 2018.
16 Sabrina A. Layman has the following conflicts:
DATE: REASON:
17
May 16, 2018 Trial in Snohomish County
18 June 20 - 25, 2018 Vacation
June 28- 29, 2018 Vacation
19 July 17, 2018 Trial in Snohomish County
July 23 -August 12, 2018 Vacation
20 September 28, 2018 Trial in Snohomish County
21
22
BREWE LAYMAN P.S.
~oFcoNmcrnATEsQRfGINAl
P.O. Box488
(4251252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
1 Dated this _2_ day of April, 2018.
2 BREWE LAYMAN P.S.
Attorneys at Law
3
By~-.L:::__~~~=====~=
4 S.abtina A. Layman, WSBA 25260
5
Address:
6
P.O. Box 488
Everett, WA 98206
7
Phone:
8 (425) 252-5167
10
11
12
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.5.
P.O. Box488
JMQJJ~ OF CONFLICT DATES - 2 !

425l 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
·.•
17-3-02497-31
NTTD 5o
Notice o1 Trial Date
il~\\~\\\\\\\\\I\\" 20!3 AFR 20 AM 10: 30
Veronica A. Freitas
544 29th Ave
Seattle WA 98122-6220
Date: April 18, 2018

NOTICE OF TRIAL SETTING
and
CERTIFICATE OF TRIAL CONFIRMATION
RE: Cause No.: 17-3-02497-31
Sally Jo Price
Plaintiff/Petitioner
and
CHARLES ALLEN JR PRICE
Defendant/Respondent
This is to notify you that the above case has been set for non-jury trial on September 12, 2018
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 SCLCR 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 8/27/2018 and no later than
12 noon of the last court day of the week 8/31/2018 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
Sabrina Ann Layman
POBOX488
EVERETT WA 98206-0488
Date: April 18, 2018


and
RE: Cause No.: 17-3-02497-31
Sally Jo Price
and
This is to notify you that the above case has been set for non-jury trial on September 12, 2018
Court Administrator
follows:
12 noon of the last court day of the week 8/31/2018 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
CR41(E)
2
2018 APR 2 7 p·urt 12:. t·
,t
17-3-02497-31 SON'' 1· · ·~
3 MT 51 C""' l'!i Kttr. 51.r1
" BUNT y .',' ~/It
Motion
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5 IIII II
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6
7
8
County of Snohomish
9
10 In re:
No. 17-3-02497-31
11 SALLY JO PRICE,
Petitioner,
12 Motion to Appoint Parenting
and
Evaluator
13
14 Respondent.
15 I. Motion
16
Based on the declaration of Charles Price submitted with this motion, the undersigned moves the
17
court for an order appointing a parenting evaluator or GAL in this matter.
18
19
Respectfully submitted on this 24th day of April, 2018.
20
21
22
23 Veronica Freitas, WSBA No. 19405

24
25
26
27
28
VERONICA FREITAS
Mtn to Appoint PE- Page 1 of 1 544 29th Ave
0.RIGINA L
WPF DR 04.0100 Mandatory (712009)
RCW 26.09.060; .1 JO; .120; .194 Seattle, WA 98122
~· (206) 328-7362
· ', v@vfreitaslaw.com
11 SALLY JO PRICE, No. 17-3-02497-31
Petitioner,
Support of Motion to Appoint
13 Parenting Evaluator or GAL
14 Res ondent.
15 My name is Charles Price and I am the Petitioner in this case. I am over the age of 18
16 and am competent to testify as a witness in this matter. The Respondent, Sally Price and I are in
17 the process of getting divorced. We have three children together, Alex, age 15, Colby age 11
18 and Madison, age 5.
19 A temporary orders hearing was conducted on November 21, 2017. This court entered
20 an agreed temporary parenting plan which granted me residential time with our children every
21 other Thursday to Monday morning and a visit on Wednesdays from after school to 7:30 pm in
22 the off week. It has become apparent to me that this residential schedule is not in our children's
23 best interests. All of the children are struggling with this arrangement. Alex is having the most
24 trouble. It has gotten to the point where Alex refuses to speak to Sally. I am very concerned
25
about the children's emotional stability.
26
When Sally and I were married, Sally made dinner for the children every night and was
generally present for them. I understand that circumstances with Sally have changed
27
28

Page 1 of4 (206) 328-7362
ORIGINAL v@vfreitaslaw.com
substantially since we separated. Sally is out frequently on nights that she has the children,
2 leaving them to fend for themselves. She has also taken an interest in witchcraft and spirits
3 which takes up a lot of her time and is confusing for the children when they witness her new
4 rituals. I know that Sally may do whatever sh.e wishes and I only mention this behavior because
5 the children are very upset by the seemingly sudden and drastic changes in their mother.
6 I recently learned that Sally was using marijuana and that Alex was aware of it. Alex's
7 adult cousin contacted me after Alex confided in her. This was the first that I had heard that
8 Sally was using marijuana currently or that Alex might also be using marijuana. I immediately
9 contacted Sally and told her what I had heard. She acknowledged having a marijuana pen and
10 said that she was not aware that Alex had taken it. She did not seem surprised that Alex was
1I
aware she had a marijuana pen. We agreed to talk to Alex together and give him a drug test. I
12
was surprised by Alex's demeanor when we met with him. I have not been present with Sally
and the children for several months. Alex was very angry and disrespectful toward Sally during
13
the discussion.
14
Alex had told his cousin that he felt like he did not want to live anymore and that he did
15
not want to live with Sally. I asked Alex about those comments. He said he wanted to live
16
with me, but denied saying anything about not wanting to live. I pointed out that he just made a
17
similar comment earlier in our conversation. He then admitted that he had been depressed
18
lately.
19
The children do not understand the changes in their mother and their home environment.
20
Alex is struggling. I have tried to discuss these issues with Sally but she is defensive and
21
refuses to hear about the children's upset and worry. What is very clear to me after trying to
22
discuss parenting with Sally is that we will not be able to agree on a final parenting plan without
23
the assistance of a parenting evaluator or GAL.
24
My attorney has asked Sally's attorney if Sally would agree to appoint a parenting
25
evaluator or GAL, more than once, and each time Sally has refused. Please see Exhibit A. Her
26
attorney argues that there are not any RCW .191 allegations against either parent, so a parenting
27
evaluator or GAL are not necessary. I do not understand that position. I hope to have a neutral
28

Page 2 of4 (206) 328-7362
v@vfreitaslaw.com
person who can evaluate our situation and speak to our children so their voices can be
2 considered in the final parenting plan decision.
3 Her attorney claims that I am only seeking an evaluation to hurt Sally by questioning her
4 role as primary parent and that I am trying to bully Sally or control her by seeking an
5 evaluation. I did tell Sally that I would seek an evaluator if we could not agree on parenting. I
6 was not trying to bully Sally, I was merely stating a fact about how I understood we would
7 have to proceed short of agreement on parenting. Sally has increasingly been identifying as a
8 victim since we separated. That is another bizarre change in Sally that I do not understand.
9 Sally and I were partners during our marriage. She was very capable. The person her attorney
10 describes in emails, etc. is a total stranger from the person I was married to.
11
I know that there is no way that either Sally or I will move from our positions without an
12
evaluation, which virtually guarantees that we will end up in trial over the final parenting plan.
A parenting evaluator will interview collateral witnesses, the children's teachers, etc. and
13
summarize their statements in their report. If nothing else, the evaluation should shorten a trial
14
by eliminating the need to call many of the witnesses whose statements are contained in the
15
parenting evaluator's report.
16
I do not understand Sally's resistance to agreeing to an evaluation. I am offering to pay
17
for 100% of the evaluator's initial retainer. If additional funds are required to complete the
18
report, I propose that we share those costs 50/50. I am paying Sally $9,000 per month in
19
undifferentiated support, which is more than half of my monthly net income. ·
20
I agreed to the current temporary parenting plan because Sally had been a stay at home
21
mother during the majority of our marriage and I worked outside the home. Sally was proposing
22
less residential time for me in her proposed temporary parenting and she was requesting
23
limitations against me. I have always been very involved in our children's lives. I coached all
24
of their sports teams and attended their school events, assisted with home work and spent
25
quality time with them. I had been trying to negotiate a final parenting plan before I was aware
26
of the extent of the dysfunction at Sally's home. I was not able to predict that Sally would
27
change so drastically so quickly.
28

Page 3 of4 (206) 328-7362
v@vfreitaslaw.com
I do not know if this court believes that a GAL or a parenting evaluator would be most
2 appropriate under these circumstances. I am fine with either so long as the children have an
3 opportunity to be heard.
6 Signed at Seattle, Washington this 24th day of April, 2018.
Cha~rice
7
10
11
12
13
14
15
16
17
18
19
20
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25
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Page 4 of4 (206) 328-7362
v@vfreitaslaw.com
EXHIBIT A

From: Veronica Freitas
To: "Sabrina A. Layman"; Katie Miller
Date: Monday, April 16, 2018 S:40:00 PM
Hi Sabrina,
Welcome back. I am following up my email message below re: the GAL/PE question. Have you heard
back from your client, or do I need to file a motion?
Mr. Price asked your client to please send him copies of things she receives from the school that are
sent home with the children such as field trip sign ups, etc. Those should be scanned to him
immediately. He has done what he can to have things sent directly to him from the school but there
are some things that are only sent home with the children.
He also requested copies of the children's homework so that he can be sure they are doing
assignments when they are at his residence. Finally, he would like to share in receiving the
children's art projects, etc. that are sent home. He would like to have some for keepsakes.
Your client indicated that she did not intend to respond to his message, so I am sending it to you.
Thank you.

Veronica
I sent to my client. I am out of the office until April 16 but will monitor
my emails to respond timely with what I get from her.
Thanks
Sabrina

Hi Sabrina,
Please see Mr. Price's 2017 W2 attached. Mr. Price is waiting for your client to provide him
with the tax return so he can complete his part of the return. When will she be getting that to
him?
Will you agree to a Parenting Evaluator or a GAL to complete a parenting investigation?

These parties will not be able to agree on a final parenting plan and we will be in trial unless
we have a 3rd party evaluation. Please let me know as soon as possible.
I was hoping we could agree on parenting. Your client's reasons for not sharing the summers
moving forward do not make sense as she will be returning to the workforce and she claims
she will not be teaching in the futures so will work summers presumably. Mr. Price has been
very involved with the children. Your client initially agreed to a 50/50 residential schedule
which is what Mr. Price believes is in the children's best interest and what he will be pursuing.
Mr. Price does need to inventory property in your client's bedroom. There is substantial
property in the closet and pictures or artwork in that room. Your client can be present when
this is accomplished.
To: Veronica Freitas <yeronica@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>;
Amy Pasco <amy@vfreitaslaw.com>
SEE ATTACHED.
Scan Date: 04.03.2018 15:55:01 (-0700)

SUPERIOR COURT OF WASHINGTON
IN AND FOR SNOHOMISH COUNTY
CASE NO. 17-3-02497-31
SALLY JO PRICE CALENDAR NOTE: (NTC)
Petitioner(s)
FAMILY LAW MOTIONS
vs. Unless otherwise provided by applicable rule or statute, this
form and the motion must be filed with the Clerk not less than
CHARLES A. PRICE JR. twelve (12) calendar days preceding the date requested.
Responses to motion must be filed five (5) court days before the
Respondent(s)
hearing. Replies to responses must be filed three (3) court days
before the hearing.
FAMILY LAW/DOMESTIC CALENDAR

Monday through Friday@ 9:00 a.m. Date requested: 05/15/2018
Department B or C as assigned. (mm/dd/yyyy)
Nature of hearing: Motion to Appoint Parenting
*Department assignment will be posted the day of the Evaluator
hearing
(Confirm hearing at 425-388-3587 or online at
PRO SE DISSOLUTION CALENDAR

Date requested:
Wednesday@ 12:30 p.m. only
(mm/dd/yyyy) **NO CONFIRMATION REQUIRED**
Department C
Agreed Matters and Default Orders only
INTERPRETER CALENDAR
Tuesday at 9:00 a.m. in Department D Date requested:
Friday @ 1:00 p.m. in Department D (mm/dd/yyyy)
Nature of hearing: _ _ _ _ _ _ _ _ _ _ _ _ _ __
Interpreters are arranged through Court Administration.
Please call 425-388-3421.
(Confirm hearing at 425-388-3587 or online at
Language needed: _ _ _ _ _ _ _ _ _ _ __
NOTE: When picking a hearing date, DO NOT schedule your hearing on a court holiday. A list of court holidays can be found
at http://www.snohomishcountywa.gov/354/County-Holidays
If noting a presentation, or if a particular Court Commissioner has already heard a recent motion in the matter, please
indicate that Court Commissioner's name here: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
WARNING! CONFIRMATION REQUIRED: In order for the matter to be heard, the moving party MUST CONFIRM
their motion two (2) court days prior to the hearing BEFORE 12:00 noon by calling 425-388-3587 or online at
www.snohomishcountywa.gov/Confirmations For additional information see confirmations notes on page 2.
Failure to notify the Court of a continuance or strike may result in sanctions and/or terms. SCLCR 7.
This form cannot be used for trial settings. SCLMAR 2.1 SCLCR 40(b ).
l:\Price, Charles Jr\Pleadings\Ours\Motion To Appoint PE\Snocnty Notice Of Hearing.Docx, 4/25/2018

OR161NAL
.
. ...
.;.
CERTIFICATE OF SERVICE BY MAIL: Notedby:~

I hereby certify that a copy of this document
and all documents listed on page 3 have been mailed to (Signature)
the attorneys/parties listed on page 3, postage prepaid Veronica Freitas
on the: (Printed name)
Date (m~5/2018 19405
WSBA#
(Signature - Attorney for: (CHECK ONE)

D Petitioner/Plaintiff []l Respondent/Defendant
Stevie Craig - Paralegal to Veronica Freitas D Pros~
(Printed name)
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 (Petitioner's signature)
not being heard.
(Petitioner's printed name)
Please check in the Law Library for more information
regarding service. (Respondent's signature)
(Respondent's printed name)

on line at www .snohomishcountywa.gov/1354/Administrative-Orders
calendar. The exceptions are matters relating to trial settings, trial continuances, motions for revision, and motions to
enforce CR2A agreements; please refer to the Civil Motion Calendar Note regarding these motions.
SPECIAL SET/EXTENDED MOTIONS BEFORE A COMMISSIONER: Special Set/Extended motions are set by the
Court Commissioner only, not by a party or by counsel.
INTERPRETER CALENDAR: Interpreters are arranged by Court Administration at 425-388-3421. Court Administration
accepts requests for interpreters from pro se litigants and all other appointed or privately retained attorneys of record. All
requestors have an ongoing obligation to provide Court Administration with correct and updated information regarding dates,
times and locations of the hearings for which the interpreter is needed. The court requests five ( 5) days' notice of each hearing, if
possible.
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Motion Calendar or
Court Commissioner Calendars must be confirmed not later than 12:00 noon two (2) court days prior to the hearing.
Confirmations are accepted for a 24 hour period beginning at 12:01 p.m. three court days prior to the hearing date. When
determining your confirmation deadline, do not count weekends or holidays. Confirmations can be made by calling 425-
388-3587 or online at www.snohomishcountywa.gov/Confirmations.
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 at http://wa-snohomishcounty.civicplus.com/1338/Calendars-and-Schedules or by
calling Court Administration at 425-388-3421.

Snohomish County Snohomish County
Superior Court Clerk's Office Superior Court
3000 Rockefeller Ave M/S 605 3000 Rockefeller Ave
!:\Price, Charles Jr\Pleadings\Ours\Motion To Appoint PE\Snocnty Notice Of Hearing.Docx, 4/25/2018 2 of 3
Name: Sabrina Layman
Address: PO Box 488 Phone# (425) 252-5167 Ext.
Everett WA 98206-0488 Attorney for: (CHE.CK ONE)

[] Petitioner/Plaintiff D Respondent/Defendant
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
D Pro Se
Name: WSBA#:
Phone# Ext.
OProSe
List all documents mailed: Notice of Hearing; Motion; Declaration with Ex A; Proposed Order
!:\Price, Charles Jr\Pleadings\Ours\Motion To Appoint PE\Snocnty Notice Of Hearing.Docx, 4/25/2018 3 of 3

17-3-02497-31
MT 54
1
Motion
3177981 2018 MAY 23 PM If : tG
SONYA KRASKI
2 1111111111111111111111111111111111111111 · COUNTY''! '-•<:K
SNOH~MlSH CO~t/ASH
3

6
7
SALLY JO PRICE, MOTION FOR COMMUNICATION
8 REQUIREMENT AND ATTORNEY FEES
Petitioner,
9
and
10
11
Respondent.
12
13 COMES NOW, Petitioner, by and through counsel undersigned, and moves the court for
14 the following:
15 A. An Order that requires the parties to communicate regarding the children through
16 App Close (family calendaring/messages system); and
17 B. An award of$20,000.00 in attorney's fees payable by Respondent to Petitioner's
18 attorney within 30 days of hearing.
19 This motion is based on the following Declaration of Sally price, the updated Financial
20 Declaration of Petitioner and the files/records herein.
21
22
ORIG~NAL I
BREWE LAYMAN P.S.
23 Attorneys at Law
P.O. Box488
24 MOTION AND DECLARATION (425l 252-5167 Phone
~~~TORNEY'SFEES-1' (425 252-9055 Fax
www.brewelaw.com
1 Dated this J.-Y day of May, 2018.
BREWE LAYMAN P.S.
2 Attorneys at Law
4 rina A. Layman, WSBA 25260

5
DECLARATION
6
I am the Petitioner herein and make this declaration based on my own personal knowledge.
7
1. Background. I filed for dissolution on October 26, 2017. At the time Respondent filed his
8
Proposed Parenting Plan and response to my Motion for Temporary Orders, we were able to come
9
to an agreement on the parenting aspects of this case. An agreed temporary parenting plan entered
10
on November 21, 2017. There have been no changes since that time in terms ofliving situation,
11
employment situation, children's schooling or anything else.
12
Respondent was not happy with the outcome of the contested hearing on the finances and filed
13
a revision motion. Judge Wilson did decrease the total financial support slightly from the original
14
order but made no other changes. Since then, I have had to serve formal discovery on Respondent
15
and his company to gather what documents I could to try and get the business valued. I have had
16
to borrow money to hire a business valuation expert and still am waiting on additional items from
17
Respondent and corporate counsel for the business in order for my valuation expert to put together
18
a report. Respondent is unhappy with my continued request for more information and essentially
19
picks and picks at me about everything else.
20
2. Parenting. I think, in retaliation for me wanting to actually get accurate information about
21
the value of the business, Respondent has decided to use our children as pawns in this case. I
22
BREWE LAYMAN P.S.
P.O. Box488
24 MOTION AND DECLARATION 425l 252-5167 Phone
If~~2TORNEY'S FEES - 2 l
425 252-9055 Fax
www.brewelaw.com
1 believe that to be true given that his initial sworn declaration stated that I am the primary parent
2 and all he wanted was to have more time that what I initially proposed with the children. NOW,
3 because I am not caving in on his demands, he ha.S decided to make this a "custody" case, and is
4 bringing a motion for a parenting evaluator and suggesting that somehow my parenting is in
5 question. He knows that is how to hurt me the very most and has taken it upon himself to use the
6 children. Respondent has told me repeatedly that I am a wonderful mother and so when he
7 threatened a costly and intrusive investigation if I did not cave in to his demand to have week
8 on/week off in the summers despite the fact that I do not and will not work in the summers and he
9 does. He said he would just get a nanny or care giver when he was at work even though my
10 schedule dovetails with the children's schedule.
11 After never once volunteering at the children's school for the last 10 years, he has decided to
12 start volunteering at school in 2018, which is fine, but instead of just doing that, he had to makes
13 sure it costs me hundreds of attorney's fees dollars to have his lawyer email saying I needed to give
14 up my regular volunteer day at school and ask if I could possibly refrain from being at the school
15 when he is now going to volunteer and back and forth.
16 Another misuse of my resources were the emails about making sure I informed him of
17 medical/dental appointments. During our marriage, Respondent never attended one single routine
18 medical or dental appointment even though he was aware of them. He has taken the children to
19 emergency appointments or met me at the emergency room when I called him, but regular teeth
20 cleaning or medication checks - he just did not worry about that. Had he said to me that he wanted
21 to be there, again no issue, but instead he makes it cost me money instead but engaging in demands
22 through the attorneys instead of letting me know. Our children attend regular appointments with

Attorneys at Law
P.O. Box488
24 MOTION AND DECLARATION (425j 252-5167 Phone
Ji'~'J2TORNEY'S FEES - 3 (425 252-9055 Fax
www.brewelaw.com
1 their dermatologists, allergists, pulmonologist/sleep medicine doctor, ADHD specialist,
2 ophthalmologist, orthodontist and well child checks, teeth cleanings or any other appointment. I
3 have always been the primary coordinator/driver/attender. No objection ifhe wants to also attend
4 but that is not what his strategy is - his strategy is to make me pay fees to find out about this.
5 The most recent resource waste is a text from him demanding that I DAILY scan and email or
6 copy every single piece of homework, handout, artwork or any other information that the children
7 bring home from school and immediately send to him. He texts me that if do not do this or fail to
8 respond in an hour then he'll have his attorney email my attorney, which of course he did. Our
9 Temporary Parenting Plan requires him to keep himself informed of the children's activities.
10 When there are immediate information needs, I regularly will snap a photo and text him but
11 otherwise he has the children, with their homework and information and those documents can go
12 back and forth between us. He also can email the school and has been doing so and has set himself
13 up for notices so he gets all the same stuff I get. So this is just another intentional waste of
14 resources of mine.
15 Allen is constantly harassing me to the point where we cannot effectively communicate about
16 our children. I receive several daily emails from him with demands that I provide him with more
17 and more information, all of which is accessible on his own OR he belittles me/patronizes me
18 when he believes I am wrong. Recent examples are attached. I have proposed we start using a
19 communication tool/family calendar where I will input the information and he can access it. That
20 will alleviate his constant berating and provide a clear record. I am requesting the court order that
21 all non-emergent communication regarding the children take place through the AppClose app.
22
BREWE LAYMAN P.S.
P.O. Box488
24 MOTION AND DECLARATION (425! 252-5167 Phone
~~'J2TORNEY'S FEES - 4 (425 252-9055 Fax
www.brewelaw.com
1 I knew of Allen's personality and demands when I decided to file for dissolution and even with
2 those issues, I have been working on issues with him. For example, recently we spoke with Alex
3 about his experimenting with marijuana as well as Alex's need to have a personal counselor. After
4 interviewing a number of counselors, we came to an agreement on a counselor. This was not
5 without massive effort on my part and involvement of my attorney which effectively depletes my
6 resources. Ultimately, Allen would only agree on one counselor and just held out until I caved in -
7 which I did because Alex needs someone and I knew Allen would not agree. Allen's motion for a
8 parenting evaluator is just another attempt to beat me up so that I give in to his demands, and I
9 decline to do so. Allen doesn't care that this costs himself funds since he seems to have available
10 resources, but I need additional fees awarded to me in order for me to continue this litigation.
11 3. Threats. Respondent has taken it upon himself to threaten that ifl do not agree to give him
12 equal time in summer then he will force a parenting evaluation. Now his demands exceed that
13 request - he wants equal time all year and despite my multiple attempts to sit down with our
14 attorneys or have mediation to talk about the parenting plan issues, Allen refuses. That is not in
15 our children's best interests. His attorney tried to propose we exchange offers, but Respondent
16 himself said, "Don't waste too much time if you don't just agree to what I want." How is that in
17 our children's interests? His attorney encouraged us to just send an offer, so we did and the
18 response was that Respondent didn't agree. Another waste of time and money.
19 Allen also informed me that he would force this case to trial ifl don't just give in to his
20 demands, which he can easily afford but I cannot without further award of fees. Respondent will
21 call me and yell at me about a sundry of things from the Direct TV dish; to why I was not as
22 detailed in my interrogatories on personal property as he would like; to demanding to walk through

BREWE LAYMAN P.S.
P.O. Box488
24 MOTION AND DECLARATION (425! 252-5167 Phone
~~'fiTORNEY'S FEES - 5 (425 252-9055 Fax
www.brewelaw.com
1 and account for my personal property in my bedroom AFTER he has already moved out and taken
2 everything he wanted for his own rental house PRIOR to the last hearing. He just yelled at me for
3 not getting our taxes done on time (we filed an extension last year as well so it's not new that we
4 are extending our tax filing) and said to me ''that's the reason you are getting the rental property
5 income and you are not doing your job". His bullying was a big reason I decided to leave our
6 marriage and he continues to do that now to me which throws me off every time I get one task
7 completed. I try not to get thrown off, but every time I feel like I have responded to his demands,
8 another comes and I am derailed. This is exactly why I am divorcing him and exactly how I
9 alleged he acted towards me/our children in the past. We would walk on eggshells.
10 When Allen submitted his Proposed Parenting Plan at the onset of our case I thought it was a
11 reasonable plan and also thought our agreement would end his behavior; but, because I am not
12 willing to simply give in to his demands, now his threat is potentially harmful to our children and
13 financially impacting for me.
14 4. Attorney's Fees. At the time of the first hearing, the court recognized that I had a need for
15 fees and that Allen had an ability to pay fees. I am sure that because we had an agreed Parenting
16 Plan, the award was intended to help in my need for professional costs to appraise the assets; but,
17 then Allen filed a revision and the fees that were awarded were long gone before discovery even
18 got started. I borrowed funds to pay for the business evaluator and appraiser. I have already paid
19 over $15,000.00 in attorney fees to date and I owe an additional almost $13,000.00 which does not
20 include the cost of my response to Allen's motion, appearance for the court hearing, and the
21 anticipation of expending likely more than $20,000 for a custody battle that is not even warranted
22 with the facts of this case. I tried to propose mediation and tried to send an offer that was in line
BREWE LAYMAN P.S.
P.O. Box488
24 MOTION AND DECLARATION (425) 252-5167 Phone
lf'~'J'iTORNEY'S FEES - 6 (425) 252-9055 Fax
www.brewelaw.com
5 Allenllas ace~ fofunds via his stocks inJPe·compcmy and diyi~n~ tha~ he.maintains as well
4 as theincomesin exce.ss o f • he~vfuuslytepres~edio the .cQurt,. He tQld the court in his
5 ·declaration.in.supp0rt ofhis-motion for revision that"he·avetaged·$14,ooo per month :gross. Uis
6 .201 rw.-~>alorte SPows'~ings·-Of$'17"'82t?$ ~fiilOmh orEX~S .OF$3,82t93 per month
7 nim·l,lenas:~uwc~~~gWl;lic!l <>tilY fli~~liistiti~~n. The cqµrt_sho1lld <;titler that h~ pay me
8 :$20;000.0Q inattomey's f~ oo,.~t I canJnaintain cqunsel 3ll,4.proc~~ tm'ough this case.
9
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13
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23 I BJtEWt . l.AYMA.N P.s.

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P.O. Box.488 .. . . . .
Ever~WcaShJngton 98206-0488
24 MOTION~ANb DECLARATION {42Sl2S2~5.167 ?1Jo11e · ·
~2TQ~Y'S FRJ3S.~. 7 (425)'.252·9055 Fax
www.brewelaw.com
Emails regarding medical/dental
appointments and volunteering
Katie Miller
From: Sabrina A. Layman

Sent: Wednesday, March 28, 2018 9:48 AM
To: 'Veronica Freitas'
Cc: Amy Pasco; Stevie Craig; Katie Miller
Subject:· RE: Price
Veronica
Thanks for the feedback. I will provide that to my client. I don't think Mr. Price
ever has attended or scheduled medical appointments in the past but I realize he
wants to now involve in that.
I also don't think she's not responding to him - I think she does not engage in the
attacks which may cause Mr. Price to believe it's "non-responsive" but when he
asks her to call or text about the kids she gets back to him.
Here's an idea, when he's at school have him pick up a photo packet and order
them himself- that way he can choose what he wants and not have to ask
Sally. That's the easiest way to handle that.
As for the regular appointments - is he wanting to know when they are now
because he plans to attend? Or am I missing the point?
Sabrina

Sent: Tuesday, March 27, 2018 9:36 PM
Subject: RE: Price
Hi Sabrina,
I am responding to your message, below, but first there are some additional matters I would like to address.
Your client is not sharing information about medical appointments, etc. with Mr. Price. Decision making on non-
emergency health care was reserved in the temporary parenting plan. Your client does not have sole decision making.
She should be informing Mr. Price about any appointments she intends to schedule and give him an opportunity to
attend or object, etc. At a minimum, she needs to respond to his inquiries about the children's medical
appointments. For example, both Colby and Alex had medical appointments today and your client did not inform Mr.
Price about them at all. Please advise her to include Mr. Price in medical decision making in the future.
Your client tends to be non-responsive to Mr. Price's inquiries, which causes bigger problems than simply not providing a
response. Most recently, Mr. Price asked your client about the children's school pictures. Apparently, the order packets
were sent home to your client. Mr. Price was hoping to order two sets or to share the cost of the children's photos, but
your client has not responded to his inquiry at all.
1
The unfortunate result of your client's lack of communication is that communication will end up going through attorneys
which is expensive and could increase tensions. Mr. Price is now reticent to communicate directly with your client given
your client's inaccurate reporting of events below. See Mr. Price's comments below.
~-------- ~-----

Sent: Monday, March 26, 2018 1:25 PM
To: Veronica Freitas <veronica@vfreitaslaw.com>; Katie Miller <katiem@brewelaw.com>
Cc: Amy Pasco <amy@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>
Subject: RE: Price
Veronica
I met with Sally this morning and we will send over a proposed Final Parenting Plan
this week. It is our hope that will resolve the parenting issues fully and finally. In
the meantime, I wanted to respond to your client's other issues and let you know
what I see happening on this case.
1. I have now copied you in on the email that was originally copied to Kirstyn on
the remaining items we need to do the business valuation. I'll send out a
formal request as well tomorrow.
2. As for the weekends that your client has business trips, my client indicates he
arrives home on Fridays from those trips and she is not opposed to having his
mother pick the kids up Thursday per the schedule as she did the last
weekend with a conflict if that remains convenient for him rather than
fussing with changes on the regular schedule. With the number of trips that
he is taking the idea of trying to figure out make up time or switching
weekends is too complicated and since his mom seems open to the idea we
are ok with that. The other option is that he just pick the kids up on Friday
from my client. That's fine too. Of course she'd love to know well in advance
as he indicated so she can make sure she knows who is getting the kids or if
they are staying with her.
3. Your client has been communicating through the children and swinging by
the house not infrequently for sundry of things. Please have him
communicate directly with Sally. She's trying to keep those lines open as
well. For example, she received some of his mail and texted to see what she
should do with that and he said he would come get the mail and that was
2
fine with her. What's not fine with her is him texting the children to say he's
purchased new shoes and that he's coming over to let the kids try them on
and then shows up without Sally knowing until he's in the driveway. Or,
inferring to the youngest child that she needs to call him every day that she is
with her mother - she's 5 years old - that's a bit much and the little girl is
stressed if she doesn't comply or forgets. When your client showed up for
his pick up this weekend he made sure to tell Sally that if she did not agree to
his proposal for visitation he would get a Guardian Ad Litem to investigate
Sally- that's a threat of abusive litigation. I understand these folks
communicate differently, but as I told you when we spoke, his techniques of
bullying or demanding are roadblocks to moving this case forward. If he
wants resolution, then he needs to back off his threats.
First this is completely untrue. 1. Alex said he needs new shoes for athletics he is 15. His mother says she
can't afford them. This is what she tells all the kids. I told him he can borrow mine if he wants to see if he
likes them. He said great swing them by he needed them badly, I told him to see if it was ok with his mom. He
did not get back to me so I called Sally and told her. She said he never told her I said ok then I don't need to
come by I can do it another time. She said I don't want to be the reason you can't come by, I said no it is fine
he should have told you. She said no go ahead. So I went over there.
As for the Madison and being stressed out over calling me, it has never happen and never would. I have never
told my kids they need to call me daily or anything like that.
As for the Guardian I told her that it is in the kids best interest to agree. They want more time with me and they
need more time with me. I said that I would have no choice but to get a Guardian if she did not agree.
4. I understand that your client is now starting to involve himself at the

children's school through volunteering and emailing the teachers. As we
stated before, that's great - my client has no issue being in the same school
or classroom with him. What he doesn't need to do is pretend that he's
been the contact or primary parent all along. What I call "parenting for
show" is unnecessary in this case (all cases actually). He doesn't need to let
Sally know that the teachers are good about emailing him back - she's
known that for years. He doesn't need to step in and secretly make
conference appointments and only tell the kids who then feel obligated to let
their mom know that "Dad's handling the conferences" - that's uncool. Sally
then has to text your client to say she'll be at the conference as well. And, he
certainly doesn't need to "buy" these kids with $800 Gucci tennis shoes or
trips with a 5 year old to iFly that the kids then feel guilty about because Sally
cannot afford the same thing. Sally wants him to be with his kids and enjoy
their time together. She is not undermining him as a parent and doesn't
down talk him when he's late to pick up or changes plans or cannot make it
3
due to business. She understands that. What she doesn't appreciate is the
newest version of this case which is Allen telling her he wants 50/50 time and
he'll just get a nanny for the kids and if she does not agree then he'll "go to
war" on the issue. As I said on the phone, whenever my client is making
progress in getting one more "Allen" project done so that she can work
towards her plan of independence, he trips her at the start line by telling her
he's gearing up for custody litigation or how terrible she did on answering
the discovery questions or demanding that she send him regular photos and
updates on the rental properties. So, as I said, please let Allen know that his
constant "pulling the rug out" only serves to make this case more costly and
lengthy- which it would seem is something he also wants to avoid. It's
within his control.
Mr. Price has worked extremely hard, to the point that it almost killed him, to financially provide for his children and
your client. That is not parenting for show. Mr. Price was able to attend all of the children's sporting events and he
coached their teams for years. He attended as many of the children's conferences and educational events as he
could while maintaining that work schedule. His efforts allowed your client the luxury of being able to stay home.
Mr. Price did not schedule a conference. The parties' had the exchange below regarding the conference:
Mr. Perkins told me the date and time that he had for Colby I did not schedule anything. Look how shit is being
shaped read the text below!
Her when did you schedule a conference w mr perkins? i want to be there

Me I can let you know later today it is n my calendar. I am in class today. He gave the time and date. He also said
if we would like we could do it separately. I told him I am fine with together but you would decide that for yourself.
Her isn't it better if we go together? Same info, both hear each others questions ...
Me I said to him I was fine with together. He said he would accommodate us considering the situation. If you
need it sooner he is really responsive via email.
Me From now on can we order pictures together since this things get sent home with the kids and I don't even
see them to order? I want my own packet.
Me So it looks like you scheduled Madison's Confrence do we want to attend that one together also? I am fine
with that.
Let me know ASAP so I can schedule my own if you don't want to.
Wed 3/28 at 1:20. i'm
Her fine w joint conference. It is preferable
Her i'll be at col bys thursday at 1:25
Me Ok great I thought it was that time but wanted to comfirm once I got to the office.
Again never answered the picture question and just gave me a couple small pictures.
I am never late to pick up kids unless I am out of town working
Here is the situation with the Gucci shoes and ifly:

The shoes were 600 and Alex paid me 200 of the 6 and I pay him for his grades and that is what I owed him. As for
lfly the kids have been asking to go there for months.
It seems your client is making different choices about how to spend her money.
4
Request for photos:
I asked for the photos on the apt interior and exterior so I could look into a CMA like opposing council requested. I
need the pies to do that. When I made the request she said she was busy with taxes and I said that was more
important than the pies so just send them after the taxes are complete. Not sure where the demand is there for
that.
5. To get a November trial date, you'll likely need to file for trial setting
sometime in June - We don't get to hand pick the date up here.
-Sabrina

Sent: Wednesday, March 21, 2018 9:27 PM
To: Sabrina A. Layman; Katie Miller
Subject: Price
Hi Sabrina,
I am following up on our telephone conference earlier today. I spoke with Allan and asked about the additional
documents that you need from his company to have the business valued. He was not aware that you had requested
additional information. Would you please forward that request to me and Allan will see what he can do to facilitate
getting you the information?
We discussed expanding the residential schedule to include a Thursday overnight in the off week, instead of the
Wednesday dinner visit. I forgot to request a 50/50 residential schedule over the summer months as well. Would you
please discuss that option with your client too?
I found out more about how frequently Allen might need to switch weekends with your client. He explained that the
only time he would need to travel for work on weekends when he had the children would be for board meetings, which
occur approximately 6 times per year. He has substantial advance notice of those meetings as they are all planned for
the upcoming year. He can give your client the dates of the board meetings that conflict with his residential weekends
several months in advance it seems. We would like some provision that allows your client to choose between her
weekend before or after Mr. Price's weekend for him to have instead of his weekend.
Please let me know if your client will agree to permit Mr. Price to go through the home and document the property
either by photo or notes. He will agree not to take any property from the home at that time. He can then compile a list
of items that he would like and I will forward it to you to discuss with your client.
I also forgot to discuss setting a trial date. Allan would like us to set a trial date in November, 2018. Please let me know
if you are not able to do a trial in November. Thank you.
Veronica Freitas
V. Freitas Law, PLLC
544 29th Avenue
Seattle, WA 98122
Phone: (206)328-7362
Fax: (206)323-0404
mailto:v@vfreitaslaw.com
5
www.vfreitaslaw.com
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information may be a violation of that law. If you received this e-mail in error, please contact the sender and delete the
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To: sabrinallal,brewelaw.com Remove this sender from my allow list

From: veronicalal,vfreitaslaw.com
You received this message because the sender is on your allow list.
6
Text from Allen/Attorney email
regarding scanning all school
related documents
Katie Miller
From: Sally Price <sallyjprice@me.com>

Subject: Text from Allen
Sally,
Here would be my expectation.

1. All children's school work This is related to daily work being brought home (not art) be copied for my to
pick up when I pick up kids.
2. (All)project or art work would be complied for us to both select certain things to go home with both parents
for fridge or keepsakes. This is not you giving me what you don't want but is separating together. This would be
done· at the same time I pick up the children.
3. All materials from the school that are sent home with the children need to be copied for my pick up.
4. If there are sign ups for anything that needs to be scanned ASAP so I can make any changes to my schedule
to volunteer or sign up to attend.
I don't think I have left anything out at this point but ifl did let me know and I will add to the list.
This is my request to you at this point. I would like a response if this is acceptable by days end. I would also
appreciate that we try and communicate ASAP on these type of things so we don't have to get lawyers involved.
My lawyer is already working on this and I need to call her off if your agreeable.
I do need to know in writing that your agreeable at this point.
Charlie Price
Sent from my iPhone
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From: sallyjprice@me.com
1
Katie Miller
From: Veronica Freitas <veronica@vfreitaslaw.com>

Sent: Monday, April 16, 2018 5:36 PM
Hi Sabrina,
Welcome back. I am following up my email message below re: the GAL/PE question. Have you heard back from your
client, or do I need to file a motion?
Mr. Price asked your client to please send him copies of things she receives from the school that are sent home with the
children such as field trip sign ups, etc. Those should be scanned to him immediately. He has done what he can to have
things sent directly to him from the school but there are some things that are only sent home with the children.
He also requested copies of the children's homework so that he can be sure they are doing assignments when they are
at his residence. Finally, he would like to share in receiving the children's art projects, etc. that are sent home. He would
like to have some for keepsakes.
Your client indicated that she did not intend to respond to his message, so I am sending it to you. Thank you.

Veronica
I sent to my client. I am out of the office until April 16 but will monitor my emails
to respond timely with what I get from her.
Thanks
Sabrina

Hi Sabrina,
Please see Mr. Price's 2017 W2 attached. Mr. Price is waiting for your client to provide him with the tax return
so he can complete his part of the return. When will she be getting that to him?
Will you agree to a Parenting Evaluator or a GAL to complete a parenting investigation? These parties will not
be able to agree on a final parenting plan and we will be in trial unless we have a 3rd party evaluation. Please let
me know as soon as possible.
1
I was hoping we could agree on parenting. Your client's reasons for not sharing the summers moving forward
do not make sense as she will be returning to the workforce and she claims she will not be teaching in the
futures so will work summers presumably. Mr. Price has been very involved with the children. Your client
initially agreed to a 50/50 residential schedule which is what Mr. Price believes is in the children's best interest
and what he will be pursuing.
Mr. Price does need to inventory property in your client's bedroom. There is substantial property in the closet
and pictures or artwork in that room. Your client can be present when this is accomplished.
To: Veronica Freitas <veronica@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>; Amy Pasco
<amy@vfreitaslaw.com>
SEE ATTACHED.
Scan Date: 04.03.2018 15:55:01 (-0700)

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To: katiem@brewelaw.com Remove this sender from my allow list

From: veronica@.vfreitaslaw.com
2
Recent emails from Allen with
demands, etc.
Sabrina A. Layman

Sent: Tuesday, May 22, 2018 9:31 AM
Subject: Fwd: Gymnastics
Attachments: ATT00001.htm
Begin forwarded message:
From: Allen Price <aprice@leader1.com>

Subject: RE: Gymnastics
Date: May 22, 2018 at 9: 18:58 AM PDT
To: Sally Price <sallyjprice@me.com>
Oh Sally come on now that is not true it sounds like your being misleading with that
statement. I will just chalk it up as lawyer talk, but we all know the truth. I have attended
choir, all of Irish soccer, band presentations for Alex, All Catholic school events, all of Alex's
flag football and Colby's flag football along with coaching Colby from Syrs old to 11 in spring,
fall football and tackle football and have the pies to prove it. Please remember I have taken
pies and sent them to you via text so you could see what you had missed. I have so many
events that I have been a part of I could just go on and on. Nonetheless I won't. You know and
our children know that I was there for them at every event.
As far as the busy comment, It would appear you may have taken that personal and I am sorry
you felt that as a personal attack, that was not at all my intention at all. I was just stating if you
had something going on like girls night out on Tuesday. I think that is what you always had or
have on Tuesdays that I would be there to help out with Madi. Considering that I pushed
gymnastics on you after talking to Madi that was the least I could do. I would love the
opportunity to spend more time with the children since we are not at all equitable in regards
to the time with OUR children Currently. Even if it is only to and from sports for now.
1
cn~1e$" :CAllen:l
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P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-9300

E: APrice@Leaderl.com Read my Reviews! Check out my website!
tilimiiiDel WhotWeBelieve APPLY NOW!

1604 Hewitt Ave Suite 401- Everett, WA 98201
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To: Allen Price <aprice@leaderl.com>
Subject: Re: Gymnastics
Allen,
I am not too busy for our children. I will let you know if I need your help. I was not aware that you were at every practice
or every activity.
Sally
On May 21, 2018, at 7:22 PM, Allen Price <aprice@leaderl.com> wrote:
Excellent thank you so much for the update. Again I can pick up and drop off when needed since your real busy.
am planning on being at every practice just as I always have been at the kids activities.
Charles (Allen) Price

Executive Vice President Production-Director
NMLS# 60272 - LeaderOne Financial Corp.
P (425) 265-9100 C (425) 345-6384 F (425) 265-9300
1604 Hewitt Ave Suite 401-Everett, Wa. 98201
APPLY ONLINE NOW!

Website I Reverse Website I Online Reviews I What We Believe I Email
Follow me on: Linkedin, Facebook, and Glassdoor!
2
CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail message and any attachments are
confidential and are solely
for addressee. The information may also be legally privileged. This transmission is sent in trust, for the sole purpose
of delivery to the
intended recipient. If you have received this transmission in error, any use, reproduction or dissemination of this
transmission is strictly
prohibited. If you are not the intended recipient, please immediately notify the sender and delete this message.

Sent: Monday, May 21, 2018 6:54:46 PM
To: Allen Price
i signed her up for tuesdays at 6:30 too.
Sent from my iPhone
On May 21, 2018, at 3:52 PM, Allen Price <aprice@leader1.com> wrote:
Thank for sending it but I am unable to print it or even enlarge it

enough to read. If you could make a copy and I will pick it up. There Is
also iScanner that is free to download on your mobile device that will
scan it to a pdf and then it will allow the recipient to do what is
needed to read it. You can always scan with the printer at the house
and send through email. These may be better choices. Unfortunately
I just can't see this copy to read it.
<image010.jpg><image011.png>
P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-9300
Check out my Reverse Website! What We Believe
<image012.jpg> <image013.jpg> <image014.jpg> <image015.jpg> <im
age016.jpg>
CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail message and any attachments are confidential and are solely
for addressee. The information may also be regally privileged. This transmission is sent in trust, for the sole purpose of delivery to the
intended recipient. If you have received this transmission in error. any use, reproduction or dissemination of this transmission is strictly

Sent: Monday, May 21, 2018 3:30 PM
Allen,
I am planning on enrolling her tonight in Monday night classes at 5:30. I will try to enroll
her in Tuesday evening classes as well, if there is availability.
I've attached the registration form.
Sally
<image008.jpg>
<image009.jpg>
3
Sent from my iPhone
On May 19, 2018, at 8:11 AM, Allen Price <aprice@leaderl.com> wrote:
Sally,
I have not heard back on the Gymnastics and what your

thoughts are. You said tenative you signed her up? I
want to know the details and I have waited patiently. I
have offered to take her another day since you have
such a busy schedule. You have not responded to that
offer. I was trying to be accommodating to say I could
take her. So at this point I am letting you know that I
want to know what you have committed to? I am also
saying this for the record this is now our decision. I
would like her to go two days a week and I can take her
Tuesdays or Saturday. I have always been involved with
our kids sports and been the primary in that
department. The gymnastics was pushed by me in a
previous email to you since she had been complaining
about you not taking her. This is our decision and we
will decide together. Could you please inform me of
what Day you have committed to and let's discuss the
2nd day that she will go. Please also send me a copy of
any form you filled out for the guardian permission.
P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
<image010.jpg> <image011.jpg> <image012.jpg> <image013.jpg>
<image014.jpg>
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intended redpient. If you have received this transmission in em;r, any use. reproduction or dissemination of this transmission is
strictly
From: Allen Price

Sent: Tuesday, May 15, 2018 7:37 PM
I can always pick her up and drop her off on Tuesdays.

4
P (425) 265-9100 C (425) 345-6384 F (425) 265-9300
APPLY ONLINE NOW!

CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail
message and any attachments are confidential and are solely
for addressee. The information may also be legally privileged. This
transmission is sent in trust, for the sole purpose of delivery to the
intended recipient. If you have received this transmission in error, any
use, reproduction or dissemination of this transmission is strictly
prohibited. If you are not the intended recipient, please immediately
notify the sender and delete this message.

Sent: Tuesday, May 15, 2018 7:11:59 PM
To: Allen Price
She is tentatively signed up for Monday at 5:30 be it doesn't conflict w

Alexs drivers ed. I'm planning to call tmrw to find out which other
classes are open. ideally i'd like her to do 2 per week.
Sally
Sent from my iPhone
>On May 15, 2018, at 6:31 PM, Allen Price <aprice@leaderl.com>

wrote:
>
>Good to know thank you. I knew she would love it. What days are you
committed to?
>
>
> P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
> E: APrice@Leaderl.com Read my Reviews! Check out my
website!
> Check out my Reverse Website! What We Believe
>
> 1604 Hewitt Ave Suite 401- Everett, WA 98201
>CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail
>for addressee. The information may also be legally privileged. This
> intended recipient. If you have received this transmission in error, any
5
> prohibited. If you are not the intended recipient, please immediately
>
>
>-----Original Message-----
> From: Sally Price <sallyjprice@me.com>
> Sent: Tuesday, May 15, 2018 6:28 PM
>To: Allen Price <aprice@leaderl.com>
>Subject: Re: Gymnastics
>
>We went to do a trial class last night. She loved it. Monday night at
5:30 has room for her. I'd like to sign her up for that. I didn't have a
chance to ask about other days/times be that place was packed .... they
said we could add another day anytime before we attend our first paid
class.
>
>Sally
>
> Sent from my iPhone
>
» On May 15, 2018, at 5:48 PM, Allen Price <aprice@leaderl.com>
wrote:
>>
»Did you end up setting this up? I have not heard anything.
>>
>>
» P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
» E: APrice@Leaderl.com Read my Reviews! Check out my
website!
»Check out my Reverse Website! What We Believe
>>
» 1604 Hewitt Ave Suite 401- Everett, WA 98201
»CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-
mail
» message and any attachments are confidential and are solely for
»addressee. The information may also be legally privileged. This
»transmission is sent in trust, for the sole purpose of delivery to the
>>
>>
»-----Original Message-----
» ~rom: Sally Price <sallyjprice@me.com>
»Sent: Thursday, May 3, 2018 1:23 PM
»To: Allen Price <aprice@leaderl.com>
»Subject: Gymnastics
>>
»Just heard back from gymnastics for Madison.
6
>>
» Rising Stars Gymnastics
» http://risingstarsgymnastics.com
» 360-653-7827
»They have 5 year old classes on Monday through Thursday at 4:30,
5:30 and 6:30 and on Saturdays at 9 and 10. I was thinking we could sign
her up for twice a week. Parents decide which day(s) and how many
times per week and that determines the monthly cost.
Total Control Panel
To: sabrinal@brewelaw.com Remove this sender from my allow list

7
1
17-3-02497-31
FNDCLRP 55 ..
2 Financial Declaration of Pet1t1oner 10'8 HAY 23 PM If: IG
3
4
l1\1i1 1 ~1 1 1 1 1 1 1 1 1 1 1 1 1 . SONYA KHASKI
COUNTY CLERK
SNOP.~M!SH CO. WASH
6
7 In re:
Petitioner:
8 No. 17-3-02497-31
SALLY PRICE
And Respondent: Name: Sally Price
10 (FNDCLR)
CHARLES PRICE, JR
11
14 Name: Sally Price
The highest year of education completed: 16
15 Your job/profession is: Stay-at-home mom
16 [ ] Yes. List the date you were hired (month I year): 2009
[X] No. List the last date you worked (month I year):
18
20 Com lete this section after fillin out the rest of this form.
21
22 4. Total Monthl Expenses+ Pa ments for Other Debts (add line 2 and line 3) $15,793.20
23 [ Gross Monthly Income of Other -Parfy- (copy_fr_;o_m_s_e_ct_io_n_3_._A~.) _ _ _ _ _~-__

$3_4~,7_0_0_.2_-(f]~
24

FL All Family 131
0Rtt3\NAL Everett, WA 98208
425.252.5167
Fami\ySoft FormPAK PL 2017

1 3. Income
3
4 Monthly income= Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
5 A. Gross Monthly Income (before taxes, deductions or retirement contributions)

Sally Charles
6
Imputed income - -
7 Monthly wage I salary $9,000.00 $34,700.20
Income from Interest and dividend Income - -
8
Income from business - -
9 Spousal support I maintenance received - -
(Paid by: )
10 Other Income $7, 125.00 -
11 Total Gross Monthly Income (add all lines above) $16,125.00 $34,700.20
Total gross income for this year before deductions - -
12 (starting January 1 of this year until now)
13 B. Monthly Deductions
Sally Charles
14
Income taxes (federal and state) $2,538.16 $9,769.19
15 FICA (Soc.Sec.+ Medicare) or self-employment taxes $897.21 $1,328.85
State Industrial Insurance (Workers' Comp.) - -
16
Mandatory union or professional dues - -
17 Mandatory pension plan payments - -
Voluntary retirement contributions (up to the limit in RCW - $416.67
18 26.19.071 (5)(Q)}
19
Soousal suooort I maintenance paid - -
Normal business expenses - -
20 Total Monthly Deductions (add all lines above) $3 435.37 $11 514.71
21 Sally
C. Monthly Net Income Charles
22 1. Total Gross Monthly Income (from A above) $16,125.00 $34,700.20
2. Total Monthly Deductions (from B above) $3,435.37 $11,514.71
23 3. Net Monthly Income (Line 1 minus Line 2) $12,689.63 $23,185.49
24

Everett, WA 98208
425.252.5167

Monthly income= Weekly x 4.3 or 2-week x 2.15 or Twice a month x 2
3
4
A. Other Income (Do not reoeat income vou alreadv listed on oaae 2.)
5 Sally Charles
6
Child suooort received from other relationships - -
Other Income From: ( ) - -
7 Other Income From: ( ) - -
8 Total Other Income (add all lines above) - -
9
B. Household Income (Monthlv income of other adults livina in the home)
10 Sallv's Home Charles's Home
11 Other adult's gross income - -
Name: ( )
12
13 Name: ( )
14 I Total Household Income of other adults in the home

(add all lines above)
- -
1
15 5. Disputed Income - If you disagree with the other party's statements about anyone's
income, explain why the other party's statements are not correct, and your statements are
16 correct:
17
6. Available Assets
18
List vour liauid assets. like cash. stocks bonds that can be easilv cashed.
19
Cash on hand and money in all checking & savings accounts (taxes to be $14, 129.87
20 paid soon)
Stocks, bonds, CDs and other liquid financial accounts -
21
Cash value of life insurance -
22 Other liquid assets -
23 Total Available Assets (add all lines above) $14,129.87
24

FL All Family 131 p. 3 of 6
Everett, WA 98208
425.252.5167

1
3 children.
A. Housing Expenses F. Transportation Expenses
4 Rent I Mortgage Payment (Family home= $2,684.00 Automobile payment (loan or lease) -
$550.00. Stanwood rental - $2134.05)
5 Property Tax (Family home= $485.91. $1,269.99 Auto insurance, license, registration $150.00
Marysville rental= $190.70. Stanwood
6 rental= $550.57. Cabins= $42.82.)
Homeowner's Insurance (Family home) $140.33'Gas and auto maintenance $456.00
7 Other mortgage (Marysville rental) $1, 100.00: Parking, tolls, public transportation -
Homeowner's Association dues or fees $67. 00 Other transportation expenses -
8 (Family home)
Total Housing Expenses $5 261.321 Total Transportation Expenses! $606.00
9
8. Utilities Expenses G. Personal Expenses (not children's)
10 Electricity/heating (Family home = $332.00) $332.00 Clothes $150.00
Water, sewer, garbage (Family home= $1,065.00 Hair care, personal care $260.00
11 $165; Stanwood rental= $900.00)
Telephone(s) $170.00 Recreation, clubs, gifts $210.00
12 Cable, Internet $200.00 Education, books, magazines $117.00
Other (specify): Pest control ($55) $115.00 Other Personal Expenses $166.67
13
ADT ($60)
14 Total Utilities Expenses $1 882.001 Total Personal Expenses! $903.67
15 c. Food and Household Expenses H. Other Expenses)

Groceries for(# of people) 4: $800.00 Life insurance (not deducted from pay) $40.00
16 Household supplies (cleaning, paper, pets) $330.00 Other (specify): House cleaner $303.33
Eating out $250.00 Other (specify): Yard maint $400.00
17 Other (specify): School lunches $180.00 Other (specify) Synchrony Bank $73.00
(mattress):
18 Total Food and Household Expenses $1.560.ool Total Personal Expenses! $816.33
19 D. Children's Expenses .List all Total Expenses from above:
Childcare, babysitting $150. 00 A Total Housing Expenses $5,261.32
20 Clothes, diapers $200.00 B. Total Utilities Expenses $1,882.00
Tuition, after-school programs, lessons - C. Total Food and Household Expenses $1,560.00
21 Other expenses for children $150.00 D. Total Children's Expenses $500.00
Total Children's Expenses $500.00IE. Total Health Care Expenses $475.42
22
.F. Total Transportation Expenses $606.00
23 E. Health Care Expenses :G. Total Personal Expenses $903.67
Insurance premium (health, vision, dental) - H. Total Other Expenses $816.33
24 Health, vision, dental, orthodontia, mental
$137.92 I. All Total Expenses (add A- H above) $12,004.74
health expense not covered by insurance
Everett, WA 98208
425.252.5167

1 Other health expenses not covered by $337.50. Use section 11 below to explain any unusual expenses,
insurance or attach additional pages.
2 Total Health Care Expenses $475.421
3
8. Debts included in Monthly Expenses listed in section 7 above
4 Debt for what expense Who do you owe Amount you owe Last Monthly
(mortgage, car loan, etc.) (Name of creditor) this creditor now Payment made
5 Family home LOC Union Bank $132,033.00 April
Marysville rental Julie Langabeer - April
6 Stanwood rental Julie Langabeer -
Mattress Synchrony Bank/Mattress Firm $3,969.20 April
7
9. Monthly payments for other debts (not included in expenses listed in section 7)
8 Describe Debt Who do you owe Amount you owe Last Monthly Payment
(credit card, loan, etc.) (Name of creditor this creditor now (Date and Amount
9 Credit card Wayfair $963.05 March $200.00
Credit card Bank of America/Alaska Air $10,344.22 April $1,000.00
10 Credit card Barclay/Hawaiian Air $5, 196.11 April $1,200.00
Credit card Synchrony Bank/Athleta $3,670.15 April $1,000.00
11 Credit card Citibank $4,940.20 April $75.00
Credit card Sears $2,445.89 March $313.46
12 Total Monthly Payments for Debts $3 788.46
13
10. Explanation of expenses or debts (if any needed):
14
15
11. Lawyer Fees
16 List your total lawyer fees and costs for this case as of today.
Source of the money you used to pay these fees and costs:
17 Amount paid $ii?, ZJ'c.l..i;j Savinqs/borrowed/credit cards
Describe your agreement with your lawyer to pay your fees and
18 Amount still owed $t:z.,~cs;. ~ costs:
19 Monthly payments
Total Fees/Costs $t8';1~.3Y-
20
21 I declare under penalty of perjury under the laws of the state of Washington that the facts I
have provided on this form are true.
22
Signed at (city and state): [v.ef.Lt£;- \A/A 1 Date: .'?I2:_i.//r6
23
~Q~
~
Sigtfhere
~ ' ~~S~~t~i
Print name tJ~P~r1~·c_0~~
24

FL All Family 131 p. s of 6
Everett, WA 98208
425.252.5167

1
2
3 local court rules. These records may include:
• Personal Income Tax Returns • Partnership or Corporate Income Tax Returns
4 • Pay stubs • Other financial records
5 Important! Do not attach financial records to this form. Financial records should be served on the other party and
filed with the court separately using the Sealed Financial Source Documents cover sheet (FL All Family 011 ). If filed
6 separately using the cover sheet, the records will be sealed to protect your privacy (although they will be available to
all parties and lawyers in this case, court personnel and certain state agencies and boards.) See GR 22(c)(2).
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Everett, WA 98208
425.252.5167

·Ff LEO
2618 MAY 23 PM 11: f 6
17-3-02497-31
1 NTC 56
So ,4i'VA
>M
·K:::u, <;:vi
l\h.,;;r11
Note for Calendar
3177986 COUNTY CLERK
2 .SHOH~HIS/i CO. WASH
111111m1mu1111111111111111111
3

6
7
SALLY JO PRICE, CALENDAR NOTE: (NTC)
8 FAMILY LAW MOTIONS
Petitioner,
9
and
10
11
Respondent.
12
13
Unless otherwise provided by applicable rule or statute, this form and the motion must be filed with the Clerk not less than
twelve (12) calendar days preceding the date requested. Responses to motion must be filed five (5) court days before the
14 hearing. Replies to responses must be filed three (3) court days before the hearing.
15
FAMILY LAW/DOMESTIC CALENDAR Date Requested: (mmldd/yyyy): 0610512018
Monday through Friday @ 9:00 a.m.
16 Department B or C as assigned. Nature of Hearing: Motion for Communication
through App and for Attorney's Fees
17 *Department assignment will be posted the day of the
hearing (Confirm hearing at 425-388-3587 or online at
18 www.snohomishcountywa.gov/Confirmations)
PRO SE DISSOLUTION CALENDAR Date Requested: (mmldd/yyyy)

19 Wednesday at 12:30 p.m. only
Department C **No confirmation required**
20
Agreed Matters and Default Orders only
21
INTERPRETER CALENDAR Date Requested: (mmldd/yyyy)
22 Tuesday at 9:00 a.m. in Department D

Attorneys at Law
24
~pARNOTE-1
ORIGlNAL P.O. Box488
(425j 252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
1 Friday @ 1:00 p.m. in Department D Nature of Hearing: _
If appearing Pro Se, interpreters are arranged through (Confirm hearing at 425-388-3587 or online at
2
Court Administration. Please call 425-388-3421. www.snohomishcountywa.gov/Confirmations)
3 Language needed: _ _ _ _ _ _ _ _ _ _ __
4 NOTE: When picking a hearing date, DO NOT schedule your hearing for a court holiday. A list of court holidays can be
found at http://www.snohomishcountywa.gov/354/County-Holidays
5 If noting a presentation, or if a particular Court Commissioner has already heard a recent motion in the matter, please
indicate that Court Commissioner's name here: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
6 WARNING! CONFIRMATION REQUIRED: In order for the matter to be heard, the moving party MUST CONFIRM
their motion two (2) court days prior to the hearing BEFORE 12:00 noon by calling 425-388-3587 or online at
7 www.snohomishcountywa.gov/Confirmations For additional information see confirmations notes on page 2.
Failure to notify the Court of a continuance or strike may result in sanctions and/or terms. SCLCR 7.
8
This form cannot be used for trial settings. SCLMAR 2.1 SCLCR 40(b).
9 CERTIFICATE OF SERVICE BY MAIL: Noted by:

I hereby certify that a copy of this document and all BREWE LAYMAN, ATTORNEYS AT LAW
other documents listed on page 3 have been mailed to A Professional Services Corporation
10 the attorneys/parties listed on page 3, postage prepaid on
11
the 4 day ofM , 2018.
§abllna A. Layman, WSBA 25260--

12
Attomey for Petitioner
13 WHERE TO NOTE VARIOUS MATTERS:

14 on line at www .snohomishcountywa.gov/I 354/Administrative-Orders
15 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
16 these motions.
EXTENDED MOTIONS BEFORE A COMMISSIONER: Extended motions are set by the Court Commissioner only,
17 not by a party or by counsel.
CONFIRMATION NOTES: All matters set on the Judge's Civil Motion Calendar, Presiding Judge's Motion Calendar or
18 Court Commissioner Calendars must be confirmed not later than 12:00 noon two (2) court days prior to the hearing.
Confirmations are accepted for a 24 hour period beginning at 12:01 p.m. three court days prior to the calendar hearing date.
When determining your confirmation deadline, do not count weekends or holidays. Confirmations can be made by calling
19 425-388-3587 or online at www.snohomishcountywa.gov/Confirmations.
20 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
21 information is available online at http://wa-snohomishcounty.civicplus.com/1338/Calendars-and-Schedules or by calling
Court Administration at 425-388-3421.
22 Calendar Notes should be filed at: All Motions Heard At:
Snohomish County
Snohomish CoultJre R E W E l Ay M A N P . S .
23 Attorneys at Law
P.O. Box488
(425j 252-5167 Phone
~pARNOTE-2 (425 252-9055 Fax
www.brewelaw.com
1 Superior Court Clerk's Office Superior Court
3000 Rockefeller Ave MIS 605 3000 Rockefeller Ave
2
3
Name: Veronica Freitas 19405
WSBA#:
4 544 29th Ave. 206-328-7362
Address: Seattle, WA 98122 Phone# Ext.
5
Attorney for:
6 Respondent
7
List all documents emailed Calendar Note; Motion for Communication and Attorney's Fees; and
8 and mailed: Financial Declaration
10
11
12
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
(425j 252-5167 Phone
~pARNOTE-3 (425 252-9055 Fax
www.brewelaw.com
2
17-3-02497-31
3 AFRSP 57 SGl-i'rA r;Kli.SKi
Affidavit of Defendant Respondent
COUIHY CLEi<K
!1\~ l l l\l l l\l \l l l \l l\l II

4 SNOH8MJSH CO. WASH
7
County of Snohomish
8
In re:
9

10
Petitioner,
Response to Motion for Attorney's
12 Fees and Communication
13 Res ondent.
14
My name is Charles Price and I am the Petitioner in this case. I am over the age of 18
15
16 and am competent to testify as a witness in this matter. I am writing this declaration in response
17 to Sally's motion seeking an order regarding how we communicate about the children and an
18
additional award of attorney's fees.
19
There was no need for Sally to file a motion regarding communication. I am happy to
20
agree to use whatever form of communication Sally prefers. I would appreciate having clear
21
22 boundaries around communication with Sally to protect me from the types of allegations she is
23 making in this motion. I began communicating through attorneys because Sally ignored my
24
email or text messages about some issues and instructed me to go through attorneys on other
25
issues, or her attorney accused me of threatening Sally when I was not being threatening.
26
27
28

Page 1 of9 (206) 328-7362
v@vfreitaslaw.com
Meanwhile Sally would call, email or text me about issues and ask me why I am was going
2
through attorneys when we can resolve issues between us.
3
With respect to attorney's fees, Sally has been awarded $9,000 per month in family
4
support, which is more than half of my monthly income (the $9,000 does not include $2,000 per
5
6 month that Sally receives from in rental income monthly). Sally's monthly expenses for the
7 family home are under $1,000 per month. Please see temporary order dated November 21, 2017
8
and order on revision (which reduced Sally's support from $12,000 to $9,000 per month) dated
9
December 12, 2017 attached hereto as Exhibit A. Sally acknowledged that my monthly income
10
11 was $17 ,821 in her declaration in support of her motion, however, in her financial declaration
12 she continue·s to falsely list my income at $34,700 per month. Sally has more available income
13
to use to pay her attorney's fees than I have available to pay mine. I do not understand, given
14
the income division, why she believes I have a greater ability to pay her attorney's fees.
15
Sally stated that I have access to funds via stock in my company and that I receiv
16
17 dividend income in addition to my income. I last received a dividend in 201 7 while Sally and
18 were still residing together. That dividend was $2,770. Please see 1099 attached at Exhibit B.
19
The Leader One Financial stock we own is not a source of funds for us. Leader One is a closel
20
held company, the stock is not publicly traded and can only be transferred to a certain group o
21
individuals. I do not receive any income besides my monthly income which was divided in th
22
23 temporary order.
24 We do have community property cash and investment accounts that can be accessed for
25
attorney's fees. We have $75,000 in a Key Bank account. I propose that we each receive a pre-
26
distribution from that account of $20,000 to use for our attorney's fees, or, alternatively, that we
27
28

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equally divide that account as a pre-distribution to each of us. Sally had withdrawn over
2
$10,500 from our community accounts prior to our temporary orders hearing, I presume for
3
attorney's fees. She was awarded an additional $5,000 for her attorney's fees at the temporary
4
5
orders hearing.
6 Response to Sally's Background Summary
7 I disagree with Sally's contention that I am pursuing a parenting investigation because I

8
am angry about financial aspects of this case. That is a false narrative her attorney has created to
9
prejudice me before this court and it does not make sense. We have a temporary support order
10
11
in place. I know that my child support obligation will not change regardless of the residential
12 schedule and custody will not impact the division of our assets and liabilities.
13
Sally claims that she has had to expend additional fees to engage in ordinary discovery.
14
I have-provided all of the financial documentation that Sally has requested from me in that
15
process. I have no idea what documents Sally is referring to when she states that she is still
16
17 waiting for additional items from me. I believe that Sally is wasting her own funds by hiring a
18 valuation expert to value a business that I do not own. I am a very minority shareholder in
19
Leader One Financial, I own less than 3.5% of the company's stock. I only receive W2 income
20
from the company. My attorney has conveyed this information to Sally's attorney several times
21
but Sally persists in seeking to value the business instead of valuing the stock we own. The
22
23 value of the stock is easily determined by looking at recent sales of stock.
24 There have been changes with respect to the children's situation since the temporary
25
orders were entered despite Sally's assertion otherwise. Please see my motion asking this court
26
to appoint a parenting evaluator or GAL that I filed several weeks before Sally filed this motion.
27
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My declaration describes the changes that have occurred since the temporary orders were
2
entered, specifically Alex's struggles and all three children's confusion with Sally.'s
3
significantly changed demeanor toward parenting the children. This court is hearing my motion
4
to appoint a GAL at the same time as this motion. I incorporate my declaration in support of
5
6 that motion into this response by reference.
7 Response to Sallv 's False Narrative re Parenting

8
I am not seeking a GAL to hurt Sally. I always hoped to have an equal residential
9
schedule with the children. Sally and I were discussing a 50/50 residential schedule when we
10
11
discussed separating. I was initially going to buy a house in the same neighborhood as our
12 family home. I needed to make the purchase before Sally filed for this dissolution so that I could
13
qualify for a loan. I planned to live close by Sally's home and be equally involved in parenting.
14
Please see a note that Sally wrote where she summarizes my proposed purchase of a house in
15
our neighborhood and she notes 50150 parenting? at Exhibit C. When Sally and I told the boys
16
17 about the divorce, Alex said he wanted to spend equal time with both of us. See Sally's notes
18 summarizing that meeting attached at Exhibit D. I do not agree with Sally's description of me
19
screaming that she was a liar during that conversation, however, she did accurately record
20
Alex's comments.
21
I agreed to the temporary residential schedule at the temporary orders hearing on the
22
23 advice of my attorney at that time and with the expectation that it was a temporary residential
24 schedule. I hoped that Sally and I would be able to be reasonable about parenting once we had
25
physically separated and were operating separately. I expected that we would be able to agree
26
to me having significantly more residential time than I currently do in the temporary parenting
27
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plan. Now that I have seen what has been happening with the children since we separated, I am
2
confident that an equal residential schedule is in the children's best interests. I am not motivated
3
at all by financial matters.
4
5
I never made any demands of Sally. I tried to reach agreements with Sally regarding
6 parenting. When we reached an impasse, I asked Sally to agree to a parenting evaluator. When
7 Sally told me that her attorney was working on a proposed parenting plan, I told Sally that was a
8
not willing to move from the proposal that my attorney sent over and that if she was not willing
9
to agree to that proposal, we should just proceed with the parenting evaluation. I was not
10
11 threatening when I made that statement. I was just talking about my position. Sally attributes a
12 comment to me in her declaration. Here is what I actually said to Sally about her pending
13
proposal, "I don't know about the time, but I would put the offer on the table. I don't think it
14
will be worked out anyway so not sure how much money you want to put into the details at this
15
point."
16
17 Sally's current narrative about my "new" interest in parenting is not accurate or fair.
18 have always been very involved in our children's lives. I coached football at Arlington Boys an
19
Girls Club, and at Lakewood Youth Football for seven years; I attended all of the children'
20
school events and extracurricular activities. I attended the children's parent teacher conferences
21
transported them to tutoring and events, and I assisted with their home work. I also spent qualit
22
23 time with them. I did this despite my working long hours every week. The one thing Sally di
24 that I did not do was take the children to their routine medical appointments because she wa
25
home during the day while I worked. Please see the letter Sally wrote to me in September 201
26
where she describes my involvement with the children attached at Exhibit E.
27
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What Sally ignores in her narrative is that I had a massive heart attack on April 19, 2017
2
which profoundly changed my work life. Before my heart attack, I had been working 6 days
3
week, up to 12 hours a day and I was on call 7 days a week. After my heart attack, I put m
4
5
health and parenting as my number one priority. I now work a regular 40-hour week. My wor
6 schedule is flexible so I now have time to volunteer at my daughter's school. See note Sall
7 wrote confirming that I asked about volunteering in Maddie's school in October, 2017, attache
8
at Exhibit F.
9
Sally talks about our settlement negotiations, which I understood were not proper t
10
11 discuss in court pleadings, and she references my request to have the children 50/50 during th
12 summer months. Sally asserts that I am acting in bad faith because she has summers off. This i
13
another unfair example from Sally because Sally stated in her interrogatory responses that sh
14
was not planning to return to teaching and was going to pursue a different career, which
15
assumed meant she would be working during the summers herself. Sally has since changed he
16
17 response to her interrogatory answers and now states that she intends to return to teaching. Sh
18 only did that after her attorney argued that Sally had summers off and my attorney pointed ou
19
Sally's interrogatory responses saying that Sally would not be returning to teaching.
20
Either way, I have the ability to work from home, which is what I intend to do in th
21
22
summers. I do not believe that seeking a 50/50 residential schedule during the summer is ba
23 faith even if Sally had a job where she has summers off. I know that the children need more tim
24 with me. I _thought Sally might find it more palatable to have an equal residential schedul
25
during the summer than the school year given her other comments on the subject.
26
Response to Sally's allegations that I have misused her funds by increasing her attorney's fees.
27
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Sally accuses me of increasing her attorney's fees because I have asked her to inform me
2
of the children's medical appointments, etc. Sally argues that she always took the children to
3
routine medical appointments during the marriage. Sally ignores that things have changed since
4
5
Sally and I separated. Yes, she did take the children to their medical appointments when were
6 married, but she also told me about everything that happened with the children when I came
7 home after work and she consulted me about decisions during the day. Now, she tells me
8
nothing and informs me about nothing. All I have asked for from Sally is notice so that I may
9
attend if I am able and so I know what is happening. Sally refused to acknowledge my request
10
11 and continued to fail provide notice so I was forced to have my attorney follow up with Sally's
12 attorney. If Sally would have communicated simple information there would not have been any
13
need for me to involve my attorney. Sally's lack of communication required me to incur
14
unnecessary attorney's fees. It is clear that Sally does not believe I need to be informed or
15
involved in the children's medical issues.
16
17 Sally complains that I have requested a walk through of the family home. I was
18 permitted to take exactly 58 items from the home when I left. Please see letter from Sally's
19
attorney stating that I was not permitted to remove items absent an agreement in writing,
20
attached at Exhibit G. Sally's interrogatories required me to make a very detailed list of
21
property items that I took from the home. I spent a lot of time on that response and worked very
22
23 hard on my interrogatory responses in general. I was looking forward to Sally's interrogatory
24 responses and detailed list of our community property so that I could use her list to determine
25
what items I wanted from the home. Sally did not spend time making a detailed list, which was
26
disappointing and it did not feel fair given how hard I had worked on my response to her
27
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interrogatories. Sally failed to include many of our community property items in her list. That
2
is why I requested a walk through.
3
I never demanded that Sally scan me the children's homework, etc. on a daily basis. I
4
5
intended to simply request that Sally provide me with copies of documents re field trips, etc.
6 that are only sent home with the children and not communicated in any other way, when she
7 receives such information. I thought she could send it over once a week. I also mentioned that it
8
would be nice if she would send me some of Maddie's work for me to display at my house. My
9
information is on file with the children's schools and I receive everything that is mailed home,
10
11 but there is a significant amount of information that is communicated to parents only by sending
12 papers home with the children. Sally responded to that my request by saying she was not going
13
to respond, so my attorney needed to follow up with her attorney. Sally could have responded
14
to me with her thoughts, etc. I had to expend attorney's fees to address this issue through
15
counsel.
16
17 Sally did not provide me the necessary information for me to submit our income
18 information for our tax return~ This was frustrating because we heed to have accurate, current
19
income information for this court and for mediation so we can resolve this case. Sally
20
represented to this court that she managed the rental property, which was not accurate. I had
21
historically handled all of the financial matters related to the rental properties. Sally's false
22
23 representations to the court resulted in us not being able to file our income taxes on time. I was
24 trying to make that point when I made the comment about her receiving the rental income.
25
Sally's excuse for not providing the income information is that she is too busy. She said the
26
same thing about her incomplete interrogatory responses, but I am expected to provide detailed
27
28

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information to her attorney on demand and I am working full time. I feel that there is a double
2
standard being applied to me by Sally's attorney.
3
I am pursuing a parenting investigation for what I believe are legitimate reasons which I
4
5
described in my motion seeking the appointment of a GAL. I do not agree that I am making
6 threats to Sally to get her acquiesce to my demands. I am pursuing what I believe is appropriate
7 in this dissolution. Sally and I have different communication styles. I have tried to work with
8
her directly and I have tried to work with her through attorneys. I agree to use a communication
9
tool. It feels to me like the problem is not my communication but the fact that Sally does not
10
11
want to have to include me in decisions about the children and she does not want to have to
12 provide timely responses to appropriate inquires or requests for documentation.

13
I have had to expend attorney's fees for basic communication with Sally. I was forced to
14
expend attorney's fees to schedule my summer vacation with the boys because Sally is non-
15
responsive and because she did not recall the current orders which required several exchanges
16
17 with attorneys for both summers.
19
20
21
22
23
24
25
26
27
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EXHIBIT A

I
1
2
FILED
NOV 2 r 2017
3 SONYA KRASKI
COUNTY ClERfi(
5 IN THE SUPERIOR COURT OF THE S.I.t\IE_OF WASHThlGION._ --·---- ··-- -··-

-- --------·-·-------JN AND FOR THE COUNTY OF SNOHOMISH
6
In re the Marriage of: Case No.: 17-3-02497-Jl
7
SALLY JOPRlCE, TEMPORARY FAMILY LAW ORDER
8
Petitioner,
9
and
10
11
Respondent.
12

15 0 No money judgment is ordered.

17
l Judgment for Debtor's name-T Credito~-;·5-1 Amount -, 1;.t~res - I
j . (person who must l name (person ! Ji I
~=-~-t:~::Jf~~-~J
18
19
20 ~- _____l_ ~·y--.-~1~-=j
21 l.
Yea!!f Int~-~~!t Rate:
Lawyer (n'!!lle)_:
o 12%unl~.§. otherwiselisted) ··----·-·-----
re resents (name): • .--~------__:)
I
22. l_1awye!.(name)~--- - __-.______ ·-.--' represents (namel_~----~-~-- . __J

___
BREWE LAYMAN P.S.
23 ttwneys at Law
iox488
24 . ffit~ Washington 98206-0488 ___..,_
(425)252-5167 Phone
l'~Mf~Y FAMILY LAW ORDER - 1 (425) 252-9055 Fax
www.brewelaw.com
1 2. Findings
5
(!'he federal Servicemembers Civil ReliefAct covers: ______________________ ... _
· ·----- -------------.----Army, Navy, 7ffrForce, Marine Corps, and Coast Guard members on active duty,'
6
row; and
• commissioned corps ofthe Public Health Service and NOAA.
7
8
10
);;> The Court Orders
11
4. Care of children
12
13
14
15
state.
18
Petitioner and Respondent shall be and hereby are restrained and eajoined from
21
22

Attorneys at Law
P.O. Box488
24 Everette. Washington 98206-0488
(425) 2:J2-5167 Phone
liMf:QRARY FAMILY LAW ORDER - 2 (425) 252-9055 Fax
www.brewelaw.com
1 5. Provide support
2 The eetll't sigtted the temporary Child Sttppm'f 0,·-der and W~rk&heets aled separaool~
l.M'\Mfr~A~A
3 The Respondent must pay4o.usal support to his spouse.
-"" t>C.
~ 11-, bl>D ._...
4 Amount: $ _ _ per month. 'b~ c=~ ..1 } 2° I '"J _
~ )tt: I I. &tot?
I i I -h.... \
5 Date 1st Pl!Yl11~f!1 _i~ dµ~_____ ,__Qa.y Q.fth~_:m_m1th_ e.a.c.h_p_aymenJ:js_ due _ '!- -~·- ·- .___ ~. _ _ .; --
112 IV\ :?J fl- .
Jkthe other spouse/domestic partner. ~ ~oslf ~
7 [] Washington State Child Support Registry (available if_c · ~ort is
8 {)}IL.{ M/ ;{1vJc..
6. Family home u:ii.,......{~ wit!<:: 'buu............
9
Stay in the home - The Petitioner may stay in the family homfud r~~us~he
ha,y \fV'l.NLA ~+.
11
/
18 vehicle/s: 2012 Audi QS.
20
8. Protect property
21
Attorneys at Law
P.O. Box488
24 {425) 252-5167 Phone
m~~y FAMILY LAW ORDER- 3 {425) 252-9055 Fax
www.brewelaw.com
1
3 consent.
to pay for basic needs. Both spouses/domestic partners must notify the other about
5
of
-any-expenses thafare«:>tit the-ordinary. -- --- - - - --- -- - ---- -- -- - - --- - --- ---- --
6
10- mortgaging, giving away, destroying, moving, hiding, disposing of, or otherwise
accounts.
12
of life.
15
18
20
21
business entity, or disposing, selling, pledging, transferring, mortgaging, conveying,
23 I BREWE LAYMAN
Attorneys at Law
P.O. Box488
P.S.

(425! 252-5167 Phone
I~~~y FAMILY LAW ORDER - 4 (425 252-9055 Fax
www.brewelaw.com
I
3
9. Household expenses '"P~2s7 J?-h /
11
4
5
-[~xp-;nse-=:~~-=- -·- ~--=~~-~~~-~:~~::_::~~=-=-'.~~--=::--=:_-::·=:=~~-=:~~~
I I
.
-~~~:-~-=--~J W~ifiliotiid_i~i_~~~---~--1
I
,.?) · · ·
\ c-.i \
6 ! First Mo~g~~g~ on family home ---···-..H·-···-- .L Petitiol!~~--··----------------·~----1 -.. . . . .

l Mortgage and utilities on _r.~!?-!~_lpropef!Y in !v!__~il!~------.JR~!itiop.er._____________ J
i Mort_g~_g_~--~d_ utilit~s on rental prope!!J_i!!__~-!~w~od ______ ! Pet!_tio~_!______________,_____ I _
7
l Utiliti~s on family hol!!~----··-·----------------J_P~!i!ioner A-~1---~-- ;1 OL-l CL ·
\ Child Care l Proportionate share
=.,.,...+ ~Lls
8 I Other: Petitioner shali be responsible fur-hlsfh~r own___ TI>etitioner________________ --------L ~ t, l
l_house}_!_old exp_~nses not above specifie4.:__________________J__,_________________,____ . .1,"'-"-"'-V
9 I Other: Respondent shall be responsible for his/her own i Respondent
I househol4~~P~!1_Se§ not above specifie~..:____________________J ____,
10
11 r~ specific designati9ns set forth_ above. ·-p-e,,+l-ho-v~ s~ill ..A-e_~V\.A/e.... ~........ <... ,\
phuY\£... t--Jf1vut. (le.~ '"'--"UL~ (.'Ve......_ • ~ ~-l- 'S ~et..V.. .c.'-'~<-k -{t:l ~ - te p lP'\.SC
12 10. Divide debts ~<A...;-t p~ lf\..L"-""'~'... · ·-p~-tl-l--'\IY'-"--dl- ~ ~ p..-L..+ ve..
A'bl, Ni.-ftl\'K-, b\t'e.t.--f--N ~h ~
13 The Petitioner and Respondent must: c.r, t=-a....vt c ~\. • , ~ .,,.__.~....:.-}- -h\ c.-·iL--"-,.,.._....,...
LO \ ~ ·-l...--L"\--<-&-- ·
15
16
I~eht (describe)________________=:==~~~=~=~=-~=-~-=-~1 Who-silouidpai__________
17 LL. Juli~ L~gabeer ·-·-----··· I Petit!on~~------------- ______ _
19
liable.
21
P. s.
23 IBREW E LAYMAN
Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
l'~Mf~RY FAMILY LAW ORDER - 5 (425 252-9055 Fax
www.brewelaw.com
1
2
5 Pay premiums
.. ··- ·--
.
as follows:
--
-·· .. ·-·· ...... .. .
[i>oli~L--=====~-=-=:·-·-·----- -----·-·-----------J ----------------=~=

wlio-iiais-
crl
6
'. 1. Medical ------..·--·---------·-----------..:.IJ.~~~ond.5?_nt _________________
7 i 2~-D~_g_!~L___ -----------..-------·------ LRespo1_1~~~L_______________
! 3. Optical _________________..__ ____. ________ . ______ ! Respondent___________________..___
8 L4.:9rthodontia -·---------------· ____ LB~-~p_Q_~ent ________
[J. AutOB!Q~g~----------- __________, ________ _j__Respond~_!lj__________________ _
9
10
. [] Reql1estres~ b
i::;tt>DD.-
&>0
~
I. /:;o} l
11
·g:, The Respondent must pay the other party's lawyer fees. Amount: $ . Make
12 payments to _ _(name) by _ _(date).
v;.,-,;v.J\.f e_ ~ ~ ~ "f'. S.
13 Money Judgment
14 {] The amel:lfltls listed abo 1e must be paid; bnt the cocu't is not enteriftg a a:ioney_
1
judgment at tms tim~

15
'fJ/--Tue amount/s listed above shall be entered as a money judgment. (Summarize
the money judgment in section 1 above). The interest rate is 12% wliess angther
16
amount j5 listed here [] Tho interest rate is % because ~t /
17 OOOcr: ~ ~~
20 No request made.
22

Attorneys at Law
P.O. Box488
24 (425} 252-5167 Phone
1jb!f;QRARY FAMILY LAW ORDER - 6 (425) 252-9055 Fax ·
www.brewelaw.com
------ -----------------
2

s o~~lJ:,....~k.c"';:~~°' --le> ~if ~ .,.~,..,_..rs ,,,- ~ ,,,~.;,.,,
6
DONE IN OPEN COURT this~f 4y ofNovember, 2017. (IJ)
7

11

Attorneys at Law
13
14

~
J.Pri~
18
19 Chru;les
...,, A. Price, Jr.,./
20
21
22

Attorneys at Law
P.O. Box488
l'!GM.f;QRARY FAMILY LAW ORDER - 7 !

425j 252-S167 Phone
425 252-9055 Fax
www.brewelaw.com
PLAINTIFF I PETITIONER
and
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DEFENDANT/RESPONDENT
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. ,.~ ..(_, c( .1 •. .1ro'\:1c,1 'r\p,~ _ ,_,_Ji\.,\~, (en \Jr ·\u.~ of\
,.,({ v\
DONE IN OPEN COURT this date: _ _ _ _ _ _ _ _ _ __
Presented By:
///
I JUDGE I COURT COMMISSIONER
Copy ReceJed: /
6101 page I o{h

/;; ' 1084·4
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CaseName \\1(0. \).
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DONE IN OPEN COURT this date:

. l ' ~~N-:._,.::.-1,-;f-l_r,__
---T/'-",,_:::.,,.J
I , _ _ __
Presented By:
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JUDGE' I GQlJR=f.€8MMfS810NER''"
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EXHIBITB

I
FDWA1102L 04i11117 CORRECTED (if checked) f-
PAYER'S name, street address, city or town, state or province, country, ZIP or 1a Total ordinary dividends OMB No. 1545-0110 l
foreign postal code, and telephone no.
I
Leader ·one Financial Corporation I
$ 2770.20 Dividends and I
1b Qualified dividends 2017 Distributions I
7500 College Blvd. Suite 1150 I
Overland Park, KS 66210 I
I
913.-747-4000 $ 2770. 20 Form 1099-DIV
I
2a Total capital gain distributions 2b Unrecap. Sec. 1250 gain I
CopyB I
For Recipient I
$ $ I
PAYER'S federal identification number RECIPIENTS identification number 2c Section 1202 gain 2d Collectibles (28%) gain I
I
I
I
48-1148159 533-86-7767 $ $
I
RECIPIENTS name, street address, city or town, state or province, country, and ZIP 3 Nondividend distributions Federal income tax withh d I
or foreign postal code
$ I
Charles Price This is important I
Investment expenses tax information I
$ and is being
1604 Hewitt Avenue, Ste 401
7
furnished to the
6 Foreign tax paid Foreign country or U.S. Internal Revenue
possession
Service. If you
Everett WA 98201
$
are required to
file a return, a
9 ~i~rrrgi3l101hiuidation negligence
8 ~fr7~1l,~~;tion penalty or other
$ $ sanction may be
FATCA filing 1 O Exempt-interest dividends 11 Specified private activity imposed on you ii
requirement bond interest dividends this income is
taxable and the
$ $ IRS determines
that it has not
Account number (see instructions) 12 State 13 State ident~icat1or. no. 14 State tax withheld been reported.
$
------- ------------
$
Form 1099-DIV (keep for your records) Department of Treasury - Internal Revenue Service
EXHIBIT C

I
EXHIBITD

I
EXHIBIT E

I
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EXHIBIT F

I
544 29th Ave Seattle, Washington 98122 tel• {206)328-7362 lfax• (206)323-0404
EXHIBITG

Kenneth E. BreWe
BREW E LAY MA l\l P.S. Sabrina A. Laymall
Karen D. Moore
Attorneys at Law Rebecca J. Torgerson
Robert J.Miller
Kent R. Goodrich
Sara M. Epler
l<en Evans
November 8, 2017 Mediation Services
COPY VIA EMAIL & ORIGINAL MAILED
Robert Mal'
Goldberg & Jones PLLC
1200 Westlake Ave. N, Ste. 700
Seattle~ WA 98109
Re: Price Dissolution
Deru•·Robe1t
It is our understanding that Mr. Pl'ice is moving out of the family home this upcoming weekend
and is demanding he have access to certain furnishings, community personal pl'operty items, and
tools. Absent written agre.ement any disputed items need to remain in the family home pending
further agreement or comt order.
Additionally, please advise Mr. Price that Ms. Price does not agree to close any community
accounts associated with the family home at this time and we request that he refrain from
harassment.
Thank you.
Sincerely,
BREWE LAYMAN P.S.

Attorneys at La
Sabrina A. Layman
Attorney at Law
SAL/km
cc: Sally Price

P.O. Box 488
Everett, Washington 96206·0488
425.252.5167 EvereU
206.971.5555 Seattle
360.419.9191 MountVernon
425.252.9055 Fax:
brewelaw.com
ekOB2h1253
.. - ....
;-~ . ':""- .....__
201BMAY 29 AMII: 14
1
2 17-3-02497-31
RSP 58
Response
3189563
3
4 Ill Illlllllllllllllllllllllllllllllll Ill

6
7
SALLY JO PRICE, PETITIONER RESPONSE TO MOTION
8 TO APPOINT A GUARDIAN AD LITEM
Petitioner, OR PARENTING EVALUATOR
9
and
10
11
Respondent.
12
13 COMES NOW, Petitioner Sally Price, and declares under penalty of perjury under the
14 Laws of the State of Washington that the following is true and correct.
15 1. I am the Petitioner in this case. I am responding to the Motion filed by Charles
16 Allen Price (I will refer to him as Allen hereinafter), to appoint a Parenting Evaluator or Guardian
17 Ad Litem. Allen in his declaration indicates he is the Petitioner, which is not correct. Since his
18 proposed orders only use the terms petitioner and respondent I want to make sure the court is clear
19 on the designation. I do not agree that a guardian ad litem or parenting evaluator is warranted. If
20 the court does approve Allen's request, I do not agree that he should control how the evaluator is
21 appointed as he suggests in his motion. I believe Allen is only asking for this now as retaliation for
22 my requests to value the business.

BREWE LAYMAN P.S.
24 PETITIONER'S RESPONSE TO
{425j 252-5167 Phone
(425 252-9055 Fax
MOTION FOR EVALUATOR - 1 www.brewelaw.com
1 2. Procedural History. I filed the petition for divorce in October of2017. My motion
2 for temporary orders outlined the involvement that I had with the children and that Allen had with
3 the children prior to our separation. I am filing my declaration as a working copy along with all
4 the third party declarations that were also filed. I am doing that for the court's ease in review. In
5 response to my motion and proposed parenting plan, Allen filed a response and also a proposed
6 parenting plan indicating a schedule of every other weekend and a mid-week visit. Allen had
7 already moved out of the house by the time of the hearing. The first six pages of Allen's response
8 dealt with financial issues. His response is also filed as a working copy, but specifically Allen
9 stated under penalty of perjury as follows:
10 "I have no problem with her being the primary parent and collecting child support - I just
11 am asking that the court that I receive Thursday afternoon through Monday morning every
12 other week ... once a week dinner ... and equal time during the holidays and vacation .. .My
13 proposed parenting plan more closely resembles the time I actually have had."
14 Once I received Allen's proposal, I was able to agree to his requests and an Agreed Temporary
15 Parenting Plan entered. Allen knows that this agreed plan is in our children's best interests and
16 remains in our children's best interests. Allen did not seek an evaluator at that time.
17 On January 18, 2018, Allen submitted answers to my discovery requests, wherein I
18 specifically ask about parenting issues. Again, under penalty of perjury, similar to his declaration
19 ofNovember 3, 2017, Allen's answers are paraphrased/quoted below (the relevant pages are
20 attached hereto as Exhibit "1 "):
21 Do you contend the other parent's involvement may have an adverse effect on the children?
22 Answer:No
BREWE LAYMAN P.S.
P.O. Box488
24 PETITIONER'S RESPONSE TO (425j 252-5167 Phone
MOTION FOR EVALUATOR - 2 (425 252-9055 Fax
www.brewelaw.com
1 Any long term emotional or physical impairment, drugs alcohol, or other impairment?
2 Ans\¥er:No
3 Any use of alcohol or marijuana and is that a problem?
4 Ans\¥er: We both have drank and smoked marijuana but not a problem for either parent.
5 Describe your \¥eakness as a parent?
6 Ans\¥er: "I have not been doing the things Sally has been doing and I have learned a lot in a short
7 period of time. I have lots more to learn in my ne\¥ role \\Tith my children, but I am excited to be a
8 part of my children's life in some of the different \¥ays that I have not done before."
9 Describe the other parent's strengths as a parent.
10 Ans\¥er: "Sally is a wonderful parent I am not going to gloat but just to tell you she is a loving
11 mother and a responsible parent."
12 Describe the other parent's \¥eaknesses as a parent.
13 Ans\¥er: "Sally could be more patient ... she could let them make some mistakes ... she could \¥Ork
14 \¥ith Alex in a less confrontational \¥ay ... "
15 Allen's ne\¥ motion/declaration, signed on April 24, 2018, 90 days after he S\¥ore in
16 discovery that I \¥as a \¥onderful, loving and responsible parent and five months after \¥e entered
17 an Agreed Parenting Plan, is full of untrue statements and conjecture. It \¥as ONLY brought after I
18 asked for information to value the o\¥Ilership interest in Leader One, \¥hich he begrudgingly
19 submitted the last bits on April 30, 2018, after he filed his motion, see attached email Exhibit "2".
20 He refuses to even do a phone conference \\Tith the valuation expert, see attached email Exhibit "3"
21 making it my attorney have to jump through hoop after hoop to just simply get a handle on the
22 assets in this case. The present motion, \¥hich is not based on la\¥ or fact, is unnecessary and

Attorneys at Law
P.O. Box488
www.brewelaw.com
1 retaliatory. And, furthermore, it has the potential to be damaging to our children who do not
2 deserve to get sucked into an investigation, be forced into an interview or made to speak - our
3 youngest child is a kindergartner 5 years old) - who in their right mind wants to make a young
4 child like that feel like she has to speak up when just a few months ago her parents were in
5 agreement on the parenting arrangements? This is intended to simply hurt me and thus the
6 children as they get sucked into Allen's attempts to bully me. I am asking the court to deny his
7 requests.
8 3. Allegations. There is no change of circumstances or emotional instability. Allen's
9 allegations about my household are baseless. There is no need for this court to look any further
10 than Allen's own previously sworn statements that PREDATE my discovery requests. Allen needs
11 to support the Agreed Parenting Plan and stop putting our children into the middle.
12 Allen alleges that Alex and I do not speak. That's untrue. Alex and I are very close and we
13 are able to communicate. Is it always perfect? No, he is a 15 year old- we have our
14 disagreements. I presume that when Allen meant in his answers to discovery that my weakness as
15 a parent is that I need to let Alex make his own mistakes, that when Alex did make a mistake his
16 Dad would not blame that on me-and yet that's exactly what he's doing. Alex smoked marijuana
17 and got caught by disclosing it to his cousin. Allen and I dealt with it. That's how parents are
18 supposed to work.
19 I am not out nights leaving the children to fend for themselves. I continue to make dinner
20 for them as I did when Allen was at home. When Allen and I were married, I made dinner every
21 night for my family, as Allen stated. I am known in my circle for being a good cook: an amateur
22 chef. I am always there for my kids with very few exceptions. Once every 6 weeks or so I will
BREWE LAYMAN P.S.
P.O. Box488
MOTION FOR EVALUATOR - 4 !425j 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 have dinner with some friends and one weekend a year, I do scrapbooking. I have continued to
2 make dinner for my children because it is important to them and to me. Some nights, we might be
3 eating leftover casseroles or pizza, but I still make them dinner and make sure they are properly
4 fed. We sit down at the table together and talk about our day and what we are grateful for. Alex
5 has been harder to manage at dinner, as he wants to eat what he wants, doesn't always like what I
6 make, so I have been working with him to make what he'd enjoy at least a couple times a week and
7 do that with all of my children as a collaborative effort, to get them more involved and have a
8 v01ce.
9 Allen's statement about frequency of me being gone, which he is not living with me, has no
10 basis in fact. Since I filed for divorce on October 26, 2017, I have been gone in the evening TEN
11 times. For five of those evenings, I was required to attend a monthly parent meeting at our
12 daughter's school, Marysville Cooperative Education Partnership from 6:30-8pm (11/9/17,
13 12/14/17, 1/11/18, 4/12/18, 5/10/18). I left our son, Alex who is now 15, in charge as a babysitter
14 with Colby, our 11 year old to help out. Colby is extremely responsible as well. Every time I leave,
15 I make sure they have dinner made and ready to eat. I do not ever leave them to fend for
16 themselves, unless there is pizza in the fridge for them to reheat. Those allegations are completely
17 FALSE. The other FIVE times that I was gone (11/7/17, 12/5/17, 1/12/18, 3/6/18 and 4/10/18), I
18 was out for dinner with girlfriends for a couple hours. Only ONCE, on 1/12/18, was I out late yet I
19 checked on the kids frequently via phone. Every other time, I am home to put Madison to bed.
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
www.brewelaw.com
1 Circumstances have not changed. Dinners have not changed, helping children with
2 homework has not changed, bathing, bedtime, cleaning their rooms and chores have not changed. I
3 am managing as I always have, staying on top of3 children's activities, homework, all sorts of
4 appointments, chauffeuring, laundry, food, nurturing, trying to include fun activities like movies
5 together, board and card games. I have had some rough days dealing with legal paperwork,
6 interrogatories and allegations like this, but I do not drag my children into any of this. I try to keep
7 my chin up and know that I am only in control of me and need to always be there for my children
8 regardless of what I am going through.

9 Regarding Allen's allegations that I have taken an interest in witchcraft and spirits that too
10 is false. I have become certified to do Reiki I and II which is a therapeutic treatment. I have also
11 become an Ordained Minister. I do pray and I do meditate, but that is hardly suspect in anyone's
12 eyes. On occasion, I burn sage, candles and incense while meditating. I am a very spiritual person
13 and read lots of books on many related topics including spirituality-related topics, reading books
14 about Law of Attraction, Earth-based Religions, Buddhism, Angels, Christianity, Reiki, Energy
15 Healing, Healing from an Abusive Relationship, none of these books are endangering my children
16 in any way. If anything, we talk about love, gratitude and what it means to be a good friend and
17 person more often than before Allen left the house. Again, Allen is not in my home. Allen calling
18 my meditation "witchcraft" is belittling. Saying that my spirituality is some home sorcery is
19 degrading. I provided all of this information to Allen in my answers to interrogatories, Exhibit "3"
20 and then, when it was obvious that my earnings in those fields would not be sustainable income, I
21 updated my answers, Exhibit "4", to return to teaching. There is nothing that I am hiding.
22
BREWE LAYMAN P.S.
P.O. Box 488 .

24 PETITIONER'S RESPONSE TO (425l 252-5167 Phone
www.brewelaw.com
1 Neither Allen nor I have drug or alcohol issues. As Allen stated in his interrogatories, both
2 of us have used marijuana in the past and we are social drinkers but neither has a problem.
3 Although accurate that I bought a vape pen, that was several years ago when Allen and I were
4 together. I never actually used it much, just as Allen stated when he was being honest in his
5 interrogatories and frankly I forgot it was in the house. Allen alleges that Alex took my marijuana
6 vape pen. I do not believe this is true. I asked my son ifhe saw my vape pen or took it and he said
7 no. He only saw some packaging that he believes was for a marijuana vape pen.
8 Regardless, upon learning about Alex's experimentation with marijuana on 4-21-18, I have
9 removed my marijuana vape pen from my house and threw it away to not take any chances. I do
10 not want Alex using marijuana. I am perfectly fine not having one. The fact that we have a
11 teenage son, who experimented with marijuana and is depressed and saying be doesn't want
12 to live anymore, should not result in Allen placing blame on my household. I certainly do not
13 fault Allen for letting Alex go over to stay the night at the friend's house who was using marijuana
14 where Alex likely also experimented. What I did instead, when Allen called to tell me about the
15 situation, was go to Allen's house where we confronted our son together. And, afterwards, I spent
16 the last month trying like crazy to get Allen to agree to a therapist for our son, frankly finally
17 caving in on someone just to get started when Allen refused any of my proposed options. Allen's
18 decision to use Alex's experimentation with marijuana as some issue that I created is not
19 appropriate. The reality is, Alex is 15, his buddies experimented with marijuana and so did he.
20 Instead of seeing that he gets help, Allen files a motion, continues to degrade me and make
21 unreasonable demands and uses every opportunity to negate what would otherwise be best for Alex
22
BREWE LAYMAN P.S.
P.O. Box488
MOTION FOR EVALUATOR - 7 !425! 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 I have discussed marijuana usage with Alex and I know that Allen has as well. I explained
2 that I do not use it, although I have in the past, because it masks emotions and I need to feel my
3 emotions and move through them to process them. I explained that in addition to being illegal for
4 anyone under 21 years old, I want him to learn how to manage his feelings too without using a
5 substance as a crutch. Our son, Alex is receptive to counseling. It has taken weeks of going
6 through counselors, with Allen vetoing all my proposals until we finally have someone that Allen
7 will agree to Alex seeing.
8 I am very aware that Allen pressures all the kids about telling me they want to live with
9 Allen (this is his newest tactic) and all three of them feel like they are afraid to displease Allen, just
10 as I alleged in my initial declaration. Allen needs to let these children be and enjoy them for who
11 they are without the added pressure of making them feel like they are pawns.
12 Allen is correct when he says he's not around the children when they are with me so he has
13 absolutely no basis to allege what happens in my household. Was the conversation we had with
14 Alex, where he was confronted about his marijuana use pleasant - no - why would Allen think it
15 was going to be easy going? That is nonsense. Alex was caught off guard, not knowing the
16 meeting was going to happen or what we would be talking about. He did get upset during the
17 meeting at Allen's house. Alex left the table to go to his room twice during the conversation when
18 he got upset. Alex was angry and disrespectful to me at one point in our conversation. Alex yelled
19 and swore at me, got up went into the kitchen and then threw a kitchen towel at me. He said I was
20 putting words in his mouth, and stormed out of the room. Allen did not correct him in any way and
21 instead said, "see he is angry with you" as if I deserved that treatment because he was angry with
22 me. I discussed this with Allen afterwards on the phone and told him how disappointed I was that
BREWE LAYMAN P.S.
P.O. Box488
24 PETITIONER'S RESPONSE TO (425) 252-5167 Phone
MOTION FOR EVALUATOR - 8 (425) 252-9055 Fax
www.brewelaw.com
1 he didn't parent Alex and use it as a moment to stand up against that behavior to his mom or any
2 woman. I did talk to Alex about the whole exchange the next day, how it is unnecessary to treat me
3 like that, I said that anger is normal and it is how you manage it that is important in life. Alex has
4 apologized to me and frankly, that moment opened up doors of communication about the depths of
5 Alex's feelings and how he's stuck in the middle-which Allen has created at this point for his
6 owngam.
7 The only changes in my household have been positive. I can finally NOT walk through my
8 house on eggshells, worried about Allen's reaction or him trying to control me. Worrying about
9 him saying mean and disparaging things in a disrespectful way, using swear words at times, even
10 when the kids could hear. Although Allen still uses emails and text messages to belittle or
11 minimize and control me, I am able to see more clearly that even this motion is a manipulation.
12 He is still minimizing my value when he tells our daughter Madison on April 8, 2018, that
13 "Mommy can't manage the Barbie's, so you will have to leave them here." or when he emails me
14 the "proper procedure" for informing him of every move the children make each week or when he
15 sends patronizing emails that begin with "Oh Sally, come on now that is not true .. .I chalk that up
16 to lawyer talk" or other types of controlling behavior. Time and time again I have asked him to
17 communicate via text or email and not just "stop by the house" but he still seems to come to the
18 door early and want to talk but his talks are him telling me something I have done wrong, how I am
19 wasting my time trying to settle and how I cannot seem to even get my answers to discovery the
20 way he wants them to be.
21 It clearly states in Allen's original response to my divorce, and again in his interrogatories
22 dated 1-19-18, that I am a good mom. Allen has worked 60-90 hours a week since Alex was born,
BREWE LAYMAN P.S.
P.O. Box488
www.brewelaw.com
1 until his heart attack in April 2017, he still works more than "full time" and he's actually earning
2 more income that he stated in November. While it's true that he did coach Colby's football team
3 and attended the events he could attend, it is far from accurate (or even physically possible ) that
4 Allen worked 60-90 hours a week and was at every single practice, game event for all three kids
5 for all their years. When there are three kids, not even a stay at home parent can be at everything
6 all the time. Allen attended two school conferences, some school functions when I insisted we
7 attend as a family and coached Colby. He does not need to rewrite history but is doing so now to
8 bolster some claim of his. He did not participate in their school activities, field trips, volunteering,
9 activities at the school, before school or end of year BBQs, doctors' appointments, counseling
10 appointments, orthodontist's appointments, and dentist appointments. He claims he helped with
11 homework. I can think of one time in 3rd grade when Allen helped Alex with homework. He would
12 stop in to kiss the kids goodnight while (or immediately after) I read books and sang songs to them
13 at bedtime, spending quality time with each child. He would sing a song to Madison in the later
14 years right before our separation. He does not claim to be the primary parent for these children and
15 until now did not question that as the truth of our marriage and family. So why now? Because
16 ultimately, he does not want to have to pay for the value of the interest he owns in Leader One.
17 His initial declaration spent 6 pages on finances and just a few paragraphs on parenting where he
18 agrees I was the primary parent. His interrogatories are the same.
19 I've been a stay at home parent for most of the last 15 years, when I wasn't teaching part-
20 time, I have taken pride in my parenting- been a "super mom" in many respects. I am a teacher and
21 am a loving, honest and reliable mother and person. This is the last thing Allen could do to really
22 hurt me. He is using the court system to bully me, perpetuate his abuse.
BREWE LAYMAN P.S.
23 IAttorneys at Law
P.O. Box488
MOTION FOR EVALUATOR - 10 !
425! 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
1 His statement that an evaluation would shorten trial is not true - all the third party
2 witnesses will still come in and testify despite an evaluation because no matter what, if Allen does
3 not get his way then he's not going to agree. I believe ifthe court denies this motion, Allen will be
4 more inclined to move towards mediation as I have been asking.
5 Allen's statement that he "agreed to the current temporary parenting plan" makes it sounds
6 like the plan we agreed to was not his proposal. It was. The idea that in the last 90 days, my house
7 has become dysfunctional is ridiculous.
8 Allen should clearly understand why I do not want our three children to be traumatized by
9 having to go through custody litigation. Why would he want them to have to undergo interviews
10 and observations? That is contrary to them having a smooth transition. I have been trying to
11 protect them and their support system-teachers, family, friends, from questions and interrogation
12 from a third party. From what I understand, it is an invasive process, and a costly one.
13
4. Conclusions. There is no factual basis for Allen's motion. There is no legal basis
14
for Allen's motion. His motion should be denied. If the court does decide to appoint a parenting
15
evaluator, I would ask that I be the one to submit the names (I will propose three qualified
16
candidates with PhDs) from which Allen can select. His proposal that I be forced to select from
17
his choices is another way to control the scenario so the court should spin that around. I also want
18
the evaluator to complete psychological evaluations for both Allen and myself - to prevent Allen,
19
when he does not like the outcome of the evaluation, to bring yet another motion asking for some
20
other evaluation.
21
22

Attorneys at Law
P.O. Box488
24 PETITIONER'S RESPONSE TO (425) 252-5167 Phone
MOTION FOR EVALUATOR - 11 (425) 252-9055 Fax
www.brewelaw.com
I Signe<! onJylay 29; 2Q.J3 at. Bve~tt,, WA.
.. . . .. :
3
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12
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15
16
17
18 ·.
19
20·
21 f,
22
.·&·REW . .·.. E LAYMAN P.S.
23 . Attorneys at Law .
P.O. Box 488 ..

24 PETitIONER'S RESPONSE 'fO ' ~~~~~~fhi1ri~820~0488
(425)252~9055 Fax .
MOTION .FOR EVALUATOR- 12 www;bre\Yelaw;c{)m
I
1

6
7
SALLY JO PRICE, FIRST INTERROGATORIES AND
8 REQUESTS FOR PRODUCTION OF
Petitioner, DOCUMENTS PROPOUNDED TO
9 RESPONDENT
and
10
11
Respondent.
12
13 TO: Charles A. Price, Jr.;

AND TO: Kirstyn Palmisano, Attorney for Respondent
14
·INSTRUCTIONS
15
In accordance with Rules 33 and 34, Civil Rules for Superior Court, please answer the
16 attached Interrogatories and Requests for Production of Documents. As required by Civil Rule 33(a)
of the Superior Court, please answer each request in the blank space provided, inserting additional
17 pages where necessary; verify your answers under oath on the fonn provided after the last
Interrogatory; and serve the completed Interrogatories on the office at 3525 Colby Avenue, Suite 333,
18 Everett, WA 98201, within thirty (30) days ofreceipt. Unless otherwise specified, all documents and
things in response to the Requests for Production shall be made available for inspection and copying
19 thirty (30) days following receipt of these Requests for Production at 3525 Colby, Suite 333, Everett,
WA 98201. In lieu of physical delivery, said documents may be mailed, or served with the
20 accompanying Interrogatories.
21 These Interrogatories call for all information that is known by or available to you, including
all information in the possession of your officers, employees, agents, attorneys, accountants, auditors,
22 or other professional persons or experts and any investigators or any person acting in your behalf or
23
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF
DOCUMENTS - 1
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
(425) 252-9055 Fax
em19b4122x www.brewelaw.com
•.
1 INTERROGATORY NO. 15.3: Identify with particularity any such property in which you claim
an interest.
2
ANSWER: The down payment to the home at 11423 4th Ave NE, Marysville
3
4 INTERROGATORY NO. 15.4: State the legal basis for your claim.
5 ANSWER: Purchased and paid for the home with separate property.
6
INTERROGATORY NO. 15.5: Do you claim you contributed, financially or in any other way, to
7 the acquisition of the property specified above? YES x NO _ _ If so, identify:
8 a). the nature of your contribution; down payment

b.) the amount or value of such contribution; $91,500
9 c.) the date such contribution was made; and 3/16/04
d.) the source of funds or property contributed. Proceeds from the sale of the 415 Rose
10 way property that I had sold.
11 ANSWER:
12
XVI. PARENTING PLAN
13
.INTERROGATORY NO. 16. l :/Do you contend that the other parent's involvement or conduct m~y
14 have an adverse effect on the child(ren)'s best interest because of the existence of any of the factors
_listed below? If so please state in detail the basis of your belief:
15
a). Neglect or substantial nonperformance of parenting functions;
16 b). A long-term emotional or physical impairment which interferes with the performance
of parenting functions;
17 c). A long-term impairment resulting from drug, alcohol, or other substance abuse that
interferes with the performance of parenting functions;
18 d). The absence or substantial impairment of emotional ties between the parent and child;
e). The abusive use of conflict by the parent which creates the danger of serious damage
19 to the child's psychological development; and/or
f). A parent has withheld from the other parent access to the child for a protracted period
20 without good cause.
21 1\NSWER:NO
22
23
DOCUMENTS - 58
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425! 252-5167 Phone
em19b4122x (425 252-9055 Fax
www.brewelaw.com
1 INTERROGATORY NO. 16.2: To your knowledge, has any complaint ever been made to law
enforcement agencies or social agencies alleging that either you or your spouse have neglected or
2 abused a child or children? If so, please state:
3 a). Whom the complaint was against;

b). The name of the child or children involved;
4 c). The date upon which the complaint was made;
d). The law enforcement agency or social agency taking the complaint;
5 e). The nature of the neglect or abuse alleged;
f). The complaining party; and
6 g). The final disposition of the complaint.
7 ANSWER:
8 a. Charles Price
b. Colby Price
9 c. I don't have the record
d. Social services
10 e. Grabbed the back of Colby's neck on the football field.
f. Colby to his counselor
11 g. Disregarded as unsubstantiated after the investigation.
12 INTERROGATORY NO. 16.3: Have you, the other parent, or anyone with whom you reside used
any non-prescribed controlled substance including, but not limited to: alcohol, marijuana, cocaine,
13 amphetamines, or barbiturates within the last five (5) years? If so, for each such person, state:
14 a). Name of person using the substance;

b). The type of drug(s )/substance used;
c). Typical amount used;
15
d). Frequency of use;
16 e). Whether you believe the substance abuse is a problem for that person;
f). Whether he/she has ever been treated for substance abuse or alcoholism at any time;
17 and
g). The name and addresses of any treatment agency and the dates of treatment.
18
ANSWER:
.a~ Charles Price I have smoked marijuana and drank during my marriage and Sally has also:·
19
b. Same as above
c. I ava a drink about a few times a week. I cannot remember the last time I smoked
20 marijuana. Sally drinks regularly.
d. a couple times a week for me sally I a bit more.
21 r e. no I don't believe it is a problem /
f. the only knowledge I have is sally was sent away to boarding school for drug use.
22 g. unknown
23
DOCUMENTS - 59
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
em19b4122x (425) 252-9055 Fax
www.brewelaw.com
1
INTERROGATORY NO. 16.4: Has the other parent ever physically assaulted or verbally abused ,.
(
2 you or the children?-If so please state for each incident:
3 a). Person who was abused;

b). What the parent did or said that was abusive;
4 c). Date of the incident;
d). Name, address, and telephone number of any witnesses; and
5 e). The place where the abuse took place.
6 ANSWER: No/
7
INTERROGATORY NO. 16.5: Have you ever physically assaulted or verbally abused the other
8 parent, your children, or any other child? If so, state for each incident:
9 a). Person who you abused;

b). What you did or said that was abusive;
10 c). Date of the incident;
d). Name, address, and telephone numbers of any witnesses; and
11 e). The place where the abuse took place.
12 ANSWER: No
13
INTERROGATORY NO. 16.6: Has anyone with whom you have previously resided, or with whom
14 you now reside, ever physically assaulted or verbally abused you or the children? If so, state for each
incident:
15
a). Name of the person who was abusive;
16 b). The person's relationship to you;
c). What they did or said that was abusive;
17 d). Date of the incident; and
e). The place where the abuse took place
18
ANSWER: NO
19
20 INTERROGATORY NO. 16.7: Have you, your spouse, or any of the children involved herein seen
a mental health professional or received counseling of any type within the last five (5) years? If so,
21 for each person please state:
22 a). The name of the person receiving counseling;
23
DOCUMENTS - 60
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
em19b4122x !425! 252-5167 Phone

425 252-9055 Fax
www.brewelaw.com
'· A
1 b). The name, address and telephone number of the mental health provider;
c). Treatment dates for each professional; and
2 d). Nature of the problem for which the person was seen.
3 ANSWER:
4 a. Sally Price, Colby Price, Alexander Price and Charles Price

b. I don't know the counsellors for sally, Colby and Alex. Sally would have those records.
5 Paula 21807 64th Ave W Mt Lake Terrace Wa 98043. 425-640-7009 for myself.
c. Once a week
6 d. dealing with my heart attack and almost dying.
7 INTERROGATORY NO. 16.8: Will you stipulate to the release of records of all health care and
drug or alcohol treatment providers listed in your answers to Interrogatories for purposes of this
8 action?
9 ANSWER: No. I may agree to a limited release relating to my heart condition, medications,
because it impacts my work. If she wants more than that, then I would sign a reciprocal release which
1o would give me access to Sally's.
11
INTERROGATORY NO. 16.9: Are there any special circumstances, not identified in your answers ,
12 to the preceding Interrogatories, which should be considered by the court insetting a.parenting plan?
If so, please state the nature of those circumstances.
13
ANSWER:NO >
14
15 INTERROGATORY NO. 16.10: If you have not filed a proposed parenting plan, please set forth
the residential schedule that you believe the children should have with each parent during the school
16 year. Describe in detail what you propose the schedule should be, and set forth any reasons for any
limitations or restrictions for the other parent on contact.
17
ANSWER: I am not sure yet. I want to see how this period of time goes:'T would not want ·
18 any limitations on Sally..,
19
INTERROGATORY NO. 16.11: If you have not filed a proposed parenting plan, please set forth
20 the residential schedule that you believe the children should have with each parent during the
holiday/winter vacation. Describe in detail what you propose the schedule should be, and set forth
21 any reasons for any limitations or restrictions for the other parent on contact.
22 ANSWER: Still not sure.
23
DOCUMENTS - 61
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
24
(425j 252-5167 Phone
em19b4122x (425 252-9055 Fax
www.brewelaw.com
i _.
1
2 the residential schedule that you believe the children should have with each parent during the mid-
winter and spring vacations. Describe in detail what you propose the schedule should be, and forth
3 any reasons for any limitations or restrictions for the other parent on contact.
4 ANSWER: Not sure yet.
5
6 the residential schedule that you believe the children should have with each parent during the summer
vacations. Describe in detail what you propose the schedule should be, and set forth any reasons for
7 any limitations or restrictions for the other parent on contact.
8 ANSWER: Not sure yet.
9
INTERROGATORY NO. 16.14: If you have not filed a proposed parenting plan, please set forth in
10 detail the residential schedule that you believe the children should have with each parent during the
holidays and special occasions listed below, including any reasons for any limitations or restrictions
11 for the other parent on contact:
12 a). New Year's Day;

b). Martin Luther King Day;
13 c). President's Day;
d). Easter Sunday;
14 e). Memorial Day;
f). July 4th;
15 g). Labor Day;
h). Veteran's Day;
16 i). Thanksgiving Day;
j). Christmas Eve;
17 k). Christmas Day;
l). Mother's Day;
18 m). Father's Day;
n). Mother's Birthday;
19 o). Father's Birthday; and
p). Each of the children's birthdays.
20
ANSWER: These should be split, alternating years. Sally should get Mother's Day/her
21 birthday and I would get Father's Day/father's birthday.
22
23 ., B R E W E LAY M A N P . s .
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF Attorneys at Law
DOCUMENTS - 62 P.O. Box488
24
(425J 252-5167 Phone
em19b4122x (425 252-9055 Fax
www.brewelaw.com
•·
INTERROGATORY NO. 16.15: Please set forth your proposal for the transportation arrangements
between the parents, and state in detail your proposals for any issues such as long distance travel
2 arrangements.
3 ANSWER: receiving parent provide transport
4
INTERROGATORY NO. 16.16: Are you willing to communicate regularly with the other parent
5 regarding the children's educational, social, medical, emotional, and spiritual development? If not,
please explain your reasons.
6
ANSWER: of course
7
8 INTERROGATORY NO. 16.17: Please describe in detail your.religious affiliations and those of
your spouse and children.
9
ANSWER: Christianity
10
11 INTERROGATORY NO. 16.18: Are there any decisions forthe children which you believe cannot
be made jointly by both parents? If so, please describe in detail:
12
a). Each type of decision;
13 b). Why it cannot be made by the parents jointly;
c). Who should make the decision; and
14 d). Why.
15 ANSWER: no
16
INTERROGATORY NO. 16.19: 1Will you agree to cooperate in mediation when necessary to _,,
17 resolve disputes regarding the children? If not, state your reasons:
18 ANSWER: Yes
/
19
INTERROGATORY NO. 16.20: Do you have a recommendation for a mental health professional,
20 or other person or agency, to either resolve current parenting plan disputes, or mediate future
problems? If so, give the name, address and telephone number, and whether recommendation is for
21 current or future use.
22 ANSWER: Not yet
23
INTERROGATORJES AND REQUESTS FOR PRODUCTION OF
DOCUMENTS - 63
I BREWE LAYMAN P.5.
Attorneys at Law
P.O. Box488
24
{425J 252-5167 Phone
em19b4122x {425 252-9055 Fax
www.brewelaw.com
1
2 INTERROGATORY NO. 16.21: What is your current work schedule? Include time you must leave
for work and when you arrive home.
3
ANSWER: Flexible, 40 hours per week.
4
5 INTERROGATORY NO. 16.22: If the children will be required to spend time in childcare during
the residential time that they spend with you, please state the following:
6
a). The reasons why the children will be in child care;
7 b). Child care arrangements you have made;
c). The name, address, and telephone number of the child care provider; and
8 d). Whether that provider has been agreed upon by the other parent:
9 ANSWER: I am not aware yet if this will happen. If needed, I can hire a nanny for some
1
work hours but it would be minimal. .
10
11 INTERROGATORY NO. 16.23: If anyone other than the children will be residing with you, please
state:
12
a). The name of such person(s);
13 b). Their relationship to you;
c). Date of birth and social security number;
14 d). Their present address and telephone number;
e). The person's employment and gross monthly income for the past year; and
15 f). Whether the person has ever been convicted of a crime or accused of any sort of
abuse or neglect of a child.
16
ANSWER:N/A
17
18 INTERROGATORY NO. 16.24: Do you now plan or foresee a relocation of your residence? If so,
please state:
19
a). The reason for such move;
20 b). The anticipated city and state of your move;
c). The date you intend to move; and
21 d). Whether this move would require that the children move out of the school district
where the children currently reside.
22
23
DOCUMENTS - 64
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425) 252-5167 Phone
em19b4122x (425) 252-9055 Fax
www.brewelaw.com
1 ANSWER: No
2
INTERROGATORY NO. 16.25: If you plan or foresee a relocation of your residence, what do you
3 propose as the residential schedule for the children and arrangements for their transportation?
4 ANSWER: NIA
5
INTERROGATORY NO. 16.26: Have there been any other proceedings concerning the children of
6 either party other than this action? If so, for each please state:
7 a). The title of the court and the court file number;
b). The name(s) of the child(ren) involved;
8 c). The name and address of all other parties to that action; and
d). The nature of that proceeding:
9
ANSWER: No
10
11 INTERROGATORY NO. 16.27: Have you kept a calendar log, journal or diary which reflects or
describes the parenting arrangements throughout the past twelve (12) months?
12
ANSWER: No
13
14 REQUEST FOR PRODUCTION NO. 16.1: Please produce copies of any and all calendars, logs,
journals, or diaries referenced in your answer to the proceeding Interrogatory.
15
RESPONSE: NIA
16
17 INTERROGATORY NO. 16.28: Describe your strengths as a parent.
18 ANSWER: My strength is I am very organized. I am consistent with rules and sending a

consistent message to them. I let the children make mistake on their own and counsel them through
19 the afterward rather than simply protecting them from every problem they will have. I am a parent
first and friend second. I have patience with my children. I have a strong communications
20 background and I can use that very effectively with our children. In the end Sally and I love these
children like no other and there is nothing we would not do for children to help them become the
21 best productive member of society they can become.
22
23
DOCUMENTS - 65
I BREWE LAYMAN P.S.
Attorneys at Law
24 P.O. Box488
(425) 252-5167 Phone
em19b4122x {425) 252-9055 Fax
www.brewelaw.com
1 INTERROGATORY NO. 16.29: Describe your weaknesses as a pare11t.
2 ANSWERS: I have not been doing the things sally has been doing and I have learned a .
lot in a short period of time. I have lots more to learn in my new role with my children, but I am /
3 excited to be a part of my children's life in some of the different ways that I have not done before.
4
INTERROGATORY NO. 16.30: Describe the other parent's strengths as a parent.
5
ANSWER: ~ally is a wonderful parent I am not going to gloat but just to tell you she is a .
6 loving mother and a responsible parent. ,
7
INTERROGATORYN0.16.31: Describe the other parent's weaknesses as a parent.
8
ANSWERS: Sally could be more patient with the kids. She could let them make some ,
lllistakes on their own. She could work with Alex in a less confrontational way and get
9
more out of the him.
10
11
XVII. CHILD SUPPORT ISSUES
12
.INTERROGATORY NO. 17.1: Since separation, have you or your spouse been voluntarily paying
support for any children of this marriage? If yes, please state:
13
a). Paid by who; Sally
14
b). The amount of each payment; 4500
c). The dates of each payment; and 15th of each month
15
d). The agreed duration of the child support. Per temporary orders until resolution of
case. Then by final agreement.
16
ANSWER:
17
18
REQUEST FOR PRODUCTION NO. 17 .1: Please produce copies of any and all canceled checks
or receipts for child support paid by you since separation.
19
RESPONSE: Direct transfers with the exception of one cashier's check which is produced.
20
21
INTERROGATORY NO. 17.2: What gross income do you contend should be used for each parent
for purposes of calculating final child support, and detail the manner in which such income was
22
calculated or determined.
23
DOCUMENTS - 66
I BREWE LAYMAN P.S.
Attorneys at Law
P.O. Box488
(425l 252-5167 Phone
(425 252-9055 Fax
em19b4122x www.brewelaw.com
1 Answers to Interrogatories and Requests for Production, completed and signed this 18th day of
January, 2018, at Seattle, Washington.
2
By:_~_'Jvt--
3
_ _ _ __
4 Kirstyn Palmisano, WSBA 41386
5
6 I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE

OF WASHINGTON THAT THE FOREGOING IS TRUE AND ACCURATE TO THE BEST OF
7 MY KNOWLEDGE.
8 DATED this 1gth day of January, 2018, at Seattle, Washington:
10 ChMI#.;., Jr.
11
12
13
14
15
16
17
18
19
20
21
22
23
DOCUMENTS - 79
I BREWE LAYMAN P.S.
Attorneys at Law
24 P.O. Box488
em19b4122x !425l 252-5167 Phone

425 252-9055 Fax
www.brewelaw.com
From: Veronica Freitas <veronica@vfreitaslaw.com>
Date~April 30, 2018 at5:47:51 PM PDT\
To: "Sabrina A. Layman" <sabrinal@brewelaw.com>
Cc: Amy Pasco <amy@vfreitaslaw.com>, Stevie Craig <stevie@vfreitaslaw.com>
Subject: FW: Request for Production
Hi Sabrina,
Please see the final items from the additional financial documents that you requested attached. Please
let me know if this is all you need.
From: Allen Price [mailto:aprice@leaderl.com]

Sent: Monday, April 30, 2018 4:30 PM
Subject: Request for Production
Here is the rest of what I was able to gather for Sabrina.

That should fulfill her request.
1. I have given the contracts and that is all I get and it also explains in detail
how I am paid.
2. I have also provide the 2017 w-2.
3. Is above and Labeled 5 years
4. Is above and labeled 2017.
On number 4 there was a question and the answer to that question is no client or
referral source generated 10% or more of Charles A Price JR revenue during the
last year. With the exception to refinance business.
~nt: Monday, May 14, 2018 6:51 PM ,
To: Sabrina A. Layman; Stevie Craig; Amy Pasco
Cc: Katie Miller
Subject: RE: Price: Schedule Meeting
Hi Sabrina,
Allen declines. He has no ownership interest in Leader One Financial except as a shareholder; He is a
W2 employee.

To: Veronica Freitas <veronica@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>; Amy Pasco
<amy@vfreitaslaw.com>
Subject: FW: Price: Schedule Meeting
Veronica -
See below-
1am fine if you want to be on a phone conference with him so you hear
the questions - but sounds like they are general and depending on his
answers they are varied.
Let me know.
Sabrina
From: Theresa Sewell [mailto:theresa@bjyvalue.com]

Sent: Friday, May 11, 2018 4:21 PM
Cc: Katie Miller; Kevin Grambush
Subject: RE: Price: Schedule Meeting
We find that providing a list of questions is not the most effective way to get the information we truly
need. Additionally, our interviews are fairly dynamic - we add or eliminate questions as we go along
depending on his responses. If it helps, the intent of the meeting is to learn as much as we can about
the company and his role in it. Generally, we will ask questions related to the history of the business and
his ownership, company operations, customers, competition, the industry, etc. There is nothing that he
would need to prepare in advance. We may have some financial questions as well but those would
likely only relate specifically to his income/production, not the company as a whole.
Best,
Theresa
Theresa Sewell, CPA/ABV

Brueggeman & Johnson Yeanoplos, PC
Direct: (206) 292-5384
Total Control Panel

From: veronica@vfreitaslaw.com
1
3
4
5
SUPERIOR COURT OF WASHINGTON, COUNTY OF KING
6
7
Petitioner: No. 17-3-02497-31
8
SALLY JO PRICE, RESPONDENT'S FIRST SET OF
9 INTERROGATORIES AND REQUESTS
And FOR PRODUCTION OF DOCUMENTS TO
10 PETITIONER
Respondent:
11
CHARLES A. PRICE. Date Propounded:1/12/18
12 Due Date: 2/15/18
CR 26(i) Conference call: 2/21/18
13
14 TO: Sally Jo Price, Petitioner;
15 AND TO: Sabrina Layman, her attorney:
16 Interrogatories. In accordance with Rule 33 of the Civil Rules for Superior Court, State
of Washington, please do the following:
17
Answer each of the following interrogatories separately and fully, in writing, under oath,
18
unless there is an objection to an interrogatory, in which case state the reason for the objection.
19 The answers and objections, if any, to interrogatories must be served upon the undersigned
attorney within 30 days after the service of these interrogatories as provided in Civil Rule 33.
20 The following interrogatories are intended to be continuing in nature, and any information which
may be discovered by you subsequent to the service and filing of your answers should be
21 brought to the attention of the inquiring party, through supplemental answers. within a
reasonable time following discovery.
22
Requests for Production of Documents: In accordance with Rule 34 of the Civil Rules
23
for Superior Court, State of Washington, please do the following:
24
Produce and permit inspection and copying of the requested documents, records and
25 materials pursuant with Civil Rule 34. The designated documents shall include writings,
26
Interrogatories and Requests for 544 29th Avenue
27
Production Seattle, WA 98122
No Mandatory Form Developed p.1 of71 (206) 328-7362
28
FILE COPY
1 a. Type(s) of drug used; Clobestasol Solution
b. Frequency of use; Daily, as needed
2 c. Purpose of use; Psoriasis on scalp
d. Dr Amy S. Cheng, 2901174th ST NE, Marysville, WA 98271, 360-454-1917
3
4 a. Type(s) of drug used; Protopic Ointment

b. Frequency of use; Twice daily, as needed
5 c. Purpose of use; Rash
d. Dr Amy S. Cheng, 2901 174th STNE, Marysville, WA 98271, 360-454-1917
6
a. Type(s) of drug used; Tacrolimus Ointment
7 e. Frequency of use; Daily, as needed
f. Purpose of use; Rash
8 d. Dr Amy S. Cheng, 2901 1741h ST NE, Marysville, WA 98271, 360-454-1917
9
10 INTERROGATORY NO. 13.: Have you ever attended, or are you now attending, AA
(Alcoholics Anonymous), or NA (Narcotics Anonymous), or any other such substance abuse
11 self-help program?
12 a. Name of program you attended/are attending:

b. How long you attended/have been attending;
13 c. Dates of attendance (past and present); and
d. Reason for attending program.
14
15 I attended Residential Treatment at 15 years old. And also did outpatient treatment, counseling,
and attended AA afterwards. I do not have any information about this. I do not currently attend,
16 nor have I since I was 16 years old.
17
11. EMPLOYEMENT
18
INTERROGATORY NO. 14.: Please state whether you are presently employed (i.e.
19
"employment," refers to any or position you hold for which you receive compensation,
20 including salaried or hourly compensation, contract work, self-employment through a sole
proprietorship or partnership, or any other position for which you perform work in exchange for
21 any sort of compensation).
22 ANSWER: Not presently employed
23
INTERROGATORY NO. 15.: Describe your education, stating highest grade attained,
24 degrees obtained, including any technical vocational, college, or other post-graduate education,
25
26
27 Production Seattle, WA 98122
No Mandatory Form Developed p. 6 of 71 (206) 328-7362
28
how many credits earned in graduate school and state how many credits remain until you could
1 earn your master's degree. ·
2 ANSWER:
BA in French, March 1996 from Western Washington University. Attended WWU post-
.3
bac to obtain my teaching credential.
4 Certified K-12 Teacher in French
Certified 4-12 Teacher in History
5 Certified 4-12 Teacher in Social Studies
6 My continuing education for my certificate is due on June 30, 2020. I still have 84 clock
· hours to complete to get to my 150 clock hour requirement.
7
I have not started a masters program, I have no 500 level credits completed.
8
I also have a Realtor Broker License, although it is on ice at the State and I have never
9
done the continuing education to maintain it. I have never worked as a Realtor.
10
[1have my Reiki I (October 26, 2017) and Reiki II (January 25, 2018) certifications. ,
11 I am also an Ordained Minister beginning on January 25, 2018. ;
12
INTERROGATORY NO. 16.: If you are presently employed, please state the following:
13
14 a. The name and address of your present employer;

15 b. The date you commenced employment;
16
c. Your job title position;
17
d. The description of your work or duties;
18
e. The name, address and position of your immediate supervisor; and
19
f. Your pay period (that is, whether you are paid monthly,
<•
weekly, every two weeks,
......~.
20
or twice per month).
21
ANSWER: Not presently employed
22
23
24
25
26
Interrogatories and Requests for 544 291h Avenue
No Mandatory Form Developed p. 7 of 71 (206) 328-7362
28
1
2
ANSWERS SUBMITTED: _ ____,3""--'-/_/3
__ .\_7/ .
\ ~ ~ -#q'2-2tJ f"V"'
3
So.J?nnv.- 1/--. la<jMIAn 1 w.s13~ V5Uo
5
STATE OF WASHINGTON
6 ) SS.
COUNTY OF KING )
7
8
SALLY JO PRICE, being first duly sworn, on oath, deposes and says:
9
That I am the Petitioner herein, and I am qualified to answer the within and foregoing
10 interrogatories; that I have read the within interrogatories, know the answers thereto and
believe the same to be true and accurate to the best of my knowledge, information and belief.
11
12
13 Sally Jo Price, Petitioner

14
15 SUBSCRIBED AND SWORN TO before me this _ _ _ day of _ _ _ _ _, 2018.
16
17 Notary's Printed Name: - - - - ' - - - - -

NOTARY PUBLIC in and for the STATE OF
18 WASHINGTON, residing at _ _ _ _ __
My commission expires: _ _ _ _ _ __
19
20
21
22
23
24
25
26
No Mandatory Form Developed p. 69 of71 (206) 328-7362
28
1
2
Sally Jo Price, Petitioner
3
4
SUBSCRIBED AND SWORN TO before me this /3 tb day of Fehrva.qy. 2018.
5
6 klfta 'J{/7 ' . .

Notary's Printed Name: m~ M1Ue-r-
7 NOTARY PUBLIC in and for the STATE OF
WASHINGTON, residing at l?1..k.f;-ft:1/&1-S
8 My commission expires: 1-/. .- I~ 'Zol 0:
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
ATTACHMENT A
24 PERSONAL PROPERTY IN POSSESION OF THE HUSBAND
25
26
1
Interrogatories and Requests for 544 29 h Avenue
28
1
2
3
5
SUPERIOR COURT OF WASHINGTON, COUNTY OF KING
6
7
Petitioner: No. 17-3-02497-31
8
SALLY JO PRICE, PETITIONER'S AMENDED ANSWERS TO
9 SELECT INTERROGATORIES
And
10 /UPDATED 4/17/2018 _;
Respondent:
11
CHARLES A. PRICE.
12
13 TO: Sally Jo Price, Petitioner;
14 AND TO: Sabrina Layman, her attorney:
15 Interrogatories. In accordance with Rule 33 of the Civil Rules for Superior Court, State
of Washington, please do the following:
16
Answer each of the following interrogatories separately and fully, in writing, under oath,
17 unless there is an objection to an interrogatory, in which case state the reason for the objection.
The answers and objections, if any, to interrogatories must be served upon the undersigned
18
attorney within 30 days after the service ofthese interrogatories as provided in Civil Rule 33.
19 The following interrogatories are intended to be continuing in nature, and any information which
may be discovered by you subsequent to the service and filing of your answers should be
20 brought to the attention of the inquiring party, through supplemental answers. within a
reasonable time following discovery.
21
Requests for Production of Documents: In accordance with Rule 34 of the Civil Rules
22 for Superior Court, State of Washington, please do the following:
23
Produce and permit inspection and copying of the requested documents, records and
24 materials pursuant with Civil Rule 34. The designated documents shall include writings,
drawings, graphs, charts, photographs, phone records and other data compilations from which
25 information can be obtained, translated if necessary or otherwise reduced through detection
26
28
fd178012dz
ORIG\NAL
,
..
1 INTERROGATORY NO. 20.: Are you claiming your mental and/or physical health limit your
employment in any manner? If yes, identify any such limitations.
2
3 ANSWER: No
5 INTERROGATORY NO. 21.: Have you had any contact with any individual or business
regarding your potential employment and/or providing contract services, including substitute
6 teaching, or have you received any offers of employment and/or been offered contract work,
since January 2015? If so, identify the following:
7
8 • The name, address, email address, and telephone number of the individual or
business;
9 • The date on which you were first contacted, and the dates of any subsequent
communications, meetings, interviews, or other contact;
10 • For each communication, meeting, interview, or other contact, provide an
explanation of the discussion(s) between you and the individual or business
11 about your potential employment and/or providing contract services;
• The job title and a description of the work duties associated with the employment
12 and/or contract work;
13
• The amount and type of compensation and benefits related to the employment
and/or contract work;
14 • Whether discussions are continuing with regard to the employment and/or
contract work, and if you are considering the employment and/or contract work;
15 • If you are not considering the employment and/or contract work, identify all
reasons for not considering the work; and
16 • For all employment and/or contract work you did not accept, provide a complete
explanation for not accepting the work.
17
18 ANSWER: I have recently submitted my name to return to substitute teaching now that ,
19 the children's schedule of visitation with their father has settled into normal pattern and they are
~adjusted.
20
21
INTERROGATORY NO. 22.: Regarding your plans for future employment or contract
22 work, identify the following:
23 • Field and/or area of employment and/or contracting services;

24 • Estimated gross income per year and basis for estimate; and
• Barriers to gaining employment and/or contracting services opportunities .
25
26
28
fd178012dz
..
ANSWER: After further consideration on my future, the best interests of my children and
1 1he hope to reduce the conflict from the other party, I realize that returning to teaching
both substitute and potentially regular schedule will best suit my future. . My other g9als
2 · for education in a different field will have to wait until a later time. -:
3
4
INTERROGATORY NO. 23.: Have you engaged in any part-time employment in
5 addition to your regular occupation during the past year. If so, please state the following:
6
a. The names and addresses of each employer for whom you have worked;
7
b. The type of work performed;
8
c. The rate of pay received for your services;
9
d. Average gross monthly and net monthly income from such employment;
10
e. The total number of hours or dates you were so employed during the past six (6) .
11
months; and
12
f. Whether you are still engaged in such part-time employment.
13
14 ANSWER: No
15
16
17
INTERROGATORY NO. 24.: Please list and describe your present employment
18
benefits, which fall into the following categories:
19
NONE
20
a. Life Insurance:
21 i. . Name of Insurer:
22 ii. Face amount of policy: $_ _ _ _

iii. Amount of premiums or payments
23 $_ _ _ _ _
made by you per month:
24
25
26 V. Freitas Law, PLLC
28
fd178012dz
j,·.
discuss this career path with a couple other massage therapists. This program costs
1 approx. $10,800 and would be a nine month program.
2 Mental Health Counseling Masters. I have been investigating attending Graduate School
to become a Mental Health Counselor. I have talked to Antioch University about their
3
online program. I have also talked to Grand Canyon University about their online
4 program. I am planning to talk to Antioch about their face-to-face program in Seattle, as
soon as I finish these interrogatories. Online program costs approx. $46,000, face to
5 face costs approx. $60,000. Both of these programs would take about 3 years to
complete. The online course load would take about 26 hours a week, equivalent to a
6 part-time job.
7 School Counseling Masters. I am also investigating enrolling in a program to become a,

school counselor.
8
9 I am working on completing the necessary credit hours for my teaching credentials. See
Answer to Interrogatory 15 above.
10
Ill. PROPERTY AND FINANCIAL INFORMATION
11
INTERROGATORY NO. 38.: Please state whether you have prepared (or had prepared
12 for you) any financial statements, financial affidavits, financial certificates, financial declarations,
credit applications or loan applications during the past three (3) years. If so, with respect to
13
each such statement provide the following information:
14
a. Date of preparation;
15
b. Purpose;
16
17 c. Preparer;
18 d. Person/entity for whom prepared; and
19 e. Person(s)/entity(ies) having copies of statement.
20 ANSWER: None, other than the statement I made that was included in my divorce filing
21
22
INTERROGATORY NO. 39.: Do you anticipate any income tax refunds within the next
23 year? Yes _X_ No. If so, state the year for which you expect a refund and the
amount.
24
ANSWER: No
25
26
28
fd178012dz
1
ANSWERS SUBMITTED: 4 I I~
~-r,~----~~~~~
, 2018
~-
2
3
/
4
5
STATE OF WASHINGTON
6 ~ <) SS.
COUNTY OFKitslG"Srtcvwyi.,i"J iL
7
8
SALLY JO PRICE, being first duly sworn, on oath, deposes and says:
9
That I am the Petitioner herein, and I am qualified to answer the within and foregoing
1o interrogatories; that I have read the within interrogatories, know the answers thereto and
believe the same to be true and accurate to the best of my knowledge, information and belief.
11
12
13
14
15 ~............~AND SWORN TO before me this Ir day of flpn -, - ,2018.

16
17
18
19
20
21
22
23
24
25
26
1
Interrogatories and Requests for 544 29 h Avenue
28
fd178012dz
((
'Sabrina A. Layman

Sent: Friday, May 25, 2018 10:02 AM
Subject: FW: Field Trips and Camps
From: Allen Price <aprice@leaderl.com>

Date: May 22, 2018 at 12:03:19 PM PDT I'
~
To: "sallyjprice@me.com" <sallyjprice@me.com>

Subject: Field Trips and Camps
Sally,
I realize that things have changed quite a bit for us and how we operate. I also
know it was very easy for you to ask or let me know what is going on with the kids
when I lived under the same roof. I am writing this because of the camp that
Colby went to last week. You sent me a picture of him and said off to camp. This
was thoughtful and very niced would ask that any permission forms you sign on>
behalfof the children as the guardian be forwarded to me. I need to fully .~
understand where, when, duration and who is responsible for our children when >
they are not in your care . .lf there was any sort of accident or natural disaster such
a~ an earthquake@ or s~mething of that nature, I would need to know where
my children are. This would enable me to go to them as quickly as humanly
possible. :I realize you sent Madison's field trip slip to me well in advance of the,
trip and this the appropriate process.. I wanted to write this to you to serve as a
/
r~eminder. I need to be informed about my children and what is going on wh~n

'·you pass their care onto someone else.
Thank you,
1
1
Sabriria A. Layman

Subject: Fwd: Gymnastics
Begin forwarded message:
From: Allen Price <aprice@leader1.com>

Subject: RE: Gymnastics
Date: May 22, 2018 at 9:18:58 AM PDT
E>h Salfycome on now that is not true it sound~ like your being misleading with that
statement. I will just chalk it up as lawyer talk,, but we all know the truth. l~have attended
choir, all of Irish soccer, band presentations for Alex, All Catholic school events, all of Alex's
flag football and Colby's flag football along with coaching Colby from Syrs old to 11 in spring,
fall football and tackle football and have the pies to prove it. Please remember I have taken
pies and sent them to you via text so you could see what you had missed:- I have so many
?Vents that r have been a part of I could just go on and on. Nonetheless I won'VYou know and
our children know that I was there for them at every event.
As far as the busy comment, It would appear you may have taken that personal and I am sorry
you felt that as a personal attack, that was not at all my intention at all~ I was just stating if yot;J
,had something going on like girls night out on Tuesday. I think that is what you always had or.,
; have on Tuesdays that I would be there to help out with Madi? Considering that I pushed
gymnastics on you after talking to Madi that was the least I could do. I would love the
opportunity to spend more time with the children since we are not at all equitable in regards
to the time with OUR children Currently. Even if it is only to and from sports for now.
1
P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-9300
tilimiiiiel WhatWeBelieve
APPLY NOW!
CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail message and any attachments are confidential and are solely
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intended recipient. ff you have received this transmission in error, any use, reproduction or dissemination of this transmission is strictly
prohibited. If you are not the intended recipient. please immediately notify the sender and delete this message.

Allen,
-:_t.am not too busy for our children. I will let you know if I need your help. I was not aware that you were at every practice
,or every actiVity~,,,
Sally
On May 21, 2018, at 7:22 PM, Allen Price <aprice@leaderl.com> wrote:
Excellent thank you so much for the update. Again I can pick up and drop off when needed since your real busy.
am planning on being at every practice just as I always have been at the kids activities.

P (425) 265-9100 C (425) 345-6384 F (425) 265-9300
APPLY ONLINE NOW!

2
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.confidential and are solely
for addressee. The information may also be legally privileged. This transmission is sent in trust, for the sole purpose
of delivery to the
intended recipient. If you have received this transmission in error, any use, reproduction or dissemination of this
transmission is strictly

Sent: Monday, May 21, 2018 6:54:46 PM
To: Allen Price
i signed her up for tuesdays at 6:30 too.
Sent from my iPhone
On May 21, 2018, at 3:52 PM, Allen Price <aprice@leader1.com> wrote:
Thank for sending it but I am unable to print it or even enlarge it

enough to read.: If you couJd make a copy and I: will pick it up. There Is
also iScanner that is free to download on your mobile device that will
scan it to a pdf and then it will allow the recipient to do what is
needed to read it. You can always scan with the printer at the house
and send through email. These may be better choices. Unfortunately
I just can't see this copy to read it.
P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-9300
<image012.jpg> <image013.jpg> <image014.jpg> <image015.jpg> <im
age016.jpg>
CONFIDENTIALITY AND SECURITY NOTICE The contents of this e-mail message and any attachments are confidential and are solely
for addressee. The infonnation may also be legally privileged. This transmission is sent in trust, for the sole purpose of delivery to the
intended recipient. If you have received this transmission in error. any use, reprodudion or dissemination of this transmission is strictly

Allen,
.i.am.planningon enrolling her tonight in Monday night classes at 5:30. lwill try to enroll,,
her in Tuesday evening classes as well, if there is availability. .:::i
c'l've attached the registration form.

Sally
<image008.jpg>
<image009.jpg>
3
Sent from my iPhone
,·
, On May 19, 2018, at 8:11 AM, Allen Price <aprice@leaderl.com> wrote:
~
Sally,
I have not heard back on the Gymnastics and what your

thoughts are. You said tenative you signed her up? I
want to know the details and I have waited patiently. I
have offered to take her another day since you have
such a busy schedule. You have not responded to that
offer. I was trying to be accommodating to say I could
take her. So at this point I am letting you know that I
want to know what you have committed to?J am c:1ls9
, saying this for the record this is now our decision. 1·
I.
~ would like her to go two days a week and I can take her
Tuesdays or Saturday. I have always been involved with .
~
our kids sports and been the primary in that .
:department. The gymnastics was pushed by me in a
previous email to you since she had been complaining
about you not taking her. This is our decision and we
will decide together. Could you please inform me of
what Day you have committed to and let's discuss the
2nd day that she will go. Please also send me a copy of
any form you filled out for the guardian permission.
P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
<imageOlO.jpg> <imageOll.jpg> <image012.jpg> <image013.jpg>
<image014.jpg>
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solely
for addressee. The information may also be legally privileged. This transmission is sent in trust, for the sole purpose of delivery to the
intended recipient. If you have received this transmission in error. any use. reproduction or dissemination of this transmission is
strictly
prohfb;fed. If you are not the intended recipient. please immediately notif)t the sender and delete this message
From: Allen Price

Sent:Tues(:fay, May 15, 20187:37 PM ,
To: 'sally Price <sallyjprice@me.com>
I can always pick her up and drop her off on Tuesdays.

4
P (425) 265-9100 C (425) 345-6384 F (425) 265-9300
APPLY ONLINE NOW!

CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail
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Sent: Tuesday, May 15, 2018 7:11:59 PM
To: Allen Price
,she is tentatively signed up for Monday at 5:30 be it doesn't conflict V'f

Alexs drivers ed. I'm planning to call tmrw to find out which other •
classes are open. ideally i'd like her to do 2 per week.
(
Sally
Sent from my iPhone
>On May 15, 2018, at 6:31 PM, Allen Price <aprice@leaderl.com>

wrote:
>
>Good to know thank you. I knew she would love it. What days are you
committed to?
>
>
> P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
> E: APrice@Leaderl.com Read my Reviews! Check out my
website!
> Check out my Reverse Website! What We Believe
>
> 1604 Hewitt Ave Suite 401- Everett, WA 98201
>CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-mail
>for addressee. The information may also be legally privileged. This
>intended recipient. If you have received this transmission in error, any
5
>prohibited. If you are not the intended recipient, please immediately
>
>
>-----Original Message-----
> From: Sally Price <sallyjprice@me.com>
>Sent: Tuesday, May 15, 2018 6:28 PM
>To: Allen Price <aprice@leaderl.com>
>Subject: Re: Gymnastics
>
~We went to do a trial class last night. She loved it. Monday night at
5:30 has room for her. I'd like to sign her up for that. I didn't have a·
~ha nee to ask about other days/times be that place was packed .... t~ey
said we could add another day anytime before we attend our first paid
class.
>
>Sally
>
>Sent from my iPhone
>
»On May 15, 2018, at 5:48 PM, Allen Price <aprice@leaderl.com>
"
wrote:
>>
~>Did you end up setting this up? I have not heard anything. __,,
>>
>>
» P: (425) 265-9100 C: (425) 345-6384 F: (425) 265-
9300
» E: APrice@Leaderl.com Read my Reviews! Check out my
website!
»Check out my Reverse Website! What We Believe
>>
» 1604 Hewitt Ave Suite 401- Everett, WA 98201
»CONFIDENTIALITY AND SECURITY NOTICE: The contents of this e-
mail
» message and any attachments are confidential and are solely for
»addressee. The information may also be legally privileged. This
»transmission is sent in trust, for the sole purpose of delivery to the
>>
>>
»-----Original Message-----
>> From: Sally Price <sallyjprice@me.com>,
»Sent: Thursday, May 3, 2018 1:23 PM
»To: Allen Price <aprice@leaderl.com>
»Subject: Gymnastics
>>
»~Jusrheafd back from gymnastics for Madison-:-"
6
>>
» Rising Stars Gymnastics
» http://risingstarsgymnastics.com
» 360-653-7827
»They haves year old classes.on Monday through Thursday at 4:30, \
.....
5:30 and 6:30 and on Saturdays at 9 and 10. I was thinking we could sign~
'her
. upfor twice a week.
..
Parents decide which day(s) and how many
~
times per week and that determines the monthly cost.
Total Control Panel

7
' Sabrina A. Layman

Sent: Wednesday, March 28, 2018 9:48 AM
To: 'Veronica Freitas'
Cc: Amy Pasco; Stevie Craig; Katie Miller
Subject: RE: Price
Veronica
Thanks for the feedback. I will provide that to my client. I don't think Mr. Price
ever has attended or scheduled medical appointments in the past but I realize he
wants to now involve in that.
I also don't think she's not responding to him - I think she does not engage in the
attacks which may cause Mr. Price to believe it's "non-responsive" but when he
asks her to call or text about the kids she gets back to him.
Here'·s an idea, when :he's at school have him pick up a photo packet and order-'.
them himself- that way he can choose what he wants and not have to ask
Sally. That's the easiest way to handle that. ,
~ ~
As for the regular appointments - is he wanting to know when they are now
because he plans to attend? Or am I missing the point?
Sabrina

Sent: Tuesday, March 27, 2018 9:36 PM
Subject: RE: Price
Hi Sabrina,
I am responding to your message, below, but first there are some additional matters I would like to address.
Your client is not sharing information about medical appointments, etc. with Mr. Price. Decision making on non-
emergency health care was reserved in the temporary parenting plan. Your client does not have sole decision making.
,She:should be:informing:Mr. Price about any appointment_s she intends to schedule and give him an opportunity to
(attend or object; etc. At a minimum, she needs to respond to his inquiries about the children's medical:
< appointments. For example, both Col_by and Alex had medical appointments today and your client did not inform Mr..
,Price about them at all. Please advise her to include Mr. Price in medical decision making in the future.'
your client tends to be non-responsive to Mr. Price's inquiries, which causes bigger problems than simply not providing a
response. Most recently, Mr. Price asked your client about the children's school pictures. Apparently, the order packets
were sent home to your client. Mr. Price was hoping to order two sets or to share the cost of the children's photos, but
your client has not responded to his inquiry at all.
1
The unfortunate result of your client's lack of communication is that communication will end up going through attorneys
'· wnich is expensive and could increase tensions. Mr. Price is now reticent to communicate directly with your client given
your client's inaccurate reporting of events below, ,See Mr. Price's comments below. )
~ ~

Sent: Monday, March 26, 2018 1:25 PM
To: Veronica Freitas <veronica@vfreitaslaw.com>; Katie Miller <katiem@brewelaw.com>
Cc: Amy Pasco <amy@vfreitaslaw.com>; Stevie Craig <stevie@vfreitaslaw.com>
Subject: RE: Price
Veronica
I met with Sally this morning and we will send over a proposed Final Parenting Plan
this week. It is our hope that will resolve the parenting issues fully and finally. In
the meantime, I wanted to respond to your client's other issues and let you know
what I see happening on this case.
1. I have now copied you in on the email that was originally copied to Kirstyn on
the remaining items we need to do the business valuation. I'll send out a
formal request as well tomorrow.
2. As for the weekends that your client has business trips, my client indicates he'
a_-rr:ives home on Fridays from those trips and she is not opposed to having his
~mother pick the kids up Thursday per the schedule as she did the last)
weekend with a conflict if that remains convenient for him rather than>
'
Jussing with changes on the regular schedule. With the number of trips that
he is taking the idea of trying to figure out make up time or switching
weekends is too complicated and since his mom seems open to the idea we
are ok with that. The other option is that he just pick the kids up on Friday
from my client. That's fine too. Of course she'd love to know well in advance
as he indicated so she can make sure she knows who is getting the kids or if
they are staying with her.
3.cYour client has been communicating through the children and swinging by
the house not infrequently for sundry of things. Please have him,
communicate directly with Sally. ;She's trying to keep those lines open as
well. For example, she received some of his mail and texted to see what she
should do with that and he said he would come get the mail and that was
2
.. fine with her. What's not fine with her is him texting the children to say he's
purchased new shoes and that he's coming over to let the kids try them on
and then shows up without Sally knowing until he's in the driveway. Or,
inferring to the youngest child that she needs to call him every day that she is
with her mother - she's 5 years old - that's a bit much and the little girl is
stressed if she doesn't comply or forgets. When your client showed up for
~his pick up this weekend he made sure to tell Sally that if she did not agree to
,his
, proposal for visitation he would get a Guardian Ad Litem to investigate-
~ Sally- that's a threat of abusive litigation.) I understand these folks
communicate differently, but as I told you when we spoke, his techniques of;
;bullying or demanding are roadblocks to moving this case forward·. If he-->
~wants resolution, then he needs to back off his threats. _;
First this is completely untrue. 1. Alex said he needs new shoes for athletics he is 15. His mother says she
can't afford them. This is what she tells all the kids. I told him he can borrow mine if he wants to see if he
likes them. He said great swing them by he needed them badly, I told him to see if it was ok with his mom. He
did not get back to me so I called Sally and told her. She said he never told -her I sa~d ok then I don't need to
(c-ome by lean do .it another time. She said I don't want to be the reason you can't come by, l said no it is fine :
che should have told you. She said no go ahead. So I went over there.
As for the Madison and being stressed out over calling me, it has never happen and never would. I have never
told my kids they need to call me daily or anything like that.
As for th~·Guardian ttold her that it is in the kids be~t interest to agree. Theywant more time withme and they '.
n~ed more time with me. l said that I would have no choice but to get a Guardian if she did not agree. '\
(. -
4. I understand that your client is now starting to involve himself at the

children's school through volunteering and emailing the teachers. As we
stated before, that's great - my client has no issue being in the same school
or classroom with him. What he doesn't need to do is pretend that he's )
cbeen the contact or primary parent all along. What I call "parenting for
show" is unnecessary in this case {all cases actually). He doesn't need to let
c Sally know that the teachers are good about emailing him back - she's;
(known that for years. He doesn't need to step in and secretly make)
~conference appointments and only tell the kids who then feel obligated to let
their mom know that "Dad's handling the conferences" - that's uncool·: Sally
then has to text your client to say she'll be at the conference as well. And, he
certainly doesn't need to "buy" these kids with $800 Gucci tennis shoes or
trips with a 5 year old to iFly that the kids then feel guilty about because Sally
cannot afford the same thing. Sally wants him to be with his kids and enjoy
their time together. She is not undermining him as a parent and doesn't,,
,down talk.him when he's ·late to pick up or changes plans or cannot make it}
3
~ I ,:due to busine·ss. She understands that' What she doesn't appreciate is the
~newest version of this case which is Allen telling her he wants 50/50 time and
,he'll just get a nanny for the kids and if she does not agree then he'll "go to
'. war" on the issue; As I said on the phone, whenever my client is making
progress in getting one more "Allen" project done so that she can work
towards her plan of independence, he trips her at the start line by telling her
he's gearing up for custody litigation or how terrible she did on answering
the discovery questions or demanding that she send him regular photos and
updates on the rental properties. So, as I said, please let Allen know that his
constant "pulling the rug out" only serves to make this case more costly and
lengthy- which it would seem is something he also wants to avoid. It's
within his control.
Mr. Price has worked extremely hard, to the point that it almost killed him, to financially provide for his children and
your client. That is not parenting for show. Mr. Price was able to attend all of the children's sporting events and he
coached their teams for years. He attended as many of the children's conferences and educational events as he
could while maintaining that work schedule. His efforts allowed your client the luxury of being able to stay home.
Mr. Price did not schedule a conference. The parties' had the exchange below regarding the conference:
Mr. Perkins told me the date and time that he had for Colby I did not schedule anything. Look how shit is being
shaped read the text below!
Her when did you schedule a conference w mr perkins? i want to be there

Me I can let you know later today it is n my calendar. I am in class today. He gave the time and date. He also said
if we would like we could do it separately. I told him I am fine with together but you would decide that for yourself.
Her isn't it better if we go together? Same info, both hear each others questions ...
( Me -; I said to him I was fine with together. He said he would accommodate us considering the situation. If you
need it sooner he is really responsive via email.
Me -~ From now on can we order pictures together since this things get sent home with the kids and I don't even
see them to order?-l want my own packet!
'
< Me ; So it looks like you scheduled Madison's Confrence do we want to attend that one together also? I am fine
with that.
Let me know ASAP so I can schedule my own if you don't want to.
Wed 3/28 at 1:20. i'm
Her fine w joint conference. It is preferable
Her i'll be at colbys thursday at 1:25
Me Ok great I thought it was that time but wanted to comfirm once I got to the office.
Again never answered the picture question and just gave me a couple small pictures.
C-:t am iieveflate to pick up kids unless I am out of town working)
Here is the situation with the Gucci shoes and ifly:

:t_he-shoes were 600 and Alex paid me 200 of the 6_ond t pay tlim for his grades and that is what l owed him. As for
lfly the kids have been asking to go there for months.
It seems your client is making different choices about how to spend her money.
4
I ft ·•
Re.quest for photos:
I asked for the photos on the apt interior and exterior so I could look into a CMA like opposing council requested. I
need the pies to do that. When I made the request she said she was busy with taxes and I said that was more
important than the pies so just send them after the taxes are complete. Not sure where the demand is there for
that.
5. To get a November trial date, you'll likely need to file for trial setting
sometime in June - We don't get to hand pick the date up here.
-Sabrina
From: Veronica Freitas [maifto:veronica@vfreitasfaw.com]

Sent: Wednesday, March 21, 2018 9:27 PM
Subject: Price
Hi Sabrina,
I am following up on our telephone conference earlier today-: I spoke with Allan and asked about the additional
~ocuments that you need from his company to have the business valued. He was not aware that you had requested:
:additional information. Would you please forward that request to me and Allan will see what he can do to facilitate
getting you the information?
We discussed-expandi~g_the residential schedule to include a Thursday overnight in the off week, instead of the ;
1Wednesday dinner visit. I forgot 1:6 request a 50/50 residential schedule over the summer months as well. Would you
please discuss that opt'ion:yitit!'·{o~r client too? . --
I found out more about how frequently Allen might need to switch weekends with your client.,He explained that the
:only time he would need to travel for work on weekends when he had the children would be for board meetings, which
,occur approximately 6 times per year. He has substantial advance notice of those meetings as they are all planned for
'the upcoming year. He can give your client the dates of the board meetings that conflict with his residential weekends
several months in advance it seems. We would like some provision that allows your client to choose between her
weekend before or after Mr. Price's weekend for him to have instead of his weekend.
Please let me know if your client will agree to permit Mr. Price to go through the home and document the property
either by photo or notes. He will agree not to take any property from the home at that time. He can then compile a fist
of items that he would like and I will forward it to you to discuss with your client.
I also forgot to discuss setting a trial date. Allan would like us to set a trial date in November, 2018. Please let me know
if you are not able to do a trial in November. Thank you.
Veronica Freitas
544 29th Avenue
Seattle, WA 98122
Phone: (206)328-7362
Fax: (206)323-0404
mailto:v@vfreitaslaw.com
5
www.vfreitaslaw.com
'6 ' • t
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From: veronica@vfreitaslaw.com
6
r
FILED
2018 MAY 29 AM t1: 14
17-3-02497-31
DCLR 59
2
1
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4
INTHESUPERIORCOURTOFTHE STA1'E-0F W'ASHLNGTQN

.. ·. .. .. IN A.ND FOR TI-IE.COUN1Y QF $NQHQMISH
c~ No.;: r7- ~- 6 z. Lf °11- ~I

De~~:; :f?tMJ;1LJr
(()ptional(Ust:!)
9 (PQLR)
Respondent
12
13 Dec\aration of _ ___;.(.na1111t)
14 J.
15
21·
23 Iigfri~s~tfa!Y'MAN P.S.
Op*m~ Form (f)5J:!I) 16) Declatatfon .?,o, Box48S . . .
24 '£.LAH fa~ty 135 p< lt>f_ Everett,, Washington 9820():-0488·
{425) 252·5167 Ptione
{42St252-9055 Fax
www.brewel<1wccom
ORIGINAL
I
.I
1J
12
1:?
14 l declare,.:under penajty of perjury under the la'¥~·9fJJie·$tate ()f Washi11gt,-0n thatth~ facts 1. have
pr0videq on this form,(and any attachments) are true. t lI have attached _ _(number) p~ges.
m~~· 1~
:: .SiSnedaf(<ltyandS!ate)1 WA . .O..c:~ - (J"
17. ~~ p~· ~-~~~:~~·.· ~.42.n ~
~;gn}t;;:e Print name
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Warning! Documents fil~(fwiiii the i!Ourt are .
a~'ailable for~anyo~, tb·s~e unless they:.. are ,
19 ' $~aied~ financ:ial~medical, andconfidentialreports. as dcscnbtd fo:(ten~lRule-22, must be f
s~al~d so ·they cap qnly ~ :~11 by the coi;irt. die othyr party. and the fawy·e!'Sin y.our case. '
20 s~ thus.c ckiClU11CtttS hy filing them sei>arn~~1y; using a S,:aleil pover speet (fonp FL All ,
...f~il)~PJI~.<>.Lg.,.~r. QJ.3-t.Xg~.~!!X.at'] t6r ~.~r9£!:,!Q3ca!.~fJ:it;f~g~~~--· . ·.·.·.-.-.·-··.······.....~
21
22
dptiooru Formf(l-'EWJth Pcclatatfon

I BREW.E LAYMAN P.S.
AtttYn'.leys at Law
t>.O~ Box4S8
24 FL AffF#mil;y 135 .p•.lof'_
r:.i~rff rrif.0~~8206"-0488
{425} S Fax
~.brevtel~w.c-Om
t;' ·r
201BMAY30 PM 3: 19
1 SONYA HRASKi
COWHY CLERK
17-3-02497-31
60
SNOHOMISH CO. W1\SH
OCLR . ·
\\\l~i\1\i\~111~\1111'
fN THI~ SljPERlOR COURT OF THE STATEOF WASIHN,GTON
IN A:NDFORTHE COUNTY Of SNQHQMISH
~a;;:;; ~J-- 3 , 07-4-17 ~ 3 I

Declaration bf
8 5ava¥i ....~ti= ·[Nan1e]
Petitioner, (OptiortaLUse}.
9 (D('LRJ
bl
·Rc.spondent.
J?
:~
l3 . Decl3ration of _ _(1u11ne)
14 L
15
2 •.
16
2.3
Optfoi;a! Fom1 (05/2016i f.kdarat~n
l. BR. EW·. E. l.AYMAN
Attorneys at ~aw
P;O; Bo1t 488 . . .
p,s,.
24 fL)\ltFa~ity 13~ Everett, Washington 982.06-0488

{425) 252~5157 Phone
ORIGINAL (425} 25M055 Fax

www.bre'Welaw.com
,,.
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11
12
l declare.under penally qf perjury under the laws: of the Slfitt: (}f Washirtgt'on that the facts I. have·
provided on this forrn {and any at1achn1ents) are.true. [ ] !have anached __· (number) pag~s.
rs
Signed at(d(}••nd .<1tile).· Yi1~· /t,-T WJI.. Dare· _j[ - ;JI.. q- JJ'
·.f?;?·..01.A.;~ ·-·-- 'Sx:?L.:·c"':.".~~ _fO_.·._o._:.n_.·-~·

Print nttine
18
Waming] Do.~ument;··1~[e(f~vith the'' <;O~rt are ~~:-ailablem for' 'a!i)~oQe to''sfe'UiiiesFthe.}i'iJ:;-
19 sealcd. Financial. medfoal.·a.ndcon11.dentialreports; asdescribed in 'General Rule ?1,:must·be
seal~cl. $0 they()C\O qnly pc ,seen by tge p,ourt, the,c 9ther patty~ and the faW)1ers in your case.
20 Seal those documents. by filing them S-0'.Parateh< using a Seale.d cov~r s4~et (f9rm Fh All
. FamHyOl l .012, or0l3}You mav ask for an......order
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21
22
BREWE LAYMAN R.s.
23
OptiOnal i=orm rOS!10J61 Dedaraliliti
I Attorneys at Law
P.O. Box ASS . . ..
24 .FL.~11 l'amily 135 p;2.or_·_ Bverctt,.Was.hingtor):98206-0488
425.) 2$2-5'167J,Mn.e
1·~.brev.;eiaw.liom
. 425.) 252-9055. Fax
._( ..
.'· :: Sarah Bennett
,. · : RE: Declaration
: May 29, 2018 at 11:35:09 AM
: SaUyPrice
"I declare under penalty of perJLJrY thatthe $tate.ment i$ true

and correct".
My .name is Sarah a·ennett and I am the Parent Coordinator at .

MCEP For Mrs. Greens classroom.
Being· partofthe CO OP program requires 2.5 hours. a week in
the .classroom,, Monthly meetings that are the. 2°<4 Thursday .of
the month at 6:3Qpn1 CJ;nd th,at·you attend 2 fieldtripsa year.
AUen .Price 1st oay Volunteering in the cla$sroom. was 3-9-2018
!He has. mis~ed his workday due to meetings on March tsth
and Match 29th. Allen has never atte:nded :a. monthly meeting .
Sarah Bennett
mass m
425-29,9-5ll5
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17-3-02497-31
RPY 61
2Dl8MAY 31 AH 11: 11
~\~tl \ \l\ \ tl \ l \ ~ \ \ \~
1

6
7
SALLY JO PRICE, PETITIONER'S REPLY MEMO
8 RE: COMMUNICATION AND FEES
Petitioner,
9
and
IO
11
Respondent.
12
13 COMES NOW, Petitioner by and through counsel undersigned and provides the following
14 reply Memo and proposed order:
15
1. I am the attorney of record for the Petitioner above.
16
2. After receiving the Respondent's response to our motion for Communication and
17 Attorney's fees, I prepared the attached agreed order based on the following sworn
statements of Respondent:
18
a. Page 1 Line 19, "There was no need for Sally to file a motion regarding
19 communication. I am happy to agree to use whatever form of communication Sally
prefers."
20 b. Page 2 line 26, "We have $75,000 in a Key Bank account. I propose ... that we
equally divide that account as a pre-distribution to each of us."
21
3. The attached order adopts those agreements and should be ordered by the court.
22
BREWE LAYMAN P.S.
24 PETITIONER'S REPLY MEMO

OR\G\NAL P.O. Box488
(425) 252-5167 Phone
RE: COMMUNICATION AND FEES - 1 (425) 252-9055 Fax
www.brewelaw.com
' . ., '
1 4. Based on the representations of agreement to the requests in the motion, Petitioner is not
responding to the other materials in the Declaration of Charles Price or attachments thereto.
2 Her lack of response does not and should not be construed as agreement or confirmation of
the allegations or statements of Charles Price.
3
Dated this~ J day of May, 2018.
4
BREWE LAYMAN P.S.
Attorneys at Law
5
6
abrina A. Layman, WSBA
7 25260
8
10
11
12
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
24 PETITIONER'S REPLY MEMO (425! 252-5167 Phone
RE: COMMUNICATION AND FEES - 2 (425 252-9055 Fax
www.brewelaw.com
1

6
7
SALLY JO PRICE, ( AGREEDf>RDER RE:
8 COMMUNICATION AND
Petitioner, PROFESSIONAL FEES
9
10
and
~
CHARLES A. PRICE, JR., 1vopo0
11
Respondent.
12
13 COMES NOW, the parties herein by and through counsel undersigned and agree to the
following:
14
1. The parties shall set up and use App Close (parenting communication and calendaring app)
15 to communicate about the children's schedules, needs, etc. This does not prohibit each
party from texting photos or notes about the children if they so choose; however,
16 information about activities, appointments, school shall be through the family calendar
system. Petitioner shall take the lead in setting the system up as it was her motion that
17 requested it but both parents shall make sure to use the system for information sharing. In
the event of emergencies (activities, medical appointments, or other such things) that have
18 less than 24 hours notice, the parents shall call or text or message in a faster method.
19 2. The parties agree to liquidate, close and split Key Bank account #2657 (value of
$75,860.00) with each parties' attorney receiving 50% of said amount for professional fees
20 and costs subject to the trial court reallocation (i.e. Petitioner does not necessarily agree
that the overall distribution of the estate will be 50/50 but for purposes of this account
21 agrees to that division). This shall be accomplished within 15 days of this order.
22

Attorneys at Law
P.O. Box488
24 AGREED ORDER RE: COMMUNICATION AND (425j 252-5167 Phone
Jt'JM4J;jl~IONAL FEES - 1 (425 252-9055 Fax
www.brewelaw.com
• ..J.. l .... ~ "'
1 DONE IN OPEN COURTthis _ _ dayofMay, 2018.
3 JUDGE/COURT COMMISSIONER
4
Presented by:
BREWE LAYMAN P.S.

5 Attorneys at Law
6
By~~~~~~~~~~-
7 Sabrina A. Layman, WSBA 25260
8

10
11 By~~~~~~~~~~~-
Veronica Freitas, WSBA
12
13
14
15
16
17
18
19
20
21
22
BREWE LAYMAN P.S.
P.O. Box488
24 AGREED ORDER RE: COMMUNICATION AND (425) 252-5167 Phone
J,?~rlj'ji~IONAL FEES - 2 (425) 252-9055 Fax
www.brewelaw.com
,,.
lfl!B MAY 31 PM 12: 34
10 SALLY JO PRICE, No. 17-3-02497-31

Petitioner,
11 and Declaration of Charles Price in Strict
Reply re Motion to Appoint Parenting
12 Evaluator.
13 Res ondent.
14
My name is Charles Price and I am the Respondent in this case. I am over the age of 18
15
16 and am competent to testify as a witness in this matter. I am writing this declaration in strict
17 reply.
18
I disagree with Sally's contention that I am pursuing a parenting investigation because I
19
am angry about her request to value my 3.5% stock ownership in Leader One. That is a false
20
narrative her attorney has created to prejudice me before this court. I am a very minority
21
22 shareholder in Leader One Financial. I only receive W2 income from the company. There is no
23 point in me doing a phone conference with Sally's valuation expert, as I have none of the
24
business .financial information, and the expert has all of my income information. I addressed
25
financial issues at the temporary orders hearing primarily because Sally was seeking 100% of
26
27
28

Declaration in Strict Reply re 544 29th Ave
Motion to Appoint PE/GAL Seattle, WA 98122
Page 1 of6 (206) 328-7362
v@vfreitaslaw.com
my income for support, which was frightening to me. I feared that I would be forced to go into
2
great debt pending trial or worse default on my support obligations.
3
There have been substantial changes with respect to the children's situation, attitude and
4
5
demeanor since the temporary orders were entered, and since I completed my interrogatories in
6 January 2018; they were served on me in December and in tum they were sent to Ms. Layman
7
in January 2018. I was home every day and I saw my children every day during the marriage.
8
Sally was the primary parent, but I was present every day. I see now that my daily absence is
9
impacting my children profoundly, particularly my sons who are older and who need me to help
10
11 provide them guidance on a consistent basis. I see that the long absences in the current
12 residential schedule is harming them.

13
I am not seeking RCW 26.09.191 restrictions against Sally and I never was. That is
14
what the interrogatory responses are addressing. I am seeking an evaluator to make
15
recommendations about what the best residential schedule for our 15 and 11-year-old sons and
16
17 5-year-old daughter should be. Sally was a stay at home mother during the marriage while I
18 worked full time. I was not aware of how Alex's demeanor with Sally had diminished when I
19
completed my interrogatory responses. I did note communication issues between Sally and
20
Alex.
21
22
I have always had concerns about Sally's engagement with the children when she stayed
23 home. For example, Sally is a teacher, but when each of our children began school, they were
24
substantially behind. ~ee Maddie's report card attached at Exhibit A. Her foundational skills
25
are a 1, which means she is significantly below grade level. The comments indicate that
26
Maddie was not prepared for school this year. She only knew numbers 1 - 4, she did not
27
28

Page 2 of6 (206) 328-7362
v@vfreitaslaw.com
recognize 5 -10. She could only identify 3 of 9 shapes and only recognized 5 of 26 words and
2
had only learned 8 out of 30 words by March 21, 2018. Maddie is still behind and Sally is not
3
able to help her for some reason. I note that none of our three children were prepared for school
4
5
when they started. They all caught up quickly, but this speaks to how Sally did her stay at home
6 parent job. Sally was also a French teacher. None of our children know a word of French. Please
7
see Alex's and Colby's 1st grade report cards at Exhibit B. Colby is now in the gifted program.
8
This does not support Sally's supermom narrative.
9
I am not seeking a GAL to hurt Sally. Sally's arguments about our temporary orders
10
11 and the interrogatories ignore reality. I always hoped to have an equal residential schedule with
12 the children. Sally and I were discussing a 50/50 residential schedule when we discussed
13
separating. I was initially going to buy a house in the same neighborhood as our family home. I
14
needed to make the purchase before Sally filed for this dissolution so that I could qualify for a
15
loan. I planned to live close by Sally's home and be equally involved in parenting. Please see a
16
17 note that Sally wrote where she summarizes my proposed purchase of a house in our
18 neighborhood and she notes 50150 parenting? at Exhibit C. When Sally and I told the boys
19
about the divorce, Alex said he wanted to spend equal time with both of us. I had not pressured
20
Alex to reside with me 50150. It was his initial response to learning about our impending
21
22
separation. See Sally's notes summarizing that meeting attached at Exhibit D. I do not agree
23 with Sally's description of me screaming that she was a liar during that conversation, however,
24
she did accurately record Alex's C<?mments.
25
I proposed the temporary residential schedule that I did at the temporary orders hearing
26
on the advice of my attorney at that time who told me that I could not expect to get more at that
27
28

Page 3 of6 (206) 328-7362
v@vfreitaslaw.com
time. I was told that it was a temporary residential schedule. I expected that Sally and I would
2
be able to agree to me having significantly more residential time than I currently do in the
3
temporary parenting plan once things settled down. Clearly my expectations were off base.
4
5
Sally is moving further and further from being reasonable as time goes on. Now that I have seen
6 what has been happening with the children since we separated, I am confident that a more
7 balanced residential schedule is in the children's best interests. I am not motivated at all by
8
financial matters as Sally asserts.
9
I have always been very involved in our children's lives. I coached football at Arlingto
10
11 Boys and Girls Club, and at Lakewood Youth Football for seven years. Sally attempts t
12 minimize my commitment to the boy's football. We practiced 5 days a week for 2.5 hours pe
13
day and there was a game on Saturday. When school started we practiced 3 days per week fo
14
2.5 hours and had games on Saturday. The Saturday games were 5 to 6 hours with drive times.
15
Sally never attended any of the boy's football practices and rarely attended their games.
16
17 submitted several declarations from parents regarding my involvement with the children at th
18 temporary orders hearing. I am submitting them with my response for the court's convenience.
19
stand by my representations about my involvement in the children's lives. Please see the lette
20
Sally wrote to me in September 2017 where she describes my involvement with the childre
21
attached at Exhibit E.
22
23 Sally ignores that I had a massive heart attack on April 19, 2017, which profound!
24 changed my work life. Before my heart attac~, I had been working 6 days a week, up to 1
25
hours a day and I was on call 7 days a week. After my heart attack, I put my health an
26
parenting as my number one priority. I now work a regular 40-hour week. My work schedule i
27
28

Page 4 of6 (206) 328-7362
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flexible so I now have time to volunteer at my daughter's school. See note Sally wrot
2
confirming that I asked about volunteering in Maddie's school in October 2017, attached a
3
Exhibit D. I volunteer every Thursday. I have missed two Thursdays due to board meetings tha
4
5
are on Thursdays, which I am required to attend. I let the school know that I would occasionall
6 have to miss a Thursday which they approved. Please see letter from Maddie's teacher, Kirste
7
Green attached at Exhibit F verifying my presence in Maddie's classroom.
8
Alex has always been very respectful to me. He is very respectful at school and with every
9
other adult he deals with. See his current report card attached at Exhibit G, which shows that he
10
11 has a 3.2 GPA and is a pleasure to have in class. I was shocked by his demeanor with Sally when
12 we all met. I stayed out of her exchange with Alex in part because I did not want to get accused
13
of interfering with her efforts to parent and in part because I was in shock. Immediately afterward
14
I spoke to Alex and explained that his behavior was totally out of line and that I never wanted to
15
hear about him talking to his mother that way again.
16
17 Alex sent a photo of Sally's marijuana pen to his cousin Katie, not a photo of packing
18 material. During the marriage, and in my interrogatory responses, I stated that Sally and I both
19
practiced the Christian religion. That has apparently changed for Sally, which is her business, but
20
it is also confusing to the children. See photo of book about Wicca attached at Exhibit H. The
21
22
children describe seeing Sally meeting in the living room with several people with strobe lights
23 and burning sage, etc. This is causing anxiety in the children. They sense an air of instability in
24 their mother which is causing them stress.
25
I declare under penalty of perjury under the laws of the state of Washington that the
26
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28

Page 5 of6 (206) 328-7362
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2
5
Charles ft;::e
6
10
11
12
13
14
15
16
17
18
19
20
21
22
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25
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EXHIBIT A

I
Rni. MarYSvllle
Progress Repprt I Student: MADISON PRICE StudentlD: 0985509 Grade Level: Page 1
V4,p &• Ju,wl n1vriq
Year: 2017-18 1-----------------------f---------------r-------r---i
School: MARYSVILLE COOP PROGRAM Teacher: KIRSTEN GREEN Kindergarten
~tlendallce Skills and BehaviorstoPromoie Learning-· ... - ... - 1s 2$ ,. FIEADiNG (coiitillu!ild)
1S 2$ 1.S 2$
···a5 y· ; . - - ... ·- .... ~-~-- ·--
Self-Directed Learner
I 2 .j - ---1 ~e~tii~~PRd~~~~~-· _.,______ _ 2
0
3 Works independently
Uses time productively 4. Above grade-level
sliili>o'rtservices ·cmari<e<i if ref.:eiveci> Organizes materials and workplace and is prepared to work
;3. At grade-level
Asks for help when needed 2. Below grade-level
IEP driven support
Reading Collaborative Worker o-c-1 1. Significantly below grade-level
I
Written Language WRITING .. --·--··--·. ·--- ·-·· -
Works well with others
......--······. ····-· ·--·
......... ··- ....
Math Respects rights, property, feelings and ideas of others
Writing Types and Purposes 3
Behavior Resolves conflict positively
OT/PT
Responsible Citizen 0--c-1 Uses a combination of drawing, dictating, and writing to compose
SLP grade-level opinion pieces
Non IEP support Follows school/class rules Uses a combination of drawing, dictating, and writing to compose
m
Reading Follows directions
grade-level informative/explanatory texts
Math Accepts responsibility for actions Uses a combination of drawing, dictating, and writing to compose
504 Plan
ESL
Work Habits n=c=i narratives
Reflects on quality of work and sets goals to improve Writing Production and Presentation of Knowledge
HICap 3
Completes class work and homework on time
With guidance and support, strengthens and publishes writing
4.
KEY for Skills and Behaviors
to Promote Learning
EKcoodlng Expoctalione
_. _J
READING
English & Language Arts
1$
=1 2$
Participates in shared research and writing projects
iSPeA.kiNG AND iisretf1N<i . 3

Consistently and independently meets eKpectallons
3. Mooting Expectations Literature I 3 I I Participates In collaborative conversations through multiple exchanges
Usually meets expectations with minimal assistance Clearly describes familiar people, places, and things orally
A _.-:::'"A-1->- - .-.. _. ---•• _ -=:i Asks and answers questions about stories that are read aloud
ILANGUAGEf -- ....
...
With prompting and support, retells stories including characters, setting, and 2
major events
Recognizes common types of texts, such as poems and storybooks, and defines Demonstrates grade-level use of English grammar
1. Below Expecl!l110ii9-,;:;:;;;. of Concern the role of an author and illustrator Demonstrates grade-level conventions of capitalization, punctuation,
y·maets expectations and requires considerable With prompting and support, uses illustrations and key details to compare and and spelling when writing
assistance and/or redirecting
contrast experiences of characters Writes letters and numbers legibly
SC" See Comments ~-~---i Acquires and uses grade-level vocabulary
KEV for AcademiC sianliards oescrlptOrs · Informational 1 x 1 uses strategies to determine the meaning of unknown words and use
......... -. · · · ---- -- -- -·-··· ·· -·-· -·- ·· --·· ··-- ··· ·- · -···- With prompting and support, asks and answers questions to identify the main them appropriately when speaking and writing
4 · Exemplary topic d k yd I ·1 0 f a I t
Consistently demonstrates mastery Of, or exceeds grade-level an e e al s ex H d ltl
an wr ng
standards
3. Proficient
Demonstrates understanding of grade-level standards and
With prompting and support, describes connections between pieces of
Information In a text
With prompting and support, identifies similarities and differences within and
Writes letters and numbers legibly, uses spacing and appropriate
size with guidance
I 2
1
1
1
can apply concepts i.n a variety al contexts _J.,eac~r~O~Ja:~===:::::::::---
2. Approaching Proficlont - - - > - - - L J ENG'L1st-i LANGUAGE Ai'trs· EFFORT
Beginning to, and occHslonally does, mcot grade-level Foundational Skllls E'naifsii LanauaCie-Arts-f:iforl" ·· ·- --· 1 3
slandards
Demonstrates understanding of basic features of print Enallsh Lanauaae Arts Effort (ELL. IEP. LAP onlvl I 3
1. Nol Yet Proficient
Not meeting grade-level standards and Is working one or Demonstrates understanding of blen~, segmenting, sound, and rhyming
more years below grade level Demonstrates knowledge of letter soun s
IE - Insufficient Evidence Knows upper case and lower case letters n D...~ S
Prollciency cannot yet be determined due to lack of evidence, Reads grade-level hi~h-frequencv words ~
and/or length of time in school Reads grade-level texts with purpose and understanding
X - Nol Appllcab!o
Standard was not addressed during the grading period
SC= Sec Comments
15
Y"L C-l...·""t..Vt
!English Language Arts Comments:
Page 2 Kindergarten I Student: MADISON PRICE
81 Comments "' ~ "'".. . ... ..... ' ' . ._.
English Language Arts MATHEMATic's
During the first semester, literacy instruction has included the 26 letter names and sounds, 18 high
frequency words, and blending letters in order to sound out words. We have also built comprehension
skills by comparing storylines. characters. and settings. We have worked on prediction. sequencing, and
Counting and Cardinality
Knows number names and the count sequence within 100
-~·-
main idea. Writing instruction has included Opinion Pieces and Personal Narrative stories. In order to Counts and tells the number of objects up to 20
write their Ideas. students apply their knowledge of letter sounds. Students should now be able to read Writes numbers up to 20
Guided Reading Level A text independently. Madison has recently mastered 13 letter names and 18 Identifies whether the number of objects in one group is greater than, less than, or equal to
letter sounds. Additional small group work at school, and practjce at home, has helped her to "fill in" the number of objects in another group
!these gaes. She will need additional review in order to begin blending letters to sound out words. Compares two written numerals between 1-1 O
Madison has mastered 3 of the expected 17 high frequency words. I have referred her to our support
team at school in order to help identify additional ways to help Madison to catch up.
Operations and Algebraic Thinking r 2 I
Understands addition as putting together and adding to; understands subtraction as taking
apart and taking from
Fluently adds and subtracts within 5
Determines the number needed to add a given number, 1-9, to make 10
Numbers and Operations In Base 10 IX!
Composes or decomposes numbers 11-19 as ten and some ones
Measurement and Data I 3 r
Describes and compares measurable attributes of objects
Classifies objects and counts the number of objects in each category
~2 Comments IGeometry I 3 I
Identifies and describes shapes (squares. circles. triangles, rectangles. hexagons, cubes,
cones, cylinders, and spheres)
Analyzes, compares, creates, and composes shapes
MATH EFFORT
Math Effort T ··-3--T
Math Effort (ELL, IEP, LAP onlv\ I I
Math Comments:
S1 Comments
Math
The math skills covered first semester have included counting aloud to 30, naming 5 of the basic 20
shapes, recognizing numbers to at least 10, and stating the addends for 5 (1+4, 2+3, etc.). In addition to
this, students are beginning to discuss their reasoning while solving matllematical problems. Madison
was able to count 12 objects and count aloud to 12. She had some djWqH!t)I with namjog the numbers
0-1 O, and placing them in order. Madison was able to write the numbers 0-4 but wasn't sure how t wri
'numbers 5-10. At home, Madison could rac Ice o locks ovens. Tv's etc. he could
a so pay mg game" with 5 objects. Qjrectiona will be sent home for how to do 1s. inally, to
make numbers meaningful to Madison. she could write down the current ages of various friends and
family, followed by the ages that they will be on their next birthday.
-· ---
Progress Report Student: MADISON PRICE Grade Level:
GM•uysville
~du111 1)11.lrkt
Year: 2017-18
School: MARYSVILLE COOP PROGRAM Kindergarten Page 3
····-
Semester 2 Comments Social Studies 1$ 2$
Understands maior ideas and relationshlos in classroom and school communitv I 3 I
S2Comments Particioates in discussion of social studies tonics In a nroun settinn I 3 I
Effort I 3 I
Demonstrates effort and strives for quality
Perseveres
. .. -... ...
Science 1S 2S
-·--------------------------------------------------------··1------r--
Demonstrates conceots and skills In the malor areas of science3
Understands science content knowledge
Inquiry - makes observations and answers questions
Applications · solves simple science problems
Systems - identifies parts of living and non-living systems
l;ffort I 3 I
Perseveres
•·····-····· ···-·· ..
$peciiii1st 1$ 2S
---·-- ---····
lieaitii&F1tness ··
...Demonstrates---------------·------------·------------···-·------1·-···T---
motor and snort skills annronriate for nrade level 3
Satelv and activelv enaaaes In a varietv of nhvsical activities I 3 I
Acouires the knowledae and skill necessarv for a healthv lifestvle I x I
Effort I 3 I
Perseveres
Music
6emonstrates and annttes music skills and concents annrooriate to arade 1ev61 rs-r--
Particioates aoorooriatelv in nroun activities I 3 I
);Hort I 3 I
Perseveres
Student Name: MADISON PRICE Page 4
S1 Comments
Madison has made progress this year with friendship skills. She enjoys free time, and other students enjoy playing with her at the dollhouse, etc. Madison has had
some difficulty with focusing during instruction. I have given her extra reminders to look at the visuals that we are discussing, and to join In when we chant something or
count aloud. This lack of participation has caused Madison to miss material. She has not retained the learning that is expected. She is currently getting extra help in
reading through our L.A.P. program. This is helping her to master more letter names and sounds. At home, Madison could practice reading the Reading a-z books that
are sent home each week. While doing this, an adult could remind Madison to point to each word, and pay attention to it's beginning letter. This will also help Madison
to master more of our high frequency words.
,....-.--.,.:_ /'I~-,,, --\
Kindergarten High Frequency Words Units 1-.9

Name: Ma s () n__ \)., - - a\ Read/Write
.Date: .~'b '\r"\ Date: "\lf Date: Date:
UNITS 1-3 UNITS 4&5 UNITS Co&7 Uf\JITS B&9
-
·Q · o.nd hQVe the're
·.~y / for he find
see here she tha.t
-the \
go / come give
I I v
you with hou:J
look v wha.t good nou'.J
this :to ·they so.id ·
. ..
IS do a.re put
Like ./ me from a.LL
UJe no one
UJQnt who
- -
some your
tittle
pLa.y
- -
\Ol\£> ·::. ~ lh is \\sf ~ s "e_

\~ c~ f'"OC'\O\ o~ :- e .._.\ 0 rtl.t.<. It# \;sts ;
Wor6s tca.'4~\\.+ . . '" \<.\f\,le,-5~r+fA .. 1\-\t. V'd •~S are
31~" : • Lt" W'-'"'o\ you..r Ch,\d hQ..5 mcrl--e.reJ. lhe.. \(\"dt..-"o..rtt.f\
e >< f e c,t*\ 04"\ \s ;z, + ulo~~ Ma.~+e.reA. 'o" 3 /a.' / 1 'it
l . ·.1 .. .,_. ,,.,,- ..,.. ··.·.. ·7
·I
I I..
1
6
1
.~.,..._,___,__,...,.-~H
. .
·.1 .
I u.
~ ~\H .. . - . . .. \. _..____
.._ . . _____, l
c;,
/ .I
I
1.
·.....
3 i
2'
..; .1
·~···,··
~· -
-~.·--- ..... .
···~
. ·c-. I
11 ..•
- " .
~
0
0
'-------------~-----------·- -
--- -----------------------------
fl ~J_ fo )lriow
H - v I- VV1tv. ~ -
Spring Conference Share-Ont Sheet
The benchmarks listed below are March expectations. June benchmarks will increase.
Items checked, are March benchmarks that your child has met
Reading: \ (}
Knows 26 letter sounds - C)
_ _ Hears correct vowel sounds in the middle of CVC words - a, e, i, o, u
_ _ Reads a Level B (or higher) b~1) C\ 0-
- - Knows 30 high frequeru:y wor

-
-T ~ vv,.,._ 4-
~~1
1
~ J 0 I(}'<> IA./
VNu~f 1)
(a, my, see, the, I, look, this, is, h1ce, and, for, here, go, you what, to, do, me, we,
have, he, she, come, with, good, they, are, from, no, want)
Writing:
__ wm@ana last name without a model.
_ _ Can print numbers 0-10 7
_ _ Can think of own idea to write about, and create a complete sentence on that topic.
~:~ }vo v ~)-L.
Math:
- - Counts aloud to 80 -
_ _ Counts 20 objects -
_ _ Reads printed numbers 0-20 in random order n G {o n \ /' Kq c k) S (_~ -- l C -)

_!
_ _ Identifies 7+ shapes- K fl 0 u...'-'.:) 3
~' triangle,~ hexagon
cube, cylinder, cone, sphere
Additional things I would like yon to know (see back as needed):

1. How is Madi doing?
,,11..- .s ~ ~ ~.cL \~ )1/1.~ ;i,-·~
(' ~ tYe1 J- £ v~ / l?i, j S /e v~J

rJ / J.-
/k-r ~ ~ ~·;:}-- II s~ Pw. A~L~'~
2. Based on the assessment that I performed in class with her sh . tty f b ~ '"/-;e:-."71'n~ .h??vJ "cl.
her peers. Is that your opinion also? e is pre ar ehmd compared to
3. ~~!~~ ~e:I sh; has ahchance at entering 1st grade at grade level? Is she catching up quickly
. ase on w at you sent me for Sight words she is pretty far behind?
l::>oe~ IV~+ kovv y~-t

~
~- fNt&; )\ <:; O~V'- ~ \A/~ f-vl/\- I" ~1-
~ .p • +, §::-~) ( !Ni- ' ~ ; iwv ')-vv€_

4· What can WE do to help pro~ress Madi? C>J..-- \Iv-_. <, M"'-/1,L._ /:>../ 'iJf vL$
wvf~ e-tA--<L- e-vv.· tl YV\IA.-~/V'OSveJJ
!hi- Tvv-.W'lt'\- '1?~ tk- ~ ·~ '

·~ hi,v,
EXHIBIT B

I
IiVlJ\rL\CULATE CONCEPTION &
OUR LADY OF PERPETUAL HELP SCHOOL ...........-............ _____
0Pcr a centur_1 of commitment in r:ducating the ll'holc child ...
1
l\farch 9. 20 I 0
Re: Alex Price, Second Trimester Report
This narrative repo1t addresses progress made by Alex Price during the second trimester of first grade
at Immaculate Conception and Our Lady of Perpetual Help School in the following academic areas:
reading. language a1ts. spelling, and math.
In the classroom, Alex has demonstrated a positive attitude and seems to enjoy participation in most
classroom activities. He has made progress. although he continues to struggle to meet grade level
expectations in most academic areas. Working independently is a challenge for Alex, and he benefits
from one-on-one assistance. At school, Alex appears to become tired frequently, and he tends to stop
working when frustrated with an assignment. He has been taking many assignments home to
complete and return.
tvlrs. Ferrians, our Learning Specialist, has been ·working with Alex four times a week, for 30-minute
sessions during the school day, on reading skills. In addition, Alex works with Mrs. Ferrians twice a
week for math. also for 30-minute sessions. Although Alex seems to benefit from this academic
assistance. focus and memory challenges have kept it from being as successful as it could be.
READING: Alex is an emergent reader whose skills are progressing. He enjoys selecting his own
books and sharing his thoughts about them with others. He does not yet demonstrate independence as
a reader. Continued work on building phonics skills and vocabulary will enable him to become a
more fluent oral reader and to build his reading comprehension.
LANGUAGE: Alex participates in class and does a satisfactory job expressing himself orally.
especially when given prompts and reminders to keep him focused and on topic. With daily
encouragement and scaffolding, he is beginning to develop written language skills. In the classroom,
he often sounds out the words with the teacher and then writes the letters that he hears. At times, he
dictates his ideas. Toward the end of the trimester, Alex had developed the confidence and written
language skills to start a simple sentence and then complete the written assignment with substantial
assistance. This progress was clearly a source of pride for Alex!
SPELLING: Although progress has been evident spelling remains a struggle for Alex, both in daily
writing and assigned words. Alex is no\v able to include more of the consonants he hears when
sounding out a word: rnwels remain more difficult.
MA TH: Over the course of the year, Alex·s number recognition and number sense have developed,
and he has demonstrated progress \vith addition and subtraction. At times, he has success in using
manipulatives to solve addition and subtraction equations; on other occasions, he loses focus before
completing the assignment. Memory continues to be an issue, particularly 'vvith math facts. In daily
work. his performance is inconsistent. Alex struggles with more abstract math concepts and problem
solving in math at this point.
Gabriele White. First Grade Teacher

A note from Mrs. Ferrians
Alex Price - Alex is significantly behind in skills and, at this time, is just beginning to
read independently. His sight vocabulary is low and he might benefit by practicing flash
cards with high frequency words. He is working very hard to decode words, but does not
always remember phonograms (sounds). When reminded what the sounds are, it may take
two or more tries before he is able to retain the information long enough to decode the
word. Once he has the sounds and can say them, he is very likely to recognize the word.
His oral language skills are very good. During testing, I remind Alex to follow along with
his finger while I read the questions. He is able to focus and comprehend stories when
they are read out loud and answers comprehension questions correctly ninety-five percent
of the time when he follows along attentively. Unfortunately, Alex is not consistently
able to stay focused on tasks. His handwriting is improving, but he is inconsistent and
often needs to be reminded to write smaller or do his best handwriting. He struggles with
remembering the vocabulary words, but his ability to remember words after practice is
improving. He is able to recall the word when given enough processing time. On the most
recent phonics fluency test for short vowel sounds, Alex scored 26. Eighty is considered
fluent.
Alex loves to use manipulatives in math; however, his inability to stay focused often
leads him to building things rather than solving math problems. He does not seem to
remember math facts, but relies heavily on counting to find sums or differences. He also
does not recognize fact families and will do two similar problems (7 + 6 and 6 + 7)
starting from the beginning. ·
Alex is a bright little boy and I am concerned about his self-esteem. He is aware that he
has a harder time with learning than the other students. We have been working very hard
to make sure we celebrate his successes. The other students are starting to tell him good
job without me reminding them.
;q !tliµ: ?n ce_
rHP-
--~
1 ' 2 I 3
=i
MU~~onstrates skills, effort and participation r 5 Is I l READING_. ________·--------·-J-...,..-+-_...~--i------t
Effort
Applies phonetic skills --------+--~1-
r\cquires basic vocabula1)' I-~--------
. ';":"':, I------~-------·
MEDIAREsoucEs&TECHNoLoGv r-STf':.-
Demonstrates skills, effort and participa1io11I I...
I I Reads orally with ease
Reads with Comprehension_____ _
Develops habit of independent reading
·····--··-·---------+-----~-
LANGUAGE __________________ ·-'-'"'-+--1-...cu..--"f----t

P.E.
Demonstrates skills, effort and sportsmanship I 0 I S I ==i
'Effort -·-··-·------·---·····-···----------
Understands and applies language I.~L
I, I ,
:
skills in oral expression _ V
=t5~ ·r±=~--
<cq~i«d ~;=-
Understands and applies language
HANDWRITING 1 =----=l. skills in written expression
VO- ---
E I
Effort --------·- · _ -\-
Devdops '1<ll1' ·
~E-==-==-
=·-
Applies skills tn all work_··-·---·-· V - ___..
SPELLING
Effort ··---------·-----==-- Vf-
x -===·
Effo~t-==--~-±tM-~
Spdling Tests _____ ·-· _- - - - - - - --------
L
Develops skills .
__
ART_ Expresses original ideas _ _ _ _
__ l V
Spd1' "'""'"ly in oth" "'igomeu" : - .
MATHEMATICS.__·-----------·--~ """"' =I ¥;:;,, 4 . ,,.4
~r~:t~-~cqui~~!!~-;;-(~~======--]-1:::--r===~~~~~-:]=~=
RELIGION_
Shows ""ntive M>d «spon•ive
-%u-1~1
otti>u~=~:
Knows. required conceiJts - - - - -
Solves problems through reasoning_ _ 'V; u I I I
Knows ret1uircd doctnne If · Computes accmatcly__________....1 ___v_- ______________
j
CHRlSTf :~;~~£;::.~:ty v
fo< oction• I
IJ I
willingly-------'----~---'-·-~---
·I
SCIENCEAND HEALTH
Effort____________
Understands required concepts
Putidpde• in di"u"ion =
'"d prnjed•
r~ ~~
__V _____ _
_ _ _i,_:'__
V
=
_ 7 ---·
$~ j-
Cooperates ....- - - - ·
SOC~STUDIES
WORK AND STUDY HABITS
Lis tens a tten tiv .. ,
Follows directio ns
II ......
v'-
l/-
i/·- J.f
Effort
Understands required
P"tioip"" in dim.,•ion
concepts~
p<ojeot•~;;
.
'"d
-~ -V
V V
1(-
~
-~---=1
Works accurate! r
Takes pride in h is/her work
.___
~
·- J
"/\ ~ee encJose..ot Vl.Otrrovf,,\1
Uses time well
Homework .
,/ -
_±::_ - __±
Attendance 1st Trimester 2 Trimester 3rd Trimester
Accepts Respon sibility V ±.:. V () 3
Contributesto ;roup discmsions
Ca.res for person 11 and school property
J. --?-- ---
--
Days Absent
V Times Tardy
0 f
Ilf ,4 N y r l'i Ce_,
0 Outstanding S Satisfactun·
I I laving difficulty yet improving H Havinv, diffirnltv
The marks below the subject grade mean:

. ·-
+ Consi~tently meeting or exn·eding grade lr\·el expl'<:t;nions
Arcl1()iocese
../ u~ually meeting grade level expectations of
- Not meeting grade level expectations
Seattle
J. u!ik
TEACH En
W~ COMMENTS
1sT TKli\ll·:STI.:it
,
P,\Rl·:N'f' <>1{ c;U.\IU>l.\N
Plll'IL P1u >c;1u.:ss R1·:l'< Jiff
PIU:tvL,\RY LEVEL
i.et ;;w- ad; ffe Cl)nf};r.Mm j Pu111I Alex Price

-------·------·----------~·-------------------
~ ....
School IMMACULATE CONCEPTION/ OuH
,)!;< -U~t-6:
LADY OF PERPETUAL HELP
Sl<;:--l.\TUIZI-:
TEACHER 2Nl> 'l'JUl\ll•::;Tl·:R 1'.\IU·:N'I' <JR (;tJ.\l([)L\N City Evmun'T
S.'.ee me@~ ecl //tCl!A' r oc!:-r've 1€/lJti, Gracie 1-B
Teacher Mrs. \Vhite

School Year- 2009-2010
"Children and young people have a right to be encouraged to weigh moral values
with an upright conscience, and to embrace them by personal choice, and to know
and love God more adequately."
"The school cultivates the intellect with unremitting attention, ripens the capacity
SJ<;N,\'J'UIU::
for right judgment, provides an introduction into the cultural heritage won by past
generations, promotes a sense of values, and readies for professional life. By creat-
TEACHER 3!U) TIUf\ll·SJ'l-:R l':\IU-:N'I' \JR CUt\RDl.\N ing friendly contacts between students of diverse temperament and background,
the school fosters among them a willingness to understand one another."
"The Catholic school aims to create an atmosphere enlivened by the gospel spirit of
freedom and charity. It aims to help the adolsecent in such a way that the develop-
ment of his own personality will be matched by the growth of that new creation
\SSJ(;N;\ll·:NT l'Olt Nl·:XT SCJIUOL YE.\R: which he became by baptism."
<;RADE-----------·---- JllNE --·------·-
Vatican II "Declaration on Christian Education"
l'KINCll':\I.
MARYSVILLE SCHOOL DISTRICT
Student: COLBY M. PRICE 2012 - 2013
MARYSVILLE COOP PROGRAM
···-·· ··-··-·--·-······- ......_........_.,
1$ 2S Total Writina -:: .. :··.··:·.··.--·.···: ·........ '
2 4.5 6.5 1S 2S
0 0 Writes clearly and effectively 3 3
0 0 0
Effort 3 3
Grade. Mark _Legend ..... .
:4
:3
. 3-
Exceeding Stand
Meeting Standar
3 Minus
communication-.--·--------····---------------····-----·--··-.----·-··:
: 3+ 3 Plus 1S 2S
•1 Meeting Standar
·2 Approaching Sta
Uses listening and observing to gain understanding 3- 3
c NE Not Evaluated
.* Individualized Uses communication strategies and skills to work effectively
3 3
: SC See Comment with others
J~---·----~-l)_upp_o.r:t. ____ . ·--· ····-· -· --· ---·-· ··-··· ··-- ··-··· ... ·-·-·-··- ·-- ··---
Communicates ideas clearly and effectively 3 3
Effort 3 3
1S 2S
Whole Numbers 3 3
Patterns and Operations 3 3
Objects and Their Locations 3 3

Class : All Day Kindergarten
Teach er: KARI BRICKEY Measurement and Graphs 3 3
Reasoning, Problem-Solving and Communication NE 3

1S 2S
Self-Directed Leamer 3 3 Effort 3 3
Collaborative Worker 3 2 .. ·.. ...
1S 2S
Responsible Citizen 3 2
Understands major ideas and relationships in classroom and
school community
3 3
Work Habits 3 2
Reaa1n·-: ···- - ·-· -·· · ·---.. -.. --··- -- -------- -·· · -·· -· ····-- ---··-· -·-· ---·---- ---..
--~·-
Participates in discussion of social studies topics in a group
setting
3 3
Effort 3 3
Understands and uses different skills and strategies to read 3 3
Understands the meaning of what is read 3 3

scieri"C:e... -.-------·----~·--:--···-·-:.-·-:---
...
---·-··--··· ·-----·-·--
.... '
1S 2S
Reads for a variety of purposes 3 3
Demonstrates concepts and skills in the major areas of 3 3
science ·
Effort 3 3
Effort 3 3
I l~s 1:s I andwntma
Writes letters and numbers legibly, uses spacing and

1S 2S
3 3
w·~1Iri. ···--··· · appropriate size with guidance
1S 2S Effort 3 3-
Uses a writing process (participates w/teacher) 3 3
Writes in a variety of forms for different audiences and 3

purposes
3
PRINCIPAL: KELLY SHEWARD 4407 116TH ST NE

PHONE: (360) 653-0630 MARYSVILLE, WA
FAX: (360) 657-6658 98270
Page 1
_J
MARYSVILLE SCHOOL DISTRICT
Student: COLBY M. PRICE 2012 - 2013
MARYSVILLE COOP PROGRAM
Class : All Day Kindergarten
Teacher: KARI BRICKEY
·-·---- ---··- -·-···-······-·-·· .. ··-···-~:
Demonstrates motor and sport skills appropriate for grade

level 3 3
Safely an_d actively engages in a variety of physical activities 3 2
Acquires the knowledge and skill necessary for a healthy

lifestyle NE 3
Effort 3 3
liihisic--··-- ·-··-·---··--·---·--~-· ··-- --.---- · ---------·--~--.·:c-:
1S 2S
Demonstrates and applies music skills and concepts
appropriate to grade level 3 3
Participates appropriately in group activities 3 3
Effort 3 2
IE:?-cirfV-eri·s-ui?Port --- -_,_- ------- -----·-::-.·-.----.-.-_ -_.-.-.1

I l1s l2s I
"No-iiTEfi-siic»oC>ri ··--·--------:·~ ·----.,---.--,-----------....,.,,
I l1s 12s I
:.c1a~j;~G:O.miTI~~}<>i~{~tQ~Jtt$'ff~~~~0_11211.1~r~·~=-~-=~~:_j
: Colby has worked hard this semester and is on track to meet year end . '
: goals for Kindergarten. He is reading independently at ievel A" and will
; progress quickly through this level with more high frequency word
;recognition
: Socially, Colby has a hard time interacting with his peers in positive ways.
: He tends to use inappropriate words, which disturbs his friends. I am
: guessing he is trying to impress his friends, but worry they may not want to
'be around him. He is working on using kind words both in the dassroom
\and on the playground.
'Colby works hard to get his work done in dass. He occasionally needs to
: be redirected to focus on his own reading during "Reader's Workshop•, as
:friends can be quite distracting. I am proud of Colby's accomplishments i
!this far and look forward to continued growth both socially and !
'.a,:;ad~i:nic;:al!Y..a~.tlJ~_yeatJ:KQg~e_ss_e.s.•,_________________1
:_cfa~.C.omm~iitS--=-tor: 2s:10112s/13 ~-~o6H3713F~~-::::::::~~--:;

'Colby has learned a lot thfa-year 1ii·i<rndergarten. He has grown bofh~
: socially and academically. l am so proud of him for working hard to learn ~
; to read ·o· level books. That is quite the accomplishment He is also l
i counting to 100, creating his own patterns, and writing creatively each day. [
i
(I worry for Colby socially. He tends to be reactive, which has not led to ,
\positive consequences in some situations. I encourage him to take a deep ;
: breath and choose his words wisely, all while keeping his hands to himself. '
.
: This is a huge skill, but one that wm serve him well in his lifetime. '
~I am excited for Colby to do great things in First grade and wish him tons {
: of success. l
: Please continue to have Colby read and write this summer to maintain the :
Ls15ill~.1:1.e..ha~111!9r:l<e.q§Q._i1ar:.qJQ_~cgµi~~'-------------·-----j
PRINCIPAL: KELLY SHEWARD 4407116TH ST NE

PHONE: (360) 653-0630 MARYSVILLE, WA
FAX: (360) 657-6658 98270
Page2
EXHIBIT C

EXHIBITD

I
EXHIBIT E

I
__ ,
~
-=-:===----=-:~;m;;;.I====-~:=·····:-~~~-~/~-~---·--·-··---······-······-·-
-- -g~-~-;;;;1e~-~· ~ ~}l~ -·-·······--
· ·· .... _ ·r~-~--~---do ..r:e_~;-~~~ .......... .
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EXHIBIT F

I
May 29, 2018
To Whom It May Concern:
Allen Price has worked in my classroom for 2 hours each week over the last 3 1lz
months. I have had him work with students in groups, and one-on-one. He is patient
and capable with the students. Allen was conscientious about notifying us ahead of
time, when he couldn' t make it in (due to a meeting). I have appreciated having
him as a volunteer in my room.
Sincerely,
Kirsten Green
Kindergarten Teacher
Marshall Elementary
Marysville School District
EXHIBIT G

I
LAKEWOOD HIGH SCHOOL
PO BOX 10
N. LAKEWOOD, WA 98259
MIKE CURL - PRINCIPAL
360-652-4505
Parent or Guardian of:

ALEXANDER C. PRICE
11423 4TH AVE NE
TULALIP, WA 98271
ALEXANDER C. PRICE
State SSID Number: 4523313384
Quarter 3 Grades For Grade: 09 Term 3 2017-18
IF YOU WOULD LIKE TO REQUEST A CONFERENCE WITH YOUR STUDENTS TEACHER/COUNSELOR
PLEASE CALL THE MAIN OFFICE AT: 360-652-4505.
Entity: 401 Q3
CONT MASTERY B A
MCINTYRED PLEASURE TO HAVE IN CLASS.
FAB &CONST A
O'HARAT
t
~ORE A
[ TEAM SPORTS A
i LEGORE
'
EARTH/PHYSICS-9 C+
NAUERTJ RESPONSIBLE STUDENT. MEETS COURSE REQUIREMENTS AND EXPECTATIONS.
I ENGLISH 9 A
HENDERSONC PLEASURE TO HAVE IN CLASS.
I COUGAR PATH-09 p
I DAVIS COUGAR PATH grades will not show on progress report. PASS/FAIL will show
I on quarter report cards.
I Normal Cumulative GPA 3.233

SUCCESSFUL COMPLETION OF All PARTS OF COUGAR PATH IS A GRADUATION REQUIRMENT.
STUDENT IS STRONGLY ENCOURAGED TO ATTEND 7TH HOUR FOR ASSISTANCE.
IF YOU HAVE ANY QUESTION PLEASE CALL THE MAIN OFFICE.
EXHIBITH

I
. . ·.
17-3-02497-31
2018 MAY 31 ···. PMJ2: 34
DCLR 63 .- ·:
3202130
SON~r. '<RA~i.q
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COUNTYCLERH
SNOHOMISH CO. W.C.SH
Ill I111111111111111111111111111111111111
.. ::...·.·.: : ......
' .. ·. ·:: '.. :·.·:_ .·. .· .. ·· . ... .:-:··:.: .
··. · . SuperiobCoul'fofWashington1.County of Snohomish ...·

-: ·; .···
.·:·.··:··.· ,· :·
No. 17-S:.02497;;31 ··
.-·· ... ·
And ~espory#~~sfotner~/pSrtieiJ: · •·.

:··.· · .. ·........ :· .. ···..'.'
~andarettMmer~
·. :":._···:: ... ·-.·

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···, , .>.···· .· :." ·. : ,.. . . ·.::

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: '"'~-··
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·. •.·••••···•·~~:v~.t~::~:~:i:7f~~~~:~~:~ ~:~~::~~;:~:~:!·~::::~;::~~~~i~~:.n.~,r;,~rs·.
.··c:·Jached Ryan ciw'!119fr.~ F~ff C;f 20~ 3 and the $piing of 20'!4. Ryan ·wanted .to play f!ag.footba!i
.. a9ain during: fue Sprtrig'of2015, Sb naturaHy we contacted Allen .t<is~e if Ryan covld be SPart of
· }1•$ team. Alle.nwas#'gfeatcoach to our son as weuas an cft'!e ot'ler ooys on our team· .
· ir,cludlng his 01:vrtsOi-1·:¢:dlby,.AJien v1asan ver}·dedlcated coach: Hewas·wefi6rganized and
.·.~.··~~~~ti:!~~=~~~~~~~~e%:;~;::~~~:~ :~% ~~~::n~~~~d~~:, :P~t~~!~r~~;,aa~drrt.

0 0
a(~eomitabtfl!y; Aller/ h$Sa sp~cia! '-J.'SY of making sure ·L'1at each ahci every one df ihe players
felt Hke•they ware.e·v~fy"irffP?riant part of the team:aU me \.\ihile·having a:!ctofnm. Heyvas an
etimttsiasticario extre~ly ~t1ent coath, and ail of the parents >;,\/ere verf.pleased withhis
dHctlcation: Ra~n·ofshirie \ive couid afwavs count on Allen being there for:e\Tery practice and ail
· · •· .·.·•• oi the games. ! ~CtualiY·Rh~~v this for a f~ct because 1was the team Moriffo_r of t~e
two
·. .>·/:.":'.._........ ..: ..·
•· • I~V:~=~~hdBr~tt 'tt~~i:kfiowli AHen since hinh schooL He Is very cdttfofutble With him.ias a
pi;rs~rr and as ~rcoach>The two of us 1.1\'0'Jid not hesitate in having Aflen ¢oach our son again: ir, ·.·
· ··• · !::J~~~;~·t~::~-~Z~~!~~v:~~:~:d~~~;;t~~~~v~;::~:~~=:~Z~r"~:::i!~!'.s.oa;d
17-3-02497-31
DCLR 64
201B HAY 31 PM 12: 34
~~~m1~111111111111~111111
hre:
Petitioner/s (person!s who started this case): No. 17-3i0'2497-31 .
SALLY JOPRICE
Declaration of
(name): Tyson Steen.__;. _ _ _ _ _ __
And Respondent/s {other party/parties): (DCLR)
. CHARLE$ ALLEN PRICE.. JR.
Peclar@tion of (qame): ·Tyson Steen.·~~-------

1. "t-1 am (age):3Ce years old and I am the (check one): D Petitioner ~Respondent
f,81 Other (relationship to the people in this case):Head Coach For Lakewood Football
Assoc.
2:e I declare:.;_·_ _ _ _ _......_...;,___ _ _ __,___,,.__ _.,...,-___,.,...._--,-----................- - - - - -
I am writing this dedaration for Allen Price. I have known Allen Price for the last 3 years. I coached his
oldest son Alex's football team when he was in ~Grade and 8th Grade. Allen was at every practice rain
or shine. He always showed encouraging words to his son and was respectful to the coaching staff. I
have had the please to coach this year with Allen in Lakewood. His son Colby plays on our team. These
boys are 9-11 yrs. old's. Allen has shown patience and has worked well with the entire group of coaches.
He has been willing to help the boys in whatever way they needed. We are not just coaches in football it
is important to teach these young men about perseverance, disappointment, courage and leadership.
Allen has provided all this to all the boys on this team. He is a great asset to our program .
.· ... · .. ··- ..-· ....... · ..
· opti~na1 ForTTI (05!2016) · Declaration

FLAii Family 135 p.1 of..L
{Number any p8ges you attach to thiS IJeclaratton..Page liI1JifS may apply.)
I dedare under penalty of perjury under the laws of the state of Washington that the facts I have
provided on this fonn (and any attachments) are true. D I have attached (number): -::S pages.
i<Signed alj.91¥anistafe):/lrlrij@.~l (A/14 Date:.l\ lt( /1 1

,L ··<~x:_. .
~~ ·····.·~=·
Optional Fonn (0512016) Declaration

FLAii Family 135 p. 2 ofZ-
2018 MAY 3 l PM f2: 34
17-3-02497-31
OCLR 65 SDr1YA KHASK!
Declaration Affidavit COUNTY CLERK
~i~l\\\\\\\\~l\U~\~~\\\\\\
SNOHOMISH CO. WASH

In re:
Petitioner/s (personls who starled this case): No. 17-3-02497-31
SALLY JO PRICE DeclaratiOn of
(name): Christi Mi//er_~....,..,....---
And Respondentls (other party/parties). (OCLR)
Declaration of (name): .Christi Miller________--.-_

1. ti am (agef '17 years old and I am the (check one): 0 Petitioner 8 Respondent
gf Other (relationship to the people in this case): Jf. 11.t? ~/tl:Jyt(er
2. I declare:_._~...._,..------~-~~~~~----_,_-~..........---~"----~
I have known Allen Price for 17years I have worked with him for14 of those 17years. fnaD ofthose
years of working with Allen, he was working about 12+ hours a day.
Allen was always in the office before I arrived in the morning. He was often stil WOfting when I left in
the evening and always scheduled appointments with Realtors on the weekend. I have recently
returned to the company Allen worts for. Since his Heart attack in mid-2.CU.7 I have noti::ed that he
made lfe changes and armes ior wart later in the morning and leaves by .tpm.
In 1he time that I have known Allen he has coached youth football with my husbend. He toacbes his
son, Colby and my son, Easton. He Is very patient, caring a,m great at teacfjng the leadership skllls that
young bop need. He neftf missed a game or practk:e and was atwaysthere for each child INhen tlley
had quest1oas or just needed someone to talk to.
Allen has been like a family member to me for many years I see how his kids adore him. He Is a great
father and role model. He would do anything for his family.

(Number any pages you attach to this Declaration. Page Jil11its mfiy app1y;) ·
I declare under penalty Of perjury under the laws of the state Of Washington that the facts I have
provided on this fonn (and any attachments) are true. 9-1 have attached (number}: 0 pages.
·,at(cityandstate): ftrua~n 1 /))/.!.- ~Date: //"/~/7
Sign here
; .· . .
· ·
· ·.
·
Christi Miller
Print name
(!.6ns6 · Nilier
j Warning! ·Documents filed with the court are· available for anyone to see unle$$ they are sealed. Financial, l
I medica~ and confidential reports, as described in General Rule 22, must be sealed so they can only be seen by I
I the court, the other party, and the lawyers in your case. Seal those documents by filing !hem separately, using a l
I Sea/edcover~eet (foon FL All F,amily011,()12, or013). You may ask fur~ order to seal other documents I
Optional Form (05/2016) Declaration

17-3-02497-31
DCLR 66 ZOIB MAY 31 PM 12: 34
3202151
So .. t-H\'
AKn 11.511•
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II I IIll II I111111111111111111111111111111 SNOHOMISH CO. l"l\S'
·N: · n
i

In re:
Petitioner/s (person/s who started this case): No. 17-3-02497-31
SALLY JO PRICE
Declaration of
(name): Kevin Coghill_ _ _ _ _ __
Declaration of (name): Kevin Coghill_ _ _ __

1. f I am (age): '5 () years old and I am the (check one): 0 Petitioner [8 Respondent
i:gJ Other (relationship to the people in this case):Athletic Director for Arlington Boys and
Girts club.
----
2. I declare: See Attached Letter:._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

FL All Family 135 p. 1 of J_
. ..
~
(Number any pages you attach to this Declaration. Page limits may apply.)
provided on this fonn (and any attachments) are true. ~ I have attached (number): 1_ pages.
~ Signed at (city and state):___...,Av~_\_,"'--_·:r·.i....;1r'-""'---.-"'-"-~------ Date:;<_ _( f,..._~_l_-_/]. ,__

f ~ L_~ Kevin Coghill_+-j4-_'(,__:_~_ _
c__o_~+-"'-'--~---'-\--'\_
Sign here Print name Z)
i Warning! Documents filed with the court are available for anyone to see unless they are sealed. Financial,
I medical, and confidential reports, as described in General Rule 22, must be sealed so they can only be seen by
I the court, the other party, and the lawyers in your case.Seal those documents by filing them separately, using a
l Sealed cover sheet (form FL All Family 011, 012, or 013). You may ask for an order to seal other documents

FL All Family 135 p. 2 of "Z.-
Our mission is to enable ail young people, especially
those who need us most, to reach their full potential
as productive, caring, responsible citizens.
October 25th 2017
To Whom It May Concern:
I am writing this declaration letter in support for Allen Price. Allen has coached Flag Football at the Arlington
Boys & Girls Club for five years. He is by far one of our more knowledgeable and requested coaches. His
teams are always some of the best coached teams in our league. He has been a dedicated coach and parent
to his teams and children while working as a volunteer for the Boys & Girls Club. Allen has provided great
leadership skills to the kids that he has coached. He has shown great patience in dealing with the kids on his
team while inspiring them perform to a higher level.
If you need to contact me, please feel free to call at any time at 360-435-4442. kcoghill@bgcsc.org
Sincerely,
·4iv~
lvin Coghill
Athletic Director
GREAT FUTURES START HERE.

Administrative Office
9502 19th Ave SE, Ste. F, Everett, WA 98208 •Phone 425-258-2436 • Fax 425-337-8583 • www.bgcsc.org
Arlington Club
18513 59th Ave NE Arlington, WA 98223 •Phone 360-435-4442 • Fax 360-403-1922
17-3-02497-31
OB 67
-i~\1\i\ \ \ i\~1 1 1 1 ~1 II~

1

6
7
SALLY JO PRICE, OBJECTION TO REPLY DECLARATION
8 OF CHARLES PRICE AND SUPPORTING
Petitioner, DOCUMENTS
9
and
10
11
Respondent.
12
13
COMES NOW, the Petitioner by and through counsel undersigned, and objects to the
14
Declaration of Charles Price in Strict Reply, Declaration of Kevin Coghill, Tyson Steen, Christi
15
Miller, and Angela and Brett Miller received by the Petitioner on May 31, 2018, on the basis of
16
excess of page limitations pursuant to Snohomish County Local Court Rule Part V. Special
17
Proceedings Rule 94.04(c)(2)(B) and (F) which provide as follows (emphasis added):
18
PART V. SPECIAL PROCEEDINGS RULES (SCLSPR)
19
Rule 94.04. Family Law Proceedings
20
(c) Family Law Proceedings - Courtroom Calendars and Procedures
21
(2) Family Law Proceedings Motions.
22
BREWE LAYMAN P.S.
24
<fm~ION-1
(425j 252-5167 Phone
(425 252-9055 Fax
www.brewelaw.com
1 (B) Generally. Absent prior authorization from the court, the entirely of all
declarations and affidavits from the parties and any non-expert witness in
2 support of motions shall be limited to a sum total of twenty-five (25) pages.
The entirely of all declarations and affidavits submitted in response to
3 motions shall be limited to a sum of twenty-five (25) pages. The entirely of
all declarations and affidavits submitted in reply shall be limited to a
4 sum total of five (5) pages. All declarations and affidavits must be legibly
hand printed or typed in at least twelve (12) point type, double-spaced, and
5 comply with GRl 4. All pages, including attached declarations and
affidavits shall be sequentially numbered. Working copies of previously
6 filed documents/orders are excluded from page limitation.
8 (F) Sanctions. Failure to comply with this rule may result in sanctions that
may include, but are not limited to, striking over limit pleadings.
9
Pursuant to Snohomish County Local Court Rule Part V. Special Proceedings Rule
10
94.04(c)(2)(B), Respondent's reply materials should not have exceeded five (5). The Respondent's
11
Declaration is five complete pages and has attached exhibits that total 17 pages. In addition, the
12
Respondent filed a new declaration, the Declaration of Kevin Coghill which is one page in length.
13
Therefore, the Respondent is significantly over the allowed five page limit. Submitting working
14
copies of previously filed declarations is not objectionable to Petitioner, but that is not the extent of
15
Respondent's violation of the local rule.
16
It should also be noted that the Respondent provided as Exhibit F a purported declaration of
17
Kirsten Green that is a typed, unsigned and unswom and should be stricken.
18
Petitioner has complied with the court's rules on page limitations. Petitioner requests that
19
the Respondent's inappropriate and over the page limit materials be stricken and not considered
20
due to his non-compliance with SCLSPR 94.04(c)(2)(b). Petitioner further requests that the court
21
enter terms against the Respondent in the amount of $1,000.00 for his failure to comply with court
22
rules.
BREWE LAYMAN P.S.
P.O. Box488
24 (425j 252-5167 Phone
CfM!~ION-2 (425 252-9055 Fax
www.brewelaw.com
1 Dated this -2J.L day of May, 2018.
BREWE LAYMAN P.S.
2
3 ByAtt~
4 Sabrina A. Layman, WSBA25260
5
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18
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BREWE LAYMAN P.S.
P.O. Box488
24 (425j 252-5167 Phone
(425 252-9055 Fax
<fm~ION-3 www.brewelaw.com
17-3 o~
MTHRG ,497_31
Motion H . 68
SUPERIOR COURT OF
WASHINGTON
1iffiiUn11111111 FOR SNOHOMISH COUNTY Cl.
'--'·
CAUSE NO.: 17-3-02497-31

SALLY PRICE COMMISSIONER: TRACY G. WAGGONER
(PETITIONER) CLERK: L. HESSEN/C. OGAWA
AND DATE: 06-05-18 @ 9:00 AM
CHARLES PRICE JR DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: MOTION FOR COMMUNICATION THROUGH APP & ATTORNEY FEES;
MOTION TO APPOINT PARENTING EVALUATOR
ACTION:
PETITIONER APPEARED: YES COUNSEL: SABRINA LAYMAN
RESPONDENT APPEARED: YES COUNSEL: VERONICA FREITAS
DOCUMENTS FILED:
ORDERS ENTERED: ORDER ON RESPONDENT'S MOTION TO APPOINT PARENTING EVALUATOR OR

GAL; AGREED ORDER RE: COMMUNICATION AND PROFESSIONAL FEES, TO BE
FILED BY COUNSEL LAYMAN
RESPONDENT'S MOTION TO APPOINT A PARENTING EVALUATOR IS DENIED. THERE IS NO
INFORMATION THAT THERE IS SOME PSYCHOLOGICALLY BROKEN RELATIONSHIP OR THAT
THERE IS SOME CHRONIC ONGOING ISSUE. THE COURT DOES NOT SEE THAT A
PARENTING EVALUATOR IS GOING TO SERVE THE PURPOSE BEING PROFFERED. THERE
WAS AN ISOLATED INCIDENT, THERE WAS NO ISSUE RAISED WITH REGARD TO THE OTHER
TWO CHILDREN, THERE IS NO LEGAL ARGUMENT WITH REGARD TO PRIMARY CARE, AND IN
TERMS OF PROVISIONS, THE PARTIES ARE IN TEMPORARY ORDERS STAGE. THE COURT
DOES NOT SEE WHY THERE IS NOT MEDIATION ON THE ISSUES.
THE COURT ACCEPTS THE AGREEMENTS ON OTHER ISSUES.
1 MINUTE ENTRY
JL
17 -3-02497
FILED
AGOR -31
Agreed Order 69
2018 JUN -5 AH JO: f O
1
SONYA KRASKJ
2 1iffe1111111111u111u C9UNiY CLERK
SNOHOMISH CO. WASH
3

6
7
SALLY JO PRICE, AGREED ORDER RE:
8 COMMUNICATION AND
Petitioner, PROFESSIONAL FEES
9
and
10
11
Respondent.
12
13 COMES NOW, the parties herein by and through counsel undersigned and agree to the
following:
14
1. The parties shall set up and use App Close (parenting communication and calendaring app)
15 to communicate about the children's schedules, needs, etc. This does not prohibit each
party from texting photos or notes about the children if they so choose; however,
16 information about activities, appointments, school shall be through the family calendar
system. Petitioner shall take the lead in setting the system up as it was her motion that
17 requested it but both parents shall make sure to use the system for information sharing. In
the event of emergencies (activities, medical appointments, or other such things) that have
18 less than 24 hours notice, the parents shall call or text or message in a faster method.
~ ~ k._ -p~.+i-1 <f,\..v.LI.-\ i'~c~vt. t:;t>•/o .f
19 2. The parties agree ta::liquidate, close and sp]jt_ Key Bank account #2657 (value of
$75,860.00) ,1J.i.tb, each flanies' attem.ey receiyjnfl 50% of said amount for professional fees
20 and costs subject to the trial court reallocation (i.e. Petitioner does not necessarily agree
that the overall distribution of the estate will be 50/50 but for purposes of this account
21 agreestothatdivision).-Ptu--\-1-~~ ~ 12Lc..r~i- ~ ~
22
~~ b~'t.. A...e..U".....~:t D'p4-iA \t ~ c;o ~6~~5 J W c;~ll
-pr;,\f\&e.. 1?r"4'f Pf aet"U\..~.+ b~'< ~ ~ ~L-l(_
23
.t-. -o.-.. L·_1_ ... ,,.,.,.s
-p.... r .....,, 1 -r "~ A-~hLul
- ;
""
Ae-
I
BREWE LAYMAN P.s.
Attorneys at Law
'~-·r_AA
~'\""CK~
(JJ/0/10.CJ A.:t ht>D~. P.O. Box488
24 AGREED ORDER RE: COMMUNICATIO~~
lmr:n<:i::<<;!s;:.IONAL FEES - 1 vltJ
G,. NA L- E!Xi~)~s'f~f~~n~~nn~ 8206 -0488
425) 252-9055 Fax
'fe309"rtll:t~ www.brewelaw.com
JUN 5 "
1 DONE IN OPEN COURT this_ f Wiune, 2018.
2
3
Presented by:
4
BREWE LAYMAN P.S.
5 Attorneys at Law

ttomey for Petitioner
8

10
11 By :di-·
Veronica Freitas, WSBA \ ., '{ 05
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15
16
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23 I BREWE LAYMAN
Attorneys at Law
P.S.
P.O. Box488
24 AGREED ORDER RE: COMMUNICATION AND
~~J;l}~IONAL FEES - 2 !425j 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
..-'·
FILED
17-3-02497-31
2018 JUN -5 AH IQ: I 0
ORDYMT 70
Order Denying Motion Petition
3234168 SONYA KRASKI
COUNTY CLERK
stmHOMISH CO. WASH
Ill I111111111111111111111111111111111111

and
De¥~lDA~HIRE.SPONDENT
~<; Atl~ fu~<:
~ Wlt.ac A-Yi )t;~-hJ ~u--~} l<)i:(h_ jlo

t5
±'J ~j m.tU.dj~v.._ A,.,zrl iJ-5 #cxA 5CkfYL_A ~zA_,~
DONE IN OPEN COURT this date: _ _ _ _ _ _ _ __
Copy Received:
JUDGE I~ COMMISSIONER
6101 page I of2 1084-4

Page# 2 ° -t 2-
2-H Cf l - ::S ) Case No. --Pvi "'c_-e_
Case Name J/ ,,,. 3- tJ
!;~ ~rti hYW· ~ ko /':£YW-/
-- ~D~,3 (?/" ~r-~' (__,
JUN 5 20\8
DONE IN OPEN COURT this date: _ _ _ _ _ _ __
p~~
~ ~:s-2&0
T COMMISSIONER
Copy Received:
6/01 page 2 of2 1084-4

\
1 20 IB JUL I 7 AM II : I 4
17-3-02497-31
NTAB 71
Notice of Absence Unavailability
3484657
1111111111111111111111111111111111111 Ill

6
7
SALLY JO PRICE, NOTICE OF UNAVAILABILITY
8
Petitioner,
9
and
10
11
Respondent.
12
13 TO: Clerk of the Court

AND TO: Veronica Freitas, Attorney for Respondent
14
PLEASE TAKE NOTICE that the undersigned attorney of record herein for the Petitioner,
15
Sally Price, will be unavailable from July 20, 2018 through August 13, 2018. Unless previously
16
agreed, it is requested that no proceedings be set during those periods of time, or within seven days
17
of the above-referred dates.
18
19
20
21
22
ORl·GINAL
Attorneys at Law
P.O. Box488
425! 252-5167 Phone
~Q~~OF UNAVAILABILITY - 1 1425 252-9055 Fax
www.brewelaw.com
--- ------------------------------------------
1 Dated this Jt day of July, 2018.

2 BREWE LAYMAN P.S.
4 brina A. Layman, WSBA 25260

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BREWE LAYMAN P.S.
P.O. Box488
(425) 252-5167 Phone
~Q'Jt!~ OF UNAVAILABILITY - 2 (425) 252-9055 Fax
www.brewelaw.com
17 -3\02497-31
NT!D . 73
Nohce of Trial Date
1~mm111m1111mm111m1
2018 JUL 23 PH 12: t 8
SONYA KRASKI
COUNTY CLERK
SABRINA A LAYMAN SNOHOMlSH CO. WASH
POBOX488
EVERETT WA 98206-0488
Date: July 18, 2018

and
RE: Cause No.: 17-3-02497-31
SALLY JO PRICE
and
This is to notify you that the above case has been set for Non-jury trial on November 28, 2018
Court Administrator
follows:
SCLR 40(d) TRIALS- CONFIRMATION
12 noon of the last court day of the week 11/ 16/2018 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.
CR 41(E)
Veronica A. Freitas
544 29th Ave
Seattle WA 98122-6220
Date: July 18, 2018


and
RE: Cause No.: 17-3-02497-31
Sally Jo Price
and
Charles Allen Price Jr
This is to notify you that the above case has been set for Non-jury trial on November 28, 2018
Court Administrator
IMPORTANT NOTICE: Your attention is directed to SCLCR 40(d) and CR 4l(e) which read as
follows:
separately confirm, no sooner than 12 noon of the first court day of the week 11/ 12/2018 and no later than
12 noon of the last court day of the week 11/16/2018 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
CR41(E)
.::··--.
FILED
26"111 JUL 23 ·. PM 12: l 8
1 SONYA KRASKl
17-3-02497-31
ORCTD 72 .
COUNTY CLERK ,
2 Order for Continuance of Trial Date SNOHOMISH CO. W!\SH
4
illll~lllllll\11111111~11111
5 IN THE SUPERIOR COURT OF THE STATE OF WASHING TON
6
7
SALLY JO PRICE, STIPULATION AND AGREED ORDER
8 STRIKING/CONTINUING TRIAL
Petitioner, DATE
9
and Clerk's Action Required
10
11
Respondent.
12
13 STIPULATION
14 The above parties, through their undersigned counsel, hereby stipulate to entry of the below
15 Agreed Order.
BREWE LAYMAN P.S.

16 Attorneys at law
17
By~--r----~~~~~~~~ By___,_~""---"-=--~~~~~~
18 Veronica Freitas, WSBA 19405
SaJ5'rina Layman, WSBA 25260
19
:~ttorney for Petitioner Attorney for Respondent
20
21
22
BRE.WE LAYMAN P.S.
I
23
24
ORlGINAL Attorneys at law
P.O. Box488
4\,~,P ORDER OF TRIAL CONTINUANCE - 1 !

425! 252-5167 Phone
425 252-9055 Fax
www.brewelaw.com
•• ¥ '
1 AGREED ORDER
2 THIS MATTER having come on pursuant to the above stipulation, NOW, THEREFORE,
3 IT IS HEREBY ORDERED as follows:
4 The non-jury trial date previously set for September 12, 2018 is stricken and continued to
5 November 28, 2018 at 9:00 a.m. before the Presiding Judge, due to the following reason(s):
6 Business valuation and appraisals need to be completed and mediation has not taken place.
7 Estimated length of trial is 3 days.
8 It is FURTHER ORDERED that the Presiding Judge must approve all subsequent changes
9 to the trial date.
10 DONE IN OPEN COURT this/6~of July, 2018.
11
~C/~
, JUDGE/COURT COMMISSIONER
12
Presented by:
13
BREWE LAYMAN P.S.
14 Attorneys at Law
15

1\ttomey for Petitioner
17

19
20 By___.__~----'----"""-==~
Veronica Freitas, WSBA 19405
21
22
BREWE LAYMAN P.S.
P.O. Box488
(425j 252-5167 Phone
~~rP ORDER OF TRIAL CONTINUANCE - 2 (425 252-9055 Fax
www.brewelaw.com
CRTMC 74
17-3-o ~- 2018 OCT -3 PM 12: 25
2 Nrssro ~497-31 -
Notice 018 75
1i1iiuiiiiiii~-~,.
3
6
7
County of Snohomish
8
In re:
9
No. 17-3-02497-31
10
Sally Jo Price,
Petitioner, NOTICE OF SETTLEMENT OF
11 and ALL CLAIMS WITHOUT
DISMISSAL
14 Charles A. Price, Jr.,
13 Respondent. [X] CLERK'S ACTION REQUIRED
14
TO: CLERK Of THE COURT
15
16 Notice is hereby given that all claims against all parties in this action have been resolved.
The Trial date of November 28, 2018, and any other hearings in this matter, may be stricken
17 from the court calendar. This notice is being filed with the consent of all parties.
18
If final documents are not filed within 60 days after the written Notice of Settlement is
19 filed, or within 60 days after the scheduled trial date, whichever is earlier, the case may be
dismissed in the Clerk's own motion pursuant to SCLR 94.04(i).
20
21 DATE: tD/1/1J
22
23 Attome:for A- __
§brina Layman WSBA No. 25260
~-19405
DATE: 10/01/2018
24
25 Attorney for Respondent
@owkt~;) 1 ~\.~ -~~ cg;)

26
iY,4'1
27
Uv ~~ ~-lo A--<--bl~~-
28

544 29th Avenue
NOTICE OF SETTLEMENT OF ALL CLAIMS Seattle, Washington 98122
Page 1 ofl (206) 328-7362
v@vfreitaslaw.com
~~ i p f)~P i2 D~:% ~? C: t;~
Lt'i\ \i\ ~-~ =~= =~ F~o~sR~u~P=s= ~ ~1=~=0=~=:=1-~=c ~=o ~=UR=-o~=T o-_UN=o~F T~Y t="'•·=: =; ; =j{=~!=~(=:r=~ =·~= ;=A :=,v=·
CAUSE NO.: 17-3-02497-31
====="
SALLY PRICE COMMISSIONER: TRACY G. WAGGONER

(PETITIONER) CLERK: L. HESSEN
AND DATE: 12-12-18 EX PARTE PM
CHARLES PRICE JR DIGITALLY RECORDED
(RESPONDENT)
THIS MATTER CAME ON FOR: DISSOLUTION - EX PARTE

ACTION:
PETITIONER APPEARED: YES, SWORN & TESTIFIED COUNSEL: SABRINA LAYMAN
RESPONDENT APPEARED: NO COUNSEL: NOT PRESENT
DOCUMENTS FILED:
ORDERS ENTERED:
THE COURT DECLINES TO ENTER FINAL ORDERS AS THE COURT DOES NOT HAVE THE
AUTHORITY TO BIFURCATE.
THE PROPERTY DIVISION IS STILL AT DISPUTE AND THE PROVISION THAT REQUIRES
BINDING ARBITRATION POST DECREE TO ADDRESS THE DISPUTED ITEMS BIFURCATES
THIS CASE.
.... .
1
~·al·
~.·.
~ R-f'
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~ ~~·
2 17-3-02497-31
FNFCL 77
Findings of Fact and Conclusions of Law
3
4 i\l\l\\l\\l\ll\\\\ll\\I\\\\II\\I SONYA KRASl11

COUNTY CLEHK
7 Superior Court of Washington, County of Snohomish

8 In re the marriage of:
9 Petitioner: No. 17-3-02497-31
10 SALLY JO PRICE Findings and Conclusions about a

Marriage
11 And Respondent: (FNFCL)
12 CHARLES A. PRICE, JR
13
14 Findings and Conclusions about a Marriage

15 1. Basis for findings and conclusions
16 Spouses' agreement.
17 The Court makes the following findings of fact and conclusions of law:
18 2. Notice
19
The Respondent has appeared in this case or has responded to or joined the Petition.
20
3. Jurisdiction over the marriage and the spouses
21
At the time the Petition was filed, the Petitioner lived in Washington State.
22
The Respondent lived in Washington State.
23
Conclusion: The court has jurisdiction over the marriage.
The court has jurisdiction over the Respondent.
24
CR 52; RCW 26.09.030; .070(3) Findings and Conclusions V. Freitas Law

Mandatory Form (05116, rev. 4125116) about a Marriage 54429thAve
FL Divorce 231 p. 1of5 Seattle, WA 98122
(206) 328-7362
FamilySoft FormPAK PL 2018 ORIGlNAL

..
. '
1 4. Information about the marriage
2 The spouses were married on October 7th, 2000, at Everett, Washington.
3 5. Separation Date
4 The marital community ended on October 26th, 2017. The parties stopped acquiring
community property and incurring community debt on this date.
5
6. Status of the marriage
6
Divorce - This marriage is irretrievably broken, and it has been 90 days or longer since
7 the Petition was filed and the Summons was served or the Respondent joined the Petition.
8 Conclusion: The Petition for divorce should be approved.
9 7. Separation Contract
10
The spouses signed a separation contract on September 28th, 2018.
11
Conclusion: The parties should be ordered to comply with the terms of the contract.
12
The contract provides that it shall not be set forth, filed, or made an exhibit to the
order.
13
8. Real Property
14
The spouses' real property is listed in the separation contract described in 7.
15
Conclusion: The division of real property described in the final order is fair Uust and
16
equitable).
17
9. Community Personal Property
18
The spouses' community personal property is listed in the separation contract described in
19 7.
20 Conclusion: The division of community personal property described in the final order
is fair Uust and equitable).
21
10. Separate Personal Property
22
The spouses' separate personal property is listed in the separation contract described in
23 7.
24 Conclusion: The division of separate personal property described in the final order is
fair Uust and equitable).
CR 52; RCW 26.09.030; .070(3) Findings and Conclusions v. Freitas Law
FL Divorce 231 p. 2 of 5 Seattle, WA 98122
(206) 328-7362

..-
1
11. Community Debt
2
The spouses' community debt is listed in the separation contract described in 7.
3
Conclusion: The division of community debt described in the final order is fair Uust
4 and equitable).
5 12. Separate Debt
6 The spouses' separate debt is listed in the separation contract described in 7.
7 Conclusion: The division of separate debt described in the final order is fair Uust and
equitable).
8
13. SpousalSupport
9
Spousal support should be based on the separation contract listed in 7.
10
14. Lawyer Fees and Costs
11
Fees and costs should be paid according to the separation contract listed in 7.
12
13
No one requested an Order for Protection in this case.
14
15
16. Restraining Order
16 No one requested a Restraining Order in this case.
17 17. Pregnancy
18 Neither spouse is pregnant.
19 18. Children of the marriage
20 The spouses have the following children together who are still dependent:
21 Child's name Age

1. Alex Price 15
22 2. Colby Price 12
3. Madison Price 6
23
24

(206) 328-7362

1 19. Jurisdiction over the children (RCW 26.27.201 - .221, .231, .261, .271)
2 The court can approve a Parenting Plan for the children the spouses have together
because:
3
Exclusive, continuing jurisdiction - A Washington court has already made a
4 custody order or parenting plan for the children, and the court still has authority to
make other orders for Alex Price, Colby Price, and Madison Price.
5
Home state jurisdiction - Washington is the children's home state because :
6
Alex Price, Colby Price, and Madison Price lived in Washington with a parent or
7 someone acting as a parent for at least the 6 months just before this case was
filed, or if the children are less than 6 months old when the case was filed, they
8 have lived in Washington with a parent or someone acting as a parent since birth.

10 The court signed the final Parenting Plan filed separately today.
11 21. Child Support

12 The dependent children should be supported according to state law.
13 The court signed the final Child Support Order and Worksheets filed separately today.
14
22. Other Findings or Conclusions
15 Boes rrol apply.
·!":) t;; L
1-e.-1 en IJY'-
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16
-\-v -s ..i...l t ~ ::r 0 l...o..re..
17
ike,.,,;µ12,:201!' ~~
Date " Judge OF-601'11/'l~fssie;:;;
18
19
20
21
22
23
24

(206) 328-7362

.
......
1 Petitioner and Respondent or their lawyers fill out below.
2 This document is presented by me: This document may be signed without notice
to me:
3
5
Re pondent signs here or lawyer signs here + WSBA #
7
Sabrina Layman Ki1sly11 Palliiissno V<A.:>.v~;:._ ~ 1J/1$)/'y
Print Name Date Print Name Date
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Mandatory Form (05116, rev. 4125116) about a Marriage 544 29th Ave
(206) 328-7362

...
1 Flll~D
2
17-3-02497-31 20f8UEC 12 PM 3.: 28
. ·'\'
DCD 78
3 Decree of Dissolution
4435857 SONYA KRASXi
4 COUNTY CLERr\ ;1
SNOHOMISH CO. WA SH
1111111111111111111111111111111111111111
5
8 In re the marriage of: No. 17-3-02497-31

Petitioner:
9 Final Divorce Order (Dissolution Decree)
SALLY JO PRICE (DCD)
10
And Respondent: [ ] Clerk's Action required: 1,2, 6, 13, 14, 16
11
CHARLES A. PRICE, JR
12
13
Final Divorce Order
14
1. Money Judgment Summary
15
No money judgment is ordered.
16
2. Summary of Real Property Judgment
17
18
Grantor's name Grantee's name Real Property
19 (person giving (person getting
Assessor's Legal description of property awarded
property) property)
property tax parcel (lot/block/plat/section, township, range,
20 or account number: county, state)
Charles Price, Sally Jo Price 00-94 76-000- ASPEN PHASE 1 Lot 17

21
Jr. 017-00
22
Charles Price, Sally Jo Price 00-8241-000- SUNNYBROOKLOT10TGW
Jr. 010-00 . 1/12 INT IN NGPA TR 99
23
&TGW 1/3 IN IN PRIV RD TR
98
24
RCW 26.09.030; .040; .070(3) Final Divorce/Legal Separation/ V. Freitas Law

Mandatory Form (0512016) Valid/Invalid Marriage Order 54429thAve
FL Divorce 241
ORIGff~AL
Seattle, WA 98122
(206) 328-7362

')
1 Charles Price, Sally Jo Price 005533000041 REECES SOUTH FORK

Jr. 00 & HIDEOUT ASSR PLAT BLK
2 005533000031 000 D-00-LOT 41 TGW UNO
02 PROP DEEDED INT LOT X &
3 13 & REECES SOUTH FORK
HIDEOUT ASSR PLAT BLK
4 000 D-02 - BEG NW COR
LOT 41 TH S 195.27FT TH
5 S89*59 05W FOR 75FT TH
N21*00 32E FOR 209.20 FT
6 TPB
7
Sally Jo Price Charles Price, 005897-003-001- Lot 1, 2, 3, and 4, Block 3,
8 JR 00 STOCKBRlDGE'S FOURTH
ADDITION TO THE TOWN OF
9 STANWOOD, AS PER PLAT
RECORDED IN VOLUME 2 OF
10 PLATS ON PAGE 96,
RECORDS OF SNOHOMISH
11 COUNTY.
Lawyer: Veronica Freitas represents: Charles Price, Jr.
12
Lawyer: Sabrina Layman represents: Sally Jo Price
13
The court has made Findings and Conclusions in this case and now Orders:
14
3. Marriage
15
This marriage is dissolved. The Petitioner and Respondent are divorced.
16
17
4. Name Changes (§} ~
-Pe+I h~ s
~ _NiJ 1'Vp8 rn ct"42' Vi~ • ~ Sa-\ l 'j :JD
18
5. Separation Contract
19
The spouses must comply with the terms of the separation contract signed on September
20 28th, 2018. This contract is approved.
21
6. Money Judgment (summarized in section 1 above)
22
None.
23
7. Real Property (summarized in section 2 above)
24
The real property is divided according to the separation contract described in 5 above.

(206) 328-7362

1 8. Petitioner's Personal Property
2 The personal property listed as Petitioner's in the separation contract described in 5

above is given to Petitioner as his/her separate property.
3
9. Respondent's Personal Property
4
The personal property listed as Respondent's in the separation contract described in 5
5 above is given to Respondent as his/her separate property.
6 1O. Petitioner's Debt

7 The Petitioner must pay all debts s/he has incurred (made) since the date of separation,
unless the court makes a different order about a specific debt below.
8
The Petitioner must pay debts as required by the separation contract described in 5
9
above.
10
11. Respondent's Debt
11
The Respondent must pay all debts s/he has incurred (made) since the date of separation,
12 unless the court makes a different order about a specific debt below.
13 The Respondent must pay debts as required by the separation contract described in 5
above.
14
12. Debt Collection
15
If one spouse fails to pay a debt as ordered above and the creditor tries to collect the debt
16 from the other spouse, the spouse who was ordered to pay the debt must hold the other
spouse harmless from any collection action about the debt. This includes reimbursing the
17 other spouse for any of the debt he/she paid and for attorney fees or costs related to
defending against the collection action.
18
13. SpousalSupport
19
Spousal support must be paid as required by the separation contract described in 5
20 above. Spousal support will end when either spouse dies, or the spouse receiving support
gets married or registers a new domestic partnership, unless the separation contract
21 provides differently.
22 14. Fees and Costs (Summarize any money judgment in section 1 above)
23 Fees and costs must be paid as required by the separation contract described in 5 above.
24
(206) 328-7362

1
No one requested an Order for Protection.
2
16. Restraining Order
3
No one requested a Restraining Order.
4
17. Children
5
This court has jurisdiction over the children as explained in the Findings and Conclusions
6 for this case.

8 The court signed the final Parenting Plan filed separately today.
9 19. Child Support

10
Court Order - The court signed the final Child Support Order and Worksheets filed
separately today.
11
Tax exemptions and post-secondary (college or vocational school) support are
12
covered in the Child Support Order.
13
20. Other orders
14
Does not apply.
15
Ordered.
16
"f&etM~ /2;) 16/I'
Date
17
18 Petitioner and Respondent or their lawyers fill out below.
19 This document: This document:
20
21 25260
22
23
24
f.. lt -£8
Sabrina Layman
Prinr:~
/
Date
PrinW
Kifstyrt Palrrlisano
Date
//,./f-~
(}"'1r/~S I)//,,.. /n(~ '7/L
Final Divorce/Legal Separation/ V. Freitas Law
Valid/Invalid Marriage Order 54429thAve
p. 4 of 4 Seattle, WA 98122
(206) 328-7362

----------------------------------. --- ·-
1 F ''·
ii~. g f
t:I!""'"'
;i;.,,,,
17-3-02497-31 201BDEct 2 pt.i .

2 pp 79
Parenting Plan Final Order
n 3: 2a
4435862
3
1111111111111111111111111111111111111111
4
7 Superior Court of Washington, County Snohomish
8 In re: No. 17-3-02497-31

Petitioner:
9 Agreed Fi I Parenting Plan
SALLY JO PRICE (PPP/PP I )
10
And Respondent: required: 1.
11
12
13
Parenting Plan
14
1. This parenting plan is a Court Order signed by a judge or commissioner. This is a Final
15 order (PP).

17
Child's name Age
18 1. Alex Price 15
19 2. Colby Price 12
3. Madison Price 6
20
21
22
a. Abandonment, neglect, child abuse, domestic violence, assault, or sex offense.
23
Neither parent has any of these problems.
24
RCW26.09.016, .181, .187, .194 Parenting Plan V. Freitas Law
Mandatory Form (0712017) 54429thAve
FL All Family 140 Seattle, WA 98122
(206) 328-7362

1 b. Other problems that may harm the children's best interests:
2 Neither parent has any of these problems.
3
4. / Limitations on a parent
4
Does not apply. There are no reasons for limitations checked in 3.a. or 3.b. above.
5
5. Decision-making
6
8
9
Type of Major Decision Joint Limited
10
(parents make (only the parent named below has
11 these decisions authority to make these decisions)
together)
12 School / Educational [X]
Health care (not [X]
13 emerQency)
14 Other: Work related child Each parent to choose their own child
care providers care in their household and pay for said
15 care.
Other: Marriage prior to [X]
16 18
Other: Entry into the [X]
17
Armed Forces prior to 18
18 Other: Counselors or [X]
Health Care Providers
19
b. Reasons for limits on major decision-making, if any:
20
21
22
the parents will go through the following protocol:
24
FL All Family 140 p. 2of15 Seattle, WA 98122
(206) 328-7362

1 a. If either parent wants to suggest a change for the child (unrelated to visitation), that
parent shall email and shall text the other parent with the subject "Re: proposed
2 change see email". The email shall contain the topic, the suggested change, the
underlying reason for change.
3 b. The other parent has 72 hours to respond or the proposed change will be deemed
agreed (note - if parent is out of range of email or away, they should try to let the other
4 parent know that they will be gone so there is no issue on response time).
c. If the other parent responds and objects timely, he or she will state the reasons why
5 they object.
d. The proposing parent can then set the issue for mediation with Wayne Pellegrini (or
6 another agreed mediator if Wayne is not available). If mediation is not successful, then
the parties shall set the matter for arbitration based on written materials only (the
7 proposal and the objection will be the written materials unless the arbitrator asks for
more detail).
8 e. The arbitrator shall be Wayne Pellegrini (or another agreed arbiter if Wayne is not
available). His fee shall be split equally between the parties.
9 f. Mr. Pellegrini does not have the authority to modify the terms of the visitation
provisions of the parenting plan such that visitation is changed, increased, decreased;
10 however, Mr. Pellegrini may interpret the pickup/drop off provisions and issues
pertaining to holidays/vacations/or other areas that would overlap the regular schedule
11 (i.e if it's Dad's holiday and Mom's regular time - what do we do?)
12 What to expect in the dispute resolution process
13 • Preference shall be given to carrying out the parenting plan.

• If you reach an agreement, it must be put into writing, signed, and both parents
14 must get a copy.
• If the court finds that you have used or frustrated the dispute resolution process
15 without a good reason, the court can order you to pay financial sanctions
(penalties) including the other parent's legal fees.
16 • You may go back to court if the dispute resolution process doesn't solve the
disagreement or if you disagree with the arbitrator's decision.
17
7. Custodian
18
The custodian is Sally Jo Price solely for the purpose of all state and federal statutes
19 which require a designation of determination of custody. Even though one parent is called
the custodian, this does not change the parenting rights and responsibilities described in
20 this plan.
21 (Washington law generally refers to parenting time and decision-making, rather than
custody. However, some state and federal laws require that one person be named the
22 custodian. The custodian is the person with whom the children are scheduled to reside a
majority of their time.)
23
24
(206) 328-7362

1
2 Parenting Time Schedule (Residential Provisions)

3
Complete the parenting time schedule in sections 8 - 11.
4
8. School Schedule
5
a. Children under School-Age
6
7
8
The children are scheduled to live with Sally Jo Price except when they are scheduled to
9 live with Charles Price, Jr. on:
10 WEEKENDS: every other weekend from Thursday pick-up at 5:00 PM until

Monday morning return to school or at 9:00 AM if no school (then drop off at
11 Mother's house). Begins with Dad's weekend on October 1ath, 2018.
12 WEEKDAYS: on the off week, Thursday pick-up at 5:00 PM until Friday morning
return to school or at 9:00 AM if no school (then drop off to Mother's house).
13 When each child turns 12 years old, then the mid-week will be from Wednesday
pick-up at 5:00 PM until Friday morning return to school or at 9:00 AM if no
14 school (then drop off at Mother's house). Begins with Dad's mid-week October
1oth to 11th.
15
9. Summer Schedule
16
Summer begins the Sunday following the last day of school for the last child to get out of
17 school (as the children are in different districts) and ends at 9:00 AM the Friday of Labor
Day weekend.
18
The parents shall have week on/week off with the children during the summer with the
19 exchange to be at 7:30 p.m. on Sundays. Mother has a family reunion each year the last
full week of July which will always be her week. The week on/week off schedule shall
20 begin the Sunday after the last day of school beginning with whichever parent will result in
Mother's family reunion week being her week (provided that for Mom's family reunion the
21 pick-up time shall be at 9 a.m. on Saturday before her week).
22 The summer schedule should be a 50/50 split. The parents may exchange weeks and will
cooperate with each other over scheduling.
23
During the summer, if either parent needs child care during their time with the children,
24 they will coordinate their own care and cover the costs for that care during the summer

FL All Family 140 p.4of15 Seattle, WA 98122
(206) 328-7362

1 months.
2
Each parent may also take an additional one-week vacation during the rest of the year (7
3 days consecutive- exchange to occur at 9 a.m. on the first day of vacation and return at
7:30 p.m. on the last day of vacation (not overnight to 9 a.m.)) not to interfere with any
4 other vacation or holiday schedule (similar to when Father took Alex to Maui in 2018). The
parties to provide 60 days' notice of said vacation and the children should only miss
5 school if they are at a "C" level in all classes and they pre-arrange the absence including
all missed homework.
6
10. Holiday Schedule (includes school breaks)
7
This is the Holiday Schedule for: All Children
8
Holiday Children with: Sally Jo Price Children with: Charles Price, Jr.
9
10 Martin Luther Begin day/time: Begin day/time:

King Jr. Day End day/time: End day/time:
11
With the parent who has the children for the attached weekend
13 Begin day/time: Thursday at 5:00 PM Begin day/time: Thursday at 5:00 PM
before the holiday before the holiday
14 weekend weekend
Presidents'
15 End day/time: return to school on End day/time: return to school on
Day
Tuesday or 9:00 AM on Tuesday or 9:00 AM on
16 Tuesday following the Tuesday following the
holiday holiday
17

19 Begin day/time: Friday after school or Begin day/time: Friday after school or 5:00
•Spring 5:00 PM. PM.
20 Break End day/time: Monday return to school End day/time: Monday return to school or
21 or9:00 AM. 9:00AM.
22
23
24
(206) 328-7362

1 Holiday Children with: Sally Jo Price Children with: Charles Price, Jr.
2 Every Yr. Even Years

Begin day/time: 9:00 AM the day of the Begin day/time:
3 holiday
•Mother's
Day End day/time: 7:30 PM the evening of End day/time:
4
the holiday
5

Begin day/time: 5:00 PM Friday of the Begin day/time: 5:00 PM Friday of the
7
holiday holiday
8 weekend weekend
•Memorial
Day End day/time: Return to school End day/time: Return to school
9
Tuesday or 9:00 AM on Tuesday or 9:00 AM on
10 Tuesday following the Tuesday following the
holiday. holiday
11
12 Every Yr.
Begin day/time: Begin day/time: 9:00 AM the day of the
13
•Father's holiday
14 Day End day/time: End day/time: 7:30 PM the evening of
the holiday
15

17 Begin day/time: 9:00 AM the morning of Begin day/time: 9:00 AM the morning of
•Fourth of the holiday the holiday
18 July End day/time: 9:00 Am the morning End day/time: 9:00 AM the morning
19 following the holiday following the holiday
20
21
22
23
24
(206) 328-7362

2
Begin day/time: Friday of the holiday Begin day/time: Friday of the holiday
3 weekend at 5:00 weekend at 5:00
PM PM
4
•Labor Day End day/time: Return to school End day/time: Return to school
5 Tuesday or 9:00 AM on Tuesday or 9:00 AM on
the Tuesday following the Tuesday following
6
7

Begin day/time: Pick-up from school Begin day/time: Pick-up from school
9 Wednesday or 5:00 Wednesday or 5:00
• Thanksgivin PM PM
10 g Day I
Break End day/time: Return to school or End day/time: Return to school or 9:00
11 9:00 AM the Monday AM the Monday after
12 after the holiday. the holiday.
13

15
Other plan: In odd-numbered years the children shall spend from after school or at 3:00 p.m.
•Winter
16 Break the day school is out until Christmas Day at 12:00 p.m. with the
Petitioner/Mother and from 12:00 p.m. Christmas Day until 7:30 p.m. the day prior to return to
17
school with the Respondent/Father. The schedule shall be reversed for even-numbered
18 years. For regular weekend scheduling, the parent who has the first 1/2 of the break shall have
the first weekend after break.
19
20 •Christmas Begin day/time: Begin day/time:

Eve End day/time: End day/time:
21
Follow the Winter Break schedule above.
22
23
24
(206) 328-7362

2
•Christmas Begin day/time: Begin day/time:
3 Day End day/time:
End day/time:
4 Follow the Winter Break schedule above.
•New Year's
5 Eve I New
Year's Day Begin day/time: Begin day/time:
6 End day/time: End day/time:
(odd/even is
based on
7
New Year's Follow the Winter Break schedule above.
Day)
8
9 Begin day/time: 9:00 AM the day of the Begin day/time: 9:00 AM the day of the
10 •Children's birthday birthday
Birthdays End day/time: 7:30 PM the day of the End day/time: 7:30 PM the day of the
11 birthday birthday
12
13 •Other Begin day/time: 9:00 AM the morning of Begin day/time: 9:00 AM the morning of the
occasion
14 the holiday holiday
important to
the family: End day/time: 7:30 PM the evening of End day/time: 7:30 PM the evening of
15
•Easter the holiday the holiday
16
•Other Even Years Odd Years
17
occasion
Begin day/time: 4:30 PM Begin day/time: 4:30 PM
important to
18 End day/time:
the family: 9:00 PM End day/time: 9:00 PM
19 •Halloween
20
Mother's/Fat Begin day/time:
21 he r's End day/time:
birthday
22 With the parent who is celebrating their birthday from 9:00 AM the day of the
birthday or after school if it is a school day to 7:30 PM the day of the birthday.
23
24
Mandatory Form (0712017) 544 29th Ave
(206) 328-7362
I_
1 11. Conflicts in Scheduling
2 The Holiday Schedule must be observed over all other schedules. If there are conflicts
within the Holiday Schedule:
3
If the residential schedule results in a conflict where the children is/are scheduled to be
4 with both parents at the same time, the following shall have priority over section 8, in the
following order (I being the highest priority and 6 being the lowest
5 priority):
1 -Section 10: Martin Luther King Jr. Day, Presidents' Day, Easter, Memorial Day, Fourth
6 of July, Labor Day, Halloween, Thanksgiving Day/Break, New
Year's Eve/New Year's Day, All three-day weekends not listed elsewhere.
7 2-Section 10: Mother's Day, Father's Day, Children's Birthdays, Mother's
Birthday, Father's Birthday.
8 3 -Section 10: Vacation with Parents
4 -Section 9: Summer Schedule
9 5 -Section 10: Winter Break, Christmas Eve, Christmas Day
6 -Section 10: Mid-winter Break, Spring Break
10 7 -Section 9: Additional vacation time
11 12. Transportation Arrangements

12 The children will be exchanged for parenting time (picked up and dropped off) at each
parent's home.
13
school or day care when in session.
14
15
Other details:
16
During father's residential time when it is a school day, he shall pick up and drop off the
17 children. If the exchange occurs on a non-school day, then receiving parent to pick up
unless otherwise stated above.
18
Transportation costs are included in the Child Support Worksheet and/or Child Support
19 Order.
20 The children shall be picked up and returned at the designated times or within fifteen
minutes thereof in the event of an unforeseen delay. Should a delay become necessary,
21 the receiving parent shall be notified immediately.

24 with the children.
(206) 328-7362

1
Move to a different school district
2
If the move is to a different school district, the relocating person must complete the form
3 Notice of Intent to Move with Children (FL Relocate 701) and deliver it at least 60 days
before the intended move.
4
Exceptions:
5
• If the relocating person could not reasonably have known enough information to
6 complete the form in time to give 60 days' notice, s/he must give notice within 5
days after learning the information.
7 • If the relocating person is relocating to a domestic violence shelter or moving to
avoid a clear, immediate and unreasonable risk to health or safety, notice may be
8 delayed 21 days.
• If information is protected under a court order or the address confidentiality
9 program, it may be withheld from the notice.
• A relocating person who believes that giving notice would put her/himself or a child
10 at unreasonable risk of harm, may ask the court for permission to leave things out
of the notice or to be allowed to move without giving notice. Use form Motion to
11 Limit Notice of Intent to Move with Children (Ex Parle) (FL Relocate 702).
12 The Notice of Intent to Move with Children can be delivered by having someone
personally serve the other party or by any form of mail that requires a return receipt.
13
If the relocating person wants to change the Parenting Plan because of the move, s/he
14 must deliver a proposed Parenting Plan together with the Notice.
15 Move within the same school district
16 If the move is within the same school district, the relocating person still has to let the
other parent know. However, the notice does not have to be served personally or by
17 mail with a return receipt. Notice to the other party can be made in any reasonable
way. No specific form is required.
18
Warning! If you do not notify...
19
A relocating person who does not give the required notice may be found in contempt
20 of court. If that happens the court can impose sanctions. Sanctions can include
requiring the relocating person to bring the children back if the move has already
21 happened, and ordering the relocating person to pay the other side's costs and
lawyer's fees.
22
Right to object
23
A person who has court-ordered time with the children can object to a move to a
24 different school district and/or to the relocating person's proposed Parenting Plan. If
FL All Family 140 p. to of 15 Seattle, WA 98122
(206) 328-7362

1 the move is within the same school district, the other party doesn't have the right to
object to the move but s/he may ask to change the Parenting Plan if there are
2 adequate reasons under the modification law (RCW 26.09.260).
3 An objection is made by filing the Objection about Moving with children and Petition
about Changing a Parenting/Custody Order (Relocation) (form FL Relocate 721 ). File
4 your Objection with the court and serve a copy on the relocating person and anyone
else who has court-ordered time with the children. Service of the Objection must be by
5 personal service or by mailing a copy to each person by any form of mail that requires
a return receipt. The Objection must be filed and served no later than 30 days after
6 the Notice of intent to Move with Children was received.
7 Right to move
8 During the 30 days after the Notice was served, the relocating person may not move
to a different school district with the children unless s/he has a court order allowing the
9 move.
10 . After the 30 days, if no Objection is filed, the relocating person may move with the
children without getting a court order allowing the move.
11
After the 30 days, if an Objection has been filed, the relocating person may move with
12 the children pending the final hearing on the Objection unless:
• The other party has scheduled a hearing to take place no more than 15 days after
14 the date the Objection was served on the relocating person. (However, the
relocating person may ask the court for an order allowing the move even though a
15 hearing is pending if the relocating person believes that s/he or a child is at
unreasonable risk of harm.)
16 • the court may make a different decision about the move at a final hearing on the
Objection.
17
Parenting Plan a'fter move
18
If the relocating person served a proposed Parenting Plan with the Notice, and if no
19 Objection is filed within 30 days after the Notice was served (or if the parties agree):
20 • Both parties may follow that proposed plan without being held in contempt of the
Parenting Plan that was in place before the move. However, the proposed plan
21 cannot be enforced by contempt unless it has been approved by a court.
• Either party may ask the court to approve the proposed plan. Use form Ex Parle
22 Motion for Final Order Changing Parenting Plan - No Objection to Moving with
Children (FL Relocate 706).
23
Forms
24
FL All Family 140 p. 11 of15 Seattle, WA 98122
(206) 328-7362

2 •The Washington State Courts' website: www.courts.wa.gov/forms,

•The Administrative Office of the Courts - call: (360) 705-5328,
3 •Washington LawHelp: www.washingtonlawhelp.org, or
•The Superior Court Clerk's office or county law library (for a fee).
4
(This is a summary of the Jaw. The complete Jaw is in RCW 26. 09. 430 through
5 26.09.480.)
6 14. Other
7 a. Family Calendaring System. The parents shall engage in a family calendaring
system (AppClose) and input all appointments and athletics for the children on the
8 calendar. Mother has historically made the family schedule and will continue to do so
and Father will set up to get alerts from the calendar system so he is aware and may
9 attend. If either parent proposes a new provider or to change a provider, they shall
go through dispute resolution process above. Each parent shall have equal and
10 independent authority to confer with physicians, counselors, schools, daycare and
other programs with regard to the progress of the children and each shall have free
11 access to counseling, medical, school, daycare, and other records. Each parent shall
have authority to give parental consent or permission as may be required concerning
12 school, daycare or other programs for the children while the children is/are in his or
her residential care.
13 b. Telephone Access (Children). The children shall have liberal telephone privileges
with the parent with whom the children is/are not then residing without the
14 interference of the residential parent.
c. Telephone Access (Parents). The non-residential parent may contact the children
15 telephonically at any reasonable time.
d. Participation in Children's Events. The children shall be transported/accompanied
16 by the parent with whom the children are residing at the time of a given event. The
other parent shall not be limited from attendance at that event, providing said
e. Notification of Children's Events. Each parent shall be responsible for keeping
18 themselves advised of school, athletic, and social events in which the children
participate(s). Both parents may participate in school activities for the children such
19 as open house, attendance at an athletic event, etc.
f. Disparaging Remarks. Neither parent shall make disparaging remarks about the
20 other parent to or in front of the children and both parents shall cooperate in fostering
a good and loving relationship between the children and the other parent.
21 g. Minimizing Impact on Children. The primary objective of the parents is to minimize
the negative impact that their separation shall have on the children. Each parent
22 seeks a full and active role in providing the children with a sound moral, social,
economic and educational environment for the children. To this end, the parents are
23
committed to cooperative and mutual involvement in the lives of their children.
h. Considering Children's Schedules. Both parents shall consider the needs and
24
interests of the children, and the children's schedule of school and other regularly
FL All Family 140 p. 12 of15 Seattle, WA 98122
(206) 328-7362

1 planned activities, when arranging visitation.
i. Alcohol/Drugs. Neither parent shall consume alcohol in excess nor consume drugs
2 other than over-the-counter or prescribed medication while the children is/are under
their care.
3 j. Consistency of Routine and Discipline. The residential arrangements are provided
for in the best interest of the children. The children's interests is/are best served by
4 responsiveness and cooperation by both parents, involvement by both parents in all
aspects of the children's needs, and a reasonable consistent routine of activities,
5 values, and discipline throughout both homes. Inconsistency and conflict are
opposed to the best interest of the children.
6 k. Good Faith of Parents. Both parents freely and wholly commit themselves to this
parenting plan with the expectation that it will provide a stable and lasting residential
7 schedule for the children and the parents. Each parent is aware that violations of this
parenting plan, abusive use of conflict, false reports to authorities, or bad-faith use of
8 dispute resolution (including court action) could lead to a reduction of residential time
with the children.
9 I. Children's Clothing/Possessions. The parents shall not interfere with the right of
the children to transport his/her clothing and possessions to each parent's home.
10 Neither parent shall stockpile the children's clothing or possessions. Both Parents
shall cooperate in providing and returning the clothing and possessions of the
11 children.
m. Deviation from Schedule. Acceptance and waiver of any deviations from the
12 provisions of this parenting plan shall not constitute acceptance or waiver of
subsequent deviations from this plan. The provisions of this plan shall remain in
13 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 writing and signed
14 by both parents and shall be effective immediately.
n. Change of Address/Telephone. Each of the parties shall keep the other parent,
15 and the Washington State Support Registry (if applicable), informed as to their
current residential address and telephone number at all times.
16 o. Notification of Change in Schedule. Each parent shall notify the other at least
forty-eight (48) hours in advance if he/she is unable to comply with the regular
17 residential schedule. Both parents acknowledge that from time to time unpredictable
situations may arise in their lives, and in the children's life/lives, which makes strict
18 adherence to the above residential plan impractical.
p. Piercing/Tattoos. Neither parent shall allow the children to be tattooed/pierced
19 without the consent of the other parent.
q. Compliance with Plan. If a parent failed to comply with a provision of this Parenting
20 Plan, the other parent's obligations under the plan are not affected.
r. Development of the children. Each parent desires to remain responsible and active
21 in the growth of the children and development consistent with the best interest of the
children. The parents will make a mutual effort to maintain an open, ongoing
22 communication concerning the development, needs and interests of the children and
will discuss together any major decision which has been made about or for the
23 children.
s. Emergency care for the children. Each parent shall be empowered to obtain
24 emergency health and dental care for the children without the consent of the other
(206) 328-7362

-------------------------------------
2 children.
t. Routine care for the children. Each parent shall have equal and independent
3 authority to provide routine medical and dental services for the children while the
children is/are in his or her care and residence. Mother will continue to make the
4 routine appointments for medical and dental. If possible, she will have the providers
directly communicate the appointment dates to Father. If not possible, she'll text him
5 the dates.
u. Religious upbringing. Each parent shall have an equal right to include the children
6 in his or her religious activities and expressions. The children shall have the right to
make his/her own religious choice as the children mature(s).
7 v. If a parent has an adult roommate/live in partner, they will provide the name and date
of birth to the other parent.
8 w. Day-to-day care. Each parent may make decisions regarding day-to-day care and
control of the children while the children resides with that parent.
9 x. Major decisions. In the event of an irreconcilable difference between the parents as
to major joint decisions set forth above, the matter shall be resolved via the dispute
10 resolution section above.
11 15. Proposal
12 Does not apply. This is a court order.
13 16. Court Order

14 This is a court order (if signed by a judge or commissioner below).
15 Findings of Fact - Based on the pleadings and any other evidence considered:
16 The Court adopts the statements in section 3. (Reasons for putting limitations on a
parent) as its findings.
17
Conclusions of Law - This Parenting Plan is in the best interest of the children.
18
Order - The parties must follow this Parenting P
19
20
Date
21
22 Warning! If you don't follow this Parenting Plan, the court may find you in contempt
(RCW 26.09.160). You still have to follow this Parenting Plan even if the other parent
23 doesn't.
24 Violation of residential provisions of this order with actual knowledge of its terms is
unishable b contem t of court and ma be a criminal offense under RCW
(206) 328-7362

.. < ' •
1 I 9A.40.060(2) or 9A.40.070(2). Violation of this order may subject a violator to arrest.
6
If this is a court order, the parties and/or their lawyers (and any GAL) sign below.
7
Is an agreement of the parties. Is an agreement of the parties.
8 Is presented by me. May be signed by the court without notice to me.
10 /\..c-,_~ 19405
Respondent signs here or lawyer signs here + WSBA #
11
Sabrina Layman
Print Name ~ Date
Veronica Freitas ld l ~J Id'
12 Print Name Date

13
Is an agreement of the parties. Is an agreement of the parties.
Is presented by me.
14
15
16 ~ther party signs here or lawyer signs here + WSBA #
17 Sally Jo Price
Print Name Date
Charles Price. Jr.
Print Name
&-11-J-& Date
18
19
20
21
22
23
24
(206) 328-7362

..
1
17-3-02497-31
2 ORS 80
Order for Support
4435866
3
4 I
Ill lllllllllllllllllllllllllllllll II Ill
5
8 In re: No. 17-3-02497-31

Petitioner:
9 Agreed Final Child Support Order
SALLY JO PRICE Final (ORS)
10
And Respondent: [X] Clerk's Action Required: WSSR
11
CHARLES A. PRICE, JR
12
13
Child Support Order
14
1. Money Judgment Summary
15
No money judgment is ordered.
16
Findings and Orders
17
2. The court orders child support as part of this family law case. This is a final order.
18
19
3. The Child Support Schedule Worksheets attached or filed separately are approved by the
court and made part of this Order.
20
4. Parents' contact and employment information
21
Each parent must fill out and file with the court a Confidential Information form (FL All
22 Family 001) including personal identifying information, mailing address, home address,
and employer contact information.
23
Important! If you move or get a new job any time while support is still owed, you must:
24
• Notify the Support Registry, and
.....
RCW 26.09.135; 26.26.132; 26.10.050 Child Support Order V. Freitas Law
54429thAve
FL All Family 130
Seattle, WA 98122
FamilySoft FormPAK 2018

ORIGINAL (206) 328-7362
' .
1
• Fill out and file an updated Confidential Information form with the court.
2
Warning! Any notice of a child support action delivered to the last address you provided
3 on the Confidential Information form will be considered adequate notice, if the party trying
to serve you has shown diligent efforts to locate you.
4
5. Parents' Income
5
Parent (name): Charles Price, Jr. Parent (name): Sally Jo Price
6
Net monthly income $ 11,320. Net monthly income $ 5,255.
7 (line 3 of the Worksheets) (line 3 of the Worksheets)
This income is: This income is:
8 [ ] imputed to this parent. [ ] imputed to this parent.
[X] this parent's actual income (after any exclusions [X] this parent's actual income (after any exclusions
9 aooroved below). aooroved below) including maintenance.
10 Does this parent have income from overtime or a Does this parent have income from overtime or a
job?
2nd job?
2nd
11 [X] No. [X] No.

[ ] Yes. [ ] Yes.
12
13 6. Imputed Income
14 Parent (name): Charles Price, Jr. Parent (name): Sally Jo Price

Does not apply. This parent's actual income is used. Does not apply. This parent's actual maintenance
15
income is used
16
7. Limits affecting the monthly child support amount
17
The monthly amount has been affected by:
18
Combined Monthly Net Income over $12,000. Together the parents earn more than
19 $12,000 per month.
20 8. Standard Calculation
21 Parent Name Standard calculation

Worksheets line 17
22 Charles A. Price, Jr.
$2, 167
23
Sally Jo Price
24 $1,220
.....
FL All Family 130 p. 2 of 9 Seattle, WA 98122
(206) 328-7362

' '
1 9. Deviation from standard calculation
2 Should the monthly child support amount be different from the standard calculation?
3 Yes - The monthly child support amount ordered in section 10 is different from the
standard calculation listed in section 8 because:
4
Other Reasons:
5
The parties' agreement.
6
The facts that support the reasons checked above are: Obliger parent pays
7 maintenance.
8 10. Monthly child support amount (transfer payment)
9 After considering the standard calc1,Jlation in section 8, and whether or not to apply a
deviation in section 9, the court orders the following monthly child support amount
10
(transfer payment).
11
Charles Price, Jr. must pay child support to Sally Jo Price each month as follows for the
12 children listed below:
13 Child's Name Age Amount

1. Alex Price 15 $1100
14
2. Colby Price 12 $1100
15 3. Madison Price 6 $800
Total monthly child support amount: $3000
16
17 11. Starting date and payment schedule
18 The monthly child support amount must be paid starting October 1st 2018 on the following
payment schedule:
19
In one payment each month by the 15th day of the month.
20
12. Step Increase (for modifications or adjustments only)
21
Does not apply.
22
13. Periodic Adjustment
23
Child support may be changed according to state law. In 24 months, the father may move
24 for an adjustment. There is no basis for a downward deviation due to the father's high
.... income .
(206) 328-7362

1
14. Payment Method (check either Registry or Direct Pay)
2
Direct Pay - Send payment to the other parent or non-parent custodian by:
3
Other method:
4 Direct deposit into bank account.
5 15. Enforcement through income withholding (garnishment)

6 DCS or the person owed support can collect the support owed from the wages, earnings,
assets or benefits of the parent who owes support, and can enforce liens against real or
7 personal property as allowed by any state's child support laws without notice to the parent
who owes the support.
8
order is not being enforced by DCS and the person owed support wants to have
If this
9 support paid directly from the employer, the person owed support must ask the court to
sign a separate wage assignment order requiring the employer to withhold wages and
10 make payments. (Chapter 26. 18 RCW)
11 Income withholding may be delayed until a payment becomes past due if the court finds
good reason to delay.
12
Income withholding will be delayed until a payment becomes past due because the court
13 has approved the parents' written agreement for a different payment arrangement.
14 16. End date for support

15 Support must be paid for each child until the child turns 18 or is no longer enrolled in high
school, whichever happens last, unless the court makes a different order in section 17.
16
17. Post-secondary educational support (for college or vocational school)
17
Reserved - A parent or non-parent custodian may ask the court for post-secondary
18
educational support at a later date without showing a substantial change of circumstances
by filing a Petition to Modify Child Support Order (form FL Modify 501 ). The Petition must
19
be filed before child support ends as listed in section 16.
20
The parties agree to address this issue when Alex is a senior in high school.
21
18. Claiming children as dependents on tax forms
22
The parties have the right to claim the children as their dependents on their tax forms as
23 follows (if and when permissible by the IRS):
24 • With 3 children: Father to claim two children in even years and the mother to claim one
child in even years. The reverse applies in odd years .
.... RCW 26.09.135; 26.26.132; 26.10.050 Child Support Order V. Freitas Law
(206) 328-7362

' .
1 • With 2 children: The father shall claim the oldest child and the mother the youngest,
every year.
2 • With 1 child: Father to claim the child in even numbered years and the mother in odd
years.
3
*Child tax credits to be aligned with the custodial parent (mother).
4
19. Medical Support
5
Important! Read the Medical Support Warnings at the end of this order. Medical Support
6 includes health insurance (both public and private) and cash payments towards premiums
and uninsured medical expenses.
7
Private health insurance ordered. Charles Price, Jr. must pay the premium to provide
8 health insurance coverage for the children. The court has considered the needs of the
children, the cost and extent of coverage, and the accessibility of coverage.
9
The other parent must pay his/her proportional share* of the premium paid. Health
10 insurance premiums are included on the Worksheets (line 14). No separate payment
is needed.
11
* Proportional share is each parent's percentage share of the combined net income
12 from line 6 of the Child Support Schedule Worksheets.
13 20. Health care coverage if circumstances change or court has not ordered
14
If the parties' circumstances change, or if the court is not ordering how health care
coverage must be provided for the children in section 19:
15
• A parent, non-parent custodian, or DCS can enforce the medical support
16
requirement.
17
• If a parent does not provide proof of accessible health care coverage (coverage
that can be used for the children's primary care), that parent must:
18
19 • Get (or keep) insurance through his/her work or union, unless the insurance
costs more than 25% of his/her basic support obligation (line 19 of the
Worksheets),
20
21 • Pay his/her share of the other parent's monthly premium up to 25% of his/her
basic support obligation (line 19 of the Worksheets), or
22
• Pay his/her share of the monthly cost of any public health care coverage, such
23 as Apple Health or Medicaid, which is assigned to the state.
24
544 29th Ave
(206) 328-7362
FamilySofl FormPAK 2018

'-/
2 21. Children's expenses not included in the monthly child support amount
3 Uninsured medical expenses - Each parent is responsible for a share of uninsured
medical expenses as ordered below. Uninsured medical expenses include premiums, co-
4 pays, deductibles, and other health care costs not paid by health care coverage.
5 Parent: Parent: Make payments to:

Person who
6 Charles Price, Jr. Sally Jo Price Service
Children's pays the
pays monthly pays monthly Provider
Expenses for: expense
7 Proportional Share* Proportional Share*
Uninsured medical
[X] [ ]
8 expenses
* Proportional Share is each parent's percentage share of the combined net income from line 6 of the Child
9 Support Schedule Worksheets.
10
These expenses shall be reimbursed within ten days of proof of payment.
11
Other shared expenses:
12
The parents will share the cost for the expenses listed below:
13
Make pa1 ments to:
14 Parent: Parent: Person
who pays Service
15 Children's Charles Price, Jr. Sally Jo Price the Provider
Expenses for: pays monthly pays monthly expense
16
17 [ x ] Day Care:
18 See Parenting Plan
19
[X ] Education:
20
Senior year expenses
21 related to graduation,
prom, cap and gown,
22 photos, year book 50%** 50%** [X] [X]
etc. driver's
23 education.
Necessary Education
24 Expenses
544 29th Ave
(206) 328-7362

1 Make pa 1ments to:
Parent: Parent: Person
2 who pays Service
Children's Charles Price, Jr. Sally Jo Price the Provider
3 Expenses for: pays monthly pays monthly expense
[X] Other (specify):
4
See below*** 50%** 50%** [X] [X]
5
6
** If any percentages ordered are different from the Proportional Share, explain why: The parties' agreement.
7
***"OTHER: these include non-child support related expenses (sports, activities, etc.) in
8 which the children have participated historically. Additional expenses (i.e. not historical)
to be paid proportionally, provided that such expenses have been agreed to between
9 the parents in writing prior to either parent being obligated financially.
10
Drivers Education will be paid 50% by each parent.
11
The father will pay 100% of the children's cell phone costs.
12
Vehicle Insurance: Whoever purchases the vehicle pays for the child's auto insurance.
13 Neither party is obligated to purchase a vehicle for the children.
14 Payments shall be made to the provider of the service whenever possible. If one parent
pays for the share of the expense for the other parent, the other parent shall reimburse
15 the paying parent within ten days of receiving verification of payment.
16
17
18
19
20 22. Past due child support, medical support and other expenses
21 As of 10/1 /18, neither parent owes:
22 [X] Past due child support [X] Interest on past due child support
[X] Past due medical support [X] Interest on past due medical support
23 [X] Past due other expenses [X] Interest on past due other expenses
24 to:
23. Overpayment caused by change
.....
(206) 328-7362

1
Does not apply.
2
24. Other Orders
3
All the Warnings below are required by law and are incorporated and made part of this
4 order.
5 Ordered.
6
7 Date
8 Petitioner and Respondent or their lawyers fill out below:
9 This document: This document:

Is an agreement of the parties Is an agreement of the parties
10 May be signed by the court without notice to me Is presented by me
May be signed by the court without notice to me
11
12
25260
13 Petitioner signs here or lawyer signs here + WSBA # spondent signs here or lawyer signs here + WSBA #
14 K'irstyfl Palfl'lisano V<.ru,v1~....., \/I p/11 Sabrina Layman

Print Name Date Date
15
16
All the warnings below are required y law and are part of the
17
order. Do not remove.
18
Warnings!
19
If you don't follow this child support order ... If you receive child support ...
20 • DOL or other licensing agencies may deny, suspend, or You may have to:
refuse to renew your licenses, including your driver's • Document how that support and any cash received for
21 license and business or professional licenses, and the children's health care was spent.
• Dept. of Fish and Wildlife may suspend or refuse to issue • Repay the other parent for any day care or special
22 your fishing and hunting licenses and you may not be able expenses included in the support if you didn't actually have
to get permits. (RCW 74.20A.320) those expenses. (RCW 26.19.080)
23
24 Medical Support Warnings!

(206) 328-7362

1 The parents must keep the Support Registry informed whether or not they have access to health care coverage for the
children at a reasonable cost, and provide the policy information for any such coverage.
2 * * *
If you are ordered to provide children's health care coverage ...
3 You have 20 days from the date of this order to send:
• proof that the children are covered, or
4 • proof that health care coverage is not available as ordered.
Send your proof to the other parent or to the Support Registry (if your payments go there).
5 If you do not provide proof of health care coverage:
• The other parent or the support agency may contact your employer or union, without notifying you, to ask for direct
6 enforcement of this order (RCW 26. 18. 170), and
• The other parent may:
7 • Ask the Division of Child Support (DCS) for help,
• Ask the court for a contempt order, or
8 • File a Petition in court.
9 Don't cancel your employer or union health insurance for your children unless the court approves or your job ends and
you no longer qualify for insurance as ordered in section 19.
10 If an insurer sends you payment for a medical provider's service:
• you must send it to the medical provider if the provider has not been paid; or
11 • you must send the payment to whoever paid the provider if someone else paid the provider; or
• you may keep the payment if you paid the provider.
12 If the children have public health care coverage, the state can make you pay for the cost of the monthly premium.
Always inform the Support Registry and any parent if your access to health care coverage changes or ends.
13
14
15
16
17
18
19
20
21
22
23
24
(206) 328-7362

Or, [X] Signed by the Judicial/Reviewing Officer. (CSW)
Charles Sally Jo
Part I: Income (see Instructions, paoe 6)
a. Wages and Salaries $23796.25 -
c. Business Income $140.00 $693.00
e.Other Income - -
f. Imputed Income - -
g. Total Gross Monthly Income (add lines 1a through 1f) $23936.25 $5,693.00
a. Income Taxes (Federal and State) Tax Year: Manual $6,122.86 $339.79
b. FICA (Soc.Sec.+Medicare)/Self-Emoloyment Taxes $1,077.54 $97.92
g. Maintenance Paid $5,000.00 -
h. Normal Business Expenses - -
rJ~ll it~~-~
!;~~ri.
1~1r
5. Basic Child Support Obligation (Combined amounts--+)
Alex Price $1206.00
i~*~
t~;,~ ,,~~'~
Colby Price $1206.00 ~~ q~; $3,387.00
~
- .,
- ~·
1~·rJ
parent)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 1of5
--------------------------------------
Charles Sally Jo

Self-Support Reserve: (125% of the Federal Poverty Guideline.) ~1:~'~1 $1,265.00 i:t't)J()}
b. Is Month I~ Net Income Less Than Self-Su1212ort Reserve? If yes,
c. Is Monthl~ Net Income egual to or more than Self-Su1212ort
amount or the presumptive $50 oer child, whichever is greater. - -
from line 7, Ba - Sc, but not less than the presumptive $50 per child. $2,313.32 $1,073.68
-
•
c. Total Monthly Health Care Expenses (line 10a plus line 10b) $461.28
(add both parent's totals from line 10c)
11. Day Care and Special Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
• $461.28
-
-
-
-
-
-
d. Other Special Expenses (describe)
- -
- -
- -
- -
e. Total Day Care and Special Expenses - -
I
both parents' dav care and special expenses from line 11 e)
plus line 12)
Expenses (multiply each number on line 6 by line 13)
IJ $315.05
-
$461.28
$146.23
WSCSS-Worksheets - Mandatory (CSW!CSWP) 0512016 Page 2 of 5
Charles Sally Jo

16. Child Suooort Credits
a. Month Iv Health Care Exoenses Credit $461.28 -
- -
- -
- -
d. Total Support Credits (add lines 16a throuah 16c) $461.28 -
whichever is areater) $2,167.09 $1,219.91
(List the estimated value of all maier household assets.)
a. Real Estate - -
b. Investments - -
- -
- -
- -
21. Household Debt
a. - -
b. - -
c. - -
d. - -
e. - -
f. - -
Name - -
Name - -
Name - -
Name - -
Charles Sally Jo
Name - -
Name - -
e. Income From Child Suooort
Name - -
Name - -
Program - -
Program - -
q. Other Income (describe)
- -
- -
- -
- -
24. Child Support Owed, Monthlv, for Bioloqical or Leqal Child(ren)
Name/age: Paid [ l Yes [ 1No - -
Name/aqe: Paid [ l Yes [] No - -
(First name(s) and aqe(s))

~---------------------------------------
Signature and Dates

c: .. \state templates\waworksheet.dtf y:lfamily softlprice, c\price, c.scp 10/11/2018 11 :49 am

17-3-02497-31 Sally Jo Price Vs Charles Allen Price Jr.

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17-3-02497-31 Sally Jo Price Vs Charles Allen Price Jr.

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17-3-02497-31 2U l1 DEC - l PM 12: 0 I ·

19 II. Relief Requested

24 Commissioner Brudvik made the following errors:

Motion for Revision VERONICA FREITAS

6 4. Ordering the Respondent to pay all premiums (medical, dental, optical,

7 orthodontia, and automobile).

12 phone number where the children can be reached.

Motion for Revision VERONICA FREITAS

18 date income of $14,000 per month when setting support.

Motion for Revision VERONICA FREITAS

24 paying for the mortgage and tax on the family home.

Motion for Revision VERONICA FREITAS

18 obligation to the mother as it already exceeds his net income.

23 insurance premiums which is $297.02 per month.

Motion for Revision VERONICA FREITAS

12 5(c)(4)(G), and LR 7(b)(5).

Motion for Revision VERONICA FREITAS

11 Dodd, 120 Wn.App. 638, 644, 86 P.3d 801 (2004).

17 Respectfully submitted on this 30th day of November 2017,

Motion for Revision VERONICA FREITAS

V. FREITAS LAW, PLLC

13 Temporary Family Law Order

15 DNo moneyjudgment is ordered.

16 O Summarize any money judgments in the table below.

22. l_!:a~! (nam!!)__~-.,-.___,____ ·--'- . represents (nal!l.!!l.~---·--- --~--J

23 ,t vvli BREWE LAYMAN P.S.

4 3. Active duty military

16 The court signed the temporary Parenting Plan filed separately.

23 I BREWE LAYMAN P.S.

13 Petitioner will possess and use:

14 property in possession now.

15 vehicle/s: 2010 Mercedes GL550

16 Respondent will possess and use:

17 property in possession now.

18 vehicle/s: 2012 Audi Q5.

5 J~ay premiums ~s follows:

21 14. Other temporary orders (if any)

23 I BR EWE LAYMAN P.S.

4 A. Marysville rental property on 66th Dr. N.E. - to Petitioner/Wife

9 This order: This order:

12 BREWE LAYMAN P.S.

16 This order: This order:

Cha.des A. Price, Jr,./

l'~M\1;QRARY FAMILY LAW ORDER - 7 !425) 252-5167 Phone

V. FREITAS LAW, PLLC

B. B. Assume that an individual loan originator's employment contract with

A. A. The compensation paid to an individual loan originator pursuant to this

B. B. At least one of.the following conditions is satisfied:

1. 1. The compensation paid to an individual loan originator pursuant to this

V. FREITAS LAW, PLLC

Part II: Basic Child Support Obligation (see Instructions, page 7)

Part IV: Gross Child Support Obligation

Part V: Child Support Credits (see Instructions, page 9)

26.0ther Factors For Consideration

WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 4 of 5

Signature and Dates

Parent's Signature (Column 1) Parent's Signature (Column 2)

Date City Date City

Judicial/Reviewing Officer Date

WSCSS-Worksheets - Mandatory (CSW/CSWP) 0512016 Page 5 of 5 SupportCalc® 2017

V. FREITAS LAW, PLLC

Madison Price $975.00

22. l_!:a~! (nam!!)~-.,-._,____ ·--'- . represents (nal!l.!!l.~---·--- --~--J

22. l_1awye!.(name)~--- - -.____ ·-.--' represents (namel_~----~-~-- . __J