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SUPERIOR COURT OF WASHINGTON FOR SNOHOMISH COUNTY

In the Guardianship of ) NO. 21-4-01316-31
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Aliyah Marie Rocha, )
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25 Grace Koelsch Rocha

Sylvia ) MOTION FOR REVISION
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NOW COMES, Raymond Rocha, Birth Father, and Hannah Koelsch, Birth Mother,

hereinafter referred to as “Respondents”, still specially appearing at arm’s length to the court,

without waiving or abandoning any previously raised objections or exceptions.

Errors Claimed by Commissioner

1. Commissioner Waggoner erred during the January 19, 2022 hearing by

continuing the unverified assertion that “clear and convincing evidence” had been shown by
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petitioner that the appointment of emergency guardian would prevent substantial harm to the

minor’s health, safety, or welfare, and no parent is willing or able to perform or exercise their

parental functions as defined in RCW 26.09.004.

2. Commissioner Waggoner erred during the January 19, 2022 hearing by claiming

that the essential elements required had shown that Raymond Rocha and Hannah Koelsch
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engaged in any action that met the evidentiary threshold to empower a court to extend and

reissue “Letters of Guardianship”.

3. Commissioner Waggoner erred during the January 19, 2022 hearing by stating

respondents did not achieve proper service on petitioners lawyer with their “Motion Challenging

Subject Matter Jurisdiction” and “Motion to Dismiss For Failure to State A Claim For Which

Relief May Be Granted” but service that was done exactly the same way was acceptable with
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respondents “Objection to Petition”. As stated in rule CR-5 (b)(1) “Under these rules service is

required or permitted to be made upon a party represented by an attorney the service shall be

made upon the attorney unless service directly upon the party is ordered by the court. Service

upon the attorney or upon the party shall be made by delivering a copy to the party or the party’s

attorney.”
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4. There has still never been a verified report with verified signatures of neglect or

abuse to the children’s safety, health, or welfare giving cause to petitioner’s claim. Respondents

still haven’t had any contact from a CPS or DCYF case worker, leaving respondents to believe

there has been no investigation commencing, as some contact with parents would be standard

policy.

Standards for Revision

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Authority for Revision. All acts and proceedings of Court Commissioners are subject to

revision by the Judge of the Superior Court. Wash Const. art. IV, sec. 23. Any party may have

such revision by filing a written motion, filed with the Clerk of Court, within ten (10) days after

the entry of any order or judgment of the Court Commissioner. RCW 2.24.050.

De Novo Review. Such revision shall be upon the records of the case and the findings of

fact and conclusions of law entered by the Court Commissioner. RCW 2.24.050. In re Smith, 8
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Wn. App. 285, 505 P.2d 1295 (1973); see also State ex rel. Biddinger v. Griffiths, 137 Wash.

448, 242 P.2d 969 (1926) ("Revision" is synonymous with "review".)

Findings/Conclusions. The Judge of the Superior Court, in reviewing decisions of the

Court Commissioner pursuant to RCW 2.24.050, should enter its own findings of fact and

conclusions of law into the record rather than simply adopting those of the Commissioner.

Matter of Estate of Larsen, 103 Wn.2d 517, 694 P.2d 1051 (1985).
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Relief Requested

Respondents hereby offers a good faith pleading of Motion for Revision over the

UGA review hearing that commenced on January 19, 2022, where no actual review of the

Guardianship took place. Respondents MOVES the court to fulfill its duties within scope as by

Washington State Law and the Commissioners sworn Oath of Office and to apply the evidence

given, that’s been verified as factual claims. Commissioner Waggoner and Commissioner
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Micheli have been extorting authorities outside of scope multiple times denying respondents

equal protection of the law, and continuing to entertain petitioners misappropriety of public

funds for her own vindictive gain and wasting the courts time and public resources. Respondents

motion to compel production of the offers of proof, I.E. test results or any other information

being cited. So the court has the opportunity to amend the issues brought against parents to enter

a dismissal with prejudice for all matters involving their minor children.
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RESPECTFULLY SUBMITTED this day of December 2021.

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.
Raymond Rocha Hannah Koelsch
UCC 1-308 UCC 1-308
All Rights Reserved All Rights Reserved