John Alika Kalii JR vs. Beth Ann Kalii 14-3-01646-7

E-FILED
IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, W ASHING TO N
April 22 2014 11:25 AM

KEVIN STOCK
COUNTY CLERK
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR PIERCE COUNTY
No. 14-3-01646-7
ORDER ASSIGNING CASE TO
JUDICIAL DEPARTMENT
D ocket Code: A S T
In accordance w ith PC LR 40(d), this case is hereby assigned to D epartm ent 12, Judge S T E P H A N IE A. AR E N D .
Notice to Petitioner:
O nce the case has been filed, the petitioner(s) shall serve a copy o f this O rder A ssigning Case to Judicial
D epartm ent on the respondent(s) w ith the sum m ons and petition. Provided, how ever, th a t in those cases w here
service is by publication the p etitioner shall serve a copy o f this O rde r A ssigning Case to Judicial D epartm ent
w ithin five (5) court days o f service o f the respondent's first response/appearance. If the case has not been filed,
but an initial pleading is served, a copy o f th is O rde r A ssigning Case to Judicial D epartm ent shall be served w ithin
five (5) court days o f filing. PC LR 1(b).
Trial Date:
A trial date m ay be obtained pursuant to PC LR 40(d) by filing a 'N ote o f Issue' fo r assignm ent o f a trial date by
noon at least six (6) court days prior to the date fixed fo r assignm ent o f the trial date. PC LR 40(d)
If a trial date is not obtained pursuant to PC LR 40(d), failure to app ea r on th is date w ill result in d ism issal o f
the case by the C ourt. PC LR 40(d)
Assignment TO SET Trial Date
Friday, September 05, 2014 9:00 AM
A t th a t tim e the C ourt w ill provide you w ith a Case S chedule w hich shall include the trial date. Failure to
app ea r on this date w ill result in d ism issal o f the case by the C ourt. PC LR 40(d).
Certificate of Completion of Mandatory Parenting Seminar due from both parties by 06/24/2014. See
PCLSPR 94.05(c). https:\\www.co.pierce.wa.us\pc\services\lawjust\parentingseminars.htm
Uncontested Dissolutions/Settlements:
If this case is agreed upon by both petitioner(s) and respondent(s) w ho are represented by attorneys, you are not
required to w a it fo r the trial date in o rd e r to settle yo u r case; after appropriate tim e requirem ents have been met,
final pleadings m ay be presented in E x Parte. If you are s e lf represented and settle yo u r case and the
appropriate tim e requirem ents have been met, you m ay file a Note fo r Pro S e /S e lf R epresented D issolution
C ale nd ar to appear before a C ourt C om m issio ne r fo r entry o f final papers.
D ATED : A pril 22, 2014

Judge S T E P H A N IE A. A R E N D
D epartm ent 12
astsup -0 0 04 .pd f
42414217
14-3-01646-7
CICS
04-23-14
SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

CASE COVER SHEET / DOMESTIC & PROBATE CASES
14 3 01646 7
Case Title____________________________________ Case Number^_________________________________________
Atty/Litigant \T < Q 4 r fr l
Address^
City_
a) l l \
K A~
K A i-l*
\ A J / U 6 f J - A r N S T-
3/tV
#__________ Phone_______________________ _
____________________________
Uc&BtMoot*_____________ ______ State_ \fJA-
Zip
Please check one category that best describes this case for indexing purposes.
Ifyou cannot determine the appropriate category, please describe the cause o f action below . This will create a
Miscellaneous cause which is not subject to PCLR 3.
DOMESTIC RELATIONS
ADOPTION / PATERNITY
DISSOLUTION
Of Marriage with Child (D1C 3) FAM LAW
____Of Marriage without Child (DIN 3) FAM LAW
____Of Domestic Partnrshp w Child (DPC 3)FAM LAW
____Of Domestic Prtnrshp w/o Child (DPN3)FAM LAW
LEGAL SEPARATION
____Of Marriage with Children {LSC 3) FAM LAW
____Of Marriage without Children (LSN 3)FAM LAW
____Of Domestic Partnership w Child (SPDC 3)FAM LAW
____Of Domestic Prtnrshp w/o Child (SPD 3)FAM LAW
____Invalidity (INV 3) FAM LAW
____Invalidity Domestic Partnership (INP 3) FAM LAW
____Child Custody (CUS 3) CUSTODY
____Parenting Plan / Child Support (PPS 3) FAM LA W
DOMESTIC RELATIONS
_ _ _ Foreign Judgment Domestic (FJU 3)Non PCLR
____Modification of Custody (MDC 3)Mod of CUSTODY
____Modification of Support Only (MDS 3) Non PCLR
___ Reciprocal, In County (RIC 3) Non PCLR
___ Reciprocal, Out of County (ROC 3) Non PCLR
___ Committed Intimate Relationship (CIR) FAM LAW
___ Mandatory Wage Assignment (MSC 3) Non PCLR
___ .Out of State Custody (MSC 3) Non PCLR
MISCELLANEOUS
Revised 09/01/2011 Fillable
_ Adoption (ADP 5) Non PCLR

_ Confidential Intermediary (MSC 5) REV4
_ Parenting-Parent Determination (PAT 5) REV 9
_ URESA / UIFSA (PUR 5) REV 9
__ Relinquishment (REL 5) Non PCLR
_ Terminate of Parent-Child Relation (TER 5) Non PCLR
_ Vulnerable Adult Petition (VAP 5) Non PCLR
_ Misc (MSC 5) REV 4
PROBATE / GUARDIANSHIP
_ Absentee (ABS 4) REV 4
_ Disclaimer (DSC 4) Non PCLR
_ Estate (EST 4) RE 12
__ Foreign Will (FNW 4) RE 12
_ Guardianship (GDN 4) REV4
_ Limited Guardianship (LGD 4) REV 4
_ Minor Settlement with Guardianship (MST 4) REV 4
__Non-Probate Notice to Creditors (NNC 4) Non PCLR
1 Will Only (WLL 4) Non PCLR
_ Misc (MSC 4) REV 4
Guardianship of Estate (GDE) REV 4
Guardianship of Person (GDP) REV 4
Limited Guardianship of Estate (LGE) REV 4
Limited Guardianship of Person (LGP) REV 4
F I LEU
ft
PIERCE COUNTY SUPERIOR COURT

KEVIN STOCK
CLERK OF THE SUPERIOR COURT
TACOMA %
I. j
o
o
14-3-016467
42414221
SM
04-23-14
14-3-01646-7
IN COUNTY c t i ^ K 'S OFFICE
a .m
8
o
Jj 10
\.+
JJ 12
,+
APR2 2 201^
pm
o:)
Acct, Date
Tima
04/22/2014 11:28 AM
Receipt/Itera ft Tran-Code Docket-Code

2014-05-04392/01 1103
$FFR
Cashier: CLH
PIERCE COUNTY, WASHINGTON

KEVIN STOCK, County Clerk
Paid By: kalii, John jr

Transaction Amount:
Superior Court of Washington

County of Pierce
14
In re the Marriage of:
No.
John Alika Kalii, Jr.
Summons
(SM)
16
if)
Rcpt, Me
04/22/2014
Petitioner,
18
14 3 01646 7
and
20
Beth Ann Kalii

Respondent.
22
24
To the Respondent: Beth Ann Kalii
26
1.
28
30
The petitioner
requesting:
has
started an action
in the
above
court
[X] that your marriage be dissolved.

[ ] that your domestic partnership be dissolved.
[ ] a legal separation.
[ ] that the validity of your marriage be determined.
[ ] .that the validity of your domestic partnership
determined.
32
34
be
36
Additional requests, if any, are stated in the petition,
copy of which is attached to this summons.
38
40
42
44
2.
You must respond to this summons and petition by serving a

copy of your written response on the person signing this
summons and by filing the original with the clerk of the
court. If you do not serve your written response within 20
days (or 60 days if you are served outside- of the State of
Washington) after the date this summons was served on you,
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 1
$290=[
exclusive of the day of service, the court may enter an order

of default against you, and the court may, without further
notice to you, enter a decree and approve or provide for the
relief requested in 'the petition.
In the case of a
dissolution, the court will not enter the final decree until
at least 90 days after filing and service. If you serve a
notice of appearance on the undersigned person, you are
entitled to notice before an order of default or a decree may
be entered.
2
4
6
8
10
12
3.
14
Your written response to the summons and petition must be on

form:
[X]
[ ]
16
18
WPF DR 01.0300, Response to Petition (Marriage).

WPF DR .01.0305, Response to Petition (Registered
Domestic Partnership).
20
4.
22
24
This form may be obtained by contacting the clerk of court at

the address below, by contacting the Adminstrative Office of
the Courts at (360) 705-5328, or from the Internet at the
Washington State Courts homepage:
http://www.courts.w a .gov/forms
26
28
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 the person signing this summons. Within 14 days after you
serve the demand, the petitioner must file this action with
the court, or the service on you of this summons and petition
will be void.
6.
If you wish to seek the advice of an attorney in this matter,

you should do so promptly so that your written response, if
any, may be served on time.
If you wish to seek the advice
of an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on time.
7.
One method of serving a copy of your response on the

petitioner is to send it by certified mail with return receipt
requested.
30
32
34
36
38
40
42
44
46
Summons (SM)
CR 4.1
Page 2
2
4
This summons is issued pursuant to

Civil Rule 4.1 of the state of Wa
Dated:
28.100 and Superior Court
ire of Petitioner {Pro Se)

or Lawyer/WSBA No.

Print or Type Name
10
12
14
File original of your response

with the clerk of the court at:
[X] Petitioner [You may list an

address
that
is
not
your
residential address where you
agree to accept legal documents.
Any time this address changes
while this action is pending, you
must notify the opposing parties
in writing and file an updated
Confidential
Information
Form
(WPF DRPSCU 09.200) with the
court clerk.]
[ ] Petitioner's Lawyer
16
18
20
22
24
26
28
30
32
Serve a copy of your response on:
Pierce County Superior Court

Clerk of Court______________
County-City Building________
930 Tacoma Avenue S., Room 110
Tacoma, WA 98402_____________
34
36
38
40
42
44
46
Summons (SM)
CR 4.1
Page 3
John Alika Kalii, Jr.___________

9711 Winona Street SW__________
Lakewood, Washington 98498_____
14-3-01646-7
42414223
PTDSS
04-23-14
AM. APR22 2014

8
PH.
E lg C f COUNTY, WASHINGTON
ri 10
C)
('\i
---- *-------DEPUTY
12
14

County of Pierce
16
No.
18
Petitioner,
20
and
22
Beth Ann Kalii
Respondent.
24
14 3 01646 7
Petition for Dissolution

of Marriage
(PTDSS)
Para. 1.12: check box if petition is
attached for:
[ ] Order for protection DV (PTORPRT)
[ ] Order for protection UH (PTORAH)
I. Basis
28
1.1
Identification of Petitioner
30
32
Birth date November 29, 1952

Name (first/last) John Alika Kalii, Jr.
Last known residence (county and state only} Pierce County, Washington
34
1.2
36
, Birth date August 11, 1968

Name (first/last) Beth Ann Kalii
Last known residence (county and state only) Pierce County, Washington
Identification of Respondent
38
1.3
Children of the Marriage Dependent Upon Either or Both Spouses
40
[ j
42
[X]
44
46
48
50
Name
Name
Name
Name
Name
Does not apply. There are no children dependent upon either or both
spouses.
The petitioner and respondent are both the legal (biological or
adoptive) parents of the following dependent children:
(first/last) Ka1ena Makani Kalii
(first/last) ___________________
(first/last)
_______
(first/last) ___________________
(first/last)
Pet forDisso of Marriage (PTDSS)

RCW 26.09.020
Page 1
Age
Age
Age
Age
Age
7 years
[ ]
The petitioner is and the respondent is not the legal parent of the
following dependent children:
4
6
Name (first/last) __________________ ____ ___________________ Age__________

Name (first/last) ______________________________________ Age
[ ]
The respondent is and the petitioner is not the legal parent of the
following dependent children:
Name
Name
(first/last) ______________________________________ Age

____
(first/last) ______________________________________ Age__________
10
12
14
1.4
Allegation Regarding Marriage
16
This marriage is irretrievably broken.
18
20
1.5
Date and Place of Marriage
22
24
The parties were married on November 21,

Hawaii.
2009 at Haleiwa,
26
[ ]
The parties had previously entered into a Washington

State
registered
domestic
partnership
on
(date)
[ ]
Other:
28
30
32
34
1.6
36
Separation
[ ]
[X]
38
40
42
Petitioner and respondent are not separated.

Petitioner and respondent separated on March 30, 2014.
This is the date (check all that apply):
[X] the parties moved into separate residences
[X] the parties divided their assets and liabilities
[ ] the petitioner filed this petition
[ ] both parties agreed is the date of separation
[ ] other:
44
46
1.7
Jurisdiction
48
This court has jurisdiction over the marriage.
50
[X]
This court has jurisdiction over the respondent because:
Pet for Disso of Marriage (PTDSS)

RCW 26.09.020
Page 2
[X]
[X]
4
6
[X]
8
[ ]
10
[ ]
12
the respondent is currently residing in Washington.

the petitioner and respondent lived in Washington
during their marriage and the petitioner continues
to reside, or be a member of the armed forces
stationed, in this state.
the petitioner and respondent may have conceived a
child while within Washington.
Other:
The
respondent is submitting to the
jurisdiction of the court by joining the petition.
This
court
respondent.
does
not
have
jurisdiction
over
the
14
16
1.8
Property
20
There is community or separate property owned by the parties.

The court should make a fair and equitable division of all the
property.
22
[ ]
24
[X]
18
The division of property should be determined by the

court at a later date.
The petitioner's recommendation for the division of
property is set forth below:
26
[ ]
The petitioner should be awarded

interest in the following property:
the
parties'
[ ]
The respondent should be awarded

interest in the following property:
the
parties'
[X]
Other: See Exhibit A.
28
30
32
34
36
38
40
42
1.9
Debts and Liabilities

[ ]
[X]
The parties have no debts and liabilities.

The parties have debts and liabilities. The court should
make a fair and equitable division of all debts and
liabilities.
44
[ ]
46
The division of debts and liabilities should be

determined by the court at a later date.
48
RCW 26.09.020
Page 3
[X]
The petitioner's recommendation for the division of

debts and liabilities is set forth below:
4
[ ]
The petitioner should be ordered to pay the

following
debts
and
liabilities
to
the
following creditors:
[ ]
The respondent should be ordered to pay the

following
debts
and
liabilities
to
the
following creditors:
8
10
12
14
[X]
16
[X]
Each party should pay their debts incurred since

separation.
.Other: See Exhibit A.
18
1.10
Maintenance
20
22
[X]
[ ]
Maintenance should not be ordered.

There is a need for maintenance as follows:
[ ]
Other:
24
26
28
1.11
Continuing Restraining Order
30
32
[X]
[ ]
34
[ ]
36
38
Does not apply.

A continuing restraining order should be entered which
restrains or enjoins the [ ] petitioner [ ] respondent
from disturbing the peace of the other party.
restrains or enjoins the [ ] petitioner [ ] respondent
from going onto the grounds of or entering the home, work
place or school of the other party or the day care or
school of the following children:
40
[ ]
46
A continuing restraining order should be entered, which

restrains or. enjoins the [ ] petitioner [ ] respondent
from knowingly coming within or knowingly remaining
within __________________ (distance) of the home, work
place or school of the other party or the day care or
school of these children:
48
Other:
42
44

RCW 26.09.020
Page 4
2
4
[ ]

restrains or enjoins ______________________ [Name] from
molesting,
assaulting,
harassing,
or
stalking
______________________ [Name]. (If the court orders this
relief, the restrained person will be prohibited from
possessing a firearm or ammunition under federal law for
the duration of the order. An exception exists for law
enforcement officers and military personnel when carrying
department/government-issued firearms.
18 U.S.C. 925 (a) (1) .)
[ ]
Other:
6
8
10
12
14
16
18
1.12
Protection Order
[X]
[ ]
20
22
[ ]
24
26
28
Does not apply.

There is a protection order between the parties filed in
case number ____ .
_____________, court _________________ ,
which expires on (date) ________________.
The court should grant the [ ] domestic violence [ ]
antiharassment petition for order for protection:
[ ] attached to this petition.
[ ] filed separately under [ ] this case number [ ]
case number _______________________.
If you need immediate protection, contact the clerk/court for

RCW 26.50 Domestic Violence forms or RCW 10.14 Antiharassment
forms.
30
32
34
1.13
Pregnancy
36
38
[X]
[ ]
Neither spouse is pregnant.

_____________________ is pregnant. Note: Under RCW
26.26.116, the other spouse is the presumed father. If
petitioner or respondent believes the other spouse is not
the parent, this presumption may be challenged up to four
years after the birth of the child or as otherwise
provided in RCW 26.26.500 through 26.26.625.
[ ]
Other:
40
42
44
46

RCW 26.09.020
Page 5
2
4
1.14
Jurisdiction Over the Children
[ ] Does not apply because there are no dependent children.
[X]
This court has jurisdiction over the children for the

reasons set forth below.
[ ]
This court has exclusive continuing jurisdiction.

The
court has previously made a child custody, parenting
plan, residential schedule or visitation determination in
this matter and retains jurisdiction under RCW 26.27.211.
[X]
This state is the home state of the children because:
10
12
14
16
[X]
18
20
22
[ ]
24
[ ]
26
[ ]
28
30
the children lived in Washington with a parent or a

person acting as a parent for at least six
consecutive
months
immediately
preceding
the
commencement of this proceeding.
the children are less than six months old and have
lived in Washington with a parent or a person
acting as a parent since birth.
any absences from Washington have been only
temporary.
Washington was the home state of the children
within six months before the commencement of this
proceeding and the children are absent from the
state but a parent or a person acting as a parent
continued to live in this state.
32
[X]
34
36
38
The children and the parents or the children and at least

one parent or person acting as a parent, have significant
connection with the state other than mere physical
presence; and substantial evidence is available in this
state concerning the children's care,
protection,
training and personal relationships; and
[X]
[ ]
40
42
the children have no home state elsewhere.

the children's home state has declined to exercise
jurisdiction on the ground that this state is the
more appropriate forum under RCW 26.27.261 or .271.
44
[ ]
46
48
All courts in the children's home state have declined to

exercise jurisdiction on the ground that a court of this
state is the more appropriate forum to determine the
custody of the children under RCW 26.27.261 or .271.

RCW 26.09.020
Page 6
2
[X]
No other state has jurisdiction.
[ ]
10
This court has temporary emergency jurisdiction over this

proceeding because the children are present in this state
and the children have been abandoned or it is necessary
in an emergency to protect the children because the
children, or a sibling or parent 'of the children is
subjected to or threatened with abuse. RCW 26.27.231.
12
[ ]
There is a previous custody determination that is

entitled to be enforced under this chapter or a
child custody proceeding has been commenced in a
court of a state having jurisdiction under RCW
26.27.201 through 26.27.221. The requirements of
RCW 26.27.231(3) apply to this matter. This state's
jurisdiction over the children shall last until
[Date].
[ ]
There is no previous custody determination that is

entitled to be enforced under this chapter and a
child custody proceeding has not been commenced in
a court of a state having jurisdiction under RCW
26.27.201 through 26.27.221. If an action is not
filed in _________________ [potential home state]
by the time the child has been in Washington for
six
months,
_______________
[Date] ,
then
Washington's
jurisdiction
will
be
final
and
continuing.
4
6
8
14
16
18
20
22
24
26
28
30
32
[ ]
Other:
34
1.15
Child Support and Parenting Plan for Dependent Children
36
38
40
[ ]
[X]
The parties have no dependent children.

A parenting plan and an order of child support pursuant
to the Washington State child support statutes should be
entered for the following children who are dependent upon
both parties:
42
Names of Children
44
Ka1ena Makani Kalii
46
48
RCW26.09.020
Page 7
2
4
6
The petitioner's proposed parenting plan for the children

listed above:
8
[X]
10
[ ]
12
is attached and is incorporated by reference as

part of this Petition.
will be filed and served at a later date pursuant
to RCW 26.09.181.
16
(The following information is required only for those

children who are included in the petitioner's proposed
parenting plan.)
18
During the last five years, the 'children have lived:
20
[X]
14
22
[ ]
24
26
28
in no place other than the State of Washington and

with no person other than the petitioner or the
respondent.
in the following places with the following persons
(list each place the children lived, including the
State of Washington, the dates the children lived
there and the names of the persons with whom the
children lived. The present addresses of those
persons must be listed in the required Confidential
Information Form):
30
32
Claims to custody or visitation;
34
[X]
36
38
[ ]
40
42
44
The petitioner does not know of any person other

than the respondent who has physical custody of, or
claims to have custody or visitation rights to, the
children.
The following persons have physical custody of, or
claim to have custody or visitation rights to the
children
(list their names and the children
concerned below and list their present addresses in
the Confidential Information Form. Do not list the
responding party):
46
48
RCW 26.09.020
Page 8
2
4
Involvement
children;
in
any
other
proceeding
concerning
the
6
[X]
8
[ ]
10
12
The petitioner has not been involved in any other

proceeding regarding the children.
The petitioner has been involved in the following
proceedings regarding the children (list the court,
the case number, and the date of the judgment or
order):
14
16
Other legal proceedings concerning the children.
18
[X]
20
[ ]
22
24
The petitioner does not know of any other legal

proceedings concerning the children.
The petitioner knows of the following legal
proceedings which concern the children (list the
children concerned, the court, the case number, and
the kind of the proceeding):
26
1.16
Other
28
30
32
II. Relief Requested
34
36
The petitioner Requests the Court to enter a decree of dissolution

and to grant the relief below.
38
[ ]
40
[X]
42
[X]
44
46
[ ]
[X]
[ ]
Provide reasonable maintenance for the [ ] petitioner [ ]

respondent.
Approve the petitioner's proposed parenting plan for the
dependent children listed in paragraph 1.15.
Determine support for the dependent children listed in
paragraph 1.15 pursuant to the Washington State child
support statutes.
Approve the separation contract or prenuptial agreement.
Divide the property and liabilities.
Change name of petitioner to (first, middle, last):
48
RCW 26.09.020
Page 9
[ ]
Change name of respondent to (first, middle, last):
[
[
[
[
Enter a domestic violence protection order.

Enter an antiharassment protection order.
Enter a continuing restraining order.
Order payment of day care expenses for the children
listed in paragraph 1.15.
Award the tax exemptions for the dependent children
listed in paragraph 1.15 as follows: The petitioner shall
be awarded the tax exemption for the child every oddnumbered year and the respondent shall be awarded the tax
exemption for the child every even-numbered year.
Order payment of attorney's fees, other professional fees
and costs.
Other:
]
]
]
]
8
[X]
10
12
14
[ ]
16
[ ]
18
20
22
or Lawyer/WSBA No.
24

Print or Type Name
26
28
30
I declare under penalty of perjury under the laws of the State of

Washington that the foregoing is true and correct.
32
34
36
38
40
42
44
46
48
[ ]
Joinder
I, the respondent, join in the petition. I understand that by
joining in the petition, a decree or judgment and order may be
entered in accordance with the relief requested in the
petition, unless prior to the entry of the decree or judgment
and order a response is filed and served.

RCW 26.09.020
Page 10
2
4
[ ]
[ ]
6
8
I waive notice of the decree.

I demand notice of all further proceedings in this
matter. Further notice should be sent to the following
address: [You may list an address that is not your
residential address where you agree to accept legal
documents]:
10
Any time this address changes while this action is
pending, you must notify the opposing parties in writing
and file an updated Confidential Information Form (WPF
DRPSCU 09.0200) with the court clerk.
12
14
16
[ ]
18
20
22
24
26
28
30
32
I have carefully read the petition and the other

pleadings prepared by the petitioner. I agree with the
statements in the petition and the other pleadings, and I
join in the petition. I understand that by joining in the
petition, I agree with the relief requested in the
petition and the other pleadings and waive any objections
I might have to the statements therein. I understand that
We Th e P e o p l e , P . S . has prepared these documents based on
information provided to them by my spouse and that We The
P e o p l e , P . S . is NOT my attorney. I have not been given
legal advice by a We T h e P e o p l e , P . S . Attorney, other
than in the Petitioner's presence, nor by any other
person at We T h e P e o p l e , P . S . I also understand that if I
have any questions about the petition or the other
pleadings, or there is anything I do not understand, I
should consult with my own attorney.
34
36

Washington that the statement above is true and correct.
38
Dated: _________________________
40
_______________________
Signature of Respondent
Beth Ann Kalii_________
Print or Type Name
42
44
46
48
RCW 26.09.020
Page 11
re: John Alika Kalii, Jr. and Beth Ann Kalii
2
4
Exhibit A
6
The petitioner shall be awarded the following community and/or separate
property, and shall be ordered to pay the following community and/or
separate debts and liabilities:
8
10
12
PROPERTY WITH ASSOCIATED DEBTS:
14
2006
Ford
F150,
VIN
1FTRX14W16NB00322, and
all
debts
associated with said vehicle;
2009 Yamaha XVI95VGY, VIN JYAVP21E99A007281, and all debts
associated with said vehicle.
16
18
The petitioner shall be awarded the real property located at

and commonly known -as 9711 Winona Street SW, Lakewood,
Washington 98498, Tax Parcel Number: 500500-488-0, and legally
described as follows:
20
22
24
Lots 17, 18 and 19, Block 60, Map of Lake City,

Washington Territory, according to Plat recorded in Book
3 of Plats at Page 18, in Pierce County, Wshington.
26
28
The petitioner shall be financially responsible for the First

Position Mortgage debt on the above-described real property,
whether such debt is held by Wells Fargo Bank (the current
First Position Mortgage debt holder), or by any assignee or
successor of Wells Fargo Bank (said current First Position
Mortgage debt holder), until such First Position Mortgage debt
has been fully paid; and shall also be financially responsible
for all other debts associated with said real property.
30
32
34
36
OTHER PROPERTY:
38
Living room furniture;
All property currently in the petitioner's possession, unless
otherwise awarded to the respondent;
All life insurance policies in the petitioner's name only, of
which the petitioner is the owner;
100% of the petitioner's Tacoma Fire Department LEOFF2
retirement account;
accounts in the petitioner's name only
40
42
44
46
Respondent Signature and Date
Exhibit A
Page 1
Harborstone Credit Union accounts in the petitioner's

only;
All other bank accounts in the petitioner's name only.
4
6
name
OTHER DEBTS:
Mastercard debt;
Lowes debt;
Target debt;
All debts incurred by the petitioner after the date of the
parties' separation, March 30, 2014;
All other debts in the petitioner's name only.
10
12
14
The respondent shall be awarded the following community and/or separate
property, and shall be ordered to pay the following community and/or
separate debts and liabilities:
16
18
20
PROPERTY WITH ASSOCIATED DEBTS:
22
2000 Dodge Durango and all debts associated with said vehicle.
24
OTHER PROPERTY:
26
42" Flatscreen TV;

King-size bed;
All property currently in the respondent's possession, unless
otherwise awarded to the petitioner;
All life insurance policies in the respondent's name only, of
which the respondent is the owner;
100% of the respondent's SERS 3 retirement account;
All other retirement accounts in the respondent's name only;
Bank of America account in the respondent's name only;
All other bank accounts in the respondent's name only.
28
30
32
34
36
OTHER DEBTS:
38
Credit card debts in the respondent's name only;
Personal loans in the respondent's name only;
All debts incurred by the respondent after the date of the
parties' separation, March 30, 2014;
All other debts in respondent's name only.
40
42
44
46
Respondent Signature and Date
Page 2
The petitioner and the respondent shall jointly be awarded the following
property and shall jointly be ordered to pay the following debts and
liabilities:
2
4
PROPERTY WITH ASSOCIATED DEBTS
1996 Wilderness 26' Travel Trailer, VIN 1ED1T2629T2383516,

all debts associated with said vehicle.
and
10
12
OTHER DEBTS
14
The parties shall be equally responsible for payment of any

additional tax owed on their 2013 joint Federal income tax
return.
16
The petitioner and the respondent have previously divided all remaining
property and debts to the satisfaction of both parties.
18
20
Effective date:
22
Unless otherwise specified this division of debts and personal

property shall be effective no later than the entry of the final
Decree of Dissolution.
24
26
28
30
32
34
36
38
40
42
44
46
Exhibit A
Page 3
Nothing Follows
IN COUNTY CLERKS OFFICE
A M.
APR22 2014
P.M.

KEVIN STOCK, C ounty Clerk
BY--------------------------------- DEPUTY
6
8
10
12

County of Pierce
14
No.
1 4 3 01 646 7
16

Petitioner,
18
and
20
Notice Re: Dependent of a

Military Service Member
(Optional Use)
(NTDMP)
Beth Ann Kalii

22
24
26
28
30
32
34
36
38
40
Respondent.
Notice: State and federal law provide protections to defendants/respondents who are in the military
service} and to their dependents. This notice only pertains to a defendant/respondent who is a dependent of
a member of the National Guard or a military reserve component under a call to active service under state
or federal authority, for a period of more than thirty (30) consecutive days. Other defendants/respondents
in military service also have protections against default judgments not covered by this notice. Dependents
o f a service member are the service members spouse, a service members minor child, or an individual for
whom the service member provided more than one-half of the individuals support for one hundred eighty
days (180) days immediately preceding an application for relief.
One protection provided is the protection against the entry o f a default judgment in certain circumstances.
If you are the dependent o f a member of the National Guard or a military reserve component under a call to
active service under state or federal authority, for a period of more than thirty (30) consecutive days, you
should notify the plaintiff/petitioner or, if the plaintiff/petitioner is represented by an attorney, the
plaintiff/petitioners attorney in writing of your status as such within twenty (20) days of the receipt of this
notice. If you fail to do so, then a court or an administrative tribunal may presume that you are not a
dependent o f an active duty member of the National Guard or reserves under state or federal authority, and
proceed with the entry o f an order of default and/or a default judgment without further proof of your status.
Your response to the plaintiff/petitioner or plaintiff/petitioners attorney about your status does not
constitute an appearancejof^ttris^lictional purposes in any pending litigation, a waiver o f your rights or a
response to the petitioifi, compjînt-thôther application for relief that was filed against you.
42
>
44
Dat
/ / / ^
re o f Petitioner
Notice re: Dep of Military Service Member (NTDMP)

WPF DRPSCU 01.0185 (6/2012)
RCW 38.42.050
Page 1
John Alika Kalii. Jr.

Print or Type Name
J
*4
r
2
4
14-3-01646-7
42414234
APRS
04-23-14
a m.
APR 22 20W
p .m.

KEVIN S T O C K /C ou nty Clerk
BY____________
DEPUTY
8
10
12
14

County of Pierce
16
No.
18
Pro se Notice of Appearance

(APPS)
20
and
22
Beth Ann Kalii
Petitioner,
14 3 01646 7
Respondent.
24
26
28
The undersigned enters an appearance in this action, and demands notice of all
further proceedings.
The Clerk of the Court and the opposing party will be
informed of any change in address.
Any notices may be sent to [You may list an
address that is not your residential address where you agree to accept legal
documents.]
30
Service Addr e s s :
32
9711 Winona Street SW

Lakewood,
Washington
98498
34
36
Any time this address changes while this action is pending, you must notify
the opposing parties in writing and file an updated Confidential Information
Form {WPF DRPSCU 09.0200) with the court clerk.
38
40
42
44
46
48
Notice of Appearance (APRS)
WPF DRPSCU 01.0320 (6/2006)
Page 1
IN COUNTY CORK'S OFFICE
AM
APR
2014
22
--------------------
PM.
.DEPUTY

County of
In re:
J'oHAsJ
A f l K *
K A L -ll
Financial Declaration
fcj Petitioner
[ ] Respondent
(FNDCLR)
Petitioner,
and
Bertf'-
kAL/i '
Respondent.
Name:
fcA L
A U K A
14 3 01646 7
No.
; O X
Date of Birth:
it j
fl
/*7f e -
I. Summary of Basic information

Declarants Total Monthly Net Income {from 3.3 below)
$ ____________
Declarants Total Monthly Household Expenses (from 5.9 below)
$ _____________
Declarants Total Monthly Debt Expenses (from 5.11 below)
$ ____________
Declarants Total Monthly Expenses (from 5,12 below)
$ _____________
Estimate of the other partys gross monthly income (from 3.1 f below)
[ ] $ ____________
[ ] unknown
II. Personal Information

2.1
Occupation:
2.2
The highest year of education completed:
2.3
Are you presently employed? [ ] Y e s ^ N o

a. If yes:
^ r / ^ P
(1)
/ i i
i t
of
-fh c o N i/k
fiff
p fP T
/4
Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
Financial Declaration (FNDCLR) - Page 1 of 6

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
Li i
b. If no:
LJ
(2)
When did you start work there (month/year)?
(1)
When did you last work (month/year)?
(2)
(3)
What were your gross monthly earnings?

Why are you presently unemployed?
12L/Z#_i2r
s
frrr(KEp>
-X
III. Income Information
Aj
.+
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip Paragraphs 3.1 and 3.2.
If maintenance, fees, costs or debts are at issue and child support is Not an issue this entire section should be
completed. (Estimate of other partys income information is optional.)
3.1
Gross Monthly Income

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your monthly wages
and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If you are paid twice
monthly, multiply your gross pay by 2. If you are paid once a month, list that amount below.
Name
hLi}
3.2
Name
a.
Wages and Salaries
sV , 3 6 Z -
b.
Interest and Dividend Income
$ __________
c.
Business Income
$ __________
$ ___________
d.
Spousal Maintenance Received
cto
3*7
From____________________________
$ ___________
e.
Other Income
$ ___________
f.
Total Gross Monthly Income (add lines 3. la through 3.le)
g-
Actual Gross Income (Year-to-date)
$ ___________
Monthly Deductions From Gross Income

a.
Income Taxes
b.
FICA/Self-employment Taxes
%__________
c.
State Industrial Insurance Deductions
$ __________
d.
Mandatory Union/Professional Dues
$ __________
e.
Pension Plan Payments
$ __________
f.
Spousal Maintenance Paid
$ __________
s_______
g.
Normal Business Expenses
$ ___________
Total Deductions from Gross Income
s 3o^> o ^
s 2-s
h.
3 o 5 . o
s 7-or. 7 3
V 3 - 1 K
(add lines 3.2a through 3.2g)
3.3
Monthly Net Income (Line 3.! f minus line 3.2h or

line 3 from the Child Support Worksheet(s).)

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
[
j
^ 5
3.4
Miscellaneous Income
a.
Child support received from other relationships
b.
Other miscellaneous income (list source and amounts)
c.
Total Miscellaneous Income (add lines 3.4a through 3.4b)
Income of Other Adults in Household

3.6
If the income of either party is disputed, state monthly income you believe is correct and explain below:
IV. Available Assets

4.1
Cash on hand
4.2
On deposit in banks
4.3
Stocks and bonds, cash value of life insurance
4.4
Other liquid assets:
/Z 3
r o o . C~u
V. Monthly Expense Information

Monthly expenses for myself and
/ ______ dependents are: (Expenses should be calculated for the future,
after separation, based on the anticipated residential schedule for the children.)
5.1
5.2
Housing
Rent, l st mortgage or contract payments
Installment payments for other mortgages or encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
f
^
Utilities
Heat (gas & oil)
Electricity

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
1 7 ' <f-Q
Water, sewer, garbage

Telephone/
5.3
5.4
//V. ft/
$ 3 Z o .o o
Cable
t jL 3 3 _ L . S C
Total Utilities
$ r3 C , t / c
Food and Supplies

__________
Food for___________ persons
Supplies (paper, tobacco, pets)
$ __________
Meals eaten out
$ __________
Other
$ __________
Total Food Supplies
Children
Day Care/Babysitting
$ __________
Clothing
s_______ -<S
$
- < *> ^
Tuition (if any)

Other child-related expenses
Total Expenses Children
5.5
,cr &
/6 - &
Transportation
Vehicle payments or leases
% 6*1
Vehicle insurance & license

Vehicle gas, oil, ordinary maintenance
5.6
5.7
Parking
$ ___________
Other transportation expenses
Total Transportation
Health Care (Omit if fully covered)

Insurance
Uninsured dental, orthodontic, medical, eye care expenses
Other uninsured health expenses
Total Health Care
Personal Expenses (Not including children)

Clothing
Hair care/personal care expenses

Financial Declaration (FNDCLR) Page 4 of 6
WPF DRPSCU 01.1550 (6/2006) RCW 26.18.220(1)
-
5.8
Clubs and recreation
Education
Books, newspapers, magazines, photos
Gifts
Other
Total Personal Expenses
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other_____________________________________________
Other_____________________________________________
Total Miscellaneous Expenses
5.9
Total Household Expenses (The total of Paragraphs 5.1 through 5.8)
5.10
Installment Debts Included in Paragraphs 5.1 Through 5.8

Creditor
5.11
Description
of Debt
Month of
Last Payment
Balance
Other Debts and Monthly Expenses not Included in Paragraphs 5.1

Through 5.8
Description
of Debt
Creditor
/ jr u ie f s
,______
__________
____________
___ ^
T t!* - ( t& r t- D
__________
Month of
Last Payment
Amount of
Monthly
Payment
____________
$ ________
Balance
___________________ $ ___________
/ ^ Z 7 , 3/
______
fiP&L $ VfiMSS
s_____
___________________________ $ ___________
___________________________ $ ___________
___________________________ $ ___________
Total Monthly Payments for Other Debts and Monthly Expenses
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
5.12
Total Expenses (Add Paragraphs 5.9 and 5.11)
VI. Attorney Fees

6.1
Amount paid for attorney fees and costs to date:
6.2
The source of this money was:
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are:
6.5
Other:
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
Signed at *
[City]
l A / / \ , [State] on *
C 7 b H -fJ
/ 4 /T^ n 2 ^ / Patel.
K A L -t/
_______
Print or Type Name
frig financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:
^ .In d iv id u a l [ ] Partnership or Corporate Income Tax returns for the years
) "TL# /
f
including all W-2s and schedules;
[ ] Pay stubs for the dates of / c / ^ a / 3
3 / z - a / A
r 1 Other:
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the sealed financial source documents cover sheet (WPF DRPSCU
09.0220). If filed separately using the cover sheet, the records will be sealed to
protect your privacy (although they will be available to all parties in the case,
their attorneys, court personnel and certain state agencies and boards.) See GR
22 (C)(2).

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
\
9
AM
APR 22 201*
p i

K E V IN S T O C K , C o u n ty C le 'k
BY--------------___________ 1 DEPU'i i
'-j
(J
OJ
Washington State Child Support Schedule Worksheets

[ ] Proposed by [ ]
[ ] State o f W A [ ] O ther
Or, [X] Signed by the Judicial/R eview ing O fficer. (CSW )
Mother Beth Ann

County PIERCE
Kalii
Father John
Case No.
(C S W P )
A lika Kalii Jr.
1 4 3 01 646 7
Child(ren) and Age(s): Ka'ena Makani Kalii, 8

Part I: Income (see Instructions, page 6)
Father
1. G ross M onthly Incom e

a. W a g e s and Salaries
b. Interest and Dividend Incom e
c. Business Incom e
d. M aintenance R eceived
e .O th e r Incom e
f. Im puted Incom e
g.T otal G ross M onthly Incom e (add lines 1a through 1f)
Mother
$2,637.00
$4,352.00
-
$4,352.00
$2,637.00
$303.06
$230.89
$201.73
2. M onthly D eductions from G ross Incom e

a. Incom e T axes (Federal and State) T a x Y ear: 2 0 1 4
b. FIC A (S oc.S ec.+M edicare)/S elf-E m ploym ent T axes
c.S ta te Industrial Insurance D eductions
d. M andatory U nion/P rofessional Dues
e. M andatory Pension Plan Paym ents
f. V oluntary R etirem ent C ontributions
g. M aintenance Paid
h. Norma) B usiness Expenses
i. T otal D eductions from G ross Incom e
(add lines 2a through 2h)
$43.85
$263.79
$303.06
$740.26
$4,048.94
$1,896.74
*$5,945.68
3. M onthly Net Incom e (line 1g minus 2i)

4. C om bined M onthly N et Incom e
(line 3 amounts combined)
5. Basic Child S upport O bligation (C om bined am ounts )

Ka'ena M akani Kalii
$850.00
'/ h
$850.00
6. P roportional Share o f Incom e

(each parent's net income from line 3 divided by line 4)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 1 of 5
.681
.319
Part II: Basic Child Support Obligation (see Instructions, page 7)

7. Each Parent's Basic Child Support O bligation w ithout consideration
o f low incom e lim itations (Each parent's Line 6 tim es Line 5.)
$271.15
$578.85
8. C alculating low incom e lim itations: Fill in only those that apply.
S elf-S upport Reserve: (125% o f the Federal Poverty G uideline.)
a. Is com bined Net Incom e Less T han $1,000? If yes. fo r each

parent enter the presum ptive $50 per child.
b. Is M onthly Net Incom e Less Than S elf-S upport R eserve? If ves.
fo r that parent e nte r the presum ptive $50 per child.
c. Is M onthly Net Incom e eaual to or m ore than Self-SuDDort
R eserve? If yes. fo r each parent subtract the self-support
reserve from line 3. If that am ount is less than line 7, e nte r that
am o un t or the presum ptive $50 per child, w hichever is greater.
9. Each parent's basic child support obligation a fter calculating
applicable lim itations. For each parent, enter the low est am ount
from line 7, 8a - 8c, but not less than the presum ptive $50 per
child.
$1,216.00
$271.15
$578.85
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
Father
10. Health C are Expenses

a. M onthly Health Insurance Paid fo r C hild(ren)
b. Uninsured M onthly Health C are Expenses Paid fo r C hild(ren)
c. T otal M onthly Health C are Expenses
(line 10a plus line 10b)
Mother
$234.34
$234.34
d. C om bined M onthly Health C are Expenses

(line 10c amounts combined)
$234.34
11. Day C are and Special Expenses

a. Day C are Expenses
b. Education Expenses
c. Long D istance Transportation Expenses
d. O th e r Special E xpenses (describe)
e. T otal Day C are and Special Expenses

(Add lines 11 a through 11 d)
12. C om bined M onthly T otal Day C are and Special Expenses

(line 11 e amounts Combined)
'
>i*
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
7.
'V
$234.34
14. Each Parent's O bligation fo r Health Care, Day Care, and Special
Expenses (m ultiply each num ber on line 6 by line 13)
$159.59
$74.75
Part IV: Gross Child Support Obligation

15. G ross Child S upport O bligation (line 9 plus line 14)
$738.44 |
$345.90
Part V: Child Support Credits (see Instructions, page 9)

16. Child S upport C redits
a. M onthly Health C are Expenses C redit
b.D ay C are and Special Expenses C redit
$234.34
-
c. O ther O rdinary E xpenses C redit (describe)

-
d.T otal Support C redits (add lines 16a through 16c)
$234.34
Part VI: Standard Calculation/Presumptive Transfer Payment (see Instructions, page 9)

17. Standard C alculation (line 15 m inus line 16d or $50 per child
w hich eve r is greater)
$738.44
$111.56
$1,822.02
$853.53
$144.71
$67.79
Part VII: Additional Informational Calculations

18. 45% o f each parent's net incom e from line 3 (.45 x am o un t from
line 3 fo r each parent)
19. 25% o f each parent's basic support obligation from line 9 (.25 x
am o un t from line 9 fo r each parent)
Part VIII: Additional Factors for Consideration (see Instructions, page 9)

20. H ousehold A ssets
(L ist the e stim a te d va lu e o f all m a jo r h o u se h o ld a ssets.)
a. Real Estate
b. Investm ents
c. V ehicles and Boats
d. Bank A cco un ts and Cash
e. R etirem ent A ccounts
f. Other: (describe)
Father's
H ousehold
M other's
Household
21. H ousehold Debt

(List liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
22. O th e r H ousehold Incom e
a. Incom e O f C urren t Spouse or D om estic Partner
(if not the other parent o f this action)
N am e
N am e
b. Incom e O f O th e r A dults in Household
N am e
N am e
c. G ross Incom e from overtim e or from second jo b s the party
is asking the court to exclude per Instructions, page 8
d. Incom e O f C hild(ren) (if considered extraordinary)

Nam e
N am e
e. Incom e From Child S upport

N am e
Nam e
f. Incom e From A ssistance Program s

Program
Program
g. O ther Incom e (describe)
23, N on-R ecurring Incom e (describe)
24. Child Support Owed, M onthly, fo r Biological or Legal C hild(ren)

N am e/age:
N am e/age:
N am e/age:
Father's
H ousehold
Paid f ] Yes [ ] No
Paid f ] Yes [ ] No
Paid f ] Yes [ ] No
25. O ther C hild(ren) Living In Each H ousehold

(First nam e(s) and age(s))
26.
O ther Factors For C onsideration
WSCSS-Worksheets Mandatory (CSW/CSWP) 07/2013 Page 4 of 5

-
M other's
Household
-
Judicial/R eview ing O fficer
Date
Worksheet certified by the State of Washington Administrative Office of the Courts.

Photocopying of the worksheet is permitted.
SupportCa/c 2014
c:..\state templates\waworksheet.dtf c:..\kalii jr, john alika\kalii jr, john alika.scp 04/18/2014 01:39 pm
Mother: Beth Ann Kalii

County: PIER C E
ifl
ro
("
J
o
n
Father: John Alika Kalii Jr.

S uperior C ourt C ause Num ber:
RESIDENTIAL SCHEDULE CREDIT USING FORMULA

16. NAM ES OF C H ILD R EN
17. BASIC S U P P O R T
(From Table)
18. O R D IN A R Y EXPENSES
Ka'ena
$850.00
iM
19. A D JU S T E D BASIC SU P P O R T
-T
20. O V E R N IG H T S W IT H M O TH E R
$850.00
117
21. % O V E R N IG H T S W IT H M O THER
(Line 20 divided by 365)
32.1
22. O V E R N IG H T S W IT H FATHER
248
Lfi
C()
23. % O V E R N IG H T S -F A T H E R
67.9
24. M O T H E R S C R E D IT PROP
.140
25. F A T H E R S C R ED IT PROP
.860
26. M O T H E R S C R E D IT
(Line 19 tim es Line 24)
$119.00
27. F A T H E R S C R E D IT
$731.00
28. O V E R N IG H T T H R E S H O LD SELEC TED :

29. T R A N S F E R PA YM EN T BE FO R E C REDIT:
30. R ES ID EN TIAL C R E D IT T O M other IS:
31. T R A N S F E R PA YM EN T A F T E R C REDIT:
Client: c:..\kalii jr. john alika\kalii jr, john alika.scp 04/18/2014 01:40 pm
S upportC a/c 2 0 1 4 {R e v . 1 0 /20 0 9 )
Cr.pyutjiu i014bv
Soif-AMM;C.tr.ubInn,
91 N IG H TS
$111.56
$119.00
-$7.44
AM. APR 22 2014

'6
k Iviw
P.M.
^ ashington
KEVIN S T O C K /p o unty Clerk

T----------------- ------ DEPUTY
8
10
12

County of Pierce
14
16
No.
[X] In re the Marriage of:
[ ] In re the Domestic Partnership of:
18
20
and
22
Beth Ann Kalii
Petitioner,
1 4 3 01 646 7
Parenting Plan
[X] Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
Respondent.
24
28
This parenting plan is:

[ ] the final parenting plan signed by the court pursuant to a
decree of dissolution, legal separation, or declaration
concerning validity signed by the court on this date or dated
30
[ ]
26
32
the final parenting plan signed by the court pursuant to an

order signed by the court' on this date or dated ___________
which modifies a previous parenting plan or custody decree.
a temporary parenting plan signed by the court.
proposed by petitioner .
34
[ ]
[X]
36
It Is Ordered, Adjudged and Decreed:

I. General Information
38
40
This parenting plan applies to the following child:
42
Name
44
Ka'ena Makani Kalii
Parenting Plan (PPP, PPT, PP)

RCW 26.09.016;. 181;. 187;. 194
Page 1
Age
7 years
II. Basis For Restrictions
Under certain circumstances, a s outlined below, the court may limit or prohibit a parent's contact with the child
and the right to make decisions for the child.
6
8
2.1
10
Parental Conduct (RCW 26.09.191(1), (2))

[X]
[ ]
12
14
16
Does not apply.

The [ ] petitioner's [ ] respondent's residential time
with the child)
shall be limited or restrained
completely, and mutual decision-making and designation of
a dispute resolution process other than court action
shall not be required, because [ ) this parent [ ] a
person residing with this parent has engaged in the
conduct which follows.
18
[ ]
20
22
[ ]
24
[ ]
26
28
Willful abandonment that continues for an extended

period of time or substantial refusal to perform
parenting functions {this applies only to parents,
not to a person who resides with a parent).
Physical, sexual or a pattern of emotional abuse of
a child.
A history of acts of domestic violence as defined
in RCW 26.50.010(1) or an assault or sexual assault
which causes grievous bodily harm or the fear of
such harm.
30
2.2
Other Factors (RCW 26.09.191(3))
32
34
36
[X]
[ ]
Does not apply.

The [ ] petitioner's [ ] respondent's involvement or
conduct may have an adverse effect on the child's best
interests because of the existence of the factors which
follow.
38
[ ]
40
[ ]
42
44
46
[ ]
Neglect or substantial nonperformance of parenting

functions.
A long-term emotional or physical impairment which
interferes with the performance of parenting
functions as defined in RCW 26.09.004.
A
long-term
impairment
resulting
from drug,
alcohol, or other substance abuse that interferes
with the performance of parenting functions.

RCW 26.09.016;.181;.187;. 194
Page 2
[ ]
[ ]
6
[ ]
8
10
[ ]
The absence or substantial impairment of emotional

ties between the parent and the child.
The abusive use of conflict by the parent which
creates the danger of serious damage to the child's
psychological development.
A parent has withheld from the other parent access
to the child for a protracted period without good
cause.
Other:
12
14
III. Residential Schedule
16
18
20
22
The residential schedule must set forth where the child shall reside each day of the year, including provisions
forholidays, birthdays of family members, vacations, and other special occasions, and what contact the child
shall have with each parent. Parents are encouraged to create a residential schedule that meets the
developmental needs of the child and individual needs of their family. Paragraphs 3.1 through 3.9 are one
way to write your residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
24
3.1
Schedule for Children Under School Age
26
28
30
[X]
[ ]
There are no children under school age.

Prior to enrollment in school, the child shall reside
with the [ ] petitioner [ ] respondent, except for the
following days and times when the child will reside with
or be with the other parent:
32
from _____________________
to
34
36
[ ] every week [ ] every other week [ ] the first and

third week of the month [ ] the second and fourth week of
the month [ ] other:
38
40
from _____________________
42
[ ] every week [ ] every other week [ ] the first and

third week of the month [ ] the second and fourth week of
the month [ ] other:
44
46

RCW 26.09.016;.181;.187;.194
Page 3
to ________________________
3.2
School Schedule
Upon enrollment in school, the child shall reside with the [X]
petitioner [ ] respondent, except for the following days and
times when the child will reside with or be with the other
parent:
4
6
8
The respondent shall have residential time with the child

from Friday at 6:00 p.m. until Sunday at 7:00 p.m. every
weekend.
10
12
[X]
14
The school schedule will start when each child begins

[ ] kindergarten [ ] first grade [X] other: currently in
effect.
16
18
3.3
Schedule for Winter Vacation

The child shall reside with the [X] petitioner [ ] respondent
during winter vacation, except for the following days and
parent:
20
22
24
Each parent shall have the child for a portion of the

winter vacation. In odd-numbered years the respondent
shall have the child from the end of classes for the
vacation until December 25th at 12:00 Noon, and the
petitioner shall have the child from 12:00 Noon on
December 25th until 7:00 p.m. the day before classes
resume. The schedule shall be reversed in even-numbered
years.
26
28
30
32
34
3.4
Schedule for Other School Breaks
36
38
40
42
44
The child shall reside with the [X] petitioner [ ] respondent

during other school breaks, except for the following days and
parent:
The child shall spend the spring vacation with the
petitioner in odd-numbered years and with the respondent
in even-numbered years.
46
RCW 26.09.016;. 181;.187;.194
Page 4
3.5
Summer Schedule
Upon completion of the school year, the child shall reside
with the [X] petitioner [ j respondent, except for the
following days and times when the child will reside with or be
with the other parent:
4
6
8
[ ]
[X]
10
Same as school year schedule.

Other:
The summer schedule shall be the same as under Paragraph
3.2, above, with the additional provision that each
parent shall have a period of up to 15 consecutive days
for a vacation with the child, during which time the
other parent's schedule with the child shall not be in
effect. Each parent shall notify the other parent in
writing of his or her proposed dates of summer vacation
time with the child, said notice to be received by the
other parent not later than May 1st of each year that
this provisions applies. If there is an overlap between
the parents' proposed vacation times, the petitioner's
dates shall have priority in even-numbered years and the
respondent's dates shall have priority in odd-numbered
years.
12
14
16
18
20
22
24
26
28
3.6
Vacation With Parents

[X]
[ ]
30
Does not apply.

The schedule for vacation with parents is as follows:
32
34
36
3.7
Schedule For Holidays

The residential schedule for the child for the holidays listed
below is as follows:
38
With Petitioner With Respondent
(Specify Year
(Specify Year
Odd/Even/Every) Odd/Even/Every)
40
42
44
46
New Year's Day

Martin Luther King Day
Presidents' Day
Memorial Day
RCW26.09.016;.181;.187;.194
Page 5
*
ODD
EVEN
ODD
*
EVEN
ODD
EVEN
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
2
4
6
EVEN__________
ODD___________
EVEN__________
ODD___________
*_____________
*_____________
ODD
EVEN
ODD
EVEN
*___
*___
8
10
For purposes of this parenting plan, a holiday shall begin and

end as follows (set forth times):
12
A.
Holidays marked with an asterisk

scheduled under Paragraph 3.3 above.
B.
Holidays shall
begin at 6:00 p.m. the day before the
holiday and shall end at 7:00 p.m. the day of the
holiday, except for those holidays marked with an
asterisk, July 4th and Thanksgiving.
C.
The July 4th holiday shall begin on July 4th at 9:00 a.m.
and shall end on July 5th at 12:00 Noon.
D.
The Thanksgiving holiday shall begin at 6:00 p.m. on the

Wednesday immediately before Thanksgiving Day, and shall
end the immediately following Sunday at 7:00 p.m.
E.
Holidays which fall on a Friday shall include Saturday

and Sunday of the same weekend, until 7:00 p.m.
on
Sunday.
F.
Holidays which
fall on a Monday shall include
the
immediately preceding Friday, Saturday and Sunday,
beginning Friday at 6:00 p.m. and ending on Monday at
7:00p.m.
(*)
are
already
14
16
18
20
22
24
26
28
30
32
34
36
3.8
Schedule for Special Occasions
38
40
The residential schedule for the child for the following

special occasions (for example, birthdays) is as follows:
With Petitioner With Respondent
(Specify Year
(Specify Year
Odd/Even/Every) Odd/Even/Every)
42
44
46
Mother's Day__________
Father's Day__________
RCW 26.09.016;. 181;. 187;. 194
Page 6
_____________
EVERY________
EVERY
_____
Mother's Birthday
Father's Birthday
Childs Birthday
2
4
6
EVERY
ODD
EVEN
A.
Special occasions shall begin at 6:00 p.m. the day before

the occasion and shall end on the day of the occasion at
7:00 p.m.
B.
In years that the respondent is not scheduled to have the

child on the child's birthday, the respondent shall have
a period of up to four hours with the child during the
seven days immediately preceding the child's birthday,
for a birthday celebration.
8
10
EVERY
12
14
16
3.9
Priorities Under the Residential Schedule
18
[ ]
22
Does not apply because one of the parents has no

visitation or restricted visitation.
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1
and 3.2, in the following order:
24
[X]
20
[X]
Rank the order of

highest priority:
priority,
with
1 being
the
26
3
5
4
28
winter vacation (3.3)

other school break (3.4)
summer schedule (3.5)
__ vacation with parents (3.6)

2 holidays (3.7)
1 special occasions (3.8)
30
[ j
Other:
32
34
36
3.10
Restrictions
[X]
Does not apply because there are no limiting factors in

paragraphs 2.1 or 2.2.
[ ]
The [ ] petitioner's [ ] respondent's residential time

with the child shall be limited because there are
limiting factors in paragraphs 2.1 and 2.2.
The
following restrictions shall apply when the child spends
time with this parent:
38
40
42
44
46

RCW 26.09.016;. 181;. 187;.194
Page 1
[ ]
2
4
There are limiting factors in paragraph 2.2, but there

are no restrictions on the [ ] petitioner's [ ]
respondent's residential time with the child for the
following reasons:
6
8
3.11
Transportation Arrangements
10
Transportation costs are included in the Child Support
Worksheets and/or the Order of Child Support and should not be
included here.
12
14
16
Transportation arrangements for the child,

shall be as follows:
between parents
18
A,
The receiving parent shall provide transportation for the

child.
B.
When the child will be traveling by motor vehicle, the

child shall be secured at all times in safety restraints
as
provided
by
applicable
law,
and any person
transporting the child shall have a valid driver's
license and valid liability insurance.
20
22
24
26
28
3.12
Designation of Custodian
The child named in this parenting plan is scheduled to reside
the majority of the time with the [X] petitioner [ ]
respondent.
This parent is designated the custodian of the
child solely for purposes of all other state and federal
statutes which require a designation or determination of
custody. This designation shall not affect either parent's
rights and responsibilities under this parenting plan.
30
32
34
36
38
3.13
Other
40
Make-up residential time:
42
44
46
If the respondent will be late for, or will be unable to

exercise, any scheduled period of residential time with the
child, the respondent shall notify the petitioner by telephone
at least 48 hours prior to the scheduled beginning of the
RCW 26.09.016;. 181;.187;. 194
Page 8
respondent's residential time with the child. If respondent is

unable to do so, respondent shall notify the petitioner as
soon as possible after learning of the problem. If respondent
complies with this notice requirement, the respondent shall
have the right to make-up residential time with the child, as
worked out between the parents. If the respondent misses a
period of residential time with the child and did not notify
the petitioner at all beforehand, the respondent shall not
have a right to make-up residential time with the child.
2
4
6
8
10
12
3.14
Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child
14
16
18
20
22
24
26
28
30
32
34
This is a summary only. For the full text, please see RCW
26.09.430 through 26.09.480.
If the person with whom the child resides a majority of the
time plans to move, that person shall give notice to every
person entitled to court ordered time with the child.
If the move is outside the child's school district, the
relocating person must give notice by personal service or by
mail requiring a return receipt. This notice must be at least
60 days before the intended move. If the relocating person
could not have known about the move in time to give 60 days1
notice, that person must give notice within 5 days after
learning of the move. The notice must contain the information
required in RCW 26.09.440. See also form DRPSCU 07.0500
{Notice of Intended Relocation of a Child).
If the move is within the same school district, the relocating
person must provide actual notice by any reasonable means. A
person entitled to time with the child may not object to the
move but may ask for modification under RCW 26.09.260.
36
38
Notice may be delayed for 21 days if the relocating person is

entering a domestic violence shelter or is moving to avoid a
clear, immediate and unreasonable risk to health and safety.
40
42
44
46
If information is protected under a court order or the address

confidentiality program, it may be withheld from the notice.
A relocating person may ask the court to waive any notice
requirements that may put the health and safety of a person or
a child at risk.
RCW 26.09.016;. 181;.187;. 194
Page 9
Failure to give the required

sanctions, including contempt.
notice
may
be
grounds
for
4
If no objection is filed within 30 days after service of the
notice of intended relocation, the relocation will be
permitted and the proposed revised residential schedule may be
confirmed.
6
8
10
A person entitled to time with a child under a court order can

file an objection to the child's relocation whether or not he
or she received proper notice.
12
14
An objection may be filed by using the mandatory pattern form

WPF DRPSCU 07.0700, (Objection to Relocation/Petition for
Modification of Custody Decree/Parenting Plan/Residential
Schedule) . The objection must be served on all persons
entitled to time with the child.
16
18
20
The relocating person shall not move the child during the time
for objection unless: (a) the delayed notice provisions apply;
or (b) a court order allows the move.
22
If the objecting person schedules a hearing for a date within

15 days of timely service of the objection, the relocating
person shall not move the child before the hearing unless
there is a clear, immediate and unreasonable risk to the
health or safety of a person or a child.
24
26
28
30
32
IV. Decision Making
34
36
4.1
Day to Day Decisions
38
40
42
Each parent shall make decisions regarding the day-to-day care

and control of each child while the child is residing with
that parent. Regardless of the allocation of decision making
in this parenting plan, either parent may make emergency
decisions affecting the health or safety of the child.
44
46
RCW 26.09.016;.181;. 187;. 194
Page 10
4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions
[ ] petitioner
Non-emergency health care
[ ] petitioner
Religious upbringing
[ ] petitioner
Driver's license
[ ] petitioner
Marriage prior to age of
majority
[ ] petitioner
Entry into military service
(If parental permission
required)
[ ] petitioner
8
10
12
14
[X]
16
18
20
22
24
[
[
[
[
]
]
]
]
respondent
respondent
respondent
respondent
(X]
[X]
(X]
[X]
j oint
j oint
j oint
j oint
[ ]
respondent
[X]
j oint
[ ] respondent
[X]
j oint
Other: Joint decision-making means that each parent shall

have the right to fully discuss with the other parent his
or her views and wishes regarding each of the decisions
listed above, before the final decision on the matter is
made. If, after fully discussing their positions, the
parents are unable to reach a mutually agreeable
decision, then the parent who has the child the majority
of the time shall make the decision, subject to the other
parent's right to invoke the dispute-resolution process
provided for herein.
26
28
4.3
Restrictions in Decision Making
30
[X]
32
[ ]
Does not apply because there are no limiting factors in

paragraphs 2.1 and 2.2 above.
Sole decision making shall be ordered to the [ ]
petitioner [ ] respondent for the following reasons:
34
[ ]
36
38
40
[ ]
[ ]
A limitation on the other parent's decision making

authority is mandated by RCW 26.09.191
(See
paragraph 2.1).
Both parents are opposed to mutual decision making.
One parent is opposed to mutual decision making,
and such opposition is reasonably based on the
following criteria:
42
(a)
44
(b)
46
The existence of a limitation under RCW

26.09.191;
The history of participation of each parent in
decision making in each of the areas in RCW
26.09.184 (4) (a);
48
RCW 26.09.016;.181;. 187;. 194
Page 11
(c)
2
4
6
(d)
8
[ ]
10
12
Whether the parents have demonstrated ability

and desire to cooperate with one another in
decision making in each of the areas in RCW
26.09.184(4)(a); and
The parents' geographic proximity to one
another, to the extent that it affects their
ability to make timely mutual decisions.
There are limiting factors in paragraph 2.2, but there

are no restrictions on mutual decision making for the
following reasons:
14
16
V. Dispute Resolution
18
20
The purpose of this dispute resolution process is to resolve disagreements about carrying out this parenting
plan. This dispute resolution process may, and under some local court rules or the provisions of this plan
must, be used before filing a petition to modify the plan or a motion for contempt for failing to follow the plan.
22
[X]
24
26
Disputes between the parties, other than child support

disputes, shall be submitted to (list person or agency):
[ ]
[X]
28
30
32
counseling by _____________________________________ , or
mediation by
Pierce
County
Center
for
Dispute
Resolution____ , if this box is checked and issues of
domestic violence or child abuse are present, then the
court finds that the victim requested mediation, that
mediation is appropriate, and that the victim is
permitted to have a supporting person present during the
mediation proceedings, or
arbitration by ______
_______________________________.
34
[ ]
36
The cost of this process

parties as follows:
shall
be
allocated between
the
38
40
[X]
[ ]
42
[ ]
44
The counseling, mediation or arbitration process shall be

commenced by notifying the other party by [X] written request
[ ] certified mail [ 3 other:
46
50 % petitioner 50 % respondent.
based on each party's proportional share of income from
line 6 of the child support worksheets.
as determined in the dispute resolution process.

RCW 26.09.016;.181;.187;.194
Page 12
2
In the dispute resolution process:
4
(a)
6
(b)
8
10
(c)
12
(d)
14
16
(e)
18
Preference shall be given to carrying.out this Parenting

Plan.
Unless an emergency exists, the parents shall use the
designated process to resolve disputes relating to
implementation of the plan, except those related to
financial support.
A written record shall be prepared of any agreement
reached in counseling or mediation and of each
arbitration award and shall be provided to each party.
If the court finds that a parent has used or frustrated
the dispute resolution process without good reason, the
court shall award attorney's fees and financial sanctions
to the other parent.
The parties have the right of review from the dispute
resolution process to the superior court.
20
[ ]
22
No dispute
ordered.
resolution
process,
except
court
action,
is
VI. Other Provisions
24
26
[ ]
There are no other provisions.
28
[X]
There are the following other provisions:
30
6.1
Unless
otherwise
required
by
a
court
of
competent
jurisdiction, each parent shall keep the other parent informed
at all times of his or her current residence address and
current residence telephone number. If there is any change in
this information, the other parent shall be notified of the
new information not later than twenty-four (24) hours after
the change goes into effect. If a parent does not comply with
this provision, any legal notice required to be served upon
the non-complying parent by any form of mail requiring a
receipt for delivery shall be satisfied by sending said notice
to the last known residence address on the non-complying
parent.
6.2
Neither parent shall speak in a derogatory manner about the

other parent in the presence of the child, nor allow the child
or any other person in the presence of the child to do so.
32
34
36
38
40
42
44
46

RCW 26.09.016;. 181;.187;. 194
Page 13
6.3
Each parent shall have the right to reasonable telephone and

e-mail contact with the child while the child is away from
that parent, at the calling parent's expense. All telephone
calls shall be made between the hours of 5:00 p.m. {time zone
of the child's location) and 8:00 p.m. Monday through Friday
during the school week, or between 9:00 a .m. and 8:00 p.m. on
Saturdays, Sundays or days there is no school for the child.
Neither parent shall interfere with the other's exercise of
his or her right to telephone/e-mail contact with the child.
If a parent calls and is unable to speak with the child, the
parent shall leave a message if possible, and the other parent
shall ensure that the child calls back within 24 hours
thereafter, or as soon as possible after the message is left.
No one shall listen in on telephone conversations between the
child and a parent, except with the express agreement of the
calling parent.
6.4
All mail and packages sent to a child by a parent shall be

given to the child immediately upon arrival at the other
parent's residence. The parent at the child's location shall
provide any necessary assistance with opening and/or reading
the contents of the mailing container.
6.5
Neither parent shall use the child to request additional or

altered time with that parent. The Parenting Plan shall be
supported by both parents in the presence of the child.
Neither parent shall use the child as a go-between for
communication with the other parent. Neither parent shall
discuss with the child or within the child's hearing any
disagreements or pending court actions the parents may have
against each other.
6.6
Each parent shall have the right to equal access to all the
child's medical, psychological, psychiatric,
counseling,
criminal, juvenile and education records, and to any other
information relevant to the child's best interest or welfare,
including, but not limited to, any records being kept by or
maintained by the State of Washington Department of Social and
Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the
child may reside. Any third party having or maintaining any
such records is hereby authorized to release any and all
information upon presentation of a copy of this Parenting Plan
by a parent named herein, without the necessity of a court
order or a subpoena duces tecum, unless a child exercises a
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46

RCW 26.09.016;. 181;. 187;. 194
Page 14
legal right to restrict access to said information. Any

person,
including but not limited to, any physician,
psychologist, counselor, or educator may speak candidly of or
concerning the child named herein to either of the above-named
parents without court order or subpoena authorizing the same,
upon presentation of a copy of this order, unless such
disclosure is prohibited by a child's exercise of statutory
rights.
2
4
6
8
10
6.7
The child's school shall be kept informed of both parents'

addresses and home and work telephone numbers, and the school
shall be requested to send information to both parents for
such events as either parent requests.
6.8
Each parent shall have equal and independent authority to

confer with school, day care and other programs with regard to
the child's progress, and each shall have free access to
school, day care and other records. Each.parent shall have
authority to give parental consent or permission as may be
required concerning school, day care or other programs for the
child while the child is in his or her care.
6.9

obtain information regarding the well-being of the child,
including, but not limited to, copies of report cards, school
meeting notices, vacation schedules, class programs, requests
for conferences, results of standardized or diagnostic tests,
notices of activities involving the child, samples of school
work, order forms for school pictures, and all communications
from all schools, regular day care providers, and counselors.
Each parent shall notify the other, as soon as that
information becomes known to the parent, of any parent teacher
conference to be conducted regarding the child, and the other
parent shall have the right to attend any such conference,
notwithstanding the existence of any restraining order
prohibiting one parent from being in the presence of the
other.
6.10

arrange routine medical, optical, and dental services for the
child, after coordinating with the other parent, while the
child is in his or her care and residence. The parent
scheduling any such services shall provide the other parent
with the name, address and office telephone number of said
care provider.
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46

RCW 26.09.016;. 181;. 187;. 194
Page 15
in
PJ
()
6.11
If a parent obtains emergency health care for a child, the

parent shall notify the other parent as soon as possible of
the fact that such care has been obtained, the nature of the
illness or injury to the child that necessitated the
treatment, and contact information for reaching the care
provider.
6.12
Each parent has the duty to respect the parenting style and
authority of the other parent, and neither parent shall
attempt to undermine the authority of the other parent with
the child. Neither parent will make plans or arrangements
involving the child which would impinge upon the other
parent's authority or time with the child, without express
agreement of the other parent. If a child has a grievance with
a parent, the other parent must encourage said child to
discuss any such grievance directly with the parent in
question.
6.13
The parties may make minor adjustments, as necessary, to the

provisions of this Parenting Plan by agreement. As a
precondition to agreeing to any such adjustment, either parent
may require that any such agreement be in writing, dated and
signed by both parents. Provided, however, that in order to
change or modify the designation of the parent who is to have
primary residential placement of the child, a petition to
modify the Parenting Plan or other similar procedure under
applicable state law must be filed.
4
6
yjf
8
(j
f\l
. 4"-J
-.j
10
12
14
16
N
18
Lf'!
CO 20
22
24
26
28
30
VII. Declaration for Proposed Parenting Plan

32
34
36
38
[ ]
[X]
Does not apply.

(Only sign if this is a proposed parenting plan.)
under penalty of perjury under the laws of the
Washington that this plan has been proposed in good
that the statements in Part II of this Plan are
correct.
I declare
State of
faith and
true and
40
42

Petitioner - (Pro Se)
Date and Place of Signature
Beth Ann Kalii

Respondent
44
46

RCW 26.09.016;. 181187;. 194
Page 16
^ IVi
l\ C 'd
9f i l l
? k'rterk
'^ - D eputy
i"j 10
,J
12

County of Pierce
-t 14
No-
Return of Service
(Optional Use)
(RTS)
16
N
ifi 18
c0
20
22
Petitioner,
and
14 3 01646 7
Beth Ann Kalii

Respondent.
24
I Declare:
26
1.
I am over the age of 18 years, and I am not a party to this action.
2.
I served the following documents to Beth Ann Kalii:
28
30
32
34
36
[X]
[X]
[X]
[ ]
[X]
[X]
[X]
38
40
42
44
46
48
[X]
[X]
[ ]
[ ]
[ ]
[ ]
[ ]
[ J
[X]
summons, a copy of which is attached

petition in this action
proposed parenting plan or residential schedule
declaration in support of parenting plan
proposed child support order
proposed child support worksheet
sealed financial source documents cover sheet and financial
documents
financial declaration
Notice Re: Dependent of a Person in Military Service
notice of hearing for _____________________________________
motion for temporary order
motion for and ex parte order
motion for and order to show cause re: _______________________
declarations of ____________________________________________
temporary order
other: Pro se Notice of Appearance, -Or dor A d signing Ga'S'e. -to
1 nnp^-rf-Tnnni-,r and (blank) Joinder
Return of Service (RTS)

WPF DRPSCU 01.0250 (7/2013)
CR 4(g); RCW 4.28.080(15)
Page 1
3.
The date, time and place of service were

Paragraph 4 below):
Time :
Date:
(if by mail refer to
a .m
Address:
/0 S /V -
10
f iv e
S '.
, W A
12
J.
14
Service was made:

[X]
[]
16
18
[]
20
[]
22
24
26
[]
28
30
by delivery to the person named in paragraph 2 above,

by delivery to (name)
_____ _________
person of suitable age and discretion residing at the
respondent's usual abode.
by publication as provided in RCW 4.28.100. (File Affidavit of
Publication separately.)
(check this box only if there is a court order authorizing
service by mail) by mailing two copies postage prepaid to the
person named in the order entered by the court on (date)
________________ _. One copy was mailed by ordinary first class
mail, the other copy was sent by certified mail return receipt
requested.
(Tape return receipt below.)
The copies were
mailed on (date) ___________________ .
(check this box only if there is a statute authorizing service
by mai l ) by mailing a copy postage prepaid to the person
requiring service by any form of mail requiring return
receipt. (Tape return receipt below.) The copy was mailed on
(date)
32
34
5.
36
Service of Notice on Dependent of a Person in Military Service.

[X]
The Notice to Dependent of .Person in Military Service was [X]
served
on
[
]
mailed
by
first
class
mai'l
on
(date)
38
[]
Other:
40
42
6.
44
I declare under penalty of perjury under the laws

Other: Does not apply.

of
the
State
46
on
Si gned at
48
50
'
{Date
{City, prate)
-^ v y o
^.Signature
52
WPF DRPSCU 01.0250 (7/2013)
CR 4(g); RCW 4.28.080(15)
Page 2
Print or Type Name v
of
2
4
Fees:
Service
Mileage
T o tal
8
10
(Attach R e t u r n R e c e i p t here,
12
File the origi n a l R e t u r n of Service with the clerk. Provide a copy to the
law e n f o r c e m e n t a g e n c y w h e r e p r o t e c t e d p e r s o n r e s i d e s if the d o c u m e n t s
s e r v e d i n c l u d e a r e s t r a i n i n g o r d e r s i g n e d b y the court.
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52

WPF DRPSCU 01.0250 (7/2013)
CR 4(g); RCW 4.28.080(15)
Page 3
if s e r v i c e was b y m a i l .)
2
4
6
8
10
12

County of Pierce
14
No.

16
Petitioner,
18
Summons
(SM)
and
20
Beth Ann Kalii
Respondent.
22
24
To the Respondent: Beth Ann Kalii
26
1.
28
The petitioner
requesting:
[X]
[ ]
[ ]
[ ]
[ ]
30
32
34
has
started an action
in the
above
court
that your marriage be dissolved.

that your domestic partnership be dissolved.
a legal separation.
that the validity of your marriage be determined.
that the validity of your domestic partnership
determined.
be
36
Additional requests, if any, are stated in the petition,
copy of which is attached to this summons.
38
40
42
44
2.
You must respond to this summons and petition by serving a

copy of your written response on the person signing this
summons and- by filing the original with the clerk of the
court. If you do not serve your written response within 20
days (or 60 days if you are served outside of the State of
Washington) after the date this summons was served on you,
Summons (SM)
CR 4.1
Page 1
#r
exclusive of the day of service, the court may enter an order

of default against you, and the court may, without further
notice to you, enter a decree and approve or provide for the
relief requested in the petition.
In the case of a
dissolution, the court will not enter the final decree until
at least 90 days after filing and service. If you serve a
notice of appearance on the undersigned person, you are
entitled to notice before an order of default or a decree may
be entered.
4
6
8
10
12
3.
14
Your written response to the summons and petition must be on

form:
[X]
[ ]
16
18
WPF DR 01.0300, Response to Petition (Marriage).

WPF DR 01.0305, Response to Petition (Registered
Domestic Partnership).
20
4.
22
24
This form may be obtained by contacting the clerk of court at

the address below, by contacting the Adminstrative Office of
the Courts at (360) 705-5328, or from the Internet at the
Washington State Courts homepage:
http://www.courts.w a .gov/forms
26
28
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 the person signing this summons. Within 14 days after you
serve the demand, the petitioner must file this action with
the court, or the service on you of this summons and petition
will be void.
6.
If you wish to seek the advice of an attorney in this matter,

you should do so promptly so that your written response, if
any, may be served on time.
If you wish to seek the advice
of an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on time.
7.
One method of serving a copy of your response on the

petitioner is to send it by certified mail with return receipt
requested.
30
32
34
36
38
40
42
44
46
Summons (SM)
CR 4.1
Page 2
mt-
This summons is issued pursuant to RCSL-4; 28.100 and Superior

Civil Rule 4.1 of the state of WasKingto
Dated:
rfe of Petitioner (
or Lawyer/WSBA No.

Print or Type Name
10
12
1.4
File original of your response

with the clerk of the court at:
[X] Petitioner [You may list an

address
that
is
not
your
residential address where you
agree to accept legal documents.
Any time this address changes
while this action is pending, you
must notify the opposing parties
in writing and file an updated
Confidential
Information
Form
(WPF DRPSCU 09.200) with the
court clerk.]
[ ] Petitioner's Lawyer
16
18
20
22
24
26
28
30
32
Serve a copy of your response on:

Clerk of Court______________
County-City Building________
930 Tacoma Avenue S., Room 110
Tacoma, WA 98402____________
34
36
38
40
42
44
46
Summons (SM)
CR 4.1
Page 3
John Alika Kalii, Jr,___________

9711 Winona Street SW__________
Lakewood, Washington 98498_____
a .m .
14-3-01646-7
42419704
DCLRM
Ap r
22
2014
p .m .
04-2 4 -H
vnn
STO
CKK, C
Wounty
T O
N
o IU C
Cleric
--- ---- <7 DEPUTY
lt
AJ
SUPERIOR COURT OF WASHINGTON COUNTY OF PIERCE

In re:
0 3 ^ 7 Ai
A L IK A
A L~U
NO
Petitioner(s),
DECLARATION OF MAILING
1 4 3 01 646 7
and
LiJ
fe n f
M W
Respondent(s).
1.
I am 18 years or older and competent to testify. I am not a party to this

action.
2.
I deposited in the United States Mail on
a true copy of the
)&>}-
following documents:
n h y > i -lA n ^
KlA
V t Z P A r e jT M . e h J 'T
/QA>fZ
___________________
to g g f t f K A L I lby mailing the same to him / her by regular first class mail
postage prepaid to the following address:
Cd \ 2_~Z
L llS T -tL 517
The copies were mailed on
/ i/U
^ 4 -
LA kLEkJ& cP \}JA f r f t f
V / 2 - Z - / 2 - 0 1A - _____________ .
I d eclare under penalty o f perjury under the laws of the State o f W ashington that the
fo reg o in g is true and correct.
Signed at
Declaration of Mailing
E-FILED
May 13 2014 11:25 AM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

JOHN ALIKA KALII JR

Petitioner(s),
vs.
NO. 14-3-01646-7
NOTICE OF APPEARANCE
BETH ANN KALII

_______________ Respondent(s)
TO: Clerk of the Court
AND TO: JOHN ALIKA JR KALII, KAENA MAKANI KALII
PLEASE TAKE NOTICE that Daniel N Cook, appears herein on behalf of the
Respondent(s) BETH ANN KALII and requests that all further pleadings and paper, except
original process, be served upon said attorney at the address listed below.
DATED: May 13, 2014
ntaprsup-0001.pdf
/s/ Daniel N Cook

Daniel N Cook, #34866
Attorney for Respondent(s)
Faubion, Reeder, Fraley and Cook, PS

5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
(253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G
May 13 2014 2:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
No. 14-3-01646-7
12
JOHN ALIKA KALII, JR.

Petitioner,
13
and
Response to Petition
(Marriage)
(RSP)
14
BETH ANN KALII,
15
16
Respondent.
To the Above-Named Petitioner: JOHN KALII
17
18
I. Response
1.1
Admissions and Denials
19
20
The allegations of the petition in this matter are adm itted or denied as follows
(check only one for each paragraph):
21
Paragraph of the Petition
22
1.1
Admitted
23
1.2
Admitted
24
1.3
Admitted
1.4
Admitted
1.5
Admitted
25
Response to Petition (RSP) - Page 1 o f 3
WPF DR 01.0300 Mandatory (12/2012) - RCW 26.09.0300

Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Response to Petition.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
Lakew ood, W A 98499
253-581-0660
1
2
3
4
1.6
Admitted in part; Denied in part.
1.7
Admitted.
1.8
Denied.
1.9
Denied.
1.10
Denied.
1.11
Admitted.
1.12
Admitted.
1.13
Admitted.
1.14
Admitted.
1.15
Admitted in part; Denied in part.
1.16
N/A
7
8
9
10
Each allegation of the petition that is denied, is denied for the following reasons (List
separately):
11
1.6
Admitted this is the date the parties moved into separate residences.
Denied that the parties have divided their assets and liabilities.
1.8
Denied. The division of the parties property should be determined by the

court at a later date.
1.9
Denied.
The division of the parties debts and liabilities should be
determined by the court at a later date.
1.10
Denied. The husband has historically made much more than the wife and
spousal maintenance would be warranted; however, it remains to be seen
what if any spousal maintenance is warranted based upon the employment
of both parties and the final division of debts and assets at the time of trial.
1.15
Respondent admits an order of child support and a parenting plan for the
parties child should be entered. Respondent denies that Petitioners
proposed parenting plan should be entered or that it is in the best interest
of the child. Respondents proposed parenting plan which will be filed later,
and she requests this be the parenting plan entered for the parties child.
12
13
14
15
16
17
18
19
20
21
22
1.2
23
Notice of all further proceedings in this matter should be sent to the address
below.
24
25
Notice of Further Proceedings
1.3
Other
Response to Petition (RSP) - Page 2 o f 3

S:\CASES1\Kalii\DRAFTS\Pleadings\Response to Petition.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
Lakewood, W A 98499
253-581-0660
1
2
II. Request for Relief
3
The respondent requests the court to grant the relief requested below.
Enter a decree.
5
6
Dispose of property and liabilities.
Provide reasonable maintenance for the respondent.
Approve Respondents parenting plan for the dependent children.
Determine support for the dependent children pursuant to the Washington

State Child Support Schedule.
10
Order payment of day care expenses for the child.

Award the tax exemptions for the dependent children as follows:
11
12
Order payment of attorney fees, other professional fees and costs.
13
14
Dated
15
16
By Daniel N. Cook, WSBA 34866

Of Attorneys for Respondent
17
18
19
20
21
22
23
24
25
Response to Petition (RSP) - P age 3 o f 3

S:\CASES1\Kalii\DRAFTS\Pleadings\Response to Petition by D N C .docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S treet SW , Ste 25
253-581-0660
E-FILED
May 13 2014 2:54 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
Case number:.
I M - 3 P l l . ^ ' 7 _________
Case names: c \ c h n /~^Li

Petitioner
K ^ / /1
& & / '/ )
/ b O lO
Respondent
To All Those To Whom This Letter May Come
The Institute for Childrens A dvocacy

Is pleased to announce that:
B e ^ Y i K a li i
Has successfully completed a Four Hour seminar
Dont Forget the Kids

And, having such distinction and perspicacity in regard to the course, is
hereby granted this
Certificate of Completion
Dated this 12th day of May, 2014
In the City of Lakewood, State of Washington
Instructors:
Susan (DeRome, M.fccC
John jiCCen Hires, SvtS'W
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, W ASHING Ti
May 13 2014 2:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9

COUNTY OF PIERCE
No. 14-3-01646-7
10
JOHN A. KALII,
Petitioner,
11
and
12
BETH A. KALII,
Motion/Declaration for Temporary

Order
(MTAF)
Respondent.
13
I. Motion
14
15
Based on the declaration below, the undersigned moves the court for a temporary order
which:
16
17
18
19
20
Requires the Husband to pay the Wife $730 per month representing the cost of his
health care insurance.
Requires the Husband to pay the Wife $175 per month representing 76% of the
cost of the childs health care insurance.
Requires the Husband to pay the Wife $150 per month representing 3.5% of his
pension income.
21
Authorizes the wife to have temporary use and possession of the property.
22
Requires the Husband to pay $1,500 in attorneys fees and costs to the wife.
23
DATED this
24
Li day of May 2014.
FAUBIQhLREEDER. FRALEY & COOK, P.S.
i ____
DamSt-NrCool?, WSBA 3466W
Attorney for Petitioner
Motion for Temporary Order - Page 1 of 5
Kalii, Beth and Kalii, John
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW , S uite 25
253-581-0660
II. Declaration
2
3
4
Temporary relief is required because:
BACKGROUND
I,
BETH KALII, am the Respondent in this action. JOHN KALII is the Petitioner.
JOHN and I have been together off and on for approximately 9 years. We had a child,
KA-ENA KALII, together 8 years ago (this month). JOHN and I were formally married in
November 2009. JOHN and I separated on March 30, 2014.
9
10
11
12
I work for Clover Park School District as a bus driver.

month.
I earn $2,667 gross per
After all of my deductions my net income is only $1,290 per month.
I work
Monday through Friday for beginning at 6:30 a.m. and ending at 6:30 p.m. But there is a
great deal of off time interspersed between those hours while I am not driving a school
13
bus. I am off on all Holidays. I will work half days for one month out of this upcoming
14
15
16
17
18
19
20
21
22
23
24
Summer. I will be off work all but two days of August 2014.
JOHN worked for the City of Tacoma Fire Department for most of our relationship.
He retired a year or two ago. His gross income is now $4,352 per month and his net is
(according to his calculations) $4,048.
Our daughter spends half of the time in JOHNS residence and half of the time in mine.
CONTRIBUTION TO MEDICAL INSURANCE

After JOHN retired he looked into healthcare insurance options.
He told me he
could not get private coverage because of a pre-existing condition. I was skeptical of this
claim, but at JOHNS request I enrolled him on my insurance through my employer, the
Clover Park School District. JOHNS coverage took effect November 2013 which was the
most recent open enrollment period.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
253-581-0660
1
I have covered our daughter KA-ENA on my medical insurance from her birth. At
2
one point while JOHN was still working for the City of Tacoma, I was not getting enough
3
hours to pay for and cover KA-ENA through my employment with Clover Park. So JOHN
4
5
covered her for the last year of his work with the City of Tacoma. But when he retired I
was working and making enough to cover her again and so she was back on my health
care insurance benefits.
The cost of healthcare insurance through my company is $1,771 per month. This
includes me, JOHN and KA-ENA.
10
Clover Park or a Trust fund set-up by the Union, pays 100% of my health care insurance.
11
12
The Union system is complicated, but essentially
You can see on my paystub that the employer paid portion in April 2014 was $882.45.
The amount may vary each month depending upon availability of funds in the Trust, but it
13
always equals out to 95%-100% of my cost.
On my April 2104 paystub it reflects a cost
14
of $887.58 per month that the Employee (me) paid but this amount varies from month to
15
month based upon how much is available in the Trust.

16
17
18
19
20
21
22
23
24
I have also filed a sealed financial source document which is my medical options
pamphlet from Human Resources at my company.
It shows the cost for me and child is $1,046. It shows that the cost for me only is
$812.45.
Hence, the cost of KA-ENAs insurance is $233.55 per month.
It shows the cost for me and JOHN is $1,543 per month. It shows that the cost for
me only is $812.45. Hence, the cost of JOHNS insurance is $730.86.
So the total cost of JOHN and KA-ENAs insurance combined would be $964.41
per month; however, when I cover them together as a Spouse and Child there is a slight
(about $6) savings each month.
The document shows that the total cost for me, JOHN

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , S uite 25
253-581-0660
1
and KA-ENA is $1,771 per month. The cost for me only is $812.45 per month. Hence,
2
when I am covering both spouse and child the cost for JOHN and KA-ENA together is
3
$958.55 per month. JOHNS is about $730 per month and KA-ENAs is about $230.
4
I am asking JOHN to pay 100% of his medical insurance of $730 per month.
Now
that I have put him on my insurance at his request, I am left with net income of only about
$1,290 per month. This is not enough to live on or get my own apartment or anything. I
absolutely cannot afford to live and pay my bills without JOHN paying his share of the
healthcare insurance. If he would prefer to forgo healthcare insurance that is his option,
10
11
12
or if he can get it cheaper somewhere else, that is fine; however, I cannot even cancel
him until the next open enrollment period in November 2014 so he must contribute at
least $730 a month until November 2014.
13
As to KA-ENA, whose insurance expense is $230 per month, I am asking him to

14
pay $175 per month which is 76% of the $230. Because he makes $4,048 net income
15
and I make $1,290 per month me makes 76% of our combined income.
16
17
18
In total I am asking JOHN to pay $905 per month toward the healthcare insurance.
PENSION
19
JOHN worked for the City of Tacoma a total of 33 years before he retired. JOHN
20
and I have been together 9 years (our daughter is 8 years old). He was employed with
21
the City of Tacoma for 7 of those years. Presumptively 7% would be community and I
22
would get 3.5%. JOHNS gross income from his pension is $4,300 per month so I am
23
24
asking the court to order him to pay $150 per month to me as a distribution of property
(pension). It can be characterized as spousal maintenance if necessary, on a temporary
basis, to shift the tax burden appropriately.
M o tio n f o r T e m p o r a r y O r d e r - P a g e 4 o f 5

F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
5920 100th S tre et SW , Suite 25

253-581-0660
1
PERSONAL PROPERTY
2
When I left the family home I took my clothing and a few personal items and my
3
car. I do not have any furnishings to set up a new apartment for my daughter and me. I
4
5
have done my best so far but I simply cannot go out and replace everything that we need
on $1,290 per month. I am asking the court to give me temporary use and possession of
the following items from the family home:
8
9
10
11
12
1.
2.
3.
4.
5.
6.
KA-ENAs bed and dresser

Wifes trunk
Wifes wardrobe
King size bed
Outdoor furniture
All of the kitchen utensils out of the camper trailer
ATTORNEY FEES
13
My attorney requested a retainer of $2,500. I paid $1,000 down. I am obligated to
14
pay the other $1,500 within 60 days. I frankly do not have that money and cannot come
15
up with it while simultaneously paying $730 for JOHNS health care insurance and while
16
having to come up with first and last months rent and security deposit on an apartment. I
17
18
need help with attorneys fees so that I can move forward in this transition.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
19
STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
20
Signed at (city)
(state)
21
22
BETH KALII, RESPONDENT
23
24

F R A L E Y & C O O K , P .S .

253-581-0660
E-FILED
PIERCE COUNTY, W ASHING T
May 13 2014 2:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner
12
and
13
BETH A. KALII,
Parenting Plan
Proposed (PPP)
Respondent.
14
15
This parenting plan is proposed by the Respondent, BETH A. KALII.
16

17
18
19
20
Name
Age
KAENA KALII
21
II. Basis for Restrictions
22
23
24
Under certain circumstances, as outlined below, the court may limit or prohibit a
parents contact with the child and the right to make decisions for the child.
2.1
Parental Conduct (RCW 26.09.191 (1), (2))

Does not apply.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 1 o f 1 0
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181;. 187;. 194

S:\CASES1\Kalii\DRAFTS\Pleadings\Proposed Parenting Plan.doc

253-581-0660
1
2.2
2
Does not apply.
3
4
5
6
7

The residential schedule must set forth where the child shall reside each day o f the
year, including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the child shall have with each parent. Parents
are encouraged to create a residential schedule that m eets the developmental needs of
the child and individual needs o f their family. Paragraphs 3.1 through 3.9 are one way
to write your residential schedule. If you do not use these paragraphs, write in your own
schedule in Paragraph 3.13.
8
3.1
10
11
3.2
School Schedule
Upon enrollment in school, the child shall reside equally with both parents on the
following schedule:
12
13
The child shall reside with the parents on a rotating and repeating
alternating week on/week off schedule. Exchanges from one home to the
other will be on Mondays after school or at 5:00 p.m. if there is no school.
14
15
3.3
16
17
18
The child shall reside with each parent during winter vacation as follows:
Winter Vacation shall be defined as commencing the day after school lets out for
the Winter Vacation Break and concluding on the day before school resumes.
19
In even numbered years, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. until December 27th at 8:00 p.m. In
even numbered years the father shall have the child from
December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
20
21
22
23
In odd numbered years, the father shall have the child for the first
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. The mother shall have the child from December 27th 8:00
p.m. through the day before school resumes at 6:00 p.m.
24
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 2 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187;. 194


253-581-0660
1
3.4
2
The child shall reside with each parent during spring break as follows:
3
The first half of Spring Break shall be with the parent who has the child the
prior week under the alternating week schedule (Par. 3.2); the second half
of Spring Break shall be with the parent who has the child the week after
Spring Break under the alternating week schedule (Par. 3.2). The
exchange shall be on Wednesday at 12:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
Upon completion of the school year the child shall reside with each parent as follows:
9
10
11
3.6

Same as School Year Schedule, and in addition: each parent shall have two
weeks uninterrupted with the child for vacation during the summer months when
the child are off from school.
12
13
Each parent shall notify the other parent in writing of his or her two weeks
of vacation no later than May 1 of each year. If there is a conflict in
vacation dates the fathers choice will control in odd years and the
mothers choice will control in even years.
14
15
16
17
18
19
20
21
22
23
24
3.7
Schedule for Holidays

The residential schedule for the child for the holidays listed below is as follows:
With Mother
With Father
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
New Years Day
See Par. 3.3
See Par. 3.3
Presidents Day
Memorial Day
Easter
Odd
Even
July 4th
Even
Odd
Labor Day
Veterans Day
Odd
Even
Thanksgiving Day
Even
Odd
Christmas Eve
See Par. 3.3
See Par. 3.3
Christmas Day
See Par. 3.3
See Par. 3.3


253-581-0660
1
2
Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
4
5
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
3.8
The residential schedule for the child for the following special occasions (for
example, birthdays) is as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
14
15
If the Special Occasion is on a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day of the Special
Occasion.
16
17
18
19
20
21
22
23
24
3.9

Paragraphs 3.31 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
Rank the order of priority, with 1 being given the highest priority:
2
4
school breaks (3.4)
holidays (3.7)
1
special occasions (3.8)
6
vacation with parents (3.6)
3
5
Restrictions
Does not apply.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,

.181; .187;. 194

253-581-0660
1
3.11
2
3
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
Transportation arrangements for the child, between parents shall be as follows:

Transportation shall be shared equally with the receiving parent picking
up, or arranging a responsible third party to pick up, the child at the start of
his or her residential time from school or afterschool care or the residence
of the other party if the exchange is not on a school day or during after
school care hours.
6
7
3.12
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are designated the custodian of the
child solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
10
11
12
3.13
Other
13
Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
14
15
16
17
18
19
20
3.14
21
This is a summary only. For the full text, please see RCW 26.09.430 through
26.09.480.
22
If the person with whom the child resides a majority of the time plans to move,
that person shall give notice to every person entitled to court ordered time with
the child.
23
24
If the move is outside the childs school district, the relocating person must give
notice by personal service or by mail requiring a return receipt. This notice must
be at least 60 days before the intended move. If the relocating person could not
have known about the move in time to give 60 days notice, that person must
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187; .194

5920 100th S treet SW, Suite 25

253-581-0660
1
give notice within 5 days after learning of the move. The notice must contain the
information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
2
3
If the move is within the same school district, the relocating person must provide
actual notice by any reasonable means. A person entitled to time with the child
may not object to the move but may ask for modification under RCW 26.09.260.
4
5
Notice may be delayed for 21 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk
to health and safety.
6
7
If information is protected under a court order or the address confidentiality

program, it may be withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may
put the health and safety of a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including
contempt.
10
11
If no objection is filed within 30 days after service of the notice of intended

relocation, the relocation will be permitted and the proposed revised residential
schedule may be confirmed.
12
13
A person entitled to time with a child under a court order can file an objection to
the childs relocation whether or not he or she received proper notice.
14
An objection may be filed by using the mandatory pattern form WPF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody
Decree/Parenting Plan/Residential Schedule). The objection must be served on
all persons entitled to time with the child.
15
16
The relocating person shall not move the child during the time for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.
17
18
If the objecting person schedules a hearing for a date within 15 days of timely
service of the objection, the relocating person shall not move the child before the
hearing unless there is a clear, immediate and unreasonable risk to the health or
safety of a person or a child.
19
20
21
IV. Decision Making

22
23
24
4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the allocation
of decision making in this parenting plan, either parent may make emergency


253-581-0660
1
4.2
Major Decisions
2
3
Education decisions
Non-emergency medical and mental health care
4
5
Regarding medical decisions, either parent may take the child for regularly
scheduled appointments with their ordinary physicians, dentists or medical
care providers for check-ups, vaccinations, routine/recurring doctor or
dental appointments or for treatment of mild or seasonal type illnesses
(e.g., cold, flu, allergy, earaches, anti-biotic, shortterm prescriptions etc.)
without triggering joint decision-making requirements. The parties shall
communicate as much as possible about even these routine medical and
dental decisions to ensure coordination of care and full advice to the
medical professionals caring for the child.
6
7
8
9
10
11
Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
12
13
14
15
16
17
18
joint
joint
joint
4.3

Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2.
19
20
21
22
23
24
The purpose o f this dispute resolution process is to resolve disagreements about

carrying out this parenting plan. This dispute resolution process may, and under som e
local court rules or the provisions of this plan must be used before filing a petition to
modify the plan or a motion for contempt for failing to follow the plan.
Disputes between the parties, other than child support disputes, shall be
submitted to (list person or agency):
Mediation by Pierce County Center for Dispute Resolution, if this box is
checked and issues of domestic violence or child abuse are present, then
the court finds that the victim requested mediation, that mediation is


253-581-0660
1
2
3
4
5
appropriate and that the victim is permitted to have a supporting person

present during the mediation proceedings, or
The cost of this process shall be allocated between the parties as follows:
50% petitioner 50% respondent.
The dispute resolution process shall be commenced by notifying the other party
by written request via certified mail:
6
7
8
9
10
11
12
13

(a)
Preference shall be given to carrying out this Parenting Plan.
(b)
Unless an emergency exists, the parents shall use the designated process
to resolve disputes relating to implementation of the plan, except those
related to financial support.
(c)
A written record shall be prepared of any agreement reached in
counseling or mediation and of each arbitration award and shall be
provided to each party.
(d)
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and
financial sanctions to the other parent.
(e)
The parties have the right of review from the dispute resolution process to
the superior court.
14
15
16
17
18
19
20
21
22
23
24

Each party shall have the right to equal access to all of the childs medical,
psychological, psychiatric, counseling, criminal, juvenile, and educational records,
and to any other information relevant to the childs best interest or welfare. These
may include, but not be limited to, any records being kept or maintained by a
State or Federal government department or agency. Any third party having or
maintaining any such records is hereby authorized to release any and all
information upon presentation of this order. Any person, including, but not limited
to, any physician, psychologist, counselor, officer or educator, may speak candidly
of or concerning the child named herein to either of the above named parents
without court order or subpoena authorizing same, upon presentation of this
order. It shall be the responsibility of the parent requesting the records to do so
directly with the source of the records.
Both parties shall allow the child to freely communicate with the other party,
including allowing the child to call the other party on the telephone. Both parties
shall have telephone access with the child, excluding the childs calls to that
party, of not less than two calls per week at reasonable times and for reasonable
durations.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181; .187;. 194

S:\CASES1\Kalii\DRAFTS\Pleadings\ProposedParentingPlan.doc

Lakew ood W A 98499
253-581-0660
1
2
To the greatest extent possible, the parents shall communicate with each other
by e-mail. Each parent shall maintain an e-mail account for this purpose and
keep the other party informed of their e-mail address.
3
4
5
Neither party shall discuss the residential schedule with the child except for plans
that have already been agreed to by both parties. Neither party shall provide
information to the child of the status of child support payments or other legal
matters regarding the parties.
6
7
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
10
11
12

(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury
under the laws of the state of Washington that this plan has been proposed in
good faith and that the statements in Part II of this Plan are true and correct.
13
14
Beth Kalii, Petitioner
15
VIII. Order by the Court

16
17
18
19
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
WARNING: Violation of residential provisions of this order with actual knowledge of its
terms is punishable by contempt of court and may be a criminal offense under RCW
9A.40.060(2) or 9A.40.070(2). Violation of this order may subject a violator to arrest.
20
21
When mutual decision making is designated but cannot be achieved, the parties shall
make a good faith effort to resolve the issue through the dispute resolution process.
22
23
If a parent fails to comply with a provision of this plan, the other parents obligations
under the plan are not affected.
24
Dated:______________________________ _
____________________
Judge/Commissioner

S:\C/\SES1 \Kalii\DRAFTS\Pleadings\Proposed Parenting Plan,doc
5920 100th S tre et SW, S uite 25

253-581-0660
1
2
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
Approved and agreed by:

Notice of presentation waived.
Daniel N. Cook, WSBA #34866

_______________ , W SB A #
Attorney for Respondent

A signature below is actual notice of this order.

John Kalii, Respondent
3
4
5
6
7
Date
Date
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Parenting Plan (PPP, PPT, PP) - Page 10 of 10

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181; .187; .194
FAUBION, REEDER,
FRALEY & COOK, P.S.
253-581-0660
E-FILED
May 13 2014 2:54 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON

JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
TO T H E C L E R K O F T H E S U P E R IO R C O U R T A N D TO :
Name: JOHN ALIKA JR KALII

Address: 9711 WINONA ST SW LAKEWOOD, WA 98498
Phone:
Petitioner
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
P ie rc e C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B u ild in g - 930 T a c o m a A v e S - T a c o m a , W A 98402
Motion - Tem porary O rder

Calendar: Show Cause/Family Law
CALENDAR DATE: Wednesday, June 11 , 2014
9:00 AM
W O R K IN G C O P IE S S H A L L BE S U B M IT T E D T O C O M M IS S IO N E R S S E R V IC E S R O O M 140,
B E F O R E 1 2:00 N O O N T W O C O U R T D A Y S P R IO R T O H E A R IN G
DATED:
M ay 13, 2014.
S ig n e d :
/s / D aniel N C ook
NAM E:
D aniel N C ook
Phone:
(253) 581-0660
A D D R E S S : 5920 100th S t S W Ste 25
W SBA#:
34866
F o r:
A tto rn e y fo r R esp o nd e n t
LA K E W O O D , W A 98499-2751
Note for Commissioners Calendar (ntc.rptdesign)
1 of 1
E-FILED
PIERCE COUNTY, WASHING'
May 13 2014 3:31 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

IN AND FOR THE COUNTY OF KING
10
11
12
13
No. 14-3-01646-7
Petitioner,
and
BETH ANN KALII,

Respondent.
14
15
I,
Sally DuCharme, am over the age of 18, and competent to testify in the
above entitled case.
16
17
18
19
20
21
On May 13, 2014, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
1.
2.
3.
4.
5.
6.
7.
Notice of Appearance;
Response to Petition;
Proposed Parenting Plan;
Motion for Temporary Order;
Sealed Financial Source Documents;
Respondents Parenting Class Certificate; and
Note for Commissioners Calendar on June 11, 2014.
22
Said documents were addressed to:
23
24
John Kalii
9711 Winona ST SW
Lakewood WA 98498
25
Declaration Of Mailing
S :\C A S E S 1 \K a lii\D R A F T S \P le a d in g s \D e c la ra tio n o f M a ilin g .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
Phone: (253) 581-0660
1
2
3
I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
DATED
May 13, 2014

A ^
______ _
-"âlly DuGmarme, Legal Assistant
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
D e c la r a tio n O f M a ilin g

S:\CASES1\Kalii\DRAFTS\Pleadings\Declaration of Mailing.doc

Lakewood, W A 98499
Phone: (253) 581-0660
CO
O
02
4
6
8
OLO
in
O
<42

County of PierceI.
14
No-
OIL 8

ii
r20
r
\
Petitioner,
and
Motion and Declaration

For Default
(MTDFL)
if 2 2
Beth Ann Kalii

24
Respondent.
26
28
I. Motion
30
32
34
36
(Name of requesting party) John Alika Kalii, Jr. moves the court
for an order of default against (name of other party being
defaulted) Beth Ann Kalii. Venue of this action is proper as set
forth in the Declaration below.
38
40
Dated:
3 3 , / 3 . 2 - 0 / /
Signature of Requesting Party

or Lawyer/WSBA No.
42
44

Print or Type Name
46
Mtn/Decl for Default (MTDFL)
WPF DRPSCU 03.0100 Mandatory (6/2012)
CR 55(a); RCW 26.09.030
Page 1
5 2
p
4
tl. Declaration
6
2.1
Proper Jurisdiction and Venue

The court has proper jurisdiction and venue pursuant to the
allegations of the petition at the time of filing.
P10
in
12
The petitioner resides in Pierce County, Washington.

The child(ren) reside(s) in Pierce County, Washington.
The respondent resides in Pierce County, Washington.
14
P 16
f
_f
018
[ ]
Other:
i\\
\20
nj
2.2
Jurisdiction Over the Other Party
^22
if )
This court has jurisdiction over the other party because:

24
26
[X]
[X]
28
30
[X]
32
[X]
34
[ ]
36
[X]
38
40
[X]
[ ]
42
[ ]
44
46
[ ]
the other party is currently residing in Washington.

the petitioner and respondent lived in Washington during
their marriage or domestic partnership and the petitioner
continues to reside, or be a member of the armed forces
stationed, in this state.
the petitioner and respondent may have conceived a child
while within Washington.
The other party was personally served with summons and
petition within this state.
The other party submits to jurisdiction of this state by
consent as evidenced by joinder or consents to
jurisdiction signed by respondent.
The other party engaged in sexual intercourse in the
state of Washington as a result of which the child may
have been conceived.
The other party resided with the child in this state.
The other party resided in this state and provided
prenatal expenses or support for the child.
The child resides in this state as a result of the acts
or directives of the other party.
Other:
48
CR 55(a); RCW 26.09.030
Page 2
2.3
Service on Other Party

The other party was; served with (documents) a Summons,
Petition, Pro se Notice of Appearance, Notice Re: Dependent of
a Person in Military Service, Proposed Parenting Plan, Order
Financial
of Child Support,
Child Support Worksheets,
Declaration, Sealed Financial Documents Cover Sheet and
attached financial documents, Order Assigning Case to Judicial
Department, and (blank) Joinder on (date) _______________:
6
8
10
12
[X]
[ ]
14
in the State of Washington.

in (state or country where served) ___________. Service
within the state of Washington could not be made for the
following reasons:
16
The Other Party cannot be found in the State of
Washington.
18
20
2.4
Time Elapsed Since Service on the Other Party
22
[X]
24
26
[ ]
28
[ ]
30
[ ]
32
The other party was served within the state of Washington

and more than 20 days have elapsed since the date of
service.
The other party was served outside the state of
Washington and more than 60 days have elapsed since the
date of service.
The other party was served by mail and more than 90 days
have elapsed since the date of mailing.
The other party was served by publication and more than
60 days have passed since the date of first publication.
34
2.5
Appearance of the Other Party
36
[X]
[ ]
38
The other party has failed to appear.

The other party has appeared, but has failed to respond.
40
42
44
2.6
Servicemembers Civil Relief Act Statement

2.6.1 A. Service member status -- (name of other party) Beth
Ann Kalii:
46
48
[X] is not a service member;

[ ] is on active duty in the U.S. armed forces
(excluding National Guard and reserves);
CR 55(a); RCW 26.09.030
Page 3
OO 11
OvLO
[
if'!
012
r-i
14
B.
] is on active duty and is a National Guard member

or a Reservist residing in Washington;
] is not on active duty in the U.S. armed forces
] is not on active duty and is a National Guard
member or a Reservist residing in Washington;
] I am unable to determine whether the other party
is or is not on active duty in the U.S. armed
forces;
] I am unable to determine whether the other party
is or is not on active duty as a National Guard
member or a Reservist residing in Washington;
Factual basis:
,16
[X] See the attached Department of Defense
Manpower Data Center Status Report Pursuant to
Servicemember Civil Relief Act (SCRA) obtained
from https://www.dmdc.osd.mil/appj/sera/. (You
must have the person's social security number
to search this site.)
[ ] Other factual basis:
q IS
l'J
\2 0
lO
22
u*'24
26
C . [ ] As indicated above, the other party is on active

duty and (check all that apply):
28
[ ] The other party is represented by an
attorney.
[ ] The court has appointed an attorney to
represent the other party.
[ ] A stay of these proceedings [ ] has [ ] has
not been entered by the court.
30
32
34
36
2.6.2 A.
Dependent of a service member status

other party) Beth Ann Kalii:
(name of
38
40
42
44
46
48
[X] is not a dependent of a resident of Washington

who is on active duty and is a National Guard
member or a Reservist;
[ ] is a dependent of a resident of Washington who
is on active duty and is a National Guard member
or a Reservist;
[ ] I am unable to determine whether the other party
is a dependent of a resident of Washington who
is on active duty and is a National Guard member
or a Reservist;
CR 55(a); RCW 26.09.030
Page 4
iM
B. Factual basis:
o^
o
4
[X] The other party failed to respond to a notice to

him or her as a dependent of a person in
Military Service that was [X] served on [ ]
mailed by first class mail on _______________ ,
therefore he or she should be presumed not a
dependent of a resident of Washington who is on
active duty and is a National Guard member or a
Reservist.
[ ] Other factual basis:
6
8
Or?-0
iCl
Cl2
ci
14
C . [ ] As indicated above, the other party is a

dependent of a resident of Washington who is on
Reservist and (check all that apply):
16
4
i8
u
l
M
v.20
[ ]
u)
r-2 2
[ ]
u24
[ ]
26
The other party is represented by an

attorney.
The court has appointed an attorney to
represent the other party.
A stay of these proceedings [ j has [ ] has
not been entered by the court.
28
2.7
Other
30
32
I declare under penalty of perjury under the laws of the state of

Washington that the foregoir^ 4^
34
36
Signed at
-F kddX A k-j IA/A(City and Sba-te-]
38
40
42
Print or Type Name
44
46
48
CR 55(a); RCW 26.09.030
Page 5
Department of D efense M anpow er Data Center
Results 8S O f: Apr-17-2014 04:11:04 PM
S C R A 3,0
fO
H
)
0(
Status Report
Pursuant to Scrviceinembers Civil R elief Act
L a s t N a m e : K A L II
F irs t N a m e : B E T H
M id d le N a m e : A N N
A c tiv e D u ty S ta tu s A s O f: A p r-1 7 -2 Q 1 4
-
O n A ctive D uty O n A ctive Duty S ta tu s D ale

A ctive D u ly S la rl Date
'
A ctive D uty End Date
Status
S ervice C om ponen t
NA
No
NA
NA
T h is re s p o n s e re fle cts the ind ivid u a ls' a c tiv e d u ty status based on the A ctive Duty S ta tu s Date
4
Left A c tiv e D u ty W ithm 367 D ays o f A c tiv e D uty S tatue Date
A ctive D uty End D ate
A ctive D u ty S la rl D ate
NA
S tatus
No
NA
S ervice C om p o n e n t
(
NA
T h is re sp o n se re fle cts w h e re the in d ivid u a l left active d u ty status w ithin 367 days preceding the A ctive D uty S ta tu s D a le
ij)
rn
in
T he M e m b e r o r H is /H e r U n it W a s N otifie d o f d F uture C a ft-lfp to A ctive D uty on A ctive D uty S ta tu s D ate

|
O rd e r N o tifica tio n S ta rt D ate
O rd e r N o tifica tio n E n d D ate
NA
NA
S tatus
. No
S ervice C om ponen t
NA
T h is re sp o n se re fle cts w h e th e r the in d iv id u a l o r h is /h e r u n it has re ce ive d e a rty notifica tio n to re p o rt fo r a c tiv e duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you .provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty,
Y k o A ij, y h .
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DM DC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
4
cH
o
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.m il/faq/pis/PC09SLDR.htm l. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. 521(c).
This response reflects the following information; (1) The individual's Active Duty status on the Active Duty Status Date (2) W hether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
tfi
O
More information on "Active Duty Status"

Active duty status as reported in this certificate is defined in accordance with 10 USC 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC 502(f) for purposes of responding to a national em ergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs), Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases

\
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
Li.)
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods,
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC 101(d)(1).
ijf'i
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: G965Q300M0E5U50
in
O :
0
6
8
(Til0
In
12

County of Pierce
14
'-"16
rH
s 18

Petitioner,
U>2 0
rH
-22
in
No-
and
\u \ ~
' ^ - ' 6 l t Q L lC p r 7
Order on Motion for Default

(ORDFL)
[X] granted (ORDFL)
[ ] denied (ORDYMT)
Beth Ann Kalii
24
Respondent.
26
I. Basis
28
30
A motion for default has been presented by

party) John Alika Kalii, Jr..
(name of requesting
32
34
II. Findings
36
38
The Court finds:
40
42
44
2.1
Proper Jurisdiction and Venue

The court has proper jurisdiction and venue.
46
Ord of Default (ORDFL)
CR 55(a); RCW 26.09.020
Page 1
o 2
ij
4
2.2
(Name of nonrequesting party being defaulted) Beth Ann Kalii

was served with a Summons , Petition, Pro se Notice of
Appearance, Notice Re: Dependent of a Person in Military
Service, Proposed Parenting Plan, Order of Child Support,
Child Support Worksheets,
Financial Declaration, Sealed
Financial Documents Cover Sheet and attached financial
documents, Order Assigning Case to Judicial Department, and
(blank) Joinder on (date)
6
8
ij'i10
ifi
012
cH
14
d16
H
q
Service on Nonrequesting Party
2.3
Time Elapsed Since Service

[X]
18
\2 0
O
H22
[ ]
u"'24
[ ]
26
[ ]
28
The nonrequesting party was served within the state of

date of service.
The nonrequesting party was served outside the state of
date of service.
The nonrequesting party was served by mail and more than
90 days have elapsed since the date of mailing.
The nonrequesting party was served by publication and
more than 60 days have passed since the date of first
publication.
30
2.4
Appearance
32
[X]
[ ]
34
The nonrequesting party has failed to appear.

The nonrequesting party has appeared but has failed to
respond.
36
38
40
2.5
Servicemembers Civil Relief Act Statement

2.5.1 Service member status -- It appears the nonrequesting
party:
42
44
46
[X] is not a service member;

[ ] is on active duty in the U.S. armed forces
[ ] is on active duty and is a National Guard member or
a Reservist residing in Washington;
48
Ord of Default (ORDFL)
CR 55(a); RCW 26.09.020
Page 2
IS
[ ] is not on active duty in the U.S. armed forces
[ ] is not on active duty and is a National Guard member
or a Reservist residing in Washington.
O 2
0
4
6
8
2.5.2 Dependent of a service member status -- It appears the

nonrequesting party:
Tao
[X] is not a dependent of a resident of Washington who

is on active duty and is a National Guard member or
a Reservist;
[ ] is a dependent of a resident of Washington who is on
Reservist;
[ ] is presumed not a dependent of a resident of
Washington who is on active duty and is a National
Guard member or a Reservist.
in
012
14
,+16
"'J
o 18
.,2 0
A
rH22
2.6
Other
III. Order
U''2 4
26
it is Ordered:
28
30
32
34
36
38
40
42
44
46
48
CR 55(a); R C W 26.09.020
Page 3
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
May 27 2014 8:
KEVIN STO
COUNTYC.
NO: 14-3-0' '
2
3
4
5
6

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
NOTICE OF APPEARANCE FOR

PETITIONER
Respondent.
12
13
TO: CLERK OF THE ABOVE ENTITLED COURT;

AND TO: Daniel N. Cook, Attorney for the Respondent
14
YOU, AND EACH OF YOU will please take notice that Thomas R. Sabin, of
15
Goldberg & Jones PLLC, hereby appears on behalf of John A. Kalii, Petitioner, and
16
requests that all further pleadings herein, except original process, be served upon the
17
undersigned attorney at the address stated below.
18
DATED this 23rd day of May, 2014
19
20
21
22
23
N otice o f A p p e a ra n c e fo r P etitio n e r
P age 1
GOLDBERG & JONES PLLC
1200 Westlake Avc. N., Suile 711(1

Seattle, Washington 98109
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABlN@GOLUBERGJONES.COM
E-FILED
IN COUNTY C L E R K
PIERCE COUNTY, W
June 04 2014 3
KEVIN STO
COUNTY C .
NO: 14-3-01
3
4
5
6
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
RESPONSIVE DECLARATION OF JOHN

KALII
Respondent.
12
I am the Petitioner in this action and make this declaration in response to the
13
motion for temporary orders filed by my wife. Her financial requests are confusing to
14
me so I will address them as best as I can. I am a retired firefighter, and I make
15
$4,028.91 per month from my retirement. My wife is a school bus driver for the Clover
16
Park School District and makes a net income for child support purposes of $2,160.03
17
per month, before deductions for health care insurance.
18
The first two of her requests for financial relief are for a contribution of $730.00
19
for my portion of the health care insurance and $175.00 for my percentage of our
20
daughters health care insurance, totaling $905.00 total contribution towards the health
21
insurance. The problem with that request is that her total average cost for health care
22
insurance over the last 8 months, including her portion thereof, is $920.73 per month.
23
Out of those 8 months four of the months the health insurance costs do not exceed
R e sp o nsive D ecla ra tio n o f J ohn Kalii
p _ nA
rd 9e
GOLDBhRG &
j o is l s p l l c
1200 Westlake Avc. N.Suite700
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABIN@GOLDBERGJONES.COM
$900.00 per month. What she is asking the court for is to have me cover the entirety of
her health insurance costs which isnt fair.
Based upon the information she provided the total insurance for my wife, me and
our daughter is $1,771.03. The cost of insurance for the employee only is $812.45.
The total cost of the insurance for the spo use is $730.86 p rio r to the em p lo ye rs
c o n trib u tio n . I computed that by taking the cost for the spouse and the employee
($1,543.31) less the employee cost ($821.45). The total cost for insurance for our
d a u g h te r p rio r to the e m ploye r c o n trib u tio n is $234.34. I computed that by taking
the cost for the employee and child ($1,046.79) and subtracted out the cost for the
10
employee ($812.45). My percentage of the insurance for our daughter should be 64.5
11
percent, using our percentages of income.
12
The real issue is how to apportion the average of $849.43 that her employer
13
contributes to her health insurance costs. If you attribute the employer contribution to
14
the total insurance costs $849.43/$1,771.03 then the employer is contributing 48% of
15
the total costs of insurance. Using that figure the costs for the insurance for me is an
16
average of $380.05, the cost for my w ifes insurance is $422.47 and the cost for our
17
daughters insurance is $121.86. If you apply my percentage of income to the cost of
18
our daughters insurance, then my contribution should be $78.60. My total contribution
19
to the costs of health insurance should be $458.65.
20
The next issue is my wifes odd request for a portion of my pension. Her
21
approach is that one would expect at a trial not on temporary orders. It is my
22
understanding that on temporary orders the court will not be involved in property
23
division; it is reserved for agreement or trial. However, even if it is assumed that this is
Responsive Declaration of John Kalii

Page 2

1200 Westlake Avc. N Suite 700
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABIN@GOI.DBERGJO 4NES.COM
some sort of request for temporary spousal maintenance there was no financial
declaration provided, no bank records, no showing of need, if any, on her part. Her
request also doesnt take into account the substantial contributions that were made to
her SERS retirement plan while we were married. Ultimately, that is why it should be an
issue for the trial court. We have had a short term marriage, less than four and a half
years and have lived together less than seven years, having moved in with me in the
summer of 2007. Even if her attorney files a financial declaration and bank records, I
will not have the opportunity to address those issues. She is claiming that she has the
need for
10
My wife has requested certain furniture and other items from me, which again
11
seem to be a request for a pretrial distribution of property. She has requested her trunk,
12
which has already been delivered to her, and her wardrobe which I have no problem
13
with her having. She has also requested all of the kitchen utensils out of the camper
14
trailer, without any showing of need, but I am willing to provide those to her. I do not
15
understand her request for the outdoor furniture but I am willing to provide those for her.
16
However, as to her request for the king size bed, that is the bed that I have, I am using it
17
and I purchased prior to our marriage. It is the only bed I have. I assume, because she
18
hasnt told us, that she has a bed where she is residing, and her possible move to an
19
apartment some time in the future is not addressed. She may ultimately move into a
20
furnished apartment, she may have the need for some of these items, but there just isnt
21
enough information provided as to her need, only her demand.
22
23
She has requested that I pay $1,500 to her attorney fees. Although at the time
that I receive my retirement check I have a good amount of money in my account, by

Page 3

1200 Westlake Avc, N., Suite 700
Tel: (206) 448-1010 - Fax: (206)448-0736
Kmail-TSABIN@GOLOBERGJONES.COM
th e e nd o f th e m on th, th e re is v irtu a lly n o th in g left in th e a ccou nt. W ith m y w ife m oving
o u t I h a ve had to p a y all o f th e u tilitie s, m ortg a g e , fo o d etc. I s im p ly d o n o t have the
m o n e y a va ila b le , in fa ct, o n e o f h e r d a u g h te rs fro m a p rio r m a rria g e is s till living with
m e and relying on m y su p p o rt.
o u ts ta n d in g lo a n s, va ca tio n , bills a nd o th e r e x p e n s e s fo llo w in g m y re tire m e n t and
a tte m p t to c le a n up m y c re d it d urin g 2 0 1 3 a s c a n be se e n b y th e ta x return. T h e little
a m o u n t th a t I d o h ave , I need to use fo r o u r d a u g h te r.
in fo rm a tio n a b o u t h e r nee d o r o th e r a s s e ts a v a ila b le to her. A g a in , e v e n if sh e does on
h e r re p ly h e r re q u e s t sh o u ld b e d e n ie d as I w ill n o t h ave a n o p p o rtu n ity to respond to
10
11
12
I h a v e v irtu a lly e m p tie d m y 4 0 2 (k ) plan to p a y o ff
S h e has n o t pro vid e d
h e r a lle g a tio n s.
T h is d e c la ra tio n is g ive n u n d e r p e n a lty o f p e rju ry o f th e law s o f th e S ta te of
W a s h in g to n a n d is tru e a n d c o rre c t to the b e s t o f m y kn o w le d g e .
13
14
15
16
17
18
19
20
21
22
23

v
Page 4
g o i .dberg &
JONES t'U X
98169
\ 200 Westlake Avc. IV., Swlle 700
ScattU,
T e l: (2 9 4 ) 4 4 M G 1 0 - F a s t (2&}44$-Q736
Email* TSAB IK @ G O LD B ERCJO KES.CO M
1
2
3
4
5
6
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
12
I declare under penalty of perjury of the laws of the State of Washington that the
13
foregoing electronic document attached to this declaration, which consists of 5 pages
14
including this declaration page, is a complete and legible image that I have examined
15
personally and that was received by me via email at the following address:
16
tsabin@ goldbergjones.com.
17
18
19
20
21
22
23
D ecla ra tio n o f S ig n a tu re on E le ctro n ic D o cum ent

P age 1

1200 Westlake Ave. N Suite 700
Tel: (206)448-1010- Fax: (206)448-0736
E-FILED
PIERCE COUNTY, W A S H IN G !
June 04 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
2
3
4
5
6
S u p e rio r C o u rt o f W a s h in g to n
C o u n ty o f PIERCE
7
8
In re:
JOHN KALII
N o. 14-3-01646-7
10
P e titio n e r,
F in a n c ia l D e c la ra tio n
P e titio n e r
(F N D C LR )
And
11
BETH KALII
12
13
R e s p o n d e n t.
Name: John Kalii
14
15
16
Date of Birth: 11/29/1952

I. S u m m a ry o f B a s ic In fo rm a tio n
Declarant's Total Monthly Net Income (from 3.3 below)

Declarant's Total Monthly Household Expenses (from 5.9 below)
Declarant's Total Monthly Debt Expenses (from 5.11 below)
Declarant's Total Monthly Expenses (from 5.12 below)
Estimate of the other party's gross monthly income (from 3.lg below)
$4,028.91
$4,658.38
$185.00
$4,843.38
$2,667.00
17
II.
18
19
P e rs o n a l In fo rm a tio n
2.1
Occupation:
2.2
The highest year of education completed: 14
2.3
Are you presently employed?

a. If yes:
20
No
(1) W h e re do you work. E m p lo y e r's n am e a n d a d d re s s m u s t be lis te d on th e

C o n fid e n tia l In fo rm a tio n F o rm .
(2) When did you start work there? (month/year)
21
b. If no:
(1) When did you last work? (month/year) 12/2012
22
(2) What were your gross monthly earnings?
23
(3) Why are you presently unemployed?
retired
24
25

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
Goldberg Jones PLLC

1200 Westlake Ave. N. Suite 700
Seattle, Washington 98x09
206-448-1010
email tsabin@goldbergjones.com
SupportCafc/FD 2014
1
III. Incom e In fo rm a tio n
2
3
4
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip
Paragraphs 3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child support is Notan
issue this entire section should be completed. (Estimate of other party's income information is
optional.)
3.1
6
7
8
9
10
11
12
Gross Monthly Income

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your
monthly wages and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If
you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that
amount below.
Beth Kalii
John Kalii
Imputed Income
a.
$4,352.37
$2,667.00
Wages and Salaries
b.
Interest and Dividend Income
c.
Business Income
d.
Spousal Maintenance Received

e.
From
**
Other Income
f.
$4,352.37
$2,667.00
Total
Gross
M
onthly
Income
9(add lines 3.1a through 3.1e)
h.
Actual Gross Income (Year-to-date)
13
Monthly Deductions From Gross Income
14
a.
b.
c.
d.
e.
f.
9h.
15
16
17
18
Income Taxes
FICA/Self-employment Taxes
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
Pension Plan Payments
Spousal Maintenance Paid
Normal Business Expenses
Total Deductions from Gross Income
$323.46
Beth Kalii
$19.86
$123.89
$5.35
$46.10
$254.11
$449.31
$4,028.91
$2,217.69
John Kalii
$323.46
-
19
20
3.3
M onthly Net Income (Line 3.1 f minus line 3.2h

orjine 3 from the Child Support Worksheet(s).)
21
22
23
24
25

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
Goldberg Jones PLLC

206-448-1010
SupportCafc/FD 2014
3.4
2
3
Miscellaneous Income
a.
Child support received from other relationships
Name:
Name:
b.
Other miscellaneous income
Beth Kalii
John Kalii
-
(list source and amounts)
Income of current spouse

Name:
Name:
Income of children
Name:
Name:
Income from assistance programs
Name:
Name:
Non-recurring income
Name:
Name:
Other Income:
4
5
6
7
8
9
10
11
c.
12
13
T o ta l M is c e lla n e o u s In c o m e
(add lines 3.4a through 3.4b)
3.5
14
Income of Other Adults in Household

Name:
Name:
3.6
If the income of either party is disputed, state monthly income you believe is correct and
explain below:
4.1
4.2
4.3
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:
15
16
17
_
-
IV. A v a ila b le A s s e ts
18
4.4
$36.00
$1,483.00
-
$5,924.16
19
V. M o n th ly E x p e n s e In fo rm a tio n
20
21
22
23
Monthly expenses for myself and 1 dependents are: (Expenses should be calculated for the future, after
separation, based on the anticipated residential schedule for the children.)
5,1
Housing
Rent, 1st mortgage or contract payments
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
T o ta l H o u s in g
$1,607.18
$1,607.18
24
25

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
Goldberg Jones
PLLC

206-448-1010
SupportCa/c/FD 2014
5.2
2
3
Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other:
$168.26
$99.40
$114.94
$320.00
$133.86
T o ta l U tilitie s
$836.46
5.3
6
7
8
9
5.4
10
11
12
5.5
14
5.6
16
17
18
5.7
21
22
T o ta l F o o d S u p p lie s
$675.00
Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
T o ta l T ra n s p o rta tio n
15
20
$400.00
$150.00
$125.00
T o ta l E x p e n s e s C h ild re n
13
19
Food and Supplies

Food for 2 persons
Supplies (paper, tobacco, pets)
Meals eaten out
Other:
$148.00
$50.00
$198.00
$684.69
$135.05
$165.00
$984.74
Health care (Omit if fully covered)

Insurance
Uninsured dental, orthodontic, medical, eye
care expenses
Other uninsured health expenses
$75.00
T o ta l H e a lth C are
$75.00
Personal Expenses (Not including children)

Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers, magazines, photos
Gifts
Other:
T o ta l P e rs o n a l E x p e n s e s
$50.00
$20.00
$95.00
$117.00
$282.00
23
24
25

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
Goldbei'g Jones PLLC

206-448-1010
SupportCa/c/FD 2014
5.8
2
3
4
5
6
7
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other:
Other:
T o ta l M is c e lla n e o u s E x p e n s e s
5.9
$4,658.38
T o ta l H o u s e h o ld E xp e n s e s
(The total of Paragraphs 5.1 through 5.8)

5.10
Installment Debts Included in Paragraphs 5.1 Through 5.8
Balance
Creditor/Description of Debt
$217,967.00
Wells Fargo Home Mortgage
$4,669.00
Wells Fargo Dealer Services
$4,895.00
Alaska USA Federal Credit
Union
Month of Last Payment

May, 2014
May, 2014
May, 2014
8
9
10
11
12
13
5.11
Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Month of
Last Payment
Creditor/Description of Debt
Balance
May, 2014
MasterCard
$1,616.71
May, 2014
Target
$224.00
June, 2014
Lowes
$520.33
Amount of
Monthly Payment
$ 100.00
$25.00
$60.00
14
15
16
17
18
19
20
21
22
23
24
25

WPF DRPSCU 01.1550 (6 /2006 ) - RCW 26 .18.220 (1)
Goldberg Jones PLLC

Seattle, Washington 98x09
206-448-1010
SupportCa/c/FD 2014
1
2
Total M onthly Paym ents fo r O ther Debts and Monthly

Expenses
5.12
Total Expenses (Add Paragraphs 5.9 and 5.11)
$185.00
$4,843.38
VI. Attorney Fees

4
6.1
A m ount paid fo r attorney fees and costs to date:
6.2
The source o f this m oney w as: earnings
6.3
6.4
A rrangem ents fo r attorney fees and costs are: D ue in full on billing
6.5
Other:
$3,000.00
6
7
$2,000.00
10
11
I declare u nder penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
Signed at
12
13
14
Signature o f Declarant
15
T he following financial records are being provided to the other party and filed separately w ith the court.
16
Financial records pertaining to myself:
17
18
19
20
21
22
[x] Individual [ ] Partnership or C orporate Incom e T ax returns fo r

the years:
including all W -2s and schedules;
[x] P ay stubs fo r the dates of
[ ] Other:
Do not attach these financial records to the financial declaration. These financial records should
be served on the other party and filed with the court separately using the sealed financial source
documents cover sheet (WPF DRPSCU 09.0220). If filed separately using the cover sheet, the
records will be sealed to protect your privacy (although they will be available to all parties in fire
case, their attorneys, court personnel and certain state agencies and boards.) See GR 22 (c)(2).
23
24
25
Financial D eclaration (F'fiDC LR) - Page 6 o f 6
W PF DRPSCU 01.1550 (6/2006) - R CW 26.18.220 (1)
G o ld b e r g J o n e s P LLC
1200 W e s tla k e A v e . N . S u ite 700
S e a ttle , W a s h in g t o n 9 8 1 0 9
2 0 6 -4 4 8 -1 0 1 0
e m a il ts a b in @ g o ld b e r g jo n e s .c o m
SupportCWFD 2014
1
2
3
4
5
6
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
Dated this 4th day of June, 2014 at Seattle, Washington
19
20
21
22
23
Declaration of Signature on Electronic Document

Page 1

1200 Westlake Avc. N., Suite 700
Tel: (206) 448-1010- Fax: (206)448-0736
Email- TSABIN@GOEDBKRG.IONES.COM
E-FILED
PIERCE COUNTY, WASHING
June 06 2014 10:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
COUNTY OF PIERCEI,
10
11
No. 14-3-01646-7

Petitioner,
12
REPLY DECLARATION OF BETH

KALII
and
13
BETH ANN KALII,

Respondent.
14
15
16
17
18
I, BETH KALII, make this declaration on the basis of my personal knowledge and in
reply to the Response Declaration of John Kalii filed on June 4, 2014.
JOHN says that my requests are confusing. There is nothing confusing about
19
them. I am asking that JOHN pay for his own health care insurance. I am asking that
20
JOHN pay 64.5% of KAENAs health care insurance.
21
community portion of his pension. I am asking for use of personal property to divided and
22
I am asking for one-half of the
I am asking for attorney fees. Nothing about these requests are confusing.
23
JOHN then goes on to reach the exact same calculation of medical insurance
24
costs for me, spouse and child. We both agree that the cost of insurance for me is
25
R e p ly D e c la r a tio n - P a g e 1 o f 5
S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration ofBeth Kalii.doc
5920-1 00 th S treet SW Ste 25

253-581-0660
1
$812.45. We both agree that the cost of insurance for JOHN is $730.86.
We were
2
within $0.79 of each other on KAENAs cost of insurance so I will just adopt his number
3
of $234.34 per month for KAENA.

4
5
We both agree that his net income is $4,048 per month. We both agree my net
income is $2,160 per month. We both agree that he should pay 64.5% of KAENAs
medical insurance cost which is $151.15. But he only agreed to pay that after I filed this
motion. Previously he refused to even help me with KAENAs medical insurance. That is
one reason I need attorney fees.
10
11
As I noted in my moving declaration, my Employers contribution to my healthcare

insurance varies each month. JOHN calculated out the average amount Employer pays
12
as $849.43 per month. That average calculation is probably close.
13
JOHN then assets that this payment by my employer should be partially applied to
14
HIS coverage. That is simply absurd. My employer pays for my coverage. The
15
amount paid by the employer is almost precisely the amount owed for my coverage each
16
17
month. If JOHN was not covered by my health care insurance plan I would pay
18
nothing for my insurance. There would also be a small part of KAENAs cost covered.
19
This is a component of my compensation package and is a benefit of my employment. It
20
is common for the employee health care cost to be fully covered by the employer and for
21
the dependents to be paid by the employee. That is exactly what is happening here.
22
23
The $849.43 paid on average by my employer exceeds the $812.45 cost of my

coverage alone by $36.98 per month. This amount should reduce the premium for
24
KAENA. So instead of sharing the cost of KAENAs insurance at $234.34 per month, we
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii.doc
5920-1 00 th S tre et SW , Ste 25

253-581-0660
1
would share the cost of $197.36. This would mean JOHNS 64.5% share of her
3
4
healthcare insurance would be $127.29.
But this should not operate to reduce JOHNS
premium. If he wants to obtain cheaper insurance elsewhere, through a healthcare
insurance exchange or through his retirement, he can do that. But if he wants to remain
on my insurance he should pay the full amount we both agree is his share of $730.86 per
month. The total combined amount he should pay for KAENAs insurance and his own
insurance is $858.15 per month.
9
10
11
JOHN makes a point about my out-of-pocket cost for insurance. He is right when
he says the total cost is $1,771.03. He is right when he says my company pays an
average of $849.43 per month. This means my out-of-pocket costs are $921.60. When
12
JOHN pays $858.15 that leaves me with an obligation of $63.45. My 35.5% share of
13
KAENAs $197.36 is almost precisely the same at $70 per month.
Because the
14
15
16
17
numbers vary a bit month to month based upon the amount of my employer
contribution my proposal is that JOHN pay a flat $850 per month to cover the cost
of his insurance and his contribution to KAENAs insurance. This is $55 less per
18
month than I originally asked for, based upon the application of the small excess my
19
employer pays on average in addition to my coverage.
20
PENSION
21
22
23
24
Regarding his pension, there is a huge difference between his pension and my
pension.
His pension is in pay status. He is receiving his pension each and every
month. My pension is not in pay status. I am do not have access to those funds and I am
not entitled to those funds while working. I cannot withdrawal them. I will not receive
25
5920-100 S treet SW , Ste 25

253-581-0660
1
them until I retire. JOHN may be entitled to a small percentage of my retirement and we
2
can sort that out, but in the meantime, he is taking and using a small amount each month
3
which presumptively belongs to me. In contrast, I am not taking and using or spending
4
5
any money which belongs to him. Any money that he is entitled to from me is and will be
preserved until final distribution. But JOHN cannot continue to take and use all of the
community portion of his pension throughout the pendency of this case.
8
9
10
11
12
This is not a request for maintenance. The court could consider a request for
maintenance in lieu of this request, or we could bring another motion; however, there is
simply no reason why he should have the full benefit of all of the community interest in his
pension during the pendency of this action.
PERSONAL PROPETY
13
JOHN misstates my request. I am not asking for a pretrial distribution of

14
property. I am asking to have temporary use and possession of certain property just as
15
he has temporary use and possession of certain property.
This is a temporary order.
16
17
The statute authorizes temporary orders. JOHN is using the vast majority of the things
18
we acquired and accumulated during our relationship. But JOHN should not have
19
exclusive use of everything. We now have two homes to furnish. I only receive (after
20
paying insurance) $1,290 per month. After paying rent I have very little left to pay for gas
21
and groceries. I cannot afford to go out and furnish an entire new house. But he just says
22
that he should get to use everything we own until trial and I should make do with nothing
23
until trial. This is totally unfair. I do not have money to rent a furnished apartment. I am
24
moving on the first of July into a two bedroom duplex and the rent is $850 per month.
25
5920-1 00 th S treet SW , Ste 25

253-581-0660
1
The only item he specifically objects to in my list was the bed. I do not have a bed
2
and I have been sleeping on a friends bed.
He says he owned it prior to commencing
our relationship. That is not entirely true he did own it prior to the wedding date, but he
4
5
purchased it during our pre-marriage cohabitation period. So technically the community
presumption would apply to the bed. However, if he is unwilling to part with the bed I
would be willing to accept the two reclining leather couches instead. I can use one of
those as a bed instead.
10
11
Regarding attorney fees, he makes far more than I do each month. His gross is
$4,352 and my gross is $2,667.
$1,290.
His net is $4,028 and my net (after health insurance) is
He has almost three times as much available income as I do.
Even if the court
12
requires him to pay $850 per month toward the health care insurances I pay, he still has
13
$3,178 and I only have $2,140.
He still have far more income available to him and can
14
take positions like I should have no use of property until trial because he has the money
15
for an attorney and I do not. He can take positions like he should be able to use all of the
16
17
18
19
community pension and I should have none of it and without some assistance from him
for attorney fees I will have no ability to maintain a lawyer for a fair division.
20
21
Signed at Lakewood, WA on June Jp_, 2014.
22
23
BETH KALII
24
25
5920-100 S tre et SW , Ste 25

253-581-0660
E-FILED
PIERCE COUNTY, WASHING'
June 06 2014 10:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
County of PIERCE *
8
9
In re:
JO H N KALII
No. 14-3-01646-7
10
Petitioner,
Financial Declaration
[ ]Petitioner
[X]Respondent
(FNDCLR)
And
11
BETH KALII
12
13
Respondent.
N am e: Beth Kalii
I. Summary of Basic Information
14
15
16
D ate o f Birth:
D eclarant's
D eclarant's
D eclarant's
D eclarant's
Estim ate o f
T otal M onthly N et Incom e (from 3.3 below)

T otal M onthly H ousehold Expenses (from 5.9 below)
T otal M onthly D ebt Expenses (from 5.11 below)
T otal M on thly E xpenses (from 5.12 below)
the o th e r party's g ro ss m on thly incom e (from 3.1g below)
$1,290.00
$2,150.00
$2,150.00
[X]
t 1
17
18
19
20
U nknow n
II. Personal Information

2.1
O ccupation:
2.2
T he h ig he st ye a r o f e du catio n com pleted:
2.3
A re you pre sen tly e m p lo ye d?

[ ] Yes
[ ] No
a. If yes:
(1) W h e re do you w ork. Employer's name and address must be listed on the
Confidential Information Form.
21
22
(2) W h e n did you sta rt w o rk th ere? (m onth/year)

b. If no:
(1) W hen did you last w o rk? (m onth/year)

(2) W h a t w ere yo ur g ro ss m onthly e arnings?
23
(3) W h y are you p re sen tly unem ployed?
24
25
Financial D eclaration (F N D C LR ) - Page 1 o f 6

W P F D R P S C U 0 1.1550 (6/2 00 6 ) - R C W 2 6.1 8.22 0 (1)
Faubion, R eeder, Fraley &

Cook, PS
5920 looth Street SW, #25

Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2014
1
III. Income Information
2
3
4
If child su pp ort is a t issue, co m p le te th e W ash in gton State C hild S upport W o rkshe et(s), skip
P arag ra ph s 3.1 and 3.2. If m aintenance, fees, costs or debts are at issue and child su pp ort is Not an
issue th is entire section should be com pleted. (E stim ate o f other party's incom e inform ation is
optional.)
3.1
6
7
8
9
10
11
12
G ross M on thly Incom e

If you are paid on a w ee kly basis, m ultiply yo u r w e e k ly g ro ss pay by 4.3 to dete rm ine your
m onthly w a g e s and salaries. If you are paid every tw o w eeks, m ultiply yo u r gross pay by 2.15. If
you are paid tw ice m onthly, m ultiply yo ur gro ss pay by 2. If you are paid once a m onth, list that
a m o un t below.
John Kalii
Beth Kalii
a.
Im puted Incom e
b.
W a g e s and S alaries
$1,290.00
c.
Interest and D ividend Incom e
d.
B usiness Incom e
e.
S pousal M aintenance R eceived
From
f.
O th e r Incom e
g-
T o ta l G r o s s M o n th ly In c o m e
h.
(add lines 3.1a th rough 3.1e)

A ctual G ross Incom e (Year-to-date)
$ 1 ,2 9 0 .0 0
-
13
14
M onthly D eductions From G ross Incom e

John Kalii
15
16
17
18
a.
b.
c.
d.
e.
f.
gh.
Beth Kalii
Incom e T axes
F IC A /S elf-e m p lo ym en t T axes
S tate Industrial Insurance D eductions
M an da to ry U n io n/P ro fe ssio n al Dues
P ension Plan P aym ents
S pousal M ainten an ce Paid
N orm al B u siness Expenses
T o ta l D e d u c tio n s fr o m G r o s s In c o m e

19
20
M o n t h ly N e t In c o m e (Line 3 .1f m inus line 3.2h
$ 1 ,2 9 0 .0 0
o N in e 3 from the C hild S u pp o rt W o rkshe et(s).)
21
22
23
24
25
Financial D eclaration (F N D C LR ) - P age 2 o f 6

W P F D R P S C U 01.1550 (6/2006) - R C W 2 6.18.220
(1)

Cook, PS
5920 100th Street SW, #25

Lakewood, WA 98499
(253) 581-0660
Support Ca/c/FD 2014
3.4
2
3
M isce lla n eo us Incom e

a.
C hild su pp ort received from other relationships
Nam e:
Nam e:
b.
O th e r m isce lla n eo us incom e
John Kalii
Beth Kalii
(lis t s o u rc e a n d a m o u n ts )
Incom e o f cu rre n t spouse

Nam e:
N am e:
Incom e o f children
Nam e:
Nam e:
Incom e from a ssistan ce program s
Nam e:
Nam e:
N on -re currin g incom e
N am e:
Nam e:
O th e r Incom e:
4
5
6
7
8
9
10
11
c.
12
13
T o ta l M is c e lla n e o u s In c o m e
(ad d lin e s 3 .4 a th ro u g h 3 .4 b )
3.5
Incom e o f O ther A d ults in H ousehold

Nam e:
Nam e:
3.6
If th e incom e o f e ithe r party is disputed, state m onthly incom e you believe is correct and
explain below :
4.1
4.2
4 .3
C ash on hand
On d e p o sit in banks
S tocks and bonds
C ash va lu e o f life insurance
O th e r liquid assets:
14
15
16
17
IV .
18
4 .4
A v a ila b le A s s e ts
19
V.
20
21
22
23
M o n th ly E x p e n s e In fo r m a tio n
M onthly e xpe nse s fo r m yse lf and 1 dep en de nts are: (E xpenses should be calculated fo r the future, after
separation, based on th e a nticipated residential sch ed ule fo r th e children.)
5.1
H ousing
Rent, 1st m ortg ag e o r co ntract p aym ents
In sta llm en t p aym ents fo r o the r m ortgages or
e n cu m b ra nce s
T axe s & insu ra n ce (if not in m on thly paym ent)
T o ta l H o u s in g
$850.00
$ 8 5 0 .0 0
24
25

W P F D R P S C U 0 1.1 55 0 (6/2006) - R C W 2 6.18.220 (1)

Cook, PS

Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2014
5.2
2
3
4
U tilities
H eat (gas & oil)
Electricity
W ater, sew er, garba ge
T ele ph on e
C able
O ther: Internet
$100.00
$25.00
$100.00
$80.00
T o ta l U t ilit ie s
$ 3 0 5 .0 0
Food and S u pplies

Food fo r 2 p erson s
S upplies (paper, to ba cco, pets)
M eals eaten o ut
O ther:
$400.00
$50.00
$50.00
T o ta l F o o d S u p p lie s
$ 5 0 0 .0 0
5.3
6
7
8
9
5.4
10
11
12
5.5
14
5.6
16
17
5.7
22
T ransportation
V e hicle p aym ents or leases
V e hicle insu ra n ce & license
V e hicle gas, oil, o rd in a ry m ainten an ce
Parking
O ther tran spo rtatio n e xpenses
$100.00
$250.00
$ 3 5 0 .0 0
H e a lth c a re (O m it if fu lly covered)

Insurance
U ninsured dental, o rthodontic, m edical, eye
ca re expenses
O th e r uninsured health e xpenses
$20.00
T o ta l H e a lth C a re
18
21
$ 5 0 .0 0
T o ta l T r a n s p o r t a t io n
15
20
$50.00
T o ta l E x p e n s e s C h ild r e n
13
19
C hildren
D ay C are/B abysitting
C lothing
T uition (if any)
O th e r child -rela ted e xpenses
$ 2 0 .0 0
P ersonal E xp en se s (N o t including children)

C lothing
H air ca re /pe rson al ca re e xpe nse s
C lubs and recreation
Education
Books, n ew spapers, m agazines, photos
Gifts
O ther:
$25.00
$50.00
T o ta l P e r s o n a l E x p e n s e s
$ 7 5 .0 0
23
24
25

W P F D R P S C U 01.1550 (6/2006) - R C W 26.18.220
(1)

Cook, PS
5920 lOOth Street SW, #25
Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2014
5.8
2
3
4
5
M isce lla n eo us E xpenses

Life insurance (if not d educted from incom e)
O ther:
O ther:
T o ta l M is c e lla n e o u s E x p e n s e s
5.9
T o ta l H o u s e h o ld E x p e n s e s
$ 2 ,1 5 0 .0 0
(The total o f P arag ra ph s 5.1 through 5.8)

5.10
Installm ent D ebts Included in P aragraphs 5.1 Through 5.8
C re dito r/D escriptio n o f D eb t
B alance
M onth o f Last P aym ent
6
7
8
9
10
11
12
5.11
O th e r D ebts and M onthly Expenses not Included in P aragraphs 5.1 - 5.8

M onth of
C re dito r/D escriptio n o f D ebt
B alance
Last P aym ent
A m o un t o f
M onthly P aym ent
13
14
15
16
17
18
19
20
21
22
23
24
25
F inancial D eclaration (F N D C L R ) - P age 5 o f 6

W P F D R P S C U 01.1550 (6/2 00 6 ) - R C W 2 6.1 8.22 0 (1)

Cook, PS
5920 100th Street SW, #25

Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2014
1
2
T otal M onthly P aym ents fo r O th e r D ebts and M onthly

Expenses
5.12
Total Expenses (Add P aragraphs 5.9 and 5.11)
$ 2 ,1 5 0 .0 0
3
V I.
A tto rn e y F ees
6.1
A m o u n t paid fo r a tto rn ey fees and costs to date:
$1,000.00
6.2
T he so urce o f th is m oney w as: $450 from bake sale at w ork; balance from w ag es and salary
6.3
6.4
A rra n g e m e n ts fo r a tto rn e y fe es and costs are:
6.5
O ther:
10
11
I declare under penalty o f perjury u nd er the law s o f the state o f W ashington th a t the fo re go ing is true and
correct.
S igned at
[City]
[S tate] on
ate].
12
13
14
15
T he fo llo w in g fin an cia l reco rd s are being provided to the o th e r party and filed se pa ra te ly w ith the court.
16
F inancial records pertaining to m yself:
17
18
19
20
21
22
[ ] Individual [ ] P a rtne rsh ip or C orp o ra te Incom e T ax returns fo r

th e years:
including all W -2 s and schedules;
[ ] Pay stubs fo r the d ate s o f
[ ] O ther;
D o n o t a tta c h th e s e f in a n c ia l r e c o r d s t o th e f in a n c ia l d e c la r a tio n . T h e s e f in a n c ia l r e c o r d s s h o u ld
b e s e r v e d o n th e o t h e r p a r ty a n d f ile d w it h th e c o u r t s e p a r a te ly u s in g th e s e a le d f in a n c ia l s o u r c e
d o c u m e n t s c o v e r s h e e t (W P F D R P S C U 0 9 .0 2 2 0 ). If f ile d s e p a r a te ly u s in g t h e c o v e r s h e e t, th e
r e c o r d s w i l l b e s e a le d t o p r o t e c t y o u r p r iv a c y ( a lth o u g h th e y w ill b e a v a ila b le t o a ll p a r tie s in th e
c a s e , t h e ir a tto r n e y s , c o u r t p e r s o n n e l a n d c e r ta in s ta te a g e n c ie s a n d b o a r d s .) S e e G R 2 2 (c )(2 ).
23
24
25
F inancial D eclaration (F N D C LR ) - Page 6 o f 6

W P F D R P S C U 01.1550 (6/2006) - R C W 2 6.1 8.22 0 (1)
Template: c:\program files (x86)\legalplus\state templatesVfd dtf

Client: m:\scdata\kalii\kalii.scp 06/05/2014 05:32 pm
SupportCa/c/FD 2014

Cook, PS

Lakewood, WA 98499
(25S) 58l -0660
E-FILED
June 06 2014 12:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
IN AND FOR THE COUNTY OF PIERCE
10
11
12
13
14
No. 14-3-01646-7
Petitioner,
ATTORNEY FEE
DECLARATION
and
BETH ANN KALII,

Respondent.
15
My name is DANIEL COOK. I am the attorney for BETH ANN KALII Respondent herein.
16
I am an attorney licensed to practice in the State of Washington. I actively practice in

17
18
Pierce, Thurston, King, Kitsap and Mason counties. I am a shareholder with Faubion Reeder
19
Fraley & Cook, PS.
20
status) since November of 2003. I have been licensed to practice law in Washington since
21
May of 2004. I devote a substantial portion of my practice, more than 75%, to the practice of
22
family law and domestic relations issues. I actively serve as a Pro Tern Commissioner in
23
Pierce County Superior Court.
24
25
I have been licensed to practice law in California (currently on Inactive
My hourly rate is $215 per hour. Based upon my knowledge of attorneys in the area,
$215/hour is a reasonable hourly rate for an attorney with over 10 years of experience.
A T T O R N E Y F E E D E C L A R A T IO N - P a g e 1 o f 2
D onahoe, D iana and D onahoe, S cott
S:\CASES1\Kalii\DRAFTS\Pleadings\Attomey Fee Declaration.doc
5920-1 00 th S treet SW, Ste 25

253-581-0660
1
A trained legal assistant assists me by performing many tasks necessary for the
2
efficient practice of domestic relations law. My legal assistant has a Bachelors Degree as
3
well as a Masters Degree in English and a Paralegal Certificate. My legal assistant has
4
5
6
7
more than 11 years of experience assisting attorneys in domestic relations and civil litigation.
It is a benefit to the client for the legal assistant to perform many tasks at a lower hourly rate.
Attached as Exhibit A is a true and correct copy of the billing history produced by my
billing software accurately reflecting the time my client was charged in connection with this
matter. These fees and costs include an estimated two and one-half (2.5) hours of attorney
10
11
12
time for appearance at a hearing on June 11,2014. Exhibit A shows that BETH KALII has
incurred total of $1,789 in fees.
I certify based upon my experience in domestic relations practice that the time
13
charged was necessary and reasonable.

14
15
16
17
I DECLARE UNDER PENALTY OF PERJURY ACCORDING TO AND UNDER

THE LAWS OF THE STATE OF WASHINGTON THE ABOVE STATEMENTS ARE
TRUE AND CORRECT.
Signed at Tacoma, Washington on June 6, 2014.
18
19
Daniel N. Cook, W SB A #34866

20
21
22
23
24
25
D onahoe, D iana and D onahoe, S co tt
S:\CASES1\Kalii\DRAFTS\Pleadings\Attomey Fee Declaration.doc

253-581-0660
Faubion, Reeder, Fraley & Cook, P.S.

5920 100th Street S.W., Suite 25
Lakewood, Washington 98499
(253) 581-0660
Tax ID# 91-1044252
Dissolution
5/1/2014
Invoice submitted to:

Beth Kalii
6114 112th St. S.W., #54
Lakewood, WA 98498
June 06, 2014

In Reference To: DNC9912
10450-1
Professional Services
Hrs/Rate
Amount
4/23/2014
DN
Conference
with Beth Kalii.
$215.00/hr
0.60
$129.00
5/12/2014
SD
Work
Open new client file
$100.00/hr
0.20
$20.00
5/13/2014
SD
Work
Draft Proposed Parenting Plan;

Draft Response to Petition; File
Notice of Appearance; Download
opposing party filings and save to
file; index and print for client file
$100.00/hr
1.50
$150.00
DN
Conference
with client to finalize Proposed

Parenting Plan and Response to
Petition. Draft motion and
declaration for temporary order.
$215.00/hr
2.00
$430.00
SD
Work
Prepare sealed coverpage; file

$100.00/hr
Notice of Appearance; file response
1.00
pleadings and save copies to file;
Note hearing; make copies and mail
to opposing party; prepare and file
$100.00
Beth Kalii
Page
Hrs/Rate
Amount
DOM re same; copy client by

E-Mail, index pleadings
5/27/2014
SD
Work
Download and E-Mail Opposing

Counsel Notice of Appearance to
client
$100.00/hr
0.10
$10.00
6/2/2014
SD
Work
Scan and E-Mail Opposing Counsel $100.00/hr

letter to client
0.10
$10.00
6/4/2014
SD
Work
Call to client re reply dec
$100.00/hr
0.10
NO CHARGE
SD
Work
Download and E-Mail opposing

$100.00/hr
party filings to client; update file and
0.20
index pleadings in advance of 6/11
hearing
$20.00
6/5/2014
DN
Conference
with client to draft reply declaration $215.00/hr

and financial declaration.
1.50
$322.50
6/6/2014
SD
Work
e-file reply pleadings; serve

$100.00/hr
Opposing Counsel by e-service and
0.60
ABC-Legal Messengers, Inc.; copy
and index working copies and send
to court for 6/11 hearing; copy client
by E-Mail; update file and index
pleadings
$60.00
6/11/2014
DN
Ct.
Appearance
for hearing.
For professional services rendered
$215.00/hr
2.50
$537.50
10.40
$1,789.00
H
RE:
_______________ _________________________________ t
C
r ^ p l
C L Q r e g -
S e A r
- V W
C)\)P&.
W (^ T U A Q
A c s
& c o \e _ f
lo g ,
e rv V e r& -d .
June 11, 2014 9:00 AM
\J C x c o u V g -
~ V n e ,
r tp 4 V x u |4 -
is
Motion - Temporary Order

KA R EN A K. K IR K E N D O LL
| ^
j(Y\
^ ^ ^VAoJlSLMdDw'ÂW^
C ourtroom num ber: 100
C alendar:C 1- S H O W C AU SE /FAM ILY LA W
Run date/time 06/11/14 8:20
Ixcrtrpt.pbldJoumatjentty_showcause_report
-fo
E-FILED
June 13 2014 1:28 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

No. 14-3-01646-7
Petitioner(s),
vs.
BETH A N N KALII
R espondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: THOMAS RAYMOND SABIN

Address: 1200 Westlake Ave N Ste 700 Seattle, WA 98109-3529
Phone: (206) 448-1010

Attorney for Plaintiff/Petitioner
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402

CALENDAR DATE: Monday, July 07, 2014 9:00 AM

WORKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,
BEFORE 12:00 NOON TWO COURT DAYS PRIOR TO HEARING
DATED:
June 13, 2014.
Signed:
NAME:
D aniel N C ook
Phone:
(253) 581-0660
ADDRESS: 5920 100th S t S W Ste 25
W SBA#:
34866
LA K E W O O D , W A 98499-2751
F o r:
1 of 1
E-FILED
June 13 2014 2:17 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

No. 14-3-01646-7
Petitioner(s),
vs.
BETH A N N KALII
R espondent(s)

Phone: (206) 448-1010



DATED:
June 13, 2014.
Signed:
NAME:
D aniel N C ook
Phone:
(253) 581-0660
ADDRESS: 5920 100th S t S W Ste 25
WSBA#:
For:
34866
LA K E W O O D , W A 98499-2751
1 of 1
v 14-3-01646-7
42776450
06-19-14
ORV
1
2
INCOUNTYCORK'S OFFICE
A.M.
\JUN l
P.M.
. K ington
'unty
Clerk
oY_
.DEPUTY
6
7
8
COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
AGREED ORDER
VACATING DEFAULT
Respondent.
14
THIS MATTER having come before the above entitled Court upon the agreement
15
16
of the parties, the court being fully advised in the premises, it is it is hereby,
17
ORDERED, ADJUDGED, and DECREED:

That the Order of Default entered on May 13, 2014, shall be and hereby is
18
19
VACATED. The matter shall be set for trial and a case schedule issued.
20
21
22
23
Dated:
JUN 1 9 2014
Juftae/Commissioner
Presented by:
fÂU BroNrTR EED ER r F R A t E /
^JBTONrÊEDE
& C O O K , P.S.

Notice
24
25

Thomas Sabin, WSBA #7748

Order Vacating Default -1

S:\CASES1\Kalii\DRAFTS\Pteadings\Agreed Order Vacating Default.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
1
2
3
4
5
6
7

10
11
12
13
No.
BETH A. KALII,
Petitioner,
DECLARATION PURSUANT TO GR
17
and
(FILING OF E-MAILED SIGNATURE)

JOHN A. KALII,
Respondent.
14
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
15
16
17
18
of Washington that the following is true to the best of my knowledge.

I am the person responsible for filing of the e-mailed signature page of the
AGREED ORDER VACATING DEFAULT.
19
I have examined the document and determined that it consists of 2 pages,
20
including this declaration page (but not including attachments), and is a complete and
21
legible image that I have examined personally and that was received by me via e-mail at
22
23
sducharme@fir-law.com.
Signed at Lakewood, WA on June 17, 2014.
24
"^Sally D0Uharme, Legal Assistant
25
D e c la r a tio n P u r s u a n t t o G R 17 - P a g e 1 o f 1
S:\CASES1\Kalii\DRAFTS\Pleadings\Declaration re E-Mailed Signature.doc
F R A L E Y & C O O K , P .S .'

Lakewood, W A 98499
Phone: (2 5 3 )5 8 1 -0 6 6 0
E-FILED
June 30 2014 2:59 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

No. 14-3-01646-7
Petitioner(s),
vs.
BETH A N N KALII
R espondent(s)
Name: DANIEL N. COOK

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

Attorney for Respondent/Defendant


DATED:
June 30, 2014.
Signed:
/s / T H O M A S R A Y M O N D S ABIN
NAME:
T H O M A S R A Y M O N D SABIN
Phone:
(206) 448-1010
WSBA#:
For:
7748
ADDRESS: 1200 W e stla ke A ve N Ste 700

S eattle, W A 98109 -3 5 2 9
1 of 1
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, V/z
June 30 2014 2:
KEVIN STO
COUNTY C.l
NO: 14-3-0'(
2
3
4
5
6
7
8

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
MOTION AND DECLARATION OF JOHN

KALII FOR TEMPORARY
(MTAF)
Respondent.I.
12
I. MOTION
13
14
15
Based on the declaration below, the undersigned moves the court for a temporary
order which:
A. Approves the parenting plan which is proposed by the Petitioner
16
17
18
B. Orders child support as determined pursuant to the Washington State child

support statutes.
C. Restrains or enjoins both parties from assigning, transferring, borrowing,
lapsing, surrendering or changing entitlement of any insurance policies of either or both
19
20
21
parties whether medical, health, life or auto insurance.

D. Makes each party immediately responsible for their own future debts whether
incurred by credit card or loan, security interest or mortgage.
E. Authorizes the family home to be occupied by the Petitioner.
22
23
Motion and Declaration for Temporary Order

Page 1
GOLDBERG & JONES Il.l.f

120(1 Westlake Ave. N., Suite 700
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABINf.GOLDBKRGJONES.COM
Dated: (C ~o-lb
9^
Thomas R. Sabin, W S b ) t7748Attorney for Petitioner
2
3
4
II. DECLARATION
Temporary relief is required because we have a minor child, KaEna who is 8
years old. Both my wife and I had been active in the raising of our daughter and the day
to day duties regarding our child. I retired from the fire department in January of 2014,
and have been providing the daily care for our daughter since that time. My wife moved
out of the family home on March 30, 2014 when I told her that we needed to discuss a
divorce action. Since that time we have been exchanging the care of our daughter each
10
week on Friday. However, as the schedule has continued it is clear the strain that it is
11
putting on our daughter, and how much time she is spending with me.
12
My wife works as a school bus driver, during the school year and during summer
13
school. During the time that we lived together she left the home at 6:30 a.m. and would
14
not return until 6:30 p.m. Since my wife moved out March 30, 2014, during the school
15
year on the weeks that our daughter is scheduled to be with her mother, our daughter
16
has been awakened at her mothers house at 5:00 a.m., driven to my house and
17
dropped off at my house at 5:30 a.m. She is often very tired and cranky. She attempts
18
to get some more sleep at my house until I get her up at 6:40 a.m. to meet the school
19
bus at 7:20 a.m. She returns to my house every day from school at 2:45 p.m. and is
20
then picked up by one of my wifes daughters from my house about 7:30 p.m. and her
21
bed time is 9:00 p.m. Additionally, from May through June she was involved in track
22
club on Monday, Wednesdays and Fridays and isnt dropped off at her mothers house
23
until 8:00 p.m. This drain on her time is impacting her development by negatively

Page 2

1200 Westlake Ave. N., Suite 700
Tel: (2(16) 448-1010- Fax: (206)440-0736
Email- TSABIN7$GOLDBEltGJOKKS.COM
impacting her sleep and will have a negative impact on her school performance if it
continues.
The Respondent is also driving for summer school and works on June 23-27,
July 7-11 and July 21-25 and then her regular school schedule will start on August 27,
2014. Assuming that the weeks with her during the summer would be the weeks of
June 30-July 4, July 14-July 18, July 28-August 1, and August 11- August 15 I would
have no problem with the alternating weeks during the summer. However, once school
starts, my proposed plan should be put into effect.
During the school schedule I am asking for one weekend per month to have our
10
daughter with me so that I can have some non school time with her to do things with her
11
and for her to spend time with her friends in the neighborhood. Otherwise, it makes little
12
sense for the health of our daughter to spend 1:55 of her waking hours with her mother
13
during the week, due to her mothers work schedule. She is picked up and dropped off
14
for the school bus every day from my house. During the 6 hours and 40 minutes she
15
spends with me she has to try to catch a nap and we can do some homework. We need a
16
parenting plan that recognizes what is good for our daughter rather than our own needs.
17
Additionally, my wife has recognized in text messages to me that our daughter wants to
18
be at my house with me.
19
I make a net income from my retirement of $4,028.91. My wife has a net income
20
of $2,160.03. I have attached to this declaration a child support worksheet. I think that
21
the court should take this into account when deciding the motions regarding the
22
distribution of my retirement funds that my wife is requesting.
23

Page 3

Tel: (206) <148-1010 - Fax: (206)448-0736
mail- TSAHliN@GOLDBERGJONKS.COM
I w o u ld p re fe r to o b ta in m y o w n h e a lth in s u ra n c e a s soon as I can. H ow e ver,
u ntil th a t is a c c o m p lish e d I d o n o t b e lie ve e ith e r p arty sh o u ld be a b le to ca nce l
in s u ra n c e th a t c o ve rs th e o th e r p arty. I d o n o t b e lie ve th a t m y w ife h as a u to in su ra n ce
th ro u g h m e o r on h e r o w n a t th is tim e . S he sh o u ld g e t s o m e in s u ra n c e on h e r ve h ic le . I
am a lso a skin g th a t m y w ife be re s p o n s ib le fo r h e r ow n d e b t in cu rre d fo llo w in g th e d a te
o f se p a ra tio n . It is a lso c le a r th a t m y w ife m ove d o u t o f m y h om e on M arch 30, 201 4
a nd has n o t re tu rn e d . S he c la im s to be m o v in g to h e r ow n a p a rtm e n t th is w e e k . I
sh o u ld b e a w a rd e d e xclu s iv e use o f m y house.
10
I d e c la re u n d e r p e n a lty o f p e rju ry u n d e r th e law s o f th e s ta te o f W a s h in g to n th a t

th e fo re g o in g is tru e and co rrect.
11
S ig n e d a t L a ke w o o d , W a sh in g to n th is 3 0 th d a y o f Ju ne , 2014.
12
13
14
15
16
17
18
19
20
21
22
23

Page 4

1 2 M W U k e A v e . N , S u ite TOO
S e a ttle , W a s h in g to n 98109
T e l: (2 0 6 ) 4 4 M 8 1 8 - F a t : (2O 6 > 8 -0 7 3 6
E m a il- T S A B IN @ G O l- D B E K G J O N F 5 .C O M

[ ] Proposed by [ ]
[ ] State of WA [ ] Other
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
Mother Beth Kalii

County PIERCE
(CSWP)
Father John Kalii

Case No. 14-3-01646-7
C h ild (re n ) and A ge(s): Ka'ena Kalii, 8

P art I: in c o m e (see Instructions, page 6)
1. Gross Monthly Income

a. Wages and Salaries
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e.Other Income
f. Imputed Income
g.Total Gross Monthly Income (add lines 1a through 1f)
2. Monthly Deductions from Gross Income
a. Income Taxes (Federal and State) T ax Y ear: M anual
b.FICA (Soc.Sec.+M edicare)/Self-Em ploym ent Taxes
c. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Mandatory Pension Plan Payments
f. Voluntary Retirement Contributions
g. Maintenance Paid
h. Normal Business Expenses
i. Total Deductions from Gross Income
3. Monthly Net Income (line 1g minus 2i)
4. Combined Monthly Net Income
5. Basic Child Support Obligation (Combined amounts
Ka'ena Kalii
$887.00
F ather
$4,352.37
M other
$2,667.00
$4,352.37
$2,667.00
$323.46
$19.86
$123.89
$5.35
$46.10
$254.11
$323.46
$4,028.91
$449.31
$2,217.69
$6,246.60
)
$887.00
6. Proportional Share of Income

.645
.355
Part II: Basic Child Support Obligation (see Instructions, paoe 7)

7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.)
8. Calculating low income limitations: Fill in only those that apply.
Self-Support Reserve: (125% of the Federal Poverty Guideline.)
a. Is combined Net Income Less Than $1,000? If ves, for each
parent enter the presumptive $50 per child.
b. Is Monthly Net Income Less Than Self-SuoDort Reserve? If ves,
for that parent enter the presumptive $50 per child.
c. Is Monthlv Net Income equal to or more than Self-Support
Reserve? If ves. for each oarent 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, 8a - 8c, but not less than the presumptive $50 per
child.
$572.12
$314.88
$1,216.00
$572.12
$314.88
10. Health Care Expenses
a. Monthly Health Insurance Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Monthly Health Care Expenses
d. Combined Monthly Health Care Expenses
11, Day Care and Special Expenses
a. Day Care Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)
e. Total Day Care and Special Expenses

(Add lines 11a through 11d)
12. Combined Monthly Total Day Care and Special Expenses
(line 11e amounts Combined)
plus line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)
Mother
Father
-
_
_
.

15. Gross Child Support Obligation (line 9 plus line 14)
$572.12
$314.88
Part V: Child Support Credits (see Instructions, page 9)

16. Child Support Credits
a. Monthly Health Care Expenses Credit
b.Day Care and Special Expenses Credit
c. Other Ordinary Expenses Credit (describe)

d.Total Support Credits (add lines 16a through 16c)
P a rt VI: S tan da rd C a lc u la tio n /P re s u m p tiv e T ra n s fe r P a ym en t (see Instructions, page 9)
17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)
$572.12
$314.88
$1,813.01
$997.96
$143.03
$78.72
P a rt VII: A d d itio n a l In fo rm a tio n a l C a lc u la tio n s
18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent)
P a rt VIII: A d d itio n a l F actors fo r C o n s id e ra tio n (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
21. Household 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
c. Gross Income from overtime or from second jobs the party
d. Income Of Child(ren) (if considered extraordinary)

Name
Name
Mother's
Household
-
Father's
Household
$36.00
e. Income From Child Support

Name
Name
f. Income From Assistance Programs

Program
Program
Father's
Household
Mother's
Household
g. Other Income (describe)
23. Non-Recurring Income (describe)
24. Child Support Owed, Monthly, for Biological or Legal Child(ren)

Name/age:
Paid [ ] Yes [ ] No
Name/age:
Paid [ ] Yes [ ] No
Name/age:
Paid f l Y e s M No
25. Other Child(ren) Living In Each Household
(First name(s) and age(s))
--------- ---------
26,
Other Factors For Consideration
WSCSS-Worksheets Mandatory (CSW/CSWP) 07/2013 Page 4 of 5
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.
Father's Signature
Mother's Signature
Date
City
Judicial/Reviewing Officer
Date
City
Date

c:..\state tempiates\waworksheet.dtf z:\supporicalc files\kalii, ]ohn\kaiii, john.scp 06/04/2014 08:25 am
SupportCalc * 2014
1
2
3
4
5
6

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
19
20
21
22
23

Page 1

Seattle. Washington 98109
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABINtffiGOLDBERGJONES.COM
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W>
June 30 2014 2:
KEVIN STO
COUNTY C.l
NO: 14-3-0'(
2
3
4
5
6
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
PROPOSED PARENTING PLAN

(PPP)
Respondent.
12
This parenting plan is a Temporary Plan proposed by the Petitioner, John Kalii.
13
14
15
I. GENERAL INFORMATION
16
17
Name
Kaena Kalii
18
Age
8
19
II.
BASIS FOR RESTRICTIONS
20
21
22
2.1

Does not apply.
23
Parenting Plan Proposed by Petitioner

Page 1

Tel: (206) 448-1010 - Fax: (206)448-0736
Kmail- TSABIN@COLDBERGJONES.COM
2.2

Does not apply.
2
3
4
III. RESIDENTIAL SCHEDULE

3.1
There is no child under school age.

3.2
Schedule for Child Under School Age
School Schedule
Upon enrollment in school, the child shall reside with the Petitioner, except for
the following days and times when the child will reside with or be with the other parent:
Every weekend except the second weekend of each month from 6:00 p.m. Friday
afternoon to be returned Sunday at 7:00 p.m.
10
11
The school schedule will start when each child begins kindergarten
3.3
12
13

The child shall reside with the father during winter vacation, except for the
following days and times when the child will reside with or be with the other parent:
In odd numbered years the child shall be with the mother from end of school to
14
15
16
December 25th at noon and the father from December 25th at noon until the start of
classes following the winter vacation. In even numbered years the child shall be with
the father from the end of school until December 25th at noon and with the mother from
December 25th at noon until 7:00 p.m. the day before classes recommence.
17
18
3.4

The child shall reside with the father during other school breaks, except for the
19
20
21
In odd numbered years the child shall spend the mid-winter break with the mother and
the spring break with the father. In even numbered years the child shall spend the
spring break with the mother and mid-winter break with the father. Mid-winter and spring
22
23
break shall begin at the end of school and terminate at 7:00 p.m. the day before school
is scheduled to restart.

Page 2
GOLDBERG & .JONES PLLC

Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABIiNrfl1COLDBKRC.MONES.COM
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the father, except
for the following days and times when the child will reside with or be with the other
3
parent:
Same as paragraph 3.2
4
5
3.6

Each parent shall be entitled to a vacation of 15 consecutive days to be
exercised during the summer vacation from school. Notice of the proposed dates for
8
9
10
2014 shall be made by July 15th. For every other year the notice of the proposed dates
of the vacation must be communicated to the other parent on or before May 15th. In the
event of a conflict in dates, mothers dates shall control in even numbered years and the
fathers proposed dates in odd numbered years.
11
12
3.7
13
14
With Father
15
16
17
18
19
20
21
22
23
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Thanksgiving Day
Christmas Eve
Christmas Day
With Mother
With paragraph 3.3

Even
Odd
Odd
Even
Even
Odd
Even
Odd
Odd
Even
Even
Odd
With paragraph 3.3
With paragraph 3.3
For purposes of this parenting plan, a holiday shall begin and end as follows (set
forth times):
Martin Luther King, Memorial Day, Labor Day shall include Saturday and Sunday
immediately preceding the holiday and shall end at 7:00 p.m.

Page 3

Tel: (206) 448-1010 - Fax: (206)4-18-0736
Email- TSABIN@GOLDBgRGJONES.COM
July 4th shall begin at 9:00 a.m. July 4th and end at noon July 5th.
Thanksgiving Day shall begin at 6:00 p.m. on Wednesday immediately preceding
3
4
Thanksgiving Day and end at Sunday at 7:00 p.m.
3.8

Mothers Day
Fathers Day
Mothers Birthday
Fathers Birthday
Kaenas Birthday
8
9
With Father
None
Every
None
Every
Odd
With Mother
Every
None
Every
None
Even
Special occasions shall begin at 6:00 p.m. the day before the special occasion
10
11
and shall end at 7:00 p.m. the day of the special occasion.
In the years the mother is not scheduled to have the child on the childs birthday,
12
13
14
the mother shall have a period of up to four hours with the child during one of the seven
days preceding the childs birthday for a birthday celebration.
3.9
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following
15
16
order:
17
3 winter vacation (3.3)

4 school breaks (3.4)
18
3.10
23
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
21
22
_1_ special occasions (3.8)
6 summer schedule (3.5) 5 vacation with parents (3.6)
19
20
2 holidays (3.7)
3.11

Page 4
GOLDBKRC & .IONICS 1'U.C

Tel: (206) 448-1010- Fax: (206)448-0736
Email- TSA!JIN(fl/GOLI)BEIUMO.NFS.COM

The receiving parent shall transport. When the child will be traveling by motor
vehicle, the child shall be secured at all times in the safety restraints as provided by
3
4
5
applicable law and any person transporting the child shall have a valid drivers license
and valid liability insurance.
3.12
The child named in this parenting plan is scheduled to reside the majority of the
6
7
time with the father. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
8
9
10
determination of custody. This designation shall not affect either parents rights and
responsibilities under this parenting plan.
3.13
If the mother will be late for, or will be unable to exercise any scheduled period of
11
12
Other
residential time with the child, the mother shall notify the father by telephone at least 48
hours prior to the scheduled beginning of the mothers scheduled residential time. If the
13
14
15
Mother is unable to provide the 48 hour notice; said notice shall be made as soon as the
mother is aware of the delay/miss of residential time. If the mother complies with this
notice requirement, the mother shall have the right to make-up residential time with the
child as established between the parents. If the mother fails to comply with the notice
16
requirement the mother shall not be permitted make-up time with the child.
17
3.14
18
19
20

26.09.480.
that person shall give notice to every person entitled to court ordered time with the child.
21
22
23
notice by personal service or by mail requiring a return receipt. This notice must be at
least 60 days before the intended move. If the relocating person could not have known
about the move in time to give 60 days notice, that person must give notice within 5
Page 5

1200 Westlake Ave. N., .Suite 700
Teh (206) 448-1010 - Fax: (206)448-0736
Email- TSABINtSlGOLDBERG.IONKS.COM
1
2
days after learning of the move. The notice must contain the information required in
RCW 26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A
Child).
3
4
5
actual notice by any reasonable means. A person entitled to time with the child may not
object to the move but may ask for modification under RCW 26.09.260.
6
7
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to

health and safety. If information is protected under a court order or the address

10
11
contempt.
12
13
14

15
16
17
07.0700, (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
18
19
20
unless: (a) the delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of
the objection, the relocating person shall not move the child before the hearing unless
21
22
there is a clear, immediate and unreasonable risk to the health or safety of a person or
a child.
23

Page 6
GOLDBERG & JONKS PLLC

Tel: (206) 448-1010 - Fax: (206)448-0736
Entail- TSABlNT7GOEDBERGJONES.COM
IV. DECISION MAKING
1
2
4.1
3
4
each child while the child is residing with that parent. Regardless of the allocation of
decision making in this parenting plan, either parent may make emergency decisions
affecting the health or safety of the children.
6
7
4.2
Major Decisions
8
Education decisions
Drivers License
Marriage prior to age 18
Entry into military prior to 18
10
11
12
4.3

Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
13
14
above.
V. DISPUTE RESOLUTION
15
16
Joint
Joint
Joint
Joint
Joint
Joint
The purpose ofthis dispute resolution process isto resolve disagreements about
carrying out thisparenting plan. This dispute resolution process may, and under some
17
18
19
local court rules or the provisions ofthisplan must be used before filinga petition to
modify the plan or a motion forcontempt forfailingto follow the plan.
20
21
22
mediation by Pierce County Center for Dispute Resolution, if this box is checked
and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation, that mediation is appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or
23

Page 7
GOLDBERG & JONES PI,IX

1200 Westlake Ave. N'., Sniff 700
Tel: (206) 448- i010 - Fax: (206)448-0736
Email- 7'SABfNfGOLDBKR<;jONTS.COM
1
50% Petitioner 50% Respondent.
3
by written request.
6
7
(a)
(b)
to resolve disputes relating to implementation of the plan, except those related to

financial support.
(c)
counseling or mediation and of each arbitration award and shall be provided to each
9
10
11
party.
(d)
process without good reason, the court shall award attorneys fees and financial
sanctions to the other parent.
12
13
(e)
the superior court.
14
VI. OTHER PROVISIONS
15
16
A.
17
18
19
Each parent shall provide the other with the address and phone number of
their residence and update such information promptly whenever it changes.

B.
Neither parent shall make derogatory comments about the other parent or
allow anyone else to do the same in the children's presence. Neither parent shall allow
or encourage the children to make derogatory comments about the other parent.
20
21
22
C.
Each parent agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the children and the
other parent, and to promote the emotions of affection, love and respect between the
children and the other parent. Said contact shall include reasonable telephone and
23
email contact with the child while away from the parent at the calling parents expense.

Page 8

Tel: (206)448-1010- Fax: (206)448-0736
Etnail-TSABIN@GOLD1IKRGJONKS.COM
1
2
All telephone calls shall be made between the hours of 5:00 p.m. and 8:00 p.m. Monday
through Friday or 9:00 a.m. and 8:00 p.m., during weekends or days where there is no
school for the child. If a parent calls and is unable to speak with the child, the parent
3
4
5
shall leave a message and the other parent shall ensure that the child calls back as
soon as is possible, but no later than 24 hours thereafter. Neither parent shall listen in
on the telephone conversations between the child and the other parent, except with the
express consent of the calling parent,
6
7
D.
All mail and packages sent to the child by a parent shall be given to the
child immediately upon arrival at the other parents residence. The parent at the childs
location shall provide any necessary assistance with opening and/or reading the
contents of the mailing container.
10
11
E.
Neither parent shall use the child to request additional or altered time with
that parent. The parenting plan shall be supported by both parents in the presence of
the child. Neither parent shall use the child as a go-between for communication with the
other parent. Neither parent shall discuss with the child or within the childs hearing any
12
13
14
disagreements or pending court actions the parents may have against the other.
F.
Each parent shall have the right to equal access to all the childs medical,
psychological, psychiatric, counseling, criminal, juvenile and education records, and to

any other information relevant to the childs best interest or welfare, including, but not
15
16
17
limited to, any records being kept by or maintained by the State of Washington
Department of Social and Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the child may reside. Any third
party having or maintain any such records is hereby authorized to release any and all
18
19
20
information upon presentation of a copy of this Parenting Plan by a parent named

herein, without the necessity of a court order or a subpoena duces tecum, unless a child
exercises a legal right to restrict access to said information. Any person, including, but
not limited to, any physician, psychologist, counselor, or educator may speak candidly
21
22
23
of or concerning he child named herein to either of the above-named parents without

court order or subpoena authorizing the same, upon presentation of a copy of this order,
unless such disclosure is prohibited by a childs exercise of statutory rights.

Page 9
GOLDBERG & JONES 1M.LC

Tel: (206) 448-1010 - Fax: (206)448-0736
1
2
G.
The childs school shall be kept informed of both parents addresses and
home and work telephone numbers, and the school shall be requested to send
information to both parents for such events as either parent requests.
3
4
5
H.
Each parent shall have equal and independent authority to confer with
school, day care and other programs with regard to the childs progress, and each shall
have free access to school, day care and other records. Each parent shall have
authority to give parental consent or permission as may be required concerning school,
6
7
day care o other programs for the child while the child is in her or her care.
I. Each parent shall have equal and independent authority to obtain information
regarding the well-being of the child, including but not limited to, copies of report cards,
school meeting notices, vacation schedules, class programs, request for conferences,
10
11
results of testing, results of diagnostic tests, notices of activities involving the child,
samples of school work, order forms for school pictures, and all communications from
all schools, regular day care providers, and counselors. Each parent shall notify the
other, as soon as that information becomes known to the parent, of any parent teacher,
12
13
14
conferences to be conducted regarding the child, and the other parent shall have the
right to attend any such conference.
J. Each parent shall have equal and independent authority to arrange routine
medical, optical, and dental services for the child, after coordinating with the other
15
16
17
parent, while the child is in his or her care and residence. The parent scheduling any
such services shall provide the other parent with the name, address and office
telephone number of said care provider.
K. If a parent obtains emergency health care for a child, the parent shall notify
18
19
20
the other parent as soon as possible of the fact that such care has been obtained, the
nature of the illness or injury and the contact information for reaching the care provider.
L. Each parent has the duty to respect the parenting style and authority of the
other parent, and neither parent shall attempt to undermine the authority of the other
21
22
23
parent with the child. Neither parent will make plans or arrangements involving the child
which would impinge upon the other parents authority or time with the child, without the
express agreement of the other parent. If a child has a grievance with a parent, the

Page 10

Tel: (206) 448-1010- Fax: (206)448-0736
Email- TSAB1NOOU)BERG.IONES.C;OM
1
2
p a re n t in q u e stio n .
M. T h e p a rtie s m a y m a ke m in o r a d ju stm e n ts, a s n ece ssary, to th e p ro visio n o f
th is P a re n tin g P la n b y a g re e m e n t. A s a p re c o n d itio n to a g re e in g to a n y su ch
3
4
5
a d ju stm e n t, e ith e r p a rty m a y re q u ire th a t a n y such a g re e m e n t be in w ritin g, d a te d and

sig n e d by b oth p a re n ts. P ro vid e d , h ow eve r, th a t in o rd e r to ch a n g e o r m o d ify the
d e sig n a tio n o f the p a re n t w h o is to h ave p rim a ry re sid e n tia l p la c e m e n t o f th e ch ild , a
p etitio n to m o d ify th e P a re n tin g P la n o r o th e r s im ila r p ro c e d u re u n d e r a p p lic a b le sta te
la w m u st b e filed .
VII. DECLARATION FOR PROPOSED PARENTING PLAN
8
9
10
I d e c la re u n d e r p e n a lty o f p e rju ry u n d e r th e la w s o f th e s ta te o f W a s h in g to n th a t
th is pla n h a s bee n p ro p o se d in goo d fa ith and th a t th e s ta te m e n ts in P a rt II o f th is Plan
a re tru e and co rrect.
11
12
^7
6 -3 0 -2 0 1 4 , L a ke w o o d , W a s h in g to n
John A. K alii
13
V III. O R D E R B Y T H E C O U R T
14
15
16
It is o rd e re d , a d ju d g e d and d e cre e d th a t th e p a re n tin g plan s e t fo rth a b o v e is a do p te d

a nd a p p ro v e d a s an o rd e r o f th is court.
W A R N IN G : V io la tio n o f re sid e n tia l p ro v is io n s o f th is o rd e r w ith actua l
17
18
19
kn o w le d g e o f its te rm s is p u n is h a b le b y c o n te m p t o f c o u rt and m a y b e a crim in a l

o ffe n se u n d e r R C W 9A .40.06Q (2) o r 9 A .4 0 .0 7 0 (2 ). V io la tio n o f th is o rd e r m a y s u b je c t a
v io la to r to a rrest.
W h e n m u tu a l d e cisio n m a kin g is d e s ig n a te d b u t c a n n o t b e a ch ie ve d , th e parties
20
21
22
sh all m a k e a goo d fa ith e ffo rt to re s o lv e th e is s u e th ro u g h th e d is p u te re so lu tio n

pro cess.
If a p a re n t fa ils to c o m p ly w ith a p ro v is io n o f th is p la n, th e o th e r p a re n ts
o b lig a tio n s u n d e r th e p la n a re n o t a ffe cte d .
23
Parenting Plan Proposed
by
Petitioner
GOLDBERG & JONES p l l c

1268 W c s fU k e A v e . N ., S u ite 708
S e a ttle , W a s h in g to n 98169
T e l: (2 0 6 ) 4 4 8-1 01 8 - F a x : (20)44JW )736
F.m srti- T S A B IN @ C O U > B K R C J O N F .S .C O M
1
2
3
4
D ated:_________________
____________________________
Judge/Commissioner
Presented by:
Approved for entry:
GOLDBERG JONES PLLC
FAUBION, REEDER, FRALEY &

COOK, P.S.
Thomas R. Sabin, WSBA 7748

Daniel N. Cook, WSBA 34866

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Parentinq Plan Proposed by Petitioner

Page 12

Tel: {206) 448-1010 - Fax: (206)448-0736
Email- 'rS A B IN @ G O L D B K R G JO N E S .C O M
1
2
3
4
5
6
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
Dated this 30th day of June, 2014 at Seattle, Washington
19
20
21
22
23

Page 1

Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSAB1N@GOU)BKRC.JONKS.COM
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 01 2014 12
KEVIN STO
COUNTY C .
NO: 14-3-0' i
2
3
4
5
6
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
SUPPLEMENTAL DECLARATION OF
JOHN KALII RE RESPONENT'S MOTION
RE USE OF PROPERTY AND PAYMENT
FROM RETIREMENT
Respondent.
12
13
I am the Petitioner in this action and make this declaration in response to the
14
motion of the Respondent for use of property and payment from my retirement fund.
15
Initially her request for the use of property has for the most part been complied
16
with at this time. The remaining issue is her demand for my bed or the couches that I
17
have. I purchased the bed before we were married and while we were not living
18
together. It was purchased at a time where she had moved out due to conflict over her
19
alcohol use and I had paid for her moving expenses in the Spring of 2009, and had
20
given her the king size bed that we had. I had to purchase a bed, which is the one that I
21
have at that time and it is my only bed. The bed that belongs to our daughter I have
22
already given to her and is a trundle bed, meaning there are actually two beds in the
23
set.
Supplemental Declaration of John Kalii re Motion for Use of Property and

Payment from Retirement.
Page 1

Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABIN(25GOLDBERGJON?ES.COM
In reply Ms. Kalii indicated that she would instead take the only couches that we
have. She has two beds already, and she has a couch and chair in her living room now.
There is no reason that my house should be stripped of the only bed that I have and the
only couch that I have.
As to her request for a portion of my pension I believe that it is also an issue that
should await the trial. Although there is a community aspect to my pension, it may very
well be offset by the community aspect to her retirement plan through the state. The
court should also take into account the $5,800 that I had to pay towards the community
income tax obligation this year. It is also to note that my pension is the only thing that I
10
receive. As a retired firefighter, I do not get social security, and a portion of this pension
11
is in lieu of social security. She did not file any bank records, so we do not know what
12
liquid assets she has available to her. Taking all of that into account, I do not believe
13
that the court should give her a portion of my pension on temporary orders. They have
14
made it clear that it is not a request for spousal maintenance, that it is a request for a
15
distribution of an asset.
16
In reviewing Ms. Kaliis financial declaration she has significantly understated her
17
income. In the one pay stub that she provided her gross earnings through April 30,
18
2014 year to date were $10,556.35. That is an average monthly gross salary of
19
$2,639.08 per month. If you look at her income figures for the prior year the average
20
salary was $2,667.00 per month. I believe her monthly base salary is spread out over
21
12 months even though it is earned late August through June of the following year.
22
Additionally, this year she is driving for summer school which will increase her salary by
23
the earnings made during the summer. Further, her financial declaration does not take

Page 2

1200 Westlake Ave. N.. Suite 700
Tel: (206) *148-1010 - Fas; (206)448-0736
Email- TSABIN@GOLDBERG.JONES.COM
into a c c o u n t th e m o n e y th a t i h ave paid to her, a nd w ill c o n tin u e to p a y to h e r fo r m y
insu ra n ce , u ntil I can o b ta in a d d itio n a l in s u ra n c e and m y c o n trib u tio n to o u r c h ild s
h e a lth in su ra n ce . I paid h e r $ 4 5 8 .6 5 fo r w h a t I c o m p u te m y p ortion a nd m y co ntribu tion
to o u r d a u g h te rs h e a lth in s u ra n c e on Ju n e 22, 2 01 4. M y w ife s fin a n c ia l d e c la ra tio n
a lso o v e rs ta te s h e r g a s e xp e n s e as sh e w o rk s o n ly 10 m in u te s fro m h e r house.
S h e c h o se to m o ve into a d u p le x on a la k e fo r $ 8 5 0 p e r m on th w h e n th e re are
m a n y e q u a lly n ice a p a rtm e n ts th a t g o fro m $ 6 5 0 to $ 7 5 0 in th e a re a. W ith o u t a fu ll
d is c lo s u re o f h e r inco m e , and fin a n c ia l re s o u rc e s it is n o t c le a r th a t s h e h as a ny
fin a n c ia l n e e d fo r a d d itio n a l in co m e fro m m e. A d d itio n a lly , I m ove d h e r 2 9 y e a r o ld
10
d a u g h te r to h e r h o u se y e s te rd a y and I b e lie v e th a t s h e w ill be c o n trib u tin g to th e co sts
11
o f th e re n t a nd u tilitie s. I h a v e e xh a u s te d v irtu a lly all o f m y 4 5 7 (b ) pla n to p a y o ff o u r
12
d e b ts b e fo re th is a ctio n w a s file d . I am livin g on a fix e d inco m e , h a vin g retire d in
13
J a n u a ry o f 2 0 1 3 , n o t 2 0 1 4 a s in c o rre c tly sta te d in a d iffe re n t d e c la ra tio n . G ive n m y
14
c u rre n t d e b ts and livin g e xp e n s e s and c a rin g fo r o u r d a u g h te r, I s im p ly do n o t h a v e any
15
e xtra m o n e y to p a y to her.
16
17
18
T h is d e c la ra tio n is g ive n u n d e r p e n a lty o f p e rju ry o f th e la w s o f th e S ta te o f

W a s h in g to n and is tru e a nd c o rre c t to th e b e s t o f m y k n o w le d g e .
S ig n e d a t L a ke w o o d , W a s h in g to n on
______ , 201 4.
19
20
21
22
23

Page 3

12 00 W c s tia k e A v e . N n S u ite 7 00
S e a ttle , W a s h in g to n 9 3109
T d : (2 0 6 ) 4 4 S - 1 B I0 - F a i: < 2 0 fi> 4 48 ^7 36
Kmafl* TSABm@GOLOBERGIONES.COM
1
2
3
4
5
6
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
Dated this 1st day of July, 2014 at Seattle, Washington
19
20
21
22
23

Page 1

1200 Wcsllako. Ave. N Suilc 700
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- 'rSABIN@GOLOBKRGJONES.COM
E-FILED
IN COUNTY C L E R k
PIERCE COUNTY, W
July 01 2014 1 2
KEVIN STO
COUNTY C .
NO: 14-3-0'i
2
3
4
5
6
7
8

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
CERTIFICATE OF
PARENTING CLASS
COMPLETION
OF
Respondent.
12
Attached is a copy of the Certificate of Completion for the Dont Forget the Kids
13
14
seminar.
15
16
17
18
19
20
21
22
23
Page 1

Tel: (206)448-1010- Fax: (206)4-18-0736
Email- ISA IMNVnXiOLPBFRG.lONKS.COM
Case number: H - 3 - O U I M / p - 7 ____________

Case names:
A- KALII_________ & Ttt

Petitioner
A .
(CAL11
Respondent
To All Those To Whom This Letter May Come
The Institute for Childrens A d v o c ac y

Is pleased to announce that:
John
k ^ a lii
Has successfully completed a Four Hour seminar
Dont Forget the Kids

And, having such distinction and perspicacity in regard to the course, is
hereby granted this
Certificate of Completion
Dated this 23rd day of June, 2014
In the City of Lakewood, State of Washington
Instructors:
Susan (PeRome, 94..(E d
R o b e rt Steger, M S W
E-FILED
PIERCE COUNTY, W ASHINGT
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

COUNTY OF PIERCE
8
9
10
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
11
and
Cover Page for Job Performance

Evaluations
12
BETH A. KALII,
Respondent.
13
14
COMES NOW attorney for Respondent, Daniel N. Cook, and presents to the
15
16
court the attached job performance evaluation of Respondent.
17
18
DATED this
day of July 2014.
19
20

21
22
23
24
C o v e rp a g e - P age 1 o f 1
S:\CASES1\Kalii\DRAFTS\Pleadings\Coverpage.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
CLOVER PARK SCHOOL DISTRICT

CLASSIFIED
SHORT EVALUATION FORM
E m p lo yee s Nam e Beth Kalii___________________________________________

E m ployee S chool/W ork Site Transportation_____________________________
E valuator's Nam e V irginia Preston______________________________________
Date o f Evaluation M ay 9, 2014________________________________________
T he above nam ed e m ployee has m et his/her jo b duties and responsibilities.
C om m ents:
Ms. Beth Kahlii is a positive influence on her students. She is able to com m unicate effectively w ith
students, coworkers, school staff, and the com m unity. Ms. Kahlii dem onstrates th a t she possesses the
specialized skills needed in o rd er to drive her bus safely. She is able to successfully com plete tasks that
are assigned to her at a m om ents notice. Beth is very dependable and conscientious in the jo b that she is
doing each day.
Date
E m ployee Signature
Date
DISTRIBUTION: Original - Personnel
Copy - Evaluatee Copy - Evaluator

CLASSIFIED
E m ployees Nam e Beth Kalii___________________________________________

Em ployee S chool/W ork Site T ransportation D epartm ent_________________
E valuators Name D elohie Nielsen______________________________________
Date o f Evaluation A pril 27, 2013_______________________________________
T he above nam ed em ployee has m et his/her job duties and responsibilities.
C om m ents:
Beth Kalii daily interactions w ith s ta ff has been professional and appropriate. H er perform ance m eets or
e xceeds departm ent sta nd ard o f expectations as it relates to interactions with students, attendance,
driving abilities and personal responsibilities (i.e., accurate reporting o f tim e). Beth has been utilized by
the dispatchers at a m om ents notice to assist the team due to a b se n ce o f a nother sta ff m em ber, lost staff
or forgotten students. She openly accepts these changes to her routine and schedule.
T ha nk you Beth fo r being a g re a t m em ber o f the team and m odel for others.

CLASSIFIED
Em ployees Name
Beth Kalii__________________________________________
Em ployee School/W ork Site

Evaluators Name
Transportation / ASC______________________
Paul Vigil__________________________________________
Date o f Evaluation May. 2012__________________________________________

The above named em ployee has m et his/her job duties and responsibilities.
C om m ents:
Beth is an excellent bus driver; she is self-m otivated and com pletes her daily duties with little or no
supervision. She is alw ays w illing to help out and does on a regular basis.
Beth has very few student
discipline issues on her bus as she is very active in preventing problem s before they start. Dispatch has
been able to use Beth on a fe w o ccasions to help during the activity time, to a ssist other buses that have
student discipline issues and no one else is available to assist from the office. T ha nk you for a great year.
I look forward to w orking with you again next year.

CLASSIFIED
Em ployee's N am e Beth Kalii___________________________________________

Em ployee S ch oo l/W o rk Site T ransportation_____________________________
E valuators Nam e V irginia Preston______________________________________
Date o f Evaluation M ay 4, 2011________________________ ________________
T he above nam ed em ployee has m et his/her job duties and responsibilities.
C om m ents:
Ms. Beth Kalii m akes a positive im pact on the students w ho ride her bus. She com m unicates with
credibility and confidence with cow orkers, school staff, and the com m unity. Ms. Kahlii dem onstrates a
high level o f com petence in the driving o f her bus. She displays a strong com m itm ent to successfully
com pleting all ta sks th a t are assigned to her. She follow s a variety o f approaches in activities and
techniques.

CLASSIFIED
E m ployees N am e
Beth Kalii__________________________________________
Em ployee S ch oo l/W o rk Site
T ransportation___________________________
Evaluator's N am e
V irginia Preston / D elphie Nielsen___________________
Date o f Evaluation
05/17/10______________________________ ____________
The above nam ed em ployee has m et his/her jo b duties and responsibilities.
C om m ents:
Beth m aintains a positive attitude when under stress and adapts well to change. She is professional and
appropriate in her com m unications with everyone in transportation. She is w illing to ask fo r help from
transportation and school sta ff when needed. She m eets or exceeds the expectations o f the
transportations departm ent.

CLASSIFIED
E m ployees N am e Beth G ilm ore________________________________________

Em ployee S ch o o l/W o rk Site T ransportation D epartm ent__________________
E va lua to rs Nam e D elphie N ielsen / K enneth Bryant______________________
Date o f Evaluation A pril 28, 2008_______________________________________
T he above nam ed em ployee has m et h is/h e r jo b duties and responsibilities.
Com m ents:
Ms. G ilm ore's perform ance as a bus d rive r m eets d epartm ent's expectations as outlined in th e class
specification. She reg ula rly perform s her dutie s and re sp o n sib ilitie s w ithout notice and interacts w ith
d epartm ent staff, school peers in a professional app ro priate manner.
Ms. G ilm ore has been utilize d th ro ug h ou t the y e a r to co ve r va riou s routes and is alw ays w illing to
support her co-w orkers and the departm ent.
D uring this rating period Ms. G ilm ore received a docum ented w ritten w arning fo r a tra ffic infraction.
Mrs. G ilm ore attended the Kids at Hope training, she show s a strong com m itm ent to the students and
com m unity that everyone is capable o f success, no exceptions.
T h a n k you fo r a g re at school year.
Em ployee S ignature
Date
S u pe rviso r Signatured
Date

CLASSIFIED
Employees Name
Beth Beliveau-Gilmore__ _______________________
Employees School/Work Site
Transportation Department____________
Evaluators Name
Delohie Nielsen________________________________
Date of Evaluator
5/19/2009_____________________________________
The above named employee has met his/her job duties and responsibilities.
Comments:
Ms. Beliveau-Gilmores performance as a bus driver meets the expectations as outlined in the class
specifications. During this year, Ms. Beliveau-Gilmore was presented with various student behavior
challenges. Once we were able to clearly define the roles of each team member, set expectations for
students; provide consistent service and consequences the challenges were reduced. This could not have
been accomplished without Ms. Beliveau-Gilmores open mindedness and desire to be an effective
resource in her students' day.
Thank you for your hard work and commitment to those students you transport.
Date
!fh M
Date
Copy - Evaluatee
Copy - Evaluator

CLASSIFIED
E m p lo yee 's N am e Beth G ilm o re ________________________________________

E m p lo yee S ch o o l/W o rk S ite T ra n spo rta tio n D epartm ent__________________
E va lu a to rs N am e D elohie N ielsen / Kenneth Bryant______________________
D ate o f E valuation M av 17, 2007_______________________________________
T h e above nam ed e m ployee has m e t h is/h e r jo b duties and responsibilities.
C om m ents:
Ms. G ilm o re's perform ance as a bus d riv e r m eets d epartm ent's e xpe cta tio n s as outlined in the class
sp ecificatio n. She regularly p erform s her d utie s and responsibilities w ith o u t notice and interacts with
d e p a rtm e n t sta ff, school peers in a professional appropriate m anner.
M s. G ilm o re has been u tilize d th ro ug h ou t th e y e a r to c o v e r va rio u s routes to su pp ort her co-w orkers and
th e d e p artm en t during e xcessive absences.
T h a n k you fo r a g re a t school year.
DISTRIBUTION: Original - Personnel Copy - Evaluatee Copy - Evaluator

CLASSIFIED
Em ployees N am e Beth G ilm ore________________________________________

Em ployee S ch oo l/W o rk Site T ransportation D epartm ent_________________
Evaluators N am e D elphie Nielsen / Bruce G ardner______________________
Date o f Evaluation M ay 17. 2006_______________________________________
T he above nam ed em ployee has m et his/her jo b duties and responsibilities.
C om m ents:
Mrs. G ilm ore's perform ance as a bus driver m eets departm ent's expectations as outlined in the class
specification. She regularly perform s her duties and responsibilities w ithout notice and interacts with
departm ent staff, school peers in a professional appropriate m anner.
T hank you fo r a g re at school year.
C lover Park School D istrict No. 40.
ANNUAL PERFORMANCE EVALUATION

Em ployee Beth G ilm ore______________________________________ Date M ay 17, 2005________________________________
Position Bus D river__________________________________________
D epartm ent T ransportation D epartm ent
PURPO SE:
W hen com pleted, this perform ance appraisal will serve as a guide fo r adm inistrative review o f an e m p lo ye e's status and
perform ance with the Em ployer.
It will be the im m ediate supe rviso r's responsibility to review and approve the cu rren t jo b description and to m a ke the
prim ary evaluation o f those em ployees w orking w ithin his or her area o f responsibility w ith the division a dm in istrato rs
approval.
A full and fra n k discussion w ith an em ployee concerning his or her w ork perform an ce is required. It w ill contribute toward
a better relationship betw een the em ployee and supervisor if conducted sincerely and wisely.
PROCESS:
Utilizing the key
done during the
responsibility or
individual rarely
each rating.
outlined below, rate the level o f perform ance o f each job responsibility and w ork trait on the basis o f w ork
year. Do not let your appraisal o f one responsibility or w ork tra it influence your rating o f another
w ork trait. Do not consult or recall prior ratings. You will be m ore o bjective if you fo rg e t them . One
m erits identical ratings in every responsibility or w o rk trait. Be se le ctive m ake independent decisions on
C onsider Overall P erform ance w ithout undue em phasis on recent or infrequent o ccurrences.
U nder C om m ents you m ust explain individual ratings and/or m ake recom m endations fo r a prom otion, tra n sfe r or further
training needs.
A ny recent C hanges in Job R esponsibilities (typical w ork) m ust be recorded on the last page fo r fu tu re review.
PE R FO R M AN C E KEY:
* 1. O utstanding (exceptional high level o f perform ance and ability).
2. S uperior (perform ance and ability above the average level).
3. Average (perform ance and ability adequate and acceptable).
* 4. Below expected level.
5. N /A (not applicable).
______* M ust be substantiated by a conference report or notation from adm in istrato r / supervisor.
Copy - Supervisor/Division Copy - Employee
Page 1 of 5
JOB RESPONSIBILITIES (typiCc.. .ork as listed in approved job description)

TO BE COMPLETED BY IMMEDIATE SUPERVISOR
PERFORMANCE
KEY
1. Operates school buses on assigned routes and trips in accordance with state and district policies.
2. Practices defensive driving at all times and displays courtesy to other vehicle operators.
3+
3. Operates bus with mechanical efficiency at all times and in an appropriate manner.
4. Completes necessary paperwork, including daily bus logs and vehicle reports in accordance with district policy.
5. Maintains student discipline on the bus, completes misconduct reports in accordance with district policy.
3+
6. Performs daily vehicle inspection, fueling and interior cleaning of the bus as outlined in district procedures.
7. Works cooperatively with other school district personnel.
3+
8. Attends state-mandated training classes and district safety meetings as required.
9. Maintains a current first aid card and Washington State School Bus Drivers permit
10. Maintains good public relations within the district and community.
Page 2 of 5
W O R K T R A IT S (P le a s e co n tin u e
j s e k e y to d e s c rib e p e rfo rm a n c e .)
1
A T T IT U D E
Willingness to adjust to change

D egree o f interest and enthusiasm
M J J D
C O M M U N IC A T IO N
Ability to convey ideas and plans
W ritte n
Oral
C O O P E R A T IO N
Ability to work with and through others including:

S upervisor
Peers
Subordinates
G o vernm e nt officials, educators, etc.
D E LE G A T IO N
A bility to e ffectively assign w ork to others
D E P E N D A B IL IT Y
P erform ance
A ttendance
C onfidentiality
X
X I
XI
P R O F E S S IO N A L G R O W TH
Ability to develop attitudes, knowledge, and skills in:

S elf
Subordinates
PLA N N IN G
A b ility to plan ahead in order to m eet changing needs
H E E D
JU D G M E N T
A b ility to arrive consistently at (a) sound decision(s).
O R G A N IZA T IO N
Ability to effectively organize time and effort on:
r a n
W o rk assignm ents
T E C H N IC A L S K IL L S
- As required by jo b description
im m
V O LU M E O F W O R K
Ability to produce expected results:

in a given tim e.
C U R R E N T O V E R A L L PE R FO R M A N C E
Page 3 of 5
H a v in g ra te d e a c h r e s p c .. J b i l i t y a n d w o r k t r a it,
p le a s e in d ic a te w h a t th e e m p lo y e e s o v e r a ll
p e r fo r m a n c e is in h is o r h e r p r e s e n t p o s it io n .
EC
Page 4 of 5
CHANGE IN JOB RESPONSIBII__ cS (Please list any recent m ajor changes1

feel should be review in the fu tu re by the School District.)
le e m p lo ye e's responsibilities that you
TO BE COMPLETED BY EMPLOYEE/SUPERVISOR
C O M M E N T S : Mrs. G ilm ore continues to perform her duties and responsibilities w itho ut notice as it relates to the class
specification o f school bus driver. She has gained and developed her know ledge, abilities and experience in w orking with
students with disabilities. H er u pbeat personality assists her in her overall p erform an ce o f providing excellent service for
NOTE: It is understood that in signing the evaluation form, the employee acknowledges having seen and discussed the contents with his or her
immediate supervisor.
Page 5 of 5
C lover Park School D istrict No. 4o^
90-Day Performance Evaluation

Em ployee Beth Gilmore______________________________________ Date N ovem ber 24, 2004__________________________
Position Bus Driver__________________________________________ D epartm ent Transportation_________________________
PU R PO SE:
W h e n com pleted, this perform ance appraisal will serve as a guide fo r adm inistrative review o f an em ployees status and
perform ance with the Em ployer.
It will be the im m ediate su pe rviso rs responsibility to review and approve the current jo b description and to m ake the
prim ary evaluation of those em ployees w orking within his or her area o f responsibility w ith the division a dm inistrators
approval.
A full and frank discussion w ith an e m ployee concerning his or her w o rk perform ance is required. It will contribute toward
a better relationship between the e m ployee and supervisor if conducted sincerely and wisely.
PR O C ESS:
Utilizing the key
done during the
responsibility or
individual rarely
each rating.
outlined below, rate the level o f perform ance o f each jo b responsibility and w ork trait on the basis o f work
year. Do not let your appraisal o f one responsibility or w o rk trait influence your rating o f another
w ork trait. Do not co n su lt or recall prior ratings. You will be m ore objective if you fo rg et them . One
merits identical ratings in every responsibility or w ork trait. Be selective, M ake independent decisions on
C onsider O verall Perform ance w itho ut undue em phasis on recent or infrequent occurrences.
U nder C om m ents you m ust explain individual ratings and/or m ake reco m m en d atio ns fo r a prom otion, tran sfe r or further
training needs.
A ny recent Changes in Job R esponsibilities (typical w ork) m ust be recorded on the last page fo r future review.
P E R FO R M A N C E KEY:
* 1. O utstanding (exceptional high level o f perform ance and ability).
2. Superior (perform ance and a bility above the average level).
3. Average (perform ance and a bility adequate and acceptable).
Below expected level.
^5 J N /A (not applicable).
* Muu st be substantiated by a co nference report or notation from a dm in istrato r / supervisor.
Page 1 of 5
J O B R E S P O N S IB IL IT IE S (typit
work as listed in approved job description)
TO BE COMPLETED BY IMMEDIATE SUPERVISOR

1. Operates school buses on assigned routes and trips in accordance with state and district policies.
PERFORMANCE |
KEY
3
______________
2. Practices defensive driving at all times and displays courtesy to other vehicle operators.
3. Operates bus with mechanical efficiency at all times and in an appropriate manner.
4. Completes necessary paper work, including daily bus logs and vehicle reports in accordance with district policy.
5. Maintains student discipline on the bus, completes misconduct reports in accordance with district policy.
6. Performs daily vehicle inspection, fueling and interior cleaning of the bus as outlined in district procedures.
7. Works cooperatively with other school district personnel.
8. Attends state-mandated training classes and district safety meetings, as required.
9. Maintains a current first aid card and Washington State School Bus Drivers permit.
10. Maintains good public relations within the district and community.
1
r
______________
J
1
______________ j|
f
Page 2 of 5
(
W O R K TR A ITS (Please contini^ .j use key to describe performance.)
1
A TTITU D E
Willingness to adjust to change

Degree of interest and enthusiasm
im n
C O M M U N IC A TIO N
Ability to convey ideas and plans
X
X
Written
Oral
C O O PER A TIO N
Ability to work with and through others including:

Supervisor
Peers
Subordinates
Government officials, educators, etc.
X
X
X
X
D ELEG ATIO N
Ability to effectively assign work to others
D E P EN D A B ILITY
X
X
Performance
Attendance
Confidentiality
PR O FE SS IO N A L G R O W TH
Ability to develop attitudes, knowledge, and skills in:

Self
Subordinates
PLANNING
Ability to plan ahead in order to meet changing needs
JU D G M E N T
Ability to arrive consistently at (a) sound decision(s).
O R G A N IZA TIO N
Ability to effectively organize time and effort on:
M JO D
W ork assignments
TE C H N IC A L S K ILLS
As required by job description
VOLUM E OF W O RK
Ability to produce expected results:
M I
in a given time.
C U R R E N T O V ER A LL P ER FO R M A N C E
Page 3 of 5
H a v in g ra te d e a c h re s , v is ib ility a n d w o r k tr a it,
p le a s e in d ic a te w h a t th e e m p lo y e e s o v e r a ll
p e r fo r m a n c e is in h is o r h e r p r e s e n t p o s itio n .
Page 4 of 5
C H A N G E IN J O B R E S P O N S I eL
TIES (Please list any recent major change^ .. i the employee's responsibilities that you
feel should be review in the future by the School District.)
T O B E C O M P L E T E D B Y E M P L O Y E E /S U P E R V IS O R
C O M M EN TS: Mrs. Gilmore's positive, willing to learn and make a difference personality has assisted her in becoming
very versatile in her abilities and knowledge. As an alternate and regular driver, Mrs. Gilmore is able to perform any route
assigned to her without incident, at various times these routes were assigned at a moments notice. Mrs. Gilmore's ability
to adapt and adjust is evident by her transition ease from driving a regular bus route to driving a special service bus route.
I encourage Mrs. Gilmore to regularly review her resources (i.e., department employee and Washington.State School Bus
//
EMPLOYEE
3 > '0 < /

DATE
'
NOTE: It is understood that in signing the evaluation form, the employee acknowledges having seen and discussed the contents with his or her
immediate supervisor.
Page 5 of 5
E-FILED
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

COUNTY OF PIERCE
8
9
10
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
11
and
12
BETH A. KALII,
MOTION FOR AN ORDER

SHORTENING TIME
Respondent.
13
I.
14
Relief Requested
15
BETH KALII, Respondent, moves the court for an order shortening the period of
16
time required for a hearing regarding a Motion for Temporary Order to be heard on July
17
14, 2014, when the parties are scheduled to be in court on this matter for a hearing on
18
Petitioners motion.
19
20
This motion is based upon the Motion and Declaration for Temporary Order
submitted herewith.
21
Respectfully submitted on July
, 2014.
22
F/^ B I O ^ E ^ D |^ F R A L E Y & COOK PS
23
24
Daniel Cook, WSBA 34866

25
M o tio n f o r a n O r d e r S h o r te n in g T im e - P a g e 1 o f 1
Kalii, John an d Kalii, Beth

S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Order Shortening Time.docx

Lakewood, W A 98499
253-581-0660
1
2
3
4
5
6
7

COUNTY OF PIERCE
8
9
10
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
11
ORDER SHORTENING TIME
and
12
BETH A. KALII,
Respondent.
13
14
15
16
This matter having come before the court on Respondents Motion for Order
Shortening Time, the court having reviewed the records and court files herein and
otherwise deeming itself fully advised, it is hereby ORDERED:
17
The motion is GRANTED; time for hearing the motion for temporary order is
18
shortened and the hearing date is set for July 14, 2014, at 9:00 a.m.
19
20
Dated:
Judge/Commissioner
21
22
Presented by:



23
24
25
O r d e r S h o r te n in g T im e - P a g e 1 o f 1
Kalii, John an d Kalii, B eth

S:\CASES1\Kalii\DRAFTS\Pleadings\Order Shortening Time.docx
5920-100 S treet SW , Ste 25

253-581-0660
E-FILED
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10

COUNTY OF PIERCE
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
11
and
12
BETH A. KALII,

Order
(MTAF)
Respondent.
13
I. Motion
14
15
which:
16
17
18
19
20
Orders child support as determined pursuant to the Washington State child

support statutes.
Approves the parenting plan which is proposed by BETH KALII.
Requires JOHN KALII to pay temporary attorney fees, other professional fees and
costs in the amount of $1,500 to: Faubion, Reeder, Fraley & Cook, P.S.
21
DATED this 3
day of July 2014.
22
23

24
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion forTemporary Order 2.doc

253-581-0660
1
II. Declaration
2
3
4
5
See Declaration of Beth Kalii in Response to Petitoiners motion for temporary order
which is incorporated herein by this reference,
,o
^
7?-ffpo
pfifl 7 1 f S
f a / i ^ ^ T J ^ C
6
7
8
Signed at (city)
L- /)x caAjo>o _______, (state)
on (date) _
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
K alii, B e th a n d K alii, J o h n
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order2.doc

253-581-0660
E-FILED
PIERCE COUNTY, W A SH IN G '
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
COUNTY OF PIERCE
10
11
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
12
and
13
BETH A. KALII,
Proposed Parenting Plan

(PPP)
Respondent.
14
15
This parenting plan is proposed by the Respondent, BETH A. KALII.
16

17
18
19
20
Name
Age
KAENA KALII
21
22
23
24
2.1

Does not apply.
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
. 181;. 187;. 194

Lakew ood W A 98499
253-581-0660
1
2.2
Other Factors (RCW 26.09.191 (3))
2
Does not apply.
3
4
5
6
7

The residential schedule must se t forth where the child shall reside each day o f the
year, including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the child shall have with each parent. Parents
are encouraged to create a residential schedule that m eets the developmental needs of
the child and individual needs of their family. Paragraphs 3.1 through 3.9 are one way
8
3.1
10
11
3.2
School Schedule
following schedule:
12
13
other will be on Fridays after school or at 2:00 p.m. if there is no school.
14
15
3.3
16
17
18
19
20
21
22
23
24

. 181;. 187;. 194

253-581-0660
3.4
2
3
by the parties.
4
5
6
7
3.5
Summer Schedule
8
9
10
11
3.6

12
13
14
15
16
17
18
19
20
21
22
23
24
3.7

With Father
With Mother
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
New Years Day
See Par. 3.3
See Par. 3.3
Presidents Day
Memorial Day
Easter
Odd
Even
July 4th
Even
Odd
*
*
Labor Day
Veterans Day
Odd
Even
Even
Thanksgiving Day
Odd
See Par. 3.3
Christmas Eve
See Par. 3.3
See Par. 3.3
See Par. 3.3
Christmas Day


253-581-0660
1
2
4
5
3.8
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
14
15
Occasion.
16
17
18
3.9
19
20
4
2
holidays (3.7)
school breaks (3.4)
6
1
3
5
21
22
23
24
3.10
Restrictions
Does not apply.
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP doc
. 181;. 187;. 194

253-581-0660
3.11
2
3

school care hours.
5
6
7
8
3.12
10
11
12
3.13
Other
13
Neither parent shall consume non-prescribed drugs or alcohol in excess of the
legal limit to drive while he or she is personally caring for the child.
14
15
The father shall provide proof of treatment for his alcohol addiction issues.
16
17
18
19
20
21
22
23
24
3.14

26.09.480.
the child.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187;. 194


253-581-0660
1
2
3
4
5
6
7
8
9

10
11
12
contempt.
13

14
15
16
17
18
19
move.
20
21
22
23
IV. Decision Making

24
4.1
WPF DR 01.0400 Mandatory (6/2008) - RC W 26.09.016, .181; .187; .194


2 53-581-0660
1
2
3
4.2
Major Decisions
Education decisions
joint
joint
joint
(e.g., cold, flu, allergy, earaches, anti-biotic, short term prescriptions etc.)
8
9
10
11
12
13
14
15
16
17
18
19
20
4.3

21
22
23
24
carrying out this parenting plan. This dispute resolution process may, and under som e


253-581-0660
1
2
3

5

6
7
8
9
10
11
12
13
14
(a)
(b)
(c)
(d)
(e)
the superior court.
15

16

17
18
19
20
21
22
23
24
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187; .194


253-581-0660
1
2
3
4
5
6
7
8
9
10
11
12
13
durations.

good faith and that the statements in Part II of this Plan are true and correct.
14
15
16
17
" / ( 3> / Z d / y
18
19
20
21
22
23
24
Dated:________________________________
____________________
Judge/Commissioner
S:\C4SES1\Kalii\DRAFTS\Pleadings\PPP.doc
. 181;. 187;. 194

253-581-0660
1
2
Presented by.





3
4
5
6
7
Date
Date
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
.181;. 187;. 194

253-581-0660
E-FILED
PIERCE COUNTY, WASHINGT
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
RESPONSE DECLARATION OF
BETH KALII
Respondent.
14
15
16
response to Petitioners Motion for Temporary Order and Proposed Parenting Plan filed
17
on June 30, 2014.
18
SUMMARY
19
20
21
22
1. The court deny Petitioners motion for parenting plan designating him as the
Primary parent.
2. The court should adopt my proposed parenting plan maintaining the equally
shared residential schedule with both parents as co-primary parents.
23
3. The court should order child support paid to me with a slight deviation for
24
Petitioner based upon the residential time the child spends with him.
25
Response Declaration of Beth Kalii - Page 1 of 7

Kalii, John and Kalii., Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Response Declaration ofBeth Kaliire Parenting.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
253-581-0660
1
4. The court should award me attorneys fees and costs incurred in bringing this
2
motion.
3
PARENTING PLAN
4
5
JOHN and I began living together in 2006. We had a child, KAENA KALII, on
June 27, 2006. JOHN voluntarily chose not to be present at the hospital with me when
KAENA was born. JOHN kicked me out of his house five days after KAENA was born.
Eventually, we got back together and we began living together again in 2007. We were
married on November 21,2009. We permanently separated on March 30, 2014.
10
11
12
Since we separated in March 2014 KAENA has been spending equal residential
time in both of our homes. After we separated JOHN went to We The People and
prepared dissolution documents. JOHN told me since he was retired and l was working
13
he would get custody if it was contested; however, JOHN told me if I would not ask for
14
any money from him he would agree to a 50/50 parenting schedule.

15
I agreed that a 50/50 parenting schedule would be in KAENAs best interest;

16
17
however, there were other (financial) issues we did not agree. So JOHN filed for
18
dissolution and asked for primary placement in his proposed parenting plan.
19
JOHN filed for dissolution and filed a proposed parenting plan asking for primary
20
placement we continued to follow the week on/week of (50/50) schedule.
21
after I filed a motion asking for JOHN to pay the cost of his health care insurance and for
22
one-half of the community portion of his retirement that he brought this motion to change
23
the residential schedule.
Even after
It was not until
JOHN is totally focused on money. As soon as I hired an
24
attorney he kicked my daughter out of his house and wrote her a note saying:
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 2 o f 7

253-581-0660
1
I dont like doing this, but Im going to have to ask you to find
2
another place to stay. Your Mom has an attorney and is

3
trying to get a ton of money from me now. I cant afford this

4
and I may end up giving this house back.
Attached as Exhibit A is a true and correct copy of the note he left my daughter.
JOHN is trying to punish me for asking him to pay his own insurance and for one-
half of the community portion of the retirement. I did not even ask for child support in my
initial motion. We were operating under a 50/50 parenting plan and it was working very
10
well for KAENA. But after I filed a motion asking for financial relief JOHN told my other
11
12
adult daughter she had to move out and then filed his own motion to only allow KAENA
to spend weekends with me.
13
Aside from being totally financially motivated, the picture that JOHN paints in his
14
declaration about the parenting plan is totally misleading and false. It omits crucial
15
information.
16
17
First, JOHN neglects to inform the court that for about one month after we
18
separated I formally added a stop to my bus route so that I could pick KAENA up from
19
the home where I was living with a roommate. So I would leave for work in the morning
20
and KAENA could stay in bed because my roommate was home and KAENA would not
21
have to wake up until her normal time to get on the bus outside of my house. That
22
schedule was in place for about a month until my roommate had surgery and I did not
23
want to leave KAENA with her in the mornings for the last week of school.
24
25

253-581-0660
1
Second, for the very first month after I moved out, while I was in the process of
2
getting the new stop on my route established at my home, I lived 15 minutes away from
3
JOHN. I agree that it was not ideal to wake KAENA up early when I was leaving - but
4
5
also I do not think it was as bad as JOHN suggests. First, I did not wake KAENA up at
5:00 a.m. I had to be at work at 6:00 a.m. and I dropped KAENA off at his house at 5:45
a.m. so I woke KAENA up between 5:15 and 5:30. Many children have to get up early
when their parents leave for work early in the morning. Nevertheless, if the early wake-
up could be avoided I would avoid it and that is why I added the stop to my route.
10
11
12
Next year things will be substantially different. When we separated in April 2014 I
was already under contract for the school year so I was stuck in the shift that required me
to clock in at 6:00 a.m. Next year, I will contract for a different route even though that
13
means I will not be KAENAs bus driver.
But I have been driving school buses for many
14
years, and I am number 33 in seniority out of 100 drivers in my district. So I have a very
15
substantial number of choices of routes. I can very easily contract for a route that
16
17
18
19
requires me to clock in at 7:00 a.m. and then I will not have to drop KAENA off until 6:45
a.m.
Another big change now versus last school year is that I have moved from the
20
temporary place I was sharing with a roommate immediately after separation and have
21
established my own residence. My duplex is only 0.36 miles away from JOHNS
22
residence. Attached as Exhibit B is a true and correct copy of a Mapquest print-out
23
showing how close our residences are now.
Because I can now change to a 7:00 a.m.
24
route and because I now live less than 5 minutes away from JOHN I will not have to wake
25
S:\CASES1\Kalii\DRAFTS\Pleadings\Response Declaration ofBeth Kaliire Parenting doc

253-581-0660
KAENA up until 6:30 a.m. which is only 10 minutes earlier than JOHN alleges she wakes
2
up in his home.
3
Another change that has occurred is that my adult daughter is now residing with
4
5
me (after JOHN kicked her out as discussed above).
She is sharing the duplex with
KAENA and me and depending upon her work schedule I may not even need JOHN to
provide any before or after school care for KAENA because my adult daughter will be
there and can watch her. Because my income is so low I also qualify for substantially
reduced before and after school care fees. The bottom line is that yes, on the weeks
10
KAENA spends with me I am working but that is not different than the vast majority of
11
12
parents in this country who have to have their children in before and/or after school care
while they work. I would like KAENA to spend time with her father rather than daycare
13
and that is why we have worked the schedule out the way we have, and that is one
14
reason I chose a duplex only 0.36 miles from JOHNS house. But my work schedule is
15
not a reason to disrupt the status quo.

16
17
JOHN also fails to mention that my work schedule during the summer is
18
substantially different than during the school year. Frankly, I am irritated that I am even
19
working at all during the summer.
20
2 summers. I have to work this summer because JOHN is refusing to pay for his medical
21
insurance.
22
contracted hours last school year. I clock in at 6:45 a.m. so I drop KAENA off at 6:30
23
24
In 10 years of driving school buses I have only worked
But with that aside, my work schedule is different during the summer than my
a.m. and since we are now living so close I only wake her up about 6:20 - so only 20
minutes earlier than he alleges she woke up at his house during the school year. And
25
5920-100 Street SW , Ste 25

253-581-0660
KAENA can sleep in much longer after I drop her off during the summer.
I will also be
2
off work for the entire month of August. There is simply no reason to modify the week
3
4
5
on/week off schedule in the summer and because my work schedule will begin later in the
fall, there is no reason to modify it once the school year begins again.
JOHN also makes reference to my alcohol use in one of his declarations. This is
totally false, irrelevant and an unabashed attempt at character assassination. I do not
have a problem with alcohol and I am frequently subjected to random UAs testing for all
illegal substances and I am frequently subject to a random alcohol test prior to work (my
10
boss has a Breathalyzer in her office). All of the full-time bus drivers are subject to these
11
tests.
I have no criminal history whatsoever - not even a speeding ticket.
Ironically,
12
JOHN has multiple speeding tickets and has been arrested at least three times, including
13
once for DUI.
I believe JOHN should be required to show proof of treatment related to
14
his DUI.
15
16
17
JOHN also makes a reference to track that KAENA was enrolled in for a while.
What JOHN fails to mention is that both JOHN and I stopped taking her to track. We
18
both came to the same conclusion that with the adjustment and transition after separation
19
that it would be better for KAENA not to go to track.
20
CHILD SUPPORT
21
22
23
24
I have adopted the calculations JOHN used in his child support worksheets for our
respective incomes.
I also included the cost of KAENAS insurance in the worksheets in
the amount of $234.34 which is the amount JOHN previously admitted was the child only
portion of the health care insurance. This results in a standard calculation of $723 per
25
S:\CASES1\Kalii\DRAFTS\Pleadings\Response Declaration ofBeth Kaliire Parenting doc

253-581-0660
month. If JOHN receives a 100% deviation for a 50/50 residential schedule credit the
2
transfer payment is still $279.77. I ask the court to order $450 per month for child support
3
which will cover child support including JOHNS portion of KAENAs health care
4
5
insurance.
JOHN says I am understating my income but I am not. The problem is, my net
income is extra-ordinarily low due to the fact that I am being charged $730 per month for
his health care insurance. So that substantially lowers my income available to pay rent,
and buy food, gas and pay necessary bills and expenses.
10
ATTORNEY FEES
11
12
This parenting plan motion should not have been necessary.
KAENA is not
suffering under the week on/week off schedule. I have made changes since the date of
13
separation (later work start time and found a residence close to the fathers home) to
14
make the 50/50 schedule even more practical.
Nevertheless, JOHN is trying to punish
15
me for bringing a motion for financial relief and he is trying to use custody of KAENA as
16
17
leverage which is what he threatened to do to me at the beginning. My attorney has
18
spent approximately 3.5 hours and charged me $750 in reviewing the materials filed by
19
JOHN related to the parenting plan and responding to them. I ask the court to award me
20
$750 for the attorneys fees incurred in responding to the parenting plan motion.
21
22
23

Signed at Lakewood, WA on July 3. 2014.
24
BETH KALII
25

5920-1 00th Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
EXHIBIT A
^ K (t /
V
j /A i
/lT
L /& T
S - 3 /P &
y o u
P T
P P P ^ \
P a a jp
p a
T P
p ^ p T ^ r
/ y
Pa
s p a
T T
y p ^ p
iP P f
P P P
P A 'P
\
/
p
/ A
/ p
EXHIBIT B
Driving Directions from 9711 Winona St SW, Lakewood, Washington 98498 to 11904 Te... Page 1 of 2
Notes
a p q u e s t
Trip to:
11904 Terry Lake Rd Sw

Lakewood, WA 98498-2717
0.36 miles /1 minute
Q
9711 Winona St SW, Lakewood, WA 98498-1252

1. Start out going east on Winona St SW toward N Gate Rd SW. Mao
<1
r*
2. Turn left onto Edgewood Ave SW. Map
Download
Free App
0.10 Mi
0.10 Mi Total
0.1 Mi
0.2 Mi Total
3. Turn right onto Washington Blvd SW. Mao
4. Take the 1st left onto Terry Lake Rd SW. Map
0.1 Mi
0.3 Mi Total
0.04 Mi
0.4 Mi Total
5. 11904 TERRY LAKE RD SW is on the left. Man
11904 Terry Lake Rd Sw, Lakewood, WA 98498-2717
http://www.mapquest.com/print?a=app.core.e5 f9 bb 6907017 ef2df07694 c
7 /3/2014
Driving Directions from 9711 Winona St SW, Lakewood, Washington 98498 to 11904 Te... Page 2 of 2
Total Travel Estimate: 0 .3 6 m ile s a b o u t 1 m in u t e
Nw
X
v
ESvdSW
_W.
Wash*>gton Bh/d SVI
121siSSW
Winona Stl
200ft-
Cmapqoest
100m
2014 MapQuest - Portions 2014 TomTom | Terms | Privacy
2014 MapQuest, Inc. Use of directions and maps is subject to the MapQuest Terms of Use. We make no guarantee of the accuracy of
their content, road conditions or route usability. You assume all risk of use. View Terms of Use
http://www.mapquest.com/print?a=app.core.e5 f9bb6907017 ef2 dfT)7694 c
7/3/2014
E-FILED
July 03 2014 4:04 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
(see Instructions page 7)

a. Is combined Net Income Less Than $ 1 .000? I f y e s . for each
parent enter the presumptive $50 p e r c h ild .
b. Is Monthlv Net Income Less Than Self-Support Reserve? If y e s .
for that parent enter the presumptive $50 p e r c h ild .
c. Is Monthly Net Income eaual to or more than Self-SuDDort
Reserve? If y e s . for each parent subtract the self-support
child.
P a rt II: B a s ic C h ild S u p p o r t O b lig a tio n
$ 5 7 2 .1 2
$ 3 1 4 .8 8
$ 1 ,2 1 6 .0 0
$ 5 7 2 .1 2
$ 3 1 4 .8 8
P a rt III: H e a lth C a re , D a y C a re , a n d S p e c ia l C h ild R e a r in g E x p e n s e s (see Instructions, page 8)

a.Monthly Health Insurance Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
d.Combined Monthly Health Care Expenses
11. Day Care and Special Expenses
d.Other Special Expenses ^describe)
F a th e r
M o th e r
-
$ 2 3 4 .3 4
$ 2 3 4 .3 4
$ 2 3 4 .3 4
e.Total Day Care and Special Expenses

plus line 12)
$ 2 3 4 .3 4
$ 1 5 1 .1 5
$ 8 3 .1 9
P a r t IV : G r o s s C h ild S u p p o r t O b lig a tio n
15. Gross Child Support Obligation (line
9 plus
line 14)
P a r t V : C h ild S u p p o r t C r e d its (see Instructions, page
$ 7 2 3 .2 7 |
$ 3 9 8 .0 7
9)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 2 o f 5
$ 2 3 4 .3 4

-
$ 2 3 4 .3 4
P a r t V I: S ta n d a r d C a lc u la tio n /P r e s u m p tiv e T r a n s f e r P a y m e n t (see Instructions, page 9)
$ 7 2 3 .2 7
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
P a r t V II: A d d it io n a l In f o r m a t io n a l C a lc u la tio n s
P a r t V III: A d d it io n a l F a c to r s f o r C o n s id e r a tio n
(see Instructions, page 9)

a. Real Estate
b. Investments
Father's
Household
Mother's
Household
21. Household Debt

a.
b.
c.
d
e.
f.
a. Income Of Current Spouse or Domestic Partner
Name
Name
b. Income Of Other Adults in Household
Name
Name
c. Gross Income from overtime or from second jobs the party
d. Income Of Children) (if considered extraordinary)

Name
Name

Name
Name
f. Income From Assistance Programs

Program
Program
g.Other Income (describe)

-
24. Child Support Owed, Monthly, for Biological or Legal

Child(ren)
Name/age
Paid [ l Yes [ ] No
Name/age
Paid [ ] Yes f ] No
Name/age
Paid n Yes f l No
26.
Father's
Household
Mother's
Household
-
Judicial/Reviewing Officer
Date

SupportCa/c 2014
c:\program files (x86)\legalplus\state templates\waworksheet.dtf m:\scdata\kalii\kalii.scp 07/03/2014 03:07 pm
Mother: Beth Kalii

County: PIERCE
Father: John Kalii

Superior Court Cause Number: 14-3-01646-7
R E S ID E N T IA L S C H E D U L E C R E D IT U S IN G F O R M U L A
16. NAMES OF CHILDREN

17. BASIC SUPPORT
(From Table)
18. ORDINARY EXPENSES
19. ADJUSTED BASIC SUPPORT

20. OVERNIGHTS WITH MOTHER
21. % OVERNIGHTS WITH MOTHER
22. OVERNIGHTS WITH FATHER
Ka'ena Kalii
$887.00
$887.00
183
50.1
182
23. %OVERNIGHTS-FATHER
49.9
24. MOTHERS CREDIT PROP
.500
25. FATHERS CREDIT PROP
.500
26. MOTHERS CREDIT

(Line 19 times Line 24)
$443.50
27. FATHERS CREDIT

(Line 19 times Line 25)
$443.50
28. OVERNIGHT THRESHOLD SELECTED:
91 NIGHTS
29. TRANSFER PAYMENT BEFORE CREDIT:

30. RESIDENTIAL CREDIT TO Father IS:
$723.27
$443.50
31. TRANSFER PAYMENT AFTER CREDIT:
$279.77

S u pportC a/c 2 0 1 4 (R e v . 1 0 /2 0 0 9 )
ly-a '
by
RrtJtVfcJV i'S 'iiii? H%-.
E-FILED
PIERCE COUNTY, WASHINGT
July 07 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

10
11
12
13
14
No. 14-3-01646-7
Petitioner,
and
ATTORNEY FEE
DECLARATION
BETH ANN KALII,

Respondent.
15
My name is DANIEL COOK. I am the attorney for BETH ANN KALII Respondent herein.
16
I am an attorney licensed to practice in the State of Washington. I actively practice in

17
18
Pierce, Thurston, King, Kitsap and Mason counties. I am a shareholder with Faubion Reeder
19
Fraley & Cook, PS.
20
status) since November of 2003. I have been licensed to practice law in Washington since
21
May of 2004. I devote a substantial portion of my practice, more than 75%, to the practice of
22
family law and domestic relations issues. I actively serve as a Pro Tern Commissioner in
23
Pierce County Superior Court.
24
I have been licensed to practice law in California (currently on Inactive
My hourly rate is $215 per hour. Based upon my knowledge of attorneys in the area,
25
$215/hour is a reasonable hourly rate for an attorney with over 10 years of experience.
Donahoe, Diana and Donahoe, Scott

S:\CASES1\Kalii\DRAFTS\Pleadings\Attomey Fee Declaration for Temporary Order.doc

Lakewood, WA 98499
253-581-0660
A trained legal assistant assists me by performing many tasks necessary for the
2
efficient practice of domestic relations law. My legal assistant has a Bachelors Degree as
3
well as a Masters Degree in English and a Paralegal Certificate. My legal assistant has
4
5
more than 11 years of experience assisting attorneys in domestic relations and civil litigation.
It is a benefit to the client for the legal assistant to perform many tasks at a lower hourly rate.
The following is an itemization of the fees charged to BETH KALII associated with the
responding to Petitioners Motion for Temporary Order and bringing Respondents own
counter-motion for temporary order:
10
7/3/2014
Conference with client. Review pleadings from

3.0
Opposing Party. Draft Responsive Declaration.
Draft Motion for Temporary Order; Motion and Order
To Shorten Time. Draft Attorney Fee Declaration.
$645
7/14/2014
Court Appearance for Hearing

(Anticipated)
$107.50
11
12
13
TOTAL
14
15
16
17
18
0.5
$752.50
I certify based upon my experience in domestic relations practice that the time
charged was necessary and reasonable.
I DECLARE UNDER PENALTY OF PERJURY ACCORDING TO AND UNDER
THE LAWS OF THE STATE OF WASHINGTON THE ABOVE STATEMENTS ARE
TRUE AND CORRECT.
19
20
Signed at Tacoma, Washington on July 3, 2014.
21
22

23
24
25
Donahoe, Diana and Donahoe, Scott

S:\CASES1\Kalii\DRAFTS\Pleadings\Attorney Fee Declaration for Temporary Orderdoc

Lakewood, WA 98499
253-581-0660
E-FILED
IN CO UNTY CLERK'S C
PIERCE COUNTY, WASH
July 07 2014 4:00 P
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
3
4
5
6
7

COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Declaration of
A
Petitioner,
12
13
and
Z ,
[Name]
BETH A. KALII,
& n J x S 6 r?
Respondent
14
15
16
17
Name:
ei
-Z
Aqe:
J
Relationship to Party(ies):
Z r
^
t
/ c V plZ
18
Number of Pages attached:
19
20
21
22
1, THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER

THE LAWS OF THE STATE OF WASHINGTON THAT THE ATTACHED PAGES ARE
TRUE AND CORRECT.
(stateI )P ~ ) on (date)
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
- ii- I lI S
!i 7 7
>
.1
! I'
7-/
::Cv:
__;
>h
-i --.v
:.*
This declaration is in regards to child custody of Kaena Kalii, daughter of Bo and

Beth Kalii. I do not know Bo as John Kalii so I will refer to him as Bo. I have known
both parties and thier (sic) daughter for several years.
Being a mother and a grandmother has brought me many life lessons. It has
always been my firm belief that no matter what, the child must always come first. And
each parent must always consider the childs (sic) feelings and well being above
anything include during a divorce. So I believe it ideal for shared custody under ideal
circumstances.
I consider both, Bo and Beth cherished friends. I am sad however over the
circumstances of this break up which I know to be true fact the heartbreak Beth feels.
She is devastated knowing the man she married no longer loves her but is in love and
back together with his exwife. This has no bearing on my opinion, but I have great
concern placing this child in her fathers (sic) home due to the nature of this womans
(sic) personality. I have seen several letters from this woman sent to Beth. These
letters are vile, mean and to me psychotic. It is my opinion that Kaena should not be in
the home around this woman. Kaena says she was told she has to call this woman
mommatami. It is my opinion that Kaena would suffer in some way due to the hatred
this woman has and displays toward Beth.
I have never heard or witnessed anything but pure love between Beth and her
daughter. Beth has always been and (sic) wonderful patient loving mom to Kaena.
Beth has always put her daughters needs before her own.
I have no doubt that Bo loves his daughter. And I have witnessed the father
daughter bond. But I have also witnessed angry outburst and heard him degrade and
insult Beth. On one occasion I was on the phone with a mutual friend while Bo was
yelling very mean insults to Beth in the background. I asked where Beth was and was
told she was in the bedroom with Kaena trying to protect her daughter from hearing
daddy yelling out adult insults.
Its my opinion based on the violence and background of this other woman, as
well as her well documented hatred of Beth, and Bos adult insults and outburst, that
Kaena should be kept safe in her mothers (sic) custody. I think Bo with his daughter on
visits are good, but I urge the court to keep the other woman away from Kaena.
s/ Cathy Gibson
6/16/2014
J OO./oisaAm /n /n mptu-cLs
M
O. U
d tt,
J it ! /- t
A ra u O r)
J & M j-tz L
o/
g 0
J d aA A
p a .r d /- e s
p /nn ^
rX /'
X n (J
p / iA - e r
g /a M t
'T o t h e r
/ '&
r (J )
/ ^ ' , X X ^zf
g # c
L te a jr S ,
/n $
M /W A
j d
-J o h n M&uc no
//?<<J #<?
Z -
/2n.//d dnc *A>/odn & p
7^
jjo
x m
q r a jw l/r u > f> 4 r
A m
A n n u d o
r J
u n -c
/x
/^
Z jo . tz AO /Wd'AMr' iQhajfcj ~T/i-C ChJcd smunA x /to n ,u ddm>-C,

J / b s t ,
A n d
e a c h
p a n p t
tu s i
a J to u $
C s n s ,d tZ
p f it
C f iJ c b
jA J /n sjs OnA ivtlL &/n>4 oJodv^ On i^Y-h/ac in auni'/A a d u r /n p

0 .
l v m r C t,
tJ 'O
S JJ
L - /J A - e i/
/ p
J n J o iC
A m
w b in m ^ n J
c /L ^ w
jx lp
(J/]d~$f~ / o/dizL 0*/ nO/U/y/^j/'&to <LJS-
t e n s e r lo A b , S e a n / I Z i h C M r A ^
A O , fo u tw r
s tfe
/W
_,
c - t /A i< A
C ,lr e ^ 3 U e * s
'f
o * * * -Z * * n p & S f & C A v ^ fc / m r / A n e a s j J ^
< ,/
-fZ e J z > ;, Jh-e> / d i t / a s j x k n j pn ^ m /n a y J a
n o /o n p u r
tp fiW )
X
,
/o m
,
A -r
/
,
A a -t
/x
, X
< j
fo c /o
h 'J
n o
V t, o w d
C to v u rn
p k t /n p
b J Z m -------z
a n rAiaA.r
/r w - r /e d L
Om J L
p L a p d -e r
h m rm g o n
A P ? /j P & s /d
m u
^
Z
d Z <
ZPb
An
lo m i
m p
^ U
J d &
rj
o p fA o n
J ro c e n Z
*
*
S A a i
A W
I t A
ir s
Z - tm
X rA
w le
J p /d
A h 'm
w o m an
o p m ,o
d b /j
x l
U O -e n a .
Z h
A a 'jn
w o a J l j
m -e a n a m
^
u m
i Z
* /
&
b e e t
'
/1
^
':
Z d
i A
an ao
ip
hut 0 W
/o v tj
^
& nL
/
0P & 71
n r
fttz A s
/M
e , M
r t i
tP
A j u /&
jr / m
udh
g M
d m c L
' A M
'b y *
t ^
^
A M
o p /Y u o m
tr
t p ^ # r
r r m
Z /-
A M L
6 / s 'd u r d j e r .
f i^ r p u u t p /M
aJ
f t l
/
(m
iO M h J u
M /M r d h n
M fh i b u M
JP M
Cw ^
/ W
u S /A -b
iftU r r u ^
1 1 )0 0
$ e
r t r , /M
tf\4 L
rp
er,
o n rs n ,
W ^x W
A
tk y y / M
A #J>
d u d ^ A A d
j&
a y ii
w
d M
---
r M n e s P te i
o L ijh & M
&
/)
M l^ /n U L r S e t t )
2 , A n tk >
//
fa r
u a /M
i) n
> 'n
g>
it fh
a i/iJ O
# n - A fM
O f M u z cAMif UAOirîn, <*S ^ A l l 0l3
g & A
rr< U Z c U 5 /< r y - ,
tA
aW & J0
A U LS
c b J U fi u a M
M s e c L
) a J z i& J l A A /O r? rA C o t jM
M M
Q
r djo & n rL M e e t
a u
t) .
A n d ,
-a
o
- f l- t jj/ r t f ib
#u
fc U A
v /o le n u .
U s< M g .
b a z tffv u ^ o L
f v v r ua4y_ (jo c
llHxeMdL,
Kstn^ -
(XncL"Bc'i (xAul-t IWSu-Kt) (XkcI. uct-bilrffs^
-KaWcu
W-- Kept Sa^ /vjuv
S
CasWAu, Z
wN-h |/us dca^rtkA cm. vMsHs ajêj
- uxg^^tR.-^
~d
b^war^
0
s n o tA h
y y \< H M m
A jM >
tX ~
~r*y*\
(X b zooJ J^t - ~ r r 0 > v \
& H l'
C o u x - 't
2-kC L , <
A A ^ -
c t( M
ir
E-FILED
IN CO UNTY CLERK'S O
PIERCE COUNTY, W ASH
July 07 2014 4:00 P

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
2
3
4
5
6
7

COUNTY OF PIERCE
10
11
JOHN A. KALII,
No 14-3-01646-7
Declaration of
Petitioner,
12
and
13
BETH A. KALII,
[Name]
Respondent.
14
15
Name:K e A l u l W ' Y ' Y L / - ^ .
Aqe:
Lf^j
16
17
Relationship to Party(ies): _ P n i n j
d0uj(yth _
18
l_________
19
20
21
22
I, THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER

TRUE AND CORRECT.
__ , (state) IpPcon (date) _
Signed at (city)
23
24
A
Signature
'
'
--------- -*
25
Declaration C overpage P age 1 o f _______
S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage.docx
Lakewood, WA 98499
253-581-0660
7-3-2014
To Whom It May Concern:

I have come to know Beth Kalii through work. She is an excellent worker, friend,
and most of all an outstanding mother.
Through the years I have known her, she has always put her children first.
Making sure there was always dinner on the table, clothes on their back, and love!!!
She had to be the only parent to her 3 oldest children, when her first husband
was incarcerated. She stepped up, went to work, and raised these three children.
Which all turned out to be responsible, independent adults.
I have no doubt in my mind, that Beth can raise her youngest, Kaena.
Thank you
s/Kelly Hartman
1 -3 -& W
~7o
lv>5h
U
ZTf
m ip
dan
ha.o<LCemt. -fa
knasI f it t .
h h ira n c k u o ic k . 'S h e is f in
iS>odLCfi fr ie n d
fund fhos.f o f n e t cu .,v
IX
d u d S 'k - v d - o - ij K h o f t - U c .
I h
<2
fl
\M p r s
liOJ.
fie lC w j
at Uo
.S lu t
tn s o ih
poLt f i r
Id u n
-fdote C
. lofU s th e ir- beck, cehd
hud
dv
h>
t i i f-j
o ld e s t(Ih !d ir e }
b o tiS l e Q l l r d i a c t z d ,
dl)
k& ~t
~ fk n r .lo d S
on M l
lo u t1
. 11
S iu
dd h u e
lU>\uu\hr f i r s t lw s h
S lu
Qn ,
u>oeL l yu M \raJCed M -iM - th r u Q hi I h e r .
u J lv o d i
aJjMild(1 a d -To b t- fis p m s h k t
l a b U p ird irt- it da. / fs .

J f
h tk o e
C u rn
flb d o u d y t
m is t
h m
tA o u u iM f )
cu. )
-Q ttddf
~~~n>
inruu i r i ' m d p - t /v e d
b u tn H ,
E-FILED
PIERCE COUNTY, WASH
July 07 2014 4:00 P

KEVIN STOCK
COUNTY CLERK
NO: 14-3-0164 5
2
3
4
5
6
7

COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name: / R P .n e.
P /)&
Age:
16
17
l/u M n r L
18
Number of Pages attached: _____________

19
20
21
22

TRUE AND CORRECT.
Signed at (city)
K ^ llJ n a d
. (state) U I a on (date)
23
24
>ignature
U LL
6 . 0 tA J
25
Declaration Coverpage Page 1 o f______

S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage. docx
F A U B IO N , REEDER,
F R A L E Y & C O O K, P.S.
5920-100th Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
I have known Beth Gilmore Kalii for about eight years. She is a hard working
dedicated person; not only on the job but also as a mother.
She has a contagious smile and gets along with most everyone she meets. She
is easy to get along with and is very outgoing.
She is a wonderful person to be around and takes her friendships to heart.
She looked forward to her future not only as a mother but also as a wife. When
she received her camping trailer for her birthday last year from her husband, she was
estatic (sic). She looked forward to spending many nights out camping with family and
friends. She has had a rough patch of late but she has pulled herself up, holds her
head high and goes on; stronger and more dedicated than before.
It is unfortunate that because she is paying so much out of her check for medical
for Bo and her daughter that she now has very little money left for herself for food and
other necessities. Her friends from work make sure she eats at least once a day but
she still has lost over 30 lbs and is still dropping. She could use a little help as she left
with only her clothes and one cooking pot. Bo wants even the pot back.
- L~
have
t fj\o u J r >
B e th
p i/r t) o e ,
X & 'i p C
ftb o u l
Safrf ye/?&S. S he i s B h^Bd uJoRRmc dedicated

person j Mah o n ly an -the. fab bed- 0.1So A s
ff M o t h e r ,
She,
h as
&
Q o /d a q /o u s
id it h
/m s h
C /fs y
ho j j d
f*
e v e ry o n e
S h e
is
fin d
fB x e s
S h e
fo o K e d
o n ly
ns
u Jh en
She
u J /h h
lO a n d z r p u .)
he&
bo
f-o fc
Y ) t f
s h e
b fs
h ad
P auph
S h e
h a s
p tille d
a & d iQ & h e d
So
M e d ic .# - /
th o d
m uch
fo p
S h e
l e P i
f r p
3 u . P
<5 d a y
h o i
f r i
o n e
W
t u t t
Q fim fiin f
jL jQ f y e f t f i
fin d
o f ic d s
u p ,
h o ld s
bePa& e*.
th a t
a n d
h fts
becau se
hbsp
hep
e & b s
o h e
s t / 1
is
o V
R b
f &
h e A -
P o+t-h r
*s
fo g ,
f in d
p ro m
c f h & jL
u J o / lu
le a s h o n c e
h fis
'
s h e
l/tb fM o n e y
p P ie n d s
S he
and
Cheep
fo o d
o p
h o p
d L a r u & h i& p
Vesy
P
bub
s b fio n c je it
h u e
& < tb
p r f& rd ,
p a tc h
cud o f
C o o K in j
f) / j h f s
th a n
h e r c c if
X If t H e
/is
n o b
f t S ft? u d 'p & -
o n ,
pouJ
M e c e s s tb id s -
3D
fa b u e
O osS
u n p & iu /J ^ -j-t
P fiy iy
h eP
h & r S e lp
fin d
R & a u L V id
Qhe iaJ a s e s i f t i l G .
fis u n ity
h ia h
/'s
ho h e a r t .
S p e t d '^ f A f in y
3 he
be.
h /r iH h d c K y
h u s h fin d
fth n j
V c f if C i l l - j o i / y
bo
h e P
t U 'd h
/5
/s '
f r i e n d s h ip s
Ita m p tn *
X l
f in d
R e c e iv e d '
U >om L f r j i M
M o e e
m e e d s .
p e rs o n
p o C a J fih d
h e r-
he& d
fin d g e /s
ft M o th e r h u h f t k o
b fc & tte
S h e
R /o n ^
s h e
te rn
d m H e.
le s t,
h
Z S
C lo th e s
06
t0 * 5
D C rb
b f iC t e ! .
< 5 ^
&
k t *
e n d
even
E-FILED
PIERCE COUNTY, WASH
K n o io
1
2
3
4
ft S
C O
ft
W o rk e r
a uso rid e r P u l m o T h c r S h e - ^
'T h u , R qJ / H j f v n ^ r / i j ^ c r S
HtfcJ
d o . /V>d
5 hou//) t h a t
fo r
L i f e , .
c U ig W e r u n T h h a r
* T h e t^
S o o7e,t>j//)^ f o r b ^ r T o
fln d
û^hter h /95
s t r u c t u r e f ln d <Y)A0 0 < u r s ,
ft l o t
/fej/GT
o f
fu n .
flc fc c i
^ 201* 4
f C cKOUNT^.CLER
6 ^ T h N^ / i S -3-|0164
S b e k ^ " )<0T e ro p t;o '
SOrne, 0/&. /ovioqC&dTbJ htf-5
flod I S /9 J a l i C f h T
fo l
c b l / c i To
D^ rtroO/)cd .
6
7
8

COUNTY OF PIERCE
9
10
11
JOHN A. KALII,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
No. 14-3-01646-7
Petitioner,
Name:
C l j6LC R __________
Aoe: ^ 1
16
17
Relationship to Party(ies): C o
k )o r IC C /'
18
Number of Pages attached: _____________

19
20
21
22

TRUE AND CORRECT.
Signed at (city)
k f ) k z . i^/Q
q >)
(state) k b
on (date) \ W i r
/ 2-O /j
23
24
l y
nature
25
S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage. docx
00 P
F A U B IO N , R EEDER,

Lakewood, WA 98499
253-581-0660
I know Beth as a co worker and Relay for Life. She is a wonderful mother. She
had her daughter with her at some of the Relay Fundraisers. They had a lot of fun.
Beth always had something for her to do and never acted like she was interupting
(sic). Her daughter has shown that some one loving (Beth) has given her structure and
manners. And is a delightful child to be around
There was one day Beth and I were on the computer at work searching for Relay
For Life products. I was looking for Thundersticks. Beth asked what they were and that
she wanted some. I told her they were long inflated balloons that when hit together
makes a big sound. Smiling she ask is this going to get my daughter in trouble cause
her Dad likes it quiet around the house? Another coworker said yup! She said shed
let her play with them when hes not home.
Two days after I gave Beth a pair of Thundersticks. She said her daughter love
them and when her dad came home she, the daughter, stuck them in her roller skates
and rolled them around the house.
s/Jana Clark
July 1, 2014
f*
1h e /'Z -
U fls
one,
0 /nj
C-orOpurû fiT W o r k J X f l r c X i n o T o r & d / 9L/ F O c i 'F < l

p ro d U e T s . X ^ /? 5 / o o ^ / ^ c F o r
(betth f l 5^ J w iv it Tiheu '/ v '- e / 'S .
th e ft sbo**-----_____ id Afile d
so ro
w
,
F c r
T 'd c v L j
)o n q
tifiD c o n s T h -ftf ujhe..A h i t l a q o t h i r mAfe-ey,# X q >5<xtoc) t h is q o / D a T<? o f T nnH Vfluqhttr
f * ____ - -.... Snothna s h f h s J ie a 'iS
m t c o o i j k ^ - C flts w
herO ex) < H v F T
i
Ol a
/F -v
)h
T X e _ house-.
rin o l h z f C O w or K e r 5 a i <j
0<
S h ^
s h w 'd
h tt
her
- " 2.
h o t^ p o t h?/n<w,
T ^ jo
cUus
X
c j/) fe
&Th> f> p / j
<y
W - - - - 'T h u n d e r
5 't/cKd F ) F e . 3 / W ^ e y ~ D A U ^ h te r Jvo - d
/ 9< W Ia/ he/) h e r c U d
csfhne, hom-e, s h e ^ j
---------------- T h e / r )
ffos
Ofiucjhfet'jytucj<
T h o jj)d
i
her
2 r
A n d ( f o i l e d rh e y r)
h r o u n o th e , h cu sQ ,,
/
-
b jw kK
**
pi
fl*
% j
Jk
P
r
V
^
__
JP L
^ _____________
*
C J v ia A
/ ,
TJdjî
E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, W ASH
July 07 2014 4:00 P

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
2
3
4
5
6
7
8

COUNTY OF PIERCE
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name:
16
17
Age: S T S "
18
__________
19
20
21
22

TRUE AND CORRECT.
Signed at
, (state) U J J V on (date) ^
) A-
23
24
Signature
25
Declaration Coverpage Page 1 of
Lakewood, WA 98499
253-581-0660
7/3/14
To Whom it may concern,

Beth A. Kalii is a wonderful, caring, hardworking person. She is always helping
at company functions, she helps set up, cooks, cleans, and always has a smile on her
face. She is a wonderful mother who to my knowledge has never been anything but a
great caring mom. She is there for her children no matter what. She is a wonderful
friend and always tries to help those less fortunate.
s/Sidney D. Gilbert
__
V /s /r t
\ q > W ^ c j'f r v
^ G T V lr
v v T ty K m . d o ' ^ C e c t O s
, V c f\G Y \
-A < iV G N
V-Ssl
cyG S -
Iv A F y S ? vwYo-'
F rc G S ^
V W O K ) i > R E U L , C -A K -iy v ,
so.
^ i.\x jfc u 5
i3 \~ r ' C j o T n r ^ A K ^ , u \
Fêv
F o N i c m 6 > 0 5 . j Sfc*i.
o S ^ , Q s o K S ,, O - F A
O K i
________
F ir fV A
^ A -e .
X j ^ f O ' f c . t R R O V ___ \ ^ ~ V t V e A , \ x i ^ G
^ V F v u l
H K lA s O S V A R
vs
t u
U G ^ F A C G -.
j\o
FK v > ^ A \ V ^ G ,
\R
~ W i - 6 : 1R - _
F A - A cT V F ^ L
_ . ^ \ O
^ )V G \o M
X.
G o M -P t R
o b
"Y ^g ^
^ -vjt-
-f^ o G
U 3 .F T S
t x
-s^
O i.t g f '- A
-^ G b o -A p s
VS
G iL iR fe e r T '
Vi
H
-A
o M
i O
___
.
? o t>
F c M o ^ F F lA _
~ T R .l& b
'v g r t o v o -f c c . ,
t F
G f t - R i t o r-a y n a t n
V c iR , ^ ^ _ G
S fo V e
'T G
H F g P
----------------------- :----------------------------
--------------------------------------------------- -----------
_________________________ __
-----
__________
____
_:_____
____
______
__
-----------------
_______
4--------;------ :-------------------------
E-FILED
IN CO UNTY CLERK'S OFFICE
July 07 2014 4:00 PM

KEVIN STOCK
COUNTY CLEF
NO: 14-3-0164 >-7
2
3
4
5
6
7

COUNTY OF PIERCE
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name:
Age:
16
( t e - l iy n k e i i ;
17
1/1 p n A ik e ^
u -qajjJ
18
slumber of Pages attached: _ J = : _____

19
20
21
22

TRUE AND CORRECT.
Signed at (city) i
, (state) IV A on (date)
*)"
23
24
25

FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
July 3, 2014
I have worked with Beth for the past nine years. During that time I have
observed Beth as a hard worker, a good friend and a wonderful mother.
I now have the privilege of being Beths next door neighbor. Beth goes beyond
the call of duty to maintain a warm, clean living environment for her family.
s/Talley Schlag
_____________________________________________ A la k ,
I_____________ ___
kctAC?
[iij
f)P,bA
-?h id lfjz
-------------------------------------------------
iO C iJ ^ J ilo 'i'U i
1
L
/U
M
& L M X j . A JU Jtm P
aJ
Cl h d J iA
j------------ i s -----Ui-
InAiM -P
m h ct
...
a j
k W tte J l. Pi # fid d ^ u o m o L /v a A cl.
0 _______________ y _
v V m M o Iw u c e H tu IM m a l A p a ^ ^ Icj2P>mC
J~LM /
v) M
h c jA s M c L A iu
c
d& oi
CMA d
k io a ju m j u m m
4m
D
1m
K & a u m f' S c M
j(W
k
O JU a c w
{ a u u h , ________ __ 0 ____ _
D
d k j
______
Cj
y
__________
__________
.._
~7J ^ZZ7
7V \
xA----------------- ^ -------------------------
_____
__________
-
'
"
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 11 201 9:
KEVIN STO
COUNTY L
NO: 14-3-01
2
3
4
5
6

7
8

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,*I
REPLY DECLARATION OF JOHN KALII
Respondent._______________________________________
12
13
I am the Petitioner in this action and make this declaration in reply to the false
14
and misleading statements made about me by my wife and her friends. Regarding the
15
declarations that have been filed by her friends, they are not based upon seeing me
16
with my daughter, or being in my house. They are based on what they have been told.
17
18
19
20
21
22
23
The fact of the matter is that, I personally do not know or even been around 5 of these 6
people and they have never even been to my home. My question is...How can they
possibly comment on who I am, what I've said or done, or what kind of parent I am, if
they don't even know me or been around me?
I filed my motion for a parenting plan based upon trying to do what is best for our
daughter. It is not good for her to be bounced around from house to house to school etc
through her school week. I am retired and have been providing the bulk of the
parenting for our daughter since I retired in January of 2013. My wife did not object to
Reply Declaration of John Kalii
Page 1

Tel: (206) 448-1010 - Fax: (206)448-0736
that, but for her own personal sense of self worth, she would rather have our daughter
transferred a number of times each day on the weeks she is to be with her mom, and to
be cared for by an aunt rather than our daughters father, solely for money and
winning.
My wifes responsive declaration is filled with misstatements: Ka'ena was born in
May, not June. She and Ka'ena did not live with me until Ka'ena was over a year old. I
did not kick her out of my house 5 days after our daughter was born. Ka'ena has not
been spending equal residential time in our homes as Beth suggests. Although her
nights in each household have been approximately equally split, Kaena spends the bulk
10
of her waking, non school hours with me. Even during Beths week Kaena spends
11
approximately 27-30 hours with me. Her proposed Child Support Schedule worksheet
12
shows her as having Ka'ena 50 percent of the time, which is terribly skewed because it
13
doesn't take into account the total hours and the time taken from my (off week) when
14
she is supposed to be under her mother's care during "Beth's week". When the hours
15
are added up for the whole year, it becomes very substantial.
16
I did not offer a 50/50 split if she didnt take money from me. All of her motions
17
have been about money, whereas my motion is based upon what is best for our
18
daughter. I do not believe having her bounced around from house to house during
19
Beths week and impacting her sleep and study schedule is good for our daughter. I
20
do not believe it is best for our daughter to be cared for by an aunt when I am available.
21
If the roles were reversed and I was working from 6:30 a.m. to 6:30 p.m. and her mother
22
was retired there would be no question that the court would think it was best for our
23
daughter to stay with the parent that is home for her during the school week. It is also

Page 2

Tel: (206) 448-1010 - Fax: (206)448-0736
important to note that my wife does not deny that I have been providing a substantial
part of the care for our daughter over the last 19 months or that I am a bad parent.
As for Beth's 29 year old daughter, she was initially asked to find another place
because of the conflict issue I had with Beth knowing about everything going on in my
house through her daughter. I later retracted the letter I gave her daughter and told her
she could stay as long as she wished and that if she were ever to need a place, she
was welcome to return.
It is odd that my wife would allege that I am focused on money, but if you look at
all of her motions, they are only about money. I do need to be able to pay the bills, but I
10
have not objected to paying my portion of the health insurance, just how it is computed.
11
It is my wife that is asking for a pre trial distribution of my pension without ever revealing
12
her bank records and other available resources to the court. It is Beth who is
13
determined to sacrifice what is best for Ka'ena, for monetary gain. Beth claims that she
14
has to work Summer School because I am refusing to pay for my medical. I began
15
paying Beth for my Medical in June and will continue to do so until I am allowed by the
16
Medical Plan to be released. I have tried but it was told by the insurance provider that
17
the divorce must be final or until the next enrollment date.
18
My reference to Beth's drinking is not a "false, irrelevant or an unabashed
19
attempt at character assassination" as Beth wants to imply. It is real and has been the
20
main reason for our separations in the past and it was stated that it was the basis for
21
our separation in the spring of 2009. A woman who loves and cares so deeply for her
22
child does not drink and smoke during the entire pregnancy of that child! She claims to
23
have taken a number of UAs over the last ten years but has not provided any of them to

Page 3

Tel: (206) 448-1010 - Fax: (206)448-0736
the court. But the point is that she is lashing out with whatever dirt she can attempt to
dig up rather than looking at what is best for our daughter. I did not allege that she has
been drinking now, but she is now attempting to make it an issue.
My Parenting Plan is necessary for the best interests of our daughter. It will
eliminate loss of sleep and stress on Ka'ena if she is not shuttled between houses twice
a day during the school weeks that Beth is supposed to have her. She should not be in
day care or cared for by other family members when I am available to provide her care.
It is sad that my wife is looking at this from the perspective of her convenience rather
than what is best for our daughter. Beth claims that her older daughter can provide the
10
care for Kaena while she is working. That daughter has a full time job with Buffelen
11
Lumber Company for over a year and has not had the luxury of caring for Ka'ena,
12
before or after school.
13
I am also in disagreement with her parenting plan as I do not believe it is in
14
Kaenas best interest. My wife submits in her declaration how she will get a later start
15
time so she doesn't have to bring Ka'ena to my home so early in the morning, when
16
Ka'ena is supposed to be under her care. What she fails to address is the fact that
17
Ka'ena will still have to be dropped off with me after school to stay until Beth is finished
18
with work and she may very well be working later in the day than she is now due to the
19
change in schedule.
20
21
22
This declaration is given under penalty of perjury of the laws of the State of
Washington and is true and correct to the best of my knowledge.
23

Page 4

Tel: (206) 448-1010 - Fax: (206)448-0736
Email-TSABIN@GOLDBERGJONES.COM
1
2
Signed at Lakewood, Washington this _//

/ / dday of July, 2014
3
4
5
J o h n K alii
6
7
8
9
10
11
12
13
14
15
16
17
18
19

Page 5

1264 Wectiakc Ave. N., Suite 700
Seattle, Washington 9*109
Tel: (206)
- Fas: (2tkTH4fM7J6
Ema- tsa bin g o ld h ek g jo .n es .c o m
1
2
3
4
5
6
7
8

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
tsabin@goldbergjones.com.
Dated this/l&i-ctay of July, 2014 at Seattle, Washington
19
20
21
22
23

Page 1

1200 Westlake Avc. N., Suite 700
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- TSABIN@GOLDBERG.IONES.COM
14-3-01646*7
42912328
; COURT OF THE STATE OF WASHINGTO

AND FOR PIERCE COUNTY
07-15-14
CME
No. 14-3-01646-7
JOHN A LIK A KALII JR

Petitioner(s),
M e m o r a n d u m o f J o u r n a l E n tr y
vs.
] Show Cause
BETH ANN KALII
(ADM02)
R espondent(s)
bÂQS
___
S (j
L in d *'
For R espondent
For Petitioner
C)a
RE:
>--- y
^ ---- f
J --- 1M
it .
C x jU A jt
ii* s &
X
-A *f
cu,S * fO z>Dji yy^y Cc^pST^l^ t t X'i
^
s
^ g>
/r C > S > Q '
&<ZfL*eF U-e^yUf___ rj^
f>Ayt^
p^\
O ^ ,^
j)J~i
eJCc^
p > W /
July 14, 2014 9:00 AM
*f\
^ i t t S At
f>Cfr&3
a /a X <
txs*s& \
t U y j^ h ^
/\^ A
tA r u
4 * oXem ^>
TÛ a^
c f*% e
Motion - Temporary Order t* 7& e

96
3 ARROW SCHIESL
Clerk:
c/ aX z
^
e^ n J ^
DEPUTY CLERK___
C ourtroom num ber: 407
IxcrtrptpbldJoumaljentry_showcau$e_report
^
/
U3
^Leosi -C/Zasf-
Calendar: C3 - S H O W CAU SE/FAM ILY L A W '

R un d a te /tim e 0 7 /1 4 /1 4 8:11
f>
H z n ^ ^ ^ y t f a J f <X & r
PT C O M M Larry Jero m e C outure
f: y
X>
fS *
.
*3 -
tit
p s x ty i& iA y
f
^
(A**
M Q /U
C#X*dXt~
gy,
'
+*&<=>
1
2
3
4
5
6
7

COUNTY OF PIERCE
10
No. 14-3-01646-7
11
JOHN A. KALII,
Petitioner,
12
and
13
BETH A. KALII,
Parenting Plan
Temporary (PPT)
Respondent.
14
15
This parenting plan is a Temporary Parenting Plan signed by the court.
16
17
18
19
20
Name
Age
KAENA KALII
21

22
23
24
Under certain circumstances, as outlined below , the court may limit or prohibit a
2.1

Does not apply.

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, .181;. 187;. 194
S;\CASES1 \Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
L akew ood, W A 98499
253-581-0660
2.2
2
Does not apply.
3
4
5
6

The residential schedule must set forth where the child shall reside each day of the
year, including provisions for holidays, birthdays o f family members, vacations, and
other special occasions, and what contact the child shall have with each parent Parents
are encouraged to create a residential schedule that meets the developmental needs of
the child and individual needs o f their family. Paragraphs 3.1 through 3.9 are one way
3.1
10
11
3.2
School Schedule
_ --
Upon enrollrmrrtsoschool, the child shall reside equally with both parents on the
following s c h e d u le :^ ^ ^ ^ ^
12
13
The child shall reside with mfes^rents on a rotating and repeating
alternating week on/week off sche&trieÊxchanges from one home to the
other will be on Mondays after school oraF5?Q&p.rn. if there is no school.
14
15
16
17
18
3.3

.
U rT fl
Winter Vacation shalPkê defined as commencing the day after school lets out for
the Winter Vacation Bre^k and concluding on the day before school resumes.
19
20
21
22
23
24
In even numbered ye^rs, the mother shall have the child for the first
school lets out at 9:00 a m until December 27th at 8:00 p.m. In
even numbered years the Tether shall have the child from
half of the Winter Vacation. Visitation siâll begin the day after
W P F D R 01.0400 M a ndatory (6/2008) -R C W 26.09.016, .181; .187; .194
S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc
FA U B IO N , R EED ER ,
FRALEY & COOK, P.S.

5920 100th Street SW , Suite 25
Lakewood, W A 98499
253-581-0660
3.4
2
ya
***
x
P x L u n fK
The child shall rekkte with each parent during spring break as follows:
/ '7
vJ
The first half of Sf>R(ig Break shall be with the parent who has the child the
prior week under the^lternating week schedule (Par. 3.2); the second half
exchange shall be on W ednesdaâM 2:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
10
11
3.6
CsfT&rC
Same as SchoohYâr Schedule, and in addition: each parent shall have two
weeks uninterruptechvith the child for vacation during the summer months when
the child are off from schctok^
12
13
Each parent shall notify the ot?fespgrent in writing of his or her two weeks
of vacation no later than May 1 of eacITYeaF-JHhere is a conflict in
vacation dates the fathers choice will control inocfcbyears and the
14
15
16
17
18
19
20
21
22
23
24
3.7

With Father
With Mother
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
See Par. 3.3
New Years Day
See Par. 3.3
*
*
*
*
Presidents Day
*
Memorial Day
Easter
Even
Odd
July 4th
Even
Odd
*
*
Labor Day
Veterans Day
Even
Odd
Thanksgiving Day
Odd
Even
Christmas Eve
See Par. 3.3
See Par. 3.3
See Par. 3.3
Christmas Day
See Par. 3.3
P a r e n tin g P la n (P P P , P P T , P P) - P a g e 3 o f 10
. 181;. 187;. 194

Lakewood, W A 98499
253-581-0660
1
2
4
5
3.8
__
The residentteKsQhedule for the child for the following special occasions ( % /
example, birthdays)S$as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
\ j M t h Mother
(Spesify^Year
Odd/Even7Evefv)^
Every
With Father
(Specify Year
Odd/Even/Everv)
E v e r y ^ -^ ^
Every
^
Every
Odd
Even
14
15
school on the day of the Special Occasion until the8:00 p.m. on the day..of the Special
Occasion.
16
17
18
3.9
Paragraphs 3.31 - 3.8, have pribqty over paragraphs 3.1 and 3.2, in the following order:
19
20
Rank the order of priority, witnNheing given the highest priority:

2
holidays (3.7)
4
school breaks (3.4)
1
special occasions (3 .8K 6
3
o
21
22
23
24
3.10
Restrictions
Does not apply.
WPF DR 01.0400 Mandatory (6/2008) - ROW 26.09.016,.
181; .187;. 194

Lakewood, W A 98499
253-581-0660
3.11

school care hours.
6
7
3.12
10
11
12
13
3.13
14
15
16
17
18
19
20
Other
3.14
21
26.09.480.
22
the child.
23
24
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008) - R C W 26.09.016, .181; .187;. 1 9 4
S.\CASES1\Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc
L ake w o od , W A 98499
253-581-0660
1
2
3
4
5
6
7

contempt.
10
11

12
13
14
15
16
move.
17
18
19
20
21
IV. Decision Making

22
23
24
4.1
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
- R C W 26.09.016,. 181; .187;. 1 94

Lakewood, W A 98499
2 53-581-0660
4.2
Major Decisions
2
3
Education decisions
4
5
6
7
8
9
10
11
12
13
14
15
16
17
joint
joint
joint
4.3
18
19
20
21
22
23
24

carrying out this parenting plan. This dispute resolution process may, and under some
modify the plan or a motion for contempt for failing to follow the plan .
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187;. 194

S:\CASES1\Kalii\DRAFTS\Pleadings\TemporaryParentingPlan.doc

253-581-0660
1
2
3
4
5

50% petitioner 50% respondent
6
7
8
9
10
11
12
13

(a)
(b)
(c)
(d)
(e)
the superior court.
14
15
16
17
18
19
20
21
22
23
24

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

S.1CASES1\Kalii\DRAFTS\Pieadings\Temporary Parenting Plan.doc

2 53-581-0660
1

3
4
5
6
8
9
10
under the laws of the state of Washington that this plan has been propose^
good faith and that the statements in Part II of this Plan are true and cor;
11
12
13
14
15
16
17
18
19
20
Date and Place of Signature1

It is ordered, adjudged and decreed that the parenting plan set forth above is adoptet
21
22
23
24
If a parent fails to comply with a provision of this plan, the othen parents obligations
Dated:
1 1
" (
181: . 187;. 194

253-581-0660
1
Presented by:
2
FAUBIObUREEDEg^-FRAbEY & COOK, P.S.

Notice ofpp^gentationjîved.


3
4
5
6
7
Date
Date
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181; .187;. 194

S:\CASES 1)Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc

253-581-0660
1
2
3
4
5
6
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
Respondent.
ORDER OF CHILD SUPPORT

TEMPORARY
(TMORS)
Clerks Action Required
12
I. JUDGMENT SUMMARY
13
1.1
Judgment Summary for Non-Medical Expenses

Does not apply.
1.2
Judgment Summary for Medical Support

Does not apply.
14
15
16
II. BASIS
17
2.1
Type of Proceeding
18
19
This order is entered under a petition for dissolution of marriage or domestic

partnership1 legal separation, or declaration concerning validity:
20
hearing for temporary child support.
21
2.2
Child Support Worksheet
22
23
The child support worksheet which has been approved by the court is attached to
this order'and is incorporated by reference or has been initialed and filed separately and
is incorporated by reference.
Temporary Order of Child Support
Page 1

1200 Westlake A\e. N.* Suite 700
Seattle. Wadiiiilmi 9ft109
Tel: (206) J4ft-1010- Ka\: (206)448-0736
Email- TSA It I
rJONK5.COM
1
2.3
Other
2
3
III. FINDINGS AND ORDER
4
It Is Ordered:
5
3.1
Child for Whom Support is Required
6
Name (first/last)
Age
Kaena Kalii
7
8
3.2
Person Paying Support (Obligor)
9
Name:
Birth date:
Service Address:
10
11
12
13
14
15
CT'OtfW
/i-ZQ-W
970
^ S u ) _______
(-JYiceoJociol ( <*j A- CfS
______
The Obligor Parent Must Immediately File With the Court and the Washington
State Child Support Registry, and Update as Necessary, the Confidential
Information Form Required by RCW 26.23.050.
The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Promptly After any Change in the Information. The Duty to Update the
Information Continues as long as any Support Debt Remains due Under This
Order
16
17
For purposes of this Order of Child Support, the support obligation is based upon the
following income:
18
A.
Actual Monthly Net Income: $
3.3
Person Receiving Support (Obligee)
^ 0^3'
19
20
21
Name:
Birth date:
Service Address:
22
23
The Obligee Must Immediately File With the Court and the Washington State Child
Support Registry and Update as Necessary the Confidential Information Form
Page 2
C O U M S K K C & JO N E S I U .C
IZIIO Westlake Asc. N Suilc 700
Seville, Wilmington 98100
Tel: (106) 4-18-1010 - Kan: (206H48-0736
Kmail-ISAltl.VffiCOUlKKIiCJOM'lS.rO.M
Required by RCW 26.23.050.
The Obligee Shall Update the Information Required by Paragraph 3.3

Promptly After any Change in the Information. The Duty to Update the
Information Continues as Long as any Monthly Support Remains Due or any
Unpaid Support Debt Remains Due Under This Order.
3
4
5
For purposes of this Order of Child Support, the support obligation is based upon the
following income:
g
A.
Actual monthly Net Income: $ H O T S , ? /
7
8
The obligor may be able to seek reimbursement for day care or special child
rearing expenses not actually incurred. RCW 26.19.080.
3.4
10
11
12
Service of Process
Service of Process on the Obligor at the Address Required by Paragraph

3.2 or any Updated Address, or on the Obligee at the Address Required by
Paragraph 3.3 or any Updated Address, may Be Allowed or Accepted as Adequate
in any Proceeding to Establish, Enforce or Modify a Child Support Order Between
the Parties by Delivery of Written Notice to the Obligor or Obligee at the Last
Address Provided.
13
3.5
Transfer Payment
14
15
16
17
The obligor parent shall pay the following amounts per month for the following
children): f r s U a j 0 /
t
M CffriLo
T4kfA/e 'Asrv
Ttter
' N a m e ^ ^ A m o u n ? ^ 7'3 ne&L7ir
Kaena Kallii
$ (/ G\<Ch oc>
18
Total Monthly Transfer Amount $
19
20
21
[]
The court finds that the obligors child support obligations owed for all his
or her biological or legal children exceed 45% of his or her net income and it is [ ] just
[ ] unjust to apply the 45% limitation based upon the best interests of the child(ren) and
the circumstances of each parent as follows:
22
23

Page 3
COUHJKItC <s ,j o m :s
n .i .c
1100 West litki A n1, N Suilc 700
Scuttle, W in liiitjtto n 0SIO*)
Tel: (200) AJJt-llMII - l-ns: (2<I(.H48-07.W

Kmuil- ISAlUNruCOl.hltKite.lONKS.COM
The Obligor Parent's Privileges to Obtain or Maintain a License, Certificate,

Registration, Permit, Approval, or Other Similar Document Issued by a Licensing
Entity Evidencing Admission to or Granting Authority to Engage in a Profession,
Occupation, Business, Industry, Recreational Pursuit, or the Operation of a Motor
Vehicle may Be Denied or may Be Suspended if the Obligor Parent is not in
Compliance With This Support Order as Provided in Chapter 74.20A Revised
Code of Washington.
3.6
2
3
4
Standard Calculation
$ -~?X2>
___ per month. (See Worksheet line 17.)
3.7
[]
The child support amount ordered in paragraph 3.5 does not deviate from the
standard calculation.
The child support amount ordered in paragraph 3.5 deviates from the standard
calculation for the following reasons:
10
Reasons for Deviation From Standard Calculation
11
12
13
14
[]
Income of other adults in the household of the parent requesting a
deviation for other reasons;
fp
The chi Id(TerT^spend (s) a significant amount of time with the parent who is
obligated to make a support transfer payment. The deviation does not result in
insufficient funds in the receiving parents household to meet the basic needs of the
child(ren). The child(ren)"do(es) not receive public assistance;
TJôblkpjMTasêîaUijshed-tbatihs-^^
15
'obligee'has-'^stabirsh^d that iFis unjust to apply4h@-slf-supWrt
16
17
[]
18
Other reason(s) for deviation:

The factual basis for these reasons is as follows:
19
20
21
22
23
3.8
Reasons why Request for Deviation Was Denied

W
{]
[j
Does not apply. A deviation was ordered.

A deviation was not requested.
The deviation sought by the [ ] obligor [ ] obligee was denied because:
[]
no good reason exists to justify deviation,
t ].
other:. . . .

Page 4
COLDliEKC A- JONES PLIX

120(1 Westlake i \ \ e . N., Suite 700
Scuit1(\ WavhiupUm 98100
Tel: (206) 448-1U10- \ ' * \ : (206)448-0736
Email- I SA EUSffiCOI JWEFUJJONES.COM
1
3.9
Starting Date and Day to Be Paid
2
Starting Date:
C TtV Ly
Day(s) of the month support is due:
3
4
3.10
*0tC
3*0/7/_________
Incremental Payments
Does not apply.
5
6
3.11
Select Enforcement and Collection, Payment Services Only, or Direct Payment:
[]
Enforcement and collection: The Division of Child Support (DCS) provides
support enforcement services for this case because: [ ] this is a public assistance
case, [ ] this is a case in which a parent has requested services from DCS, [ ] a parent
has signed the application for services from DCS on the last page of this support
order. (Check all that apply.) Support payments shall be made to:
9
10
11
12
Making Support Payments
Washington State Support Registry

P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or 1-800-442-5437
13
14
[]
Payment services only: The Division of Child Support will process and
keep a record of all payments but will not take any collection action. Support payments
shall be made to:
15
17

P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or 1-800-442-5437
18
Direct Payment: Support payments shall be made directly to:
19
Name_
Mailing Address_______
16
20
21
22
23
A party required to make payments to the Washington State Support Registry will
not receive credit for a payment made to any other party or entity. The obligor parent
shall keep the registry*informed whether he or she has access to health insurance
coverage at reasonable cost and, if so, to provide the health insurance policy :v
information.
' :
.

Page 5
( ; o u >i i i ; k <; & .j o n k s v i a x :

HIM) WVslLakc Avc, N Suilr 700
Scat lie. WacliiiiKlmi OS 101
Tel: (206)448-11)10 - Kan: (206)448-0736
Kmail- TSAItliMS'iCOl.llHKKC.JONKS.COM
Any time the Division of Child Support is providing support enforcement services
under RCW 26.23.045, or if a party is applying for support enforcement services by
signing the application form on the bottom of the support order, the receiving parent
might be required to submit an accounting of how the support, including any cash
medical support, is being spent to benefit the child(ren).
3.12
Withholding action may be taken against wages, earnings, assets, or benefits,

and liens enforced against real and personal property under the child support statutes of
this or any other state, without further notice to the obligor parent at any time after entry
of this order unless an alternative provision is made below:
1
2
Wage Withholding Action
7
8
9
10
11
12
[If the court orders immediate wage withholding in a case where Division of Child
Support does not provide support enforcement services, a mandatory wage assignment
under Chapter 26.18 RCW must be entered and support payments must be made to the
Support Registry.]
Wage withholding, by notice of payroll deduction or other income
withholding action under Chapter 26.18 RCW or Chapter 74.20A RCW, without further
notice to the obligor, is delayed until a payment is past due, because:
^
the parties have reached a written agreement that the court
approves that provides for an alternate arrangement.
13
14
15
[]
the Division of Child Support provides support enforcement
services for this case [see 3.11] and there is good cause [as stated below under "Good
Cause"] not to require immediate income withholding which is in the best interests of the
child(ren) and, in modification cases, previously ordered child support has been timely
paid.
16
17
[]
the Division of Child Support does not provide support enforcement
services for this case [see 3.11] and there is good cause [as stated below under "Good
Cause"] not to require immediate income withholding.
18
Good Cause:
19
20
21
3.13
Termination of Support
22
23
Support shall be paid provided that this is a temporary order, until a subsequent
child support order is entered by this court. ..
*.

Page 6
c o k d b k iu ; a j o n k s p k l c
1200 WVslIakc A\ e. N., Suite 700
Seattle, Wnthingimi 9K1 09
Tel: (206)448-1010(206)448-0736
Kmail- ISAinNrftCOUHJKRCJONKS.COM
3.14
Post Secondary Educational Support
The right to request post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.
3
4
3.15
Does not apply because all payments, except medical, are included in the
transfer payment.
S'
. c
The petitioner shall pay
% and the respondent
^
%
(each'parents proportional share of income from the Child Support Schedule
Worksheet, line 6) of the following expenses incurred on behalf of the child(ren) listed in
Paragraph 3.1:)
[]
day care.
[]
educational expenses.
[]
long distance transportation expenses.
[]
other:
6
7
8
9
Payment for Expenses not Included in the Transfer Payment
10
11
Payments shall be made to [ ] the provider of the service [ ] the parent

receiving the transfer payment.
12
13
3.16
14
15
Periodic Adjustment
Does not apply.
3.17
Income Tax Exemptions
16
Tax exemptions for the child(shall be allocated as follows:
17
The parents shall sign the federal income tax dependency exemption waiver.
fZ e s & u /6 >
18
3.18
Medical Support - Health Insurance
19
Each parent shall provide health insurance coverage for the child(ren) listed in
paragraph 3.1, as follows:
20
21
3.18.1 Health Insurance (either check box A(1), or check box A(2) and complete
sections B and C Section D applies in all cases.)
22
A.
23
Evidence
There is sufficient evidence for the court to determine which parent must provide
coverage and which parent must contribute a.sum certain. Fill in B and C below. .

Page 7
(.'OLPliEltG & JONES I'LLC

1200 Westlake Ave, N*. Sidle 700
Seal tie. Washington 9RlttlJ
Tel: (206) 448-1010- Y a x : (ZlirH4K<4173fi
Email- TSAIJIN^fiOLDItEIUJJONES.COM
1
B.
Findings about insurance:
2
The court makes the following findings:
3
John Kalii
Beth Kalii
4
11
5
6
[X]
7
8
9
[ i
10
[ ]
11
12
13
11
14
15
[ ]
16
17
18
i i
[ ]
t i
[ ]
19
20
21
Check at least one of the following findings

for each parent.
Insurance coverage for the child(ren) is
available and accessible to this parent at
$
cost (child(ren)s portion of the
premium, only).
'
(
s
$ Q - 'iH
premium, only).
available but not accessible to this parent at
$
premium, only).
$
premium, only).
Neither parent has available or accessible
insurance through an employer or union; but
this parent is able to provide private coverage
at a cost not to exceed 25% of this parents
basic support obligation.
(Check only one parent) Both parties have
available and accessible coverage for the
child(ren). The court finds that this parent has
better coverage considering the needs of the
child(ren), the cost and extent of each parents
coverage, and the accessibility of the
coverage.
Other:
22
23

Page 8
COI.DKKKC & JONES 1MTC

1200 Wrstliiki AVI'. Suite 7011
S o tlk , Wiishiiiglun 98109
Tel: (206) 448-101(1- K.n: (206)448-0736
Km all- ISA HI.SVoKiOl.DHKRCl.lOA KS.COM
o
1
ir"i
()
C.
Parties obligations:
The court makes the following orders:
2
John Kalii
Beth Kalii
11
[X]
11
f-
11
[ ]
i ]
[ ]
11
[ ]
rj
3
4
,
H
n"i
H
6
7
if)
10
11
r12
13
14
15
16
Check at least one of the following options

for each parent.
This parent shall provide health insurance
coverage for the child(ren) that is available
through employment or is union-related as
long as the cost of such coverage does not
exceed 25% of this parents basic support
obligation.
through employment or is union-related
even though the cost of such coverage
exceeds 25% of this parents basic support
obligation. It is in the best interests of the
child(ren) to provide such coverage despite
the cost because T U fy fS
n
77/iT
Q e Z 'v
7 * o w /lf J /L D Z t& P
This parent shall provide private healtn
insurance coverage for the child(ren) as long
as the cost of such coverage does not exceed
25% of this parents basic support obligation.
This parent shall provide private health
insurance coverage for the child(ren) even
though the cost of such coverage exceeds
It is in the best interests of the child(ren) to
provide such coverage despite the cost
because:
17
18
19
20
21
22
23
h
Page 9
(7
This parent shall pay $

towards the
health insurance premium being paid by the
other parent. This amount is this parents
proportionate share of the premium or 25% of
this parents basic support obligation,
whichever is less. This payment is only
required if this parent is not providing
insurance as described above.
This parents contribution to the health
insurance premium is calculated in the
Worksheet and included in the transfer
1 '
payment.
G O M H iE K C & .i o n k s i m j . c
1200 Weil Inkc A VC. N., Suilc 700
Scalllc. Wiishinglon 08109
I'd: (206) 448-1010 - K;u: (206)448-0736
Kmsil- TMfllAW mLlHIKItO.IONKS.COM
[ ]
2
3
[ ]
This parent shall be excused from the

responsibility to provide health insurance
coverage and from the responsibility to
provide monthly payment towards the
premium because:
4
(Only one parent may be excused.)
5
6
7
D.
Both parties obligation:
If the child(ren) are receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parents monthly premium.
8
9
10
11
12
13
14
15
16
The parent(s) shall maintain health insurance coverage, if available for the child(ren)
listed in paragraph 3.1, until further order of the court or until health insurance is no
longer available through the parents employer or union and no conversion privileges
exist to continue coverage following termination of employment.
A parent who is required under this order to provide health insurance coverage is liable
for any covered health care costs for which that parent receives direct payment from an
insurer.
A parent who is required under this order to provide health insurance coverage shall
provide proof that such coverage is available or not available within 20 days of the entry
of this order to the other parent or the Washington State Support Registry if the parent
has been notified or ordered to make payments to the Washington State Support
Registry.
18
If proof that health insurance coverage is available or not available is not provided within
20 days, the parent seeking enforcement or the Department of Social and Health
Services may seek direct enforcement of the coverage through the other parents
employer or union without further notice to the other parent as provided under Chapter
26.18 RCW.
19
3.18.2 Change of Circumstances and Enforcement
20
A parent required to provide health insurance coverage must notify both the Division of
Child Support and the other parent when coverage terminates.
17
21
22
23
If the parents circumstances change, or if the court has not specified how medical
support shall be provided, the parents medical support obligations will be enforced as
provided in
; .. T
v
RCW.26:18.170.,,If a parent.does not provide proof of accessible coverage for the
child(ren):throughprivate insurance, a parent may be required to satisfy his or her
./.
Tem porary Order of Child Support
Page 10
COl.DliKRC & JONKS PLLC

1 2 0 0 W r s t i a k c A s c . N .. S u it e 7 0 0
S e a l tie ,. W a s h i n g ! [i n 9 (1 10 0
T e l: (2 0 6 ) 4 4 8 - 1 0 1 0 - F a * : (2 0 6 )4 4 8 -0 7 3 6
E m a i l - T S A I ! I . V i 'S i C O l . l ) I t F K ( i J O S 'K S . C O M
medical support obligation by doing one of the following, listed in order of priority:
1)
Providing or maintaining health insurance coverage through the parents
employment or union at a cost not to exceed 25% of that parents basic support
obligation;
2)
Contributing the parents proportionate share of a monthly premium being paid by
the other parent for health insurance coverage for the child(ren) listed in paragraph 3.1
of this order, not to exceed 25% of the obligated parents basic support obligation; or
3)
Contributing the parents proportionate share of a monthly premium paid by the
state if the child(ren) receives state-financed medical coverage through DSHS under
RCW 74.09 for which there is an assignment.
3
4
5
6
7
8
A parent seeking to enforce the obligation to provide health insurance coverage may
apply for support enforcement services from the Division of Child Support; file a motion
for contempt (use form WPF DRPSCU 05.0100, Motion/Declaration for an Order to
Show Cause re Contempt); or file a petition.
9
3.19
Uninsured Medical Expenses
10
11
12
13
14
Both parents have an obligation to pay their share of uninsured medical expenses.
The petitioner shall pay G
_____ % of uninsured medical expenses (unless stated
otherwise, the petitioners proportional share of income from the Worksheet, line 6) and
the respondent shall pay
_____ % of uninsured medical expenses (unless stated
otherwise, the respondents proportional share of income from the Worksheet,
line 6).
**T'*4fr*Lc
t/vclur&jA-y
f f a t d-Gd-Lr# / * s s o n f a x *
rt is //vtLuv&o ^ rfr?
/ ^ re v s t f / X i r t T f * * # } - S ' 3.20 Back Child Support
(N
No back child support is owed at this time.
No back interest is owed at this time.
15
16
17
3.21
Past Due Unpaid Medical Support

No past due unpaid medical support is owed at this time.
No back interest is owed at this time.
18
19
20
21
3.22
Other Unpaid Obligations

[]
[.]..
Other obligations that may be owed are not affected by this order.
Back interest that may be owed is not affected by this order.
22
23
:{
, <
r
(N am e)________________is awarded a judgment against

x:;. . f . .____________ in the amount of $ . >. ,-< :y ..Tor other ______._____:_______ forthe period from:(date) -
Tem porary Order of Child Support

Page 11
C O LD IS K R C & JO N K S IM .I.C
1200 WVstliikc A ir. N..Siiilr 700
Sfitltlc, Washington JB1(19
Tel: (206) 448-1010 - Fas: (20(>H4N-0736
Krnail- 'rSAUIN(!nOU)UKU(;.IOM'.S.(;().VI
1
2
through (date)
3.23
Other
3
4
5
Dated: ^ j
1^ f
6
7
8
Presented by:
GOLDBERG JONES PLLC
'9
10
11
12

13
14
15
16
17
18
19
20
21
22
23

Page 12

[ ] Proposed by [ ]
Or, [ 1 Signed by the Judicial/Reviewing Officer. (CSW)
Mother Beth Kalii

County PIERCE :
(CSWP)
Father John Kalii

Case No. ,14-3-01646-7
C h ild (re n ) a n d A g e (s ): Ka'ena Kalii, 8

P a rt I: In c o m e (see Instructions, page 6)
1. Gross Monthly Income

c. Business Income
d.Maintenance Received
e.Other Income
f. Imputed Income
F a th e r
$ 4 ,352 .37
5. Basic Child Support Obligation (Combined amounts ->)

Ka'ena Kalii
$887.00

$ 2 ,667 .00
$4,352.37
$ 2 ,667 .00
$323.4 6
$19.86
$123.89
$5.35
$46.10
$254.11
a.lncome Taxes (Federal and State) Tax Y e a r M anual

b.FICA (Soc.Sec.+MedicareVSelf-Employment Taxes
g.Maintenance Paid
M o th e r
$323.46
$449.31
$ 2 ,217 .69
$4 ,028.91
$6,246.60
"
- v- ';
$887.00
.645
h t-
'i
r *,
ji
.355
WSCSS-Worksheets Mandatory (CSW/CSWP) 07/2013 Page 1 o f 5

-
P a r t II: B a s ic C h ild S u p p o r t O b lig a tio n
(see Instructions, page 7)
7. Each P arent's Basic Child S upport O bligation w itho ut consideration

of low incom e lim itations (Each parent's Line 6 tim es Line 5.)
$ 5 7 2 .1 2
$ 3 1 4 .8 8
8. C alculating low incom e lim itations: Fill in only those that apply.
S e lf-S up p ort R eserve: (125% o f the Federal P overty G uideline.)
a. Is com bined N et Incom e Less T han $ 1 .0 0 0 ? If v e s . fo r each

p arent e nte r the presum ptive $ 5 0 p e r c h ild .
b. Is M onthlv N et Incom e Less Than Self-SuDDort R eserve? If v e s .
fo r th at parent e nte r the p resum ptive $50 p e r c h ild .
c. Is M onthlv N et Incom e eaual to or m ore than Self-SuDDort
R eserve? If y e s . fo r each parent subtract the self-su pp ort
reserve from line 3. If th at am o un t is less than line 7, e nte r that
am o un t or the p resum ptive $50 per child, w h ich e ve r is greater.
9. Each parent's b asic child support obligation after calculating
a pplicable lim itations. For each parent, e nte r the low est am ount
from line 7, 8a - 8c, but not less than the p resum ptive $50 per
child.
$ 1 ,2 1 6 .0 0
$ 5 7 2 .1 2
$ 3 1 4 .8 8
P a rt III: H e a lth C a re , D a y C a re , a n d S p e c ia l C h ild R e a rin g E x p e n s e s (see Instructions, page 8)
10. H ealth C are E xpenses
F a th e r
a. M onthly Health Insurance Paid fo r C hild(ren)

b. U ninsured M onthly Health C are E xpenses Paid fo r C hild(ren)
c.T o ta l M onthly Health C are E xpenses
M o th e r
-
$ 2 3 4 .3 4
d. C om bined M onthly Health C are Expenses

$ 2 3 4 .3 4
ft
$ 2 3 4 .3 4
11. D ay C are and Special E xpenses

a. D ay C are E xpenses
b. Education E xpenses
c. Long D istance T ransportation E xpenses
d. O th e r Special E xpenses (describe)
'
e.T otal D ay C are and Special E xpenses

(Add lines 11a through 11 d)
12. C om bined M onthly Total D ay C are and Special E xpenses

13. T otal Health C are, D ay C are, and Special E xpenses (line 10d
plus line 12)
' 4
14. Each P arent's O bligation fo r Health C are, D ay C are, and Special

E xpenses (m ultiply each n um be r on line 6 by line 13)
$ 2 3 4 .3 4
$ 1 5 1 .1 5
$ 8 3 .1 9
15. G ross Child S u pp o rt O bligation (line 9 plus line 14)
$ 7 2 3 .2 7 |
$ 3 9 8 .0 7
P a r t V : C h ild S u p p o r t C r e d its (see Instructions, page 9)
16. C hild S upport C redits

a. M onthly Health C are E xpenses C redit
b .D a y C are and Special E xpenses C redit
$ 2 3 4 .3 4
-
c. O th e r O rdin ary E xpenses C re dit (describe)

-
d .T ota l S u pp o rt C redits (add lines 16a through 16c)
$ 2 3 4 .3 4
P a r t V I: S ta n d a r d C a lc u la tio n /P r e s u m p tiv e T r a n s fe r P a y m e n t (see Instructions, page 9)
17. S tandard C alculation (line 15 m inus line 16d or $50 per child
w h ich e ve r is greater)
$ 7 2 3 .2 7
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
P a rt V II: A d d it io n a l In fo r m a tio n a l C a lc u la tio n s
18. 45% o f each parent's net incom e from line 3 (.45 x am o un t from
line 3 fo r each parent)
19. 25% o f each parent's b asic su pp ort obligation from line 9 (.25 x
a m o u n t from line 9 fo r each parent)
P a r t V III: A d d it io n a l F a c to r s f o r C o n s id e r a tio n (see instructions, page 9)
20. H ousehold A ssets

(List th e e stim a te d va lu e o f all m a jo r house h o ld asse ts.)
Father's
H ousehold
M other's
H ousehold
a. Real Estate
b. Investm ents
c. V e hicles and Boats
d .B a n k A cco un ts and C ash
e. R etirem ent A cco un ts
f. O ther: (describe)
.
.
-
21. H ousehold D ebt

(List liens a ga in st household assets, e xtraordinary debt.)
a.
b.
c.
d.
e.
f.
22. O th e r H ousehold Incom e

a. Incom e O f C urren t Spouse or D om estic P artner
(if not the o the r parent o f this action)
N am e
N am e
b. Incom e O f O th e r A d ults in H ousehold
N am e
N am e
c.G ro s s Incom e from overtim e or from second jo b s the party
d. Incom e O f C h ild r e n ) (if considered e xtraordinary)

N am e
N am e
e .ln co m e From C hild S upport

N am e
Nam e
f. Incom e From A ssista nce Program s

Program
Program
g .O th e r Incom e (describe)
23. N on-R ecurring Incom e (describe)
24. C hild S u pp o rt O w ed, M onthly, fo r Biological or Legal

C hild(ren )
N am e/age:
Paid [ ] Y es [ l No
N am e/age:
Paid [ ] Y e s [ l No
N am e/age:
Father's
H ousehold
M other's
H ousehold
25. O th e r C hild(ren) Living In Each H ousehold

26.
O th e r F actors For C onsideration

W S C S S -W orksheets - M a n d a to ry (CSW/CSWP) 07/2013 Page 5 o f 5
c:\program files (x86)\legalplus\state templates\waworksheet.dtf m:\scdafa\kalii\kalii.scp 07/03/2014 03:07 pm
SupportCalc 2014
M other: Beth Kalii

C ounty: PIER C E
Father: John Kalii

S uperior C ourt C ause N um ber: 14-3-01646-7
R E S ID E N T IA L S C H E D U L E C R E D IT U S IN G F O R M U L A
16. NAM ES OF C H ILD R E N

17. BASIC S U P P O R T
(From T able)
18. O R D IN A R Y EX PE N S E S
19. A D JU S T E D BASIC S U P P O R T
20. O V E R N IG H T S W ITH M O T H E R
21. % O V E R N IG H T S W ITH M O T H E R
22. O V E R N IG H T S W ITH F ATH ER
Ka'ena Kalii
$887.00
$887.00
183
50.1
182
23. % O V E R N IG H T S -F A T H E R
49.9
24. M O T H E R S C R E D IT PR O P
.500
25. F A T H E R S C R E D IT PR O P
.500
26. M O T H E R S C R E D IT
$443.50
27. F A T H E R S C R E D IT
$443.50
28. O V E R N IG H T T H R E S H O L D S E LE C T E D :
91 N IG H TS
29. T R A N S F E R P A Y M E N T BE FO R E C R ED IT:
30. R E S ID E N T IA L C R E D IT TO F ather IS:
$723.27
$443.50
31. T R A N S F E R P A Y M E N T A F T E R C R ED IT:
$279.77

SupportCa/c 2 0 1 4 {R e v . 1 0 /2 0 0 9 )
CcpyrtQht 25*4 r?y LtsaHPiuft Software Group m
z.

COUNTY OF PIERCE
10
11
No. 14-3-01646-7
12
JOHN A. KALII,
Temporary Order
(TMO)
13
and
Petitioner,
14
BETH A. KALII,
Respondent.
15
[] Clerks Action Required

[ ] Law Enforcement Notification, H
3.1
I. Money Judgment Summary
16
17
Does not apply.
18
II. Basis
A motion for a temporary order was presented to this court and the court finds
reasonable cause to issue the order.
III. Order
22
23
24
25
it is Ordered:
3.1
Restraining Order
There are no restraining orders in effect under this cause number and the court is
not entering one now.
T e m p O rd e r (T M O ) - P a g e 1 o f 4
W PF DR 04.0250 Mandatory (06/2012) - R C W 26.09.060; .110;. 120;. 194, .300(2)

S:\G4SES1 \Kalii\DRAFTS\Pleadings\Temporary Order.docx

253-581-0660
3.2
Temporary Relief
2
3
4
5
th representing the cost of his
JOHN KALII shall pay to 6ETH

health care insurance.
JOHN KALII shall pay m HI- I h r<"Xlt H ? 1! per month representing 76% of the
cost of the childs health care insurance.
JOHN KALII shall m v to
pension income.
J
r month representing 3.5% of his
Starting Date:
Day(s) of the month payment is due:
8
9
-jtjgBPAUPf l a rQ
^0 g **
- p ^ t/tc & p rn ^ ju ( y
ymex/T
By W> eFt/ort/f
Payments shall be made to:
10
[]
11
the Washington State Child Support Registry (if child support is

ordered).
directly to the other spouse or domestic partner.
the clerk of this court as trustee for remittance to the other spouse or
domestic partner (if there are no dependent children).
Other:
12
13
[]
14
Child support shall be paid in accordance with the order of child support,
signed by the court.
15
The parties shall comply with the Temporary Parenting Plan signed by the
court.
16
17
BOTH PARTIES are restrained and enjoined from transferring, removing,

encumbering, concealing or in any way disposing of any property except in
the usual course of business or for the necessities of life and requiring each
party to notify the other of any extraordinary expenditures made after the
order is issued.
18
19
20
21
[]
22
BOTH PARTIES are restrained and enjoined from assigning, transferring,

borrowing, lapsing, surrendering or changing entitlement of any insurance
policies of either or both parties whether medical, health, life or auto
insurance.
23
24
25
BOTH PARTIES are restrained and enjoined from removing any of the
children from the state of Washington.
Each party shall be immediately responsible for their own future debts
whether incurred by credit card or loan, security interest or mortgage.
T e m p O r d e r (T M O ) - P a g e 2 o f 4
W PF DR 04.0250 Mandatory (0 6 /2 01 2)-R C W 26.09.060; .110; .120; .194,. 300(2)

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Order.docx
5920-100 S treet SW, Ste 25

Lakew ood W A 98499
253-581-0660
1
2
Responsibility for the debts of the parties is divided as follows:

(y\cnW ^ 'S fy A ll /MA jH/TA/SJ A \)
&&&
-f/X lL M ^ /e O s / / ? ZZc
s
y
j
/bul> QTWFrt
4
5
&
The family home shall be occupied by the^petitioner [ ] respondent.
[]
Use of property shall be as follows:
[]
JOHN KALII shall pay temporary attorney fees, other professional fees and
costs in the amount of $_
to: FAUBION, REEDER,
FRALEY & COOK, P.S.
[]
Other:
8
9
10
11
12
13
14
15
16
17
18
19
K,
20
Dated:___2 . /
/ W
J udge/cbm miss ione r
T^T^l
21
22
23
24
25
bylARRY COUTURE
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
Approved and agreed


Thomas Sabin, WSBA #77^8"-------Attorney for Respondent
T e m p O rd e r (T M O ) - P a g e 3 o f 4
W PF D R 04.0250 Mandatory (06/2012) - R C W 26.09.060; .110;. 120;. 194, .300(2)

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Order.docx

Lakewood, W A 98499
2 53-581-0660
1
2

A signature below is actual notice of this
order.

order.
3
4
Date
Date
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
T e m p O r d e r (T M O ) - P a g e 4 o f 4

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Orc/er.c/ocx
5920-100 S treet SW , Ste 25

Lakewood, W A 98499
253-581-0660
E-FILED
July 23 2014 12:42 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
IN A N D F O R P IE R C E C O U N T Y
JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
NOTE FOR MOTION DOCKET
vs.
BETH ANN KALII

Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO OPPOSING PARTY:
Name: Daniel N Cook

Name: THOMAS R. SABIN
Address: null
Phone: (253) 581-0660

Phone: null
Attorney for Petitioner/Plaintiff
Please take notice that the undersigned will bring on for hearing a motion for:
M o t io n - R e v is io n
C a le n d a r : STEPHANIE A. AREND
CALENDAR DATE: Friday, August 15, 2014 9:00 AM

WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
P A R T Y S E T T IN G H E A R IN G S H A L L C O N F IR M B Y N O O N T W O C O U R T D A Y S P R IO R T O H E A R IN G
Submitted by:
DATED:
July 23, 2014.
Signed:
/s/ THOMAS RAYMOND SABIN
NAME:
THOMAS RAYMOND SABIN
Phone:
(206) 448-1010
WSBA#:
For:
7748
ADDRESS: 1200 Westlake Ave N Ste 700
Seattle, WA 98109-3529
Note for Motion Docket (ntmtsup.rptdesign)
1 of 1
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 23 2014 12
KEVIN STO
COUNTY CL
NO: 14-3-0H
2
3
4
5
6
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
MOTION FOR REVISION OF

COMMISSIONER RULING ON JULY 14,
2014
Respondent.
12
I. MOTION
13
COMES NOW Petitioner, by and through his attorney of record, Thomas R.

14
Sabin, of Goldberg Jones PLLC and moves the court for a revision of Commissioner pro
15
tern Larry Coutures ruling from the hearing held on July 14, 2014.
16
Counsel specifically requests the following revisions:
17
1. The court enter the temporary parenting plan proposed by the Petitioner.
2. The court should change the temporary order of child support to reflect no
18
19
20
transfer payment be ordered.

3. The court should change the temporary order deleting the temporary
undifferentiated support ordered in the amount of $1,050 which includes $150.00 of
child support and order that the Petitioner contribute $458.65 towards the cost of health
21
22
insurance for the Petitioner and his contribution to his proportional share of the costs of
the health insurance for minor child.
23
Motion for Revision of Commissioners Ruling

Page 1
GOLDBERG & JONES I LLC

Tel: (206) 448-1010- Fax: (206)448-0736
1
2
DATED July 23, 2014
3
4

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Motion for Revision of Commissioners Ruling

Page 2
GOLDBERG & JONES lLLC

Tel: (206) 448-1010 - Fax: (206)448-0736
Email-TSABIN@GOLDBEUGJONES.COM
E-FILED
July 30 2014 12:31 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
IN A N D F O R P IE R C E C O U N T Y
JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
NOTE FOR MOTION DOCKET
vs.
BETH ANN KALII

Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO OPPOSING PARTY:
Name: Daniel N Cook

Name: THOMAS R SABIN
Address: null
Phone: (253) 581-0660

Phone: null
Attorney for Petitioner/Plaintiff
Please take notice that the undersigned will bring on for hearing a motion for:
M o t io n - R e v is io n
C a le n d a r : STEPHANIE A. AREND
CALENDAR DATE: Friday, September 05, 2014 9:00 AM

WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
P A R T Y S E T T IN G H E A R IN G S H A L L C O N F IR M B Y N O O N T W O C O U R T D A Y S P R IO R T O H E A R IN G
Submitted by:
DATED:
July 30, 2014.
Signed:
/s/ THOMAS RAYMOND SABIN
NAME:
Phone:
(206) 448-1010
WSBA#:
For:
7748
ADDRESS: 1200 Westlake Ave N Ste 700
Note for Motion Docket (ntmtsup.rptdesign)
1 of 1
E-FILED
PIERCE COUNTY, W ASHING Ti
August 04 2014 3:09 PM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

COUNTY OF PIERCE
8
9
10
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
11
and
12

Order
(MTAF)
BETH A. KALII,
13
_________________________ Respondent.
14
15
16
17
I. Motion
which:
Approves the parenting plan which is proposed by BETH KALII,
18
DATED this
day of July 2014.
FAUBiQN, REEDER, FRALEY & COOK, P.S.
19
20
21
22
II. Declaration
23
24

S:\CASES1\Kalii\DRAFTS\PleadingsWlotion for Temporary Order 3.doc

Lakewood, W A 98499
253-581-0660
1
A temporary residential schedule for the parties child was ordered on July 14, 2014, for
2
3
4
5
6
the summer schedule only. The childs residential schedule for the school year has yet to
be determined. It is necessary to put a hearing on the court calendar in advance of the
new school year so that the childs time with each parent during the school year is clearly
established.
7
8
10
Signed at (city)
(state)
on (date)
rf'
11
12
13
14
15
16
17
18
19
20
21
22
23
24

S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order 3. doc
FAUBION, REEDER,
5920 100th Street SW , Suite 25

Lakewood, W A 98499
253-581-0660
E-FILED
August 04 2014 3:09 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.
BETH ANN KALII

Respondent(s)

Phone: (206) 448-1010

Please take notice that an issue of law in this case will be heard on the date and time shown below:

CALENDAR DATE: Wednesday, August 27, 2014 9:00 AM

DATED:
August 4, 2014.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
ADDRESS: 5920 100th St SW Ste 25
WSBA#:
For:
34866
1 of 1
11miII111! MU I : in.! II
43075795
ORCNT

NO. 14-3-01646-7
JOHN A. KALII,
Petitioner,
and
BETH A. KALII,
STIPULATION AND O RDER FOR

CONTINUANCE OF HEARING ON
M OTION FOR REVISION OF
CO M M ISSIO NER'S RULING
Respondent.
STIPULATION
COM ES NO W Thomas R. Sabin, attorney for Petitioner, and Daniel Cook,
attorney for Respondent and Stipulate to a continuance of the hearing set for August 15,
2014 for Revision of the July 14, 2014 ruling of Commissioner Pro Tern Larry Couture
due to the absence of the attorney for the Petitioner for bereavement purposes and a
pre scheduled family vacation for the attorney for the Respondent. Counsel stipulate to
the continuance of the hearing to September 5, 2014 which is the next available date,
and consent tg ih e .setting of the hearing after the limitation sent in Civil Rule 59 (b).
Thomas R. Sabin, W SBA 7748

Daniel N. Cook, W SBA 34866

ORDER
The courthaving considered the above stipulation and the files and records
herein and deeming itself fully advised in the premises hereby
Stipulation and Order for Continuance of Hearing on Motion for Revision of

Commissioners Ruling
Page 1
C O U JH K R G & JONKS I l.l.C

1100 W rit lake A v r. N., Suite 700
S cju llr, W in] li lif t on 98109
Tel: (200) 448-1010 - Km: (206)148-0730
Ktitnil- T S A iIIK @ G 0 1 .D IItv itG JO iV E S .C O M
1
2
3
ORDERS, ADJUDGES and DECREES that the Revision hearing set for August
15, 2014 be continued to September 5, 2014.
DATE
y /
S? ^
/y
4
rudae/Gourt Commissioner-
5
6
Presented by:
Approved for Entry:


7
8
9
10
11
DEPT. 12
12
13
W-OPCN COUKT )
AUG 0 8 2014
^PIERCE
COjJNTf,
Clerk
14
15
16
17
18
19
20
21
22
23
Stipulation and Order for Continuance of Hearing on Motion for Revision of

Commissioners Ruling
Page 2
GOUMfEiKG Ji JONES 1*1X C

1200 Weilfokc Ave. N Suite 700
Seattle. Washington 9! 109
Tel: (200) JJS-10KI - Km: t20fiH-0736
Email- TSAI)INlSIGOl.lUlEHCJONES.COM
'COURT OF THE STATE OF WASHINGTON

iHD FOR PIERCE COUNTY
% MD
No. 14-3-01646-7 /
08-25-14
ORDER SETTING!
CASE SCHEDULI
Petitioner(s)
AU621 2014
pier c e
vs.
Type o f Case: DIC
COUHty 'lerk
Estim ated Trial (days):

Track A ssignm ent. D issolution
A ssigned D epartm ent: 20 - Judge K. A. van Doorninck
BETH AN N KALII
R espondent(s)
D ocket C ode: O R S C S
('!]I
1,1"l
Set Settlement Conference Date with Judge/Commissioner JOHN A. MCCARTHY (See PCLR 16 & PCLSPR
94.04)
Plaintiffs/Petitioners Disclosure of Primary Witnesses
12/08/14
Defendants/Re'spondents Disclosure of Primary Witnesses
01/19/15
. -L
Disclosure of Rebuttal Witnesses
H
l^M
j
Deadline for Filing Motion to Adjust Trial Date
02/23/15
Discovery Cutoff
03/30/15
Exchange of Witness and1Exhibit Lists and Documentary Exhibits
04/13/15
Joint Statement of Evidence
04/13/15
i\l
]\!
12/22/14
Settlement Conference (To be held)
r\)
02/09/15
Week Of 04/27/15
Tria!
05/11/15 9:00
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
on the date of trial.
N O T IC E T O P L A IN T IF F /P E T IT IO N E R
If the case has been filed, the p la intiff shall serve a copy o f the Case S chedule on the d efendant(s) w ith the su m m on s and
com plaint/petition: Provided th at in those cases w here service is by publication the p laintiff shall serve the C ase S chedule
w ithin five (5) court days o f se rvice o f the d efe nd a nts first response/appearanee. If the case has not been filed, but an
initial pleading is served, the C ase S chedule shall be served w ithin five (5) court days o f filing. See PCLR 3.
N O T IC E T O A L L P A R T IE S
All attorneys and parties shall m ake them selve s fa m ilia r with the Pierce C ounty Local Rules, particularly those relating to
case scheduling. C om pliance w ith the scheduling rules is m andatory and failure to com ply shall result in sanctions
appropriate to the violation. If a sta te m e nt o f arbitrability is filed, PC LR 3 does not apply w hile the case is in arbitration.
Judge K. A. Van D oorninck

D epartm ent 20 (253) 798-6688

No. 14-3-01646-7
JO H N A LIK A KALII JR
ORDER SETTING
CASE SCHEDULE
Petitioner(s)
vs.
Type o f Case: DIC

Estim ated Trial (days):
T rack Assignm ent: D issolution
BETH ANN KALII
Assigned D epartm ent: 20 - Judge K. A. van Doorninck

R espondent(s)
CC:
D ocket C ode: O R S C S .
Daniel N Cook, A tty

THOMAS RAYMOND SABIN, A tty
Page 2 of 2
S u p e r io r C o u r t
14-3-01646-7
43169102
LTR20
08-25-14
o f th e
i a t e o f W a s h in g t o n
f o r P ie r c e C o u n t y
K. A. van Doorninck, JUDGE

MICHELE TUFTS, Judicial Assistant
Department 20
(253) 798-6688
334 COUNTY-CITY BUILDING

930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108
p il e
August 21, 2014
AUG2 12014
1200 Westlake Ave N Ste 700
RE:
DANIEL N. COOK
5920 100th St SW Ste 25
JOHN ALIKA KALII JR vs. BETH ANN KALII

Pierce County Cause No. 14-3-01646-7
Dear Counsel/Litigant:
The above referenced case has been reassigned to The Honorable K. A. van Doorninck,
Department 20. The Assignment for Trial date set for September 5, 2014 has been cancelled.
Please find enclosed an Order Setting Case Schedule. If you have any questions please call
me at (253) 798-6688.
Sincerely,
MICHELE TUFTS
Judicial Assistant
Enclosure
cc:
Pierce County Clerk for filing

\
IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE

No. 14-3-01646-7
JOHN A LIK A KALII JR
Request for Reassignment

[
] For Trial
[
Issuance of Case Schedule
Petitioner(s)
vs.
BETH ANN KALII
R espondent(s)
Plaintiff/Petitioner's Attorney
PART A
] For Motion Only
J t& K -
Defen dant/Respondents Attorney

Daniel N Cook
___________________
F o r d u e c a u s e ( j u d i c i a l A s s ig n m e n t R o ta tio n !! )
O th e r
/ R e c u s a l / J u v e n ile F a m ily
C o u r t / R e fe rre d t o F a m ily C o u r t ), th e a b o v e e n title d a c tio n is r e fe r r e d t o A d m in is t r a t io n
fr o m D e p t.
/ 2 f o r r e a s s ig n m e n t.
Date: A u gu st 12, 2014

J u d g e /J u d ic ia l A s s is ta n t
PART B
a c t o n is re a s s ia n e d t e r h e a r in q t o D e p t. N o .
day o f
^ T rid /pp.m
.m . A lllf p a r tie s a re t o r e p o r t
, 20 I f
, at
//J
r e c tly ^ fn d im m e d ia te; lv
ly t o th e a b o v e n u m bb e re a d e p
e n t i f r e a s s ig n m e n t is f o r
im m e d ia te t r ia l.
(
C a s e t o re m a in in D e p t. N o __________, J u d g e ___________________________ f o r m o n it o r in g a n d
c a s e m a n a g e m e n t p u r p o s e s b u t d e c la r e d a V is it in g J u d g e (V IS I) c a s e o n __________d a y
o f ______________________ , 20______ b y P r e s id in g J u d g e ___________________________ .
A v is it in g J u d g e f r o m a n o th e r W a s h in g to n S ta te C o u n ty w ill b e a s s ig n e d t o p re s id e o v e r
t h is c a s e .
r l , /)
r\ .
/)
C a le n d a r C o o rd in a to r
lxreport.pbl/d_civil_reassignment_report (rev 10/02/09)

Printed: August 12, 2014
E-FILED
August 27 2014 1:58 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
vs.
BETH ANN KALII

Respondent(s)

Phone: (206) 448-1010

Motion - Modify Temp O rder

CALENDAR DATE: Tuesday, September 23, 2014 9:00 AM

DATED:
August 27, 2014.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
1 of 1
E-FILED
August 28 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8

COUNTY OF PIERCEI,
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Respondent.
14
15
16
17
DECLARATION OF BETH KALII

RE WORK SCHEDULE FOR
REVIEW
in support of my Motion for Temporary Parenting Plan.
This declaration is for a review hearing.
JOHN and I have already previously
18
submitted full declarations regarding the parenting plan. I am asking the court to adopt
19
my proposed parenting plan maintaining the equally shared residential schedule with both
20
parents as co-primary parents we have maintained since we separated in March 2014.
21
22
review hearing is needed because the prior Pro Tern commissioner mistakenly believed
the trial date was September 5, 2014, so the Pro Tern commissioner only ordered a
23
residential schedule for the summer. See, Clerks Minute Entry dated July 14, 2014.
24
am asking the court to maintain the alternating week on/week off in the school year.
25
S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii re Work Schedule.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00 th S tre et S W Ste 25
253-581-0660
John and I also have a history of cooperative and peaceful shared parenting.
2
In a prior declaration I explained I am a bus driver with the Clover Park School District.
3
4
5
John complained that I had to leave for work early and that caused a problem for KAENA
in the shared residential schedule.
In my prior declaration I said I would have a new
work schedule for this upcoming school year.
adult daughter. A major reason for both of these changes was to avoid early morning
wake-ups for KAENA. I also explained that my residence is only 0.36 miles from Johns
residence. See, Page 4 of Declaration of Beth Kalii filed July 3, 2014.
10
reasons, the shared residential schedule should be maintained.
11
12
I also moved into an apartment with my
For all of these
I write this supplemental declaration to explain to the court my work schedule in the
upcoming school year.
My work schedule for the 2014/2015 school year will be:
13
14
15
16
17
18
I clock in for my morning run at 7:00 a.m. and then out at 9:15 a.m.
I clock in again for a mid-morning run at 10:30 a.m. to 12:30 p.m.
I clock in again for my afternoon run at 2:00 and out at 4:15 (sometimes
4:30 depending upon weather and traffic)
This is projected to be about 6.5 hours per week.
With a week on/week off
schedule I can also pick-up additional routes on the weeks that KAENA is not with me.
Overall I anticipate working an average of almost 40 hours per week by working more
19
hours on the weeks KAENA is not with me.
20
The child care arrangements for KAENA on the weeks she is with me will be:
21
22
23
24
25
In the MORNING: I will get KAENA up around 6:15 a.m. and drop her off at
JOHNS house around 6:45 a.m. Her bus stopped at JOHNS house around
7:20 a.m. last year. This is not unreasonably early for KAENA at all.
In the AFTERNOON: KAENA will take the bus to JOHNS house. Last year
the bus stopped at his house around 2:55 p.m. I will be there to pick
KAENA generally by 4:30 p.m. but no later than 5:00 p.m.

S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration o f Beth Kalii re Work Schedule.doc
5920-100 S treet SW , Ste 25

253-581-0660
1
If JOHN does not want KAENA to come to his house in the morning or afternoon it
2
is a very simple matter to arrange brief before and after school care through the YMCA
3
programs at her school. The fact is, KAENA only needs one-half hour in the morning (30
4
5
minutes) and one hour and a half (90 minutes) of care before and after school based
upon my revised work schedule this year.
shared residential schedule with both parents.
separation and the status quo should be maintained.
10
KAENA should continue to enjoy the equally

She has done quite well since our

11
12
Signed at Lakewood, WA on August 27, 2014.
13
BETH KALII
14
15
16
17
18
19
20
21
22
23
24
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii re Work Schedule.doc

Lakewood, W A 98499
253-581-0660
SCHOOL
f DISTRICT
tody, It&diyCoHO/row.
TRANSPORTATION DEPARTMENT
Delphie Nielsen, Director
August 13, 2014
Sally Ducharme
Legal Assistant to Daniel N Cook
Faubion, Reeder, Farley & Cook
5920 100,h St Sw Suite #25
Tacoma, WA 98499
Reference: Beth Kalii - Work Schedule

Dear Ms. Ducharme:
Please accept this as official notification that Ms, Beth Kalii is an employee with Clover Park School
District's transportation as a school bus driver.
Clover Park's school year will begin on Wednesday, August 27, 2014 and is anticipated to end June 9,
2015 pending no delays in school due to inclement weather or unforeseen circumstances.
Due to her level of seniority, Ms. Kalii was able to acquire the following bus routes and schedule and will
remain as such up until Ms. Kalii bids on additional assignments if she so desires.
Regular Core Route (Morning / Afternoon)
7 :0 0 -9 :1 5 /1 4 0 0 -1 6 :1 5
Regular Assigned Mid-day
10:15-12:15
Should you have any questions regarding this information, please do not hesitate to contact me or Paul
Vigil in my absence at (253) 583-5494 or via email at dnielsen@cloverDark.k12.wa.us .
O '
Delphie Nielsen
Director of Transportation
Cc: Paul Vigil
E-FILED
IN COUNTY CLERK'S O
PIERCE COUNTY, WASH
September 02 2014 3:05

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-
3
4
5
6
IN THE SUPERIOR COURT FOR THE STATE OF WASHINGTON
)
9
IN RE:
MARRIAGE OF
)
)
10
JOHN KALII,
Cause No.14-3-01646-7
)
11
Petitioner,
versus
12
BETH ANN KALII,
13
14
)
)
Respondent.
)
)
15
16
17
18
19
Official record of proceedings

Held before the Honorable
Commissioner pro tern Larry Couture
Held on July 14, 2014
Held in Pierce County, Washington
20
21
22
23
Patricia Tuffield Transcriptionist

Flygare & Associates, Inc.
1715 South 324th Place, Suite 250
Federal Way, WA 98003
(253) 661-2711
24
25
Roger G. Flygare & Associates, Inc.
Professional Court Reporters 1.800.574.0414
APPEARANCES
2
3
4
FOR THE PETITIONER,
Thomas R. Sabin,
GOLDBERG JONES,
1200 Westlake Avenue North,
Seattle,
(206)
10
JOHN KALII:
Attorney at Law
PLLC
Suite 700
Washington 98109
448-1010
tsabin@g o l d b e r g j o n e s .com
11
12
13
14
15
FOR THE RESPONDENT,
16
Daniel Cook,
17
FAUBION REEDER FRALEY & COOK,
18
5920 100th Street Southwest,
19
Lakewood,
20
(253)
21
BETH ANN KALII:
Attorney at Law
P.S.
Suite 25
Washington 98499-2751
581-0660
d c o o k 0 f l r - l a w .com
22
23
24
25
1
2
3
4
COMMISSIONER COUTURE:
SABIN:
01646-7.
10
Okay. Are you ready on the
is it Kalii?
MR.
9:35:04
AUDIO BEGINS
MR.
Kalii.
Counsel,
COOK:
11
MR.
This is Cause No. 14-3-
identify themselves,
Good morning,
behalf of the petitioner.

motions,
Kalii.
Your Honor,
please.
Daniel Cook on
And we kind of have counter
but I think we filed the original motion first.
SABIN:
And,
may it please the Court,
12
Sabin representing John Kalii in the matter.
13
just for the sake of flow,
14
address all the issues and then I'll respond?
15
I'm Tom
And I think
why don't we have Mr. Cook
Okay,
just also for the record
16
so there's no misunderstanding.
17
case that you contacted me about the procedure that
18
Pierce County follows in dual motions.
19
Mr.
I believe this is the
Is that correct,
Sabin?
20
MR.
21
SABIN:
That is correct.
Okay.
Mr.
Sabin and I had a
22
case against each other about two months ago that we
23
tried.
24
email asking me about his ability to file,
25
have to file separately.
And because he's from Seattle,
he sent me an
or does he
I told him he could file them
at the same time,
think you should be aware that we did have that contact.
and that's the contact we had.
He didn't identify the case either,
But I
but I just kind of
assumed since they're dual motions and he's down here
that --
6
7
MR.
COOK:
What a coincidence if you had two of those
and asked the question twice,
right?
MR.
10
send it some place else,
11
I don't believe that there's any prejudice here to
12
anybody in this case,
13
question,
14
MR.
15
SABIN: . Yes.
Cook,
if you want me to
I certainly will.
COOK:
No objection,
Your Honor.
Thank you.
Thank you for that.
17
MR.
COOK:
Okay,
go ahead.
Did you have an opportunity to review the
working copies?
COMMMISSIONER COUTURE:
I did.
I reviewed all the
20
working copies that have been provided to me,
21
are a lot of them.
22
MR.
COOK:
23
And frankly,
24
are.
25
But
so.
19
Mr.
you know,
and it was just a procedural
16
18
So,
Obviously,
Roger G. Flygare
&
Well,
it's
and there
and there are a couple of motions.

I don't know how overlapping they
we have the temporary parenting plan issue
Associates, Inc.
that Mr.
motion.
Sabin brought that motion later as a counter
Originally, we had filed this as a motion for one, Mr.
Kalii, to pay his share of the medical insurance.
was really the biggest thing.
that my client on his behalf is about $731.
wanted him to pay his share of that.
his
That
Because that insurance

So, we
Or pay him pay
pay the cost of that.
We also would ask for a temporary award of the
10
pension.
11
very brief, brief time during the marriage.
12
calculation was about 7% of that pension was community.
13
A brief time before he was marry
14
that is.
15
He is in pay status.
They were married for a

My
before he retired,
And so my calculation was 7% community.
Three and a
16
half per cent would be the presumptive share that she
17
would receive.
18
that.
19
So, we were asking that she would receive
That would be about $150 dollars a month.
Subsequent to that then, along with the motion for
20
temporary parenting plan, there was a motion for
21
temporary child support which would, of course, include
22
the child's portion of the medical insurance.
23
24
25
And so, I don't know how the Court is going to kind of

amalgamate all of those things.
I mean, we believe that this status quo should remain.
That there should be a maintained, equally shared
residential schedule that the parties have maintained
since they separated.
In that event, with the parties' income disparity,
frankly, there would be a transfer payment in child
support from the father to the mother.
The basic support, I don't think we have any
disagreement on the worksheets.
basic support of dad was the obligor and mom was
I'm just using
if the
10
receiving support, the basic support would be $723.
11
full deviation for residential schedule credit would take
12
it down to $280.
13
14
15
So, somewhere in between there would be the child

support number.
But, and I think in terms of the medical insurance
16
issue, the crux of that is, who is Ms. Kalii's
17
Ms. Kalii's employer paying for?
18
Ms. Kalii is paying about $1717 per month.
19
cost of her medical insurance.
20
$849, on average.
21
who is
That's the
Her employer is paying
Ms. Kalii's insurance is $812.
And I would suggest to
22
the Court that the payment that the employer is making is
23
for the employee.
24
paying on average -- and this is one of those large,
25
shared trusts that the amount goes up and down.
Roger G. Flygare
&
That it
Associates, Inc.
the $849 the employer is
But, you
1
2
know, the $849 is an average.

I would suggest that the $849 that cover -- that the
employer is contributing to the $1770 is to cover the
employee's share of the insurance.
the spouse are additional on top of that.
are extra funds, those can be applied to those additional
obligations as each employee chooses to take them.
8
9
10
Then the child and

And if there
But the primary payment from the employer goes to the

employee's cost of the their insurance.
And so other than that, there's no real dispute on the
11
numbers.
12
insurance is $234, that should go on the worksheet.
13
the spouses' share is $731.
14
We agree that the child's portion of the

And
It's just that Mr. Kalii should pay the full amount of
15
his insurance, which is the $731.
16
the amount that the employer is paying for Ms. Kalii's
17
insurance.
18
Should be reduced by
On the parenting plan, they have, by everyone's
19
admission, had a shared residential schedule.
20
Mr. Kalii is saying "Oh, it doesn't work.
21
for the child."
22
And now
This is bad
Well, frankly, you know, this is not bad for the
23
child.
24
it on to as a counter motion to the original motion that
25
we filed.
And, you know, while it, you know, he's tagging
You know, it might make some economic
efficiency to get a temporary parenting plan entered,
it doesn't equate to this being bad for the child.
The child finished the entire school year under the
shared residential schedule.
going half-way through the summer before
way,
was filed.
And the child has been

or not half
but a good portion of the summer before this motion
And this schedule is in the child's best interest.
Essentially what it boils down to is, Mr.
Kalii says
10
"Well,
since I'm providing daycare during Ms. Kalii's
11
weeks,
I should be the primary residential parent."
12
that just simply is not the case.
13
but
And
This child should continue to have a shared
14
residential schedule with both parents.
15
for the child and for the parents that Mr. Kalii can
16
provide care for the child during the child's weeks with
17
mom.
18
child should not reside and stay overnight with this
19
mother during the mother's weeks with this child.
20
And it is a plus
But that is not a reason that she shouldn't
Now,
the
there was complaints about the early morning
21
schedule.
My client is a bus driver.
22
Now,
first of all,
frankly,
Okay?
she specifically chose a
23
route that she could pick up her child day-in and day-
24
out,
25
from school,
and take her to school every day and bring her home
and drop her off,
you know,
when they were
residing together.
year.
So, that's what she was doing last
Now, when they separated, okay, keep in mind this is a
person who's making, you know, about $13, $15 an hour,
something like that.
paying $1700, or $920 after the employer share, in
medical insurance.
available to her.
She
Not making a ton of money.
She does not have a lot of funds

She is hiring an attorney.
it took some time for her to transition into
10
housing that made sense for her.
11
got within .36 miles of the father's house.
12
be able to maintain this residential schedule.
13
She's
But when she did she

She wants to
There's not complaints that they're not getting along.
14
The conflict isn't the problem for the child.
15
the fact that dad is providing daycare is why he wants to
16
change the schedule.
17
somewhat early on mom's days.
18
And that the child has to wake up
But she was locked into a contract when she moved out
19
in March, she was locked into a contract.
20
immediately change that.
21
morning wakeup days for this child.
22
Which,
frankly,
for children,
24
work an early schedule,

But,
She couldn't
So there were some early
is not all that out of the question
23
25
It's just
certain children,
do have to get up.
mom didn't ignore that.
because their parents
Mom said "Well,
look,
if
1
2
I can ameliorate this problem,

And so,
I will."
she got a roommate who could watch the child
when she left for work early.
added a bus stop to her route so that she would be able
to pick up the child at the ordinary
time from the home where she was living temporarily,
transitioned from separating from the father and getting
her own place.
So,
She went to work and she
a more ordinary
she had done everything she can to ameliorate the
10
difficulty of this transition and change.
11
been,
you know,
12
this,
or putting her own need to residential schedule
13
above the child's.
14
and
And has not
ignoring the interests of the child in
She has been trying to keep this child as normalized
15
as possible as she begins to live in two separate homes.
16
And I think that that should continue.
17
question about that.
18
Also,
There's no
the summer schedule is lighter.
19
have to get up as early.
20
think I got served the reply declaration.
21
late also,
22
But,
You know,
She doesn't
I didn't
I don't
I think it was
so I don't know if Your Honor has seen it.
maybe it came in e-file or something.
23
assistant was out on Friday.
24
after the noon deadline.
25
just
But I
anyway,
My
it was
But I'm not objecting to it.
I read it,this weekend.
10
And, you know, one of the issues was that, you know,
if she gets the later schedule this fall, which is what
she plans to do so she doesn't have to wake the child up
when she bids a new contract.
she'll be working later in the day, in the afternoon.
And then she'll picking up the child later.
She'll be
you know,
Well, she's still going to be off by 4:30, 5:00
o'clock in the afternoon.
working an ordinary work schedule.
This is an ordinary mom

And she should not be
10
punished or prohibited from having overnights because she
11
works an ordinary work shift.
12
And so, she's going to bid a new job.
She's going to
13
be working, you know, she's got to clock in by 7:00 and
14
probably be off by 4:30 or 5:00 o'clock.
15
up the child before and after school.
16
And she'll pick
And, you know, the child will get to spend that time
17
with dad, and that's great.
18
the child should not have residential time with the mom.
19
She has a great work history.
20
evaluation.
21
That's a total red herring.
22
calling the kettle black.
23
But it's not a reason why
We filed her work
You know, they talked about her drinking.

And, frankly, that's the pot
Mr. Kalii has a relatively recent DUI. Ms. Kalii has
24
never had a DUI. And she gets regularly drug tested at
25
work .
Roger G. Flygare
&
Associates, Inc.
11
They said we didn't produce those.
to get them we can get them.
evaluations are solid.
mom.
to make the transition.
child.
So,
Well,
if we need
But the fact is her work
There is no problem with this
She did not have a lot of money.
It took some time
But she's always cared about the
the shared residential schedule should continue.
And I'll just reserve the rest.
that come up.
10
11
MR.
SABIN:
Okay,
Your Honor,
There might be questions
Mr.
Sabin?
first of all,
there are number
12
of issues.
13
request for contribution to the health insurance,
14
support,
15
The primary one is the parenting plan.
The
child
temporary orders.
I'm assuming counsel,
having not argued it,
is
16
dropping their request for a bed or couches.
17
also assuming counsel is dropping their request for
18
attorney's fees,
having not argued that.
19
MR. COOK:
20
MR.
21
22
MR.
23
With regard to the parenting plan,
24
25
SABIN:
SABIN:
And I'm
Not the attorney's fees.

Okay.
Yeah,
I bet you that surprises you.
there's a shock.
counsel kind of
misstates what's happened.
They did separate March 30th, and they were doing a
12
week here and a week there.
during school?
But what was happening
And the reason for the request for a temporary
3
4
parenting plan that he proposed, was that little eight-
year-old girl was awakened at 5:00 o'clock in the
morning, delivered to dad's house; tried to sleep some
more until 6:45 where he got her up, put her on the bus
at 7:20.
house, stay there until about 7:30 when she was picked
10
11
Following school she would then come to dad's
up.
Mom worked a 6:30 to 6:30 schedule.
And I read their
12
responsive declaration where they claim she's bidding on
13
a route that now will be starting at 7:00.
14
do not remember that in her declaration they said she
15
would be off at 5:00.
16
before and she's now starting at 7:00, it would only
17
assume that she's working a later -- even later than
18
that.
19
Didn't
But if she worked 6:30 to 6:30
So, the net affect is, this little girl was getting
20
bounced.
21
back to sleep, get up, go to school, get home from
22
school, go to dad's; then go to mom's late at night, long
23
enough, I mean, he feeds her dinner.
24
it's like, "Hi, it's now bedtime, go to bed."
25
Get out of bed, get over to dad's. Quick, get
Late enough that
So, our proposal was that during school that the child
13
be primarily with dad.
second weekend of the month where dad would have one
weekend a month.
weekends she would get four of them, and on the other
month she would get three of them.
the rest of the time.
In fact,
Weekends with mom except the
So, on months where there were five
And that they split
And split summer 50/50.
in his declaration we said during the summer
she works these weeks,
like every other week was she wasn't working.
10
So,
boom,
boom,
And it seems
we had no problem with during the summer the child
11
being with mom Friday to Friday,
12
following week.
13
boom.
So, that was what our
and then to dad the
that's what our proposal is.
14
Is during the summer go week on, week off.
15
school we have to take a look at what's happening with
16
this young 'this young girl.
17
school work's being impacted.
18
worse further up in school she gets.
19
But during
Is, she's grumpy, her

And it's only going to get
And that we a situation where she's spending the bulk
20
of her waking school
21
She should just stay there.
22
time,
non school hours at dad's house.

And we move the most of the
the other time on weekends,
to mom.
23
And the only reason this was filed was for that, to
24
address that issue, that we're causing a lot of stress on
25
this young girl; having to bounce back and forth, get up
14
1
2
early,
go to bed,
whatever.
With regards to their request for a portion of his
pension.
something that is really a trial issue.
not provided us enough data to even sit down and compute
that.
That seems like a very premature request for

And they have
They are presuming that she will be entitled to half
of
portion,
or a portion of his pension and half of that

a portion of it being community.
Not taking
10
into account what other assets she will be getting
11
awarded,
12
decisions.
13
Because,
and not taking into account the Rockwell
being a retired firefighter,
14
social security.
15
is in lieu of social security.
16
17
18
So,
distribution of his pension.

And when I said "Are they asking for spousal
maintenance?
20
data?"
maintenance,
23
property."
25
Why aren't they giving us all the financial
They came back with "Nope,
22
24
a good portion of what he's getting
I think it's premature to ask for a pre-trial
19
21
So,
he doesn't get
not asking for spousal
we want a pre-trial distribution of
And the curious thing about this.
When you do this
long enough you start looking for red flags.
What's not
15
1
2
being said?
What's obvious?
What are we not seeing?
And what's the one big thing that we're not seeing
here?
haven't seen her bank records.
We see her pay records,
and
But we don't see her bank
records.
She
even though it's been invited, we still
at least from this job.
So, we have no way to judge what -- are there other
sources of income?
resources?
What are her other financial
Is there really need here?
10
So, with regards to the child support issue which
11
would be based upon her income, and we're stuck with
12
whatever she's reported to us, I'm
13
We're saying that dad should be the primary parent,
14
and that there be a minimal transfer of the $50 for child
15
support.
16
With regards to the issue of the insurance payment,
17
it's interesting that counsel in his argument to the
18
Court made mention to the Court that the reason they were
19
doing this this way with the
20
transporting and for the school, and whatnot, was she was
21
locked into a contract.
22
Well, likewise
with regards to the
so we should keep it the same.
23
likewise, they are locked into an insurance contract
24
as
25
period.
But,
he can't get out of it until the next enrollment
16
So, we have to take a look at how do we allocate
the
employer's contribution to the overall insurance costs?
the real issue is, how do we allocate the
They want the Court to say it's all for her.
doesn't even add up.
paying an average of $849.
for something more than just her.
8
9
10
11
But that
Her insurance is $812, and they're

So clearly, they are paying
More importantly, these two parties ordered their

lives, at least for the next year, based upon "this is
what the costs will be, these are the insurance costs".
So, what I'm saying is, the Court should allocate the
12
employer contribution to insurance proportionally to each
13
of their insurances, because they can't change it.
14
And, if we do that, then Mr. Kalii's portion of the
15
his insurance and his portion of his daughter's insurance
16
would be $458.65, which he has said from the very start,
17
willing to pay that.
18
19
20
"It's just, I don't think you should get
be making
money on the health insurance, and me paying everything."

With regards to
child support, I dealt with, health
21
insurance, I talked about.
22
for the use of the home, each pay their own bills.
23
should not be a problem.
24
25
Temporary orders, we asked

That
As to the attorney's fees, again, we've only got part

of their record.
Roger G. Flygare
&
And it's -- they're required to show us
Associates, Inc.
17
what her available resources are,
of that.
and we don't have any
She claims she has need, but she somehow went and got
into an $850 a month condominium on a lake, or a -- not a
condominium, townhouse on a lake, first and last, all
that.
We don't have all of her financial records.
8
9
10
But we don't have any of her financial records.
In fact, her financial declaration has kind of come in

in bits and drabs throughout this process, so.
Your Honor, to summarize, I think the parenting plan
11
we're proposing which primarily impacts when she's
12
involved in school related transportation which is late
13
August on, should be that little girl is with dad.
14
that all weeks except the second weekend of the month, go
15
to mom.
And
And they split the summer, week on, week off.
16
Thank you, Your Honor.
17
18
MR. COOK:
Very brief.
Your Honor, the incomes here, his net
19
income here is undisputed at $4,028, just over $4000 a
20
month.
21
Her net income for child support purposes, and you
22
recognize
23
support income is different from available income.
24
Sometimes it's more, sometimes it's less.
25
of course the Court recognizes that child
In this case it's less.
The reason is, she's having
18
$920 a month on average, deducted from her income.
from the $2200, she's getting $90
She's got about $1400 a month to live on.
are vastly disparate in this case.
So,
$920 deducted.
It did take some time for transition.
The incomes
The Court
should not take Mr. Kalii's bouncing the child argument
at face value, because this mother has done all that she
can to establish the very most consistent and steady
schedule for this child.
10
And I think what's most important is she went when
11
she finally could get the money together she got an
12
apartment or condo, .36 miles away from the father's
13
residence.
14
relationship with both parents.
15
up super early.
16
So, this child can have a very close

She doesn't have to get
She'll drop, if necessary, could drop them off.
17
mean, really, she's going to be on the bus route either
18
way at this point.
19
will be living with her.
20
And she's got a
her older daughter
I mean, they're making a big issue about bank records.
21
If they want to do discovery, they can do discovery.
22
They lived together.
23
knows her sources of income.
Mr. Kalii knows her income, he
24
She's got her adult daughter living with her now, and
25
that's she's able to afford the apartment that she moved
19
into,
and we disclosed that.
So, if they want to do discovery, have at it.
they lived together.
She's a bus driver, and that's what she does.
He knows her sources of income.
They are in an enrollment period, that's why we want a
But
contribution to each.
do.
parenting plan.
Okay.
Here's what I'm going to
First, I'm not going to change the existing

But, I want to
and the reason I'm not
10
is because it's summertime, and you've got a September
11
5th trial date.
12
So, your trial date is at the very beginning of
13
school.
I want the arrangement between the parents to
14
work out so that the first week of school, the child is
15
with the father.
16
And then you can let Judge Arend, or whoever hears
17
this trial, make the ultimate decisions on the parenting
18
plan.
19
I don't think it's appropriate at this time,
20
considering the father's concurrence to half the summer
21
goes to the mother and half to the father, for me to be
22
interjecting that.
23
later, then you would have a different issue, but you
24
don't .
25
And if your trial date were much
I checked, and you're September 5th, so just make sure
20
1
2
the child's with the father the first week.

With reference to the other issues,
I agree with Mr.
Sabin.
property divisions for whole bunch of reasons,
least of which
It's not appropriate to make a preliminary

not the
While she may be entitled, for example, to 3Vs % of his
pension, he's entitled to what looks like close to 50% of
hers.
dollar amount?
10
So, how do you off-set the two, and what's the

That's not an appropriate function.
However, I do believe that there is sufficient
11
evidence and sufficient information to indicate that the
12
economic circumstances of the two parties are different.
13
And so what I'm going to order is that child support be
14
paid in the amount of $150.
15
And I have the authority, I think, so responding to order
16
maintenance based upon the factors of $900, and it's
17
undifferentiated.
18
And maintenance be paid.
So, it's $1050 that he's going to pay to her.
And she
19
will maintain out of that sum all of the current existing
20
things that she pays.
21
in insurances; she makes no changes in bank accounts; she
22
doesn't dispose of property, the standard restraints that
23
we have here.
24
25
And that is, she makes no changes
So, he will continue to receive the insurance benefit,

but there will be some payment by him for that benefit.
21
I'm going to reserve the issues of attorney's fees.
don't have enough information for me to make a decision
on attorney's fees for a whole bunch of reasons.
think it's more appropriate that they be heard by the
Court.
trial.
you're going to be arguing this, right?
10
11
12
13
And I
I mean, we're talking about less than eight weeks to
You're talking less than two full months before
MR. COOK:
Well, Your Honor, I thought that September
5th was the assignment to set trial date.

I thought that the trial date
itself was September 5th.

MR. COOK:
No, I
because we just filed this in
14
April.
15
the Department saying "We're going to set a trial date
16
September 5th".
17
note it up for trial setting sooner.
18
And, I mean, I do see the order assigning case to
And we could move that up.
We could
Well, maybe I misread the
19
thing, I looked at trial date, and it said September 5th,
20
so I assumed that was the trial date, not the
21
22
23
24
25
MR. SABIN:
That's the assigned
is that trial date,
Your Honor?
It's just the assignment to set
the trial date, then I'm mistaken about that.

So, now we've got a different kind of a problem with
22
1
2
the parenting plan.

Well, being an idiot, I didn't do what I should have
done, which is to review these two things. And I'm going
to have to defer to ask you to ask you to reset the issue
of the parenting plan to a later date with
argue that one issue about the appropriateness of the
parenting plan.
8
9
10
and just
Between now and then, when you do that, I think that

the existing plan that you have coincides with the
recommendations of the father and the mother anyway.
11
MR. COOK:
12
Right.
That is they alter
and it
13
doesn't alter my order about temporary support being
14
ordered in this particular case.
15
16
MR. COOK:
And to clarify, it's
18
MR. COOK:
20
I guess the
order should read $1050, undifferentiated.
17
19
it
$1050, undifferentiated.
And don't even mess with that silly order
of child support.
Just propose it all in that.
Well, I don't
I think by law
21
I have to set a child support amount.
22
$150 which is the child support amount, which is the
23
deviation based upon the
24
parties, and the needing the mother's household to bring
25
her back to some kind of --
Roger G. Flygare
&
Associates, Inc.
A rv e y
So, I'm setting
split between the two
23
1
2
MR.
SABIN:
I guess,
Your Honor,
understand what the orders need to say.
MR. SABIN:
I'm just trying to
You say in the order
So, Mr. Kalii's going to be out of pocket
$1050 total?
Total.
And it's
undifferentiated between child support and the
maintenance.
and the child support portion of that undifferentiated,
10
But the maintenance portion is the $900,
is $150.
11
MR. SABIN:
12
Thank you, Your Honor.

And I'm going to hand back the
13
working copies that you both provided to me.
14
apologize to you.
15
order in terms of when the trial was, and thought that we
16
were probably looking at something entirely different.
17
So, I apologize.
18
MR. SABIN:
19
It's my mistake.
And will
I misunderstood the
Well, you just gave me a heart attack, I
thought, oh my gosh, I got to get ready for
20
MR. COOK:
That's a quick trial.
21
Well, I didn't even think about
22
the date of filing which clearly would be way too soon.
23
But what do I know, I haven't been doing this very long.
24
25
MR. COOK:
Pierce County's real good.
Thank you, Your
Honor.
24
MR.
SABIN:
Straton Lucas
(phonetic).
k
AUDIO ENDS - 10:02:47
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Roger G. Flygare
&
Associates, Inc.
25
1
2
IN RE:
CAUSE NO.
The Marriage of JOHN KALII versus BETH ANN KALII

14-3-01646-7
4
5
6
7
8
9
AFFIDAVIT
I, Patricia Tuffield, do certify that the audio recording
10
provided to me of the proceedings held before the Honorable
11
Commissioner pro tern, Larry Couture, in The Superior Court
12
for Pierce County, Washington, was transcribed by me to the
13
best of my ability.
14
15
16
17
18
Patricia Tuffield
19
Transcriptionist
20
21
22
23
24
25
ORIGINAL
Roger G. Flygare & Associates,
Inc.
26
E-FILE
IN COUNTY CLE
PIERCE COUNTY
September 05 2
KEVIN St
COUNTY
NO: 14-3-0
2
3
4
5


NO. 14-3-01646-7
JO HN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
N O T IC E O F IN T E N T TO W IT H D R A W
Respondent.
12
TO:
13
A N D TO:
A N D TO:
14
15
16
17
THE CLERK OF THE COURT

Daniel Cook, Attorney for Respondent
John Kalii
PLEASE TAKE N O TIC E TH A T the undersigned intends to withdraw as attorney of

record for Petitioner, John Kalii as of the 15th day of September, 2014. Said date is at
least 10 days after service of this notice. This withdrawal shall be effective without order of
the court unless an objection to the withdrawal is served upon said withdrawing attorney
prior to the date set forth in this notice.
Trial is set for
_____________
T'herelSTro-sehedtJeeHfiat'dal'e:18
19
20
21
The last known address of Petitioner is Mr. John A. Kalii,9711 Winona St SW,
Lakewood, W A 98498, and all future pleadings in this matter should be directed to him at
said address. If no address is stated above, then after said withdrawal of the undersigned
attorney of record and so long as the address of the withdrawing attorneys client remains
undisclosed and no new attorney is substituted, the party may be served by filing with the
clerk of the court an affidavit of attempt to serve pursuant to Civil Rule 5(b)(1)-
22
Dated this 5th day of September, 2014.
23
N otice o f Intent to W ith d ra w

P age 1
GOLDBERG & JONES I'l.I.C

Tel: (206)448-1010- Fax: (206)448-0736
Email- TSABlN@GOLDBERG.JONES.COM
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Notice of Intent to Withdraw

Page 2
/
f,J
43247986
court
09-09-14
ORFR
4
5
6
7
IN T H E S U P E R IO R C O U R T O F W A S H IN G T O N , C O U N T Y O F P IE R C E
JO H N A LIK A KALII JR
ORDER
P etitioner(s) ,
(O R )
vs.
10
C ause No: 14-3-01646-7
BETH ANN KALII,

_______________ R espondent(s) .__________________ _________________________________________________
11
12
IS
13
r n E / A ' o s 8 > f r N O s
S T l Z / Q f i t 'P .A J
P e ^ e o i^ iC r
fiG m r tiS S /n /J f-s tS

14
P>f
o h
7M
15
<f / y 3 / ^ T ) / V
16
U H U ,
17
18
19
20
{3 )
9F O O
fr > n (L ? S
7M
P LA tJ.
a /yinHUT
P o p
P < / ( / a J
rA -c r*J Q f* .
/ o e a e M ^ v
A T
N 7 )rs &
/yi a fiord
/2
T 7 tf.
7K
o u
Z r M tP W CP/U._______
$ e s / *z > < y L & > ___ o F
/hsrt.
___________
_______________
T7p -
P tU C O G / Z ^ fr
/ S S tJ fS '*- O ') T E /W P O & fA
) A /n n U M T A f
S c//& a> Z 7~ />/*>,
GF 7 F /K 7 f& s r e M fX /S tffT tn
77)
fiP flc fr/P P /Z g -
)^ U / tfh C . ThZ r Q u a ys
P r P s %
O r J f /*-.-?
2 . &PLAe6
f> t T u u t u i o /
Ar->o e u rlz /? tP /f/z r ? s r)# ? '
n\o\j T t e w s * - T frE
<7 / 1 3 U * ' 0 to & z < : / p
m ey
u /s f i.
D ATED this
*7 7f day o f S & T F ' G / X ) /
__
21
JU D G E K. A. van D oorninck
22
23
fo r P laintiff/P etitioner
24
25
WSBA#35f//v/ /a
u l
r w
t*0
A tto rfre y io r D efen da nt/R esp on de nt ^ c ^ r A * J C
w sba#
2 > ^
& &

BY______________________DEPUTY

County of
In re:
A - KAL-li
No.
Petitioner^,
and
Declaration of
A .
K A U (
[Name]
(Optional Use)
(PCLR)
R e s p o n d e n t^ .
This declaration is made by:
C T & tfl At K A rlf<____________
Name:
Age:
A /_____________________________________
Relationship to the parties in this action:
P -T IT I
I Declare:
kCJLePT
TH-g tOFFKR
'>
A3
f~B A S oN A g L
AU
Declaration (DCLR) - Page Y of _

WPF DRPSCU 01.0100 (6/2006)
O F $>
A TT.
PATM E/SlT
1A/A3
M A -P
A H O h lfU
P A U lE i
fU - d O O K .
<gr C A -ILP ^g -F R o K f.
f ? /g /z Z ) /V -
(Attach Additional Pages if Necessaiy and Number Them.)

I declare under penalty of perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at
LAKL\AJ<D0D
[City]
[State]on
* )
lb- Z-Q[A-
[Date],
Print or Type Name
Do not attach financial records, personal health care records or confidential

reports to this declaration. Such records should be served on the other party and
filed with the court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220j for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records will be sealed to protect your
privacy (although they will be available to all parties in the case, their attorneys,
court personnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 2 of___
WPF DRPSCU 01.0100 (6/2006)
14-3-01646-7
43301863
09-16-14
DCLR
IN COUNTYc l ^ cs OFFICE
am
S E P jU 7 2 (m
PtFRCE COUNTY. WASHINGTON

k I v i n s t o c * . County C te $
mn
BY.

County of
A'
f^ A L -M
Petitione
and
No.
/if ~
" 7
^ > fP aJ
___f^ A K t 4 T < M 6 T L - h h l
Respondent (^f?
[Name]
(Optional Use)
(DCLR)_______________________
Age:
>
Declaration of
A < KArL-ll
Name:
^ T/OHri. A t A
*1
(________________
r e r i r i p n t ^
I Declare:
s e z
h rrN re M p
Declaration (DCLR) - Page 1 of_

WPF DRPSCU 01.0100 (6/2006)
(Attach Additional Pages if Necessary and Number Them.)

I declare under penalty of perjury under the laws of the state o f Washington that the foregoing is true and
correct.
Signed at
L A Kt-IK>/0>P
[City]
IA/A~
[State] on
), / .
[Date].
Print or Type Name

1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
Declaration (DCLR) - Page 2 of____
WPF DRPSCU 01.0100 (6/2006)
Parenting Plan:
I,
John Alika Kalii, will agree with the 50/50% Parenting Plan
proposed by Beth Kalii. I do understand that our daughter

Ka'ena Makani Kalii does need to spend time with both of her
parents. I've never denied that. However, in agreeing to this
50/50% arrangement, it needs to be noted that I will be under
no obligation to constantly take charge of Ka'ena (2) times a
day, during the school weeks that Ka'ena is under Beth's care.
Beth will have the sole responsibility of seeking and providing
child care for Ka'ena during the course of her week of care.
I will be happy to continue keeping Ka'ena in my care 3-4
hours a day, before and after she goes to school, during the
weeks that she is in Beth's care, whenever I am available.
Ka'ena's care and welfare when her mother is working is
important. But to have Beth relieved by me, of her parental or
financial responsibility during the period that Ka'ena is
supposed to be under her care is neither reasonable nor fair to
me. This is the result of the Parenting Plan that she has
proposed. I should be afforded some consideration as well as
compensation in relieving her of that responsibility. I feel that
my time is worth just as much as hers and there will be times
that I may not be able to watch her. Beth needs a contingency
i
plan for such emergencies. And as it stands now, I do not have

the luxury of a "carefree" week, as she does, during the period
Ka'ena is with me, under her Parenting Plan.
My Plan was to have Ka'ena during the school week and
Beth to have her on the weekends, with the option of taking
her during times she was off. Beth could also have kept her
same bus route as Ka'ena's bus driver and still had contact with
her twice a day during the school week. She still has that bus
route option, as there are re-bids for bus routes coming up. I
felt that this would have been the more viable plan, both
timewise and financially. I would have adjusted my life to have
made that happen. Her explaination for not accepting my Plan
w as, "I have a life and need to have my weekends." Under the
circumstances, I will concede to Beth's plan for her sake, but my
Plan will remain on the table for her reconsideration.
If there is a better Plan, I'm willing to listen to that as well.
14-3-01646-7
43301867
09-18-14
DCLR
'NC W T Y ? f8 ^ 0FF(ce
AM
s e p it
W *
KEVIN

County of
In re:
A Petitioner^,
No.
" V
and
D a M m ' i z e s f M < z e
R e sp o n d e n t^
[Name]
M , P f A -C .
(Optional Use)

Name:
Age:
\.7 2 > tb U A -
K A - L j t ______________
____I_______________________________
p g r n t > tie
/ Declare:
___________ A T T A ^ t t M & M r s
Declaration (DCLR) - Page 1 of 2

W PF DRPSCU 01.0100 (6/2006)
r -

I declare under penalty of peijury under the laws o f the state of Washington that the foregoing is true and
correct.
Signed at L k k C l K l D P P
, [ C ity ]
tv /A
_ [State] on _
? )/
< 7 c >1+k L
I b 'Z O l^ r
K A L -1
rD a te l
I________
Print or Type Name

Declaration (DCLR) - Page 2 of 2- WPF DRPSCU 01.0100 (6/2006)
GroupHealth Insurance Payments
I, John Alika Kalii, am asking for relief of further health

insurance payments to Beth Kalii concerning my medical
coverage under her GroupHealth Medical Plan. After many
months and attempts to discontinue said coverage, I was finally
able to do so through Human Resources Dept of the Clover Park
School District.
The issue that prevented me from stopping coverage sooner
was that I had to wait until the new CPSD Enrollment Period or
until our divorce was final or until I had aquired my own
Medical Plan. As of Sept 1, 2014 the CPSD HR dept, assured
me that I was no longer a dependant under Beth Kalii's
GroupHealth medical plan because I had enrolled into my own
Plan with UnitedHealthcare.
Member ID: 105580930_______ Group Number:

WAHLOP
; Member:
Payer ID: 67726
JOHN A KALII
OPTUMRx"
POP Name:
COMMUNITY HEALTH CAR E OF TACOMA

POP Phone: (253) 589-7030
10510 GRAVELLY LAKE DR SW
LAKEWOOD, WA 984995036
0501
Rx Bin:
Rx GRP:
Rx PCN:
610494
ACUWA
9999
Apple Health - Adult Coverage

Administered by United Healthcare of Washington. Inc.
'
, Washington
healthplanfinder
d id t com pare, covered.
Washington Health Benefit Exchange

PO Box 657
Olympia WA 98507
JOHN A KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
j'f
07/24/2014
Application ID:
1163284
sf Subject - Eligibility Decision

!:r; Dear John A Kalii,
Vi
ct>We received and reviewed your application and determined the following:
Name "
John A Kalii
Program
. EligibilityBegin Date{
-Washington Apple
Health Adult Coverage
07/01/2014
"
, EVigibi 1tty End Date N

06/30/2015
Appeal Rights
If you disagree with the decisions above you have the right to appeal. See the attached information about
your appeal rights. There are deadlines to appeal so you should act quickly.
How to Contact Washington Healthplanfinder

Contact us if you have any questions about this letter. Let us know if you need help applying for or
accessing your health insurance due to a disability. You can contact us in any of the following ways:
.
Online at http://www.wahealthplanfmder.org:
By email at CustomerSupport@wahbexchange.org
By calling 1-855-WAFINDER (855-923-4633) and 855-627-9604;
By Fax 360-841-7620;
By mail at:
PO Box 946
Olympia WA 98507
You can drop off an application, renewal form, or any other documents requested by the
Washington Healthplanfinder at a local Community Service Office. To locate the nearest
Community Service Office, call the Washington Healthplanfinder number above or go online at
Correspondence ID: EE004-7636968
Page 1 of 9
E-FILED
PIERCE COUNTY, WASHINGT(
September 18 2014 11:34 A m
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8

IN AND FOR THE COUNTY OF KING
9
10
11
No. 14-3-01646-7
Petitioner,
12
and
13
BETH ANN KALII,

Respondent.
14
15
16
17
I, Sally DuCharme, am over the age of 18, and competent to testify in the
above entitled case.
On September 17, 2014, I placed in the U.S. Mail a copy of the following
18
1. Declaration of Beth Kalii re Review Hearing.
19
20
John Kalii
9711 Winona ST SW
Lakewood WA 98498I
21
22
23
I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
24
DATED
September 18, 2014
25
Sally DiSCFiarme, Legal Assistant

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, W A 98499
Phone: (253) 581-0660
E-FILED
PIERCE COUNTY, WASHINGTt
September 18 2014 11:34 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

COUNTY OF PIERCEI,
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
DECLARATION OF BETH KALII

RE REVIEW HEARING
Respondent.
14
15
16
17
in support of my Motion for Temporary Parenting Plan.
This declaration is for a review hearing.
This declaration is made after John
18
entered an agreed order striking his Revision hearing and setting over all issues for
19
review on September 23, 2014.
20
documents Pro Se regarding the issues to be reviewed on September 23, 2014.
21
22
23
Parenting Plan.
This declaration is also made after John submitted
John submitted a declaration saying he agrees to the 50/50
parenting plan. That is good. We can continue that.

John discusses child care and indicates that it may become inconvenient for him to
24
watch KaEna before and after school on my weeks. That is fine. If we need to set up
25
S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii re Review.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
253-581-0660
1
commercial child care I will do so. But it cannot be just for contingencies - it would have
2
to be set up every other week or I will not be able to hold a spot in a commercial daycare.
3
So if John notifies me that he will not provide before and after school care on his weeks I
4
5
will set up commercial child care and the cost will be a shared expense.
Health Care Insurance. John submitted a declaration saying he obtained his own
insurance and that he will no longer be covered by my plan. That means I will no longer
be paying for him from my check.
was coming off of my benefits. I was told that I would receive a refund of the premium I
10
11
12
My human resources department confirmed that he
already paid for September 2014. Presuming that does actually take place that is good.
Of course, if the understanding John and I have is mistaken in some way than we will
need to come back to court to address it.
13
Child
Support/Maintenance.
Previously
the
court
ordered
$1,050
in
14
undifferentiated family support and spousal maintenance.
Part of that payment was
15
predicated on the substantial amount I was paying for Johns insurance so I agree that
16
17
18
19
the payment should be reduced.
However, there should still be a full child support
payment; or, if the court deviates in child support because of the 50/50 residential
schedule than spousal maintenance should be ordered.
20
The standard calculation of child support on the worksheets I filed on July 3, 2014,
21
(and nothing has changed since then) is $723 per month with inclusion of the health care
22
insurance I am still paying for KaEna.
23
24
If the court orders child support at $723 per month
with no deviation then I am not requesting spousal maintenance.
If the court deviates
from $723 per month then I request spousal maintenance in amount sufficient to equal
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration o f Beth Kalii re Review.doc

Lakewood, W A 98499
253-581-0660
1
$723 per month. This is still a reduction of $327 per month from the amount the court
2
previously ordered for undifferentiated family support.
3
John improperly references settlement negotiations in his materials filed with the
4
5
6
court.
I understand that he probably did not understand the rules related to settlement
negotiations so I am not claiming he acted in bad faith; however, that information should
not be stricken.
conversation allegedly took place. But I did have conversation with my attorney after the
revision motion where my attorney asked me if I would accept Johns offer of $300 per
10
month child support. I declined to accept $300 per month. As of the date of writing this
11
12
Furthermore, I was not present at the revision hearing where this
declaration we have not been able to reach an agreed upon number to settle this issue
short of court action. So I am asking for the court to order the full payment of $723 per
13
month. Particularly if I am going to have to get child care for KaEna even with that as a
14
shared expense that is going to further tax my monthly budget and I will need the full
15
16
17
18
payment of $723 per month.

19
Signed at Lakewood, WA on September 17, 2014.
20
21
BETH KALII
22
23
24
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration o f Beth Kalii re Review.doc
5920-100 S treet SW , Ste 25

253-581-0660
IN COUNTY c llE R K S OFFICE
am.
43321699
14-3-01646-7
09 -22-H
AFPT
SEP 19 20ft PM
K E V IN S T O C K ^ o u n ty C le rk

County of
In re:
'B f o /M
A ' f c /u - /r
Petitioners),
and
no.
/ f
- 3 - > /^ 6 'r 7
Declaration of
B A T H
K A * - i /
Respondent(s).
at** &T tt K A C /(
[Name]
(Optional Use)
(DCLR)_______________________

Name:
A r < K A U ! _________________
7<D 4M
Age:
/ ______________________________________
I Declare:
A iT A c m o
/M p ju t jE O '
M Y rAAeUT/A/r PfiAAi
^
S iA T A /e j-Z E Z ?
J T A H rH S A
re
A e v /z r io
rjfc S A / L D
U T T T tT T
&A?
7Z>
M Y
0 A
3 T H
k H A //
A t e A /f L /A /f r ____________________________________
A A v e r:
Declaration (DCLR) - Page 1 of _

WPF DRPSCU 01.0100 (6/2006)
/it & T
5 B - 2 z T .

I declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at
I/O
[City]
lA /A '
[State] on
[Date].
Print or Type Name

If hied separately using a cover sheet, the records will be sealed to protect your
privacy (although they will be available to ail parties in the case, their attorneys,
Declaration (DCLR) - Page 2 o f ____
WPF DRPSCU 01.0100 (6/2006)
A few of my concerns and reasons for adopting my Parenting Plan
1. Drinking and smoking through her entire pregnancy with Ka'ena. This
may be the cause for Ka'ena's hyperactivity and lack of attention
problems. I can present family witnesses who lived in our home as well
as personal friends of both of us who can support this claim.
2. Continued alcohol use during marriage. I have family witnesses that
can also support this claim.
4. No insurance on her vehicle past or present. Would request that she
provide proof of insurance.
5. Passenger in past vehiclular homicide/ hit and run with ex-husband
and continues to drink. I have court documents to support this.
6. Submited inaccurate notarized statements against me as to my
parenting skills and history, by co-workers who neither knew me
personally and/or had never been to my home. I have notarized
statements to dispute these statements.
8. Leaving Ka'ena in the care of others during Beth's scheduled week
(example...Daughter Katerri's ex-boyfriend, 30's male) to watch her
when Beth was at work seminars. I was uncomfortable with Ka'ena's
safety in that and disapproved, but told by Beth that I couldn't tell her
what to do.
9. Beth's purchase of a pet and not supervising and providing proper
l
care for the animal (hamster), resulting in the death of said pet by
accidental suffocation by Ka'ena.
After meeting with Beth's attorney (Daniel N. Cook) at a Sept 5, 2014
court hearing, I mentioned to Mr. Cook that I could not afford to be
paying Beth $700 to $1000 a month, as I am now on a fixed income. He
agreed that it was a bit extreme. He then went on to add, "Would you
be willing to settle on $300 a month and agree to the 50/50 custody?" I
replied "I would be willing to do that." "But she's not going to go for
that." And he replied, "Yes, she will." In a subsequent meeting on Sept.
17, 2014, Mr. Cook informed me that Beth would not accept my $300
agreement and that Beth now needed $400. Also assuring me that this
was only temporary and not final, I again agreed. The next day, Sept.
18, 2014,1recieved a Declaration of Beth Kalii re: Review Hearing
stating that they were again seeking $723 a month with inclusion of
Spousal maintenance. The deviation reduction of $327 a month from
the court ordered undifferentiated family support of $1,050 fails to
address the additional deduction of the Sept. 1, 2014 cancellation of my
health care insurance with Beth. I am asking the Court to dismiss any
Spousal maintenance on the grounds that this has only been a (4) four
year marriage and does not warrant such action. Dispite all attempts by
Mr. Cook to seek an agreement on my part to his extended offers, I am
now refusing Beth's Parenting Plan and asking the Court for it's
consideration of my Parenting Plan. In addition I am asking that Beth
pay (according to the Child Suport Schedule provided to me by Mr.
Cook) the amount of $314.88 minus my portion of $151.15. Which
comes to $163.73. This schedule is also attached.

I recently retired from a 33 year career with the Tacoma Fire Dept in
Januay of 2013.1am now available for my 8 year old daughter Ka'ena
100% of time. Basically, this clearly defines my status now, as a "stay at
home Dad". Ka'ena is under my complete care before and after she
attends school when she is with me during my week. She is also under
my care for about three hours a day before and after school during her
mothers week. This will all significantly change if I have to find work to
supplement my income.
Being retired, I am on a fixed income making 50% less than I made
while I was working for the City of Tacoma. On the other side of the
coin, Beth is now making $1000 more a month on her job than she did
during the better part of our marriage. Paying $700+ a month in Child
Support would force me to seek supplemental income by coming out of
retirement because I would no longer be able to afford my present
living expenses. This would also leave Kaena without parental care for
unnecessary periods of time by both parents. I would not be able to
take care of her in the mornings or after school on either weeks (Beth's
or mine) with the 50/50 Parenting Plan. Additionally, I would end up
having to pay for child care during my week and half of Beth's child care
during her week.
My Parenting Plan would prevent all of these financial stresses,
problems and obligations, as well as securing Ka'ena a consistant level
of Parental care during the entire 9 month school year. She would not
have to be shuttled to and from a Child Care Center twice every school
3
,v
[0
H
day, every school week, for the entire 9 month school year. Not to
mention other issues that might arise, such as colds or viruses
associated with such facilities. I would hope that the Court find that this
is much more beneficial where it concerns care and welfare of Ka'ena. It
is my belief that the degree of her welfare is solely dependent on which
rO
Parenting Plan is accepted.
1
/
Additionally it should be noted that Beth had the option and still has
the opportunity of being Ka'enas bus driver. She every/school day
h
f\
during the entire school year, in addition to the weekends. As a bus
\j
driver for Clover Park School District Beth also has all holidays, Spring
r,
and W inter breaks, Summer breaks off, in which she can adjust child
C1
care options with me.
O'*
In closing, In the event that my Parenting Plan is not accepted, I

would also ask the Court to consider a Residential Credit Adjustment for
the following reasons:
On Beth's Parenting Plan, I have Ka'ena 60 hours a month more than
Beth has her. My added expenses already include School Supplies,
School clothes as well as saving Beth the monthly Day Care expense of
$300.00 a month. Also attached is a Day Care cost sheet from "Kidz
Zone" child care center in Lakewood.
IN COUNTY C & IR k 'S OFFICE
AM
SFP 19 20ft
RM.
HfRpE COUNTY WASHINGTON

Dr-----------
.DEPUTY

C o u n ty o f
In re:
C fo H N
K A L I/
Petitioner^),
and
& T rt
A -
no .
Declaration of
K A L I /
t a m m y
R espondent^.
Name:
^
________________________________ ]p r _
\3 ^ V \-o ^
I D e c la re :
L T r& <
/s >
A T T /t e m
p A /L e y
[Name]
(Optional Use)
(DCLR)____________________ _
A ge:
f V - 3 - 0 / b 6 - 7
p *
State o f.
3 8 *
Connty of
A A A A A A A AA A
Subscribed and morn/affirmed to before me this
SÂNTHARTBODCHARD'
TAHW Qi M W
Notarv Public
Notary Pubflc
State or W ashington
M y Com m ission Expires
Decem ber 1 ,2 0 1 7
m imt v
. tcc \ . m i
My Commission Expires;

I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed
_______ , [City]
[State] on ^
- .
[Date],
Do n o t attach financial records, personal health care records or confidential

filed with the court using one o f these cover sheets:
privacy (although they will be available to ail parties in the case, their attorneys,
WPF DRPSCU 01,0100 (6/2006)
~ 6 ? - 1 4
/
M y name is Tammy Dailey, ex wife of John Kalii of 24 years and have known him
for 40 years. I refer to him as Bo.
Bo and I raised 2 beautiful respectful God fearing sons together. Bo is a very good
father, then and now, as well as a loving caring grandfather taking our grandkids
anytime. I've also witnessed Bo with Kaena and I have no doubt she will grow up
knowing how loved she is and will be respectful in all ways as well. Bo cares for
all her needs and spends quality tim e with Kaena.
A fter finding out Bo and Beth split up, I began visiting my grandchildren at his
home. Soon after, I lost my job and Bo, as he helps everyone else, let me move in
as well, being in a bad situation not able to pay my rent. Katerri (Beths daughter)
was living there as well. W hen Kaena m et me she began calling me mama Tammy
because she knows Im her 2 half brothers mom. I wasnt comfortable with that
because I feared it would only cause trouble with Beth. Bo told me she calls her
1 /2 sisters dad papa Steve that it was no big deal. I told Kaena if she wanted to
call me Tammy thats okay with me, but she continued to happily call me mama
Tammy and I felt for me to dispute this it would only cause confusion for her so I
just let it go.
Since I've been here Kaena and I have baked cookies, planted flowers, painted
wood flowers for our flow er garden, gone to the lake several times, gone
shopping, cleaned the pool together, gone to the dog park, sat outside in the
mornings playing computer games and never have I ever disgussed anything
about her m other with her. However, Kaena came back to Bo's house after her
week with her m other and said to me "my mom says you're mean to her." Besides
the fact I've not seen Beth in 4 years, Im puzzled as to why she would be having
this conversation with her 8 year old who seems just fine with everything until
Beth starts questioning her and having this kind of talk with her. Soon after that,
Kaena said " M y mom says her sister and brother are mean to her." im puzzled by
this. The very first tim e I m et Beth, within minutes she began telling me about herl
life and was literally crying. It appeared to me she was thriving on sympathy and
my concern is she is doing this with her daughter now by the things she is telling
Kaena. Beth has also text Bo calling him very terrible names, In am concerned,
weather she is doing this in front of Kaena as well. Also claiming Katerri was
kicked out of the house as soon as Beth retained an attorney about 2 months ago.
I was here the day Katerri moved out, Bo and my son took 3 truck loads to Beth
and I helped Katerri put things in her car. It was July 1st when her mother got her
place. Katerri was never kicked out in fact after Bo giving her a letter asking her to
plan on moving, he later told her if she wanted to stay she could that she didnt
have to leave I was sitting right there with them when he told her this.
As far as Cathy Gibsons letter to the court. The only time I have ever crossed
paths with her, is when I was Bartending and she would come in and drink almost
on a daily basis. I knew her boyfriend Casey since the 70s but I knew nothing
about her and she knew nothing of me. Very disheartening being called vile, mean
and psychotic by someone who has never had a conversation with me. She also
states Kaena was forced to call me mama Tammy, as stated above, that was
completely Kaena's choice and Cathy wasn't in the state when any of this
occurred. Her information is hear say.
In reference to the letters Cathy Gibson said I wrote to Beth years ago, it was out
of total frustration because Beth was interfearing, knowing Bo and I were trying
to reconcile our 24 year marriage and she was married at that time to Steve. The
fact of the matter is, I was granted a one year restraining order on Beth after she,
her then husband Steve and his girlfriend showed up at the house and began
threatening me. I was living with Bo at that time, from 2006-2007. i moved in
with Bo again in 2009 we were again trying to repair our marriage. Beths
constant calling and texting all day caused havok with Bo and I and I moved out.
According to Bo he broke up with Beth on both occasions because of her
continuous drinking. The first time, drinking and smoking during the entire term
2
of her pregnancy. This was very upsetting to Bo it bothered him a lot. Beths
oldest daughter was born 1.5 lbs so he couldnt understand why she was drinking
and smoking during her entire pregnancy.
Bo has expressed to me, this is the main reason he is divorcing her now along with
working full time and not contributing to any of the expenses in the household.
That he has been wanting to start this divorce for the last 2 years and just kept
putting it off that he was losing motivation because of the situation and was
finding it hard to even start a divorce. That he was so busy taking care of this
house, cleaning, cooking and paying bills he was just tired and beginning to feel
hopeless. When I asked him why he married her knowing she drank so much, he
said because of Kaena. He felt it was the right thing to do and he thought she
would stop drinking with his constant complaints, but it became very clear that
her drinking came first and he was tired of it.
I have watched Bo willingly taking Kaena anytime on Beths time without malice at
all, about 30 hours a week of her time. He gladly takes her anytime Beth wants
him to. But Kaena, being dropped off and picked up so many times each day, does
seem a bit hectic and disturbing to the day just alot of back and forth going on
making the stability factor a little unstable. Bo has expressed concern that during
the school year, Beth picking her up just in time to put her to bed and that just
doesnt make sense to him.
Beth has maliciously spread the word, not only to the court but mutual friends
that Bo kicked her and Kaena out of the house leaving them homeless. Bo would
NEVER do such a thing, ever. But Beth insists on dragging Bo's name through the
mud for her own benefit.
Bo is a very caring and loving man, always ready to stand up to the plate and help
someone in need and do the right thing. I know for a fact, he has Kaena's best
interest in mind. As long as I've known Bo, money has never been that important
to him, in fact when he and I thought we may be losing our Lake house of 18
3
Ou
H
years, Bo said to me, "This house is made of wood and glass. Our family is the only
thing important about it" Family and friends have always come first. I have no
doubt, Kaena will grow to have these same caring qualities and morals.
With all due respect,
Tammy Dailey
JU R A T
]. j
State of.
C':j
County of.
A A A AA A
Subscribedandsworn/affirmedtobeforem
ethis id_dayof
20_M_, by
SAM AN TH A R. BO UCHARD
N otary Pubflc
State o f W ashington
M y Com m ission Expires
Decem ber 1 ,2 0 1 7
^
VAFrtM
.<I
Notary Public
My Commission Expires:
bee l - M i

am.
SEP 19 20ft
p .m.
WASHINGTON
Br- ------------ --------_ DEPUTY

County of
A . KAL 11
!" re:
P etitio n er^,
and
pgTtf A . KALit
R espondent^.
No.
Declaration of
com
[Name]
(Optional Use)
(DCLR)

Name:
t 9S
d & /? ? ^ ) >
Age:
I D e c la re :
is
- 3 '
ATTACHED
sro ct^

I declare under penalty o f perjury under the laws of the state o f Washington th a y ^ fo ^ o n V g ij^ s true and
Signed at
J ail 6~
[City] L
[State] on
V ^ D a te ].

Declaration (DCLR) - Page 2 of ____
WPF DRPSCU 01.0100 (6/2006)
To whom it may concern,
I, C a s e y C o m s to c k , h a v e b e e n f r ie n d s w i t h B o K a lii f o r 3 0 + y e a r s . I h a v e s p e n t m a n y o f th e s e
y e a r s a r o u n d B o a n d h is f a m ily . I'v e w a t c h e d h is t w o s o n s a n d d a u g h t e r g r o w in t o a m a z in g
in d iv id u a ls . B o h a s h e lp e d m a n y p e o p le t h r o u g h t o u g h a n d f in a n c ia lly h a r d t im e s in t h e p a s t.
F ro m p a y in g t h e i r r e n t a n d g r o c e r ie s , t o p r o v id in g s h e lt e r in h is o w n h o m e . H e h a s d o n e t h a t
f o r h is o w n f a m ily m e m b e r s m a n y t im e s . A f t e r 3 3 y e a r s w i t h t h e T a c o m a F ire D e p a r t m e n t , h e
is n o w r e t ir e d a n d c h e e r is h e s a ll t h e t i m e t h a t h e c a n s p e n d w i t h h is 8 y e a r o ld d a u g h t e r ,
K a 'e n a .
I a m a ls o w r i t i n g t h is l e t t e r b e c a u s e m y e x - g ir lf r ie n d , C a th y G ib s o n , w h o I a m s t ill c lo s e
f r ie n d s w i t h , e x p la in e d t o m e t h a t a l e t t e r s h e w r o t e o n B e th K a lii's b e h a lf , a b o u t B o K a lii a n d
h is e x - w if e T a m m y K a lii w e r e b a s e d o n h e a r s a y . S h e d o e s n 't k n o w B o w e ll o r e v e r s p e n t t i m e
w i t h h im a n d h is f a m ily in h is h o m e , as I h a v e . H e r s t a t e m e n t a b o u t w h a t K a 'e n a s a id is n o t
t r u e as s h e h a s n e v e r t a lk e d t o K a 'e n a . I w a s p r e s e n t w h e n K a 'e n a a s k e d h e r f a t h e r B o , w h a t
s h e s h o u ld c a ll T a m m y . H is r e s p o n s e w a s , " Y o u c a ll y o u r s is t e r K a te r r i's d a d , P a p a S te v e , y o u
c a n j u s t c a ll h e r M a m a T a m m y . I h a v e a lw a y s b e e n c a lle d U n c le C a s e y b y a ll o f h is c h ild r e n ,
s in c e t h e y w e r e t o d d le r s . I t's a H a w a iia n t h in g . It s a d d e n s m e t h a t C a th y d i d n 't t h i n k h e r
s t a t e m e n t s o u t , b u t I k n o w s h e w a s m is le a d b y h e a rs a y . H e r d e s c r ip t io n s o f B o b e in g a n g r y
a n d in s u lt in g a n d T a m m y b e in g v io le n t a n d h a t e f u l is s o m e t h in g t h a t I h a v e n e v e r s e e n in t h e
3 0 y e a r s I'v e k n o w n t h e m . H o w e v e r , C a th y d id t e l l m e t h a t T a m m y a lw a y s t r e a t e d h e r w i t h
r e s p e c t, n o t e v e n k n o w in g s h e w a s B o 's e x - w if e . C a th y m o v e d t o B o is e , Id a h o o n M a y 1 0 ,
2014.
B o 's h o u s e is a h o m e a n d a n e x c e lle n t e n v ir o n m e n t f o r K a 'e n a 's g r o w t h . H is s o n s a n d
g r a n d c h ild r e n a r e t h e r e m a n y t im e s a w e e k . I c a n s e e K a e n a 's b o n d a n d lo v e f o r h e r f a t h e r .
A n d I a ls o s e e B o s t w o s o n s as c o n s id e r a t e , lo v in g , a n d w e ll r o u n d e d a d u lt s , w h o lo v e t h e i r
fa th e r.
Thank you,
C a s e y C o m s to c k
LM
r, 1
i. -j
14-3-01646-7
DCLR
43323439
09-22-14
A.M
SFP 19 2014
PM.
PIERCE COUNTY WASHINGTON

i/ c \/ i m a n r . K
C n u n tv C lerk

County of
In re:
no.
Petitioner(s),
and
/ / ' S '
~ 7
Declaration of
[Name]
(Optional Use)
(DCLR)______
Respondent(s).

Name:
Age:
5~$-
-A
'______________
Relationship to'the paifties

^ in:thrsâction:
,. 5. ,
..u
.r.V*V.<
* 1 *
i-"*' *
I D e c fa r e :
S rT T & l
/ < & )__
ttz u ? ___ A y #
t _ 4.4
Declaration (DCLR) - Page 1 o f _

W P F DRPSCU 01.0100 (6/2006)

I declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at
ity]
State] on
[Date].
/4
i f A r l ' \ rr\ o OvTf \ m o
Print
or Type Name
.e
r

privacy (although they will be available to a ll parties in the case, their attorneys,
Declaration (DCLR) - Page 2 o f_

WPF DRPSCU 01.0100 (6/2006)
S f HOTARy \ o =
"vte&eUnn out T O Conoco
Ot>m o o t - x p i t e o
f ii ! 6 k's office
, COUNTY C L E W S u r

[ ] P roposed by [ ]
[ ] S tate o f W A [ ] O th e r
Or, [ ] S igned by the Judicial/R evie w in g O fficer. (C S W )
Mother Beth
Father John
County
Case No.
Kalii
P IE R C E
(C S W P )
Kalii
14-3-01646-7
C h ild ( r e n ) a n d A g e ( s ) : Kaena Kaili, 8

P a r t I: In c o m e (see Instructions, page 6)
1. G ross M on thly Incom e

a. W a g es and S alaries
b. Interest and D ividend Incom e
c. B usine ss Incom e
d. M aintenance R eceived
e. O th e r Incom e
f. Im puted Incom e
g .T o ta l G ross M on thly Incom e (add lines 1a through 1f)
F a th e r
M o th e r
$ 4 ,3 5 2 .3 7
$ 2 ,6 6 7 .0 0
$ 4 ,3 5 2 .3 7
$ 2 ,6 6 7 .0 0
2. M onthly D ed uctio ns from G ross Incom e

a. Incom e T axe s (Federal and State) Tax Year: Manual
b .F IC A (S o c.S e c.+ M ed icareV S e lf-E m p loym en t T axes
c. S tate Industrial Insurance D eductions
d .M a n d a to ry U nion/P rofessional D ues
e .M a n d a to ry Pension Plan P aym ents
f. V o lu n ta ry R etirem e nt C ontributions
g .M a in te n a n ce Paid
h .N orm a l B usiness E xpenses
i. Total D eductions from G ross Incom e
$ 3 2 3 .4 6
-
$ 5 .3 5
$ 4 6 .1 0
$ 2 5 4 .1 1
3. M onthly N et Incom e (line 1g minus 2i)

4. C om bined M on thly N et Incom e
$ 1 9 .8 6
$ 1 2 3 .8 9
$ 3 2 3 .4 6
$ 4 4 9 .3 1
$ 4 ,0 2 8 .9 1
$ 2 ,2 1 7 .6 9
i P
$ 6 ,2 4 6 .6 0
i s m
5. B asic C hild S u pp o rt O b ligation (C om bined am o un ts )

K a'ena Kalii
$887.00
t i l
i s
$ 8 8 7 .0 0
ip f
6. P ro po rtio na l S hare o f Incom e
(each parents net income from line 3 divided by line 4)
.6 4 5
.3 5 5
P a r t II: B a s ic C h ild S u p p o r t O b lig a t io n (s e e In s tru c tio n s , p a g e 7 )
7. E a c h P a re n t's B a s ic C h ild S u p p o rt O b lig a tio n w ith o u t c o n s id e ra tio n

o f lo w in c o m e lim ita tio n s (E a c h p a re n t's L in e 6 tim e s L in e 5 .)
6 5 7 2 .V
$ 3 1 4 .8 8
8. C a lc u la tin g tow in c o m e lim ita tio n s : F ill in o n ly th o s e th a t ap p ly.

S e lf-S u p p o rt R e s e rv e : (1 2 5 % o f th e F e d e ra l P o v e rty G u id e lin e .)
5.00
a. Is c o m b in e d N e t In c o m e L e s s T h a n $ 1 .0 0 0 ? I f y e s , fo r e a c h
p a re n t e n te r th e p re s u m p tiv e $ 5 0 p e r c h ild .
b. Is M o n th lv N e t In c o m e L e s s T h a n S e lf-S u D o o rt R e s e rv e ? If v e s .
fo r th a t p a re n t e n te r th e p re s u m p tiv e $ 5 0 p e r c h ild .
c. Is M o n th ly N e t In c o m e e a u a l to o r m o re th a n S e lf-S u D D o rt
l s I3
R e s e rv e ? I f v e s . fo r e a c h p a re n t s u b tra c t th e s e lf-s u p p o rt
re s e rv e fro m lin e 3. If th a t a m o u n t is le s s th a n lin e 7, e n te r th a t
a m o u n t o r th e p re s u m p tiv e $ 5 0 p e r c h ild , w h ic h e v e r is g re a te r.
9. E a c h p a re n t's b a s ic c h ild s u p p o rt o b lig a tio n a fte r c a lc u la tin g
a p p lic a b le lim ita tio n s . F o r e a c h p a re n t, e n te r th e lo w e s t a m o u n t
fro m lin e 7, 8 a - 8c, b u t n o t le s s th a n th e p re s u m p tiv e $ 5 0 p e r
c h ild .
$ 3 1 4 .8 8
$ 5 7 2 .1 2
P a r t III: H e a lth C a re , D a y C a re , a n d S p e c ia l C h ild R e a r in g E x p e n s e s (s e e In s tru c tio n s , p a g e 8)

F a th e r
10. H e a lth C a re E x p e n s e s
d. C o m b in e d M o n th ly H e a lth C a re E x p e n s e s
M o tH e r
-
a. M o n th ly H e a lth In s u ra n c e P a id fo r C h ild (re n )

b. U n in s u re d M o n th ly H e a lth C a re E x p e n s e s P a id fo r C h ild (re n )
c. T o ta l M o n th ly H e a lth C a re E x p e n s e s
(lin e 10 a p lu s lin e 1 0 b )
/$ 2 3 4 .3 4 '
$ 2 3 4 .3 4
K ill
$ 2 3 4 .3 4
m
*
11. D a y C a re a n d S p e c ia l E x p e n s e s
a. D a y C a re E x p e n s e s
b. E d u c a tio n E x p e n s e s
c .L o n g D is ta n c e T ra n s p o rta tio n E x p e n s e s
d .O th e r S p e c ia l E x p e n s e s (d e s c rib e )
e .T o ta l D a y C a re a n d S p e c ia l E x p e n s e s
(Add lines 11 a through 11 d)
*
SB!
$ 2 3 4 .3 4
Ip S fe l
12. C o m b in e d M o n th ly T o ta l D a y C a re a n d S p e c ia l E x p e n s e s

13. T o ta l H e a lth C a re , D a y C a re , a n d S p e c ia l E x p e n s e s (lin e 10d
p lu s lin e 12)
|g g j
14. E a c h P a re n ts O b lig a tio n fo r H e a lth C a re , D a y C a re , a n d S p e c ia l

E x p e n s e s (m u ltip ly e a c h n u m b e r o n lin e 6 b y lin e 1 3 )
$ 1 5 1 .1 5
$ 8 3 .1 9

15. G ro s s C h ild S u p p o rt O b lig a tio n (lin e 9 p lu s lin e 14)
$ 7 2 3 .2 7 I \
$ 3 9 8 .0 7
P a r t V : C h ild S u p p o r t C r e d its (s e e In s tru c tio n s , p a g e 9 )

16. C h ild S u p p o rt C re d its
a .M o n th ly H e a lth C a re E x p e n s e s C re d it
b .D a y C a re a n d S p e c ia l E x p e n s e s C re d it
$ 2 3 4 .3 4
-
c. O th e r O rd in a ry E x p e n s e s C re d it (d e s c rib e )
d .T o ta l S u p p o rt C re d its (a d d lin e s 1 6a th ro u g h 1 6 c)
$ 2 3 4 .3 4
P a rt V I: S ta n d a rd C a lc u la tio n /P re s u m p tiv e T ra n s fe r P a y m e n t (s e e In s p e c tio n s , p& qe

17. S ta n d a rd C a lc u la tio n (lin e 15 m in u s lin e 16d o r $ 5 0 p e r c h ild
w h ic h e v e r is g re a te r)
P a rt V II: A d d itio n a l In fo rm a tio n a l C a lc u la tio n s
,s
(
x
$ 7 2 3 .2 7
;
'
18. 4 5 % o f each p aren ts net incom e from line 3 (.4 5 x a m o u n t from

lin e 3 fo r e a c h p a re n t)
19. 2 5 % o f e a c h p a re n t's b a s ic s u p p o rt o b lig a tio n fro m lin e 9 (.2 5 x
a m o u n t fro m lin e 9 fo r e a c h p a re n t)
/ /
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
P a rt V III: A d d itio n a l F a c to rs fo r C o n s id e ra tio n (s e e In s tru c tio n s , p a g e 9)

20. H o u s e h o ld A s s e ts
F a th e r's
H o u s e h o ld
M o th e r's
H o u s e h o ld
a. R e a l E s ta te
b .In v e s tm e n ts
c. V e h ic le s a n d B o a ts
d .B a n k A c c o u n ts a n d C a s h
e. R e tire m e n t A c c o u n ts
f. O th e r: (d e s c rib e )
2 1 . H o u s e h o ld D e b t
(L is t lie n s a g a in s t h o u s e h o ld a s s e ts , e x tra o rd in a ry d e b t.)
a.
b.
c.
d.
e.
f.
2 2 . O th e r H o u s e h o ld In c o m e
a .ln c o m e O f C u rre n t S p o u s e o r D o m e s tic P a rtn e r
(if n o t th e o th e r p a re n t o f th is a c tio n )
Nam e
Nam e
b. In c o m e O f O th e r A d u lts in H o u s e h o ld
N am e
Nam e
c. G ro s s In c o m e fro m o v e rtim e o r fro m s e c o n d jo b s th e p a rty
is a s k in g th e c o u rt to e x c lu d e p e r In s tru c tio n s , p a g e 8
d. In c o m e O f C h ild (re n ) ( if c o n s id e re d e x tra o rd in a ry )

N am e
N am e
e. Incom e F rom C hild S u pp o rt

N am e
N am e
f. Incom e F rom A ssista n ce P rogram s
P rogram
P rogram
g .O th e r Incom e (describe)
23. N on-R ecurring Incom e (de scrib e)

-
24. C hild S u pp o rt O w ed, M onthly, fo r B iological o r Legal

C hild(ren)
N am e/age:
N am e/age:
N am e/age:
Paid f l Y es [ j No
25. O th e r C hild(ren ) Living In Each H ousehold
26.
M other's
H ousehold
Father's
H ousehold
O th e r F actors F or C onsideration
/
09-22-14
14-3*01646-7
43323446
PPP
a .m
SEP 19 2014
p m.
PIERCE COUNTY WASHINGTON

BY____________________DEPUTY
3
4
5
6

7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
PROPOSED PARENTING PLAN
(PPP)
Respondent.
12
This parenting plan is a Temporary Plan proposed by the Petitioner, John Kalii.
13
14
15
I. GENERAL INFORMATION
16
17

Name
Kaena Kalii
18
Aae
8
19
II. BASIS FOR RESTRICTIONS
20
21
22
2.1

Does not apply.
23
Parenting Plan Proposed by P etitioner
GOLDBERG & j o n e s p l l c
LUO WntHke Ave. N Suite TOO
Seattle, Wellington 98109
Tel: ( 204) 44 S-10 I 0 - Fat: ( 206) 448-0736
Email* IS AB IN GO LOBE RGJ ONES.COM
2.2

Does not apply.
III. RESIDENTIAL SCHEDULE
3
4
3.1
There is no child under school age.
5
6
3.2
School Schedule
Upon enrollment in school, the child shall reside with the Petitioner, except for
7
8
Schedule for Child Under School Age
the following days and times when the child will reside with or be with the other parent:
Every weekend except the second weekend of each month from 6:00 p.m. Friday
afternoon to be returned Sunday at 7:00 p.m.

The school schedule will start when each child begins kindergarten
.10
11
3.3
The child shall reside with the father during winter vacation, except for the
12
13
In odd numbered years the child shall be with the mother from end of school to
14
15
16
December 25th at noon and the father from December 25th at noon until the start of
classes following the winter vacation. In even numbered years the child shall be with
the father from the end of school until December 25th at noon and with the mother from
December 25th at noon until 7:00 p.m. the day before classes recommence.
17
18
3.4

The child shall reside with the father during other school breaks, except for the
19
20
21
In odd numbered years the child shall spend the mid-winter break with the mother and
the spring break with the father. In even numbered years the child shall spend the
spring break with the mother and mid-winter break with the father. Mid-winter and spring
22
23
break shall begin at the end of school and terminate at 7:00 p.m. the day before school
is scheduled to restart.
GOLDBERG & j o n e s PLLC

1100 Westlake Ave. N Suite TOO
Tet: (206) 448*1010 - Fax: (106)448-0736
Email- TSABIN@GOLDBERGJOMES.COM
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the father, except
for the following days and times when the child will reside with or be with the other
3
parent:
4
5
Same as paragraph 3.2
3.6

Each parent shall be entitled to a vacation of 15 consecutive days to be
exercised during the summer vacation from school. Notice of the proposed dates for
8
9
10
2014 shall be made by July 15th. For every other year the notice of the proposed dates
of the vacation must be communicated to the other parent on or before May 15th. In the
event of a conflict in dates, mothers dates shall control in even numbered years and the
fathers proposed dates in odd numbered years.
11
12
3.7
13
14
With Father
15
16
17
18
19
20
21
22
23
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Thanksgiving Day
Christmas Eve
Christmas Day
With paragraph 3.3

Odd
Even
Odd
Odd
Even
Odd
With paragraph 3.3
With paragraph 3.3
With Mother
Even
Odd
Even
Even
Odd
Even
For purposes of this parenting plan, a holiday shall begin and end as follows (set
forth times):
Martin Luther King, Memorial Day, Labor Day shall include Saturday and Sunday
immediately preceding the holiday and shall end at 7:00 p.m.

1200 Wexttake Ave. N , Suite 700
Seattle, Washington 9S109
Tel: (206) 440-I010 - Fax: (206>M5-07J*
Email- TSABEVigGOLDBERGJ ONES.COM
July 4th shall begin at 9:00 a.m. July 4th and end at noon July 5th.
Thanksgiving Day shall begin at 6:00 p.m. on Wednesday immediately preceding
3
4
Thanksgiving Day and end at Sunday at 7:00 p.m.
3.8
5
6
Mothers Day
Fathers Day
Mothers Birthday
Fathers Birthday
Kaenas Birthday
8
9
With Father
None
Every
None
Every
Odd
WithMother
Every
None
Every
None
Even
Special occasions shall begin at 6:00 p.m. the day before the special occasion
10
11
and shall end at 7:00 p.m. the day of the special occasion.
In the years the mother is not scheduled to have the child on the childs birthday,
12
13
14
the mother shall have a period of up to four hours with the child during one of the seven
days preceding the childs birthday for a birthday celebration.
3.9
15
16

Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following
order:
17
18
3.10
23
4 school breaks (3.4)
1 special occasions (3.8)
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
21
22
2 holidays (3.7)
6 summer schedule (3.51 5 vacation with parents (3.6)
19
20
3 winter vacation (3.3)
3.11
T ransportation Arrangements


I I N Wtiflaite Ave. N_, Suite 700
Td: (206) 448-1010 - Fax: (106)4484736
Email- TSAB1N@GOLDBERGJ ONES.COM

The receiving parent shall transport. When the child will be traveling by motor
vehicle, the child shall be secured at all times in the safety restraints as provided by
3
4
5
applicable law and any person transporting the child shall have a valid drivers license
and valid liability insurance.
3.12
6
7
The child named in this parenting plan is scheduled to reside the majority of the
time with the father. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
8
9
10
determination of custody. This designation shall not affect either parents rights and
responsibilities under this parenting plan.
3.13
11
12
Other
If the mother will be late for, or will be unable to exercise any scheduled period of
residential time with the child, the mother shall notify the father by telephone at least 48
hours prior to the scheduled beginning of the mothers scheduled residential time. If the
13
14
15
Mother is unable to provide the 48 hour notice; said notice shall be made as soon as the
mother is aware of the delay/miss of residential time. If the mother complies with this
notice requirement, the mother shall have the right to make-up residential time with the
child as established between the parents. If the mother fails to comply with the notice
16
requirement the mother shall not be permitted make-up time with the child.
17
3.14
18
19
20

26.09.480.
that person shall give notice to every person entitled to court ordered time with the child.
21
22
23
notice by personal service or by mail requiring a return receipt. This notice must be at
least 60 days before the intended move. If the relocating person could not have known
about the move in time to give 60 days notice, that person must give notice within 5
go ldberg
& Jon es pll c
1100 YVeitlake Ave. N , Snlte TOO

Scettle, Washington <18100
TH: (106) 448-1010 Fax: (106)44041736
Email- TSABIN@GOLOBERGJONES.COM
1
2
days after learning of the move. The notice must contain the information required in
RCW 26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A
Child).
4
5
actual notice by any reasonable means. A person entitled to time with the child may not
object to the move but may ask for modification under RCW 26.09.260.
6
7
8
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to

health and safety. If information is protected under a court order or the address
9
10
11

contempt.

12
13
14
the child's relocation whether or not he or she received proper notice.
15
16
17
07.0700, (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to
time with the child.
18
19
20
unless: (a) the delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of
the objection, the relocating person shall not move the child before the hearing unless
21
22
there is a clear, immediate and unreasonable risk to the health or safety of a person or
a child.
23
1100 WntUkc Ave. N , Suite 700
Seattle, Waihingtoti 98109
TH: (200) 448-1010 Fax: (206)4484736
Entail- TSABENigGOLDBERGJONES.COM
IV. DECISION MAKING
1
2
4.1
3
4
each child while the child is residing with that parent. Regardless of the allocation of
decision making in this parenting plan, either parent may make emergency decisions
affecting the health or safety of the children.
6
7
4.2
Major Decisions
8
Education decisions
Drivers License
Marriage prior to age 18
Entry into military prior to 18
9
10
11
12
4.3
15
16

Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
13
14
Joint
Joint
Joint
Joint
Joint
Joint
above.
V. DISPUTE RESOLUTION
The purpose of this dispute resolution process is to resolve disagreements about
17
18
19
20
21
22
mediation by Pierce County Center for Dispute Resolution, if this box is checked
and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation, that mediation is appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or
23

I ZOO Westlake Ave. N Suite 700
Seattle, Washington OKI 09
Tel: (106) 448-1010 - Fax: (106)448-0736
Email. TSABIN GOLDBERGJ ON ES.COM
1
50% Petitioner 50% Respondent.
3
by written request.
5
6
7
(a)
(b)
to resolve disputes relating to implementation of the plan, except those related to

financial support.
(c)
counseling or mediation and of each arbitration award and shall be provided to each
9
10
11
party.
(d)
process without good reason, the court shall award attorneys fees and financial
sanctions to the other parent.
12
13
(e)
the superior court.
14
VI. OTHER PROVISIONS

15
16
A.
17
18
19
Each parent shall provide the other with the address and phone number of
their residence and update such information promptly whenever it changes.

B.
Neither parent shall make derogatory comments about the other parent or
allow anyone else to do the same in the children's presence. Neither parent shall allow
or encourage the children to make derogatory comments about the other parent.
20
21
22
C.
Each parent agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the children and the
other parent, and to promote the emotions of affection, love and respect between the
children and the other parent. Said contact shall include reasonable telephone and
23
email contact with the child while away from the parent at the calling parents expense.
Td: (WW) 448-1010 Fai: (206)4484736
Email- TSABINQGOLDBEKGJ ON ES.COM
1
2
All telephone calls shall be made between the hours of 5:00 p.m. and 8:00 p.m. Monday
through Friday or 9:00 a.m. and 8:00 p.m., during weekends or days where there is no
school for the child. If a parent calls and is unable to speak with the child, the parent
shall leave a message and the other parent shall ensure that the child calls back as
soon as is possible, but no later than 24 hours thereafter. Neither parent shall listen in
on the telephone conversations between the child and the other parent, except with the
express consent of the calling parent.
6
7
8
D.
All mail and packages sent to the child by a parent shall be given to the
child immediately upon arrival at the other parents residence. The parent at the childs
location shall provide any necessary assistance with opening and/or reading the
contents of the mailing container.
9
10
11
E.
Neither parent shall use the child to request additional or altered time with
that parent. The parenting plan shall be supported by both parents in the presence of
the child. Neither parent shall use the child as a go-between for communication with
the other parent. Neither parent shall discuss with the child or within the childs hearing
12
13
14
any disagreements or pending court actions the parents may have against the other.
F.
Each parent shall have the right to equal access to all the childs medical,
psychological, psychiatric, counseling, criminal, juvenile and education records, and to

any other information relevant to the childs best interest or welfare, including, but not
15
16
17
limited to, any records being kept by or maintained by the State of Washington
Department of Social and Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the child may reside. Any third
party having or maintain any such records is hereby authorized to release any and all
18
19
20
information upon presentation of a copy of this Parenting Plan by a parent named

herein, without the necessity of a court order or a subpoena duces tecum, unless a child
exercises a legal right to restrict access to said information. Any person, including, but
not limited to, any physician, psychologist, counselor, or educator may speak candidly
21
22
23
of or concerning he child named herein to either of the above-named parents without

court order or subpoena authorizing the same, upon presentation of a copy of this
order, unless such disclosure is prohibited by a childs exercise of statutory rights.
P arenting Plan P roposed by Petitioner
Go l d b e r g & j o n e s p l l c
Tel: (105) 448-1010 - Fax: (106)448-0736
1
2
G.
The childs school shall be kept informed of both parents addresses and
home and work telephone numbers, and the school shall be requested to send
information to both parents for such events as either parent requests.
3
4
5
H.
Each parent shall have equal and independent authority to confer with
school, day care and other programs with regard to the childs progress, and each shall
have free access to school, day care and other records. Each parent shall have
authority to give parental consent or permission as may be required concerning school,
6
7
8
day care o other programs for the child while the child is in her or her care.
I. Each parent shall have equal and independent authority to obtain information
regarding the well-being of the child, including but not limited to, copies of report cards,
school meeting notices, vacation schedules, class programs, request for conferences,
9
10
11
results of testing, results of diagnostic tests, notices of activities involving the child,
samples of school work, order forms for school pictures, and all communications from
all schools, regular day care providers, and counselors. Each parent shall notify the
other, as soon as that information becomes known to the parent, of any parent teacher
12
13
14
conferences to be conducted regarding the child, and the other parent shall have the
right to attend any such conference.
J. Each parent shall have equal and independent authority to arrange routine
medical, optical, and dental services for the child, after coordinating with the other
15
16
17
parent, while the child is in his or her care and residence. The parent scheduling any
such services shall provide the other parent with the name, address and office
telephone number of said care provider.
K. If a parent obtains emergency health care for a child, the parent shall notify
18
19
20
the other parent as soon as possible of the fact that such care has been obtained, the
nature of the illness or injury and the contact information for reaching the care provider.
L. Each parent has the duty to respect the parenting style and authority of the
other parent, and neither parent shall attempt to undermine the authority of the other
21
22
23
parent with the child. Neither parent will make plans or arrangements involving the child
which would impinge upon the other parents authority or time with the child, without the
express agreement of the other parent. If a child has a grievance with a parent, the
other parent must encourage said child to discuss any such grievance directly with the
Go l d b e r g & j o n e s p l l c
1 II Westlake Ave. N , Suite 700
Tel: (706) 448-1010 - Fax: (106)448-0736
1
2
parent in question.
M.
The parties may make minor adjustments, as necessary, to the provision of
this Parenting Plan by agreement. As a precondition to agreeing to any such

3
4
5
adjustment, either party may require that any such agreement be in writing, dated and
signed by both parents. Provided, however, that in order to change or modify the
designation of the parent who is to have primary residential placement of the child, a
petition to modify the Parenting Plan or other similar procedure under applicable state
law must be filed.
VII. DECLARATION FOR PROPOSED PARENTING PLAN

8
9
10
I declare under penalty of perjury under the laws of the state of Washington that
this plan has been proposed in good faith and that the statements in Part II of this Plan
are true and correct.
11
12
6-30-2014, Lakewood, Washington

John A. Kalii
13
VIII. ORDER BY THE COURT

14
15
16
WARNING: Violation of residential provisions of this order with actual

17
18
19
knowledge of its terms is punishable by contempt of court and may be a criminal

offense under RCW 9A.40.060(2) or 9A.40.070(2). Violation of this order may subject a
violator to arrest.
When mutual decision making is designated but cannot be achieved, the parties
20
21
22
shall make a good faith effort to resolve the issue through the dispute resolution
process.
If a parent fails to comply with a provision of this plan, the other parents
obligations under the plan are not affected.
23

1200 Westlake Ave. N Suite TOO
SaUle,WaihiD(lDn 98101
Tel: (206) 440-1010- Fai: (206)4404736
Email- TSABtN@GOLDBEKGJONES.COM
Dated:
Judge/Commissioner
2
Presented by:
Approved for entry:
e QLDBERG JONES
3
4
A '
K fiU r
5
6
7
2 *
Thomas-Rr Sabin, WSBA 7746
.

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

1200 WcsUafcc Arc.
Suite 700
Scuttle, Washington 98109
Td: (20) 448-1010 - Fax: (206)448-0736
Email- TSABINGOl DBF.RGJONES.COM
BEFORE & AFTER SCHOOL RATES
5 PAYS - $75 A WEEK

4 DAYS - $60 A WEEK
3 DAYS - $50 A WEEK
( HALF DAYS & NO SCHOOL DAYS $6 ADDITIONAL FEE
ADDED TO WEEKLY RATE.
FLAT RATE - $30 A WEEK / MINIMUM OF 2 HOURS AND

UNDER A DAY
SCHOOLS WE PROVIDE IS :
A
IN COUNTY S t lR x 'S OFFICE
01646-7
43334214
PPT
A M.
09-24-14
SEP 2 3
2014
P.M.
J
K l5fM irR )!yASHINGTON
KEVIN
stock;
Br----------- C .
C ountyC lerk
DEPUTY
6
7

COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Temporary Parenting Plan

(PPT)
Respondent.
14
15
This parenting plan is a temporary parenting plan signed by the court.
16

17
18
19
20
Name
Age
KAENA KALII
21
22
23
parent's contact with the child and the right to make decisions for the child.
2.1

Does not apply.

S ;\C j4 SES1 \Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc

253-581-0660
2.2
2

Does not apply.
3
4
5
6

The residential schedule must set forth where the child shall reside each day of the
year; including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the child shall have with each parent Parents
are encouraged to create a residential schedule that meets the developmental needs of
the child and individual needs of their family. Paragraphs 3.1 through 3.9 are one way
3.1
10
11
3.2
School Schedule
following schedule:
12
13
other will be on Fridays after school or at 2:00 p.m. if there is no school.
14
15
16
17
18
3.3

19
20
21
22
23
24
W P F D R 01.0400 M a n d a to ry (6/2008) - R C W 26.09.016, .1 8 1 ;. 187 ;.194

S:\CASES1\Kalii\DRAFTS\Pfeadings\Temporary Parenting Plan.doc

Lakewood, W A 98499
253-581-0660
3.4
2
3
by the parties.
4
5
6
7
3.5
Summer Schedule
8
9
10
11
3.6

12
13
14
15
16
17
18
19
20
21
22
23
24
3.7

With Father
With Mother
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
See Par. 3.3
See Par. 3.3
New Years Day
Presidents Day
Memorial Day
Even
Odd
Easter
Even
Odd
July 4th
*
*
Labor Day
Even
Veterans Day
Odd
Even
Odd
Thanksgiving Day
See Par. 3.3
See Par. 3.3
Christmas Eve
See Par. 3.3
See Par. 3.3
Christmas Day
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
- R C W 26.09.016, .181; .187; .194

Lakewood, W A 98499
253-581-0660
1
2
4
5
3.8
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
14
15
Occasion.
16
17
18
3.9
19
20
4
school breaks (3.4)
2
holidays (3.7)
1
6
3
5
21
22
23
24
3.10
Restrictions
Does not apply.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181; .187; .194


Lakewood, W A 98499
253-581-0660
1
2
3.11

5

school care hours.
6
7
8
9
3.12
10
11
12
13
3.13
14
The father shall provide proof of treatment for his alcohol addiction issues.
16
17
18
19
20
21
22
24
Other
Neither parent shall consume non-prescribed drugs or alcohol in excess of the
legal limit to drive while he or she is personally caring for the child.
15
23
3.14
Summary of RCW 26.09.430 .480, Regarding Relocation of a Child

26.09.480.
.181;. 187;. 194

253-581-0660
1
2
3
4
5
6
7
8
9
10
11
12
the child.
13
14
15
16
17
18
19
20
21
22
23
24
contempt.
move.
.181;. 187;. 194

253-581-0660
IV. Decision Making

2
4.1
4
5
4.2
Major Decisions
Education decisions
10
joint
joint
joint
11
12
13
14
15
shall notify the other parent of the proposed major decisions he or she .
16
17
18
19
20
21
22
23
4.3

V.
24
Dispute Resolution
The purpose of this dispute resolution process is to resolve disagreements about

W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
- R C W 26.09.016,. 181;. 187;. 1 9 4
S:\CASES1\Kalii\DRAFTS\Pteadings\Temporary Parenting Plan.doc

Lakewood, W A 98499
253-581-0660
1
2
4
5
10
11
12
13
14
15
16
17
18

(a)
(b)
(c)
(d)
(e)
the superior court.
19
20
21
22
23
24

W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
- R C W 26.09.016, . 1 8 1 ; . 1 8 7 ; . 1 9 4

Lakewood, W A 98499
2 53-581-0660
1
2

3
4
5
6
7
8
9
10
11
12
13
durations.
14

15
16
17
good faith and that the statements in Part II of this Plan are true and correct.*V
I.
18
19
20

21
22
23
24
S:\CASES1 \Kalii\DRAFTS\Pleadings\Temporary Parenting Plan.doc
.181; .187; .194

Lakewood, W A 98499
253-581-0660
1
2
3
4
5
Dated:
sioner
6
7
Presented by:
FAUBIO
R, FRALEY & COOK, P.S.
greed by: ROBYN A LINDSAY

presentation WayB.T COMMISSIONER
8
9
10
11



Approved ao4-agieed by:

/)
F t> g sn o tfU Y ;
tv
12
13
Date
alii, Respondent
Date
14
15
IN COUNTY C lI
16
a .m
17
r KS
OFFICE
SEP 2 3 201^
pm

KEV IN S TO C K , C o u n ty C lerk
BY_____________________ DEPUTY
18
19
20
21
22
23
24
P a re n tin g P la n (P P P , P P T , P P ) - P a g e 10 o f 10
W P F D R 01.040 0 M a n d a to ry (6/2008) - R C W 26.09.016, . 1 8 1 ;. 1 8 7 ;. 194

Lakewood, W A 98499
253-581-0660
\
l
i
01646-7
43334216
ORSW
09-24-14
IN COUNTY
CLERKS OFFICE
4
am.
SEP 23 2014
p-m-

KEVIN STOCK. County,Clerk
BY________ C
^
DEPUTY
7
8
9
COUNTY OF PIERCE
10
11
No. 14-3-01646-7

12
JOHN A. KALII,
Order of Child Support

Petitioner,
13
Temporary Order (ORS)
and
14
BETH A. KALII,
Clerks Action Required
15
Respondent.
16
I. Judgment Summary
17
1.1
Does not apply.
18
19
Judgment Summary for Non-Medical Expenses
1.2
Judgment Summary for Medical Support

Does not apply.
20
II. Basis
21
2.1
Type of Proceeding
22
23
This order is entered under a petition for dissolution of marriage or domestic

partnership, legal separation, or declaration concerning validity:
O r d e r o f C h ild S u p p o r t (T M O R S , O R S ) - P a g e 1 o f 13
WPF DR 01.0500 Mandatory (06/2014) - R C W 26.09.175; 26.26.132

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R

Lakewood, WA 98499
253-581-0660
1
Hearing for temporary child support.
2
2.2
Child Support Worksheet
3
The child support worksheet which has been approved by the court is attached to
this order and is incorporated by reference or has been initialed and filed
separately and is incorporated by reference.
4
5
2.3
Other
6
Does not apply.
7
III. Findings and Order
8
It is Ordered:
9
3.1
Child(ren) for Whom Support is Required
10
Name (first/last)
KAENA KALII
11
12
13
14
3.2
Age
7
Person Paying Support (Obligor)

Name (first/last): JOHN KALII
Birth date: 11/29/1952
Service Address: (You may list an address that is not your residential address
where you agree to accept legal documents.)
15
9711 Winona ST SW
Lakewood WA 98498
16
17
18
19
20
The obligor parent must immediately file with the court and the Washington
State Child Support Registry, and update as necessary, the Confidential
Information Form required by RCW 26.23.050.
The obligor parent shall update the information required by paragraph 3.2
promptly after any change in the information. The duty to update the
information continues as long as any monthly support remains due or any
unpaid support debt remains due under this order
21
22
For purposes of this Order of Child Support, the support obligation is based upon
the following income:
23
A.
Actual Monthly Net Income: $ 4,028.91.
WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132

S:\CdSES1 \Katii\DRAFTS\Pleadings\Temporary OrderofChildSupport,doc

La ke w o od , W A 98499
253-581-0660
1
2
3.3
Person Receiving Support (Obligee)

Name (first/last): BETH KALII
Birth date: 08/11/1968
Service Address: (You may list an address that is not your residential address
where you agree to accept legal documents.)
6 1 1 4 -112th ST SW #54
Lakewood, WA 98498
The obligee must immediately file with the court and the Washington State
Child Support Registry and update as necessary the Confidential
Information Form required by RCW 26.23.050.
The obligee shall update the information required by paragraph 3.2

promptly after any change in the information. The duty to update the
information continues as long as any monthly support remains due or any
unpaid support debt remains due under this order.
10
11
12
For purposes of this Order of Child Support, the support obligation is based upon
the following income:
13
A.
14
3.4
Actual monthly Net Income: $2,217.69.
Service of Process
Service of process on the obligor at the address required by paragraph 3.2
or any updated address, or on the obligee at the address required by
paragraph 3.3 or any updated address, may be allowed or accepted as
adequate in any proceeding to establish, enforce or modify a child support
order between the parties by delivery of written notice to the obligor or
obligee at the last address provided.
15
16
17
18
3.5
Transfer Payment
19
20
The obligor parent shall pay the following amounts per month for the following
child(ren):
21
Name
22
KAENA KALII_____________________________
$723.27
23
Total Monthly Transfer Amount
$723.27

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Order ofChild Support.doc
Amount

Lakewood, W A 98499
253-581-0660
The obligor parents privileges to obtain or maintain a license, certificate,

registration, permit, approval, or other similar document issued by a
licensing entity evidencing admission to or granting authority to engage in
a profession, occupation, business, industry, recreational pursuit, or the
operation of a motor vehicle may be denied or may be suspended if the
obligor parent is not in compliance with this support order as provided in
Chapter 74.20A Revised Code of Washington.
3
4
5
6
3.6
$723.27__________ per month. (See Worksheet line 17.)
7
8
Standard Calculation
3.7
Reasons for Deviation From Standard Calculation

The child support amount ordered in paragraph 3.5 does not deviate from the
standard calculation.
9
10
3.8
11
Reasons why Request for Deviation Was Denied

ojouco fzes (JUT / aT
A deviation w a s not requested.
( k </pP{j a/ T
F a FOC t / f
12
3.9
Starting Date and Day to Be Paid
13
Starting Date:
Day(s) of the month support is due:
14
15
3.10
S e PTF0S c /2. S - O /t f
__________ ________________
Incremental Payments
t
Does not apply.
16
17
18
19
20
21
3.11
Making Support Payments

Select Enforcement and Collection, Payment Services Only, or Direct Payment:
Enforcement and collection: The Division of Child Support (DCS) provides
support enforcement services for this case because: [ ] this is a public
assistance case, [ ] this is a case in which a parent has requested services
from DCS, [ ] a parent has signed the application for services from DCS
on the last page of this support order. (Check all that apply.) Support
payments shall be made to:
22
23

P. O. Box 45868
Olympia, WA 98504

S:\CASES1\Kalii\DRAFTS\PIeadings\Temporary OrderofChildSupport.doc

Lakewood, W A 98499
253-581-0660
Phone: 1-800-922-4306 or 1-800-442-5437

2
[]
Payment services only: The Division of Child Support will process and
keep a record of all payments but will not take any collection action.
Support payments shall be made to:
4
P. O. Box 45868
Olympia, WA 98504
Phone:
1-800-922-4306 or
1-800-442-5437
5
6
7
[]
Direct Payment: Support payments shall be made directly to:
8
Name:
Mailing Address:
BETH KALII
6114 - 1 12th ST SW #54
Lakewood, WA 98498
10
A party required to make payments to the Washington State Support Registry will
not receive credit for a payment made to any other party or entity. The obligor
parent shall keep the registry informed whether he or she has access to health
insurance coverage at reasonable cost and, if so, to provide the health insurance
policy information.
11
12
13
Any time the Division of Child Support is providing support enforcement services
under RCW 26.23.045, or if a party is applying for support enforcement services
by signing the application form on the bottom of the support order, the receiving
parent might be required to submit an accounting of how the support, including
any cash medical support, is being spent to benefit the child(ren).
14
15
16
3.12
Wage Withholding Action
17
Withholding action may be taken against wages, earnings, assets, or benefits,
and liens enforced against real and personal property under the child support
statutes of this or any other state, without further notice to the obligor parent at
any time after entry of this order unless an alternative provision is made below:
18
19
20
3.13
Termination of Support
Support shall be paid:
21
provided that this is a temporary order, until a subsequent child support

order is entered by this court.
22
23
3.14
Post Secondary Educational Support
O rd e r o f C h ild S u p p o rt (TM O R S, ORS) - P age 5 o f 13

W P F D R 0 1 . 0 5 0 0 M a n d a t o r y (06/2014) - R C W 26.09.175; 26.26.132
253-581-0660
1
The right to request post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.
2
3
3.15
Payment for Expenses not Included in the Transfer Payment
4
N
Does not apply because all payments, except medical, are included in the
transfer payment.
The petitioner shall pay 65% and the respondent 35% (each parents
proportional share of income from the Child Support Schedule Worksheet,
line 6) of the following expenses incurred on behalf of the child(ren) listed
in Paragraph 3.1:)
DAO
day care^ UJOdtC &&tA~pcD ^D *-i7V/2
Uoi
T'
educational expenses.
N
long distance transportation e>$nfes. 'p w v to s %finCA/t TU r t& re|
[]
other:
Se r u T f i C w f r O A t N
tJ/?H *
P ee.
Payments shall be made to [ ] the provider of the service [ ] the parent
receiving the transfer payment.
6
7
8
9
10
11
12
13
The obligor shall pay the following amounts each month the expense is
incurred on behalf of the child(ren) listed in Paragraph 3.1:
14
[]
15
[]
16
[]
17
[]
[]
day care: $ ________________ payable to the [ ] day care provider [

] other parent;
educational expenses: $ ________________ payable to the [ ]
educational provider [ ] other parent;
long distance transportation: $ ________________ payable to the
[ ] transportation provider [ ] other parent.
other:
18
19
3.16
Does not apply.
20
21
22
Periodic Adjustment
3.17
Income Tax Exemptions

Tax exemptions for the child(ren) shall be allocated as follows: To the Father in
even years and to the mother in odd years.
23

S:\CASES1\Kalii\DRAFTS\Pteadings\Temporary OrderofChildSupport.doc
253-581-0660
1
The parents shall sign the federal income tax dependency exemption waiver.
2
3.18
Medical Support - Health Insurance
3
4
Each parent shall provide health insurance coverage for the child(ren) listed in
paragraph 3.1, as follows:
3.18.1 Health Insurance (either check box A(1), or check box A(2) and complete
sections B and C. Section D applies in all cases.)
6
A.
10
Evidence
(1) [ ] There is insufficient evidence for the court to determine which
parent must provide coverage and which parent must contribute a
sum certain. Therefore, the court is not specifying how insurance
coverage shall be provided. The petitioners and respondents
medical support obligations may be enforced by the Division of
Child Support or the other parent under RCW 26.18.170 as
described in paragraph 3.18.2, below.
11
OR
12
(2) J ^ T h e r e is sufficient evidence for the court to determine which parent

must provide coverage and which parent must contribute a sum
certain. Fill in B and C below.
7
8
13
14
B.
Findings about insurance:
15
[]
16
17
18
19
Does not apply because A (1) is checked, above.

The court makes the following findings:
JOHN KALII
(Parents Name)
[ i
20
21
22
23
[ i
BETH KALII
(Parents Name)
Check at least one of the following findings

for each parent.
$
premium, only).
$ <2-3*/
premium, only).
$
premium, only).
WPF DR 01.0500 Mandatory (06/2014) -RCW 26.09.175; 26.26.132

S:\CASES1\Kalii\DRAFTS]Pieadings\Temporary OrderofChildSupport.doc

Lakewood, W A 98499
2 53 -581-0660
1
[ ]
2
3
4
[ ]
5
6
[ ]
7
8
[ ]
[ ]
[ ]
[ ]
10
11
12

$
premium, only).
(Check only one parent) Both parties have
available and accessible coverage for the
child(ren). The court finds that this parent has
better coverage considering the needs of the
child(ren), the cost and extent of each parents
coverage, and the accessibility of the
coverage.
Other:
13
14
15
16
17
C.
Parties obligations:
Does not apply because A (1) is checked above.
The court makes the following orders:
18
19
20
21
22
23
S.1C4SES1 \Kalii\DRAFTS\Pleadings\Temporary OrderofChildSupport,doc
253-581-0660
1
2
3
4
JOHN KALII
(Parents Name)
[ ]
BETH KALII
(Parents Name)
[ ]
5
6
7
[ ]
8
9
10
11
12
[ ]
[ ]
[ ]
[ 1
13
14
15
16
Check at least one of the following options

for each parent
through employment or is union-related as
long as the cost of such coverage does not
exceed 25% of this parents basic support
obligation.______________________________
through employment or is union-related
even though the cost of such coverage
exceeds 25% of this parents basic support
obligation. It is in the best interests of the
child(ren) to provide such coverage despite
the cost because: rw/4
T^C.
*
j
O U e.tr'Io
? > f m
insurance coverage for the child(ren) as long
as the cost of such coverage does not exceed
insurance coverage for the child(ren) even
though the cost of such coverage exceeds
It is in the best interests of the child(ren) to
provide such coverage despite the cost
because:
17
18
[ 1
19
20
21
22
23
[ ]
This parent shall pay $________ towards the

health insurance premium being paid by the
other parent. This amount is this parents
proportionate share of the premium or 25% of
this parents basic support obligation,
whichever is less. This payment is only
required if this parent is not providing
insurance as described above.
This parents contribution to the health
insurance premium is calculated in the
Worksheet and included in the transfer
payment.__________________________
O rd e r o f C h ild S u p p o rt (TM O R S, ORS) - Page 9 o f 13

S.1C-4SES1 \Kalii\DRAFTS\Pieadings\Temporary OrderofChild Support,doc
5920 100th S tre et SW , S uite 25
La ke w o od , W A 98499
253-581-0660
1
2
[ ]
[ ]
This parent shall be excused from the

responsibility to provide health insurance
coverage and from the responsibility to
provide monthly payment towards the
premium because:
(Only one parent may be excused.)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
D.
Both parties obligation:

If the child(ren) are receiving state financed medical coverage, the
Division of Child Support may enforce the responsible parents monthly
premium.
The parent(s) shall maintain health insurance coverage, if available for the
child(ren) listed in paragraph 3.1, until further order of the court or until
health insurance is no longer available through the parents employer or
union and no conversion privileges exist to continue coverage following
termination of employment.
A parent who is required under this order to provide health insurance
coverage is liable for any covered health care costs for which that parent
receives direct payment from an insurer.
A parent who is required under this order to provide health insurance
coverage shall provide proof that such coverage is available or not
available within 20 days of the entry of this order to the other parent or the
Washington State Support Registry if the parent has been notified or
ordered to make payments to the Washington State Support Registry.
If proof that health insurance coverage is available or not available is not
provided within 20 days, the parent seeking enforcement or the
Department of Social and Health Services may seek direct enforcement of
the coverage through the other parents employer or union without further
notice to the other parent as provided under Chapter 26.18 RCW.
You may have separate obligations to provide health insurance coverage
for the child(ren) under federal law.
22
3.18.2 Change of Circumstances and Enforcement

23
A parent required to provide health insurance coverage must notify both the
253-581-0660
1
Division of Child Support and the other parent when coverage terminates.
2
If the parents circumstances change, or if the court has not specified how
medical support shall be provided, the parents medical support obligations will
be enforced as provided in RCW 26.18.170. If a parent does not provide proof of
accessible coverage for the child(ren) through private insurance, a parent may be
required to satisfy his or her medical support obligation by doing one of the
following, listed in order of priority:
3
4
5
1) Providing or maintaining health insurance coverage through the parents

employment or union at a cost not to exceed 25% of that parents basic
support obligation;
2) Contributing the parents proportionate share of a monthly premium being
paid by the other parent for health insurance coverage for the child(ren)
listed in paragraph 3.1 of this order, not to exceed 25% of the obligated
parents basic support obligation; or
3) Contributing the parents proportionate share of a monthly premium paid
by the state if the child(ren) receives state-financed medical coverage
through DSHS or HCA (Health Care Authority) under RCW 74.09 for
which there is an assignment.
7
8
9
10
11
A parent seeking to enforce the obligation to provide health insurance coverage

may apply for support enforcement services from the Division of Child Support;
file a motion for contempt (use form WPF DRPSCU 05.0100, Motion/Declaration
for an Order to Show Cause re Contempt); or file a petition.
12
13
14
3.19
Uninsured Medical Expenses
15
Both parents have an obligation to pay their share of uninsured medical
expenses.
The FATHER shall pay 65% of uninsured medical expenses (unless
stated otherwise, the petitioners proportional share of income from the
Worksheet, line 6) and the respondent shall pay 35% of uninsured medical
expenses (unless stated otherwise, the respondents proportional share of
income from the Worksheet,
line 6).
16
17
18
19
20
3.20
Back Child Support
Back child support that may be owed is not affected by this order.
21
22
3.21
Past Due Unpaid Medical S upport
23
Unpaid medical support that may be owed is not affected by this order.
Order of Child Support (TMORS, ORS) - Page 11 of 13

S:\CASES 1\Kalii\DRAFTS\Pleadings\Temporary Order of Child Support, doc
FAUBION, REEDER
FRALEY & COOK, P.S.
La kewood, WA 98499
253-581-0660
1
I(a
0 2
u
3

3.22
IN COUNTY CORK'S
Other Unpaid Obligations
Other obligations that may be owed are not affected by this order!'
2014 p.m.
Back interest that may be owed is not affected by this order. kevPn S$UNTY Washington
BY
o office
3.23
N bTCK, County Clerk
O ther
Does not apply
f1"; 6
rn
7
8
h
S io
Dated:
Presented by:
P.S.
r n
({j
ianTeTTTCobk, WSBA #34866
Cj /TH
______________
__________________ , WSBA #_______

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

order.
(i 12
13
/)s
14
15
Tt>
F O ft/n O A /tY 'f
16
17
BETH KALII
18
[]
19
KALII, PETITIONER
I apply for full support enforcement services from the DSHS Division of Child
Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee
applies if over $500 is disbursed on a case, unless the fee is waived by DCS.)
20
Signature of Party
21
22
23
[]
Approval required in Public Assistance cases. The DSHS Division of Child

Support received notice required by RCW 26.23.130. This order has been
reviewed and approved as to:
[ ] Current Child Support
Order of Child Support (TMORS, ORS) - Page 12 of 13


S:\CASES1 \Kalii\DRAFTS\Pleadings\Temporary Order o f Child Support.doc
FAUBION, REEDER
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
1
2
[ ] Back Child Support

[ ] Medical Support
[] Other:
Deputy Prosecuting Attorney/WSBA No.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
O rd e r o f C h ild S u p p o rt (T M O R S , O R S ) - P a g e 13 o f 13

S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary Order of Child Support.doc

Lakewood, WA 98499
253-581-0660
E-FILED
July 03 2014 4:04 PM
KEVIN STOCK
, W 5V C S OFflCfcoUNTY CLERK
IN COUNTY CLERK
N0: 14_3_01646-7
SEP 23 20^ PM

[ ] Proposed by [ ]
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
Mother Beth Kalii
County PIERCE
(CSWP)
Father John Kalii

Case No. 14-3-01646-7
Child(ren) and Age(s): Ka'ena Kalii, 8

Parti: Income (see Instructions, page6)
1. Gross Monthlv Income
c. Business Income
d.Maintenance Received
e. Other income
f. Imputed Income
a. Income Taxes (Federal and State) Tax Year: Manual
b.FICA (Soc.Sec.+MedicareVSelf-Employment Taxes
g.Maintenance Paid
5. Basic Child Support Obligation (Combined amounts
)
Ka'ena Kalii
$887.00
Father
$4,352.37
Mother
$2,667.00
$4,352.37
$2,667.00
$323.46
-
$19.86
$123.89
$5.35
$46.10
$254.11
$449.31
$323.46
$2,217.69
$4,028.91
$6,246.60
1'
$887.00
,;* "Tj

.645
.355
Part II: Basic Child Support Obligation (see Instructions, page 7)

a. Is combined Net Income Less Than $1,000? If ves. for each
parent enter the presumptive $50 per child.
b. Is Monthlv Net Income Less Than Self-Support Reserve? If yes.
for that parent enter the presumptive $50 per child.
c. ls_Monthlv Net income eaual to or more than Self-SuDoort
Reserve? If yes. for each parent subtract the self-support
child.
$572.12
$314.88
| $1,216.00
$314.88
$572.12
a.Monthly Health Insurance Paid for Child(ren)
b.Uninsured Monthly Health Care Expenses Paid for Chiid(ren)
d.Combined Monthly Health Care Expenses
11. Day Care and Special Expenses
d. Other Special Expenses (describe)
Father
Mother
$234.34
$234.34
$234.34
e.Total Day Care and Special Expenses

plus line 12)
; f."!
ci.'S
.
i "
$234.34
$151.15
3.3
$83.19

15. Gross Child Support Obligation (line 9 plus line 14)
$723.27 |
$398.07
PartV: Child Support Credits (see Instructions, page 9)

$234.34
-

-
$234.34
Part VI: Standard Calculation/Presumptive Transfer Payment (see Instructions, page 9)

$723.27
$163.73
$1,813.01
$997.96
$143.03
$78.72
Part VIII: Additional Factors for Consideration (see Instructions, page 9)

Father's
Household
.
a. Rea! Estate
b. Investments
___ ___
......... -...
Mother's
Household
_
-_
Part VII: Additional Informational Calculations

------------------ -
----------
- __
- ..................................
21. Household Debt

a.
b.
c.
d.
e.
f.
a. income Of Current Spouse or Domestic Partner
Name
Name
b.Income Of Other Adults in Household

Name
Name
c. Gross income from overtime or from second jobs the party
d. Income Of Child(ren) (if considered extraordinary)

Name
Name
___*........ ........ .......................

-------------1
-

Name
Name
f, Income From Assistance Programs
Program
Program
---------g . Other
............. -
..............
................
Income (describe) ......................................................
...................................... ........................
- - -------
......... ...................... , , ___
............... -
__ _

-
24. Child Support Owed, Monthly, for Biological or Legal

Child(ren)
Name/age:
Paid { l Yes f l No
Name/age:
Paid [ ] Yes f l No
Name/age:
Paid [ ] Yes [ l No
............ ...............- ^
.............
26.
Mother's
Household
Fathers
Household
- ............... ...
........ ----------------------

SupportCafe 2014
c:\program files (x86)\legaiplus\state templates\waworksheet.dtf mAscdatatkaliitkalii.scp 07/03/2014 03:07 pm
_____
ROBYN A LINDSAY
COURT COMMISSIONER
FILED
a .m .
SEP 2 3 2014 pm

BY----------------------------- DEPUTY
T J a n ie d
R e s j 0 o n d ^ + 'S
p A r w U n a
'
nod
S h a re d
-ft)
e /n A e jr
iD o lc in a
-h >
^4npom n^
e n + er-
S u m v .O D Y - h .
n r ri-e v c d .
siA Q to o rt
S i ^ i /i o r d -
A kO
O r d ' O Y * __ Q - f -
nYY)
C h ild
W\o-Vioo
p la in .
\ tM f\ V 0 Y ~ T \ rL A
)s
_________
For Respondent
For Petitioner
re:
r o o t-'
n o d __ ( \ t \ j \ a M A .___IWa ' m - t e n a n c s . ________

o rd < v r _ d .
j U ji ___ C
a re *
__ f J c h o e / n s . ^
.__ AI d ___ f i u j g r d __ o - t ___ a - H - o m e ^ c s
Septem ber 23, 2014 9:00 AM
L \ry)
*
ID ' 31 awn
7 lS
Motion - Modify Temp O rder

ROBYN LINDSAY
Clerk:_
Courtroom number: 407
Calendar:C3 - SHOW CAUSE/FAMILY LAW

Ixcrtrpt.pbi djoumal_entry_showcause_report
_____
14-3-01646-7
43335496
09-24-14
AFPT
T /M
'
A .M .
SEP 2 2 2014
P.M.

KEVIN STOCK County Clerk
M
____DEPUTY

County of
In re:
No.
Petitionert1,
and
/Y
Declaration of
A - K A U I
[Name]
(Optional Use)
(DCLR)
Respondent#).

Name:
Age:
\fo ^ r fd
^
A <
_________
/ ______________________________________
l T~l
/ Declare:
_______ A g -T A T C -H M S a J t
Declaration (DCLR) - Page 1 of_

WPF DRPSCU 01.0100 (6/2006)

correct.
Signed at
, [City]
M/ A
[State] on
* 2 -2
^ 0
[Date].
Print or Type Name
D o n o t a ttac h fin a n c ia l reco rd s, p e rs o n a l h ealth c a re reco rd s o r c o n fid en tial

rep o rts to th is d eclaratio n . S uch reco rd s s h o u ld b e s e rv e d on th e o th e r p a rty a n d
file d w ith th e c o u rt usin g one o f th ese c o v e r sh eets:
1) S ealed Financial Source Docum ents (W P F DRPSCU 09.0220) fo r financial records
2) S ealed P ersonal H ealth Care R ecords (W P F DRPSCU 09.0260) fo r health records
3) S ealed C onfidential R eport (W PF DRPSCU 09.270) fo r confidential reports
I f file d s e p a ra te ly u sin g a c o v e r sh eet, th e reco rd s w ill be s e a le d to p ro te c t y o u r
p riv a c y (alth o u g h th ey w ill be a v aila b le to a ll p a rtie s in th e case, th e ir atto rn eys ,
c o u rt p e rs o n n e l a n d certain sta te ag en cies a n d bo ard s.) S ee G R 22(C )(2).
WPF DRPSCU 01.0100 (6/2006)
OTHER MEDICAL INSURANCE OPTIONS

If you are not eligible or feel you cannot afford District medical insurance, the following options are available. These plans are
not endorsed by the District, and the information is provided strictly as a courtesy. No allocation dollars may be used towards
these insurance options and the District cannot deduct premiums from your paycheck.
INDIVIDUAL MEDICAL COVERAGE OPTIONS
In some instances, you may be able to insure your dependent spouse and/or dependent children for medical coverage less
expensively by applying for an individual medical policy. If you would like to review available options use the quoting services
at w w w.affordable-insurance.com or call (877) 466-1999. if calling, mention that you are a CPSD employee. If you or your
spouse are 65 or older you may review Medicare plans at www.emedicaresuDDlements.com or call (877) 275-2808.
I
APPLE HEALTH FOR KIDS PROGRAM
In Washington State, a program is offered to provide health insurance coverage to children under age 19, and qualification is
based on the family income level. The program is funded by federal tax dollars, and almost all states have taken advantage
of these dollars and developed similar programs.
Qualification for the Apple Heath for Kids program is as shown below:
The Fam ilys Income is:
Up to 200% o f "federal
poverty level"*
250% o f "federal poverty

level"*
Examples o f Q ualifying U ; For a family of 2 p e o p le ,v ;
For a family of 2 people,S!:-;

1200% of federal p o v e rty ^ 250% of federal poverty
tlevel is $2,753 monthly. For level is $3,409 monthly. For
a family of 4,200% is
\ a family of 4,250% is & f * ^
$4,174 monthly.
$5,168 m onthly.' ; ^ - ^
M onthly C ost to the

Family
Notes:
Free
$20 per child per month

($40 per month maximum).
300% o f "federal poverty

level"*
^ o i^ fe m il^ q f;^ p e o p le j# ^
3(W%5tf federal poverty : v;
level is ^ ,0 9 0 monthly. For;
a family of.4^250% is ;$ s :
^ ^ 0 lim o n th iy ? ^ 5 ^ lS ^
$30 per child per month
($60 per month maximum).
Income is figured on gross monthly wages minus

$90 per person working. Monthly childcare
expenses (and child support payments for a child
not living in the home) may also be deducted
from monthly income when determining eligibility.
If you have questions Apple Health for Kids and other

programs you might qualify for, please call 877- 543-7669.
A pregnant woman counts as a family size of

two. Other programs with different eligibility
requirements are available for families and
pregnant women. Cali toll-free 1-877-543-7669 to
find out more.
If you declined coverage when you were eligible to enrol!

in the Districts medical plan, you may subsequently apply
for coverage in the event that the Department of Social
and Health Services (DSHS) has determined that it is
cost-effective to enroll you or your eligible dependents in
a medical plan offered by your employer. Applications
must be submitted within 60 days following the
determination by DSHS.
STATE SPONSORED COVERAGE
DENTAL BENEFITS - Principals/ESPCP/Non-Bargaining (Voluntary)

Rate
Employee
METUFE DENTAL
WILLAMETTE DENTAL
$ 69.57
$ 66.65
$138:32
$124.25
$138.32
$124.25
$227.12
$124.25
$227.12
$181.45
$227.12
$181.45
Use any Ijcensed dentist.Use of a MetLife:; { j Use.a Willamette Dental Group Provider; ;c
PRO Network dentist may provide additional:
benefits.
;:C^vvcVCf 'V:
$2,250 per calendar year
No maximum benefit, except TMJ
Employee and Spouse

Employee and Child
Employee and Children
Employee, Spouse and Child
Employee, Spouse and Children
;Provider Network
;C
Annual Individual Benefit

Maximum
Annual Deductible
c p f e $25 individual ($75 family maximum)p
7 f /None V p v p p / p p - p C V p y p p p V V
100% after $10 copay ($30 copay for Specialty
office visit)
Diagnostic and Preventive Care

Covered at 100%
- Exams, x-rays, cleanings,
sealants, fluoride application
Routine Care - Filiings. oral
Covered at 100%"
t surgery, root canals,;periodontics/ ^
p-VJ---ifr^r 3 -'
: endodontics.extractionsCCV; V; r~ 7 : '
Crowns
Covered at 100%
V- P;100% aften$10;rapay>pv C p P p p p v p
- VC ;;V v V | p a p p p p V C p C p
i:ViPP -T:P^pPPPp \;p VP/P --PPPPP-PPPP
\.v&
l' [cpvf,<Ci:\~;c=V;-\ y.> ; V
100% after $10 copay
Dentures, Bridges, Partials
Covereât 50%p:P?p c f c
Implants
Covered at 50%
^100% afltef $10

Not covered
Êmergencyfr e a t m e n t ^ v V ^Coveredas anyother^mcejPp ryj; VJp;^Covered after $50 copay, or up to $100 for. oiitp
v
v5V C y C C C V : VV
of-area emefoen&lreatfoentP
50% to $1,000 lifetime maximum (for
dependents to age 26)
iiNot^veredppvp
Orthodontia
Jtmj
,VV/,.
,W Cv- -ViV-JCCC'
Definition of Dependent Children
' j - V C , P/
s'*
V n
To age 26 regardless of student or marital

status
Treatment paid in full after co-pay of $400. $10

office visit copays apply
J$1,000 annua! maximum, $5,000 lifetime| P p C
maximum - P - v p p l p p c c p p p v
To age 26 regardless of student or marital
status
Note for MetLife new enroilees:

Late entrant waiting period applies for anyone coming on the plan outside of open enrollment without prior coverage (6 months
for Fillings, 12 months for Basic Services, 24 months for Major Services and Orthodontia). Those coming on during the annua!
open enrollment period do not have to satisfy the late entrant waiting period.
Note for Willamette Dental subscribers:
Office visit copays are waived after three consecutive years of being on the Willamette Dental plan (except for Orthodontia).
You must request the waiver of copays: it is not automatic in Willamette's computer system. (Emergency Treatment copays
still apply.)
o Willamette Dental is an exclusive provider network. Benefits are covered under a Willamette Dental group provider. To find
a provider in your area, please visit their website at www.wiiiamettedental.com or call 1.855.433.6825 to speak to a member
services representative.
DECLARATION IN RESPONSE TO BETH KALII'S PARENTING PLAN

It has recently been brought to my attention that Beth Kalii
has not been forthright as to her options concerning her Work
Schedule and Medical Plan.
I
1.) Beth Kalii has worked an (8) eight hour work day schedule
the entire period of our marriage. In her initial bus route
bidding, she elected to choose a bus route giving her only a (6)
six hour work day, reducing her weekly hours from (40) forty
hours to (30) thirty hours. She is presently recieving pay for (40)
forty hours a week, because by Contract with The Clover Park
School District, she continues to be paid full time until re
bidding (for bus routes) are finalized. The date for re-bid is Oct
7, 2014. If she fails to bid on a route with more hours by that
date, she will be locked into her (30) thirty hour a week work
schedule for the remainder of the school year and be salaried
as such. As it stands now, By Beth bidding on the (30) hours a
week, She has essencially voluntarily reduced her work hours
by (40) forty hours a month, reducing her monthly gross
income by $760.00.
Her reasoning for this move was so that she did not have to
wake our daughter, Ka'ena Kalii, an hour sooner in the morning
on her school days. I believe this move was intended to
i
strengthen her argument for her Parenting Plan. However it still

does not change the fact that Ka'ena is still wakened at 6am in
order to be tranported to my home by 6:30am, the time in
which she would normally be awakened to prepare for the
school day at my home. Again she is dropped off from school at
my home at 2:45pm and transported once more to her
mother's house at around 5:00pm after Beth leaves from work.
As submitted in my Response, (dated 09.19.2014) it is my
strong concern that Ka'ena be relieved from being shuttled
back and forth so much during Beth's Week. It would also avoid
Child Care and the costs included. A greater portion of which
Beth is requesting that I pay. Under the revised Parentin Plan
that I requested, Beth will be able to return to her (40) forty
hour week at full pay again. She would still have Kaena 3 of 7
days a week (Friday - Sunday) under my plan. If Beth needs (her
weekend), as she has already expressed to me, I will be more
than happy to take Ka'ena and accomodate her request.
Beth has more than enough seniority to make the changes to
her work route, as she has been working for (10) ten plus years
and is 31 out of 100 on the seniority list.
2.) In matters concerning Ka'ena's Medical and Dental Plan,
it has also come to my attention that in Beth's concerns about
2
N
ll
not having enough money, she has failed to consider her

options through her Employer, (Clover Park School District) to
apply for Medical and Dental programs that would allow her, as
well as myself, greater relief of additional financial burden.
Attached are those options, taken from the Clover Park Benefits
P-!
Handbook 2014-2015.
The reason why I consider this Medical Insurance change so
important is that both Beth and I will financially benefit. Both
Beth and Ka'ena will get 100% free coverage under the offered
!'V,;
>
Plan. Additionally, the dental plan will only cost $138.00 a

month.
This is an important time sensitive option as the Enrollment
Deadline to apply for this change is September 30,2014. After
that date, it cannot be changed until next year.
in c o u n t y J
/
a .m .
\ i
"
14-3-01646-7
43345929
09-25-14
TMO
SEP 23 201% PM
PIERCE COUNTY ,'ASHINGTON

KEVIN S T O - ' ounty Clerk
.DEPUTY
BY---------
3
4
e r k 's o f f ic e
I j
1.! J
l'"U
9
SU PER IO R CO URT OF W A SH IN G TO N
CO UNTY OF PIERCE
10
n
ijj 11
It:
No. 14-3-01646-7
12
JOHN A. KALII,
Tem porary O rder

(TMO)
13
and
14
BETH A. KALII,
Petitioner,
'Tl
Respondent.
[ ] C lerks Action Required

[ ] Law Enforcem ent Notification, H
3.1
15
M oney Judgm ent Sum m ary
16
Does not apply.
17
18
II. Basis
A motion for a temporary order was presented to this court and the court finds
reasonable cause to issue the order.
21
22
23
24
25
III. Order
It is O rd ered :
3.1
Restraining Order
There are no restraining orders in effect under this cause number and the court is
not entering one now.
Temp Order (TMO) - Page 1 of 2


S:\CASES1\Kalii\DFlAFTS\Pleadings\Temporary Order 2.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
3.2
Temporary Relief
2
The parties shall comply with the Temporary Parenting Plan signed by the court.
3
O&
Other:
N fi
s p o ils A c
c v /to
1 7 i
//V < ;c//Z & *JG

s u e p o s it
m O sIPPA
70
7
3.3
,
Does not apply.
3.4
R>
As
$ !. O S D
SVPPO/ZZ~ 0 *S L Y
Bond or Security
^
8
9
c o ^ m /e c /y p ^
-Tt?
p ^ V rJr H
S o rro a r
&F
f f /Z
f X fje<7 /T fjB & s t# '

S e r r e s n ffe ?
f O A rty / r
f F / } r r t o i / / ^ T O F # 1 <23-3-7
P i / l Z U / \ ^ T 7> /ME- O to E e
s c /E ^ fi J >
# *
O F C tf/tO
/> /& & *
Other
10
11
12
Dated: _
13
14
15
16
17
18
19
Presented by:
FAUBION, REEDER, FRALEY & COOK.
ROBYN A LINDSA
Approvedarra agreed by:
COURT COMMISSIO
N o tice^ p rese n ta tio n waived.
Pa
( jJ
OanuJnJ_______


T
order.
O fiJ o /
Approved ar id- uyrOCTJ byTA signature below is actual notice of this
20
21
Date
22
23
A.M. SEP 2 3 20H PM
24

25
Temp Order (TMO) - Page 2 of 2
W PF DR 04.0250 Mandatory (0&2012) - R C W 26.09.060; .110; .120; .194, .300(2)

S:\CASES1\Katii\DRAFTS\Pleadings\Tempom ryOrder2.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660
14-3-01646-7
43347400
LTRSTC
09-25-14
1 S u p e r io r C o u r t
J
OF THE
S t a t e o f W a s h in g t o n
f o r P ie r c e C o u n t y
SUPERIOR COURT
(253) 798-3654
334 COUNTY-CITY BUILDING

930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108
September 24, 2014
Daniel N Cook
ATTORNEY AT LAW
5920 100th ST SW Ste 25
LAKEWOOD WA 98499-2751
John Alika Kalii Jr.
9711 Winona ST SW
LAKEWOOD WA 98498
Dear Counsel/Litigant:
This is to confirm the following settlement conference:
Case:
Cause No.:
Before:
Date & Time:
JOHN ALIKA KALII JR VS. BETH ANN KALII

14-3-01646-7
Judge JOHN MCCARTHY, County-City Bldg, Room 323
Apr 15 2015 8:30AM
The court requires all parties to:

1.
Be personally present unless excused by the Judge;
2.
Deliver the pretrial information and any supplemental information to the

department conducting the settlement conference at least two business days
before the settlement conference: and
3.
Be fully prepared, with all discovery matters completed.
Please remember that failure to supply the settlement judge with appropriate forms in a timely
manner may result in the imposition of sanctions. For complete information regarding settlement
conferences, please refer to the Pierce County Local Rules.
Sincerely,
d iiu s )
}
Judicial Assistant
CC: Pierce County Clerk for Filing
E-FILED
IN COUNTY CLERK'S OFFI<
PIERCE COUNTY, W ASHING
September 29 2014 3:21 P

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7

9
No. 14-3-01646-7

10
11
12
13
Petitioner,
and
BETH ANN KALII,
Respondent.
14
15
16
I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
On September 17, 2014, I placed in the U.S. Mail a copy of the following
17
18
19
20
21
22
23
1. Temporary order entered on September 23, 2014

2. Temporary Parenting Plan entered on September 23, 2014
3. Temporary Order of Child Support entered on September 23, 2014.
John Kalii
9711 Winona ST SW
Lakewood WA 98498 I
I declare, under the penalty of perjury and the Laws of the State of Washington, that
the foregoing is true and correct.
24
DATED
September 29,2014
25
^
Sniffy DuCharme, Legal Assistant

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
PIERCE COUNTY, W ASHING T(
January 15 2015 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
IN THE S U PE R IO R C O U R T OF THE STATE OF W A SHING TO N

IN A N D FO R THE C O U N TY OF PIERCE
10
11
No. 14-3-01646-7
JOHN A LIK A KALII, JR.
12
Petitioner,
and
13
BETH ANN KALII,
14
M otion/D eclaration for an

O rder to Show Cause re
Contem pt
(M TSC)
Respondent.
15
I. Motion
16
17
18
19
(Name of requesting party) BETH KALII moves the court for an order directing (name of
other party) JOHN KALII to appear personally before the court and show cause why an
order should not be entered:
1.1
Finding Contem pt
Finding contempt for failure to comply with:
20
The order of child support signed by the court on (date) September 23,
2014, in (county and state) Pierce County, Washington.
21
22
1.2
Establishing a Judgm ent
23
24
25
Establishing a judgment in the amount of $2,893.08 plus interest for delinquent

child support and $150 costs for the period from September 2014 through January
2015.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 1 of 4
WPF DRPSCU 05.0100 Mandatory (10/2009) - R C W 26.09.160
S:\CASES1\Kalii\DRAFTS\Pleadings\Contempt\Motion for Order to Show Cause.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
1
1.3
Granting Sanctions
2
Granting sanctions for contempt, including a forfeiture for each day the contempt of
court continues, and establishing conditions by which the contempt may be purged
and granting any other relief, including reasonable attorney fees and costs and
m ake up residential time, as may be appropriate under Chapter 7.21 RCW ,
Chapter 26.09 RCW , Chapter 26.10 RCW , Chapter 26.26 RCW , and R C W
26.18.040.
3
4
5
Imprisonment is sought as a sanction.
1.4
Other
8
Does not apply.
9
10
11
This motion is based upon the declaration which follows.

D A TED this
} L(
day of January 2015.
FA UBIO N, R E E D E R , FR A LEY
12
Daniel N. Cook, W S B A 34866
O f Attorneys for Respondent
13
14
II. Declaration
15
JO HN KALII should be held in contempt for the following reasons:

16
17
18
Failure to comply with the provision of the child support order which directed
payment of:
Current child support in the amount of $ 723.27 per month.
19
20
21
22
23
24
25
Child care, educational expenses, transportation expenses, or other special

expenses as described below:
65% of all work-related daycare.
This order was violated in the following manner:
JO H N KALII has not paid the $ 72 3.2 7 in child support since September 2014.
Currently the amount he has not paid is $2,893.08 through January 2015.
In October or Novem ber 201 4 JO H N told me he would not pay the court ordered
child support. JO H N claimed he had no money. JO HN told me he would sign

FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
3
4
5
6
7
8
9
10
11
12
13
over a trailer that we acquired during our marriage in lieu of paying me child
support.
I knew of two friends who wanted to buy the trailer. Faced with the prospect of no
support from JOHN and the opportunity to sell the trailer and have some cash
available I agreed to JOHNS proposal.
I had no money and owed a balance to my attorney so I did not discuss the matter
with him. JOHN told me that in order to get the trailer I had to sign a document
saying he would not pay child support for six months if he gave me the trailer. I
had no other option and I signed it hoping to sell it and have cash for bills.
Then both potential buyers backed out. I now have a trailer, which was arguably
my separate property to begin with since it was a gift to me during the marriage,
sitting in my driveway and no cash for child support. I need JOHN to begin paying
child support again. I will attempt to sell the trailer and JOHN will receive credit for
one-half of the amount received for the trailer against the back support he owes
but I need child support to be paid at this time. I will not ask for interest on the
back amount due.
John receives approximately $5,000 per month in income. He is retired. He could
work if he wished or if he needed money. But he is happy in retirement living on
his $5,000 per month. That is fine if he wants, but child support needs to be paid.
14
15
16
17
18
I work full-time as a bus driver for the Clover Park School District. I receive net
income of $1,900 per month. I am currently paying $950 for rent each month. My
utilities are $400 per month. Car insurance is $70 per month. My gas expense is
$200 per month. I have monthly prescription medication and regular doctor visits
which cost $50 per month. That is $1,670 per month and only leaves me with
$230 per month for groceries, supplies, personal /toiletries and clothing for KaEna
and me.
It is simply not enough. I have had to borrow lots of money from friends
to simply make ends meet.
19
20
21
22
23
24
25
If JOHN begins paying child support for the month of January 2015 and forward
without requiring a contested hearing then I will not ask for a finding of contempt.
I understand that JOHN stopped paying because he released his interest in the
trailer. But the deal that JOHN forced me to sign under threat of no payment at all
was not fair and should not be maintained. JOHN needs to pay child support. If
JOHN does not pay child support beginning with the month of January 2015 then
he should be held in contempt. He is now on notice that his releasing of his
interest in the trailer is not adequate to offset child support.
JOHN also needs to pay his share of daycare. KAENA spends equal amounts of
time with both parents. She is with me for a week and then with JOHN for a week.
WPF DRPSCU 05.0100 Mandatory (10/2009) - RCW 26.09.160

FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253)581-0660
1
2
3
4
5
6
7
Historically JOHN has watched KAENA before and after school on my weeks
because I am employed and he is retired. He recently told me he would not watch
KAENA on my weeks anymore. That is fine and is his option and I will put
KAENA in a commercial daycare. But the Temporary Order of Child Support
specifically and unambiguously requires JOHN to pay his share of daycare on my
weeks if he does not provide the care. JOHN has told me he will refuse to pay
daycare. If he does not pay daycare he should be held in contempt.
8
Signed at
9
'
on
O
(City)
(State)
10
11
BETH KALII
12
13
14
15
16
17
18
19
20
21
22
23
24
25

FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
January 15 2015 8:30 AM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
vs.
BETH ANN KALII

Respondent(s)

Phone:
Petitioner
Show Cause
Nature of Hearing: Contempt
CALENDAR DATE: Thursday, February 05, 2015 9:00 AM

DATED:
January 14, 2015.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
1 of 1
E-FILED
January 16 2015 11:11 AM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

JOHN ALIKA KALII JR

No. 14-3-01646-7
Petitioner(s),
vs.
BETH ANN KALII

Respondent(s)

Phone:
Petitioner
Show Cause
Nature of Hearing: Contempt,CNTP~Contempt
CALENDAR DATE: Wednesday, February 04, 2015 9:00 AM

DATED:
January 16, 2015.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
1 of 1
to
C2
0
i C O U H * CSOFBCE
3
4
43961564
U-3-0164-7
ORTSC
01-16-15
j . JAH15286 ^
J6
N
7
m
8
IN THE SUPERIO R COURT OF THE STATE OF W ASHINGTON
IN AND FOR THE CO UNTY OF PIERCE
U?

tM
11
n
(\jl2
No. 14-3-01646-7
Petitioner,

C ontem pt
(ORTSC)
Respondent.
C lerks Action Required
and
t 13
BETH ANN KALII,

14
15
It is O rdered :
16
(Name of nonrequesting party) JOHN KALII shall appear in person before this court at
the place and time below and show cause why the relief requested in the motion should
not be granted.
17
18
Date:
Time:
Place:
19
20
21
22
23
February 5, 2015
9:00 a.m.
Room/Department: 117, 407 or 2-A as assigned
If you fail to appear in person and defend at these proceedings the court may grant all
of the relief requested and/or issue a bench warrant for your arrest without further notice
to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may
request the court to appoint an attorney to represent you.
24
Dated:
' 5
25
Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1

S:\CASES1\Kalii\DRAFTS\Pleadings\Contempt\Orderto Show Cause re Contempt
(form).doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
#- -
i<)
3)
3
4
Presented by:
P.S.
5
j.6
Ci
7

Li?
'H
;;10
N
\11
0
.12
i3
14
15
16
17
18
19
20
21
22
23
24
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Contempt\Order to Show Cause re Contempt
(form).doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
1
i? l
S '
c?
IN COUN^
' clerk s OFFICE
\AN 20 2015 pW
I
4v
5
6
&
wi
u8
IN THE SUPERIO R COURT OF THE STATE OF W ASHING TO N
IN AND FOR THE C O U N TY OF PIERCE
Ifi
H10
o
r 11
, 12

No. 14-3-01646-7
JOHN A LIK A KALII, JR.
Petitioner,

Contem pt
(ORTSC)
Respondent.
Clerk's Action Required
and
13
BETH ANN KALII,
14
15
It is Ordered:
16
(Name of nonrequesting party) JOHN KALII shall appear in person before this court at
the place and time below and show cause why the relief requested in the motion should
not be granted.
17
18
Date:
Time:
Place:
19
20
21
22
23
February 4, 2015
9:00 a.m.
Room/Department: 117, 407 or 2-A as assigned
If you fail to appear in person and defend at these proceedings the court may grant all
of the relief requested and/or issue a bench warrant for your arrest without further notice
to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may
request the court to appoint an attorney to represent you.
24
Dated:
25
JAN 2 0 2015
MARY E DICKE
_
. .
COURT COMMISSIONER
(Com m issioner
JudgsCommissi<


S:\CASES1\Kalii\DRAFTS\Pleadings\Contempt\Orderto Show Cause re Contempt
(fonv).doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
<#
-1
;i
VI
"I
3
Presented by:
P.S.
.6
3!

J:7
9
.0
10
"'in
;\j'n
>3
14
15
16
17
18
19
20
21
22
23
24
25

S:\CASES1\Kalii\DRAFTS\Pleadings\Contempt\Order to Show Cause re Contempt
(form), doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
14-3-01646-7
44047520
AFPT
01-30-15

a .m.
JAN 2 9 2015
p,A

K E V IN S T O C K , C ounty C lerk

County of
In re:
A-U K &
K A U /
CTA
No.
Petitioners),
and
"7
Declaration of
& ? {{ A H N
K A U I1
ia t
^ cT ) ^
727
CO NTEM P T .
[Name]
(Optional Use)
(DCLR)__________________________
Respondent(s).
Name:
Age:
j 7 2 / c L
/ K -A
1/
s.772^
7? 2 _____________________________
ffiT f l~V 1.0
I Declare:
k w iT io H k L ___ A / U P
a a a
h r-T A T C H z ry
M ( 1 < M E ^ f 7 . ______________________________
Declaration (DCLR) - Page f of_
WPF DRPSCU 01.0100 (6/2006)
v
^

correct
Signed at
LA
. [City]
\a)A
<Tofa4 AUKA KALII
vTR
Print or Type Name
D o n o t atta c h fin a n c ia l reco rd s, p e rs o n a l health care reco rd s o r c o n fid en tial

rep o rts to th is declaratio n . S uch reco rd s s h o u ld be s e rv e d on the o th e r p a rty a n d
file d w ith th e co u rt usin g o n e o f th ese c o v e r sh eets:
1) S e ale d F in a n c ia l S o u rce D o cu m e n ts (WPF DRPSCU 09.0220) for financial records

2) Seated Persona/ H ealth Care Records (W PF DRPSCU 09.0260) fo r health records
3) S ealed C onfidential R eport (W PF DRPSCU 09.270) fo r confidential reports
If file d s e p a ra te ly using a c o v e r sh eet, th e reco rd s w ill b e se a le d to p ro te c t y o u r
p riv a c y (altho ugh th ey w ilt b e av a ila b le to a ll p a rtie s in th e case, th e ir atto rn eys,
c o u rt p e rs o n n e l a n d certain sta te ag en cies a n d bo ards.) S ee G R 22(C )(2 ) .
Declaration (DCLR) - Page 2 of____
WPF DRPSCU 01.0100 (0/2000)
I. Response to Declaration re: C ontem pt
It is John Kalii's belief th a t this recent e ffo rt by Beth Kalii to accuse

him of contem pt is in retaliation of him confronting her w ith his issues
and concerns about her drinking and driving w ith Ka'ena Kalii in her
vehicle. This was a huge issue which initiated our breakup during th e
period she was pregnant w ith Ka'ena, in which she refused to stop
drinking and smoking during th e en tire pregnancy. O ther m atters
concerning Ka'ena's personal hygeine and schoolwork are also in
question now. These are issues th a t John Kalii is extrem ely passionate
about because it directly concerns Ka'ena's health, safety, and w ell
being. In an e ffo rt to address these concerns, these m atters are on
record and have been brought to th e attentio n of Child Protection
Services, as w ell as th e Lakewood Police in th e form of a protection
order request. This request was denied because it was th e ir contention
th a t it should be handled through th e divorce proceedings. These issues
are on-going and will continue to be addressed into th e fu tu re. Ka'ena
Kalii's w elfare is goal one.
M y next step is to file an em ergency m otion for Tem porary Custody
of Ka'ena Kalii, as it is my understanding th a t th e Court's forem ost
concern, as is m ine, is fo r th e safety and w ell being of my daughter.
Response
In th e m a tte r of contem pt fo r failure to comply w ith th e order of child
support on (date) Septem ber 23, 2014, in (court and date) Pierce
County, W ashington. John Kalii should not be held in contem pt for th e

follow ing reasons:
John Kalii is not delinquent, but current on his child support
paym ents from Septem ber 2014 through February 2015. Proof of this
current support status is docum ented by th e Acceptance A greem ent
signed and notarized on O ctober 9, 2014.
John Kalii w ould also like to ask th e court th a t Beth Kalii show proof
of her claim th a t John Kalii, in any m anner or form , forced or coersed
her into signing above m entioned agreem ent, which was her her idea
from th e beginning.
*
Beth Kalii was contacted by John Kalii in O ctober 2014, through
phone text, th a t he was struggling financially to make ends m eet. This is

w hen th e transfer of a com m unity travel tra ile r was brought up and
agreed upon. The agreem ent was th a t Beth Kalii w ould take possession
of th e tra ile r which w ould be sold by her, as satisfaction of child
support paym ents through February 2015. Additionally, it was also a
dem and of Beth Kalii th a t an agreem ent le tte r be drawn up, signed and
notarized, along w ith th e transfer of title, of th e travel trailer. A fter
signing both docum ents, Beth Kalii was quite satisfied w ith the
agreem ent, voicing to John Kalii th a t she had buyers for th e trailer. She
appeared happy w ith th e transfer of th e tra ile r and expressed gratitude
for him delivering it personally to her home.
A copy of th e NADA bluebook guideline is provided and outlines th e
current value of th e travel trailer. It is in very good condition, inside and
2
out.
Having been satisfied fo r fo ur (4) m onths concerning th e child
support paym ent, Beth Kalii is now claiming th a t John Kalii is in
co n tem p t fo r non-paym ent.
*
John Kalii does not recieve $5,000 per m onth in income as Beth Kalii
suggests. Prior and current financial disclosures shows John Kalii's net
incom e to be $4,02 8.91 . Beth Kalii and M r. Cook are w ell aw are of this
as th ey both have seen and signed copies of this. A Pension Verification
Letter is provided here, as well as a benefit sum m ary from th e
W ashington State of R etirem ent Systems. Beth Kalii also claims to
recieve a net income o f $1,900 a m onth. According to her signed
financial disclosures, her reported net incom e is $2,217.69. O ther
claims concerning rent ($950), gas ($200) and utilities ($400) are also
subject to question and appear to be clearly inflated. I w ould ask th a t
th e Court require Beth Kalii to o ffer th ree (3) months proof of these
d ifferen t reported figures.
*
As fa r as m atters concerning Beth Kalii's claim fo r th e "need" of
John Kalii to pay fo r his share of daycare:

John Kalii has from day one (1) to present, personally provided
"daycare" for Ka'ena M akani Kalii. This is and has been inclusive to
every w eek th a t Ka'ena Kalii has been and still is under Beth Kalii's care.
Historically, John Kalii has always been th e prim ary caregiver of
Kaena Kalii w hile th e fam ily has been to g eth er and m ore so now,
during this divorce and his recent retirem en t. He has always provided
3
pre-school and after-school care even during his career w orking as a

Tacoma Firefighter (1 9 80 -20 13 ) because his flexable w ork schedule.
Today Ka'ena continues to spend th e m ajority of her tim e w ith her
Father, which includes care tw ice a day, (every school day) am ounting
rH
to th irty (30) hours a m onth th a t she is supposed to be under her
r)
M other's care.
John Kalii has never refused to pay child support or child care at
any tim e. Beth Kalii should be held accountable for these statem ents by
h
providing proof of such claims. All of our corespondence is done
:i
through te x t messaging as w e are not on m utual speaking term s.

Lastly, as a final note, th ere was no issue about child support
paym ents for fo ur months until Beth Kalii was confronted by John Kalii
about her drinking and driving habits involving Ka'ena Kalii and o ther
children in her vehicle.
ACCEPTANCE AGREEMENT
:l, Beth Ann Kalii, acknowledge on this day O ctober 9 ,2 0 1 4 , th a t

Child Support paym ents to m e, by John Alika Kalii, are current and paid
in full through February, 2015 by acceptance o f ownership and Title o f
his 1996 W ilderness 26/SC travel trailer. Title # 1 3 2 4 6 1 6 0 1 0
i, John Alika Kalii relinquish all legal rights and ownership o f
afo rem entio ned travel tra ile r to Beth Ann Kalii as paym ent in full o f
Child Support obligations through February, 2015, w ith th e
understanding th a t any monies m ade by sale o f tra ile r are to cover
Child Support paym ents and th a t any rem aining funds to be kept solely
by Beth Ann Kalii.
I declare under penalty o f perjury under th e laws o f th e State o f

W ashington th a t th e foregoing is tru e and correct.
Signed at Lakwood, W ashington on O ctober 9, 20 14
I-,,
^'^'
'-. f s ' ^ >'S-'oS.-'jy).

j-*
:T v
*-* .'Jr-l'--. -,:
,\: -'J'rfjZf.rr>1 .i
3 " .r3 Ali ,*' 1 > v\t
* 5 ^ -:' : V-rr.; --
S.;8-;S7- V
:;..' .V-i- %Aj '?S>;|'6-a l>"
- .. =i;;;o :tn;.
:;W :
,:;1*Q. S5*i! "
-
S-
v - .:
;:i^D;^"0.',
'
>r
, l> ,J.
,|Zy.^Ô.V
:...'
s.,'.
o--:^Wr3.
>~ -
..:ts 7?;
v."
'.- .. -fr:
'
0:-.C.
(r
'
^ V ^ V 'W :S ,T V -y ;. v ; r : -CD.'-IS.-:. .
;-;i;^||vV-/,;:- - v v ^ i ; ;r
;:-yi;:i't-J-4 1it'.;-S;1;; ,bC-t n &X
7^ i > :7=:-:r^
:,>.'
-.:m>;/'^ )- : :
7:i;V'7 ' 7 ' '-Mi;I;: ' r ;
'.-i9-c :S v-'^S;.,&\ f?io r^r: /;

.$:=. -,
^ ^ ^ :'
'. 1 -'' r '.f:'^ .-'.-Ji':î">f"'.'-

r<D '..
/ , \ : v . v ;i=^::v-- v.- ' &.&&
v-tfstD^zr:
$'WS
:-'Vi-.ttt'itWiiO ;
'..tti-aSu--.:
,
.--,!*.;.
-:
.
Keep in a safe place. Any alteration or erasure voids this title.
1/24/2015
1996 Wilderness M-24L Standard Equipment, Prices & Specs - NADAgtides

AUTOS
MOTORCYCLES
CLASSIC CARS
RVS
BOATS
MANUFACTURED HOMES
Change Manufacturer > Change Year & Model > Change Options > Values
PRODUCT STORE
AcCncicesO
1 9 9 6 W ild e rn e s s
M -2 4 L
Researchanother travel trafer/Sth wheel

Values
Specifications
Floor Plan
Special Notes
V alues
Values
Suggested
List Price
Low
Retail
Average
Retail
$ 1 5 ,1 2 8
$ 3 ,9 0 0
$ 4 ,6 8 0
$100
$70
$505
$100
$240
$35
$100
$85
$35
$55
Awnhg 25* (Each)
$85
$60
$420
$85
$200
$30
$85
$70
$30
$45
$235
Exterior Pant
Traler Hlch
$555
$25
$670
$30
$ 5 ,8 2 5
$ 6 ,9 9 0
Base P rice
O p tio n s : tetemgcl
110 Vot - 15,000 Brru (Roof Mount)

Furnace (21,000*28,000 BTU)
10 cu. ft.
Flushing T oiet/HoUing T ank
Gas/Efec. 7 cu. ft.
Microwave Oven
Waste Water Holdiig Tank
Water Heater 6 Galon Gas/Elec w/DSI
AM/FM Cassette Stereo
Stabler Jacks-Crank Down (Each)
TOTAL PRICE:
RVs for Sale

Find 1996 Wilderness M-24L listings near
you In Lakewood, WA
$ 1 5 ,1 2 8
$285
RV Insurance
See how much money you can save with a
FREE quote on a 1996 Wilderness
Poweredby RV Trader
RV Resources
Need RV firtanctig? Get approved now
Sel your RV at RVTrader
Buy an RV price guide
RV history report- Get the feds

E n te r V IN o r C lick GO
Next: Specifications
ValueTyneDefinitions
http7/www.nadaguides.com/R\/s/1996AMIderness/M-24U4073974A/aiues
1/2
STATE OF W ASHINGTON
DEPARTM ENT O F RETIREMENT SYSTEMS

P.O. Box 48380 O lym pia, W A 98504-8380 (360) 664-7000 T oll Free 1-800-547-6657 w w w .drs.w a.gov
January 9, 2015
JOHN A. KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
RE: Pension Verification
SSN: XXX-XX- 5489

John A. Kalii receives a gross monthly retirement benefit amount o f $4,405.47 from the
Washington State Law Enforcement Officers and Firefighters Retirement System. This is a
lifetime benefit.
If you need further assistance, please contact us at 1-800-547-6657.
Sincerely,
David Nelsen
Assistant Director
Customer & Policy Services
PLEASE REFER TO SS#, RETIREMENT SYSTEM AND PLAN ON ALL CORRESPONDENCE
Benefit Summary
1/22/2015
WASHINGTON STATE DEPARTMENT OF RETIREMENT SYSTEMS

M a k in g it
easy to see
y o u r fuiure
360-664-7000 | 800-547-6657
B e n e fit S u m m a ry
Help
T h is s c re e n p re s e n ts in fo rm a tio n a s re p o rte d b y y o u o r y o u r e m p lo y e r a s o f T h u rs d a y , J a n u a ry 2 2 ,2 0 1 5 . If
in fo rm a tio n d is p la y e d is in c o rre c t, p le a s e s e e th e in s tru c tio n s o n h o w to m a k e c h a n g e s .
Membership Details
N am e:
J o h n A K a lii
S y s te m /P la n :
L a w E n fo rc e m e n t O ffic e rs a n d F ire fig h te rs ' R e tire m e n t S yste m P la n 2
S ta tu s :
R e tire d
Retirement Details
D o w n lo a d P e n s io n V e r ific a tio n L e tte r
D a te :
0 1 /0 1 /2 0 1 3
S e rv ic e C re d it:
T ype:
S e rvice
O p tio n :
S in g le L ife
3 9 6 .0 0 m o n th s o r 3 3 .0 0 ye a rs
W e u s e th e m o s t re c e n t in fo rm a tio n yo u ve g ive n u s to m a k e p a y m e n ts . A ny c h a n g e s th a t you s e n d u s a fte r th e

1 5 th, m a y n o t ta ke e ffe c t u n til th e fo llo w in g m o n th .
M o n th ly P a y m e n t
1 1 /2 8 /2 0 1 4
1 2 /3 1 /2 0 1 4
G ro s s B e n e fit
$ 4 ,4 0 5 .4 7
$ 4 ,4 0 5 .4 7
(Rate Below):
-3 3 1 .4 3
-3 3 1 .4 3
N e t B e n e fit A m o u n t:
$ 4 ,0 7 4 .0 4
$ 4 ,0 7 4 .0 4
IR S W ith h o ld in g
IRS W ith h o ld in g R a te : M a rrie d - 3 A llo w a n c e s e s ta b lis h e d 0 1 /2 0 1 3

P a y m e n t D e liv e ry M e th o d : E le c tro n ic F u n d s T ra n s fe r (E F T ) to H a rb o rs to n e C u e ffe c tiv e 1 2 /2 0 1 2 .
P a D e r B e n e fit S ta te m e n t D e liv e rv : If C h a n g e Is M ade A nd E nd O f Y e a r
Beneficiary
httpsjfta rtre s s j wago^d'S/drsonlinesso/M errfcer/BenefitSmmary1
1/1
E-FILED
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY-CLERK
N O : 14-3-016 46-7
H
!'")
n
^
W a s h in g t o n S t a t e C h ild S u p p o r t S c h e d u le W o r k s h e e t s
[ ] P roposed b y [ ]
[ ] S tate o f W A [ ] O th e r
O r, [ ] S igned b y th e J u d icia l/R e vie w in g O ffice r. (C S W )
M o t h e r B eth K alii
F a th e r John K a lii
C o u n ty P IE R C E
C a s e N o . 14-3-016 46-7
(C S W P )
C h ild fre n ) a n d A q e (s ): Ka'ena K a lii, 8

P a rt I: In c o m e (se e In s tru ctio n s , page 6 )
1. G ro ss M o n th ly Incom e
a. W ages and S a la rie s
b .ln te re s t and D ivid e n d Incom e
c. B usiness Incom e
d .M a in te n a n ce R eceived
e. O th e r Incom e
f. Im puted Incom e
g .T o ta l G ross M o n th ly Incom e (add lin e s 1a th ro u g h 1f)
F a th e r
$4,3 5 2 .3 7
-
M o th e r
$2,6 6 7 .0 0
-
_
.
$4,3 5 2 .3 7
$2,6 6 7 .0 0
$323.4 6
_
-
$ 1 9.86
$ 1 23.8 9
$5.35
$46 .1 0
$254.11
2. M o n th ly D ed u ctio n s fro m G ro ss Incom e

a. Incom e T axes (F e d e ra l a nd S ta te ) Tax Year Manual
b .F IC A (S o c.S e c.+ M e d ica re V S e lf-E m p lo ym e n t T a xe s
c .S ta te In d u stria l In su ra n ce D e d u ctio n s
d. M andatory U n io n /P ro fe ssio n a l D ues
e .M a n d a to ry P ension P lan P aym ents
f. V o lu n ta ry R e tire m e n t C o n trib u tio n s
g. M a intenan ce P aid
h. N orm al B u sin e ss E xp e n se s
i. T o ta l D ed u ctio n s fro m G ro ss Incom e
3. M o n th ly N et Incom e (line 1g minus 2i)
4. C om bined M o n th ly N e t Incom e
$32 3 .4 6
$449.31
$ 2 ,2 1 7 .6 9
$4,028.91
$ 6 ,2 4 6 .6 0
5. B a s ic C h ild S u p p o rt O b lig a tio n (C o m b in e d am ounts )

K a'ena K a lii
$ 8 8 7 .0 0
$887.0 0
6. P ro p o rtio n a l S h a re o f In co m e
(each parents net income from line 3 divided by line 4)
.6 4 5
.355
E-FILED
IN COUNTY CLERI
PIERCE COUNTY, W
February 03 2015
KEVIN STO
COUNTYC.
NO: 14-3-0'
2
3
4
5
6
7
8
9
10

)
)
)
)
Case No: 14-3-01646-7

DECLARATION OF
SERVICE:
Petitioner,
31
and
12
BETH ANN KALII,
13
Respondent.
M OTION FOR ORDER TO

SHOW CAUSE, ORDER TO
SHOW CAUSE AND NOTE
FOR COM MISSIONERS
CALENDAR
14
15
16
17
18
19
20
21
22
23
The undersigned declares under penalty o f perjury under the laws o f the State o f
Washington that the following is true and correct.
The declarant is now and at all times herein mentioned was a citizen o f the United
States and a resident o f the State o f Washington, over the age o f 18, not a party to nor
interested in the above-entitled action and competent to be a witness therein:
On the 21st Day O f JANUARY, 2015 at 5:10 PM I served the above-described
documents on JOHN ALIKA KALII, JR, and all other occupants named defendant (s), by then
and there:
Personally delivering ONE (1) true and correct copy(ies) thereof to JOHN ALIKA
KALII, JR, PERSONALLY.
24
The service address is: 9711 Winona Street SW, Lakewood, Pierce County, WA 98498.
25
Dated this 2nd Day O f February, 2015 at Tacoma, Pierce County, WA.
A n d er so n I n v e s t ig a t io n s , L L C
P.O. B ox 7770
Tacoma, W A 98417
Telephone: (253)301-2240
Cost: $70.00
2
3
fichael K. Anderson
Private Investigator, WA Lie. #3317
Process Server
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A nderso n I n v e s t ig a t io n s , LLC
P.O. Box 7770

Tacoma, WA 98417
Telephone: (253) 301-2240
E-FILED
PIERCE COUNTY, W A S H IN G !
February 04 2015 8:58 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10

COUNTY OF PIERCE
11
12
13
No. 14-3-01646-7
Petitioner,
14
and
15
BETH ANN KALII,
Motion/Declaration for Ex Parte

Restraining Order and for Order to
Show Cause
(MTSC)
Respondent.
16
I. Motion
17
18
Based upon the declaration below, the undersigned moves the court for a temporary
order and order to show cause.
19
1.1
Ex Parte Restraining Order
20
21
22
23
24
25
A temporary restraining order should be granted without written or oral notice to

the other party or the other partys lawyer because immediate and irreparable
injury, loss, or damage will result before other party or the other partys lawyer
can be heard in opposition. This order should restrain or enjoin:
JOHN KALII from disturbing the peace of the other party or of any child.
JOHN KALII from going onto the grounds of or entering the work place of
the other party.
Mtn/Decl for Ex Parte Restraining Ord (MTSC) - Page 1 of 4

WPF DR 04.0150 M andatory (07/2013) - CR 65 (b); R C W 26.09.060.
Kalii, John and Kalii, Beh
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Ex Parte Order.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW, Ste 25
253-581-0660
1
The other party should be required to appear and show cause why these
restraints should not be continued in full force and effect pending final
determination of this action.
2
3
1.2
Other Ex Parte Relief
JOHN KALII should be restrained or enjoined from contacting, by telephone, fax,

e-mail, or in person, persons who employ or supervise BETH KALII.
1.3
Surrender of Deadly Weapons
Does not apply.

8
1.4
Other Temporary Relief
Does not apply.
10
11
1.5
Other
Does not apply.
12
13
DATED this 3 ^
day of February 2015. FAUBION, REEDER, FRALEY & COOK, P.S.
14
15
Daniel N. Cook, W S B A ^ 8 6 6
AttOrney for Respondent '
16
17
II. Declaration
18
19
20
2.1
Injury to be Prevented
The ex parte restraining order requested in paragraph 1.1 and 1.2 above is to
prevent the following injury (define the injury):
21
22
23
24
25
JOHN KALIIS actions have threatened my job, for which I am

dependent for support of myself and my child. I am a school bus driver.
On February 2, 2015, JOHN KALII went to my workplace and told my
employer that I was driving school buses while drunk. This was a
completely false statement. My bosses took me into their office and did
a breathalyzer on me. It came up 00.0. I believe JOHN KALII is
harassing me and trying to get me fired in retaliation for my filing a
motion for contempt against him.
M tn /D e c l f o r E x P a rte R e s tra in in g O rd (M T S C ) - P a g e 2 o f 4
WPF DR 04.0150 Mandatory (07/2013) - CR 65 (b); RCW 26.09.060.

5920-100 S tre et SW , Ste 25

Lakewood, W A 98499
253-581-0660
1
2
2.2
This injury may be irreparable because:
Not only would I lose my job if JOHN KALII continues to spread untrue
rumors about me that I would drink on the job, but this could affect my
ability to get other jobs driving or working with children in the future.
5
6
2.3
2.4
See 2.1 and 2.2 above.
12
2.5
14
16
17
18
19
Reasons for a Temporary Order

It is necessary that the court issue a temporary order with the relief requested in
paragraph 1.4 above for the reason set forth below:
11
15
Clear and Convincing Reasons why Weapons Should be Surrendered

Does not apply.
10
13
Reasons why the Injury may be Irreparable
Service Member or Dependent of Service Member

Does not apply.
2.6
Was notice of this request for an emergency order given to the other party or
lawyer?
Yes. Explain what efforts have been made to give written or oral notice
to the other party or other partys lawyer:
JOHN KALII WILL BE SERVED WITH THIS MOTION AT THE PARTIES
SHOW CAUSE HEARING ON FEB. 3 AND NOTIFIED THE EX PARTE
RESTRAINING ORDER WILL BE SOUGHT.
20
21
22
23
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
Signed at (city)
QU O >
(state) (/- ^ i
on (date)
2~ 3
24
25
Beth Kalii
M tn /D e c l fo r E x P a rte R e s tra in in g O rd (M T S C ) - P a g e 3 o f 4
WPF DR 04.0150 Mandatory (07/2013) - CR 65 (b); R C W 26.09.060.

5920-100 S tre et SW , Ste 25

Lakewood, W A 98499
253-581-0660
1
2
3
4
5
6
7

filed with the court using one o f these cover sheets:
1) Sealed Financial Source Documents (W PF DRPSCU 09.0220) for financial
records
2) Sealed Personal Health Care Records (W PF DRPSCU 09.0260) for health
records
3) Sealed Confidential Report (W PF DRPSCU 09.270) for confidential reports
I f filed separately using a cover sheet, the records will be sealed to protect your
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Mtn/Decl for Ex Parte Restraining Ord (MTSC) - Page 4 of 4

WPF DR 04.0150 M andatory (07/2013) - CR 65 (b); R C W 26.09.060.

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
^po
For Petitioner
For Respondent
(V z>& Ths\ vx.
RE:
/y g ^ r m o ^ r -
.....r^ Q
5 lX X ^ vV2_<3------ _________________________________________ O T^ cv~ Q\^p 2 > /rre,JL

^g<Th2^(7
-So-^r
< ^ ie ^
~K?
00^1
? s
n.
February 4, 2015 9:00 AM
__ ^Q-_ - X T ' > , ^
Show Cause
ROBYN LINDSAY
Clerk:
Courtroom number: 117
Calendar:C2 - SHOW CAUSE/FAMILY LAW

Ixcrtrpt.pbl djourna!_entry_showcause_report
^ ^,
^-0^6-7 4*07813'
tprotsc
02-0&-15
IN COUNTY Clerics OFFICE
A M
FEB
2015
p m.
6
7

County of Pierce
8
9
10
11
12
13
No. 14-3-01646-7
Petitioner,
and
BETH ANN KALII,

Respondent.
14
15
16
Ex Parte Restraining Order/ Order

to Show Cause
(TPROTSC/ORTSC)
[ ] Clerks Action Required
[] Law Enforcement Notification, U
4.1,4.3
Restraining Order Summary:

Restraining Order Summary is set forth below:
17
Name of person(s) restrained: JOHN KALII______
18
Name of person(s) protected: BETH KALII_______
19
See paragraph 4.1.
21
Violation o f a Restraining Order in paragraph 4.1 below with actual knowledge

o f its terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest. RCW 26.09.060.
22
I. Show Cause Order
20
23
24
25
It is Ordered the petitioner appear and show cause, if any, why the restraints below
should not be continued in full force and effect pending final determination of this action
and why the other relief, if any, requested in the motion should not be granted. A hearing
has been set far the following date, time and place:
Date:
Time:
Place: PIERCE COUNTY SUPERIOR COURT
Room/Department: TBD
Ex P arte R e s tra in in g O rd (TP R O T S C /O R T S C ) - P age 1 o f 4

W P F D R 0 4 . 0 1 7 0 M a n d a t o r y (6/2014) - C R 6 5 (b); R C W 26.09.060
S:\CASES1\Kalii\DRAFTS\Pleadings\Ex Parte Restraining Order.doc
9:00 a.m.
F A U B IO N , R EEDER, F R ALEY
& C O O K , P.S.
5920-100 S treet SW, Ste 25
LakewoOd, W A 98499
253-581-0660
1
2
3
4
5
If you disagree with any part of the motion, you must respond to the motion in
writing before the hearing and by the deadline for your county. At the hearing, the
court will consider Written sworn affidavits or declarations. Oral testimony may
Not be allowed. To respond you must: (1) file your documents with the court; (2)
provide a copy of those documents to the judge or commissioners staff; (3) serve
the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and
service of documents within the time period required by the local court rules in
effect in your county. If you need more information, you are advised to consult an
attorney or a courthouse facilitator.
Failure to appear may result in a Temporary Order being entered by the court that
grants the relief requested in the motion without further notice.
9
10
II. Basis
A motion for a temporary restraining order without written or oral notice to the petitioner
or that party's lawyer has been made to this court.
11
12
13
III. Findings
The court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte
Restraining Order and for an Order to Show Cause (Form W P F DR 04.0150) as its
findings, except as follows:
14
15
16
IV. Order
It is Ordered:
4.1
Restraining Order
Violation of a Restraining Order in paragraph 4.1 with actual notice of its
terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest. RCW 26.09.060.
17
18
JOHN KALII is restrained and enjoined from:
19
20
Disturbing the peace of the other party or of any child.
21
Going onto the grounds of or entering the work place of the other party.
22
23
24
25
[]
Clerks Action. The clerk of the court shall forward a copy of this order, on or
before the next judicial day, to (name of the appropriate law enforcement
agency) SO U TH S O U N D 911 which shall enter this order into any computerbased criminal intelligence system available in this state used by law
enforcement agencies to list outstanding warrants. (A law enforcement
information sheet must be completed by the party or the partys attorney

and provided with this order before this order will be entered into the law
_____ enforcement computer system.)___________________________________
Ex P a rte R e s tra in in g O rd (TP R O T S C /O R T S C ) - P age 2 o f 4
S:\G4 SES1 \Kalii\DRAFTS\Pleadings\Ex Parte Restraining Order, doc
F A U B IO N , REEDER, FR A LE Y
& C O O K , P.S.
5 920-10 0 th Street SW, Ste
Lakewood, W A 98499
253-581-0660
25
1
2
Service
The requesting party must arrange for service of this order on the restrained
party. File the original Return of Service with the clerk and provide a copy to
the law enforcement agency listed above.
3
4
5
Full Faith and Credit

Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of
Columbia, Puerto Rico, any United States territory, and any tribal land within
the United States shall accord full faith and credit to the order.
6
7
4.2
Other Restraining Orders

Other:
10
JOHN KALII shall not contact, by telephone, fax, e-mail, or in person,

persons who employ or supervise BETH KALII.
11
12
4.3
Surrender of Firearm or other Dangerous Weapons

Does not apply.
13
14
4.4
Expiration Date
This order shall expire on the hearing date set forth above or 14 days from the
date of issuance, which ever is sooner, unless otherwise extended by the court.
15
16
4.5
Waiver of Bond
17
18
4.6
Does not apply.
IN COUNTY
Other
a m
Does not apply.

KEVIN S T O C K , C ounty C lerk
BY
DtPUTi
19
20
Dated:
at
vt
23
. F E B 0 4 2015
pm
^rr^p.m.
21
22
CLERKS OFFICE
Judge/C
Presented by:
FAUBIOti-EEEDER, FRALEY & COOK, P.S.
Copy received:
A signature below is actual notice of
this
24
25

Petitioner
Pro se
Ex P arte R e s tra in in g O rd (TP R O T S C /O R T S C ) - Page 3 o f 4

S:\CASES1\Kaiii\DRAFTS\Pleadings\Ex Parte Restraining Order.doc
'
F A U B IO N , REEDER, F R A L E Y
& C O O K , P.S.
5 920-1 0 0 th S tre e t S W , S te 25
Lakewood, W A 98499
253-581-0660
44076140
02-05-15
orcnt
! 4-3-01646-7
I N T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N F O R P IE R C E C O U N T Y
no.
D o tt/O
k^R U l
j , fZ.
O R D E R RE: C O N T IN U A N C E T O
A P P L Y F O R C O U R T A P P O IN T E D
P e tition e r/P laintiff

and
ATTO RNEY
R espondent/D efendant
ORCNT
T H IS M A T T E R having com e on regularly fo r hearing, and the C ourt having found th a t the
P etitioner/R espondent is a t substantial risk o f incarceration, it is now th erefore,
ORDERED,
th a t
ADJ
this
m a tte r
hereby
continued
to :
___________ , a t 0 9 : 0 0 AM
1:30 PM in
such Room as posted, Pierce C ounty C dlirthouse, C ounty-C ity Building, 930 Tacom a Avenue South,
Tacom a, WA
98402.
This m a tte r is continued to allow the P etitioner/R espondent to obtain
representation th ro u g h th e D epartm ent o f Assigned Counsel, b u t only in th e event the
Petitioner/R espondent financially qualifies fo r said representation. To a pp ly fo r legal representation
you m ust co nta ct the fo llo w in g o ffice w i t h i n 3 d a y s o r Y O U W IL L BE D E E M E D T O H A V E W A IV E D
Y O U R R IG H T T O C O U N S E L :
P r e t r ia l S e rv ic e s :
N O T IC E :
930 Tacom a Ave. S., Room 110, Tacom a, WA, 98402

10:00 a.m . to 2:00 p.m . only
253-798-3781
T H E P E T IT IO N E R 'S /R E S P O N D E N T 'S P R E S E N C E A T T H E S A M E T IM E A N D PLA C E
S E T F O R T H A B O V E I S M A N D A T O R Y A N D S H O U L D T H E P E T IT IO N E R /R E S P O N D E N T F A IL T O
A P P E A R , T H E C O U R T W I L L IS S U E A B E N C H W A R R A N T F O R H I S / H E R A P P R E H E N S IO N A N D
I C A N BE H E A R D .
C O N F IN E M E N T I N J A IL U N T IL S U C H T IM E A S T H E M A T T E R
DONE IN OPEN COURT this
_day o f
, 20.
c o u r t c o m m is s io n e r
ROBYN A LINDSAY
COURT COMMISSIONER
Respondent
C<%>
ORDER RE: CONTINUANCE TO APPLY FOR COURT APPOINTED ATTORNEY - Page 1 o f 1 (updated 0 1 /07 /1 5 )
E-FILED

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7

No. 14-3-01646-7
Petitioner(s),
vs.
BETH A N N KALII
R espondent(s)

Phone:
Petitioner
Show Cause
Nature of Hearing:
C hild Support, C on te m p t
C A LE N D A R DATE: Tuesday, March 24, 2015
9:00 AM

DATED:
F ebruary 5, 2015.
Signed:
NAME:
D aniel N C ook
Phone:
(253) 581-0660
WSBA#:
For:
34866
ADDRESS:
5920 100th S t S W Ste 25

LA K E W O O D , W A 98499-2751
A tto rn e y fo r R esp o nd e n t
1 of 1
E-FILED
PIERCE COUNTY, W A S H IN G T
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8

County of PIERCE
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Return of Service
(Optional Use)
(RTS)
Respondent.
14
15
16
17
I Declare:
1.
lam over the age of 18 years, and I am not a party to this action.
2.
I served the following documents to (name) JOHN KALII:

a. Motion for Ex Parte Restraining Order
b. Ex Parte Restraining Order entered on Feb. 4, 2015
c. Order Of Continuance For Application To Pre-Trial Services;
18
19
20
3.
21
Date: February 4. 2015_______ Time:____________________ a.m./p.m.
22
Address:
23
24
The date, time and place of service were (if by mail refer to Paragraph 4 below);
4.
930 Tacoma Avenue South Room____________

Tacoma, WA 98402
____________________________________
Service was made:

By delivery to the person named in paragraph 2 above.
25
R e tu rn o f S e rv ic e (R T S ) - P a ge 1 o f 2
W P F D R P S C U 0 1 . 0 2 5 0 (07/2013) - C R 4(g), R C W 4.28.080(15)
S :\C A S E S l\K a lii\D R A F T S \P le a d in g s \R e tu r n o f S e r v ic e .d o c
F A U B IO N , REEDER,
Phone: (253) 581-0660
1
5.
Service of Notice on Dependent of a Person in Military Service.
2
Does not apply.
3
6.
Other:
4
5
Does not apply.
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
Signed at (city) Lakewood, (state) WA, on (date) February 4, 2015.
10
Daniel NTcook, WSBAT#34866
11
12
13
14
File the original Return of Service with the clerk. Provide a copy to the law enforcement
agency where protected person resides if the documents served include a restraining
order signed by the court.
15
16
17
18
19
20
21
22
23
24
25
Return of Service (RTS) - Page 2 of 2

WPF DRPSCU 01.0250 (07/2013) - CR 4(g), RCW 4.28.080(15)
S : \C A S E S 1 \K a lii\ D R A F T S \ P le a d in g s \R e tu r n
o f S e r v ic e , d o c

Phone: (253) 581-0660
E-FILED
IN CO UNTY CLERK'S OFF
PIERCE COUNTY, WASHIN
February 10 2015 10:54
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-'
3
4
5
6
7
8

No. 14-3-01646-7
10
11
12
13
Petitioner,
and
BETH ANN KALII,

Respondent.
14
15
16
17
18
19
20
21
22
I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
On February 9, 2015, I placed in the U.S. Mail a copy of the following
1. Note for Commissioners Calendar on March 24, 2015
2. Order Re: Continuance to Apply for Court-Appointed Attorney.
John Kalii
9711 Winona STSW
Lakewood WA 98498I
23
I declare, under the penalty of perjury and the Laws of the State of Washington, that
the foregoing is true and correct.
24
DATED
February 9, 2015
^
25
S:\CASES1\Kalii\DRAFTS\Pieadings\Dedaration of Mailing.doc
Sal^miCharme, Legal Assistant

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
Phone: (253) 581-0660
E-FILED
February 11 2015 3:46 PM

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E STA TE O F W A S H IN G T O N
IN A N D F O R T H E C O U N T Y O F PIE R C E
IN RE
)
)
JOHN KALII, JR,
)
)
PETITIONER
CAUSE NO. 14 - 3 - 0 1646-7
)
vs
)
L IM IT E D N O T IC E O F
)
A
PPEARANCE
)
BETH ANN KALII,
C O N T E M PT H E A R IN G S
)
RESPONDENT
)
)
TO:
P IE R C E C O U N T Y S U P E R IO R C O U R T C L E R K
YOU AND EACH OF YOU will please take notice that ROSE EBERHART
herewith enters a lim ited notice of appearance for and on behalf of the Petitioner, JOHN
KALII, JR nam ed above, in connection w ith the contem pt show cause hearing and any
subsequent review hearings only. Please direct any further notices concerning the
above-referenced contem pt hearing, except for original process, to the attorney at the
address given below. All other notices related to this action should be directed to the
Petitioner at his address of record.
ROSE EBERHART, # 38 737
40 09 BRIDGEPORT WAY W, STE. E -1
UNIVERSITY PLACE, WA 98466
( 2 53 ) 686-980 2
DATED this 11 th day of FEBRUARY, 2 0 15 .
Respectfully submitted:
_______________ / / s / / ___________
JANENE GORE, WSBA #18918
Department of A ssigned Counsel
SPECIAL NOTICE OF APPEARANCE

O N CONTEMPT - 1
E-FILED
March 03 2015 10:08 AM

KEVIN STOCK
COUNTY CLERK

JOHN ALIKA KALII JR VS. BETH ANN KALII
The case(s) listed above were previously assignedto Department 20 Judge K. A. VAN DOORNINCK. Judge
GRETCHEN LEANDERSON has assumedthis case. Unless otherwise notified, your trial date and case schedule, if set,
remain unchanged.
If the case is resolved, call Department 15 at (253) 798-3966 or e-mail to: supcrtdept15@co.pierce.wa.us
If you are an attorney and have withdrawn fromthis case, contact the Clerk's office.
Dated March 3, 2015

Mailed to:
Rose Marie Eberhart
Daniel N Cook
Frank E. Cuthbertson
Presiding Judge
rast-0007.pdf
E-FILED
IN CO UNTY CLERK'S C
PIERCE COUNTY, WASH
March 03 2015 1:32

KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
2
3
4
5
6
7
8
9
10
11
12
13
14
Superior Court of W ashington

County of Pierce
In re:
John Alika Kalii, Jr
No. 14-3-01646-7
Amended Response to
Motion/Declaration for an
Order to Show Cause re
Contempt
Petitioner,
and
Beth Ann Kalii,
Respondent.
15
16
To the Above-Named Respondent:
17
I. Response
18
19
20
21
22
1.1 Admissions and Denials

The allegations of the petition in this matter are Admitted or Denied as follows (check only
one for each paragraph):
Paragraph of the Motions
23
1.1
[]
Admitted
[x]
Denied
[]
Lacks Information
24
1.2
Admitted
[X]
Denied
[]
Lacks Information
1.3
[]
Admitted
[X]
Denied
[]
Lacks Information
25
26
ROSE M. EBERHART
Response to Mot/Dec Ord Show Cause re Contempt - Page 1
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09.160
ATTORNEYATLAW
4009Bridgeportwayw.steE-l
UniversityPlace,WA. 98466
(253)686-9802
Each allegation of the petition that is denied is denied for the following reasons (List separately):
1
2
1.1
Is denied because there is no contempt.
1.2
Is denied because there are no reasons.
1.3
Is denied because sanctions are not necessary.
II. Responsive Declaration
4
5
6
7
In response to the Motion/Declaration for an Order to Show Cause re Contempt filed.

January 15, 2015:
I believe that this contempt about child support is smoke screen by Mrs. Kalii. It is my belief
8
that this recent effort by Mrs. Kalii to accuse me of contempt is in retaliation of me confronting her with
9
10
11
my concerns and issues about her drinking and driving her vehicle with our daughter, Ka'ena Kalii, on
board. This issue is what initiated our breakup in 2006 when Mrs. Kalii, while in her third trimester,
12
continued to drink and smoke throughout the entire pregnancy despite my objections. Other matters
13
concerning Ka'ena's hygiene, sleeping habits, and schoolwork while in her mother's care are also in
14
question when she is dropped off at my home during the school week.
15
Since March of 2014, Mrs. Kalii and I have primarily communicated through text message. If I
16
17
18
bullied her, she would be able to prove it. If you read through all the texts I have supplied, you will see
that Mrs. Kalii is constantly calling me names and being borderline verbally abusive to me.
19
Unfortunately our daughter broke the phone I had been using during that time. Mrs. Kalii is aware of
20
that fact. See Supplied text messages page 2.
21
I believe I am not delinquent, but current on my child support payments from October 2014
22
23
24
25
through February 2015. Proof of this current support status is documented by the attached Acceptance
Agreement involving a trailer that I had purchased during our marriage. See Exhibit A. This transfer was
signed and notarized by both of us on October 9, 2014. Mrs. Kalii and I were in total agreement, with the
26
ROSE M. EBERHART
ATTORNEYATLAW
4009Bridgeportwayw.STEE-l
(253)686-9802
understanding that everything was legal and binding. She even brought the notary because she wanted it
1
binding.
2
3
4
In her declaration Mrs. Kalii states that in October or November that I told her that I would not
pay the court ordered child support. This is not true, as I have never stated that I would not pay child
support. I did contact Mrs. Kalii in the first week of October 2014 through phone text that I was
financially struggling to make ends meet. This is when the transfer of our community travel trailer was
brought up, by her. 1referenced this in a text I sent her on January 9, 2015, and she did not dispute that it
was her idea, just that He said tack me to court..
was that Mrs. Kalii would take possession of the trailer to be sold by her, as satisfaction of child support
10
11
See Supplied text messages pg 5. The agreement
payments through Februaiy, 2015. She gave me the ultimatum that it was to be just through February or
not at all. I agreed. Additionally, it was also a demand of Beth that an agreement letter be drawn up,
12
signed and notarized, along with the signing over of the transfer of title. She had the notary there at the
13
14
15
exchange. I signed both the agreement and the title. See Exhibits A and B. As for her claim that the
trailer was her separate party, please note that it was solely in my name. Also please note that she is well
16
aware that the trailer is community property and reference it as such. See Supplied Text messages pg 16.
17
Following the signing, Beth was very happy, voicing her satisfaction and informing me that she had
18
buyers for the trailer. She also expressed her gratitude to me for delivering it to her home. 1would guess
19
that she was expecting to receive more than the child support amount. A copy of the NADA guideline is
20
21
provided and outlines the current value of the travel trailer. See exhibit C. It is in very good condition,
inside and out. Only after her buyer back out and waiting for four (4) months in matters concerning the
22
payment of child support, it is now Mrs. Kalii's contention that I am in contempt for non-payment.
23
24
25
26
Please read the supplied text messages, they show Mrs. Kaliis intentions and her bad faith.
I do not receive $5,000 per month in income as Mrs. Kalii claims. Current and prior financial
disclosures show that for the last two (2) years, my service retirement income to be $4,028.91. See
ROSE M. EBERHART
ATTORNEYATLAW
(253)686-9802
Exhibit D. Mrs. Kalii and her attorney, Mr. Cook is well aware of this as they have both seen and signed
1
orders that state that show my income.
2
3
4
Mrs. Kalii also claims to receive a net income of $1,900 a month. According to her last signed
financial disclosures, her reported net income is $2,217.69. rent ($950), gas ($200) and utilities ($400)
are also subject to question and I would ask the court to have her provide three (3) months proof of
financial statements to show these reported figures as I have provided.
In matters concerning Mrs. Kalii's claim that I need to pay for my share of daycare: There is none
8
and has never been any daycare involving our daughter. I have, from day one (1) to present, personally
9
10
II
provided parental "daycare" for our daughter, Ka'ena. This is and has been inclusive to every week that
Ka'ena spends during her mother's week of care. Previously Mrs. Kalii had agreed to pay me $75 a month
12
to take care of our child during her residential time, since I am paying her child support. See Supplied
13
Text messages pg 4. I did say that she would need to pay someone else that money if she was not going
14
to follow through with our agreement. Id at 6. Her response is to threaten to go to HR about me and call
15
me evil. Id. She even states at one point that You made me mad 1 am honoring that agreement. Id. pg
16
17
10. I was unsure as to which agreement she was referencing, but its clear that she acts out at me in anger
against our childs best interest.
18
19
Historically, I have always been the primary caregiver while our family was together and even
20
more so now, during this ongoing divorce. I have always provided pre-school and after-school care for
21
Ka'ena, even during my career as a firefighter for the Tacoma Fire Dept. (1980-2013) because of my
22
flexible work schedule.
23
24
1oday Ka'ena continues to spend the majority of her time with me, which includes care twice
25
a day, (every school day) amounting to thirty (30) hours a month that she is supposed to be in her
26
mother's care.
ROSE M. EBERHART
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09 160
ATTORNEYATLAW
4009BRIDGEPORTWAYWSTEE-1
(253)686-9802
Lastly, as a final note, therewas no issue about child support payments for four (4) monthsuntil
Mrs. Kalii was confrontedabout recent concerns by me, about her drinking and driving habits involving
our daughter Ka'ena and other childrenin her vehicle.
I declare under penalty of perjury under the laws of the stateof Washington that the foregoing is
true and. correct
Date
John Kalii
III. Request for Relief

pCJDenythe Motion for contempt
[X] Grant reasonable attorneys fees and costs under RCW 26.09.160 (?)
RoseEberiiart/WSBA 38737
Response toMot/Dec OrdShowCause re Contempt - Page 5

ROSE M. EBERHART
ATTORNEYATLAW
4009Bridgeportwayw.STE-1
(253)686-9802
Exhibit A
ACCEPTANCE AGREEMENT
'
I, Beth Ann Kalii, acknowledge on this day October 9, 2014, that

Child Support payments to me, by John Alika Kalii, are current and paid
in full through February, 2015 by acceptance of ownership and Title of
his 1996 Wilderness 26/SC travel trailer. Title #1324616010
I, John Alika Kalii relinquish ail legal rights and ownership of
aforementioned travel trailer to Beth Ann Kalii as payment in full of
Child Support obligations through February, 2015, with the
understanding that any monies made by sale of trailer are to cover
t
Child Support payments and that any remaining funds to be kept solely
by Beth Ann Kalii.

Signed at Lakwood, Washington on October 9, 2014
U
My Commission E ipira:____
el
|o / /
& * * * * *
Exhibit B
Assignment by-registered owner;
s.yT1: s-,
'W
(D
v-.-'(T
,33
J 'W
O' 9.
2 S: ,5
: e <-' 3
S' ' Z V, ;-3
tU 0) >3*; -TO.:
IS
^S,;/ ;;<
3r
Q.^
r-rQ
o.::s
c 2
: O
m 5
.
2
.
S
<D
sn
.g
.
s
S
5
;
a
:5
;
;Q
i
/W
O
3^.
^3 Q.
o> i rC/'O & .'oO
.a
.
3 .f. <Q':i ; -S ;
; o>2: .3
111
CD-i tffij'E
tJ3
--S'jS'
: I
.
C
r
<CJ
r3:-o,
' 5
;
c
u
v
0
Icr
::W:
.O
n S
&
,9>O-: *!.
[.;<to
" Si
. TI O
I
er.
O CDf;. S
- **'.:t
35
/=
>S5
' c
=
P i
<D
2.g.
O' >
S
t/t
#
;?g
.A O ) C&
V<:"
a
^
0>:
X. 4 ;0 , :y<S\ O
!.0>;0J
f<t>. -
9
Ljs,'
3; i a ; ,
ro
c
a.
8
tP:;cS< II g:
fl
'C
0>,::,: 'S'
CD ;' 5t<
y:
c
/
>
3
; co'.'g ! o
*:<q
w
to
;
s.
!
s.a;
a^
an ct> -c
p.
= \ $ *: 2.3 9- cE;;
"yiW * f g:' . ' 2;
' .(S .iS'i:
l.-k.-X
;S
o-;Vr :5i; / oj
; ..
;.a>: > o
3>.
Q
, w;
-3
r;vj*,
^*.:7<-Q
n
r.iijig =a
ir.i-io
3m
..^5 ;r g
.'O
. ;'5 tX e
;) ;| . 8
' tl
C
P Vo
Jjj. # #!>' . 2>W <P 3

^ V t og S-. u- 3 B:;S :
a '. 4a. ;- ' P ^ S'
fm
e .l5.1
t
lui
, ;:
^-
'
fe - V ':
Keep In a safe place. Any alteration or erasure voids this title.
1y f
1 -3
^2 <o'S
r . ~
.X :X -' '*#/
' r .?/
"Vj
S i
:'
. '
O; :*
Exhibit C
1996 Wilderness M-24L Standard Equipment, Prices & Specs - NADAgtides
1/24/2015
AUTOS
CLASSICCARS
RVS MANUFACTUREDHOMES
MOTORCYCLES
ChangeManufacturer>ChangeYear&Model >ChangeOptions>Values
PRODUCT STORE
MCralraslP
1 9 9 6 W ilderness
M-24L
Research a n o th e r tr a ve l tra fe r/S th w h eel
j V alues
i
j Values
Specifications
Floor Plan
Special Notes
I
!
Values
Base P rice
Suggested
List Price
Low
Retail
Average
Retail
$ 1 5 ,1 2 8
$ 3 ,9 0 0
$ 4 ,6 8 0
$85
$100
O ptions: (channel
110 Vot - 15,000 BTU (Roof Mount)
$60
$70
10 cu. ft.
Flushrrg T oJet/Hotiing Tank
$420
$505
$85
$100
Gas/Efec. 7 cu. f t
$200
$240
Microwave Oven
Waste Water HofcTng Tank
$30
$85
$100
Water Heater 6 Galon Gas/Etec w/DSI
$70
$85
AM/FM Cassette Stereo
$30
$35
Furnace (21,000-28,000 BTU)
Stabizer Jacks-Crank Down (Each)
$35
$45
$55
Awnhg 25' (Each)
$235
$285
Exterior Part
$555
$670
$25
$30
$ 5 ,8 2 5
$ 6 ,9 9 0
TraferHtch
TOTAL PRICE:
RVs for Sale

Find 1996 Wilderness M-24L listings near
you In Lakewood, WA
$ 1 5 ,1 2 8
RV Insurance
See how much money you can save with a
FREE quote on a 1996 Wilderness
PoweredbyKV Trader
erene rrrr wW r r f ~
RV Resources___________
Need RV fiiancrig? Get approved now
Sel your RV at RVTtader
Buy an RV price guide
RV history report - Get the facts
Enter VINor ClickGO

Next: Specifications
Value Type Definitions
httpy/www.radag uides.corrVRVs/1996AMIderness/M- 24L/4G73974A/a!ues
1/2
Exhibit D
STATE OF WASHINGTON
DEPARTMENT OF RETIREMENT SYSTEMS

P.O. Box 48380 Olympia, WA 98504-8380 (360) 664-7000 Toll Free 1-800-547-6657 www.drs.wa.gov
January 9, 2015
JOHN A. KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
RE: Pension Verification
SSN: XXX-XX-5489

John A. Kalii receives a gross monthly retirement benefit amount o f $4,405.47 from the
Washington State Law Enforcement Officers' and Firefighters' Retirement System. This is a
lifetime benefit.
If you need further assistance, please contact us at 1-800-547-6657.
Sincerely,
David Nelsen
Assistant Director
Customer & Policy Services
PLEASE REFER TO SS#, RETIREMENT SYSTEM AND PLAN ON ALL CORRESPONDENCE
1/220015
Benefit Sunnmary
W A S H IN G T O N S TA TE D E P A R T M E N T O F R E T IR E M E N T S Y S T E M S
M aking it easy to see yo u r future
360-664-7000 |800-547-6657
B enefit Sum m ary
Help
This screen presents information as reported by you or your employer as of Thursday, January 22,2015. If
information displayed is incorrect, please see the instructions on how to m a k e changes.
Membership Details
Name:
Systeni/Plan:
Status:
John A Kalii
Law Enforcement Officers' and Firefighters' Retirement System Plan 2
Retired
Retirement Details
Download Pension Verification Letter
Date: 01/01/2013
.
Type: Service
Option: Single Life
: ..
Service Credit: 396.00 months or 33.00 years

We use the most recent information youve given us to make payments. Any changes that you send us after the
15th, maynottake effect until the following month.
..
Monthly Payment
11/28/2014
12/31/2014
Gross Benefit
_
_____
$4,405.47 ___
$4,405.47
IRS Withholding ( R a t e B e l o w ) : w w : U . i L - W ' a u n i> iM .............................................i
-331.43
imr
>s 1
1. n i. r i- n ! . -331.43
- iv
m
m
im
n
____________________Net Benefit Amount:_________________ $4,074.04__________________$4,074.04
IRS Withholding Rate: Married - 3 Allowances established 01/2013
Payment Delivery Method: Electronic Funds Transfer (EFT) to Harborstone Cu effective 12/2012.
Paper Benefit Statement Delivery: If Change Is Made Aid End Of Year_________________________________
mi
B eneficiary
https^/fartress.'Aa(|oVdrs/drsorlinesso/Merrtr/BenEfitSumnaryl1
1/1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
S uperior Court of W ashington

County of Pierce
16
17
18
19
20
In re
John Kalii Jr.
Petitioner
V.
No. 14-3-01646-7
Declaration re: Electronic
Signature Page
Beth Ann Kalii

Respondent
21
22
COMES NOW the declarant, and hereby states as follows:
23
1. My name is Rose Eberhart. I am the attorney for the above named Petitioner. I
24
25
make this affidavit concerning the electronic signature of John Kalii, my client, on a document
26
entitled Amended Response to Motion/Declaration for an Order to Show Cause re Contempt.

ROSE M. EBERHART
Declaration re: Electronic Signature Page - Page 1
m9 bA
J twlvwT tee-i
(253)686-9802
2 . I have examined the document, which consists of 4 regular pages, followed by
1
2
ly 1 electronic signature page, followed by 9 exhibit pages, followed by this two-page

Declaration Re: Electronic Signature Page. The electronic signature page was received on [] my
fax machine at (253 ) 507 5766 [x] via my e-mail at roseeberhart@hotmail.com. The entire
4
5
6
7
document totals 16 pages in length, is complete and legible.

I declare, under the penalty of perjury according to the laws of the State of
Washington, that the foregoing is true and correct.
8
9
Signed at University Place, Washington, on this 3rd day of March, 2015 .

10
11
^ z-
12
'
Rose Eberhart, WSBA 38737
13
14
15
16
17
18
19
20
21
22
23
24
25
26
ROSE M. EBERHART
Declaration re: Electronic Signature Page - Page 2
ATTORNEYATLAW
(253)686-9802
E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, WASH
March 03 2015 2:15
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
2
3
4
5
6
7
S uperior Court of W ashington

County of Pierce
In re:
Petitioner
10
And
Beth Ann Kalii
No. 14-3-01646-7
Cover Sheet: Supplied Text
Messages
Respondent.
11
12
13
14
Text message between parties from January 7, 2015 and February

13, 2015.
'
Messages from John Alika Kalii, Jr. are aligned to the right and
are darkly shaded.
15
16
Messages from Beth Ann Kalii are aligned to the left and are
lightly shaded.
17
Respectfully submitted by,

18
19
20
DATED:
21
22
Rose Eberhart, WSBA 38737

23
24
25
26
Cover Sheet:
ROSE M. EBERHART
ATTORNEYATLAW
(253)686-9802
**o o o Sprint
2:58 PM
tes
aaa
B e th
Wed, d:.n7, 13:28 AM

She did but she said she
was still hunger so I m ade
her more food,...
Didnt think it w as bad is
she ok?
Wed, Jan 7, 11:42 AM
IS SHE O K ....D ID She stay
hom e?....does She have
the flew?
-f A 56% B D
Details
o o o Sprint *?
^ Messages
3:29 PM
aaa
B e th
She had a bowl of cereal

and a bagel. ...She must
be g ro w in g ....
Thu, Jan 8 ,7:02 PM
Thank you for give m e the
food that I asked for for Mr
Reeves I'm hungry you
know I'm starving lost 50
pounds K ea'na com es
first......Always, .must be ni
ce to have a new Iphone......don't ever tell
our child not to tell me
anything, ....bad
choice.......and I thought I
loved you..........ouch
O i: 59%
*o o o Sprint
Messages
3:30 PM
aaa
B e th
You have m ade our child

crazy....don't tell m am a
this..w e are
j
59% m u
Details
o o o Sprint =?
Messages
3:30 PM
aaa
B e th
o i 5 9 % B ill-
Details
fighting, ..don't tell

m am m a that. .Thank God
she loves me knows it's
wrong and tells me
everything....... I am
warning you stop.....she
needs help..jeez Bo...Nick
it off I don't care...! know
eve r about you tw o ......ITS
A B O U T HER. . . 9
If she tell s need you
yelling at her I am calling
sps
She told me she would get
punished if she told
m e....no more B o......
Oh and by the play my
house is spotless thank
you very much you tell my
friends that you going to
oo o Sprint
Messages
3:30 PM
aaa
B e th
% 59% H D
Details
call C P S and my house is

dirty there you go go
ahead an
d try our daughter needs
psychiatry you are making
her crazy
You make me crazy too all
I w ant is our child to be
happy rem em ber that
Do you even understand
how much I adored and
love you your children
suck every ounce of
happiness out of my
soul ....I lost 50 pounds
lighter I look beau
tiful I feel beautiful and I'm
in love so leave us alone
let's just raise this baby
Send
o o o Sprint *?
< Messages
3:30 PM
aaa Beth
.......................... 4 ................................................................... W .........................
and copacetic
h a p p in es s.....i want a
divorce, ..A.S.A.P.,...
59% B O
Details
o o o Sprint *?
M essages
3:36 PM
aaa
B e th
V t 58% M O
D e ta ils
Thu, Jan 8,11:13PM

Talk to my layer you are an
creep...
You still ow e m y back child
support...... that paper
means nothing.....you will
pay....tack m e to
c o u rt.....ass
Going to m y lawer. ...he
seen your Ass a
lopenesses does not not
.....................................
Ill
0!*Jk.. <r*.M.........L-jaMeUBfc.................................................. -.........
Send
o o o Sprint
< M essages
3:36 PM
aaa
B e th
like you at all....I am

done..with you
F rt, J a n 9 , 8 :5 1 A M
He said ta ck me to
court.....I have proof.. Civil
court just because you
erased it... I have all the
O i 58% B D
Details
o o o Sprint "=?
^ Messages
3:36 PM
aaa
B e th
V $ 58% I
Details
proof
M y lawer loves m e
I will not be nice ever
again. ...you are evil. .,m
You tell our child not to tell
me stuff the first thing she
does is tell me... Big
mistake
Send
o o o Sprint
^ Messages
3:37 PM
aaa Beth
O |
58% 1
Details
You can go ahead and let

sherlyn know that I'm
going to human resources
and taking action against
her
Send
o o o Sprint <?
< M essages
3:37 PM
aaa
B e th
I 58% M D
D e ta ils
o o Sprint
Messages
3:3? PM
aaa Beth
58% T V
Details
I just got off the phone

with Delfi sherlyn is done
I'm filing a claim at HR you
have turned into a spiteful
evil human being and
you're nothing but mise
ry I'm calling Kid Zone and
setting her up why do you
have to be so evil
By the w ay it's none of
your business like a tree
picture up none of your
business
It's none of your business I
had things I had to do it
Send
o o Sprint =?
^ Messages
3:38 PM
aaa Beth
was gracious enough to

go and pick it up because
I had things I had to do
W hatever bo please just

leave me alone I'm so tired
of how you act now its so
disgusting I can tell you're
with her again is this is
how you act may God
forgive
O # 58% B O
Details
00 Sprint
<( M e s s a g e s
3:38 PM
aaa
B e th
$ 58% B D
D e ta ils
She is at kidzone you ow e

half.,.the registration feel
of 6 5
and 7 5 ....calling
M y law er today. ..stop
texting m e unless it
pertains to Kae'na
tH
;i
Send
o o Sprint =?
< M essages
3:38 PM
aaa
S e th
$ 58%m.>
Details
Send
go Sprint
K,
Messages
3:38 PM
Details
aaa Beth
F ri, J a n 9 , 12
57% M D
'1
Do you w ant HER?,,..I am

not paying you but you
don't have to pay
either ????.... I am so
done with .... God help m e
I love you so much not
anym ore
Yesterday yes today he'll

s no....... I am ducking.
You.....happy w ife happy
life...as [Tamil said in so
m any of her
letters...... W ichita I got
o o Sprint ?
^ Messages
3:38 PM
aaa
B e th
'<#
57% I D
Details
spous
al support thank her ugly
ass for me would you
thanks so no to going to
cleaners I hate you now go
ahead and show my child
grade I will show that to
the
park in the guardian ad
litem
Spell check new phone
i
M y whole life until now oh
Taking to my lawer
j
Send
O O Sprint
< M essages
3:38 PM
aaa
B e th
, 57%m.,,
Details
first..,.I didn't think you

would be s ok evil......hate
hate hater....God knows
how much I loved
you...and yes I am
50ib...light
er.......... ....S O WHAT?
Sat, .jar;10, 1:4? PM

Are you going to continue
w atch your daughter or
pay kidzone I need to
know so I can fill out the
registration next w eek
Sat, Jan 10, 3:17 PM
Send
o o Sprint
^ Messages
3:39 PM
aaa
B e th
57% * D
Details
You made m e mad Ia m

honoring that agreement
Is she going to kid zone or
not? Just a simple yes or
no olease
Send
**oo Sprint !?
<[ Messages
3:39 PM
aaa
B e th
What are you talking

about?am Iputting her at
kidzone zone or not
O it 57%HD
Details
*ooo Sprint ^
^ Messages
3:43 PM
aaa
B e th
Ok so she is going to kid

zone then....GO H A W K S
O | 56% H D
Details
(\
3:44 PM
* ogo Sprint
Message:
aaa
B e th
W if
56% f D
Details
N o itchanged when ihad

no child rapport trying to
sell the trailer,,..havent
had lucky...You are
already putting m e
through personal hard
ship
.1 have no money left until I
get child support or sell
the trailer...
imMzam
iMwmm
* 6 0 Sprint =?
^ Messages
3:49 PM
aaa
B e th
R M w I N n U M . . .
55% B O '
Details
* * * o o Sprint
<
3:50 PM
aaa
B e th
Idont pay for that you

sure seems to know a lot
about m y business.. I
don't drink beer
anymore. ,.i have barely
enough to survive...must
O i| 55% H D
* * 6 0 Sprint
3:50 PM
<( Messages
aaa Beth
a t 55%
Details
be nice t
o buy a new Iphone
5..Taking about
contributing Your piece of
work T a m m y does
nothing..,.,.
Ok that's why you told our

child not to tell me,.,we
agree that Idon't care for
m e and !don't care for
you.....
i i
'
sn;
o o Sprint
{ Messages
3:50 PM
aaa Beth
Red flags go up when you

tell your child not to tell
their parents something
wrong and it's bad you
shouldn't be doing that to
her
Iwould like to talk our
child please have her call
m e please,,.My lawer said
Iget two a week..,
O $ 55% W D
Details
o o Sprint =?
^ Messages
3:50 PM
aaa Beth
a 7 55% b
Details
Please let m e speak to

O U R CHILD..ID O N O T
DRINK A N D DRIVE Y O U
A N D Y O U R S O N DO...
Sat, Jan 10, 7:31 PM
You are so
miserable ,lol...enjoy
vour life..Ia m
Send
f=
**o o Sprint
{ Messages
3:53 PM
aaa Beth
fulfilled, ......God bless
ee days shes going to

jump on the bus with
Trinity Ihave to go back to
work she have anymore
questions you'll have to
text m e later thank you
Idont have any money
until Iget paid she doesn't
want to go to daycare so if
you still want to watch her
you'll have to wait till Iget
paid these thr
55% H D
Details
*oo Sprint
O 1 55% I
3:53 PM
' Messages
aaa Beth
Ok....I will drop her off

same time..are you sure I
have no money until
payday ?
Ok ...thats not what I

understood..! a m happy
she will be with you so will
she...thanks
V ';
M -D
^..............
**000 Sprint
3:53 PM
55%
:>
You can't give community

property that is half mine
in Lou of child sapport I
a m going to listen to m y
iawer from now on its what
the judge says ...I d
on't want to discuss this
with you..OK PLEASE talk
to Dan Cook....
Send
*o o o Sprint "5
^ Messages
3:54 PM
aaa
B e th
53% B D
Details
You did you said you

would not paying m e child
sapport or any medical. ...I
had to have
something. ..we will see
what the judge says. ...so
be it..
Send
0 0 0 Sprint
Messages
3:54 PM
aaa
B e th
% 53% ..>
Details
Ididn't lie Itold Dan that

you gave m e no choice
PLEASE leave m e
alone...Thanks
You can't give community
property child sapport is
court ordered...
Ihave to take care of m y

family....I have to do what I
have to do...that's all
Ok w e will see what the
i
Send
o o o Sprint '5'
Messages
O' | 53%
3:54 PM
Details
aaa Beth
judge says ...OK...
::
. ..
iPSH i
11mm%isiw:m m m is
i
t
!(
m B
No you will get half of the
value of the trailer off but
no one wants to buy it1
have been trying itto old
Itold m y lawer ifanything
happens to m y property
you look at T a m m y Ihave
proof and an eye
witness..
mM
**o o o Sprint ^
*(Messages
3:54 PM
aaa
B e th
53% ^
Details
Her flattening an exboy

friends tires in front of
someone....just like she
did mine..
Idon't have to worry

anymore Dan instructed
m e to go thru sapport
inforcement. ..I don't want
Send
o o Sprint =?
^ Messages
3:54 PM
aaa Beth
to talk to you IfIdon't

have to you have done
enough to
Ineed this over.....
Please stop thank vou.no
more just talk to Dan..
# 53% I D
Details
*oo Sprint
3:55 PM
O'
i 53% B D
Ihave things to do please

stop
Send
* 0 0 Sprint -=?
^ Messages
3:55 PM
aaa
B e th
Fri, Jan 23, 11:29 AM
What time would you like

our child?:
Kaena said five dropping

her off then
Oh I'm sorry Iwas trying to

be respectful Iforgot you
don't know what that
means
O' |
53% * 3
Details
d o Sprint
3:55 PM
aaa
B e th
of her cost. ..enough said

Friday food is for m y
house stop sterling itfrom
me...how dare you.. by
the way medical has
changed. ...2000.00
dollars deductible. ..you
Wii pay 6 5 %
G % 53% D
Details
o o Sprint
^ Messages
3:55 PM
aaa
B e th
Could Iplease talk to
53% H D
Details
* 0 0 Sprint
Messages
3:56 PM
aaa Beth
Kaena..
Iwould like to know why
she wasn't in school
please and would like to
talk to her thanks
Iwould not do this to you I
deserve to know what's
wrong with her
H o w was Iwould Iknow

you should have tested m e
53%
..>
Details
o o Sprint =?
^ Messages
3:56 PM
aaa
B e th
Iwould like to talk to her

tomorrow at 6:00 please
thank you
This will mot look good in

court Bo and that is m it
true Iwould tell you she
was sick
Iwould please like to talk
to Kaena sometime after
O'
i 53% * Q
Details
* 0 0 Sprint
Messages
3:56 PM
aaa Beth
6:00 tomorrow
please....thank you
It says on our agreement i
t 63% * ;:>
Details
o o Sprint *?
Messages
3:56 PM
aaa Beth
get to talk to her twice a

week the court will know
you are not
complying, .and are very
hostile...
Not trying to be just want

to talk to her you won't let
m e tonight Iwas hoping
for tomorrow Iwon't be
home tillaround 6:00....
O $ 53%
WD
0 0 Sprint
4 53% m i)
3:57 PM
Messages
aaa Beth
* 'I I 1:5
iff:
Iwill your wrong....you

must know that...I a m
done talk to you Iwant to
talk to our daughter.,..you
won't let m e it's that
simple
Thank you.,..
Details
{
i;|;
o o Sprint "5
< Messages
3:57 PM
aaa Beth
What are you saying to m e

you are a sick angry
miserable lier only talk
about Kaena to m e please
S T O P HARASSING M E
WITH A B U N C H O F
GARBAGE. ..GET A LIFE
O F Y O U R OWN...LEAVE
M E ALONE
0 | 53% H O
Details
* * 0 0 Sprint
t( M essages
3:57 PM
aaa
B e th
You are slandering

me....LEAVE M E A L O N E
LEAVE M E ALONE.,,
No No that's you...
% 53% W D
D e t a ils
3:57 PM
o o Sprint
Messages
aaa Beth
Mon, Feb 2, 8:45 AM
W h y are you at my work?

00.0 asshole
Iwould have LOVED to

pick her at five but I
thought itwas a five thirty
pick u p ...
PPIKM M
a 1 53% m >
Details
0 0 Sprint
3:57 PM
M essages
aaa
B e th
'O'
53% * I >
D e t a ils
That's that's ridiculous I

would never say
something like that
Send
* *o o Sprint *?
^
M essages
3:58 PM
aaa
B e th
Yes she just told m e she

made itup so she could
tast coffee
N O N O IHAVE NEVER
GIVEN H E R COFFEE. ..!!!
Call her
D ln n c o R o / i f l t 5 r
O >; 53% * D
D e t a ils
c o Sprint <?
<
M essages
3:58 PM
aaa
B e th
| 52% I D
Details
Please Bo get over

yourself....
Idid not give her

coffee...leave m e
alone...stop texting m e
Ido no drink and
drive. ...no more Bo
Can Caffeine Help
Send
o o Sprint *?
^ Messages
''
3:59 PM
aaa Beth
52% H I ! 1
Details
<oari u a iieirie neip

Hyperactive Children? i
LIVESTR Q N G .C O M
htt
www.livestrona .com /
article/485843-can caffeine-help-hvperactive-children/#paae -
IM .IIM M *
I did not give her coffee
but have permission to
give it to one of my friends
child
i Send
o o Sprint
^ Messages
3:69 PM
aaa
B e th
children/#page=
I did not give her coffee

but have permission to
give it to one of my friends
child
I 52% I D
Details

John Alika Kalii JR vs. Beth Ann Kalii 14-3-01646-7

Enviado por

Dados do documento

Título original

Direitos autorais

Formatos disponíveis

Compartilhar este documento

Compartilhar ou incorporar documento

Opções de compartilhamento

Você considera este documento útil?

Este conteúdo é inapropriado?

Direitos autorais:

Formatos disponíveis

John Alika Kalii JR vs. Beth Ann Kalii 14-3-01646-7

Enviado por

Direitos autorais:

Formatos disponíveis

E-FILED

IN COUNTY CLERK'S OFFICE

April 22 2014 11:25 AM

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

Assignment TO SET Trial Date

Friday, September 05, 2014 9:00 AM

D ATED : A pril 22, 2014

SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

Uc&BtMoot*_____________ ______ State_ \fJA-

_ Adoption (ADP 5) Non PCLR

PIERCE COUNTY SUPERIOR COURT

Receipt/Itera ft Tran-Code Docket-Code

PIERCE COUNTY, WASHINGTON

Paid By: kalii, John jr

Superior Court of Washington

John Alika Kalii, Jr.

Beth Ann Kalii

To the Respondent: Beth Ann Kalii

[X] that your marriage be dissolved.

You must respond to this summons and petition by serving a

exclusive of the day of service, the court may enter an order

Your written response to the summons and petition must be on

WPF DR 01.0300, Response to Petition (Marriage).

This form may be obtained by contacting the clerk of court at

If you wish to seek the advice of an attorney in this matter,

One method of serving a copy of your response on the

This summons is issued pursuant to

28.100 and Superior Court

ire of Petitioner {Pro Se)

John Alika Kalii, Jr.

File original of your response

[X] Petitioner [You may list an

Serve a copy of your response on:

Pierce County Superior Court

John Alika Kalii, Jr.___________

IN COUNTY CLERK'S OFFICE

AM. APR22 2014

Superior Court of Washington

Petition for Dissolution

Birth date November 29, 1952

, Birth date August 11, 1968

Children of the Marriage Dependent Upon Either or Both Spouses

Pet forDisso of Marriage (PTDSS)

Name (first/last) __________________ ____ ___________________ Age__________

(first/last) ______________________________________ Age

Allegation Regarding Marriage

Date and Place of Marriage

The parties were married on November 21,

The parties had previously entered into a Washington

Petitioner and respondent are not separated.

This court has jurisdiction over the marriage.

This court has jurisdiction over the respondent because:

Pet for Disso of Marriage (PTDSS)

the respondent is currently residing in Washington.

There is community or separate property owned by the parties.

The division of property should be determined by the

The petitioner should be awarded

The respondent should be awarded

Other: See Exhibit A.

Debts and Liabilities

The parties have no debts and liabilities.

The division of debts and liabilities should be

The petitioner's recommendation for the division of

Uc&BtMoot*_______ State_ \fJA-

Name (first/last) ________ _ Age__