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E-FILED

IN COUNTY CLERK'S OFFICE


PIERCE COUNTY, WASHINGTON
September 18 2008 3:55 PM
KEVIN STOCK
COUNTY CLERK

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR PIERCE COUNTY

No. 08-3-03291-3
ORDER ASSIGNING CASE TO DEPARTMENT

In accordance with PCLR 40(b), this case is hereby assigned to Department 06, Judge ROSANNE BUCKNER.

Notice to Petitioner:

Once the case has been filed, the petitioner shall serve a copy of this Order Assigning Case to Department on the
respondent with the summons and petition. Provided, however, that in those cases where service is by
publication the petitioner shall serve a copy of this Order Assigning Case to Department within five (5) court days
of service of the respondent's first response/appearance. If the case has not been filed, but an initial pleading is
served, a copy of this Order Assigning Case to Department shall be served within five (5) court days of filing.
PCLR 1(b).
Trial Date:

A trial date may be obtained pursuant to PCLR 40(d) by filing a 'Note of Issue' for assignment of a trial date by
noon at least six (6) court days prior to the date fixed for assignment of the trial date. PCLR 40(d)
If a trial date is not obtained pursuant to PCLR 40(d), failure to appear on this date will result in dismissal of
the case by the Court. PCLR 40(d)
Assignment to Set Trial Date

Friday, January 23, 2009 9:00 AM

At that time the Court will provide you with a Case Schedule which shall include the trial date. Failure to
appear on this date will result in dismissal of the case by the Court. PCLR 40(d).
Certificate of Completion of Mandatory Parenting Seminar due from both parties by 11/20/2008. See
PCLSPR 94.05(c) & (4)(i). http:\\www x o.pierce.wa.us\pc\services\lawjust\parentingseminars.htm
Uncontested Dissolutions/Settlements:

If this case is agreed upon by both petitioner and respondent, you are not required to wait for the trial date in
order to settle your case. If you settle your case and the appropriate time requirements have been met, you may
file a Note for Commissioner's Calendar' to appear before a Court Commissioner for entry of final papers.

DATED: September 18, 2008


Judge ROSANNE BUCKNER
Department 06
astsup-0003.pdf

18741

08-3-03291-3

30563265

CICS

9/22/2688

09-22-08

SUPERIOR COURT OF W ASHINGTON FOR PIERCE COUNTY


CASE COVER SHEET / DOMESTIC & PROBATE CASES

IJi 3 03291 3
Atty/Litigant

H illa ry
S o u th

A.

H o lm e s

Address

317

City

P u y a l l u p _____________________ State

Bar# 2 6 2 0 8

Phone

2 5 3 -8 4 8 -3 5 1 3

a n ___________________________________________________________

WA_______________ Zip

98371

Please check one category that best describes this case for indexing purposes.
Presumed tracks are listed next to the cause codes. (Non PCLR indicates no Track Assignment Request
is required.)
Ify o u cannot determine the appropriate category, please describe the cause o f action below. This w ill create a
Miscellaneous cause which is not subject to PCLR I, and does not require a Track Assignment Request Form.

DOMESTIC RELATIONS
____Invalidity (INV 3) DISSOLUTION
A id Custody (CUS 3) DISSOLUTION
^ Dissolution with Children (DIG 3) DISSOLUTION
____Dissolution without Children (DIN 3) DISSOLUTION
____Foreign Judgment Domestic (FJU 3) Non PCLR
____Legal Separation (SEP 3) DISSOLUTION
____Parenting Plan / Child Support (PPS 3) DISSOLUTION
____Modification of Custody (MDC 3) Non PCLR
____Modification of Support Only (MDS 3) Non PCLR
____Reciprocal, In County (RIC 3) Non PCLR
____Reciprocal, Out o f County (ROC 3) Non PCLR
____Mandatory Wage Assignment (MSC 3) Non PCLR
Out of State Custody (MSC 3) Non PCLR
ADOPTION I PATERNITY
Adoption (ADP 5) Non PCLR
Confidential Intermediary (MSC 5) Non PCLR
Paternity (PAT 5) Non PCLR
URESA / UIFSA (PUR 5) Non PCLR
Relinquishment (REL 5) Non PCLR
Terminate of Parent-Child Relation (TER S)Non PCLR
Vulnerable Adult Petition (VAP 5) Non PCLR
Misc (MSC 5) Non PCLR
MISCELLANEOUS.

PROBATE / GUARDIANSHIP
Absentee (ABS 4) Non PCLR
Disclaimer (DSC 4) Non PCLR
Estate (EST 4) Non PCLR
Foreign Will (FNW 4) Non PCLR
Guardianship (GDN 4) Non PCLR
Limited Guardianship (LGD 4) Non PCLR
Minor Settlement w/Guardianship(MST 4)Non PCLR
Non-Probate Notice to Creditors (NNC 4) Non PCLR
Will Only (WLL 4) Non PCLR
Misc (MSC 4) Non PCLR

348128

18741

9/22/2808

34

y^
08-3-03291-3

30563268

SM

09-22-08

2
3
IN

C0^ V % e D ,

AM,

SEP i s

4
5

2088

6
-----DiPUTY

7
Superior Court o f W ashington
County o f PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

11

and

12

VICTORIA J. GOFF

u (IS 3 03291: 3

No.
Petitioner,

Summons
(SM)
Respondent.

13

14

To the Respondent: VICTORIA J. GOFF

15

1.

The petitioner has started an action in the above court requesting that your marriage be
dissolved.

16
Additional requests, if any, are stated in the petition, a copy of which is attached to this
summons.

17
18

2.

19

20
21

22

You must respond to this summons and petition by serving a copy of your written
response on the person signing this summons and by filing the original with the clerk of
the court. If you do not serve your written response within 20 days (or 60 days if you are
served outside of the State of Washington) after the date this summons was served on
you, exclusive of the day of service, the court may enter an order of default against you,
and the court may, without further notice to you, enter a decree and approve or provide
for the relief requested in the petition. In the case of a dissolution of marriage, the court
will not enter the final decree until at least 90 days after filing and service. If you serve a
notice of appearance on the undersigned person, you are entitled to notice before an
order of default or a decree may be entered.

23
3.

24
25

Your written response to the summons and petition must be on form WPF DR 01.0300,
Response to Petition (Domestic Relations). This form may be obtained by contacting
the clerk of the court at the address below, by contacting the Administrative Office of the
Courts at (360) 705-5328, or from the Internet at the Washington State Courts
Summons (SM) - Page 1 of 2
Campbell, Dille, Barnett, Smith &
WPF DR 01.0200 (6/2006)- CR 4.1
Wiley
31 jS o u th Meridia n
Puyallup, WA 98371
FamilySoft FormPAK 2006

253-848-3513
253-845-4941 - Facsimile

18741

http://www.courts.wa.gov/forms
4.

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.

5.

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

6.

One method of serving a copy of your response on the petitioner is to send it by certified
mail with return receipt requested.

4
5
6

3 4 B1

Homepage:

9S22/2&8B

7
8

This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state of Washington.

10
26208

11

Hillary j
Signati

vyer/WSBA No.

12

13
14
15
16

File original of your response with


the clerk of the court at:
Clerk of the Court
Pierce County Court
County-City Building
930 Tacoma Ave. S., Rm 110
Tacoma, WA, 98402

Serve a copy of your response on:


Petitioner's Lawyer
Hillary A. Holmes
Campbell, Dille, Barnett, Smith
317 S. Meridian
P. O. Box 488
Puyallup, WA 98371

17
18
19
20
21
22
23
24
25
Summons (SM) - Page 2 of 2
WPF DR 01.0200 (6/2006)- CR 4.

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FamilySoft FormPAK 2006

253- 845-4941 - Facsimile

18741

08-3-03291-3

30583269

PTDSS

BS2

/ 2

80S

3401

09-22-08

3
IN COUNTVF CLERK'S OFFICE

A.M.

SEP 1 8

p ie r c e c o u n t v w
kew nstock.c

2008 P.H.
ASHINGTON
'unty Clerk
----- DEPUTY

7
Superior Court o f W ashington
County o f PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

US 3 0 3 2 9 1

No.
Petitioner,

11

and

12

VICTORIA J. GOFF

Petition fo r D issolution
o f Marriage
(PTDSS)
Respondent.

13
14
15

I. Basis
1.1

16

Identification of Petitioner
Name (first/last) Brent Goff, Birth date 6/4/71
Last known residence PIERCE County, WA [county and state].

17
18

1.2

Name (first/last) Victoria Goff, Birth date 8/19/72


Last known residence King County, WA [county and state],

19
20

Identification of Respondent

1.3

21

Children of the Marriage Dependent Upon Either or Both Spouses


The husband and wife are both the parents of the following dependent children:
Name (first/last) Kolby Hunter Goff Age 7

1.4

Allegation Regarding Marriage


This marriage is irretrievably broken.

Pet for Disso of Marriage (PTDSS) - Page 1 of 4


WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020

Campbell, Dille, Barnett, Smith &


Wiley

317 South Meridian


Puyallup, WA 98371
253- 848-3513
Family Soft FormPAK 2007

253-845-4941 - Facsim ile

18741

1.5

Date and Place of Marriage

1.6

Separation
Husband and wife separated on 5/31/06.

1.7

Jurisdiction

This court has jurisdiction over the marriage.

This court has jurisdiction over the respondent because:

The respondent is presently residing in Washington.


The petitioner and respondent lived in Washington during their marriage.

9
10

1.8

Property

11

There is community or separate property owned by the parties. The court should make a
fair and equitable division of all the property.

12

The petitioner's recommendation for the division of property is set forth below.

13

Other: See Separation Agreement which is incorporated herein by reference as


though fully set forth herein.

14
15

1.9

17

The petitioner's recommendation for the division of debts and liabilities is set forth
below.

18

Other: See Separation Agreement which is incorporated herein by reference as


though fully set forth herein.

19
1.10

21

22
23

Debts and Liabilities


The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.

16

20

348

The parties were married on 8/29/98 at Auburn, King County, Washington.

4
5

088

Spousal Maintenance
Spousal maintenance should not be ordered.

1.11

Continuing Restraining Order


Does not apply.

24
25
Pet for Disso of Marriage (PTDSS) - Page 2 of 4
WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020

FamilySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
31 j South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

1874 i

1.12

Protection Order

1.13

Pregnancy
The wife is not pregnant.

1.14

Jurisdiction Over the Children

This court has jurisdiction over the child for the reasons set forth below.

This state is the home state of the child because the child 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.

9
10

11

1.15

Child Support and Parenting Plan for Dependent Children


Support for the dependent child listed below, should be set pursuant to the Washington
State Child Support Schedule.

12

Name of
Child

Mothers
Name

Father's
Name

13

Kolby Hunter Goff

Victoria Goff

Brent Goff

14
15
16
17
18
19
20
21

348

Does not apply.

4
5

9/22/2808

The petitioner's proposed parenting plan for the child listed above will be filed and
served at a later date pursuant to RCW 26.09.181.
(The following information is required only for the child who is included in the petitioner's
proposed parenting plan.)
During the last five years, the child has lived in no place other than the State of
Washington and with no person other than the petitioner or the respondent.
Claims to custody or visitation:
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 child.
Involvement in any other proceeding concerning the child:

22

The petitioner has not been involved in any other proceeding regarding the child.

23

Other legal proceedings concerning the child:

24

The petitioner does not know of any other legal proceedings concerning the child.

25
Pet for Disso of Marriage (PTDSS) - Page 3 of 4
WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020

FamilySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

18741

9^2222088

3401

f*

1.16

Other
Does not apply.

II. Relief Requested

The petitioner Requests the Court to enter a decree of dissolution and to grant the relief below.

Approve the petitioner's proposed parenting plan for the dependent child listed in
paragraph 1.15.

Determine support for the dependent child listed in paragraph 1.15 pursuant to the
Washington State Child Support Schedule.

Approve the separation agreement.

Divide the property and liabilities.

10

Order payment of day care expenses for the child listed in paragraph 1.14.

11

Award the tax exemptions for the dependent child listed in paragraph 1.14 as follows:

12

The mother shall claim the tax exemption for Kolby in odd years. The father
shall claim the tax exemption for Kolby in even years.

13
14
15

Dated:

16

iln ln )
1' '

1 A
M
^
_
Hillary A. Hoimes\
Signature oKgejitbner or Lawyer/WSBA No.

26208

17
18

I declare under penalty of perjury under the laws of the State of Washington that the foregoing
is true and correct.

19

Signed at

, [City] V - k r [State] on.

< = j-l7 -0 &

[Date],

20
21
22

Brent Goff
Signature of Petitioner

23
24
25
Pet for Disso of Marriage (PTDSS) - Page 4 of 4
WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FamilySoft FormPAK 2007

253-845-4941 - Facsim ile

18741

OS-3-03291'3

30563271

ACSR

9/22/28S8

348

09-22-08

2
3
4
5
6
*"-J T ~ - DEPUfy

7
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

11

and

12

VICTORIA J. GOFF

NO.

0329T

Petitioner,
ACCEPTANCE OF SERVICE
(ACSR)
Respondent.
13
14

1.

ACCEPTANCE OF SERVICE.
Victoria Goff accepts service of:

15

The summons and petition in this action.


Confidential Information Form
Child Support Worksheets
Proposed Parenting Plan

16
17
18
2.

CONSENT TO PERSONAL JURISDICTION.

19
Does not apply.

20
3.

OTHER:

21
22
23
24
25
ACCEPTANCE OF SERVICE (ACSR) - Page 1 of 1
WPF DR 01.0310 (9/2001) - RCW 26.09.030 (1)

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FamilySoft FormPAK 2004

253-845-4941 - Facsim ile

08-3-03291-3

30563273

CSW

09-22-08

IN

CouryF,cL
J& <

OFFICE

Washington State Child Support Schedule Worksheets


[ ]

Proposed by [ ] Mother [ ] Father


Or, [ ]
Mother: Victoria J. Goff
County: PIERCE

[ ] State of WA [ ] Other
. (CSWP)
Signed by the Judicial/Reviewing Officer. (CSW)
Father: Brent D. Goff

Superior Court/OAH Case No,:

0SI 3 032:9'1! 3;

____________________ Child Support Order Summary Report____________________

A. The order [ ] does [ 1does not replace a prior court or administrative order.__________________
B. The STANDARD CALCULATION listed on line 15e of the Worksheet for the paying parent is:
$334.38.___________________________________________________________________ _
C. The TRANSFER AMOUNT ordered by the Court from the Order of Child Support is:
_____ $334.38 to be paid by [ ] mother [X] father. _________ __ ______________________ __
D. The Court deviated (changed) from the STANDARD CALCULATION for the following reasons:
[ ] Does not apply
[ ] Nonrecurring income
[ ] Sources of income and tax planning
[ ] Split custody
[ ] Residential schedule (including shared custody)
[ j Children from other relationships for whom the parent owes support
[ ] High debt not voluntarily incurred and high expenses for the child(ren)
[ j Other (please describe):
E. Income for the Father is [ ] imputed [X] actual income.
Income for the Mother is [ ] imputed [X] actual income.________________________________
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the
worksheets in Part II.

Worksheets
Children and Ages: Kolby Hunter Goff, 7
Parti: Basic Child Support Obligation (See Instructions, Page 1)
1. Gross Monthly Income
a.
b.
c.
d.
e.
f.

Wages and Salaries


Interest and Dividend Income
Business Income
Spousal Maintenance Received
Other Income
Total Gross Monthly Income
(add lines 1a through 1e)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 1 of 5

Father

Mother

$2,990.00

$3,293.00

$2,990.00

$3,293.00

18741

972272888

Monthly Deductions from Gross Income


a. Income Taxes (Federal and State) Tax Year: 2008
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes
c. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Pension Plan Payments
f. Spousal Maintenance Paid
g. Normal Business Expenses
h. Total Deductions from Gross Income
(add lines 2a through 2g)
3. Monthly Net Income
(line 1f minus 2h)
4. Combined Monthly Net Income
(Line 3 amounts combined)
(If line 4 is less than $600, skip to line 7.)
5. BASIC CHILD SUPPORT OBLIGATION: Combined
Kolby Hunter Goff
$701.00

Mother

Father

2.

$339.75
$228.74

$402.33
$251.91

$167.00

$167.00
-

$735.49

$821.24

$2,254.51

$2,4 71.76

$4,726.27

$701.00

6. Proportional Share of Income


(Each parent's net income from line 3 divided by line 4)
7. Each Parent's Basic Child Support Obligation
(Multiply each number on line 6 by line 5)
(If line 4 is less than $600, enter each parents support
obligation of $25 per child. Number of children: 1
(Skip to line 15a and enter this amount.)

.477

.523

$334.38

$366.62

Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 3)
8. Health Care Expenses
a. Childrens Monthly Health Insurance
b. Children's Uninsured Monthly Health Care
c. Total Monthly Health Care Expenses
(line 8a plus line 8b)
d. Combined Monthly Health Care Expenses
S |||
f *

(add father's and mother's totals from line 8c)
e. Maximum Ordinary Monthly Health Care
m
s s
.V
l
(multiply line 5 times .05)
$35.05
t il*
f. Extraordinary Monthly Health Care Expenses
(line 8d minus line 8e., if "0" or negative, enter "0")
9. Day Care and Special Child Rearing Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)

e. Total Day Care and Special Expenses


(Add lines 9a through 9d)
10. Combined Monthly Total Day Care and Special Expenses
(Combine amounts on line 9e)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 2 of 5

348129

18741

9 /2 2 /2 8 6 8

11. Total Extraordinary Health Care, Day Care, and Special


Expenses (line 8f plus line 10)
Father

Mother

12. Each Parent's Obligation for Extraordinary Health Care,


Day Care, and Special Expenses
(Multiply each number on line 6 by line 11)
Part III: Gross Child Support Obligation
13. Gross Child Support Obligation (line 7 plus line 12)

$334.38 |

$366.62

Part IV: Child Support Credits (See Instructions, Page 3)


14. 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 14a through 14c)

Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 4)


15. Standard Calculation
a. Amount from line 7 if line 4 is below
$600. Skip to Part VI.
b. Line 13 minus line 14d, if line 4 is over
$600 (see below if appl.)
Limitation standards adjustments
c. Amount on line 15b adjusted to meet 45%
net income limitation
d. Amount on line 15b adjusted to meet
need Standard limitation
Need Standard Year: 2008
e. Enter the lowest amount of lines 15b, 15c or 15d:

Father

Mother
-

$334.38

$366.62

$334.38

$366.62

Part VI: Additional Factors for Consideration (See Instructions, Page 4)


16. Household Assets
(List the Present estimated value of all major household assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
e. Pensions/IRAs/Bank Accounts
f. Cash
g. insurance Plans
h. Other:

Father's
Household

17. Household Debt


(List liens against household assets, extraordinary debt.)
a.
b.
c.
W5CSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 3 of 5

Mother's
Household
-

346136

10741

(Household Debt continued)

Father's
Household

d.
e.
f.
18. Other Household Income
a. Income Of Current Spouse
(if not the other parent of this action)
Name
Name

9^22/2808

Mother's
Household

b. Income of Other Adults in Household


Name
Name

c. Income of Children (if considered extraordinary)


Name
Name

d. Income from Child Support


Name
Name

e. Income From Assistance Programs


Program
Program

f. Other Income (describe)

19. Non-Recurring Income (describe)

20. Child Support Paid For Other Children


Name/age:
Name/age:
Name/age:
21. Other Children Living In Each Household
(First names and ages)
------------- -------- ---

WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 4 of 5

340131

iS?4 1

Judge/Reviewing Officer

9/22s'2B88

Date

Worksheet certified by the State of Washington Administrative Office of the Courts.


Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 5 of 5
c:\program files\Iegalplus\state templates\waworksheel.dtf i:\data\scdir\goff, brentlgoff, brent.scp 09/06/2006 06:31 am

SupportCa/c 2008

346132

18741

Mother: Victoria J. Goff


County: PIERCE

9222^2088

340133

Father: Brent D. Goff


Superior Court Cause Number:
RESIDENTIAL SCHEDULE CREDIT USING FORMULA

16. NAMES OF CHILDREN


17. BASIC SUPPORT
(From Table)

Kolby
$701.00
'

'

'

18. ORDINARY EXPENSES


-

$35.05

c. Ord. Health Care


(Lesser 18a or 18b)

d. Other Ordinary Expenses

e. Total Ordinary Expenses


(Line 18c plus Line 18d)

"

a. Health Care Expenses


b. Max Health Care

19. ADJUSTED BASIC SUPPORT


20. OVERNIGHTS WITH MOTHER
21. % OVERNIGHTS WITH MOTHER
(Line 20 divided by 365)
22. OVERNIGHTS WITH FATHER

$701.00
182
49.9

183

23. %OVERNIGHTS-FATHER
(Line 22 divided by 365)

50.1

24. MOTHERS CREDIT PROP

.500

25. FATHERS CREDIT PROP

.500

26. MOTHERS CREDIT


(Line 19 times Line 24)

$350.50

27. FATHERS CREDIT


(Line 19 times Line 25)

$350.50

28. OVERNIGHT THRESHOLD SELECTED:

91 NIGHTS

29. TRANSFER PAYMENT BEFORE CREDIT:


30. RESIDENTIAL CREDIT TO Father IS:

$334.38
$350.50

31. TRANSFER PAYMENT AFTER CREDIT;

-$16.12

Client: i:\data\scdir\goff, brent\goff, brent.scp 09/08/2008 08:29 am

Support Ca/c 2008

1S741

08-3-03291-3

30563276

PPP

9^22^2688

3481

09-22-00

1
2
3
FILED
IN COUNTY CLERK'S OFFICE

4
5

AiH.

SEP 1 8 2008 P.H.

Y, WA
PIERCE COUNTY,WASHINGTON
KEVIN STOCK, Grounty Clerk
' *
DEPUTY
BY____

Superior Court of Washington


County PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

NoPetitioner,

11

and

12

VICTORIA J. GOFF

OS

03291;

Parenting Plan
Proposed (PPP)

Respondent.
13
14

This parenting plan is proposed by petitioner.

15

It Is Ordered, Adjudged and Decreed:

16
17

I. General Information
This parenting plan applies to the following child:

18

Name

Age

19

Kolby Hunter Goff

20
21
22
23
24
25

II. Basis for Restrictions


Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the right to make decisions for the child.

2.1

Parental Conduct (RCW 26.09.191(1), (2))


Does not apply.

Parenting Plan (PPP, PPT, PP) Page 1 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

Puyallup, WA 98371
253- 848-3513
253-845-4941 - Facsimile
FamilySoft FormPAK 2007

18741

2.2

5
6

2 2 /2 0 8 8

:4 Bl:

Other Factors (RCW 26.09.191(3))


Does not apply.

3
4

III. Residential Schedule


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 to write your residential
schedule, if you do not use these paragraphs, write in your own schedule in Paragraph 3.13.

7
8

3.1

There are no children under school age.

9
10

3.2

12

The parties shall share joint residential time with Kolby. Kolby shall reside with
his mother every Monday picking him directly from school or daycare until Wednesday
morning returning Kolby directly to school or daycare. Kolby shall then reside with his
father directly from school or daycare until Friday morning when the father returns Kolby
to school or daycare. The parties shall alternate weekends from Friday after school or
daycare until Monday morning returning him to school or daycare.

13
14
15

3.3

17

Same as Section 3.2

19

3.4

22

24
25

Schedule for Other School Breaks


The child shall reside with the mother and father during other school breaks, except for
the following days and times when the child will reside with or be with the other parent:

21

23

Schedule for W inter Vacation


The child shall reside with the mother and father during winter vacation, except for the
following days and times when the child will reside with or be with the other parent:

18

20

School Schedule
Upon enrollment in school, the child shall reside equally in the homes of both the
mother and father, except for the following days and times when the child will reside
with or be with the other parent: other:

11

16

Schedule for Children Under School Age

Same as Section 3.2

3.5

Summer Schedule
Upon completion of the school year, the child shall reside with the mother and father,

Parenting Plan (PPP, PPT, PP) Page 2 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile
FamilySoft FormPAK 2007

18741

3^22^2888

3481

except for the following days and times when the child will reside with or be with the
other parent:

1
2

Same as Section 3.2

3
3.6

Vacation With Parents

4
The schedule for vacation with parents is as follows:
5

The parents shall each be allowed vacations as they agree. In the event there is
no agreement, each parent shall be allowed seven days vacation time with the child
every year during the summer break from school. A parent shall provide 14 days notice
to the other parent of their intention to take a vacation. In the event of a disagreement,
the mother's dates for vacations shall have priority in odd years and the father's dates
shall have priority in even years.

7
8

9
10

3.7

Schedule for Holidays


The residential schedule for the child for the holidays listed below is as follows:

11
12
13
14
15
16
17
18
19
20
21
22

23
24
25

New Year's Day


Martin Luther King Day
Presidents' Day
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
Day after Thanksgiving
New Years Eve
Halloween
Valentine's Day

With Mother
(Specify Year
Odd/Even/Every)

With Father
(Specify Year
Odd/Even/Every)

Odd
Every
Every
Odd
Odd
Even
Every
Every

Even

Every
Odd
Even
Even
Odd

Even
Even
Odd
Every
Every
Even
Odd
Odd
Even

For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
All holiday times shall be as the parties agree. In the event the parties have a
disagreement then holidays shall be from 10:00 a.m. to 8:00 p.m.
Thanksgiving Day shall be evenly shared by the parties. There shall be two
blocks if the parties cannot agree. The blocks shall be from 9:00 a.m. to 3:00 p.m. and
then 3:00 p.m. to 9:00 p.m.
Parenting Plan (PPP, PPT, PP) Page 3 of 8 Laws of 2007, ch. 496, 301
Campbell, Dille, Barnett, Smith &
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194
Wiley
317 South Meridian

Puyallup, WA 98371
253- 848-3513
253- 845-4941 - Facsimile
FamilySoft FormPAK 2007

1874 i

9 ^ 2 2 ^ 2 '0 8 B

1
In odd years, the father shall have Kolby on Christmas Eve until his family
festivities end for the night but in no event later than 11:00 p.m. Kolby shall then reside
with his mother from 11:00 p.m. on Christmas Eve through Christmas Day.

3
In even years, Kolby shall reside with his father until 12:00 noon on Christmas
Day. Kolby shall then reside with his mother until the day after Christmas at 8:00 p.m.

4
5

3.8

Schedule for Special Occasions


The residential schedule for the child for the following special occasions (for example,
birthdays) is as follows:

7
With Mother
(Specify Year
Odd/Even/Every)

With Father
(Specify Year
Odd/Even/Every)

9
Mother's Day
Father's Day
Mother's Birthday
Father's Birthday
Kolby's Birthday

10
11

Every
Every
Every
Odd

Every
Even

12
Other:

13
Special occasions shall be from 12:00 noon until 8:00 p.m. The parties may
agree to any other times.

14
15

3.9

16

Priorities Under the Residential Schedule


If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the children
are scheduled to be with both parents at the same time, the conflict shall be resolved by
priority being given as follows:

17
18

Rank the order of priority, with 1 being given the highest priority:

19

5 school schedule (3.1, 3.2)


4 winter vacation (3.3)
4 school break(s) (3.4)
4 summer schedule (3.5)
3 vacation with parents (3.6)
1 holidays (3.7)
2 special occasions (3.8)

20
21

22
23
24
25

3.10

Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.

Parenting Plan (PPP, PPT, PP) Page 4 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

FamitySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

18741

3.11

9 ^ 2 2 -'2B0B

3461

Transportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.

3
Transportation arrangements for the child between parents shall be as follows:

4
The receiving parent shall provide transportation. If a return it to school or
daycare the following morning, then the parent with whom the child is residing at the
time shall return the child.

5
6

3.12

Designation of Custodian
Kolby is scheduled to reside the majority of time with both the mother and the father.
Both the mother and father are designated the custodians of the child for the purposes
of all 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.

8
9

10
11

3.13

Does not apply.

12

13
14
15
16
17
18
19
20
21
22

23
24
25

Other

3.14

Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child


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 days' notice, that person must give notice within 5 days after
learning of the move. The notice must contain the information required in RCW
26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A Child).
If the move is within the same school district, 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.
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.
If information is protected under a court order or the address confidentiality program, it
may be withheld from the notice.

Parenting Plan (PPP, PPT, PP) Page 5 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
3 17 South Meridian

Puyallup, WA 98371
253-848-3513

253-845-4941 - Facsimile
FamitySoft FormPAK 2007

18741

9/22^2008

348

1
2

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.

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.

5
6

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.

7
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.

8
9
10

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.

11
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.

12

13
14
15

IV. Decision Making


4.1

16

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.

17
18
19
20
21
22
23

Day-to-Day Decisions

4.2

Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions:

joint

Non-emergency health care:

joint

Religious upbringing:

joint

24
25

Parenting Plan (PPP, PPT, PP) Page 6 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

253-845-4941 - Facsimile
FamitySoft FormPAK 2007

18741

1
2

4.3

3481

Restrictions in Decision Making


Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.

3
4

9^22^2S8S

V. Dispute Resolution
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 .

7
8

9
10
11

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 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% mother 50% father.

12

13

The dispute resolution process shall be commenced by notifying the other party by
written request.

14

In the dispute resolution process:

15

(a)

Preference shall be given to carrying out this Parenting Plan.

16

(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.

17
18
19
20
21

22
23
24
25

VI. Other Provisions


There are no other provisions.
Parenting Plan (PPP, PPT, PP) Page 7 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
3 17South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

FamilySoft FormPAK 2007

18741

S/'22^288S

3481

VII. Declaration for Proposed Parenting Plan

(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 ifvlpart l/ofnhis Plan are true and correct.

3
4
5

Date and Place of Signature

Victoria Goff
Mother

[j

6
q - p 'O K

7
8

Brent Goff
Father

9
10

11
12

13
14
15
16

Date and Place of Signature


igtfa

VIII. Order by the Court


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.
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.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
plan are not affected.
Before signing the final parenting plan, the court consulted the judicial information
system and databases, if available, to determine the existence of any information and
proceedings that are relevant to the placement of the children.

17
18
19

Dated:

Judge/Commissioner

20
21

p o y ^ l ^ p

Presented by:

Approved for entry:

22
26208

23

Hillary A. H
Signature

or LawyerAA/SBA No.

Signature of Party or LawyerA/VSBA No.

24
25

Parenting Plan (PPP, PPT, PP) Page 8 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

Puyallup, WA 98371
253- 848-3513
253-845-4941 - Facsimile
FamifySofl FormPAK 2007

18823

9 /2 4 /2 0 8 8

08

1
08-3-03291-3

30581639

RCOPC

09-24-08

* COUNTY 'c ii& s ofrce

3
'2 0 0 8

4
5

'

p.m .

DDEPUTE

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF PIERCE

10

In Re the Marriage of:


NO. 08-3-03291-3
BRENT D. GOFF,
Petitioner,

11
12
13
14

CERTIFICATE OF PARENTING
SEMINAR FOR RESPONDENT

and
VICTORIA J. GOFF,
Respondent.
See attached

15
16
17
18
19
20
21
22
23
24
25
26

- Page 1
525\D\GOFF, BRENT\A

CAMPBELL, DILLE, BARNETT,


SMITH & WILEY, P.L.L.C.
ATTORNEYS AT LAW
317 SOUTH MERIDIAN
PUYALLUP, WASHINGTON 98371-0164
(253) 848-3513

18823

9^24/2808

V
I

Court Cause Number: _______________

THIS CERTIFIES THAT

Goff, Victoria
Has successfully completed the four-hour class,

What Children o f Divorce Really Need


Presented by Lesa Swanson, LICSW and Richard MacLeod,LICSW
Dated this 24th day o f June. 2006 at the City o f Tacoma, State o f Washington.

80121

1 S 913

16'

IN COUNTY CLERICS'

a.m.

SEP 2 5 2008

p.m.

PIERCE COUNTY, WASHINGTON


KEVIN STOCK, County Clerk
BY___________ ________ DEPUTY

08-

-03291-3

30598204

PCOPC

* C0u^

09-26-08

c^ % 0Feice

4
5
"

"

1---- - DEPUTY

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF PIERCE

9
10

In Re the Marriage of:


NO. 08-3-03291-3
BRENT D. GOFF,
Petitioner,

11

12
13
14

CERTIFICATE OF PARENTING
SEMINAR FOR PETITIONER

and
VICTORIA J. GOFF,
Respondent.
See attached

15
16
17
18
19
20
21
22
23
24
25
26

- rage 1
525\D\GOFF, BRENTVA

CAMPBELL, DILLE, BARNETT,


SMITH & WILEY, P.L.L.C
ATTORNEYS AT LAW
317 SOUTH MERIDIAN
PUYALLUP, WASHINGTON 98371-0164
(253)848-3513

18913

s\

9/26/2088

318164

J
i

Pierce County Superior Court Number:

This

Certificate of ghtenbance
is hereby awarded to

Brent G off
for attending and completing the

impact on Cfjilbren Seminar


Conducted by Gateways for Youth and Families
In Pierce County, Washington on this
1st day o f July, 2006

A .

Wende Wertley,TVlS

Brad Hoover, MA

Attendees are responsible fo r filing certificate with the appropriate case number

/ y

< w
n : - . s*, v
I f <*OA '

* i
i

223

1/2^2*309

88871

12-31-08

,N CUNTYF CLERK'S OFFICE

AJ- EC 3 12008

P.M

OlINTY, WASHikim

8=

DEPUTY

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

7
8

In re the Marriage of:

BRENT D. GOFF

NO. 0 ^ " >


Petitioner,

and

10
11

VERIFICATION RE:
UNCONTESTED DISSOLUTION

VICTORIA J. GOFF

Respondent.

12
13

STATE OF WASHINGTON

14

>
) ss.

County o f Pierce

15
16
17
18

BRENT D. GOFF, being first duly sworn, on oath, deposes and says:
I am the Petitioner in this case and I have read the foregoing findings of fact and have
also read the conclusions o f law, decree and the support order and related documents, if included
herein, and they are true and accurate to the best o f my knowledge. I am not seeking any relief
beyond that specifically requested in the petition. The support requested, if any, is in compliance
with the Child Support Schedule. The wife is not pregnant.

19

S /lM d t

20

{ 2 _l

BRENT D. GOFF

21

S U B ^yjJjpE D AND SW O RN to before


ifore me this _l__{_
l~~7 day o f

, 2008.

22

23

f j/ #

24
25

:3 A 1

= i3 * /
% \

:5 s

.*>A .*l Ce5 "i

%z - . V /*****

Print
NOTARY PU B LIC in and for the State of
Washington, residing at (rw^Vvscrv
My commission expires: (Y-\\-2Ptc>

VERIFICAlHo/^((^5lf^TESTED DOCKET - Page 1 of 1

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

FamilySoft FormPAK 2003

Puyallup, WA 98371
253-848-3513
253- 845-4941 - Facsimile

223

08-3-03291-3

31210830

1/2S2009

00072

12-31-08

VRR

IN C O U N T /C L E R K 'S OFFICE

AN- DEC 312008

P.E.

PKEVIN S T O c V '/ fASH,NGT N


BY
s J O p K , County Clerk

--------W ----------- deputy

COUNTY OF PIERCE

7
8

In re the Marriage of:

BRENT D. GOFF

no.

Petitioner,
10

and

11

VICTORIA J. GOFF

VERIFICATION RE:
UNCONTESTED DISSOLUTION
Respondent

12
13

STATE OF WASHINGTON

14

County of Pierce

15
16
17
18

>
) ss.

VICTORIA J. GOFF, being first duly sworn, on oath, deposes and says:
I am the Respondent in this case and I have read the foregoing findings o f fact and have
also read the conclusions o f law, decree and the support order and related documents, if included
herein, and they are true and accurate to the best o f my knowledge. I am not seeking any relief
beyond that specifically requested in the petition. The support requested, jfa n y ,J s in compliance
with the Child Support Schedule. The wife is not pregnant.

19
20
21

TCTORIA J. GOFF

SUBSCRIBED AND SWORN to before me this r ?

day o f S c ^ f e ^ U i n ,2008.

22
%

23

P rinteJyante

NOTARY PUBLIC m and for the State o f


Washington, residing at Fw aY acO ______
My commission expires:

24
25
VERIFICATI

ED DOCKET - Page 1 of 1

Campbell, Dille, Barnett, Smith &


Wiley

317 South Meridian

FamilySoft FormPAK 2003

Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

223

08-3-03291-3

31210831

PRYSA

1/2/2809

008?3

* C0ury% % 0
LS*K'S

12-31-08

A. II,

SEPARATION A G REEM EN T

TH IS A G RE EM EN T is being made and entered into this

Dec

ri -

9SS&Z. day of_SjQjAffijQ#0081

by and between BRENT D. GOFF, (hereinafter referred to as "husband") and VICTORIA J. GOFF,
(hereinafter referred to as "wife").
W HEREAS, the parties are residents o f the State o f Washington, County o f Pierce; were
married on the 29th day o f August, 1998, in Auburn, Washington; and
W HEREAS, one child was bom of this marriage, Kolby bom April 3,2001; and
W H ER EA S, differences have arisen between the parties as a result of which they have
separated on or about May 31, 2006 and the parties have a pending action for dissolution o f this
marriage in the Superior Court o f Pierce County, Washington; and
W HEREAS, each party has fully disclosed to the other all property he or she owns and all
income he or she derives from any other source, and all claims, liens or encumbrances affecting such
property and income, and in entering into this contract, the parties have attempted to divide their
property in such a manner that each will receive property or cash or both netting a fair and equitable
division of their total community estate; and
W HEREAS, at the time o f this agreement, both parties acknowledge that the property and
obligations herein listed and disposed o f is all o f the property and all o f the obligations either or both
have accumulated; and
W HEREAS, each party has had the opportunity to consult his or her respective counsel with

Separation Agreement
525\D\GOFF, BRENT\ASEPAGMT 090808

Page 1

0 f F IC e

2 2 3 .1-/2/2-8 8-9

8 3 8 .7 4

this agreement, and


W H ER EA S, both parties agree to submit themselves and all o f their property wherever
situated to the laws and courts of the State o f Washington to dispose o f their property as set forth
below; and
W H ER EA S, both parties waive freely any and all o f their respective rights in favor o f the
rights granted them under this agreement, and both parties agree that if a decree o f dissolution or a
decree of legal separation is entered, that it shall be done only in accordance with the terms set forth
herein; and
W H ER EA S, the wife is not a person in the military service o f the United States; and
W H ER EA S, the husband is not a person in the military service o f the United States; now,
therefore,
IN C O N SID ER A TIO N o f the rights and obligations set forth herein, the mutual promises
hereinafter made, and the acts, agreed to be performed by each o f the, the parties have agreed and
by their signatures appearing hereon, do agree as follows:
I

FINDINGS AND JU D G M EN T
Each party agrees to be bound by all the terms o f this agreement, and this settlement
agreement shall be embodied within any such judgment regarding property rights, spousal
maintenance, child support, and a parenting plan which may ultimately issue with respect to the
dissolution herein.

Separation Agreement
525\D\GOFF, BRENT\ASEPAGMT.090808

Page 2

223

l/_ 2 /.2 e a '9 :B ea?S

II
COURT APPROVAL OF SETTLEMENT AGREEMENT
It is the intent o f each party that the court approve this settlement agreement as being fair and
equitable at the time it was entered into as well as in the best interests o f their children and as being
enforceable.

III
WARRANTY AS TO INTERESTS IN PROPERTY
Each party hereby warrants to the other that he or she is not now possessed o f any interest
in property of any kind or description whatsoever, other than as set forth in this agreement, and each
party specifically warrants that he or she has no vested, contingent or residual interest whatsoever
in any real or personal property, except as stated herein. Each party warrants to the other that no
individual is holding any real or personal property for said party as trustee, bailee or otherwise.
If it shall hereafter be determined that either the husband or the wife is now possessed o f or
has any interest in any property not set forth herein, or that heretofore the husband or wife has
transferred or otherwise disposed o f property in excess o f Five Hundred Dollars and No Cents
($500.00) without the consent or knowledge o f the other, or that another is holding real or personal
property in trust, bailment or otherwise, each o f the parties hereto covenants and agrees to pay to the
other, upon demand, an amount equal to one-half o f the fair market value o f any such property.

IV
INHERITANCE
Each party hereby waives any and all right to inherit from the estate o f the other at his or her

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death, or take property from the other by devise or bequest, unless under a will executed subsequent
to the effective date hereof, or to claim any family allowance or probate homestead, or to act as
personal representative (unless under a Will executed subsequent to the effective date hereof).

V
AFTER ACQUIRED PROPERTY
It is hereby agreed and understood that any and all property acquired by either o f the parties
to this agreement from and after the effective date o f this agreement, shall be the sole and separate
property o f the one acquiring same, and each party hereby waives any and all right in or to such
future acquisitions o f property by the other.

VI
PROPERTY TO THE WIFE
The wife shall be granted and conveyed the following real and personal property, which
comprises her equitable share o f the separate and community property, free and clear o f any right,
title or interest o f the husband herein:
(1)

(2)
(3)
(4)
(5)

The wife is awarded the sum o f Thirty Eight Thousand Dollars ($38,000) payable by
husband to wife representing her share o f equity in the family residence. This sum
shall be paid in full within 30 days from the date o f entry o f the Decree o f
Dissolution except for extraordinary circumstances beyond the husbands control due
to a delay in the husbands refinancing o f the home. This sum shall be interest free
if paid in full within 30 days from the date o f the Decree o f Dissolution. The wife
shall sign a Quit Claim Deed and Excise Tax Affidavit which she shall tender into
escrow for husband to be recorded simultaneously with the payment o f $38,000 to
her.
2004 Dodge Intrepid automobile with VIN 2B3HD56G94H615920
100% o f wifes retirement through her employment with the State o f Washington
100% o f wifes Smith Barney retirement account
All furnishings, housewares, home decor items, tools and equipment in the
possession of the wife

Separation Agreement
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Page

223

( 6)
(7)
( 8)

1/2/2009

0087?

All clothing, jewelry and personal effects o f wife


All bank accounts solely in the name o f wife
All property acquired by wife since the date o f separation

VII
PROPERTY TO THE HUSBAND
The husband shall be granted and conveyed the following personal property, which comprises
his equitable share o f the separate and community property, free and clear o f any right, title or
interest of the wife herein:
(1)

Real property located at 11911 - 218thAvenue Court East, Bonney Lake, Washington
98391 with a legal description as follows: Lot 36, FIR BAU ESTATES,
ACCORDING TO PLAT RECORDED FEBRUARY 16, 1993 UNDER
RECORDING NO. 9302160232, IN PIERCE COUNTY, WASHINGTON.
SITUATE IN THE COUNTY OF PIERCE, STATE OF WASHINGTON.

(2)
(3)
(4)
(5)
( 6)
(7)

Subject to the husband paying the wife $38,000 as provided above, the wife shall
sign a Quit Claim Deed and Excise Tax Affidavit releasing her interest to husband
simultaneous with receipt o f the $38,000.
1996 Dodge Ram pickup truck with VIN 3B7KF23W 3TM163374
100% o f all retirements through husbands employment with Pape Machinery
100% o f husbands Smith Barney IRA account
All furnishings, housewares, home decor items, tools and equipment currently in the
possession o f husband
All clothing, jewelry and personal effects o f husband
All bank accounts solely in the name o f husband

VIII
SOCIAL SECURITY RIGHTS
Each party retains all rights accorded to him or her by virtue o f the Social Security Act,
notwithstanding that some or all o f those rights accrue solely by virtue o f the marriage o f the parties
and contributions o f the other spouse.

Separation Agreement
525\D\GOFF. BRENTAASEPAGMT 090808

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223

2 :2 2 2 8 8 9

88878

IX

INCOME TAX LIABILITIES


The parties shall file taxes separately for the year 2008 and all subsequent years with each
party keeping the refund or paying taxes on their income as appropriate. The wife shall claim the
tax exemption for the child in odd years and the husband shall claim the tax exemption for the child
in even years.
X

OBLIGATIONS
Both parties represent and warrant that there are no community obligations except those
which are mentioned in this paragraph.
The husband shall pay and hold the wife harmless from any payment thereon, and indemnify
the wife if she should be required to pay on the following debts:
(1)
(2)
(3)
(4)

The sum o f $38,000 payable to wife no later than 30 days from the date o f entry o f
the Decree of Dissolution. This sum shall be interest free.
Mortgages on the real property located at 11911 - 218th Avenue Court East, Bonney
Lake, WA 98391
Visa credit card in the name o f husband
Any debts or obligations incurred by husband since the date o f separation

The wife shall pay and hold the husband harmless from any payment thereon, and indemnify
the husband if he should be required to pay on the following debts:
(1)

(2)
(3)

The loan on the 2004 Dodge Intrepid automobile. The wife shall immediately pay
off this loan upon receipt o f the lump sum payment o f $38,000 to husband. If for any
reason the wife does not pay off the 2004 Dodge Intrepid loan, she shall be required
to refinance this loan out o f the husbands name within 60 days from the date of
receipt of the lump sum payment.
Any credit card solely in the wifes name
Any debts or obligations incurred by wife since the date o f separation

Separation Agreement
525VD\GOFF, BREN'RASEPAGMT.090808

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223

1 S 2 S 28B 9 8 8 8 79

XI
SPOUSAL MAINTENANCE
Does not apply*

XII
DEPENDENT CHILDREN
The parties have dependent children o f their marriage, Kolby. The parties have agreed to
a final order parenting plan. The parties agree that this plan is in the best interests o f the children.
This parenting plan is incorporated into this agreement as though fully set forth herein and shall be
enforceable as to the parties upon affixing their signatures thereto whether signed by a judge or court
commissioner.

XIII
CHILD SUPPORT
Child support shall be paid pursuant to the final order o f child support and the Washington
state child support schedule worksheets which are incorporated into this agreement as though fully
set forth herein and shall be enforceable as to the parties upon affixing their signatures thereto
whether signed by a judge or court commissioner.

XIV
AGREEMENT EFFECTIVE AFTER DEATH
Should the death of either party to this agreement occur following execution o f this
agreement, the distribution of property agreed upon, the allocation o f debts agreed upon, and other
obligations agreed upon shall nonetheless be valid and shall be enforceable against the estate o f

Separation Agreement
525\D\GOFF, BRENT\ASEPAGMT.090808

Page

233

1X2X2&89

aesee

either party insofar as applicable law permits.

XV
EXECUTION OF NECESSARY DOCUMENTS
Both parties agree to execute all documents and papers necessary, including any Qualified
Domestic Relations Order, Order on Retirement, Quit Claim Deed, Excise Tax Affidavit,
Vehicle/Boat registrations, to effectuate this agreement and to sign same promptly.

XVI
FINALITY
The parties agree that this arrangement with respect to their property rights and obligations,
subject to the approval o f the court, shall constitute a full and complete settlement o f all their
property rights, and obligations, and neither party will claim, assert or demand o f or against the other
any relief different than is embodied in this agreement, and will not assert or demand that which is
inconsistent or contrary to the terms embodied herein.

XVII
NO INDUCEMENTS
It is understood and agreed that no inducements or promises o f any kind or nature have been
made or extended from either o f the parties to the other which has induced the execution o f this
agreement, and that the same embodies in this entirety the agreement between the parties relative to
the disposition of their property rights and community obligations, and there is no other agreement
existing between them with reference to such property rights and community obligations.
Advise of Legal Counsel. The parties acknowledge and agree that they each have had the

Separation Agreement
525\D\GOFF, BREKRASEPAGMT.090808

Page

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1^ 2^ 2388

88881

opportunity to be represented by their own independent legal counsel o f their choice with respect to
the negotiation and content o f this agreement. Both parties have had the opportunity to have this
agreement reviewed by legal counsel o f their choosing and have been fully advised o f the nature and
scope of this agreement.

Both parties have read this agreement and each party has had the

opportunity to have the contents fully explained to them by legal counsel o f their choosing. Each
party is fully aware o f the contents thereof and the legal effects o f this agreement. The husband is
represented by attorney Hillary A. Holmes, who solely represents the interests o f the husband. The
wife fully understands that attorney Hillary A. Holmes and the law firm o f Campbell, Dille, Barnett,
Smith & Wiley do not represent the interests o f the husband. Both parties are signing this agreement
of their own free will after opportunity to consult with legal counsel.

XVIII
ENFORCEMENT
A.

COSTS OF ENFORCEMENT

In the event that it becomes necessary for either party hereto to enforce any o f the terms or
provisions of this agreement through legal proceedings, then in that event, the prevailing party to any
such litigation shall be entitled to reasonable attorney's fees and costs incurred.

B.

POWER OF ATTORNEY

In full consideration of the mutual agreements contained herein, each spouse will execute any
deeds, bills o f sale, assignments, promissory notes, transfers or other instruments and documents
necessary to complete and effectively carry out the terms o f this agreement. This paragraph shall
also be binding on the heirs, executors, administrators, successors and assigns of each o f the parties.

Separation Agreement
525\D\GOFF, BREN1AASEPAGMT.090808

Page

223

C.

1^2/2009

00082

C LE R IC A L M ISTAK ES

In the event that legal descriptions or account numbers are omitted, incorrect or insufficient,
each party agrees to promptly execute such additional or new documents as may be required to
effectuate the terms o f this agreement.
D. ATTO RN EY FEES

Each party shall be responsible for the payment o f their own attorneys fees and costs.
IN W ITN ESS W H ER EO F, the parties hereto have cause their presents to be executed and

STATE O F W A SHINGTON
C ounty o f P ierce

)
) ss.
)

On this W * day o f
2008, before me, the undersigned, a Notary
Public in and for the State o f Washington, duly commissioned and sworn, personally appeared before
me BRENT D. GOFF, husband, to me known to be the individual described in and who executed
the foregoing instrument, and acknowledged to me that he signed and sealed the said instrument as
his voluntary act and deed, for the uses and purposes therein mentioned.
W ITN ESS my hand and official seal hereto affixed the day and year in this certificate above
written.

OO ; -c ~

Separation Agreement
525\D\GOFF, BRENTVASEPAGMT.090808

o f Washington, residing at
My commission expires ^ r W ' Z D ID-

Page

10

223

STATE O F W A SH IN G TO N
C ounty o f Pierce

1 ^2 ^ 2 0 9 9

00883

)
) ss.
)

On this V \fo day o f


, 2008, before me, the undersigned, a Notary Public in
and for the State o f Washington, duly commissioned and sworn, personally appeared before me
VICTORIA J. GOFF, wife, to me known to be the individual described in and who executed the
foregoing instrument, and acknowledged to me that she signed and sealed the said instrument as her
voluntary act and deed, for the uses and purposes therein mentioned.
W ITN ESS my hand and official seal hereto affixed the day and year in this cettificafeabove
written.

v<SN O k. v

F
a

Printed
NOTARY PU B LIC in and for the State
of Washington, residing at
W
My commission expires
Z O lC l

a*

Separation Agreement
525\D\G0FF, BRENT\ASEPAGMT.090808

Page

11

223

1 S 2 X2 M 9

00084

4
m

county" clerks

DEC 3 1 2008

1 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
8

V I N STOCJC
ASHlNGToN
BKy.E_______
'U C K , cCounty
Clerk
i t / deputy

O F F IC E

pm.

No.

In re the Marriage of:

08- 3- 03291-3

BRENT GOFF

10

Petitioner,
and

11

Residential Time Summary


Report
(RTSR)

VICTORIA GOFF

12
13
14
15
16
17
18
19

Clerks Action Required


Submit with final Parenting Plan, only. This form is for statistical reporting purposes only.
Respondent.

1. The Parenting Plan


The court signed the Parenting Plan on TDatel lL M OP,
It is: [x ] an original order
It was: [x ] by agreement of the parties
[ ] a modification of a prior order
[ ] after a contested hearing or trial
[ ] by default
How many childrent under the parenting plan have the residential schedule summarized in paragraph 2, below?
1
2. Residential Schedule From Part III of the Parenting Plan

20 If the same schedule does not apply to all children, fill out a separate Residential
Time Summary Report for each schedule.
21
22
23

Check the box that


comes closest to
representing the time
spent with each
parent:

24
25
26

[
[
[
[

1
]
]
]

Lk

% of time the children spend


with the Mother

% of time the children spend


with the Father

0%
10%
20%
30%
40%
50%

0%
10%
20%
30%
40% ^
50% S

Res. Time Summary Rpt (RTSR) - Page 1 of 2

CAMPBELL, DILLE, BARNETT,


SMITH & WILEY, P.L.L.C.
ATTORNEYS AT LAW
317 SOUTH MERIDIAN
PUYALLUP, WASHINGTON 98371-0164
(253) 848-3513

223

[ ]

60%

60%

[
[
[
[

70%
80%
90%
100%

70%
80%
90%
100%

3
4

]
]
]
J

/ 2

2 0 9

00085

3. Information about the Parents


5

6
7

Father:

[ ] self-represented [x ] represented by an attorney_____________________

The court found under paragraphs 2.1 and 2 .2 : [ ] does not apply, or
the Father [ ] committed domestic violence
[ ] abused or neglected a child
[ ] has chemical dependency issues
[ ] has mental health issues
___________ \ 1 other:

Mother: [x ] self-represented [ ] represented by an attorney


9

10

11
12
13
14

The court found under paragraphs 2.1 and 2 .2 : [ ] does not apply, or
the Mother
[ ] committed domestic violence
[ ] abused or neglected a child
[ ] has chemical dependency issues
[ ] has mental health issues
f 1 other:

4. Dispute Resolution From Part V. of the Parenting Plan


[ ] Arbitration
action.

Dated this j f r

^ M ediation

[ ] Counseling

[ ] No dispute resolution process except court

day o f ___ txj.o.lu'

. 2008.

T lM t-

15

Hillary A (H ol es, W SBA #26208


O f CampbenTDille, Barnett, Smith & Wiley,
P.L.L.C.
Attorney for Petitioner

16
17
18
19

20
21
22
23
24
25
26

Res. Time Summary Rpt (RTSR) - Page 2 of 2

CAMPBELL, DILLE, BARNETT.


SMITH & WILEY, P.L.L.C.
ATTORNEYS AT LAW
317 SOUTH MERIDIAN
PUYALLUP, WASHINGTON 98371-0164
(253) 848-3513

223

1
2

1/2/2889

08086

Residential Time Summary Report


Percentage Conversion Tool
(Based on 365 days)

3
4
5

6
7

8
9

10
11
12
13
14
15
16
17

Percentage Categories/Time Equivalents


1 - 34%
1 to 3065 hours
1 to 126 days
Less than 18 weeks
Less than 4 m onths
3 5 -4 9 %
3066 to 4379 hours
127 to 182 days
18 to 25 w eeks
A t least 4 m onths but less than 6 m onths
50%
4380 hours
182.5 days
26 w eeks
6 m onths
51 - 65%
4381 to 5780 hours
183 to 240 days
27 to 33 w eeks
M ore than 6 m onths and up to 8 m onths
66 - 99%
5781 to 8759 hours
241 to 364 days
34 to 51 w eeks
M ore than 8 m onths but less than 12 m onths

18
19

20
21
22
23
24
25
26
Prep red by the Administrative Office of the Courts
For i e with the Residential Time Summary Report (RTSR) WPF DR 01.0410
Fori ita tracking purposes pursuant to Chapter 496, Laws of 2007 (2SSB 5470)
July 1007

CAMPBELL, DILLE, BARNETT,


SMITH & . WILEY, P.L.L.C.
ATTORNEYS AT LAW
317 SOUTH MERIDIAN
PUYALLUP. WASHINGTON 98371-0164
(253) 848-3513

223

1^ 2^ 2609

0008?

1
2
filed

M COUNTY CLERK*

fjk.

0 ff \ce

.........................

DEC 31

?.*

5
6

7
Superior Court of Washington
County PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

No.

08- 3- 03291-3

Parenting Plan
Petitioner,

11

and

12

VICTORIA J. GOFF

Final Order (PP)


Respondent
13
14

This parenting plan is the final parenting plan signed by the court pursuant to a decree of
dissolution, legal separation, or declaration concerning validity entered on

15
It Is Ordered, Adjudged and Decreed:
16
I. General Information
17
This parenting plan applies to the following child:

18
Name

Age

Kolby Hunter Goff

19
20

II. Basis for Restrictions

21
22

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the right to make decisions fo r the child.

23

2.1

24
25

Parental Conduct (RCW 26.09.191 (1), (2))


Does not apply.

Parenting Plan (PPP, PPT, PP) Page 1 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

253-845-4941 - Facsimile
FamilySoft FormPAK 2007

223

2.2

5
6

08888

Other Factors (RCW 26.09.191 (3))


Does not apply.

3
4

1 ^2 '''2809

III. Residential Schedule


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 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.

7
8

3.1

There are no children under school age.

9
10

3.2

12

The parties shall share joint residential time with Kolby. Kolby shall reside with
his mother every Monday picking him directly from school or daycare until Wednesday
morning returning Kolby directly to school or daycare. Kolby shall then reside with his
father directly from school or daycare until Friday morning when the father returns Kolby
to school or daycare. The parties shall alternate weekends from Friday after school or
daycare until Monday morning returning them to school or daycare.

13
14
15
3.3

17

Same as Section 3.2

19
3.4

22

24
25

Schedule for Other School Breaks


The child shall reside with the mother father during other school breaks, except for the
following days and times when the child will reside with or be with the other parent:

21

23

Schedule for W inter Vacation


The child shall reside with the mother father during winter vacation, except for the
following days and times when the child will reside with or be with the other parent:

18

20

School Schedule
Upon enrollment in school, the child shall reside equally in the homes of both the
mother and father, except for the following days and times when the child will reside
with or be with the other parent: other:

11

16

Schedule for Children Under School Age

Same as Section 3.2

3.5

Summer Schedule
Upon completion of the school year, the child shall reside with the mother and father,

Parenting Plan (PPP, PPT, PP) Page 2 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsim ile

FamilySoft FormPAK 2007

223

1S 2 S Z G B 9

008B9

except for the following days and times when the child will reside with or be with the
other parent:

2
Other:
3
Same as Section 3.2
4

3.6

Vacation With Parents

5
The schedule for vacation with parents is as follows:
6
The parents shall each be allowed vacations as they agree. In the event there is
no agreement, each parent shall be allowed seven days vacation time with the child
every year during the summer break from school. A parent shall provide 14 days notice
to the other parent of their intention to take a vacation. In the event of a disagreement,
the mothers dates for vacations shall have priority in odd years and the father's dates
shall have priority in even years.

7
8
9
10

3.7

Schedule for Holidays


The residential schedule for the child for the holidays listed below is as follows:

12
13
14
15
16
17
18
19
20

21

New Year's Day


Martin Luther King Day
Presidents' Day
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
Day after Thanksgiving
New Years Eve
Halloween
Valentine's Day

With Mother
(Specify Year
Odd/Even/Every)

With Father
(Specify Year
Odd/Even/Every)

Odd
Every
Every
Odd
Odd
Even
Every
Every
Every
Every
Odd
Even
Even
Odd

Even

Even
Even
Odd
Every
Every
Even
Odd
Odd
Even

For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
23
24

All holiday times shall be as the parties agree. In the event the parties have a
disagreement then holidays shall be from 10:00 a.m. to 8:00 p.m.

Parenting Plan (PPP, PPT, PP) Page 3 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - F acsim ile

FamilySoft FormPAK 2007

223

1/2/2680

80600

Thanksgiving Day shall be evenly shared by the parties. There shall be two
blocks if the parties cannot agree. The blocks shall be from 9:00 a.m. to 3:00 p.m. and
then 3:00 p.m. to 9:00 p.m.

In odd years, the father shall have Kolby on Christmas Eve until his family
festivities end for the night but in no event later than 11:00 p.m. Kolby shall then reside
with his mother from 11:00 p.m. on Christmas Eve through Christmas Day.

3
4

Jn even years, Kolby shall reside with his father until 12:00 noon on Christmas
Day. Kolby shall then reside with his mother until the day after Christmas at 8:00 p.m.

5
6

3.8

Schedule for Special Occasions

7
The residential schedule for the child for the following special occasions (for example,
birthdays) is as follows:

With Mother
(Specify Year
Odd/Even/Every)

10

11

;
[

With Father
(Specify Year
Odd/Even/Every)

Every

13

Mother's Day
Father's Day
Mothers Birthday
Father's Birthday
Kolby's Birthday

14

Other:

15

Special occasions shall be from 12:00 noon until 8:00 p.m. The parties may
agree to any other times.

12

Every
Every
Odd

Every
Even

16
17

3.9

Priorities Under the Residential Schedule


If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the children
are scheduled to be with both parents at the same time, the conflict shall be resolved by
priority being given as follows:
Rank the order of priority, with 1 being given the highest priority:

20
5 school schedule (3.1, 3.2)
4 winter vacation (3.3)
4 school break(s) (3.4)
4 summer schedule (3.5)
3 vacation with parents (3.6)
1 holidays (3.7)
2 special occasions (3.8)

21
22

23
24

Parenting Plan (PPP, PPT, PP) Page 4 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsim ile

FamilySoft FormPAK 2007

223

3.10

1S 2 S 29B 9

60891

Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.

3.11

Transportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.

5
Transportation arrangements for the child between parents shall be as follows:
6
The receiving parent shall provide transportation. If a return it to school or
daycare the following morning, then the parent with whom the child is residing at the
time shall return the child.

7
8
9

3.12

Kolby is scheduled to reside the majority of time with both the mother and the father.
Both the mother and father are designated the custodians of the child for the purposes
of all 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.

10
11
12

13

3.13

16
17
18
19
20
21
22

23
24
25

Other
Does not apply.

14
15

Designation of Custodian

3.14

Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child


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 days' notice, that person must give notice within 5 days after
learning of the move. The notice must contain the information required in RCW
26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A Child).
If the move is within the same school district, 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.
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

Parenting Plan (PPP, PPT, PP) Page 5 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley

317 South Meridian


Puyallup, WA 98371
253-848-3513
253-845-4941 - F acsim ile
FamilySoft FormPAK 2007

223

1/2/2009

and safety.

If information is protected under a court order or the address confidentiality program, it


may be withheld from the notice.

00892

3
4

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.

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.

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.

9
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.

10
11
12

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.

13
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.

14
15
16
17

IV. Decision Making


4.1

18

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 decisions affecting
the health or safety of the child.

19
20
21
22

23
24
25

4.2

Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions:

joint

Non-emergency health care:


Religious upbringing:

joint

joint

Parenting Plan (PPP, PPT, PP) Page 6 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
2 5 3 - 8 4 5 -4 9 4 1 - Facsim ile

FamilySoft FormPAK 2007

223

1
2

4.3

Restrictions in Decision Making


Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.

3
4
5

1 S .2 S 2 B B 9 S 0 0 9 3

V. Dispute Resolution
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 some local court rules or
the provisions o f this plan must, be used before filing a petition to m odify the plan o r a motion
for contempt for failing to follow the plan.

7
8

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 appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or

10
The cost of this process shall be allocated between the parties as follows:
11
50% mother 50% father.
12

13

The dispute resolution process shall be commenced by notifying the other party by
written request.

14

In the dispute resolution process:

15

(a)

Preference shall be given to carrying out this Parenting Plan.

16

(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.

17
18
19
20
21
22

23
24
25

VI. Other Provisions


There are no other provisions.
Parenting Plan (PPP, PPT, PP) Page 7 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371

253-848-3513
253-845-4941 - Facsimile
FamilySoft FonnPAK 2007

223

1
2

08094

VII. Declaration for Proposed Parenting Plan


Does not apply.

3
4

1^2^2889

VIII. Order by the Court


It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and
approved as an order of this court.

5
6

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.

7
8
9

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.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
plan are not affected.

10
11

Before signing the final parenting plan, the court consulted the judicial information
^system and databases, if available, to determine the existence of any information t
proceedings that are relevant to the placement of the children.

12
13
14
15
16
17
18
19
20
21
22
23
24
Parenting Plan (PPP, PPT, PP) Page 8 of 8 Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsim ile

FamilySoft FormPAK 2007

2 2 3 .3 .& Z Z 2 B & 3 m-B&S

Court Cause Xutuber:

THIS CERTIFIES THAT

Goff, Victoria
Has successfully completed the four-hour class

What Children o f Divorce Really Need


Presented by Lesa Swanson, LICSW and Richard MacLeod,LICSW

Dated this 24th day o f June, 2006 at the C itv o f Tacoma, State o f Washington

223

1S ,2 S ;Z 0 0 9

B 0B S 6

Pierce C o unty S u p e rio r C o u rt N um ber:

This

Certificate of gfttenbance
is hereby awarded to

Brent G off
for attending and completing the

impact on Cfnlbteu Seminar


Conducted by Gateways for Youth and Families
In Pierce County, Washington on this
.

1st day o f July, 2006

Wende Wertley/MS

Brad Hoover, MA

Attendees are responsible fo r filing certificate with the appropriate case number

223

08-3-03291-3

31210848

ORSW

i^ 2 '2 0 0 9

0009?

12-31-08

2
3
FILED

IN COUNTY CLERK'S OFFICE

DEC 3 1 2008

PM

a.m,

PIERCE COUNTY, WASHINGTON


^BVIN STOCK. County a*

Superior Court of Washington


County of PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

11

and

12

VICTORIA J. GOFF

No.

08-3-03291-3

Order of Child Support


Petitioner,
Final Order (ORS)
Clerk's Action Required
Respondent

13

I. Judgment Summary

14
15

Does not apply because no attorney's fees or back child support has been ordered.

II. Basis

16
17

2.1

18

Type of Proceeding
This order is entered under a petition for dissolution of marriage, legal separation, or
declaration concerning validity:

19
decree of dissolution, legal separation or a declaration concerning validity.

20
2.2

Child Support Worksheet

21
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.

22
23
24
25

2.3

Other
Does not apply.

Order of Child Support (TMORS, ORS) - Page 1 of 7


WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

Campbell, Dille, Barnett, Smith &


Wiley

317 South Meridian


Puyallup, WA 98371
FamilySoft FormPAK 2007

253-848-3513
253-845-4941 - Facsimile

223

1
2

i '2 / 2 0 0 9

08898

III. Findings and Order


It Is Ordered:
3.1

3.2

Children for Whom Support is Required


Name (first/last)

Age

Kolby Hunter Goff

Parent No. 1
Name (first/last):
Brent Goff
Birth date:
6/4/71
Service Address: [You may list an address that is not your residential address where
you agree to accept legal documents.]
11911 218th Avenue Court East
Bonney Lake, WA 98391

11

The Obligor Parent M ust Immediately File With the Court and the
Washington State Child Support Registry, and Update as Necessary, the
Confidential Information Form Required b y R C W 26.23.050.

12
13

15

The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Promptly A fter any Change in the Information. The Duty to Update the
Information Continues as long as any Support Debt Remains due Under
This Order.

16

Monthly Net Income: $2,255

14

17
18
19

3.3

Parent No. 2
Name (first/last):
Victoria Goff
Birth date:
8/19/72
Service Address: [You may list an address that is not your residential address where
you agree to accept legal documents.]

20
2228 L Street NE #B
Auburn, WA 98002

21
22
23
24
25

The Obligee M ust 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 3.3
Promptly A fter any Change in the Information. The Duty to Update the
Order of Child Support (TMORS, ORS) - Page 2 of 7
WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

FamilySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253- 848-3513
253-845-4941 - Facsimile

223

1 /2 /2 6 0 9

66099

Information Continues as Long as any Monthly Support Remains Due or


any Unpaid Support Debt Remains Due Under This Order.

2
Monthly Net Income: $2,472

3
The obligor may be able to seek reimbursement for day care or special child rearing
expenses not actually incurred. RCW 26.19.080.

4
5

3.4

Service o f 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 o f Written Notice to the
Obligor or Obligee at the Last Address Provided.

7
8

9
10

Service of Process

3.5

Transfer Payment

11

The obligor parent shall pay the following amounts per month for the following child:

12

Name

Amount

13

Kolby Hunter Goff


Total Monthly Transfer Amount

$-0$-0-

14
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 o f a Motor Vehicle m ay Be Denied or m ay Be Suspended if
the Obligor Parent is not in Compliance With This Support Order as
Provided in Chapter 74.20A Revised Code o f Washington.

15
16
17
18
19

3.6

$16.12 per month. (See Worksheet line 15.)

20

21
22

Standard Calculation

3.7

Reasons for Deviation From Standard Calculation


The child support amount ordered in paragraph 3.5 deviates from the standard
calculation for the following reasons:

23
24
25

The child spend(s) a significant amount of time with the parent who is obligated
to make a support transfer payment. The deviation does not result in insufficient
funds in the receiving parent's household to meet the basic needs of the child.
The child does not receive public assistance;
Order of Child Support (TMORS, ORS) - Page 3 of 7
WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

FamilySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

223

1^ 2^ 2889

80180

The factual basis for these reasons is as follows:

The parties are following an equal residential time schedule since May 2006.
The child spends equal amounts of time in the home of both the mother and the father.
The parties may relatively equal incomes in their jobs and no transfer payment is
appropriate. The calculation provides for a residential credit and transfer payment of
$16.12. With the mother providing the health insurance through her employment, there
is no transfer payment that is appropriate.

3
4
5
3.8

Reasons why Request for Deviation Was Denied

6
Does not apply. A deviation was ordered.

7
3.9

Starting Date and Day to Be Paid

Starting Date: 1/1/09

Day(s) of the month


support is due:

3.10
12

13

3.11

3.12

3.13

until the child reaches the age of 18, or as long as the child remain(s) enrolled in high
school, whichever occurs last, except as otherwise provided below in Paragraph 3.14.

20
3.14

25

Post Secondary Educational Support


The right to petition for post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.

22

24

Termination of Support
Support shall be paid:

19

23

Wage Withholding Action


Does not apply.

18

21

How Support Payments Shall Be Made


Does not apply.

16
17

Incremental Payments
Does not apply.

14
15

1st

3.15

Payment for Expenses not Included in the Transfer Payment


The mother shall pay 50% and the father 50% (each parent's proportional share of
income from the Child Support Schedule Worksheet, line 6) of the following expenses

Order of Child Support (TMORS, ORS) - Page 4 of 7


WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FamilySoft FormPAK 2007

253-845-4941 - Facsimile

223

1^ 2/2669

incurred on behalf of the child listed in Paragraph 3.1:

Day care.

Other:

4
5

The parties shall split evenly other mandatory costs for the child such as school
fees, ASB cards, school supplies, sports or extracurricular fees for agreed upon
activities for the child.

Payments shall be made to the provider of the service.

3.16

Periodic Adjustment
Does not apply.

3.17

Income Tax Exemptions

10

Tax exemptions for the child shall be allocated as follows:

11

The mother shall claim the tax exemption in odd years. The father shall claim
the tax exemption in even years.

12

13
14
15
16
17
18
19
20
21
22

23
24
25

0 0181

3.18

Medical Insurance for the Children Listed in Paragraph 3.1


Unless one or more of the alternatives below are checked, each parent shall maintain
or provide health insurance coverage if:
(a) Coverage that can be extended to cover the child is or becomes available to each
parent through employment or is union-related; and
(b) The cost of such coverage for the mother does not exceed $92 (25 percent of
mother's basic child support obligation on Worksheet line 7), and the cost of such
coverage for the father does not exceed $84 (25 percent of father's basic child support
obligation on Worksheet Line ).
The parent(s) shall maintain health insurance coverage, if available for the child 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 twenty days of the
entry of this order to the physical custodian or the Washington State Support Registry if
the parent has been notified or ordered to make payments to the Washington State
Order of Child Support (TMORS, ORS) - Page 5 of 7
Campbell, Dille, Barnett, Smith &
WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132
Wiley
317 South Meridian
Puyallup, WA 98371
253- 848-3513
253-845-4941 - Facsimile
FamilySoft FormPAK 2007

223

1/2^2069

60102

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 parent's
employer or union without further notice to the other parent as provided under Chapter
26.18 RCW.

3
4
5

3.19

E xtra o rd in a ry Health Care Expenses


Unless specifically ordered otherwise, the person receiving support is
responsible for ordinary health care expenses of the children. However, both
parents have an obligation to pay their share of extraordinary health care
expenses. Extraordinary health care expenses mean those monthly medical
expenses that exceed 5% of the basic support obligation from the Child Support
Schedule Worksheet, Line 5.

7
8

9
Each parent shall pay 50% of all uninsured medical expenses incurred for the child. A
parent shall bill the other parent within 30 days of receiving the a bill. A parent shall
reimburse the other parent within 14 days of receiving the bill.

10

11

12

3.20

No back child support is owed at this time.

13
14

3.21

17
18
19

IN

Back Interest

COUNTY C l I r K'S

OEC 3 1 Z008

p*

No back interest is owed at this time.

15
16

Back Child Support

3.22

Other
Does not apply.

Dated: _______ \

Presented by:

20

21
22

___ 26208
Hillary A. Holmes
S ignature^ Party or Lawyer/WSBA No.

23
24

Brent'D. Goff

Victoria Goff
Signature of Party or Lawyd

___

25
Order of Child Support (TMORS, ORS) - Page 6 of 7
WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

FamilySoft FormPAK 2007

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsim ile

223

1 ^ 2 / 2 8 8 9 {88:133

3
4
5
6

7
8
9
10
11
12

13
14
15
16
17
18
19
20
21
22

23
24
25
Order of Child Support (TMORS, ORS) - Page 7 of 7
WPF DR 01.0500 Mandatory (7/2007) - RCW 26.09.175; 26.26.132

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

Puyallup, WA 98371
253-848-3513
FamilySoft FormPAK 2007

253-845-4941 - Facsim ile

223

1A2V2889

count? CORK'S OFFICE

Washington State Child Support Schedule Worksheets


[ ]

Proposed by [ ] Mother [ ] Father


Or, [ ]
Mother: Victoria J. Goff
County: PIERCE

[ ] State of WA [ ] Other
. (CSWP)
Signed by the Judicial/Reviewing Officer (CSW)
Father: Brent D. Goff
Superior Court/OAH Case No.:

____________________ Child Support Order Summary Report___________________


A. The order [ ] does [ ] does not replace a prior court or administrative order.
B. The STANDARD CALCULATION listed on line 15e of the Worksheet for the paying parent is:
$334.38.
C. The TRANSFER AMOUNT ordered by the Court from the Order of Child Support is:
- to be paid by [ ] mother [X] father.__________________________________________
D. The Court deviated (changed) from the STANDARD CALCULATION for the following reasons:
[ ] Does not apply
[ j Nonrecurring income
[ ] Sources of income and tax planning
[ j Split custody
[ ] Residential schedule (including shared custody)
[ ] Children from other relationships for whom the parent owes support
[ ] High debt not voluntarily incurred and high expenses for the child(ren)
[ ] Other (please describe):
E. Income for the Father is [ ] imputed [X] actual income.
Income for the Mother is [ ] imputed [X] actual income.
F. If applicable: [ j All health care, day care and special child rearing expenses are included in the
worksheets in Part II.

Worksheets
Children and Ages: Kolby Hunter Goff, 7

Part I: Basic Child Support Obligation (See Instructions, Page 1)

1. Gross Monthly Income


a.
b.
c.
d.
e.
f.

Wages and Salaries


Interest and Dividend Income
Business Income
Spousal Maintenance Received
Other Income
Total Gross Monthly Income
(add lines 1a through 1e)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 1 o f 5

8184

Mother

Father
$2,990.00

$3,293.00

$2,990.00

$3,293.00

223

2. Monthly Deductions from Gross Income


a. Income Taxes (Federal and State) Tax Year 2008
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes
c. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Pension Plan Payments
f. Spousal Maintenance Paid
g. Normal Business Expenses
h. Total Deductions from Gross Income
(add lines 2a through 2g)
3. Monthly Net Income
(line 1f minus 2h)
4. Combined Monthly Net Income
(Line 3 amounts combined)
(If line 4 is less than $600, skip to line 7.)
5. BASIC CHILD SUPPORT OBLIGATION: Combined^
Kolby Hunter Goff
$701.00

i/2 ^ 2 8 0 5

Father
$339.75
$228.74

88185

Mother
$402.33
$251.91

$167.00

$167.00

$735.49

$821.24

$2,254.51

$2,471.76

r'

$4,726.27

'

ir .S S
rM -U -

$701.00

6. Proportional Share of Income


(Each parent's net income from line 3 divided by line 4)
7. Each Parents Basic Child Support Obligation
(Multiply each number on line 6 by line 5)
(If line 4 is less than $600, enter each parent's support
obligation of $25 per child. Number of children: 1
(Skip to line 15a and enter this amount)

.477

.523

$334.38

$366.62

Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 3)

8. Health Care Expenses


a. Childrens Monthly Health Insurance
b. Children's Uninsured Monthly Health Care
c. Total Monthly Health Care Expenses
(line 8a plus line 8b)
d. Combined Monthly Health Care Expenses
(add fathers and mother's totals from line 8c)
e. Maximum Ordinary Monthly Health Care
(multiply line 5 times .05)
f. Extraordinary Monthly Health Care Expenses
(line 8d minus line 8e., if "0" or negative, enter "0")
9. Day Care and Special Child Rearing Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)

S sJ HisIfF-?.
jr-^'jj'

-V
lH
.j

$35.05

**

e. Total Day Care and Special Expenses


(Add lines 9a through 9d)
10. Combined Monthly Total Day Care and Special Expenses
(Combine amounts on line 9e)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 2 o f 5

u p s

i. 5

223

11. Total Extraordinary Health Care, Day Care, and Special


Expenses (line 8f plus line 10)

122^2089

Mother

Father

12. Each Parent's Obligation for Extraordinary Health Care,


Day Care, and Special Expenses
(Multiply each number on line 6 by line 11)

Part III: Gross Child Support Obligation

13. Gross Child Support Obligation (line 7 plus line 12)

$334.38 |

$366.62

Part IV: Child Support Credits (See Instructions, Page 3)

14. 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 14a through 14c)

Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 4)

15. Standard Calculation


a. Amount from line 7 if line 4 is below
$600. Skip to Part VI.
b. Line 13 minus line 14d, if line 4 is over
$600 (see below if appl.)
Limitation standards adjustments
c. Amount on line 15b adjusted to meet 45%
net income limitation
d. Amount on line 15b adjusted to meet
need Standard limitation
Need Standard Year: 2008
e. Enter the lowest amount of lines 15b, 15c or 15d:

Father

Mother

$334.38

$366.62

$334.38

$366.62

Part VI: Additional Factors for Consideration (See Instructions, Page 4)

16. Household Assets


(List the Present estimated value of all major household assets.)

a.
b.
c.
d.
e.
f.
g.
h.

00186

Father's
Household

Real Estate
Stocks and Bonds
Vehicles
Boats
Pensions/IRAs/Bank Accounts
Cash
Insurance Plans
Other:

17. Household Debt


(List liens against household assets, extraordinary debt.)
a.
b.

c.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 3 of 5

Mothers
Household
.
-

.
.
.
-

223 > i : X 2 ^ 2 e S S

(Household Debt continued)

Mother's
Household

Father's
Household

d.
e.
f.
18. Other Household Income
a. Income Of Current Spouse
(if not the other parent of this action)
Name
Name

b. Income of Other Adults in Household


Name
Name

c. Income of Children (if considered extraordinary)


Name
Name

d. Income from Child Support


Name
Name
e. Income From Assistance Programs
Program
Program

f. Other Income (describe)


-

19. Non-Recurring Income (describe)


-

20. Child Support Paid For Other Children


Name/age:
Name/age:
Name/age:
21. Other Children Living In Each Household
(First names and ages)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 4 of 5

6S18?

223

W SCSS-W orksheets - Mandatory (CSW /CSWP) 7/2007 Page 5 of 5


c:\program files\legalplus\state templates\waworksheet.dtf i:\data\scdir\goff, brent\goff, brent.scp 09/08/2008 10:43 am

1/2/2009

SupportCa/c 2008

00108

2 2 3 i l -y .2 S 2 B B -9 & & 1B 9

Father: Brent D. Goff


Superior Court Cause Number:

Mother: Victoria J. Goff


County: PIERCE

RESIDENTIAL SCHEDULE CREDIT USING FORMULA

16. NAMES OF CHILDREN


17. BASIC SUPPORT
(From Table)

Kolby
$701.00

18. ORDINARY EXPENSES


-

$35.05

c. Ord. Health Care


(Lesser 18a or 18b)

d. Other Ordinary Expenses

e. Total Ordinary Expenses


(Line 18c plus Line 18d)

"

a. Health Care Expenses


b. Max Health Care

19. ADJUSTED BASIC SUPPORT


20. OVERNIGHTS WITH MOTHER
21. % OVERNIGHTS WITH MOTHER
(Line 20 divided by 365)
22. OVERNIGHTS WITH FATHER

**
'

$701.00

182
49.9

183

23. %OVERNIGHTS-FATHER
(Line 22 divided by 365)

50.1

24. MOTHERS CREDIT PROP

.500

25. FATHERS CREDIT PROP

.500

26. MOTHERS CREDIT


(Line 19 times Line 24)

$350.50

27. FATHERS CREDIT


(Line 19 times Line 25)

$350.50

28. OVERNIGHT THRESHOLD SELECTED:

91 NIGHTS

29. TRANSFER PAYMENT BEFORE CREDIT:


30. RESIDENTIAL CREDIT TO Father IS:

$334.38
$350.50

31. TRANSFER PAYMENT AFTER CREDIT:

-$16.12

Client i:\data\sctiirtgoff, brent\goff, brent.scp 09/08/2008 10:43 am


S upportC a/c 2008

22 3 1 / 2^2009

e e i i a

c
FNFCL

12-31-08

2
F l L f D ~ oFF4cE

IN COUNTY CLERKS

DEC 3 1 M M

v/

nn f f lt f K & 'S

5
6

Superior Court of Washington


County of PIERCE

8
9

In re the Marriage of:

10

BRENT D. GOFF

11

and

12

VICTORIA J. GOFF

No.

08-3-03291-3

Petitioner,
Findings of Fact and
Conclusions of Law
(FNFCL)
Respondent

13
I. Basis for Findings

14
15

The findings are based on agreement.

16

II. Findings of Fact

17

Upon the basis of the court record, the court Finds:

18

2.1

19
20

The Petitioner is a resident of the State of Washington.

2.2

21
22

23
24
25

Residency of Petitioner

Notice to the Respondent


The respondent appeared, responded or joined in the petition.

2.3

Basis of Personal Jurisdiction Over the Respondent


The facts below establish personal jurisdiction over the respondent.
The respondent is presently residing in Washington.
The parties lived in Washington during their marriage.

Fndngs of Fact and Cond of Law (FNFCL) - Page 1 of 5


WPF DR 04.0300 (6/2006) - CR 52; RCW 26.09.030;.070(3)

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian

FamilySoft FormPAK 2006

Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

223

2.4

2.5

2.6

2.7

2.8

Community Property
The parties have real or personal community property as set forth in the separation
agreement referenced above.

13
2.9

Separate Property
The parties have separate property as set forth in the separation agreement referenced
above.

15
2.10

17

Community Liabilities
The parties have community liabilities as set forth in the separation agreement
referenced above.

18
19

Separation Contract or Prenuptial Agreement

The separation agreement should be approved.

12

16

Status of Marriage

A written separation agreement was executed on this date and is incorporated herein.

10

14

Status of the Parties

The marriage is irretrievably broken and at least 90 days have elapsed since the date
the petition was filed and since the date the summons was served or the respondent
joined.

11

Date and Place of Marriage

Husband and wife separated on 5/31/06.

00111

The parties were married on 8/29/98 at Auburn, King County, Washington.

4
5

1^2^2009

2.11

Separate Liabilities
The parties have separate liabilities as set forth in the separation agreement referenced
above.

20
21
2.12

Maintenance

22
Maintenance shall be paid as set forth in the separation agreement referenced above.

23
2.13

Continuing Restraining Order

24
Does not apply.

25
Fndngs of Fact and Concl of Law (FNFCL) - Page 2 of 5
WPF DR 04.0300 (6/2006) - CR 52; RCW 26.09.030;.070(3)

FamilySoft FormPAK 2006

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - F acsim ile

223

2.14

2
3

1/2,''20 89

80112

Protection Order
Does not apply.

2.15

Fees and Costs


Attorney fees, other professional fees and costs shall be paid as set forth in the
separation agreement referenced above.

5
6

2.16

The wife is not pregnant.

7
8

2.17

Dependant Children
The child listed below are dependent upon either or both spouses.

Name of
Child
Kolby

10
11
12

Pregnancy

2.18

13

This court has jurisdiction over the child for the reasons set forth below:
This state is the home state of the child because the child 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.

15

2.19

17

2.20

21

23

Child Support
There are children in need of support and child support should be set pursuant to the
Washington State Child Support Schedule. The Order of Child Support signed by the
court on this date and the child support worksheet, which has been approved by the
court, are incorporated by reference in these findings.

20

22

Parenting Plan
The parenting plan signed by the court on this date is approved and incorporated as part
of these findings.

18
19

Mothers/Father's
Names
Victoria Goff
Brent Goff

Jurisdiction Over the Children

14

16

Age
7

2.21

Other:
Does not apply.

24

Fndngs of Fact and Concl of Law (FNFCL) - Page 3 of 5


WPF DR 04.0300 (6/2006) - CR 52; RCW 26.09.030;.070(3)

Campbell, Dille, Barnett, Smith &


Wiley

317 South Meridian


Puyallup, WA 98371
FamilySoft FormPAK 2006

253-848-3513
253-845-4941 - Facsim ile

223

1/2/2089

III. Conclusions of Law

1
2

The court makes the following conclusions of law from the foregoing findings of fact:

3.1

4
5

3.2

3.3

3.4

12

13
14
3.5

Continuing Restraining Order


Does not apply.

16
3.6

Protection Order
Does not apply.

18
19

Disposition
The court should determine the marital status of the parties, make provision for a
parenting plan for any minor child of the marriage, make provision for the support of any
minor child of the marriage entitled to support, consider or approve provision for
maintenance of either spouse, make provision for the disposition of property and
liabilities of the parties, make provision for the allocation of the child as federal tax
exemptions, make provision for any necessary continuing restraining orders, and make
provision for the change of name of any party. The distribution of property and liabilities
as set forth in the decree is fair and equitable.

11

17

Pregnancy
Does not apply.

10

15

Granting a Decree
The parties should be granted a decree.

Jurisdiction
The court has jurisdiction to enter a decree in this matter.

00113

3.7

Attorney Fees and Costs


Attorney fees, other professional fees and costs should be paid as provided in the
separation agreement.

20
21

3.8

rOV3*^
\H c

Other

22
Does not apply.

O tf, *

23
24

Dated:

\if5 i | gd

25
Fndngs of Fact and Concl of Law (FNFCL) - Page 4 of 5
WPF DR 04.0300 (6/2006) - CR 52; RCW 26.09.030;.070(3)

FamilySoft FormPAK 2006

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

223

1/2/2800

08114

Presented by:
2
3
4
5

262Q3
Hillary A^Holmes
Date
Signatuife ofj?arty or Lawyer/WSBA No.

6
7

Brent

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Fndngs of Fact and Concl of Law (FNFCL) - Page 5 of 5


WPF DR 04.0300 (6/2006) - CR 52; RCW 26.09.030;.070(3)

FamilySoft FonnPAK 2006

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsimile

223

1 /2 ^ 2 0 6 9

00115

C O ^

^S S LS g?^

4
5
6
7
8
9

Superior Court of Washington


Coun ty of PIERCE
In re the Marriage of:
BRENT D. GOFF

No.

10

and
11
12

08-3-03291-3

Petitioner,
Decree of Dissolution (DCD)

VICTORIA J. GOFF
Respondent

13

I. Judgment/Order Summaries
14

1.1

Restraining Order Summary:

15
Does not apply.
16
17

1.2

Does not apply.

18
19
20

Real Property Judgment Summary:

1.3

Money Judgment Summary:


Does not apply.

I. Basis

21
22

Findings of Fact and Conclusions of Law have been entered in this case.

III. Decree

23
24

It Is Decreedt hat:

Decree (DCD) (DCLSP) (DCINMG) - Page 1 of 3


WPF DR 04.0400 (6/2006) - RCW 26.09.030; .040; .070 (3)

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FamilySoft FonnPAK 2006

253-845-4941 - Facsim ile

223

3.1

1/2/2009

00116

Status of the Marriage


The marriage of the parties is dissolved.

3.2

Property to be Awarded the Husband


The husband is awarded as his separate property the property set forth in the separation
agreement executed by the parties on this date. The separation agreement is
incorporated by reference as part of this Decree. The prenuptial agreement or, pursuant
to RCW 26.09.070(5), the separation contract is filed with the court.

5
6

3.3

The wife is awarded as her separate property the property set forth in the separation
agreement referenced above.

3.4

10

Unless otherwise provided herein, the husband shall pay all liabilities incurred by him
since the date of separation.

12

3.5

14

Unless otherwise provided herein, the wife shall pay all liabilities incurred by her since
the date of separation.

16
3.6

18

20

3.7

Spousal Maintenance
Spousal maintenance shall be paid as set forth in the separation agreement referenced
above.

22

23

Hold Harmless Provision


Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable attorney's fees
and costs incurred in defending against any attempts to collect an obligation of the other
party.

19

21

Liabilities to be Paid by the Wife


The wife shall pay the community or separate liabilities as set forth in the separation
agreement referenced above.

15

17

Liabilities to be Paid by the Husband


The husband shall pay the community or separate liabilities as set forth in the separation
agreement referenced above.

11

13

Property to be Awarded to the Wife

3.8

Continuing Restraining Order

24
Does not apply.

25
Decree (DCD) (DCLSP) (DCINMG) - Page 2 of 3
WPF DR 04.0400 (6/2006) - RCW 26.09.030; .040; .070 (3)

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513

FimilySoft FormPAK 2006

253-845-4941 - Facsim ile

223

3.9

122'2809

00117

Protection Order
Does not apply.

3.10

Jurisdiction Over the Children


The court has jurisdiction over the children as set forth in the Findings of Fact and
Conclusions of Law.

5
6

3.11

The parties shall comply with the Parenting Plan signed by the court on this date. The
Parenting Plan signed by the court is approved and incorporated as part of this decree.

7
8

3.12

12

Child Support
Child support shall be paid in accordance with the order of child support signed by the
court on this date. This order is incorporated as part of this decree.

10
11

Parenting Plan

3.13

Attorney Fees, Other Professional Fees and Costs


Attorney fees, other professional fees and costs shall be paid as set forth in the separation
agreement referenced above.

13
14
15
16
17
18
19
20
21
22

23
24

Brent D. Goff

25
Decree (DCD) (DCLSP) (DCINMG) - Page 3 of 3
WPF DR 04.0400 (6/2006) - RCW 26.09.030; .040; .070 (3)

FamilySoft FonnPAK 2006

Campbell, Dille, Barnett, Smith &


Wiley
317 South Meridian
Puyallup, WA 98371
253-848-3513
253-845-4941 - Facsim ile

23?

l S 2 S 2d e 9

360190

IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON


BRENT D GOFF

Cause Number:08-3-03291-3
Petitioner(s)

MEMORANDUM OF JOURNAL ENTRY

vs.

Page 1 of 2

VICTORIA J GOFF
Respondent(s)
Judge/Commissioner: ROBYN LINDSAY
Court Reporter: Smart Court
Judicial Assistant/Clerk: Windy Frazier

GOFF, BRENT D

HILLARY ANN HOLMES

Attorney for Plaintiff/Petitioner

GOFF, VICTORIA J
GOFF. KOLBY HUNTER

Proceeding Set: Exparte Action


Proceeding Outcome: Uncontested Resolution
Resolution:

Outcome Date: 12/31/2008 10:29

Clerk's Scomis Code:MTHRG

Proceeding Outcome code:RESHRG


Resolution Outcome code:
Amended Resolution code:

Report run date/time: 12/31/08 10:31 AM


I x c a lc iv il.p b l. d _ d v i l J o u r n a l j r e p o r i j c o v e r

23?

1^2/2889

368191

IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON


BRENT D GOFF

Cause Number: 08-3-03291-3


MEMORANDUM OF
JOURNAL ENTRY

vs.
Page: 2 of 2
Judge/Commissioner:
ROBYN LINDSAY

VICTORIA J GOFF

Judicial Assistant/Clerk: Windy Frazier

MINUTES OF PROCEEDING____________________
Court ReportenSmart Court

Start Date/Time: 12/31/08 10:29 AM

December 31, 2008 10:29 AM


Hillary A. Holmes, Attorney for Petitioner appeared before this Court with final pleadings for
a Dissolution of Marriage with Children.
JIS reviewed and final pleadings are signed as presented.
End Date/Time: 12/31/08 10:30 AM

fu E D

p rteESepS

nT

Otc31im
:RCE CO)JNTV.Cl#f)

JUDGE/COMMISSIONER: ROBYN LINDSAY Year 2008

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
March 13 2014 1:43 PM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN TH E SU PER IO R CO U R T OF TH E STATE O F W A SH IN G TO N
IN AND F O R P IE R C E COUNTY
BRENT D GOFF
Petitioner(s),
vs.

NO. 08-3-03291-3
NOTICE OF INTENT TO WITHDRAW

VICTORIA J GOFF
________________ Respondent(s)
TO: Clerk of the Court
AND TO: VICTORIA J GOFF, Pro Se

NOTICE IS HERBY GIVEN that HILLARY ANN HOLMES intends to withdraw as


attorney for Petitioner/Plaintiff(s) BRENT D GOFF, in the above-entitled action on March 13,
2014. This notice is given pursuant to Civil Rule 71(c) of the Rules for Superior Court.

Withdrawal shall be effective without court order and without the service and filing of any
additional papers unless an objection to the withdrawal is served upon the withdrawing attorney
prior to the date set forth above.

There is no trial date scheduled for this case.

PAGE 1 OF 2
ntiwdsup-0002.pdf

Campbell, Dille, Barnett & Smith, PLLC


317 S Meridian
PUYALLUP, WA 98371-5913
(253) 848-3513

08-3-03291-3

The last known name and address of the parties I have been representing are listed below:
BRENT D GOFF
11911 218TH AVE CT E
BONNEY LAKE, WA 98391

CERTIFICATE OF SERVICE
I certify under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct: That on March 13, 2014, I mailed a copy of this document to the attorney(s) of
record and/or parties at their respective addresses of record.

DATED: March 13, 2014

PAGE 2 OF 2
ntiwdsup-0002.pdf

/s/ HILLARY ANN HOLMES


HILLARY ANN HOLMES, #26208
Attorney for Petitioner/Plaintiff(s)

Campbell, Dille, Barnett & Smith, PLLC


317 S Meridian
PUYALLUP, WA 98371-5913
(253) 848-3513

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 01 2014 11:26 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN TH E SU PER IO R CO U R T OF TH E STATE O F W A SH IN G TO N
IN AND F O R P IE R C E COUNTY
BRENT D GOFF
Petitioner(s),
vs.

NO. 08-3-03291-3
NOTICE OF APPEARANCE

VICTORIA J GOFF
________________ Respondent(s)
TO: Clerk of the Court
AND TO: BRENT D GOFF, KOLBY HUNTER GOFF

PLEASE TAKE NOTICE that Daniel N Cook, appears herein on behalf of the
Respondent(s) VICTORIA J GOFF and requests that all further pleadings and paper, except
original process, be served upon said attorney at the address listed below.

DATED: August 01, 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 OFFICE
PIERCE COUNTY, WASHINGTC

August 01 2014 11:26 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6
7
8
9

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR THE COUNTY OF PIERCE

10
11

In re:

No. 08-3-03291-3

12

BRENT D. GOFF,

Petition for Modification/


Adjustment of Custody Decree/
Parenting Plan/Residential
Schedule
(PTMD)

Petitioner,

13

and

14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.

15
16

1.1

Identification of Requesting Party/Parties

17
Name (first/last) V IC TO R IA G O FF-EN G ELH ART

18

Last known residence (county and state only) PIERCE COUNTY, W A

19
20

1.2

Identification of Other Party/Parties

21

Nam e (first/last) BR ENT GOFF

22

Last known residence (county and state only) PIERCE COUNTY, W A

23
24

1.3

Dependent Children
Name (first/last) KO LBY G O FF

Age 13

25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 1 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;
.260; .270, R C W 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

II. Basis
2

2.1
3
4

This is a petition fo r an order modifying the prior custody decree/parenting


plan/residential schedule/judgm ent establishing parentage and approving my
proposed parenting plan/residential schedule, which is filed with this petition.

5
6

Petition for an Order Modifying Custody Decree/Parenting Plan/Residential


Schedule

2.2

Adequate Cause

7
There is adequate cause for hearing the petition for modification.
8

2.3

Child Support

9
Child support should be modified or established if the court grants the petition to
modify the parenting plan or residential schedule. A child support w orksheet and
financial declaration m ust be filed with this action. RCW 26.09.170.

10
11
12

2.4

Jurisdiction and Venue


The court has proper jurisdiction and venue.

13

The requesting party/parties reside(s) in (county and state only) PIERCE CO, W A .

14

The children reside in (county and state only) PIERCE CO, W A


15
16

The other party/parties reside(s) in (county and state only) PIERCE CO, W A

2.5

Jurisdiction Over Proceeding

17
This court has jurisdiction over this proceeding for the reasons below:
18
This court has exclusive continuing jurisdiction. The court has previously
made a child custody, parenting plan, residential schedule or visitation
determ ination in this m atter and retains jurisdiction under RCW 26.27.211.

19
20
21
22
23
24
25

2.6

Uniform Child Custody Jurisdiction and Enforcement Act Information


Name o f Child
KO LBYG O FF

Parents Name
VIC TO R IA GO FF-ENG ELHART

Parents Name
BRENT GOFF

During the last five years, the children have lived:


in no place other than the state o f W ashington and with no person other
than the requesting party or the other party.
Pet for Mod/Adj Parenting Pin (PTMD) - Page 2 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;
.260; .270, RCW 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
Claims to custody or visitation:
2
The requesting party does not know of any person other than the other
party who has physical custody of, or claims to have custody or visitation
rights to, the children.

3
4

Involvem ent in any other proceeding concerning the children:

The requesting party has not been involved in any other proceeding
regarding the children.

6
7

Other legal proceedings concerning the children:


8

The requesting party does not know of, any other legal proceedings
concerning the children.

10

2.7

The Custody Decree/Parenting Plan/Residential Schedule was entered on (date)


Decem ber 31, 2008, at (county and state) Pierce County, WA. A certified copy of
the Custody Decree/Parenting Plan /Residential Schedule to be modified is filed
with or attached to this petition, if the decree or plan to be modified was entered in
another county or state.

11
12
13
14

Custody Decree or Parenting Plan/Residential Schedule

2.8

Modification Under RCW 26.09.260(1), (2)


The custody decree/parenting plan/residential schedule should be modified
because a substantial change of circum stances has occurred in the circumstances
o f the children or the other party and the modification is in the best interests o f the
children and is necessary to serve the best interests of the children. This request is
based on the factors below.

15
16
17

The children have been integrated into my fam ily with the consent of the
other party in substantial deviation from the decree/parenting
plan/residential schedule.

18
19
20

The childrens environm ent under the custody decree/parenting


plan/residential schedule is detrimental to the childrens physical, mental or
emotional health and the harm likely to be caused by a change in
environm ent is outweighed by the advantage of a change to the children.

21
22

2.9

Modification or Adjustment Under RCW 26.09.260(4) or (8)

23
24
25

The custody decree/parenting plan/residential schedule should be adjusted


because the nonresidential party has voluntarily failed to exercise residential time
for one year or more and the adjustm ent is in the best interest of the children.
Pet for Mod/Adj Parenting Pin (PTMD) - Page 3 of 6

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;


.260; .270, RCW 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

2.10

Adjustments to Residential Provisions Under RCW 26.09.260(5)(a) and (b)

2
Does not apply.
3
4

2.11

Does not apply.

2.12

8
9

Dispute resolution.
Decision making.
Transportation arrangements.

10

12
13
14
15
16
17
18
19

20
21
22
23
24

Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)


The following nonresidential provisions of the parenting plan should be adjusted
because there is a substantial change o f circum stances o f either party or of the
children and the adjustm ent is in the best interest of the children:

11

Adjustments to Residential Provisions Under RCW 26.09.260(5)(c), (7), (9)

2.13

Substantial Change in Circumstance


(You must complete this part if you request a modification or adjustment in
paragraphs 2.8, 2.10, 2.11.1, 2.11.3 or 2.12.)
The requested modification or adjustm ent of the custody decree/parenting
plan/residential schedule is based upon the following substantial change in
circumstance:
In Decem ber 2008 the parties entered a Parenting Plan which provided for
the parents to equally share residential time with the child, Kolby Goff.
As Kolby grew older he and Brent began to experience conflict. Kolby and
Brent got into fights which becam e increasingly severe. At times the fights
were physical and there were som e bruises left on Kolby. The conflict
continued to escalate until it culminated in a m ajor blow-up argum ent in
August 2012. Brent then dropped Kolby off to Victoria Goff-Engelhart and
said he needed a break from Kolby.
Since August 2012 Brent G off has voluntarily relinquished his residential
time with Kolby. The child has resided exclusively with Victoria GoffEngelhart for the last two years.
Since A ugust 2012 Kolby has had in-person visitation with Brent Goff on
only about eight (8) occasions. The 8 in-person visits during the last two
years have lasted no more than 2-5 hours of residential time per visit. The
child has spent no overnights with Brent G off in the last two years. The

25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 4 of 6

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;


.260;.270, RCW 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
father has occasionally, maybe four to six (4-6) times, attended a sporting
event or activity where the child was participating. The father texts or calls
the child approxim ately once per week.

2
3

The parents arrange the daytime only visitation by text or phone call. The
m other has permitted visitation when requested.

4
5

2.14

Protection Order

6
Does not apply.
7

2.15

Servicemembers Civil Relief Act Statement

8
2.15.1 A. Service m em ber status - BRENT GOFF:
9

Is not a service mem ber;

10

B. Factual basis:

11

See the attached Defense Man Power Data C enter Report obtained
from https://w w w .dm dc.osd.m il/scra/ow a/hom e.

12
13

2.15.2 A. Dependent o f a service m em ber status - BRENT GOFF:


14

Is not a dependent o f a resident o f W ashington w ho is on active duty


and is a National Guard m em ber or a Reservist;

15
16

B. Factual basis:

17

The other party failed to respond to a notice to him or her as a


dependent o f a person in M ilitary Service that was served on with this
petition, therefore he or she should be presum ed not a dependent o f a
resident o f W ashington who is on active duty and is a National Guard
m em ber or a Reservist.

18
19

20

2.16

Other

21
22

Does not apply.

/ I l l /

23
24

I I I I I

25

I I I I I
Pet for Mod/Adj Parenting Pin (PTMD) - Page 5 of 6

WPP DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;


.260; .270, RCW 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

III. Relief Requested

2
3
4
5
6
7
8

The moving party requests that the court find that there is adequate cause for hearing
this petition and enter an order modifying the custody decree/parenting plan/residential
schedule in this matter and approving the proposed parenting plan/residential schedule,
which is filed with this petition.
The moving party also requests that the court enter an order establishing child support in
conjunction with the proposed parenting plan/residential schedule. The child support
worksheet and financial declaration are filed with this petition.
Dated July 30, 2014.

FAUBION, REEDER, FRALEY & CO O K P.S.

10

By: DANIEL N. COOK, W SBA #34866


O f Attorneys fo r Respondent

11
12

III. DECLARATION

13
14

I declare under penalty o f perjury under the laws o f the state o f W ashington that I am
the petitioner hereinabove named, that I have m ade the allegations contained in this
petition based upon my first hand knowledge, and therefore believe that they are true.

15
16

Signed at (city)

CaJQ Q Q

(state)

on (date)

/ $ $ /'/'

17
18
19
20
21
22
23
24
25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 6 of 6

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;


.260; .270, RCW 26.26.130(7)(b)
Hoff, Brent and Goff-ENGELHART, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Petition
Plan.doc

for Modification

of Parenting

FAUBION, REEDER, FRALEY &


COOK, P.S.

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

Department of Defense Manpower Data Center

Results as o f : Jul-30-2014 11:25:34 AM


SCRA 3.0

Status Report
Pursuant to Servieemembers Civil Relief Act
Last Name: GOFF
First Name: BRENT
Middle Name:
Active Duty Status As Of: Jul-30-2014
On Active Dutv On Active Duty Status Date
Active Duty Start Date

Active Duty End Date

Status

Service Component

NA

NA

No

NA

This response reflects the individuals' active duty status based on the Active Duty Status Date

Left A ctive Duty Wtthln 367 Days o f Active Duty Status Dale
Active Duty Start Dale

A ctive Duty End Date

Status

Service Component

NA

NA

No

NA

This response reflects where the individual left active duty status within 367 days preceding the Active Dutv Status Date

The Member o r His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale
Order Notification Start Date

Order Notification End Date

Status

Service Component

NA

NA

No

NA

This response reflects whether the individual o r his/her unit has received early notification to report for active duly

Upon searching the data banks o f the D epartment o f D efense M anpow er 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 o f the Uniformed Servfces (Army, Navy, Marine Corps, A ir Force, NOAA, Public Health, and
Coast Guard). This status includes information on a S ervicem em ber or his/her unit receiving notification of future orders to report fo r Active Duty.

y k & y .y h .
Mary M. Snavely-Dixon, Director
D epartment o f Defense - M anpow er Data Center
4800 M ark C enter Drive, Suite 04E25
Arlington, VA 22350

The Defense Manpower Data Center (DMDC) is an organization o f the Department o f Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source o f data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement o f the Servicem em bers Civil Relief A ct (50 USC App. 501 et seq, as am ended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act o f 1940). DMDC has issued hundreds o f thousands o f "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 m anner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections o f the SCRA, you are strongly encouraged to obtain further verification o f the person's status by contacting that person's Service via the
"defenselink.m il" URL: http://www.defenselink.m il/faq/pis/PC 09SLD R .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 o f 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) W hether the individual or his/her unit received early notification to report fo r active
duty on the Active Duty Status Date.

More information on "Active Duty Status"


A ctive duty status as reported in this certificate is defined in accordance with 10 USC 101(d) (1). Prior to 2010 only some o f the active duty periods less
than 30 consecutive days in length were available. In the case o f a m em ber o f the National Guard, this includes service under a call to active service
authorized by the President or the Secretary o f D efense under 32 USC 502(f) fo r purposes o f responding to a national emergency 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 o f the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program A dm inistrator (RPAs). Active Duty status also applies to a Uniformed Service m em ber w ho is an active duty commissioned officer o f the U.S.
Public Health Service or the National O ceanic and A tm ospheric Adm inistration (NOAA Comm issioned Corps).

Coverage Under the SCRA is Broader in Some Cases


Coverage under the SCRA is broader in som e cases and includes some categories o f persons on active duty for purposes o f the SCRA who would not be
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 o f Active Duty are not covered by SCRA, as defined in accordance with 10 USC 101(d)(1).
Many tim es orders are am ended to extend the period o f active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on w hich SCRA protections are based have not been am ended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons w ho have received orders to report fo r active duty or to be inducted, but w ho have not
actually begun active duty or actually reported fo r induction. The Last Date on A ctive Duty entry is im portant because a number of protections o f the SCRA
extend beyond the last dates o f active duty.
Those w ho 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
W ARNING: 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: LCQ4F580I04EQ00

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTO

August 01 2014 11:26 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6

7
8

9
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE

10
11

In re:

12

BRENT D. GOFF,

No. 08-3-03291-3

Petitioner,

13

and

14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

15

Summons(Modification/ Adjustment of
Custody Decree/Parenting Plan/
Residential Schedule)
(SM)

16

To.

Brent Goff

17

1.

An action has been started in the above court requesting that a custody
decree/parenting plan/residential schedule be modified/adjusted. Additional requests, if
any, are stated in the petition, a copy of which is attached to this notice.

2.

You must respond to this notice and petition by serving a copy of your written response
on the person signing this summons and by filing the original with the clerk of the court.
If you do not serve your written response within 20 days (or 60 days if you are served
outside of the state of Washington) after the date this summons was served on you,
exclusive of the day of service, the court may enter an order of default against you, and
the court may, without further notice to you, enter an order regarding adequate cause
and a decree to modify/adjust the custody decree/parenting plan/residential schedule
and providing for other relief requested in the petition. If you serve a notice of
appearance on the undersigned person, you are entitled to notice before an order of
default or a decree may be entered.

3.

The court shall deny the petition unless it finds that adequate cause for hearing the
petition is established, in which case it shall set a date for hearing on an order to show
cause why the requested order or modification should not be granted.

18
19
20
21
22

23
24
25

Summons Mod/Adj Parenting Plan (SM) - Page 1 of 2

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; RCW 26.09.270;


26.10.020
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Summons.docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
Temporary residential placement or custody is being sought. If adequate cause is
found, the court may proceed immediately to hear the motion for temporary
placement/custody or may continue the matter to a later time.

2
3
4

4.

You may file an opposing declaration to show that there is not adequate cause to hold a
full hearing. If you do not file an opposing declaration or respond and the court finds that
adequate cause exists, the court may enter an adequate cause order and an order
modifying/adjusting the custody decree/parenting plan/residential schedule without
notice to you pursuant to RCW 26.09.270.

5.

Your written response to the summons and petition must be on form WPF DRPSCU
07.0200, Response to Petition for Modification/Adjustment of Custody Decree/Parenting
Plan/Residential Schedule. This form may be obtained by contacting the clerk of the
court at the address below, by contacting the Administrative Office of the Courts at (360)
705-5328, or from the Internet at the Washington State Courts homepage:

6
7

8
9

http://www.courts.wa.gov/forms

10
11

6.

If this action has not been filed with the court, you may demand that the petitioner file
this action with the court. If you do so, the demand must be in writing and must be
served upon the person signing this notice. Within 14 days after you serve the demand,
the petitioner must file this action with the court, or the service on you of this notice and
motion will be void.

7.

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

8.

One method of serving a copy of your response on the petitioner is to send it by certified
mail with return receipt requested.

12
13
14
15
16
17

This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state of Washington.
FAUBION, REEDER, FRALEY & COOK, P.S.

18
19

Dated: - 7 / 3 6 / ? o ' /
20

Daniel N. Cook, WSBA 34866


Of Attorneys for Respondent

21
22
23
24

File original of your response with


the clerk of the court at:
Clerk of the Superior Court
Pierce County Court
County-City Building
930 Tacoma Ave. S., Rm 110
Tacoma, WA, 98402

Serve a copy of your response on:


Daniel N. Cook
FAUBION, REEDER, FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Telephone: 253-581-0660

25

Summons Mod/Adj Parenting Plan (SM) - Page 2 of 2

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; RCW 26.09.270;


26.10.020
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Summons.docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC

August 01 2014 11:26 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6
7
8

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

9
10
11
12

No. 08-3-03291-3

In re:

BRENT D. GOFF,
Petitioner,
and

Notice Re: Dependent of a Person


in Military Service
(NTDMP)

13
14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

15
16

Notice. State and federal law provide protections to defendants/respondents who are on

17

active duty in the m ilitary service, and to their dependents. This notice only pertains to a

18

defendant/respondent who is a dependent o f a m em ber o f the National Guard or a military

19

reserve com ponent under a call to active service fo r a period o f more than thirty (30)

20
21

consecutive days. O ther defendants/respondents in m ilitary service also have protections


against default judgm ents not covered by this notice. D ependents of a service m em ber are

22
the service m em bers spouse, a service m em bers m inor child, or an individual for w hom the
23
service m em ber provided m ore than one-half o f the individuals support for one hundred
24
eighty days (180) days im m ediately preceding an application fo r relief.
25
Notice re: Dep. of Person in Military Service (NTDMP)
Page 1 of 2

WPF DRPSCU 01.0185 (6/2006) - Laws of 2006, ch. 80 1(3)


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Notice re Military
Dependentdocx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
One protection provided is the protection against the entry o f a default judgm ent in
2
certain circum stances. If you are the dependent o f a m em ber o f the National Guard or a
3
4
5

m ilitary reserve com ponent under a call to active service fo r a period o f 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 o f your status as such

within tw enty (20) days o f the receipt o f this notice. If you fail to do so, then a court or an

adm inistrative tribunal m ay presum e that you are not a dependent of an active duty member

o f the National Guard or reserves, and proceed with the entry o f an order o f default and/or a

10

default judgm ent w ithout further proof o f your status. Y our response to the plaintiff/petitioner

11
12

or plaintiff/petitioners attorney about your status does not constitute an appearance for
jurisdictional purposes in any pending litigation, a w aiver o f your rights or a response to the

13
petition, com plaint or other application fo r relief that was filed against you.
14
15
16

Dated July 30, 2014.

FAUBION, REEDER, FRALEY & COOK P.S.

17
18

By: DANIEL N. COOK, W S B A #34866


O f Attorneys fo r Petitioner

19
20
21
22
23
24
25
Notice re: Dep. of Person in Military Service (NTDMP) Page 2 of 2

WPF DRPSCU 01.0185 (6/2006) - Laws of 2006, ch. 80 1(3)


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Notice re Military
Dependent.docx

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

5920-1 00th Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC

August 01 2014 11:26 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5

6
7

8
9

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

10
In re:
BRENT D. GOFF,

11

No. 08-3-03291-3
Petitioner,

12
and

Parenting Plan
Proposed (PPP)

13

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.

14
15
16

This parenting plan is proposed by Victoria G off-Engelhart.

17

It Is Ordered, Adjudged and Decreed:

18
19

I. General Information
This parenting plan applies to the following child:

20

Nam e
Kolby G off

21

II. Basis for Restrictions

22
23

Age
13

U nder certain circum stances, as outlined below, the court m ay lim it o r prohibit a
p a re n ts contact with the child and the right to m ake decisions fo r the child.

24

2.1

Parental Conduct (RCW 26.09.191(1), (2))


Does not apply.

Parenting Plan (PPP, PPT, PP) - Page 1 of 8


WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187;. 194
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood WA 98499
253-581-0660

2.2

Other Factors (RCW 26.09.191 (3))

2
The P etitioners involvem ent or conduct may have an adverse effect on the
childs best interests because o f the existence o f the factors which follow:

3
4

Neglect o r substantial nonperform ance o f parenting functions.

III. Residential Schedule

6
7

8
9

10
11

The residential schedule m ust se t forth where the child shall reside each day o f the
year, including provisions fo r holidays, birthdays o f fam ily members, vacations, and
o th e r special occasions, and w hat contact the child shall have with each p a re n t Parents
are encouraged to create a residential schedule that m eets the developm ental needs o f
the child and individual needs o f their family. Paragraphs 3.1 through 3.9 are one way
to write y o u r residential schedule. If you do not use these paragraphs, write in y o u r own
schedule in Paragraph 3.13.

3.1

There are no child under school age.

12
13

3.2

15
16

Up to fo u r hours per visit, with the dates and tim es to be agreed upon by
the parents with at least two w eeks notice to the mother.

17

3.3

20

Sam e as 3.2 above.

21

23
24

Schedule for W inter Vacation


The child shall reside with the m other during w inter vacation, except fo r the
following days and tim es when the child will reside with or be with the other
parent:

19

22

School Schedule
Upon enrollm ent in school, the child shall reside with the mother, except fo r the
following days and tim es when the child will reside with or be with the other
parent:

14

18

Schedule for Child Under School Age

3.4

Schedule for Other School Breaks


The child shall reside with the m other during other school breaks, except fo r the
following days and tim es when the child will reside with or be with the other
parent:
Sam e as 3.2 above.

Parenting Plan (PPP, PPT, PP) - Page 2 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

1
3.5

Summer Schedule

2
Upon com pletion o f the school year, the child shall reside with mother, except for
the following days and tim es when the child will reside with or be with the other
parent:

3
4

Sam e as 3.2 above.

5
6

3.6

Does not apply.

7
8

3.7

9
10

Schedule for Holidays


Does not apply.

3.8

11
12

Vacation With Parents

Schedule for Special Occasions


See 3.2 above.

3.9

Priorities Under the Residential Schedule

13
Does not apply.
14

3.10

Restrictions

15
There are limiting factors in paragraph 2.2, but there are no restrictions on the
Petitioners residential tim e with the child for the following reasons:

16
17

The visitation in by mutual agreem ent o f the parents and will take into
consideration the lengthy lack o f visitation by father and the needs and
w ishes o f Kolby.

18
19

3.11

Transportation Arrangements

20
21

Transportation costs are included in the Child Support W orksheets and/or the
O rder o f Child S upport and should not be included here.

22

Transportation arrangem ents fo r the child, between parents shall be as follows:


The father shall provide transportation.

23
24

3.12

Designation of Custodian
The child named in this parenting plan are scheduled to reside the m ajority o f the
tim e with the m other. This parent is designated the custodian o f the child solely

Parenting Plan (PPP, PPT, PP) - Page 3 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

1
fo r purposes o f all other state and federal statutes which require a designation or
determ ination o f custody. This designation shall not affect either parents rights
and responsibilities under this parenting plan.

2
3
4

3.13

Does not apply.

6
7

8
9

10

11
12
13
14
15
16
17
18
19

20
21
22
23
24

Other

3.14

Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child


This is a sum m ary only. For the full text, please see RCW 26.09.430 through
26.09.480.
If the person with w hom the child resides a m ajority o f the tim e plans to move,
that person shall give notice to every person entitled to court ordered tim e with
the child.
If the move is outside the childs school district, the relocating person m ust 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 m ove in tim e to give 60 days notice, that person m ust
give notice w ithin 5 days after learning o f the move. The notice m ust contain the
information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice o f Intended Relocation o f A Child).
If the move is within the sam e school district, the relocating person m ust provide
actual notice by any reasonable means. A person entitled to tim e with the child
may not object to the m ove but may ask fo r m odification under RCW 26.09.260.
Notice m ay be delayed fo r 21 days if the relocating person is entering a dom estic
violence shelter or is moving to avoid a clear, im m ediate and unreasonable risk
to health and safety.
If inform ation is protected under a court order or the address confidentiality
program, it may be w ithheld from the notice.
A relocating person may ask the court to w aive any notice requirem ents that may
put the health and safety o f a person or a child at risk.
Failure to give the required notice may be grounds fo r sanctions, including
contem pt.
If no objection is filed w ithin 30 days after service o f the notice o f intended
relocation, the relocation w ill be permitted and the proposed revised residential
schedule may be confirm ed.
A person entitled to tim e with a child under a court order can file an objection to
the childs relocation w he the r or not he or she received proper notice.

Parenting Plan (PPP, PPT, PP) - Page 4 of 8


WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181;. 187;. 194
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Pian.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660

1
An objection m ay be filed by using the m andatory pattern form W PF DRPSCU
07.0700, (Objection to Relocation/Petition fo r Modification o f Custody
D ecree/Parenting Plan/Residential Schedule). The objection m ust be served on
all persons entitled to tim e with the child.

2
3

The relocating person shall not move the child during the tim e for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.

4
5

If the objecting person schedules a hearing for a date within 15 days of tim ely
service of the objection, the relocating person shall not move the child before the
hearing unless there is a clear, im m ediate and unreasonable risk to the health or
safety o f a person or a child.

6
7
8

IV. Decision Making

9
10

4.1

11

Each parent shall make decisions regarding the day-to-day care and control of
each child w hile the child is residing with that parent. Regardless of the allocation
o f decision making in this parenting plan, either parent may make em ergency
decisions affecting the health or safety o f the child.

12
13
14

Day-to-Day Decisions

4.2

Major Decisions

15

M ajor decisions regarding each child shall be m ade as follows:

16

Education decisions
N on-em ergency health care
Religious upbringing

17
18
19
20
21
22

4.3

Restrictions in Decision Making


Sole decision m aking shall be ordered to the m other fo r the following reasons:
One parent is opposed to mutual decision making, and such opposition is
reasonably based on the follow ing criteria:
(a)
(b)

23
(c)
24

m other
m other
m other

The existence o f a lim itation under RCW 26.09.191;


The history o f participation o f each parent in decision making
in each o f the areas in RCW 2 6 .0 9 .184(4)(a);
W hether the parents have dem onstrated ability and desire to
cooperate with one another in decision making in each o f the
areas in
RCW 2 6 .0 9 .184(4)(a); and

Parenting Plan (PPP, PPT, PP) - Page 5 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

1
(d)
2

The parents geographic proxim ity to one another, to the


extent that it affects their ability to make tim ely mutual
decisions.

3
4

There are limiting factors in paragraph 2.2, but there are no restrictions on mutual
decision m aking for the following reasons:

V. Dispute Resolution

6
7
8
9
10

The purpose o f this dispute resolution process is to resolve disagreem ents about
carrying out this parenting plan. This dispute resolution process may, and under some
local court rules o r the provisions o f this plan m ust be used before filing a petition to
m odify the plan o r a m otion fo r contem pt fo r failing to follow the plan.
Disputes between the parties, other than child support disputes, shall be
subm itted to (list person or agency):
M ediation by Pierce C ounty C enter fo r Dispute Resolution, if this box is
checked and issues o f dom estic violence or child abuse are present, then
the court finds that the victim requested m ediation, that mediation is
appropriate and that the victim is permitted to have a supporting person
present during the m ediation proceedings, or

11

12
13
14

The cost o f this process shall be allocated between the parties as follows:

15
16
17

50% petitioner 50% respondent.


The dispute resolution process shall be com m enced by notifying the other party
by written request via certified mail:

18

In the dispute resolution process:

19

(a)
(b)

20
21

(c)

22
23
24

(d)

(e)

Preference shall be given to carrying out this Parenting Plan.


Unless an em ergency exists, the parents shall use the designated process
to resolve disputes relating to im plem entation o f the plan, except those
related to financial support.
A w ritten record shall be prepared o f any agreem ent reached in
counseling or m ediation 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 w ithout good reason, the court shall award attorneys' fees and
financial sanctions to the other parent.
The parties have the right o f review from the dispute resolution process to
the superior court.

Parenting Plan (PPP, PPT, PP) Page 6 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

VI. Other Provisions


2
There are the following other provisions.
3
4
5
6
7
8
9
10

11
12
13
14
15
16
17
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Both parties shall allow the child to freely com m unicate 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, o f not less than two calls per w eek at reasonable tim es and for reasonable
durations.
To the greatest extent possible, the parents shall com m unicate with each other
by e-mail. Each parent shall maintain an e-mail account fo r this purpose and
keep the other party inform ed o f their e-mail address.
N either party shall ask the child to make decisions or requests involving the
parenting plan, including changes o f prim ary residence or skipping scheduled
residential tim es. Neither party shall discuss the residential schedule with the
child except fo r plans that have already been agreed to by both parties. Neither
party shall provide inform ation to the child o f the status o f child support payments
or other legal m atters regarding the parties. Neither party shall use the child,
directly or indirectly, to gather inform ation about the other party or takes
m essages to the other party.
Neither parent shall m ake disparaging rem arks about the other parent or any
other rem arks that m ight cause dim inishm ent of the childs respect fo r the other
parent either to the child o r in the presence o f the child, nor shall they allow the
child to make disparaging rem arks about the other parent.

VII. Declaration for Proposed Parenting Plan


(Only sign if this is a proposed parenting plan.) I declare under penalty o f perjury
under the laws o f the state o f W ashington that this plan has been proposed in
good faith and that the statem ents in Part II o f this Plan are true and correct.

20
21
22
23
24

VIII. Order by the Court


It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order o f this court.

Parenting Plan (PPP, PPT, PP) - Page 7 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

1
2

W A R N IN G : Violation o f residential provisions of this order with actual knowledge o f its


term s is punishable by contem pt of court and may be a crim inal offense under RCW
9A .40.060(2) or 9A .40.070(2). Violation of this order may subject a violator to arrest.

3
4
5
6

W hen mutual decision making is designated but cannot be achieved, the parties shall
make a good faith effort to resolve the issue through the dispute resolution process.
If a parent fails to com ply with a provision o f this plan, the other parents obligations
under the plan are not affected.

7
Dated:
8
9
10

Judge/Commissioner
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.

Approved by:
Notice of presentation waived:

11
12

Daniel N. Cook, W S B A #34866


A ttorney fo r R espondent

13
14

Approved and agreed by:


A signature below is actual notice of this order.

, W SBA #_
Attorney fo r Petitioner
Approved and agreed by:
A signature below is actual notice of this order.

15
16
17

Victoria Goff-En

pondent

rent Goff, Petitioner

18
19
20
21
22
23
24

Parenting Plan (PPP, PPT, PP) - Page 8 of 8

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


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Proposed Parenting Plan.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC

August 01 2014 11:26 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5

6
7

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR THE COUNTY OF PIERCE

In re:

No. 08-3-03291-3

10
11
12
13
14

BRENT D. GOFF,

(MTAF)

and

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.

15
16
17
18
19

20

Motion and Declaration for


Temporary Order

Petitioner,

I. Motion
Based on the declaration below, the undersigned moves the court fo r a tem porary order which:
Finds adequate cause fo r hearing this petition.
approves the parenting plan which is proposed by VICTO RIA GOFFENGELHART.
orders child support as determ ined pursuant to the W ashington State child support
statutes.

21
appoints a guardian ad litem on behalf of the m inor child if this matter is contested.
22
23

DATED this 3 d

day o f July 2014.


, P.S.

24
25

Daniel N. Cook, W SBA 34866


A ttorney for Respondent
Mtn/Decl for Temp Ord (MTAF) - Page 1 of 4
WPF DR 04.0100 Mandatory (7/2009) - RCW 26.09.060;. 110;. 120;. 194
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\MotionforTemporaryOrder.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood WA 98499
Phone: (253) 581-0660

1
2
3
4
5

II. Declaration
Tem porary relief is required because:
I, VIC TO RIA GOFF-ENGELHART, make this declaration am the Respondent in this
matter. I am over the age o f 18 and com petent to testify. I make this declaration on the basis

6
o f my personal knowledge in support o f my request for Adequate Cause to modify the
7

Parenting Plan and my Motion for Tem porary Orders.


8
BRENT GOFF and I were form erly married. BRENT and I had one child, KOLBY (now
9

10
11
12

age 13), during our marriage. In Decem ber 2008 BRENT and I entered a Parenting Plan
which provided fo r the parents to equally share residential tim e with KOLBY.
As KOLBY grew older he and BRENT began to experience conflict. KOLBY and

13

BRENT got into fights which becam e increasingly severe. At tim es the fights were physical

14

and there were some bruises left on Kolby. KOLBY and I also had disagreements but they

15

never resulted in physical altercations between KOLBY and me.

16
17
18

KOLBY was struggling. He had a very hard tim e accepting the separation o f his
parents.

BRENT and I both agreed to take him to counseling 4-5 years ago. KOLBY did not

open up to the first counselor.

W e took a break and then tried another counselor about a year

19

or so later. KOLBY did open up som ewhat to the second counselor and mentioned physical
20
abuse by his father. The counselor reported the physical incidents to CPS and thereafter
21
22
23

KOLBY refused to open up to the counselor.


Unfortunately the conflict between BRENT and KOLBY continued to escalate until it

24

culminated in a m ajor blow-up in August 2012. After the blow-up BRENT dropped KOLBY off

25

to me and said he needed a break from KOLBY.


Mtn/Decl for Temp Ord (MTAF) - Page 2 of 4
WPF DR 04.0100 Mandatory (7/2009) - RCW 26.09.060;. 110;. 120;. 194
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\MotionforTemporaryOrder.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660

1
Since August 2012 BRENT has voluntarily relinquished his residential time with KOLBY.
2
The child has resided exclusively with me for the last two years.

Since August 2012 KOLBY

3
4
5

has had in-person visitation with BRENT only about eight (8) times. The 8 in-person visits
during the last two years have lasted no more than 2-5 hours per visit. KOLBY has spent no

overnights with BRENT in the last two years.

tim es in the last two years, attended sporting events or activities where KOLBY was

participating. BRENT and KOLBY also text each other fairly regularly.

10
11

BRENT occasionally, maybe four to six (4-6)

During the last two years the visits have been arranged between BRENT and me by
text or phone call. I have permitted visitation w henever BRENT has requested it. I know that
KOLBY loves his father but KOLBY also harbors a great deal of resentm ent toward his father.

12
I am asking the court to adopt a parenting plan which continues this pattern, although, I would
13

prefer to arrange the visits by email instead of text or phone call.


14

I do not necessarily believe a Guardian Ad Litem is necessary in this case if BRENT


15
16
17

does not contest it. But if BRENT contests this action a Guardian Ad Litem should be
appointed to talk to KOLBY. The initial retainer of $1,125 should be paid by BRENT because

18

he has a greater ability to pay than I do, and because BRENT has paid no child support for the

19

last two years even though KOLBY has resided exclusively with me.

20

The court should set tem porary child support at this time. I have submitted child

21

support worksheets reflecting my income at my last job. I am currently unemployed because I

22

have two other children age 3 and 2 with my current husband. My net income at my last job

23

was about $2,700 per month and daycare for my two youngest children is about $1,600 per

24

month. My three year old is special needs so daycare for her is not optimal. My current
25

husband and I have had me stay at home with these two younger children since the cost of
Mtn/Decl for Temp Ord (MTAF) - Page 3 of 4
WPF DR 04.0100 Mandatory (7/2009) - RCW 26.09.060;. 110; .120;. 194
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\MotionforTemporaryOrder.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660

1
daycare is only m arginally less than my net income was. I am currently looking for w ork that I
2
can do while my husband is home in the evening or on weekends. For child support purposes
3
4
5

6
7

I imputed my income to my last job. I have used the am ount o f $45,000 per year for BRENT
based upon my understanding o f his current income.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF W ASHINGTON TH AT THE FOREGOING IS TRUE AND CORRECT.

8
Signed at (city) 6 4

________ (state) A

on (date)

Z7/ 3 C j / 2 O /C ^

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13
14
15
16
17
18

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 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
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).

19

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25
Mtn/Decl for Temp Ord (MTAF) - Page 4 of 4

WPF DR 04.0100 Mandatory (7/2009) - RCW 26.09.060; .110;. 120;. 194


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Motion for Temporary Order.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
Phone:(253)581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 01 2014 11:26 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

Part II: Basic Child Support Obligation (see Instructions, page 7)


7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.)
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 yes. for each
parent enter the presumptive $50 per child.
b. Is Monthlv Net Income Less Than Self-SuDDort 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 yes. for each parent subtract the self-support
reserve from line 3. If that amount is less than line 7, enter that
amount or the presumptive $50 per child, whichever is greater
9. Each parent's basic child support obligation after calculating
applicable limitations. For each parent, enter the lowest amount
from line 7, 8a - 8c, but not less than the presumptive $50 per
child.

$558.60

$491.40

| $1,216.00

$558.60

$491.40

Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
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
(line 10a plus line 10b)
d.Combined Monthly Health Care Expenses
(line 10c amounts combined)
11. Day Care and Special Expenses
a.Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d.Other Special Expenses (describe)

Father

Mother
$15.00

$15.00
$15.00

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)
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)

$15.00
$7.98

$7.02

Part IV: Gross Child Support Obligation


15. Gross Child Support Obligation (line 9 plus line 14)

$566.58 |

$498.42

PartV: Child Support Credits (see Instructions, page 9)


16. Child Support Credits
a. Monthly Health Care Expenses Credit
b.Day Care and Special Expenses Credit
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 2 o f 5

$15.00
-

c. Other Ordinary Expenses Credit (describe)


-

d.Total Support Credits (add lines 16a through 16c)

$15.00

Part VI: Standard Calculation/Presumptive Transfer Payment (see Instructions, page 9)

17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)

$566.58

$483.42

$1,401.64

$1,233.38

$139.65

$122.85

Part VII: Additional Informational Calculations

18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent)

Part VIII: Additional Factors for Consideration (see Instructions, page 9)


20. Household Assets
Father's
(List the estimated value of all major household assets.)
Household
a. Real Estate
b. Investments
c. Vehicles and Boats
d. Bank Accounts and Cash
e. Retirement Accounts
f. Other: (describe)

Mother's
Household

21. Household Debt


(List liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
22. Other Household Income
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name Jeffrey Engelhart
Name
b. Income Of Other Adults in Household
Name
Name
c. Gross Income from overtime or from second jobs the party
is asking the court to exclude per Instructions, page 8

d. Income Of Child(ren) (if considered extraordinary)


Name
Name
IVSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 3 of 5

.
-

$2,694.00
-

e.Income From Child Support


Name
Name

f. Income From Assistance Programs


Program
Program

5 .Other Income (describe)

23. Non-Recurring Income (describe)


-

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


Child(ren)
Name/age:
Paid [ l Yes f l No
Name/age:
Paid f l Yes f l No
Name/age:
Paid f ] Yes f l No
25. Other Child(ren) Living In Each Household
(First name(s) and age(s))

26.

Father's
Household

Other Factors For Consideration

Basis for Wages and Salaries for Father: $3,750.00


$45,000.00 Annually

Basis for Imputed Income for Mother: $3,266.58


$39,199.00 Annually

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

Mother's
Household
-

Judicial/Reviewing Officer

Date

Worksheet certified by the State of Washington Administrative Office of the Courts.


Photocopying of the worksheet is permitted.

WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 5 o f 5


c: Astate templates\waworksheet.dtf m:\scdata\goff-engelhart\goff-engelhart scp 07/30/2014 10:59 am

SupportCa/c 2014

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
August 01 2014 11:26 AM

1
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6

7
8

Superior Court of Washington


County of PIERCE
In re:

BRENT GOFF

No. 08-3-03291-3

10

Petitioner,

Financial Declaration
[ Petitioner
[X]Respondent
(FNDCLR)

And

11
VICTORIA GOFF-ENGELHART

12

13

Respondent.

Name: Victoria Goff-Engelhart

14
15
16

Date of Birth:
I. Summary of Basic Information

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 3.1g below)

[X]
[ 1

17
18
19
20

$3,620.87
$842.00
$4,462.87
$3,750.00
Unknown

II. Personal Information

2.1

Occupation:

2.2

The highest year of education completed:

2.3

Are you presently employed?


[ ] Yes
[ ] No
a. If yes:
(1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.

(2) When did you start work there? (month/year)

21
22

b. If no:

(1) When did you last work? (month/year)


(2) What were your gross monthly earnings?

23

(3) Why are you presently unemployed?

24
25

Financial Declaration (FNDCLR) - Page 1 of 6


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

SupportCa/c/FD 2014

Faubion, Reeder, Fraley &


Cook, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660

1
III. Income Information

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 Not an
issue this entire section should be completed. (Estimate of other party's income information is
optional.)

5
6

3.1

7
8
9
10
11
12
13
14

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.
Brent Goff
Victoria GoffEngelhart
a.
Imputed Income
$3,266.60
b. Wages and Salaries
$3,750.00
c.
Interest and Dividend Income
d.
Business Income
e. Spousal Maintenance Received
"
From
f.
Other Income
Total
Gross
Monthly
Income
$3,750.00
$3,266.60
g(add lines 3.1a through 3.1e)
h. Actual Gross Income (Year-to-date)

Monthly Deductions From Gross Income


Brent Goff

15
a.
b.
c.
d.
e.
f.
gh.

16
17
18
19

Victoria GoffEngelhart
$275.85
$249.90

Income Taxes
FICA/Self-employment Taxes
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
Pension Plan Payments
Spousal Maintenance Paid
Normal Business Expenses

$348.36
$286.88

Total Deductions from Gross Income

$635.24

$525.75

$3,114.76

$2,740.85

(add lines 3.2a through 3.2g)

20
21

3.3

Monthly Net Income (Line 3.1f minus line 3.2h

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

22
23
24
25
Financial Declaration (FNDCLR) - Page 2 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

SupportCa/c/FD 2014

Faubion, Reeder, Fraley &


Cook, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660

3.4

Miscellaneous Income
a.

3
b.

Brent Goff

Victoria GoffEngelhart

Child support received from other relationships


Name:
Name:
Other miscellaneous income
(list source and amounts)

Income of current spouse


Name: Jeffrey Engelhart
Name:
Income of children
Name:
Name:
Income from assistance programs
Name:
Name:
Non-recurring income
Name:
Name:
Other Income:

5
6
7
8
9
10

$2,694.00

11
12

c.

Total Miscellaneous Income

$2,694.00

(add lines 3.4a through 3.4b)

13

3.5

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:

18

4.1
4.2
4.3

19

4.4

Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:

14
15
16
17

20
21
22
23
24

IV.

V.

Available Assets

Monthly Expense Information

Monthly expenses for myself and 4 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)
Total Housing

$1,542.00

$1,542.00

25
Financial Declaration (FNDCLR) - Page 3 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

SupportCa/c/FD 2014

Faubion, Reeder, Fraley &


Cook, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660

5.2

2
3
4

Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other: Internet

$141.00
$140.00
$260.00
$85.00
$31.00

Total Utilities

$657.00

5
6

5.3

Total Food Supplies

8
9

5.4

10
11
12

5.5

13
14

5.6

17

20
21
22

$50.00

Total Expenses Children

$50.00

Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses

Health care (Omit if fully covered)


Insurance
Uninsured dental, orthodontic, medical, eye
care expenses
Other uninsured health expenses
Total Health Care

18
19

Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses

Total Transportation

15
16

Food and Supplies


Food for 5 persons
Supplies (paper, tobacco, pets)
Meals eaten out
Other:

5.7

Personal Expenses (Not including children)


Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers, magazines, photos
Gifts
Other:
Total Personal Expenses

$592.00
$57.00
$350.00

$999.00

$227.00

$10.00
$237.00

$50.00
$50.00
$27.37

$127.37

23
24
25
Financial Declaration (FNDCLR) - Page 4 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

SupportCa/c/FD 2014

Faubion, Reeder, Fraley &


Cook, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660

5.8

2
3

Miscellaneous Expenses
Life insurance (if not deducted from income)
Other: Netflix
Other:

5.9

5.10 Installment Debts Included in Paragraphs 5.1 Through 5.8


Creditor/Description of Debt
Balance
Umpqua Bank
$15,391.00
Hapco Community Credit
$16,991.00
Union
Homestreet Bank
$229,792.00
$700.00
Dyocytogentics

7
8

$8.50

Total Miscellaneous Expenses

$8.50

$3,620.87

Total Household Expenses

(The total of Paragraphs 5.1 through 5.8)


Month of Last Payment
July 2014
July 2014
July 2014
July 2014

9
10
11
12
13
14
15

5.11

Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Month of
Creditor/Description of Debt
Last Pavment
Balance
Citi Bank Credit Card
$1 1 ,000.00
July 2014
Student Loans
$1 1 ,000.00
Prior attorney fee bill
$2,250.00
July 2014
Jeffs Dad
$5,490.00
Olympic Sports and Spine
$25.00
July 2014
Chase Card
$10,942.00
July 2014
American Express
$10,799.00
July 2014

Amount of
Monthly Payment
$225.00
$50.00
-

$150.00
$216.00
$201.00

16
17
18
19
20
21
22
23
24
25
Financial Declaration (FNDCLR) Page 5 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

Faubion, Reeder, Fraley &


Cook, PS
5920 looth Street SW, #25
Lakewood, WA 98499
( 253) 581-0660

SupportCa/c/FD 2014

1
2
3

Total Monthly Payments for Other Debts and Monthly


Expenses
5.12

$842.00

Total Expenses (Add Paragraphs 5.9 and 5.11)


VI.

$4,462.87

Attorney Fees

4
6.1

Amount paid for attorney fees and costs to date:

6.2

The source of this money was: husband's 401 (k)

6.3

Fees and costs incurred to date:

6.4

Arrangements for attorney fees and costs are: paid in full monthly

6.5

Other:

5
6

$1,000.00

$1,000.00

9
10
11

I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.

Signed at

OJOClQ

[City]

_ [State] on 7 / 5 d / Z o / 9 [Date],

12
13

np\l J A iT I

14

If
Victoria^ (joff-Engelhart
Signature of Declarant

15

The following financial records are being provided to the other party and filed separately with the court.

16

Financial records pertaining to myself:

17
18
19
20
21
22

t r

[ ] Individual [ ] Partnership or Corporate Income Tax returns for


the years:
including all W-2s and schedules;
[ ] Pay stubs for 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 the
case, their attorneys, court personnel and certain state agencies and boards.) See GR 22 (c)(2).

23
24
25
Financial Declaration (FNDCLR) - Page 6 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

Faubion, Reeder, Fraley &


Cook, PS
5920 100th Street SW, #25
Lakewood, WA 98499

Template: c:\program files (x86)\legalplus\state templatestfd.dtf


Client: m:\scdata\goff-engelhart\goff-engelhart.scp 07/30/2014 11:13 am
SupportCa/c/FD 2014

f 2St] ^81-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
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
I N A N D F O R P IE R C E C O U N T Y

August 01 2014 11:28 AM


KEVIN STOCK
COUNTY CLERK

No. 08-3-03291-3
NO: 08-3-03291-3
ORDER SETTING CASE SCHEDULE

BRENT D GOFF
Petitioner(s)

Type of case:

DIC

Estimated Trial (days):

Vs.
VICTORIA J GOFF
Respondent(s)

Track Assignment:

Modification of Custody

Assignment Department:

TOLL

Docket Code:

ORSCS

8/8/2014

Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
Confirmation of Service

8/22/2014

Certificate of Parenting Class - Petitioner's (Must be filed on or before)

10/3/2014

Certificate of Parenting Class - Respondent's (Must be filed on or before)

10/3/2014

Adequate Cause Hearing on Commissioner Calendar to be held. (If this hearing is not held by this date,
petition will be dismissed)

10/3/2014

Set Settlement Conference Date with Judge/Commissioner FRANK CUTHBERTSON

10/3/2014

Requesting Party's Disclosure of Primary Witnesses

12/5/2014
12/26/2014

Non-Requesting Party's Disclosure of Primary Witnesses

1/9/2015

Disclosure of Rebuttal Witnesses

1/23/2015

Deadline for Filing Motion to Adjust Trial Date

Week of 3/6/2015

Settlement Conference (To be held)


Discovery Cutoff

3/13/2015

Exchange of Witness and Exhibit Lists and Documentary Exhibits

3/27/2015
4/13/2015 9:00

Trial

U n le ss o th e rw is e in s tr u c te d , A L L A tto r n e y s /P a r tie s s h a ll r e p o r t to th e t r i a l c o u r t a t 9 :0 0 A M on
th e d a te o f tr ia l.
NOTICE TO PLAINTIFF/PETITION ER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and complaint/
petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule within five (5) court days
of service of the defendant's first response/appearance. If the case has not been filed, but an initial pleading is served, the Case Schedule
shall be served within five (5) court days of filing. See PCLR 3.
NOTICE TO ALL PARTIES
All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to case
scheduling. Compliance with the scheduling rules is mandatory and failure to comply shall result in sanctions appropriate to the
violation. If a statement of arbitrability is filed, PCLR 3 does not apply while the case is in arbitration.

Dated: August 1, 2014

Judge FAMILY COURT - 2


Department TOLL

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 01 2014 11:34 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON


IN AND FOR PIERCE COUNTY

BRENT D GOFF
No. 08-3-03291-3
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

VICTORIA J GOFF
Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: BRENT D GOFF
Address: 11911 218TH AVE CT E BONNEY LAKE, WA 98391

Phone:
Petitioner

Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402

Adequate Cause - Custody


Nature of Hearing: Parenting Plans

Calendar: Show Cause/Family Law

CALENDAR DATE: Thursday, August 28, 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:

August 1, 2014.

Signed:

/s/ Daniel N Cook

NAME:

Daniel N Cook

Phone:

(253) 581-0660

WSBA#:
For:

34866
Attorney for Respondent

ADDRESS: 5920 100th St SW Ste 25


LAKEWOOD, WA 98499-2751

Note for Commissioners Calendar (ntc.rptdesign)

1 of 1

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 01 2014 11:34 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON


IN AND FOR PIERCE COUNTY

BRENT D GOFF
No. 08-3-03291-3
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

VICTORIA J GOFF
Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: BRENT D GOFF
Address: 11911 218TH AVE CT E BONNEY LAKE, WA 98391

Phone:
Petitioner

Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402

Motion - Tem porary O rder


Calendar: Show Cause/Family Law

CALENDAR DATE: Thursday, August 28, 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:

August 1, 2014.

Signed:

/s/ Daniel N Cook

NAME:

Daniel N Cook

Phone:

(253) 581-0660

WSBA#:
For:

34866
Attorney for Respondent

ADDRESS: 5920 100th St SW Ste 25


LAKEWOOD, WA 98499-2751

Note for Commissioners Calendar (ntc.rptdesign)

1 of 1

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC

August 01 2014 11:34 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6

7
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE

9
10

In re:
BRENT D. GOFF,

11

and

No 08-3-03291-3
Petitioner,

12

13
14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
To the Clerk of Court and to: Brent Goff
1.

Please note that the court will be asked to determine if adequate cause exists to
modify/adjust the custody decree/parenting plan/residential schedule as requested in the
petition filed in this case.

2.

A hearing has been set for the following date, time and place.

15
16

Date:
t&ucrLjsJ t 2.% ^01 V
Place: Pierce uountv Superior Court

17
18
19

Time: 9:00 A.M._______________________


Room/Department: TBD________________

3.

This request is based on the declaration in the Petition for Modification/Adjustment of


Custody Decree/Parenting Plan/Residential Schedule [ ] and on the additional declarations
served on the nonmoving party.

4.

You may serve and file a response and opposing declarations prior to the hearing date. If
the court determines that adequate cause for hearing the petition is established by the
declarations, it will set a date for hearing on an order to show cause why the petition should
not be granted.

5.

If you do not file a response to the petition, opposing declarations, or a notice of


appearance, an order may be entered without further notice to you finding you in default
and granting the relief requested in the petition.

20
21
22

Petitioners Notice of
Hearing for Adequate Cause
Determination
(Optional Use)
(NTHG)
[ ] Clerks Action Required

23
24
25

Presented by:
FAUBIQN, -REEDER^F

& COOK, P.S.

J .
Daniel N. Cook, WSBA #34866
Attorney for Petitioner
Petitioners Not of Hrng (Adequate Cause) (NTHG) - Page 1 of 1
WPF DRPSCU 07.0250 (6/2006) - RCW 26.09.260; .270; 26.10.200
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Notice of Hearing re Adequate Cause.doc

FAUBION, REEDER, FRALEY


& COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
August 08 2014

KEVIN ST O
COUNTY C

NO: 08-3-03

2
3
4
5

6
7

8
9
10

11
12
13
14
15
16
17
18
19

20
21
22

IN T H E SU PE R IO R C O U R T O F T H E STA TE O F W A SH IN G TO N
IN AND F O R T H E CO UN TY O F PIE R C E
)
IR E N T D G O FF,
)
Petitioner(s),
) Case No: 08-3-03291-3
)
vs.
) D EC LA R A TIO N O F SER V IC E
)
VICTORIA J G O FF,
) SUM M ONS, PE T IT IO N FO R
) M O D IFIC A T IO N O F
Respondent(s).
) CUSTODY, O R D E R SETTIN G
) CASE SCH ED U LE, N O T IC E re
) M IL IT A R Y D EPEN D EN T,
) PR O PO SED PA R EN TIN G
) PLAN, M O T IO N FO R
) TE M PO R A Y O R D ER , C H ILD
) SU PPO R T W O R K SH E ET S,
) SEA LED FIN A N C IA L SO U RCE
) D O CU M EN TS, FIN A N C IA L
) D EC LA R A TIO N AND N O TE
) F O R C O M M ISS IO N E R S
) C A LEN D A R AND N O T IC E OF
) AC H EA R IN G
)
)
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.

23
24

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:

25
Anderson Investigations, LLC

P.O. Box 7770


Tacoma, WA 98417
Telephone: (253) 301-2240

1
2
3

On the 5th Day O f AUGUST, 2014 at 12:21 PM I served the above-described documents
on BRENT D GOFF, named respondent(s), by then and there:
Personally delivering ONE (1) true and correct copy(ies) thereof to BRENT D GOFF,
PERSONALLY.

4
5

The service address is: Pape Machinery 19808 W est Valley Hwy., Kent, King County,
WA 98032.

Dated this 6th Day O f August, 2014 at Tacoma, Pierce County, WA.

Cost: $70.00

8
9

10

Michael K. Anderson
Private Investigator, WA Lie. #3317
Process Server

11
12
13
14
15
16
17
18
19

20
21

22
23
24
25
A nderson Investigations, LLC

P.O. Box 7770


Tacoma, WA 98417
Telephone: (253)301-2240

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 21 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK

This is to certify that


Victoria Goff Engelhart
Cause # -08-3-03291-3

NO: 08-3-03291-3

attended our 4 hour parenting seminar

Always Parents:
Families in Transition
Presented by

Always Parents

This completes all requirements outlined in


Pierce County Superior Court
Local Rule for Special Proceedings 94.05

Susan L. Wilson, LM HC
Electronically Signed
8/20/2014
Date of attendance

6824 19th St W , PM B 163 U niversity Place, W A 98466 253-267-3622 alw aysparents@ live.com

E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHINGT

August 26 2014 10:21 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5
6
7
8
9

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

10

11
12

In re:

No. 08-3-03291-3

BRENT D. GOFF,

Motion and Declaration for Default


(MTDFL)

Petitioner,

13
and
14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

15
16

I. Motion

17
18

RESPO NDENT, V IC TO R IA G O FF-EN G LEH ARD , m oves the court fo r an order of

19

default against PETITIO NER, BRENT GOFF, o f this action is proper as set forth in the

20

Declaration below.

21
22

Dated

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

23
24
D ANIEL N. COOK, W S B A
O f Attorneys fo r Respondent

25
Mtn/Decl for Default (MTDFL) - Page 1 of 3

WPF DRPSCU 03.0100 Mandatory (06/2012) - CR 55(a); RCW 26.09.030


Goff, Brent and Goff-Englehard, Victoria
\\dcserver\Company Data\CASES1 \Goff-Engelhard\DRAFTS\Pleadings\Motion for

Default.docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
II. Declaration

2
3

2.1

Proper Jurisdiction and Venue


The court has proper jurisdiction and venue pursuant to the allegations o f the petition
at the tim e o f filing.

The R espondent resides in Pierce County, W ashington.


6
7

Petitioner resides in Pierce County, W ashington

2.2

Jurisdiction Over the Other Party


This court has jurisdiction over the other party because:

9
This court has exclusive continuing jurisdiction. The court has previously made
a child custody, parenting plan, residential schedule or visitation determination
in this m atter and retains jurisdiction under RCW 26.27.211.

10
11

12

2.3

Service on Other Party


The other party w as served with (docum ents):

13

o
o
o
o
o
o
o
o
o
o

14
15
16
17
18
19

20

Petition fo r M odification o f Custody


Sum m ons
O rder Setting C ase Schedule
Notice re M ilitary D ependent
Proposed Parenting Plan
Motion fo r Tem porary O rder
Child Support W orksheets
Sealed Financial Source Docum ents
Financial Declaration
Note fo r C om m issioners C alendar on Aug 28, 2014 (Tem porary O rder and
Adequate Cause) and Notice o f A dequate Cause Hearing.

On A ugust 5, 2014, by personal service in the State o f W ashington.

21

2.4

Time Elapsed Since Service on the Other Party

22
The other party was served w ithin the state o f W ashington and more than 20 days
have elapsed since the date o f service.

23
24
25

2.5

Appearance of the Other Party


The other party has failed to appear.

Mtn/Decl for Default (MTDFL) - Page 2 of 3

WPF DRPSCU 03.0100 Mandatory (06/2012) - CR 55(a); RCW 26.09.030


Goff, Brent and Goff-Englehard, Victoria
\\dcserver\Company Data\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Motion for

Default.docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
2

2.6

Servicemembers Civil Relief Act Statement


2.6.1

is not a service member;

B. Factual basis:

See the attached D epartm ent o f Defense M anpower Data C enter Status
Report Pursuant to Servicem em ber Civil R elief A ct (SCRA) obtained
from https://w w w .dm dc.osd.m il/appj/scra/. (You m ust have the persons
social security num ber to search in this site.)

6
7
8

2.6.2

A. D ependent of a service m em ber status -- (name o f other party) BRENT


GOFF:
is not a dependent o f a resident o f W ashington who is on active duty and
is a National Guard m em ber or a Reservist;

10

B. Factual basis:

11

The other party failed to respond to a notice to him or her as a


dependent o f a person in M ilitary Service that was served on July 12,
2012; therefore he or she should be presum ed not a dependent o f a
resident o f W ashington w ho is on active duty and is a National Guard
m em ber or a Reservist.

12
13
14

A. Service m em ber status -- (nam e o f other party) BRENT GOFF

2.7

Other

15
Does not apply.
16
17

I D ECLAR E UNDER PEN ALTY OF PER JUR Y UNDER THE LAW S OF THE STATE OF
W ASH IN G TO N TH A T TH E FO REG O ING IS TRUE A N D CORRECT.

18

Dated this

day o f

19

2013, at Lakewood, W ashington.


FAUBION, R EEDE FLERALEY, & COOK, P.S.

20
21
D ANIEL N. COOK, W S B A #34866
O f A ttorneys fo r Respondent

22
23
24
25
Mtn/Decl for Default (MTDFL) - Page 3 of 3

WPF DRPSCU 03.0100 Mandatory (06/2012) - CR 55(a); RCW 26.09.030


Goff, Brent and Goff-Englehard, Victoria
WdcserveACompany Data\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Motion for

Default.docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

Results as o f : Jul-30-2014 11:25:34 AM

Department o f Defense Manpower Data Center

SCRA 3.0

Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: GOFF
First Name: BRENT
Middle Name:
Active Duty Status As Of: Jul-30-2014
On Active Duty On Active Duty Status Dete
A c t iv e

Duty Start Dale


NA

Active Duty End Date

Status

Service Component

NA

No

NA

This response reflects the individuals' active dutv status based on the Active Duty Status Date

Left Active Duty Within 367 Days of Active Dutv Status Dale
Active Duty Start Date

NA

Active Duty End Date

Status

Service Component

NA

No

NA

This response reflects where the individual left active duly status within 367 days preceding the Active Duty Status Date

The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Dutv Status Date
Order Notification Start Date

Order Notification End Dale

Status

Service Component

NA

NA

Klo

NA

This response reflects whelher the individual or his/her unit has received early notification to report for active duly

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.

Yhi^yh.
Mary M. Snavely-Dixon, Director
Department o f Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350

E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHINGT

August 26 2014 10:30 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR THE COUNTY OF PIERCE

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In re:

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BRENT D. GOFF,

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No. 08-3-03291-3
DECLARATION OF MAILING
Petitioner,

and

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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

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I, Sally DuCharm e, am over the age o f 18, and com petent to testify in the
above entitled case.

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On A ugust 26, 2014, I placed in the U.S. Mail a copy o f the following
docum ents in the above-entitled caption:

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1. Motion fo r Default.

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Said docum ents w ere addressed to:

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Brent Goff
11911 -218th AVE C T E
Bonney Lake WA 98391

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I declare, under the penalty o f perjury and the Laws o f the State o f W ashington,
th a t the foregoing is true and correct.

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DATED

A ugust 26, 2014

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,
_ /i3 a lly D tfth a rm e , Legal A ssistant

Declaration Of Mailing
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Declaration of Mailing.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
Phone: (253) 581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 26 2014 1:07 PM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN TH E SU PER IO R CO U R T OF TH E STATE O F W A SH IN G TO N
IN AND F O R P IE R C E COUNTY
BRENT D GOFF
Petitioner(s),
vs.

N O . 08-3-03291-3
NOTICE OF APPEARANCE

VICTORIA J GOFF
Respondent(s)
TO: Clerk of the Court
AND TO: Daniel N Cook, attorney for Respondent, KOLBY HUNTER GOFF, VICTORIA J
GOFF

PLEASE TAKE NOTICE that HILLARY ANN HOLMES, appears herein on behalf of the
Petitioner/Plaintiff(s) BRENT D GOFF and requests that all further pleadings and paper, except
original process, be served upon said attorney at the address listed below.

DATED: August 26, 2014

ntaprsup-0001.pdf

/s/ HILLARY ANN HOLMES


HILLARY ANN HOLMES, #26208
Attorney for Petitioner/Plaintiff(s)

Campbell, Dille, Barnett & Smith, PLLC


317 S Meridian
PUYALLUP, WA 98371-5913
(253) 848-3513

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 26 2014 1:48 PM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON


IN AND FOR PIERCE COUNTY

BRENT D GOFF
No. 08-3-03291-3
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

VICTORIA J GOFF
Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: HILLARY ANN HOLMES
Address: 317 S Meridian PUYALLUP, WA 98371-5913

Phone: (253) 848-3513


Attorney for Plaintiff/Petitioner

Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402

Motion - Tem porary O rder


Calendar: Show Cause/Family Law

CALENDAR DATE: Thursday, October 02, 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:

August 26, 2014.

Signed:

/s/ Daniel N Cook

NAME:

Daniel N Cook

Phone:

(253) 581-0660

WSBA#:
For:

34866
Attorney for Respondent

ADDRESS: 5920 100th St SW Ste 25


LAKEWOOD, WA 98499-2751

Note for Commissioners Calendar (ntc.rptdesign)

1 of 1

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 26 2014 1:53 PM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON


IN AND FOR PIERCE COUNTY

BRENT D GOFF
No. 08-3-03291-3
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

VICTORIA J GOFF
Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: HILLARY ANN HOLMES
Address: 317 S Meridian PUYALLUP, WA 98371-5913

Phone: (253) 848-3513


Attorney for Plaintiff/Petitioner

Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402

Adequate Cause - Custody


Nature of Hearing: Parenting Plans

Calendar: Show Cause/Family Law

CALENDAR DATE: Thursday, October 02, 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:

August 26, 2014.

Signed:

/s/ Daniel N Cook

NAME:

Daniel N Cook

Phone:

(253) 581-0660

WSBA#:
For:

34866
Attorney for Respondent

ADDRESS: 5920 100th St SW Ste 25


LAKEWOOD, WA 98499-2751

Note for Commissioners Calendar (ntc.rptdesign)

1 of 1

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
September 24 2014 10:28 AM
KEVIN STOCK
COUNTY CLERK

This is to certify that


Brent Goff
Cause # 083032913

NO: 08-3-03291-3

attended our 4 hour parenting seminar

Always Parents:
Families in Transition
Presented by

Always Parents

This completes all requirements outlined in


Pierce County Superior Court
Local Rule for Special Proceedings 94.05

Susan L. Wilson, LM HC
Electronically Signed
9/23/2014
Date of attendance

6824 19th St W , PM B 163 U niversity Place, W A 98466 253-267-3622 alw aysparents@ live.com

E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHIN<

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September 26 2014 9:34

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

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IN T H E SU PE R IO R C O U R T O F W A SH IN G TO N
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IN AND F O R T H E COUNTY O F PIE R C E

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BRENT D. GOFF
P etitioner
And

No. 08-3-03291-3
RESPO N SIV E D EC LA R A TIO N OF
BREN T G O FF

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VICTORIA J. GOFF
R espondent

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CO M ES N O W BRENT GOFF and states under the penalty o f perjury under the laws of
the State o f Washington that the following is true and correct to the best o f his knowledge and
belief.

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R elief R equested.

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1. Continue adequate cause until after mediation or deny adequate cause and require
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mediation.
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2. Require Kolby attend counseling with Jennifer Evinger or another counselor selected

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by father.
3. Allow Jennifer Evinger to expand residential time up to one-half time over the next 90

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days.

Declaration of Brent G off - Page 1


I:\DATAYDVHAH\D\Goff, Brent.002\Arespdecl.092514.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
A ttorneys at Law
South M eridian
Puyallup, W ashington 9 8 3 7 1
317

253- 848-3513
2 5 3 -8 4 5 - 4 9 4 1

facsimile

4. If child support is ordered, order an incremental increase effective September 1st.


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5. Ordering child support in the amount of $269 per month.


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B ackground. The mother and I entered into a joint residential schedule at the end of
2008 for our son Kolby. We shared residential time but we were informal as to dates and times.
There was a certain degree o f flexibleness and a certain degree o f cooperation.
Over time it became quite apparent that our parenting styles were quite different. I was

the disciplinarian for Kolby and the mother was quite indulgent o f Kolby. This meant that I had

rules and boundaries in my household like being respectful, doing chores, completing homework

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assignments, and similar guidelines. The mother is not a disciplinarian at all and Kolby took

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advantage o f this becoming increasingly defiant in both o f our homes.


In addition an estrangement developed between us over time. She moved on into a new

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relationship. I likewise dated. There was a certain resentment o f the mother of my new
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girlfriend which then Kolby felt some allegiance towards his mother. The mother also wanting
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her new relationship to succeed tried restricting contact with me making co-parenting with her
very difficult. Over time this left us having a defiant young man on our hands.
O ppositional Defiance D isorder Diagnosis. The behavior became so extreme that our

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son was diagnosed with oppositional defiance disorder. He went to counseling with Good

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Samaritan Behavioral Health. As I am the strict parent and the mother was completely

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permissive, this did not help our child. It is important to note that children with ODD can then

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progress into conduct disorders which are what we are seeing now and perhaps anti-social

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personality disorders in adulthood based upon reviewing information on this. We did therapy all
together and then alternated sessions and did testing. Eventually the counseling was closed.
Declaration of Brent G off - Page 2
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
A ttorneys at Law
South M eridian
Puyallup, W ashington 9 8 3 7 1
2 5 3 - 8 4 8 -3 5 1 3
2 5 3 - 8 4 5 - 4 9 4 1 facsimile
3 17

Concurrent with this, the mother started triangulating Kolby against me whether
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purposeful at first or simply inadvertent.


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False CPS R e p o rt. There was a false CPS report that I was beating Kolby. I dont know
if his mother was the origin o f this report. I never beat my son. At this time he was 10 so I did

spank him appropriately for discipline. CPS did not find that there was any wrongdoing on my

part. It was the mothers reaction to this that I believe was inappropriate. Instead o f working

with me on discipline and behavioral issues, the mother worked on undermining my relationship

by physically looking at Kolby for bruises upon return from my home. This reinforced the

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thought that somehow I was bad. She also listened to all my conversations on speaker phone.

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Again, this suggested that somehow what I was saying to him was inappropriate and that I

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needed to be listened to. The m others inappropriate behavior included speaking about CPS in
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front o f Kolby.
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B ehavioral P roblem s. A t this time the behavioral problems escalated. Kolby was
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completely unruly. He had no respect for authority. During this same time he was kicked out of
Sumner Parks and Recreation before and after school care program. He then was kicked out two
more times in a two week period for bullying and rude behavior.
At this point, Kolby had no respect for either his mother or I. He was disrespectful and
out o f control at the age o f 10. His other behaviors included spitting, hitting and kicking.
M others R esponse. I tried to work with the mother on solutions. This included not
rewarding bad behavior. This means not accepting invitations to fun events that he was invited
to. This meant limiting his participation in extracurricular activities.

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Diet Issues. I was very concerned about my sons diet. I noticed that sugar was a trigger
Declaration o f Brent G off - Page 3
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CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

for him. His behavior calmed when sugar was removed. His mother allowed him to drink sports
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drinks which were full o f sugars as well as red dye 40 which seemed to influence him. He also
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ate candy bars. I tried to speak to the mother that sugar seemed to be exaggerating the behavior
if not being a trigger for it. Her response was I dont need you telling me how to parent him.
At the same time he was disrespectful to his mom in her face pointing putting his hand in
her face even though he was only 10 .
New B aby. The mother then had a new baby in approximately May 2011. She has a

second child who is a toddler and a stepchild who lives with her and her husband part of the

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time. I think it was a bit o f a challenge for her to parent Kolby, take care o f the new baby and

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two other children, and work her job with the Washington State Department o f Revenue. As a

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result, video games became the parent at his mothers home. He had a Gameboy that was over at
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his moms that he played nonstop. He then obtained another gaming system and played games
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on end even when it affected his grades. Again I tried to work with his mother and she refused.
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F a th e rs E ffo rts. I made extreme efforts. I even called a crisis line to try to document
my sons outbursts at this point in time. As my son wasnt suicidal the crisis line didnt want to
help. His behavior continued to be a challenge.
B reak . There was a blowup with Kolby in August 2012 where he was defiant with me.

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He was very disrespectful and inappropriate. As a result, I wanted to do what was right so I had

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him go to his mothers to think about the unacceptable behavior. I then tried to work with the

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mother to get back onto the residential schedule and there just was no will by the mother.
P arenting C lasses. I signed up for parenting classes taking the Love and Logic

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parenting class. I asked the mother to take these classes with me so we could work together on
Declaration o f Brent G off - Page 4
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
2 5 3 - 8 4 8 -3 5 1 3

253- 845-4941 facsimile

our co-parenting. She refused.


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M eetings. I asked the mother to meet with me to get on the same page as to our
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parenting. She had no will to do this and simply would not meet with me.
W anting to R e tu rn . Kolby then has wanted to live primarily with me but I will not let

him triangulate his mom against his dad. When he has had issues with his mother then he wants

to come running to my house and live primarily with me. I w ont allow that to happen. I have

been steadfast that Kolby and I need to clear up the expectations about behavior. I am not going

to do to his mom what she is trying to do to me by allowing Kolby to play us against each other.

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I dont allow him to run to my house whenever he gets mad at his mom.

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It is an exaggeration to say that our relationship is strained. It is not. However, I am not


going to allow the bad behavior.

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L ack of P aren tin g a t M o th e rs. There is a continuing lack o f parenting at the mothers
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home. He has had major discipline issues in school, school attendance issues, and problems. I
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have reached out to the mother to get together and she simply refuses. I even called her on her
honeymoon and she answered the phone. It is an aside that she would answer her phone to her

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ex-husband on her honeymoon. I knew it was not the appropriate time to get into the discussion

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and I asked her for to call me upon return. She never did. I have reached out to her many other

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times. The bottom line is that she has refused to sit down and meet with these issues. Mediation

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is what needs to happen. She cannot parent Kolby alone.

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School. In the most recent school year Kolby missed 25.83 days of school and had
another 24 tardies. This means he missed approximately 15% o f the school days last year.
Discipline P roblem s. Our sons discipline problems are escalating. During 6th grade he
Declaration o f Brent G off - Page 5
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CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
2 5 3 -8 4 8 -3 5 1 3

253- 845-4941 facsimile

had two major disciplinary incidents. This was a dangerous behavior and insubordination.
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During last school year which was 7th grade he had five incidents which included
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insubordination, harassment with the subset o f intimidation and bullying, disrespect, use of
profanity, and use o f tobacco.
P oor G rades. Our son also has poor grades in school. He is smart but not working up to

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his level. I have attached his report cards. They are on a scale o f 1 through 4. The 4 is

exceeding expectation and 3 is meeting the expectation. The 1 and 2 are below the expectation.

In important core classes he has done exceedingly poorly starting in the six grade year. In

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Language Arts at the end o f the year he failed to meet five o f five expectations. In Math he also
failed to meet expectations in six o f six areas. In Social Studies he failed to meet them in two of

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two. Out o f all his other classes he failed to meet expectations in part except for Young Living
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for one semester and PE. He continued to fail to meet expectations last school year in many
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areas.
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This School Y e ar. Although we are already just at the start o f the school year he is
already missing eight different assignments as o f Monday o f this week. This was basically the

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first two weeks o f school he has already missed eight assignments all in important classes of

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Algebra and Language Arts.

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Involvem ent w ith School. I have continued to make sure that I am involved in his

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school. I have met with teachers. I have met with the Vice Principal. I have had emails with

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various teachers. I am anything but detached or not involved. I have attached a sampling of the

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emails and correspondence. They also indicate other disciplinary issues that arent necessarily

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documented through formal action.


Declaration o f Brent G off - Page 6
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

Visit w ith K olby L ast W eek. I am in regular contact with Kolby. The mother alleges
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that I am somehow estranged but we are extremely friendly. We text and call daily or every
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other day. I talk to him. I talk to him about homework issues. I attend sporting events for him.
I go to meetings at the school. I have separate meetings with the teachers. I am proactive in
trying to see him succeed.
This week he came over. I asked him if he was done with his homework and he said that

he was. It was actually a lie. I knew that he had outstanding homework assignments. After

some prodding he admitted that he had homework. I made him do his homework first before

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dinner or any type o f recreation. He then completed his homework. We had dinner and then we

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hung out playing basketball and talking.

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Kolby Im m atu re . Kolby is an immature 13 year old. He has been given all this power
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by his mom to choose when to come and see me and to run to his mom when he doesnt like the
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discipline in my home. This is wrong. I have asked the mother to get on the same page with me
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as far as parenting classes and counseling.


I would like him to see counselor Jennifer Evinger. She works with adolescents and I

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believe she could work on setting boundaries in my home so that Kolby can get back on his one-

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half time arrangement. At this time the counseling should be between Kolby and I with the

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mother brought in as needed. If there needs to be a separate co-parenting counseling element

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between the mother and I to get on the same page then I am willing to do whatever it takes for

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Kolby to be successful. If we continue down the path that we are with the mother submitting a

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ridiculous parenting plan stating that Kolby can see me when he and his mother agree that he can

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see me, then Kolby will continue to spiral downhill. Kolby wants to see me. He needs to have
Declaration o f Brent G off - Page 7
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CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

1
this a b ility to choose whether to see me or not taken away from him w hich is what his mother

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has empowered him w ith .
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No D etrim ent. The m other alleges in her p e titio n that there was detrim ent by me. There
is absolutely no detrim ent. K o lb y has seen me. He sees me unsupervised. I am involved in his
life . There is absolutely no detrim ent by me whatsoever.

In teg ratio n . There is not integration w ith m y consent. The m other has empowered

K o lb y over m y objection. I have wanted to w ork w ith the m other to get on the same page w ith

parenting and it has not been a p rio rity . She had the demands o f w ork, she ju s t got m arried, has

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tw o other children and a stepchild. A ll o f these things have overshadowed m aking K o lb y the

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p rio rity.

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Jennifer E vinger should be allow ed to expand residential tim e up to one-half tim e over

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the next 90 days. A t this tim e K o lb y should come over at least tw o days a week. I can at least

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ensure his hom ework is com pleted on those tw o days. A fte r tw o weeks it could be expanded to

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overnights w ith further expansion by agreement after m ediation or by the recommendations o f


Jennifer Evinger.

C hild S u p p o rt. This has nothing to do w ith ch ild support in the sense o f me not wanting

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to pay it. I am proposing an in te rim transfer payment o f $269 effective September 1st. We

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agreed on a start date o f September 1st.

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I have included m y W -2 fo r last year as w e ll as m y pay through August. I did not easily
have m y September paychecks but they are not different. That is w hy I am providing m y 2013
pay inform ation. M y year to date pay through 8/20 is $30,852.72. This includes some overtime.

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I divided this by 7.65 m onths to obtain a gross income o f $3,992.51 per m onth. This puts me on
D eclaration o f B rent G o ff - Page 8
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law
317 South Meridian
Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

09: 07

PAGE

PAPE MACHINERY

20657501B4

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pace to make $47.910 this year. I then deducted my deductions and my net incbme is $2,987.
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The mother voluntarily quit her job with the Department of Revenue. She then! was work ing
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limited time because o f having the baby. The State of Washington public disclosure shot' cd her
201.3 income to be $42,918. She provides a paystub for almost that amount which was $'12,863.

She provides no date on it. It appears to be less than a flill year. Her regular rate o f pay wus

$22.69 meaning she was set to make $47,195. This is almost the exact same anfiount o f money I

am making. However, i used to the lower public disclosure for imputing incorhe. This makes

her gross $3,576.50 with a net o f $3,095.81. She claims to have a $15 health insurance payment.

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1 dont have proof o f that but I have provided the credit. This results in a transfer payment of

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$538. An incremental increase would provide for it to be $269. I believe it should be this for the
next six months with preview if Kolbys time is expanded up to one-halftime. :

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Signed at
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J )

ja il up, a w-

on

c f - Z U

. 11.i

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Brent Goff

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Declaration o f Brent Goff - Page 9


I:\DATA\D\HAH\P\Goff, Bront.0Q2\Arespdecl.092514.rtf

CAMPBELL, DIIXK. BARNETT,


& SiVflTH, P J ..L.C.
Attorneys at I .a w
31^ South Meridian
Puyallup, Washington 08371
5 3 - 8 4 8 -3 ms
253"845-494i fn-simile

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S uperior C o u rt of W ashington
C ounty of Pierce

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In re the M atter of:


BRENT GOFF

No. 08-3-03291-3
Petitioner,

and

D ECLA RA TIO N O F R EN EE M.
SM ITH P E R G R 17(2) IN SUPPORT
O F FILIN G FAXED DOCUM ENT

13

VICTORIA GOFF
14

R espondent.

15
16
17
18
19

I hereby declare under penalty o f perjury under the laws o f the State o f Washington, as follows:
1.
The facsimile attached hereto was personally filed with the court by the
undersigned.
2.
I am the assistant to the attorney for Petitioner. I have examined the document to
which this affidavit is attached; have determined that said documents consists o f
pages
including this affidavit page; and that it is complete and legible.

20
21
22
23
24

DECLARATION OF RENEE M. SMITH PER GR 17(2) - Page 1 of 1

CAMPBELL, DILLE, BARNETT,


& SM ITH, P.L.L.C.
Attorneys at Law
3 1 7 South Meridian
Puyallup, Washington 9 8 3 7 1
2 5 3 - 8 4 8 -3 5 1 3
2 5 3 - 8 4 5 - 4 9 4 1 facsimile

09/25/2014

12:00

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14/31

Brent Goff
From:
Sent:
To:
Subject:

Jill Soholt <ji!l_soholt@sumnersd,org>


Thursday, June 12, 2014 8:01 AM
Brent Goff; Vicki Goff
Kolby

Good Morning,
Unfortunately Kolby made some poor choices in his Math/Science block on Tuesday. They arc currently doing
a required AIDS unit in that class and last Tuesday Kolby struggled to behave respectfully and appropriately
during that lesson. On Tuesday he raised his hand, was called on and said, "Can you make time go faster, this
boring." It was reported to his teacher that he was making noises and antagonizing another student to say rude
things, in a. whisper. His teacher asked Kolby to come talk to her and he shrugged hi^ shoulder ; and didn't
come. His friends encouraged him and he yelled, "why?".
I talked to Kolby about this yesterday. Unfortunately it was after he had already had he same class again.
Fortunately he did ok yesterday during that class. Today we are keeping him out o f that lesson due to bis
behavior choices on Tuesday, Also, after reviewing his discipline for the year, we have decided to keep him
from going to our Talent Show assembly on the last day o f school. I told him this this morning and he
responded positively.
If you have any questions, please let me know.

Thank you,
Jill Soholt
SMS Dean of Students
Athletic Coordinator
891-5000

09/25/2014

12:00

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Brent Goff
From:
Sent:

To:
Subject:

Shawna Hunt <shawna_hunt@sumnersd,org>


Friday, March 14, 2014 12:53 PM
KHSMOM2001@hotmail.com; bgoff@papemachinery.com

Kolby

Hello, I wanted to let you know that Kolby is missing some sketchbook assignments! I have tried other things to
get him to do them but I am still missing diem. Could you please remind him to get them done this weekend?
They are sketchbook #3, draw something from your kitchen and #4, draw ice cream, fhey belli need to be
shaded in. They can. be done on any paper.
Thank you,
Shawna Hunt

09/25/2014

12:00

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Brent Goff
From:
Sent:
To:
Subject:

Jill Soholt [jilLsoholt@sumnersd.org]


Friday, December 06, 2013 9:18 AM
Vicki Goff; bgoff@papemachinery.com
Kolby

Hi Vicki and Brent,


I just wanted to update you on a recent issue Kolby had with a girl in PE. The girl fe .1 that he was picking on
her yesterday. He came up to her while they were sitting in their stretching lines and said, "What would you do
if I kicked you in the face?" and then swung his foot toward her. He didn't connect and I don't iLink he intended
to but she didn't like it and felt like he might actually kick her. Later he made fun of he way site was dribbling
the basketball.
She talked to him in my office today about this. He didn't seem to have much remorse. When I asked him if he
felt bad he nodded his head, but it was hard to tell if he really cared.
I am going to keep him out o f PR today. Hopefully this behavior toward her will slot but if it doesn't, T'll let you
know,
Thank you,
Jill Soholt
SMS Dean of Students
253-891-5000

09/25/2014

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Brent Goff
From:
Sent:
To:
Subject:

Jill Soholt [lill_soholt@5umnersd.org]


Tuesday, October 29, 2013 10:50 AM
Vicki Goff; bgoff@papemachinery.com
Kolby

Good Morning,
I just wanted to let you know that T had a serious conversation with Kolby this morning. Apparently he has been
calling students (mostly his friends) names at school like "faggot", "whore", and "slut". Last J-Yiday he called a
girl these names and she came and reported it to us. When T talked to Kolby, be said that it's true that be does
call his friends these names at school. I told him that what he thinks is funny is now liming into potential
bullying and harassment, especially when he's calling girls these names, I told him that all name calling, even to
friends, needs to stop at school. If it continues or there is any retribution toward the student thuL reported, there
would be serious consequences.
Please follow up with Kolby and let him know how serious this is,
Scut.;

f .
i

Thank you,
111! Soholt

SMS Dean o f Students


Athletic Coordinator
shr-5000

Thank

); r' sv .
' V

A '{*'

E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHIN
September 26 2014 9:34

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-1

3
4
5
6
7

Superior Court of Washington


County of PIERCE

8
In re:

BRENT D. GOFF

10
11

No. 08-3-03291-3
Petitioner,

Financial Declaration
[X]Petitioner
[ ]Respondent
(FNDCLR)

And

VICTORIA J. GOFF

12
13

Respondent.

Name: Brent D. Goff

14
15
16

Date of Birth: 6/4/71


I. Summary of Basic Information

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 3.1g below)

[X]

[ ]

17
18
19
20

$2,987.00
$2,798.09
$193.80
$2,991.89
$3,576.50
Unknown

II. Personal Information

2.1

Occupation: Equipment Sale/Rentals

2.2

The highest year of education completed:

2.3

Are you presently employed?


[X] Yes
[ ] No
a. If yes:
(1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.

21
22

(2) When did you start work there? (month/year) 7-1-07


b. If no:

(1) When did you last work? (month/year)

23

(2) What were your gross monthly earnings?

24

(3) Why are you presently unemployed?

25
Financial Declaration (FNDCLR) - Page 1 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

CAMPBELL, DILLE,
BARNETT & SMITH PLLC
317 S. Meridian
Puyallup, WA 98371
253-848-3513

SupportCa/c/FD 2014

1
III. Income Information

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 Not an
issue this entire section should be completed. (Estimate of other party's income information is
optional.)

5
6
7
8
9
10
11
12

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.
Brent Goff
Victoria Goff
a.
Imputed Income
$3,576.50
$3,992.51
b.
Wages and Salaries
c.
Interest and Dividend Income
d.
Business Income
Spousal Maintenance Received
e.
From
f.
Other Income
$3,576.50
$3,992.51
g- Total Gross Monthly Income
(add lines 3.1a through 3.1e)
h. Actual Gross Income (Year-to-date)

13
14

Monthly Deductions From Gross Income

15

a.
b.
c.
d.
e.
f.

16
17
18

9h.

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

Brent Goff
$523.53
$305.43
$16.85
-

$159.70
-

Victoria Goff
$207.09
$273.60
-

$1,005.51

$480.69

$2,987.00

$3,095.81

(add lines 3.2a through 3.2g)

19
20

Monthly Net Income (Line 3.1 f minus line 3.2h

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

21
22
23
24
25
Financial Declaration (FNDCLR) - Page 2 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

CAMPBELL, DILLE,
BARNETT & SMITH PLLC
317 S. Meridian
Puyallup, WA 98371
253-848-3513

SupportCs/c/FD 2014

3.4

2
3

Miscellaneous Income
a.
Child support received from other relationships
Name:
Name:
b. Other miscellaneous income

Brent Goff

Victoria Goff

(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

Total Miscellaneous Income


(add lines 3.4a through 3.4b)

3.5

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:

14
15
16
17
18

IV. Available Assets

4.4

$3,800.00
-

$32,000.00

19
V. Monthly Expense Information

20
21
22
23
24

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)
Total Housing

$1,103.95

$1,103.95

25
Financial Declaration (FNDCLR) - Page 3 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

CAMPBELL, DILLE,
BARNETT & SMITH PLLC
317 S. Meridian
Puyallup, WA 98371
253-848-3513

SupportCa/c/FD 2014

5.2

2
3
4

Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other:

$95.00
$125.00
$95.00
$80.00
$118.14

Total Utilities

$513.14

Food and Supplies


Food for 2 persons
Supplies (paper, tobacco, pets)
Meals eaten out
Other:

$200.00
$65.00
$120.00

Total Food Supplies

$385.00

5
6

5.3

7
8
9

5.4

10
11
12

Total Expenses Children

5.5

13
14

5.6

17

20

21
22

Healthcare (Omit if fully covered)


Insurance
Uninsured dental, orthodontic, medical, eye
care expenses
Other uninsured health expenses
Total Health Care

18
19

Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation

15
16

Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses

5.7

Personal Expenses (Not including children)


Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers, magazines, photos
Gifts
Other:
Total Personal Expenses

$92.00
$220.00

$312.00

$184.00

$20.00
$204.00

$120.00
$50.00
$55.00
$5.00
$50.00
$280.00

23
24
25
Financial Declaration (FNDCLR) - Page 4 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

CAMPBELL, DILLE,
BARNETT & SMITH PLLC
317 S. Meridian
Puyallup, WA 98371
253-848-3513

SupportCa/c/FD 2014

5.8

Miscellaneous Expenses
Life insurance (if not deducted from income)
Other:
Other:

Total Miscellaneous Expenses

5.9

5.10 Installment Debts Included in Paragraphs 5.1 Through 5.8


Creditor/Description of Debt
Balance

Total Household Expenses

$2,798.09

(The total of Paragraphs 5.1 through 5.8)


Month of Last Payment

6
7
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
Balance
Creditor/Description of Debt
9/2014
American Express
$121.96
9/2014
$801.29
Chase Visa
$2,693.89
Sumner Carpet

Amount of
Monthlv Payment
$45.99
$147.81

14
15
16
17
18
19
20
21
22
23
24
25
Financial Declaration (FNDCLR) - Page 5 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)

CAMPBELL, DILLE,
BARNETT & SMITH PLLC
317 S. Meridian
Puyallup, WA 98371
253-848-3513

SupportCa/c/FD 2014

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i
i
1
2
3

$ 193.80

Total Monthly Payments for Other Debts and Monthly


Expenses
5,12

$2,991.89

Total Expenses (Add Paragraphs 5.9 and 5.11)


t

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:

5
6

tt-

9
10
11

1declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
/i
Signed at

s j a lU

jf - _ [City] U } $ 1

[State] on

9' ' L

b - H

[date].

12
13
14

0
Brent D. Goff
Signature of Declarant

15

The following financial records are being provided to the other party and filed separatelyjwith the court.

16

Financial records pertaining to myself:

17
18
19
20
21
22

J f r

[ ] Individual [ ] Partnership or Corporate Income Tax returns for


the years;
Including all W-2s and schedules;
[ ] Pay stubs for the dates of

[ ] Other:

Do not attach these financial records to the financial declaration. These financial fecPrds should
be served on the other party and filed with the court separately using the sealed financial source
documents cover sheet (WPP 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.) Seel GR 22 (c)(2).

23
24
25
Financial Declaration (FNDCLR) - Page 6 of S
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
TartiplHte: rWalatsertirtpoff, branMri edited Off

Client: I:\dal9\st;dlr\gaff, brenitgoir, Dront.IMp09(25/201404:17pm


Support Ca/c/FD 2014

CAMPBELL, DILLE,
BARNfc lT & SMITH PLLC
i317 S. Meridian
Puyallup, WA 98371
i 253H548-35 13

1
2
3
4
5
6
7
8

S uperio r C o u rt of W ashington
C ounty of Pierce

9
10
11
12

In re the M atter of:


BRENT GOFF

No. 08-3-03291-3
Petitioner,

and

D EC LA R A TIO N O F R EN EE M.
SM ITH PE R G R 17(2) IN SUPPORT
O F FILIN G FAXED DOCUM ENT

13

VICTORIA GOFF
14

R espondent.

15
16
17
18
19

20

I hereby declare under penalty of perjury under the laws o f the State of Washington, as follows:
1.
The facsimile attached hereto was personally filed with the court by the
undersigned.
2.
I am the assistant to the attorney for Petitioner. I have examined the document to
which this affidavit is attached; have determined that said documents consists o f ~7
pages
including this affidavit page; and that it is complete and legible.
DATED this 26th day of September, 2014.

21
22
23

11Renee M. Smith
o f Campbell, Dille, Barnett & Smith, P.L.L.C.

24

DECLARATION OF RENEE M. SMITH PER GR 17(2) - Page 1 of 1

CAMPBELL, DILLE, BARNETT,


& SM ITH, P.L.L.C.
A ttorneys at Law
South M eridian
Puyallup, W ashington 9 8 3 7 1
2 5 3 - 8 4 8 -3 5 1 3
2 5 3 - 8 4 5 - 4 9 4 1 facsimile
3 17

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
September 26 2014 9:34 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

Part II: Basic Child Support Obligation (see Instructions, page 7)


7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.)
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 Monthlv Net Income Less Than Self-Support Reserve? If ves.
for that parent enter the presumptive $50 per child.
c. Is Monthlv Net Income equal to or more than Self-SuDDort
Reserve? If yes. for each parent subtract the self-support
reserve from line 3. If that amount is less than line 7, enter that
amount or the presumptive $50 per child, whichever is greater.
9. Each parent's basic child support obligation after calculating
applicable limitations. For each parent, enter the lowest amount
from line 7, 8a - 8c, but not less than the presumptive $50 per
child.

$530.77

$550.23

[ $ 1 ,216.00

$550.23

$530.77

Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
Mother
$15.00

Father

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
(line 10a plus line 10b)
d. Combined Monthly Health Care Expenses
(line 10c amounts combined)
11. Day Care and Special Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)

$15.00

$15.00

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)
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)

$15.00
$7.36

$7.64

Part IV: Gross Child Support Obligation

15. Gross Child Support Obligation (line 9 plus line 14)

$538.13 |

$557.87

PartV: Child Support Credits (see Instructions, page 9)

16. Child Support Credits


a. Monthly Health Care Expenses Credit
b.Day Care and Special Expenses Credit
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 2 of 5

$15.00

c. Other Ordinary Expenses Credit (describe)


-

d. Total Support Credits (add lines 16a through 16c)

$15.00

Part VI: Standard Calculation/Presumptive Transfer Payment (see Instructions, page 9)

17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)

$538.13

$542.87

$1,344.15

$1,393.11

$132.69

$137.56

Part VII: Additional Informational Calculations

18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent)

Part VIII: Additional Factors for Consideration (see Instructions, page 9)

20. Household Assets


(List the estimated value of all major household assets.)
a. Real Estate
b. Investments
c. Vehicles and Boats
d. Bank Accounts and Cash
e. Retirement Accounts
f. Other: (describe)

Father's
Household
!

21. Household Debt


(List liens against household assets, extraordinary debt.)
a.
b
c.
d
e.
f.
22. Other Household Income
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name
Name
b. Income Of Other Adults in Household
Name
Name
c. Gross Income from overtime or from second jobs the party
is asking the court to exclude per Instructions, page 8

d. Income Of Child(ren) (if considered extraordinary)


Name
Name
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 3 o f 5

Mother's
Household
j

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 [ ] Yes [ ] 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

09/26/2014

09:07

2065750164

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PAGE

PAPE MACHINERY

Date

Worksheet certified by the State of Washington Administrative Office of the Courts.


Photocopying of the worksheet is permitted.

WSCSS-Worksheets- Mandatory (CSW/CSWP) 07/2013 Page 5 of 5

SuppottCa/c * 201-1

c; '.stale templatostovaworksheeldtf i:\cl3Ut\scdlr\goff. brent\gDff, brent SCp Q9/24/2014 00:97 am

02/04

2
3
4
5
6
7
8

S uperio r C o u rt of W ashington
C ounty of Pierce

9
10

11

12

In re the M atter of:


BRENT GOFF

No. 08-3-03291-3
Petitioner,

and

D ECLA RA TIO N O F R EN EE M.
SM ITH P E R G R 17(2) IN SUPPORT
O F FILIN G FAXED DOCUM ENT

13

VICTORIA GOFF
14

R espondent.

15
16
17
18
19

I hereby declare under penalty o f perjury under the laws o f the State o f Washington, as follows:
1.
The facsimile attached hereto was personally filed with the court by the
undersigned.
2.
I am the assistant to the attorney for Petitioner. 1 have examined the/document to
which this affidavit is attached; have determined that said documents consists o f ( jy pages
including this affidavit page; and that it is complete and legible.

20
21
22
23
24

DECLARATION OF RENEE M. SMITH PER GR 17(2) - Page 1 of 1

CAMPBELL, DILLE, BARNETT,


& SM ITH, P.L.L.C.
A ttorneys at Law
South M eridian
Puyallup, W ashington 9 8 3 7 1
2 5 3 - 8 4 8 -3 5 1 3
2 5 3 - 8 4 5 - 4 9 4 1 facsimile
3 17

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC

September 30 2014 9:49 AM

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
4
5

6
7
8
9

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

10
In re:

No. 08-3-03291-3

12

BRENT D. GOFF,

REPLY DECLARATION OF
VICTORIA GOFF-ENGLEHARD

13

and

14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

11

15
16
17

Petitioner,

I, VIC TO RIA GO FF-ENGLEHARD, make this declaration on the basis of my


personal knowledge and in reply to the Response Declaration of BRENT GOFF dated

18
S eptem ber 26, 2014.
19

BR ENT exaggerates and inaccurately blam es KO LBYS struggles on me. BRENT


20
falsely claim s I am not a disciplinarian.

B R E N Ts entire declaration is a character

21
22
23
24

assassination o f me and my parenting.

Y et BRENT openly adm its he left KOLBY in my

care with virtually no in-person contact with BRENT fo r two years.


ludicrous.

His position is

If I w as as poor o f a parent as BRENT now claim s there is no way he would

25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 1 of 13

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G offE n g le h a rd .d o c

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
have left KOLBY with m e fo r two years.

BRENT w as happy for me to care fo r KOLBY

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100% o f the tim e but he did not take this back to court because he knew he would be
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4

required to pay child support if he did.


There is no w ay that BR ENT would have left KO LBY in my house if I had no

discipline, no rules, no chores or if hom ework did not get done.

great deal.

hitting KOLBY.

respectful, do chores and com plete hom ework.

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not respectful, does not do his chores, or does not com plete his hom ework in my

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I discipline KO LBY a

The difference is BR ENT does not believe it is discipline unless it involves


BRENT claim s his household is superior because he makes KOLBY be
S o d o I. The difference is if KOLBY is

household, he loses privileges or is grounded. I have a progressive system to determ ine


which privileges to take or how long or severe a grounding is. But BRENT has no such

13

progressive system . If KO LBY does not do w hat BR ENT wants he is im m ediately totally
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grounded.

If the problem escalates from there BRENT creates a physical confrontation

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with KOLBY, under the guise o f spanking.

This totalitarian rule sim ply did not w ork as

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KO BLY got older and rebelled m ore forcefully.


There is also a drastic difference in attitude.

BRENT treats KOLBY like a robot

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who m ust do and say w hatever BRENT thinks is appropriate. BRENT does not allow any

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room fo r KOLBY to be im perfect, im m ature or even have emotions.

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constantly berating K O LBY fo r even the sm allest things.

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put-downs from BR ENT eventually snowball into bigger issues and BRENT then has to hit

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(spank) KOLBY.
BRENT.

So BR ENT is

These constant criticism s and

But there is no love or understanding in KO LBYs relationship with

KOLBY loves his father and w ants to spend short periods o f tim e with him but

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 2 of 13
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G o ffE n g le h a rd .d o c

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
when BRENT tries to make him into a robot and then spanks him when he does not
2
KO LBY sim ply cannot function in that environm ent.
3
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5

There is also no w ay BRENT would have been content to leave KOLBY with me
with virtually no in-person contact with him if KO LBY was doing as poorly in school as

Significantly, BRENT did not submit KOLBYs m o s t recent report

BR ENT infers.

card from the end of 2013/2014. BRENT subm itted the 2012/2013 report card which

was not a good one.

KOLBY.

10

incentives and consequences fo r poor school perform ance. This is discipline. By the end

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But the 2013/2014 report card showed am azing im provem ent by

I talked to KO LBY after his poor year in 2012/2013 and we im plem ented

o f 2013/2014 he was meeting or exceeding grade standards in alm ost all areas, including
core classes. KOLBY had 3s and 4s ( M eets or Exceeds expectations) in every single

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subject. KOLBY had only had a single 1 on that report card and he did not com plete his
14
com puter class.

The only 1 he received w as in Art.

Both o f these classes KOLBY

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struggled in w ere not core classes such as math, English, Social Studies or science.
KO LBY buckled down and did much better in 2013/2014.

BRENT subm itted the

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attendance report from 2013/2014, but not the report card from 2013/2014 because it

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showed KO LBY is doing fine - he still has room fo r im provem ent but it is clear that

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KO LBY is m oving in the right direction. BR ENT is ju st trying to sm ear me to avoid child

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support. BRENT has been happy to have KOLBY live in my home and virtually never see

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him so long as BRENT did not have to pay support.

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I was not resentful o f B R E N Ts girlfriend. As BRENT admits, both o f us have been


involved with new relationships fo r a long time.

But once again, even though it is a lie

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 3 of 13

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G o ffE n g le h a rd d o c

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
BRENT says anything he can to sm ear me.

The allegation does not make sense and

2
exposes the underlying problem with B R E N Ts parenting.

BRENT says KOLBY felt

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allegiance toward me when he got his new girlfriend and that caused KOLBY to react to
him. That is sim ply not the case at all. This is an exam ple o f how BRENT lacks insight

and/or refuses to take responsibility fo r the breakdown in his relationship with KOLBY.

BRENT does not understand w hy his relationship with KOLBY has deteriorated over the

years to the point o f KO LBY and him now only being able to spend a couple o f hours

together at a time. BR ENT refuses to acknow ledge how his constant criticism , inability to

10

pick im portant battles with KOLBY, overreaction to m inor issues and his reliance upon

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spanking as discipline has torn down the bond between him and KOLBY.

Instead he

says I did not like his girlfriend and so KO LBY becam e hostile in his relationship with

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BRENT. This is ludicrous and dem onstrates B R E N Ts lack o f insight into parenting.
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BR E N Ts discussion o f K O LB Y s as possibly ODD is unfortunate. This is a public
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record and I am saddened by the fact that our discussion o f this option with KO LBY in
therapy is now a perm anent public records for all o f his peers, fam ily and potentially even

18

future em ployers to discover.

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was ever a form al diagnosis. My recollection was that the therapist said he may m eet the

20

criteria fo r ODD but she referred us to a medical doctor or psychologist fo r diagnosis.

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She m ay have coded item s in her com puter fo r insurance as ODD because this was the

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closest possible diagnosis, but I do not believe he was ever form erly diagnosed. Second,

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First, this was 3-4 years ago and I do not believe there

and m ore im portantly, BR ENT does not have any thing helpful to say in regard to this
potential diagnosis.

He adm its that he stopped the counseling back then (after KOLBY

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 4 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
mentioned the abuse and CPS investigated BRENT).

BRENT uses this discussion as

2
another springboard fo r him to proudly proclaim he is the disciplinarian and to further
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castigate me.
I was not the origin o f the CPS report.

The counselor reported the abuse based

upon her sessions with KOLBY.

interviewed KOLBY.

included speaking about CPS in front o f KO LBY but CPS directly talked to KOLBY. A fter

the case w as closed I was told by CPS to docum ent w hether there were bruises in the

10

future.

11

I only talked to CPS after they closed the case.

CPS

BRENT attacks me again by saying my inappropriate behavior

But once again BRENT blam es me and says I was wrong because I looked for

bruises on KOLBY w hen that w as precisely w hat CPS said to do after their investigation.

12

I never m onitored K O LB Y s calls with BRENT.

KO LBY always talked on speaker

13
phone by his own choice. He could have talked on the phone w ithout using the speaker
14
function but he chose not to. KO LBY would generally play gam es (e.g., Legos or cards)
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while

was talking on the phone and he wanted his hands free. KO LBY could and did go

into w hatever room in the house he wanted.

Som etim es he was in the living or kitchen

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w here I could hear the conversation but other tim es he talked in his room where I could

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not hear the conversation.

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happened that som etim es I heard them because KO LBY w as using the speaker phone in

21

the room I was in.

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suggests that som ehow his m eant I was re-inforcing the idea that BRENT was bad.

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Even BR ENT does not say I listened to all of the calls. It just

But once again BRENT springboards that into a criticism o f me and

That is sim ply not true.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 5 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
BRENT exaggerates KO BLYs behavioral problems by use o f imprecise
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hyperbole. BRENT says KOLBY was kicked out of before and after school care. That
3

is sim ply not true. KOLBY was suspended on a couple o f occasions for bullying and
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5

being rude. I agreed with the suspensions. I grounded KOLBY on those days he missed
from after school care to reinforce that KO LBYs behavior was not acceptable. I do not

know w hat BRENT did on his days with KOLBY when he was suspended but this

occurred when KOLBY was still spending half of his time with BRENT.

problems are not as severe as BRENT says and KOLBY was having behavioral problems

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when he was spending half-time with BRENT just as he has had behavioral problems

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KO LBYs

when he only sees BRENT for a few hours every 6-8 months. KOLBY was not kicked
out as BRENT claim s but his exaggeration is characteristic o f BR ENTs approach and

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his failure to take any personal responsibility in his entire declaration.


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BR ENTs claims that KO LBYs problems were all my fault are not true and
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exaggerated. BRENT is exaggerating in an attem pt to justify his two year hiatus from in16
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person contact.
On Page 3, BRENT again says he tried to work w ith me on solutions. He says

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he did not w ant to reward bad behavior, accept invitations to fun events that he was

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invited to and limit participation in extra-curricular activities. BRENT does not mention a

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single specific intervention of this type. He just generalizes that he tried these things. If

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he did, great, because I think those are more appropriate than spanking. But he does not

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provide any specific exam ples o f how I disagreed with this approach.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 6 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
Regarding diet, the only conversation BRENT and I had about this involved
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Gatorade and candy bars. My response was not w hat BRENT said. And my response
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came after years o f BRENT telling me not impose rules on BRENT. BRENT has always
told me its my house and my rules. From the time we separated and through the time

we attended counseling with KOLBY I would often make suggestions about how we could

im plem ent consistent rules and consequences in both houses.

BRENT rebuffed these suggestions. He always said he would do it his w ay. He always

proudly proclaimed that he was the disciplinarian and would brush aside any suggestion

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from me.

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On numerous occasions

So when BRENT suggested no Gatorade and candy bars I said that BRENT

has always said we have our own rules in our own homes. That was all. But the fact is, I
have experim ented with many different dietary interventions. One o f my other children is

13
gluten free so I am very aware of how diet impacts childrens behavior and performance.
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With KO LBY I have tried a reduced sugar diet and I have tried not allowing him to have
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Gatorade.
BR ENTs claim that the new baby created a situation where it was too m uch for

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me to care fo r KOLBY is also contradicted by his later actions. I did not allow video

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gam es to becom e KO LBYs parent. Before KOLBY could play with friends or play video

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games he had to do his homework. At least 50-60% of the time after he was done his

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hom ework KOLBY would choose to play outside with his friends. BRENT knew this and

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his claim now that I was baby sitting KOLBY with the video gam e is illogical in light of

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the fact that he choose in August 2012 to have KOLBY spend more time (100% of the
tim e) in my home. If I truly had been letting the video game babysit KOLBY it would have

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 7 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
made more sense fo r BRENT to have KOLBY at least keep coming to his house half of
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the time. But BR ENTs claim is false and that is w hy he was com fortable letting KOLBY
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spend 100% o f his tim e with me.


BRENT claim s he tried to work with me but provides no specifics on how I

refused to cooperate. It is just another exam ple of BRENT claiming I am the problem and

ignoring his own contribution to the breakdown in his relationship with KOLBY.

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BRENT claim s he called the crisis line because of KOLBYs outbursts. Once
again, this is BRENT pointing the finger at KOLBY. In my opinion, the reason counseling
failed the first time, and the reason BRENT has not sought counseling again, is because
BRENT ju st wants to point the finger at KO LBY and refuses to acknowledge ways that he

12
can improve his parenting.
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BRENT claim s he w ent to the Love and Logic Parenting Class. I have no idea
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when he did that. I do not recall him ever asking me to participate. If he did attend the
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class I hope it helped but at least in the last three years there has not seemed to be any
positive change in the relationship between BRENT and KOLBY.

There is a significant

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difference between the sitting in an anonym ous group class or sem inar and actually

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sitting down in a counseling session and accepting responsibility for hurts and broken

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relationships. This is w hy counseling did not seem to work. Everything was KOLBYs

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fault and BRENT lacked insight or refused to acknowledge how he contributed to

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KOLBYs anger and behavior.

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BR ENTs statem ent that he tried to w ork with me to get back on the residential

24

schedule is totally false. BR ENTs statem ent is lacks all credibility. If BRENTs statement
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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 8 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
was true, that I was the reason he was not seeing KOLBY as the parenting plan stated he
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could have gone to court at any time. But the fact is BRENT knew KOLBY was better off
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not spending substantial amounts o f time with him. BRENT admitted that w hat was
right was for KOLBY to spend more time with me. BRENT did not w ant to go to court for
fear that child support would be imposed.
BRENT and I have had conversations on the phone. BRENT and I have met in-

person to discuss w hat we should do. BRENT and I have attended counseling (long ago)

to try and fix things. All o f our conversations always digress into BRENT telling me how I

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have failed. BRENT always berates me and blames all of the problems on me and

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KOLBY.

BRENTs entire declaration is all more of the same. At this point it is pointless

w ithout professional help for us to meet.

As BRENT points out, I do answer the phone

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when he calls, I even answered while on my honeymoon because it is rare for BRENT to
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call and I thought there m ight be something important to talk about.
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KOLBY has never wanted to live primarily with BRENT. Significantly, though,
BRENT admits that KOLBY has issues with me. The reason is because, contrary to all

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o f BRENTs claims, I do discipline KOLBY in my house (I just dont spank him). The only

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tim es KOLBY has tried to play BRENT against me is when I have enforced a rule or

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required KOLBY to experience a consequence for behavior. The fact that BRENT knows

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about this totally underm ines his claims I have no discipline. I just do not spank like

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BRENT and I also do not constantly criticize every little thing.

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BRENT com plains that KOLBY missed a lot of school. I agree that is a concern.
But one w eek he missed five days for a legitimate illness that I know he was very sick.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 9 of 13

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G o ffE n g le h a rd .d o c

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

5920-1 00th Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
There was another w eek he missed because I was away on my honeymoon and BRENT
2
did not keep KOLBY so I had to send KOLBY to stay with my sister out o f town. There
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were a couple o f days that we took off as a fam ily for an outing so it was an excused
absence. At least 12-13 days o f the 25 days he missed I know KOLBY legitimately could
not be at school.

There are other tim es that he says he is sick and his sym ptom s seem more minor

or contrived. I often force him to go anyway. Many tim es I send him when he says he is

sick and tell him to see the nurse and if she says he is too sick I will come get him. But

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there are some days I have let him stay home even when his illness is minor. This is
something I think he needs to get better at, but I think screaming at him or forcing him to

12
go, or imposing an unduly severe punishm ent would be counter-productive. If he stays
13

home sick, the rule is, he is sick and he does not get to play with friends or go outside.
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BRENT claims KO LBYs discipline problems are escalating. I agree there are
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issues which need to be addressed. But BRENT claims to have a very open and close
com m unication with KO LBYs teachers and others at school and yet he did absolutely

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nothing about these issues until after I filed a motion for child support. I am concerned

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about KO LBYs discipline issues and I would like to talk to a counselor about how to

20

properly help KOLBY in this regard.

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and KOLBY needs to be involved and feel safe in the relationship. Last time we went to

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counseling KO LBY refused to open up after his Dad berated him fo r talking about the

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But I need to be involved so that I can help KOLBY

spankings which led to the CPS investigation. The counseling should not just be an

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opportunity fo r BRENT to castigate KOLBY (or me for that matter).


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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 10 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW Ste 25


Lakewood, WA 98499
253-581-0660

1
I already discussed grades. Page 6 o f BR ENTs declaration is absolutely a
2
travesty. He goes through and discusses last years grades and raises all kinds of
3

concerns about these grades (which I agree merit concern) and yet he totally ignores
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KO LBYs much better report card from the end o f this year. BRENT is just on a smear
campaign to make me look bad. After skipping last years report card BRENT goes on to

discuss assignm ents missing from this year. But I am aware of all of these and I am

working with KOLBY to get them turned in. Som e have already been turned in.

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BRENT had his first in-person visit with KOLBY two weeks ago in seven months. I
was fully supportive o f KOLBY spending tim e with BRENT. The months before I filed this
action BRENT was content to not see KO LBY at all.

BRENTs statem ent that they text or

call daily may be true - I do not monitor their conversations or com m unications but I was

13

under the im pression it was less frequent than that.


14

BRENTs declaration is also misleading about the homework situation at the visit
15

two weeks ago. BRENT says KOLBY cam e over and he asked about hom ework.
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That conversation actually took place via text because when BRENT arrived to pick

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KO LBY up I came out to the car with KOLBY and reminded KOLBY and BRENT to finish

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his homework. BRENT then told me that KOLBY had already told him, via text, that he

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was done his homework. There was not prodding by BRENT - the only w ay BRENT

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found out KOLBY had been less than forthright was because I was the one involved.

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I do not oppose KOLBY seeing a counselor. I think he should see a counselor.


KOLBY is on insurance so I think that the counselor should be one who accepts my
insurance. I have not particular objection to JENNIFER EVINGER so long as she

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 11 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
Child support has not been paid for two full years even though KOLBY has not
2
spent more than 2-5 hours with BRENT a few times.

The incremental increase BRENT

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refers to only applies adjustm ents brought based upon a 24 months elapsing from the
date o f the last order and changes to the income o f the parents or changes in the

econom ic table. See RCW 26.09.170(7). Incremental increases do not apply to

modifications based upon a change in custody, or in this case, a change from 50/50 to

something else.

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v * '

I am not aware o f any agreem ent that child support would be effective September
2014. This motion was originally filed August 1, 2014.

It was served on August 5, 2014.

It was originally set fo r hearing for August 28, 2014. I filed a motion for default on August

12
26, 2014, because I had received no response or notice o f appearance.

That same day

13
my attorney received a Notice o f Appearance by BRENTs attorney. I know that my
14
attorney set over the hearing to allow BRENT tim e to respond with his attorney.

They

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may have discussed the effective date of support in hopes o f reaching an agreed order
when they set over the hearing but I am not aware of a formal agreement.

W e discussed

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meeting but ultim ately ju st exchanged proposed orders. W e were not able to reach an

19

agreement. I think support should be effective in August since the motion was filed and

20

served on A ugust 5 and BRENT has paid no support for the last two years.

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I have now provided proof that KOLBY is covered by my husbands insurance.


The cost fo r children coverage is actually $60 per month but I divided it by 4 children
since we have 4 children covered.

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Reply Declaration of VICTORIA GOFF- ENGELHART - Page 13 of 14
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Reply Declaration of Victoria GoffEnglehard.doc

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
I did not quit my job. My 2013 W2 was exactly w hat I earned and I did not have
2
any unpaid time o ff in 2013. That was exactly my pay. I did not earn $22 per hour. I left
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6

my job to care for our tw o children under school, one o f whom has special needs which
makes daycare difficult to find and astronom ically expensive.
The court should find adequate cause. Should adopt my parenting plan which

maintains the status quo of BRENT and KOLBY working out days and tim es for visits as a

tem porary plan. Since BRENT is contesting this action the court should appoint a GAL

and have BRENT pay the retainer since he has paid no support for the last two years.

10

The GAL can then make recomm endations about w hat would be in KO LBYs best interest

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12

as a permanent plan. Until then, the status quo should remain.


I DECLARE UNDER PENALTY OF PER JUR Y UNDER THE LAWS OF THE

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STATE OF W ASH IN G TO N TH A T THE FO REG O ING IS TRUE AN D CORRECT.
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Signed at Lakewood, W A on S e p tmh^ r

oma

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Reply Declaration of VICTORIA GOFF- ENGELHART - Page 14 of 14

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G offE n g le h a rd .d o c

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK'S OFFI
PIERCE COUNTY, WASHING
IN COUNTY CLERK'S OFFICE
PIERseptemberSO^OIA1
/

SeptembKEVIN STOCK

2
NO: 08-3-03291-3
3
4
5

6
7

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

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In re:

No. 08-3-03291-3

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BRENT D. GOFF,

REPLY DECLARATION OF
VICTORIA GOFF-ENGLEHARD

13

and

14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

11

15
16

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Petitioner,

I, VICTORIA GOFF-ENGLEHARD, make this declaration on the basis of my


personal knowledge and in reply to the Response Declaration of BRENT GOFF dated
September 26, 2014.
BRENT exaggerates and inaccurately blames KOLBYS struggles on me. BRENT

20
falsely claims I am not a disciplinarian."

BRENTs entire declaration is a character

21
assassination of me and my parenting.

Yet BRENT openly admits he left KOLBY in my

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care with virtually no in-person contact with BRENT for two years.

His position is

ludicrous. If I was as poor of a parent as BRENT now claims there is no way he would

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 1 of 13

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1\G o ff-E n g e lh a rd \D R A F T S \P le a d in g s\R e ply D eclaration o f Victoria GoffE nglehard.doc

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
have left KO LBY with me for two years.

BRENT was happy for me to care fo r KOLBY

2
100% o f the tim e but he did not take this back to court because he knew he would be
3

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5

required to pay child support if he did.


There is no w ay that BRENT would have left KOLBY in my house if I had no

discipline, no rules, no chores or if hom ework did not get done.

great deal.

hitting KOLBY.

respectful, do chores and com plete hom ework.

10

not respectful, does not do his chores, or does not com plete his hom ew ork in my

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12

I discipline KO LBY a

The difference is BRENT does not believe it is discipline unless it involves


BR ENT claim s his household is superior because he makes KO LBY be
S o d o I. The difference is if KO LBY is

household, he loses privileges or is grounded. I have a progressive system to determ ine


which privileges to take or how long or severe a grounding is. But BRENT has no such

13

progressive system . If KO LBY does not do w hat BRENT wants he is im m ediately totally
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grounded.

If the problem escalates from there BR ENT creates a physical confrontation

15
with KOLBY, under the guise o f spanking.

This totalitarian rule sim ply did not w ork as

16
17

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KO BLY got older and rebelled more forcefully.


There is also a drastic difference in attitude.

BRENT treats KOLBY like a robot

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who m ust do and say w hatever BRENT thinks is appropriate. BRENT does not allow any

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room fo r KO LBY to be im perfect, im m ature or even have emotions.

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constantly berating KO LBY fo r even the sm allest things.

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put-dow ns from BR ENT eventually snowball into bigger issues and BRENT then has to hit

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(spank) KOLBY.
BRENT.

So BRENT is

These constant criticism s and

But there is no love or understanding in K O LBYs relationship with

KO LBY loves his father and w ants to spend short periods o f tim e with him but

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 2 o f 13
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V ic to ria G o ffE n g le h a rd .d o c

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
when BRENT tries to m ake him into a robot and then spanks him when he does not
2
KOLBY sim ply cannot function in that environm ent.
3
4
5

There is also no w ay BRENT would have been content to leave KOLBY with me
with virtually no in-person contact with him if KOLBY was doing as poorly in school as

Significantly, BRENT did not submit KOLBYs most recent report

BRENT infers.

card from the end of 2013/2014. BRENT subm itted the 2012/2013 report card which

was not a good one.

KOLBY.

10

incentives and consequences for poor school perform ance. This is discipline. By the end

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But the 2013/2014 report card showed am azing im provem ent by

I talked to KO LBY after his poor year in 2012/2013 and we im plem ented

o f 2013/2014 he w as m eeting or exceeding grade standards in alm ost all areas, including
core classes. KOLBY had 3s and 4s ( M eets or Exceeds expectations) in every single

13

subject. KOLBY had only had a single 1 on that report card and he did not com plete his
14

com puter class.

The only 1 he received was in Art.

Both o f these classes KOLBY

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struggled in were not core classes such as math, English, Social Studies or science.
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KO LBY buckled down and did much better in 2013/2014.

BRENT subm itted the

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attendance report from 2013/2014, but not the report card from 2013/2014 because it

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showed KOLBY is doing fine - he still has room fo r im provem ent but it is clear that

20

KO LBY is moving in the right direction.

21

support. BRENT has been happy to have KOLBY live in my home and virtually never see

22

him so long as BRENT did not have to pay support.

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BRENT is ju st trying to sm ear me to avoid child

I was not resentful o f B R E N Ts girlfriend. As BR ENT admits, both o f us have been


involved with new relationships fo r a long time.

But once again, even though it is a lie

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 3 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
BRENT says anything he can to sm ear me.

The allegation does not make sense and

2
exposes the underlying problem with B R E N Ts parenting.

BRENT says KOLBY felt

3
4
5

allegiance toward me when he got his new girlfriend and that caused KOLBY to react to
him. That is sim ply not the case at all. This is an exam ple o f how BRENT lacks insight

and/or refuses to take responsibility fo r the breakdown in his relationship with KOLBY.

BR ENT does not understand w hy his relationship with KOLBY has deteriorated over the

years to the point o f KO LBY and him now only being able to spend a couple o f hours

together at a time. BR ENT refuses to acknowledge how his constant criticism , inability to

10
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pick im portant battles with KOLBY, overreaction to m inor issues and his reliance upon
spanking as discipline has torn down the bond between him and KOLBY.

Instead he

says I did not like his girlfriend and so KOLBY becam e hostile in his relationship with

13

BRENT. This is ludicrous and dem onstrates BR ENTs lack o f insight into parenting.
14
BR E N Ts discussion o f K O LB Y s as possibly ODD is unfortunate. This is a public
15
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record and I am saddened by the fact that our discussion o f this option with KOLBY in
therapy is now a perm anent public records for all o f his peers, fam ily and potentially even

18

future em ployers to discover.

19

was ever a form al diagnosis. My recollection was that the therapist said he m ay meet the

20

criteria fo r ODD but she referred us to a medical doctor or psychologist for diagnosis.

21

She m ay have coded items in her com puter fo r insurance as ODD because this was the

22

closest possible diagnosis, but I do not believe he w as ever form erly diagnosed. Second,

23
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First, this was 3-4 years ago and I do not believe there

and m ore im portantly, BR ENT does not have any thing helpful to say in regard to this
potential diagnosis.

He adm its that he stopped the counseling back then (after KOLBY

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 4 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
m entioned the abuse and CPS investigated BRENT).

BRENT uses this discussion as

2
another springboard fo r him to proudly proclaim he is the disciplinarian and to further
3
4

castigate me.
I w as not the origin of the CPS report.

The counselor reported the abuse based

upon her sessions with KOLBY.

interview ed KOLBY.

included speaking about CPS in front o f KO LBY but CPS directly talked to KOLBY. After

the case w as closed I was told by CPS to docum ent w hether there w ere bruises in the

10

future.

11

I only talked to CPS after they closed the case.

CPS

BR ENT attacks me again by saying my inappropriate behavior

But once again BRENT blam es me and says I was wrong because I looked for

bruises on KOLBY w hen that was precisely w hat CPS said to do after their investigation.

12

I never m onitored K O LB Ys calls with BRENT.

KOLBY always talked on speaker

13
phone by his own choice.

He could have talked on the phone w ithout using the speaker

14
function but he chose not to. KO LBY would generally play gam es (e.g., Legos or cards)
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w hile

w as talking on the phone and he wanted his hands free. KOLBY could and did go

into w hatever room in the house he wanted.

Som etim es he w as in the living or kitchen

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w here I could hear the conversation but other tim es he talked in his room where I could

19

not hear the conversation.

20

happened that som etim es I heard them because KO LBY was using the speaker phone in

21

the room I was in.

22

suggests that som ehow his m eant I w as re-inforcing the idea that BRENT was bad.

23

Even BRENT does not say I listened to all of the calls. It just

But once again BRENT springboards that into a criticism o f me and

That is sim ply not true.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 5 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
BRENT exaggerates KO BLYs behavioral problem s by use of imprecise
2
hyperbole. BRENT says KOLBY was kicked out o f before and after school care. That
3
4
5

is simply not true. KOLBY was suspended on a couple of occasions for bullying and
being rude. I agreed with the suspensions. I grounded KOLBY on those days he missed

from after school care to reinforce that KO LBYs behavior was not acceptable. I do not

know w hat BRENT did on his days with KOLBY when he was suspended but this

occurred when KOLBY was still spending half of his time with BRENT.

problems are not as severe as BRENT says and KOLBY was having behavioral problems

10

when he was spending half-time with BRENT just as he has had behavioral problems

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KO LBYs

when he only sees BRENT for a few hours every 6-8 months. KOLBY was not kicked
out as BRENT claim s but his exaggeration is characteristic o f BRENTs approach and

13
his failure to take any personal responsibility in his entire declaration.
14
BR ENTs claims that KO LBYs problems were all my fault are not true and
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exaggerated. BRENT is exaggerating in an attem pt to justify his two year hiatus from inperson contact.
On Page 3, BRENT again says he tried to work w ith me on solutions. He says

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he did not w ant to reward bad behavior, accept invitations to fun events that he was

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invited to and limit participation in extra-curricular activities. BRENT does not mention a

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single specific intervention o f this type. He just generalizes that he tried these things. If

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he did, great, because I think those are more appropriate than spanking. But he does not

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provide any specific exam ples o f how I disagreed with this approach.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 6 of 13

Goff, Brent and Goff-Englehard, Victoria


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FAUBION, REEDER,

FRALEY & COOK, P.S.


5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
Regarding diet, the only conversation BRENT and I had about this involved
2
Gatorade and candy bars. My response was not w hat BRENT said. And my response
3
4
5

came after years of BRENT telling me not impose rules on BRENT. BRENT has always
told me its my house and my rules. From the time we separated and through the time

we attended counseling with KOLBY I would often make suggestions about how we could

implement consistent rules and consequences in both houses.

BRENT rebuffed these suggestions. He always said he would do it his w ay. He always

proudly proclaimed that he was the disciplinarian and would brush aside any suggestion

10

from me.

11
12

On numerous occasions

So when BRENT suggested no Gatorade and candy bars I said that BRENT

has always said we have our own rules in our own homes. That was all. But the fact is, I
have experim ented with many different dietary interventions. One o f my other children is

13
gluten free so I am very aware of how diet impacts childrens behavior and performance.
14
W ith KOLBY I have tried a reduced sugar diet and I have tried not allowing him to have
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Gatorade.
BR ENTs claim that the new baby created a situation where it was too m uch for

18

me to care for KOLBY is also contradicted by his later actions. I did not allow video

19

gam es to become KO LBYs parent. Before KOLBY could play with friends or play video

20

games he had to do his homework. At least 50-60% of the time after he was done his

21

homework KOLBY would choose to play outside with his friends. BRENT knew this and

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his claim now that I was baby sitting KOLBY with the video game is illogical in light of

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the fact that he choose in A ugust 2012 to have KOLBY spend more time (100% of the
time) in my home. If I truly had been letting the video game babysit KOLBY it would have

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 7 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
made more sense for BRENT to have KOLBY at least keep coming to his house half of
2
the time. But BRENTs claim is false and that is why he was com fortable letting KOLBY
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5

spend 100% o f his tim e with me.


BRENT claims he tried to work with m e but provides no specifics on how I

refused to cooperate. It is just another exam ple of BRENT claiming I am the problem and

ignoring his own contribution to the breakdown in his relationship with KOLBY.

BRENT claims he called the crisis line because of KOLBYs outbursts. Once

again, this is BRENT pointing the finger at KOLBY. In my opinion, the reason counseling

10

failed the first time, and the reason BRENT has not sought counseling again, is because

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BRENT ju st wants to point the finger at KOLBY and refuses to acknowledge ways that he
can improve his parenting.

13
BRENT claims he w ent to the Love and Logic Parenting Class. I have no idea
14
when he did that. I do not recall him ever asking me to participate. If he did attend the
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class I hope it helped but at least in the last three years there has not seemed to be any
positive change in the relationship between BRENT and KOLBY.

There is a significant

18

difference between the sitting in an anonym ous group class or sem inar and actually

19

sitting down in a counseling session and accepting responsibility for hurts and broken

20

relationships. This is w hy counseling did not seem to work. Everything was KO LBYs

21

fault and BRENT lacked insight or refused to acknowledge how he contributed to

22

KO LBYs anger and behavior.

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BR ENTs statem ent that he tried to w ork with me to get back on the residential
schedule is totally false. BR ENTs statem ent is lacks all credibility. If BRENTs statement

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 8 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
was true, that I was the reason he was not seeing KOLBY as the parenting plan stated he
2
could have gone to court at any time. But the fact is BRENT knew KOLBY was better off
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5
6
7

not spending substantial amounts o f time with him. BRENT admitted that w hat was
right was for KOLBY to spend more time with me. BRENT did not w ant to go to court for
fear that child support would be imposed.
BRENT and I have had conversations on the phone. BRENT and I have met in-

person to discuss w hat w e should do. BRENT and I have attended counseling (long ago)

to try and fix things. All o f our conversations always digress into BRENT telling me how I

10

have failed. BRENT always berates me and blames all of the problems on me and

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KOLBY.

BR ENTs entire declaration is all more of the same. At this point it is pointless

w ithout professional help for us to meet.

As BRENT points out, I do answer the phone

13
when he calls, I even answered while on my honeymoon because it is rare for BRENT to
14
call and I thought there might be som ething im portant to talk about.
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KOLBY has never wanted to live primarily with BRENT. Significantly, though,
BRENT admits that KOLBY has issues with me. The reason is because, contrary to all

18

o f BR ENTs claims, I do discipline KOLBY in my house (I just dont spank him). The only

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times KOLBY has tried to play BRENT against me is when I have enforced a rule or

20

required KOLBY to experience a consequence for behavior. The fact that BRENT knows

21

about this totally underm ines his claims I have no discipline. I just do not spank like

22

BRENT and I also do not constantly criticize every little thing.

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24

BRENT com plains that KOLBY missed a lot of school. I agree that is a concern.
But one w eek he missed five days for a legitimate illness that I know he was very sick.

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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 9 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
There was another w eek he missed because I was away on my honeymoon and BRENT
2
did not keep KOLBY so I had to send KOLBY to stay with my sister out of town. There
3
4
5

were a couple o f days that we took off as a fam ily for an outing so it was an excused
absence. At least 12-13 days o f the 25 days he missed I know KOLBY legitimately could
not be at school.

There are other tim es that he says he is sick and his sym ptom s seem more minor

or contrived. I often force him to go anyway. Many tim es I send him when he says he is

sick and tell him to see the nurse and if she says he is too sick I will come get him. But

10

there are som e days I have let him stay home even when his illness is minor. This is

11
12

something I think he needs to get better at, but I think screaming at him or forcing him to
go, or imposing an unduly severe punishm ent would be counter-productive. If he stays

13
home sick, the rule is, he is sick and he does not get to play with friends or go outside.
14

BRENT claim s K O LBYs discipline problems are escalating. I agree there are
15
16

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issues which need to be addressed. But BRENT claims to have a very open and close
com m unication with K O LBYs teachers and others at school and yet he did absolutely

18

nothing about these issues until after I filed a motion for child support. I am concerned

19

about KO LBYs discipline issues and I would like to talk to a counselor about how to

20

properly help KOLBY in this regard.

21

and KOLBY needs to be involved and feel safe in the relationship. Last tim e we w ent to

22

counseling KOLBY refused to open up after his Dad berated him for talking about the

23
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But I need to be involved so that I can help KOLBY

spankings which led to the CPS investigation. The counseling should not just be an
opportunity for BRENT to castigate KOLBY (or me for that matter).

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Reply Declaration o f VICTORIA GOFF-ENGLEHARD - Page 10 of 13
Goff, Brent and Goff-Englehard, Victoria
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
I already discussed grades. Page 6 of BRENTs declaration is absolutely a
2
travesty. He goes through and discusses last year's grades and raises all kinds of
3

concerns about these grades (which I agree merit concern) and yet he totally ignores
4
5

KO LBYs much better report card from the end o f this year. BRENT is just on a smear
campaign to make me look bad. After skipping last years report card BRENT goes on to

discuss assignm ents missing from this year. But I am aware of all o f these and I am

working with KOLBY to get them turned in. Some have already been turned in.

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11
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BRENT had his first in-person visit with KOLBY two weeks ago in seven months. I
was fully supportive o f KOLBY spending time with BRENT. The months before I filed this
action BRENT was content to not see KOLBY at all.

BRENTs statem ent that they text or

call daily may be true - I do not m onitor their conversations or com m unications but I was

13

under the impression it was less frequent than that.


14

BRENTs declaration is also m isleading about the hom ework situation at the visit
15

two weeks ago. BRENT says KOLBY cam e over and he asked about hom ework.
16
17

That conversation actually took place via text because when BRENT arrived to pick

18

KOLBY up I came out to the car with KOLBY and reminded KOLBY and BRENT to finish

19

his homework. BRENT then told me that KOLBY had already told him, via text, that he

20

was done his homework. There was not prodding by BRENT - the only way BRENT

21

found out KOLBY had been less than forthright was because I was the one involved.

22
23
24

I do not oppose KOLBY seeing a counselor. I think he should see a counselor.


KOLBY is on insurance so I think that the counselor should be one who accepts my
insurance. I have not particular objection to JENNIFER EVINGER so long as she

25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 11 of 13

Goff, Brent and Goff-Englehard, Victoria


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

5920-1 00th Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

1
accepts my insurance. But I also believe both parents should be involved in the
2
counseling as requested by the counselor. I know that KOLBY and BRENT need to work
3
4
5

on their relationship, but I think it is im portant for me to be involved as well because there
are things that I can improve on with parenting KOLBY (e.g., making sure he gets to

school and does not just pretend to be sick, helping him reduce his disciplinary incidents).

I also w ant to ensure that the counseling is not ju st BRENT blaming KOLBY for all of the

problems. I think the counselor needs to have perspective from both parents. Each of us

should participate to the extent the counselor recommends. The counselor should not

10

11

have the authority to change the parenting plan. I am also concerned that KOLBY will be
unwilling to participate in counseling. If KOLBY does not engage in the process we

12
should be able to term inate the process if he refuses to engage.
13
There is detrim ent to put KOLBY in BR ENTs home. KOLBY has been integrated
14
100% into my home in deviation from the 50/50 parenting plan.

The inaction by BRENT

15
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for the last two years com pletely underm ines his denial now, and his attem pt to blame me
fo r the fact that BRENT has voluntarily failed to spend time with KOLBY.

Significantly,

18

BRENT does not cite a single specific time when I have prevented him from seeing

19

KOLBY.

20

him to address KOLBYs needs, but he never once even claims I prevented him from

21

seeing or spending tim e with KOLBY.

22
23

BR ENTs com plaints are all generalized claims that I have not w orked with

BRENT admits that he voluntarily took a break

from seeing KOLBY. This is integration into my home with consent, and to put KOLBY
back into a 50/50 plan with BRENT at this point would be very detrimental to KOLBYs

24
emotional, physical and psychological well-being.
25
Reply Declaration of VICTORIA GOFF- ENGELHART - Page 12 of 14
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G o ffE n g le h a rd .d o c

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
Child support has not been paid fo r two full years even though KOLBY has not
2
spent more than 2-5 hours with BRENT a few times.

The incremental increase BRENT

4
5

refers to only applies adjustm ents brought based upon a 24 months elapsing from the
date o f the last order and changes to the income o f the parents or changes in the

econom ic table. See RCW 26.09.170(7). Incremental increases do not apply to

modifications based upon a change in custody, or in this case, a change from 50/50 to

something else.

10
11

> - v' - '

I am not aware o f any agreem ent that child support would be effective September
2014. This motion was originally filed A ugust 1 ,2014.

It was served on August 5, 2014.

It was originally set for hearing for August 28, 2014. I filed a motion for default on August

12
26, 2014, because I had received no response or notice o f appearance.

That same day

13
my attorney received a Notice o f Appearance by BRENTs attorney. I know that my
14
attorney set over the hearing to allow BRENT tim e to respond with his attorney.

They

15
16
17

may have discussed the effective date o f support in hopes of reaching an agreed order
when they set over the hearing but I am not aware o f a formal agreement.

W e discussed

18

meeting but ultim ately ju st exchanged proposed orders. W e were not able to reach an

19

agreement. I think support should be effective in A ugust since the motion was filed and

20

served on August 5 and BRENT has paid no support for the last two years.

21
22
23

I have now provided proof that KOLBY is covered by my husbands insurance.


The cost for children coverage is actually $60 per month but I divided it by 4 children
since we have 4 children covered.

24
25
Reply Declaration of VICTORIA GOFF- ENGELHART - Page 13 of 14
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G o ffE n g le h a rd .d o c

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

1
I did not quit my job. My 2013 W2 was exactly what I earned and I did not have
2
any unpaid tim e off in 2013. That was exactly my pay. I did not earn $22 per hour. I left
3
4
5
6

my job to care fo r our tw o children under school, one o f whom has special needs which
makes daycare difficult to find and astronom ically expensive.
The court should find adequate cause. Should adopt my parenting plan which

maintains the status quo o f BRENT and KOLBY working out days and tim es for visits as a

tem porary plan. Since BRENT is contesting this action the court should appoint a GAL

and have BRENT pay the retainer since he has paid no support for the last two years.

10

The GAL can then make recomm endations about w hat would be in KO LBYs best interest

11
12

as a permanent plan. Until then, the status quo should remain.


I DECLARE UNDER PENALTY OF PER JUR Y UNDER THE LAW S OF THE

13
STATE OF W A S H IN G TO N TH AT THE FO REG O IN G IS TRUE AND CORRECT.
14
15

Signed at Lakewood, W A on S e p ^ mh^ r

oma

16
17
18
19
20
21
22
23
24
25
Reply Declaration of VICTORIA GOFF- ENGELHART - Page 14 of 14

Goff, Brent and Goff-Englehard, Victoria


S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \R e p ly D e c la ra tio n o f V icto ria G offE n g le h a rd .d o c

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
October 02 201

1
KEVIN ST
COUNTY C

2
3
4
5
6
7
8

IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE

BRENT D GOFF

Petitioner(s),
10

Cause No. 08-3-03291-3


Order Granting
Adequate Cause

vs.
11

VICTORIA J GOFF
12

Respondent(s)

Clerks Filing code: ORAGR

13
14
15
16

THIS MATTER having come on regularly for hearing to determine if there is adequate cause to
proceed to trial with regard to a Petition which has been filed.

17

Now, therefore, it is hereby

18

ORDERED the Show Cause hearing determining Adequate Cause is granted.

19
20
21
22
Dated this 02 day of October, 2014
23
24
25

/S/Mark L. Gelman
Mark L. Gelman

Judge/Commissioner

Q jS T rt^
For Petitioner

For Respondent

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Q = ____ 0 2 ___ 1MP>0

____________

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Adequate Cause - Custody

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Mark L. Gelman
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October 2, 2014 9:00 AM

p ^& ~ v^ y

(B /4 <

DARROW SCHIESL
D EPUTY C L E R K

Courtroom number: 407


Calendar:C3 - SHOW CAUSE/FAMILY LAW
Rundate/time 10/02/14 8:12
Ixcrtrpt.pbl dJoumal_entry_showcause_report

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1
2
3
4
5

6
7

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

9
In re:
BRENT D. GOFF,

10

No. 08-3-03291-3
Petitioner,

11

and

12

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

13

Order re Adequate Cause


(Modification/Adjustment of Custody
Decree/Parenting Plan/Residential
Schedule)
GRANTED (ORRACG)

14
15
16

I. Basis
1.1

A petition requesting the m odification/adjustm ent of the custody decree/parenting


plan/residential schedule in this m atter has been presented to the court.

1.2

A hearing was held on: does not apply because this order is an agreed order.

17
18

II. Findings

19

The Court Finds:


20
2.1

Jurisdiction

21
This court has jurisdiction over the proceeding and the parties.

22
23
24
25

2.2

Service on Nonmoving Party


The nonmoving party was served with a copy o f the petition or joined in the
petition for m odification/adjustm ent of custody decree/parenting plan/residential
schedule, sum m ons, a proposed parenting plan, and child support worksheet, if
any, on July 28, 2014.

Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 1 of 2

WPF DRPSCU 07.0300 Mandatory (7/2007) - RCW26.09.260; .270; 26.10.200


Goff and Goff-Englehard
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\OrderReAdequateCause.docx

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

5920-100 Street SW, Ste 25


Lakewood WA 98499
253-581-0660

1
2

2.3

Time Elapsed Since Service on the Nonmoving Party


The nonm oving party was served (or joined) within the state of W ashington and
few er than 20 days have elapsed since the date of service. However, the
nonmoving party was present on July 28, 2014, when the com m issioner ordered
that the hearing be moved forward to August 11 because of the n^tufe-ef-ttie

4
5

case
6

/ F I L E D
IN OPEN COURT

2.4

Response

7
The nonmoving party has b d responded.

O2 20H

2.5
9

12

ITY, Clerk

J3yC ctrir
u ii
v : de ? ut > > , ,
The p a rtie s s tipulate that there is adequate cause for hearing the petwentSio H ^

10
11

PIERCE

Adequate Cause Finding

2.6

Servicemembers Civil Relief Act Statement


2.6.1

fcr
^
t y&UuWJ
cUiCd Cf '{orVw lrv;v>w.
Service m em ber status It appears the nonmoving party: is not a service
member;

13
2.6.2

14

Dependent of a service m em ber status It appears the nonmoving party:


is not a dependent of a resident of W ashington w ho is on active duty and
is a National Guard m em ber or a Reservist;

15
III. Order

16
it is Ordered :
17
18
19

The m atter is set for hearing or trial at:


Date: April 13, 2015
Place: Pierce County Superior Court

Time: 9:00 a.m.


)artment: TBD

20
Dated:
21
22

23
24
25

/C o m m is s i o n e r yfyiARK L GELMAN
Presented by:
FAUBIO

OOK, P.S.

_URT COMMISSIONER
iroved by:
Notice of presentation waived:

irW S B rtT m S S fT
Attorney for Respondent

Imes, W S B A #26208
or Petitioner

Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 2 of 2

WPF DRPSCU 07.0300 Mandatory (7/2007) - RCW 26.09.260; .270; 26.10.200


Goff and Goff-Englehard
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Order Re Adequate Cause.docx

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

5920-1 00th Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

Resultsas of:Jcl-3C-2314 11:25.34 AM

Department o f Defense Manpower Data Center

SCRA3 0

: Status Report
1Pursuant to Servicemembers Civil Relief Act
Last Name: GOFF
First Name: BRENT
Middle Name:
Active Duty Status As Of: Jul-30-2014
On Active Outv On Active Duty Status Data
Active Duty Start Ctota

Actnro Duty End Oats

Status

Service Component

NA

NA

No

NA

This response reflects the individuals' active duty status based on the Active Duty Status Date

Ltifl Active Duty WUhln 367 Davs of Active Doty Statu* Data
Active Duty S u it Date

Acbvo Dutv End DaU)

Status

Service Component

NA

NA

No

NA

Ths response reflects whora ttw Individual toll active duty ataUja within 367 (toys preceding the Active Duty Status Date

The Member or KiaJHer Unit Was Noltfted e ta Future CaSAJp lt> Acbve Duty on Active Dutv Status Data
I

Order NofiflcaSon Start Date

Order Notification End Date

Status

Sarvtoe Componenl

NA

NA

NO

NA

This response fa c e ts whether the individual or his/her uml has received eorty oolificaticn to report for active duly

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 indudes information on a Servicememberor his/her unit receiving notification of future orders to report for Active Duty.

Mary M. Snaveiy-Dixon, Director


Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350

10-06.14
4
5

6
7

8
9

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

10

11
12

In re:
BRENT D. GOFF,

13

and

14

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.

No. 08-3-03291-3
Petitioner,

Order of Child Support


Temporary (TMORS)

15

I. Judgment Summary

16
17

1.1

Judgment Summary for Non-Medical Expenses


Does not apply.

18
19

Clerk's Action Required

1.2

Judgment Summary for Medical Support


Does not apply.

20

I. Basis
21
22
23

2.1

Type of Proceeding
This order is entered under a petition for dissolution of marriage or dom estic
partnership, legal separation, or declaration concerning validity:

Order of Child Support (TMORS, ORS) - Page 1 of 13

WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\PIeadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

1
Hearing for tem porary child support.

2
2.2

Child Support Worksheet

3
The child support w orksheet 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)
Kolby G off

11
12
13
14

3.2

Age
13

Person Paying Support (Obligor)


Name (first/last): Brent G off
Birth date: 06/04/1971
Service Address: (You m ay list an address that is not your residential address
where you agree to accept legal docum ents.)

15
11911 -2 1 8 th AVE C T E
Bonney Lake W A 98391

16
17
18
19

20

The obligor parent m ust 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
prom ptly after any change in the information. The duty to update the
information continues as long as any m onthly support remains due or any
unpaid support debt remains due under this order.

21
22

For purposes o f this O rder of Child Support, the support obligation is based upon
the following income:

23

A.

Actual M onthly Net Income:

/H ii-T e 2 .^

Order of Child Support (TMORS, ORS) - Page 2 of 13


WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelharxt\DRAFTS\Pteadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660

3.3

Person Receiving Support (Obligee)

2
3
4

Name (first/last): Victoria Goff-Englehard


Birth date: 08/19/1972
Service Address: (You may list an address that is not your residential address
where you agree to accept legal docum ents.)
14404 72nd St E
Sum ner W A 98390

6
7

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 R C W 26.23.050.

8
9
10
11

The obligee shall update the information required by paragraph 3.2


prom ptly after any change in the information. The duty to update the
information continues as long as any m onthly support remains due or any
unpaid support debt remains due under this order.
For purposes of this O rder of Child Support, the support obligation is based upon
the following income:

12
C.

The net income of the obligee is imputed at $2,740.85 because:

13
the obligee is voluntarily unem ployed.
14
15

The am ount of imputed incom e is based on the following


inform ation in order of priority. The court has used the first option
for which there is information:

16
[]
17
18
19

current rate of pay;


reliable historical rate of pay information;

[]

Past earnings when there is incom plete or sporadic


inform ation of the parents past earnings;

[]

minim um w age in the jurisdiction w here the parent lives at


full-tim e earnings because the parent:

20

[]
[]

21

22
23

[]
[j
[]

has a recent history o f m inim um w age jobs;


recently cam e o ff public assistance, general
assistance-unem ployable, supplem ental security
income; or disability
was recently released from incarceration, or
is a high school student;

M edian Net M onthly Income Table.

Order of Child Support (TMORS, ORS) - Page 3 of 13

WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P Ie a d in g s \T e m p o ra ry O rd e r o f C h ild S u p p o rt.d o c

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

The obligor may be able to seek reim bursem ent for day care or special child
rearing expenses not actually incurred. RCW 26.19.080.

3.4

Service of Process
Service o f 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 o f written notice to the obligor or
obligee at the last address provided

4
5
6

3.5

Transfer Payment

The obligor parent shall pay the following am ounts per month for the following
child(ren):

10

Name

11

KOLBY GOFF____________________________

$5WW-*fl

_________

12

Total Monthly Transfer Amount

$566 .58

_________

13

The obligor parent's privileges to obtain or maintain a license, certificate,


registration, permit, approval, or other sim ilar 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 o f a m otor vehicle m ay be denied or m ay be suspended if the
obligor parent is not in compliance with this support order as provided in
Chapter 74.20A Revised Code o f Washington.

14

<5
16
17

3.6

Standard Calculation
(CW.OO
$ 'i & 5 8 _ per month. (See W orksheet line 17.)

3.7

Reasons for Deviation From Standard Calculation

18
19

A m ount

The child support am ount ordered in paragraph 3.5 does not deviate from the
standard calculation.

20
21

3.8

Reasons why Request for Deviation Was Denied

22
A deviation was not requested.
23

Order of Child Support (TMORS, ORS) - Page 4 of 13

WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

3.9

Starting Date and Day to Be Paid


Starting Date:
Day(s) o f the month support is due:

3.10

(rW i

Incremental Payments
Does not apply.

3.11

ICL

Making Support Payments

lo I l (
jW U

e><f

W - U lU L tf

Ckikcl ( h ^ p o < f o 'W

CK.

(^ .U ^ U A -d /v A ( t f d O c L

Select Enforcem ent and Collection, Paym ent Services Only, or Direct Payment:
[]

Enforcem ent and collection: The Division of Child S upport (DCS) provides
support enforcem ent services fo r this case because: [ ] this is a public
assistance case, [ ] this is a case in w hich 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
paym ents shall be m ade to:
W ashington State S upport Registry
P. O. Box 45868
Olympia, W A 98504
Phone:
1-800-922-4306 or
1-800-442-5437

[]

Paym ent services only: The Division o f Child S upport will process and
keep a record o f all paym ents but will not take any collection action.
S upport paym ents shall be m ade to:
W ashington State Support Registry
P. O. Box 45868
Olympia, W A 98504
Phone:
1-800-922-4306 or
1-800-442-5437
Direct Payment: Support paym ents shall be made directly to:
Name
Mailing A ddress

A party required to m ake paym ents to the W ashington State Support Registry will
not receive credit fo r a paym ent made to any other party or entity. The obligor
parent shall keep the registry inform ed w hether he or she has access to health
Order of Child Support (TMORS, ORS) - Page 5 of 13
W P F D R 0 1 .0 5 0 0 M a n d a t o r y (0 6 / 2 0 1 4 ) - R C W 2 6 .0 9 .1 7 5 ;

2 6 .2 6 .1 3 2

Goff, Brent and Goff-Englehard, Victoria


S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

insurance coverage at reasonable cost and, if so, to provide the health insurance
policy information.

A ny tim e the Division of Child Support is providing support enforcem ent services
under RCW 26.23.045, or if a party is applying fo r support enforcem ent services
by signing the application form on the bottom of the support order, the receiving
parent m ight be required to subm it an accounting of how the support, including
any cash m edical support, is being spent to benefit the child(ren).

3
4
5
6

7
8

3.12

Wage Withholding Action


W ithholding 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, w ithout further notice to the obligor parent at
any tim e after entry of this order unless an alternative provision is made below:

11

[If the court orders im m ediate wage withholding in a case where Division of Child
Support does not provide support enforcem ent services, a m andatory w age
assignm ent under C hapter 26.18 RCW must be entered and support paym ents
must be made to the Support Registry.]

12

[]

10

13

W age withholding, by notice of payroll deduction or other income


w ithholding action under Chapter 26.18 RCW or C hapter 74.20A RCW,
w ithout further notice to the obligor, is delayed until a paym ent is past due,
because:

14
[]

the parties have reached a written agreem ent that the court
approves that provides for an alternate arrangem ent.

[]

the Division o f Child Support provides support enforcem ent


services for this case [see 3.11] and there is good cause [as stated
below under "Good Cause"] not to require im m ediate income
w ithholding which is in the best interests of the child(ren) and, in
m odification cases, previously ordered child support has been
tim ely paid.

[]

the Division o f Child Support does not provide support enforcem ent
services fo r this case [see 3.11] and there is good cause [as stated
below under "Good Cause"] not to require im m ediate income
withholding.

15
16
17
18
19
20

Good Cause:

Order of Child Support (TMORS, ORS) - Page 6 of 13

WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

3.13

'V, I
V'l

9
!' j 2

Termination of Support
Support shall be paid:

3
provided that this is a tem porary order, until a subsequent child support
order is entered by this court.

4
5

3.14

Post Secondary Educational Support


The right to request post secondary support is reserved, provided that the right is
exercised before support term inates as set forth in paragraph 3.13.

9 6
i^t
1y

3.15

Payment for Expenses not Included in the Transfer Payment

Does not apply because all paym ents, except medical, are included in the
transfer paym ent.

of

H 9
[]

\ 11
H 12
13

The petitioner shall pay 53% and the respondent 47% (each parents
proportional share o f incom e from the Child Support Schedule W orksheet,
line 6 ) of the follow ing expenses incurred on behalf of the child(ren) listed
in Paragraph 3.1:)
[]
day care.
[]
educational expenses.
[]
long distance transportation expenses.
[]
other:

14
Paym ents shall be m ade to [ ] the provider of the service [ ] the parent
receiving the transfer payment.

15
[]

16

The obligor shall pay the following am ounts each month the expense is
incurred on behalf of the child(ren) listed in Paragraph 3.1:

17
[]
18
[]
19
[]
20

[]

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:

21

3.16

Periodic Adjustment

22
Does not apply.
23

Order of Child Support (TMORS, ORS) - Page 7 of 13

WPF DR 01.0500 Mandatory (06/2014) - R C W 26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \T e m p o ra ry O rd e r o f C h ild S upport, d o c

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, W A 98499
253-581-0660

3.17

Income Tax Exemptions

Tax exem ptions for the child(ren) shall be allocated as follows:


3

l j3 a ^ y g . iH v .

tr>

4
The parents shall sign the federal incom e tax dependency exem ption waiver.
5

3.18

Medical Support - Health Insurance

7
8

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 com plete
sections B and C. Section D applies in ali cases.)

9
A.

13

Evidence
(1) [ ] There is insufficient evidence for the court to determ ine which
parent must provide coverage and which parent m ust contribute a
sum certain. Therefore, the court is not specifying how insurance
coverage shall be provided. The petitioners and respondents
m edical 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.

14

OR

15

(2) [ ] There is sufficient evidence for the court to determ ine which parent
m ust provide coverage and which parent must contribute a sum
certain. Fill in B and C below.

10
11
12

16
17
B.

Findings about insurance:

18
[]
[*T

19

20
21
22
23

BR ENT GOFF
(Parents Name)

11

Does not apply because A (1) is checked, above.


The court makes the following findings:
VIC TO R IA GOFFENGLEHARD
(Parents Name)

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).

Order of Child Support (TMORS, ORS) - Page 8 of 13


WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \T e m p o m ry O rd e r o f C hild S u p p o rt.d o c

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood WA 98499
253-581-0660

1
2

l '/ '

3
4

[ ]

5
6

[ ]

7
8

[ ]

9
10

[ ]

11
12

13

[ ]

[ ]

14
15
16

Insurance coverage for the child(ren) is


available and accessible to this parent at
$ lfTiP 9cost (child(ren)s portion of the
premium, only).
Insurance coverage for the child(ren) is
available but not accessible to this parent at
$
cost (child(ren)s portion of the
premium, only).
Insurance coverage fo r the child(ren) is
available but not accessible to this parent at
$
cost (child(ren)s portion of the
premium, only).
Neither parent has available or accessible
insurance through an em ployer or union; but
this parent is able to provide private coverage
at a cost not to exceed 25% of this parents
basic support obligation.
Neither parent has available or accessible
insurance through an em ployer 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 o f the
child(ren), the cost and extent of each parents
coverage, and the accessibility of the
coverage.
Other:

[ ]
17
18
^9
C.

P arties obligations:

20
21

Does not apply because A (1) is checked above.


The court m akes the following orders:

22

23

Order of Child Support (TMORS, ORS) - Page 9 of 13


WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1 \Goff-EngelharcNDRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660

1
2

3
4

BRENT GOFF
(P arents Name)

VIC TO R IA GO FFENGLEHARD
(Parents Name)

11

5
6

11

11

t ]

[ i

[ i

[ i

9
10

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
lonq as the cost of such coveraae does not
exceed 25% of this parents basic suDDort
obligation.
This parent shall provide health insurance
coverage fo r the child(ren) that is available
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 :

11
12

13
14
15
16
17
18
19
20
21
22

23

This parent shall provide private health


insurance coverage for the child(ren) as long
as the cost o f such coveraae does not exceed
25% o f this parents basic support obligation.
This parent shall provide private health
insurance coverage fo r the child(ren) even
thouqh the cost of such coveraae 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 :

This parent shall pav $


towards the
health insurance prem ium being paid by the
other parent. This am ount is this parents
proportionate share of the premium or 25% of
this parents basic support obligation,
w hichever is less. This paym ent 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
[ i
W orksheet and included in the transfer
payment.
Order of Child Support (TMORS, ORS) - Page 10 of 13
FAUBION, REEDER
WPF DR 01.0500 Mandatory (06/2014) - RCW26.09.175; 26.26.132
FRALEY & COOK, P.S.
Goff, Brent and Goff-Englehard, Victoria
5920 100th Street SW, Suite 25
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \T e m p o ra ry O rd e r o f C hild S u p p o rt.d o c
Lakewood, WA 98499

11

[ i

iS

253-581-0660

1
2

[ ]

[ ]

This parent shall be excused from the


responsibility to provide health insurance
coverage and from the responsibility to
provide m onthly paym ent towards the
prem ium because :

4
(Only one parent may be excused.)

5
6

7
8

9
10
11
12

13
14
15
16
17
18
19
20

D.

Both parties obligation:


If the child(ren) are receiving state financed medical coverage, the
Division o f Child Support may enforce the responsible parents m onthly
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 em ployer or
union and no conversion privileges exist to continue coverage following
term ination of em ploym ent.
A parent w ho is required under this order to provide health insurance
coverage is liable fo r any covered health care costs fo r which that parent
receives direct paym ent from an insurer.
A parent w ho is required under this order to provide health insurance
coverage shall provide proof that such coverage is available or not
available w ithin 20 days of the entry of this order to the other parent or the
W ashington State Support Registry if the parent has been notified or
ordered to make paym ents to the W ashington State Support Registry.
If proof that health insurance coverage is available or not available is not
provided within 20 days, the parent seeking enforcem ent or the
D epartm ent of Social and Health Services may seek direct enforcem ent of
the coverage through the other parents em ployer or union w ithout 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.

21

3.18.2 Change of Circumstances and Enforcement


22

23

A parent required to provide health insurance coverage m ust notify both the
Division of Child Support and the other parent when coverage term inates.

Order of Child Support (TMORS, ORS) - Page 11 of 13


WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132
Goff, Brent and Goff-Englehard, Victoria
S :\C A S E S 1 \G o ff-E n g e lh a rd \D R A F T S \P le a d in g s \T e m p o ra ry O rd e r o f C h ild S u p p o rt.d o c

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660

If the parents circum stances change, or if the court has not specified how
m edical support shall be provided, the parents m edical 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 m edical support obligation by doing one of the
following, listed in order o f priority:
1) Providing or m aintaining health insurance coverage through the parents
em ploym ent or union at a cost not to exceed 25% o f that parents basic
support obligation;
2) Contributing the parents proportionate share of a m onthly 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 m onthly 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 fo r
w hich there is an assignm ent.
A parent seeking to enforce the obligation to provide health insurance coverage
may apply for support enforcem ent services from the Division of Child Support;
file a m otion fo r contem pt (use form W PF DRPSCU 05.0100, M otion/Declaration
for an O rder to Show Cause re Contempt); or file a petition.

3.19

Uninsured Medical Expenses


Both parents have an obligation to pay their share of uninsured m edical
expenses.
5^
The petitioner shall pay,53% of uninsured m edical expenses (unless
stated otherwise, the petitioners proportional share of incom e from the
W orksheet, line 6 ) and the respondent shall pay.47% of uninsured m edical
expenses (unless stated otherwise, the respondents proportional share of
incom e from the W orksheet,
line 6 ).
m

3.20

Back Child Support

\J 0 t^

Back cfc^ild support that nftay be owed iSmot affected by this order.
Back interest that may be o ^ e d is not affected by tros order.

3.21

Past Due Unpaid Medical Support


Unpaid m edical support that may be owed is not affected by this order.
Back interest that may be owed is not affected by this order.

Order of Child Support (TMORS, ORS) - Page 12 of 13

WPF DR 01.0500 Mandatory (06/2014) - RCW26.09.175; 26.26.132


Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

3.22

Other Unpaid Obligations


O ther obligations that may be owed are not affected by this order.
Back interest that may be owed is not affected by this order.

3.23

Other
Does not apply.
/A c ?

Dated:

Commissioner MARK L UELMAN

COURT COMMISSIONER
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.

Tpproved by:
Notice o f presentation waived:

Daniel Ns^ e e k r W S B A #34866


Attorney fo r Respondent

Hillary H olr
A ttornew fo

Approved and agreed by:


A signature below is actual notice of this
order.

ApprovW -arrd agreed by:


A signature below is actual notice o f this
order.

Victoria Goff-Engelhard, Respondent


[]

s, W S B A #26208
etitioner

off, Petitione

I apply fo r full support enforcem ent services from the D SHS 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.)
Signature of Party

[]

Approval required in Public A ssistance cases. The D SHS Division of Child


Support received notice required by RCW 26.23.130. This OFdgrJii
reviewed and approved as to:
,
.
IN OPEN COURT
[]
[]
[]
[]

Current Child Support


Back Child Support
Medical Support
Other:

OCT0 2 2014
PIERCE C|

1TY, Clerk

Deputy Prosecuting Attorney/W S B A


Order of Child Support (TMORS, ORS) - Page 13 of 13
WPF DR 01.0500 Mandatory (06/2014) - RCW 26.09.175; 26.26.132
Goff, Brent and Goff-Englehard, Victoria
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order of Child Support.doc

FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660

E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 01 2014 11:26 AM
KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

-4.
tfi[ft

Washington State Child Support Schedule Worksheets


[ ] Proposed by [ ]
[ ] State of WA [ ] Other
Or, [ ] Signed by the Judicial/Reviewing Officer, (CSW)
'J

Mother Victoria Goff-Engelhart


County PIERCE

(CSWP)

Father Brent Goff


Case No. 08-3-03291-3

Chiidfren) and Agefs): Kolby Goff, 13

Part I: Income (see Instructions, page 6)


1. Gross Monthly Income
__ a. Wages and Salaries {Imputed for Mother)
.3 9 4 i.,r J .
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e. Other Income
f. Imputed Income
gTotal Gross Monthly Income (add lines 1a through 1f)
2. Monthly Deductions from Gross Income
a. Income Taxes (Federal and State) Tax Year: 2014
b.FICA (Soc.Sec.+Medicare)/Self-Emplovment Taxes
.*?
c. State Industrial Insurance Deductions
u
...
d.Mandatory Union/Professional Dues
e.Mandatory Pension Plan Payments
f. Voluntary Retirement Contributions
iT 'i. n o
g.Maintenance Paid
h. Normal Business Expenses
i. Total Deductions from Gross Income
(add lines 2a through 2h)
3. Monthly Net Income (line 1g minus 2i)
4. Combined Monthly Net Income

~ U W T ~

Father
$9,-750*0

Mother
-

$$750:00
T~7
an i n
yOTUiwV

$22%.88
-

- $3,266.60
$3,266.60
$275.85
$249.90
-

StJotjT-cA
$525.75
$2,740.85
$5t+1C76
^ *:
$s*5 5 .e r

(line 3 amounts combined)

5. Basic Child Support Obligation (Combined amounts -)


Kolby Goff
$1056:60 ( 0 3 j '

6. Proportional Share of Income


(each parent's net income from line 3 divided by line 4)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 1 of 5


i

i1UJS
r\ 3 1
$1,050*0-

3~2.T
.532

> :>

t;-vft' 1
** .. tA--
M ^7 o
.468

Part II: Basic Child Support Obligation (see Instructions, page 7)


7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations (Each parent's Line 6 times Line 5.)
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 Monthlv Net Income Less Than Self-SuDDort Reserve? If ves.
for that parent enter the presumptive $50 per child.
c. Is Monthlv Net Income eaual to or more than Self-Support
Reserve? If yes. for each parent subtract the self-support
reserve from line 3. If that amount is less than line 7, enter that
amount or the presumptive $50 per child, whichever is greater.
9. Each parent's basic child support obligation after calculating
applicable limitations. For each parent, enter the lowest amount
from line 7, 8a - 8c, but not less than the presumptive $50 per
child.

$401.40

| $4316.00

------------------------

'

. .

$494:40

$65fe66'

Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)

10. Health Care Expenses


Father
Mother
a.
Monthly Health Insurance Paid for Child(ren)
- _____$15.00
b.
Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Monthly Health Care Expenses
(line 10a plus line 10b)
$15.00
d.Combined Monthly Health Care Expenses
$15.00
(line 10c amounts combined)
/W. J11 . Day Care and Special Expenses
.
.
a. Day Care Expenses
b. Education Expenses

c.Long Distance Transportation Expenses


d. Other Special Expenses (describe)

e.Total Day Care and Special Expenses


(Add lines 11a through 11d)
12. Combined Monthly Total Day Care and Special Expenses

J4,
*

(line 11e amounts Combined)

13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)

:Y
'

$15.00
a_Q n

<pr .Jlr

1 - L O

Part IV: Gross Child Support Obligation

15. Gross Child Support Obligation (line 9 plus line 14)

$566.SB-1

$408.42

PartV: Child Support Credits (see Instructions, page 9)

16. Child Support Credits


a. Monthly Health Care Expenses Credit
b.
Day Care and Special Expenses Credit
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 2 of 5

$15.00

c. Other Ordinary Expenses Credit (describe)


*
-

d.Total Support Credits (add lines 16a through 16c)

$15.00

Part VI: Standard Caleulation/Presumptive Transfer Payment (see Instructions, page 9)

17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)

^$666^8

$463.42

Part VII: Additional Informational Calculations

18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
$1*401*64
19. 25% of each parent's basic support obligation from fine 9 (.25 x
amount from line 9 for each parent)
W 5 '
Part VIII: Additional Factors for Consideration (see Instructions, page 9)
20. Household Assets
Father's
(List the estimated value of all major household assets.)
Household
a. Real Estate
b.Investments
c. Vehicles and Boats
.
d.Bank Accounts and Cash
e. Retirement Accounts
f. Other: (describe)

$1-29338
$122*85

Mother's
Household

21. Household Debt


(List liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
22. Other Household Income
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name Jeffrey Engelhart
Name
b. Income Of Other Adults in Household
Name
Name
c. Gross Income from overtime or from second jobs the party
is asking the court to exclude per Instructions, page 8
d. Income Of Child(ren) (if considered extraordinary)
Name
Name
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 3 of 5

$2,694.00
-

e. Income From Child Support


Name
Name

f. Income From Assistance Programs


Program
Program

.
-

g.Other Income (describe)


.
-

................... :...
23. Non-Recurring Income (describe)

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


Child(ren)
Name/age:
Paid f ] Yes [ l No
Name/age:
Paid f l Yes f l No
Name/age:
Paid [ l Yes f l No
25. Other Child(ren) Living In Each Household
(First name(s) and age(s))

26.

Mother's
Household

Father's
__Household__

Other Factors For Consideration

Basis for Wag es^pd^Sa lanes for FathenJ&3r?52Jl&-^


$40tToO Annually--------

Basis for Imputed Income for Mother: $3,266.58


$39,199.00 Annually

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
tsheets is complete, true, and correct.

/orksheet certify/ d t^yQUf^laieQM/b^d&i^ME&iministrative Office of the Courts.


Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 Page 5 o f 5
Sup portCa/c* 2014
c;,.Estate templates\wawork6heetdtf m;\scdata\goff-engelhartVgoff-engelhartscp 07/30/2014 10:59 am

V'-
1
2
3
4
5

6
7

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

9
10
11

In re:

No. 08-3-03291-3

BRENT D. GOFF,

Temporary Order
(TMO)

Petitioner,

12

and

13

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.

14
15

I. Money Judgment Summary

16

Does not apply.

17
18
19

20

II. Basis
A m otion for a tem porary order was presented to this court and the court finds
reasonable cause to issue the order.

21
22

III. Order
It is Ordered.

23

3.1

Restraining Order

24
25

There are no restraining orders in effect under this cause num ber and the court is
not entering one now.
Temp Order (TMO) - Page 1 of 3
WPF DR 04.0250 Mandatory (06/2012) - RCW26.09.060; .110;. 120;. 194, .300(2)

Goff and Goff-Englehard


S:\C4 SES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order, docx

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

5920-100 Street SW, Ste 25


Lakewood, WA 98499
253-581-0660

3.2

Temporary Relief

Child support shall be paid in accordance with the order of child support, signed by
the court.

Adequate Cause is established to modify the parties parenting plan.

The following residential provisions for the child KOLBY GOFF (age 13) shall control:

KOLBY shall reside primarily with the VIC TO RIA G O FF-ENGLEHARD.

7
KOLBY and the father and the m other shall engage in functional family
therapy. The therapist shall be chosen by mutual agreem ent giving
consideration to the factors of cost, insurance coverage and availability of
the therapist. Issues such as frequency, length and duration of therapy
shall be guided by the therapist.

9
10

V
(
J
^

13

KOLBY shall have residential time with his father as agreed between
KOBLY, the father and the mother.
vprfc/U <J!rvU
KoUiu a o d
fir
crcUaEilhei pdi en lm a y move fui m odification o fth o c o residential provisions
anchor ootablichm ont of a fu ll parenting plan-0 6 days after entry of th is .

14

^(V\H jfy^irVr -T AWzU W . tYv/r<yjur gy a P ir r U o i L u - i __io c io r)

11
12

15
16
17
18
19

\W * c

Oi-u

W.tAKj fiV d

f*
^ ____
W - fY & W L r d l U i b r . fa r r w fS arlA Q
TCio m ^
V Y .( ^ \lr iio cV\?U ryrA .vrta .
rispAaoSis; r& r (AoU m^ f
p f A t l i df>CftO0gU 0 *>
Jrvy
......
L ((, nnyvpH/oil/WonJ . 0 r>no ta'nV- ,4Vt f f kjjL- dW?U' r t vi tu) 4W rr^ c U W t
- W t f i t fe.VW, .------ ---------------------p--------------- ---------------------------------------H p IK a U
<foorX XcfiooV ^ r C ir ifw > o c ^ ,______________
__ U
5 IV Arccii__ W: ^*K_f w ouI j o f i U A lvt| *
u y,

20
21
22

23
24
25
Temp Order (TMO) - Page 2 o f 3
WPF DR 04.0250 Mandatory (06/2012) - RCW26.09.060; .110;. 120;. 194, .300(2)

Goff and Goff-Englehard


S:\CASES1\Goff-Engelhard\DRAFTS\Pteadings\Temporary Order.docx

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

/ '

3.3

B o n d o r S e c u rity

Does not apply.

3
4
5
6

3.4

O th e r
Does not apply.

Dated:

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^ / C o m m is s io n e r
'

m ark

|_ GELMAN

Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.

Approved by:

COURT COMMISSIONER

Daniel N. Cook, WSB7T#3486t!


A ttorney fo r Respondent

H illa r y ftd A ^ s , W S B A #26208


A tto rn e y 'fo rV e titio n e r

Approved and agreed by:


A signature below is actual notice of this order.

ApproveeF^nd agreed by:


A signature below is actual notice of this order.

Notice of presentation waived:

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Temp Order (TMO) - Page 3 of 3
W P F D R 0 4 .0 2 5 0 M a n d a to ry (06/2012) - R C W 2 6 .09 .0 6 0 ; .1 1 0 ;. 1 2 0 ;. 194, .300(2)

Goff and Goff-Englehard


S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Temporary Order.docx

FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660

IN COUNTY

office

Superior Court
of the
S tate of Washington
for Pierce County
334 COUNTY-CITY BUILDING
930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108

SUPERIOR COURT
(253) 798-3654

October 9, 2014

HILLARY ANN HOLMES


ATTORNEY AT LAW
317 S Meridian
PUYALLUP, WA 98371-5913

Daniel N Cook
ATTORNEY AT LAW
5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751

Dear Counsel/Litigant:
This is to confirm the following settlement conference:
Case:
Cause No.:
Before:
Date & Time:

BRENT D GOFF VS. VICTORIA J GOFF


08-3-03291-3
Judge FRANK CUTHBERTSON, County-City Bldg, Courtroom 2A
Mar 24 2014 4:15PM

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.

SfffefcreKr
Rasheedah McGoodwin
Judicial Assistant
CC: Pierce County Clerk for Filing

Superior Court
of the
tate of Washington
for Pierce County
1
334 COUNTY-CITY BUILDING
930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108

SUPERIOR COURT
(253) 798-3654

',JU

October 24, 2014


!"0
HILLARY ANN HOLMES
ATTORNEY AT LAW
317 S Meridian
PUYALLUP, WA 98371-5913

Daniel N Cook
ATTORNEY AT LAW
5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751

Dear Counsel/Litigant:

i"v*

This is to confirm the following settlement conference:


Case:
Cause No.:
Before:
Date & Time:

BRENT D GOFF VS. VICTORIA J GOFF


08-3-03291-3
Judge FRANK CUTHBERTSON, County-City Bldg, Courtroom 833
Mar 24 2015 4:15PM

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.

Rasheedah McGoodwin
Judicial Assistant
CC: Pierce County Clerk for Filing

E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHIN<

January 05 2015 2:15 P

KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-3

3
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5
6

S uperior C o u rt of W ashington
C ounty of Pierce

In re the M atter of:

10

BRENT GOFF

11
12

No. 08-3-03291-3
Petitioner,

and

P E T IT IO N E R S D ISC LO SU RE OF
PR IM A R Y W ITN ESSES

VICTORIA GOFF
R espondent.

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PCLR 5

14

COMES NOW, the BRENT GOFF in the above entitled action and hereby discloses the
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following primary witnesses which the petitioner may call at time o f trial:
1.

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Name:
Address and Phone Number:

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Brent G off
c/o Hillary A. Holmes
317 S. Meridian
Puyallup, WA 98371
253-848-3513

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Brief Description o f relevant knowledge: All facts regarding this matter


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2.
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Name:
Address and Phone Number:

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Victoria Goff
c/o Daniel Cook
Attorney at Law
5920 100th Street SW, Ste 25
Lakewood, WA 98499

Brief Description o f relevant knowledge: All facts regarding this matter


Disclosure of Primary Witnesses - Page 1 of 2
I:\DATA\D\HAH\D\Goff, Brent.002\Disclosure of Primary Witnesses.rtf

CAM PB ELL, D IL L E , B AR NETT,


& S M IT H , P.L.L.C.
A ttorneys at Law

317 South Meridian


Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

Petitioner reserves the right to add further witnesses to this Witness list upon completion

3
o f discovery or to rebut exhibits/testim ony offered by Respondent.

4
D A T E D this 26th day o f December, 2014.

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7

Hillary A. HolmesYWSBA #26208


O f Campbell, Dille\Barnett & Smith, P.L.L.C.
Attorney for Petitioner

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Disclosure o f P rim ary W itnesses - Page 2 of 2


I:\DATA\D\HAH\D\Goff, Brent.002\Disclosure o f Primary Witnesses.rtf

CAMPBELL, DILLE, BARNETT,


& SMITH, P.L.L.C.
Attorneys at Law

317 South Meridian


Puyallup, Washington 98371
253- 848-3513
253- 845-4941 facsimile

E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHIN

January 29 2015 1:54 F


KEVIN STOCK
COUNTY CLERK

NO: 08-3-03291-1

3
4
5

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8

SUPERIOR COURT OF WASHINGTON


COUNTY OF PIERCE

9
In re:

10

No. 08-3-03291-3

BRENT D. GOFF,
Petitioner,

11

and

12

VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.

13

RESPONDENTS
DISCLOSURE OF PRIMARY
WITNESSES

14
COMES NOW the Respondent, Victoria J. Goff, by and through her attorney of

15
record, Daniel N. Cook, o f Faubion, Reeder, Fraley & Cook, P.S. and subm its the

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following list o f prim ary w itnesses fo r the trial scheduled for April 13, 2015.

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The following witnesses may testify as to their personal observation o f the

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Petitioner, Respondent, and any other related pertinent matters.

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WITNESSES EXPECTED TO BE CALLED AT TIME OF TRIAL
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1. Victoria J. Goff
c/o Daniel Cook
Faubion, Reeder, Fraley & Cook, P.S.
5920 100th Street SW, Suite 25
Lakewood, W A 98499

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W itness is Respondent in this matter and m ay testify as to all facts relevant to the
case.
WITNESS LIST - Page 1 of 2
S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Witness List.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

2
3
4

2. Brent D. G off
c/o Hillary Holm es
Campbell Dille Barnett & Smith PLLC
317 S Meridian
Puyallup, W A 98371-5913

W itness is P etitioner in this m atter and will testify as to all facts relevant to the
case.

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8

EXPERT WITNESS EXPECTED TO BE CALLED AT TIME OF TRIAL


1. A psychologist or counselor w ho has worked with the m inor child.

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The Respondent reserves the right to call any w itnesses disclosed by the other

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party w hether or not the other party elects to call that witness.

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The Respondent reserves the right to amend his disclosure o f w itnesses as
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discovery in this action proceeds.

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The Respondent reserves the right to call w itnesses necessary for rebuttal of

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testim ony offered by Petitioner.

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17

Dated th is c^-7

day of

2015.

Subm itted by:

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

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C

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By Daniel N. Cook, W S B A 34866


O f Attorneys fo r Respondent

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22

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WITNESS LIST - Page 2 of 2


S:\CASES1\Goff-Engelhard\DRAFTS\Pleadings\Witness List.doc

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

5920 100th Street SW, Suite 25


Lakewood, WA 98499
253-581-0660

08-3-03291-3

44224100

NONC

03-03-15

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR PIERCE COUNTY
BRENT D GOFF
Petitioner(s)

No. 08-3-03291-3
vs.
VICTORIA J GOFF

NOTICE OF NONCOMPLIANCE
AND ORDER SETTING
NONCOMPLIANCE HEARING

Respondent(s)

Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case Schedule in
regard to the following item:
Response - Not Filed

Deadline:

10/03/14

You are hereby ORDERED to appear for a hearing at 1:30 pm on Friday, 03/20/15 to comply with the Case
Schedule, or deliver a report of the same no later than the time set for the hearing.
The court may impose sanctions or terms for failure to comply with the Case Schedule. If the court finds that an
attorney or party has failed to comply with the Case Schedule and has no reasonable excuse, the court may order
the attorney or party to pay monetary sanctions to the court, or terms to any other party who has incurred expense
as a result of the failure to comply, or both; in addition, the court may impose such other sanctions as justice
requires. See PCLR 3 (k).

DATED: 03/02/15
Department AREN
Phone #: 253-798-3654
Copies mailed to:

Hillary Ann Holmes


Daniel N Cook

TO:

Superior Court Clerk for Filing


(Court File Copy)
PAGE 1 OF 1

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