Académique Documents
Professionnel Documents
Culture Documents
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
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.
18741
08-3-03291-3
30563265
CICS
9/22/2688
09-22-08
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
10
BRENT D. GOFF
11
and
12
VICTORIA J. GOFF
u (IS 3 03291: 3
No.
Petitioner,
Summons
(SM)
Respondent.
13
14
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
17
18
19
20
21
22
23
24
25
Summons (SM) - Page 2 of 2
WPF DR 01.0200 (6/2006)- CR 4.
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
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
19
20
Identification of Respondent
1.3
21
1.4
18741
1.5
1.6
Separation
Husband and wife separated on 5/31/06.
1.7
Jurisdiction
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
14
15
1.9
17
The petitioner's recommendation for the division of debts and liabilities is set forth
below.
18
19
1.10
21
22
23
16
20
348
4
5
088
Spousal Maintenance
Spousal maintenance should not be ordered.
1.11
24
25
Pet for Disso of Marriage (PTDSS) - Page 2 of 4
WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020
1874 i
1.12
Protection Order
1.13
Pregnancy
The wife is not pregnant.
1.14
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
12
Name of
Child
Mothers
Name
Father's
Name
13
Victoria Goff
Brent Goff
14
15
16
17
18
19
20
21
348
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
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
18741
9^2222088
3401
f*
1.16
Other
Does not apply.
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.
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
[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
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
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
16
17
18
2.
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)
08-3-03291-3
30563273
CSW
09-22-08
IN
CouryF,cL
J& <
OFFICE
[ ] State of WA [ ] Other
. (CSWP)
Signed by the Judicial/Reviewing Officer. (CSW)
Father: Brent D. Goff
0SI 3 032:9'1! 3;
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.
Father
Mother
$2,990.00
$3,293.00
$2,990.00
$3,293.00
18741
972272888
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
.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)
348129
18741
9 /2 2 /2 8 6 8
Mother
$334.38 |
$366.62
Father
Mother
-
$334.38
$366.62
$334.38
$366.62
Father's
Household
Mother's
Household
-
346136
10741
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
340131
iS?4 1
Judge/Reviewing Officer
9/22s'2B88
Date
SupportCa/c 2008
346132
18741
9222^2088
340133
Kolby
$701.00
'
'
'
$35.05
"
$701.00
182
49.9
183
23. %OVERNIGHTS-FATHER
(Line 22 divided by 365)
50.1
.500
.500
$350.50
$350.50
91 NIGHTS
$334.38
$350.50
-$16.12
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.
Y, WA
PIERCE COUNTY,WASHINGTON
KEVIN STOCK, Grounty Clerk
' *
DEPUTY
BY____
8
9
10
BRENT D. GOFF
NoPetitioner,
11
and
12
VICTORIA J. GOFF
OS
03291;
Parenting Plan
Proposed (PPP)
Respondent.
13
14
15
16
17
I. General Information
This parenting plan applies to the following child:
18
Name
Age
19
20
21
22
23
24
25
2.1
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
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:
3
4
7
8
3.1
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
19
3.4
22
24
25
21
23
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
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
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
3
3.6
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
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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
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
17
18
Rank the order of priority, with 1 being given the highest priority:
19
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
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
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Other
3.14
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
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.
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
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
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
253-845-4941 - Facsimile
FamitySoft FormPAK 2007
18741
1
2
4.3
3481
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
15
(a)
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)
(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
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25
18741
S/'22^288S
3481
(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
Victoria Goff
Mother
[j
6
q - p 'O K
7
8
Brent Goff
Father
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10
11
12
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Dated:
Judge/Commissioner
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21
p o y ^ l ^ p
Presented by:
22
26208
23
Hillary A. H
Signature
or LawyerAA/SBA 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
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
3
'2 0 0 8
4
5
'
p.m .
DDEPUTE
10
11
12
13
14
CERTIFICATE OF PARENTING
SEMINAR FOR RESPONDENT
and
VICTORIA J. GOFF,
Respondent.
See attached
15
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- Page 1
525\D\GOFF, BRENT\A
18823
9^24/2808
V
I
Goff, Victoria
Has successfully completed the four-hour class,
80121
1 S 913
16'
IN COUNTY CLERICS'
a.m.
SEP 2 5 2008
p.m.
08-
-03291-3
30598204
PCOPC
* C0u^
09-26-08
c^ % 0Feice
4
5
"
"
1---- - DEPUTY
9
10
11
12
13
14
CERTIFICATE OF PARENTING
SEMINAR FOR PETITIONER
and
VICTORIA J. GOFF,
Respondent.
See attached
15
16
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22
23
24
25
26
- rage 1
525\D\GOFF, BRENTVA
18913
s\
9/26/2088
318164
J
i
This
Certificate of ghtenbance
is hereby awarded to
Brent G off
for attending and completing the
A .
Wende Wertley,TVlS
Brad Hoover, MA
Attendees are responsible fo r filing certificate with the appropriate case number
/ y
< w
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I f <*OA '
* i
i
223
1/2^2*309
88871
12-31-08
AJ- EC 3 12008
P.M
OlINTY, WASHikim
8=
DEPUTY
7
8
BRENT D. GOFF
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
, 2008.
22
23
f j/ #
24
25
:3 A 1
= i3 * /
% \
:5 s
%z - . V /*****
Print
NOTARY PU B LIC in and for the State of
Washington, residing at (rw^Vvscrv
My commission expires: (Y-\\-2Ptc>
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
P.E.
COUNTY OF PIERCE
7
8
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
day o f S c ^ f e ^ U i n ,2008.
22
%
23
P rinteJyante
24
25
VERIFICATI
ED DOCKET - Page 1 of 1
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
Dec
ri -
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
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
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
Separation Agreement
525\DVGOFF, BRENTVASEPAGMT. 090808
Page 3
223
1^2^2069
088?b
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
525\D\GOFF, BRENTVASEPAGMT.090808
Page
223
( 6)
(7)
( 8)
1/2/2009
0087?
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
Page
223
2 :2 2 2 8 8 9
88878
IX
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
Page
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
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
223
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.
)
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.
08- 3- 03291-3
BRENT GOFF
10
Petitioner,
and
11
VICTORIA GOFF
12
13
14
15
16
17
18
19
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
24
25
26
[
[
[
[
1
]
]
]
Lk
0%
10%
20%
30%
40%
50%
0%
10%
20%
30%
40% ^
50% S
223
[ ]
60%
60%
[
[
[
[
70%
80%
90%
100%
70%
80%
90%
100%
3
4
]
]
]
J
/ 2
2 0 9
00085
6
7
Father:
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:
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:
Dated this j f r
^ M ediation
[ ] Counseling
. 2008.
T lM t-
15
16
17
18
19
20
21
22
23
24
25
26
223
1
2
1/2/2889
08086
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
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
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
10
BRENT D. GOFF
No.
08- 3- 03291-3
Parenting Plan
Petitioner,
11
and
12
VICTORIA J. GOFF
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
19
20
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
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
253-845-4941 - Facsimile
FamilySoft FormPAK 2007
223
2.2
5
6
08888
3
4
1 ^2 '''2809
7
8
3.1
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
19
3.4
22
24
25
21
23
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
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
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
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
12
13
14
15
16
17
18
19
20
21
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
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
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
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
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
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
223
1/2/2009
and safety.
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.
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
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
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
223
1
2
4.3
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
15
(a)
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)
(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
253-848-3513
253-845-4941 - Facsimile
FamilySoft FonnPAK 2007
223
1
2
08094
3
4
1^2^2889
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
Goff, Victoria
Has successfully completed the four-hour class
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
This
Certificate of gfttenbance
is hereby awarded to
Brent G off
for attending and completing the
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
DEC 3 1 2008
PM
a.m,
8
9
10
BRENT D. GOFF
11
and
12
VICTORIA J. GOFF
No.
08-3-03291-3
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
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.
253-848-3513
253-845-4941 - Facsimile
223
1
2
i '2 / 2 0 0 9
08898
3.2
Age
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
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
223
1 /2 /2 6 0 9
66099
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
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
$-0$-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
20
21
22
Standard Calculation
3.7
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
223
1^ 2^ 2889
80180
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
6
Does not apply. A deviation was ordered.
7
3.9
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
22
24
Termination of Support
Support shall be paid:
19
23
18
21
16
17
Incremental Payments
Does not apply.
14
15
1st
3.15
253-845-4941 - Facsimile
223
1^ 2/2669
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.
3.16
Periodic Adjustment
Does not apply.
3.17
10
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
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
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
13
14
3.21
17
18
19
IN
Back Interest
COUNTY C l I r K'S
OEC 3 1 Z008
p*
15
16
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
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
Puyallup, WA 98371
253-848-3513
FamilySoft FormPAK 2007
223
1A2V2889
[ ] State of WA [ ] Other
. (CSWP)
Signed by the Judicial/Reviewing Officer (CSW)
Father: Brent D. Goff
Superior Court/OAH Case No.:
Worksheets
Children and Ages: Kolby Hunter Goff, 7
8184
Mother
Father
$2,990.00
$3,293.00
$2,990.00
$3,293.00
223
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
.477
.523
$334.38
$366.62
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 3)
S sJ HisIfF-?.
jr-^'jj'
-V
lH
.j
$35.05
**
u p s
i. 5
223
122^2089
Mother
Father
$334.38 |
$366.62
Father
Mother
$334.38
$366.62
$334.38
$366.62
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:
c.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 7/2007 Page 3 of 5
Mothers
Household
.
-
.
.
.
-
223 > i : X 2 ^ 2 e S S
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
6S18?
223
1/2/2009
SupportCa/c 2008
00108
2 2 3 i l -y .2 S 2 B B -9 & & 1B 9
Kolby
$701.00
$35.05
"
**
'
$701.00
182
49.9
183
23. %OVERNIGHTS-FATHER
(Line 22 divided by 365)
50.1
.500
.500
$350.50
$350.50
91 NIGHTS
$334.38
$350.50
-$16.12
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
8
9
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
16
17
18
2.1
19
20
2.2
21
22
23
24
25
Residency of Petitioner
2.3
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
12
16
Status of Marriage
A written separation agreement was executed on this date and is incorporated herein.
10
14
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
00111
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
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)
223
2.14
2
3
1/2,''20 89
80112
Protection Order
Does not apply.
2.15
5
6
2.16
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
14
16
Age
7
2.21
Other:
Does not apply.
24
253-848-3513
253-845-4941 - Facsim ile
223
1/2/2089
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
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
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)
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
223
1 /2 ^ 2 0 6 9
00115
C O ^
^S S LS g?^
4
5
6
7
8
9
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
15
Does not apply.
16
17
1.2
18
19
20
1.3
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:
223
3.1
1/2/2009
00116
3.2
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
19
21
15
17
11
13
3.8
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)
223
3.9
122'2809
00117
Protection Order
Does not apply.
3.10
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
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)
23?
l S 2 S 2d e 9
360190
Cause Number:08-3-03291-3
Petitioner(s)
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
GOFF, VICTORIA J
GOFF. KOLBY HUNTER
23?
1^2/2889
368191
vs.
Page: 2 of 2
Judge/Commissioner:
ROBYN LINDSAY
VICTORIA J GOFF
MINUTES OF PROCEEDING____________________
Court ReportenSmart Court
fu E D
p rteESepS
nT
Otc31im
:RCE CO)JNTV.Cl#f)
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
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.
PAGE 1 OF 2
ntiwdsup-0002.pdf
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.
PAGE 2 OF 2
ntiwdsup-0002.pdf
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.
ntaprsup-0001.pdf
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
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In re:
No. 08-3-03291-3
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BRENT D. GOFF,
Petitioner,
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and
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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.
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1.1
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Name (first/last) V IC TO R IA G O FF-EN G ELH ART
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1.2
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1.3
Dependent Children
Name (first/last) KO LBY G O FF
Age 13
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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
II. Basis
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2.1
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2.2
Adequate Cause
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There is adequate cause for hearing the petition for modification.
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2.3
Child Support
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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.
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2.4
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The requesting party/parties reside(s) in (county and state only) PIERCE CO, W A .
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The other party/parties reside(s) in (county and state only) PIERCE CO, W A
2.5
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This court has jurisdiction over this proceeding for the reasons below:
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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.
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2.6
Parents Name
VIC TO R IA GO FF-ENG ELHART
Parents Name
BRENT GOFF
for Modification
of Parenting
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Claims to custody or visitation:
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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.
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The requesting party has not been involved in any other proceeding
regarding the children.
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The requesting party does not know of, any other legal proceedings
concerning the children.
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2.7
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2.8
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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.
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2.9
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for Modification
of Parenting
2.10
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Does not apply.
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2.11
2.12
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Dispute resolution.
Decision making.
Transportation arrangements.
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2.13
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Pet for Mod/Adj Parenting Pin (PTMD) - Page 4 of 6
for Modification
of Parenting
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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.
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The parents arrange the daytime only visitation by text or phone call. The
m other has permitted visitation when requested.
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2.14
Protection Order
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Does not apply.
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2.15
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2.15.1 A. Service m em ber status - BRENT GOFF:
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B. Factual basis:
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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.
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B. Factual basis:
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2.16
Other
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/ I l l /
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I I I I I
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I I I I I
Pet for Mod/Adj Parenting Pin (PTMD) - Page 5 of 6
for Modification
of Parenting
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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.
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III. DECLARATION
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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.
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Signed at (city)
CaJQ Q Q
(state)
on (date)
/ $ $ /'/'
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Pet for Mod/Adj Parenting Pin (PTMD) - Page 6 of 6
for Modification
of Parenting
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
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
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
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.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTO
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
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SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
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In re:
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BRENT D. GOFF,
No. 08-3-03291-3
Petitioner,
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and
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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
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Summons(Modification/ Adjustment of
Custody Decree/Parenting Plan/
Residential Schedule)
(SM)
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To.
Brent Goff
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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.
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FAUBION, REEDER,
FRALEY & COOK, P.S.
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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.
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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:
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http://www.courts.wa.gov/forms
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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.
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This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state of Washington.
FAUBION, REEDER, FRALEY & COOK, P.S.
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Dated: - 7 / 3 6 / ? o ' /
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FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
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No. 08-3-03291-3
In re:
BRENT D. GOFF,
Petitioner,
and
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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
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Notice. State and federal law provide protections to defendants/respondents who are on
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active duty in the m ilitary service, and to their dependents. This notice only pertains to a
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reserve com ponent under a call to active service fo r a period o f more than thirty (30)
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the service m em bers spouse, a service m em bers m inor child, or an individual for w hom the
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service m em ber provided m ore than one-half o f the individuals support for one hundred
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eighty days (180) days im m ediately preceding an application fo r relief.
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Notice re: Dep. of Person in Military Service (NTDMP)
Page 1 of 2
FAUBION, REEDER,
FRALEY & COOK, P.S.
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One protection provided is the protection against the entry o f a default judgm ent in
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certain circum stances. If you are the dependent o f a m em ber o f the National Guard or a
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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
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
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default judgm ent w ithout further proof o f your status. Y our response to the plaintiff/petitioner
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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
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petition, com plaint or other application fo r relief that was filed against you.
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Notice re: Dep. of Person in Military Service (NTDMP) Page 2 of 2
FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
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In re:
BRENT D. GOFF,
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No. 08-3-03291-3
Petitioner,
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and
Parenting Plan
Proposed (PPP)
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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.
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I. General Information
This parenting plan applies to the following child:
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Nam e
Kolby G off
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Age
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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.
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2.1
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood WA 98499
253-581-0660
2.2
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:
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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
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3.2
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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.
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3.3
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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:
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3.4
FAUBION, REEDER,
FRALEY & COOK, P.S.
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3.5
Summer Schedule
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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:
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3.6
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3.7
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3.8
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3.9
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Does not apply.
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3.10
Restrictions
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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:
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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.
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3.11
Transportation Arrangements
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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.
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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
FAUBION, REEDER,
FRALEY & COOK, P.S.
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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.
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3.13
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Other
3.14
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
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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.
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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.
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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.
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4.1
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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.
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Day-to-Day Decisions
4.2
Major Decisions
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Education decisions
N on-em ergency health care
Religious upbringing
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4.3
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(c)
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m other
m other
m other
FAUBION, REEDER,
FRALEY & COOK, P.S.
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(d)
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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
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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
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The cost o f this process shall be allocated between the parties as follows:
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(a)
(b)
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(c)
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(d)
(e)
FAUBION, REEDER,
FRALEY & COOK, P.S.
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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.
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FAUBION, REEDER,
FRALEY & COOK, P.S.
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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.
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Dated:
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Judge/Commissioner
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
Approved by:
Notice of presentation waived:
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, W SBA #_
Attorney fo r Petitioner
Approved and agreed by:
A signature below is actual notice of this order.
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Victoria Goff-En
pondent
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FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
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In re:
No. 08-3-03291-3
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BRENT D. GOFF,
(MTAF)
and
VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGELHART,
Respondent.
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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.
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appoints a guardian ad litem on behalf of the m inor child if this matter is contested.
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DATED this 3 d
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood WA 98499
Phone: (253) 581-0660
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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
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o f my personal knowledge in support o f my request for Adequate Cause to modify the
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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
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BRENT got into fights which becam e increasingly severe. At tim es the fights were physical
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and there were some bruises left on Kolby. KOLBY and I also had disagreements but they
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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
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or so later. KOLBY did open up som ewhat to the second counselor and mentioned physical
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abuse by his father. The counselor reported the physical incidents to CPS and thereafter
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culminated in a m ajor blow-up in August 2012. After the blow-up BRENT dropped KOLBY off
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
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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.
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
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
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
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
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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11
12
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14
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Mtn/Decl for Temp Ord (MTAF) - Page 4 of 4
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
$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
$15.00
$7.98
$7.02
$566.58 |
$498.42
$15.00
-
$15.00
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
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)
Mother's
Household
.
-
$2,694.00
-
26.
Father's
Household
Mother's
Household
-
Judicial/Reviewing Officer
Date
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
BRENT GOFF
No. 08-3-03291-3
10
Petitioner,
Financial Declaration
[ Petitioner
[X]Respondent
(FNDCLR)
And
11
VICTORIA GOFF-ENGELHART
12
13
Respondent.
14
15
16
Date of Birth:
I. Summary of Basic Information
[X]
[ 1
17
18
19
20
$3,620.87
$842.00
$4,462.87
$3,750.00
Unknown
2.1
Occupation:
2.2
2.3
21
22
b. If no:
23
24
25
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
3.1
7
8
9
10
11
12
13
14
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
$635.24
$525.75
$3,114.76
$2,740.85
20
21
3.3
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
3.4
Miscellaneous Income
a.
3
b.
Brent Goff
Victoria GoffEngelhart
5
6
7
8
9
10
$2,694.00
11
12
c.
$2,694.00
13
3.5
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 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
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
8
9
5.4
10
11
12
5.5
13
14
5.6
17
20
21
22
$50.00
$50.00
Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
18
19
Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
Total Transportation
15
16
5.7
$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
5.8
2
3
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other: Netflix
Other:
5.9
7
8
$8.50
$8.50
$3,620.87
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)
SupportCa/c/FD 2014
1
2
3
$842.00
$4,462.87
Attorney Fees
4
6.1
6.2
6.3
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
17
18
19
20
21
22
t r
23
24
25
Financial Declaration (FNDCLR) - Page 6 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
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
No. 08-3-03291-3
NO: 08-3-03291-3
ORDER SETTING CASE SCHEDULE
BRENT D GOFF
Petitioner(s)
Type of case:
DIC
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
10/3/2014
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
10/3/2014
12/5/2014
12/26/2014
1/9/2015
1/23/2015
Week of 3/6/2015
3/13/2015
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.
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
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
9:00 AM
DATED:
August 1, 2014.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
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
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
9:00 AM
DATED:
August 1, 2014.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
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
3.
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.
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
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
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
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
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 21 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
Always Parents:
Families in Transition
Presented by
Always Parents
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
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
3
4
5
6
7
8
9
10
11
12
In re:
No. 08-3-03291-3
BRENT D. GOFF,
Petitioner,
13
and
14
VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
15
16
I. Motion
17
18
19
default against PETITIO NER, BRENT GOFF, o f this action is proper as set forth in the
20
Declaration below.
21
22
Dated
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
Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
II. Declaration
2
3
2.1
2.2
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
13
o
o
o
o
o
o
o
o
o
o
14
15
16
17
18
19
20
21
2.4
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
Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
2
2.6
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
10
B. Factual basis:
11
12
13
14
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
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
Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
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
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
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
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
3
4
5
6
7
8
9
In re:
10
BRENT D. GOFF,
11
No. 08-3-03291-3
DECLARATION OF MAILING
Petitioner,
and
12
13
VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
14
15
I, Sally DuCharm e, am over the age o f 18, and com petent to testify in the
above entitled case.
16
17
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:
18
1. Motion fo r Default.
19
20
21
Brent Goff
11911 -218th AVE C T E
Bonney Lake WA 98391
22
23
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.
24
DATED
25
,
_ /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.
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.
ntaprsup-0001.pdf
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
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
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
9:00 AM
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
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
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
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
9:00 AM
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
September 24 2014 10:28 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
Always Parents:
Families in Transition
Presented by
Always Parents
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<
1
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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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
19
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.
253- 848-3513
2 5 3 -8 4 5 - 4 9 4 1
facsimile
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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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
19
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
21
permissive, this did not help our child. It is important to note that children with ODD can then
22
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
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Concurrent with this, the mother started triangulating Kolby against me whether
2
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
10
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
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf
for him. His behavior calmed when sugar was removed. His mother allowed him to drink sports
2
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
10
time. I think it was a bit o f a challenge for her to parent Kolby, take care o f the new baby and
11
two other children, and work her job with the Washington State Department o f Revenue. As a
12
result, video games became the parent at his mothers home. He had a Gameboy that was over at
13
his moms that he played nonstop. He then obtained another gaming system and played games
14
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.
20
He was very disrespectful and inappropriate. As a result, I wanted to do what was right so I had
21
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
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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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
14
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
19
and I asked her for to call me upon return. She never did. I have reached out to her many other
20
times. The bottom line is that she has refused to sit down and meet with these issues. Mediation
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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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had two major disciplinary incidents. This was a dangerous behavior and insubordination.
2
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
13
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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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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Visit w ith K olby L ast W eek. I am in regular contact with Kolby. The mother alleges
2
that I am somehow estranged but we are extremely friendly. We text and call daily or every
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5
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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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Kolby Im m atu re . Kolby is an immature 13 year old. He has been given all this power
13
by his mom to choose when to come and see me and to run to his mom when he doesnt like the
14
discipline in my home. This is wrong. I have asked the mother to get on the same page with me
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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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between the mother and I to get on the same page then I am willing to do whatever it takes for
22
Kolby to be successful. If we continue down the path that we are with the mother submitting a
23
ridiculous parenting plan stating that Kolby can see me when he and his mother agree that he can
24
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
I:\DATA\D\HAH\D\Goff, Brent.002\Arespdecl.092514.rtf
1
this a b ility to choose whether to see me or not taken away from him w hich is what his mother
2
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
10
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.
12
Jennifer E vinger should be allow ed to expand residential tim e up to one-half tim e over
13
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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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
19
to pay it. I am proposing an in te rim transfer payment o f $269 effective September 1st. We
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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
09: 07
PAGE
PAPE MACHINERY
20657501B4
1
pace to make $47.910 this year. I then deducted my deductions and my net incbme is $2,987.
2
The mother voluntarily quit her job with the Department of Revenue. She then! was work ing
3
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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.
10
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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1
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S uperior C o u rt of W ashington
C ounty of Pierce
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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.
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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.
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09/25/2014
12:00
PAPE MACHINERY
2065750164
PAGE
14/31
Brent Goff
From:
Sent:
To:
Subject:
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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PAGE
16/31
Brent Goff
From:
Sent:
To:
Subject:
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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20/31
Brent Goff
From:
Sent:
To:
Subject:
09/25/2014
12:00
PAPE MACHINERY
20B5750164
PAGE
21/31
Brent Goff
From:
Sent:
To:
Subject:
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
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
8
In re:
BRENT D. GOFF
10
11
No. 08-3-03291-3
Petitioner,
Financial Declaration
[X]Petitioner
[ ]Respondent
(FNDCLR)
And
VICTORIA J. GOFF
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13
Respondent.
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[X]
[ ]
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$2,987.00
$2,798.09
$193.80
$2,991.89
$3,576.50
Unknown
2.1
2.2
2.3
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22
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24
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
13
14
15
a.
b.
c.
d.
e.
f.
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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
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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
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c.
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3.5
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:
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18
4.4
$3,800.00
-
$32,000.00
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V. Monthly Expense Information
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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
$200.00
$65.00
$120.00
$385.00
5
6
5.3
7
8
9
5.4
10
11
12
5.5
13
14
5.6
17
20
21
22
18
19
Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation
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Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
5.7
$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:
5.9
$2,798.09
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
PAGE
PAPE MACHINERY
2065750164
09: 07
i
i
1
2
3
$ 193.80
$2,991.89
6.1
6.2
6.3
6.4
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
17
18
19
20
21
22
J f r
[ ] 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
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
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
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
$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
$15.00
$15.00
$15.00
$7.36
$7.64
$538.13 |
$557.87
$15.00
$15.00
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
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)
Father's
Household
!
Mother's
Household
j
Father's
Household
Mother's
Household
-----------------------------------
26.
09/26/2014
09:07
2065750164
Judicial/Reviewing Officer
PAGE
PAPE MACHINERY
Date
SuppottCa/c * 201-1
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
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
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTC
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
3
4
5
6
7
8
9
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,
18
S eptem ber 26, 2014.
19
21
22
23
24
His position is
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 1 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
have left KOLBY with m e fo r two years.
2
100% o f the tim e but he did not take this back to court because he knew he would be
3
4
great deal.
hitting KOLBY.
10
not respectful, does not do his chores, or does not com plete his hom ework in my
11
12
I discipline KO LBY a
13
progressive system . If KO LBY does not do w hat BR ENT wants he is im m ediately totally
14
grounded.
15
with KOLBY, under the guise o f spanking.
16
17
18
19
who m ust do and say w hatever BRENT thinks is appropriate. BRENT does not allow any
20
21
22
put-downs from BR ENT eventually snowball into bigger issues and BRENT then has to hit
23
24
(spank) KOLBY.
BRENT.
So BR ENT is
KOLBY loves his father and w ants to spend short periods o f tim e with him but
25
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
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 KO LBY was doing as poorly in school as
BR ENT infers.
card from the end of 2013/2014. BRENT subm itted the 2012/2013 report card which
KOLBY.
10
incentives and consequences fo r poor school perform ance. This is discipline. By the end
11
12
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
13
subject. KOLBY had only had a single 1 on that report card and he did not com plete his
14
com puter class.
15
16
17
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.
18
attendance report from 2013/2014, but not the report card from 2013/2014 because it
19
showed KO LBY is doing fine - he still has room fo r im provem ent but it is clear that
20
KO LBY is m oving in the right direction. BR ENT is ju st trying to sm ear me to avoid child
21
support. BRENT has been happy to have KOLBY live in my home and virtually never see
22
23
24
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 3 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
BRENT says anything he can to sm ear me.
2
exposes the underlying problem with B R E N Ts parenting.
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.
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
11
12
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
13
BRENT. This is ludicrous and dem onstrates B R E N Ts 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
16
17
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
19
was ever a form al diagnosis. My recollection was that the therapist said he may m eet the
20
21
She m ay have coded item s in her com puter fo r insurance as ODD because this was the
22
closest possible diagnosis, but I do not believe he was ever form erly diagnosed. Second,
23
24
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 4 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
mentioned the abuse and CPS investigated BRENT).
2
another springboard fo r him to proudly proclaim he is the disciplinarian and to further
3
4
castigate me.
I was not the origin o f the CPS report.
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
CPS
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
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)
15
16
17
while
was talking on the phone and he wanted his hands free. KO LBY could and did go
18
w here I could hear the conversation but other tim es he talked in his room where I could
19
20
happened that som etim es I heard them because KO LBY w as using the speaker phone in
21
22
suggests that som ehow his m eant I was re-inforcing the idea that BRENT was bad.
23
Even BR ENT does not say I listened to all of the calls. It just
24
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 5 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
BRENT exaggerates KO BLYs behavioral problems by use o f imprecise
2
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
4
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
10
when he was spending half-time with BRENT just as he has had behavioral problems
11
12
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
13
BR ENTs claims that KO LBYs problems were all my fault are not true and
15
exaggerated. BRENT is exaggerating in an attem pt to justify his two year hiatus from in16
17
18
person contact.
On Page 3, BRENT again says he tried to work w ith me on solutions. He says
19
he did not w ant to reward bad behavior, accept invitations to fun events that he was
20
invited to and limit participation in extra-curricular activities. BRENT does not mention a
21
single specific intervention of this type. He just generalizes that he tried these things. If
22
he did, great, because I think those are more appropriate than spanking. But he does not
23
provide any specific exam ples o f how I disagreed with this approach.
24
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 6 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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 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
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
With KO LBY I have tried a reduced sugar diet and I have tried not allowing him to have
15
16
17
Gatorade.
BR ENTs claim that the new baby created a situation where it was too m uch for
18
me to care fo r KOLBY is also contradicted by his later actions. I did not allow video
19
gam es to becom e 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
hom ework KOLBY would choose to play outside with his friends. BRENT knew this and
22
his claim now that I was baby sitting KOLBY with the video gam e is illogical in light of
23
24
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 7 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
made more sense fo r BRENT to have KOLBY at least keep coming to his house half of
2
the time. But BR ENTs claim is false and that is w hy he was com fortable letting KOLBY
3
4
5
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.
8
9
10
11
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.
13
BRENT claim s 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
15
16
17
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 KOLBYs
21
22
23
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 8 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
3
4
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 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
10
have failed. BRENT always berates me and blames all of the problems on me and
11
12
KOLBY.
BRENTs entire declaration is all more of the same. At this point it is pointless
13
when he calls, I even answered while on my honeymoon because it is rare for BRENT to
14
call and I thought there m ight be something important to talk about.
15
16
17
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 BRENTs claims, I do discipline KOLBY in my house (I just dont spank him). The only
19
tim es 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
23
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.
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 9 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
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
11
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.
14
BRENT claims KO LBYs discipline problems are escalating. I agree there are
15
16
17
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
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
21
and KOLBY needs to be involved and feel safe in the relationship. Last time we went to
22
counseling KO LBY refused to open up after his Dad berated him fo r talking about the
23
spankings which led to the CPS investigation. The counseling should not just be an
24
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
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 of these and I am
working with KOLBY to get them turned in. Som e have already been turned in.
10
11
12
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.
call daily may be true - I do not monitor their conversations or com m unications but I was
13
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.
16
17
That conversation actually took place via text because when BRENT arrived to pick
18
KO LBY 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 w ay BRENT
21
found out KOLBY had been less than forthright was because I was the one involved.
22
23
24
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 11 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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.
3
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
modifications based upon a change in custody, or in this case, a change from 50/50 to
something else.
9
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 August 1, 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.
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 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
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 August since the motion was filed and
20
served on A ugust 5 and BRENT has paid no support for the last two years.
21
22
23
24
25
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
3
4
5
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
11
12
13
STATE OF W ASH IN G TO N TH A T THE FO REG O ING IS TRUE AN D CORRECT.
14
15
oma
16
17
18
19
20
21
22
23
24
25
Reply Declaration of VICTORIA GOFF- ENGELHART - Page 14 of 14
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
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
18
19
Petitioner,
20
falsely claims I am not a disciplinarian."
21
assassination of me and my parenting.
22
23
24
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 1 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
have left KO LBY with me for two years.
2
100% o f the tim e but he did not take this back to court because he knew he would be
3
4
5
great deal.
hitting KOLBY.
10
not respectful, does not do his chores, or does not com plete his hom ew ork in my
11
12
I discipline KO LBY a
13
progressive system . If KO LBY does not do w hat BRENT wants he is im m ediately totally
14
grounded.
15
with KOLBY, under the guise o f spanking.
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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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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
KO LBY loves his father and w ants to spend short periods o f tim e with him but
25
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
BRENT infers.
card from the end of 2013/2014. BRENT subm itted the 2012/2013 report card which
KOLBY.
10
incentives and consequences for poor school perform ance. This is discipline. By the end
11
12
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
15
struggled in were not core classes such as math, English, Social Studies or science.
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17
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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
21
support. BRENT has been happy to have KOLBY live in my home and virtually never see
22
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24
25
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.
2
exposes the underlying problem with B R E N Ts parenting.
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
11
12
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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17
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
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,
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24
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 4 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
m entioned the abuse and CPS investigated BRENT).
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.
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
CPS
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
13
phone by his own choice.
14
function but he chose not to. KO LBY would generally play gam es (e.g., Legos or cards)
15
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17
w hile
w as talking on the phone and he wanted his hands free. KOLBY could and did go
18
w here I could hear the conversation but other tim es he talked in his room where I could
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20
happened that som etim es I heard them because KO LBY was using the speaker phone in
21
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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
24
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 5 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 ictoria 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 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
11
12
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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18
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
19
he did not w ant to reward bad behavior, accept invitations to fun events that he was
20
invited to and limit participation in extra-curricular activities. BRENT does not mention a
21
single specific intervention o f this type. He just generalizes that he tried these things. If
22
he did, great, because I think those are more appropriate than spanking. But he does not
23
provide any specific exam ples o f how I disagreed with this approach.
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25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 6 of 13
FAUBION, REEDER,
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
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
15
16
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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
22
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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 7 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
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
3
4
5
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
11
12
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
15
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17
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
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22
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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
25
Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 8 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
3
4
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
11
12
KOLBY.
BR ENTs entire declaration is all more of the same. At this point it is pointless
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.
15
16
17
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
19
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
23
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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.
25
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 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
17
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
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
24
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).
25
Reply Declaration o f VICTORIA GOFF-ENGLEHARD - Page 10 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
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.
10
11
12
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.
call daily may be true - I do not m onitor their conversations or com m unications but I was
13
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.
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Reply Declaration of VICTORIA GOFF-ENGLEHARD - Page 11 of 13
FAUBION, REEDER,
FRALEY & COOK, P.S.
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.
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16
17
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
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22
23
BR ENTs com plaints are all generalized claims that I have not w orked with
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.
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
modifications based upon a change in custody, or in this case, a change from 50/50 to
something else.
10
11
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 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.
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.
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22
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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
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
oma
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Reply Declaration of VICTORIA GOFF- ENGELHART - Page 14 of 14
FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
October 02 201
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
BRENT D GOFF
Petitioner(s),
10
vs.
11
VICTORIA J GOFF
12
Respondent(s)
13
14
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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
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19
20
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Dated this 02 day of October, 2014
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25
/S/Mark L. Gelman
Mark L. Gelman
Judge/Commissioner
Q jS T rt^
For Petitioner
For Respondent
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1
2
3
4
5
6
7
9
In re:
BRENT D. GOFF,
10
No. 08-3-03291-3
Petitioner,
11
and
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VICTORIA J. GOFF
n/k/a VICTORIA GOFF-ENGLEHARD,
Respondent.
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I. Basis
1.1
1.2
A hearing was held on: does not apply because this order is an agreed order.
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II. Findings
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Jurisdiction
21
This court has jurisdiction over the proceeding and the parties.
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2.2
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
2
2.3
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
2.6
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
15
III. Order
16
it is Ordered :
17
18
19
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
FAUBION, REEDER,
FRALEY & COOK, P.S.
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
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
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
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.
10-06.14
4
5
6
7
8
9
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,
15
I. Judgment Summary
16
17
1.1
18
19
1.2
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:
FAUBION, REEDER
FRALEY & COOK, P.S.
1
Hearing for tem porary child support.
2
2.2
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
3.1
10
Name (first/last)
Kolby G off
11
12
13
14
3.2
Age
13
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.
/H ii-T e 2 .^
FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
3.3
2
3
4
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
12
C.
13
the obligee is voluntarily unem ployed.
14
15
16
[]
17
18
19
[]
[]
20
[]
[]
21
22
23
[]
[j
[]
FAUBION, REEDER
FRALEY & COOK, P.S.
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
$566 .58
_________
13
14
<5
16
17
3.6
Standard Calculation
(CW.OO
$ 'i & 5 8 _ per month. (See W orksheet line 17.)
3.7
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
22
A deviation was not requested.
23
FAUBION, REEDER
FRALEY & COOK, P.S.
3.9
3.10
(rW i
Incremental Payments
Does not apply.
3.11
ICL
lo I l (
jW U
e><f
W - U lU L tf
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
FAUBION, REEDER
FRALEY & COOK, P.S.
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
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
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 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:
FAUBION, REEDER
FRALEY & COOK, P.S.
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
9 6
i^t
1y
3.15
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
[]
21
3.16
Periodic Adjustment
22
Does not apply.
23
FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, W A 98499
253-581-0660
3.17
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
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.
18
[]
[*T
19
20
21
22
23
BR ENT GOFF
(Parents Name)
11
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
[ ]
17
18
^9
C.
P arties obligations:
20
21
22
23
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
11
12
13
14
15
16
17
18
19
20
21
22
23
11
[ i
iS
253-581-0660
1
2
[ ]
[ ]
4
(Only one parent may be excused.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
D.
21
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.
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
3.20
\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
FAUBION, REEDER
FRALEY & COOK, P.S.
3.22
3.23
Other
Does not apply.
/A c ?
Dated:
COURT COMMISSIONER
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
Tpproved by:
Notice o f presentation waived:
Hillary H olr
A ttornew fo
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
[]
OCT0 2 2014
PIERCE C|
1TY, Clerk
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
(CSWP)
~ 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
i1UJS
r\ 3 1
$1,050*0-
3~2.T
.532
> :>
t;-vft' 1
** .. tA--
M ^7 o
.468
$401.40
| $4316.00
------------------------
'
. .
$494:40
$65fe66'
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
J4,
*
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
$566.SB-1
$408.42
$15.00
$15.00
17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)
^$666^8
$463.42
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
$2,694.00
-
.
-
................... :...
23. Non-Recurring Income (describe)
26.
Mother's
Household
Father's
__Household__
V'-
1
2
3
4
5
6
7
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
16
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)
FAUBION, REEDER,
FRALEY & COOK, P.S.
3.2
Temporary Relief
Child support shall be paid in accordance with the order of child support, signed by
the court.
The following residential provisions for the child KOLBY GOFF (age 13) shall control:
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
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)
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
3
4
5
6
3.4
O th e r
Does not apply.
Dated:
7
8
^ / 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
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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)
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
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:
2.
3.
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
Daniel N Cook
ATTORNEY AT LAW
5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
Dear Counsel/Litigant:
i"v*
2.
3.
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<
KEVIN STOCK
COUNTY CLERK
NO: 08-3-03291-3
3
4
5
6
S uperior C o u rt of W ashington
C ounty of Pierce
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.
13
PCLR 5
14
COMES NOW, the BRENT GOFF in the above entitled action and hereby discloses the
15
16
following primary witnesses which the petitioner may call at time o f trial:
1.
17
Name:
Address and Phone Number:
18
Brent G off
c/o Hillary A. Holmes
317 S. Meridian
Puyallup, WA 98371
253-848-3513
19
2.
21
Name:
Address and Phone Number:
22
23
24
Victoria Goff
c/o Daniel Cook
Attorney at Law
5920 100th Street SW, Ste 25
Lakewood, WA 98499
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.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHIN
NO: 08-3-03291-1
3
4
5
6
7
8
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
16
following list o f prim ary w itnesses fo r the trial scheduled for April 13, 2015.
17
The following witnesses may testify as to their personal observation o f the
18
Petitioner, Respondent, and any other related pertinent matters.
19
WITNESSES EXPECTED TO BE CALLED AT TIME OF TRIAL
20
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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.
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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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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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Dated th is c^-7
day of
2015.
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C
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FAUBION, REEDER,
FRALEY & COOK, P.S.
08-3-03291-3
44224100
NONC
03-03-15
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:
TO: