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11 LEVI:" & MARGOLIN

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5 Attorn.y.-Ior Petitioner. DEBORAH A.S. VAN SICKLE
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
81
91 FOR THE COUNTY OF LOS ANGELES
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111I In RQ the Marriage of: ) CASE NO. BD003554
)
121 Petitioner: DEBORAH A.S. VAN SICKLE) DECLARATION OF
) DEBORAH A.S. VAN SIC:
13 and ) IN SUPPORT OF REQUES'
) FOR TEMPORARY AND
14 Respondent: BARRY L. VAN SICKLE ) PERMANENT RESTRAININI
ORDERS, SUPPORT,
15 -----------------------------) ATTORNEYS' FEES AND
COST
16
17
18 I, Deborah A.S. Van Sickle, declare and state and, if called
101 as a witness would competently testify to the following facts
20 11within my personal knowledge.
211
2211 1. I am the Petitioner in this action. I currently reside
!
23. with my 13 month old daughter, Heather, at 1617 steinhart Ave.,

24[, RedondO Beach, California. On March 25, 1990, the Respondent

I
251 (hereinafter referred to as "Barry") left the family home after
2alI a physical attack upon me, which necessitated calling the police
.
27 1, for which a report was filed at the Redondo Beach police. A true
28 1 and correct copy of Which is attached hereto as Exhibit "1".
vonalcklo\docl.dvo 1
 1 Barry has not resided at the former family home since. Barry, I
2! believe, has spent two nights since March 25,1990, at the family

31 home sleeping in a downstairs bedroom.

41 2. I request the Court issue a "Stay Away Order" requiring
5 Barry fo stay at least 25 yards away from my home except for

6 purposes of picking up our daughter for visitation.

3. During the course of our 4 year marriage, Barry has
8 physically assaulted me at least 11 times. As a result of the
9\, last incident on March 25, 1990, I have currently been in
101! counselling one day a week at 1736 Family Crisis Center, the
II
IIi South Bay Center for Battered Women. Barry is 39 years of age
z 12
I this July. He is approximately 6 foot 1 inch in height and

13 : weighs between 230 and 240 pounds. He is a former college

1

141 football player. I am approximately 5 foot 6 inches and between

151 118 and 122 pounds. After the most recent physical assault on me

161 in March of 1990, Barry agreed to leave the family home. I fiied
17: for divorce in June of 1990. Barry's agreement not to enter the
18\: family home except by agreement or for visitation and to allow me
191 1 to use it as my residence was confirmed in writing by his
201 counsel. Attached hereto as Exhibit "2" is a true and correct
21i, copy of his lawyer's letter to my lawyer with this assurance.
2211 4. On March 25, 1990, after an approximately 20 minute

23 argument
11 which commenced in our bedroom, and continued down intc
241' the garage, Barry pushed me back into the front entryway of om

25 1 home. Barry had become increasingly visibly angry. I hac

261 previously put my daughter down on the floor upstairs for feal
27\ that Ba~ry would physically assault me which could cause injur)
281 to our daughter. In September of 1989, he attacked me while 1

ii vansieUe\decl.dvs 2
 1 was holding my daughter. on March 25, 1990, Barry grabbed me
2 around my thighs, lifted me approximately three feet up into the
3 air and slammed me down against a tile floor which was covered by
4 an area rug. I struck my head and was dazed. I got up and ran

5 to a tBiephone to call "911". Barry ran after me and pulled the

)

6 telephone out. I then ran upstairs to the bedroom telephone. I

71 1
was able to call "911" and complete a call before Barry ripped
8 the telephone I was using out of the wall. He then ripped the
9 I kitchen telephone out of the wall as well. The police did
!
arrive. They stayed until Barry completed packing his car.
10 I·

~ 11 Barry, who is a trial lawyer, had been preparing to leave for an

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5. After this incident, Barry agreed that we should live
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13
,. ~~ i~~ 14. separate and apart. He moved out.
"l z !: ~ 15 I 6. From March 25, 1990, through the current date, I have
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~ ~~ 16 I lived in the family home with our daughter,
I

Heather. Barry has

~ 1711 resided primarily with his unCle, Joseph Cummins, the Senior
18 : Partner in the firm in which Barry is a partner, cummins and
191 White.
20i 7. Shortly after filing my Petition for Dissolution, my
211 attorney has been attempting to negotiate temporary restraining
22: orders in this matter. During this process, as indicated above,
23 Barry's counsel has represented that Barry would make no effort
24 to reoccupy our home. I, thus, have taken no action to keep hi~

25' away from my home pending these negotiations or to request its

26 e)Cclusi va use and occupancy, hoping to save these costs if an
27 agreement was forthcoming.
28 8. On wednesday evening, June 27, 1990, I made

vano'ckle\decl.dv. 3
 1 I arrangements for Barry to come to the house to visit OUI
211 daughter, Heather, who is 13 months of age. At Barry's request,
3 and to facilitace his continuing contact with our daughter, 1
4 permitted him to exercise visitation in the house. Although 1
5 I continli-e to be afraid of Barry because of his volatile temper anc
6 proclivity to physical violence, there has been no repetition oj

I
any physical assaults since the March 25, 1990 incident.
8 However, Barry has no regard for my physical and personal privacl
9 as reflected by the incident on the evening of June 27, 1990.

10 9. In order to minimize tension and not to intrude upor

11 Barry's time with our daughter, I made arrangements to be awal
z from the home during his agreed upon visitation period betweer
12

13 7:00 and 9:30 p.m. I informed Barry that I would be out of thE

14 home and would return between 9: 00 and 9: 30 p. m. It waf

15 understood that that was the time when his visitation perioe

16 would end upon my return home. I used the services of ml

17 domestic caretaker to take care of our daughter and arrangement!

18 were made with her to let Barry into the house upon his arrival.
19 I returned home at 9:30 p.m., on the evening of June 27, 1990.
20 Upon pulling up to the driveway of my home, there were two car!
21 in the driveway blocking my access to the garage. I recognizee
one of the cars as belonging to Joe Yanny, an acquaintance oj
mine and a former client and colleague of Barry.
24 10. Barry had not informed me nor obtained my agreement al

25 any time to invite "friends over to the house" while he visitec

1

26 with Heather. Upon entering the house, I discovered that ir

27 addition to Joe Yanny, he had another former client and colleagUE

28 in attendance, a Richard Aznaran. I observed dirty dishes anc

v"noickle\decl.dvs 4
1 soft drinks and cans of beer from my own refrigerator. From what
2 I observed, I conclude that he had his friends over for dinner in
3 my house consuming my soft drinks and beer while he was
4 ostensibly visiting with his daughter.
I
51 11. I requested to speak privately with Barry. During our
6 conversation he informed me that it was his house and that he
7 could bring over anyone he wishes to.
8 12. I informed him that, as a result of his prior agreement
9. and the representation of his lawyer, I would occupy the house
and that he would not make unauthorized entries. I did not
belIeve that any further confrontation was safe for me given his
past history of physical violence towards me. Barry did, in
fact, leave shortly thereafter.

CHILD AND sFOqSAL SUFPORT

14. In October of 1988, with Barry's approval, I left my
job as a non-equity partner with Cummins and White, the same firm
in which Barry is a partner. My annual salary was then $75,000
a year, from which health insurance premiums were deducted. On
July 2, 1990, I started a job paying $43,200 a year for three
days work, which would permit me to spend more time at home with
our child. It was our agreement when I left work that I would
not have to resume work until I felt it appropriate in order to
spend time with our daughter. I am informed and believe that
Barry's ~ as a partner is at least $10,000 a month from which
he pays approximately $400 a month for health insurance premiums.
I am requesting child and spousal support commensurate with
Barry's income, my income, and our marital standard of living.
vanoi.ktt\dtcl.dvs 5
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1 ATTORNEYS' FEES AND COSTS

2' 15. I borrowed from my friends the initial $5,000 to retain

3 my attorney. Barry is being represented by Arthur Katz, a

4 partner in his law f inn and. therefore, is not incurring any

5 current legal' fees. Since Barry is getting his legal

6 representation for free I request an immediate pendente lite

i award of attorneys' fees and costs to repay my borrowing and to

8 permit me to conduct litigation on a parity with Barry. Barry's

9 recent conduct in direct contradiction to his lawyer's

representations indicates the prospect of costly litigation. In
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~ 111 addition, Barry is an equity partner and a senior partner in
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13 currently experiencing financial difficulties. Since I left

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..::a~!V! cummins and White in October of 1.988, I have no first hand
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,. "- 15 knowledge of these matters. I had been advised that Barry's
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> ~ ~ i lawyer has presented a detailed financial statement to my counsel
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16
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171, as to the state of the law firm as of December 31, 1989, prepared
~

18 by Ernst and Young. However, I will need a forensic accountant

191 to evaluate the practice for purposes of settlement or, prior to

201 trial in this issue. I am informed and believe that a $2,500

211 retainer is required to hire such an expert. I also request a~

22:1 additional $1,500 on account of necessary depositions,
231 photocopying costs, and the cost of business record subpena feee
24 and copying costs.

25 i
26 INTERNAL REVENUE DEBT

27 16. Prior to separation Barry and I were discussing takin~

281 out an equity loan against our home to payoff an outstandin~

I. 6
 I

1 debt owed to the Internal Revenue Service in the approximate sum

2 of $10,000. I am still willing to take out this loan to satisfy

3 the Internal Revenue Service obligation to prevent the IRS from

attaching either of our current monthly incomes or placing a lien
41
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again our home. I would also consent to a portion of borrowed

6 funds being used to reduce our outstanding credit card debts

i since the interest rate on these types of obligations are greater

8 than the interest rate which we would be charged from our home

91 equity loan. I am requesting the Court to make an order that

!
1011 both parties cooperate in obtaining this equity loan. From this

ull(' equity loan, my cost of litigation can be advanced to me subject

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to allocation at the time of trial.
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17. Prior to separation and exclusively thereafter, I have
had possession and use of a Nissan 300 ZX automobile, License No.
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~ 2FVG765. I request that I be awarded temporary exclusive use and
• 17
18 possession of this automobile.

19 •
II
201 CUSTODY AND VISITATION
I

IS. At the current time, without prejudice to eithex

211
221 party's claims I request that the Court make an Order of join1
23 legal custody, with primary physical custody to me subject tc
1
It is my understandin~
241 Barry's reasonable visitation rights.
I that Respondent wishes to visit with our daughter one evening ,
25
26 week on Wednesday. I consent to a Wednesday visitation from 7:0(

27 to 9:30p.m. However, based upon the Respondent's recent conduc1

281 in having "guests over for pizza and beer" while I was no1
I 7
 1 present and while he was supposed to be visiting with our

2 daughter I request that this visitation be done outside of the

3 house. Respondent has also requested a weekly visitation on

weekends. I consent to a two hour Saturday visit from 3:00 to
41
I
5 5:00 p.m., on alternate weekends. Prior to our separation, the

6 Respondent, who is a trial lawyer, was not actively involved in

i child rearing activities. He was not actively involved in our

8 child's life. I believe the visitation set forth above is

consistent with the Respondent's own request other than my
9\
1011 objection to him visiting in my home.
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RESTRAINING ORDERS
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~ ~ 13 19. Prior to the initiation of this request, my attorney
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has unsuccessfully attempted to have the Respondent stipulate to
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15 a restraining order which I am informed is customary in family
> law matters with respect to property and the incurring of debts
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~ other than in the ordinary course of business or for the
17
18 necessities of life. The Respondent has refused to do so. From

19 his refusal, I, therefore, infer that he intends to transfer and

201 hypothecate property in derogation of my rights. I, therefore,

21 request that the Court enter the restraining orders requested.

221 These restraining orders can be mutual.

1
23
24 INSURANCE COVERAGE

25 20. The Respondent currently has both myself and minor

26 daughter covered under his health insurance. If I obtain

27 employment, 1 will determine whether or not coverage for myself

28 and our daughter is available to me at a more economical rate

vlnoickl.\dte1.dv. 8
 1 considering both monthly costs and the deductible limit. Pending
that determination, I request the court order the Respondent to
21
3 1 maintain all existing health care coverage available to him

41 through his employment. In addition, the Respondent has life

5 insurance insuring his life, naming me as a beneficiary. I

6 request that the Respondent be ordered to maintain such life

7: insurance coverage and, if he has changed it, to restore it to

8 the coverage which was in effect as of March 1, 1990. I request

9 that the Respondent provide proof within ten (10) days of the

101 hearing on this matter as to the coverage in effect as of

111 Mar:::h t, 1990, and proof that such coverage has remained in
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;; 121 effect or been restored •
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, <: ~~~ SHORTENING TIME FOB DISCQVERY
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15 21. I am requesting that the court shorten the time for the
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161 service of a C.c.P; 1987 Notice upon the Respondent be shortened
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171, to 7 days and that service for Subpena Duces Tecum for Business
I
181 Records and/or for Court upon the law firm of Cummins and White
i
1!)1 be shortened to 7 days to permit discovery to be made prior tc

201 the Order to Show Cause hearing to be set in this matter.

,
ThE

21 I Respondent's income information for the past 12 months was

22 requested by letter dated June 8, 1990, but has not yet beer
23i supplied. As a result of Barry's conduct on June 27, 1990, anc

241 his failure to commit to a schedule of payments for the support

251 of myself and my daughter, it is necessary to obtain a court

i
261
27
28
I 9
 • Order for reautar support payments. It is, therefore, necessary

~1 to shorten time for the discovery of these items.

31
4
1
I declare under penalty of perjury under the laws of the

5 State of California that the foregoing is true and correct.

6 Executed on this 3rJ day of July, 1990, at Beverly Hills,

7 California.
8
9 D A.S. SICKLE ""

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28
vonolekl.\~1.dvI 10
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CUMMINS lQS~Coumv
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Los Angeles

Lionel P. Levin, Esq.

Levin & Margolin
8484 Wilshire Boulevard
Suite 800
8484 Wilshire Boulevard
Beverly Hills, California 90211

Re: Marriage of Van Sickle

LASe No. BD003554
Our File No. G227

Dear Mr. Levin:

I am enclosing. herewith a copy of the Sixth Amended
Partnership Agreement of Cummins & White, along with the firm's
financial statement for the years ended December 31, 1989 and
1988. This materials is being furnished with .the understanding
that it will be kept confidential and its use restricted to the
matter at hand. I do expect to be able to forward additional
financial material to you covering the period through May 31,
1990, within the next several weeks.
With regard to the stipulation which you forwarded, I
find myself unable to agree to its provisions in their present
form, or without some further understanding as between
ourselves. I have no problem with paragraph 2. Nor do I have
any problem with paragraphs 1 and 5 I provided we can work out
some arrangement, where Barry can go to the family home to get
his personal belongings. He advises me that he has previously
been prevented from doing so. I will assure you, however, that
during this interim period Barry will not seek to enter the home
except by agreement or order of court. Paragraph 3 is
acceptable provided the word "separate" is omitted or I can have
more specific understanding of what is meant by "the necessities
of life." .. In this particular Case, it could become an issue.
Paragraph 4 is also acceptable provided we have a more specific
understanding of the word "extraordinary." I am not trying to
CUMMINS
&WHITE
Lionel P. Levin, Esq.
June 15, 1990
Page :2
AMK4583jAMK3

be petty with regard to these issues, but I think their

clarification will avoid future problems.
Within the next several days, I will prepare the
language for a proposed child custody and visitation order, and
suggest what we are prepared to offer for support.
Very truly yours,

~?k'ATZ
For the firm of
AMK:K CUMMINS 6< WHITE

Enclosures
cc: Barry Van Sickle, Esq.