Jolene Marie Harrison vs. Christopher Lee Harrison 08-3-00821-4

E-FILED
IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON
March 07 2008 3:45 PM
KEVIN STOCK
COUNTY CLERK
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR PIERCE COUNTY
No. 0 8 -3-008 21-4

ORDER ASSIGNING CASE TO DEPARTMENT
In accordance with PCLR 40(b), this case is hereby assigned to Department 05, Judge VICKI L. HOGAN.
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)
A ssignm ent to Set Trial Date
Friday, Ju ly 11, 2008 9:00 AM
At that time the Court will provide you with a Case Schedule which shall include the trial date. Failure to
appear on this date will result in dismissal of the case by the Court. PCLR 40(d).
Certificate o f Com pletion o f Mandatory Parenting Sem inar due from both parties by 05/09/2008. See
PCLSPR 94.05(c) & (4)(i). http:\\w w w x o.pierce.wa.us\pc\services\lawjust\parentingsem inars.htm
Uncontested Dissolutions/Settlem ents:
If this case is agreed upon by both petitioner and respondent, you are not required to wait for the trial date in
order to settle your case. If you settle your case and the appropriate time requirements have been met, you may
file a Note for Commissioner's Calendar' to appear before a Court Commissioner for entry of final papers.
DATED: March 7, 2008

Judge VICKI L. HOGAN
Department 05
astsup-0003.pdf
12971
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CICS
SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

CASE COVER SHEET / DOMESTIC & PROBATE CASES
Case Title
Case Number
Atty/Litigant
Address
___________
~7
c lO f * *
city__ (d # A t.
Bar#
IftL
08 3 00821 4
Phonefc35'i,) /P ^ - ^ ^ f . 7
-
______ State
IsdA-
Zip f f S
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.)
I f you cannot determine the appropriate category, please describe the cause o f action below. This will create a
Miscellaneous cause which is not subject to PCLR l, and does not require a Track Assignment Request Form.
DOMESTIC RELATIONS
Invalidity (INV 3) DISSOLUTION
Child Custody (CUS 3) DISSOLUTION
Dissolution with Children (DIC 3) DISSOLUTION
Dissolution without Children (DIN.3) DISSOLUTION
Foreign Judgment Domestic (FJU 3) Non PCLR
Legal Separation (SEP 3) DISSOLUTION
M 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 of County (ROC 3) Non PCLR
____Mandatory Wage Assignment (MSC 3) Non PCLR
____Out of State Custody (MSC 3) Non PCLR
ADOPTION I PATERNITY
____Adoption (A DP 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 5)Aon PCLR
-____Vulnerable Adult Petition (VAP 5) Aon PCLR
____Misc (MSC 5) Aon 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)Aon PCLR
Non-Probate Notice to Creditors (NNC 4) Non PCLR
Will Only (WLL 4) Non PCLR
Misc (MSC 4) Non PCLR
12971
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08-3-00B21
3/12/28BB
03-11-08
m COUNTY CLERK'S
office
Jf*pE COUHIY
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UZPUTY
SUPERIOR COURT OF WASHINGTON COUNTY OF PIERCE

In re
m A r u iity j^
o9
"Soitnc. m
)
Petitioner,
)
)
and
,
C sh riS tO p h cT l
_________
v
^
Respondent.
no.
Qg
QQ821
MOTION AND ORDER TO PROCEED

IN FORMA PAUPERIS
)
) ________ ____________________________
MOTION AND DECLARATION

I certify under penalty of perjury, according to the laws of the State of Washington, that
the following is true and correct:
[ ]
lam the applicant, and I seek an order authorizing me to proceed as an indigent

person. I believe that I have valid reasons for bringing this action and that I am
entitled to relief. I am unable to pay the filing fee in this case.
[ ]
lam the applicant, and I seek an order authorizing me to file this action by paying
only the Family Law Facilitator surcharge of $10.00 at the time of filing. I shall
pay the filing fee prior to the entry of the final papers with proof of payment
provided to the court at the final hearing.
[ ]
lam the applicant, and I seek an order authorizing me to file this action by paying
only the Family Law Facilitator surcharge of $10.00 at the time of filing. The
Respondent has joined (or if the Respondent joins) in the petition, the filing fee
will be paid prior to entry of the final papers with proof of payment provided to the
court at the final hearing.
The attached Financial Statement accurately describes my financial condition.
5 -7 Date
y \/l
0 8
Sic
jQ x n /zM * o n
ture
TVoi
Print/Type Name
MOTION AND O R D E R TO P R O C E E D IN FO R M A PA U PER IS P A G E 1 o f 2
F:\W ORDDOCS\DOMFORMS\FACILITATOR\MTIFP.DOC 9/2001
iAA
14
S08B2
12571
3/ 12/2008
NO.08 3 00821 4
ORDER
IT IS HEREBY ORDERED THAT:

[ ]
This case/action may be filed without payment of the filing fee.
[ ]
The party(ies) will be required to pay the filing fee prior to entry of the final
papers with proof of payment being provided to the court at the final hearing.
The Respondent has joined (or if the Respondent joins) in the petition, the filing
fee will be paid prior to entry of the final papers with proof of payment being
provided to the court at the final hearing
[X]
THE FAMILY LAW FACILITATOR SURCHARGE OF $10.00 WILL BE PAID

PRIOR TO FILING THIS CASE.
[ ]
Motion Denied
[ l
Other-
Presented by:
PRINT/TYPE NAVE
MOTION AND O R D ER TO P R O C E E D IN FO RM A PA U P ER IS P A G E 2 o f 2
F;VWORDDOCSVOOMFORMS\FACILITATOR\MTIFP.OOC 9/2001
00003
12971
3^12/2888
80804
Case Number
1) My name is 3 n l e n t , f\f\,
2) My spouses name is
4
eei c
3. SELF
Hfl/\rO<>Qt4______ I am P>0,
years of age
k*
who is 3 H
years of age
I1
l
*! eSPOUSE
o A i i c e (complete
,__ 7717. If joint
7. * petition)
.... *
3.
Employer
Employer
Employer Address/!)(].<>,
[ ] Full Time
(H e x U ta ^
Pf ull Time dtpeMiw on L^PartTime
pfl Part Time
Gross pay per m o n th ^ S tlO ^ H rs per w k :3 4
4.
[j)b .
Employer Address:
Gross pay per mont h. 1
IF UNEMPLOYED
Hrs per wk:
" 40
4. IF UNEMPLOYED
a. Reason;
a. Reason:
b. Date last employed:
c. Reason for Termination;
c. Reason for Termination:
5. OTHER SOURCES OF INCOME PER

MONTH

MONT H
Public Assist
Gifts
Public Assist
Gifts
Unemployment
L&l
Unemployment
L&l
Other:
TOTAL:
Other:
TOTAL:
6. MY WIONTHL.Y EXPENSES
Rent/Mort
Food
Utilities
Transportation
Med/Dental
cj6zS.ca
fcO e/30
h oo
l5V ,
acof
tl2DP
Daycare
6. MY SPOUSES MON TH LYE X ENSES

Rent/Mort
Daycare
Food
Tuition
Utilities
Insurance
Other:
Transportation
Other
TOTAL:
Med/Dental
TOTAL:
Tuition
Insurance
I 2 C oX)
7. THE FO LLOWIN G PEOPLE LIVE

WITH ME
Name: Cd
dSdp % A gea /Relationship:
A durtF
HA&aik)*) / 4
Cd.O
Jlyjfec F/phr ,
3
HaaJaJA'H'
7. THEFOLLOW IN 3 PEOPLE LIVE

WITH MY SI30U S E
Name:
Age:
Relationship:
H/T/U^SOkI 12.
Ffohf
ii _ A a S Z
8. 1OWE THE FOLLOWING DEBTS
9. MY ASSETS &EQ UITY VALUES ARE:
Total Debt:
Payment
Home
EFClL a uf
S /^ D O O y
$5L.ooo,
Q_d4^C/(dtf
\hos CtoXvt uFcf) i/iti $ 3 ,^ 0 0 /
$130/"
$m f
$ osr
Checking
Creditor:
TOTAL OWED;
Savings
Cash
Vehicles
Stock/Bond
Life Ins.
Retirement
Other:
1 0 0 / J
0 , '
0
.
TOTAL:
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct.
_ _
Signed at lA L O r n J \ .
Sinnature
/h
IaX *______________________ (City & State) on 3 ~ 7 " 6 > 3

________
Financial Affidavit for Motion and Order to Proceed In Forma Pauperis

F:\W ORDDOCS\DOMFORMS\FACiLITATOR\FININFO.DOC 9/2001
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Print/Type Name
(Date).
12371
08-3-00821 -4
29341198
3 /1 2 /2 8 0 S
03-11-08
PTOSSJ
in c o u n t e d
office
Superior Court of Washington

County of
S S a R 'f f lw m .
DEPUTY
In re the Marriage of:
No.
Jolene Marie Harrison
08 3 00821 4
Petitioner,
and
Christopher Lee Harrison
Respondent.
Petition for Dissolution of

Marriage
(PTDSS)
I. Basis
1.1
Identification of Petitioner
Name (first/last)
Jolene Harrison, Birth date July 15, 1975
Last known residence Pierce County, Washington State [county and state].
1.2
Identification of Respondent
Name (first/last)
Christopher Harrison, Birth date April 16, 1970
Last known residence
1.3
Pierce County, Washington State [county and state],
Children of the Marriage Dependent Upon Either or Both Spouses
The husband and wife are both the parents o f the following dependent children:
Name (first/last) Christopher Lee Harrison Jr,
Age 3 years
Name (first/last)______________________________________________________A ge______

Name (first/last)_____________________________________________________ A ge______
Name (first/last)______________________________________________________A ge______
Pet forDisso o f Marriage (PTDSS) - Page 1 o f 10
WPP DR 01.0100 Mandatory (7/2007) - R C W 26.09.020
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Name (first/last)_____________________________________________ ________ Age

Name (first/last)_____________________________________________________ Age
The husband is and the wife is not the parent of the following dependent children:
Name (first/last) A lyssa Ray Harrison
________________________________ Age 14 years
Name (first/last) Kathrina Jean Harrison_________________________________ Age
12 years___
The wife is and the husband is not the parent of the following dependent children:
Name (first/last) Tyler Michael Flohr___________________________________ Age
13 years
Name (first/last) Hannah Marie Flohr___________________________________ Age
10 years
1.4
Allegation Regarding Marriage

This marriage is irretrievably broken.
1.5
Date and Place of Marriage
1.6
The parties were married on June 5, 2004 at Bonney Lake, Washington.

[Date]
[City and State]
Separation
[]
[X]
1.7
Husband and wife are not separated.

Husband and wife separated on August 15, 2007 [Date].
Jurisdiction
This court has jurisdiction over the marriage.
[X]
This court has jurisdiction over the respondent because:

[X]
The respondent is presently residing in Washington.
[X]
The petitioner and respondent lived in Washington during their marriage and the
petitioner continues to reside, or be a member of the armed forces stationed, in
this state.
[X]
The petitioner and respondent may have conceived a child while within
Washington,
[]
Other:
[]
This court does not have jurisdiction over the respondent.
Pet for Disso of Marriage (PTDSS) - Page 2 o f 10

WPF DR 01.0100 Mandatory (7/2007) - RCW 26.09.020
88086
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1.8
3/12/2008
Property
There is community or separate property owned by the parties. The court should make a fair and
equitable division of all the property.
[X]
[]
The division of property should be determined by the court at a later date.

The petitioners recommendation for the division of property is set forth below.
[]
The petitioner should be awarded the parties interest in the following property:
[]
The respondent should be awarded the parties interest in the following property:
[]
Other.
Pet for Disso of Marriage (PTDSS) ~ Page 3 of 10

WPF DR 01.0100 Mandatory (7/2007) - R C W 26.09.020
00807
12971
1.9
Debts and Liabilities

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

The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.
The division of debts and liabilities should be determined by the court at a later date.
[]
The petitioners recommendation for the division of debts and liabilities is set
forth below.
[X]
[X]
1.10
3/ 12/2668
[]
The petitioner should be ordered to pay the following debts and

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

To Be Determined
Each party should pay their debts incurred since separation.

Other: Each party should pay their debts incurred before the marriage.
Spousal Maintenance
[X]
[]
Spousal maintenance should not be ordered.

There is a need for spousal maintenance as follows:
[]
Other:
Pet for Disso o f Marriage (PTDSS) - Page 4 o f 10

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1.11
3 /1 2 /2 8 8 8
Continuing Restraining Order

[X]
[]
[]
[]
Does not apply.

A continuing restraining order should be entered which restrains or enjoins the
[ ] husband [ ] wife from disturbing the peace of the other party.
[ ] husband [ ] wife from going onto the grounds of or entering the home, work place or
school of the other party or the day care or school of the following children:
A continuing restraining order should be entered which restrains or enjoins the [ ] husband
[ ] wife from knowingly coming within or knowingly remaining within___________
(distance) of the home, work place or school of the other party or the day care or school
of these children:
Other: _________________________ ________________________________________ .
1.12
[]
A continuing restraining order should be entered which restrains or enjoins

__________________________[Name ] from molesting, assaulting, harassing, or
stalking ______________________________ [Name]. (If the court orders this relief, the
restrained person will be prohibited from possessing a firearm or ammunition under
federal law for the duration of the order. An exception exists for law enforcement
officers and military personnel when carrying department/govemment-issued firearms.
18 U.S.C. 925(a)(1).)
[]
Other:
Protection Order
[X]
[]
Does not apply.

A domestic violence protection order should be entered protecting
___________________________ [Name] from ___________________________ [Name]
because_____________________________ [Name] has committed domestic violence as
defined by 26.50 RCW against_____________________________ [Name]. (If the court
orders this relief, the restrained person will be prohibited from possessing a firearm or
ammunition under federal law for the duration of the order. An exception exists for law
enforcement officers and military personnel when carrying department/govemmentissued firearms. 18 U.S.C. 925(a)(1).)
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms.
1.13
Pregnancy
[X]
The wife is not pregnant.
Pet for Disso o f Marriage (PTDSS) - Page 5 of 10

80009
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1.14
3/12/2808
[]
The wife is pregnant. Note: Under RCW 26.26.116, the husband is the presumed
father. If husband or wife believes the husband is not the father, this presumption
may be challenged up to two years after the birth of the child or as otherwise
provided in RCW 26.26.500 through 26.26.625.
[]
Other:
Jurisdiction Over the Children

[]
[X]
Does not apply because there are no dependent children.

This court has jurisdiction over the children for the reasons set forth below:
[]
This court has exclusive continuing jurisdiction. The court has previously made a child
custody, parenting plan, residential schedule or visitation determination in this matter and
retains jurisdiction under RCW 26.27.211.
[X]
This state is the home state of the children because

[X]
[]
[]
[]
[X]
The children lived in Washington with a parent or a person acting as a parent for at
least six consecutive months immediately preceding the commencement of this
proceeding.
the children are less than six months old and have lived in Washington with a
parent or a person acting as parent since birth.
Any absences from Washington have been only temporary.
Washington was the home state of the children within six months before the
commencement of this proceeding and the children are absent from the state but a
parent or person acting as a parent continued to live in this state.
the children and the parents or the children and at least one parent or person acting as a
parent, have significant connection with the state other than mere physical presence; and
substantial evidence is available in this state concerning the childrens care, protection,
training and personal relationships; and
[X]
[]
The children have no home state elsewhere.

the childrens home state has declined to exercise jurisdiction on the ground that
this state is the more appropriate forum under RCW 26.27.261 or .271.
[]
All courts in the children's home state have declined to exercise jurisdiction on the ground
that a court of this state is the more appropriate forum to determine the custody of the
children under RCW 26.27.261 or .271.
[X]
No other state has jurisdiction.
[]
This court has temporary emergency jurisdiction over this proceeding because the children
are present in this state and the children have been abandoned or it is necessary in an
Pet for Disso of Marriage (PTDSS) - Page 6 of 10

08018
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3 /1 2 /2 8 0 8
emergency to protect the children because the children, or a sibling or parent of the children
is subjected to or threatened with abuse. RCW 26.27.231.
[]
1.15
[]
There is a previous custody determination that is entitled to be enforced under

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

this chapter and a child custody proceeding has not been commenced in a court
of a state having jurisdiction under RCW 26.27.201 through 26.27.221. If an
action is not filed in _________________ _ _ _ [potential home state] by the time
the child has been in Washington for six months,___________________ [Date],
then Washington's jurisdiction will be final and continuing.
Other:
Child Support and Parenting Plan for Dependent Children

[]
[X]
The parties have no dependent children.

Support for the dependent children listed below, should be set pursuant to the
Washington State Child Support Schedule.
Name
of Child
Mothers
Name
Fathers
Name
Christopher Harrison Jr.
Jolene Harrison
Christopher Harrison
The petitioners proposed parenting plan for the children listed above:
[X]
[]
Is attached and is incorporated by reference as part of this Petition.

will be filed and served at a later date pursuant to RCW 26.09.18 1.
(The following information is required only for those children who are included in the
petitioners proposed parenting plan.)

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3 /1 2 ^2 8 8 8
During the last five years, the children have lived:

[X]
[]
in no place other than the state of Washington and with no person other than the
petitioner or the respondent.
in the following places with the following persons (list each place the children
lived, including the state of Washington, the dates the children lived there and
the names of the persons with whom the children lived. The present addresses of
those persons must be listed in the required Confidential Information Form):
Claims to custody or visitation:

[X]
[]
The petitioner does not know of any person other than the respondent who has
physical custody of, or claims to have custody or visitation rights to, the
children.
The following persons have physical custody of, or claim to have custody or
visitation rights to the children (list their names and the children concerned
below and list their present addresses in the Confidential Information Form. Do
not list the responding party):
Involvement in any other proceeding concerning the children:

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

[X]
[]
The petitioner does not know of any other legal proceedings concerning the
children.
The petitioner knows of the following legal proceedings which concern the
children (list the children concerned, the court, the case number, and the kind of
proceeding):

0801
12971
1.16
3 /1 2 /2 8 0 8
Other
II. Relief Requested

The petitioner Requests the court to enter a decree of dissolution and to grant the relief below.
[]
[X]
[X]
[]
[X]
[]
[]
[]
[]
[X]
[X]
[]
[X]
Provide reasonable maintenance for the [ ] husband [ ] wife.

Approve the petitioners proposed parenting plan for the dependent children listed in
paragraph 1. 15.
Determine support for the dependent children listed in paragraph 1.15 pursuant to the
Washington State Child Support Schedule.
Approve the separation contract or prenuptial agreement.
Divide the property and liabilities.
Change name o f wife to (first, middle, last): _______________________________ .
Change name o f husband to (first, middle, last): _______________________________ .
Enter a domestic violence protection order.
Enter a continuing restraining order.
Order payment of day care expenses for the children listed in paragraph 1.15.
Award the tax exemptions for the dependent children listed in paragraph l . 15 as follows:
To the petitioner.
Order payment of attorney fees, other professional fees and costs.

Other: 50% of Filing fee cost
Dated: February 27, 2008

/

Print Name
ignature o f Petitioner or Lawyer/WSBA No.
f\f[
T Z /U kry-W
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at Bonney Lake, [City] WA. [State] on February 27, 2008 [Date].
V73...
lature of Petitioner

Print Name
Joinder
I, the respondent, join in the petition. I understand that by joining in the petition, a decree or judgment
and order may be entered in accordance with the relief requested in the petition, unless prior to the entry
of the decree or judgment and order a response is filed and served.
08013
12371
3/12/2888
[ ] I waive notice of entry of the decree.

[ ] 1 demand notice of all further proceedings in this matter. Further notice should be sent to the
following address [You may list an address that is not your residential address where you agree
to accept legal documents]:
Any time this address changes while this action is pending, you must notify the opposing parties in
writing and file an updated Confidential Information Form (WPF DRPSCÛ 09.0200) with the court
>
clerk.
Dated:
C 4- '
Signature of Respondent
b/^>
Pet for Disso o f Marriage (PTDSS) - Page 10 o f 10

rjC i/f.Xo 1
80-814
12971
3 /1 2 /2 0 6 8
IN COUNTYF C L E R K 'S O FFIC E
MAR 0 7 2008
a.h.
pji.

KEVIN STOCK, Co inly Cleric

County of
BY______ ______V-j DEPUTY
No

Petitioner,
and
Respondent.
08 3 00821 4
Parenting Plan
[X] Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
This parenting plan is:

[]
[]
[]
[X]
the final parenting plan signed by the court pursuant to a decree of dissolution, legal
separation, or declaration concerning validity entered o n _______________ [Date].
the final parenting plan signed by the court pursuant to an order entered on
____________ [Date] which modifies a previous parenting plan or custody decree.
a temporary parenting plan signed by the court.
Proposed by Jolene Harrison_____________________ ,
[Name].
It Is Ordered, Adjudged and Decreed:

I. General Information
This parenting plan applies to the following children:
Name
Christopher Lee Harrison Jr.
Age
3 years
Parenting Plan (PPP, PPT, PP) - Page 1 of 11- Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - R C W 26.09.181;. 187;. 194
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3 /1 2 /2 8 8 8
II. Basis for Restrictions

Under certain circumstances, as outlined below, the court may limit or prohibit a parents
contact with the child(ren) and the right to make decisions for the child(ren).
2.1
Parental Conduct (RCW 26.09.191(1), (2))

[X]
[3
Does not apply.

The [ ] mothers [ ] fathers residential time with the child(ren) shall be limited or
restrained completely, and mutual decision-making and designation of a dispute
resolution process other than court action shall not be required, because [X] this parent
[ ] a person residing with this parent has engaged in the conduct which follows:
[]
[]
[]
2.2
Willful abandonment that continues for an extended period of time or substantial

refusal to perform parenting functions (this applies only to parents, not to a
person who resides with a parent).
Physical, sexual or a pattern of emotional abuse of a child.
A history of acts of domestic violence as defined in RCW 26.50.010(1) or an
assault or sexual assault which causes grievous bodily harm or the fear of such
harm.
Other Factors (RCW 26.09.191(3))

[X]
[]
Does not apply.

The [ ] mothers [ ] fathers involvement or conduct may have an adverse effect on the
child(ren)s best interests because of the existence of the factors which follow:
(]
[]
[]
[]
[]
[]
[]
Neglect or substantial nonperformance of parenting functions.

A long-term emotional or physical impairment which interferes with the
performance of parenting functions as defined in RCW 26.09.004.
A long-term impairment resulting from drug, alcohol, or other substance
abuse that interferes with the performance of parenting functions.
The absence or substantial impairment of emotional ties between the parent and
child.
The abusive use of conflict by the parent which creates the danger of serious
damage to the childs psychological development.
A parent has withheld from the other parent access to the child for a protracted
period without good cause.
Other:
Parenting Plan (PPP, PPT, PP) - Page 2 o f 11- Laws o f 2007, ch. 496, 301
WPP DR 01.0400 Mandatory (7/2007) - R C W 26.09.181; .187;. 194
88818
12971
3/12/2008
III. Residential Schedule

The residential schedule must set forth where the child(ren) shall reside each day o f the year,
including provisions for holidays, birthdays of family members, vacations, and other special
occasions, and what contact the child(ren) shall have with each parent. Parents are encouraged
to create a residential schedule that meets the developmental needs of the child(ren) and
individual needs of their family. Paragraphs 3.1 through 3 .9 are one way to write your
residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
3.1
Schedule for Children Under School Age

[]
[X]
There are no children under school age.

Prior to enrollment in school, the child(ren) shall reside with the [X] mother [ ] father,
except for the following days and times when the child(ren) will reside with or be with
the other parent:
from Friday at 4pm to Sunday at 8am
[]
[]
every week [X] every other week [ ] the first and third week of the month
the second and fourth week of the month [X] other: Every other weekend alternating
with every other weekday schedule
from Wednesday at 8am to Thursday at 8am
[]
[]
3.2
the second and fourth week of the month [X] other: Every other weekday alternating
with every other weekend schedule
School Schedule
Upon enrollment in school, the child(ren) shall reside with the [X] mother [ ] father, except for
the following days and times when the child(ren) will reside with or be with the other parent:
from Friday at 4pm to Sunday at 7pm
[]
[]
the second and fourth week of the month [X] other: Eveiy other week alternating
with every other weekday schedule.
from Wednesday at 8am to Thursday at 8am

[]
[]
the second and fourth week of the month [X] other: Every other week alternating with
every other weekend schedule
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181;. 187;. 194
8001
12971
[]
3.3
3 /i2 ^ 2 0 6 S
The school schedule will start when each child begins [ ] kindergarten [X] first grade
[ ] other:
Schedule for W inter Vacation

The child(ren) shall reside with the [X] mother [ ] father during winter vacation, except for the
following days and times when the child(ren) will reside with or be with the other parent:
To be determined between mother and father 50/50
3.4
Schedule for Other School Breaks

The child(ren) shall reside with the [X] mother [ ] father during other school breaks, except for
the following days and times when the child(ren) will reside with or be with the other parent:
To be determined between mother and father 50/50
3.5
Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the [X] mother [ ] father,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
[X]
Same as school year schedule.
[X]Other: 3 week to be determined between the mother and father
3.6
Vacation With Parents

[X]
[]
Does not apply.

The schedule for vacation with parents is as follows:
6691B
12971
3.7
3 ^ 1 2 /2 8 6 8
Schedule for Holidays

The residential schedule for the child(ren) for the holidays listed below is as follows:
New Years Day

Martin Luther King Day
Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
With Mother
(Specify Year
Odd/Even/Everv)
With Father
(Specify Year
Odd/Even/Everv)
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Odd
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Even
[X]
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times): 8am to 8pm
[]
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday
[]
Other:
Schedule for Special Occasions

The residential schedule for the child(ren) for the following special occasions (for example,
birthdays) is as follows:
With Father
With Mother
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
Every
Mothers Day
Every
Fathers Day
Every
Mothers Birthday
Every
Fathers Birthday
Parenting Plan (PPP, PPT, PP) - Page 5 of 11- Laws o f 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194
88819
12371
[]
3.9
Other:
Priorities Under the Residential Schedule

[]
[]
Does not apply.

If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the children
are scheduled to be with both parents at the same time, the conflict shall be resolved by
priority being given as follows:
[X]
Rank the order of priority, with 1 being given the highest priority:
1 school schedule (3.1, 3.2)
____winter vacation (3.3)
____school breaks (3.4)
____summer schedule (3.5)
[]
3.10
3.11
3/12/2068
2 vacation with parents (3.6)

____holidays (3.7)
3
special occasions (3.8)
Other:
Restrictions
[X]
[]
Does not apply because there are no limiting factors in paragraphs 2 .1 or 2.2.
The [ ] mothers [ Jfathers residential time with the children shall be limited because
there are limiting factors in paragraphs 2 .1 and 2.2. The following restrictions shall
apply when the children spend time with this parent:
[]
There are limiting factors in paragraph 2.2, but there are no restrictions on the
[ ] mothers [ ] fathers residential time with the children for the following reasons:
Transportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Support and should not be included here.
Transportation arrangements for the child(ren), between parents shall be as follows: To be
worked out fairly half and half between the mother and father for the purpose of accommodating
work schedules. The children are not to ride with anyone that does not have a valid Washington
State Drivers License or other valid State Drivers License. The Driver must have proof of
liability insurance and there must be a seat and seatbelt available for each child. The children
shall be restrained properly according to the Washington State Law of proper restraints wile
riding in a motor vehicle.
Parenting Plan (PPP, PPT; pp) - Page 6 of 11- Laws of 2007, ch. 496, 301
06828
12971
3.12
3/12/2888
Designation of Custodian
The children named in this parenting plan are scheduled to reside the majority of the time with
the [X] mother [ ] father. This parent is designated the custodian of the child(ren) solely for
purposes of all other state and federal statutes which require a designation or determination of
custody. This designation shall not affect either parents rights and responsibilities under this
parenting plan.
3.13
Other
3.14
Summary of RCW 26.09.430 .480, Regarding Relocation of a Child

This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
If the person with whom the child resides a majority of the time plans to move, that person shall
give notice to every person entitled to court ordered time with the child.
If the move is outside the childs school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60 days before
the intended move. If the relocating person could not have known about the move in time to give
60 days notice, that person must give notice within 5 days after learning o f the move. The
notice must contain the information required in RCW 26.09.440. See also form DRPSCU
07.0500, (Notice of Intended Relocation of A Child).
If the move is within the same school district, the relocating person must provide actual notice by
any reasonable means. A person entitled to time with the child may not object to the move but
may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is moving to avoid a clear, immediate and unreasonable risk to health and safety.
If information is protected under a court order or the address confidentiality program, it may be
withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may put the health
and safety of a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt.
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
88B2i
12971
3/12/2608
A person entitled to time with a child under a court order can file an objection to the childs
relocation whether or not he or she received proper notice.
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.
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.
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.
IV. Decision Making

4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of each child while
the child is residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the
children.
4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions
Non-emergency health care
Religious upbringing
4.3
[]
[]
[X]
[]
[]
[]
[]
[]
[]
mother
mother
mother
mother
mother
mother
mother
mother
mother
[]
[]
[]
[]
[]
[]
[]
[]
[]
father
father
father
father
father
father
father
father
father
[X]
[X]
[]
[]
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
joint
joint
Restrictions in Decision Making

[]
[]
Does not apply because there are no limiting factors in paragraphs 2 .1 and 2.2 above.
Sole decision making shall be ordered to the [ ] mother [ ] father for the following
reasons:
[]
[]
A limitation on the other parents decision making authority is mandated by

RCW 26.09.19l (See paragraph 2 .1).
Both parents are opposed to mutual decision making.
Parenting Plan (PPP, PPT, PP) - Page 8 o f 11- Laws of 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - R C W 26.09.181;. 187; .194
0BB22
12371
[]
One parent is opposed to mutual decision making, and such opposition is

reasonably based on the following criteria:
(a)
(b)
(c)
(d)
[]
3 /1 2 /2 0 0 8
The existence of a limitation under RCW 26.09.191;

The history o f participation of each parent in decision making in each of
the areas in RCW 26.09.184(4)(a);
Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in
RCW 26.09.184(4)(a); and
The parents geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
There are limiting factors in paragraph 2.2, but there are no restrictions on mutual
decision making for the following reasons:
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 o f this plan must be used before filing a petition to modify the plan or a motion for
contempt for failing to follow the plan.
[X]
Disputes between the parties, other than child support disputes, shall be submitted to (list person
or agency):
[X]
Counseling by The Bishop of the Church of Jesus Christ of Latter Day Saints,
or by a licensed counselor.
[X]
mediation by a G.A.L. or C.O.S.A. worker______________, if this box is checked and

issues of domestic violence or child abuse are present, then the court finds that the victim
requested mediation, that mediation is appropriate and that the victim is permitted to
have a supporting person present during the mediation proceedings, or
[]
arbitration by
____________________________________
The cost of this process shall be allocated between the parties as follows:
[X]
[]
[]
________ 50% mother_______ 50% father.

based on each partys proportional share of income from line 6 of the child support
worksheets.
as determined in the dispute resolution process.
The dispute resolution process shall be commenced by notifying the other party by [X] written
request [X] certified mail [ ] other:
Parenting Plan (PPP, PPT, PP) - Page 9 o f 11- Laws o f 2007, ch. 496,
301
80023
129?i
3/12/2668
In the dispute resolution process:

(a)
(b)
(c)
(d)
(e)
[]
Preference shall be given to carrying out this Parenting Plan.

Unless an emergency exists, the parents shall use the designated process to resolve
disputes relating to implementation of the plan, except those related to financial support.
A written record shall be prepared of any agreement reached in counseling or mediation
and o f each arbitration award and shall be provided to each party.
If the court finds that a parent has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys fees and financial sanctions to the
other parent.
The parties have the right of review from the dispute resolution process to the superior
court.
No dispute resolution process, except court action is ordered.
VI. Other Provisions

[X]
[]
There are no other provisions.

There are the following other provisions:
VII. Declaration for Proposed Parenting Plan

[]
[X]
Does not apply.

(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under the laws
of the state o f Washington that this plan has been proposed in good faith and that the statements
in Part II o f this Plan are true and correct.
MotKeir
'jn fylm M & n -s
3 r 7 '0 8
~1PCOrvÂ t t j ] A
Date and Place of Signature
Father
VIII. Order by the Court

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an
order of this court.
WARNING: Violation of residential provisions o f 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.
Parenting Plan (PPP, PPT, PP) - page 10 of 11- Laws of 2007, ch. 496, 301
06624
12971
3/12/20B8
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 parents obligations under the plan are
not affected.
Before signing the final parenting plan, the court consulted the judicial information system and
databases, if available, to determine the existence of any information and proceedings that are
relevant to the placement of the children.
Dated:__________________________________ ______________________________
Judge/Commissioner
Presented by:
Approved for entry:
Signature o f Party or Lawyer/WSBA No.
Signature of Party or Lawyer/WSBA No.
Print Name
Print Name
parenting Plan (PPP, PPT, PP) - Page 11 of 11- Laws o f 2007, ch. 496, 301
WPF DR 01.0400 Mandatory (7/2007) - RCW 26.09.181; .187; .194
00025
15386
08-3-00821-4
29753744
LTR5
5 /1 4 /2 0 8 8
08200
SUPERIOR COURT
05-14-08
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
(253) 798-3654
334 County-City Building
FA X (253) 798-7214
930 Tacoma Avenue South

Tacoma, Washington 98402-2102
DATED: May 13, 2008

Re:
Cause No. 08-3-00821-4
Docket code: CRRSP
JOLENE MARIE HARRISON

vs.
CHRISTOPHER LEE HARRISON
Dear Counsel or Pro Se Litigant:

Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case
Schedule or Order Assigning Case to Department in regard to the following items:
Petitioner's Certificate of Parenting Class - Not Filed
Deadline:
05/09/08
Respondent's Certificate of Parenting Class - Not Filed
Deadline:
05/09/08
Pursuant to Pierce County Local Rules and also pursuant to the Case Scheduling Order or Order Assigning
Case to Department given to you at the time of filing this case, you are out of compliance. Please take the
actions necessary to immediately comply with the Case Schedule or Order Assigning Case to Department.
Please file and deliver a courtesy copy of the document to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule or Order Assigning
Case to Department 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 1(k) or PCLSPR 94.05
Copies mailed to:
Sincerely,
Harrison, Jolene Marie

PAM MAYHEW
Department 05
Phone #: 253-798-7566
Judicial assistant to:
Judge Vicki L. Hogan
Superior Court Clerk for Filing

(Court File Copy)
\]xcivil.pb!\d^noncomptianceJetter__report
17494
7 ^ 1 4 /2 6 8 8
IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

Cause N u m b er:08-3-00821-4
MEMORANDUM OF JOURNAL ENTRY
Petitioner(s)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: VICKI L. HOGAN
Court Reporter: RAELENE SEMAGO
Judicial Assistant/Cierk: PAM MAYHEW
HARRISON, JO LE N E MARIE
HARRISON, CH R IS T O PH ER LE E
HARRISON, C H R IS T O PH ER L E E JR
Proceeding Set: Assignment to Set Trial Date

Proceeding Outcome: Continued
Outcome Date: 07/11/2008 10:07
Resolution:
Clerk's Scomis Code:HCNTU

Proceeding Outcome code CONT
Resolution Outcome code:
Amended Resolution code:
Report run date/time: 07/11/08 10:26 AM
Ixcalcivil. pbl. d_civilJoumalreport_cover
86183
17494
7 /1 4 /2 9 0 8
*-

Cause Number: 08-3-00821-4
MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
VICKI L. HOGAN
Judicial Assistant/Clerk: PAM MAYHEW
MINUTES OF PROCEEDING
Court Reporter;RAELENE SEMAGO
Start Date/Time: 07/11/08 10:11 AM

July 11, 2008 10:10 A M Pro Se Jolene Harrison present. Court indicates that the case has
a joinder and case over to 9/12/08.
Pro Se should m ake an appointment with the
courthouse facilitator. Certificates need to be filed.
End Date/Time:
JUDGE/COM M ISSIONER: VICKI L. HOGAN Year 2008
99184
17454
7S1 4 /2 0 6 8
E STATE OF WASHINGTON
CE COUNTY
08-3-00821-4
30119682
ORSCS
07-11-08
No. 08 -3 -0 0 8 2 1 -4
ORDER SETTING
CASE SCHEDULE
Petitioner(s)
vs.
Respondent(s)
Type of Case:
Estimated Trial (days):
Track Assignment:
Assigned Department:
Docket Code:
DIG
Family Law
05 - Jud9e VICKIL
ORSCS
Respondents Certificate of Parenting Class (Must be filed on or before)
05/09/08
Petitioner's Certificate of Parenting Class (Must be filed on or before)
05/09/08
Assignment to Set Trial Date
09/12/08 9:00
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
Ion the date of trial.
NOTICE TO PLAINTIFF/PETITIONER
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 1.
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 1 does not apply while the case is in arbitration.
DATED: 7/11/08

Department 05 (253) 798-7566
08185
17494
7 /1 4 /2 3 8 8

No. 08-3-00821-4
ORDER SETTING
CASE SCHEDULE
Petitioners)
vs.
Type of Case: DIC

Track Assignment: Family Law
Assigned Department: 05 * Judge v i c k i
Respondent(s)
CC:
DocketCode: ORSCS
CHRISTOPHER LEE HARRISON, Pro Se

JOLENE MARIE HARRISON, Pro Se
Page 2 of 2
l. h o gan
80136
18548
08-3-00821-4
30524876
CME
3/1S/288S
09-15-08
IN THE SUPERIOR COURT,

Cause Number: 0 8 -3 -0 0 8 2 1 -4
Petitioners)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: VICKI L. HOGAN
Court Reporter: RAELENE SEMAGO
HARRISON, CH R IS T O PH ER L E E JR

Proceeding Outcome: Continued
Outcome Date: 09/12/2008 9:50
Resolution:
Clerk's Scomis CodeiHCNTU

Proceeding Outcome code:CONT
Ixcalcivil.pbl. d_civilJoumal_report_cover
118180
1 8 548
9 / 15-"288 8 118181

MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
VICKI L. HOGAN
__________________________________MINUTES OF PROCEEDING___________________
Court Reporter; RAELENE SEMAGO
September 12, 2008 09:49 AM Pro Se Jolene Harrison, CIF filed for Petitioner. Court
indicates to the Pro Se to set an appointment with the courthouse facilitator to help with the
documents to possibly finalize the case prior to 11/7/08. JA gave copy of the 11/7/08 trial
assignment date to the Pro Se.
End Date/Time:
JUDGE/COMMISSIONER; VICKI L. H O G AN
Year 2008
18548
8/16/2888
118182
: STATE OF WASHINGTON
; e COUNTY
No. 08-3-00821-4
ORDER SETTING
CASE SCHEDULE
Petitioner(s)
vs..
Type of Case:
Track Assignment:
Assigned Department:
Docket Code:

Respondent(s)
DIC
Family Law
05 Judge vicki l . hoga

ORSCS
Respondents Certificate of Parenting Class (Must be filed on or before)
05/09/08
Petitioner's Certificate of Parenting Class (Must be filed on or before)
05/09/08
Assignment to Set Trial Date
11/07/08 9:00
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
on the date of trial.
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 1.

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 1 does not apply while the case is in arbitration.
DATED: 9/12/08
l(
ic in '
k -

Department 05 (253)798-7566
1954S
9 / 1 6 S2893

No. 08-3-00821-4
ORDER SETTING
CASE SCHEDULE
Petitioner(s)
vs.
Type of Case: DIC

Track Assignment: Family Law
Assigned Department: 05 Judge v i c k i
Respondent(s)
CC:
Docket Code: ORSCS
CHRISTOPHER LEE HARRISON, Pro Se

JOLENE MARIE HARRISON, Pro Se
Page 2 of 2
l. hogan
119183
SS4S
IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE
JOLENE MARIE HARRISON,

Cause No. 08-3-00821-4
Petitioner(s) ,
Petitioner's Certificate
vs.
CHRISTOPHER LEE HARRISON,
Respondent(s) .
3/16/2383
119184
PARENTING BY DESIGN
2220 CALDWELL STREET
P.O. BOX 272
SANDUSKY, OH 44870
C ertificate o f C om pletion
Date: 07-12-08
Case Number: 08-3-00821-4
Name: Jolene Harrison

Course Content:
Recognize parenting styles and authority.
The importance o f setting boundaries
A nger management techniques fo r adults/cltildren/adolescents.
Learn appropriate developmental stages o f childhood/adolescents.
Learn appropriate stages o f discipline.
Enjoy a fu lle r life in the process of divorce/separation.
Fam ily C onflict Resolution

Learn appropriate communication skills.
Talking w ith children about sensitive subjects.
Process and stages o f divorce.
R aising se lf esteem fo r adults/childrenfadolescents.
Design a successful co-parenting plan.
Kathy Garber, R.N., B.S.N., M.A. Psychology

Licensed Marriage and Family Therapist
Certified Anger Management Facilitator
Certified Parenting Instructor
Certified Online Instructor
Certified Mediator
E-FILED
October 08 2008 1:01 PM
KEVIN STOCK
COUNTY CLERK

JO LEN E M ARIE H A R R IS O N
Petitioner(s),
vs.
N o. 0 8 -3-008 21-4
NOTE OF ISSUE
PRO SE UNCONTESTED
DISSOLUTION DOCKET
C H R IS T O P H E R LEE H A R R IS O N
Respondent(s)
TO THE PIERCE COUNTY CLERK:
Please place on the Uncontested PRO SE Dissolution Docket

which is to be called on
Friday, October 17,2008 9:30 AM
REQUESTED BY:
Courtroom 407
JO LEN E M ARIE H A R R IS O N
PLEASE HAVE FINAL PAPERS SIGNED AND COMPLETED PRIOR

TO ENTRY OF COURT ROOM.
COURT WILL START PROMPTLY AT 9:30.
Calendar C3 - PRO SE DISSOLUTION
ntusup-0001.pdf
13266
08*3-00821-4
30679188
PTIN
10-00-08
18 / 9 / 2 8 8 8
89882
IN C O U N T lT C L E R K 'S O F F IC E
ma .
OCT 0 8 2008 m.
PIER CE COUNTY, WASHINGTON

K E V IN S T O C K , C o u f ! ^ l j

County of
No. 0>iT - 3 - d O
Petition for Declaration

Concerning Validity (Marriage)
(PTIN)
Para.1.12: check box if petition is
attached for:
[ ] Order for protection DV (PTORPRT)
[ ] Order for protection UH (PTORAH)
I. Basis
1.1
T ic a t ic m of
o t Petitioner
P e t it io n e r
Identification
Name (first/last)t)__ Birth date
7 ~ /5 '- /9 7 ^
Last known residence (county and state only)
1.2
Identification
"' ^
tion jof
Of Respondent
Name (first/last)
Birth date_
1.3
Children of the Marriage Dependent Upon Either or Both Spouses
[]
Does not apply. There are no children dependent upon either or both spouses.
The husband and wife are both the legal (biological or adoptive) parents of the following
dependent children:
Name (first/last)
_ Age
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age,
Pet for Decl Concerning Validity (PTIN) - Page 1 of 10

WPF DR 01.0120 Mandatory (6/2008) - RCW 26.09.020; .040
13266
jk
Name (first/last)
Age
Name (first/last)
Age
The husband is and the wife is not the legal parent of the following dependent children:
Name (first/last) j 2 L
____________ Age
Name (first/last)
$
/5 " ~
/S
Age
The wife is and the husband is not the legal parent of the following dependent children:
Name (first/last)
_____ Age / /
Name (first/last)
1.4
18/9/2888
J s/tf'J iJ L s________________ '
Age
/ /
Allegation Regarding Marriage

This is a petition to have this marriage declared invalid. The marriage should not have been
contracted and the marriage should be declared invalid for the reasons which follow.
[]
[]
Jf^f
[]
[]
[]
[]
1.5
Because of the age of one or both of the parties and because the parties have not ratified
their marriage by voluntarily cohabitating after attaining the age of consent.
Because of lack of required parental or court approval and because the parties have not
ratified their marriage by voluntarily cohabitating after attaining the age of consent.
Because of a prior undissolved marriage of one or both of the parties.
Because of reasons of consanguinity.
Because a patty lacked capacity to consent to the marriage and because the parties have
not ratified their marriage by voluntarily cohabitating after attaining capacity to consent.
Either because of mental incapacity or because of the influence of alcohol or other
incapacitating substances and because the parties have not ratified their marriage by
voluntarily cohabitating after attaining capacity to consent.
Because a party was induced to enter into the marriage by force or duress, or by fraud
involving the essentials of marriage, and because the parties have not ratified their
marriage by voluntarily cohabitating after cessation of the force or duress or discovery of
the fraud.
Because the marriage was contracted in a jurisdiction other than this state and the
m s i r r i n n o . i.t'.c' ifnJrl
t rt^ islokl o. i
law/ rtf' fkp nlu p p nrliprp flip m r rin fip WflC
------- ~ ----------------t '----------------------------------- D ~ ----contracted and because the marriage has not been subsequently validated by the laws of
the place of contract or a subsequent domicile of the parties.

The parties we
and state)_
at (city
larried on (date).
w ill/ f c f j z / ,,
y -
1.6
Separation
[]
JK
Husband and wife are not separated.

Husband and wife separated on (date)
^
I
( /f itte r
/

WPF DR 01.0120 Mandatory (6/2008) - R C W 26.09.020; .041
08883
ISZhb
10/9/2888
This is the date (check all that apply):

the parties moved into separate residences,
the parties divided their assets and liabilities.
[ ] petitioner filed this petition.
both parties agreed is the date of separation.
[ ] other:
1.7
Jurisdiction
This, court has jurisdiction over the marriage.
Kl
This court has jurisdiction over the respondent because:

the respondent is currently residing in Washington.
the petitioner and respondent lived in Washington during their marriage and the
petitioner continues to reside, or be a member of the armed forces stationed, in
this state.
the petitioner and respondent may have conceived a child while within
Washington.
Other:
N
[]
[]
1.8
This court does not have jurisdiction over the respondent.
Property
There is community or separate property owned by the parties. The court should make a fair and
equitable division of all the property.
[]
[]
The division of property should be determined by the court at a later date.

The petitioners recommendation for the division of property is set forth below.
fQ
The petitioner should be awarded the parties interest in the following property:
0/C ;
Pfl
The respondent should be awarded the parties interest in the following property:
9_
a j o k / ? S /Z -
Pet for Decf Concerning Validity (PTiN) - Page 3 o f 10

_u
88884
19266
1.9
1 8 /9 /2 8 8 8
Debts and Liabilities

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

The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.
[]
The division of debts and liabilities should be determined by the court at a later
date.
The petitioners recommendation for the division of debts and liabilities is set
forth below.
Ml
|)(j
The petitioner should be ordered to pay the following debts and

/
71/ 7-
/ 97.
/U a >iJ 7 7
y /.io
C ju tlc A
/) -
,M D.
3 & 0 -O
n Y /V T
The respondent should be ordered to pay the following debts and

<jf-
/ r n g o f M
c H /t
3 ' C a A ts a j * <TrUL~
fa- j O i ^ a 4 / u f >
'
,
,
C e & tf
7 C f a w W p & t l T 0
2 //// //
W
./ c
P sy . 7 7
*=>
/* ? . 7 ?
Y /7 . / y
/ /
//< H .d 6
/< D a ,^ o
(P-
^ 0 ^ s)
A-/
Pet for Dec! Concerning Validity (PTiN) - Page 4 o f 10
\ I /^n->'?'X/Zs7
89885
137.B6
m*
'ifc
C jszj/
tk jL
18/9/2883
J/ jau I&/ cAu O

J ^
^
W
( _ C 0 h ' )
H -
* /? * ?
- T
^ ^ s r p
/5-
j* y > U
/V -
L O ft C a M & c W s >
/ S '/&
* "
/ y . / 9 t T
p & t -par b * c / C<A7C*??WJ, V a / y p j y

W
o / . o / 36
Vy
/ i'V -
/ /
._ -? s 9. a .y
/A ^ -C -J y
3 , 7 * //> 3 J
/O & rA a -n
y < iv J 'Z 0 y ^ J
* C l.
3 & <S 3 & '

/p ~ 0 d ,j-t)
*t
V p jA
A^
f J h
88836
92&&
1.10
Maintenance
K
[]
[]
1.11
1 8 /9 /2 8 8 8
Maintenance should not be ordered.

There is a need for maintenance as follows:
Other:

[]
[]
[]
[]
Does not apply.

[ ] husband [ ] wife from disturbing the peace of the other party.
[ ] husband [ ] wife from going onto the grounds of or entering the home, work place or
school of the other party or the day care or school of the following children:________
A continuing restraining order should be entered which restrains or enjoins the [ ] husband
[ ] wife from knowingly coming within or knowingly remaining within
(distance)____________ of the home, work place or school of the other party or the day
care or school of these children:
Other:__________________________________________________________________
[]
[]
A continuing restraining order should be entered which restrains or enjoins

(name)___________________________from molesting, assaulting, harassing, or
stalking (name) ___________________________ . (If the court orders this relief, the
restrained person will be prohibited from possessing a firearm or ammunition under
federal law for the duration of the order. An exception exists for law enforcement
officers and military personnel when carrying department/government-issued firearms.
court______________________ , which expires on (date)__________

The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this petition.
[ ] filed separately under [ ] this case number [ ] case number_____________________ .
Violence forms or RCW 10.14 Antiharassment forms.
Pet for DecI Concerning Validity (PTIN) - Page 5 o f 10
WPF DR 01.0120 Mandatory (6/2008) - RC W 26.09.020; .040
88887
13266
1.13
Pregnancy
- P$
[]
[]
1.14
18/3/2888

The wife is pregnant. Note: Under RCW 26.26,116, the husband is the presumed
Other:

[]
This court has jurisdiction over the children for the reasons set forth below:
[]
custody, parenting plan, residential schedule or visitation determination in this matter and:
This state is the home state of the children because:
ftf
[]
[]
^
The children and the parents or the children and at least one parent or person acting as a
parent have significant connection with the state other than mere physical presence, and
substantial evidence is available in this state concerning the childrens care, protection,
training and personal relationships; and
[]
[]
[]
the children lived in Washington with a parent or a person acting as a parent for at
proceeding.
the children are less than six months old and have lived in Washington with a
parent or a person acting as parent since birth.
any absences from Washington have been only temporary.
Washington was the home state of the children within six months before the
parent or person acting as a parent continued to live in this state.
the children have no home state elsewhere.

the childrens home state has declined to exercise jurisdiction on the ground that
this state is the more appropriate forum under RCW 26,27.261 or .271.
All courts in the children's home state have declined to exercise jurisdiction on the ground
Pet for Dec! Concerning Validity (PTiN) - Page 6 of 10

8888
-i-ft.
[]
[j
1.15
92 b&
10/9/2888
emergency to protect the children because the children or a sibling or parent of the children
are subjected to or threatened with abuse. RCW 26.27.231.
[]

this chapter or a child custody proceeding has been commenced in a court of a
state having jurisdiction under RCW 26.27.201 through 26.27.221. The
requirements of RCW 26.27.231(3) apply to this matter. This states jurisdiction
over the children shall last until (date)__________________ ____________ .
[]

this chapter and a child custody proceeding has not been commenced in a court
action is not filed in (potential home state)
_________________ by the time
the child has been in Washington for six months, (date)___________________ ,
then Washington's jurisdiction will be final and continuing.
Other:
Child Support and Parenting Plan for Dependent Children

[]
[]
The parties have no dependent children.

A parenting plan and an order of child support pursuant to the Washington State child
support statutes should be entered for the following children who are dependent upon
both parties:
Names of Children
/
-
The petitioners proposed parenting plan for these children:

[Xf
[]
is attached and is incorporated by reference as part of this Petition.

will be filed and served at a later date pursuant to RCW 26.09.181.
(The following information is required only for those children who are included in the
petitioners proposed parenting plan.)

petitioner or the respondent.
88889
19266
[]
1 0 S 9 S 2 883
lived, including the state of Washington, the dates the children lived there and
the names of the persons with whom the children lived. The present addresses of
those persons must be listed in the required Confidential Information Form):
[]
The petitioner does not know of any person other than the respondent who has
physical custody of, or claims to have custody or visitation rights to, the
children.
visitation rights to, the children (list their names and the children concerned
not list the responding party):
[]
The petitioner has not been involved in any other proceeding regarding the
children.
The petitioner has been involved in the following proceedings regarding the
children (list the court, the case number, and the date of the judgment or order):
[]
The petitioner does not know of any other legal proceedings concerning the
children.
The petitioner knows of the following legal proceedings that concern the
children (list the children concerned, the court, the case number and the kind of
proceeding):
Pet for Dec! Concerning Validity (PTiN) - Page 8 o f 10

9809
192&&
182922888
II. Relief Requested

The petitioner R e q u e s ts the court to declare this marriage invalid and to grant the relief below.
[]
w
M
[]
[]
M
[]
[]
[]
[]
[]
M
Provide reasonable maintenance for the [ ] husband [ ] wife.

Approve the petitioners proposed parenting plan for the dependent children.
Determine support for the dependent children pursuant to the Washington State child
support statutes.
Approve the separation agreement.
Divide the property and liabilities.
. /' I
Change name o f wife to (first, middle, last): {Jrfk/pjL.
Change name of husbandd to (first, middle, l
a
s
^
Enter an antiharassment protection order.
Enter a continuing restraining order.
Order payment of day care expenses for the children.
Award the tax exemption^ for the dependent children as follows:
7 ^ ^ Zs,
fa g -
[]
[]
Dated :
Order payment of attorney

Other:
7 )d ~
s, other professional fees and costs.
/Y l
h coT '
lature of Petitioner or Lawyer/WSBA No.

fa k jh
z n /iy /e
Print or Type Name

f declare under penalty o f perjury under the laws of the state o f Washington that the foregoing is true and
correct.
Signed at (city)_
hO C
(state)
_ on (date)
3 rd A .
__ - r Y l 4 ^ n n r i h y e r r \ ^
K^nature o f Petitioner
Print or Type Name

D<]
Joinder
1, the respondent, join in the petition. 1 understand that by joining in the petition, a decree or judgment
and order may be entered in accordance with the relief requested in the petition unless, prior to the entry
of the decree or judgment and order, a response is filed and served.
88891
19288
1 8 /3 /2 8 8 8

Petitioner(s)
vs.
Cause N u m b er:08 -3 -0 08 2 1-4 .

Page 1 of 2

Respondent(s)
Judge/Commissioner: ROBYN LINDSAY
Court Reporter: Smart Court
Judicial Assistant/Clerk: Jennifer Segobia
HARRISON, C H R IS T O PH ER LEE
HARRISON, C H R IS T O PH ER LE E J R
Proceeding Set: Exparte Action

Proceeding Outcome: Held
Outcome Date: 10/08/2008 10:53
Resolution:
Clerk's Scom is Code:MTHRG

Proceeding Outcome code: HELD
!xca!civil. pbi. d_ civilJoum a}_feportjzover
88334
13266
1 8 /9 /2 8 8 8
88895


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
ROBYN LINDSAY
__________________________________MINUTES OF PROCEEDING_____________________
Judicial Assistant/Clerk: Jennifer Segobia
Court ReporterSmart Court
Start DatefTime: 10/08/08 11:03 AM
October 08, 2008 11:02 AM
Petitioner Jolene Harrison comes before the court with a motion to convert
decree of
dissolution to invalidity. Decree has not been entered.
Petitioner needs to file am ended petition for invalidity.
End Date/Time: 10/08/08 11:13 AM
EX PARTE
d epa r t m en t
OCT 0 8 2008
VP I E R C E < | W TY, C le r k
d epu ty
JU D GDCO M M ISSIO NER: ROBYN LINDSAY Year 2008
192&S
00-3-00821-4
30679987
ORPRFP
18/9/2888
10-00-08
1
2
3
FILED
IN C O U N T Y C L E R K 'S O F F IC E
A.M.
SUPERIOR COURJ OF WASHINGTON

COUNTY OF
___________
OCT 0 8 2008
P.M.
KfcVtN STOCK, County Clerk
by- - --- .------ -- DEPUTY
M a r ie - J n m s M
NO. 0
Petitioner(s),
and
/)/)
I '

IN FORMA PAUPERIS
10
f 'J n tis f d p U r
11
n a .v r is 6 7 i
(No Mandatory Form Developed)
__________________________ Respondent(s).
12
I. MOTK
MOTION
13
Petitioner,__________ '_____________ , moves this Court for an order as follows:
14
1.
15
2.
16
17
18
Allowing commencement and prosecution of this action in forma pauperis; and

Directing the Clerk of the Court to file and issue papers and pleadings as required by the
petitioner without the payment of any fees, costs, or charges, subject to recovery from the opposing party.
This motion is based upon the attached declaration.
DATED: G r i n U r
J td tt
*
19
jM -J m J V lL a & y y -,
20
21
g,
Print or Type Name
H u r h S /a ? )
22
23
II. ORDER
p ; p ' u
88878
192S&
1 8 /9 /2 8 0 8
THIS MATTER having come before the undersigned this day on petitioners motion, and the Court,
having reviewed the files and records herein, and finding that petitioner has presented a sufficient declaration
3
4
to proceed in forma pauperis,

IT IS HEREBY ORDERED THAT the Petitioner is hereby allowed to prosecute this action in
forma pauperis, and tho Clerk of this, Court ic dirootod to file and issue papeis and'plcaUinga ao requested by-
e x w t . . . t o . 6 ic ( I j h ' p ' f e e of-coste frompefifiener without prepayment of any fees, coster
6
the opposingjaartv.
7
DONE IN OPEN COURT this
8
9
10
Presented by:
11
12
m
13
14
15
16
17
18
19
20
21
22
23
-$ a n n iA * T *
FILED
IN C O U N T Y C L E R K S O F F IC E
Optioner
J v W . M a r ie - M i r r i j o n
Print or Type Name
OCT 0 8 2008
p j.
COUNTY, WASHINGTON
K L \ . o T O C K , C o u n ty CiorEt
bY -----------------------DEPUTY
88879
13266
08-3-00821-4
306791?'
1 0 /9 /2 3 8 8
88892
10-08-08
JN
F V V t f l l t S O F F IC E
COUNTV CLERK

County of
In re:
No. 08-3-0082T4

Petitioner,
and
Joinder
(JN)

Respondent.
1.
Joinder
I have read the petition and join in it. I understand that by joining in the petition, a decree or
judgment and order may be entered in accordance with the relief requested in the petition, unless
prior to the entry of the decree or judgment and order a response is filed and served.
2.
Notice of Further Proceedings

[X]
I waive notice of entry of the decree.
[]
I demand notice of all further proceedings in this matter. Further notice should be sent to
the following service address: [You may list an address that is not your residential
address where you agree to accept legal documents.]
Any time this address changes while this action is pending, you must notify the opposing
parties in writing and file an updated Confidential Information Form (WPF DRPSCU
09.0200) with the court clerk.
3.
Dated:
Other
/ o
- v -
i t y

Print or Type Name
Joinder (JN) - Page 1 of 1
WPF DRPSCU 01.0330 (6/2006)
îginal
1926&
18/9/2888

County of
In re:
No. 08-3-00821-4
Petitioner,
Acceptance of Service
(ACSR)
and
Respondent.
[Name] accepts service of:
[X] the summons and petition in this action.

[X] a proposed order of child support.
[X] proposed Child Support Worksheets.
[X]Confidential Information Form,
[X]Findings of Fact and Conclusions of Law
[X] a proposed parenting plan.

[X] a financial declaration.
[X] other: Copy of Final Orders,
[X]Residential Tttne Summary Report
[X] Joinder
\
Consent to Personal Jurisdiction

[X] Does not apply.
Dated:
J6- v-'Z .w r
re of Party or Lawyer /WSBA No. Accepting Service
Christoper Lee Harrison___________________________

Print or Type Name
Notice to party: You may list an address that is not your
residential address where you agree to accept legal documents.
Any time this address changes while this action is pending,
you must notify the opposing parties in writing and file an
updated Confidential Information Form (WPF DRPSCU
3 1 /5
. J 7 ._ _ _ _ _ _ _ _ _ _
[Address]
l& cc& n a^ \a SA._________________

Acceptance of Service (ACSR) - Page 1 of 1
WPF DRPSCU 01.0310 (6/2006)
88893
132&&
08-3-00821-4
30680094
AFS
18/9/2888
10-08-00
1
'2
3
4
OCT 0 6 2008
8
9
SUPERIOR COURT OF WASHINGTON

COUNTY OF
___________
----------- - ~ W -------'DEPUTY
fy
In
3 q }s j m > M a r i e
M a rn s& ti
no.
Petitioner(s),
10
and
11
CJl'f'istD jpJrer
12
__________________________ Respondent(s).
13
14
15
Pm
rM C
STK,r U 'J?',SHWGT'>N
KcVsM
STOCK,
County Clerk
6
7
H /ttr fiS o ? }
P etition^"vc^
tition
/c^"7
~0 6 $ < ^)- P
DECLARATION IN SUPPORT OF
MOTION TO PROCEED IN
FORMA PAUPERIS
(No Mandatory Form Developed)
hereby certii
certifies and declares under penalty of perjury under
the laws of the State of Washington that the following is true and correct:
1.
lam the Petitioner in this action. This proceeding is brought in good faith and it is my
present intention to proceed to a final order on the merits of my petition.

16
2.
1believe I have valid reasons for bringing this action and that I am entitled to relief
3.
I have no means or ability with which to pay any of the legal fees, charges, costs, or
17
18
19
20
21
22
23
disbursements necessary to commence and prosecute this action or with which to post security for same.
4.
My household consists of myself and nlxJSS/L ^ / p

H oIty - J 3 ,
T y lc y F /d h r :
to tfh & y $ r - 3 ______. My income per month is $___
afcM Joy
b if f 0@ . which is derived from S &
S72zJZ~ s fs y /s J a s r c jL .
following monthly expenses:
joy
this income I.have the

'OIS4-'
DECLARATION IN SUPPORT OF MOTION
ORIGINAL
88888
192&6
10/9/2808
80881
1
Rent
Phone
PUD/Utilities
Food
Transportation
A-L/C Insurance
Medical
Laundry -f SU fph^ LS
Babysitting
Clothing
Miscellaneous
2
3
4
5
$ }} 0 } 5 . 0 O
$ 7 0 .0 0
$ V75~. 4 0
$ 1*00- 2 0
$736*06
$SlO0'O6
$ 7 7 3 .0 0
$500* 0
$/0 0 -O O
$J0O*OO
7
Total
8
9
10
11
12
4.
$ ^ 3 3 - **
My assets consist of household furnishings o f nominal value and clothing and personal
effects for myself and my children.

5.
I have no assets or income other than those stated above. I have no means or ability to pay
any of the legal fees, charges, costs, or disbursements necessary to prosecute this action or to post security.
SIGNED AND DATED on J P - d X - S L O O f t . at
lO U __________ , Washington.
13
A fl M d S V ltqgrw
14
15
M a s/e,
Print or Type Name
16
17
18
19
20
21
22
23
DECLARATION IN SUPPORT OF MOTION

TO PROCEED IN FORMA PA UPERIS - Page 2 o f 2
n a jr n s & n
19444
08-3-00821-4
30723360
LTRPA
FAMILY S U P P O R T DIVISION
949 Court
Tacoma, Washington 98402-5616
Family Support: (253) 798-7444
FAX: (253) 798-4157
(800) 248-5130
Prosecuting Attorney
FILED
October 13, 2008
u.
OCT 1 5 2008 pj.
P ER C E COUNTY, WASHINGTON
KEVIN STOCK, County Clerk
B Y _ ------- ------------- DEPUTY
Jolene M Harrison/Christopher L Harrison

Pierce County Cause Number 08-3-00821-4
Dear Ms. Harrison:

Thank you for providing our office with notice of the above-referenced matter. The public
assistance currently being provided by the State is medical coverage only. Therefore, our interest
is limited to provision 3.18 of the Order of Child Support.
RCW 26.23.050(5)(h) and RCW 26.09.105 require parents to pay for medical insurance for the
child(ren) if available through an employer or union and if it can be obtained at 25% or less of the
basic child support obligation. RCW 26.09105(8) specifically excludes medical assistance provided
by the State from meeting this requirement.
W e are, therefore, asking that any Order of Child Support which may be entered either be run by
my office for approval/signature or that you use the first paragraph in 3.18 which provides that both
parents be required to provide the insurance coverage. Please do not check any of the boxes for
the alternative provisions in this section.
If you intend to request a medical insurance provision that is not in compliance with the statutes
and this request, please call me at 253-798-3396 to discuss this matter. If we are not in
agreement, I may need to file a notice of appearance and argue this issue on the record.
Please be advised that if the minor child(ren) start(s) to receive financial assistance from the State
of Washington, you will need to provide our office with notice of any actions done in the Pierce
County Superior Court.
Thank you for your cooperation.
Sincerely,
Monica I. LaBeck
Deputy Prosecuting Attorney
MIL/led
cc:
court file
Medical Only to Parties Letter.frm (Rev 6/04)

Prinled on recycled paper
8812?
Gerald A. Horne
10-15-08
JOLENE HARRISON
12107 209 th AVE CT E
BONNEY LAKE WA 98391
RE:
10/15^2888
08-3-00021-4
30750630
CME
JRT OF THE STATE OF WASHIN

) FOR PIERCE COUNTY
10-20-08
No. 08-3 -0 0 8 2 1 -4
Petitioner(s),
Memorandum of Journal Entry
vs.
] Dissolution
] Legal Separation
Respondent(s)
(ADM04)
[|X I Petitioner appeared and testified
J ,
a t '
Attorney For Petitioner
___________________
Attorney For Respondent
] No one appeared
[^ G R A N T E D
] VERIFICATION
] FORMAL PROOF ONLY
] DENIED FOR THE LISTED REASONS:
] Respondent appeared and testified
] Service insufficient
] No proof of service
] State Notification
] 90 days not elapsed
] Paternity at issue
] GAL needs to be appointed
] Contested / response filed
J Needs State Signature
] Other
October 17, 2008 9:30 AM

a ./? ) .
/ . 6 /
Annulment-Invalidity
H. EDWARD HAARMANN
Clerk
Courtroom number: 407

Calendar: C3 - PRO SE DISSOLUTION
Run date/time 10/16/08 14:32
Ixcrtrpt.pbt dJoumai_entry_disso_report
14. OCC
^ UU"7
4
a / 7 RS G -t o c a

County of Pierce
No. 08-3-00821-4
Petitioner,
and
Residential Time Summary

Report
(RTSR)
Clerks Action Required
Respondent.
Submit with final Parenting Plan, only. This form is for statistical reporting purposes only.
1. The Parenting Plan

The court signed the Parenting Plan on (Date)
IQ/l 7/08
________________________________
It was: [X] by agreement of the parties
It is: [ ] an original order
[ ] after a contested hearing or trial
[ ] a modification of a prior order
_______ [ l by default________________________________ ____________________________________
How many children under the parenting plan have the residential schedule summarized in paragraph 2,
below?
one _________ ____________________________________________________________
2. Residential Schedule from Part III of the Parenting Plan
If the same schedule does not apply to all children, fill out a separate Residential
Time Summary Report for each schedule.
Check the box that comes
closest to representing the
time spent with each parent:
[ I
[ 1
[ 1
[ 1
_______ LJ_______
[ ]
[ ]
_______ U _______
[ 1
rx i
% of time the
children spend
with the Mother
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
% o f time the
children spend
with the Father
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
Res. Time Summary Rpt (RTSR) - Page 1 of 2

WPF DR 01.0410- Mandatory (4/2008) - RCW26.09.231, 26.18.230
[ ]
100%
0%
3. Information about the Parents

Father: [ X] self-represented [ ] represented by an attorney___________________
The court found under paragraphs 2.1 and 2.2: [ ] does not apply, or
the Father [X] committed domestic violence
[X] abused or neglected a child
[X] has chemical dependency issues
[X] has mental health issues
[ ] other:_______________________________________________________
Mother: [XI self-represented [ ] represented by an attorney_____________________________________
The court found
the Mother [
[
[
under paragraphs 2.1 and 2.2: [ X ] does not apply, or

] committed domestic violence
[ ] abused or neglected a child
] has chemical dependency issues
[ ] has mental health issues
] other:________________________________________________________________
4. Dispute Resolution from Part V. of the Parenting Plan

[ ] Arbitration
Prepared by:
[ ] Mediation
[ ] Counseling
Jolene M. Harrison
[X ] No dispute resolution process except court action
on (Date) 10/04/2008 .
Res. Time Summary Rpt (RTSR) - Page 2 of 2
WPF DR 01.0410 - Mandatory (4/2008) - RCW 26.09.231, 26.18.230

County of Pierce
In re: Marriage of:
No. 0 8 - 3 - 0 0 8 2 1 - 4
Petitioner,
and
Financial Declaration
[ X] Petitioner
[ 1 Respondent
(FNDCLR)
Respondent.
Name:
DateofBirth:
J u ly
1 5 ,1 9 7 5
I. Summary of Basic Information

Declarants Total Monthly Net Income (from 3.3 below)
$ 2,478.50
Declarants Total Monthly Household Expenses (from 5.9 below)
$ 3,976.00
Declarants Total Monthly Debt Expenses (from 5.11 below)
$ 0________
Declarants Total Monthly Expenses (from 5.12 below)
S 3,976.00
Estimate o f the other partys gross monthly income (from 3 .If below)
fXl$ 2,080.00
[ ] unknown
IK Personal Information
2.1
Occupation: Pharmacy Technician
2.2
The highest year of education completed: 12th grade
2.3
Are you presently employed? [X] Yes [ ] No

a. If yes:
(1)
Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
Safeway Pharmacy Store 0244

611 South Meridian
Financial Declaration (FNDCLR) - Page 1 of 6

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
Puyallup, Wa. 98371
b. I f no:
(2)
When did you start work there (month/year)?
September 2004
(1)
When did you last work (month/year)?
_____________
(2)
(3)
What were your gross monthly earnings?

Why are you presently unemployed?
$ ____________
III. Income Information

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 N o t an issue this entire section should be
completed. (Estimate of other partys income information is optional.)
3.1
Gross Monthly Income

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your monthly wages
and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If you are paid twice
monthly, multiply your gross pay by 2. If you are paid once a month, list that amount below.
Name
Christopher (father)
Name
Jolene (mother)
a.
Wages and Salaries
$ 2 .0 8 0 .0 0
$ 2 ,6 9 3 .0 0
b.
Interest and Dividend Income
c.
Business Income
d.
Spousal Maintenance Received

From
e.
Other Income
f.
Total Gross Monthly Income (add lines 3.la through 3 .le)
$ 2 ,0 8 0 .0 0
$ 2 ,6 9 3 .0 0
g*
Actual Gross Income (Year-to-date)
$ Unknown
$ 24.240.28
Monthly Deductions From Gross Income

a.
Income Taxes
$ 2 0 3 .2 5
$ 5 9 .0 0
b.
FICA/Self-employment Taxes
$ 1 5 9 .1 2
$ 1 5 1 .0 0
c.
State Industrial Insurance Deductions
d.
Mandatory Union/Professional Dues
$ 4 .5 0
e.
Pension Plan Payments
f.
Spousal Maintenance Paid
g*
Normal Business Expenses
Total Deductions from Gross Income
$ 3 6 2 .3 7
$ 2 1 4 .5 0
$ 2 ,4 7 8 .5 0
h.
(add lines 3.2a through 3.2g)
Monthly Net Income (Line 3. If minus line 3.2h or

line 3 from the Child Support Worksheet(s).)
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
1 . 7 1 7 .6 3
3.4
Miscellaneous Income
a.
Child support received from other relationships
b.
Other miscellaneous income
c.
$0
$0
(list source and amounts)
_________________________________________ $ ___________
$_
_________________________________________
$_
__________
_________________________________________ $ ___________
$_
_________________________________________ $ ___________
$_
Total Miscellaneous Income (add lines 3.4a through 3.4b)
________________
$0
$_
3.5
Income of Other Adults in Household
SO
3.6
If the income of either party is disputed, state monthly income you believe is correct and explain below;
IV. Available Assets

4.1
Cash on hand
$0
4.2
On deposit in banks
so
4.3
Stocks and bonds, cash value of life insurance
$0
4.4
Other liquid assets:
$0
V. Monthly Expense Information

Monthly expenses for myself and Alyssa, Tyler, Hannah, and C.J. dependents are: (Expenses should be calculated
for the future, after separation, based on the anticipated residential schedule for the children.)
5.1
5.2
Housing
Rent, l st mortgage or contract payments
S 1,015.00
Installment payments for other mortgages or encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
$ 1,015.00
Utilities
Heat (gas & oil)
$ 200.00
Electricity
$ 200.00
Financial Declaration (FNDCLR) - Page 3 o f 6

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
4a, o r "
5.3
5.4
5.5
5.6
5.7
Water, sewer, garbage
$ 35.00
Telephone
$ 70.00
Cable
$ 15.00
Other
$38.00
Total Utilities
$ 558.00
Food and Supplies

Food for 6 persons
$ 600.00
Supplies (paper, tobacco, pets)
$ 200.00
Meals eaten out
$ 100.00
Other
Total Food Supplies
$ 900.00
Children
Day Care/Babysitting
$ 200.00
Clothing
$ 100.00
Tuition (if any)
Other child-related expenses
$ __
Total Expenses Children
$ 300.00
Transportation
Vehicle payments or leases
$ 180.00
Vehicle insurance & license
$ 200.00
Vehicle gas, oil, ordinary maintenance
$ 250.00
Parking
$ ___
Other transportation expenses
$ ___ !_
Total Transportation
$ 630.00
Health Care (Omit if fully covered)

Insurance
$ 208.00
Uninsured dental, orthodontic, medical, eye care expenses
$ 175.00
Other uninsured health expenses
$ 60.00
Total Health Care
$ 443.00
Personal Expenses (Not including children)

Clothing
$ 50.00
Hair care/personal care expenses
$ 50.00

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
< a / oA11ov */ ' j o a o
4s a t c
5.8
Clubs and recreation
-_
Education
Books, newspapers, magazines, photos
$ 10.00
Gifts
$20.00
Other
Total Personal Expenses
$ 130.00
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other_______________________________________________
O ther_______________________________________________
Total Miscellaneous Expenses
5.9
Total Household Expenses
5.10
Installment Debts Included in Paragraphs 5.1 Through 5.8
5.11
(The total of Paragraphs 5.1 through 5.8)
$ 3 ,9 7 6 .0 0
Creditor
Description
of Debt
Balance
Month of
Last Payment
BECU
Auto Loan
5,000.00
September
Care Credit
_________________ __________________________
Other Debts and Monthly Expenses not Included in Paragraphs 5.1

Through 5.8
Creditor
Description
o f Debt
Balance
Month of
I .ast Payment
Amount of
Monthly
Payment
__________________
_____________________ ______________________________ $ ___________
__________________
_____________________ ______________________________ $ ___________
__________________
_____________________
______________
________________ _______________________ $________
__________________
_____________________ ______________________________ $ ___________
__________________
_____________________
__________________
_____________________ ______________________________ $ ___________
____________
____________
Total Monthly Payments for Other Debts and Monthly Expenses

WPF DRPSCU 01.1550 (6/2006) - R C W 26.18.220(1)
____________
____________
$ ________
$ ________
$ ________
5.12
Total Expenses (Add Paragraphs 5.9 and 5.11)
%1.976.00
VI. Attorney Fees

6.1
Amount paid for attorney fees and costs to date:
6.2
The source of this money was:
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are:
6.5
Other:
1 declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
Signed at Bonney Lake, [City] Washington [State] on
171 -M ohoM
ature of Declarant
October 15. 2008
[Date].

Print or Type Name
The following financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:
[X] Individual [ ] Partnership or Corporate Income Tax. returns for the years 2007_________
_______________________________________________ including all W-2s and schedules;
[X] Pay stubs for the dates of October 2, 2008 .
[ ] Other:
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party a n d filed with the court separately
using the sealed financial source docum ents cover sheet (W PF DRPSC U
09.0220). If filed separately using the cover sheet the records w ill be sealed to
protect yo u r privacy (although they will be available to a ll parties in the case,
their attorneys, court personnel an d certain state agencies and boards.) See GR
22 (C)(2).

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

County of Pierce
[X] In re the Marriage of:
[ ] In re the Domestic Partnership of:
Petitioner,
and
No. 08-3-00821-4
Parenting Plan
[ ] Proposed (PPP)
[ ] Temporary (PPT)
[X] Final Order (PP)
Respondent.
[X]
[]
[]
[]
separation, or declaration concerning validity signed by the court on this date or
dated________________________ .
the final parenting plan signed by the court pursuant to an order signed by the court on
this date or dated_________________________ , which modifies a previous parenting
plan or custody decree.
proposed by (name)_______________________________ .

Name
Parenting Plan (PPP, PPT, PP) - Page 1 of 11

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187;. 194
Age
3 years
4a
< ao*XIj
" V'
K /^CIQQ
Ijli Wl> i a o

contact with the children) and the right to make decisions for the child(ren).
2.1

[]
[X]
Does not apply.

The [ ] petitioners [X] respondents residential time with the child(ren) shall be limited
or restrained completely, and mutual decision-making and designation of a dispute
resolution process other than court action shall not be required, because [X] this parent
[X]
[X]
[X]
2.2

harm.

[]
[X]
Does not apply.

The [ ] petitioners [X] respondents involvement or conduct may have an adverse effect
on the child(ren)s best interests because of the existence of the factors which follow:
[X]
[X]
[X]
[]
[X]
[]
[]

A long-term impairment resulting from drug, alcohol, or other substance abuse
that interferes with the performance of parenting functions.
child.
Other:

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181; .187;. 194
iS H h ?
J
.
ic j/p a y ^ aao
<
ju w
u

The res/denf/a/ scbec/u/e m usf sef forth where the chiid(ren) shall reside each day o f fhe year,
including provisions for holidays, birthdays o f family members, vacations, and other special
individual needs o f their family. Paragraphs 3.1 through 3.9 are one way to write your
Paragraph 3.13.
3.1

[]
[X]

Prior to enrollment in school, the child(ren) shall reside with the [X] petitioner
[ ] respondent, except for the following days and times when the child(ren) will reside
with or be with the other parent:
from (day and time) Friday night at 8:00 pm to (day and time) Sunday night at 8:00
pm (See limitations - 3 .10)
[]
[]
every week [ ] every other week [ ] the first and third week of the month
the second and fourth week of the month [X] other: Every other weekend
alternating with every other weekday schedule.
from (day and time) Wednesday from after work to Thursday 8:00 am
(See limitations - 3.10)
[]
[]
3.2
the second and fourth week of the month [X] other: Every other weekday
alternating with every other weekend schedule.
School Schedule
Upon enrollment in school, the child(ren) shall reside with the [X] petitioner
[ ] respondent, except for the following days and times when the child(ren) will reside with or be
with the other parent:
from (day and time)
Friday night at 8:00 pm to (day and time) Sunday night at 8:00
pm (See limitations - 3.10)
[]
[]

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181;. 187;. 194
ao v
>1
From (day and time) Wednesday from after work to Thursday 8:00 am
(See limitations - 3.10)
[]
[]
[]
3.3
The school schedule will start when each child begins [ ] kindergarten [X] first grade
[ ] other:
Schedule for Winter Vacation

The child(ren) shall reside with the [X] petitioner [ ] respondent during winter vacation, except
for the following days and times when the child(ren) will reside with or be with the other parent:
Mutually Arranged, (See limitations -3.10)
3.4

The child(ren) shall reside with the [X] petitioner [ ] respondent during other school breaks,
parent: To be determined between mother and father. (See Restrictions 3.10)
3.5
Summer Schedule
Upon completion of the school year, the chitd(ren) shall reside with the [X] petitioner
[X]
[]
3.6

Other:

[X]
[]
3.7
Does not apply.


New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Odd
Even
Odd
Even
Odd
Even
Odd
Even
Odd
Even
[X]
times): 8am to 8pm Restrictions apply. (See 3.10)
[]
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
[]
Other:

With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
Mothers Day_______________
Every
Every
Fathers Day________________
______________
Mothers Birthday
Every
Every
Fathers Birthday

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181; .187;. 194
[]
3.9
Other:

[X]
[]
Does not apply because one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
[]
[]
3.10
____ holidays (3.7)

____ special occasions (3.8)
____ vacation with parents (3.6)
Other:
Restrictions
[]
[X]
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
The [ ] petitioners [X] respondents residential time with the children shall be limited
because there are limiting factors in paragraphs 2.1 and 2.2. The following restrictions
shall apply when the children spend time with this parent:
The father is not to drink within 8 hours of taking the child and must abstain
from drinking during the childs stay. Residential time to be supervised or limited if
father demonstrates evidence of mental health issues, abusive behavior, or drinking.
The children are not to ride with anyone that does not have a valid Washington State
Drivers License or other valid State Drivers License. The Driver must have proof of
liability insurance and there must be a seat and seatbelt available for each child. The
children shall be restrained properly according to the Washington State Law of proper
restraints while riding in a motor vehicle.
[]
[ ] petitioners [ ] respondents residential time with the children for the following
reasons:

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181;. 187;. 194
3.11
Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Transportation arrangements for the child(ren), between parents shall be as follows:
To be worked out fairly half and half between the mother and father for the purpose of
accommodating work schedules. The children are not to ride with anyone that does not have a
valid Washington State Drivers License or other valid State Drivers License. The Driver must
have proof of liability insurance and there must be a seat and seatbelt available for each child.
The children shall be restrained properly according to the Washington State Law of proper
restraints while riding in a motor vehicle.
3.12
the [X] petitioner [ ] respondent. This parent is designated the custodian of the child(ren) solely
for purposes of all other state and federal statutes which require a designation or determination of
parenting plan.
3.13
Other
3.14
Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child

60 days notice, that person must give notice within 5 days after learning of the move. The

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181; .187; .194
confirmed.
(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.
IV. Decision Making

4.1
children.
4.2
Major Decisions
Education decisions
[X]
[X]
[X]
U
[]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[3
[]
[]
[3
[3
[3
[3
Parenting Plan (PPP, PPT, PP) ~ Page 8 of 11

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;.187;. 194
respondent
respondent
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
[]
[]
4.3
petitioner
petitioner
[]
[]
respondent
respondent
[]
[]
joint
joint

[]
[X]
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.
Sole decision making shall be ordered to the [X] petitioner [ ] respondent for the
following reasons:
[X]
[]
[]

RCW 26.09.191 (See paragraph 2.1).
(a)
(b)
(c)
(d)
[]

The history of participation of each parent in decision making in each of
RCW 26.09.184(4)(a); and
the provisions o f this plan must be used before filing a petition to modify the plan o ra motion for
[]
or agency):
[]
counseling by ____________________________________ , or
Parenting Plan (PPP, PPT, PP) - Page 9 o f 11

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181;. 187;. 194
iqccj
<s ,"?s /
a a r< iau7*j
[]
mediation by ____________________________________ , if this box is checked and

[]
arbitration by
________________________.____________ .
[]
[]
[]
__________ % petitioner _________ % respondent.

worksheets.
The dispute resolution process shall be commenced by notifying the other party by [ ] written
request [ ] certified mail [ ] other:
(a)
(b)
(c)
(d)
(e)
[X]

and of each arbitration award and shall be provided to each party.
other parent.
court.

[X]
[]


[X]
[]
Does not apply.

of the state of Washington that this plan has been proposed in good faith and that the statements
in Part II of this Plan are true and correct.

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, .181;. 187;. 194
Petitioner
Respondent

WARNING: Violation of residential provisions of this order with actual knowledge of its terms is
not affected.
. 1
Dated:
October 17. 2008
iWdgolCommissioner '
H. Edward Haarmann
Presented by:
Ifl y h x s ? n M < r r^
^
Jolene Marie Harrison__________
Print Name
Approved for entry:
Court Commissioner

Print Name

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181;. 187; .194
t Q
ETC
JroU
08-3-00821-4
30750654
ORSW
i*- o
*/ *I - b
v f/ -Ja
b u c
u io
u
10- 20-08

County of Pierce
No. 08-3-00821-4
Order of Child Support
Petitioner,
and
[ ] Temporary (TMORS)
[X] Final Order (ORS)
Respondent.
I. Judgment Summary
[X]
[]
Does not apply because no attorneys fees or back child support has been ordered.
The judgment summary:
A.
B.
C.
Judgment creditor
_____________
Judgment debtor
_____________
Principal judgment amount (back child support)
$
from (date)______________ to (date)______________
Interest to date of judgment
$
Attorney fees
$
Costs
$
Other recovery amount
$
Principal judgment shall bear interest a t__________% per annum
Attorney fees, costs and other recovery amounts shall bear interest a t__________ % per annum
Attorney for judgment creditor
_____________________________
Attorney for judgment debtor
_____________________________
Other:
D.
E.
F.
G.
H.
I.
J.
K.
L.
Order of Child Support (TMORS, ORS) Page 1 of 11

PF DR 01.0500 Mandatory (6/2008) - R C W 26.09.175; 26.26.132
si uku;s -7i a_#
II. Basis
2.1
Type of Proceeding
This order is entered under a petition for dissolution of marriage or domestic partnership, legal
separation, or declaration concerning validity:
[X]
decree of dissolution, legal separation or a declaration concerning validity.
[]
order for modification of child support.
[]
hearing for temporary child support.
[]
order of adjustment.
[]
order for modification of a custody decree or parenting plan.
[]
other:
2.2
Child Support Worksheet

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.
2.3
Other
III. Findings and Order

It Is Ordered:
3.1
3.2
Children for Whom Support is Required

Name (first/last)
Age
3 years
Person Paying Support (Obligor)

Name (first/last): Christopher Lee Harrison
Birth date: April 16th 1970
Service Address: (You may list an address that is not your residential address where you agree
to accept legal documents.)
No known address. Lives in the home he is working on for his employer. Residence changes with
the job.
The Obligor Parent M ust Im m ediately File With the Court and the
Washington State C hild Support Registry, an d Update as Necessary, the
Order of Child Support (TMORS, ORS) - Page 2 of 11
PF DR 01.0500 Mandatory (6/2008) - RC W 26.09.175; 26.26.132
Confidential Information Form R equired by R C W 26.23.050.
The Obligor Parent S hall Update the Inform ation R equired by Paragraph 3.2
Prom ptly A fter any Change in the Information. The D uty to Update the
Inform ation Continues as long as any Support D ebt Rem ains due U nder
This Order.
[]
[]
3.3
Monthly Net Income: $1.717.63_____________

The income of the obligor is imputed at $ 12.00
because:
[]
the obligors income is unknown.
[]
the obligor is voluntarily unemployed.
[]
the obligor is voluntarily underemployed.
[X]
other: The obligor states that his income is $12.00 per hour.
Person Receiving Support [Obligee]

Name (first/last): Jolene Marie Harrison
Birth date:
July 15, 1975
Service Address: 8418 184th St. E.
Bonney Lake, Wa. 98321
The Obligee M ust Im m ediately File With the Court and the W ashington
State Child Support R egistry an d Update as N ecessary the Confidential
Inform ation Form R equired by R C W 26.23.050.
The Obligee Shall Update the Inform ation R equired by Paragraph 3.3
Prom ptly A fter any Change in the Information. The D uty to Update the
Inform ation Continues as Long as any M onthly Support Rem ains Due or
any Unpaid Support D ebt Rem ains Due Under This Order.
[X]
[]
Monthly Net Income: $ 2.478.50______________

The income of the obligee is imputed at $ _______________ because:
[]
[]
[]
[]
the obligees income is unknown.

the obligee is voluntarily unemployed.
the obligee is voluntarily underemployed.
other:
The obligor may be able to seek reimbursement for day care or special child rearing expenses not
actually incurred. RCW 26.19.080.
PF DR 01.0500 Mandatory (672008) - RCW 26.09.175; 26.26.132
3.4
Service of Process
Service o f Process on the Obligor at the Address R equired b y Paragraph
3.2 o r any Updated Address, or on the Obiigee at the Address R equired by
Paragraph 3.3 o r any Updated Address, m ay Be A llow ed o r A ccepted as
A dequate in any Proceeding to Establish, Enforce o r M odify a Child
Support O rder Between the Parties by D elivery o f Written Notice to the
O bligor o r Obligee at the Last Address Provided.
3.5
Transfer Payment
The obligor parent shall pay the following amounts per month for the following children:
Name
Amount
_________________________________________________
_________________________________________________
_________________________________________________
Christopher Lee Harrison Jr._______________________
$283.88
______________
$_________________________
$_________________________
$_________________________
Total Monthly Transfer Amount
$283.88__________________
[]
The parents1 combined monthly net income exceeds $7,000 and the court sets child
support in excess of the advisory amount because:
[]
If one of the children changes age brackets, the child support shall be as follows:
[]
This is a downward modification that has caused an overpayment of $ ________

This amount shall be repaid or credited as follows:
[]
This is an upward modification that has caused an underpayment of $_________

This amount shall be paid as follows:
[]
Other:
The Obligor Parent's Privileges to Obtain o r M aintain a License, Certificate,

Registration, Permit, Approval, o r O ther Sim ilar D ocum ent Issued by a
Licensing Entity Evidencing Adm ission to o r Granting A uthority to Engage
in a Profession, Occupation, Business, Industry, Recreational Pursuit, o r
the Operation o f a M otor Vehicle m ay Be D enied o r m ay Be Suspended if
Order of Child Support (TMORS, ORS) - Page 4 o f 11
PF DR 01.0500 Mandatory (6/2008) - RCW 26.09.175; 26.26.132
the O bligor P arent is not in Com pliance With This Support O rder as
Provided in Chapter 74.20A R evised Code o f Washington.
3.6
Standard Calculation
$ 283.88
3.7
per month. (See Worksheet line 15.)
Reasons for Deviation From Standard Calculation

[X] The child support amount ordered in paragraph 3.5 does not deviate from the standard
calculation.
[ ] The child support amount ordered in paragraph 3.5 deviates from the standard calculation for
the following reasons:
[ ] Income of a new spouse or new domestic partner of the parent requesting a deviation for
other reasons;
[ ] Income of other adults in the household of the parent requesting a deviation for other
reasons;
[ ] Child support actually paid or received for other children from other relationships;
[ ] Gifts;
[ ] Prizes;
[ ] Possession of wealth;
[ ] Extraordinary income of a child;
[ ] Tax planning which results in greater benefit to the children;
[ ] A nonrecurring source of income;
[ ] Extraordinary debt not voluntarily incurred;
[ ] A significant disparity in the living costs of the parents due to conditions beyond their
control;
[ ] Special needs of disabled children;
[ ] Special medical, educational, or psychological needs of the children;
[ ] The child spends a significant amount of time with the parent who is obligated to make a
support transfer payment. The deviation does not result in insufficient funds in the
receiving parents household to meet the basic needs of the child. The child does not
receive public assistance;
[ ] Children from other relationships;
[ ] Costs incurred or anticipated to be incurred by the parents in compliance with courtordered reunification efforts or under a voluntary placement agreement with an agency
supervising the child;
[ ] The obligor has established that it is unjust or inappropriate to apply the presumptive
minimum payment of $25.00 per child.
[ ] Other:
The factual basis for these reasons is as follows:
[ ] Other:
Order o f Child Support (TMORS, ORS) - Page 5 of 11

3.8
Reasons why Request for Deviation Was Denied

[]
[X]
[]
3.9
Does not apply. A deviation was ordered.

A deviation was not requested.
The deviation sought by the [ ] obligor [ ] obligee was denied because:
[]
no good reason exists to justify deviation.
[]
other:
Starting Date and Day to Be Paid

Starting Date:
Day(s) of the month support is due:
3.10
Incremental Payments
[X]
[]
3.11
October 1.2008______
15th______________
Does not apply.

This is a modification of child support. Pursuant to RCW 26.09.170 (9)(a) and (c), the
obligation has been modified by more than 30 percent and the change would cause
significant hardship. The increase in the child support obligation set forth in Paragraph
3.5 shall be implemented in two equal increments, one at the time of this order and the
second on (date)_______________ six months from the entry of this order.
How Support Payments Shall Be Made

Select Enforcement and Collection, Payment Services Only, or Direct Payment:
[]
Enforcement and collection: The Division of Child Support (DCS) provides support
enforcement services for this case because: [ ] this is a public assistance case, [ ] this is
a case in which a parent has requested services from DCS, [ ] a parent has signed the
application for services from DCS on the last page of this support order. (Check all
that apply.) Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or
1-800-442-5437
[]
Payment services only: The Division of Child Support will process and keep a record of
all payments but will not take any collection action. Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or
1-800-442-5437

PP DR 01.0500 Mandatory (6/2008) - RCW 26.09.175; 26.26.132
[X]
Direct Payment: Support payments shall be made directly to:
Name__________ Jolene Harrison_______

Mailing Address: 8418 184th Ave. E
Bonney Lake, Wa 98391
A party required to make payments to the Washington State Support Registry will not receive
credit for a payment made to any other party or entity. The obligor parent shall keep the registry
informed whether he or she has access to health insurance coverage at reasonable cost and, if so,
to provide the health insurance policy information.
3.12
Wage Withholding Action

Withholding action may be taken against wages, earnings, assets, or benefits, and liens enforced
against real and personal property under the child support statutes of this or any other state,
without further notice to the obligor parent at any time after entry of this order unless an
alternative provision is made below:
[If the court orders immediate wage withholding in a case where Division of Child Support does
not provide support enforcement services, a mandatory wage assignment under Chapter 26.18
RCW must be entered and support payments must be made to the Support Registry.]
[]
Wage withholding, by notice of payroll deduction or other income withholding action

under Chapter 26.18 RCW or Chapter 74.20A RCW, without further notice to the
obligor, is delayed until a payment is past due, because:
[]
the parties have reached a written agreement that the court approves that
provides for an alternate arrangement.
[]
the Division of Child Support provides support enforcement services for this
case [see 3.11] and there is good cause [as stated below under "Good Cause"]
not to require immediate income withholding which is in the best interests of the
child and, in modification cases, previously ordered child support has been
timely paid.
[X]
the Division of Child Support does not provide support enforcement services for
this case [see 3.11] and there is good cause [as stated below under "Good
Cause"] not to require immediate income withholding.
Good Cause: Mother will attempt collection on her own.

19567
3.13
18 / 2 8 / 2 8 8 8
Termination of Support
Support shall be paid:
[]
[X]
[]
[]
[]
[]
3.14
Post Secondary Educational Support

[X]
[]
[]
[]
3.15
provided that this is a temporary order, until a subsequent child support order is entered
by this court.
until the child(ren) reach(es) the age of 18 or as long as the child(ren) remain(s) enrolled
in high school, whichever occurs last, except as otherwise provided below in Paragraph
3.14.
until the child(ren) reach(es) the age of 18, except as otherwise provided below in
Paragraph 3.14.
after the age of 18 for (name)_______________________________who is a dependent
adult child, until the child is capable of self-support and the necessity for support ceases.
until the obligation for post secondary support set forth in Paragraph 3.14 begins for the
child(ren).
Other:
The right to petition for post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3 .13.
The parents shall pay for the post secondary educational support of the child(ren). Post
secondary support provisions will be decided by agreement or by the court.
No post secondary educational support shall be required.
Other:
Payment for Expenses not Included in the Transfer Payment

[]
[X]
Does not apply because alt payments, except medical, are included in the transfer
payment.
The petitioner shall pay______ 59.1 % and the respondent _______ 40.9 % (each
parents proportional share of income from the Child Support Schedule Worksheet, line
6) of the following expenses incurred on behalf of the children listed in Paragraph 3.1:
[X]
day care.
[]
educationalexpenses.
[]
long distance transportation expenses.
[]
other:
Payments shall be made to [ ] the provider of the service [X] the parent receiving the
transfer payment.
[]
The obligor shall pay the following amounts each month the expense is incurred on
behalf of the children listed in Paragraph 3.1:
[]
day care: $ _______________ payable to the [ ] day care provider [ ] other

28836
[]
[]
[]
3.16
3.17
3.18
parent:
payable to the [ ] educational
educational expenses: $
provider [ ] other parent;
payable to the
long distance transportation: $
[ ] transportation provider [ ] other parent,
other:
Periodic Adjustment
fX]
[]
Does not apply.

Child support shall be adjusted periodically as follows:
[]
Other:
Income Tax Exemptions

[]
[X]
Does not apply.

Tax exemptions for the children shall be allocated as follows:
All childrens tax exemptions to go to the mother, (petitioner, obligee)
[]
[]
The parents shall sign the federal income tax dependency exemption waiver.
Other:
Medical Insurance for the Children Listed in Paragraph 3.1

Unless one or more of the alternatives below are checked, each parent shall maintain or
provide health insurance coverage if:
(a) Coverage that can be extended to cover the child(ren) is or becomes available to each parent
through employment or is union-related; and
(b) The cost of such coverage for the petitioner does not exceed $94.27___________ (25 percent
of petitioners basic child support obligation on Worksheet line 7), and the cost of such coverage
for the respondent does not exceed $65.24__________ (25 percent of respondents basic child
support obligation on Worksheet Line 7).
*
[ ] Alternative 1: The parent below shall maintain or provide health insurance coverage if
coverage that can be extended to cover the child(ren) is or becomes available to that parent
through employment or is union-related and the cost of such coverage does not exceed
$____________ (25 percent of that parent's basic child support obligation on Worksheet line 7).
[ ] petitioner
[ ] respondent
[ ] Alternative 2: The parent below shall maintain or provide health insurance coverage if
coverage that can be extended to cover the child(ren) is or becomes available to that parent
through employment or is union-related even if such coverage exceeds $_____________ (25
percent of that parent's basic child support obligation on Worksheet line 7).

[ ] petitioner
[] respondent
[ ] Alternative 3: The parent below is not obligated to provide health insurance coverage
because the other parent provides insurance coverage:
[ ] petitioner
[ ] respondent
The parents) shall maintain health insurance coverage, if available for the children listed in
paragraph 3.1, until further order of the court or until health insurance is no longer available
through the parents employer or union and no conversion privileges exist to continue coverage
following termination of employment.
A parent who is required under this order to provide health insurance coverage is liable for any
covered health care costs for which that parent receives direct payment from an insurer.
A parent who is required under this order to provide health insurance coverage shall provide
proof that such coverage is available or not available within 20 days of the entry of this order to
the physical custodian or the Washington State Support Registry if the parent has been notified
or ordered to make payments to the Washington State Support Registry.
If proof that health insurance coverage is available or not available is not provided within 20
days, the parent seeking enforcement or the Department of Social and Health Services may seek
direct enforcement of the coverage through the other parents employer or union without further
notice to the other parent as provided under Chapter 26.18 RCW.
3.19
Extraordinary Health Care Expenses

Unless specifically ordered otherwise, the person receiving support is responsible for
ordinary health care expenses of the children. However, both parents have an obligation
to pay their share of extraordinary health care expenses. Extraordinary health care
expenses mean those monthly medical expenses that exceed 5% of the basic support
obligation from the Child Support Schedule Worksheet, Line 5.
The petitioner shall pay_____ 59.1 % of extraordinary health care expenses (unless
stated otherwise, the petitioners proportional share of income from the Worksheet, line
6) and the respondent shall pay______40.9 % of extraordinary health care expenses
(unless stated otherwise, the respondents proportional share of income from the
Worksheet, line 6).
3.20
Back Child Support

[]
[X]
[]
No back child support is owed at this time.

Back child support that may be owed is not affected by this order.
The obligee parent is awarded a judgment against the obligor parent in the amount of
$ _________ _____ for back child support for the period from (date)_______________
to (date)__ ____________________.
[]
Other:

3.21
Back Interest
[]
[X]
[]
No back interest is owed at this time.

Back interest that may be owed is not affected by this order.
Presented by:
Approved for entry:

Notice of presentation waived:
ature of Partyi or Lawyer/WSBA No.

Print Name
[]
Court Commissioner
Print Name
I apply for full support enforcement services from the DSHSJ Division of Child Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if over
$500 is disbursed on a case, unless the fee is waived by DCS.)
Signature of Party
[]
Approval required in Public Assistance cases. The DSHS Division of Child Support received
notice required by RCW 26.23.130. This order has been reviewed and approved as to:
[]
[]
[]
[]
Current Child Support

Back Child Support
Medical Support
Other:
Deputy Prosecuting Attomey/WSBA No.

Order of Child Support (TMORS, ORS) - Page 11 o f 11
Washington State Child Support Schedule Worksheets

[X ] Proposed by [X ] Mother [ ] Father [ ] State of WA [ ] Other_________________ . {CSWP)
Or, [ ] Signed by the Judicial/Reviewing Officer. (CSW)
Mother
Father
Christopher Lee Harrison________
County
Pierce__________Superior Court/OAH Case No.
08-3-00821-4
Child Support Order Summary Report

A. The order [ ] does [X ] does not replace a prior court or administrative order.
B. The Standard Calculation listed on line 15e of the Worksheet for the paying parent is:
$283.88________________ t
C. The Transfer Amount ordered by the Court from the Order of Child Support
is: $ 283.88 _________________ to be paid by [ ] mother [X ] father.
D. The Court deviated (changed) from the Standard Calculation for the following reasons:
[ X] Does not apply
[ ] Nonrecurring income
[ ] Sources of income and tax planning
[ j Split custody
[ j Residential schedule (including shared custody)
[ j Children from other relationships for whom the parent owes support
[ j High debt not voluntarily incurred and high expenses for the child(ren)
[ l 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: [X ] All health care, day care and special child rearing expenses are included in the
worksheets in Part II.
Worksheets
Children and Ages:
Parti: Basic Child Support Obligation (See Instructions, Page 1)
1. Gross Monthly Income
a. Wages and Salaries
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e. Other Income
f. Total Gross Monthly Income
(add lines 1a through 1e)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2008 Page 1 of 5
Father
$2,080.00
Mother
$2,693.00
$
$
$
$
$
$
$
$
$2,080.00
$2,693.00
2. Monthly Deductions from Gross Income

a.
b.
c.
d.
e.
f.
g.
h.
Income Taxes (Federal and State)

FICA (Soc.Sec,+Medicare)/Self-Employment Taxes
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
Pension Plan Payments
Maintenance Paid
Normal Business Expenses
Total Deductions from Gross Income
{add lines 2a through 2g)
3. Monthly Net Income {line 1f minus 2h)

4. Combined Monthly Net Income
(add fathers and mothers monthly net incomes from line 3)
(If combined monthly net income is less than $600, skip to line 7.)
5. Basic Child Support Obligation (enter total amount in box -+)
Child #1
Child #3
Child #2
Child #4
6. Proportional Share of Income

(each parents net income from line 3 divided by line 4)
7. Each Parents Basic Child Support Obligation
(multiply each number on line 6 by line 5)
(If combined net monthly income on line 4 is less than $600,
enter each parents support obligation of $25 per child. Number
of children:
. Skip to line 15a and enter this amount.)
Father
$203.25
$159.12
Mother
$59.00
$151.00
$
$
$
$
$
$
$
$
$
$
$362.37
$1,717.63
$214.50
$2,478.50
ISpjj
4.50
-
||
$4,196.13
jf
' 3?-V
$638.00
Tt
.409
.591
$260.94
$377.06
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 3)
8. Health Care Expenses
a. Monthly Health Insurance Premiums Paid for Child(ren)
$88.00
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
_$
c. Total Monthly Health Care Expenses

(line 8a plus line 8b)
d. Combined Monthly Health Care Expenses
(add fathers and mothers totals from line 8c)
e. Maximum Ordinary Monthly Health Care
(multiply line 5 times .05)
f. Extraordinary Monthly Health Care Expenses
(line 8d minus line 8e., if u0 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)
$88.00
$
;j
$
' >r
s rs m
{ $88.00
k
*
l $31.90
IP-
>
}c:
$56.10
$
$
$
$
$
$
$
$
$
$
e. Total Day Care and Special Expenses

(add lines 9a through 9d)
$
10. Combined Monthly Total Day Care and Special Expenses (add i; | p
fathers and mothers day care and special expenses from line 9e)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2008 Page 2 o f 5
'
Bui
<OC
L *7
^ U I
11. Total Extraordinary Health Care, Day Care, and Special

Expenses (line 8f plus line 10)
...
4i V a J '/ 9* *G / 9t 4 V lJ ft if O
\J
$56.10
Mother
Father
12. Each Parents Obligation for Extraordinary Health Care, Day
Care, and Special Expenses (multiply each number on line 6 by
line 11)
Part III: Gross Child Support O bligation
13. Gross Child Support Obligation (line 7 plus line 12)
Part IV: Child Support Credits (See Instructions, Page 3)
14. Child Support Credits
a. Monthly Health Care Expenses Credit
b. Day Care and Special Expenses Credit
c. Other Ordinary Expenses Credit (describe)
d. Total Support Credits (add lines 14a through 14c)
$22.94
$33.16
$283.88
$410.22
$
$
$88.00
$88.00
Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 4)

15. Standard Calculation
a. Amount from line 7 if line 4 is below $600. Skip to Part VI.
$
$
b. Line 13 minus line 14d, if line 4 is over $600 (see below if appl.)
$283.88
$322.22
Limitation standards adjustments

c. Amount on line 15b adjusted to meet 45% net income limitation
d. Amount on line 15b adjusted to meet need standard limitation
e. Enter the lowest amount of lines 15b, 15c or 15d
$283.88
$322..22
Part VI: Additional Factors fo r Consideration (See Instructions, Page 4)

16. Household Assets
Father's
Household
(List the estimated present value of all major household assets.)
a. Real Estate
$
b. Stocks and Bonds
c. Vehicles
Mothers
Household
$
$
d. Boats
e. Pensions/IRAs/Bank Accounts
f. Cash
g. Insurance Plans
h. Other (describe)
$
$
$
$
$
$
17. Household Debt

(List liens against household assets, extraordinary debt.)
HSCSS-Wor/cshee/s - Mandatory (CSW/CSWP) 6/2008 Page 3 o f 5
7i 4 QL MQ J O^ Ot t
<OC7
1Q
X^V
M
J
X1
/'
L
*uv
>
u
Mothers
Household
Father's
Household
(Household Debt continued)
ku*
$
$
$
$
$
$
18. Other Household Income

a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name
Name
b. Income Of Other Adults In Household
Name
Name
c. Income Of Children (if considered extraordinary)
Name
Name
d. Income From Child Support
Name
Name
e. Income From Assistance Programs
Proa ram
Proa ram
f. Other Income (describe)
19. Non-Recurring Income (describe)
20. Child Support Paid For Other Children

Name/age:
Name/age:
Name/age:
21. Other Children Living In Each Household

(First names and ages)
Tyler -1 4
Hannah -11
Alyssa -1 5
WSCSS-Wor/rsheefs - Mandatory (CSW/CSWP) 6/2008 Page 4 of 5
OGtG*GO
L
iU
U
|J
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2008 Page 5 o f 5
4 q c c *7 ^ a
J
_
_
u
/? s a o
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L
W
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i u'
LiUVU

County of Pierce
No. 08-3-00821-4
Petitioner,
and
Findings of Fact and

Conclusions of Law
(Marriage)
(FNFCL)
Respondent.
I. Basis for Findings

The findings are based on:
m
[]
Ei
agreement.
an order of default signed by the court
trial. The following people attended:
[]
[]
[]
[]
[]
Petitioner.
Petitioners Lawyer.
Respondent.
Respondents Lawyer.
Other:
II. Findings of Fact

Upon the basis of the court records, the court F in ds:
2.1
Residency of Petitioner
The Petitioner
[X]
[]
[]
is a resident of the state of Washington.

is not a resident of the state of Washington.
is a member of the armed forces and has been stationed in this state for at least 90 days.
Fndngs o f Fact and Cone! of Law (FNFCL) - Page 1 o f 11

WPF DR 04.0300 Mandatory (6/2008) - CR 52; RCW 26.09.030;. 070(3)
t-tJV
>

sacre *
7 *a
2.2
" a
y~a ho -sesac
Notice to the Respondent

The respondent
[X]
[]
2.3
appeared, responded or joined in the petition.

was served in the following manner:
Basis of Personal Jurisdiction Over the Respondent

[]
[X]
There are no facts to establish personal jurisdiction over the respondent.

The facts below establish personal jurisdiction over the respondent.
[X]
[X]
[X]
[]
2.4
The respondent is currently residing in Washington.

The parties lived in Washington during their marriage and the petitioner continues
to reside, or be a member of the armed forces stationed, in this state.
The parties may have conceived a child while within Washington.
Other:

The parties were married on (date)
06-05-04__________________________________ at
(city and state only)
Bonnev Lake , Washington_____
2.5
Status of the Parties

Husband and wife separated on (date)
2.6
August 15. 2007__________________________.
Status of Marriage
[]
[]
[X]
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.
The petitioner wishes to be legally separated.
The petitioner is petitioning for a declaration concerning the invalidity of the marriage.
The court finds the following facts concerning the validity of the marriage:
The Respondent, Christopher Lee Harrison, was already married to Janelle Alaine
Harrison at the time he married the petitioner, Jolene Marie Flohr (Harrison).
Exhibits Attached:
Exhibit 1: Joinder signed on 10-04-08 by the respondent, Christopher Lee
Harrison, in a petition for dissolution by Janelle Alaine Harrison.
Exhibit 2: Acceptance of Service signed on 10-04-08 by the respondent,
Christopher Lee Harrison. Petitioner is Janelle Alaine Harrison.
Exhibit 3: Declaration of Janelle Alaine Harrison by e-mail, attesting to the fact
that she is still married to Christopher Lee Harrison and is in the
process of filing for divorce. Original Declaration sent by mail
follows the e-mail.
Fndngs of Fact and Concl of Law (FNFCL) - Page 2 o f 11

WPF DR 04.0300 Mandatory (6/2008) - CR 52; R C W 26.09.030; .070(3)
The Petitioner, in this case #08-3-00821-4, Jolene Marie Harrison, has located the
marriage license of Christopher Lee Harrison to Janelle Alaine Harrison in Coeur
dAlene, Idaho, on October 2, 2001. The certified marriage license has been ordered by
mail.
Janelle Alaine Harrison
303 E. 7th Avenue
Ritzville, Washington 99169
Phone# 509-659-1848
509-768-5801
2.7
Separation Contract or Prenuptial Agreement

[X]
[]
There is no written separation contract or prenuptial agreement.

A written separation contract or prenuptial agreement was executed on
(date)___________________________________ and is incorporated herein.
[]
[]
[]
2.8
Other:
Community Property
[]
[]
[]
[]
[X]
2.9
The separation contract or prenuptial agreement should be approved.

The separation contract or prenuptial agreement should not be approved because:
The parties do not have real or personal community property.

The parties have real or personal community property as set forth in Exhibit____ . This
exhibit is attached or filed and incorporated by reference as part of these findings.
The parties have real or personal community property as set forth in the separation
contract or prenuptial agreement referenced above.
The parties have the following real or personal community property:
Other: The parties divided their personal belongings and household items by agreement at
the time o f separation on August 15, 2007.
Separate Property
[]
[]
The husband has no real or personal separate property.

The wife has no real or personal separate property.
Fndngs o f Fact and Cond of Law (FNFCL) - Page 3 of 11

[]
[]
[]
2.10
The parties have separate property as set forth in the separation contract or prenuptial
agreement referenced above.
The husband has real or personal separate property as set forth in Exhibit____. This
The wife has real or personal separate property as set forth in Exhibit_____. This exhibit
is attached or filed and incorporated by reference as part of these findings.
[]
The husband has the following real or personal separate property:
[]
The wife has the following real or personal separate property:
[X]
Other: The husband and wife each took their own personal separate property by
agreement at the time of separation on August 15, 2007.
Community Liabilities
[X]
[]
[]
[]
There are no known community liabilities.

The parties have incurred community liabilities as set forth in Exhibit_____ . This
The parties have community liabilities as set forth in the separation contract or prenuptial
The parties have incurred the following community liabilities:
Creditor
[]
Other:
Fndngs of Fact and ConeI of Law (FNFCL) - Page 4 of 11

Amount
2.11
Separate Liabilities
[]
[]
[]
[]
[]
[X]
The husband has no known separate liabilities.

The wife has no known separate liabilities.
The husband has incurred separate liabilities as set forth in Exhibit____ . This exhibit is
attached or filed and incorporated by reference as part of these findings.
The parties have separate liabilities as set forth in the separation contract or prenuptial
The wife has incurred separate liabilities as set forth in Exhibit____ . This exhibit is
attached or filed and incorporated by reference as part of these findings.
The husband has incurred the following separate liabilities:
Creditor
Church Chiropractic Clinic
IRS
(Chris-2006 unemployment compensation)
Northland Group Inc/ Capital One (Chris)
Tribute (Chris-credit card)
Aspen (Chris-credit card)
Mt. Rainier Emera. Phvs. fAlvssa-hospital)
MBCHA-CHA (Katie-Phvsician billing)
PSC-(Puvallup Municipal Court) (Chris)
Multi Care (Chris)
Jessv A. Ana, M.D. (Chris)
Good Samaritan Medicine O f Sumner (Chris)
Washington Collectors Tri-Cities (Chris)
Park Dansan (Chris)
Verizon (Chris)
At&t (Chris)
People First Recovery (Chris)
Cavalry Portfolio Services. LLC (Chris)
All Personal Medical Bills
[X]
Amount
$40.00
$1810.80
$854.77
$154.18
$267.44
$207.00
$464.16
$1882.89
$110.00
$120.00
$88.00
$2941.31
$304.28
$1200.00
$400.00
$859.24
$417.14
The wife has incurred the following separate liabilities:

Creditor
Boeina Employees Credit Union (Jolene-Mini Van)

Jessv A. Ana. M.D. (Jolene)
Anzi Dental Center (Jolene-root canal)
RMA (Jolene)
Vons Employees Federal Credit Union Visa
All Personal Medical Bills
Fndngs of Fact and Cone/ of Law (FNFCL) - Page 5 of 11

Amount
$5747.08
$30.00
$197.20
$134.68
$1800.00
[]
2.12
Maintenance
[X]
[]
2.13
[]
Maintenance was not requested.

Maintenance shall be paid as set forth in the separation contract or prenuptial agreement
referenced above.
Maintenance should not be ordered because:
[]
Maintenance should be ordered because:
[]
Other:

[X]
[]
[]
2.14
Does not apply.

A continuing restraining order against the [ ] husband [ ] wife [ ] both parties is necessary
because:
Other:
Protection Order
[X]
[]
2.15
Other:
Does not apply.

The [ ] domestic violence [ ] antiharassment Order for Protection signed by the court on
this date or dated______________________ , is approved and incorporated as part of
these findings.
Fees and Costs

[X]
[]
[]
[]
There is no award of fees or costs.

Attorney fees, other professional fees and costs shall be paid as set forth in the separation
The [ ] husband [ ] wife has the need for the payment of fees and costs and the other
spouse has the ability to pay these fees and costs. The [ ] husband [ ] wife has incurred
reasonable attorney fees and costs in the amount of $____________________ .
Other:
Fndngs o f Fact and Concl o f Law (FNFCL) - Page 6 o f 11

2.16
2.17
Pregnancy
[X]
[]

The wife is pregnant. Note: Under RCW 26.26.116, the husband is the presumed
[]
Other:
Dependent Children
[]
[X]
The parties have no dependent children of this marriage.

The children listed below are dependent upon either or both spouses.
Name of
Child
Christopher Jr.
Hannah Flohr
Kathrina Harrison
Tvler Flohr
Alvssa Harrison
[]
2.18
11 vears
13 vears
14 vears
15 vears
M others
Name
Jolene Harrison
Jolene Harrison
Laura Liles
Jolene Harrison
Laura Liles
Fathers
Name
Michael Flohr
Michael Flohr
Other:

[]
[]
[X]

This court does not have jurisdiction over the children.
This court has jurisdiction over the children for the reasons set forth below.
[]
This court has exclusive continuing jurisdiction. The court has previously made
a child custody, parenting plan, residential schedule or visitation determination in
this matter and retains jurisdiction under RCW 26.27.211.
[X]

[X]
[]
the children lived in Washington with a parent or a person acting as a

parent for at least six consecutive months immediately preceding the
commencement of this proceeding.
the children are less than six months old and have lived in Washington
with a parent or a person acting as parent since birth.
Fndngs of Fact and Concl o f Law (FNFCL) - Page 7 of 11

[]
[]
[]
The children and the parents or the children and at least one parent or person acting
as a parent, have significant connection with the state other than mere physical
presence; and substantial evidence is available in this state concerning the childrens
care, protection, training and personal relationships; and
[]
[]
[]
2.19

Washington was the home state of the children within six months before
the commencement of this proceeding and the children are absent from
the state but a parent or person acting as a parent continued to live in this
state.

the childrens home state has declined to exercise jurisdiction on the
ground that this state is the more appropriate forum under RCW 6.27.261
or .271.
[]
All courts in the childrens home state have declined to exercise jurisdiction on the
ground that a court of this state is the more appropriate forum to determine the
custody of the children under RCW 26.27.261 or .271.
[X]
[]
This court has temporary emergency jurisdiction over this proceeding because
the children are present in this state and the children have been abandoned or it is
necessary in an emergency to protect the children because the children, or a
sibling or parent of the children is subjected to or threatened with abuse.
RCW 26.27.231.
[]
There is a previous custody determination that is entitled to be enforced

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

under this chapter and a child custody proceeding has not been
commenced in a court of a state having jurisdiction under RCW
26.27.201 through 26.27.221. If an action is not filed in (potential home
state)_____________________ by the time the child has been in
Washington for six months, (date)__________________________, then
Washington's jurisdiction will be final and continuing.
Other:
Parenting Plan
[]
Does not apply.
Fndngs of Fact and Concl of Law (FNFCL) - Page 8 of 11

WPF DR 04.0300 Mandatory (6/2008) - CR 52; RCW 26.09.030; .070(3)
[X]
The parenting plan signed by the court on this date or dated_________

is approved and incorporated as part of these findings.
[X]
[]
2.20
Child Support
[]
[X]
[]
2.21
This parenting plan is the result of an agreement of the parties.

Other:
Does not apply.

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 or dated_________________________________, and the child support
worksheet, which has been approved by the court, are incorporated by reference in these
findings.
Other:
Other
III.
Conclusions of Law
The court makes the following conclusions of law from the foregoing findings of fact:
3.1
Jurisdiction
[X]
[]
3.2
The court has jurisdiction to enter a decree in this matter.

Other:
Granting a Decree
[X]
[]
The parties should begranted a decree.

Other:
Fndngs o f Fact and Concl of Law (FNFCL) - Page 9 o f 11

WPF DR 04.0300 Mandatory (6/2008) - CR 52; RCW 26.09.030; .070(3)
jQct-7
3.3
Pregnancy
[X]
[]
3.4
18/29/2SSS
Does not apply.

The wife is pregnant. Any challenge to the husbands presumed paternity shall be
initiated by: 1) signing and filing a valid denial of paternity and a valid
acknowledgement of paternity under RCW 26.26.300 through 26.26.375; or, 2) a
proceeding to determine the parentage of the unborn child under RCW 26.26.500 through
26.26.625.
Disposition
The court should determine the marital status of the parties, make provision for a parenting plan
for any minor children 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 children 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.
3.5

[X]
[]
3.6
Does not apply.

A continuing restraining order should be entered.
Protection Order
[X]
[]
Does not apply.

A [ ] domestic violence [ ] anti harassment Order for Protection should be entered.
Fndngs o f Fact and Concl o f Law (FNFCL) - Page 10 of 11

2 9 IS"1
3.7
Attorney Fees and Costs

[X]
[]
Does not apply.

Attorney fees, other professional fees and costs should be paid.
filed
IN OPEN COURT
o c r | 7 2000
3.8
Other
.PIERCE C0OMTY, Clerk

IEPUTY
Dated:
October 17. 2008
m issio ner
Presented by:
H. Edward Haarmann
Approved for entry:
Court Commissioner
flA, j4 a n n J U k n ^ >

Print or Type Name
________________
Print or Type Name
10-15-2008
Date
Fndngs of Fact and ConeI of Law (FNFCL) - Page 11 of 11

Date

County of
In re:
No.

Petitioner,
and
x k M
Joinder
(JN)

Respondent.
1.
Joinder
I have read the petition and join in it. I understand that by joining in the petition, a decree or
judgment and order may be entered in accordance with the relief requested in the petition, unless
prior to the entry of the decree or judgment and order a response is filed and served.
2.

[X]
[]
I demand notice of all further proceedings in this matter. Further notice should be sent to
the following service address: [You may list an address that is not your residential
address where you agree to accept legal documents.]
Any time this address changes while this action is pending, you must notify the opposing
parties in writing and file an updated Confidential Information Form (WPF DRPSCU
3.
Other
Dated:
/O -i-Z o o Y
Print or Type Name

Joinder (JN) - Page 1 of 1
WPF DRPSCU 01.0330 (6/2006)

County of
In re:
No.
Petitioner,
x h i h i f
<2-
(ACSR)
and
Respondent.
1.
Christopher Lee H a rriso n ______________ [Name] accepts service of:
[X] the summons and petition in this action.
[ ] a proposed order of child support.
[ ] proposed Child Support Worksheets.
[X] Findings of Fact and Conclusions of Law
2.
Consent to Personal Jurisdiction
3.
[X]Does not apply.

Other
Dated:
/ & ' V~ 3
[ ] a proposed parenting plan.

[ ] a financial declaration.
[X] Decree of Dissolution
[X] Confidential Information
[X] Joinder
Signature of^Party ortaw yer /WSBA No. Accepting Service
f'J>h sfop/y#r ['ls. e.
Print or Type Name
Notice to party: You may list an address that is not your

residential address where you agree to accept legal documents.
Any time this address changes while this action is pending,
you must notify the opposing parties in writing and file an
updated Confidential Information Form (WPF DRPSCU
[Address]
Acceptance of Service (ACSR) - Page 1 of 1

WPF DRPSCU 01.0310 (6/2006)
Truman & Jeanette Jepson <tandjjepson@gmail.com>

byG o o g le
8 ETA
declaration
1 message*I
Janelle Harrison <janelle003@ritzville.com>
Fri, Oct 3, 2008 at 4:28 PM
Reply-To: Janelle Harrison <janeile003@ritzville.com>

To: tandjjepson@gmail.com
To whom it may Concern:
My name is Janelle Alaine Harrison, the wife of Christopher Lee Harrison, we were married on October 2, 2001 in
Coeur d' Alene, Idaho.
We were separated on September 3, 2003, when he and his two daughters Alyssa Rae and Kathrina Jean moved to
Warden and later to Tacoma,
As of this date we are still married, but I am in the process of filing for a divorce.
I declare under penalty and perjury that the forgoing information is true and correct.
Janelle A Harrison
//jah
^
QCw
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7
AJ
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C iO
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#w
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1J\J-U

County of PIERCE
In re the marriage of:
-3
No. 08-00821-4
Petitioner(s),
And
Declaration of
Janelle Harrison

Respondent(s).
This declaration is made by:

Name:
Age:
Janelle Harrison
________________________________________
Relationship to the parties in this action: Married to Christopher Harrison
Declare:
That 1 am Janelle Harrison. I married Christopher Lee Harrison on October 2. 2001. He left our home
with his two girls. Alvssa and Katie. September 3. 2003. We have never been divorced but 1 am in the
process of filing for divorce at this time.______________________________________________________
I declare under penalty of perjury under the laws of the state o f Washington that the foregoing is true and
correct.
Signed at
_________ , [City] l
Signature of Declarant
Daplhration (DCLR) - Page 1 o f_

WPRJ)RPSCU 01.0100 (6/2006)
_ [State] on
o \\o _ p \
Print or Type Name
[Date].
4
-.UA
U
1 OTl 7
OB- 3-00821 -4
30750661
DC1NMG
--v..'' tiW
1 0 / 7 0 / 7 0 1 1 0
10-20-08

County of Pierce
No. 08-3-00821-4
Petitioner,
and
Respondent.
[]
[]
Decree of Dissolution (DCD)

Decree of Legal Separation
(DCLGSP)
[X ] Declaration Concerning
Validity (DCINMG)
(Marriage)
[]
[]
Clerks action required

Law Enforcement Notification, H 3.8
I. Judgment/Order Summaries
1.1 Restraining Order Summary:
[X ] Does not apply. [ ] Restraining Order Summary is set forth below:
Name of person(s) restrained:_____________________________________________. Name of person(s)
protected:________________________________________________ . See paragraph 3.8.
Violation of a Restraining Order in Paragraph 3.8 Below With Actual Knowledge of its
Terms is a Criminal Offense Under Chapter 26.50 RCW and Will Subject the Violator to
Arrest. RCW 26.09.050._______________________________________________________
1.2 Real Property Judgment Summary:
[X ] Does not apply. [ ] Real Property Judgment Summary is set forth below;
1.3 Money Judgment Summary:

[X ]Does not apply.
[]
Judgment Summary is set forth below.
A. Judgment creditor
__________________
Decree (DCD) (DCLGSP) (DCINMG) - Page 1 of 8
WPF DR 04.0400 Mandatory (6/2008) - R C W 26.09.030; .040; .070 (3)
X J.\J
7SS 4 4 Q
B. Judgment debtor
C. Principal judgment amount

D. Interest to date of judgment
E. Attorney fees
F. Costs
G. Other recovery amount
H. Principal judgment shall bear interest at
% per annum
I. Attorney fees, costs and other recovery amounts shall bear interest at
J. Attorney for judgment creditor
K. Attorney for judgment debtor
L. Other:
$
$
$
$
$
% per annum
End o f Summaries
II. Basis
Findings of Fact and Conclusions of Law have been entered in this case.
III. Decree
It is Decreed th a t:
3.1
Status of the Marriage

[]
[]
[X ]
[]
3.2
The marriage of the parties is dissolved.

The husband and wife are legally separated.
The marriage of the parties is invalid.
The marriage of the parties is valid.
Property to be Awarded the Husband

[]
[]
[]
The husband is awarded as his separate property the property set forth in Exhibit_____.
This exhibit is attached or filed and incorporated by reference as part o f this decree.
The husband is awarded as his separate property the property set forth in the separation
contract or prenuptial agreement executed by the parties on (date)___________________ .
The separation contract or prenuptial agreement is incorporated by reference as part of this
Decree. The prenuptial agreement or, pursuant to RCW 26.09.070(5), the separation
contract [ ] is [ ] is not filed with the court.
The husband is awarded as his separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):

[X]
3.3
Property to be Awarded to the Wife

[]
[]
[]
[X ]
3.4
Other: Personal items and household properties as mutually decided upon at the time of
separation, August 15,2007.
The wife is awarded as her separate property the property set forth in Exhibit_____. This
exhibit is attached or filed and incorporated by reference as part of this decree.
The wife is awarded as her separate property the property set forth in the separation
The wife is awarded as her separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):
Other: Personal items and household properties as mutually decided upon at the time of
separation, August 15, 2007.
Liabilities to be Paid by the Husband

[]
[]
[]
[X ]
Does not apply.

The husband shall pay the community or separate liabilities set forth in Exhibit_____ .
This exhibit is attached or filed and incorporated by reference as part of this decree.
The husband shall pay the community or separate liabilities as set forth in the separation
The husband shall pay the following community or separate liabilities:
Creditor
M t . Rainier E m e r g . P h y s , (Alyssa-hospital)
IRS
(Chris-2006 unemployment compensation)
MBCHA -CHA
(Katie-Physician billing)
Northland Group Inc/ Capital One (Chris)
P S C - (Puyallup Municipal Court) (Chris)
Cavalry Portfolio Services, LLC (Chris)
MultiCare (Chris)
Jessy A. Ang, M.D.
(Chris)
Good Samaritan Medicine Of Sumner (Chris)
Decree (DCD) (DCLGSP) (DCINMG) - Page 3 o f 8
WPF DR 04.0400 Mandatory (6/2008) - RCW 26.09.030; .040; .070 (3)
Amount
$207.00
$40.10
$1810.80
$464.16
$854.77
$1882.89
$417.14
$110.00
$120.00
$88.00
Aspen (Chris-credit card)

Tribute (Chris-credit card)
People First Recovery (Chris)
Washington Collectors Tri-Cities
Park Dansan (Chris)
Verizon (Chris-Cell Phone)
At&t (Chris-Cell Phone)
[]
(Chris)
$267.44
$154.18
$859.24
$2941.31
$304.28
$1200.00
$400.00
Other:
Unless otherwise provided herein, the husband shall pay all liabilities incurred by him since the date
of separation.
3.5
Liabilities to be Paid by the Wife

[]
[]
[]
[X ]
Does not apply.

The wife shall pay the community or separate liabilities set forth in Exhibit_____. This
exhibit is attached or filed and incorporated by reference as part of this decree.
The wife shall pay the community or separate liabilities as set forth in the separation
The wife shall pay the following community or separate liabilities:
Creditor
Amount
Boeing Employees Credit Union (MiniVan-Jolene)$5747.08

$197.20
Anzi Dental Center (Jolene-root canal)
$40.00
$30.00
Jessy A. Anq, M.D.
(Jolene)
$134.68
RMA (Jolene)
[]
Other:
Unless otherwise provided herein, the wife shall pay all liabilities incurred by her since the date of
separation.
3.6
Hold Harmless Provision

[X ]
Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable attorney's fees and
costs incurred in defending against any attempts to collect an obligation of the other party.
Decree (DCD) (DCLGSP) (DCINMG) - Page 4 o f 8

3.7
Maintenance
[X]
[]
[]
[]
Does not apply.

The [ ] husband [ ] wife shall pay maintenance as set forth in Exhibit_____. This exhibit
is attached or filed and incorporated by reference as part of this decree.
Maintenance shall be paid as set forth in the separation contract or prenuptial agreement
referenced above.
The [ ] husband [ ] wife shall pay $ _______________ maintenance. Maintenance shall be
paid [ ] weekly [ ] semi-monthly [ ] monthly.
The first maintenance payment shall be due on (date)____________________ .
The obligation to pay future maintenance is terminated upon the death of either party or the
remarriage of the party receiving maintenance unless otherwise specified below:
Payments shall be made:

[]
[]
[]
[]
[]
[]
3.8
directly to the other spouse.

to the Washington State Child Support Registry (only available if child support is
ordered).
to the clerk of this court as trustee for remittance to the other spouse (only
available if there are no dependent children).
If a maintenance payment is more than 15 days past due and the total of such past due
payments is equal to or greater than $100, or if the obligor requests a withdrawal of
accumulated contributions from the Department of Retirement Systems, the obligee may
seek a mandatory benefits assignment order under Chapter 41.50 RCW without prior notice
to the obligor.
The Department of Retirement Systems may make a direct payment of all or part of a
withdrawal of accumulated contributions pursuant to RCW 41.50.550(3).
Other:

[X]
[]
Does not apply.

A continuing restraining order is entered as follows:
[]
[]
_LL_
The [ ] husband [ ] wife is restrained and enjoined from disturbing the peace of
the other party.
The [ ] husband [ ] wife is restrained and enjoined from going onto the grounds
of or entering the home, work place or school of the other party, or the day
care or school of the following named children:
The 1"] husband [ 1 wife is restrained and enjoined from knowingly coming

within or knowingly remaining within (distance)________________ of the

home, work place or school of the other party, or the day care or school of
these children:________________________________________________ .
other:
[]
[]
(Name)__________________________is restrained and enjoined from

molesting, assaulting, harassing, or stalking (name)____________________ .
(The following firearm restrictions apply if this box is checked: Effective
immediately and continuing as long as this continuing restraining order is in
effect, the restrained person may not possess a firearm or ammunition. 18
U.S.C. 922(g)(8). A violation of this federal firearms law carries a
maximum possible penalty of 10 years in prison and a $250,000 fine. An
exception exists for law enforcement officers and military personnel when
carrying department/govemment-issue firearms. 18 U.S.C. 925(a)( 1).)
Other:
Violation of a Restraining Order in Paragraph 3.8 With Actual Knowledge of its Terms
Is a Criminal Offense Under Chapter 26.50 RCW and Will Subject the Violator to Arrest
RCW 26.09.060.
[]
Clerks Action. The clerk of the court shall forward a copy of this order, on or
before the next judicial day, to: _____________________________________ law
enforcement agency which shall enter this order into any computer-based criminal
intelligence system available in this state used by law enforcement agencies to list
outstanding warrants. ( A l a w e n f o r c e m e n t i n f o r m a t i o n s h e e t m u s t b e c o m p l e t e d
b y t h e p a r t y o r t h e p a r t y s a t t o r n e y a n d p r o v i d e d w i t h t h i s o r d e r b e f o r e t h i s
o r d e r w ill b e e n te re d in t o th e la w e n f o r c e m e n t c o m p u t e r s y s t e m .)
Service
[]
[]
The restrained party or attorney appeared in court or signed this order; service of this
order is not required.
The restrained party or attorney did not appear in court; service of this order is required.
The protected party must arrange for service of this order on the restrained party. File
the original Return of Service with the clerk and provide a copy to the law enforcement
agency listed above.
Expiration
This restraining order expires on: (month/day/year)_____ ________________.
This restraining order supersedes all previous temporary restraining orders in this cause
number.
[]
Any temporary restraining order signed by the court in this cause number is terminated.
Clerkfs Action. The clerk of the court shall forward a copy of this order, on or
before the next judicial day, to: ______________________________ law enforcement
agency where Petitioner resides which shall enter this order into any computer-based
criminal intelligence system available in this state used by law enforcement agencies to
list outstanding warrants.
Full Faith and Credit

Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of Columbia,
Puerto Rico, any United States territory, and any tribal land within the United States
shall accord full faith and credit to the order.
3.9
Protection Order
[X ]
[]
3.10

[]
[X]
3.11
Does not apply.

Child support shall be paid in accordance with the Order of Child Support signed by the
court on this date or dated________________________ . This order is incorporated as part
of this decree.
Attorney Fees, Other Professional Fees and Costs

[X ]
[]
[]
3.14
Does not apply.

The parties shall comply with the Parenting Plan signed by the court on this date
or dated____________________________ . The Parenting Plan signed by the court is
approved and incorporated as part of this decree. The Parenting Plan is Agreed upon.
Child Support
[]
[X ]
3.13

The court has jurisdiction over the children as set forth in the Findings of Fact and
Conclusions of Law.
Parenting Plan
[]
K]
3.12
Does not apply.

The parties shall comply with the [ ] domestic violence [ ] antiharassment Order for
Protection signed by the court on this date or dated _____________________________ ,
in this cause number. The Order for Protection signed by the court is approved and
incorporated as part of this decree.
Does not apply.

Attorney fees, other professional fees and costs shall be paid as set forth in the separation
Attorney fees, other professional fees and costs shall be paid as follows:
Name Changes

[X]
[]
[]
3.15
Does not apply.

The wife's name shall be changed to
(first, middle, last name)
The husband's name shall be changed to
(first, middle, last name)
Other
Dated:_____ October 17. 2008________________
Petitioner or petitioners lawyer:

A signature below is actual notice of this order.
[X ] Presented by:
[ ] Approved for entry:
[ ] Notice for presentation waived:
A signature below is actual notice of this order.

[ ] Presented by:
[X ] Approved for entry:
[X ] Notice for presentation waived:
IM
k^
rV\ - jA x n n X o jr y ^
/Signature of Petitioner or Lawyer/WSBA No.
Signature of Respondent or Lawyer/WSBA No.
JoIftngL. nn Harrison
Print or Type Name
toh<rh8
Date
Print or Type Name

Date
E-FILED
September 09 2009 4:10 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

IN AND FO R PIER C E COUNTY

Petitioner(s),
NO. 0 8 - 3 - 0 0 8 2 1 - 4
vs.
N O T E F O R C O M M ISSIO N E R 'S C A L E N D A R

Respondent(s)
T O T H E C L E R K O F T H E S U P E R IO R C O U R T A N D T O :
N AMEC H R IST O PH E R L E E H A R R IS O N
A D D RESS- 12107 209T H A V E. CT. E
' B O N N E Y LA K E , W A 98391
PH O N E: (253) 347-2028
R espondent
Please take notice that an issue o f law in this case w ill b e h eard on the date b elow and the clerk is directed to note this
issue on the appropriate calendar:
C A L E N D A R D A T E W ednesday - O ctober 21, 2009 at 9:30 A M
N ature o f Case: R E L O C A T E
SELECT ONE BOX BELO W
M (M O ) Show C ause/Fam ily Law , C onfirm ation R eq u ired............................................................ (9:30 M on.- Thurs.)
(Y Y )
(OE)
(U D )
(G D )
(D D )
(FC)
PA R T Y SE T T IN G H E A R IN G M U ST C O N FIR M B Y C A L L IN G (253)798-6697 B Y N O O N , T W O (2)

C O U R T /W O R K IN G D A Y S PR IO R TO H E A R IN G O R H E A R IN G W IL L B E C A N C ELLED
A doption, No C onfirm ation R equired ........................................................................................................... (9:30 Fri.)
Supplem ental Proceedings, No C onfirm ation R eq u ired ........................................................(1:30 M on.- Fri.)
U nlaw ful D etainer, No C onfirm ation R eq u ired ...........................................................................(1:30 M on.- Fri.)
Probate/G dnshp/M nr Settlem ent, No C onfirm ation R eq u ired ............................................(1:30 M on.- Fri.)
U ncontested D issolutions, No C onfirm ation R eq u ired................................. w /A ttorneys (3:00M on.- Fri.)
Paternity, No C onfirm ation R equired ....................................................................... (1:30 M on., Tues. & Thur.)
I hereby certify all supporting docum ents in accordance w ith P C L R 0.4 (a) (1) (C) have b e e n filed o r w ill b e filed
today w ith the C lerk of the C ourt.
D ated: Septem ber 09, 2009_______________
N A M E:
JO L E N E M A R IE H A R R ISO N
A D D RESS: 12107 209T H A V E CT E
B O N N E Y LA K E , W A 98391
Signed:/s/ JO L E N E M A R IE H A R R ISO N
PH O N E: (253) 862-2933
P etitioner
T H E A B O V E IN F O R M A T IO N M U S T B E C O M P L E T E D A N D S IG N E D
page 1 o f 1
431?
9 / 1 4 -^ 2 8 8 9
1 & 8191
FI LED
IN C O U N T Y C L E R K S O F F I C E
0B-3-00B21-4
32813983
PPP
09-11-09
am
SEP - 9 2009

KEVIN STOCK, County Cio'k
B Y _____________________ DEPUTY

County of Pierce
Jolene Marie Charlton
Petitioner,
and
Christopher Lee Harrison_______Respondent.
Parenting Plan
[X] Proposed (PPP)
[ ] Temporary (PPT)

[]
[]
[]
[X]
the fInal parenting plan signed by the court pursuant to a decree of dissolution, legal
dated_________________________.
this date or dated__________________________, which modifies a previous parenting
proposed by (name) Jolene Marie Charlton_______________________________ .

Name

Age
4
4 3 1 V
9-y i 4 ^ 2 8 8 9
Ifeei92
il. Basis for Restrictions

2.1

[]
[X ]
Does not apply.

The [ ] petitioners [X ] respondent's residential time with the child(ren) shall be limited
resolution process other than court action shall not be required, because [X J this parent
[X]
[X]
[X]
2.2

harm.

[]
[X]
Does not apply.

[X]
[X]
[X]
[X]
[X]
[]
Lj

child.
Other:

The residential schedule must set forth where the child(ren) shall reside each day of the year,
occasions, and what contact the child(ren) shall have with each parent Parents are encouraged
individual needs of their family. Paragraphs 3.1 through 3.9 are one way to write your
Paragraph 3.13.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181; .187;. 194
-1 3 1 ?
3.1
3 ^ 1 4 /2 ^ 8 3
1 6 B i9 i

| ]
[X]

Prior to enrollment in school, the chiid(ren) shall reside with the [X] petitioner
L] respondent, except for the following days and times when the child(ren) will reside
from (day and time) Saturday noon to (day and time) Saturday at 4:00 p.m.
[]
t]
the second and fourth week of the month [X] other: Under supervision when
respondent and child are in the same city.
from (day and time)

[]
[]
3.2
Sunday 4:00 p.m. to (day and time) Sunday 8:00 p.m.
the second and fourth week of the month [X] other: Under supervision when the
respondent and the child are in the same city.
School Schedule
From (day and time) Saturday noon to (day and time) Saturday 4:00 p.m.
[]
[l
[X]
every week [ ] every' other week [ ] the first and third week of the month
the second and fourth week of the month
Other: Under supervision when the respondent and the child are in the same city.
From (day and time) Sunday 4:00 p.m. to (day and time) Sunday 8:00 p.m.
tJ
[j
[X]
[J
every week [ j every other week [ ] the first and third week of the month
The school schedule will start when each child begins [ ] kindergarten [X ] first grade
[ ] other:
Parenting Plan (PPP, p p t , PP) - Page 3 of 11

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, .181; .187; .194
431?
3.3
lb S 1 94

To coordinate with times that the child and the respondent are in the same city; using the same
schedule as 3.1 above and under supervision.
3.4

The child(ren) shall reside with the [X] petitioner [ j respondent during other school breaks,
parent:
schedule as 3.1 above and under supervision.
3.5
Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the [X] petitioner
[X]
[]
3.6

Other:

[X]
[]
Does not apply.


WPF OR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181; .187;. 194
431?
3.7
3/'X4?2B00
ib81yi>

New Y ears Day

Presidents1 Day
Memorial Day
July 4th
Labor Day
Veterans1 Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Every
Every
Every
Every
Odd
Even
Even
Even to coordinate with 3.1

Odd to coordinate with 3.1
[X]
times): 8am to 8pm
[]
[X]

With Respondent
With Petitioner
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
Mothers Dav
Every
Fathers Dav
Every
Mothers Birthday
Every
Fathers Birthday
Every
[X] Other: To coordinate with times that the child and the respondent are in the same city, using
same schedule as 3.1 above, and under supervision.

WPP DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187; .194
4317
3.9

[X]
[]
[]
__ ^school breaks (3.4)
summer schedule (3.5)
[]
3.10
3.11
9^14^2889
holidays (3.7)
____special occasions (3.8)
Other:
Restrictions
t]
[X]
The [ ] petitioners [X] respondents residential time with the children shall belimited
because there are limiting factors in paragraphs 2 .1 and 2.2. The following restrictions
shall apply when the children spend time with this parent: Under supervision when the
respondent and the child are in the same city.
[]
reasons:
A licensed individual responsible to transport children shall transport the child in a licensed and
insured vehicle with proper restraints.
The respondent shall arrange the transportation and payment of the child to visit him,_____
under supervision when the respondent and the child are in the same city.
The petitioner shall arrange the transportation and payment of the child to return home.

431?
3.12
9^14^2889
1 &8 1 9 ?
The children named in this parenting plan are scheduled to reside the majority o f the time with
parenting plan.
3.13
Other
3.14

This is a summary' only. For the full text, please see RCW 26.09.430 through 26.09.480.
notice must contain the information required in RCW 26,09.440. See also form DRPSCU
and safety' of a person or a child at risk.

4 9 1?
9^14^2089
confirmed.
A person entitled to time with a child under a court order can file an objection to the child's
IV. Decision Making
4.1
children.
4.2
Major Decisions
Education decisions
[X]
[XJ
[X]
[]
[]
[]
[]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[]
[]
[]
[]
[]
[]
[]
[]

respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
U
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
joint
joint
188198
4317
4.3
if e193

[]
[X]
following reasons:
[]
[]
[X]

(a)
(b)
(c)
(d)
[]
9/14/2003

RCW 26.09.184(4)(a); and
There are limiting factors in paragraph 2.2, but there are no restrictions on mutual decision
making for the following reasons:

4317
9 / 1 4 "''20139 1 6 0 2 B S
the provisions of this plan must be used before filing a petition to modify the plan or a motion for
[J
or agency):
[]
counseling by _____________________________________ , or
[]
mediation by _____________________________________ , if this box is checked and

[]
arbitration by
_____________________________________ .
[]
[]
[]
% petitioner _________ % respondent.

worksheets.
(a)
(b)
(c)
(d)
(e)
[X ]

other parent.
court.

[]
[]


WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187;. 194
^317
9 214'2 889
16828

[]
[]
Does not apply.

(Only sign if this is a proposed parenting plan.) 1 declare under penalty of perjury under the laws
M civil? ItF ru
/Pefitioner
Respondent
Date and Place o f Signature

order o f this court.
not affected.
Dated:__________________________________
_______________________
Judge/Commissioner
Presented by:
Approved for entry:
Print Name
Print Name

4591
3 / 2 4/2889
339182
in county "C l I r K'S office

08-3-00821-4
32890256
RTS
09-24-09
A.M.
SEP 2 3 2009 p.m.
P(f?CP COUNTY, WASHINGTON

KEVIN
BY___ S T O CK, County Clork
______________ DEPUTY
ik

County of Pierce
In re:
Tyler Michael Flohr
Hannah Marie Flohr
Child(ren),
Petitioner(s),
and
No. 08-3 -0 0 8 2 1 -4
Respondent(s).
R eturn o f S ervice
(N otice o f Intended R elocation
o f C h ild ren )
(R TS )______________________________
I Declare.
1.
2.
Iam over the age of 18 years, and I am not a party to this action.
I served (name) Christopher Lee Harrison
[X]
[X]
[]
[]
3.
with the following documents:
Notice of Intended Relocation of Children.

Parenting Plan.
Residential Schedule.
Other:
The date, time and place of service were:

Date:
Address:
9-14-09
Time of service or time of mailing

,i
c2 *D O
bl-2.1
O u t* * * , w *
JBonnev Lake, WA. 98391________
4.
Service was made pursuant to RCW 26.09.440(l)(a):
Return of Service (Not Intended Reloc) (RTS) - Page 1 of 2

WPF DRPSCU 07.0600 (6/2008) - RCW 26.09.440(1)(a)
a .m ./^ )
"a y /G l
4591
[]
[]
[X]
5.
9 /2 4 /2 8 8 9
338183
by delivery to the person named in paragraph 2.

by delivery' to (name) _______________________________________ . a person of suitable
age and discretion residing at the usual abode o f the person named in paragraph 2.
by mailing a copy to the person named in paragraph 2. by any form of mail requiring a
return receipt, (Tape return receipt below.)
Other:
1declare under penalty o f perjury' under the laws of the state of Washington that the foregoing is true and
correct.
Signed at (city) Bonnev Lake
(state) Wa
on 9-14-09 .
Print or Type Name

Fees:
Service
Mileage
Total
S E N D E R : COMPLETE THIS SECTION
Complete items 1, 2, and 3. A lso complete
ttem 4 it Restricted Delivery is desired.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
1. ArticleUdressed.to:
2. Art ^
P S Form i
SETT BDE9T 9 0 0
4S39
080-00821-4
32975424
ORPRFP
S09
FILED
10-07-09
A.M.
OCT - 7 2009
h i
PIERCE COUNTY, Y/ASHINOTQN

KEV1M
BY-
S T O C K , C o u t 7
_ ._ _ 7
C \$;U
- .5=.?til'/
SUPERIOR COURT OF WASHINGTON COUNTY OF PIERCE

In re
A&hw-e
.
u W / f o ^ Petitioner,
and
opbLet
Respondent.
!
)
)
)
no.
o f - ' s - o o f j . i - y

IN FORMA PAUPERIS
)______________________________________
MOTION AND DECLARATION

I certify under penalty of perjury, according to the laws of the State of Washington, that
the following is true and correct:
I am the applicant, and I seek an order authorizing me to file this action by paying
only the Family Law Facilitator surcharge of $20.00 I believe that I have valid
reasons for bringing this action and that I am entitled to relief. I am unable to pay
the rem ainder of the filing fee in this case.
[ ]
la m the applicant, and I seek an order authorizing m e to file this action by paying
only the Fam ily Law Facilitator surcharge of $20.00 at the time of filing. I shall
pay the filing fee prior to the entry of the final papers with proof of payment
provided to the court at the final hearing.
[ ]
la m the applicant, and I seek an order authorizing m e to file this action by paying
only the Family Law Facilitator surcharge of $20.00 at the time of filing. The
Respondent has joined (or if the Respondent joins) in the petition, the filing fee
will be paid prior to entry of the final papers with proof of payment provided to the
court at the final hearing.
The attached Financial Statem ent accurately describes my financial condition.
Date
Signature
,
*/ / S
PrintTType Name
MOTION AND O R D ER T O P R O C E E D IN FO R M A PA U P ER IS P A G E 1 o f 2
F:\W ORDDOCS\DOMFORMS\FACILITATOR\1FPMTIFP09.DOC
Revised: 09/15/2009
2001
49BB
10/8/2089
NO.
ORDER
IT IS HEREBY ORDERED THAT:

[X]
The filing fee is waived. THE FAMILY LAW FACILITATOR SURCHARGE OF

$20.00 W ILL BE PAID PRIOR TO FILING THIS CASE.
[ ]
The filing fee is waived. The family law facilitator surcharge does not apply.
[ ]
The party(ies) will be required to pay the filing fee prior to entry of the final
papers with proof of payment being provided to the court at the final hearing.
[ ]
The Respondent has joined (or if the Respondent joins) in the petition, the filing
fee will be paid prior to entry of the final papers with proof of payment being
provided to the court at the final hearing. The respondent may present a motion
and Order to Waive the filing fee prior to finalization for review and consideration.
[ ]
Motion Denied
[ ]
Other:
FILED
IN COUNTY C L E R K S OFFICE
A.M.
O C E - ? 2009
pm

K E V Iri STOCK, C o u i :ly CtJsrU
, OtPUTY
________________OtPUTY
Ls
DATE
MOTION AND ORDER TO PROCEED IN FORMA PAUPERIS PAGE 2 o f 2

F:\W ORDDOCS\DOMFORMS\FACILITATOR\IFPM TIFP09.DOC
Revised: 09/15/2009
28817
4939
ifl^ .8 ^ 2 - 0 0 9
Case Number___________________________
1) My name is
ftÔlas iM
11_______________ I am 3 )
years of age
2) My spouses name is_________________ ___________ who is________ years of age
3. SPOUSE (complete if joint petition)
3. SELF
Employer:
Employer Address:
Employer
'
[ ] Full Time
[ ] Full Time
[ ] Part Time
Gross pay per month:

a. Reason:
Employer Address:
*---------
[} Part Time
Gross pay per month:
Hrs per wk:
4. IF UNEMPLOYED
4. IP UNEMPLOYED
f/I
a. Reason:
OTHER SOURCES OF INCOME PER

MONTH
5.
Hrs per wk:

MONTH:
Public Assist
Gifts
Public Assist
Gifts
Unemployment
L&l
Unemployment
L&l
Other:
TOTAL:
Other:
TOTAL:
6. MY MONTHLY EXPENSES
6. MY SPOUSES MONTHLY EXPENSES
Rent/Mort
Daycare
Rent/Mort
Daycare
Food
Tuition
Food
Tuition
Utilities
Insurance
Utilities
Insurance
Transportation
Other:
Transportation
Other
Med/Dental
TOTAL:
Med/Dental
TOTAL:
7. THE FOLLOWIN G PEOPLE LIVE

WITH ME
Name:
Age:
(ftbt-------*---fbw'** ------------- --------
Age:
Relationship:
11
Total Debt:
Payment
$
$
$
$
$
TOTAL OWED:
Name:
Relationship:
8. 1OWE THE FOLLOWING DEBTS

Creditor:
7. THE FOLLOWINI3 PEOPLE LIVE

WITH MY SI9OUSE
$
$
$
$
$
9. MY ASSETS & EGIUITY VALUES ARE:

Home
Checking
Savings
Other:
Cash
Vehicles
Stock/Bond
Life Ins.
Retirement
TOTAL:
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct.
,
Signed at
Signature
'~
A _____ w f t __________________ {City & State) on / CsyC? ^

P rin t/T y p e N a m e
Financial Affidavit for Motion and Order to Proceed in Forma Pauperis

F:\W ORDDOCS\DOMFORMS\FACILfTATOR\IFPFININFO.DOC 9/2001
(Date).
26S1S
4939
08-3-00821-4
32975467
OBPT
10-07-09
(N
* 0 /8 /2 80 9
C0UNTYF
28019
R X 'S O F F IC E
cler k
AM OCT- 7 2009
PM.
Cotiiijy Cfork
Depurr

County of
^ ^ 3
In re:
No . - & g - e * 3 2 l
Child(ren),
Petitioners),

and
Respondents).
Objection to Relocation/
Petition for Modification of
Custody Decree/Parenting
Plan/Residential Schedule
(OBPT)
Para. 3.10: check box if petition is
attached for:
(] Order for protection UH (PTORAH)
I. Identification of Parties
1.1
Objecting Party
Name (first/last) o f objecting party Christopher Lee Harrison
1-2
Relocating Party
Name (first/last) of relocating party Jolene Marie Charlton
1.3
Other Persons With Court-Ordered Time With the Children

List other persons with court-ordered time with the children.
Name (first/last)
Name (first/last)
Name (first/last)
1.4
Dependent Children
Name (first/last)__Christopher Lee Harrison Jr.

_____ _______________________________________ A ge__ 4_______
Name (first/last) _______ _______________________________________ Age
II. Objection to Relocation or Proposed Revised Residential Schedule

(Check all that apply)
2.1
[X ]
f, (objecting party) Christopher Lee Harrison

____________________________________ , object to the intended relocation
described in (relocating party) Jolene Marie Charlton
________________________________ s Notice of Intended Relocation of
Children dated___9-09-09______________________________
2.2
[X ]
1, (objecting party) Christopher Lee Harrison

___________________________________________, object to the proposed
revised parenting plan/residential schedule attached to
(relocating party) Jolene Marie Charlton
_______________________________________ s Notice of Intended Relocation
o f Children dated 9-09-09_________________________ .
A true and correct copy o f the Notice o f Intended Relocation o f Children, [ ] without [x ]
with proposed new parenting plan/residential schedule, is attached.
III. Basis
3.1
Petition for an Order Modifying Custody Decree/Parenting

Plan/Residential Schedule Pursuant to Relocation
This is a petition for modification o f custody decree/parenting plan/residential schedule
pursuant to relocation. The objecting party asks the court to enter an order:
[x ]
[]
[x ]
[]
3.2
Restraining the intended relocation o f the children.

Retaining the custody decree/parenting plan/residential schedule entered on
(date)______________________________ .
Approving the parenting plan/residential schedule filed with this petition. (Use
the Washington State mandatory pattern form.)
Other:
Adequate Cause
The relocation o f the children is being pursued. There is no need for adequate cause for
hearing this petition for modification.
3.3
Child Support
[x ]
[]
Does not apply.

An order establishing child support in conjunction with the proposed parenting
plan should be entered. A child support worksheet and financial declaration
have been filed with this action. (No separate petition for modification of child
support needs to be filed.)
4 93 3
3,4
IS^S 2Be9
Jurisdiction and Venue

The court has proper jurisdiction and venue.
The objecting party resides in (county and state only) Pierce county, WA
The children reside in (county and state only) Pierce county,

WA____________________________________________ .
The relocating party resides in (county and state only) Pierce county, WA
The current custody decree/parenting plan/residential schedule was entered in (county

and state) Pierce county, WA__________________________________________
. A
certified copy o f the current custody decree/parenting plan/residential schedule is filed
with or attached to this petition, if the decree or plan to be modified was entered in
another county or state.
3.5
Jurisdiction Over Proceeding

This court has jurisdiction over this proceeding for the reasons below.
[x ]
This court has exclusive continuing jurisdiction. The court has previously made
a child custody, parenting plan, residential schedule or visitation determination
in this matter and retains jurisdiction under RCW 26.27.211.
[]

[x ]
[]
[]
[]
[x ]
The children and the parents or the children and at least one parent or a person
acting as a parent have significant connection with the state other than mere
physical presence, and substantial evidence is available in this state concerning
the childrens care, protection, training and personal relationships, and
[x ]
[j
[]
the children lived in Washington with a parent or a person acting as a

parent for at least six consecutive months immediately preceding the
commencement o f this proceeding.
the children are less than six months old and have lived in Washington
with a parent or a person acting as parent since birth.
Washington was the home state o f the children within six months before
the commencement of this proceeding and the children are absent from
the state, but a parent or person acting as a parent continues to live in
this state.

the childrens home state has declined to exercise jurisdiction on the
ground that this state is the more appropriate forum under RCW
26.27.261 or.271.
All courts in the children's home state have declined to exercise jurisdiction on
the ground that a court o f this state is the more appropriate forum to determine
S8S21
4939
1B/'8^200S
the custody o f the children under RCW 26.27.261 or .271.

[x ]
[]
This court has temporary emergency jurisdiction over this proceeding because
the children are present in this state and the children have been abandoned or it
is necessary in an emergency to protect the children because the children, or a
sibling or parent o f the children is subjected to or threatened with abuse. RCW
26.27.231.
[]
3.6
[]
There is a previous custody determination that is entitled to be enforced

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

under this chapter and a child custody proceeding has not been
commenced in a court o f a state having jurisdiction under RCW
26.27.201 through 26.27.221. If an action is not filed in (potential home
state)_____________________________ by the time the child has been
in Washington for six months,
(date)_______________________________ , then Washington's
jurisdiction will be final and continuing.
Other:
Uniform Child Custody Jurisdiction and Enforcement Act Information

[x ]
[]
in no place other than the state o f Washington and with no person other than the
objecting party or another party.
lived, including die state o f Washington, the dates the children lived there and
the names o f the persons with whom the children lived. The present addresses of
those persons must be listed in the required Confidential Information Form.):

[x ]
[]
The objecting party does not know of any person other than the relocating party
who has physical custody of, or claims to have custody or visitation rights to, the
children.
visitation rights to, the children (list their names and the children concerned
not list the relocating party.):
8BE22
4939

[x ]
children.
[]
The objecting party has not been involved in any other proceeding regarding the
The objecting party has been involved in the following proceedings regarding
the children (list the court, the case number, and the date o f the judgment or
order):

[x ]
(]
3.7
The objecting party does not know of any other legal proceedings concerning the
children.
The objecting party knows of the following legal proceedings that concern the
children (list the children concerned, the court, the case number, and the kind of
proceeding):
Reasons for Objecting to the Relocation

Based upon the following factors, the detrimental effects of allowing the children to
move with the relocating person outweigh the benefits o f the move to the children and
the relocating person:
3.7.1
The relative strength, nature, quality, extent of involvement, and stability of the
childs relationship with each parent [x ] sibling [x ] and other significant
persons in the childs life.
[ ] Does not apply.
[x ] Does apply. Explain: All of the childs family resides in western Washington
and the mother has a very close family that the child sees on a regular basis, as well as the childs
older siblings and father.
3.7.2
Prior agreements of the parties,

[x ] Does not apply.
[ ] Does apply. Explain:
.0.0623
4 93 3
3.7.3
10>'.8^2-a09
Disrupting contact between the child and the objecting party or parent is more
detrimental to the child than disrupting contact between the child and the person
with whom the child resides a majority of the time.
[xs ] Does not apply.
3.7.4a The objecting party or parent [ ] is [x ] is not subject to limitations under RCW
26.09.191.
[ ] Does not apply.
3.7.4b The following parents or persons entitled to residential time with the child are
subject to limitations under RCW 26.09.191.
3.7.5
The reasons and good faith of each person seeking or opposing the relocation.
[ ] Does not apply.
[x ] Does apply. Explain: The mother would be taking the child away from a
very close family, to include, father, siblings, grandparents, aunts, uncles, and
cousins, that the child sees on aregular basis.The mother has a good paying job
that she has been at for over 11 years.
86624
3.7.6
The age, developmental stage, and needs o f the child, and the likely impact the
relocation or its prevention will have on the childs physical, educational, and
emotional development, taking into consideration any special needs o f the child,
3.7.7
The quality of life, resources, and opportunities available to the child and to the
relocating party in the current and proposed geographic locations.
[ ] Does not apply.
[x ] Does apply. Explain: Cj has a very high quality o f life as far as he is in the
church he was bom in to and everyone there knows him, several children there
are his close friends. Cj is part o f a very close family on his mothers side,
grandparents, aunts, uncles, and cousins that he sees on aveiy regular basis. A
sister that he sees everyday at daycare, and a sister that he spends weekends
with on a regular basis. He gets to see both his parents on a regular basis.
3.7.8
The availability of alternative arrangements to foster and continue the childs

relationship with and access to the other parent,
fx ] Does not apply.
3.7.9
Alternatives to relocation and whether it is feasible and desirable for the other
party to relocate.
[ ] Does not apply.
[x ] Does apply. Explain: Niether Jolene or her newest husband have any family
in Idaho. Her husband should be able to find a job here in Washington, there are
numerous fertilizer companys in this area.
CT' ij
4 93S
I 0 > '8 ^ 2 0 0 S 8 8 8
1 S -'"8 s:z 0 0 9 S 0 8 2 f.
3.7.10 The financial impact and logistics o f relocation or its prevention.

[ ] Does not apply.
[x ] Does apply. Explain: Jolene will be leaving a good job that she has been at
for over 11 years. If Cj is allowed to move to Idaho it will be very costly to transport him
back and forth, as well as Jolene has 2 other children from a previous marriage that she
would have to transport as well.
3.8
Reasons for Objecting to the Relocating Partys Proposed Parenting

[]
Does not apply.
[x ]
I object to the relocating partys proposed parenting plan/residential schedule
because:Jolene wants to change my everyother weekend, friday through Sunday visits
and change them to 4 hours on Sunday, supervised, only when Jolene and l are in the
same city. This is without cause except to make it impossibe for me to see my son.
3.9
Modification or Adjustment to the Residential Provisions of the
4939
1 0 /8 V 2 0 9
Parenting Plan or Residential Schedule

[]
[x ]
[]
3.10
Does not apply.

The objecting party requests an adjustment o f the residential provisions o f the
relocating partys proposed parenting plan. The adjustment does not include a
change in the residence in which the children reside the majority o f the time.
The objecting party requests a modification o f the relocating partys proposed
parenting plan/residential schedule, including a change in the residence in which
the children reside the majority of the time.
Protection Order
[x ]
[]
[]
Does not apply.

There is a protection order between the parties filed in case number
________________ , court____________________________ , which expires on
(date)___________________ .
The court should grant the [ ] domestic violence [ ] antiharassment petition for
order for protection:
[ ] filed separately under [ ] this case number [ ] case number
Violence forms or RCW 10.14 Antiharassment forms.
3.11
Other
IV. Relief Requested

The objecting party requ ests that the court:
[x ]
[]
[]
[x ]
[]
Restrain the relocation of the children.

Permit the relocation o f the children.
Retain the custody decree/parenting plan/residential schedule signed by the court
dated on _____________________________ .
Approve the proposed parenting plan/residential schedule which is filed with this
Objection/Petition. (Use the Washington State mandatoiy pattern form.)
Enter an order establishing child support in conjunction with the objecting
partys proposed parenting plan/residential schedule. The child support
worksheet and financial declaration are filed with this petition.
9B027
4939
[]
[]
Dated:
l /8 ^ 2 0 .0 9

Other:
-CJ
1
iature of Objecting
< ^
Signature
Party or Lawyer/WSBA
No.
'^ 1
Print or Type Name C i h / i s
rf
I declare under penalty o f peijuiy under the laws o f the state o f Washington that the foregoing is
true and correct.
Signed at (city)
Taco
, (state)
wA
on (date) / Q -7 ~ 0 > \
Signature o f Objecting Party

Chris Harrison_
Print or Type Name
88028
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-9 7 5 4 7 0
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w cou"TyF,c ' i i & s

am.
OFF/CC
OCT -/!
pi c e CpUNj
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DEPUTY
IN RE:
( A - C W * A \ok>
Petitioner/Plaintiff,
Vs.
Dated this
day of_________ 20
2007.document.coversheet doc
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)
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88029
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ie ,'8 y2 S 9
My name is Christopher Lee Harrison and this is my statement. In Jolenes parenting plan she stated
that I abandoned my son, but the truth is that she has withheld him from me. In January I started a
dual diagnosis program and part of that was to move in to clean and sober housing. I called several
times begging to see my son, but she would always no, claiming that she didn't know any of the
other people that lived there. In March I moved in with my girlfriend and for one time she let us
come and pick him up and bring him to our house, and Jolene had no problem with that. The next
week when I texted her to see if I could see my son again she claimed that she couldn't let him go
for safety concerns and that she could not let him come here unless she had my address. And I
would not mind giving my sons mother my address except or the fact that she has driven around
(with my older kids in the car) for hours looking for my house, and once she found my house I
would see her driving by all the time. This has happened on two separate occasions and I didn't
want it to happen again, and didn't want to bring that in to my girlfriends life. On the 9th of
September we entered our neighborhood to the sight of Jolenes car driving around up and down
streets, obviously looking for our house. The next Monday the 14th I was served the court papers
through the mail, so I texted her and said now that you have my address can I see my son and she
said no because you did not give it to me. So I texted her my address and her reply was "that wasn't
so hard now was it?" Two days later on the 16th she dropped him off at my house at 3 in the
afternoon and picked him up at 8:30 in the evening. But in her proposed parenting plan she states
that feels that my son is not safe with me. Then she allows me to pick him up from daycare on
Friday the 18th and she came to pick him up that Sunday the 20th and showed no concern for his
safety while he was with me, no calls to check on him or anything like that.
Jolene also stats that a contributing factor to me not being able to see my son is drug, and
alcohol abuse. The only trouble I have been in due to alcohol is I received a DWI 6 years ago.
Currently I am in a dual diagnosis program that I am in full compliance with, and this is my 9th
month in a 1 year program.
1 do not believe that Jolene is acting in her kids best interest by moving so far away, not only is she
moving all her kids away from all their dads, but away from all their family, all of her kids extended
family live in Washington. Jolene has a very close family she has 9 siblings and they all live in this
area and the kids see all grandparents, aunts, uncles, and cousins on a regular basis. This move can
not be in the childrens best interest. Also Jolene has also been in her job for 12 years so she has a lot
vested in the company. The facts state that her moving would be detrimental to my son and all the
children involved. My calls, messages, and texts pleading to see my son are repeatedly ignored. In
Jolenes proposed parenting plan she states that I should get only 4 hour visits whenever we are in
the same town and that they be supervised. There is absolutely no reason for that other than she has
with held my son from me for no good reason. W hile talking to her on the phone recently she has
stated that she knows I am a good father and she knows our son is safe with me. On Monday the
2 2st I entered in to a verbal agreement that I would get to see my son everyother weekend starting
the 3rd of October. On the 30th of Setember I woke to see that I had 7 missed calls from her cell
phone, when I called back she told me that my son wanted to talk to me at 1:45am (obviously my
son wanted to talk to me), and while talking to my son I was informed that I would not be getting
883%
4939
him on the dates as stated but it would be put back 1 week to accomodate her days off, so I changed
my schedule so that I would be able to see my son. On October the 4th at 2 am I was awaken to a
call from my son who had a bad dream and wanted to talk to me after talking to him for a few
minutes he wanted to see me, but I told him that I couldnt see him till Friday and he was very
upset. 1 called him later in the morning to how he was doing and he was still upset that he couldnt
see me, Around 3 pm I heard the door bell ring and when I answered it there was my son with a
huge smile on his face. No arrangements were made for his return. As always when he was with me
no calls from his mother to check on him and his well being. I returned my son at about 7:30pm.
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BY_______ <_________ DEPUTY
r
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SUPOUOft COURTOP WAffiMOnM FOBHMMCECOUNTY

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-939
I, Margie Lacey would like to confirm that I have viewed Chris and his behavior with his daughter,
Alyssa. They spent the weekend vacationing with me and my family in July of 2009. He was
much in tuned to her needs, kept her happy and made sure she was cared for. It was very clear
he was her father and she showed him love and respect that you would expect to see with a
father and daughter relationship. He also appeared to have patience for a teenager which was
very encouraging to me, a mother of 4.
M A R G IE L A C E Y
Human Resources Manager

Manheim Seattle
19711 77th Ave So
Kent, WA 98032
p:253/437-2604
f: 253/872-2819
www .ss-aa.net
OS-3-00821 - d
32975501
ST
10-07-09
IN C O U N T Y F C L E R K '
a..
IFFICE
o c j \ m m
COUNTrÂSHIN8TON
KEVIN STOCK, county Clerk
BY
___ DEPUTY
September 25, 2009

My name is Karleen S
I met Christopher Harrison in March of 2009. Since meeting Christopher Harrison I have come to
know him a great deal and have witnessed his interaction with his children, C.J., Alyssa and Katie
Harrison.
The interaction that I have witnessed between Christopher Harrison and his children has been
postive and loving between Chris and the children mentioned above.
When he has been able to spend time and interact with his children, I have observed that Chris has
a great father bond with the children. I have witnessed all of them laughing, playing and talking
with each other.
On numerious occasions since March of 2009 I have witnessed Chris repeatedly trying to initiate
contact with his son, CJ Harrison, his son with his mother Jolene, by numerious phone calls, texts
and emails pleading with her to allow him too see his son.
I have never seen any type of behavior by Chris with and without his children that would call for
any concern. The behavior that I have witnessed by Christopher Harrison in every occasion is that
of a caring and considerate person, whether for his children, his family and his friends. Never any
moment of outrage or violent tendencies, never any drug or alchol tendencies or use of it in any
sort.
I see Christopher Harrison as a friend, a father , a person who would do anything good in any way
possible to help any person in his life, to want too see and help his children grow mentally,
emotionally and morally in every way possibly to help themselves benefit, as I believe Christopher
Harrison has also done
Karleen S
4 33 3
10/'8-/rZ@&9 SBSBfe
c o u n t y FIc l I ri
A.M.
IfF/C E
OCT
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9/26/2009
4' 3 3 9
IB
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To whom it may concern:

My name is Kayla, I am writing this letter on behalf of Chris Harrison. Chris and my
mom have been dating for approximately 7 months and he has spent a lot of time with our
family.
I want to state that Chris is a great father. I have seen first hand how Chris interacts with
not only his own children but the children in my family. I have seen the way he treats
them, like they are his own. A couple of weeks ago I was visiting with my family and
Chris was there with his son CJ and his daughter Alyssa. We had a barbeque at my
mothers (and Chris's) house. I noticed that Chris was explaining things to CJ so that he
could understand and learn. There are a lot o f parents that do not involve their children in
the tasks that they are doing but Chris does. He explained why we cook meat this way and
why we do the potatoes a certain way. When CJ said that he didnt like potatoes Chris
asked him why not, when just a few days earlier had eaten the same potatoes at another
barbeque. CJ tried the potatoes, liked them, and ate.
Recently during this past summer we went camping with my family near Yakima. While
we were camping Chris made sure that the children didnt stray off on their own. He
walked with them to the bathrooms when they needed to go. He helped them all make
smores and was concerned that they might get to close to the fire so he moved the chairs
back just incase. He walked with diem to the nearby field so that they could play
horseshoes and see the river. They walked to the river while my boyfriend went fishing
and then walked together around the camp grounds.
While CJ and Alyssa stayed overnight with Chris a couple of weeks ago CJ told me all
about how his dad camped out with him in the living room and they watched movies and
played games together. 1 could tell that CJ was very very happy to spend time with his
father. Alyssa always loves spending time with her father. She has come to many of our
family events like barbeques and birthday parties. She even volunteered to baby sit for my
cousin who has an infant. They are involved with our family. They play, laugh, and enjoy
being around us. I wish that they could spend more time with us but seems nearly
impossible to get enough time with them. I can't imagine how Chris feels.
I believe that if Chris was given a chance to actually spend time with his children, he
would. He wants to be there to watch them laugh and grow, to teach them right and
wrong. I hope that Chris gets this chance to be around his children more. He deserves it
just as much as any other parents does.
Sincerely,
Kayla D
3 0 B .3
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To Whom It May Concern:

My name is Brenda Lambert Char is my sister, Chris and Char first started dating last year
and he has become a vital part of our family, He has been at all the family functions and is a
wonderful addition.
Chris has a son C J . that is a few months older then my youngest son T.J. when Chris and
Char have C J . over for the weekend my son spends the weekends with them or at least one
night, T.J. loves it when C.J. is their and he loves to go to his Aunt Chars house it is one of
the three homes that he is allowed to spend the night at and he will periodically ask to go
spend the night.
I have seen Chris with his children and he really is a good father caring and concerned not
only with just his own but my sons as well as the other children in our family.
I have never seen Chris spank, yell or loose his calm collectiveness in dealing with any
children or adults.
I know his children are not to ride bikes without helmets and protective wear.
I saw his concern and compassion for my son who scraped his leg riding a scooter at another
relatives home (my son was not using a helmet) Chris scolded us both I would never allow
my kids to ride without helmets or protective wear.
Chris has always shown guidance in the care of his children, as well as with my two sons,
when the kids are in their home he takes them to the park, they wash cars, play water
balloons, ride bikes, skate board, play games, talk.
Chris was also very concerned that his daughter who had just turned 16 Elisa did not get a
sweet 16 birthday party, so on the weekend that she got to spent in their home he planned her
party, Barb a qued for our entire family, he gave a sweet 16 that was memorable down to the
homemade cake he made her.
I think as a responsible adult, a reasonable court, and with the best of these childrens
interest that all the children in that house should be given the courteousness of at least
addressing how they feel and think.
Thank You.
Brenda Lambert
\ 0 - l
CA
8033
49 3 S
3 .0 2 B - ' 2 0 6 9
3864S
FILED
08-3-00821-4
3297353d
ST
10-07-09
u / T K j ^ 2009
p.m.
W tC E tO U N T Y , WASHINSTON
KEVIN STOCK, County C lark
BVr
IN RE:
^ \J"0 l e ^
)
)
)
)
W \x
Petitioner/PIaintifT,
Vs.
Lo.
Ckn5-/o/*V" L> l/^rlson

Respondent/Defeodant______________
Dated this
dav of
)
)
)
)
1
g > y - y o o ^ / - 6/
(Document Tctk)
20
Signature
2007.documa&eovenhMtdoc
0EWTY
4 9 i* 9
83S41
September 29th 2009
To Whom It May Concern:
I, Amanda Ann Marie, (niece to Charlotte, Chris Harrisons girlfriend) concede that
Christopher Lee Harrison Sr. is in fact an excellent parent to all of his children, including
Christopher Jr. (CJ)
I have witnessed Christopher Lee Harrison Sr. with son Christopher Lee Harrison Jr. on
many occasions; they have a very fun and playful time together. Christopher Jr. laughs
and plays with father Christopher Sr.
I am appalled at the statement that father Christopher Lee Harrison Sr. is abusive. 1
Amanda Ann Marie, protest that I have never observed any abuse or neglect or failure to
provide all that is needed for son Christopher Lee Harrison Jr. by father Christopher Lee
Harrison Sr.
Amanda Ann Marie
4933
08-3-00621-4
32$75550
ST
188/2003
380*1
10-07-09
IN
co u
HT^
c l
r k
o f f ic e
7 2009
P.M-
PIERB&'COUNTY, WASHINGTON
KEVIN STOCK, C ounty C lo i*
BY
IN RE:
Petitioner/PlaintifT,
Vs.
j N o. 0
y ~ \
(^kr^fopher L. r^ ''^
Rcspondent/Defendant
Dated this
day of.
20
Signature
20Q7.docuraem.comshecldoc
My name is Char,
I ask and choose to keep my last name withheld out of fear of retaliation and harrassment by Jolene
Charlton.
I am Chris Harrison's girlfriend. We have been living together since March.
About myself. I am the mother of one child, a daughter who is of legal age. I have worked in HR
for more than 13 years, being with the same company for over 7 1/2 years. I come from a large
family of 5 girls and 2 boys.
Chris has been welcomed into my family with open arms. He is very highly respected by my sisters,
brothers, neices, nephews and in-laws. Everyone respects him because of the person that he is and
the charachter he has shown them. My daughter and her boyfriend of 4 years respect and admire
Chris and have formed a close bond with him.
In the past several months that we have been together I have seen Chris make contact with Jolene
on almost a daily basis...trying, asking and even pleading with her to see his son CJ.
I have personally witnessed him texting and calling Jolene on so many different occasions, asking
her when he gets to see his son. She has repeatedly ignored him, shut him down and denied him
the right, until just recently, when she filed her parenting plan with her intent to move out of the
state of Washington.
Jolene filed her parenting plan paperwork on Wednesday, September 9, 2009 & she had Chris
served on Monday, September 14th. Chris called Jolene many times from September 14th & on to
find out when he could see CJ, telling her "Now that you have my address when do I get to see my
son?" Two days later she replied to him that even though she has the address (which she told him
was pretty easy to get) he could not see his son until he physically told her the what our address is.
So he spoke the words and gave our address to her. Her response was "Well, that wasn't so hard
now, was it?" She then dropped CJ off at our house the very same day, Wednesday September 16th
at 3:00pm and picked him up at 8:30 pm.
CJ w a s very happy and excited to see his dad. W e all had a great time. Chris and CJ played with
our cat, played the X-Box, and since it was raining and cold outside Chris took CJ into the garage
and he skateboarded in the garage. Chris made sure that CJ was wearing his knee pads and stood
close by to ensure that he wasn't harmed in any way. CJ was fed a warm dinner and was well taken
care of while he was here.
On 9 /1 8 /0 9 Jolene allowed us to pick CJ up from his daycare at 3:00 pm to spend Friday thru Sunday
with us. W e got there to pick him up and discovered that she didn't leave a car seat or booster seat
for him. W e had to borrow one from my sister. He came home with us with a bag of clothes, 1 pull
up (for 2 nights) and a garbage bag full of dirty miss-matched Legos that didnt even fit together.
4933
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88844
She picked him up from our house on 9/20/09 at aproximately 3 pm. She didn't call one time to talk
to CJ or ask how he was doing. CJ's sister Alyssa also spent that weekend with us.
Chris's daughter Alyssa, who refers to Jolene as her stepmom, spends time with us at our house and
with my family on a regular basis. She has been accepted by my family and she feels very
comfortable here at our house and around my family. His other daughter Katie has also been here.
I have seen Chris interact with all of his children and I have never seen him act inappropriate with
any of them. My family has made several comments to me about how patient & interactive he is
with not only his children, but with my daughter, neices and nephews.
I've never seen Chris raise his voice with anyone, especially with a chid. He has never shown me
any act of violence nor has he been disrespecful in any way at all. He tries so hard to be a good dad
and him & I both love having his kids here with us. I know that there is nothing he wouldn't do for
them.
He teaches his kids good morals and proper behavior and they show a great amount of respect for
him. Chris's kids are very much at ease around him and it is obvious to me and my friends and
family that they all love each other very much. W hen they are here at our house he always spends
quality time with them, always doing something with them that they particularly enjoy doing. He
takes Alyssa to the park and plays basketball with her, (I tease her about the cute boys at the park)
he takes CJ out in the cul-de-sac and helps him ride his skate board, he plays dominoes with Katie.
My own neices and newphews are continuosly asking to come over and stay the night because they
too love hanging out with Chris.
Chris is a good person who has shown me nothing but good charachter. It has been very painful for
him that Jolene has withheld his son from him. He is constantly telling me "I just want to see my
son" My heart aches for him everytime he says that.
Chris deserves the right to be his son's father and CJ deserves to have his father. Tearing them apart
is only going to damage both of them permanately.
Thank you for the time and consideration.
Char
d
L e u .
4933
08-3-00821-4
32975569
ST
iê/28g9
BB04
10-07-09
filed
IN C O U N T Y C L E R K 'S
AM
O F F IC E
p .m :
PIERCE CD-UWTY, WASHIN6 T 0 N

DEPUTY
BY.
IN RE:
M
%C k e \ f l \ z A
Petitioner/Plaintiff,
Vs.
)
)
)
)
)
) No,
L
{SC^
Respondent/Defendant
Dated this
day o f___________20_____
2007.doeunentcovcnheetdoc
_______
Signature
- 1
839
.1 8 /6 /2 8 8 9
September 29, 2009
To whom it may concern:

I have known Chris for approximatly 6 months. He is my roommate.
I have on several occasions seen him with his children. I have never seen him
loose his tem p e r, yell (or even raise his voice), abuse (physically or emotional).
When he does have his kids they are his number one priority. He takes them to
the park. Pays attention to them, and makes them listen. They are well behaved around
him.
I have my grand daughter almost every other weekend. He is awesome with her.
She totally adores Chris. I have no problem letting Chris watch her while I have to do
something. I feel 100% that she is in safe hands.
I have herd Chris on the phone way to many times trying to get to see CJ. His ex
wife will not let him see CJ. I think CJ has only been here twice. When he is here Chris
and CJ get along great. CJ loves his dad. They play together and have a good time.
Chris has way more patience then I would have.
Chris talks to his kids all the time on the phone. They call him and he calls them.
From what I have observed Chris has a good relationship with all three o f his
kids. They have no problem calling, talking, and interacting with Chris.
I have on several occasions witnessed Chris with other kids as well. His
girlfriends family comes over and they have kids. Chris is good with them. He will
listen to them, play with them, and help them. I have never seen any kid including my
grand daughter act like they are afraid of, dont want to be around, or act strange around
Chris.
I have known Chris girlfriend family for years. There is no way they would let
him go camping, go to family functions, or just visit with him if they thought he was not
a decent guy.
Like I said I have known Chris for approximately 6 months and I believe Chris to
be a decent, honorable person. I trust him with my grand daughter and that is not easy to
come by. I have known some people for a lot of years that I would not leave my grand
daughter with. They are not bad people, I just dont think they would pay enough
attention to her and she might get into something. (She is only 20 months old).
S0046
43 3 S 8 g M 9 3
08-3-00821-4
32975588
PPP
i 8*$4?
10-07-09
,N COUNTy'itl-O
O F F /C e
O C T - 7 2009
Depyry

County of
In re Parentage:

and
Petitioner,

and
Respondent
8 - ^ - 0
N o- 0
5 1 - ^
Parenting Plan
[x ] Proposed (PPP)
[ ] Temporary (PPT)
[ j Final Order (PP)
Respondent
[]
[]
[]
[x ]
the final parenting plan signed by the court pursuant to an order determining parentage
signed by the court on this date or dated____________ _________________ .
this date or dated_____________________________ , which modifies a previous
parenting plan or custody decree.
proposed by (name) Christopher Lee Harrison_______ _______________________ .
Name
Christopher Lee Harrison Jr
Aee
4

2.1
resolution process other than court action shall not be required because [ ] this
parent
[]
[]
[]
2.2
Willful abandonment that continues for an extended period of time or

substantial refusal to perform parenting functions (this applies only to
parents, not to a person who resides with a parent).
Physical, sexual or a pattern o f emotional abuse of a child.
A history o f acts o f domestic violence as defined in RCW 26.50.010(1)
or an assault or sexual assault which causes grievous bodily harm or the
fear of such harm.

[]
[J
Does not apply.

The [x ] mother's [ ] fathers involvement or conduct may have an adverse effect
on the childs best interests because o f the existence of the factors which follow.
[]
[]
[]
[]
[]
[x ]
[]
Neglect or substantial nonperformance o f parenting functions.

abuse that interferes with the performance of parenting functions.
The absence or substantial impairment o f emotional ties between the
parent and child.
The abusive use o f conflict by the parent which creates the danger o f
serious damage to the childs psychological development.
A parent has withheld from the other parent access to the child for a
protracted period without good cause.
Other:

The residential schedule must set forth where the child(ren) shall reside each day o f the
year; including provisions for holidays, birthdays o f family members, vacations, and
other special occasions; and what contact the child(ren) shall have with each parent
Parents are encouraged to create a residential schedule that meets the developmental
needs of the child(ren) and individual needs o f their family. Paragraphs 3.1 through 3 .9
are one way to write your residential schedule. If you do not use these paragraphs,
write in your own schedule in Paragraph 3.13 .
3.1
4339
[]
[x ]
1 gyS ^28 9

Prior to enrollment in school, the child(ren) shall reside with the [x ] mother [ ]
father, except for the following days and times when the child(ren) will reside
from (day and time)Friday 8pm_____________________to (day and time)
Sunday 8pm_____________________
[]
[]
the second and fourth week of the month [x ] other: First week o f the
month starting on the first friday
from (day and tim e)_____________________to (day and time)

[]
[]
3.2
every week [ ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
School Schedule
Upon enrollment in school, the child(ren) shall reside with the [x ] mother [ ] father,
the other parent:
from (day and time) Friday 8pm _____________________to (day and time)
Sunday 8pm____________________
[]
[]
the second and fourth week o f the month [ ] other: First week o f the
month starting on the first friday.
from (day and tim e)_____________________to (day and time)

[]
[]
[]
3.3
every week f ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
The school schedule will start when each child begins [x ] kindergarten [ ] first
grade
[ ] other:

The child(ren) shall reside with the [ ] mother [x ] father during winter vacation, except
for the following days and times when the child(ren) will reside with or be with the other
l0fi4 9
parent:
3.4

The children) shall reside with the [ ] mother [x ] father during other school breaks,
the other parent:
3.5
Summer Schedule
Upon completion o f the school year, the child(ren) shall reside with the [x ] mother [ ]
father, except for the following days and times when the child(ren) will reside with or be
[]
[x ]
3.6

[ x]
[]
3.7

Other: One week after school lets out child is to reside with the father for 30
consecutive days.
Does not apply.


New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
With Mother
(Specify Year
Odd/Even/Everv
With Father
(Specify Year
Odd/Even/EvervJ
even
odd
even
odd
even
odd_
odd
even
even
even_
odd
odd
< 5933
3.8
S S2 8 0 3
[x ]
For purposes o f this parenting plan, a holiday shall begin and end as follows (set
forth times): 8am to 8pm
[x ]
[x ]
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday,
Other:Thanks giving shall be from Wed 8pm to Sunday 8pm

The residential schedule for the child(ren) for the following special
example, birthdays) is as follows:
With Mother
(Specify Year
Odd/Even/Everv)
every___________________
Mothers Dav
Fathers Dav
_______________________
_______________________
Fathers birthday.
[]
3.9
i-8
occasions (for
With Father
(Specify Year
Odd/Even/Everv)
___
every_____
every_____
Other:

[]
[x ]
Paragraphs 3.3 - 3.8 have priority over paragraphs 3.1 and 3.2 in the following
order:
Rank the order of priority, with I being given the highest priority:
_2__ winter vacation (3.3)
_4__ school breaks (3.4)
_1___summer schedule (3.5)
[]
3.10
3__ holidays (3.7)

_5___special occasions (3.8)
Other:
Restrictions
[x ]
[]
The [ ] mothers [ ] fathers residential time with the children shall be limited
because there are limiting factors in paragraphs 2.1 and 2.2. The following
restrictions shall apply when the children spend time with this parent:
l& S fl-5 i
4 933
[]
3.11
18
S 288 3
[ ] mothers [ ] fathers residential time with the children for the following
reasons:
Transportation costs are included in the Child Support Worksheets and/or the Order for
Child Support and should not be included here.
Transportation arrangements for the child(ren) between parents shall be as follows:
Both parents are to pay 50% transportation costs or provide transportation 1/2 way
3.12
The children named in this parenting plan are scheduled to reside the majority o f the
time with the [x ] mother [ ] father. This parent is designated the custodian o f the child
(ren) solely for purposes o f all other state and federal statutes which require a
designation or determination o f custody. This designation shall not affect either parents
rights and responsibilities under this parenting plan.
3.13
Other
3.14

If the person with whom the child resides a majority o f the time plans to move, that
person shall give notice to every person entitled to court ordered time with the child.
If the move is outside the childs school district, the relocating person must give notice
by personal service or by mail requiring a return receipt. This notice must be at least 60
days before the intended move. If the relocating person could not have known about the
move in time to give 60 days notice, that person must give notice within five days after
learning o f the move. The notice must contain the information required in RCW
16 8 8 5 2
26.09.440. See also form DRPSCU 07.0500, (Notice o f Intended Relocation o f a Child).
If the move is within the same school district, the relocating person must provide actual
notice by any reasonable means. A person entitled to time with the child may not object
to the move but may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to health
and safety.
If information is protected under a court order or the address confidentiality program, it
may be withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may put the
health and safety o f a person or a child at risk.
If no objection is filed within 30 days after service of the notice of intended

relocation, the relocation will be permitted and the proposed revised residential
schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection to the
childs relocation whether or not he or she received proper notice.
(Objection to Relocation/Petition for Modification o f Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
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.
If the objecting person schedules a hearing for a date within 15 days o f timely service o f
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.
IV. Decision Making

4.1
Day to Day Decisions

Each parent shall make decisions regarding the day-to-day care and control of each child
while the child is residing with that parent. Regardless o f the allocation o f decision
making in this parenting plan, either parent may make emergency decisions affecting the
health or safety of the children.
4.2
Major Decisions
Education decisions
joint
joint
[]
mother
[]
father
[x]
[]
mother
[]
father
[x]
[x ]
mother
[]
father
[]
joint
[]
mother
[]
father
[]
[]
mother
[]
father
[J
[]
mother
[]
father
[]
[]
mother
[]
father
[]
mother
[]
father
[]
[]
mother
[]
father
[]
joint
joint
joint
joint
joint
joint
4.3

[x ]
[]
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
above.
Sole decision making shall be ordered to the [ ] mother [ ] father for the
following reasons:
[]
A limitation on the other parents decision making authority is mandated
by RCW 26.09.191 (See paragraph 2.1).
[]
[]
(a)
(b)
(c)
(d)
[]
The existence o f a limitation under RCW 26.09.191;

The history o f participation of each parent in decision making in
each o f the areas in RCW 26.09.184(4Xa);
Whether the parents have demonstrated ability and desire to
cooperate with one another in decision making in each of the
areas in
RCW 26.09.184(4Xa); and
The parents geographic proximity to one another, to the extent
that it affects their ability to make timely mutual decisions.
There are limiting factors in paragraph 2.2, but there are no restrictions on
mutual decision making for the following reasons:
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
modify the plan or a motion for contempt for failing to follow the plan.
Disputes between the parties, other than child support disputes, shall be submitted to (list
person or agency):
[]
counseling by______________________________________ , or
[x ]
mediation b y __Compassionate Resolutions________________________ , if this

box is checked and issues of domestic violence or child abuse are present, then
the court finds that the victim requested mediation, that mediation is appropriate
and that the victim is permitted to have a supporting person present during the
mediation proceedings, or
[]
arbitration b y _______________________________________.
[]
[]
[]
____50______ % mother_____ 50_____ % father.

based on each partys proportional share of income from line 6 of the child
support worksheets.
The dispute resolution process shall be commenced by notifying the other party by [ ]
written request [ ] certified mail [x ] other: e-mail

(a)
(b)
(c)
(d )

Unless an emergency exists, the parents shall use the designated process to
resolve disputes relating to implementation of the plan, except those related to
financial support.
A written record shall be prepared of any agreement reached in counseling or
mediation and of each arbitration award and shall be provided to each party.
I f th e c o u r t f in d s th a t a p a re n t h a s u s e d o r fru st ra te d d ie d is p u t e r e s o lu t io n
p r o c e s s w i t h o u t g o o d r e a s o n , t h e c o u r t s h a l l a w a r d a t t o r n e y 's f e e s a n d f i n a n c i a l
s a n c t io n s to th e o t h e r p a re n t.
(e)
The parties have the right of review from the dispute resolution process to the
superior court.


[]
[x ]
Does not apply.

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

Signature

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and
approved as an order o f this court.
Warning: Violation o f residential provisions o f this order with actual knowledge of its terms is
RCW 9 A .40.0 70(2). Violation o f this order may subject a violator to arrest.
When mutual decision making is designated but cannot be achieved, the parties shall make a
good faith effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parents obligations under the
plan are not affected.
Dated:
Judge/Commissioner
Presented by:
Approved for entry:

No.
Signature of Party or Lawyer/WSBA
Print Name
Print Name
E-FILED
October 09 2009 12:37 PM
KEVIN STOCK
COUNTY CLERK
IN T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
IN A N D F O R P IE R C E C O U N T Y
No. 08-3-00821-4
IN R E :
R E L O C A T IO N :
O R D E R A S S IG N IN G
Petitioner(s)
C A S E T O F A M IL Y
C O U R T
& N O T IC E O F H E A R IN G
Vs.
C H R IST O PH E R L E E H A R R ISO N
(A ST R E L O )
R espondent(s)
This case is determined to be a family court matter (RCW 26.12.010) and has been assigned to
F A M IL Y
C O U R T - 1,
Judge S T E P H A N IE A . A R E N D .
N o t ic e to O b j e c t in g P a r t y :
Once the objection is filed, the objecting party shall serve a copy of this Notice & Order on the relocating party. (RCW
25.09.480)
T r ia l D ate :
Hearings involving relocations or intended relocations of children are to be accorded priority by the court. (RCW
25.09.560.)
A s s ig n m e n t to S e t T r ia l D a t e
F r id a y - O c to b e r 23, 2 0 0 9 9 :0 0 A M
A t th at tim e, the court w ill provide y ou a trial date fo r hearing the o b jection to relocation. Failure to appear w ill result in the dism issal
o f the objection and allow ing the relocation.
Dated: October 9, 2009
Judge: FAMILY COURT - 1

Department AREN
Pierce County Superior Court: County-City Building, 930 Tacoma Avenue South, Tacoma WA 98402.
Oct 9, 2009 12:37 PM
5165
' 2S99
998246
33037094
06-3-00821-4
10-19-09
RSP
IN C0UNTYF C L E R K S OFFICE
0 C l l 6 i m

County of Pierce
In re:
No. 08-3-00821-4
Child(ren),

and
Petitioner,
Respondent.
Response (Objection to
Relocation/Petition for
Modification of Custody
Decree/Parenting Plan/ Residential
Schedule)
(RSP)
Check box if petition is attached for:
[} Order for protection DV (RTORPRT)
[ j Order for protection UH (PTORAH)
To: Christopher Lee Harrison
I. Response
1.1
Admissions and Denials

The allegations of the objection/petition in this matter are admitted or denied as follows (check
only one for each paragraph):
Paragraph of the Petition
LI
L2
[x]
1.3
1.4
[x]
2.1
[x]
[x]
2.2
[x]
3.1
3.2
[]
3.3
[x]
3 .4
[x]
[x]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[]
[]
[]
[]
[x]
[]
[]
[]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Den ied
[J
[]
[]
[]
[1
[]
[x]
[]
[]
[]
Resp (Obj to Relocation/Pet Mod P Plan) (RSP) - Page 1 of 4

WPF DRPSCU 07.0730 Mandatory (6/2008) - R C W 26.09.260(6), .480, .520
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
P .H .
3.5
3.6
3.7
3.7.1
3.7.2
3.7.3
3.7.4a
3.7.4b
3.7.5
3.7.6
3.7.7
3.7.8
3.7.9
3.7.10
3.8
3.9
3.10
3.11
[x]
M
[]
[]
[x]
[]
[]
[]
[]
[x]
[]
[]
[]
[]
[]
[]
[]
[X j
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[x]
[x]
[]
[x]
[x]
[x]
[x]
[]
[x]
[x]
[X]
[X]
[X]
[X]
[X]
[ ]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[3
[3
[3
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Each allegation of the petition that is denied, is denied for the following reasons (list separately):
3-1
Relocation of the child should not be restrained because the child will be moving with the parent
who takes care of almost all of his needs- including financial, physical, spiritual, emotional, medical,
educational-etc. He is very comfortable with his step-father and calls him dad The childs halfbrother and half- sister will be moving with him, as well.
3.7
The detrimental effects of allowing the child to move with the relocating parent do not outweigh the
benefits of the move to the child and the relocating parent.
3.7.1
While the child has a lot of relatives in Western WA. he also has relatives in Idaho, Utah, Eastern
WA., and Canada The child will be able to visit his relatives as well as see his older half-sisters who
do not live with either their biological father or their biological mother.
The childs relocating parent has been the one to make sure the child maintains contact with the
half-sisters. The modified parenting plan includes visitation with the objecting party.
3.7.3
Does apply Explain: It would be more detrimental to disrupt contact between the child and the
relocating party because the 4 yr. old child has spent most of his time (approximately 98%) with the
relocating parent
3.7.4a Does apply- detail proof of RCW 26.09.191

March 2002 - Hospitalized for bi-polar disorder, and suicidal ideation, (eight days)
Sacred Heart Medical Center, Adams County Mental Health Center.
Thirteen year old step-daughter (previous wife) made him angry. Opposing parent fractured
his fist when he hit the shower door where the step-daughter was hiding. Fist was casted.

*982!
September 2003 - Involuntary hospitalization, detained due to depression, suicidal Ideations and a
plan. Referred by Patrice Dial, CDMHP of Adams County.
Lourdes Medical Center PCI, Richland, Washington
2005 Pregnant wife (relocating parent) discovered that Chris (opposing parent) knowingly was
transporting the children and herself with a revoked/suspended driver's license.
2005 - Fired from job for lying to employer about having a valid driver's license.
2005 Drove wifes car without permission or valid drivers license, totaled her car in an accident.
2005 - violated his court probation (unknown to new wife)
2006 - Opposing parent received nearly $20,000.00 insurance settlement from the accident. The
money was placed in his personal bank account.
2006 - Spent five days in jail for violating probation.
2006 - Claimed he couldnt get a job because he wasnt allowed to drive, leaving the majority of
the family financial responsibility on the relocating parent, as well as, all transportation.
2006 - Relocating parent got counseling for step-daughter, Katie. Opposing parent was
investigated by CPS for reported child abuse. Child too afraid to come forward.
2007 - Voluntarily Hospitalized for suicidal ideations, (ten days)
St. Josephs Hospital, Tacoma, Washington
2007 - Family was being evicted from their home because opposing parent was not paying the rent
and hiding the notices while the relocating parent was at work. Notice of the eviction came
to light because opposing parent was in the hospital and could not hide the mail.
2007 - Opposing parent threw relocation parent down a half flight of stairs. Would not allow
relocating parent to leave with the traumatized children. 911 was called.
(See Exhibit Number 1)
2007 Opposing parent was asked to leave the home permanently. He abandoned and neglected
his children for several months, including no financial support. Never supported them at
school activities or banquets. He refiised to answer the childrens calls or visits to his home
on the holidays. Later he sporadically allowed some calls and visits. Still, a lot of
emotionally abusive behavior went on.
2007 - 2008: Relocating parent had full responsibility of opposing parents two daughters and son.
2008 - Relocating parent took a medical leave of absence from work to get help for seriously
traumatized 12-year-old step-daughter, (feeling suicidal, and aggressive behavior)
2008 - Father (opposing parent) took the fourteen-year-old daughter out of stepmothers home in a
very traumatic way and instigated a breach between the step-daughter and step-mother,
which has never been able to be bridged.
vf <4.
'
2008 - Relocating parent discovered that opposing parent was having the fourteen-year-old
daughter drive him home when he was too drunk to drive. Relocating parent tried to discuss
serious concerns with this behavior, an argument developed, so relocating parent left the
yard and went home.
2008 Relocating parent would not answer her phone so opposing parent started to drive to
relocating parents home. He was stopped by the police on the way and arrested for an
outstanding warrant for Domestic Violence. Officer called relocating parent and asked if
she would be able to come and pick-up his possessions so they would not go with the
impounded vehicle. The relocating parent was also asked to go to the opposing parents
home and pick up the fourteen-year-old child and move her back home.
2008 - 2009: Convicted on the DV charge and interference with a 911 call. Jail time was served
and the Domestic Violence No-Contact Order issued for cause # 7YC010751, was issued
as a condition of the defendants sentence. Valid until July 15, 2010.
2008 - 2009: Opposing parent wrote letters to daughter, Katie, from jail stating that he was hearing
his dead sisters voice telling him to do wrong things. His dead sister committed suicide
and he told Katie that he was concerned she could be going down the same path as his sister
because Katie looks like his sister and was named after her.
2009 Opposing parent told three-year-old son a permanent goodbye because daddy was going
to be dying, he had the child veiy upset. Opposing parent talked with relocating parent
about his suicide plans, which included a shotgun, and it involved taking out three past
employers he felt had done him wrong . The swat team picked up opposing parent and took
him to jail on suicide watch.
The relocating parent has documents and letters concerning many of the listed offenses above, and
will be happy to show them to the court if the court wants to see them.
3.7.4b See above 3.7.4a
307.5
The relocating party and husband have been struggling financially to maintain two separate
households until the move can be made. The relocating party has had full financial responsibility for
' the child for the past two years, and will make certain that the child is always taken care of.
The child will continue to have visits with all his family, and will have an opportunity to meet some
new distant cousins and make some new friends. The relocating parent sees this as a wonderful
growing opportunity for the child. The move allows the family to reunite.
3.7.7
While the child has a good quality of life here with many opportunities, he will have an equally
wonderful quality of life in the new location. The relocating parent has checked out the new
location. It will provide a close knit community that is very family friendly and supportive. The
relocating parent is looking forward to the added help, support and stability that a two parent family
will provide.
Resp (Obj to Retocation/Pet Mod P Plan) (RSP) - Page 4 of 4

-*_' --
3.7.8
The opposing parent has opportunities to see the child as designated in the parenting plan. The
relocating parent wants the child to continue a relationship with the opposing parent and will help to
accommodate the time, but limitations imposed under RCW 26.27.211 are due to the opposing
parents own behavior and mental health issues:
Abandonment and neglect of his children,
Abusive behavior with children,
Driving the three year old child without a car seat,
Forcing fourteen year old daughter to drive him because he was drunk,
Domestic violence conviction,
Driving drunk,
Driving with open alcoholic container in the car,
Driving with revoked/suspended license,
Multiple arrest warrants and jail time,
Alcohol and drug addiction,
Diagnosed bi-polar disorder,
Suicidal Ideologies and hospitalizations.
3.7.9
My husbands job is not transferable to this area. We would have located in this area if we could
have. 1 do have some family in Idaho, but will always maintain a close contact with my family here.
3.7.10 The financial impact and logistics of maintaining two separate households is very difficult and we
are looking forward to the relief from stress that the relocation and combining the two households
will afford us. The children are having difficulty with the relocation up in the air like it is.
3.8
The objecting parent is subject to limitations under RCW 26.09.191. The relocating parent will
make every effort for the child to see his biological father on a frequent basis, but as per the original
parenting plan he must not drink within 8 hours of seeing the child, transport the child only with a
licensed, insured driver with appropriate safety seat restraints. And the opposing party needs to keep
the relocating party informed of his current address.
3.9
The relocating parent requests that the relocation be approved, and the proposed relocating
parenting plan be ordered.
3.10
The relocating party did not ask for the current court order, but the Judge ordered a two year
Domestic Violence No-Contact order on, July 15, 2008. The order was issued for cause
# 7YC010751 and the expiration date is, July 15, 2010. (See Exhibit N um ber 4)
1.2
Reasons for the Relocation of the Children

Reasons for the relocation of the children are stated in the Notice of Intended Relocation of
Children filed with the court.
Resp (Obj to Relocation/Pet Mod P Plan) (RSP) - Page 5 o f 4

1.3

Notice of all further proceedings in this matter should be sent to the address below.
1.4
Other
Letter of Recommendation to Jolene Harrison (aka: Jolene Charlton)
from Darlene Hagel, Respondents Mother
Letter of parental knowledge from Kim Sherwood
Certificate of Training: Post Traumatic Stress Disorder, six hour workshop

March 20, 2008, trainer: Randi Hankins CSW CMHS, DSHS Resource Family Training
Relocating Parent, Jolene Charlton, took the State Mandatory Parenting Class.
Opposing Parent, Christopher Harrison, Refused to take the State Parenting Class.
II.
2.1
Request for Dismissal

[]
[X]
2.2
Requests
Does not apply.

The non moving party requests that the objection/petition be dismissed.
Request for Relief

[]
[X]
[]
Does not apply.

The relocating party requests that the court enter an order permitting the relocation and
approving the proposed parenting plan/residential schedule, which is filed with the Notice
of Intended Relocation of Children or attached to this response.
The nonmoving party requests that the court 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 or attached to this response.
Protection Order:
[]
[]
There is a protection order between the parties filed in case num ber_______________ ,
court ________________________ , which expires on (date)
_______________.
The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this response.
[ ] filed separately under [ ] this case number [ ] case number _____________________
Violence forms or RCW 10.14 Anti harassment forms.
[]
Dated: 0 c
Other:
Up , i D o q
Notice to party: you may list an address that is

not your residential address where you agree
to accept legal documents. Any time this
address changes while this action is pending,
you must notify the opposing parties in
writing and file an updated Confidential
Information Form (WPF DRPSCU 09.0200)
with the court clerk.
Y \a n \J u
____
Signature of Nonmoving Party or Lawyer/WSBA No,
Jolene Marie Charlton_______________________
Print or Type Name
12107 209th Ave. Ct. E.______________________
(Address)
Bonnev Lake. WA. 98391___________________

WPF DRPSCU 07.0730 Mandatory (6/2008) - RCW 26.09.260(6), .480, .520
E-FILED
October 20 2009 9:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


Petitioner(s),
NO. 0 8 - 3 - 0 0 8 2 1 - 4
vs.

Respondent(s)
N AMEJO L E N E M A R IE H A R R IS O N
A D D RESS- 12107 209T H A V E CT E
' B O N N E Y LA K E , W A 98391
PH O N E:
Petitioner
N ature o f Case: C N T EM p F C U R T
13 (M O) Show C ause/Fam ily Law , C onfirm ation R eq u ired............................................................ (9:30 M on.- Thurs.)
(YY)
(OE)
(UD)
(GD)
(DD)
(FC)

U ncontested D issolutions, No C onfirm ation R eq u ired ................................. w /A ttorneys (3:00M on.- Fri.)
today w ith the C lerk o f the Court.
D ated: O ctober 20, 2009
N A M E:
A D D RESS: 6721 N A T H A N AVE. SE
A U B U R N , W A 98092
Signed:/s/ C H R IST O PH E R L E E H A R R ISO N

PH O N E:
R espondent
page 1 o f 1
5199
FI LED
06-3-00821-4
33044163
DCLR
10-20-09
a.m.
OCT 1 9 2009 M-
p i e r c e c o u n t y , Wa s h i n g t o n

County of Pierce
In re:
No. 08-3-00821-4
Petitioners),
and
Declaration of
William R. C. Charlton [Name]

Respondents).
(Optional Use)
(DCLR)

Name:
William R. C. Charlton_____
Age:
35 Years___________________________
Relationship to the parties in this action: Husband of Jolene Marie Charlton
I Declare:
The following are rough dates and estimates on times and events i recall regarding Christopher Lee Harrison and the
events that have transpired over the last several months.
Christopher Harrison demonstrated social and behavioral problems
May 2009 - was residing in jail when I first met Jolene, and then was placed in a half way house. 1 read messages to
Jolene from Mr. Harrison regarding his time in the half way house.
June 2009 - according to text messages received by Jolene, which 1 read, apparently sometime, Mr. Harrison had
moved in with his girlfriend, and they refused to give a physical address to Jolene, I advised Jolene that for CJs well
being that she should not allow him to see his Father without a proper residential address first.
June - Current 2009 - Mr. Flohr has numerous times violated a court ordered restraining order against him
contacting Jolene, as he has called the house and text messaged her numerous times. Even being insulting in several
messages I have read.
Sept 2009 - Chris sees Cj after finally submitting his address (only after Jolene had already found it from other
sources to file court papers), and Jolene permits Mr. Harrison time with CJ, and arranges time for returns.
Declaration (DCLR) - Page 1 o f ____
WPF DRPSCU 01.0100 (6/2006)
SX33
i-8y2y-289
October 2009 - Jolene calls me very distraught as Mr. Harrison refused to deliver CJ to the Jolenes parents home at
the appointed time forcing Jolene to retrieve CJ from Mr. Harrison home that night
October 2009 - Mr. Harrison continues to violate the restraining order as he continues to call, and text Jolene.
Two households to cover expenses for
Currently, we are maintaining two households, with two separate expenses associated with this, as I am needing to
reside in Idaho with my occupation and she in Washington pending the outcome of the courts decision.
Bonding with the Children - Almost immediately CJ began calling me Daddy, without prompting from anyone.
And runs up to give me a hug every time he sees me. I anticipate that this bond will grow stronger over time.
My personal testimony and thoughts as well as Commitment to the well being of the Children
In the time I have dated and been involved with Jolene, CJ has seen Mr. Harrison only a handful o f times recently,
through various reasons such as Mr. Harrison being in jail, and at other times refusal to provide the exact address to
Mr. Harrisons physical location. Wherever possible, Jolene has encouraged CJ to spend time with his Dad, taking
into consideration child risks, such as discovering once that Mr Harrison had driven CJ, while being without a
drivers License. Jolene works hard to ensure that her children maintain some level of contact with their fathers even
though Mr. Harrison has never paid Child support or attempted to, in any way, provide for the financial needs o f the
Children.
When I married Jolene I told her that I would do treat these Children as though they were my own, and so 1 intend to
do, including meeting their financial, religious, mental, social and physical needs. By all sense of the word, these
children I WILL treat as my own.
(Attach Additional Pages if Necessary and Number Them.)

correct.
Signed at Bonney Lake, [City] Washington [State] on October 19, 2009 [Date].
William R. C. Charlton
Print or Type Name
Do not attach financial records, personal health care records or confidential

reports to this declaration. Such records should be served on the other party and
filed with the court using one o f these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records will be sealed to protect your
privacy (although they will be available to all parties in the case, their attorneys,
court personnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 2 o f_

WPF DRPSCU 01.0100 (6/2006)
5 IS S
08-3-00921-4
33044169
i- 8 A 2 & ^ 2 .8 S
23B18'
FI LED
DCLR
IN COUNTY C L E R K S OFFICE
10-20-09
OCT 1 9 2009
a .m .
P'M'

KEVIN STO CK, County Clerk
RY
_________
DEPUTY
f

County of Pierce
In re:
Petitioner(s),
and
N o. 08-3-00821-4
Declaration of
Katherine Avers
Namel
Respondent(s).
(Optional Use)
(DCLR)
Name:
Katherine Ayers
Age:
61
Relationship to the parties in this action: Guardian of Kathrina Harrison, child o f Chris Harrison
I Declare:
ABANDONMENT. NEGLECT. EMOTIONAL ABUSE
AND NON-PERFORMANCE OF PARENTING FUNCTIONS
I have had voluntary guardianship of Kathrina Harrison, age 14. since April 2008.
When I received
this child she was very fragile emotionally. Her father had abandoned her many times in her short life, but
usually there was a plan as to how and where she would live without him. Chris had again abandoned his
children with no explanation or plan for reunification even after several months' absence. Both Kathrina
i Katie 1 and her sister Aivssa were acting out in inappropriate wavs and it was determined that they should
be separated for their own safety and well-being. Kathrina was taking 2 antidepressants as well as an anti
Declaration (DCLR) - Page 1 o f ____
WPF DRPSCU 01.0100 (6/2006)
5-5/99
re / < / 8 v ^ :e 0 5
anxiety medication and she underwent more than a year of counseling before she could face her life.
2 & & 1-86
Our
life together began when I took her home from a mental health facility where she was placed after a suicide
attempt. Katie has a tremendous amount of anger against her father for a lone list of grievances and has
attempted to share her feelings with him many times. Chris, however, wants to take no responsibility for
his daughters anger and is insulting demeaning, and off-putting when Katie wants to discuss their
relationship. He has even gone so far as to tell her that he doesn't know if he is her real father. Tm sure
the court is aware o f Chris recent history and thus knows that he is vet unable to care for any of his
children financially but I would like to add that I have not seen much ability or effort to care for them
emotionally either.
FIRST VISIT IN PAST YEAR
Although he has lived less than 40 miles awav. Katie has only been invited to visit with her father
twice in the past year, both times at the home of his girlfriend. Charlene, and both times a disaster. After
the first visit Chris took an offhand and innocent remark that Katie made to her step-mother as she was
telling Jolene about her visit and made it into what he believed was a deliberate, personal attack on the
girlfriend Katie did an excellent job of explaining herself (I was beside her as she talked to him via phone),
however Chris would not listen to her and was unbelievably harsh even when Katie was obviously sohhingChris eventually discovered the truth of what Katie had told him and he apologized to her, unfortunately
not before reconfirming himself to Katie as someone who feels she is corrupt and detestable and not worth
loving.
Because of the damage that was done unnecessarily bv Chris both to Katie and to her new
relationship with the girlfriend, it was several months before Katie was again invited for a visit.
In the interim Katie would try to share things that were happening in her life with her father, some
serious things at school and, rather than rushing to her defense as would be normal for a parent to do. Chris
put his daughter off bv saving he didn't think she was telling the whole story and that he wanted to call the
school to get *~the real storv. He never did call the school and Tm sure he has long forgotten the incident but Katie does not bother to call him anymore to tell him about things that are going on with her life.
LAST VISIT FOR PAST YEAR
The second visit with her father made Katie so uneasy that she called her step-mom to come get her and
take her home. Jolene didn't have Chris girlfriend's address so didnt know where Katie was and didnt
feel Chris would approve of Jolene picking her up. Jolene encouraged Katie to finish the visit and go home
as early as possible the next morning, or to call me if she felt she could not stay any longer. Katie came
Declaration (DCLR) - Page 2 of __________

WPF DRPSCU 01.0100 (6/2006)
51^*9
2 a .i'e 7
home the next morning vowing that she wouldnt go over there again. When 1 asked her why, she simply
stated that her Dad always makes her feel bad about herself and is constantly scolding her.______________
LACK OF COMMUNICATION AND MORE EMOTIONAL ABUSE
I am sorry to sav that Chris does not ever phone his daughter.
Katie always initiates the
communication - she even calls Chris to tell him that it is her birthday so that he can sav happy birthday
to her. No card, present or call comes for Christmas, graduation or anv other time. Chris last talked to
Katie more than 3 months ago, on July 1st. It was not a pleasant conversation because Katie again tried to
get her father to understand whv their relationship was strained and Chris would have none of it. I have
talked to Chris at length about his problems with Katie (more than once) but nothing seems to have an
impact or prompts a chnngp in behavior. Chris has made no offer of financial or in-kind support for Katie
since 1 have had her.
FINAL OBSERVATIONS AND RECOMMENDATION
There is a reason that none of Chris Harrisons four children are living with him and I hope that the
court will see that his years of verbal abuse, neglect and abandonment clearly show the pattern o f an
uncommitted, even dangerous parent.
To think that he would suddenly change into a reliable, loving,
unwavering support for his children (anv of them! is not realistic. 1 don't feel that his 4 year old son. CJ.
would miss anything bv moving out o f state, with occasional visits with his father as may be required by
the court. In fact from what 1 know about his mother and new stepfather. I think CJ will have much to
gain with this move.
t have become very well acquainted with Jolene Charlton since taking Katie into mv home. She has
always had the best interest of the children at heart, and has carried an unbelievable load since November
2007 when Chris left the family: she cared completely for all five children (her own two children. Chriss
two daughters, and Chris
and
Jolene's son. CJ) with no financial or physical help from either father. Even
though Jolene is no longer officially Katies stepmother, they both honor and maintain their relationship bv
seeing each other regularly Katie and I are welcomed into the extended family as one of them. Katie calls
both of us "Mom" (something shes never had before). 1 provide Katies primary care and Jolene adds
continuity to the bonding that began over five years ago. Jolene is a wonderful mother to her children.
I had heard many good things about Will Charleton before I met him, some of them from church
leaders and people who had known him several years. I was pleased to have mv impressions o f him live up
to mv expectations. Although 1 am thrilled for Jolene to have found such a fine new husband: 1 am even
happier for the children to have pained a righteous father. I was impressed with how loving and gentle Will
Declaration (DCLR) - Page 3 of __________
WPF DRPSCU 01.0100 (6/2006)
ir 3 ^
2 .0 .^ 2 ^ 8 1?
is with the children and how positive and enthusiastic he is about life. He is a natural teacher and I know
he will be an involved, caring and self-sacrificing father to them all. The fact that Will is employed in
fHahn with his own business is another obvious benefit to the children. Even though the family will be
leaving behind much-loved family members and friends. I believe the move to Idaho will be in everyones
best interest. We already know that Katie will be making visits there to keep connected to Jolene and
family: Jolene has made it clear that visits to this area will include Katie.
I declare under penalty of peijury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at Tacoma, WA on 15 October 2009
ru>-P (Vyg-tS_______
Signature o f Declarant
^
Declaration (DCLR) - Page 4 of_

WPF DRPSCU 01.0100 (6/2006)
Katherine Ayers
Print or Type Name
W fT T W lO
.3-0OB21-4
FILED
IN C O U N T Y C L E R K 'S O FF IC E
A.M.
OCT 1 9 2009
p.m.
P IER C E COUNTY, WASHINGTON
j$ EVlN STOCK, County ^ f r

County of
In re:
No. 08-3-00821-4
Child(ren),

Petitioners),
and
Motion/Declaration for
Temporary Order Permitting
Relocation of Children and
Temporary Parenting Plan
(MTAF)
Respondent(s).
I. Motion
Based upon the declaration below and pursuant to RCW 26.09.510(2), the undersigned moves the court
for a temporary order authorizing the intended relocation of the children pending final hearing.
Dated: b h
l Cj /
(m L , '
C l n n b t T r h . _____
Signature of Moving Party or Lawyer/WSBA No.
Jolene Marie Charlton______________________
Print or Type Name
II. Declaration
2.1
The Notice of Intended Relocation of Children.

[X]
The required Notice of Intended Relocation of Children was provided in a timely

manner. Proof of Service of the Notice of Intent to Relocate has been filed or is being
filed with this motion.
Mot/Dect for Temp Ord Permit: Reloc (MTAF) - Page 1 o f 3

WPF DRPSCU 07.0870 (6/2006) - R C W 26.09.510(2)
[]
2.2
I request a temporary order permitting the intended relocation pending final hearing because:
The relocating family must maintain two separate households until the relocation takes place.
This situation creates an unnecessary financial burden and stress on the relocating family.
The relocating family has been in this divided situation for nearly two months now.
The other children are getting further and further into the new school year and need to settle
into their new school.
The children are distressed by the uncertainty created by the disagreement between the
relocating and objecting parents.
This distress is causing more acting out by the children, and the objecting parents encourage
this bad behavior.
The objecting parent has not asked for custody of the child, just that he be allowed more
visitation time and the relocating parent not be allowed to move.
The objecting parent provides no financial support for the child and the relocating family
needs the finanacial relief that the move will provide.
The relocating parent cannot give two weeks notice at work until the move is approved by
the court.
There is a likelihood that on final hearing the court will approve the intended
relocation of the children.
The relocating parent has family here and can return for any necessary court hearings.
2.3
Based upon the following circumstances, the court should permit the intended relocation
and issue a revised parenting plan/residential schedule in the absence of compliance with
the notice requirements:
[]
Service member or dependent of service member:
If the nonmoving party is not present and:

a) is on active duty and is a National Guard member or Reservist residing in Washington, or
b) is a dependent of a National Guard member or Reservist residing in Washington on active duty,
list the reasons why this temporary order should be granted despite the absence of the other party:
2.4
Other: J request a temporary order permitting the temporary parenting plan pending final
Mot/Decl for Temp Ord Permit: Reloc (MTAF) - Page 2 of 3

WPF DRPSCU 07.0870 (6/2006) - RCW 26.09.510(2)
S 199
1 8 f- Z 0 ^ 2 6 8 9
29S i l l
hearing to accommodate the relocation.
correct.
Signed at f c o n n e y
, [City]
[State] on
/Signature o f Moving Party

Print or Type Name
Mot/Decl for Temp Ord Permit: Reloc (MTAF) - Page 3 of 3

WPF DRPSCU 07.0870 (6/2006) - RCW 26.09.510(2)
l3 j Z o c fi
[Date],
s2 2 2
08-3-00821-4
33046187
DCLR
1 /-2 1A 2 89 #1324
10-20-09

County of
In re:
no.
Petitioners),
and
$ -3 - ^
Declaration of

a.k.a. Jolene Marie Harrison
Respondent(s).
[Name]
(Optional Use)
(DCLR)

Name:
__Alyssa Rae Harrison____________
Age:
_ 16_____________________________
Relationship to the parties in this action: ^Daughter to

Petitioner
/ Declare:
Mv name is Alyssa Harrison and 1 am 16 years old. Jolene used to be mv step mom, she was
married to
mv dad but they got a divorce, so 1 staved with her for a while when mv dad moved out, t took on
a lot of
responsibility when that happened. 1 went to school, went to help mv friend with daycare, then
came home
to clean and cook for mv 3 siblings, then I had to clean t he whole house or it would get really
messy and I
would get into trouble.And I had to do this every dav. Even though 1 didn't make Enough money
like mv step
220
1 0 / 2 iV 2 0 9
mom did I felt like the mom o f the house. I would stay up till 10 or 10:30 doing everything, and
mv step mom usually
wouldn't get home till 10 or even when Im sleeping when she gets off work at 7.
If Jolene takes Cj to Idaho she is taking him away from his dad, his sister Kate, me and his
huge extended family.
He won't see all of his family members here that he sees a lot.My dad does a lot for Ci. Ci is mv
dads only boy.
and he is so hapovwith him. Evervtime I'm at mv dads and Ci is there he is playing with Ciand
always making Ci
laugh.I don't think it's right for mv step mom to take Ci away from his real dad. 1 don't think she
should take Tyler and Hannah away from their dad too.Mv dad is a good guv and dosen't deserve
to get his son taken away from him.

I declare under penalty o f peijury under the laws of the state o f Washington that the foregoing is
true and correct.
Signed at
U 4&
m O
[City] jjd O ^
^ f
if
Cy
[State] on
Alyssa Harrison
Print or Tyi
Type Name
Do not attach financial records, personal health care records or

confidential reports to this declaration . Such records should be
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial
records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health
records
If filed separately using a cover sheet, the recoids will be sealed to protect
your privacy (although they will be available to all parties in the case, their
attorneys, court personnel and certain state agencies and boards.) See GR
22(C)(2).
g25
08-3-00821-4
33046198
DCLR
10-20-09
IN
COUHrf&ED
CLERK'S
**- Oct 2
PIERCE
0 2003

County of
No. 0 8 ^ -0 0 8 2 1 -4
Petitioners),
and
Declaration of
_Joe Flink
fNamel

Respondents).
(Optional Use)
(DCLR)

Name:
Age:
PM.
D E P U T Y
In re:
OFFICE
_Joseph M Flink______
43_________________
Relationship to the parties in this action:

room ate
/ Declare:
That 1 have witnessed Chris call his ex-wife several times to try and see his bov. He was told
no. Chris does not get to see his boy on any reular schedule. In the last six months Chris has had
his bov (C.J.L four or five times. The four or five times that Chris has seen C.J. has been with in
the last two months.
I have been roommates with Chris for about Six Months. Chris has tried to get to see C.J. ever
since 1 have known him.______

I declare under penalty o f peijury under the laws o f the state o f Washington that the foregoing is
true and correct.
T 8 Z 2 1/2:889
S t a t e ] o n ___O c t o b e r 1 9 , 2 0 0 9 ___[ D a t e ] .
Joseph M Flink
Print or Type Name

confidential reports to this declaration. Such records should be served on
the other party and filed with the court using one o f these cover sheets:
records
records
If filed separately using a cover sheet, the records will be sealed to protect
22(C)(2).
68827
S-224*
08-3-00821-4
33046200
DCLR
Sgg
10-20-09
OCT 2 0 2009 PiB;
A..
KEVIN
BYJ__

County of
- -4- deputy
l
In re:
Petitioners),
and
No. 08-3-00821-4
Declaration of
_Karleen Seigle
fNamel
Respondents).
(Optional Use)
(DCLR)
Name:
Age:
Karleen
____________ 38________________________________
Relationship to the parties in this action: _______________________friend of

respondant_____________________________
/ Declare: Since March o f 2009 I have witnessed on numerous occasions Mr. Harrison
repeatedly calling and texting and emailing Joleen the mother o f his son C.J. Harisson, in
repeated attempts too have all and any contact with his son* In my presence I have witnessed
most of these occasions too have no responce from Joleen, and the few responses I have seen
from her were about her and what she wanted from Mr. Harrison and it seemed her conceme was
never o f their son C J. Harrison but of her control o f the cituation and on her.

I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
true and correct.
[City]
l Q l \ ___ __ [State] on
Print or Type Name
Do not attach financial records , personal health care records or

confidential reports to this declaration. Such records should be served on
the other party and filed with the court using one o f these cover sheets:
records
records
22(C)(2).
08-3*00021-4
MTSC
33046201
10-20-09
W COUNt T CLERK'8 OFFICE
y,
OCT 2 o 2009
^ n r ^ O U N T Y . WASHINGTON

County of
In re Parentage:
No.
and
Petitioner,

and
Respondent
Motion and Declaration for an Order

to Show Cause re Contempt
(Parentage)
(MTSC)
Respondent.
I. Motion
[Namel moves the court for
an order directing Jolene Charlton_____________________________________ [Name] to
appear personally before the court and show cause why an order should not be entered.
1.1
Finding Contempt
[]
[x ]
Does not apply.

Finding contempt for failure to comply with:
[]
[x ]
[]
[]
the order of child support.

the residential schedule/parenting plan.
the restraining order.
other:
entered on lO-l 7-2008_______________ [Date] in Pierce County, WA

_______________________________ [County and State].
1.2
Establishing a Judgment
[x ]
[]
1.3
Does not apply.

Establishing a judgment in the amount of $__________ plus
$__________ interest for delinquent child support and $________ costs for the
period from _____________ [Date] through________________ [Date].
Granting Sanctions
[]
[]
Does not apply.

Granting sanctions for contempt, including a forfeiture for each day the contempt
o f court continues, and establishing conditions by which the contempt may be
[]
[x ]
Imprisonment is sought as a sanction.

Imprisonment is not sought as a sanction.
1.4
Other
Christopher Harrison requests that missed days with his son Christopher Lee Harrison Jr. be
made up in a timely manner.
This motion is based upon the declaration which follows.
Dated: _
o *!
featu re o f Moving Party or
Lawyer/WSBA No.
Chris Harrison
Print or Type Name
II. Declaration
Jolene Marie Charlton______________________________ [Name] should be held in contempt
for the following reasons:
[]
Failure to comply with the provision o f the child support order which directed payment
of:
[]
[]
current support in the amount o f $__________ per month.

day care or special expenses/extraordinary costs/educational expenses or provide
health insurance coverage as described below:
[]
Other:
[x ]
Failure to comply with the residential schedule/parenting plan as follows: Jolene refused
to let me see my son when 1 enerted clean and sober housing, claiming that she did not
know the other people in the house. Once I moved into a private house Jolene still
refused to let me see my son saying for his safety she could not let him stay over untill
she had my address, after she let him stay 1 weekend with me. Jolene has a history of
driving around untill she comes across my truck then driving around my house all the
time.
[]
Failure to comply with the restraining order which required:
This order was violated in the following manner: Jolene refused to let me see my son for
8 months.
[]
Other:
I declare under penalty of peijury under the laws o f the state o f Washington that the foregoing is
true and correct.
Signed at
[Date].
h n (\
, [CityL. VV / ^ _______[State] on
l d
Signature o f Moving Party

Chris Harrison____
Print or Type Name
5228
09-3-00821-4
33046207
ORTSO
18^ 2122889
' 8 8 3 3
10-20-09
oW

County of
In re:
N o- o ^ - 3 - o e f ^ - f
A kA
^ y o k we
Petitioner,
Order to Show Cause re

Contempt
(ORTSC)
Respondent.
and
Ci/'~s7d P h
16 c?*Q
ef
It is Ordered:
(Name of nonrequesting party) J o / a f l f t C W / / * 7 ____________ _______shall appear in
person before this court at the place and time below and show cause why the relief requested in the
motion should not be granted.
.22(v
o a 7
Date:
_______ Cn&p.m.
Time:
7
Place: P i t f R e c ? c o o / v s r y
Room/Department: tOOj IQ j A
If you fail to appear in person and defend at these proceedings the court may grant all of the relief
requested and/or issue a bench warrant for your arrest without further notice to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court
to appoint an attorney to represent you.
Other:
Dated : / O
- <=> 7
missioner
Presented by;
ti
mature of Requesting Party or

o Lawyer/WSBA No.
Signature
Print or Type Name
Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1

WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW26.09.160
E-FILED
October 21 2009 11:22 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


Petitioner(s),
NO. 0 8 - 3 - 0 0 8 2 1 - 4
vs.

Respondent(s)
N AM E:
C H R IST O PH E R L E E H A R R IS O N
A D D RESS- 6721 N A T H A N A V E. SE
' A U B U R N , W A 98092
PH O N E:
R espondent
C A L E N D A R D A T E W ednesday - D ecem ber 02, 2009 at 9:30 A M
N ature o f Case: Parenting P lans/R E L O C A T IO N

M (M O ) Show C ause/Fam ily Law , C onfirm ation R eq u ired............................................................ (9:30 M on.- Thurs.)
(Y Y )
(OE)
(U D )
(G D )
(D D )
(FC)

U ncontested D issolutions, No C onfirm ation R eq u ired................................. w /A ttorneys (3:00M on.- Fri.)
today w ith the C lerk o f the Court.
D ated: O ctober 21, 2009__________________
N A M E:
A D D RESS: 12107 209T H A V E CT E
B O N N E Y LA K E , W A 98391
Signed:/s/ JO L E N E M A R IE H A R R ISO N
PH O N E:
P etitioner
page 1 o f 1
5244
i . / 2- i*'* 2 & 8 9
20025
/ filed qt
lo-n-os
.3-00821-4
33056498
DR COURT OF THE STATE OF WASHfNOTOW^

IHIN
r f '" nT
|N AND FOR PIERCE COUNTY
OCT 21 2009
cM
No. 0 8 -3 -0 0 8 2 tv^
Petitioner(s),
ierce
COU^p. Clerk
Y By.
OEPUTV
Memorandum of Journal Entry
vs.
] Show Cause
CHRISTOPHER LEE HARRISON /
(ADM02)
Respondent(s)
__ ______
Pm^
_______ f(D
For Respondent
For Petitioner
RE:__________________
___ _________ JW h
____________
?&A\
________________ PfJlkaus
October 21, 2009 9:30 AM
did
dk
appsvpAd*^ nob'te.
Show Cause
MEAGAN M. FOLEY
Clerk:
Calendar:C3 - SHOWCAUSE/FAMILY LAW
Run date/time 10/20/09 8:06
Ixcrtrpt.pbl d jouma/_enf/y_s/iowcause_report
5322
1 8 2 2 5 /288S

Cause Number: 0 8 -3 -0 0 8 2 1 -4
Petitioner(s)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: STEPHANIE A. AREND
Court Reporter: JAN-MARIE GLAZE
Judicial Assistant/Clerk: Denese Overhulse
HARRISON, JO LE N E M ARIE
HARRISON, C H R IS T O PH E R L E E
HARRISON, C H R IS T O PH ER L E E J R

Outcome Date: 10/23/2009 10:06
Resolution:
Clerk's Scom is Code:MTHRG

txcalcivii. pbl.d_ civilJoumal_report_cover
88124
5322
1 8 ^ 2 6 ^ 2 8 ^ 9 -88-1-25

MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner
STEPHANIE A. AREND
Court Reporter:JAN-MARIE GLAZE
Judicial Assistant/Clerk: Denese Overhulse

October 23, 2 0 0 9 09:55 A M This matter comes before the Court on a motion to set the trial
date.
Parties appear Pro Se.
Court/counsel collqouy.
January 2 0 1 0 at 9:00 am. Court is at recess on this matter.
JU D G E/CO M M ISSIO N ER :STEPH AN IE A. AR EN C
Year2009
Court sets Relocation trial for
1 0 - ' 2
/ 2
* 9
2 0
r *
33070511
08-3-00821-
10-23-09
F IL E D
IN COUNTY CLER K S OFFICE

a .m .
QCT 2 3 20C9

County of
In re:
No. 08-3-00821-4
Petitioner,
and
Return of Service
(Optional Use)
(RTS)
Respondent.
/ Declare:
1.
2.
I served the following documents to (name)
[]
[]
[x ]
[]
[]
[]
[]
[]
[]
[]
[]
[]
summons, a copy of which is attached

petition in this action
proposed parenting plan or residential schedule
proposed child support order
proposed child support worksheets
sealed financial source documents cover sheet and financial documents
financial declaration
Notice Re: Dependent o f a Person in Military Service
notice of hearing fo r__________________________________________
motion for temporary order
motion for and ex parte order
motion for and order to show cause re:
[]
declarations o f
[]
[x ]
temporary order
other: objection to relocation, statements for, Margie Lacy, Karleen, Kayla,
Brenda Lambert, Char, Amanda, Joe Flink, Christopher Harrison
7 6
5294
3,
___
The date, time and place o f service were (if by mail refer to Paragraph 4 below):
Date:
_ 10-09-2009__________________________ Time:
_________________ a.m./p.m.
Address:
4.
[]
[]
by delivery to the person named in paragraph 2 above.

by deliveiy to (name)_________________________________________, a person
of suitable age and discretion residing at the respondents usual abode.
by publication as provided in RCW 4.28.100. (File Affidavit of Publication
separately.)
(check only if there is a court order authorizing service by mail) by mailing two
copies postage prepaid to the person named in the order entered by the court on
(date)__________________________ . One copy was mailed by ordinary first
class mail, the other copy was sent by certified mail return receipt requested.
(Tape return receipt below.) The copies were mailed on (date)
Service of Notice on Dependent o f a Person in Military Service.

[]
[]
6.
__611 Mederian st. Puyallup, WA 98371
Service was made pursuant to Civil Rule 4(d):

[x ]
[]
5.
1:35
The Notice to Dependent of Person in Military Service was [ ] served on [ ]

mailed by first class mail on (date)_________________________________
Other:
Other:
I declare under penalty o f peijuiy under the laws of the state o f Washington that the foregoing is
true and correct.
, (state)
W A __________ on (date)l 0-
Kayla Pergrim_
Print or Type Name
Fees:
Service
Mileage
Total
___________________________
___________________________
_____________ ______ _____
(Tape Return Receipt here, if service was by mail.)

File the original Return o f Service with the clerk. Provide a copy to the law enforcement agency
W T T
52S4
18^23^2 8 8 9
where protected person resides if the documents served include a restraining order signed by the
court.
248878
1 0
2 6 ^
2 8 0
1 2 0
FILED
08- 3 - 00821-4
33071949
RTS
10-: ;3-09
AM.
OCT 2 3 2im /p.M .

KEVIN STOCK, C ounty C lrk
HV
-----QgWJTY

County of Pierce
In re:
No. 08-3-00821-4
Petitioner,
and
Return of Service
(Optional Use)
(RTS)
Respondent.
/ Declare:
1.
2.
I served the following documents to (name)

[]
f]
t]
[]
[]
[]
[]
[]
[]
[X]
[]
[]
[X]
[]
[X]

Notice Re: Dependent of a Person in Military Service
notice of hearing fo r__________________________________________
motion for temporary order permitting relocation of children
motion for and order to show cause re :___________________________
declarations of _ William R.C. Charlton. Katherine Avers___________
temporary order
other: Response (Objection to Relocation) with Exhibits
Return of Service (RTS) - Page 1 of 2

WPF DRPSCU 01.0250 (6/2008) - CR 4(g), RCW4.28.080(15)
8 8 2
5323
3.
The date, time and place of service were (if by mail refer to Paragraph 4 below):
Date:
Oct. 21. 2009_________ Time:
Address:
Pierce Co. Superior Court House.__________
_____
4.
[]
[]

by delivery to (name)________________________________________ , a person of
suitable age and discretion residing at the respondent's usual abode.
by publication as provided in RCW 4.28.100. (File Affidavit of Publication separately.)
(check only if there is a court order authorizing service by mail) by mailing two copies
postage prepaid to the person named in the order entered by the court on
(date)__________________________. One copy was mailed by ordinary first class mail,
the other copy was sent by certified mail return receipt requested. (Tape return receipt
below.) The copies were mailed on (date)_______________________________ .
Service of Notice on Dependent of a Person in Military Service.

[]
[]
6.
9:00 a.m._______ a.m./p.m.
Tacoma AVE. Tacoma . Wa.___________
[X]
[]
5.
1280
The Notice to Dependent of Person in Military Service was [ ] served on [ ] mailed by

first class mail on (date)__________________________________ .
Other:
Other:
correct.
WA
on (date)
Oct. 21.2009
Jeanette Jepson__________
Print or Type Name
Service
Mileage
Total
File the original Return of Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides if the documents served include a restraining order signed by the court.
Return of Service (RTS)- Page 2 of 2

its-' ^ 6 /2 -H S S
08-
3
4
5
IN TH E S U P E R IO R C O U R T O F W A S H IN G T O N , C O U N T Y O F P IE R C E
6
7
_ O o lftn e ;
v \& Y Y \S c m
Cause No:
3 ^ 0 0 8 ^ -J *
* "/'
Petitioner(s),
ORDER REGARDING
FAMILY COURT HEARING
8
9
(^ y v s V o L g ^
1
ORHFC1
ORHFC2
W
Rocn
Respondent(s).
10
CLERKS ACTION REQUIRED
11
[
12
] A Status Conference hearing is set before Family C o u rt____ , in Room_________ on
th e __________ day of___________________________ , 20______ a t_______________ a.m.

13
14
iV )
15
the
( a i o e f l i k j N * :ial is set before Family Court

_day ofJ^Q j^ i- n
on
. in Room
^ l^ _______ , 20 \O _at
a.m.
16
17
18
19
20
Dated this _ P 3 d a y of
21
22
23
24
f A p J y i)d tfc # n ^
rney for Petitioner(s) WSBA#
25
Guardian Ad Litem
Regarding Family Court Hearing - Mod 6/3/09

:-250
Attorney for Respondent(s) WSBA#
(page 1 of_____ )
5852
08-3-00821-4
33241802
APPS
11X 23X 2889
88193
11-23-09

County of
In re: contempt parenting plan
No. 08-3-00821-4
Jolene (Harrison) Charlton

Petitioner,
Pro se Notice of Appearance

(APPS)
and
Respondent.
The undersigned enters an appearance in this action, and demands notice of all further proceedings. The
Clerk of the Court and the opposing party will be informed of any change in address. Any notices may
be sent to [You may list an address that is not your residential address where you agree to accept legal
documents.]
Service Address:
___________
________________
1^57771^
/ r
/ ? ?
A u*.
,
US/9
_______________
? 9/____________
Any time this address changes wmle this action is pending, you must notify the opposing parties in
writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the court
clerk.
Phone Number: Listed on Confidential Information Form.
Dated:
I1~ 2{) " O^j

ature of Party Appearing
Print or Type Name
Notice o f Appearance (APPS) - Page 1 of 1

WPF DRPSCU 01.0320 (6/2006)
5S52
11223/2389
801
08-3-00821-4
c OUNTyF CLERK';
s O FFICE

County of
By___
m ow
In re: Parenting Plan/ Contempt Response
Jolene Marie (Harrison) Charlton
No. 08-3-00821-4
Petitioners),
and
Respondents).
Declaration of
Response to Contempt
(Optional Use)
(DCLR)
Name:
Age:
Jolene Marie Charlton____________________

34_________________________________________________
Mother to Christopher Lee Harrison, Jr. and Co-Parent with
Christopher Lee HarrisonTmoving party)
Declare:
In regards to the contempt charge. I Did Not willfully or intentionally fail to comply with the Final
Parenting Plan dated October 17. 2008. I have acted as a responsible and concerned parent who wants
her child to have a relationship with his father. The following reasons explain why Mr. Harrison would
have missed visits with the child.
Declaration (DCLR) - Page 1 of 4

WPF DRPSCU 01.0100 (6/2006)
S852
11S 2 3 /Z & 8 9
88206
11 There are restrictions for Parental Conduct per (RCW 26.09.191 (11(21(3V) Please see Final Parenting
Plan dated October 17. 2008, page 2 of 11 (2.1 and 2.2), and page 6 of 11 (3.10) Residential time to be
supervised or limited if father demonstrates evidence of mental health issues, abusive behavior or
drinking,-1
21 Mr. Harrison had very little contact with the child from July of 2007, when he was removed from the
family residence for Domestic Violence. (For shoving the Petitioner (former spouse') down a flight of stairs.)
3) Mr. Harrison has frequently been unable and, at times, unwilling to take the child for regular visits.
4) Mr. Harrison has never made contact in regards to Wednesday visitations and has sometimes been
unwilling or unable to see the child on his weekend visitation times. Some weekends were shortened, one to
only a three-hour visit
s') In mid to late 2008. Mr. Harrison spent several months in and out of Jail. On July 15th 2008. Mr.
Harrison received a post conviction No-Contact Order for Domestic Violence, Cause No. 7YC010751. This
was issued as a condition of the defendants sentence, and is valid until July 15. 2010.
61 In late 2008. into mid January 2009. Mr. Harrison spent 3 !/: months in a suicide watch tank at the King
County Jail down town Seattle. Upon his release, Mr. Harrison was Court ordered to complete a one-year
Dual-Diagnoses Treatment Program.
71 When Mr. Harrison was released from Jail in January of 2009. he entered a Clean and Sober house,
Mr. Harrison did not contact the child until late February to wish him a Happy Birthday. Mr. Harrison
then mailed a letter to me in March in regards to the progress he was making in group. The letter was in
regards to Mr. Harrisons coming to grips with his losses of loosing me. and feelings he had regarding the
things he had done to me.
81 1 never denied Mr. Harrison the right to see his son. 1 was not allowed to bring the children to visit
him in the jail. During the time Mr. Harrison was in the Clean and Sober house I allowed visits when
there was a responsible licensed adult driver, but refused over nights in the Clean and Sober house
because that was not an appropriate place for a three or four-year-old child to be staying. Mr. Harrison
WPF DRPSCU 01.0100 (6/2006)
1 1 2
arranged a weekend visit at a responsible friends home while he was living at the Clean and Sober
house. Later. Mr, Harrison told me that he lost his place at the Clean and Sober house because he was
seen leaving a liquor store with a bottle in hand.
When Mr. Harrison moved to a new residence, he refused to give me his address. I was very willing to
arrange visits at a mutually agreeable place, but I could not as a responsible parent send a four-year-old
child to weekend overnight visits where 1 had no idea of the address. Mr. Harrisons fourteen-year-old
daughter called me from that home one night when she was staving for an overnight visit. She wanted
me to come get her because she was feeling insecure and unsafe, she did not know the address and
wanted to walk two blocks in the dark to a business place where I could find her. 1 helped her resolve the
problem, but it underscored my concerns with sending my child where I had no address for contacting the
father if it was needed. That concern was reinforced further after 1 was given Mr. Harrison's address and
weekend visits resumed. Three hours after the child was picked up bv Mr. Harrison, 1 received a phone
call telling me 1 needed to come pick the child up immediately because Mr. Harrison and his girlfriend
were having a serious fight and he was packing to move out.
I want Mr. Harrison to have a relationship with his son, Christopher Lee Harrison. Jr.. However. 1 want
that relationship to be a healthy one that appropriately supports the childs safety and well being. 1 have
worked hard to follow the parenting plan while acting as a responsible parent and watch out for the
childs physical safety, and his emotional, and mental well-being.
Mr. Harrison repeatedly demonstrates that he has little or no regard for the law and obeying court orders.
The following conditions and behaviors have caused the petitioner (non-moving party) to walk a very
fine line between the court order and protecting the child.________________________________________
Multiple documented suicide ideations and hospitalizations,
Three plus months in the suicide watch tank. King Co. Jail,
Alcohol Addiction.
Drinking and driving, habitual offender.
Driving without a license, habitual offender.
Mental Illness (depression or bi-polar disease') different doctors have diagnosed each.
Multiple warrants for arrest.
Multiple violations of the No Contact order.

WPF DRPSCU 01.0100 (6/2006)
5852
Physical and emotional abuse of a child,
Neglect and substantial nonperformance of parenting functions.
Domestic Abuse and violence.
1 1 /2 3 /2 8 8 9
88282
Given Mr. Harrison's history and his recent behaviors, the proposed modified parenting plan will
probably better meet the needs of everyone involved without putting anyone in danger of contempt._____

1 declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at
Bonnev Lake
nature of Declarant
[City] WA_____ [State] on
11'Q P
______ [Date].

Print or Type Name


WPF DRPSCU 01.0100 (6/2006)
5852
08-3-00821-4
33241810
DCLR
1 1 /2 3 /2 3 8 8
03283
11-23-09
%%j!Nry it,
P-H-

County of
In re: Relocation/Parenting Plan Contempt
No. 08-3-00821-4
Petitioners),
and
Respondent(s).
Declaration of
Jeanette Jepson
[Name]
(Optional Use)
(DCLR)

Name:
Age:
Jeanette Jepson
65_____ ________
Mother to Jolene (Harrison) Charlton
Declare:
1 have raised ten (10) children, worked ten (10) vears as a counselor/advocate for the sexual assault crisis
line (KCSARC). and have been a CASA volunteer for the past six (6) years. This broader experience
and training gives me perspective to observe, evaluate, and advocate in the best interest o f children.
_____ I have known Mr. Harrison for the past six (6) vears and have been a surrogate grandmother to his
two oldest daughters. Alyssa (16) and Katie (14), for most of that time. Mr. Harrison managed a really
good Con job and cover-up for the first year after his invalid marriage to our daughter. Jolene
(Harrison) Charlton, but things began to deteriorate when we discovered the drivers license he produced
in-order to drive for our family business was false, and we had to fire him to protect the company. The
Declaration (DCLR) - Page 1 ofJ3 ___
WPF DRPSCU 01.0100 (6/2006)
5852
1 -1 S 2 3 S 'Z B 8 S 8 8 2 8 4
lies, drinking, driving, and abuses began to escalate until the dav he came up behind our daughter and
pushed her down a half flight of stairs, prevented her from leaving with the children, and threw her cell
phone to the ground while she was calling 9 1 1 for help. When our daughter and grandchildren arrived at
our home, Alyssa and Katie fell into mv arms sobbing. This final Domestic Violence prompted Mr.
Harrison's exit from their family residence. He left Alyssa, Katie, and CJ ('their 2]/ i vear-old son) with
Jolene (Harrison) Charlton at the end of the summer. 2007. She also had her own two children from a
previous marriage.
_____ The abandonment, neglect, and refusal to perform almost any parenting functions continue to this
dav. There is constant emotional abuse of all the children, and both girls have told me they are scared of
their father, and have reported physical abuse to a doctor and a counselor. On numerous occasions and in
the presence o f the girls, (and others) Mr. Harrison has referred to Alyssa as the good child and Katie
as the bad child".
_____ It is my belief that a Child Protective Services background report will substantiate that none of the
children should be left with Mr. Harrison for any substantial length of time, and the four-year-old should
be seen under supervised visits only. The biological mother and father abandoned both girls as a baby
and toddler, and they were in foster care for two vears (six homes) At the ages o f 9 and 11 years-old,
Jolene ('Harrison) became the only mother the girls had ever known.
_____ Alyssa and Katie both have wonderful homes now with families who love them. We maintain
extended family involvement so the girls can have continuity of bonding and not be deserted once again.
The girls still call Jolene (Harrison) Charlton Mom even though they live with different families now.
Although the relationship between sixteen H 61) year old Alyssa and Jolene Charlton is strained at the
present time, Jolene Charlton will continue to maintain the bonding she and the girls have built together.
Christopher Lee Harrison, Jr, CJ

_____ After Mr. Harrison deserted the family in 2007. 1 saw CJ four(4) or five(5J days a week for the
next year and a half because mv daughter-in-law dav-cared him in our home. I personally observed the
damages caused by Mr. Harrisons abandonment, neglect, and lack of parenting.
Jolene (Harrison)
Charlton made repeated efforts to have Mr. Harrison visit or make phone calls to CJ and the other
children. Mr. Harrisons contact with the children was very sporadic at best, and the children were
suffering.
_____ 1 was aware of a number of times when Jolene (Harrison) took CJ to see his daddy were Mr.
Harrison lived and worked on remodeling houses, so CJ could spent just a little time with his dad. 1 was
Declaration (DCLR) - Page 2 of_3 __
WPF DRPSCU 01.0100 (6/2006)
5352
1 1 /2 3 /2 8 3 9
8820
with her to pick CJ up after one visit when Mr. Harrison acknowledged that even though he did not have
a drivers license or a car seat he had driven CJ down the road because CJ wanted a little ride in Mr.
Harrisons truck.
_____Jolene (Harrison) Charlton has worked very hard to help the child maintain a relationship with Mr.
Harrison while, at the same time, providing responsible and appropriate safe guards with the visits. It
would have been irresponsible of Jolene Charlton to arrange visits without knowing the address where
the child would be staving and verifying that anyone providing transportation was a licensed responsible
driver. Mr. Harrisons availability for visits has been inconsistent and his unwillingness to comply with
the parenting plan limitations has been concerning.______________________________________________

correct.
Signed at
[Date].
Bonnev Lake
[City]
WA
[State] on
11/17/2009
______ Jeanette R. Jepson

Print or Type Name

Declaration (DCLR) - Page 3 of_3

WPF DRPSCU 01.0100 (6/2006)
5852
33241843
DCLR
l1 / 2 3 / . 2 $ 8 9
88286
11-23-09

County of Pierce
In re: Contempt Response
No. 08-3-00821-4
Petitioners),
and
Declaration of
Katherine Avers

Respondent(s).
Name]
(Optional Use)
(DCLR)________

Name:
_K atherine Ayers
Age:
__61
Relationship to the parties in this action: guardian o f Kathrina Harrison, child o f Chris HarrisonI
I Declare:
I have known Jolenes family for 15 years and have known Chris Harrison for approximately 1-1/2 years
when 1 became intimately involved with the family as guardian to Kathrina.. one of Chris' daughters. 1
can testify that Jolene is a wonderful mother who uses the well-being and best interest of her three
children as a measuring stick against which she measures everything she says, does and thinks. This is
not to sav that being a single parent has been easy - it is a rough road bv definition and I admire how well
Jolene balances all the demands she has on her. Since I first met Chris, he has had difficulty providing
for himself financially and has essentially been homeless, relying on friends, employers and the state to
provide him a bed. He also has not had a valid driver's license. .Because of the transient nature of Chris'
lifestyle and his lack o f transportation, Jolene has generally made 100% of the effort so that their son, CJ.

WPF DRPSCU 01.0100 (6/2006)
5352
11^ 23/2939
3028?
could have time with his father.. I know of at least two instances when Jolene brought CJ for a visit to
homes in Tacoma where Chris was working: once when Katie (Kathrina1) was present with them and
another when Jolene and her mother visited with me in my home while CJ was visiting with his father a
short distance away.. Jolene has expressed to me that she knows it is important for CJ to maintain a
relationship with his father and she has proven this commitment to her son bv her actions..
_____Speaking from mv perspective as Katie's guardian, Jolene (stepmother) has maintained a close
relationship with Katie, talking with her bv phone and inviting her to her home regularly. Katie and 1 are
generally invited to extended family gatherings so that Katie can interact with her grandparents, cousins,
aunts & uncles. Katie has told me that Jolene is the first woman in her life she felt comfortable in
calling Mom and she continues to call her Mom when talking about or to Jolene. From this same
perspective. Chris, has not exhibited even a half-hearted interest in his child. Katie and her father have
seen each other only twice in the past year even though Chris has never been more than 30 miles away..
After not hearing from her father in over four months. Chris called Katie recently to invite her to spend
last weekend with him. Much adjustment was made to schedules so that this would be possible and Katie
was very much looking forward to spending time with both her dad and her sister. Alyssa. who lives in
vet another home and was planning on being there as well.
The appointed dav for pick-up came and
went, many phone calls were made both to Chris and to his current girlfriend with no reply. Katie was
very disappointed and still doesnt understand whv her father hasn't called her with an explanation or
apology. From my perspective. Chris children are pretty low on his list of priorities - which explains
whv they all four live in different households (two with non-relatives) and not with him..

correct.
Signed at
Tacoma_______ , [City]
Signature o f Declaranr
Declaration (DCLR) - Page 2 o f 2

WPF DRPSCU 01.0100 (6/2006)
WA
fStatel on
______ Katherine Ayers .

Print or Type Name
[Date].
5852
08-3-00021-4
33241^47
i 1 /2 3 ^ 2 0 0 9
11-23-09
PPP
c o u n t / c l I b k 's o f f i c e
NOV 2 0 2009 PH
KEVIN
ciyoci:

County of Pierce
In re relocation parenting plan modified:
No. 08 3 00821 4
Jolene Marie (Harrison) Charlton Petitioner,
and
Respondent.
Parenting Plan
[X] Proposed (PPP) Modified
[ ] Temporary (PPT) Modified

[]
[]
[]
[X]
dated_________________________.
proposed by (name) Jolene Marie Charlton_______________________________.

Name

Age
4
88288
5852
1 1 /2 3 ^2 6 0 3

2.1

[]
[X]
Does not apply.

The [ ] petitioners [X ] respondents residential time with the child(ren) shall be limited
resolution process other than court action shall not be required, because [X ] this parent
[X]
[X]
[X]
2.2

A history o f acts o f domestic violence as defined in RCW 26.50.010(1) or an
harm.

[]
[X]
Does not apply.

on the child(ren)s best interests because of the existence o f the factors which follow:
[X]
[X]
[X]
[X]
[X]
[]
[]

performance o f parenting functions as defined in RCW 26.09.004.
The absence or substantia! impairment of emotional ties between the parent and
child.
Other:

The residential schedule must set forth where the child(ren) shall reside each day o f the year,
Paragraph 3.13.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181; .187; .194
,8 6209
5852
3.1
1122322889

[]
[X]

from (day and time) Saturday 10:00 a.m. to (day and time) Saturday at 8:00 p.m.
[]
[]
respondent and child are in the same city, or every other weekend if the child and
respondent are living in the same city.
from (day and time)

[]
t]
3.2
Sunday 8:00 p.m. to (day and time) Sunday 6:00 p.m.
School Schedule
From (day and time) Saturday 10:00 a.m. to (day and time) Saturday 8:00 p.m.
[]
[]
[X]
every week [ ] every other week [ j the first and third week of the month
Other: Under supervision when respondent and child are in the same city, or
every other weekend if the child and respondent are living in the same city.
From (day and time) Sunday 8:00 a.m. to (day and time) Sunday 6:00 p.m.
[]
[]
[X]
[]
Other: Under supervision when respondent and child are in the same city, or
every other weekend if the child and respondent are living in the same city.

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181;. 187;. 194
88218
5852
1 1 /2 3 2 2 8 3 9
[ ] other:
3.3

schedule as 3.1 above.
3.4

The child(ren) shall reside with the [X] petitioner [.] respondent during other school breaks,
parent:
3.5
Summer Schedule
[X]
[]
3.6

[X]
[]
3.7

Other:
Does not apply.



8321
5852
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
11/23/2005
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Every
Every
Every
Every
Odd
Even
Even

[X]
For purposes o f this parenting plan, a holiday shall begin and end as follows (set forth
times): 8am to 8pm
[]
[X]
Other: Under supervision when respondent and child are in the same city, or every other
weekend if the child and respondent are living in the same city.

With Respondent
With Petitioner
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
Mothers Dav
Every
Fathers Dav
Every
Mothers Birthdav
Every
Fathers Birthdav
Every
[X] Other:
Under supervision when respondent and child are in the same city, or every other
weekend if the child and respondent are living in the same city (using same
schedule as 3.1 above).

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181;. 187; .194
# 021
5852
3.9

[X]
[]
[]
[]
3.10
3.11
1122322885
____ holidays (3.7)

Other:
Restrictions
[]
[X]
restrictions shall apply when the children spend time with this parent: Under
supervision when respondent and child are in the same city, or every other
weekend if the child and respondent are living in the same city.
[]
reasons:
3.12
The respondent shall arrange the transportation and payment of the child to visit him, and_____
The petitioner shall arrange theTransportation and payment
nent of the child to return home.
p
r
u
^
3 ~ 77 2
? v^ 9 Tra/?Sflarfat/ ayu
-TAL.
rfo jo a y jr-fu jid
) f
C Y IJ /V '
^
s w f Cy? 7 ?
YD 7 A * -' <
7 7 w s p 0 ? 7 a //d > ^ '
f o u /a fc t
parenting plan.

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181;. 187; .194
88213
5852
1 IV 2 3 2 2 8 9 9
3.13
Other
The petitioner will claim the child on the annual income taxes.
The Petitioner shall have sole authority to apply for a U.S. Passport as directed by Public Law
106-113 and Regulation 22 CFR 51.21 and 51.28, for the purpose o f visiting family in Canada.
3.14

confirmed.
89214
5852
I1 2 2 3 2 2 S S 9
IV. Decision Making
4.1
child.
4.2
Major Decisions
Education decisions
[X]
[X]
[X]
[]
n
[]
[]
[]
[]
4.3
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[]
[]
[]
[]
[]
[]
[j
[3
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
[]
[]
[]
[3
[3
joint
joint
joint
joint
joint
joint
joint
joint
joint

[J
[X]
Does not apply because there are no limiting factors in paragraphs 2 .1 and 2.2 above.
following reasons:
[X]
A limitation on the other parent's decision making authority is mandated by


WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181; .187; .194
8821
5-3-52
[]
[X]

(a)
(b)
(c)
(d)
[]
1 1 /2 3 /2 0 0 3

RCW 26.09.184(4)(a); and
The purpose o f this dispute resolution process is to resolve disagreements about carrying out
the provisions o f this plan must be used before filing a petition to modify the plan o r a motion for
[]
or agency):
[]
counseling by _____________________________________ , or
[]

[]
arbitration by
_____________________________________ .
The cost o f this process shall be allocated between the parties as follows:
[]
[]
[]
% petitioner _________ % respondent.

worksheets.

80216
5852
ii/2 3 /2 8 8 3
(a)
(b)
(c)
(d)
(e)
[X]

other parent.
court.

[]
[X]

The Respondent must keep the Petitioner informed of his current residential address for
visitations to take place, or be willing to visit the child at a location acceptable to both parties.
If the respondent has completed and shown proof of the Certificate for the required Parenting
Class, and can show proof of acceptable progress for court ordered treatments for: (or voluntary
treatment programs engaged in by the Respondent)for:
Alcohol Addiction,
Driving without a License,
Driving while under the influence,
Emotional/Mental Health Problems,
Domestic Abuse,
Parenting Training, or
* Anger Management;
The Defendant can begin overnight visits starting with one night at a time working up to a two
night weekend every other week, provided the Respondent and the child are in the same city
together, or the Respondent is willing to pay for the adults and childs transportation, or the
respondent and child are living in the same city.
The Respondent must not bad-mouth the other parent or step-parent, or prompt the child into
asking for things the Respondent knows are outside o f the parenting plan guidelines.

8821?
5852
M V23/2883

[]
[X]
Does not apply.

(Only sign if this is a proposed parenting plan.) 1 declare under penalty of perjury under the laws
o f the state o f Washington that this plan has been proposed in good faith and that the statements
in Part II o f this Plan are true and correct.

Petitioner
______________ Tacoma. WA
Respondent

order o f this court.
punishable by contempt of court and may be a criminal offense under RCW 9 A.40.060(2) or
not affected.
Dated:
Judge/Commissioner
Presented by:
Approved for entry:
m
Q m f i k z r y 1.
Signature
nature o f Party or Lawyer/WSBA No.
Print Name

Jolene Marie Charlton____________
Print Name

882
6848
________Pm
84B053
____ Pfp ^
For Respondent
For Petitioner
RE:
1 2 '3 / 2 8 8 9
OrdUr
AApDur aiitoji/d
h> __iyJ/)Sa K '
U)\Hn dhilJ
'bo TA/ihn ~ p a r t l y
f w n ^ ___
CauA- bU<-________________________________________________________
L<udf^hti
fh h f
f) V w ___ fnftir
m&j
a \isnch^ ujcs/pfld^ non &j>p,nAs+J
not Wampt>&__ G.hilA__ m i f l w
v&M
d n v t& _ J ts j^
a*A ___
______Xp&pmttJ__________________________ _________________________________
1^4
i'TtofitoiAite ___ t __ lk$p>Aditf fr> C har up
\~Jl5 j <yxeXQ/bt#Jl
December 2, 2009 9:30 AM

W'yft
S fio s rh Af\UL-
ali O u fc fa u fu ^
ld&iwk_
P d ftfC S _________________ $>&
/ill
Show Cause
MEAGAN M. FOLEY
Clerk

Calendar:C3 - SHOW CAUSE/FAMILY LAW
ixcrtrpt.pbl dJoumal_entry_showcause_report
'\
848
fo r
1 2 2 3 /2 8 8 9
848054
FILED \
IN OPEN COURT \
08-3-OOB21-4
33299253
PPT
DEC 02 2009
12-03-09
PIERCE COUNTY,
fly
.<>/>
DEPUTY

County of Pierce
In re relocation parenting plan modified:
No. 08 3 00821 4
Jolene Marie (Harrison) Charlton Petitioner,
and
Respondent.
Parenting Plan
[ ] Proposed (PPP) Modified
[X] Temporary (PPT) Modified

[]
[]
[X]
[]
the final parenting plan signed by the court pursuant to a decree o f dissolution, legal
dated
.
proposed by (name) Jolene Marie Charlton_______________________________ .

Name

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181; .187;. 194
Age
4
-b e4 0
1 2 / 3 '2 3 6 9
8 4 0 3 S3

2.1

[J
[X]
Does not apply.

The [ ] petitioners [X ] respondents residential time with the child(ren) shall be limited
resolution process other than court action shall not be required, because [X ] this parent
[X]
[X]
[X]
2.2

A history of acts of domestic violence as defined in RCW 26.50.010( 1) or an
harm.

[]
[X]
Does not apply.

[X]
[X]
[X]
[X]
[X]
[]
[]

child.
Other:

Paragraph 3.13.
WPF DR 01.0400 Mandatory (6/2008) - RCW26.09.016, . 181;. 187;. 194
6840
3.1
12/3/2089
848SSS

[]
[X]

from (day and time) Saturday 10:00 a.m. to (day and time) ^tunjay-eHHftrpTrrT
[]
[]
every week every other week^p^4tie first and third week of the month
the second and fourth week of the month [-X] other: Under superv ision w hen
respondent and child-arc in the same city, or ovory other weekend if the child and
respondent are living in the snme oky^ ^
from (day and t ime)

[]
[]
3.2
to (day and time) Sunday 6:00 p.m.
every week ^ every other weetejb^flie first and third week of the month
School Schedule
From (day and time) Saturday 10:00 a.m. to (day and time) Siltiirdiy ft-ftff frm
[]
[]
every week every other w eek

f^th e first and third week of the month
ikepfttfe
Other: Under supervision .when respondent and child arc in the 3amc-city, ofevery other weekend if the ehild and respondent are living in the same city* -
From (day and time) SundavJMffiTTfnT to (day and time) Sunday 6:00 p.m.
[]
[]
[]
every week [}d every other w eekg^the first and third week of the month
Other: Under supervision when respondent and chiId-arc in the same eity, ore>very other weekend if the child and respondent are living in the same city.-

WPF DR 01.0400 Mandatory (6/2008) - RCW26.09.016, .181; .187; .194
B4B
2389
84885?
[ ] other:
3.3

3.4

The child(ren) shall reside with the [X] petitioner [ ] respondent during other school breaks,
parent:
3.5
Summer Schedule
[X]
[]
3.6

[X]
[]
3.7

Other:
Does not apply.



WPF DR 01.0400 Mandatory (6/2008) - RCW26.09.016, .181;. 187;. 194
648
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
12^3^2669
846656
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
Every__________________
Every__________________
Every__________________
Every__________________
Every__________________
Every__________________
Every__________________
Odd____________________
Even___________________
Even___________________
_______________________
_______________________
_______________________
_______________________
_______________________
_______________________
_______________________
[X]
times): 8am to 8pm
[]
[X]
Other: Under supervision when respondent and child aie in the same cllyT'oT eveiy utber*
wookcnd if the child and respondent are living 111 the same lily r

The residential schedule for the child(ren) for the following special
With Petitioner
(Specify Year
Odd/Even/Everv)
Mothers Dav_______________
Every__________________
Fathers Dav________________
________________________
Mothers Birthdav___________
Every__________________
Fathers Birthdav____________
_______________________
fX] Other:
occasions (for example,

With Respondent
(Specify Year
Odd/Even/Everv)
_______________
Every_________
_______________
Every__________
Under supervision when respondent and child are in the same city, or every otheranrirf^n.... L n l nra living in the <:ame city (ii<dng_gamg .
schedule as 3.1 above).

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181;. 187; .194
6949
3.9
[]
Rank the order o f priority, with 1 being given the highest priority:
[]
3.11
84 959

[X]
[]
3.10
i'2 /^ 3 /2 8 0 9
____holidays (3.7)
____vacation with parents (3.6)
Other:
Restrictions
[]
[X]
restrictions shall apply when the children spend time with this parents tender
.supervision when respondent and child arc in thc-samc eity, or evciy Other
lv rrkcnd if t hr ch ild Tild h 'ijuuiili ill .in liung in thr unmr rity
[]
reasons:
The respondent shall arrange the transportation and payment of the child to visit him, and_____
The petitioner shall arrange the transportation and payment of the child to return home.
3.12
the [X] petitioner [ ] respondent. This parent is designated the custodian of the chiid(ren) solely
parenting plan.

WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016,. 181;. 187; .194
6340
1 Z S 3 /'Z 8 B 3
3.13
Other
The petitioner will claim the child on the annual income taxes.
The Petitioner shall have sole authority to apply for a U.S. Passport as directed by Public Law
106-113 and Regulation 22 CFR 5l.2l and 51.28, for the purpose of visiting family in Canada.
3.14
848863
and safety o f a person or a child at risk.
confirmed.
WPF DR 01.0400 Mandatory (6/2008) - R C W 26.09.016, . 181; .187; .194
684@
1 2 /3 ^ 2 0 8 9
1340861
If the objecting person schedules a hearing for a date within 15 days o f timely service of the
IV. Decision Making
4.1
child.
4.2
Major Decisions
Education decisions
4.3
[X]
[X]
[X]
[]
[]
[]
[]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[]
[]
[]
[]
[]
[]
[]
[]
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
joint
joint

[]
[X]
following reasons:
[X]

RCW 26-09.19 1 (See paragraph 2 .1).

&840
[]
[X]
840962

(a)
(b)
(c)
(d)
[]
.1 2 / 3 / 2 0 8 9

RCW 26.09.184(4)(a); and
this parenting plan. This dispute resolution process may; and under some local court rules or
[]
or agency):
[]
counseling by
_____________________________________, or
[]

[]
arbitration by
_____________________________________ .
[]
[]
[]
__________ % petitioner_________ % respondent.

worksheets.

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, . 181;. 187; .194
'-68-48
1 2 X 3 X .2 B 8 9
848963
(a)
(b)
(c)
(d)
(e)
[X]

other parent.
court.

[]
[X]

The Respondent must keep the Petitioner informed of his current residential address for
visitations to take place, or be willing to visit the child at a location acceptable to both parties.
If the respondent has completed and shown proof of the Certificate for the required Parenting
Class, and can show proof of acceptable progress for court ordered treatments for: (or voluntary
treatment programs engaged in by the Respondent)for:
Alcohol Addiction,
Driving without a License,
Driving while under the influence,
Emotional/Mental Health Problems,
Domestic Abuse,
Parenting Training, or
Anger Management;
The Defendant can begin overnight visits starting with one night at a time working up to a two
night weekend every other week, provided the Respondent and the child are in the same city
together, or the Respondent is willing to pay for the adults and childs transportation, or the
respondent and child are living in the same city.
The Respondent must not bad-mouth the other parent or step-parent, or prompt the child into
asking for things the Respondent knows are outside of the parenting plan guidelines.
Parenting Plan (PPP, P P T P P ) - Page 10 o f 11

.& 8 4 8
1 2 ^3^2889
B4BB64

[]
[X]
Does not apply.

______________Tacoma. WA

effort to resolve the issue through the dispute resolution
If a parent fails to comply with a provision of this plan, the ot
not affected.
ts obligations under the plan are

MEAGAN M. FOLEY
Court Commissioner
mmissioner

6049
1'2S3S.ZB& 9
B4S06
>
FILED
IN OPEN COURT \
-3-00921-4
33299255
TMORELO
12-03-09
DEC 022009
PIERCE COUNTV, Clerk
*r
d eu

County of
In re:
No. 0 8 -3 -0 0 8 2 1 -4
Child(ren),

and
Petitioners).
Temporary Order re:

Relocation of Children and
Temporary Parenting Plan
(TMORELO)

Respondent(s).
I. Basis
[]
A motion for a temporary order [ ] restraining relocation of children [ ] ordering the return of the
children was filed pursuant to RCW 26.09.510(1).
[X]
A motion for a temporary order authorizing the intended relocation of the child pending final
hearing was filed pursuant to RCW 26.09.510(2).
It. Findings
2.1
Notice of intended relocation of the children.

[X] The required notice of intended relocation of the children was provided in a timely manner.
[ ] The required notice of intended relocation of the children was not provided in a timely manner
and the non re locating party [ ] was [ ] was not substantially prejudiced.
[ ] The relocating party did not comply with the notice requirements. Circumstances warrant
issuance of an order authorizing the relocation and issuing a revised parenting plan/residential
schedule.
2.2
The relocation of the children:

[X] has not occurred.
[ ] has occurred without agreement of the parties or a court order.
Temporary Order re Reloc (TMORELO) - Page 1 of 2

WPF DRPSCU 07.0890 (6/2006) - RCW26.09.510
6-04'B 1 2 / 3 / 2 8 8 9 ;8 4 8 8 6 6
tk
2.3
* After examining the evidence presented at the hearing for temporary orders in which the parties
had adequate opportunity to prepare and be heard:
[ ] there is a likelihood that on final hearing the court will not approve the intended relocation of
the children.
[ ] no circumstances exist sufficient to warrant a relocation o f the children prior to a final
determination at trial.
[X] there is a likelihood that on final hearing the court will approve the intended relocation o f the
children.
2.4
2.5
[ ] Further, the court finds that the nonmoving party is absent and a) is on active duty as a National
Guard member or Reservist residing in Washington, or b) is a dependent of a National Guard
member or Reservist residing in Washington on active duty. Despite the service members or
dependents absence, failure to enter the temporary orders below would result in manifest
injustice to the other interested parties.
Other:
............
fia r b & r T*
c [ r / # x - ~ / fT V /"
C m + ih u < .- P a r f / ^ s - f *
... .. ,
t,s
[]
[]
[X]
U P e tJ c a
? </
,
^ r y ,- e r n e s '
j / / J V7 3 >
h a /f^ u a y
/ Or d e r -
A r
ae u tf ttz / c/}JS sai& *x*sir
[X]
m
Dated:
lb 7ajbe-
X & n* b r
/ ) * /'< v e -* r 7 7 / > / _
^Tn^rnotion for temporary order restraining relocation of the children is [ ] granted [ ] denied.
q) /7
The motion for temporary order ordering the return of the children is [ ] granted [ ] denied.
The motion for temporary order permitting relocation of the children is [X] granted [ ] denied.
It is Further Ordered:
[]
[]
[X]
[]
i1
The relocating party' is restrained from moving the children pending the final hearing.
The relocating party is ordered to return the children.
The relocating party is permitted to change the childrens principal residence.
The custody decree/parenting plan/residential schedule signed by the court and entered on
____[Date] shall remain in affect.
The parties shall comply with the temporary parenting plan/flesidential schedule signed by the
court on
[Date].
Other: The motion for approval o f temporaiy parentin
as granted.
.'EAGAN M. FOLEY
Court Commissioner
V t e iU / ^ i w y i
missioner
ssented by:
)or Lawyer/WSBA No.

Print or Type Name
fa /g /g /> o ?
Date
FILED
IN OPFN COURT \ / L
Temporary Order re Reloc (TMORELO) - Page 2 of
WPF DRPSCU 07.0890 (6/2006) - RCW 26.09.510
DEC 0 2 200*
PIERCE COMITY, Clerk
8y
OEPUTV
3- ' 7
08-3-00821-4
33324782
RTS
12-08-09
FI LED
u . dec - y a m
PIERCE COUNTYfWASHINI
I^BVIN STO CK /$ our

County of
In re: contempt parenting plan/relocation
No. 08 3 00821 4
Petitioner,
and
Return of Service
(Optional Use)
(RTS)
Respondent.
I Declare:
1.
Iam over the age of 18 years, and 1 am not a party to this action.
2.
1 served the following documents to (name)

[]
[]
[X]
[]
[]
[]
[]
[]
[]
[]
[]
[3
[X]
[3
[X]

proposed parenting plan or residential schedule: ^modified*
Notice Re: Dependent of a Person in Military Service
notice of hearing fo r________________________________________ ___
motion for and order to show cause re :___________________________
declarations of Katherine Avers, and Jeanette Jepson_
temporary order
other: Appearance Pro Se, and Affidavit/Declaration of Petitioner

WPF DRPSCU 01.0250 (6/2008) - CR 4(g), RCW 4.28.080(15)
fi-1 3 /
3.
Date:
11 /22/2009______________ Time:
Address:
Bonney Lake Safeway on 214th and Hwy 410_________
________
4.
[]
[]
p.m.
Bonnev Lake. WA______ _____________________________

by delivery to (name)________________________________________ , a person of
suitable age and discretion residing at the respondents usual abode.
by publication as provided in RCW 4.28.100. (File Affidavit of Publication separately.)
(check only if there is a court order authorizing service by mail) by mailing two copies
postage prepaid to the person named in the order entered by the court on
(date)__________________________. One copy was mailed by ordinary first class mail,
the other copy was sent by certified mail return receipt requested. (Tape return receipt
below.) The copies were mailed on (date)_______________________________ .
Service o f Notice on Dependent of a Person in Military Service.

[j
[j
6.
5:30

[X]
[}
5.
1 .2 /9 - /'-2 S 9 , 8 8
The Notice to Dependent of Person in Military Service was [ ] served on [ ] mailed by

first class mail on (date)__________________________________ .
Other:
Other:
I declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed ak(city)
Bonnev Lake^________, (state)

a
WA
Signature
Fees:
Service
Mileage
Total
on (date) 11/22/2009______ .
Truman A Jepson______________________
Print or Type Name
__________________________
________ __________________
______ ____________________

File the original Return of Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides if the documents served include a restraining order signed by the court.

WPF DRPSCU 01.0250 (6/2008) - CR 4(g), RCW 4.28.080(15)
E-FILED
January 21 2010 4:28 PM
KEVIN STOCK
COUNTY CLERK
Case No.
08-3-00821-4
Petitioner(s),
vs.
Notice of Address Change for Litigant

(NTC A)
R espondent(s) .
Please take notice that my address for service of court records is:
6721 N A T H A N A V E SE
A U B U R N , W A 98092
Dated
January 21, 2010
Address provided to the clerk in open court.
?.S8
ST PORE
1 /2 9 ^ 2 8 1 8
01-29-10

Petitioner(s) ,
vs.
Respondent(s) .
Cause No. 08-3-00821-4

STIPULATION AND ORDER FOR
RETURN OF EXHIBITS
It is hereby stipulated that at such time as the Judgment in the above entitled action shall
become final, or upon Judgment becoming final after Appeal, or upon the filing of a Dismissal, or upon
filing a Satisfaction of Judgment, the County Clerk may return all exhibits offered and received in
evidence in the above entitled action to the party introducing said exhibits.
Remittitur Filed^___________________________
Dismissal Filed
Satisfaction Filed
RECEIPT FOR EXHIBITS

Received from the PIERCE COUNTY CLERK the following exhibits:
Petitioner(s) s Exhibit(s)
______________________________
No.
D a te _____________ Attorney for Petitioner(s)
Respondent(s) s Exhibit(s)
No.
____________________
D a te ______________
Attorney for Respondents)
13885
Y^S 8*3
O0-3'OO82^.4
3366510s
'1
V. S s' 2 8 I S
V\fTRC
4
5
6
7

Petitioner(s)
Case No. 08-3-00821-4
vs.
WITNESS RECORD

____________ Respondent(s)
10
11
NAME
12
13
RELATIONSHIP TO CASE
DATE
JOLENE HARRISON
PETITIONER
1/ 21/10
CHRISTOPHER HARRISON
RESPONDENT
1/ 21/10
14
15
16
17
18
19
20
21
22
23
24
25
WITNESS RECORD -1
JOLENE MARIE HARRISON VS. CHRISTOPHER LEE
HARRISON, 08-3-00821-4
1 ^ 2 .^ 2 0 1 .0
08*3-00821-
33665113
t3 m z
01-29-10
EXRV
4
5
6
7
8
9

Petitioner(s)
EXHIBIT RECORD
vs.
10
11
Cause No. 08-3-00821-4

____________ Respondent(s)
12
13
14
15
P
No.
Description
Off
Obj
16
17
Admitted
Agreed
Denied
Illustrative
Published
Redacted
Reserved
Withdrawn
Medical Records
Denied
Counseling Records
Denied
Date
18
DUI Victims Impact Panel Certificate
Admitted
1/ 21/10
19
Center East Certificate
Admitted
1/ 21/10
Habitual Traffic Offender Document Review
Admitted
1/ 21/10
Jensen Rentals Late Charge Notice
Admitted
1/ 21/10
Sheriff Arrest Report
Admitted
1/ 21/10
Pierce County Corrections Booking Document
Admitted
1/ 21/10
Letter from Pierce County Victim Advocate
Admitted
1/ 21/10
10
Letter from Pierce County District Court

Probation
Admitted
1/ 21/10
11
Correspondence from Darlene Hagel
12
Find My Court Date Printable Case Detail
20
21
22
23
24
25
EXHIBIT RECORD-1
JOLENE MARIE HARRISON VS. CHRISTOPHER LEE HARRISON, 08-3-00821-4
Denied
Admitted
1/21/10
Recd
by
Clerks
Office
-T-BB*
1
2
Description
No.
Off
Obj
Admitted
Agreed
Denied
Illustrative
Published
Redacted
Reserved
Withdrawn
4
5
6
133*5
Date
13
Letters to Katie from Dad
Admitted
1/21/10
14
Letter from Chris to Jolene
Admitted
1/21/10
15
Letter from Dad
Admitted
1/21/10
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
EXHIBIT RECORD - 2
JOLENE MARIE HARRISON VS. CHRISTOPHER LEE HARRISON, 08-3-00821-4
Recd
by
Clerks
Office
1^20/2818
100098

Petition er(s)
vs.
Cause N um ber:08-3-00821-4
Page 1 of 3

Respondent(s)
Judge/Commissioner: KATHRYN J. NELSON
Court Reporter: DANA EBY
Judicial Assistant/Clerk: GINELE EILERT
HARRISO N, JO LE N E MARIE
HARRISON, CH R IS T O PH ER L E E JR
Proceeding Set: Relocation Trial

Proceeding Outcome: Non-Jury Trial
Outcome Date:01/25/2010 9:26
Resolution:
C lerk's Scom is CodeiNJTRIAL

Proceeding Outcome code:NJTRIAL
IxcalciviLpbl. d_dvi)joumal_report_cover
7333
1 ^ 79^ 2:313
13 SB


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 3
Judge/Commissioner:
KATHRYN J. NELSON
__________________________________MINUTES OF PROCEEDING__________________
Court ReporterDANA EBY
January 20, 2010 09:21 AM This matter is held in open court for trial. Jolene Harrison (pro
se) and Christopher Harrison (pro se) are present. 09:26 AM Colloquy. Christopher
Harrison indicates he does not object to relocation, but has concerns about parenting plan
provisions.
09:40 AM Recess.
09:51 AM Colloquy.
09:52 AM Recess. This matter will
resume on 1/21/10 at 9:00 re: parenting plan issues.

Start Date/Time: 01/21/10 1:53 PM
Court Reporter:DANA EBY
January 2 1 ,2 0 1 0 01:53 PM Court is reconvened. Parties are present.

parties are duly sworn.
0 1 :56 PM Both
0 1 :56 PM Petitioner Jolene Harrison - opening statement.
PM Respondent Christopher Harrison - opening statement.

takes the stand and testifies - direct examination.
02:54 PM Recess (mark exhibits).
02:00
02:01 PM Jolene Harrison
02:54 PM Colloquy re: scheduling.
03:15 PM Jolene Harrison resumes the stand and
continues testimony.
03:16 PM Exhibit 1 and 2 are offered, objected to, denied.

03:18 PM Exhibit 3, 4, 5, 6, 7, 8, 9 ,1 0 are offered, no objection, admitted.
03:25 PM Exhibit 11 is denied.
03:28 PM Exhibit 12 is offered, no objection, admitted.
03:29 PM Exhibits 1 3 ,1 4 ,1 5 are offered, objected to, admitted.

03:29 PM Christopher Harrison declines cross examination of Jolene Harrison.
03:29 PM Christopher Harrison takes the stand and testifies - direct examination.
PM Jolene Harrison - cross examination of Christopher Harrison.
JUDGE/COM M ISSIONER: KATHRYN J. N E LSO N
Year 2010
03:45
04:11 PM Discussion re:
? -& B S
13SS

MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 3 of 3
Judge/Commissioner:
KATHRYN J. NELSON
__________________________________MINUTES OF PROCEEDING______________________________
possible witness scheduling.
04:16 PM Jolene Harrison - closing argument.
Christopher Harrison - closing argument.

ruling.
04:22 PM
04:25 PM Colloquy. Court will issue a written
04:29 PM Recess.
End Date/Time: 01/21/10 4:29 PM

Court ReportenDANA EBY
COURT ISSUES WRITTEN DECISION AND MAILS COPIES OF FINAL PARENTING PLAN TO PARTIES.
JUDGE/COM M ISSIONER: KATHRYN J. N ELSO N
Year 2010
i> 29/2010

County of
JOLENE CHARLTON AKA JOLENE
HARRISON
No. 08-3-00821-4
Petitioner,
and
Respondent.
Parenting Plan
[ ] Proposed (PPP)
[ ] Temporary (PPT)
fXI Final Order (PP)

[X]

Name
CHRISTOPHER LEE HARRISON JR

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181; .187; . 194
Age
la a a fe i
ls2By2& i&
139662

Under certain circumstances, as outlined below, f/re court m ay limit or prohibit a parents
contact with the child and the right to make decisions for the child.
2.1

[X]
2.2
Does not apply.

[X]
The fathers involvement or conduct may have an adverse effect on the childs best
interests because of the existence of the factors which follow:
[X]
[]
[X]
t]
[]
[]
[X]

that interferes with the performance o f parenting functions,
The absence or substantial impairment o f emotional ties between the parent and
child.
The abusive use o f conflict by the parent which creates the danger of serious
Other: The factors above were prior to current 11 month (and continuing)
treatment to address dual issues of mental health and alcohol abuse by father.

The residential schedule must set forth where the child shall reside each day of the year,
occasions, and what contact the child shall have with each parent Parents are encouraged to
create a residential schedule that meets the developmental needs o f the child and individual
needs of their family. Paragraphs 3.1 through 3.9 are one way to write your residential
schedule. If you do not use these paragraphs, write in your own schedule in Paragraph 3.13.
3.1

[X]
Prior to enrollment in school, the child shall reside with the mother, except for the
following days and times when the child will reside with or be with the other parent:
Every other week
If Fathers time is exercised in the Tri Cities, it begins on Fridays at the time of transfer
of CJ to Fathers care.with a target of Father being back in Tri Cities with CJ by 8:00
p.m. on Friday, and CJ should be transferred to Mother in time to be home by 8:00 p.m.
on Sunday.

I s.2 9
IS
1 3 ?fe 3
I f F a t h e r s t im e i s e x e r c i s e d i n S e a t t le , 8 : 0 0 p .m . i s t h e la t e s t a p p r o x i m a t e t im e o f f l i g h t
a r r i v a l i n S e a t t le , a n d C J s h a l l h e r e t u r n e d t o t h e h o m e a ir p o r t n o la t e r t h a n
a p p r o x i m a t e l y 6 : 0 0 p .m . o n S u n d a y .
3.2
School Schedule
U p o n e n r o llm e n t in s c h o o l, th e c h ild s h a ll r e s id e w it h th e m o t h e r e x c e p t f o r th e f o llo w in g d a y s
a n d t im e s w h e n t h e c h i l d w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a r e n t :
S a m e as above.
3.3

T h e c h ild s h a ll r e s id e w it h th e m o t h e r d u r in g w in t e r v a c a t io n , e x c e p t f o r th e f o l l o w i n g d a y s a n d
t im e s w h e n th e c h ild w i l l r e s id e w it h o r b e w it h th e o t h e r p a re n t:
S e e S e c t i o n 3 .7 .
3.4

T h e c h ild s h a ll re s id e w it h the m o t h e r d u r in g o t h e r s c h o o l b re a k s, e x c e p t f o r the f o llo w in g d a y s
a n d t im e s w h e n t h e c h i l d w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a r e n t :
T h a n k s g i v i n g - S e e S e c t i o n 3 .7 .
3.5
Summer Schedule
U p o n c o m p le t io n o f the s c h o o l y e a r, the c h ild s h a ll re s id e w it h the m o th e r, e x c e p t f o r th e
f o l l o w i n g d a y s a n d t im e s w h e n t h e c h i l d w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a r e n t :
F a t h e r to b e a llo w e d in a d d it io n to r e g u la r e v e r y o t h e r w e e k e n d v is it :
I w e e k in June, 1
w e e k in J u ly a n d 1 w e e k in A u g u s t b e g in n in g w it h the F r id a y o f a r e g u la r w e e k e n d v is it
f o r f a t h e r.
3.6

T h e s c h e d u le f o r v a c a t io n w it h p a re n ts is a s f o llo w s :
A s t h e c h i l d g r o w s t h e t im e d u r i n g th e
s u m m e r m a y i n c r e a s e i n t o b l o c k s o f t im e f o r b o t h p a r e n t s e s p e c i a l l y t o a c c o m m o d a t e s p e c i a l
v a c a tio n s .
3.7

T h e r e s id e n t ia l s c h e d u le f o r th e c h ild f o r th e h o lid a y s lis t e d b e l o w i s a s f o llo w s :

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181;. 187;. 194
' j / , 2 5 / 2 If i
W it h M o t h e r
W it h Father
(S p e c if y Y e a r
(S p e c ify Y e a r
O d d / E ve n / E ve rv)
N e w Y e a r s D a y
Even
Odd
M a r t in L u th e r K in g D a y
S e e W e e k e n d S c h e d u le
P r e s id e n t s D a y
M e m o r ia l D a y
J u ly 4th
S e e S u m m e r S c h e d u le
Labor Day
V e te ra n s D a y
E ve ry
T h a n k s g iv in g D a y
Even
C h r is t m a s E v e
Odd
Even
C h r is t m a s D a y
Odd
Even
C h r is t m a s B r e a k
Odd
Even
[x ]
, i 3 if
Odd
F o r p u r p o s e s o f t h is p a r e n t in g p la n , a h o lid a y s h a ll b e g in a n d e n d a s f o llo w s (s e t fo rth

t im e s ) :
S e e S e c t i o n 3 .1 a b o v e . W e e k e n d s m a y i n c l u d e h o l i d a y M o n d a y s . i n w h i c h c a s e
t h e S u n d a y r e t u r n t im e b e c o m e s M o n d a y .
3.8

T h e r e s id e n t ia l s c h e d u le f o r th e c h ild f o r th e f o llo w in g s p e c ia l o c c a s io n s ( f o r e x a m p le , b ir t h d a y s )
is a s fo llo w s :
M o t h e r s D a v
W i t h P e t itio n e r
W it h R e sp o n d e n t
O d d / E ve n/ E ve rv)
E ve ry
F a t h e r s D a v
3.9
E ve ry

D o e s n o t a p p ly .
3.10
Restrictions
[X ]
T h e r e a re lim it in g fa c to r s in p a r a g r a p h 2.2 , a n d th e re a re r e s t r ic t io n s o n th e
[ ] p e t i t i o n e r s [ X ] f a t h e r s r e s i d e n t i a l t im e w i t h t h e c h i l d r e n f o r t h e f o l l o w i n g r e a s o n s :
H i s t o r y o f D W L S a n d a lc o h o l a b u s e r e q u ir e s n o v is it s e x c e p t w it h a p p r o v e d p e r s o n s a n d
s o m e o n e t r a n s p o r t i n g w i t h a v a l i d d r i v e r s l i c e n s e a n d i n s u r a n c e . M o t h e r h a s s o l e
d e c i s i o n m a k i n g a u t h o r it y .
3.11
T r a n s p o r t a t i o n a r r a n g e m e n t s f o r th e c h i l d , b e t w e e n p a r e n t s s h a l l b e a s f o l l o w s :

rt
i.y 2 5 * 2-1s(2.S s
W h e n v is it s o c c u r in T r i C itie s , F a t h e r s h a ll t ra v e l 7 5 % a n d M o t h e r s h a ll tra v e l 2 5 % o f th e w a y ,
a n d F a t h e r s h a l l p a y M o t h e r $ 2 5 u n t il s u c h t im e t h a t F a t h e r s t a r t s p a y i n g c h i l d s u p p o r t , t h e n th e
a r r a n g e m e n t s h a l l c h a n g e to s h a r i n g c o s t s 5 0 / 5 0 .
A i r t r a v e l c o s t s a r e s h a r e d 5 0 / 5 0 w i t h e a c h a l t e r n a t i n g p a y m e n t o f t h e e n t ir e r o u n d t r i p c o s t a n d
s t e w a r d e s s fe e o r fe e f o r a c c o m p a n y in g p e r so n .
3.12
T h e c h i l d r e n n a m e d i n t h i s p a r e n t i n g p l a n a r e s c h e d u l e d t o r e s i d e t h e m a j o r i t y o f t h e t im e w i t h
th e [ X ] M o t h e r .
T h i s p a r e n t i s d e s i g n a t e d t h e c u s t o d i a n o f t h e c h i l d s o l e l y f o r p u r p o s e s o f a ll
o t h e r s ta te a n d f e d e r a l s t a t u t e s w h i c h r e q u i r e a d e s i g n a t i o n o r d e t e r m i n a t i o n o f c u s t o d y .
T h is
d e s i g n a t i o n s h a l l n o t a f f e c t e it h e r p a r e n t s r i g h t s a n d r e s p o n s i b i l i t i e s u n d e r t h is p a r e n t i n g p la n .
3.13
Other
N o t r a n s p o r t i n g o f c h i l d u n l e s s a p p r o v e d d r i v e r h a s l i c e n s e a n d i n s u r a n c e . M s . P e r g r i m , F a t h e r s
a u n t o r u n c l e , M o t h e r a n d F a t h e r a ll a p p r o v e d a n d o t h e r s a s m e n t i o n e d b y M o t h e r a r e a p p r o v e d .
I n T r i C it ie s , C J w i l l s p e n d n ig h t s at a p p r o v e d lo c a t io n s : A u n t a n d U n c l e a n d F a t h e r s M o t h e r
a n d F a t h e r s F a t h e r a r e a p p r o v e d .
I n A u b u r n , M s . P e r g r im i s a p p r o v e d a n d F a t h e r m a y h o s t C J at th a t h o m e o r w it h in h o m e s o f
o t h e r a p p r o v e d p e r s o n s s u c h a s r e la t iv e s m e n t io n e d in c o u rt.
T h e p a r e n t s m a y m e d ia t e w h e n o r i f F a t h e r s t im e n o l o n g e r n e e d s to b e i n c o n j u n c t i o n w i t h
o v e r n i g h t s a t a f a m i l y h o m e o r i n th e p r e s e n c e o f a n o t h e r a d u lt ( M s . P e r g r i m ) . I f m e d i a t i o n f a il s ,
th e p a r t ie s m a y b r in g th e is s u e to co u rt.
3.14

T h i s i s a s u m m a r y o n l y . F o r t h e f u l l te xt, p l e a s e s e e R C W
2 6 .0 9 .4 3 0 th ro u g h 2 6 .0 9 .4 8 0 .
I f t h e p e r s o n w i t h w h o m t h e c h i l d r e s i d e s a m a j o r i t y o f t h e t im e p l a n s t o m o v e , t h a t p e r s o n s h a l l
g i v e n o t i c e t o e v e r y p e r s o n e n t it le d t o c o u r t o r d e r e d t im e w i t h t h e c h i l d .
I f t h e m o v e i s o u t s i d e t h e c h i l d s s c h o o l d is t r ic t , t h e r e l o c a t i n g p e r s o n m u s t g i v e n o t i c e b y
p e r s o n a l s e r v i c e o r b y m a i l r e q u i r i n g a r e t u r n r e c e ip t . T h i s n o t i c e m u s t b e a t le a s t 6 0 d a y s b e f o r e
th e in t e n d e d m o v e .
I f t h e r e l o c a t i n g p e r s o n c o u l d n o t h a v e k n o w n a b o u t t h e m o v e i n t im e t o g i v e
6 0 d a y s n o t ic e , th a t p e r s o n m u s t g iv e n o t ic e w it h in 5 d a y s a fte r le a r n in g o f th e m o v e . T h e
n o t ic e m u s t c o n t a in the in f o r m a t io n r e q u ir e d in R C W
2 6 .0 9 .4 4 0 .
S e e a ls o fo rm D R P S C U
0 7 . 0 5 0 0 , ( N o t ic e o f In t e n d e d R e lo c a t io n o f A C h ild ) .
I f t h e m o v e i s w i t h i n t h e s a m e s c h o o l d is t r ic t , t h e r e l o c a t i n g p e r s o n m u s t p r o v i d e a c t u a l n o t i c e b y
a n y r e a s o n a b l e m e a n s . A p e r s o n e n t it le d t o t im e w i t h t h e c h i l d m a y n o t o b j e c t to t h e m o v e b u t
m a y a s k f o r m o d if ic a t io n u n d e r R C W
2 6 .0 9 .2 6 0 .
N o t i c e m a y b e d e l a y e d f o r 2 1 d a y s i f t h e r e l o c a t i n g p e r s o n i s e n t e r i n g a d o m e s t i c v i o l e n c e s h e lt e r
o r i s m o v i n g t o a v o i d a c le a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o h e a l t h a n d s a f e t y .
I f i n f o r m a t i o n i s p r o t e c t e d u n d e r a c o u r t o r d e r o r t h e a d d r e s s c o n f i d e n t i a l i t y p r o g r a m , it m a y b e
w i t h h e l d f r o m t h e n o t ic e .

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187; .194
Y B tiB .1Y 2^9Y^2B i-B .43-88o>
A r e lo c a t in g p e r s o n m a y a s k th e c o u rt to w a iv e a n y n o t ic e r e q u ir e m e n t s th a t m a y p u t th e h e a lth
a n d s a f e t y o f a p e r s o n o r a c h ild at ris k .
F a i l u r e t o g i v e t h e r e q u i r e d n o t i c e m a y b e g r o u n d s f o r s a n c t io n s , i n c l u d i n g c o n t e m p t .
confirmed.
A p e r s o n e n t it le d t o t im e w i t h a c h i l d u n d e r a c o u r t o r d e r c a n f i l e a n o b j e c t i o n to t h e c h i l d s
r e l o c a t i o n w h e t h e r o r n o t h e o r s h e r e c e i v e d p r o p e r n o t ic e .
A n o b je c t io n m a y b e f ile d b y u s in g the m a n d a t o r y p a tte rn f o r m W P F D R P S C U 0 7 . 0 7 0 0 ,
( O b j e c t io n to R e lo c a t io n / P e t it io n f o r M o d i f i c a t i o n o f C u s t o d y D e c r e e / P a r e n t in g P la n / R e s id e n t ia l
S c h e d u l e ) . T h e o b j e c t i o n m u s t b e s e r v e d o n a l l p e r s o n s e n t it le d t o t im e w i t h t h e c h i l d .
T h e r e l o c a t i n g p e r s o n s h a l l n o t m o v e t h e c h i l d d u r i n g t h e t im e f o r o b j e c t i o n u n l e s s : ( a ) th e
d e la y e d n o t ic e p r o v is io n s a p p ly ; o r ( b ) a c o u r t o r d e r a llo w s th e m o v e .
I f t h e o b j e c t i n g p e r s o n s c h e d u l e s a h e a r i n g f o r a d a t e w i t h i n 1 5 d a y s o f t i m e l y s e r v i c e o f th e
o b je c t io n , th e r e lo c a t in g p e r s o n s h a ll n o t m o v e th e c h ild b e fo r e th e h e a r in g u n le s s t h e re is a
c le a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o t h e h e a l t h o r s a f e t y o f a p e r s o n o r a c h i l d .
IV. Decision Making

4.1
E a c h p a re n t s h a ll m a k e d e c is io n s r e g a r d in g th e d a y -t o -d a y ca re a n d c o n tro l o f e a c h c h ild w h ile
t h e c h i l d i s r e s i d i n g w i t h t h a t p a r e n t . R e g a r d l e s s o f t h e a l l o c a t i o n o f d e c i s i o n m a k i n g i n t h is
p a r e n t in g p la n , e it h e r p a r e n t m a y m a k e e m e r g e n c y d e c is io n s a ff e c t in g th e h e a lt h o r s a f e t y o f th e
c h ild r e n .
4.2
Major Decisions
M a j o r d e c is io n s r e g a r d in g e a c h c h ild s h a ll b e m a d e a s fo llo w s :
E d u c a t io n d e c is io n s
4.3
[X ]
N o n - e m e r g e n c y h e a lth c a re
[X ]
R e lig io u s u p b r in g in g
[X ]
[]
re sp o n d e n t
[]
jo in t
M oth e r
[]
re sp o n d e n t
[]
jo in t
M oth e r
[]
re sp o n d e n t
[]
jo in t
M oth e r

[X ]
S o l e d e c is io n m a k i n g s h a ll b e o r d e r e d to th e [ X ] M o t h e r f o r th e f o llo w i n g re a s o n s :
[X ]
O n e p a re n t is o p p o s e d to m u tu a l d e c is io n m a k in g , a n d s u c h o p p o s it io n is
r e a s o n a b l y b a s e d o n t h e f o l l o w i n g c r it e r ia :
(a )
T h e e x is t e n c e o f a lim it a t io n u n d e r R C W
(b )
W h e t h e r th e p a r e n t s h a v e d e m o n s t r a t e d a b il it y a n d d e s ir e t o c o o p e r a t e
2 6 .0 9 .1 9 1 ;
w it h o n e a n o t h e r in d e c is io n m a k in g in e a c h o f th e a re a s in
R C W
2 6 .0 9 .1 8 4 (4 )(a ); a n d

?33
(c )
ls29/Zm ?i
A.
T h e p a r e n t s g e o g r a p h i c p r o x i m i t y t o o n e a n o t h e r , t o th e e x t e n t t h a t it
a ffe c ts t h e ir a b ilit y to m a k e t im e ly m u t u a l d e c is io n s .
[X ]
D i s p u t e s b e t w e e n t h e p a r t ie s , o t h e r t h a n c h i l d s u p p o r t d is p u t e s , s h a l l b e s u b m i t t e d t o ( l i s t p e r s o n
o r a g e n c y ):
[X ]
m e d i a t i o n b y C o m p a s s i o n a t e R e s o l u t i o n s , S e a t t le , W a s h i n g t o n ,
i f t h is b o x i s c h e c k e d
a n d i s s u e s o f d o m e s t i c v i o l e n c e o r c h i l d a b u s e a r e p r e s e n t , t h e n t h e c o u r t f i n d s t h a t th e
v i c t i m r e q u e s t e d m e d ia t io n , t h a t m e d i a t i o n i s a p p r o p r ia t e a n d t h a t t h e v i c t i m i s p e r m it t e d
to h a v e a s u p p o r t in g p e r s o n p r e se n t d u r in g th e m e d ia t io n p r o c e e d in g s , o r
T h e c o s t o f t h i s p r o c e s s s h a l l b e a llo c a t e d b e t w e e n t h e p a r t ie s a s f o l l o w s :
[X ]
5 0 % M o t h e r 5 0 % Father
T h e d i s p u t e r e s o l u t i o n p r o c e s s s h a l l b e c o m m e n c e d b y n o t i f y i n g t h e o t h e r p a r t y b y c e r t i f i e d m a il.
M e d i a t i o n w o u l d b e b y t e l e c o n f e r e n c i n g t o a c c o m m o d a t e M o t h e r s lo c a t io n .
In th e d is p u t e r e s o lu t io n p ro c e s s :
(a )
P r e f e r e n c e s h a ll b e g iv e n to c a n y i n g o u t t h is P a r e n t in g P la n .
(b )
U n l e s s a n e m e r g e n c y e x is t s, th e p a r e n t s s h a ll u s e th e d e s ig n a t e d p r o c e s s to r e s o lv e
(c )
A w r it t e n r e c o r d s h a ll b e p r e p a r e d o f a n y a g re e m e n t r e a c h e d in c o u n s e l in g o r m e d ia t io n
d i s p u t e s r e l a t i n g t o i m p l e m e n t a t i o n o f t h e p l a n , e x c e p t t h o s e r e la t e d to f i n a n c i a l s u p p o r t .
a n d o f e a c h a rb itr a t io n a w a r d a n d s h a ll b e p r o v id e d to e a c h p a rty .
(d )
I f th e c o u rt f in d s th a t a p a re n t h a s u s e d o r fru stra te d th e d is p u t e r e s o lu t io n p r o c e s s
w i t h o u t g o o d r e a s o n , t h e c o u r t s h a l l a w a r d a t t o r n e y s f e e s a n d f i n a n c i a l s a n c t i o n s to th e
o t h e r p a re n t.
(e )
T h e p a r t ie s h a v e th e r ig h t o f r e v ie w f r o m th e d is p u t e r e s o lu t io n p r o c e s s to th e s u p e r io r
c o u rt.

[X ]
T h e r e a re th e f o llo w in g o th e r p r o v is io n s :
1.
F a t h e r s h o u l d b e i n f o r m e d i n d e t a il a b o u t a l l e d u c a t i o n a l , m e d i c a l a n d r e l i g i o u s d e c i s i o n s ,
p r o v i d e r s , etc. F a t h e r m a y g i v e i n p u t t o M o t h e r a n d M o t h e r s h a l l c o n s i d e r it i n g o o d f a it h
b e f o r e h e r d e c i s i o n s a r e m a d e w h e n p r a c t i c a b le .
F a t h e r i s e n t i t le d t o a l l r e c o r d s a n d m a y
f u l l y p a r t i c i p a t e a s a p a r e n t i n a l l c o n c e r n i n g t h e c h ild .

7585
2.
1^ 29'Z'JW
1 3 & 0& B
F a t h e r s a l t e r n a t i n g w e e k e n d s h a l l b e d e s i g n a t e d f o r t h e y e a r i n a d v a n c e . T h e r e a r e n o m a k e
u p s a s it i s a n t ic i p a t e d b y t h e C o u r t th a t s o m e w e e k e n d v i s i t s w i t h F a t h e r m a y n o t o c c u r a n d
F a t h e r m u s t w a it fo r h is n e x t w e e k e n d .
T h e C o u r t b e l i e v e s t h a t a lt e r n a t in g s c h e d u l e w h i c h
i n c l u d e s m o s t M o n d a y h o l i d a y s w o u l d b e a p p r o p r ia t e f o r F a t h e r s s c h e d u l e e a c h y e a r .
3.
T h e p a r t i e s m a y a l w a y s m u t u a l l y a g r e e t o a v a r i a t i o n i n t h e s c h e d u l e e s p e c i a l l y w h e n it i s in
t h e c h i l d s b e s t in t e r e s t t o d o s o .
4.
I f M o t h e r a s c e r t a i n s F a t h e r h a s le f t o r b e e n d i s m i s s e d u n s u c c e s s f u l l y f r o m t r e a t m e n t o r
i n c u r s a c r i m i n a l a r r e s t , w a r r a n t , o r c h a r g e a f t e r t h e d a te o f t h i s P a r e n t i n g p la n , i n p e r s o n
v i s i t s s h a l l b e s u s p e n d e d p e n d i n g f u r t h e r c o u r t a c t io n .
5.
F a t h e r s h a l l h a v e r e a s o n a b l e t e le p h o n e c o n t a c t w i t h t h e c h i l d w h i c h m a y e x t e n d t o e l e c t r o n i c
c o m m u n i c a t i o n w h e n F a t h e r d e e m s a p p r o p r ia t e .
6.
F a t h e r s h a l l c o n f i r m h i s a lt e r n a t i n g w e e k e n d v i s i t a t i o n b y W e d n e s d a y a t 6 : 0 0 p . m . p r i o r t o
t h e w e e k e n d v is i t . I f F a t h e r f a i l s to c o n f i r m t h e v i s i t a t i o n b y t h i s t im e , t h a t w e e k e n d
v i s i t a t i o n s h a l l b e f o r f e it e d .


It i s o r d e r e d , a d j u d g e d a n d d e c r e e d t h a t th e p a r e n t i n g p l a n s e t f o r t h a b o v e i s a d o p t e d a n d a p p r o v e d a s a n
o rd e r o f t h is c o u rt.
W A R N IN G :
V i o l a t i o n o f r e s id e n t ia l p r o v i s i o n s o f t h is o r d e r w it h a c t u a l k n o w l e d g e o f it s t e r m s is
p u n is h a b le b y c o n te m p t o f c o u r t a n d m a y b e a c r im in a l o f fe n s e u n d e r R C W
9 A .4 0 .0 7 0 (2 ).
9 A .4 0 .0 6 0 (2 ) o r
V i o l a t i o n o f t h i s o r d e r m a y s u b j e c t a v i o l a t o r t o a rre st .
W h e n m u t u a l d e c i s i o n m a k i n g i s d e s i g n a t e d b u t c a n n o t b e a c h i e v e d , t h e p a r t i e s s h a l l m a k e a g o o d f a it h
e f f o r t to r e s o l v e t h e i s s u e t h r o u g h t h e d i s p u t e r e s o l u t i o n p r o c e s s .
I f a p a r e n t f a i l s t o c o m p l y w i t h a p r o v i s i o n o f t h i s p la n , t h e o t h e r p a r e n t s o b l i g a t i o n s u n d e r t h e p l a n a r e
n o t a ff e c t e d .
D ated :
f^n J. Nelson
P re se n te d b y :
(jcrp^
A p p r o v e d f o r e n try :
Jo(&r){_ C h arlton
S ig n a t u r e o f P a r t y o r L a w y e r / W S B A N o .
S ig n a t u r e o f P a r t y o r L a w y e r / W S B A ' T
P r in t N a m e
P r in t N a m e

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181;. 187; ,194
i 3 -Q 5 3
u p e r io r
o u rt
o f th e
V I, a
06-3-00^^
t e o f
fo r
a s h in g t o n
ie r c e
o u n ty
KATHRYN N ELSO N FAM ILY C O U R T - 1, JU D G E

GINELE EILERT, Judicial Assistant
(253) 798-3654
334 COUNTY-CITY BUILDING

930 T A C O M A A V E N U E SOUTH
TACO M A, W A 98402-2108
January 25, 2010
TO:
JOLENE CHARLTON AKA JOLENE HARRISON

RE:
JOLENE MARIE HARRISON vs. CHRISTOPHER LEE HARRISON
Pierce County Cause No. 08-3-00821-4

Dear Counsel/Litigants:
Thank you for your trial presentation.
entered by the Court.
Enclosed is a copy of the Final Parenting Plan
Sincerely,
GINELE C. EILERT
Judiciai Assistant
Ginele C. Eilert
Judicial Assistant
cc:
Pierce County Clerks Office for filing
' i & S 2 B S 2 e i &
11293
#0033
KEVIN STOCK
Clerk of the Superior Court and
Director of Arbitration
08-3-00821-d
35269719
LTDEX
10-26-10
F t t S f r * ^ C
u '
CCAxrfrt
DATE- October 25, 2010

TO WHOM IT MAY CONCERN:
RE:
Vo *
--
Pierce County Cause Number:
08-3-00821-4
C a s e Title: J O L E N E M A R I E H A R R I S O N V S . C H R I S T O P H E R
L E E H A R R IS O N
Appeal No.:
Appeal Status.
Please come in and withdraw the exhibits or authorize the County Clerk to
destroy them Return this letter with an "X " in the appropriate square
signifying your intentions.
L E x h ib its W ill B e D e s tr o y e d O n D E C E M B E R 1 , 2 0 1 0
LI f Y o u D o N o t R e s p o n d . >
Sincerely,
Kevin Stock, Clerk
Pierce County Superior Court
By
Michael Kapfhammer
Deputy Clerk, Evidence Section
798-7717
**********************************************************************-**************
____ I will pick up the exhibits DPetitioners DDefendants o n __________

(Date)
____ I hereby authorize the Pierce County Clerk to destroy the
Petitioners Defendants exhibits in Pierce County Cause Number
JOLENE MARIE C H A R LTO N

8418 184TH AVE E
B O N N EY LAKE, W A 98391
N \WORDDOCS\linx forms\vault\destroy exhibits

j
cm
I 2 a tto rn e ys\ C r
Pnrrt^t! on i**cyct!d J<sper
jr
SR
its
FILED
IN C O U N T Y C L E R K ' S O F F I C E
AM
DEC 1 4 2010
p.H.
sjERCE COUNTY, WASHINGTON

08-3-00821 -4
35545138
NTDE
12-15-10
K E V H I S T O C K . C -x -n iv * v i : t
pv
___ P tr*. I t
PIERCE COUNTY SUPERIOR COURT, STATE OF WASHINGTON

Plaintiff,
vs.

Defendant.
)
)
)
Case No.: 08-3-00821-4
)
|
Notice of Destruction of
Exhibits
(NTDE)
Receipt of Exhibits
(EXRECT)
ED A notice was filed and sent regarding destruction of exhibits on
/ / - /~ / &
EDNo response was received from either p arty

B N o response was received from Plaintiff/Petitioner__
No response was received from Defendant/Respondent

The exhibits in the above referenced case where destroyed on
/ ' / Y-
ED Exhibits in the above referenced case where picked up o n _____________________ by:

ED Plain tiff/Petitioner___________________________________________
EDDefendant/Respondent________________________________________
Deputy Clerk
Jjs 1 ?
08-3-00821-4
35665628
ORTSC
5. I
. 'J #
01-07-11

County of
AM!
JAN T & W fl
ay,
, In re:
No. 08-3-00821-4
Jolene Charlton
A.K.A. Jolene Harrison
Petitioner,
and

Contempt
(ORTSC)
Clerk's Action Required
Respondent.
It is Ordered:
(Name of nonrequesting party) _Jolene Charlton
shall appear in person before this court at
the place and time below and show cause why the relief requested in the motion should not be
granted.
/
/
Date: _
a.m7p.m.
Place:
Time:
/ / / _____________ ____ Time:
PIERCE COUNTY SUPERIOR COURT

------ 930 TACOMA AVE SOUTH-----TACOMA, W A 98402
^______
' 3 (_3
Room/Department:
If you fail to appear in person and defend at these proceedings the court may grant all o f the
relief requested and/or issue a bench warrant for your arrest without further notice to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may request
the court to appoint an attorney to represent you.
O th e r
Dated:
//
PM
PIER
l (/
Presenterbhy:
Signature o f Requesting Party or Lawyer/WSBA No.
Print or Type Name
\)
-------- .DEPUTY
ED
RK'S OFFICE
08-3-00821-4
35665638
PPP
01-07-11
- 6 2 tm
. deputy

County of
No. 08-3-00821-4
Jolene Charlton
and
Petitioner,
Respondent.
Parenting Plan
Proposed (PPP)
[ 1 Temporary (PPT)
[X ]
[X ]

proposed by (name)__Christopher Harrison__

Name
PM
Age
5

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's contact with the child(ren)
and the right to make decisions for the child(ren).
2.1

[x ]
2.2
Does not apply*

[x ]
The [ ] petitioners [ ] respondents involvement or conduct may have an adverse effect on the child(ren)s best
interests because o f the existence of the factors which follow:
[x ]
[]
[x ]
[]
f]
[]
[x ]
Neglect or substantial nonperformance o f parenting functions.

A long-term emotional or physical impairment which interferes with the performance o f parenting
functions as defined in RCW 26.09.004.
A long-term impairment resulting from drug, alcohol, or other substance abuse that interferes with the
performance of parenting functions.
The absence or substantial impairment of emotional ties between the parent and child.
The abusive use o f conflict by the parent which creates the danger o f serious damage to the childs
psychological development.
A parent has withheld from the other parent access to the child for a protracted period without good
cause.
Other: the factors above were prior to 12 months o f treatment which started 26 months ago (and
continuing) treatment to address dual issues o f mental health and alcohol abuse by father.

The residential schedule must set forth where the child(ren) shall reside each day o f the year, including provisions for
holidays, birthdays o f family members, vacations, and other special occasions, and what contact the child(ren) shall
have with each parent Parents are encouraged to create a residential schedule that meets the developmental needs
of the child(ren) and individual needs o f their family. Paragraphs 3 .1 through 3.9 are one way to write your residential
3.1

[x ]
Prior to enrollment in school, the child(ren) shall reside with the mother
except for the following days and times when the child will reside with or be with the other parent:
from (day and tim e)____________________ to (day and tim e)____________________
55
& JL'/
1>
~3
e ve ry oth e r w e e k e n d
3.2
School Schedule
U p o n e n r o llm e n t in s c h o o l, t h e c h ild s h a ll r e s id e w it h th e m o t h e r
e x c e p t f o r th e f o l l o w i n g d a y s a n d t im e s w h e n th e c h ild w i l l r e s id e w it h o r b e w it h th e o t h e r p a re n t:
sam e a s a b o ve
3.3

T h e c h il d s h a ll r e s id e w it h th e m o t h e r d u r in g w in t e r v a c a t io n , e x c e p t f o r th e f o l l o w i n g d a y s a n d t im e s w h e n th e c h ild w i l l
r e s id e w it h o r b e w it h th e o t h e r p a re n t:
S e e S e c t io n 3 .7 .
3.4

T h e c h i l d s h a l l r e s i d e w i t h t h e m o t h e r d u r i n g o t h e r s c h o o l b r e a k s , e x c e p t f o r t h e f o l l o w i n g d a y s a n d t im e s w h e n t h e c h i l d
w ill r e s id e w it h o r b e w it h th e o t h e r p a re n t:
T h a n k s g i v i n g - S e e S e c t i o n 3 .7 .
3.5
Summer Schedule
U p o n c o m p le t io n o f th e s c h o o l y e a r, th e c h ild ( r e n ) s h a ll r e s id e w it h th e m o t h e r
e x c e p t f o r d i e f o l l o w i n g d a y s a n d t im e s w h e n t h e c h i l d ( r e n ) w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a r e n t :
F a t h e r t o b e a lo o w e d in a d d it io n to r e g u la r e v e r y o t h e r w e e k e n d v is it :
1 w e e k in J u n e , 1 w e e k i n J u l y a n d 1 w e e k in
A u g u s t b e g i n n i n g w i t h t h e F r i d a y o f a r e g u l a r w e e k e n d v i s i t f o r fa t h e r.
3.6

T he schedule for vacation w ith parents is as follows: As the child grows the tim e during the sum m er may increase into
blocks o f tim e for both parents especially to accom m odate special vactions.
3.7

T h e r e s id e n t ia l s c h e d u le f o r th e c h il d f o r t h e h o l id a y s lis t e d b e l o w is a s f o llo w s :
W it h P e t itio n e r
e v e n _______________________
Odd
M a r t in L u th e r K in g D a y
S e e W e e k e n d S c h e d u le ,
S e e W e e k e n d S c h e d u le .
J u ly 4th
Se e S u m m e r S c h e d u le ^
Labor Day
V e te ra n s D a y
E v e r y _____________________
E v e n ______________________
O d d _______________________
Even
O d d ________________________
Even
W in t e r H o lid a y B re a k
O d d _______________________
Even
[x ]
Odd,
F o r p u r p o s e s o f t h i s p a r e n t i n g p la n , a h o l i d a y s h a l l b e g i n a n d e n d a s f o l l o w s ( s e t f o r t h t im e s ) : S e e s e c t i o n 3 .1
a b o v e . W e e k e n d s m a y i n c l u d e h o l i d a y M o n d a y s i n w h i c h c a s e t h e S u n d a y r e t u r n t im e b e c o m e s M o n d a y .
[x ]
3.8
H o l i d a y s w h ic h f a ll o n a F r id a y o r a M o n d a y s h a ll in c lu d e S a t u r d a y a n d S u n d a y .
Schedule fo r Special Occasions

T h e re s id e n t ia l s c h e d u le f o r th e c h ild ( r e n ) f o r th e f o l l o w i n g s p e c ia l o c c a s io n s ( f o r e x a m p le , b ir t h d a y s ) is a s f o llo w s :
W it h P e t it io n e r
M o t h e r s D a v
e v e r y ___________________________
__________________________________
F a t h e r s D a v
__________________________________
e v e r y ___________________________
3.9 . Priorities Under the Residential Schedule

Does not apply
3.10
Restrictions
t]
There are limiting factors in paragraph 2.2, and there are restrictions on the fathers residential time with the child
for the following reasons:
History of DWLS and alcohol abuse requires no visits except with approved persons someone transporting with a
valid diver's license and insurance. Mother has sole decision authority.
3.11

Child shall only be transported by a licensed, insured driver.
3.12
The children named in this parenting plan are scheduled to reside the majority of the time with the mother. This parent is
designated the custodian of the child solely for purposes of all other state and federal statutes which require a designation
or determination of custody. This designation shall not affect either parents rights and responsibilities under this
parenting plan.
3.13
Other
Does not apply
2 2 2 v ^ 2. '
3.14
i t
Summary of RCW 26.09.430 - .480, Regarding Relocation o f a Child

T h i s i s a s u m m a r y o n l y . F o r t h e f u l l te x t, p l e a s e s e e R C W
2 6 .0 9 .4 3 0 th ro u g h 2 6 .0 9 .4 8 0 .
I f t h e p e r s o n w i t h w h o m t h e c h i l d r e s i d e s a m a j o r i t y o f t h e t im e p l a n s t o m o v e , t h a t p e r s o n s h a l l g i v e n o t i c e t o e v e r y
p e r s o n e n t it le d t o c o u r t o r d e r e d t im e w i t h t h e c h i l d .
I f t h e m o v e i s o u t s i d e t h e c h i l d s s c h o o l d is t r ic t , t h e r e l o c a t i n g p e r s o n m u s t g i v e n o t i c e b y p e r s o n a l s e r v i c e o r b y m a i l
r e q u i r i n g a r e t u r n r e c e ip t . T h i s n o t i c e m u s t b e a t le a s t 6 0 d a y s b e f o r e t h e i n t e n d e d m o v e .
I f th e r e lo c a t in g p e r s o n c o u ld
n o t h a v e k n o w n a b o u t th e m o v e in t im e t o g iv e 6 0 d a y s n o t ic e , th a t p e r s o n m u s t g i v e n o t ic e w it h in 5 d a y s a ft e r le a r n in g
o f t h e m o v e . T h e n o t ic e m u s t c o n t a in th e in f o r m a t io n r e q u ir e d in R C W
2 6 .0 9 .4 4 0 .
S e e a ls o fo r m D R P S C U 0 7 .0 5 0 0 ,
( N o t i c e o f In t e n d e d R e l o c a t i o n o f A C h i l d ) .
I f t h e m o v e i s w i t h i n t h e s a m e s c h o o l d is t r ic t , t h e r e l o c a t i n g p e r s o n m u s t p r o v i d e a c t u a l n o t i c e b y a n y r e a s o n a b l e m e a n s .
A p e r s o n e n t it le d t o t im e w i t h t h e c h i l d m a y n o t o b j e c t t o t h e m o v e b u t m a y a s k f o r m o d i f i c a t i o n u n d e r R C W
2 6 .0 9 .2 6 0 .
N o t i c e m a y b e d e la y e d f o r 2 1 d a y s i f th e r e lo c a t in g p e r s o n is e n t e r in g a d o m e s t ic v io le n c e s h e lt e r o r is m o v i n g t o a v o id a
c le a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o h e a l t h a n d s a f e t y .
I f i n f o r m a t i o n i s p r o t e c t e d u n d e r a c o u r t o r d e r o r t h e a d d r e s s c o n f i d e n t i a l i t y p r o g r a m , it m a y b e w i t h h e l d f r o m t h e n o t ic e .
A r e lo c a t in g p e r s o n m a y a s k th e c o u r t to w a iv e a n y n o t ic e r e q u ir e m e n t s th a t m a y p u t th e h e a lth a n d s a f e t y o f a p e r s o n o r
a c h i l d a t ris k .
F a ilu r e t o g i v e t h e r e q u ir e d n o t ic e m a y b e g r o u n d s f o r s a n c t io n s , i n c l u d in g c o n t e m p t
If no objection is filed within 30 days after service of the notice of intended relocation, the relocation will be
permitted and the proposed revised residential schedule may be confirmed.
A p e r s o n e n t it le d t o t im e w i t h a c h i l d u n d e r a c o u r t o r d e r c a n f i l e a n o b j e c t i o n t o t h e c h i l d s r e l o c a t i o n w h e t h e r o r n o t h e
o r s h e r e c e i v e d p r o p e r n o t ic e .
A n o b je c t io n m a y b e f ile d b y u s i n g th e m a n d a t o r y p a tte rn f o r m W P F D R P S C U 0 7 . 0 7 0 0 , ( O b j e c t io n to
R e lo c a t io n / P e t it io n f o r M o d i f i c a t i o n o f C u s t o d y D e c r e e / P a r e n t in g P la n / R e s id e n t ia l S c h e d u le ) . T h e o b j e c t io n m u s t b e
s e r v e d o n a l l p e r s o n s e n t it le d t o t im e w i t h t h e c h i l d .
T h e r e l o c a t i n g p e r s o n s h a l l n o t m o v e t h e c h i l d d u r i n g t h e t im e f o r o b j e c t i o n u n l e s s : ( a ) t h e d e l a y e d n o t i c e p r o v i s i o n s
a p p ly ; o r ( b ) a c o u rt o r d e r a llo w s th e m o v e .
I f th e o b j e c t in g p e r s o n s c h e d u le s a h e a r in g f o r a d a te w it h in 1 5 d a y s o f t im e ly s e r v ic e o f th e o b je c t io n , th e r e lo c a t in g
p e r s o n s h a l l n o t m o v e t h e c h i l d b e f o r e t h e h e a r i n g u n l e s s t h e r e i s a c l e a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o t h e h e a lt h
o r s a f e t y o f a p e r s o n o r a c h ild .
IV. Decision Making

4.1
E a c h p a re n t s h a ll m a k e d e c is io n s r e g a r d in g th e d a y -t o -d a y c a re a n d c o n t r o l o f e a c h c h ild w h ile th e c h ild is r e s id in g w it h
t h a t p a r e n t R e g a r d l e s s o f t h e a l l o c a t i o n o f d e c i s i o n m a k i n g i n t h i s p a r e n t i n g p la n , e i t h e r p a r e n t m a y m a k e e m e r g e n c y
d e c is io n s a ff e c t in g th e h e a lth o r s a f e t y o f th e c h ild r e n .
4,2
Major Decisions
M ajor decisions regarding each child shall be m ade as follows:
Education decisions
4.3
[x]
[X]
[X]
petitioner
petitioner
petitioner
[]
[]
[]
respondent
respondent
respondent
[3
[3
[]
joint
joint
joint

[x ]
Sole decision making shall be ordered to the mother for the following reasons:
[x ]
One parent is opposed to mutual decision making, and such opposition is reasonably based on the
following criteria:
(a)
The existence o f a limitation under RCW 26.09.191;
(b)
Whether the parents have demonstrated ability and desire to cooperate with one another in
decision making in each of the areas in
RCW 26.09.184(4)(a);
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 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.
[x ]
Disputes between the parties, other than child support disputes, shall be submitted to (list person or agency):
[x ]
mediation by Compassionate Resolutions, Seattle Washington, 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
[x ]
50 % petitioner 50 % respondent.
The dispute resolution process shall be commenced by notifying the other party by [ ] written request [ ] certified mail [ ]
other:

(a)
(b)
(c)
(d)
(e)

Unless an emergency exists, the parents shall use the designated process to resolve disputes relating to
implementation of the plan, except those related to financial support.
A written record shall be prepared o f any agreement reached in counseling or mediation and o f each arbitration
award and shall be provided to each party.
If the court finds that a parent has used or frustrated the dispute resolution process without good reason, the court
shall award attorneys fees and financial sanctions to the other parent.
The parties have the right o f review from the dispute resolution process to the superior court.

1. Father shall be informed in detail about all educational, medical and religious decisions, providers etc. Father may give
input to Mother and Mother shall consider it in good faith before her decisions are made when practicable. Father is
entitled to all records and may fully participate in all concerning the child.
(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under the laws of the state of
Washington that this plan has been proposed in good faith and that the statements in Part II of this Plan are true and
correct.

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an order o f this court.
WARNING: Violation o f residential provisions of this order with actual knowledge o f its terms is punishable by contempt o f
court and may be a criminal offense under RCW 9A.40.060(2) or 9A.40.070(2). Violation o f this order may subject a violator to
arrest.
When mutual decision making is designated but cannot be achieved, the parties shall make a good faith effort to resolve the issue
through the dispute resolution process.
If a parent fails to comply with a provision o f this plan, the other parents obligations under the plan are not affected.
Dated:
j ~ '6 '/ /
Judge/Commissioner
Approved for entry:

Print Name Christopher Harrison
Print Name
E-FILED
IN
T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
KEVIN STOCK
COUNTY CLERK
No. 08-3-00821-4
January 12 2011 9:53 AM
ORDER SETTING CASE SCHEDULE
Petitioner(s)
Type o f case:
IN V
Vs.
R espondent(s)
T rack A ssignm ent:
M odification o f C ustody
A ssignm ent D epartm ent:
N ELS
D ocket Code:
ORSCS
1/19/2011
N otice o f A dequate C ause & N ote fo r C om m Cal filed w /P etition or no later th an

C onfirm ation o f Service
2/2/2011
A dequate Cause H earing o n C om m issioner C alendar to b e held. (If this hearing is not held by this date,
p etition w ill b e dism issed)
3/2/2011 9:30
Set Settlem ent C onference D ate w ith Judge/C om m issioner E D M U N D M U R PH Y
3/16/2011
Certificate o f Parenting Class - Petitioner's (M ust be filed o n o r before)
3/16/2011
Certificate o f Parenting Class - R espondent's (M ust be filed on o r before)
3/16/2011
PlaintifFs/Petitioner's D isclosure o f Prim ary W itnesses
5/18/2011
6/8/2011
D efendant's/R espondent's D isclosure o f Prim ary W itnesses
6/22/2011
D isclosure o f R ebuttal W itnesses
7/6/2011
D eadline fo r F iling M otion to A djust T rial D ate
W eek o f 8/17/2011
Settlem ent C onference (To be held)
8/24/2011
E xchange o f W itness and E xhibit L ists and D ocum entary E xhibits
9/7/2011
D iscovery C utoff
9/21/2011 9:00
Trial
Unless otherwise instructed, A L L Attorneys/Parties shall report to the trial court at 9 :0 0 A M on

the date o f trial.
I f the case has b e e n filed, the p lain tiff shall serve a copy o f the Case Schedule o n the defendant(s) w ith the sum m ons and com plaint/
petition: P rovided th at in those cases w here service is by p u b lication the p lain tiff shall serve the Case Schedule w ith in five (5) co u rt days
o f service o f the defendant's first response/appearance. I f the case has not b e e n filed, b u t a n initial pleading is served, the Case Schedule
shall be served w ithin five (5) court days o f filing. See P C L R 1.

A ll attorneys and parties shall m ake them selves fam iliar w ith the Pierce County L ocal R ules, particularly those relating to case
scheduling. C om pliance w ith the scheduling rules is m andatory and failure to com ply shall result in sanctions appropriate to the
violation. I f a statem ent o f arbitrability is filed, P C L R 1 does n ot apply w hile the case is in arbitration.
Dated: January 12, 2011
Judge F A M IL Y C O U R T - 1
D epartm ent N ELS
in c o u n t y C le r k 's o ffic e
08-3-00821
35693109
01- 12* 11
AM JAN 12 2011
p .m.
PIERCE COUNTY WASHINGTON

ov
_______________
deputy

County of
In re:
No. 08-3-00821-4
Jolene Charlton
Petitioner,
and
Summons(Modifl cation/ Adjustm ent

of Custody Decree/Parenting Plan/
Residential Schedule)
(SM)
________________ ____________ Respondent.

To:
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 o f 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 o f the court.
If you do not serve your written response within 20 days (or 60 days if you are served
outside o f the state of Washington) after the date this summons was served on you,
exclusive o f the day of service, the court may enter an order o f default against you, and
the court may, without further notice to you, enter an order regarding adequate cause and
a decree to modify/adjust
custody decree/parenting plan/residential schedule and
providing for other relief requested in the petition. If you serve a notice o f appearance
on the undersigned person, you are entitled to notice before an order o f 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.
[x ]
[]
4.
Temporary residential placement or custody is not being sought.

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.
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/adjlisting 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 o f Custody Decree/Parenting
Plan/Residential Schedule. This form may be obtained by contacting the clerk o f 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:
http://www.courts.wa.gov/forms
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 o f this notice and
motion will be void.
7.
If you wish to seek the advice o f 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 o f your response on the petitioner is to send it by certified
mail with return receipt requested.
This summons is issued pursuant to Superior Court Civil Rule 4.1 o f the state o f Washington.
Dated:
/
Signature o f Moving Party or
Lawyer/WSBA No.
(Z k ffc
Print Name
File original of your response with

the clerk of the court at:
/J-c\
Serve a copy of your response on:

[ ] Moving Party [You may list an address
that is not your residential address where
you agree to accept legal documents. Any
time this address changes while this action
is pending, you must notify the opposing
parties in writing and file an updated
Confidential Information Form (WPF
DRPSCU 09.0200) with the court clerk ]
[ ] Moving Partys Lawyer
[Name o f Court]
[Name]
[Address]
[Address]
Zsx^Ztkll
08-3-00821-4
35811036
RTS
12381
02-01-11
FILED
FEB 01 2011
IN C O U N T Y C L E R K S O F F I C E
am
p .m .
PIERCE COUNTY. WASHINGTON

KEVIN S T O C l^ C o u n ty C le rk
BY---------------------^
DEPUTY

County of
In re:
No. 08-3-00821-4
Jolene Charlton
Petitioner,
and
Return of Service
(Optional Use)
(RTS)
Respondent.
/ D e c la r e :
1.
la m over the age of 18 years, and I am not a party to this action.
2.
I served the following documents to (name)__Jolene Charlton_____________
3.
[x ]
[x ]
[x ]
[]
[]
[]
[]
[]
[]
[]
[]
[x ]
[x ]

Notice Re: Dependent o f a Person in Military Service
notice o f hearing fo r_______________________
motion for and order to show cause re: Contempt_________________
declarations o f Christopher Harrison (2) Charlotte Pergrim (2)
[]
[]
temporary order
other:
SS83SS
2^122811
Date:
[]
[]
6.
6601 166th Ave.E., Sumner, WA 98390

[x ]
[]
5.
59836?
___1-28-2011________________________ Time: ___8:00 p.m.
Address:
4.
1 2 3 S i

by delivery to (name)________________________________________ , a person of suitable age and discretion
residing at the respondents usual abode.
by publication as provided in RCW 4.28.100. (File Affidavit o f Publication separately.)
(check only if there is a court order authorizing service by mail) by mailing two copies postage prepaid to the
person named in the order entered by the court on
(date)__________________________ . One copy was mailed by ordinary first class mail, the other copy was sent
by certified mail return receipt requested. (Tape return receipt below.) The copies were mailed on (date)
Service o f Notice on Dependent of a Person in Military Service.

[]
The Notice to Dependent of Person in Military Service was [ ) served on [ ] mailed by first class mail on (date)
[]
Other:
Other:
I declare under penalty o f peijury under the laws o f the state of Washington that the foregoing is true and correct.
ite)
W A __________ on (date) 1-31-11
Joe Flink
p L (~ L i /J [<
Print or Type Name
Service
Mileage
Total
File the original Return of Service with the cleric. Provide a copy to the law enforcement agency where protected person resides
if the documents served include a restraining order signed by the court.
E-FILED
January 12 2011 9:39 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
IN THE SUPER IO R CO URT OF THE STATE OF W ASHING TO N

IN A N D FOR PIERCE COUNTY

No. 08-3-00821-4
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:
Name: JOLENE MARIE HARRISON
Address: 12107 209TH 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
S h o w C ause
Nature of Hearing: Contempt
C alendar: Show Cause/Fam ily Law
CALENDAR DATE: Thursday, February 17, 2011
9:30 AM
WORKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,

BEFORE 12:00 NOON TWO COURT DAYS PRIOR TO HEARING
DATED:
January 12, 2011.
Signed:
NAME:
Phone:
ADDRESS: 6721 NATHAN AVE SE

AUBURN, WA 98092
Note for Commissioners Calendar (ntc.rptdesign)
/s/ CHRISTOPHER LEE HARRISON
WSBA#:
For:
1 of 1
E-FILED
January 12 2011 9:47 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)
Address: 12107 209TH AVE. CT. E. BONNEY LAKE, WA 98391
Phone:
Petitioner
M o tio n - T e m p o ra ry O rd e r
CALENDAR DATE: Thursday, February 17, 2011
9:30 AM

DATED:
January 12, 2011.
Signed:
NAME:
Phone:

AUBURN, WA 98092
WSBA#:
For:
1 of 1
FILED
08-3-00821-4
35693111
SPTMDC
01-12-11
JAN 1 2 2011
a m
P ERCE COUNTY WASHINGTON

KEVIN^p Sc K, County Clerk

County of
8V.
1' V
,< r
In re:
No. 0 0 -3
Jolene Charlton
Petition for Modification/

Adjustment of Custody Decree/
Parenting Plan/Residential
Schedule
(PTMD)
Petitioner,
and
Respondent.
'
Identification of Requesting Party/Parties
Name (first/last) Christopher Harrison_________________________ _ _ Birth date 04-16-1970.

King. WA_________________ __________ .
Name (first/last)__________________________________________ _ _ _ Birth d ate__________

Last known residence (county and state only)_____________________________________ .
1.2
Identification of Other Party/Parties
Name (first/last) Jolene Charlton______________________________ _
Birth date07-15-l975_
Last known residence (county and state only) Pierce, WA______________________ *

Name (first/last)_______________________________________________Birth d ate__________
Last known residence (county and state only)_____________________________________ .
Name (first/last)________________________________________ _
Birth d ate__________
Last known residence (county and state only)__________________________________.
1.3
Dependent Children
Name (first/last)

attached for:
1.1
PM
Christopher Lee Harrison Jr._____________________ Age
Name (first/last) _______ ______________________________________ A ge___

Name (first/last)____ .________________ __________________________ A ge___
............
DEPUTY
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age
II. Basis
2.1
Petition for an Order Modifying Custody Decree/Parenting Pfan/Residentiai Schedule

This is a petition for an order modifying the prior custody decree/parenting plan/residential schedule in this matter and
approving the proposed parenting plan/residential schedule, which is filed with this petition.
2.2
Adequate Cause
There is adequate cause for hearing the petition for modification.
2.3
Child Support
[x ]
[]
2.4
Does not apply.

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

The requesting party/parties reside(s) in (county and state only) ____________________________ .
The children reside in (county and state only) Pierce, WA________________________________________
The other party/parties reside(s) in (county and state only) _Pierce, WA_________________________ _
2.5

This court has jurisdiction over this proceeding for the reasons below;
[x ]
This court has exclusive continuing jurisdiction. The court has previously made a child custody, parenting plan,
resident ial schedule or visitation determination in this matter and retains jurisdiction under RCW 26.27.211.
f]

[]
[]
the children lived in Washington with a parent or a person acting as a parent for at least six consecutive
months immediately preceding the commencement of this proceeding.
the children are less than six months old and have lived in Washington with a parent or a person acting a
2 1595
[]
[]
[]
parent since birth.

any absences from Washington have been oniy temporary.
Washington was the home state o f the children within six months before the commencement o f this
proceeding and the children are absent from the state but a parent or person acting as a parent continues
to live in this state.
The children and die parents or the children and at least one parent or a person acting as a parent have significant
connection with the state other than mere physical presence, and substantial evidence is available in this state
concerning the children's care, protection, training and personal relationships, and:
[]
[j

The children's home state has declined to exercise jurisdiction on the ground that this state is the more
appropriate forum under RCW 26.27.261 or .271.
[]
All courts in the children's home state have declined to exercise jurisdiction on the ground that a court o f this
state is the more appropriate forum to determine the custody of the children under RCW 26.27.261 or .271.
[]
[]
This court has temporary emergency jurisdiction over this proceeding because the children are present in this
state and the children have been abandoned or it is necessary in an emergency to protect the children because the
children, or a sibling or parent of the children is subjected to or threatened with abuse. RCW 26.27.231.
[j
2.6
tvSStvS
[]
There is a previous custody determination that is entitled to be enforced under this chapter or a child
custody proceeding has been commenced in a court of a state having jurisdiction under RCW 26.27.201
through 26.27.221. The requirements of RCW 26.27.231(3) apply to this matter. This state's
jurisdiction over the children shall last until (date)________________________________ .
[]
There is no previous custody determination that is entitled to be enforced under ibis chapter and a child
custody proceeding has not been commenced in a court of a state having jurisdiction under RCW
26.27.201 through 26.27.221. If an action is not filed in (potential home state)
______________________________ by i'e lime the child has been in VVasn o ; c c r s.cv monrh-s
(date)________________________________ , then Washington's jurisdiction win be final and
confirming.
Other:
Name of Child
Christopher * ee 1larrison Jr.
Parent's Name
Christopher Tee larrison Sr.
Parents Name
Jolene Charlton

[x ]
in no place other than the state of Washington and with no person other than the requesting party or the other
party.
?' .
[]
in the following places with the following persons (list each place the children lived, including the state of
Washington, the dates the children lived there and the names o f the persons with whom the children lived. The
present addresses of those persons must be listed in the required Confidential Information Form.):

[]
[]
The requesting party does not know o f any person other than the other party who has physical custody of, or
claims to have custody or visitation rights to, the children.
The following persons have physical custody of, or claim to have custody or visitation rights to, the children (list
their names and the children concerned below and list their present addresses in the Confidential Information
Form. Do not list the other party.):

[x ]
[]
The requesting party has not been involved in any other proceeding regarding the children.
The requesting party has been involved in the following proceedings regarding the children (list the court, the
case number, and the date of the judgment or order):

[x ]
[]
2.7
The requesting party does not know of, any other legal proceedings concerning the children.
The requesting party knows of, the following legal proceedings that concern the children (list the children
concerned, the court, the case number, and the kind o f proceeding);
Custody Decree or Parenting Plan/Residentia! Schedule

The Custody Decree/Parenling Plan/Residentiai Schedule was entered on (date) _ 0 1-25-20JO____________ at (county
and state)
Pierce, WA_________________________________________ . A certified copy of the Custody
Dec re e/Pa renting Plan /"Residential Schedule to be modified is filed with or attached to this petition, if the decree or plan,
to be modified was entered in another county or state.
2.8
M o d ific a tio n U n d er R C W 2 6 .09.26 0(1 ), (2)
[x ]
Does not apply,
[]
The custody decree/parenting plan/residential schedule should be modified because a substantial change of
circumstances has occurred in the circumstances of the children or the other party and the modification is in the
best interests of the children and is necessary to serve the best interests of the children. This request is based on
the factors below.
2.9
2.10
[]
The parties agree to the modification.
[]
The children have been integrated into my family with the consent of the other party in substantia!
deviation from the decree/parenting plan/residentiai schedule.
[]
The childrens environment under the custody decree/parenting plan/residential schedule is detrimental
to the childrens physical, mental or emotional health and the harm likely to be caused by a change in
environment is outweighed by the advantage of a change to the children,
[]
The other party has been found in contempt of court at least twice within three years because the party
failed to comply with the residential time provisions in the court-ordered parenting plan, or the parent has
been convicted of custodial interference in the first or second degree under RCW 9 A.40.060 or
9A.40.070.
Modification or Adjustment Under RCW 26.09.260(4) or (8)

[x ]
Does not apply.
[]
The custody decree/parenting plan/residential schedule should be modified because the reduction or restriction
o f the residential time for the person with whom the child does not reside a majority o f the time would serve and
protect the best interests of the child using the criteria in RCW 26.09.191, as described here:
[]
The custody decree/parenting plan/residential schedule should be adjusted because the nonresidenlial party has
voluntarily failed to exercise residential time for one year or more and the adjustment is in the best interest of the
children.
Adjustments to Residential Provisions Under RCW 26.09.260(5)(a) and (b)

[]
Does not apply.
[x ]
The custody decree/parenting plan/residential schedule should be adjusted because a substantial change in
circumstances of either parent or of the child has occurred and the proposed modification to the custody
decree/parenting plan/residential schedule is in the best interest of the children and is a minor modification in the
residential schedule that does not change the residence the children are scheduled to reside in (he majority o f die
time and:
2.11
[x ]
is not more than 24 full days in a calendar year; or
[]
is based on a change o f residence o f the parent with whom the child does not reside a majority o f the time
or an involuntary change in work schedule by a party which makes the residential schedule in the
parenting plan impractical to follow.
Adjustments to Residential Provisions Under RCW 26.09.260(5)(c), (7), (9)

[x ]
Does not apply.
This section only applies to a person with whom the child does not reside a majority o f the time who is
seeking to increase residential time.
2.11.1 Parent subject to limitations under RCW 26.09.191(2) or (3)
[]
[]
The residential time of (name)__________________________________________ is not subject to limitations.

The residential time of (name)
______________________ ____ _ is subject to limitations. This parent
demonstrates a substantial change in circumstances specifically related to the basis for the limitation.
2.11.2 Parent Required to Complete Evaluations, Treatment, Parenting or Other Classes

f]
[]
(Nam e)______________________________ is not required under the existing Parenting Plan/Residential

Schedule to complete evaluations, treatment, parenting or other classes.
(N am e)_________________ _________ , is required by the existing Parenting Plan/Residentiai Schedule to
complete evaluations, treatment, parenting or other classes. This parent has fully complied with such
requirements as described here:
2.11.3 Adjustment to Residential Provision Under RCW 26.09.260(5)(c)

[]
2.12
The Custody Decree/Parenting Plan/Residential Schedule should be adjusted because a substantial change in
circumstances of (parents name)____________________________ _ or (child(ren)s name(s))
___________________________________________________ has occurred. The proposed modification to the
Custody Decree/Parenting Plan/Residential Schedule is in the best interest o f the children. It is a minor
modification in the residential schedule that does not change the residence the children are scheduled to reside in
the majority o f the time. The increase is more than 24 full days but less than 90 overnights per year total. The
Custody Decree/Parenting Plan/Residentiai Schedule does not provide reasonable time with the nonprimary
residential party.
Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)
[x ]
[ J
T h e f o l l o w i n g n o n r e s id e n t ia l p r o v i s i o n s o f th e p a r e n t in g p la n s h o u ld b e a d ju s t e d b e c a u s e th e re is a s u b s t a n t ia l
c h a n g e o f c i r c u m s t a n c e s o f e i t h e r p a r t y o r o f t h e c h i l d r e n a n d t h e a d j u s t m e n t i s in t h e b e s t in t e r e s t o f t h e
c h ild r e n :
[ ] D i s p u t e r e s o lu t io n .
[ ] D e c is io n m a k in g .
[ ] T r a n s p o r t a t io n a rra n g e m e n ts.
[]
2.13
O th e r:
Substantial Change in Circum stance
(You must complete this part if you request a modification or adjustment in paragraphs 2.8, 2.10,
or 2.12.)
T h e r e q u e s t e d m o d i f i c a t i o n o r a d j u s t m e n t o f t h e c u s t o d y d e c r e e / p a r e n t in g p la n / r e s i d e n t i a l s c h e d u l e i s b a s e d u p o n t h e
f o l l o w i n g s u b s t a n t i a l c h a n g e in c i r c u m s t a n c e :
T h e p a r e n t i n g p la n w a s s e t u p in o r d e r t o a c c o m o d a t e t h e m o t h e r m o v i n g o u t o f t o w n t o j o i n h e r n e w h u s b a n d . T o d a t e 14
m o n t h s la te r, t h e m o t h e r s t i l l h a s n o t m o v e d o u t o f sta te , n e w h u s b a n d h a s m o v e d t o t h i s s ta te , n e w h u s b a n d n o l o n g e r
r e t a i n s a p p r o v e d n e w r e s i d e n c e , o r la n d li n e , a n d i s e m p o l y e d i n P i e r c e C o u n t y .
2.14
Protection Order
[x ]
[ ]
T h e r e i s a p r o t e c t i o n o r d e r b e t w e e n t h e p a r t ie s f i l e d in c a s e n u m b e r ___________
, co u rt
_______________________________________, w h i c h e x p i r e s o n ( d a t e ) ___ ________________________

[ ]
T h e c o u r t s h o u l d g r a n t t h e [ ] d o m e s t i c v i o l e n c e [ ] a n t i h a r a s s m e n t p e t i t i o n f o r o r d e r f o r p r o t e c t io n :
[ ] a t t a c h e d t o t h i s p e t it io n .
[ ] f i l e d s e p a r a t e l y u n d e r [ ] t h i s c a s e n u m b e r [ ] c a s e n u m b e r ________________________________.
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic Violence forms or RCW 10.14
Antiharassment forms.
2.15
Servicem em bers Civil Relief Act Statem ent

2 .1 5 .1
A.
S e r v i c e m e m b e r s t a t u s ( n a m e o f o t h e r p a r t y ) __________________________ __________________:
[ ]
is n o t a s e rv ic e m e m b e r;
[ ]
i s o n a c t i v e d u t y in t h e U . S . a r m e d f o r c e s ( e x c l u d i n g N a t i o n a l G u a r d a n d r e s e r v e s ) ;
[ ]
i s o n a c t i v e d u t y a n d i s a N a t i o n a l G u a r d m e m b e r o r a R e s e r v i s t r e s i d i n g in W a s h i n g t o n ;
[ ]
i s n o t o n a c t i v e d u t y in t h e U . S . a r m e d f o r c e s ( e x c l u d i n g N a t i o n a l G u a r d a n d r e s e r v e s ) ;
[ ]
i s n o t o n a c t i v e d u t y a n d i s a N a t i o n a l G u a r d m e m b e r o r a R e s e r v i s t r e s i d i n g in W a s h i n g t o n ;
[ ]
l a m u n a b l e t o d e t e r m in e w h e t h e r t h e o t h e r p a r t y i s o r i s n o t o n a c t i v e d u t y i n t h e U . S . a r m e d f o r c e s ;
[ ]
l a m u n a b l e t o d e t e r m in e w h e t h e r t h e o t h e r p a r t y i s o r i s n o t o n a c t i v e d u t y a s a N a t i o n a l G u a r d m e m b e r
o r a R e s e r v i s t r e s i d i n g in W a s h i n g t o n .
B.
F a c t u a l b a s is :
[ ]
S e e th e a tta c h e d D e f e n s e M a n P o w e r D a t a C e n t e r R e p o r t o b t a in e d fr o m
[ ]
O t h e r fa c tu a l b a s is :
https://w w w .dm dc.osd.m il/scra/ow a/hom e.
C.
2 .1 5 .2
A.
[ ]
A s in d i c a t e d a b o v e , t h e o t h e r p a r t y i s o n a c t i v e d u t y a n d ( c h e c k a l l t h a t a p p l y ) :
[ ]
T h e o t h e r p a rty is re p re se n t e d b y a n a tto rn e y .
[ ]
T h e c o u r t h a s a p p o in t e d a n a t t o r n e y t o r e p r e s e n t t h e o t h e r p a rty .
[ ]
A s ta y o f th e se p r o c e e d in g s [ ] h a s [ ] h a s n o t b e e n e n te re d b y th e c o u rt.
D e p e n d e n t o f a s e r v i c e m e m b e r s t a t u s ( n a m e o f o t h e r p a r t y ) _________________________
[ ]
is a d e p e n d e n t o f a r e s id e n t o f W a s h i n g t o n w h o i s o n a c t iv e d u t y a n d is a N a t io n a l G u a r d m e m b e r o r a
R e s e rv is t ;
[ ]
is n o t a d e p e n d e n t o f a re sid e n t o f W a s h in g t o n w h o is o n a c tiv e d u t y a n d is a N a t io n a l G u a r d m e m b e r o r
a R e s e rv is t ;
[ ]
l a m u n a b l e t o d e t e r m in e w h e t h e r t h e o t h e r p a r t y i s a d e p e n d e n t o f a r e s i d e n t o f W a s h i n g t o n w h o i s o n
a c tiv e d u t y a n d is a N a t io n a l G u a r d m e m b e r o r a R e s e r v is t .
B.
F a c t u a l b a s is :
[ ]
T h e o t h e r p a r t y f a i l e d t o r e s p o n d t o a n o t i c e t o h i m o r h e r a s a d e p e n d e n t o f a p e r s o n in M i l i t a r y S e r v i c e
th a t w a s f ] s e r v e d o n [ ] m a ile d b y fir s t c l a s s m a il o n (d a te )
________________________ ______________________________, t h e r e f o r e h e o r s h e s h o u l d b e p r e s u m e d n o t a
d e p e n d e n t o f a r e s id e n t o f W a s h i n g t o n w h o i s o n a c t i v e d u t y a n d i s a N a t i o n a l G u a r d m e m b e r o r a
R e s e rv is t .
[ ] O t h e r f a c t u a l b a s is :
C.
[ ]
A s i n d i c a t e d a b o v e , t h e n o n m o v i n g p a r t y i s a d e p e n d e n t o f a r e s i d e n t o f W a s h i n g t o n w h o i s o n a c t iv e
d u t y a n d is a N a t io n a l G u a r d m e m b e r o r a R e s e r v is t a n d ( c h e c k a ll th a t a p p ly ):
2.16
[ ]
T h e n o n m o v in g p a rty is re p re se n t e d b y a n a tto rn e y .
[ ]
T h e c o u r t h a s a p p o in t e d a n a t t o r n e y t o re p r e s e n t th e n o n m o v i n g p a rty .
[ ]
A s t a y o f th e se p r o c e e d in g s [ ] h a s [ ] h a s n o t b e e n e n te re d b y th e c o u rt.
Other
III. R elief Requested

T h e m o v in g p a rty
r e q u e s ts
th a t th e c o u r t f in d th a t t h e r e i s a d e q u a t e c a u s e f o r h e a r in g t h is p e t it io n a n d e n t e r a n o r d e r m o d i f y i n g
t h e c u s t o d y d e c r e e / p a r e n t in g p la n / r e s i d e n t i a l s c h e d u l e in t h i s m a t t e r a n d a p p r o v i n g t h e p r o p o s e d p a r e n t i n g p la n / r e s i d e n t i a l
s c h e d u l e , w h i c h i s f i l e d w i t h t h i s p e t it io n .
[ ]
T h e m o v i n g p a r t y a ls o re q u e st s th a t th e c o u rt:
[ ]
E n t e r a n o r d e r e s t a b l i s h i n g c h i l d s u p p o r t i n c o n j u n c t i o n w i t h t h e p r o p o s e d p a r e n t i n g p la n / r e s i d e n t i a l s c h e d u l e .
T h e c h i l d s u p p o r t w o r k s h e e t a n d f i n a n c i a l d e c l a r a t i o n a r e f i l e d w i t h t h i s p e t it io n .
[ ]
E n t e r a d o m e s t ic v io le n c e p r o t e c t io n o rd e r,
f 1
E n t e r a n a n t ih a r a s s m e n t p r o t e c t io n o rd e r.
[ ]
O th e r:
D ate
S ig n a t u r e o f R e q u e s t in g P a rty o r L a w y e r / W S B A N o .
P r in t N a m e
D ate
S ig n a t u r e o f R e q u e s t in g P a rty o r L a w y e r / W S B A N o .
P r in t N a m e
1 d e c la re u n d e r p e n a lt y o f p e r j u r y u n d e r th e la w s o f t h e sta te o f W a s h i n g t o n th a t t h e f o r e g o in g i s tru e a n d c o rre c t.

S i g n e d at ( c i t y )
/ 4 v f t o s f / \ ____________________ , ( s t a t e )
_ o n (d a te )
lit*
Joinder
[ ]
I,
_______________.
>Ao
( s t a t e ) ________________ o n ( d a t e )
S ig n a tu re o f R e q u e s t in g P a rt y
[]
H -ff
P r in t N a m e
S ig n a t u r e o f R e q u e s t in g P a r t y
S i g n e d a t ( c i t y ) __________________
/-
P r in t N a m e
___________________________________, j o i n in t h e p e t it io n .
I u n d e r s t a n d t h a t b y j o i n i n g in t h e p e t it io n , a d e c r e e o r j u d g m e n t
a n d o r d e r m a y b e e n t e r e d in a c c o r d a n c e w i t h t h e r e l i e f r e q u e s t e d in t h e p e t i t i o n u n l e s s , p r i o r t o t h e e n t r y o f t h e d e c r e e o r
j u d g m e n t a n d o r d e r, a r e s p o n s e is f ile d a n d s e rv e d .
[ ]
[ ]
I w a iv e n o t ic e o f e n try o f th e d e c re e .
I d e m a n d n o t i c e o f a l l f u r t h e r p r o c e e d i n g s i n t h i s m a tt e r . F u r t h e r n o t i c e s h o u l d b e s e n t t o t h e f o l l o w i n g a d d r e s s
( y o u m a y lis t a n a d d re s s th a t is n o t y o u r r e s id e n t ia l a d d r e s s w h e re y o u a g re e to a c c e p t le g a l d o c u m e n t s ):
A n y t im e t h i s a d d r e s s c h a n g e s w h i l e t h i s a c t i o n i s p e n d i n g , y o u m u s t n o t i f y t h e o p p o s i n g p a r t ie s in w r i t i n g a n d f i l e a n
u p d a t e d C o n f id e n t ia l In f o r m a t io n F o r m ( W P F D R P S C U 0 9 . 0 2 0 0 ) w it h th e c o u r t c le rk .
D ate
[ ]
S ig n a t u r e
I, _ _ ___________________________
P r in t N a m e
, j o i n i n t h e p e t it io n .
I u n d e r s t a n d t h a t b y j o i n i n g in t h e p e t it io n , a d e c r e e o r j u d g m e n t
a n d o r d e r m a y b e e n te re d in a c c o r d a n c e w it h th e r e l i e f re q u e st e d in t h e p e t it io n u n le s s , p r io r to th e e n t r y o f t h e d e c r e e o r
j u d g m e n t a n d o rd e r, a r e s p o n s e is f ile d a n d se rv e d .
[ ]
[ ]
I w a i v e n o t i c e o f e n t r y o f t h e d e c re e .
I d e m a n d n o t i c e o f a l l f u r t h e r p r o c e e d i n g s i n t h i s m a tt e r. F u r t h e r n o t i c e s h o u l d b e s e n t t o t h e f o l l o w i n g a d d r e s s
( y o u m a y lis t a n a d d r e s s t h a t i s n o t y o u r r e s i d e n t i a l a d d r e s s w h e r e y o u a g r e e t o a c c e p t l e g a l d o c u m e n t s ) :
A n y t im e t h i s a d d r e s s c h a n g e s w h i l e t h i s a c t i o n i s p e n d i n g , y o u m u s t n o t i f y t h e o p p o s i n g p a r t i e s i n w r i t i n g a n d f i l e a n
u p d a t e d C o n f id e n t ia l In f o r m a t io n F o r m ( W P F D R P S C U 0 9 . 0 2 0 0 ) w it h th e c o u rt c le rk .
D ate
[ ]
S ig n a t u r e
P r in t N a m e
I , _______________________________________ , j o i n i n t h e p e t it io n . I u n d e r s t a n d t h a t b y j o i n i n g i n t h e p e t it io n , a d e c r e e o r j u d g m e n t
a n d o r d e r m a y b e e n te re d in a c c o r d a n c e w it h th e r e l i e f re q u e st e d in th e p e t it io n u n le s s , p r io r t o th e e n t r y o f th e d e c re e o r
j u d g m e n t a n d o rd e r, a r e s p o n s e is file d a n d se rv e d .
[ ]
[ ]
I w a i v e n o t ic e o f e n t r y o f th e d e c re e .
I d e m a n d n o t i c e o f a l l f u r t h e r p r o c e e d i n g s i n t h i s m a tt e r . F u r t h e r n o t i c e s h o u l d b e s e n t t o t h e f o l l o w i n g a d d r e s s
( y o u m a y lis t a n a d d r e s s th a t is n o t y o u r r e s id e n t ia l a d d r e s s w h e r e y o u a g re e t o a c c e p t le g a l d o c u m e n t s) :
A n y t im e t h i s a d d r e s s c h a n g e s w h i l e t h i s a c t i o n i s p e n d i n g , y o u m u s t n o t i f y t h e o p p o s i n g p a r t i e s in w r i t i n g a n d f i l e a n
u p d a t e d C o n f id e n t ia l In f o r m a t io n F o r m ( W P F D R P S C U 0 9 . 0 2 0 0 ) w it h t h e c o u r t c le rk .
D ate
S ig n a t u r e
P r in t N a m e
F IL E D
IN COUNTY CLERKS OFFICE

00-3-00821-4
35693117
PPP
01- 12-11
a .m

County of
P e t it io n e r ,
Parenting Plan
Proposed (PPP)
[ ] Temporary (PPT)
[ j Final O rder (PP)
and
[x ]
R e sp o n d e n t.
T h i s p a r e n t i n g p l a n is:
f ]
[x ]
a t e m p o r a r y p a r e n t in g p la n s ig n e d b y th e c o u rt,
p ro p o se d b y (n a m e )
C h r is t o p h e r H a r r is o n

T h i s p a r e n t in g p la n a p p lie s to th e f o l l o w in g c h ild r e n :
Nam e
C h r is t o p h e r L e e H a r r is o n
p y
BY------ ---------------------------------- .DEPUTY
No. 08-3-00821-4
JAN12 20tt

KEVIN STOCK, County Cleric
J o le n e C h a r lt o n
A . K . A . J o le n e H a r r is o n
Age
i-4 3 - 9 -3 -

Under certain circumstances, as outlined below, the court may limit or prohibit a parents contact with the child(ren)
and the right to make decisions for the child(ren).
2.1

[x J
2.2
[x ]
T h e [ ] p e t i t i o n e r s
[ x ] r e s p o n d e n t s i n v o l v e m e n t o r c o n d u c t m a y h a v e a n a d v e r s e e f f e c t o n t h e c h i l d ( r e n ) s b e s t
in t e r e s ts b e c a u s e o f t h e e x is t e n c e o f th e f a c t o r s w h ic h f o llo w :
[x ]
O t h e r : t h e f a c t o r s a b o v e w e r e p r i o r t o 12 m o n t h s o f t r e a t m e n t w h i c h s t a r t e d 2 6 m o n t h s a g o ( a n d
c o n t in u in g ) tre a tm e n t t o a d d r e s s d u a l is s u e s o f m e n t a l h e a lt h a n d a lc o h o l a b u s e b y fa th e r.

The residential schedule must set forth where the child(ren) shall reside each day o f the year, including provisions fo r
holidays, birthdays of family members, vacations, and other special occasions, and what contact the child(ren) shall
have with each parent. Parents are encouraged to create a residential schedule that meets the developmental needs
o f the child(ren) and individual needs o f their family. Paragraphs 3.1 through 3.9 are one way to write your residential
3.1
[x j
P r i o r t o e n r o l l m e n t in s c h o o l , t h e c h i l d ( r e n ) s h a l l r e s i d e w i t h t h e m o t h e r
e x c e p t f o r t h e f o l l o w i n g d a y s a n d t im e s w h e n t h e c h i l d w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a re n t:
f r o m ( d a y a n d t im e )
F r id a y
8 :0 0 p m
to ( d a y a n d t im e )
Sunday
8:0 0 p m
e v e ry o ther w e e ke n d
3.2
School Schedule
U p o n e n r o l l m e n t in s c h o o l , t h e c h i l d s h a l l r e s i d e w i t h t h e m o t h e r
e x c e p t f o r t h e f o l l o w i n g d a y s a n d t im e s w h e n th e c h ild w i l l r e s id e w it h o r b e w it h t h e o t h e r p a re n t:
sam e as a b o ve
1 1 3 5 3 -
3.3
Schedule fo r W inter Vacation

T h e c h i l d s h a ll r e s id e w it h th e m o t h e r d u r in g w in t e r v a c a t io n , e x c e p t f o r th e f o l l o w i n g d a y s a n d t im e s w h e n t h e c h ild w i l l
r e s i d e w i t h o r b e w i t h t h e o t h e r p a re n t:
S e e S e c t io n 3 .7 .
3.4
Schedule for O ther School Breaks

T h e c h i l d s h a l l r e s id e w it h th e m o t h e r d u r in g o t h e r s c h o o l b r e a k s , e x c e p t f o r th e f o l l o w i n g d a y s a n d t im e s w h e n th e c h il d
w ill r e s id e w it h o r b e w it h th e o t h e r p a re n t:
T h a n k s g i v i n g - S e e S e c t io n 3 .7 .
3,5
Sum m er Schedule
U p o n c o m p le t io n o f th e s c h o o l y e a r, th e c h ild s h a ll r e s id e w it h th e m o t h e r
e x c e p t f o r t h e f o l l o w i n g d a y s a n d t im e s w h e n t h e c h i l d w i l l r e s i d e w i t h o r b e w i t h t h e o t h e r p a r e n t :
F a t h e r t o b e a l o o w e d in a d d i t i o n t o r e g u l a r e v e r y o t h e r w e e k e n d v i s i t :
1 w e e k i n J u n e , 1 w e e k in J u l y a n d 1 w e e k in
A u g u s t b e g in n in g w it h the F r id a y o f a r e g u la r w e e k e n d v is it f o r fa th e r.
3.6
Vacation W ith Parents

T h e s c h e d u l e f o r v a c a t i o n w i t h p a r e n t s i s a s f o l l o w s : A s t h e c h i l d g r o w s t h e t im e d u r i n g t h e s u m m e r m a y i n c r e a s e i n t o
b l o c k s o f t im e f o r b o t h p a r e n t s e s p e c i a l l y t o a c c o m m o d a t e s p e c i a l v a c t i o n s .
3.7

T h e r e s i d e n t i a l s c h e d u l e f o r t h e c h i l d f o r t h e h o l i d a y s lis t e d b e l o w i s a s f o l l o w s :
W it h R e s p o n d e n t
( S p e c if y Y e a r
O d d / E ve n / E ve ry)
e v e n _________________________ _ _
Odd
M a rt in L u t h e r K i n g D a y
S e e W e e k e n d S c h e d u l e ______
_____
S e e W e e k e n d S c h e d u l e ______
_____
J u ly 4 th
S e e S u m m e r S c h e d u le _
Labor D ay
S e e W e e k e n d S c h e d u le .
V e te ra n s D a y
E v e r y ____________ _ _______
E v e n ______________ _
O d d _______________________
Even
O d d _______________________
Even
W in t e r H o lid a y B re a k.
O d d _______________________
Even
[x ]
Odd_
F o r p u r p o s e s o f t h i s p a r e n t i n g p l a n , a h o l i d a y s h a l l b e g i n a n d e n d a s f o l l o w s ( s e t f o r t h t im e s ) : S e e s e c t i o n 3 .1
a b o v e . W e e k e n d s m a y i n c l u d e h o l i d a y M o n d a y s i n w h i c h c a s e t h e S u n d a y r e t u r n t im e b e c o m e s M o n d a y .
[x ]
3.8
H o lid a y s w h ic h fa ll o n a F r id a y o r a M o n d a y s h a ll in c lu d e S a t u r d a y a n d S u n d a y .

T h e re s id e n t ia l s c h e d u le f o r th e c h f ld (r e n ) f o r th e f o llo w in g s p e c ia l o c c a s io n s ( f o r e x a m p le , b ir t h d a y s ) is a s f o llo w s :
3.9
M o t h e r s D a y ______________________
e v e ry
F a t h e r s D a y _______________________
_______________________ ___________
_________________
__________________________________
e v e r y ____________________________

D o e s n o t a p p ly
3.10
Restrictions
[x ]
T h e r e a r e l i m i t i n g f a c t o r s in p a r a g r a p h 2 . 2 , a n d t h e r e a r e r e s t r i c t i o n s o n t h e f a t h e r s r e s i d e n t i a l t i m e w i t h t h e c h i l d
f o r th e f o llo w in g re a so n s:
H i s t o r y o f D W L S a n d a lc o h o l a b u s e r e q u ir e s n o v is it s e x c e p t w it h a p p r o v e d p e r s o n s s o m e o n e t r a n s p o r t in g w it h a
v a l i d d i v e r s l i c e n s e a n d i n s u r a n c e . M o t h e r h a s s o l e d e c i s i o n a u t h o r i t y .
3.11
Transportation Arrangem ents
T r a n s p o r t a t io n a r r a n g e m e n t s f o r th e c h ild (r e n ), b e tw e e n p a re n ts s h a ll b e a s f o llo w s :
C h i l d s h a l l o n l y b e t r a n s p o r t e d b y a li c e n s e d , i n s u r e d d r i v e r .
3.12
T h e c h i l d r e n n a m e d i n t h i s p a r e n t i n g p l a n a r e s c h e d u l e d t o r e s i d e t h e m a j o r i t y o f t h e t im e w i t h t h e m o t h e r .
T h is p a re n t is
d e s ig n a t e d t h e c u s t o d ia n o f th e c h ild s o le l y f o r p u r p o s e s o f a ll o t h e r sta te a n d fe d e ra l s ta tu te s w h i c h r e q u ir e a d e s ig n a t io n
o r d e t e r m i n a t i o n o f c u s t o d y . T h i s d e s i g n a t i o n s h a l l n o t a f f e c t e i t h e r p a r e n t s r i g h t s a n d r e s p o n s i b i l i t i e s u n d e r t h i s
p a r e n t i n g p la n .
3.13
O ther
D o e s n o t a p p ly
3.14
Sum mary o f RCW 26.09.430 - .480, Regarding Relocation o f a Child

T h i s i s a s u m m a r y o n l y . F o r t h e f u l l te x t , p l e a s e s e e R C W
2 6 .0 9 .4 3 0 th ro u g h 2 6 .0 9 .4 8 0 .
I f t h e p e r s o n w i t h w h o m t h e c h i l d r e s i d e s a m a j o r i t y o f t h e t im e p l a n s t o m o v e , t h a t p e r s o n s h a l l g i v e n o t i c e t o e v e r y
p e r s o n e n t i t le d t o c o u r t o r d e r e d t im e w i t h t h e c h i l d .
I f t h e m o v e i s o u t s i d e t h e c h i l d s s c h o o l d i s t r ic t , t h e r e l o c a t i n g p e r s o n m u s t g i v e n o t i c e b y p e r s o n a l s e r v i c e o r b y m a i l
r e q u i r i n g a r e t u r n r e c e ip t .
T h i s n o t i c e m u s t b e a t le a s t 6 0 d a y s b e f o r e t h e in t e n d e d m o v e . I f t h e r e l o c a t i n g p e r s o n c o u l d
n o t h a v e k n o w n a b o u t t h e m o v e i n t im e t o g i v e 6 0 d a y s n o t i c e , t h a t p e r s o n m u s t g i v e n o t i c e w i t h i n 5 d a y s a f t e r l e a r n i n g
o f the m o ve .
T h e n o t ic e m u s t c o n t a in th e in f o r m a t io n r e q u ir e d in R C W
2 6 .0 9 .4 4 0 .
S e e a ls o f o r m D R P S C U 0 7 .0 5 0 0 ,
( N o t ic e o f In t e n d e d R e l o c a t io n o f A C h ild ) .
I f t h e m o v e i s w i t h i n t h e s a m e s c h o o l d is t r ic t , t h e r e l o c a t i n g p e r s o n m u s t p r o v i d e a c t u a l n o t i c e b y a n y r e a s o n a b l e m e a n s .
A p e r s o n e n t i t le d t o t i m e w i t h t h e c h i l d m a y n o t o b j e c t t o t h e m o v e b u t m a y a s k f o r m o d i f i c a t i o n u n d e r R C W
2 6 .0 9 .2 6 0 .
N o t ic e m a y b e d e la y e d f o r 2 1 d a y s i f t h e r e lo c a t in g p e r s o n is e n t e r in g a d o m e s t ic v io le n c e s h e lt e r o r is m o v i n g t o a v o i d a
c le a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o h e a l t h a n d s a f e t y .
I f i n f o r m a t i o n i s p r o t e c t e d u n d e r a c o u r t o r d e r o r t h e a d d r e s s c o n f i d e n t i a l i t y p r o g r a m , it m a y b e w i t h h e l d f r o m t h e n o t ic e .
A r e l o c a t i n g p e r s o n m a y a s k t h e c o u r t t o w a i v e a n y n o t i c e r e q u i r e m e n t s t h a t m a y p u t t h e h e a lt h a n d s a f e t y o f a p e r s o n o r
a c h il d at ris k .
F a ilu r e t o g i v e t h e r e q u ir e d n o t ic e m a y b e g r o u n d s f o r s a n c t io n s , in c l u d in g c o n te m p t.
If no objection is filed within 30 days after service of the notice of intended relocation, the relocation will be
permitted and the proposed revised residential schedule may be confirmed.
A p e r s o n e n t i t le d t o t i m e w i t h a c h i l d u n d e r a c o u r t o r d e r c a n f i l e a n o b j e c t i o n t o t h e c h i l d s r e l o c a t i o n w h e t h e r o r n o t h e
ii'3 9 3
* ' ' * * - * -
o r s h e r e c e i v e d p r o p e r n o t ic e .
A n o b je c t io n m a y b e f ile d b y u s in g th e m a n d a t o r y p a tte rn fo r m W P F D R P S C U 0 7 . 0 7 0 0 , ( O b j e c t io n to
R e lo c a t io n / P e t it io n f o r M o d i f i c a t i o n o f C u s t o d y D e c r e e / P a r e n t in g P la n / R e s id e n t ia i S c h e d u le ) . T h e o b j e c t io n m u s t b e
s e r v e d o n a l l p e r s o n s e n t it le d t o t im e w i t h t h e c h i l d .
T h e r e l o c a t i n g p e r s o n s h a l l n o t m o v e t h e c h i l d d u r i n g t h e t im e f o r o b j e c t i o n u n l e s s : ( a ) t h e d e l a y e d n o t i c e p r o v i s i o n s
a p p ly ; o r (b ) a c o u rt o r d e r a llo w s th e m o v e .
I f t h e o b j e c t in g p e r s o n s c h e d u le s a h e a r in g f o r a d a te w it h in 15 d a y s o f t im e ly s e r v ic e o f t h e o b je c t io n , th e r e lo c a t in g
p e r s o n s h a l l n o t m o v e t h e c h i l d b e f o r e t h e h e a r i n g u n l e s s t h e r e i s a c le a r , i m m e d i a t e a n d u n r e a s o n a b l e r i s k t o t h e h e a l t h
o r s a f e t y o f a p e r s o n o r a c h ild .
IV. [>ecision Making

4.1
E a c h p a re n t s h a ll m a k e d e c is io n s r e g a r d in g th e d a y -t o -d a y c a re a n d c o n tr o l o f e a c h c h ild w h ile th e c h ild is r e s id in g w it h
th a t p a re n t. R e g a r d l e s s o f t h e a llo c a t io n o f d e c i s i o n m a k in g in t h is p a r e n t in g p la n , e it h e r p a r e n t m a y m a k e e m e r g e n c y
d e c is io n s a f f e c t in g th e h e a lth o r s a fe ty o f th e c h ild r e n .
4.2
M ajor Decisions
M a j o r d e c is io n s r e g a r d in g e a c h c h ild s h a ll b e m a d e a s fo llo w s :
4.3
E d u c a t io n d e c is io n s
[x ]
p e t it io n e r
[]
re sp o n d e n t
[]
jo in t
N o n - e m e r g e n c y h e a lth c a re
[x ]
p e t it io n e r
[]
re sp o n d e n t
E]
jo in t
R e lig io u s u p b r in g in g
[X ]
p e t it io n e r
[]
re sp o n d e n t
[]
jo in t
[x ]
S o l e d e c is io n m a k in g s h a ll b e o rd e re d to th e m o t h e r f o r th e f o llo w in g re a so n s:
[x ]
O n e p a r e n t i s o p p o s e d t o m u t u a l d e c i s i o n m a k i n g , a n d s u c h o p p o s i t i o n i s r e a s o n a b l y b a s e d o n th e
f o l l o w i n g c r it e r ia :
(a )
(b )
T h e e x is t e n c e o f a lim it a t io n u n d e r R C W
2 6 .0 9 .1 9 1 ;
W h e t h e r t h e p a r e n t s h a v e d e m o n s t r a t e d a b i l i t y a n d d e s i r e t o c o o p e r a t e w i t h o n e a n o t h e r in
d e c is io n m a k in g in e a c h o f th e a r e a s in
R C W
26.09.lS4(4)(a)'
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 modify the plan or a motion for contempt for failing to follow the plan.
[x ]
D i s p u t e s b e t w e e n t h e p a r t ie s , o t h e r t h a n c h i l d s u p p o r t d i s p u t e s , s h a l l b e s u b m i t t e d t o ( l i s t p e r s o n o r a g e n c y ) :
[x ]
m e d i a t i o n b y C o m p a s s i o n a t e R e s o l u t i o n s , S e a t t le W a s h i n g t o n ,
i f t h is b o x is c h e c k e d a n d is s u e s o f d o m e s t ic
v io l e n c e o r c h i l d a b u s e a re p re se n t, t h e n th e c o u r t f in d s th a t th e v ic t im r e q u e s t e d m e d ia t io n , th a t m e d ia t io n is
a p p r o p r ia t e a n d th a t th e v ic t im i s p e r m it t e d to h a v e a s u p p o r t in g p e r s o n p r e s e n t d u r in g t h e m e d ia t io n
p r o c e e d in g s , o r
T h e c o s t o f t h i s p r o c e s s s h a l l b e a llo c a t e d b e t w e e n t h e p a r t i e s a s f o l l o w s :
[x ]
50 %
p e t it io n e r
50 %
re sp o n d e n t.
T h e d is p u t e r e s o lu t io n p r o c e s s s h a ll be c o m m e n c e d b y n o t if y in g th e o t h e r p a r t y b y [ ] w r it t e n r e q u e s t [ ] c e r t ifie d m a i l [ ]
o th e r:
In th e d is p u t e r e s o lu t io n p ro c e ss:
(a )
P r e f e r e n c e s h a l l b e g i v e n to c a r r y i n g o u t t h i s P a r e n t i n g P la n .
(b )
U n l e s s a n e m e r g e n c y e x is t s, th e p a r e n t s s h a ll u s e th e d e s ig n a t e d p r o c e s s t o r e s o lv e d is p u t e s r e la t in g to
(c )
i m p l e m e n t a t i o n o f t h e p la n , e x c e p t t h o s e r e la t e d t o f i n a n c i a l s u p p o r t .
w r i t t e n r e c o r d s h a l l b e p r e p a r e d o f a n y a g r e e m e n t r e a c h e d in c o u n s e l i n g o r m e d i a t i o n a n d o f e a c h a r b i t r a t i o n
a w a r d a n d s h a ll b e p r o v id e d to e a c h p a rty .
(d )
I f t h e c o u r t f in d s tha t a p a re n t h a s u s e d o r fru stra te d th e d is p u t e r e s o lu t io n p r o c e s s w it h o u t g o o d re a s o n , th e c o u r t

s h a ll a w a r d a t t o r n e y s fe e s a n d f in a n c ia l s a n c t io n s t o t h e o t h e r p a re n t.
(e )
T h e p a r t ie s h a v e th e r ig h t o f r e v ie w f r o m t h e d is p u t e r e s o lu t io n p r o c e s s t o t h e s u p e r io r c o u rt.
[x ]
T h e r e a re th e f o llo w in g o th e r p ro v is io n s :
1. F a t h e r s h a l l b e i n f o r m e d in d e t a il a b o u t a l l e d u c a t i o n a l , m e d i c a l a n d r e l i g i o u s d e c i s i o n s , p r o v i d e r s e tc . F a t h e r m a y g i v e
i n p u t t o M o t h e r a n d M o t h e r s h a l l c o n s i d e r it i n g o o d f a i t h b e f o r e h e r d e c i s i o n s a r e m a d e w h e n p r a c t i c a b le . F a t h e r i s
e n t it le d t o a l l r e c o r d s a n d m a y f u l l y p a r t ic ip a t e i n a l l c o n c e r n i n g t h e c h i l d .
2. F a t h e r s h o u ld h a v e r e a s o n a b le p h o n e c o n t a c t a s f o llo w s :
M o n d a y a n d F r i d a y t e le p h o n e v i s i t t o s t a r t a t 7 : 0 0 p m
W e d n e s d a y a n d S u n d a y V i d e o / S k y p e v i s i t to sta rt at 7 : 0 0 p m
A l l v i s i t s n e e d t o b e in a q u i e t r o o m a w a y f r o m T V / v i d e o g a m e s / o t h e r d i s t r a c t i o n s
[x ]
( O n l y s ig n i f t h is i s a p r o p o s e d p a r e n t in g p la n . ) I d e c la re u n d e r p e n a lt y o f p e j j u j y u n d e r th e l a w s o f th e s ta te o f
W a s h i n g t o n t h a t t h i s p l a n h a s b e e n p r o p o s e d in g o o d f a it h a n d t h a t t h e s t a t e m e n t s i n P a r t U o f t h i s P l a n a r e t r u e a n d
co rre ct.
V III. Order by the Court

It is o r d e re d , a d ju d g e d a n d d e c re e d th a t th e p a r e n t in g p la n se t fo rt h a b o v e i s a d o p te d a n d a p p r o v e d a s a n o r d e r o f t h is c o u rt.
W A R N IN G :
V i o l a t i o n o f r e s i d e n t i a l p r o v i s i o n s o f t h i s o r d e r w i t h a c t u a l k n o w l e d g e o f it s t e r m s i s p u n i s h a b l e b y c o n t e m p t o f
c o u rt a n d m a y be a c r im in a l o ffe n se u n d e r R C W
9 A . 4 0 . 0 6 0 ( 2 ) o r 9 A . 4 0 .0 7 0 ( 2 ) . V io l a t io n o f t h is o r d e r m a y s u b je c t a v io la t o r t o
a rre st.
W h e n m u t u a l d e c is io n m a k i n g is d e s ig n a t e d b u t c a n n o t b e a c h ie v e d , th e p a r t ie s s h a ll m a k e a g o o d f a it h e f f o r t t o r e s o lv e t h e i s s u e
t h ro u g h th e d is p u t e r e s o lu t io n p ro c e ss.
I f a p a r e n t f a i l s t o c o m p l y w i t h a p r o v i s i o n o f t h i s p l a n , t h e o t h e r p a r e n t 's o b l i g a t i o n s u n d e r t h e p la n a r e n o t a f f e c t e d .
D a t e d : ________ _________________________________________ ____________________________________________________________ ________
Judge/Com m issioner
P re se n te d b y :
jj
A p p r o v e d fo r e n try :
______ ~________________________________
S ig n a t u r e o f P a rty o r L a w y e r / W S B A N o .
S ig n a t u r e o f P a rty o r L a w y e r / W S B A N o .
Print Name Christopher Harrison
Print Name
i v i :
p
IN COUNTY1
S lI
08-3-00821-4
35693156
DCLR
r KS
OFFICE
JAN 12 2011
01 - 12-11
p .m .
KEVIN STOCK, County Clerit

____________ DEPUTY
BY

County of
I n re :
No. 08-00821-4
A .K .A .
J o le n e M a r i e H a r r i s o n
P e t it io n e r s ) ,
and
R e sp o n d e n ts).
Declaration o f
Charlotte Pergrim
(Optional Use)
(DCLR)
T h is d e c la r a t io n i s m a d e b y :
Nam e:
C h a r lo t t e P e r g r im
Age:
39
R e l a t i o n s h i p t o t h e p a r t i e s in t h i s a c t io n :
D o m e s t ic P a rt n e r o th e r to re sp o n d a n t
/ Declare:
I. C h a r l o t t e P e r g r i m . d e c l a r e t h a t t h i s i s m v t r u e s t a t e m e n t in r e g a r d s t o t h e f o r e s a i d . I a m C h r i s t o p h e r L e e H a r r i s o n S r s
D o m e s t i c P a r t n e r . I a m a l s o t h e c o n t a c t / g o b e t w e e n p e r s o n t h a t c o n f i r m s t h e b i - w e e k l v v i s i t s w i t h J o l e n e M a r i e Jepson F l n h r
H a r r i s o n C h a r l t o n f o r C h r i s s v i s i t s w i t h h i s s o n C J t o c o m e t o o u r h o m e e v e r y o t h e r w e e k e n d d u e t o a r e s t r a i n i n g o r d e r w hich
f o r b id s d ir e c t c o n t a c t b e t w e e n C h r is t o p h e r L e e H a r r i s o n S r. & J o le n e M a r i e J e p s o n F l o r h H a r r i s o n C h a r lt o n .
O n Decem ber R
2 0 1 0 1 s e n t a t e x t t o J o l e n e M a r i e J e p s o n F l o h r H a r r i s o n C h a r l t o n a t a p r o x i m a t e l v 8 : 0 0 a .m . t o c o n f i r m t h a t w e w o u l d b e pickinp
C J u p o n F r id a y . D e c e m b e r 1 0 th . 2 0 1 0 @
8 : 0 0 p .m . f o r o u r r e g u l a r l y s c h e d u l e d v i s i t a n d w a s a l s o c o n f i r m i n g t h a t in a d d it i o n t o
that 1 w a s a ls o c o n f i r m i n g th a t w e w o u ld h a v e C J f o r o u r c o u rt a p p o in t e d C h r is t m a s b r e a k a s s p e lle d o u t a c c o r d in g t o the

p a r e n t i n g p l a n . J o l e n e t e x t e d b a c k t o m e s t a t in g t h a t t h e y w e r e o n v a c a t i o n a n d w e c o u l d p i c k h i m
p .m . a t t h e S h e l l S t a t i o n a n d s h e w a s s o r r y f o r a n y c o n f u s i o n .
o n D e c e m b e r 2 0 t h at 8 : 0 0
M v r e s p o n s e b a c k t o J o l e n e w a s t h a t 1. t o o , w a s c o n f u s e d , i s n 't t h a t
w h a t I ju st s a i d a n d I w a s iu s t c o n f ir m in g o u r v is it s f o r b o t h a n d o f c o u r s e w e w o u ld b e p i c k i n g h im
D e c e m b e r 8. 2 0 1 0 @
u p
1 0 : 0 6 p .m . J o l e n e s c e ll c a l l e d m v c e ll, C h r i s a n d I w e r e b o t h in b e d .
op
o n t h e 2 0 t h a s w e ll. O n
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\ r s r
a n s w e r e d t h e p h o n e a n d it w a s C J a s k i n g f o r h i s d a d .
I w o k e C h r i s u p to t a lk to C J .
T h e y t a lk e d f o r 8 . 2 6 m in u t e s .
t im e J o l e n e w a s in t h e b a c k g r o u n d p r o m p t i n g C J t o t e ll h i s d a d t h a t h e w a s i n H a w a i i .
D u r i n g a ll t h is
In h in d s ig h t t h is w a s h e r w a v o f
n o t i f i v i n g u s th a t s h e w a s w it h h o l d in g b o t h C h r i s a n d C J o f t h e ir c o u r t a p p o in t e d s c h e d u le d v is i t f o r D e c e m b e r 1 0 th . 2 0 1 0 .
On
F r id a y , D e c e m b e r 1 0 . 2 0 1 0 I d r o v e to th e S h e l l g a s s t a t io n in S u m n e r. W A to p ic k C J u p . I a r r iv e d a p p o x im a t e lv 2 0 m in u t e s
e a r l y . J o l e n e & h e r h u s b a n d W i l l i a m R o b e r t C h a r l t o n a r e r e g u l a r l y 5 - 1 0 m i n u t e s la t e w h e n d r o p p i n g o f f C J . N o t t h i n k i n g m u c h
o f i t 1 w a i t e d u n t i l 8 : 0 5 p .m . a n d t e x t e d J o l e n e ,,R u n n i n g l a t e ? " N o r e s p o n s e . I t h e n c a l l e d J o l e n e 's c e l l p h o n e a t 8 : 1 0 p .m .
It
w e n t d i r e c t l y t o h e r v o i c e m a i l. A t a o r o x i m a t e l v 8 : 1 5 p .m . I c a l l e d J o l e n e 's m o t h e r . J e a n e t t e , a n d e x p l a i n d e d t o h e r t h a t w e w e r e
a t t h e S h e l l S t a t i o n w a i t i n g f o r C J . a n d a s k e d i f s h e k n e w i f t h e y w e r e r u n n i n g la te . H e r r e p l y t o m e w a s t h a t " t h e y w e r e in
H a w a i i a n d th a t J o le n e t o ld h e r s h e h a d a lr e a d y m a d e p r e v io u s a r r a n g e m e n t s w it h u s to tra d e " O U R " w e e k e n d w it h C J f o r t h e
fo llo w in g w e e k e n d .
I t r ie d t o e x p l a i n t o J e a n e t t e t h a t w e w e r e n o t o n l y u n a w a r e o f b u t d i d n o t a g r e e t o a n y s u c h t h i n g , t h a t t h k
w a s o u r s c h e d u l e d w e e k e n d a s a l s o w a s t h e n e x t w e e k e n d , s o w h y w o u l d w e t r a d e f o r s o m e t h i n g t h a t w e a l r e a d y h a d ? J o l e n e 's
m o t h e r g o t v e r y c o n f r o n t a t i o n a l w i t h m e a n d t o l d m e t h a t J o l e n e h a d " d e c i s i o n m a k i n g r i g h t s a n d d i d n o t n e e d t o n o t i f y u s o f an y
c h a n g e s t o t h e p a r e n t i n g p la n a s l o n g a s s h e s a w it f i t A t t h a t p o i n t I t o l d J e a n e t t e t h a t it w a s n o t u p t o J o le n e . b u t t h e J u d g e & 1
h u n g th e p h o n e u p . I se n t te x t m e s s a g e s to J o le n e th a t n i g h t th e n e x t n i g h t a n d s e v e ra l n ig h t s f o llo w in g , a s k in g h e r to h a v e C J
c a ll h is d a d .
C J d i d n o t c a l l h i s d a d o n e t im e f r o m D e c e m b e r 8. 2 0 1 0 t o D e c e m b e r 2 0 . 2 0 1 0 .
T h e n e x t c o n ta tc t th a t w e h a d w it h
C J (a n d J o le n e i w a s o n D e c e m b e r 2 0 . 2 0 1 0 w h e n w e p ic k e d h im u p fro m d ie S h e ll S t a t io n in S u m n e r. W A at 8 : 0 0 p m .
A c c o r d i n g t o t h e c u r r e n t p a r e n t i n g p l a n f i l e d in o p e n c o u r t & d e c la r e d o n 1 / 2 5 / 2 0 1 0 i n S u p e r i o r C o u r t o f W a s h i n g t o n , t h e f e t h p r 'g
a l t e r n a t i n g w e e k e n d s h a l l b e d e s i g n e d f o r t h e y e a r i n a d v a n c e . T h e r e a r e n o m a k e u p s a s it i s a n t ic i p a t e d b v t h e c o u r t a n d t h a t
a l t e r n a t i n g s c h e d u l e s w h i c h i n c l u d e m o s t M o n d a y h o l i d a y s w o u d b e a p p r o p r ia t e f o r t h e f a t h e r 's s c h e d u l e e a c h y e a r .
It i s a l s o o r d e r e d , a d j u d g e d a n d d e c r e e d t h a t t h e p a r e n t i n g p l a n s e t f o r t h i s a d o p t e d a n d a p p r o v e d a s a n o r d e r o f t h e c o u r t .
V i o l a t i o n s w i t h a c t u a l k n o w l e d g e o f it s t e r m s i s p u n i s h a b l e b v c o n t e m p t o f c o u r t a n d m a v b e a c r i m i n a l o f f e n s e u n d e r R C W
9 A .4 0 .0 6 0 m or R C W
9 A .4 0 .0 7 (?a V
W h e n m u t u a l d e c i s i o n m a k i n g i s d e s i g n a t e d b u t c a n n o t b e a c h i e v e d , t h e p a r t ie s s h a l l m a k e g o o d f a it h e f f o r t t o r e s o l v e t h e i s s u e
t h r o u g h th e d is p u t e re s o lu t io n p ro c e s.
F a t h e r s h a l l h a v e r e s o n a b l e t e le p h o n e c o n t a c t w i t h t h e c h i l d w h i c h m v e x t e n d t o e l e c t r o n i c c o m m u n i c a t i o n w h e n F a t h e r deems
a p p r o p r ia t e .
I t e x t J o l e n e 4 - 5 d a y s e a c h w e e k a s k i n g h e r to h a v e C J c a l l h i s d a d . 9 0 % o f t h e t im e t h e y a r e u n a n s w e r e d , a n d w h e n
t h e y a r e it i s a s n v d e r e m a r k o f s o m e s o r t f r o m J o l e n e M a r i e J e p s o n F l o h r H a r r i s o n C h a r l t o n i n d i c a t i n g t h a t it i s n o t g o i n g t o
h a p p e n . I f C h r i s i s e x t r e m e l y l u c k y C J c a l l s o n t h e a v e r a g e o n e t im e p e r w e e k .
W h e n h e d o e s c a ll h is m o t h e r h a s h im c a ll w h e n
h e i s in a r o o m f u l l o f p e o p l e , a t t h e f a ir , in a c a r o n a s p e a k e r p h o n e , p l a y i n g w i t h h i s c o u s i n s , in a c a f e , w a t c h i n g a m o v i e o r
p l a y i n g v i d e o g a m e s , e t c . ..s o t h a t h i s a t t e n t io n i s f o c u s e d o n s o m e t h i n g o t h e r t h a n t h e c a ll.
S h e h a s d e lib e r a t e ly w it h h e ld b o t h r . l
a n d C h r i s 's p h o n e v i s i t s o n a n o n g o i n g b a s i s f o r a t le a s t 2 y e a r s .
I d e c l a r e u n d e r p e n a l t y o f p e i j u r y u n d e r t h e l a w s o f t h e s ta te o f W a s h i n g t o n t h a t t h e f o r e g o i n g i s t r u e a n d c o r r e c t .
S ig n e d at
[C it y ]
__________ [ S t a t e ] o n _
[D a te ].
P r in t o r T y p e N a m e
Do not attach financial records, personal health care records or confidential reports to this
declaration . Such records should be served on the other party and filed with the court using one o f
these cover sheets:

If filed separately using a cover sheet, the records will be sealed to protect your privacy (although
they will be available to all parties in the case, their attorneys, court personnel and certain state
agencies and boards.) See GR 22(C)(2).
01-12-H
DCLR
35693162
08-3-00021
IN COUNTY % RK'S OFFICE

a .m .

County of
JAN 12 2011 PM

TC
KEVIN STOCIC Count
ounjy-eierk
.DEPUTY
I n re :
No. 08-3-00821-4
and
Declaration of
Charlotte Pergrim
(Optional Use)
(DCLR)
[Name]
T h i s d e c la ra t io n is m a d e b y :
Nam e:
Age:
39
R e l a t i o n s h i p t o t h e p a r t ie s i n t h i s a c t io n :
D o m e s t ic P a rtn e r o f C h r is t o p h e r L e e H a r r s io n Sr.
/ Declare:
O n W e d n e s d a y . J a n u a r y 5. 2 0 1 1 1 te x te d J o le n e M a r i e J e p s o n F l o h r H a r r is o n C h a r lt o n a t a p r o x im a t e lv 7 :0 5 a m t o c o n f ir m th a t
w e w o u ld b e n i c k i n g C J u n o n F r id a y . J a n u a r y 7th @
8 : 0 0 p m f o r o u r l o n g s t a n d in g , s c h e d u le d b i- w e e k lv w e e k e n d v is it .
Her
r e p ly te xt b a c k t o m e w a s " L o l . v o u r f a n n y ! Y o u ju st h a d o u r w e e k e n d .*1 1 r e p lie d b a c k t o J o le n e " T h i s is o u r s c h e d u le d w e e k e n d .

Y o u c a n 't m a k e it u p a s y o u g o .
W e a r e g o i n g o f f w h a t i s in b l a c k & w h it e . . . p e r t h e J u d g e 's o r d e r s . S e e y o u F r i d a y "
Her
r e s p o n s e b a c k t o m e : " Y o u k e p t h i m la s t w e e k d u r i n g m v t im e . I h a v e h i m o n w i n t e r v a c a t i o n . C h r i s h a s h i m f o r C h r i s m a s b r e a k
o n e v e n y e a r s n o t th e w h o le w in t e r v a c a t io n . Y o u a re n o t g e t t in g h im 3 w e e k e n d s in a r o w . It d o e s n o t w o r k th a t w a v .
h a p p e n e d to h is e ve a n d h is h a n d ? "
M v r e s p o n s e : " W e a re f o l l w o i n g th e p a r e n t in g p la n t o a T .
d i d n 't s e e h i m f o r a m o n t h b e c a u s e y o u w i t h h e l d h i m o n D e c e m b e r 1 0 th . T h i s i s o u r w e e k e n d .
d r iv e w a y c h a s in g K a t ie . H e r re sp o n s e :
ta k e h im to th e d r . ? ? ? ? ? ? ?
sc ra tc h e d h is h a n d .
" M u s t h a v e b e e n a r e a lly b i g t rio !
S o r r y it w o r k s o u t t h a t w a v .
S e e y o u F r id a y .
d r w h e n W i l l s la m m e d h is h a n d in a d o o r ? "
J o l e n e 's r e s p o n s e :
D id v o n
" Y o u a re b e in g r id ic u lo u s .
D i d u ta k e h im to the d o c t o r w h e n T v le r g a v e h im a b ig b r u is e o n h is lip a n d c h in ?
W e
H e t r i p p e d in t h e
H e s t i l l h a s b i g d e e p s o r e s in h i s k n u c k l e s .
L o o k s l i k e it m i g h t le a v e s o m e s c a r s . " M v r e s p o n s e b a c k t o J o le n e :
A ls o w hat
He
D id y o u ta k e T y le r to the
" Y o u d o n 't e v e n h a v e v o u r f a c t s s t r a ig h t s o I a m n o t e v e n g o i n g t o
g o in t o it w i t h y o u . H o w e v e r . I h a v e n o t i c e d o n s e v e r a l o c c a s i o n s w e r e c i h a s r e t u r n e d h o m e f r o m h i s d a d s h o u s e w i t h i n j u r i e s . "
M v r e p ly b a c k to h e r w a s:
a n d p la v s h a rd .
" H e h a s a l s o c o m e w i t h i n j u r i e s s e v e r a l t i m e s w h i c h h a v e a l s o b e e n n o t e d . H e i s a lit t le h o v
whn nms
I f y o u w it h h o ld h im a g a in t h is w e e k e n d that is a g a in s t y o u . J o le n e h a s a lw a y s u s e d im p lie d th re a ts t o w a r d s
m vself and Chris when she is not in complete control or getting her wav. This is her form o f harassment and intimidation that
*
she uses on a regular basis.

I declare under penalty o f peijury under the laws o f the state o f Washington that the foregoing is true and correct
Signed at
ft
___________________,
Signature o f Declaranh
[City]
.____________________________
______[State] oncil t c- c r e
__________________
\ fci
/*
[Date].
_________________
Print or Type Name
declaration. Such records should be served on the other party and filed with the court using one o f
these cover sheets:
If filed separately using a cover sheet, the records will be sea led to protect your privacy (although
agencies and boards.) S ee GR 22(C)(2).
00-3-00821*4
35693214
AFRSP
01-12*11
IN COUNTY
AM.

County of
,'S OFFICE
JAN 12 2011 PM

B Y_---------------------------------
I n re :
A X . A J o le n e H a r r is o n
No. 08-3-00821*4
and
R e sp o n d e n t(s).
Declaration of
C hristopher Harrison
(Optional Use)
(DCLR)
T h i s d e c la r a t io n is m a d e b y :
Nam e:
_ C h ris t o p h e r H a r r is o n _
Age:
_ 4 0 _________________________
R e l a t i o n s h i p t o t h e p a r t i e s in t h i s a c t io n :
R e s p o n d e n t ________________________________
/ Declare:
I d e c la r e th a t J o le n e C h a r lt o n k n o w in g l y w it h h e ld o u r s o n C i. f r o m m e o n m v s c h e d u le d b i
m o n t h l y v i s i t a n d t o o k h i m t o H a w a i i . O n 12-10-10 w e s h o w e d u p a t t h e a g r e e d u p o n t im e , a t th e
a g r e e d u p o n p la c e a n d w a i t e d f o r m v s o n . 15 m i n u t e s a f t e r it w a s t i m e t o p i c k h i m u p . m v
g i r l f r i e n d C h a r c a l l e d J o l e n e s m o t h e r to f i n d o u t t h a t m v s o n i s in H a w a i i . S h e a l s o t e lls u s t h a t
J o l e n e h a d a c o n v e r s a t i o n a b o u t t h i s w it h m e a l o n g t im e a g o s a v i n g t h a t w e a g r e e d t o t r a d e
t im e s . T h a t c a n n o t b e r i g h t s i n c e t h e r e h a s b e e n a r e s t r a i n g o r d e r b e t w e e n u s f o r t h e la s t 2 + y e a r s ,
a n d I r e f u s e t o h a v e a n y c o n t a c t w i t h h e r . W e w e r e a i s o t o l d t h a t I a g r e e d t o 's w i t c h * d a y s w i t h h e r
s o th a t 1 c o u ld ge t h im f o r C h r is t m a s b re a k . W h y w o u ld I tra d e f o r s o m e t h in g I a lr e a d y h a d ?
A c c o r d i n g to th e p a re n t in g p la n I g o t m v s o n fo r C h r is t m a s E v e . C h r is t m a s d a y , a n d C h r is t m a s
b r e a k f r o m s c h o o l w h i c h a c c o r d i n g to t h e s c h o o l w e b s i t e s t a r t s o n 1 2 -2 0 t il l 12-31. I n a d d i t i o n
a c c o r d i n g t o t h e p a r e n t i n g p la n I a l s o g o t h i m f o r N e w y e a r s d a y . S o w h a t w a s 1 t r a d i n g f o r ? O n
S u n d a y t h e d a y a ft e r C h r is t m a s J o le n e a n d h e r h u s b a n d c a m e to o u r h o u s e a n d sta rte d p o u n d in g
o n o u r d o o r , I c a l l e d 9 1 1 a n d a s k e d th a t o f f i c e r s b e s e n t t o o u r h o u s e . U p o n a r r i v i n g a t o u r h o u s e
t h e p o l i c e t o l d u s t h a t s i n c e t h e r e w e r e n o c r i m e s b e i n g c o m i t t e d a n d t h a t J o l e n e w a s in v i o l a t i o n
o f h e r o w n r e s t r a i n g o r d e r t h e y a s k e d J o le n e a n d h e r h u s b a n d to l e a v e a n d a d v i s e d m e to f i l e a
re s t ra in in g o r d e r a g a in s t b o th o f th e m .
I n a d d i t i o n t h e p a r e n t i n g plan states t h a t I b e g r a n t e d r e a s o n a b l e t e l e p h o n e v i s i t s . I f I 'm l u c k y I
g e t t o ta lk t o m v s o n o n c e a w e e k , a n d o u r c a l l s a r e r e c o r d e d b v J o le n e . a n d c a l l s a r e o n l y m a d e
w h i l e m v 5 y e a r o l d s o n i s p l a y i n g v i d e o g a m e s o r w a t c h i n g T V . H e i s a l w a y s o r e - o c c u p ie d , a n d
som etim es h e i s b e i n g p l a y e d w i t h a n d / o r t i c k e l e d b v h i s m o t h e r . A c c o r d i n g t o R C W
9 .7 3 .0 3 0
i t i s i l l e g a l t o r e c o r d m y p h o n e c a l l s a n d it i s a v i o l a t i o n o f m y c i v i l r i g h t s
(A tt a c h A d d it io n a l P a g e s i f N e c e s s a r y a n d N u m b e r T h e m .)
I d e c la re u n d e r p e n a lt y o f p e ij u r y u n d e r th e la w s o f t h e sta te o f W a s h in g t o n th a t t h e f o r e g o in g is
tru e a n d co rre ct.

confidential reports to this declaration . Such records should be served on
the other party and fifed with the court using one o f th ese cover sheets:
records
records
attorneys^court personnel and certain state agencies and boards.) See GR
22(C)(2).
IT J T V '
t; /
08-3-00821-4
35693219
AFRSP
FILED
01- 12-11
Superior court ot Washington

County of
AM.
JAN 12 2011
P.M.
PIEMECpUNTY WASHINGTON
KEVIN STOCK, County Cleric
I n re:
BY.
---- DEPUD
A K A J o le n e H a r r is o n
No. 08-3-00821-4
and
Declaration o f
_Christopher H arriso n __[Name]
(Optional Use)
(DCLR)
T h i s d e c la ra t io n is m a d e b y :
Nam e:
C h r i s t o p h e r L e e H a r r i s o n ________________________
Age:
4 0 _____________________________________________________
R e l a t i o n s h i p t o t h e p a r t i e s in t h i s a c t i o n :
I a m the re sp o n d e n t
/ Declare:
I d e c la r e t h a t o n 0 1 - 0 7 - 2 0 1 1 1 a r r i v e d a t t h e p r e - a r r a n g e d d r o n - o f f / p i c k - u p p la c e , a t t h e p r e - a r r a n g e d t im e . O n l y t o w a i t u n t i l l 3 0
m i n u t e s a f t e r s a i d t im e a n d le f t w i t h o u t m v s o n a g a i n ! M v g i r l f r i e n d C h a r h a d t e x t e d a s s h e a l w a y s d o e s c o n f i r m i n g t h a t w e
w o u l d b e p i c k i n g C J u p . J o l e n e 's r e s p o n s e w a s a n d I q u o t e " L o l v o u r f u n n y ! Y o u j u s t h a d v o u r w e e k e n d " . S h e la t e r t e x t s t o s a v
t h a t I k e p t m v s o n d u r i n g h e r t im e w h e n t h e p a r e n t i n g p l a n s t a t e s i n s e c t i o n 3 . 7 t h a t I a m t o g e t m v s o n f o r C h r i s t m a s b r e a k ,
w h ic h a c c o r d in g t o th e h is s c h o o l d is t r ic t w e b s it e is f r o m 1 2 - 2 0 to 1 2 -3 1 .
It a ls o sta te s th a t I g e t h im o n N e w Y e a r s D a y .
T h e re
i s n o m e n t i o n a b o u t w i n t e r v a c a t i o n i n t h e p a r e n t i n g p la n a s J o l e n e s a i d t h a t I s t o l e f r o m h e r. I h a v e g i v e n h e r 2 w e e k s t o f i le
c o n t e m p t a g a i n s t m e . B u t s h e h a s n o t ! S h e a l s o g o e s o n t o s a v t h a t I d o n * t g e t m v s o n 3 w e e k e n d s in a r o w , a n d 1 q u o t e " It d o e s
n o t w o r k th a t w a v " . M v w e e k e n d s w it h m v s o n a re v e r y e a s y to k e e p t ra c k o f. E v e r y o t h e r f r id a v
1 g e t m v s o n . G o i n g b a c k in
o r d e r m v w e e k e n d s S H O U L D h a v e b e e n , a n d a c t u a lly J o le n e m a d e o u t a c a la n d a r 1 y e a r in a d v a n c e w it h m v w e e k e n d s m a rk e d I
d id n o t n e e d th a t b e c a u se I c a n k e e p tra c k o f m v w e e k e n d s w it h m v so n .
J a n u r a r v 7. 2 0 1 1
n o sh ow
D e c e m b e r 2 4 . 2 0 1 0 a lr e a d y h a d m v s o n f o r C h r is t m a s b re a k a c c o r d in g to s e c t io n 3 .7
Decem ber
1 0 .2 0 1 0 no sh o w
J o l e n e h a d le f t f o r H a w a i i o n l y a f e w d a y s b e f o r e
N o v e m b e r 2 6 . 2 0 1 0 p ic k e d u p s o n
N o v e m b e r 1 2 . 2 0 1 0 p ic k e d u p s o n
O c t o b e r 2 9 . 2 0 1 0 p ic k e d u p s o n
O c t o b e r 15. 2 0 1 0 p ic k e d u p s o n
I a l s o d e c l a r e t h a t J o le n e C h a r l t o n i s a l s o in c o n t e m p t o f c o u r t u n d e r 2 m o r e s e c t i o n s o f o u r p a r e n t i n g p la n . S e c t i o n 6. n u m b e r 5.
I t s t a t e s " F a t h e r s h a l l h a v e r e a s o n a b l e t e le p h o n e c o n t a c t w i t h t h e c h i l d w h i c h m a y e x t e n d t o e l e c t r o n i c c o m m u n i c a t i o n w h e n th e
F a t h e r d e e m s a p p r o p r i a t e " I f I m l u c k y I g e t t o t a l k t o m v s o n t w i c e a w e e k t h a t d o e s n o t h a p p e n t o o f t e n , u s u a l l y it 's o n c e a w e e k
a n d 1 h a v e t o b e g f o r tha t. T h e r e h a v e b e e n s e v e r a l t im e s t h a t I h a v e h e a r d T e l l v o u r d a d .... " o v e r a n u m b e r o f t h i n g s . J u s t a b o u t
e v e r v t i m e w h e n m v s o n c a l l s , h e i s p l a y i n g v i d e o g a m e s , w a t c h i n g a m o v i e , o u t t o d i n n e r a n d t h e r e h a s b e e n a t im e w h e n h i s
m o t h e r d e c i d e d t o s t a r t t i c k e l i n g h i m d u r i n g o u r c a ll. T h e p a r e n t i n g p l a n a l s o s t a t e s in s e c t i o n 6 . n u m b e r 1. it s t a t e s t h a t t h e f a t h e r
s h a l l b e i n f o r m e d in d e t a il t o a ll e d u c a t i o n a l , m e d i c a l a n d r e l i g i o u s d e c i c i o n s a n d p r o v i d e r s . J o l e n e f la t o u t r e f u s e s to t e ll m e
a n y t h i n g a b o u t m v s o n a n d w h a t s g o i n g o n w i t h h im .
I a m s u r e th a t J o le n e C h a r lt o n k n o w s t h is p a r e n t in g p la n f r o n t w a r d s a n d b a c k w o r d s . A s s h e h a s q u o te d th e p la n v e r b a t im w h e n I
w a s a f e w h o u r s la te in c o n f i r m i n g m y w e e k e n d ( w h i c h w a s s e t u p f o r b e i n g 1 2 h o u r s a w a y n o t 1 2 m i l e s ) . S h e q u o t e d s e c t i o n and
p a r a g r a p h n u m b e r s t a t i n g t h a t I d i d n o t c o n f i m b v 6 p m W e d n e s d a y s o t h e r e f o r e i d o n o t g e t m v v i s i t ! S h e w a s r ig h t . A c c o r d i n g t o
t h e p a r e n t i n g p la n . B U T i s t h a t i n o u r s o n s b e s t i n t e r e s t ? W i t h J o l e n e h a v i n g k n o w l e d g e o f t h e p a r e n t i n g p l a n a n d a b l e t o q u o t e it
w o r d f o r w o r d . s h e n e e d s to b e h e ld a c c o u n ta b le u n d e r R C W
9 A .4 0 .0 6 0 (2 ) o r R C W
9 A . 4 0 . 0 7 0 (2 ). I w a s a ls o t o ld b y J e a n e tte
J e p s o n ( J o le n e s m o t h e r) th a t J o le n e h a s s o le d e c is io n m a k in g a u t h o r it y a n d c a n c h a n g e t h e p a r e n t in g p la n w h e n s h e se e f it . T h is
w a s t o ld t o m y g ir lf r ie n d a n d I w h il e J o le n e t o o k m y s o n to H a w a i i d u r in g m y w e e k e n d v is it . I f t h is is s o w h y d o w e g o t o c o u r t ?
i d e c la r e
S ig n e d at
under penalty o f perjury under the
Jaw s
f r / w r j _________________ , [ C i t y ]
o f t h e state o f W a s h i n g t o n
lA y
[S ta te ] o n _
th a t th e
I " )0-
foregoing is true and correct.
7 / _____________ [ D a t e ] .
P rin t o r T y p e N a m e
these cover sheets:
5 r i1 3 S 3

County of
I n re:
No. 08-3-00821-4
P e t it io n e r ,
and
Motion/Declaration for an Order to

Show Cause re
Contem pt
(MTSC)
R e sp o n d e n t.
I. Motion
( N a m e o f r e q u e s t in g p a r t y )
C h r i s t o p h e r H a r r i s o n __
d ir e c t in g ( n a m e o f o t h e r p a r t y )
_________ m o v e s t h e c o u r t f o r a n o r d e r
t o a p p e a r p e r s o n a lly b e fo r e th e c o u r t
a n d s h o w c a u s e w h y a n o r d e r s h o u ld n o t b e e n te re d :
Finding Contem pt
[]
[X ]
F i n d i n g c o n t e m p t f o r f a ilu r e to c o m p l y w it h :
[]
th e o r d e r o f c h ild s u p p o rt
[]
t h e o r d e r o f m a in t e n a n c e
[x ]
t h e p a r e n t in g p la n / c u s t o d y o r d e r
[]
th e re s t ra in in g o rd e r
[]
o th e r:
S i g n e d b y t h e c o u r t o n ( d a t e ) ___0 1 - 2 5 - 2 0 1 0 ________________________________________________ in ( c o u n t y a n d sta te )
1.2
Establishing a Judgm ent

[x ]
[ ]
E s t a b l i s h i n g a j u d g m e n t in t h e a m o u n t o f $ ____________________ p l u s $
in t e r e s t f o r d e l i n q u e n t c h i l d
s u p p o r t a n d $ ___________________________ c o s t s f o r t h e p e r i o d f r o m
( d a t e ) ___________________________________t h r o u g h ( d a t e ) ____________________
[ ]
E s t a b l i s h i n g a j u d g m e n t i n t h e a m o u n t o f $ _____________________p l u s $
in t e r e s t f o r d e l i n q u e n t
r i' r r
_ r w
v i J
^ '
m e d i c a l s u p p o r t a n d $ _________________________ _ c o s t s f o r t h e p e r i o d f r o m
( d a t e ) ____ ______________________________ t h r o u g h ( d a t e ) _________________________________________ .
[ ]
E s t a b l i s h i n g a j u d g m e n t in t h e a m o u n t o f $ ___________________ p l u s $ ____________________ in t e r e s t f o r d e l i n q u e n t c h i l d
ca re , e d u c a t io n a l e x p e n s e s , t r a n s p o r t a t io n e x p e n s e s , o r o t h e r s p e c ia l e x p e n s e s a n d $
f o r t h e p e r i o d f r o m ( d a t e ) _____________________ __ t h r o u g h ( d a t e ) ____________
[ ]
_____________________ c o s t s
.
E s t a b l i s h i n g a j u d g m e n t in t h e a m o u n t o f $ __________________ p l u s $ __________________ in t e r e s t f o r d e l i n q u e n t
m a i n t e n a n c e a n d $ ______________________ c o s t s f o r t h e p e r i o d f r o m
(d a te )
1.3
-_____________________________ t h r o u g h ( d a t e ) ________________________________________ .
Granting Sanctions
[x ]
[ ]
G r a n t i n g s a n c t io n s f o r c o n te m p t , i n c l u d in g a f o r f e it u r e f o r e a c h d a y th e c o n t e m p t o f c o u r t c o n t in u e s , a n d
e s t a b l i s h i n g c o n d i t i o n s b y w h i c h t h e c o n t e m p t m a y b e p u r g e d a n d g r a n t i n g a n y o t h e r r e lie f , i n c l u d i n g r e a s o n a b l e
a t t o r n e y f e e s a n d c o s t s a n d m a k e u p r e s i d e n t i a l t im e , a s m a y b e a p p r o p r ia t e u n d e r C h a p t e r 7 . 2 1 R C W , C h a p t e r
2 6 .0 9
[ J
1.4
R C W , C h a p te r 2 6 .1 0 R C W , C h a p te r 2 6 .2 6 R C W , a n d R C W
2 6 .1 8 .0 4 0 .
I m p r i s o n m e n t i s s o u g h t a s a s a n c t io n .
O ther
T h is m o t io n is b a se d u p o n the d e c la r a t io n w h ic h f o llo w s .
D ate d :
/ / ___________________________
_____________________
S ig n a t u r e o f R e q u e s t in g P a r t y o r L a w y e r / W S B A N o .
________ / / ^
Sf___________________
II.
[ ]
Declaration
____________________________ _ _ _ s h o u l d b e h e l d in c o n t e m p t f o r t h e f o l l o w i n g r e a s o n s :
F a i l u r e t o c o m p l y w i t h t h e p r o v i s i o n o f t h e c h i l d s u p p o r t o r d e r w h i c h d i r e c t e d p a y m e n t o f:
[ ]
c u r r e n t c h i l d s u p p o r t in t h e a m o u n t o f $ ______________________ p e r m o n t h .
[ ]
m e d ic a l s u p p o r t , i n c l u d in g h e a lth in s u r a n c e c o v e r a g e a n d c a s h m e d ic a l s u p p o r t a s d e s c r ib e d b e lo w :
[ ]
c h ild c a re , e d u c a t io n a l e x p e n s e s , t ra n s p o rt a t io n e x p e n s e s , o r o t h e r s p e c ia l e x p e n s e s a s d e s c r ib e d b e lo w :
O th e r:
[ ]
F a i l u r e t o c o m p l y w i t h t h e m a i n t e n a n c e o r d e r w h i c h d i r e c t e d p a y m e n t o f m a i n t e n a n c e in t h e a m o u n t o f $
______________________ p e r m o n t h a s d e s c r i b e d b e l o w :
[X ]
F a i l u r e t o c o m p l y w i t h t h e p a r e n t i n g p la n a s f o l l o w s :
D i d n o t s h o w u p w i t h c h i l d a t t h e p r e - a r r a n g g e d m e e t i n g p l a c e a t t h e p r e - a r r a n g e d t im e f o r f a t h e r s b i - m o n t h l y v i s i t
[ ]
F a i l u r e t o c o m p l y w i t h t h e r e s t r a i n i n g o r d e r a s w h i c h r e q u ir e d :
T h i s o r d e r w a s v io la t e d in t h e f o l l o w in g m a n n e r
[ ]
O th e r:
I d e c la r e u n d e r p e n a l t y o f p e r j u r y u n d e r t h e l a w s o f t h e s ta te o f W a s h i n g t o n t h a t t h e f o r e g o i n g i s t r u e a n d c o r r e c t .
S ig n e d at (c it y )
///;
b y /( a ____________________ (s t a t e )
^ 4
o n (d a te )
C h r i s H a r r i s o n ____ ______
Signature o f Requesting Party
Print or Type Name
I I _____________
FILED
CLERK'S OFFICE
01- 12-11
08-3-008
12 2011 py
OUWTYWASHWGTON
STOCK, County Clerk

County of
DEPUTY
. I n re ;
No. 08-3-00821-4
P e t it io n e r ,
and
O rder to Show Cause re

Contem pt
(ORTSC)
C lerks Action Required

R e sp o n d e n t.
it is Ordered:
( N a m e o f n o n r e q u e s t in g p a rty ) _ J o le n e C h a r lt o n
s h a l l a p p e a r i n p e r s o n b e f o r e t h i s c o u r t at
trie
ueiow
th e p la c e a n d t im
e b
e l o w anu
a n d snow
s h o w uau.se
c a u s e w h y th e r e lie f re q u e s t e d i n th e m o t io n s h o u ld n o t b e
g ra n te d .
D ate:
a .m V p .m .
P la c e :
piercT counS
ldh
RI0R
\ COURT
930 TACOMA AVE SOUTH

TAC0M A7W A 98402
_______ o a u i n M W " i n .,. ' . ' " i r , ' ,
T im e :
G-
R o o m / D e p a rtm e n t:
I f y o u f a i l t o a p p e a r in p e r s o n a n d d e f e n d a t t h e s e p r o c e e d i n g s t h e c o u r t m a y g r a n t a l l o f t h e
r e lie f re q u e st e d a n d / o r is s u e a b e n c h w a rr a n t f o r y o u r a rre st w it h o u t fu rth e r n o tic e to y o u .
I f im p r is o n m e n t is re q u e s t e d in th e m o t io n a n d y o u c a n n o t a f f o r d a n a tto rn e y , y o u m a y re q u e s t
th e c o u r t to a p p o in t a n a tto rn e y to re p re se n t y o u .
iy
E-FILED
January 26 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
County of
In re:
Jolene Charlton
N o

Petitioner,
. 0 8 -3 -0 0 8 2 1 -4
M o t io n / D e c la r a t io n f o r a n O r d e r to
Show
C a u s e re
C o n te m p t
and
(M T S C )
Respondent.
I. M o t i o n
(Name of requesting party) _Christopher

Harrison_______________________________________moves the court for an order
directing (name of other party)__Jolene
Charlton_________________________________to appear personally before the court
and show cause why an order should not be entered:
1 .1
F in d in g C o n te m p t
[ ] Does not apply.

[x ] Finding contempt for failure to comply with:
[ ] the order of child support
[ ] the order of maintenance
[x ] the parenting plan/custody order
[ ] the restraining order
[ ] other:
Signed by the court on (date)__01-12

2011________________________________in (county and state) _Pierce,
WA .
1 .2
E s t a b lis h in g a J u d g m e n t

[ ] Establishing a judgment in the amount of $
_____________plus $ _____________ interest for
delinquent child support and $__________________ costs
for the period from
(date) _______________________ through (date)
_____________ plus $ _____________ interest for
delinquent medical support and $________________
costs for the period from
(date) _______________________ through (date)
_____________ plus $ _____________ interest for
delinquent child care, educational expenses, transportation
expenses, or other special expenses and
$__________________ costs for the period from (date)
________________ through (date) ___________________
____________ plus $ ____________ interest for
delinquent maintenance and $ _______________ costs for
the period from
(date) ________________________ through (date)
1 .3
G r a n t in g S a n c t io n s

[ ] Granting sanctions for contempt, including a forfeiture
for each day the contempt of court continues, and
establishing conditions by which the contempt may be
purged and granting any other relief, including reasonable
attorney fees and costs and make up residential time, as
may be appropriate under Chapter 7.21 RCW, Chapter
26.09 RCW, Chapter 26.10 RCW, Chapter 26.26 RCW,
and RCW 26.18.040.
[ ] Imprisonment is sought as a sanction.
1 .4
O th e r
Dated: 1-12-11
Signature of Requesting Party or Lawyer/WSBA No.
Chris Harrison
Print or Type Name
II. D e c la r a t io n
_Jolene Charlton_____________________________ should be held in contempt for the

following reasons:
[ ] Failure to comply with the provision of the child support order which
directed payment of:
[ ] current child support in the amount of $
_______________per month.
[ ] medical support, including health insurance coverage
and cash medical support as described below:
[ ] child care, educational expenses, transportation

expenses, or other special expenses as described below:
[ ] Other:
[ ] Failure to comply with the maintenance order which directed payment

of maintenance in the amount of $ _______________per month as
described below:
[X ] Failure to comply with the parenting plan as follows:

Did not show up with child at the pre-arrangged meeting place at the pre
arranged time for fathers bi-weekly visit
[ ] Failure to comply with the restraining order as which required:
This order was violated in the following manner:

[ ] Other:
I declare under penalty of perjury under the laws of the state of Washington that the
Signed at (city) Auburn_________________________(state)___ WA_________on
(date)___1-12-11__________________ .
Chris Harrison
Signature of Requesting Party Print or Type Name

County of
In re:
N o . 0 8 -3 -0 0 8 2 1 -4
Petitioner(s),
and
A.K.A.. Jolene Marie Harrison
D e c la r a t io n o f
_ C h r is t o p h e r H a r r is o n
[N a m e ]
(O p t io n a l U se )
Respondent(s).
(D C L R )

Name: _Christopher__________________________________________
Age: _40__________________________________________
_Respondent_________________________________________________
I
D e c la re :
I declare that Jolene Charlton knowingly withheld our son Cj, from me on my scheduled
bi-monthly visit and took him to Hawaii. On 12-10-10 we showed up at the agreed upon
time, at the agreed upon place and waited for my son. 15 minutes after it was time to pick
him up, my girlfriend Char called Jolenes mother to find out that my son is in Hawaii.
She also tells us that Jolene had a conversation about this with me a long time ago saying
that we agreed to trade times. That cannot be right since there has been a restraining order
betweenus for the last 2+ years, and I refuse to have any contact with her. We were told
that I agreed to 'switch" days with her so that I could get him for Christmas break. Why
would I trade for something I already had? According to yhe parenting plan I got my son
for Christmas Eve, Christmas day, and Christmas break from school which according to
the school website starts on 12-20 till 12-31. In addition according to the parenting plan I
also got him for New Years day. So what wa I trading for? On Sunday the day after
Christmas Jolene and her husband came to our house and started poundingon our door, I
called 911 and asked that officers be sent to our house. Upon arriving at our house the
police told us that since there were no crimes being comitted and that Jolene is in
violation of her own restraining order they asked Jolene and her husband to leave and
advised me to file a restraining order against both of them.
In addition the parenting plan states that I be granted reasonable telephone visits. If I'm
luckyI get to talk to my son once a week, and our calls are recorded by Jolene, and calls
a re o n ly m a d e w h ile m y 5 y e a r o ld s o n is p la y in g v id e o g a m e s o r w a t c h in g T V . H e is
a lw a y s p r e - o c c u p ie d , a n d s o m e t im e s h e i s b e in g p la y e d w it h a n d / o r t ic k e le d b y h is
m o th e r. A c c o r d in g to R C W
9 . 7 3 . 0 3 0 it i s i ll e a g a l t o r e c o r d m y p h o n e c a l l s a n d it i s a
v io la t io n o f m y c iv il rig h t s
(A tt a c h A d d it io n a l P a g e s i f N e c e s s a r y a n d N u m b e r T h e m .)
I d e c la r e u n d e r p e n a lt y o f p e r j u r y u n d e r t h e la w s o f t h e sta te o f W a s h i n g t o n th a t th e
f o r e g o in g is tru e a n d c o rre ct.
S i g n e d a t ___ A u b u r n __________________________________ , [ C i t y ] ______ W A _____________ [ S t a t e ] o n

_____1 - 6 - 2 0 1 1 [ D a t e ] .
S ig n a t u r e o f D e c la r a n t P r in t o r T y p e N a m e
n o t a tta c h f in a n c ia l reco rd s, p e r s o n a l h e a lth c a re r e c o rd s o r c o n fid e n tia l re p o rts to

th is d e c la ra tio n . S u c h re c o rd s s h o u ld b e s e r v e d o n th e o th e r p a r ty a n d f i l e d w ith th e
c o u r t u s in g o n e o f th e se c o v e r sh e e ts:
1) S e a le d F in a n c ia l S o u rc e D o c u m e n ts (W P F D R P S C U 0 9 .0 2 2 0 ) f o r f in a n c ia l re c o rd s
2) S e a le d P e r s o n a l H e a lth C a re R e c o r d s (W P F D R P S C U 0 9 .0 2 6 0 ) f o r h e a lth re c o rd s
3) S e a le d C o n fid e n tia l R e p o r t (W P F D R P S C U 0 9 .2 7 0 ) f o r c o n fid e n tia l re p o rts
D o
I f f i l e d s e p a r a te ly u s in g a c o v e r sh eet, th e r e c o rd s w ill b e s e a le d to p r o te c t y o u r p r iv a c y
(a lth o u g h th e y w ill b e a v a ila b le to a ll p a r tie s in th e case, th e ir a tto rn e y s, c o u r t
p e r s o n n e l a n d c e rta in s ta te a g e n c ie s a n d b o a rd s.) S e e G R 2 2 (C )(2 ).

County of
In re:
Jolene Charlton
No. 08-3-00821-4
AKA Jolene Harrison
Declaration of
Petitioner(s),
and
_Christopher H arrison__[Name]
(Optional Use)
Respondent(s).
(DCLR)

Name: Christopher Lee Harrison_______________________
Age: 40__________________________________________
Relationship to the parties in this action: _I am the respondent
D e c la re :
I declare that on 01-07-2011 I arrived at the pre-arranged drop-off / pick-up place, at the
pre-arranged time. Only to wait until 30 minutes after said time and left with out my son
again! My girlfriend Char had texted as she always does confirming that we would be
picking CJ up, Jolene's response was and I quote " Lol your funny! You just had your
weekend". She later texts to say that I kept my son during her time when the parenting
plan states in section 3.7 that I am to get my son for Christmas break, which according to
the his school district website is from 12-20 to 12-31. It also states that I get my son on
New Year's Day. There is no mention about winter vacation in the parenting plan as
Jolene said that I stole from her. I have given her 2 weeks to file contempt against me.
But she has not! She also goes on to say that I don't get my son 3 weekends in a row, and
I quote " It does not work that way". My weekends with my son are very easy to keep
track of. Every other Friday I get my son every other weekend. Going back in order, my
weekends SHOULD have been, and actually Jolene made out a calandar 1 year in
advance with "my" weekends marked. I do not need a homemade Microsoft calendar that
she created at home. I can keep track of my weekends with my son on my own, without
Jolene's help. I have picked my son up every weekend on a regular schedule without the
help of anyone else.
Janurary 7, 2011 - no show

December 24, 2010 - already had my son for Christmas break according to section 3.7
December 10, 2010 - no show. Jolene had left for Hawaii only a few days before without
my prior knowledge.
November 26, 2010 - picked up son
November 12, 2010 - picked up son
October 29, 2010 - picked up son
October 15, 2010 - picked up son
I also declare that Jolene Charlton is also in contempt of the court under 2 more sections
of our parenting plan. Section 6, number 5. It states "Father shall have reasonable
telephone contact with the child which may extend to electronic communication when the
Father deems appropriate." If Im lucky I get to talk to my son twice a week. That does
not happen too often, usually it's once a week and I have to beg for that. There have been
several times that I have heard "Tell your dad...." over a number of other things. Just
about every time when my son calls he is playing video games, watching a movie, out to
dinner, once his mother decided to start tickling him during our call to distract our phone
time. The parenting plan also states in section 6, number 1, that the father shall be
informed in detail to all educational, medical and religious decicions and providers.
Jolene flat out refuses to tell me anything about my son and what is going on with him.
I am sure that Jolene Charlton knows this parenting plan frontwards and backwords. As
she has quoted the plan verbatim the one time when I was a few hours late in confirming
my weekend (which was set up for being 12 hours away not 12 miles). She quoted
section and paragraph number stating that I did not confirn by 6 pm on Wednesday, so
therefore I do not get my visit with my son! She was right. According to the parenting
plan. This parenting plan was designed under the pretence that her and my son would be
permanately residing in Idaho. Is this in our sons best interest? Jolene has full knowledge
of the parenting plan and is able to quote it word for word on several occasions, when it
behooves HER. She needs to be held accountable under RCW 9A.40.060 (2) or RCW
9A.40.070 (2). I was also informed by Jeanette Jepson (Jolene's mother) that Jolene has
sole decision making authority and can change the parenting plan at anytime when she
see's it fit. This was told to my girlfriend and I while Jolene took my son to Hawaii
during my weekend visit. If this is so why do we go to court?
Signed at
__________ , [City]
[Date].
[State] on
Signature of Declarant Print or Type Name
Do n o t
a tta c h f in a n c ia l reco rd s, p e r s o n a l h e a lth c a re re c o rd s o r c o n fid e n tia l re p o rts to

th is d e c la ra tio n . S u c h re c o rd s s h o u ld b e s e r v e d o n th e o th e r p a r ty a n d f i l e d w ith th e
c o u r t u s in g o n e o f th e se c o v e r sh e e ts:
1) S e a le d F in a n c ia l S o u rc e D o c u m e n ts (W P F D R P S C U 0 9 .0 2 2 0 ) f o r f in a n c ia l re c o rd s
2) S e a le d P e r s o n a l H e a lth C a re R e c o r d s (W P F D R P S C U 0 9 .0 2 6 0 ) f o r h e a lth re c o rd s
3) S e a le d C o n fid e n tia l R e p o r t (W P F D R P S C U 0 9 .2 7 0 ) f o r c o n fid e n tia l re p o rts
I f f i l e d s e p a r a te ly u s in g a c o v e r sh eet, th e r e c o rd s w ill b e s e a le d to p r o te c t y o u r p r iv a c y
(a lth o u g h th e y w ill b e a v a ila b le to a ll p a r tie s in th e case, th e ir a tto rn e y s, c o u r t
p e r s o n n e l a n d c e rta in s ta te a g e n c ie s a n d b o a rd s.) S e e G R 2 2 (C )(2 ).
E-FILED
February 01 2011 9:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

J O L E N E M A R IE H A R R IS O N
No. 08-3-0 08 2 1 -4
Petitioner(s),
N O T E F O R C O M M I S S I O N E R 'S C A L E N D A R
vs.
C H R I S T O P H E R L E E H A R R IS O N
R e sp o n d e n t(s)
T O T H E C L E R K O F T H E S U P E R I O R C O U R T A N D TO :

Address: 12107 209TH AVE. CT. E. BONNEY LAKE, WA 98391
Name: JOLENE CHARLTON
Address: 12107 209TH AVE. CT. E BONNEY LAKE, WA 98391
Phone:
Petitioner
Phone:
Involved Party
P le a s e ta ke notice that an is s u e o f law in this c a s e w ill be heard on the date and tim e sh ow n below:
P ie r c e C o u n t y S u p e r io r C o u rt, C o u n t y - C it y B u ild in g - 9 30 T a c o m a A v e S - T a c o m a , W A 9 8 4 0 2
S h o w C ause
N a tu re o f H e a rin g :
C o n te m p t
CALENDAR DATE: Thursday, February 17, 2011 9:30 AM

W O R K I N G C O P I E S S H A L L B E S U B M I T T E D T O C O M M I S S I O N E R S S E R V I C E S R O O M 140,
B E F O R E 12:00 N O O N T W O C O U R T D A Y S P R I O R T O H E A R I N G
DATED:
F e b ru a ry 1, 2011.
S ig n e d :
NAM E:
C H R I S T O P H E R L E E H A R R IS O N
Phone:
A D D R E S S : 6721 N A T H A N A V E S E
A U B U R N , W A 98092
/s/ C H R I S T O P H E R L E E H A R R IS O N
W SBA#:
Fo r:
1 of
H feS fe
2 ./ 1 ^'28-3.1
IIII! 1
11!tillI!HillmilIII] I millIIIJJ.M
IllllJIJIIII)If
08-3-00821-4
35811402
AFRSP
02-01-11
FILED

County of
FEB 01 2011
p.jh,

BY
^
_ DEPUTY
I n re:
A K A J o le n e H a r r i s o n
No. 08-3-00821-4
and
Declaration of
_Christopher H arrison__[Name]
(Optional Use)
(DCLR)
T h i s d e c la r a t io n is m a d e b y :
Nam e:
C h r i s t o p h e r L e e H a r r i s o n ________________________
Age:
4 0 _____________________________________________________
R e l a t i o n s h i p t o t h e p a r t i e s in t h i s a c t io n : _ i a m t h e r e s p o n d e n t
/ Declare:
T h a t m v g ir lf r ie n d C h a r P e r g r im . n o t if ie d J o le n e o n 1 - 1 9 - 1 1 th a t w e w o u ld b e p i c k i n g m v s o n
p r e - a r r a n g e d t im e . A
up a t
t h e p r e - a r r a n g e d p la c e , a t th e
f e w h o u r s b e f o r e w e w e r e t o p i c k h i m u p C h a r r e c i e v e d a t e x t m e s s a g e f r o m J o l e n e s a v i n g th a t a f t e r h e r
h u s b a n d h a d r e - r e a d t h e p a r e n t i n g p la n a n d t h a t s i n c e
1g o t
m v so n o n n e w y e a rs d a y
fa d a t e
c a lle d o u t in th e p a r e n t in g
1 w a s t o h a v e h i m ) t h a t w o u l d o f f s e t t h e o r d e r o f m v v i s i t s a n d 1 w o u l d n 't b e a b le t o s e e h i m u n t i l l 1 - 2 8 - 1 1 .
plan
w h ic h
T h e la s t t im e 1 s a w
h im w a s 1 - 1 - 1 1 . s o n o w 1 h a v e t o g o 2 7 d a y s w it h s e e in g m v s o n . T h is is p r o o f r ig h t th e re th a t J o le n e t h in k s s h e c a n d o w h a t e v e r
s h e w a n t s w i t h a t o ta l d i s r e g a r d f o r t h e J u d g e 's o r d e r s . A l s o a c c o r d i n g t o RCW Z6.09.002 quote: "Parents have the
responsibility to make decisions and perform other parental functions necessary for the care and growth of their minor
children. In any proceeding between parents under this chapter, the best interests of the child shall be the standard bv
which the court determines and allocates the parties* parental responsibilities. The state recognizes the fundamental
importance of the parent-child relationship to the welfare of the child, and that the relationship between the child and
each parent should be fostered unless inconsistent with the child's best interests. Residential time and financial snpport
are equally important components of parenting arrangements. The best interests of the child are served by a Parenting
arrangement that best maintains a child's emotional growth, health and stability, and physical care. Further, the hwt
interest of the child is ordinarily served when the existing pattern of interaction between a parent and child is altered only
to the extent necessitated by the changed relationship of the parents or as required to protect the child from physical 1
mental, or emotional harm. T h i s i s N O T i n t h e best in t e r e s t o f o u r c h i l d . I n t h e la s t 2 m o n t h s I h a v e m i s s e d 2 b l o c k s o f r i m *
w i t h m v s o n , t h e f i r s t f o r 2 4 d a y s , t h e s e c o n d f o r 2 7 d a y s . I n s i d e t h a t w a s m v c o u r t d e c l a r e d t i m e ( s e c t i o n 3.7 o f t h e parenting
plan - C h r i s t m a s b r e a k , a n d a c c o r d i n g t o t h e s c h o o l 's w e b s i t e C h r i s t m a s b r e a k i s f r o m 1 2 - 2 0 - 1 0 t o 1 2 - 3 1 - 1 0 ) in w h i c h w e
r e c e i v e d s e v e r a l n a s t y t e x t s d e m a n d i n g t h e r e t u r n o f m v s o n o r w e w e r e g o i n g t o b e s u e d , (see attached texts). A f t e r t h e A u b u r n
p o l i c e c h a s e d t h e m o f f s t a t in g t h a t b o t h J o l e n e a n d h e r h u s b a n d h a d a t o ta l d i s r e g a r d f o r t h e p o l i c e , a s t h e h u s b a n d w e n t s o f a r a s
t o p u t h i s h a n d s in t h e O f f i c e r 's f a c e t h e n j u s t w a l k e d o f f .
T h i s a g a i n i s p r o o f t h a t J o l e n e a n d h e r n e w e s t h u s b a n d c h o o s e to d o a s
t h e y p le a s e a n d d o n 't f e e l t h e y h a v e t o a n s w e r t o a n y o n e : t h e p o li c e , t h e J u d g e o r a n y o n e w h o d o e s a n y t h i n g th a t u p s e t s th e m
J o l e n e i s c l e a r l y n o t t h i n k i n g a b o u t w h a t i s b e s t f o r h e r s o n a n d iu s t w h a t i s b e s t f o r J o le n e .
1 h a v e a v e r y g o o d r e la t i o n s h i p w it h
m v s o n a n d t h e f e w p h o n e c a l l s I 'm a l l o w e d a r e a l w a y s f i l l e d w i t h " I l o v e y o u d a d , a n d " I m i s s y o u d a d ! S o w h v a re m y

c o m m u n i c a t i o n s w i t h m v s o n g e t t i n g m o r e a n d m o r e s p o r a t i c ? 1 u s e d t o g e t 2 c a l l s r e t u r n e d a w e e k n o w . T m l u c k y i f 1 g e t n n r in
a w e e k 's t im e .
3IhB h
? ./ \ SZ&lt 1
I n t h e m o t i o n I f ile d f o r t h i s c o n t e m p t 1 a m a s k i n g f o r j a il t im e f o r J o le n e . I f e e l 3 w e e k e n d s in j a i l i s f a ir . I n t h e la s t 2 m o n t h c r
h a v e m i s s e d 3 w e e k e n d s w o r t h o f t im e w i t h m v s o n .
a t t h e la s t m in u t e , m v w e e k e n d f e e l s l i k e
Iam
A n d w h e n I lo o k fo r w a r d to m v w e e k e n d w it h m v s o n o n ly to g e t sh o t d o w n
i n ia il. M v
repeated r e q u e s t s
t o t a lk t o m v s o n f a l l o n d e a f e a r s . A l s o . I f e e l i f
J o l e n e i s g i v e n j a il t im e , m a y b e s h e w i l l f o l l o w t h e J u d g e s o r d e r s , in s t e a d o f m a k i n g u p h e r o w n p a r e n t i n g p l a n a s s h e p r ^ g
a lo n g .
1 d e c la re u n d e r p e n a lt y o f p e r ju r y u n d e r th e la w s o f th e sta te o f W a s h in g t o n th a t th e f o r e g o in g is tru e a n d c o rre c t.
S i g n e d a t ____ A u b u r n
/ _____________ , [ C i t y ] ____________ W A _______________[ S t a t e ] o n ________ 1 - 3 1 - 2 0 1 1
/7
/
f iig ija t t jr e o f D e c l a r a n t
______________
[D a te ],
C h r i s H a r r i s o n _ _____________________________________________ __
these cover sheets:
1.16B
2 ^ 1 / Z S I l
In reply to a missed call at 8:02 pm on 12-26-10

Char:
After revieving the parenting plan, we will be exercizing our full visition as spelled out in the parenting plan.
Jolene:
I'm sorry but you did not make arrangements for that. We will be calling the police!
Jolene:
Char, I am here to pick up cj. If you refuse to release him I will have no choice but to contact an attorney and press charges.
Char:
We are excercizing the parenting plan.
Joiene:
Actually you are violating the plan. Christmas break is past Winter break is with us. Would you like to return him now.
Jolene:
Refusal to return him is grounds for a law suit.
2S2S2& X1
123S4
11&858
08-3-0082
tU r r i& v t
Plsiniiff(s)/Petitioner(s)
vs
C ftf
C h A sL o p h cr
W a rn s o ^
TO THE CLERK
ADDRESS
P fX -
U M M
NOTE FOR COMMISSIONERS CALENDAR
(fiic)
Defendant{s)/Responden:(s)
N -M E
O S -T p o S z iR
F THE SUPERIOR COURT AND TO.
fe ty V tc r
E d is o n
d o tp .n ft
V V frm sc A o
W SBAiTTORNEY FOR
PHONE
{Please no*e sdditonal attorneys cn an attached cage)
Please take notice that an issue of law in tms case will be heard on tne da:e below and the clerk is directed tc note inis
on the appropriate calendar
C A LE N D A R DATE
A -1 7 -U
Ns*ure cr Heannc
WORKING COPIES SHALL BE SUBMITTED TWO COURT DAYS PRIOR TO HEARING
.
SELECT ONE BOX BELOW
[ v f (MO) Snow Cause/Family Lav/, Confirmation Required

(9 30 Mon-Tnurs)
Pierce County Local Rule 0 a requires tnat tms Note for Commissioners Calendar be filed a: the same time as your
Motion and/or Notice of Hearing and any supporting documents, unless m s is a renote of previously filec Meson and/
or Notice of Hearing Monetary sanctions will be imposed it this Local Rule is no* followed I heresy certify tna: all
documents m accordance witn this rule nave been filed cn tne following d a te _________________
PARTY SETTING HEARING MUST CONFIRM 5Y CALLING (253)7SS-6SS7 SY NOON
TWO(2] COURT/WORKING DAYS PRIOR TO hEARING OR HEARING WILL BE CANCELLED
[ 1 (YY) Aaocton, No Confirmation Reauirsa
(9 00 Fn)
[ ] (OE) Suoplementsl Proceedings, No Confirmation Required
(1 30 Mon-Fn)
I 1 (UD1 Unlawful Detainer, No Confirmation Required
(1 30 Mon-Fri)
[ ] (GD) Probate/Gdnshp/Mnr Settlement No Confirmation Required
(1 30 Mon-Fn)
[ ] (FC) Paternity, No Confirmation Required
(1 30 Mon,Tues & Thud
DATED
NAME
ADDRESS:
DIANA LYNN KIESEL N-H

COURT COMMISSIONER
Signed
Phone
WSBA#
__________For
THE ABOVE INFORMATION MUST BE COMPLETED AND SIGNED

SUPERIOR COURT OF PIERCE
930 Tacoma Avenue South
Tacoma, W A 98401
X
CSD
w m e ty
08-3-00621-4
358J1409
f il e d
02-01-1J
DCLR
P IE R C E C O U N T Y , W A S H IN G T O N
K E V I N S T O C K , Cro
o uu nn tty
y C
< le r k
BY-________

County of
* '
DEPUTY
In re:
Jolene Charlton
A.K..A. Jolene Harrison
No. 08-3-00821-4
Petitioners),
and
Respondents).
Declaration o f
Charlotte Pergrim
(Optional Use)
(DCLR)
[Name]

Name:
Charlotte Pergrim
Age:
39
Relationship to the parties in this action: Domestic Partner of Christopher Lee Harrsion Sr.
/ Declare:
January 19. 2011 - 1 texted Jolene at 7:23 am to confirm that we would be picking CJ up on Friday. January 21st at 8:00 pm as per
the schedule. Jolene did not reply back until Friday. January. 21 st.
January 19. 2011 - Texted Jolene at 6:53 pm to please have CJ call his dad. No response, no call.
January 20.2011 - Texted Jolene at 6:17 pm to please have CJ call his dad. No response, no call.
January 21.2011 - 3:51 pm Jolene texts me informing me that her husband went through the parenting planand because we had
him on January 1s t we would not be getting him for our weekend again, for the SECOND scheduled visitin a row. She informed
me that William Charlton had calculated that our scheduled visit on Saturday. January 1st had changed the schedule for the_
weekend visits. I told her I was confused how she could just change the rotation of the visits and specifically asked her via text
message: "So what vou are saving is that you are going against the Judge's orders, changing the rotation of the schedule and
withholding CJ from his dad for the second time in a row? Her reply was "Actually we are keeping the schedule of alternating
weekends- According to that schedule next weekend is his." Mv reply back to Jolene was "The parenting plan states that th*
father can't make u p for missed weekend visits. It does not sav that vou can change the rotation of the visits because one OR thp
1X 68&
2@ 1 1
other parent has the child on a scheduled visit which happens to fall on the other parent's weekend. In addition, we did not have
CJ for New Years weekend, just New Years day, which we were entitled to according to section 3.7 - so vou, and vour husband,
that dissected the parenting plan for you, are wrong once again." We did not have CJ for New Year's weekend. We had CJ for
New Year's Day, which was a Saturday, and returned him that night at 8:00 pm. CJ was not delivered to us on January 21 s t 2011
for the second scheduled bi-weekly visit in a row, the 3rd time in 7 weeks. Previous to that, due to the visit that Jolene withheld
on December 10th, 2010. we did not get to see CJ from November 28th. 2010 until December 20th. 2010.
January 21.2011 - Texted Jolene at 8:33 pm to have CJ call his dad, pointing out that we have been asking since Saturday,
January 16th and it has been almost a week since she has allowed them to talk. No response, no call.
January 22, 2011 - Texted Jolene to at 12:26 pm to please have CJ call his dad, as we have been asking her to do so for going on a
week now. CJ called at 1:40 pm, talked to his dad for 11:50 minutes.
January 23, 2011 - Texted Jolene at 6:49 pm to please have CJ call his dad. No response, no call.
January 24. 2011 - Texted Jolene at 6:46 pm to please have CJ call his dad. No response, no call.
January 25. 2011 - Text from Char to Jolene at 10:07 am "Jolene...Will vou please explain to me in what section & paragraph nf
the parenting plan it states that vou can withhold or change the rotation o f Chris & CJs visits as vou please?" She never replied
back with an answer.
January 26. 2011 - Texted Jolene at 7:01 am to confirm that we would be picking CJ up on Friday @ 8:00 pm per her new
schedule.
January 26. 2011 - Texted Jolene at 7:45 pm to please have CJ callhis dad. No response, no call.
January 27. 2011 - Texted Jolene at 6:23 pm to please have CJ callhis dad. CJ called at 6:27 pm. talked for 9:56 minutes
January 31.2011 - Texted Jolene at 6:04 pm to please have CJ callhis dad. No response, no call.

I declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and correct.
ll&BA
Signed a t____Auburn
(U hvJy& T li
Signature of Dec
2 /1 V 2 8 1 1
, [City]__WA__________ [State] o n ____ 1-31-2011
2W&&T
[Date],
Charlotte Pergrim_
Print or Type Name
these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220} for financial records
3) Seated Confidential Report (WPF DRPSCU 09.270) for confidential reports
agencies and boards.) S ee GR 22(C)(2).
Od-3-00821-4
35811421
MTSC
02 - 01-11
FILED
IN C O U N T Y C L E R K 'S
a .m .
FEB 0 1 2011
P.M,
P IE R C E C O U N T Y , W A S H IN G T O N
K E V I N S T O C K , C o u n t y C le r k
BY ---------------- ______ DEPUTY

County of
In re:
Jolene Charlton
O F F IC E
No. 08-3-00821-4
Petitioner,
and

Show Cause re
Contempt
(MTSC)
Respondent.
I. Motion
(Name of requesting party) _Christopher Harrison_
directing (name of other party)__Jolene Charlton_
and show cause why an order should not be entered
______ moves the court for an order

to appear personally before the court
Finding Contempt
[]
[X]
Does not apply.

[]
[3
[x]
n
[]
1.2
the order of child support

the order of maintenance
the parenting plan/custody order
the restraining order
other:
Signed by the court on (date)__01-12-2011_________________________________in (county and state) Pierce,

WA .
[x ]
[]
[]
[]
Does not apply.

Establishing a judgment in the amount o f $ _____________ plus $ _____________ interest for delinquent child
support and $__________________ costs for the period from
(date)________________ _______ through (date)____________________________ .
Establishing a judgment in the amount of $ _____________ plus $ _____________ interest for delinquent
medical support and $__________________ costs for the period from
(date)_______________________ through (date)_________________ _______
.
Establishing a judgment in the amount of $ _____________ plus $ _____________ interest for delinquent child
care, educational expenses, transportation expenses, or other special expenses and $_____________ _____costs
for the period from (date)________________ through (date)____________________ .
[]
1.3
Granting Sanctions
[]
[]
[x ]
1.4
Establishing a judgment in the amount of $ __________ plus $ _____________interest for delinquent

maintenance and $ ___ ____________costs for the period from
(date) ________________________ through (date)___________________________
Does not apply.

Granting sanctions for contempt, including a forfeiture for each day the contempt of court continues, and
establishing conditions by which the contempt may be purged and granting any other relief, including reasonable
attorney fees and costs and make up residential time, as may be appropriate under Chapter 7.21 RCW, Chapter
26.09 RCW, Chapter 26.10 RCW, Chapter 26.26 RCW, and RCW 26.18.040.
Imprisonment is sought as a sanction.
Other
II.
Declaration
Jolene Charlton_________________ ____________should be held in contempt for the following reasons:
[X ]
Failure to comply with die parenting plan as follows:
Did not show up with child at the pre-arrangged meeting place at the pre-arranged time for fathers bi-weekly visit on 1-21-2011.
Changing the rotation of fathers weekend visits as signed by Judge Kathryn J. Nelson on 1-25-J0
[]
Other:
I declare under penalty o f perjury under the laws o f the state of Washington that the foregoing is true and correct.
Signed at (city) Auburn^
. -J t
Signature of Requesting
(state)
WA_________ on (date)___ 1-31-11
Chris Harrison__________________________
Print or Type Name
4-S-SX2
FILED
08-3-00821-4
35811423
ORTSC
a.m.
FEB 0 1 2011
p.m.
02-01-11
fm W ASHINGTON
P IER C E CO U NTY,
Superior uuui i 01 .............
)CK County Clerk

KEVIN STOCK,
<-------------oEPurr
by._______
County of
In re:
No. 08-3-00821-4
Jolene Charlton
Petitioner,

Contempt
(ORTSC)
Respondent.
and
It is Ordered:
(Name o f nonrequesting party) Jolene Harrison / Charlton
shall appear in person before this court at the place and time below and
show cause why the relief requested in the motion ^hould not be granted.
J n l f f ____
pierce county superior court
Date:
Place:
i MIV (ACOfflA
i r i w w m n AVE
n v ^ SOUTH
w w w m
930
T im e:_
Room/Department:
/'!</)
//
If you fail to appear in persorr^^gJg(jEjn<jf^t^jjgroceedings the court may grant all of the relief requested and/or issue a bench
warrant for your arrest without further notice to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court to appoint an attorney to
represent you.
Other:
Dated:
l l
1 1 / ..
Presented
Signattue^f Requesting Pqrty or Lawyer/WSBA No.
Christopher Harrison__________________________
Print or Type Name
^Jpdfj&Commissioner
11763
Ill
0B-3-00821-4
35847733
AFSR
2 /3 /2 8 1 1
38887
m
02-07-11
*J*.
to o
FF,c e
Kc<
'^ pUry
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON, IN AND FOR THE COUNTY OF
PIERCE
Cause No. 08-3-00821-4
IN RE:
JOLENE CHARLTON
AKA JOLENE HARRISON
Plaintiff/Petitioner
and
Defen dant/Respondent
Declaration of Service of:

DECLARATION O F CHRISTOPHER HARRISON
DECLARATION OF CHARLOTTE PERGRIM
MOTION/DECLARATION FOR AN ORDER TO SHOW
CAUSE RE CONTEM PT
ORDER TO SHOW CAUSE RE: CONTEMPT
Hearing Date: March 8, 2011
The undersigned, hereby declares under penalty of perjury under the laws o f the State of Washington, that the
following is true and correct: I am now, and at all times herein mentioned, a citizen of the United States and a
resident of the State of Washington, over the age of eighteen years, not a party to or have an interest in the above
entitled action and competent to be a witness.
Personal Service
On the date o f FEBRUARY 2, 2011 at 7:10PM, at the address of 12107 209th Ave. C t E City of BONNEY
LAKE. WASHINGTON 98391 affiant duly served the above described documents upon Jolene M arie Harrison
by then and there personally delivering ONE true and correct copy thereof and leaving same with JOLENE
MARIE HARRISON.
Date: February 3, 2011
Service:
Travel:
Bad Address:
Proof:
Tacoma, Washington
Other:
TOTAL $
Trips by
Rock Solid Legal Support
(253)682-1230
Miles
E-FILED
February 10 2011 3:31 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
IN THE SU PERIOR COURT OF THE STATE OF WASHINGTON


Petitioner(s),
vs.
NO. 08-3-00821-4
NOTICE OF APPEARANCE

Respondent(s)
TO: Clerk of the Court
AND TO: CHRISTOPHER LEE JR HARRISON, CHRISTOPHER LEE HARRISON
PLEASE TAKE NOTICE that Daniel N Cook, appears herein on behalf of the
Petitioner/Plaintiff(s) JOLENE MARIE HARRISON and requests that all further pleadings and
paper, except original process, be served upon said attorney at the address listed below.
DATED- February 10, 2011
ntaprsup-0001.pdf
/s/ Daniel N Cook

Daniel N Cook, #34866
Attorney for Petitioner/Plaintiff(s)
Faubion, Johnson, Reeder & Fraley PS

5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
(253) 581-0660
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
February 17 201
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
JO LE N E M A R IE H A R R IS O N
9
P etitioner(s),
10
Cause No. 08-3-00821-4

O rder Continuing
Adequate Cause Hearing
vs.
11
C H R IS T O P H E R L E E H A R R IS O N
12
Respondent(s)
C lerks Filing code: ORACONT
13
14
15
THIS MATTER having come on regularly for hearing to determine if there is adequate cause to
16
proceed to trial with regard to a Petition which has been filed,
17
Now, therefore, it is hereby
18
ORDERED the Show Cause hearing determining Adequate Cause is continued.
19
20
21
22
Dated this 17 day o f February, 2011
23
24
_ S /W E N D Y E L L E N Z IC H T
25
W E N D Y E L L E N Z IC H T
Judge/Commissioner
08-3-00821-4
35908751
ORCNT
W COUN77 fi led
02-17-11
CLERK'S Office
6
2cUTY
7
8

COUNTY OF PIERCE
9
10
In re
No. 08-3-00821-4
11

N/K/A JOLENE MARIE CHARLTON,
Petitioner,
MOTION AND ORDER TO

CONTINUE HEARINGS
12
and
13
Respondent.
14
15
MOTION
C O M E S N O W , JO LEN E M ARIE C H AR LTO N, Petitioner, and her attorney of
record, Daniel N Cook, and, based on his recent appearance as attorney for Petitioner,
18
moves the court for an Order continuing the show cause and temporary orders hearings
19
scheduled in this m atter for February 17, 2011
20
21
DATED this
j 7 $ day of February 2011
22
FAUBIO N, R E E D E R , FRALEY
& CO O K, P S
23
Daniel N Cook, W S B A 34866
O f Attorneys for Petitioner
24
25
Order to Continue Hearings - Page 1 o f 2
Charlton v Harrison
C \Documents and Settmgs\dcook\Local Settings\Temporary internet

Files\Content Outlook\13RLZYMV\Order to Continue Hearings docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
'/V
c 0Utrry ^Lh
clrrk 'S
4 m F g
p}SRCFnr, 1 7 20]]
FFilU P
ORDER
4
5
IT IS HEREBY ORDERED ADJUDGED AND DECREED
That the hearings for show cause and temporary orders currently set for
February 17, 2011, shall be and is hereby continued to
S f /A t- c
f
9
10
11
12
13
14
o /r P M
/M u
7 3 ^
- A
/ / .
W
e s S /C O
F /Z C S S
c ^ ^ .
T he Clerk for the Judicial Officer signing this order shall m ake any requisite
entries and/or issue any required electronic notices or orders in the electronic docketing
and calendaring system (i e , LINX) maintained by the court to effectuate this order
7 h
P A /v n e s
s ^ t t
r t f T Z f n t P PQ
Done in open Court this / f o dav of February 2011
15
16
17
18
19
20
Presented by
FAUBION, R E E D E R , FRALEY,
& COOK, P.S.
21
22
23
By: DA NIEL N. C O O K , W SB A #34866

Of Attorneys for Petitioner
24
25
Order to Continue Hearings - Page 2 of 2
Charlton v Harrison
C \Documents and Settings\dcook\Locai Settings\Temporary Internet
F//es\con(enfOutlook\13RLZYMV\Orderto Continue Hearings docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
______
____ P .n
For Petitioner
For Respondent
C . O i i 'm J L j x m
u jjd t ,
C r M ^ t iA /u
i u
jj
{ a J i k u . n J J I n u r td l
0
February 17, 2011 9:30 AM
I o ja u L
in
TJ / / 1 q
3 > jq
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iw
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n -f,
Motion - Temporary Order

WENDY ELLEN ZICHT
l O ' 0 5 f l . f f V
Clerk
Courtroom number 2-A
Calendar C1- SHOW CAUSE/FAMILY LAW
Run date/time 02/17/11 9 21
Ixcrtrpt pbl djoumal_entry_showcause_report
iw
1
08-3-00021-4
35971208
MTSC
03-02-11
2
3
4
5
IN C O U N T Y C L p !K S OFFICE
AM
M AR 0 1
2011
pw
7
.DEPUTY
8
9

COUNTY OF PIERCE
10
11
In re:
12
No. 08-3-00821-4

13
Petitioner,
and
14
Motion/Declaration for an
Contempt
(MTSC)

15
Respondent.
16
17
I. Motion
19
Comes now, JO LEN E CHARLTON, by and through her attorney of record DANIEL N.
COOK, of FAUBION, R E ED ER , FRALEY & COOK, PS, and moves the court for an order
directing C H R IS TO P H E R H A R R ISO N to appear personally before the court and show cause
why an order should not be entered:
20
1.1
18
21
Finding contempt for failure to comply with the Order of Child Support signed by the
court on October 17, 2008, in Pierce County, W A.
22
23
24
25
Finding Contempt
1.2
Establishing a judgment in the amount of $8,232.52 plus $1,234.48 interest for
delinquent child support and $75 (est.) costs for the period from October 2008 through
March 2011.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 1 of 2

Charlton v Harrison
S:\CASES1\Chariton, Jo!ene\Word\Pleadings\Motion for Contemptdocx
FAUBION, REEDER,
FRALEY & COOK, P.S.
D
I C
LJ L \ J
j K |5SfcoJ-100 Street SW, Ste 25
J | \J r\ Jake wood WA 98499

253-581-0660
1.3
Granting Sanctions
2
Granting sanctions for contempt, including a forfeiture for each day the contempt of
court continues, and establishing conditions by which the contempt may be purged and
granting any other relief, including reasonable attorney fees and costs and make up
residential time, as may be appropriate under Chapter 7.21 RC W , Chapter 26.09 R C W
Chapter 26.10 RC W , Chapter 26.26 RCW , and R C W 26.18.040.
3
4
5
6
7
8
1.4
Other
Awarding attorney's fees and costs in the amount of not less than $1,000.
FAUBION, R E ED ER , FRALEY & COOK, PS
10
11
Attorney for Jolene Charlton
12
II. Declaration
13
14
C H R IS TO P H E R H A R R IS O N should be held in contempt for the following reasons:
15
Failure to comply with the provision of the child support order which directed payment of:
16
17
18
current child support in the amount of $283.88 per month.

This order was violated in the following manner:
20
Christopher Harrison has not paid a single penny toward child support since the Order
was entered in October 2008. Attached hereto is a true and correct copy of a Debt
Calculation showing each and every payment that is due and owing.
The Debt
Calculation also shows interest on the unpaid support at 12% per annum.
21
I DECLA RE U N D E R PE N A LTY OF PE R JU R Y U N D E R TH E LAWS O F TH E STATE
19
22
23
O F W A S H IN G TO N T H A T T H E F O R E G O IN G IS TR U E A N D C O R R E C T.
Signed at
/,
______________ , W A on
., 2011
24
P h n dpH j
25
ENE CHARLTO N
Mot/Dec Ord Show Cause re Contempt \^ /sC ) - Page 2 of 2

WPF DRPSCU 05,0100 Mandatory (10/2009) - RCW26,09.160
Charlton v Harrison
S:\CASES1\Char1ton, Jolene\Word\Pleadings\Motion for Contemptdocx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
JO LEN E CHARLTON ARREARS C ALC ULATIO N

JOLENE CHARLTON
SUMMARY CALCULATION DATE
March 16, 2011
INTEREST
Simple
APPLY PAYMENTS TO
Principal then Interest
OBLIGATIONS
29
PAYMENTS
P A Y M E N T S A P P L I E D T O D E B T S P R I O R T O P A Y M E N T IN A S C E N D I N G D A T E O R D E R
PRINCIPAL
PRINCIPAL PAID
$6,232.52
$0.00
$8,232.52
PRINCIPAL OWING
INTEREST ACCRUED
INTEREST PAID
$1,234.48
$0.00
INTEREST OWING
$1,234.48
TOTAL PRINCIPAL AND INTEREST OWING
$9,467.00
PER DIEM INTEREST
$2.71
2,70658191780821917811
February 28, 2011
5:31:04 PM
Page
JOLENE CHARLTON ARREARS C ALC ULATIO N

JOLENE CHARLTON
j Debt Detail i. O C T 15,2008
".V
$283.88
C h ild S u p p o r t
X"
Inte re st 12.00%
Interest a c c ru e d
M A R 16,2011 interest calculation date

2.
N O V 15,2008
$283.88
$82.32

D E C 15,2008
$283.88
C h ild S u p p o rt

J A N 15,2009
$283.88
$79.42

5.
$283.88

M A R 15,2009
$283.88
$76.62

7.
A P R 15,2009
$283.88

8.
M A Y 15,2009
$283.88
$73.73
M A R 16,2011interest calculation date

9.
J U N 15,2009
$283.88

10.
J U L 15,2009
$283.88
Child Support
11.
A U G 15,2009
$283.88
12.
S E P 15,2009
$283.88

13.
O C T 1 5,2009
$283.86
M A R 16,2011interest calculation date

14.
N O V 15,2009
$283,88
U n p a id
$346.41
U n p a id
$343.52
U n p a id
$340.72
U n p a id
$337.82
U n p a id
$334.93
U n p a id
$332.13
U n p a id
$329.24
Interest d a y s
$62.53
670
Interest d a y s
$59.64
639
Interest 12.00%
Inte re st d a y s
$56.84
609
Interest 12.00%
Interest d a y s
$53.94
578
Interest 12.00%
Interest d a y s
$51.05
547
Interest 12.00%
Interest d a y s
$48.25
517
Inte re st 12.00%
$45.36
$349.21
700
Interest 12.00%
U n p a id
Interest d a y s
$65.33
$352.10
731
Interest 12.00%
U n p a id
In te re st d a y s
$68.22
$354.72
759
Inte re st 12.00%
U n p a id
Inte re st d a y s
$70.84
$357.61
790
Interest 12.00%
U n p a id
Interest d a y s
Interest 12.00%
$360.50
821
Interest 12.00%
U n p a id
Interest d a y s
6.
$363.30
851
Inte re st 12.00%
Inte re st a c c ru e d
F E B 15,2009
U n p a id
Interest d a y s
4.
$366.20
882
Interest 12.00%
3.
U n p a id
Interest d a y s
Interest d a y s
486
February 28, 2011
5:31:04 PM
Page
JO L E N E C H A R LT O N A R R E A R S C A L C U L A T IO N
JO LE N E CH ARLTO N
> Debt Detail

15.
D E C 15,2009
$283.88
Interest 12.00%
In te re st accrued

16.
J A N 15,2010
$283.88
$42.56

F E B 15,2010
$283.88

M A R 15,2010
$283.88
$39.67
M A R 16,20111nterest calculation date

A P R 15,2010
$283.88

20.
M A Y 15,2010
$283.88
$36.77

21.
J U N 15,2010
$283.88

22.
J U L 15,2010
$283.88

23.
A U G 15,2010
$283.88

24.
S E P 15,2010
$283.88
M A R 16,2011 Interest calculation date

25.
O C T 15,2010
$283.88

26.
N O V 15,2010
$283.88

27.
D E C 15,2010
$283.88

28.
J A N 15,2011
$283.88

29.
F E B 15,2011
$283.88
$306.65
U n p a id
$303.76
U n p a id
$300.87
U n p a id
$298.07
U n p a id
$295.17
U n p a id
$292.37
U n p a id
$289.48
U n p a id
$286.59
244
Inte re st d a y s
$19.88
213
Interest 12.00%
Inte re st d a y s
$16.99
182
Interest 12.00%
Inte re st d a y s
$14.19
152
Interest 12.00%
Interest d a y s
$11.29
121
Interest 12.00%
Inte re st d a y s
$8.49
91
Interest 12.00%
Interest d a y s
$5.60
60
Interest 12.00%
$2.71
U n p a id
Interest d a y s
$22.77
$309.45
274
Interest 12.00%
U n p a id
Inte re st d a y s
$2 5.57
$312.35
305
Inte re st 12.00%
U n p a id
Interest d a y s
$28.47
$315.15
335
Interest 12.00%
U n p a id
In te re st d a y s
$31.27
$318.04
366
Interest 12.00%
U n p a id
Inte re st d a y s
$34.16
$320.65
394
Inte re st 12.00%
U n p a id
Inte re st d a y s
Interest 12.00%
$323.55
425
Interest 12,00%
19.
U n p a id
Interest d a y s
18.
$326.44
456
Inte re st 12.00%
17.
U n p a id
Interest days
Inte re st d a y s
29
February 28, 2011
5:31:04 PM
Page
3 S*S
3^3
B .31 i
JOLENE CHARLTON ARREARS C ALC ULATIO N

JO'LENE CHARLTON
t o t a Ls
:
v fPRINCIPAL
PAID
''
$8,232.52
$0.00
BALANCE
$8,232.52
TOTAL OWING
$9,467.00
' v V t" ' ."

INTEREST ACCRUED
$1,234.48
v J'
\ "T
PAID
/U
$0.00
BALANCE
PER DIEM INTEREST
February 28, 2011
$1,234.48
$2.71
2.70658191780821917811 |
5:31:04 PM
Page
2
3
4
5
6
7
8
9
COUNTY OF PIERCE
10
11
12
13
In re:
No. 08-3-00821-4

ORDER TO SHOW CAUSE RE:

CONTEMPT (ORTSC)
Petitioner,
and
14
15
16
17
18
19
Respondent.
IT IS O RDERED:
That C H R IS T O P H E R LEE HA RR ISO N shall appear in person before this court at the
place and time below and show cause why the relief requested in the Motion/Declaration for
an Order to Show Cause re: Contempt should not be granted.
20
21
22
23
24
25
Date:
Time:
Place:
^
9:30 a.m.
A <rPierce County Superior Court, ^ 3 0
n^c
Room/Department: 117, 407 or 2-A as assigned
7~a co/nfl
ojA^W /oz.
If vou disagree with any part of the motion, vou must respond to the motion in
writing before the hearing and bv the deadline for vour county. At the hearing, the
court will consider WRITTEN sworn affidavits or declarations. Oral testimony may
NOT be allowed.
I
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160
Charlton v Harrison
S:\CASES1\Chariton, Jolene\Word\Pleadings\Order to ShowCaus
ORIGINAL
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
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f i " t;
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To respond you must: (1) file your documents with the court; (2) provide a copy
of those documents to the judge or commissioner's staff; (3) serve the other partys
attorney with copies of your documents (or have the other party served if that party
does not have an attorney); and (4) complete your filing and service of documents
within the time period required by the local court rules in effect in your county. If you
need more information, you are advised to consult an attorney or a courthouse
facilitator.
IF YOU FAIL TO APPEAR IN PERSON.
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THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST

AND/OR GRANT THE RELIEF REQUESTED IN THE MOTION.
D O N E IN O P E N C O U R T this
! _ day March, 2011.
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P R E S E N TE D BY:
FAUBIO N, REED ER, F R A LE Y & C O O K P.S.
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DA NIEL N. CO O K, W S B A # 34866
Of Attorneys for Jolene Charlton

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BV,
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-DEPUTY
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Charlton v Harrison
S:\CASES1\Char1ton, Jolene\Word\P!eadings\Order to Show Cause.dOCX
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
E-FILED
March 02 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)
TO T H E C L E R K O F T H E S U P E R IO R C O U R T A N D TO:
Name: CHRISTOPHER LEE HARRISON

Address: 6721 NATHAN AVE SE AUBURN, WA 98092
Phone:
Respondent
P ie r c e C o u n t y S u p e r io r C o u r t , C o u n t y - C it y B u ild in g - 9 3 0 T a c o m a A v e S - T a c o m a , W A 9 8 4 0 2
S h o w C ause
N a t u r e o f H e a r in g :
Contempt
CALENDAR DATE: Tuesday, March 22, 2011 9:30 AM

W O R K I N G C O P I E S S H A L L B E S U B M I T T E D T O C O M M I S S I O N E R S S E R V I C E S R O O M 14 0,
B E F O R E 1 2 :0 0 N O O N T W O C O U R T D A Y S P R I O R T O H E A R I N G
DATED:
March 1,2011.
S ig n e d :
/s/ Daniel N Cook
NAM E:
Daniel N Cook
Phone:
(253) 581-0660
W SBA# :
34866
ADDRESS:
5920 100th St SW Ste 25

F o r:
1 of
E-FILED
March 11 2011 3:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

IN AND FOR THE COUNTY OF PIERCE
No. 07-3-01638-3
JOLENE CHARLTON; AKA JOLENE
HARRISON
Petitioner,
and
___________________________ Respondent
Response to Petition for

Modification/Adjustment of Custody
Decree/Parenting Plan/Residentiai
Schedule (RSP)
[ ] Order fo r protection DV (PTORPRT)
[ J Order fo r protection UH (PTORAH)
To: Court and all Parties

I. Response
1.1

The allegations of the petition in this matter are
{check only one for each paragraph):
a d m itted or d en ied as follows

1.1
1.2
1.3
2.1
2.2
EX]
[X]
[X]
[]
[X]
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[]
[X]
[]
Denied
Denied
Denied
Denied
Denied
Resp to Pet for Mod/Adj (RSP) - Page 1 o f 5

WPF DRPSCU 07.0200 Mandatory (6/2008) - R C W 26.09.260; .270;
26.10.200
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Lacks
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Lacks
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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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2.3
2.4
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2 .1 0
2.11
2 .11.1
2 .11.2
2.11.3
2.12
2.13
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[X]
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[X]
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[X]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
n
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n
[X]
[X]
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[X]
[X]
[X]
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Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
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Lacks
Lacks
Lacks
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Lacks
Lacks
Lacks
Lacks
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Lacks
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Each allegation of the petition that is denied, is denied for the following reasons:
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2.1
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Petitioner/mother (non-moving party) does not agree with approving the

proposed parenting plan filed with this petition.
This Petition should be
dismissed and if it is not dismissed, then Petitioner/mother will file a different
proposed parenting plan. The case should be dismissed because before the
Father was permitted to seek relief from court to modify the parenting plan
(and get his visitation unsupervised) the court specifically directed him to
engage in mediation first.
The Fathers chosen mediation provider has
declined to mediate because of the Fathers domestic violence history and
existence of a criminal no contact order. The mother (through counsel) also
contacted P C C D R to determine if mediation was a possibility with this agency;
however, P C C D R regulations also make mediation with them unlikely or more
complicated in light of the criminal no contact order. Mediation with a private
attorney will probably be necessary. The mother is open to mediation with a
private attorney but due to time constraints in the court action had to file this
response before private mediation could be arranged.
The case should also be dismissed because, on information and belief the
Petitioner/mother alleges that the father has not completed his Domestic
Violence Perpetrators Program as required in the criminal case.
The case should also be dismissed because, on information and belief the
Petitioner/mother alleges that the father has never completed the
mandatory impact on children seminar required by local court rules in
Pierce County.
Resp to Pet for Mod/Adj (RSP) - Page 2 of 5
WPF DRPSCU 07.0200 Mandatory (6/2008) - RCW 26.09.260; .270;
26.10.200
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone:(253)581-0660
2.9
The Father has a history of domestic violence and has not yet successfully
completed his Domestic Violence Program nor engaged in mediation as
required before modification of the parenting plan could be considered.
Som e examples of the domestic violence history include: He threw one
daughter so hard against the couch that her knee cap was dislocated to the
side of her leg. Another daughter was hurt on the wooden night stand when
she was yanked out of bed. She reported this to her counselor but when
CPS cam e to investigate she denied it because she was too afraid of her
Dad. Mr. Harrison ran up behind Jolene Harrison and shoved her so hard
in the back that he sent her flying through the air into the back side of the
box springs on the landing below. She was scraped and bruised on her
arms and legs; and momentarily could not stand because she was stunned
and dizzy. Then he violently tried to prevent her from leaving. Forcing the
window down and reaching into the car, Mr. Harrison yanked the car keys
from Mrs. Harrisons hand, cutting her fingers. In great fear she dialed 911
only to have Mr. Harrison grab the phone from her hand and smash it on
the ground. Jolenes thirteen year old son was trying to help his mother and
the other children get away, and all three of Mr. Harrisons children were
hysterical and crying in the car. Copies of pictures of injuries to the mother
are attached hereto as an exhibit. Mr. Harrison was charged with criminal
domesic violence, pled guilty, and on information and belief has not yet
completed his required Domestic Violence Perpetrators Treatment
Program.
Mr. Harrison has not included all of the other factors for (R C W 26.09.191)
that are included in the current parenting plan. Neglect or substantial
nonperformance of parenting functions. A long-term impairment resulting
from drug, alcohol, or other substance abuse that interferes with the
performance of parenting functions.
2.10
There is no change in the circumstances of the family moving to

Idaho. The family is still moving but had to make some adjustments in the
timing of the move, due to the length of time it took to fight for approval to
move the children. The family budget could not sustain two households for
that length of time, and since the children could not move Mr. Charlton had
to move here and commute back and forth. Shortly after the relocation
action finally concluded (granting Petitioner/mother the right to move)

but before the family could actually move, Mr. Charlton became very ill
last summer, requiring multiple trips to the emergency room: two trips
via ambulance. After two surgeries they resolved the kidney stones and
the additional problem going on in the kidney.
Finances had to be
reworked, another house located, as well as, getting the right timing
for the children with their schooling. The company expects Mr. Charlton
to m ake the move as soon as possible. Mr. and Mrs. Charlton expect to be
26.10.200
FAUBION, REEDER,
FRALEY & COOK P.S.

Lakewood, WA 98499
Phone: (253) 581-0660
moved no later than this summer, and will be notifying Mr. Harrison of the
new address as soon as possible. A declaration from Kurt Christianson, Mr.
Charltons employer is filed herewith and supports these facts.
2.13
The long court battle trying to get approval for the move to take place
created a lot of obstacles to overcome and delayed the move. Mr. Charlton
also had a protracted illness but things are back on track for the move to be
completed by this summer. Husband is not employed in Pierce County, is
having to commute, and does have to move to Idaho. (See Section 2.10
above)
2.14
There is a No Contact Order currently in place. #7Y C 0 10751 ,

in Pierce
County, Expires in A u gust 2011. The Order is part of Mr. Harrisons
sentence and probation when he was found guilty of 4th degree assault,
and interfering with a 911 call.
The original two year No Contact Order ended on July 15, 2010. An
additional year w as added sometime during 2 01 0 but Mrs. Charlton was
not informed about the extension and does not know why it was extended
to August of 2011.
1.2

Notice of all further proceedings in this matter should be sent to the address below
1.3
Other
Does not apply.
II. Requests
2.1

The nonrequesting party requests that the petition be dismissed.
2.2
Request for Modification or Adjustment

Should the court not dismiss this action then, the nonrequesting party requests that
the court enter an order modifying or adjusting the custody decree/parenting
plan/residential schedule in this matter and approving the proposed parenting
plan/residential schedule, which is filed by the Petitioner/mother with this response
at a later date.

26.10.200
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
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2.3
Protection Order
[X]
There is a protection order between the parties fifed in case number

7Y C010751___________ , court Pierce_____________ which expires on (date)
August 2011
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Submitted this day
~?Df' of March 2011.
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FAUBI
LEY & CO O K, P.S.
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Daniel N. Cook, W S B A 34866
O f Attorneys for Respondent
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I, TH E U N D E R S IG N E D , DECLARE U N D E R PE N A LTY O F PE R JU R Y UN D ER
T H E LAWS OF TH E S T A TE O F W A S H IN G TO N TH A T TH E A TTA C H ED PAGES ARE
TR U E AN D C O R R EC T.
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Signed at (city)
LfX fa V*QQ&
_, (state)
Ia
on (date)
P lA ttjn ^ f ; 9o!l
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26.10.200
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone:(253)581-0660
E-FILED
March 11 2011 3:54 PM
^
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
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COUNTY OF PIERCE
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In re:
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No. 08-3-00821-4

Ppfifinnpr
and
DECLARATION OF JOLENE
HARRISON IN RESPONSE TO
MOTION RE CONTEMPT

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Respondent.
I, Jolene Charlton, am the Mother of CJ Harrison.
I am the Petitioner in this case and
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the non-moving party in the motion for contempt.
I make this declaration on the basis of my
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personal knowledge in Response to the Motion for Contempt by Mr. Harrison.
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First: the father has never taken the mandatory impact on children seminar.
Prior to
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enforcing this parenting plan through a motion for contempt, the father should be required to
undergo the mandatory impact on children seminar.
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Second: the January 25, 2010, parenting plan specifically provides: If the Mother
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ascertains Father has left or been dismissed unsuccessfully from treatment or incurs a criminal
DECLARATION IN RESPO NSE TO CONTEMPT - Page 1 of 11
Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Response to Contempt MOtion.docx
FAUBION, REEDER,
FR A LEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
arrest, warrant or charge after the date of this Parenting plan, in personal visits shall be
suspended pending further court action. I am aware that the father was on house arrest
during the Sum m er of 2010.
I am not sure why.
The father should be required to disclose
what the reason for the house arrest was. The father should also be required to provide proof
of continuing treatment because the Parenting Plan very clearly requires him to continue
successfully in treatment.
Third: I am not in contempt because I did not intentionally and willfully and in bad faith
fail to comply with the Parenting Plan/Custody Order. CJ did not have the ordinarily scheduled
visit with Father on 12/10/2010, because the child was on a vacation.
The Father was informed about the plan for this vacation trip in advance.
The
Father made no objection to our scheduling a special vacation that resulted in some
time being missed on his weekend.
I do not recall the exact date and time when the Father was told about the Vacation. I
do recall that the first tim e the trip was communicated to the Father was in a phone call to his
girlfriend about two months before the vacation. There was no objection from the father after
he was advised about the plans at least two months in advance.
I also specifically recall that about two weeks prior to the special vacation CJ mentioned
to his father during a phone call. The trip came up again, during a phone call between CJ and
his father about one w eek prior to the special vacation.
Then on D ecem ber 7, 2010, the Fathers girlfriend/fiancee texted me saying that they
would be picking up CJ that Friday (Decem ber 10).
Her text was sent at 10:52 p.m.
The Fathers girlfriend sent another text on Decem ber 8, 2010, at 8:13 a.m. asking to
pick up CJ on Friday.
DECLARATION IN RESPONSE TO CONTEMPT - Page 2 of 11
Charlton v Harrison
S:\CASES1\Chariton, Joiene\Word\Pleadings\Response to Contempt MOtion.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
On December 8, 2010, at 8:35 a.m. I responded to the Fathers girlfriends text message
with the following: Im sorry but I told Chris a long time ago that we have a vacation planned.
You can pick CJ up on Monday Dec. 20th at 8 pm and keep him until Sunday Dec. 26th Sorry
for any confusion.
Seven (7) minutes later, the Fathers girlfriend sent back a text saying: Isnt that what I
asked?
O ne (1) minute later I responded with a text: W e are gone until the 20th.
Three (3) minutes later, the Fathers girlfriend replied by text: O k... So we pick him up
at 8 pm on the 20th at the Shell. (Emphasis added.)
Attached as Exhibit A are true and
correct copies of my cell phone which show the text messages referenced above.
Chris was aware, prior to our departure that we would be going and he would
miss a weekend but he did not object. The response on Decem ber 8, 2010, to my message
clearly stating that I had previously told Chris was not contradicted or questioned in any
manner. The response clearly indicates they were aware of the trip prior to the text exchange
on Decem ber 8 because there was no objections or questions and had agreed to it.
All of these text messages were sent prior to our departure for Hawaii. W e did not
leave for the vacation to Hawaii until the next day, Decem ber 9, 2010. At no time prior to our
departure did Chris object to CJ going on this vacation with us to Hawaii.
Had Chris
objected to the vacation w e might have been able to m ake other arrangements. For example,
we might have left CJ with my mother and he could have had his visitation with his father and
stayed the remainder of the time with my mother while my husband and l were on the cruise.
Obviously, that would not have been our first choice and seem s a little unreasonable, but the
fathers failure to object did not even put us in a position where w e would have to make that
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
decision.
The father was notified well in advance and again reminded of the special
vacation the week of and never objected until after the fact.
contempt.
That is not a basis for
Clearly I was not intentionally or willfully violation the parenting plan in bad faith.
Had the Father objected at any time prior to our departure I would have assessed my options
and done what was necessary. Depending upon how far in advance he objected, I may have
scheduled mediation, I may have sought a court order, I may have left CJ with my mom even
though he would have missed the vacation.
However, because the Father never objected
when notified in advance and then the week of the trip even went so far as to agree (by saying
Ok in response to my text), I in good faith believed that it was okay to skip the weekend.
Significantly, the parenting plan specifically states that some weekends would be
missed and that missed weekends would not be made up. This particular provision was
probably contemplated more in light of times when the father might have to cancel a visit and
he has missed a number of them; however, there is nothing specifically restricting it to the
fathers cancellations and as long as I am not taking advantage of it (which I am not since
almost an entire year went by without problems) I believe it is a mutual provision.
THE FATHER MANIPULATES THE PARENTING PLAN

The Father also used self-help to make up the visitation he missed on the December
10, 2010, weekend.
This is a parenting plan with limiting factors as to the father and with
restrictions on how the fathers residential time is to be spent and w here he is allowed to reside
with the child.
The parenting plan also provides for the father to have three weeks in the
summer but specifically and intentionally limits those weeks to one at a time beginning with the
Friday of a regular visit with the father.
Under Paragraph 3.6 Vacation with Parent the Court
stated: As the child grows the time during the summer may increase into blocks of time for
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
both parents especially to accommodate special vacations. Clearly, it was the intent of the
court in entering this parenting plan that, at least at first, the child not spend more than one
week away from his mother.
The parenting plan is ambiguous as to how W inter Vacation versus Christmas Break is
defined.
On the one hand, Paragraph 3.4 W inter Vacation is designated entirely with the
mother except for time with father as defined in Paragraph 3.7.
In Paragraph 3.7 Christmas
Break (not W inter Vacation) is designated as Even with Father and Odd with Mother.
But
given the restriction to only having one week periods of time in the summer, it would seem that
the distinction between W inter Vacation and Christmas Break was because there would only
be one week for Christmas Break and not the entire two w eek W inter Vacation defined by the
school calendar.
The Parenting Plan requires the exchange of a calendar at the beginning of each year.
I provided a calendar to the father in February 2010.
A true and correct copy of the calendar I
prepared is attached to this declaration as Exhibit B. W e have followed this calendar for the
entire year.
Originally when l wrote up Christmas Break on the calendar I scheduled for CJ to reside
with the father for about one w eek (actually a little over a w eek because the Christmas Break
overlapped the New Years break). W hen I prepared the Calendar (Exhibit B) in February 2010
(shortly after the trial judge issued her ruling) I originally tried to be generous and provide the
Father with more than just one week at Christmas but still only slightly more than a week
because of my concerns about the child being gone for too long.
After the vacation plans came up for the beginning of December, I modified the
Christmas Break schedule at their request. I allowed them to pick up CJ on Decem ber 20,
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
5920-100TH Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
2010, instead of having the pick up for Christmas Break be on Decem ber 24 as originally
scheduled.
In making that change, we also agreed that they would bring him back on
Decem ber 26, 2010.
That would mean CJ was gone for just one week.
Then CJ would be
with me for most of the week after Christmas and would be back with his Father the very next
weekend for New Years.
It was a very reasonable agreement that we made.
The father
specifically referenced this agreed scheduled in his text messages starting on December 7,
2010, and continuing into Decem ber 8, 2010, which are attached as Exhibit A.
The text
messages from the Fathers girlfriend clearly reference pick up on December 20, 2010,
and then return on December 26, 2010.
p.m. on January 1, 2011.
The Father kept CJ all the way through to 8:00
I am not sure why he returned him on January 1, 2011 - that was
originally scheduled as his weekend and it was his holiday which included the entire weekend.
So I am not sure why the Father brought CJ back on January 1, 2011, but since CJ had been
gone for almost two full weeks I was glad that he was back and he was very happy to be back
and disturbed after being with his father for such a long period of time (started bedwetting
again when he had not done that for several years).
The Father also specifically states in one of his declarations re contempt that he
provided me sufficient time to file a motion for contempt on the issue of him keeping CJ longer
than we agreed for the Christmas Break.
playing games with this parenting plan.
I raise that only to say that it is the Father who is

I have tried to be reasonable and then the Father
refuses to honor our agreement.
JANUARY 7, 2011, WAS NOT THE FATHERS WEEKEND AND I AM NOT IN CONTEMPT
The father then goes on to say that I am in contempt for not allowing him to have
visitation on January 7, 2011; however, the weekend of January 7, 2011, was not the fathers
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
S:\CASES1\Charlton, JoIene\Word\Pleadings\Response to Contempt MOtion.docx

Lakewood, WA 98499
253-581-0660
weekend.
The father had just had the child for two weeks (straight, without a break) from
Decem ber 20, 2010, to January 1, 2011. I told the father that he had just had two weekends in
a row during the two weeks he took for Christmas / W inter Break (which I did not agree with
but he did anyway). I told him after he returned CJ on January 1 ,2 0 1 1 , that the next weekend,
the weekend of January 7, 2011, CJ would be with me. That only m ade sense since CJ had
been with the father two full weeks and most of two weekends immediately prior to January 7,
2011 .
In addition, I completed a new calendar for 2011 pursuant to the requirement on page 8
of the parenting plan.
T he parenting plan says: Fathers alternating weekends shall be
designated for the year in advance. There are no make ups as it is anticipated by the Court
that some weekend visits with Father may not occur and Father must wait for his next
weekend. The Court believes that alternating schedule which includes most Monday holidays
would be appropriate for Fathers schedule each year. Pursuant to that direction, l drafted a
calendar and provided it to the father which designated his alternating weekends. A true and
correct copy of the calendar is attached hereto as Exhibit C.
The Exhibit C calendar clearly
specifies that the January 7, 2011, weekend was to be with me and the January 14, 2011,
weekend (which was a long weekend for Martin Luther King, Jr., Day), was to be with the
father. The father simply chose to ignore this calendar. He insisted he was entitled to January
7, 2011, and I told him that was incorrect based upon him taking two full weeks and most of
two consecutive w eekends over the holidays as well as based upon the continuation of the
calendar into 2011.
The fathers voluntary choice to ignore the January 14, 2011,
weekend that was designated as his (and which was a continuation of the calendar from
2010) is not my contem pt I did not willfully and intentionally refuse to comply with the
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
parenting plan. Frankly, it may be that he simply did not want that weekend, or he had plans or
was otherwise unable to visit with the child that weekend as the parenting plan very specifically
provides that the father may miss some weekends and that missed weekends would not be
made up.
PHONE CALLS ARE ONLY TO BE REASONABLE AND I AM NOT IN CONTEPT BUT

THIS ISSUE SHOULD BE CLARIFIED
Regarding phone calls, this is a sore subject. Our child, CJ, is six years old. He just
turned six on February 22, 2011, so during all of the period for which the father is
complaining about phone calls the child has been five years old. The fact is, all five year olds
have attention spans that are quite short. I cannot get our five year old to talk with me on the
phone more than 2-3 minutes.
Another problem is that the father constantly barrages with text messages demanding
that I have his son call him. Sometimes I get texts while l am at work asking to have CJ call.
Sometimes I get texts while CJ is asleep or otherwise unavailable.
Sometimes l get a text
and request that CJ call his dad but CJ just isnt interested in stopping w hatever he was
doing at that moment and making a phone call. W hen I respond by text saying that CJ did
not want to call, they (the father and his girlfriend) respond by demanding that I have CJ call
and tell them personally he does not want to talk.
I finally stopped texting him back
explaining every time that I cannot respond and get CJ to call him (for w hatever reason) and
the father has sent the police on three separate occasions in the last six months to my home
for a welfare check. There w as nothing wrong with the child - I simply cannot respond to
numerous dem ands via text message for phone calls.

Charlton v Harrison
The parenting plan provides for
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
reasonable telephone contact. I believe reasonable telephone contact should be defined

as two calls per week.
The father and I have also differed on the issue of who should place the call. W hen it
is convenient for the father, he hides behind a criminal no contact order that was entered by
Pierce County District Court after he threw me down a flight of stairs and into an over-turned
box spring (so that the metal spring side was up and exposed). I had bruises all over and can
still provide the pictures to the court.
from that criminal action.
In any event, there is still a restraining order in place
The restraining order was extended beyond the date it was
normally set to expire because of Mr. Harrisons actions - not at any request of mine.
nothing to do with the extension.
I had
I never contacted the prosecuting attorney or the court
when the order was set to expire. T he court just did it, probably because Mr. Harrison was
not in compliance with the other conditions of his release.
But in any event, Mr. Harrison sometimes says I will not call you because then I could
get in trouble with the restraining order. So he insists that I have CJ call him. But obviously I
have to be the one initiating the call because CJ was only five (now just turned six) and
cannot do it himself.
But other times, Mr. Harrison calls me or my house to discuss other
issues, and in fact on two other occasions he actually cam e up to the door of my house. So
hides behind this restraining order only when he wants to dem and that 1 do something. This
is another exam ple of his domestic violence behavior.
He wants to be in control of me and
demand what I do and when I do it.

Frankly, if it w as the restraining order that was truly preventing him from initiating a call
to his son, his asking his girlfriend to text m e to is arguably a violation.
Otherwise, why not
just have his girlfriend initiate the call and then if and when CJ answers his girlfriend can
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
S:\CASES1\Chadton, Jolene\Word\Pleadings\Response to Contempt MOtion.docx

Lakewood, WA 98499
253-581-0660
connect the two of them. But he refuses to do that - not because of any restraining order or
other valid reason but only because he wants to demand that I make CJ call w henever he
texts me.
I ask the court to define the reasonable telephone contact provision of the parenting
plan as meaning two calls per w eek at a scheduled time when the father is to initiate the call.
I will have CJ ready to answ er the call and talk to his father at the scheduled times.
designate the days of the w eek and times by text m essage.
I will
I will try to make the
designations long standing, so that they do not change from w eek to week, but there needs
to be some flexibility for schedule changes and extra-curricular activities that change over
time.
Then the father can choose to call at the designated times or not.
But the fact is, I am not in contempt of the parenting plan regarding telephone calls. I
have allowed reasonable telephone contact and that is w hat is provided in the parenting
plan.
In summary:
the D ecem ber 10, weekend visit w as missed because it had been
planned in advance and the father did not object. It was a special family vacation and when
reminded of it the w eek that it occurred he still did not object. T he father had the opportunity
to object prior to me leaving with the child and did not do so. I did not willfully, intentionally or
in bad faith violate the parenting plan.
The January 2011 w eekend visit was the fathers own refusal to exercise a visit on the
w eekend of January 14.
I clearly told him that the w eekend of and January 14 which
included Martin Luther King Jr., holiday, was his w eekend and he refused saying that it was
not his weekend.

Charlton v Harrison
S:\CASES1\CharIton, Jolene\Word\Pleadings\Response to Contempt MOtion.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
The telephone calls only require reasonable telephone contact and the fathers
demands are not reasonable.
I ask the court to clarify this provision so that we can avoid
future contact.
I D E C LA R E U N D E R PE N A LTY O F P E R JU R Y U N D E R T H E LAWS O F TH E STA TE
O F W A S H IN G T O N T H A T T H E F O R E G O IN G IS TR U E A N D C O R R E C T.
Signed at
________________ , W A on
2011.
^ IfY l p ) h r t f ) J t t r y \ __________
XJ0LEN E CH A R LTO N
DECLARATION IN RESPONSE TO CONTEMPT - Page 11 o f 11
Charlton v Harrison
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
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March 11 2011 3:54 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
2
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SUPERIOR COURT OF W ASHINGTON

COUNTY OF PIERCE
11
12
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In re:
No. 08-3-00821-4

N/K/A JO LENE MARIE CHARLTON,
Petitioner,
and
DECLARATIO N COVERSHEET

Respondent.
Name:
"K fjr'T
Aae:
18
19
20
21
22
23
Relationship to Party(ies):
Number of Pages attached:
/ ) u.*(
dcw r- -r
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I, THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS

OF THE STATE O F WASHINGTON THAT THE ATTACHED PAGES ARE TRUE AND
CORRECT.
u _________ , (state) jf\
Signed at (city)
s /?
on (date) 3
~ / if
24
25
Signature
DECLARATION COVERSHEET - Page 1 of 1

Chariton v Harrison
S;iCASS 1[Charlton, JoteneIWaruWlezdings'iDectiration CovsfshesLdoox
FAUBiON, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Mar
01
11
1 2 :02p
Lance
8 8 8 2 2 13G33
To Whom It May Concern;

This letter is to confirm that William (Will) R. C. Charlton has been working with
Renewable Ag Energy, LLC (an Idaho LLC) and Agri-Energy Producers Association for
the past year. It is our intent that Will be relocated to western Idaho in order to fulfill his
responsibilities with our companies as soon as he can. We anticipated that he would
move nearer to western Idaho during the late summer of 2010, but because of health
reasons he was unable to make that happen. Now that his recent health problem is no
longer an issue, we anticipate that he will relocate as soon as it is possible.
Will began working with the Association and Renewable Ag Energy in assisting to
develop a closed loop biomass facility with the agricultural community here. Will is one
of the three main individuals on this project and his time is needed here.
Mr. Charlton currently travels 2-3 times per month to our offices in Ontario, Oregon to
conduct business for 3-5 days at a time.
Again, it is our intention to have Mr. Charlton and his family relocated to the region to
better spend his time on this and other projects in Western Idaho and Eastern Oregon.
Mr. Charlton has since been added as a partner to our firm for his efforts and the skills he
brings to the project and to our company.
Sincerely,
President of Renewable Ag Energy, LLC

156 SE 1st Ave, Suite # 1
Ontario, OR 97914
p . 2

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION RE
SIGNATURE ON EMAILED
DOCUMENT

__________________________ Respondent.
I, Daniel Cook, declare under penalty of perjury that the foregoing faxed document(s)
attached to this Declaration of Kurt Christensen, which consists of 3 pages including this
declaration page (but not including attachments), is a complete and legible image that I have
exam ined personally and that w as received by m e via email and dcook@fjr-law.com
Signed at Lakewood, W A on March 7, 2011.
Daniel Cook, W S B A 34866
DECL re EMAIL SIGNATURE - Page 1 of 1

Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Declaration re Email Signature.docx
FAUBION, REEDER,
FR ALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
March 14 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
S U P E R IO R C O U R T O F W A S H IN G T O N
C O U N T Y O F P IE R C E
In re:
No. 0 8 -3 -0 0 8 2 1 -4
JO L E N E M A R IE H A R R IS O N ,
N /K /A J O L E N E M A R IE C H A R L T O N ,
Petitioner,
and
D E C L A R A T IO N O F M A ILIN G
C H R IS T O P H E R L E E H A R R IS O N ,
.........
......
Respondent.
I, Sally DuCharm e, am over the age of 18, and competent to testify in the above
entitled case.
On March 11, 2011, I placed in the U.S. Mail a copy of the Response to Petition,
Declaration of Jolene Harrison in Response to Motion for Contempt, and Declaration of Kurt
Christiansen in the above-entitled caption.
Said documents w ere addressed to:
SE, A u burn, W A 9 8 0 6 2 .
C h ris to p h e r H arriso n , 6721 N athan A v e n u e
I declare, under the penalty of perjury and the Laws of the State of Washington, that
the foregoing is true and correct.
D A TED
March 11, 2011

------------"'Sally D u ^ ra rm e , Legal Assistant
DECL of Mailing - Page 1 of 1

Charlton v Harrison
S:\CASES1\Chariton, Jolene\Wortf\Pleadings\Declaration of Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
March 14 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
I n re :
NO: 08-3-00821-4
J O L E N E M A R E H A R R IS O N , N / K / A
DECLARATION OF SERVICE
J O L E N E M A R IE C H A R L T O N ,
P e t itio n e r ,
and
C H R IS T O P H E R L E E H A R R IS O N ,
R e sp o n d e n t.
T h e u n d e r s ig n e d s ta te s th a t I a m a c it iz e n o f t h e U n it e d S t a t e s a n d o f t h e S t a t e o f W a s h in g t o n , o v e r th e
a g e o f e ig h t e e n y e a r s , n o t a p a r t y t o th e a b o v e e n t it le d a c t io n , c o m p e t e n t t o b e a w it n e s s t h e r e in , a n d
w a s a t a ll t im e s h e r e in m e n t io n . I e ffe c te d s e r v ic e a s in d ic a t e d b e lo w :
[a ] N u m b e r o f c o p ie s s e rv e d : O n e ( l )
[b ]
T it le o f P a p e r s s e rv e d :
O r d e r t o S h o w C a u s e re : C o n t e m p t a n d M o t io n / D e c la r a t io n f o r a n O r d e r
t o S h o w C a u s e re : C o n t e m p t
[c ]
D a t e a n d T im e o f S e r v ic e :
[d ]
P e r s o n ( s ) t o b e s e rv e d :
[e ]
P la c e o f S e r v ic e :
M a r c h 2 , 2 0 1 1 a t 7 :1 5 P .M ,
6 7 2 1 N a th a n A v e . S E
A u b u rn , W A
98092
S e r v ic e w a s m a d e p u r s u a n t t o C i v i l R u le 4 ( d )
DECLARATION OFSERVICE
Page I
[ X ] B y d e liv e r y t o t h e p e r s o n ( s ) n a m e d in p a r a g r a p h ( d )
[ ] B y d e h v e iy t o
, a p e r s o n o f s u it a b le a g e a n d d is c r e t io n r e s id in g a t th e
d e fe n d a n t s u s u a l a b o d e .
S ig n e d a t L A K E W O O D , W A S H I N G T O N o n M a r c h 3 , 2 0 1 1.
FEES: Service $10.00 Rush: $25.00 Miles: $52.00 Misc: $39.00 TOTAL: $126.00
DECLARATION OFSERVICE
Page 2
1 01:34p
Bob Pagay
253-536-1784
.
l, )
'..
P-2
E-FILED
March 17 2011 3:58 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

County of Pierce
I n re :
J o le n e M a r i e C h a r lt o n
No. 08-3-00821-4
and
Declaration of
Jana L Fuale
[Name}
(Optional Use)
(DCLR)
T h i s d e c la r a t io n i s m a d e b y :
Nam e:
J a n a L . F u g l e ____________________________________________ _________________ _____________________________
A ge:
4 1 __________________________________________ ________________________________ ______________________________
R e la t io n s h ip t o t h e p a r t ie s i n t h is a c t io n :
S is t e r o f J o le n e C h a r it o n _______________________________________________
I Declare:
1 h a v e b e e n C P s b a b y s it t e r m a n y t im e s t h r o u g h o u t h i s lif e . F r o m S e p t e m b e r 2 0 0 9 M a y 2 0 1 0 I w a s
t a k in g c a re o f C J s o h e c o u ld a tt e n d p r e - s c h o o l a n d w o u ld k e e p h im
u n t il h i s m o t h e r g o t o f f w o r k o r
s o m e t im e s I w o u ld k e e p h im o v e r n ig h t a s h e lo v e s t o s le e p o v e r h e r e w it h c o u s in s . I f J o le n e w a s h e ld u p
a t w o r k t h e n I w o u ld t a k e C J t o h e r w o r k t o h a v e t im e w it h h i s m o t h e r b e f o r e t a k in g h im t o m e e t C h r i s
a n d C h a r o n h is w e e k e n d s w it h h is d a d .
D u r i n g t h a t t im e I a g r e e d t o b e a c o n t a c t p o in t f o r C h r i s t o
c o n f ir m h i s w e e k e n d s b v t h e W e d n e s d a y o f t h e w e e k o f v is it a t io n , a s o u t lin e d b y t h e p a r e n t in g p la n , and.
I b e c a m e t h e p la c e t h a t C h r i s o r C h a r w o u ld e it h e r c a ll C J o r w o u ld r e q u e s t b v t e x t t h a t C J c a ll h i s d a d .
B e c a u s e t h e r e h a d b e e n m a n y in a p p r o p r ia t e t h i n g s s a id t o C J o n p h o n e c a l l s f r o m h i s d a d , a t h is
m o m s h o u s e . 1 w o u ld o f t e n lis t e n c lo s e b v t o t h e p h o n e c a l l s a t m v h o u s e . D u r i n g o n e o f t h e c a lls J o le n e

WPF DRPSCU 01.0100 (6/2006)
Mar 17 11 01:34p
Bob Pagay
253-536-1784
h a d a r r iv e d a t m v h o u s e ,
P-3
f w a s lis t e n in g b v t h e p h o n e a n d C J h a d b e e n t r y in g t o g e t o f f t h e p h o n e . C h r i s
h a d p e r s is t e d w it h
q u e s t io n s a n d I L o v e Y o i T s a n d I m is s
d a y s , a l l o f w h ic h
h a d b e e n t o ld n u m e r o u s t im e s a lr e a d y . C J s ta te d t h a t h is m o m w a s t h e r e a n d C h r i s
a c k n o w le d g e d
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C J I d o a o t w a n t t o t a l k t o v o u r m o m . I w o u ld r a t h e r p o k e b o t h o f m v e v e s o u t w i t h p e n c ils t h a n
t a l k t o y o u r m o m , I d o n o t w a n t t o t a l k t o y o u r m o m ! T h a n k f u lly C J h a d p u t t h e p h o n e d o w n a n d
w a s g o n e t o s e e h i s m o m . I t o ld J o le n e t h is a n d s h e h a d C J g e t b a c k o n th e p h o n e t o h is d a d a t w h ic h
p o in t C h r i s s a id C J D o N o t E v e r g o g e t y o u r m o m , 1 d o n 't E v e r w a n t t o t a lk t o h e r " . T h e n C J s a id
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W h e n I w o u ld t a k e C J t o m e e t h i s d a d I o b s e r v e d t h a t C h r i s w o u ld b e c o r d ia l, e v e n f r ie n d ly a n d
j o k i n g a r o u n d * a s lo n g a s C h a r w a s n o t t h e o n e b r i n g i n g h im t o p i c k u p C J . O n t h e o c c a s io n s t h a t C h a r
w a s t h e d r iv e r . C h r i s w a s s h o r t a n d c u r t d u r in g t h e e x c h a n g e a n d e v e n a c te d a n g r v a t t im e s . F u r t h e r m o r e .
i f I a c c o m p a n ie d J o le n e o n t h e e x c h a n g e .
J n o t ic e d
C h r i s s b e h a v io r t o b e e v e n w o r s e t o t h e p o in t t h a t
J o le n e c o u l d n 't e v e n g i v e h im a n y in s t r u c t io n s t h a t m ig h t b e p e r t in e n t t o C P s c a re . O n e t im e h e t h r e w h is
h a n d s u p in t h e a ir b a c k in g a w a y f r o m J o le n e w h ile v e ilin g , D o n 't t a lk t o m e F m
n o t g o i n g b a c k t o ia ll-
d o n t t a lk t o m e I m n o t g o in g h a c k t o j a i l o v e r a n d o v e r a g a in a s lo u d ly a s h e c o u l d
O v e r th e c o u rse o f
t im e J o le n e b e c a m e f r ig h t e n e d o f b o t h C h r i s a n d C h a r t o t h e p o in t t h a t s h e w o u ld n o t g o a lo n e e it h e r t o
t a k e C J t o m e e t t h e m o r t o p ic k h im u p . I o b s e r v e d s i m i la r b e h a v io r d u r in g t h e r e t u r n e x c h a n g e in c lu d in g
o n e t im e w h e n J o le n e w a s t h e r e e a r ly w a it in g f o r t h e m a n d w h e n t h e y p u lle d u p C J w a s n o t r e t u r n e d t o
h e r, s o W i l l w e n t o v e r t o C h a r s c a r a n d w a s v e ile d a t t h r o u g h t h e w in d o w t h a t t h e y h a v e C J u n t il 8 p .m .
a n d h e w o u ld n o t b e o u t o f t h e c a r u n t il t h e ir t im e w a s u p , w h ic h w a s in a m a t t e r o f 2 3 m in u t e s .
On
a n o t h e r o c a s s io n C J h a d a b ir t h d a y p a r t y t o g o t o o n e F r id a y n ig h t a n d I t r ie d t o a r r a n g e f o r C h r i s a n d
C h a r t o p ic k h im u p a t t h e p la c e it w a s b e in g h e ld b e c a u s e it w e n t u n t il 9 p .m . T h e y r e f u s e d s a v in g t h a t
t h e y w e r e u n a b le t o a c c o m m o d a t e a n v d e v ia t io n f r o m t h e s c h e d u le a n d w e n t s o f a r a s t o s a v t h a t C h a r
h a d t o f l y o u t o f t o w n o f t e n f o r w o r k a n d s o t h e y a b s o lu t e ly c o u ld h o t p ic k u p a n y t im e a ft e r 8 p .m . a n d
t h a t t h e y w o u ld o n l y e x c h a n g e a t t h e g a s s t a t io n ,
I a s k e d C J o n th a t M o n d a y i f h e g o t t o s e e C h a r a t a ll
t h a t w e e k e n d s in c e s h e h a d t o f l v o u t o f t o w n a n d h e r e p lie d t h a t s h e h a d n o t g o n e a n y w h e r e a n d th a t s h e
w a s th e re a ll w e e k e n d .
_________________________________ _________________________ _______________________________
W h e n C h r i s o r C h a r w o u ld t e x t m e o r c a ll m v c e ll p h o n e a s k in g t o s p e a k t o C J . 1 w o u ld a c c o m m o d a t e
t h e m w h e n e v e r p o s s ib le a n d h a v e C J c a ll h i s d a d b u t s o m e t im e s h e d id n o t w a n t to . W h e n I w o u ld t e x t
j
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Declaration (DCLR) - Page 2 of_3 __

WPF DRPSCU 01.0100 (6&006)
Mar 17 11 01:34p
Bob Pagay
253-536-1784
T
p .4
b a c k th a t h e d i d n 't w a n t t o c a ll a n d C h a r w o u ld r e q u e s t th a t C J c a ll a n d t e ll t h e m h im s e lf . O n t h o s e
o c c a s io n s C J w o u ld c a ll a n d t e ll h i s d a d th a t h e d i d n t w a n t t o t a lk t h e n a n d C h r i s w o u ld b a d g e r h im t o
t a lk u n t il t h e k i d e n d e d u p t a lk in g t o b o t h C h r i s a n d C h a r . O t h e r t im e s C J w o u ld iu s t b a n d t h e p h o n e b a c k
t o m e o r w o u ld s e t it d o w n a n d w a lk a w a y .
T h i s b e h a v io r w o u ld u s u a lly h a p p e n o n t h e M o n d a y a ft e r a
v is it a t io n o r w h e n h e h a d a lr e a d y t a lk e d t o h i s d a d s e v e r a l t im e s th a t w e e k . T h e r e w e r e a lw a y s m u lt ip le
t e x t s t h r o u g h o u t t h e w e e k r e q u e s t in g C J c a ll h i s d a d r e g a r d le s s o f t h e n u m b e r o f t im e s t h e c h ild h a d
a lr e a d y s p o k e n w it h h i s d a d .
______________ _________________________________________ __ ________________________ _
( A t t a c h A d d it io n a l P a g e s i f N e c e s s a r y a n d N u m b e r T h e m . )
I d e c la r e u n d e r p e n a lt y o f p e i j i n y u n d e r t h e la w s o f t h e s ta te o f W a s h in g t o n t h a t t h e f o r e g o in g i s t r u e a n d
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____

reports to this declaration . Such records should be served on the other party and
2) Sealed Personal Health Care Records (W PF DRPSCU 09.0260) for health records
If filed separately using a cover sheet, the records will be sea led to protect your
privacy (although they will b e available to all parties in the case, their attorneys,
court personnel and certain sta te agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 3 o f J 3

WPF DRPSCU O f 0100 (6/2006) '
E-FILED
March 17 2011 4:14 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:

Petitioner,
and
No. 08-3-00821-4
REPLY DECLARATION OF
JOLENE HARRISON

Respondent.
I, JO LENE C H A R LTO N , am the Mother of CJ Harrison, i am the Petitioner in this case
and the non-moving party in the motion for contempt. I m ake this declaration on the basis of
my personal knowledge.
In his declaration Mr. Harrison admits he was on notice regarding the support
order. Mr. Harrison claims, without proof of any kind, that he thought the support obligation
was only $200 per month which is not the case.
per month.
But the fact is he never paid even $200
Mr. Harrison says he wants child support to go through support enforcement
but he submits no proof that he ever tried to set up an account or m ake payments to the
REPLY DECLARATION - Page 1 of 5

Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Reply Declaration, docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
support registry.
Furthermore, it is not as if Mr. Harrison is unfamiliar with the concept of
paying child support.
Mr. Harrison has four children between the ages of 6 and 17.
He is
ordered to pay child support for two of his four children so he knows how it works (as is
demonstrated by his response saying he wants to go through support enforcement).
has just ignored the issue as to CJ.
He
Mr. Harrison has willfully and intentionally violated his
obligation to pay support.
Mr. Harrisons claim that the No Contact Order somehow stands in the wav of
paving child support is completely ridiculous. The original No Contact order was issued
for two years (not three) as part of Mr. Harrisons sentence for domestic violence and
interference with a 911 call. Mr. Harrison broke the no contact order many, m any times but
the police w ere called only once. The police picked Mr. Harrison up and put him in jail for his
four outstanding warrants. Mr. Harrison blamed Jolene for his jail time, and told CJ that CJs
mother was the reason Mr. Harrison did not show up to pick up CJ for his scheduled visit.
The judge extended the order for an additional year. I was not even consulted about the
extension, and actually did not know about it until recently. Again, this is a situation where
Mr. Harrison hides behind the No Contact order when it benefits him but ignores it when he
wants to.
Mr. Harrison accuses me of being retaliatory but I am not. I did not file a motion
for contempt for Mr. Harrisons violation of the parenting plan by keeping CJ for more time at
Christmas than he was supposed to. The reason I filed a motion for contempt on the back
support issue is for judicial economy. Since I am having to pay an attorney to respond to the
parenting issues I wanted to address the back support at the sam e time to reduce the costs
involved.
Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Reply Declaration.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
The problem is Mr. Harrison blames me for his time in jaif and the No Contact
order and takes out his anger toward me on the child.
Mr. Harrison tells CJ that his
mother and step-father are bad parents; they are called filthy names; and CJ is told a list of
things his mother does or doesnt do that shows what a bad parent she is. The truth is I am
not being retaliatory, just trying to be economical, but Mr. Harrison has been bitter, angry and
resentful since he went to jail for domestic violence and takes it out on CJ.
Mr. Harrison says he was not notified in advance of the trip to Hawaii. This is clearly
false. The text messages I submitted show that he was aware of the trip in advance
and made no objection. Mr. Harrison cannot agree by not objecting and then come back in
and say it was contempt of court. Furthermore, Mr. Harrison violated the parenting plan in
response by taking far more than his allotted time for Christmas.
Mr. Harrison does not address my Response to his Petition for Modification of the
parenting Plan. There is not adequate cause for modification. We are still moving and
have only been unavoidably delayed due to medical issues.
Mr. Harrison does not
even propose a change to the primary residential schedule - his proposed changes are
primarily just to modifies the RCW 26.09.191 limitations and to remove or reduce the
supervision requirement imposed upon his visitation.
Mr. Harrison says there are many other things going on here. Mr. Harrison alleges
that far more important issues ... will be brought forward in court later.
There are much
bigger problems here - but it is not on my side. Mr. Harrison is drinking around the child.
Mr. Harrison is driving the child even though the parenting plan does not allow him to do so.
Mr. Harrison is talking negatively about me and my spouse in front of the child.
Alyssa
Harrison (Chris Harrisons daughter) has told me that Mr. Harrison calls my spouse, (Will
Charlton v Harrison
S:\CASES1\Charlton, Jolene\W ord\PIeadings\Reply Declaration.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet S W , Ste 25
Lakewood, W A 9 8 4 9 9
2 5 3 -5 8 1 -0 6 6 0
Charleton) Wildo the Dildo in front of CJ.
I found this out when CJ called my husband
Wildo and while Alyssa was visiting and I asked where he had heard that. Alyssa told me
that was what Chris called my husband. Alyssa also told me that Mr. Harrison has called me
Cunt One and my mother Cunt Two in front of CJ. I do not offer these statements for the
truth of the matter asserted, but only for the purpose of showing that the words were spoken.
Mr. Harrison alleges there is some nefarious other activity out there which will come
to light. The only other activity which may come to light is that Mr. Harrison is angry
and selfish and is focused completely on himself and not what is in the best interest of
his children. Mr. Harrison recently told his daughter Alyssa she could not live in his home.
When Alyssa called me crying with no place to live I assisted her until she could go live with
her grandmother. Mr. Harrison disparages other people in front of the children at will and his
parenting is focused only on what he perceives as his rights and not on the childrens
needs. This is the only other nefarious activity that will come to light.
Mr. Harrison does not respond to my position regarding phone calls.
I have
asked for the court to clarify this provision of the parenting plan with a reasonable solution:
Two calls per week at a scheduled time while the father is not
working when the father is to initiate the call. The mother will have
CJ ready to answer the call and talk to his father at the scheduled
times. The mother will designate the days of the week and times
by text message. The mother will try to make the designations long
standing, so that they do not change from week to week, but there
needs to be some flexibility for schedule changes and extra
curricular activities that change over time.
The court should clarify the existing parenting plan which allows reasonable telephone
contact by adopting this provision as the definition of reasonable telephone calls. The court
should not find me in contempt.
The court should find Mr. Harrison in contempt for non-

Charlton v Harrison
S:\CASES1\Charlton, Jolene\W ord\P leadings\R eply Declaration, docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet S W , Ste 25
Lakewood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
payment and set a review date in three months to determine if he has begun complying with
the order of child support.
The court should dismiss his Petition for Modification of the
Parenting Plan because there are many things he still has not done that are required (e.g.,
mediation, mandatory parenting seminar, domestic violence treatment) and there is no
substantial change in circumstance.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE
OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
Signed at
L a k e . ! jJ O q A .

Charlton v Harrison
S:\CASES1\Charlton, Jolene\W ord\P leadings\R eply Declaration.docx
, WA on
, 2011.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet SW , Ste 25
Lakew ood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
E-FILED
March 18 2011 8:30 AM

KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7
8

COUNTY OF PIERCE
10
11
12
13
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION OF MAILING
14
15
16
17
18

Respondent.
I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
On March 17, 2011, I placed in the U.S. Mail a copy of the Reply Declaration of Jolene
Harrison and Declaration of Jana Fugle in the above-entitled caption.
19
20
21
22
23
Said documents were addressed to: Christopher Harrison, 6721 Nathan Avenue
SE, Auburn, WA 98092.
DATED
March 17, 2011
24
Sally QpOharme, Legal Assistant

25
v Harrison
Charlton
S:\CASES1\Charlton, Jolene\W ord\Pleadings\D eclaration o f M ailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet S W , S te 25
Lakewood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
March 22 2011
1
KEVIN S
COUNTY
2
3
4
5
6
7
8
9
P etitioner(s),
10
Cause No. 08-3-00821-4

O rder Continuing
Adequate Cause Hearing
vs.
11
12
Respondent(s)
C lerks Filing code: ORACONT
13
14
15
16
proceed to trial with regard to a Petition which has been filed,
17
18
ORDERED the Show Cause hearing determining Adequate Cause is continued.
19
20
21
22
Dated this 22 day o f M arch, 2011
23
24
25
Judge/Commissioner
" 2 3 / 2 - e j'i'
^ O'CTfc. .3
... _
F fL E D
08-3-00821-4
36090805
ORRE
MAR 2 2
03-22-11
2011
p.m.
7 c>La/
S # A c T0jH ___________
No. 0
Petitioner(s),
and
O H '2 'O O / Q .I - Y
OF CGV7)*IOAf/CV /A o / M / f
ORDER
F tizism p tftC tf
TO
// m &ysoH
Clerks action required
Respondent(s).
THIS M ATTER having com e before the Court upon the m oving p a rty s Motion, and the
Court having heard the argum ent o f the parties and having co nside re d the records and files
herein, it is now therefore,
ORDERED, AD JU D G ED AND D ECR EED ________________________________________
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Ixcrtrpt p b l djoum al_entry_show cau$e__report
28611.3
08-3-00621-4
ORNCH
36110311
03-25-11
IN THE SUPERIOR COURT OF THE STATE OF WA

Petitioner(s)
No. 08-3-00821-4
vs
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 items
Certificate of Parenting Class - Petitioner's - Not Filed
Certificate of Parenting Class - Respondent's - Not Filed
Settlement Conference not confirmed by deadline - (See PCLR 16 & PCLSPR 94 04)
Deadline 03/16/11
Deadline
Deadline
You are hereby ORDERED to appear for a hearing at 9 00 am on Friday, 04/22/11 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 lustice
requires See PCLR 1( j
DATED 03/24/11
C o p i e s m a ile d to :
Daniel N Cook
Harrison, Christopher Lee
TO:
Superior Court Clerk for Filing
(Court File Copy)
Judge Family Court - 1

Department NELS
Phone# 253-798-3654
E-FILED
April 08 2011 11:41 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION COVERSHEET

Respondent.
Name: \ )L A c 3 lC ^ V ^
P ,. V ' " " l - j (_ 1, Age:
Relationship to Party(ies):
^ EP A /

OF THE STATE OF WASHINGTON THAT THE ATTACHED PAGES ARE TRUE AND
CORRECT,
Signed at (city)
r (state)
DECLARATION COVERSHEET - Page 1 o f 1

Cnarlton v Harrison
S:\CASES1\Chariton, Jolene\W ord\P leadings\D eclaration Coversheet.docx
on (date) M 7 9 ? ( 2 0 \ {
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
04/07/2011
To w hom it may concern,
M y name is Jordan Sherwood, I am a frie n d o f Tyler Flohr's and have known both his m o the r
Jolene Charlton and Christopher Harrison fo r a bout 3 years now.
On Tuesday M arch 22nd, 2011; I was driving m y frie n d Tyler Flohr to his house around 12:30pm .
Tyler and 1Saw Christopher Harrison and his frie n d standing in Tyler and Jolene's yard.
C hristopher was holding up his phone taking pictures as his friend was knocking at th e ir fro n t
door.
Tyler to ld me n o t to leave ye t and he ju m ped o u t o f m y car to c o n fro n t Christopher Harrison as
to w h a t he was doing a t his house. 1stayed in m y car so I am n ot really sure about w h a t was
said. I saw Tyler and Chris talking and then C hristopher Harrison and his friend walked dow n th e
stre et to a car th a t was parked a t the end o f th e road.
Sincerely,
Jordan Sherwood
E-FILED
April 08 2011 11:41 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and

Respondent.
Name: T
Age:___ l_L ____
PLi o ' h / '
Relationship to Party(ies): 5 ^
r,A fi.W ,fa s \ ________
Number of Pages attached: _______________

CORRECT.
Signed at (city)
T V
l,/ Id fca
1^
, (state) l/j/ A
on (date) H / ^ 7 / ^ &H________ .
_____________________________________
Signature
DECLARATION COVERSHEET - Page 1 o f 1
Charlton v Harrison
S:\CASES1 \Charlton, Jolene\W ord\Pleadings\D eclaration Coversheet. docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
04/07/2011
To whom it may concern,

My name is Tyler Flohr and I am the son of Jolene Charlton.
On Tuesday March 22nd, 2011 my friend Jordan Sherwood was dropping me off at my home
around 12:30pm. As we drove up, I Saw Christopher Harrison and his friend standing in our
yard.
Chris was holding up his phone taking pictures and his friend was knocking at our front door, f
told Jordan not to leave yet and I jumped out of Jordan's car and asked Chris what the heck he
was doing here.
Chris said "oh, hey Tyler!" (Totally dismissing my question to him.) When 1asked Chris again he
replied that It was just business and that he was there looking for "Wildo". (my step dad, Will)
Chris said that he was looking for "Wildo" so that he could catch my mom in a lie.
He asked me where my step dad was. I told Chris he was out of town on a business trip.
Chris then wanted to know if the Blue Honda CRV in the drive way belonged to Will.
He asked me how my step dad got to Idaho if his car was here. I told Chris that Will took an
airplane and then told Chris and his friend that they needed to leave. I watched as they walked
down to the end of the street were a car was parked on the side of the road waiting for them. I
ran inside our house and I immediately called my mom on her cell phone. I was freeking out
and asked her why the heck Chris was at our house and what were him and his friend doing
there? My mom told me to call 911 and tell them what happened. I called but did not have all
of the information the 911 operator was looking for, so she gave me a number to have my mom
call her back.
E-FILED
April 08 2011 11:46 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)

Phone:
Respondent
A d e q u a te C ause - C u s to d y
N a t u r e o f H e a r in g :
Parenting Plans
CALENDAR DATE: Thursday, May 12, 2011 9:30 AM

DATED:
April 8, 2011.
S ig n e d :
/s/ Daniel N Cook
NAM E:
Daniel N Cook
Phone:
(253) 581-0660
W SBA# :
34866
ADDRESS:
5920 100th St SW Ste 25

F o r:
1 of
E-FILED
April 08 2011 11:47 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)

Phone:
Respondent
M o tio n - T e m p o ra ry O rd e r
CALENDAR DATE: Thursday, May 12, 2011 9:30 AM

DATED:
April 8, 2011.
S ig n e d :
/s/ Daniel N Cook
NAM E:
Daniel N Cook
Phone:
(253) 581-0660
W SBA# :
34866
ADDRESS:
5920 100th St SW Ste 25

F o r:
1 of
4 /1 1 /2 0 1 1
13196
OB 1 0 7

COUNTY OF PIERCE
7
8
In re
No. 08-3-00821-4
CHRISOPHER LEE HARRISON, JR.
Summons(Modification/
Adjustment of Custody
Decree/Parenting Plan/ Residential
Schedule)
(SM)
Child,
10

11
Petitioner/M other,
12
and
13

_________________ R espondent/Father
14
18
To
C h risto p h e r L ee H arrison
An action has been started in the above court requesting that a custody
decree/parenting plan/residential schedule be m odified/adjusted. A dditional requests, if
any, are stated in the petition, a copy of which is attached to this notice.
You m ust respond to this notice and petition by serving a copy of yo ur written response
on the person signing this sum m ons and by filing the original with the clerk of the court
If you do not serve your w ritten response within 20 days (or 60 days if you are served
outside of the state o f W ashington) after the date this sum m ons w as served on you,
exclusive o f the day of service, the court may enter an order of default against you, and
the court may, w ithout further notice to you, enter an order regarding adequate cause
and a decree to m odify/adjust the custody decree/parenting plan/residential schedule
and providing for other relief requested in the petition If you serve a notice o f
appearance on the undersigned person, you are entitled to notice before an order of
default or a decree may be entered
The court shall deny the petition unless it finds that adequate cause fo r hearing the
petition is established, in which case it shall set a date fo r hearing on an order to show
cause why the requested order or m odification should not be granted
19
20
21
22
25
Summons Mod/Adj Parenting Plan (SM) - Page 1 o f 2
W P F D R P S C U
2 6
0 7 0 1 2 0 M a n d a to r y (7 /2 0 0 7 ) - C R
1, R C W 2 6
09 270,
10 0 2 0
Charlton v Harrison
S \CASES1\Chariton, Jolene\W ord\Pleadings\Sum m ons door
ORIGINAL
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet S W , Ste 25
Lakewood, W A 9 8499
2 5 3 -5 8 1 -0 6 6 0
4 1 1 ''2 0 1 1
1319t
901S8
1
Tem porary residential placem ent or custody is being sought. If adequate cause is
found, the court m ay proceed im m ediately to hear the m otion fo r tem porary
placem ent/custody or m ay continue the m atter to a later tim e.
3
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
m odifying/adjusting the custody decree/parenting plan/residential schedule w ithout
notice to you pursuant to R C W 26.09 270.
Your written response to the sum m ons and petition m ust be on form W P F DRPSCU
07 0200, Response to Petition fo r M odification/Adjustm ent of C ustody Decree/Parenting
Plan/Residential Schedule This form may be obtained by contacting the clerk of the
court at the address below, by contacting the A dm inistrative Office of the Courts at (360)
705-5328, or from the Internet at the W ashington State Courts hom epage
4
5
6
7
8
10
6
If this action has not been filed with the court, you may dem and that the petitioner file
this action with the court. If you do so, the dem and m ust be in w riting and m ust be
served upon the person signing this notice W ithin 14 days after you serve the demand,
the petitioner m ust file this action with the court, or the service on you of this notice and
motion will be void
If you wish to seek the advice o f an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on tim e
One method of serving a copy of your response on the petitioner is to send it by certified
mail with return receipt requested
11
12
13
14
15
16
This sum m ons is issued pursuant to S uperior Court Civil Rule 4 1 of the state of W ashington
17
FAUBION, REEDER, FRALEY & COOK, P S
18
19
Dated
^ / 7/ z 6ft
O f Attorneys for Petitioner/M other
20
21
F ile o rig in a l o f y o u r r e s p o n s e w ith

th e c le rk o f th e c o u rt a t:
22
C lerk of the Superior Court

Pierce County Court
County-C ity Building
930 Tacom a Ave S., Rm 110
Tacom a, W A, 98402
23
24
S e r v e a c o p y o f y o u r r e s p o n s e on :
Daniel N. Cook
FA U B IO N , REEDER, F R A LE Y & C O O K P.S.
Lakewood, W A 98499
Telephone' 253-581-0660
25
Summons Mod/Adj Parenting Plan (SM) - Page 2 of 2
WPF DRPSCU 07 0120 Mandatory (7/2007) - CR4 1, RCW26 09 270;

26 10 020
Charlton v Harrison
S \CASES1\Chartton, Joiene\W orti\Pleadings\Sum m ons docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4/ 11
08-3-00821-4
2 0 I 5.
" W
36191008
A^ slSS
90 i 8
, 0(n ci
M- APR0S 20ii PM

COUNTY OF PIERCE
In re:
Child,
No. 08-3-00821-4

Petitioner/Mother,
and
Respondent/Father.
1.1
Petition for Modification/

Adjustment of Custody Decree/
Parenting Plan/Residential
Schedule (PTMD)
attached for:
[ ] Order fo r protection UH (PTORAH)
Identification of Requesting Party/Parties
Name (first/last) JOLENE CHARLTON
Birth date 07/15/1975
Last known residence (county and state only) PIERCE COUNTY, WASHINGTON
1.2
Identification of Other Party/Parties
Name (first/last) CHRISTOPHER HARRISON
Birth date 04/16/1970
Last known residence (county and state only) KING COUNTY, WASHINGTON
1.3
Dependent Children
Name (first/last) Christopher Lee Harrison, Jr
Age 6
Pet fo r Mod/Adj Parenting Pin (PTMD) - Page 1 o f 6
WPF DRPSCU 07 0100 Mandatory (6/2008) ~ CR 4 1, RCW 26 09 181,

260, 270
Charlton v Harrison
S \CASES1\Chahton, Jolene\Word\Pleadmgs\Petition for Modification of Parenting
Plan docx
ORIGINAL
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 '1 1 V 2 B 1 1
1315fc
1
II. Basis
2
2.1
3
4
This is a petition for an order modifying the prior custody decree/parenting

plan/residential schedule, which is filed with this petition.
5
6
Petition for an Order Modifying Custody Decree/Parenting Plan/Residential

Schedule
2.2
Adequate Cause

8
2.3
Child Support
Does not apply.
10
11
2.4
12
13
The requesting party/parties reside(s) in (county and state only)

14
The children reside in (county and state only)

15
16
The other party/parties reside(s) in (county and state only)

KING COUNTY, WASHINGTON.
17
18
2.5

This court has jurisdiction over this proceeding for the reasons below
19
This court has exclusive continuing jurisdiction The court has previously made a
child custody, parenting plan, residential schedule or visitation determination in
this matter and retains jurisdiction under RCW 26.27.211
20
21
2.6

Name of Child
Christopher Harrison, Jr
Parents Name
Jolene Charlton
Pet for Mod/Adj Parenting Pin (PTMD) - Page 2 o f 6

WPF DRPSCU 07 0100 Mandatory (6/2008) - CR 4 1, RCW 26 09 181,
260, 270
Charlton v Harrison
S \CASES1\Charlton,
Plan docx
Jolene\Word\Pleadmgs\Petition for Modification of Parenting
Parent's Name
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 ^ i3 v 2 S li
31Sb
3 g i l i
1
During the last five years, the children have lived
2
requesting party or the other party.
Claims to custody or visitation
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.
5
6
Involvement in any other proceeding concerning the children'
The requesting party has not been involved in any other proceeding regarding
the children.
Other legal proceedings concerning the children
10
The requesting party does not know of, any other legal proceedings concerning
the children.
11
12
2.7
The Custody Decree/Parenting Plan/Residential Schedule was entered on (date)

January 25, 2010, at (county and state) Pierce County, WA. A certified copy of the
Custody Decree/Parenting Plan /Residential Schedule to be modified is filed with or
attached to this petition, if the decree or plan to be modified was entered in another
county or state
13
14
15
16
2.8
17
18
Custody Decree or Parenting Plan/Residential Schedule
Modification Under RCW 26.09.260(1), (2)

Does not apply.
2.9
19

The custody decree/parenting plan/residential schedule should be modified because
the reduction or restriction of the residential time for the person with whom the child
does not reside a majority of the time would serve and protect the best interests of the
child using the criteria in RCW 26.09 191, as described here'
20
21
22
See Declaration of Jolene Charlton, filed separately, which is incorporated herein

by this reference
23
24

260, 270
Charlton v Harrison
S \CASES1\Chartton,
Plan docx
Jolene\Worcf\Pleadings\Petition for Modification o f Parenting
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 / i i / 2 8 i i
131S&
9011
1
2.10
Does not apply.

3
4
2.11

Does not apply.
This section oniy applies to a person with whom the child does not reside a
majority o f the time who is seeking to increase residential time.
2.11.1 Parent subject to limitations under RCW 26.09.191(2) or (3)

8
The residential time of CHRISTOPHER HARRISION is subject to limitations There

has been NO substantial change in circumstances specifically related to the basis for
the limitation
9
10
2.11.2 Parent Required to Complete Evaluations, Treatment, Parenting or Other

Classes
12
CHRISTOPHER HARRISON is required by the existing Parenting Plan/Residential

Schedule to complete evaluations, treatment, parenting or other classes This parent
HAS NOT fully complied with such requirements as described here:
13
14

15
Does not apply.

16
2.12
17
The following nonresidential provisions of the parenting plan should be adjusted

because there is a substantial change of circumstances of either party or of the children
and the adjustment is in the best interest of the children1
18
19
Dispute resolution.
20
2.13
21
22
23
24
25
Substantial Change in Circumstance
(You m ust complete this part if you request a modification or adjustment in

paragraphs 2.8, 2.10, 2.11.1, 2.11.3 or 2.12.)
The requested modification or adjustment of the custody decree/parenting plan/
residential schedule is based upon the following substantial change in circumstance:
See Declaration of Jolene Charlton, filed separately, which is incorporated herein
by this reference.

260; 270
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Plea dmgs\Pe tition for Modification of Parenting
Plan docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
l l - ' < 3 i
1319&
9i
2.14
Protection Order
Does not apply.

3
If you need immediate protection, contact the clerk/court for RCW 26.50
Domestic Violence forms or RCW 10.14 Antiharassment forms.
4
5
2.15
Servicemembers Civil Relief Act Statement
2.15.1 A Service member status - Christopher Lee Harrison

7
Is not a service member,

B Factual basis:
See the attached Defense Man Power Data Center Report obtained from
https //www.dmdc.osd.mil/scra/owa/home
10
2.15.2 A. Dependent of a service member status - Christopher Lee Harrison

is not a dependent of a resident of Washington who is on active duty and
is a National Guard member or a Reservist,
11
12
B Factual basis:
13
The other party failed to respond to a notice to him or her as a dependent

of a person in Military Service that was [X] served on [ ] mailed by first
class mail on (SAME DATE AS THIS PETITION), therefore he or she
should be presumed not a dependent of a resident of Washington who is
on active duty and is a National Guard member or a Reservist
14
15
16
17
C
2.16
18
Other
Does not apply
19
20
21
22
Does not apply.
III. Relief Requested

The moving party r e q u e s ts 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.
23
Date
V /
24
25
By Daniel Cook, WSBA 34866

Of Attorneys for Petitioner/Mother
260, 270
Charlton v Harrison
S \CASES1\Char1ton, Jolene\Word\Ploadings\Petition for Modification of Parenting
Plan docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4,"11^2811
13196
98114
1
2

OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT
3
4
Signed at L /)/^ C O O O O __________, fCitvl^ / / ^ [Statel on
[Date]
5
6
.ENE CHARLTON
fetitioner/M other
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Pet for Mod/Adj Parenting Pin (PTMD) - Page 6 of 6

260, 270
Charlton v Harrison
S \CASES1\Chaiiton,
Plan docx
Jolene\Word\Pleadings\Petition for Modification o f Parenting
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 , 1 1 .-Z 8 H
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R e p o rt ID : H 0 S B J 0 0 9 B 2
4/7/2011
1&
1276.9
08-3-00821-4
36194278
CME
4 /1 1 /2 8 1 1
98883
04-11-11

Cause N u m b er;08 -3 -0 08 2 1-4
Petitioner(s)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: DIANA LYNN KIESEL
Court Reporter: Smart Court
Judicial Assistant/Clerk: Jennifer Allyn
HARRISON, JOLENE MARIE
Daniel N Cook
Attorney for Plaintiff/Petitioner
HARRISON, CHRISTOPHER LEE

HARRISON, CHRISTOPHER LEE JR
Proceeding Set: Exparte Action

Outcome Date: 04/08/2011 9:03
Resolution:
Clerk's Scomis Code:MTHRG

R eport run date/time: 04/08/11 9:44 A M

Ixcalcivil. pbl. d_civilJoum al_report_cover
127S9
9BSB4


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
DIANA LYNN KIESEL
Judicial Assistant/Clerk: Jennifer Allyn
Court ReporterSmart Court
April 08, 2011 09:18 AM

Attorney Daniel Cook along with petitioner Jolene Harrison k/n/a Charlton come before the
court with a motion for an exparte restraining order and to suspend father's visitation.
JIS reviewed. Father's visitation is suspended. Order is signed.
JUDGE/COMMISSIONER: DIANA LYNN KIESEL Year 2011
4 /1 1 /2811
1313b
30117
IN COUNTY Cl ! RDk .S0FF)
OB-3-00821
.4
36191010
MTR OTSC
04-08-11
4 m APR 08 20
PM,
BY.
deputy
5
6
7
8

COUNTY OF PIERCE
10
11
12
13
In re-
No. 08-3-00821-4

Child,
Motion/Declaration for Ex Parte

Restraining Order and for Order
to Show Cause
(MTSC)

Petitioner/Mother,
and
14
15

Respondent/Father.
16
17
18
19
I. Motion
Based upon the declaration below, the undersigned moves the court for a
temporary order and order to show cause.
Suspending visitation with the father pursuant to the January 25, 2010,
Parenting Plan because the father has been charged with a crime
20
21
22
The other party should be required to appear and show cause why these
restraints should not be continued in full force and effect pending final determination of
this action.
23
24
25
1.2
Other Ex Parte Relief

Order that JOLENE CHARLTON shall be the person with whom the child resides
until the hearing
Mtn/Decl for Ex Parte Restraining Ord (MTSC) - Page 1 of 4
WPF DR 04 0150 Mandatory (7/2009) - CR 65 (b), RCW 26 09 060

Charlton v Harrison
S \CASES1\Char1ton, Jolene\Word\PleadingsWlotion for Ex Parte
tfRIGTOAL
FAUBION, REEDER, FRALEY

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 /1 1 /2 0 1 1
1 3 3 3
9S115
1.3
Surrender of Deadly Weapons

Does not apply.
1.4
Other Temporary Relief

CHRISTOPHER LEE HARRISON should also be required to appear and show
cause why the court should not enter a temporary order which
approves the parenting plan which is proposed by JOLENE

CHARLTON providing for only professionally supervised visits for
father and allows for phone calls between father and child to be
monitored by an adult in the mothers household
9
appoints a guardian ad litem on behalf of the minor child.
10
11
1.5
Other
Does not apply.
12
FAUBION, REEDER, FRALEY & COOK, P.S.
13
14
Dated: 4 v 7 / ^ V /
15
'
Daniel N Cook, WSBA 34866

Of Attorneys for Petitioner/ Mother
16
II. Declaration
17
18
19
2.1
Injury to be Prevented
The ex parte restraining order requested in paragraph 1 1 and 1.2 above is to
prevent the following injury (define the injury)
20
21
22
23
24
The Parenting Plan final ordered entered by Judge Kathryn Nelson after a trial
(both parties Pro Se) contains the following findings'
Neglect or substantial nonperformance of parenting functions
A long-term impairment from drug, alcohol, or other substance abuse that
interferes with the performance of parenting functions.
25
Mtn/Decl fo r Ex Parte Restraining Ord (MTSC) - Page 2 of 4
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\PleadmgsWIotion for Ex Parte Restraining Order docx

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 /1 1 /2 6 1 1
13196
3B113
These factors were prior to current 11 month (and continuing) treatment to

2
address dual issues of mental health and alcohol abuse by father.
3
These findings were then followed by limitations such that the father is currently
4
5
6
o n ly allowed residential time with the child when he is accompanied by an approved
third party.
In addition, the Court specifically ordered If Mother ascertains Father has left
or been dismissed unsuccessfully from treatment or incurs a criminal arrest,
warrant, or charge after the date of this Parenting plan, in personal visits shall be
10
suspended pending further court action.
11
The mother has no proof of continuing successful treatment
12
The mother has personal knowledge that the father has been charged with a
13
crime.
14
2.2
Reasons why the Injury may be Irreparable
15
This injury may be irreparable because.
16
Christopher Harrison has restrictions in the Parenting Plan because of his

disregard for the law. He has been charged with DWLS/DWLR, Assault in the 4th
degree with DV enhancement, Interruption of a 911 call. He also has a history
of mental health problems with suicidal ideations, death threats, alcohol
dependency, warrants, probation and abuse and neglect of his children There is
no proof that he is in compliance with treatment and he has been charged with a
violation of the law. The court hearing this matter about a year ago was
concerned enough to order limitations on the fathers time and specifically
required suspension of the fathers time unless he continued treatment and
remained free of violations of the law.
17
18
19
20
21
22
23
24
2.3
Clear and Convincing Reasons why Weapons Should be Surrendered

Does not apply.
25
Mtn/Deci fo r Ex Parte Restraining Ord (MTSC) - Page 3 o f 4

& COOK, P.S.
Charlton v Harrison
S \CASES1\Chariton, Joiene\Word\PleadingsWotion for Ex Parte Restraining Order docx
5 9 2 0 -1 00 th S treet S W , Ste 25
Lakewood, W A 9 8 499
253-581-0660
4- 'll'Z B i 1
2.4
l3 1 S i,
2& I2
Reasons for a Temporary Order

See Declaration of Jolene Charlton filed separately.
2.5
Service Member or Dependent of Service Member
[X]
If the other party is not present and.

a) is on active duty and is a National Guard member or Reservist residing in
Washington, or
b) is a dependent of a National Guard member or Reservist residing in Washington
on active duty, list the reasons why this temporary order should be granted despite
the absence of the other party:
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE

STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
Signed at (city) L flte & o o D _______ , (state)
on (date)
7 /^ C f/
/JOLENE CHARLTON
Do not attach financiat records, personal health care records or confidential

records
2) Sealed Persona/ Health Care Records (WPF DRPSCU 09.0260) for health
records
III. Efforts to Give Other Party Notice
The following efforts have been made to give the other party or other partys lawyer
notice and the following reasons exist why notice should not be required
Phone call to Respondents housemate
Dated:
Daniel N. Cook, WSB3V94666----Of Attorneys for Petitioner/Mother
Mtn/Decl fo r Ex Parte Restraining Ord (MTSC) - Page 4 o f 4
WPF DR 04 0150 Mandatory (7/2009) - CR 65 (b), RCW 26 09 060.

Charlton v Harrison
S
\CASES1\Char1ton, Jolene\Word\Pleadmgs\Motion for Ex Parte Restraining Order docx

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 - 3 1 .-'201 1
133 9 6
96121
2
3
08-3-00821-4
36191016
PPP
04-08-11
,N C UHTYFc t i & S Q F n cE
APR 0 8 2011
PM
5
--------
O E P u r -
8
COUNTY OF PIERCE
10
11
12
13
14
In re
No. 08-3-00821-4

Child,
PROPOSED
PARENTING PLAN
(PPP)

Petitioner/Mother,
and
15
16
17
18

_________________Respondent/Father.
This parenting plan is proposed by the Petitioner/Mother JOLENE CHARLTON
IT IS HEREBY ORDERED, ADJUDGED AND DECREED
19
20
I. GENERAL INFORMATION
This parenting plan applies to the following child
21
22
Name
CHRISTOPHER HARRISON, JR
Date of Birth
Age
6
23
II. BASIS FOR RESTRICTIONS
24
U nder certain circum stances, as outlined below, the court m ay lim it o r prohibit a parent's
contact with the child a n d the rig h t to m ake decisions fo r the child

WPF DR 01 0400 Mandatory (6/2008) - RCW26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadings\Pruposed Parenting Plarbd(\
j p
FAUBION, REEDER,
FRALEY & COOK, P.S.
I K | ft 1
Lakewood, WA 98499
253-581-0660
UKIblNAL
4>-1 1 ^ 2 6 1 1
1319&
'3 8 1 2 2
2.1
T h e R e s p o n d e n ts re sid en tial tim e with th e child(ren) sh all b e limited o r

re stra in e d co m p le tely , a n d m utual d e cisio n -m ak in g a n d d e sig n a tio n of a d isp u te
reso lu tio n p r o c e s s o th e r th a n court actio n sh all n ot b e req u ired , b e c a u s e [X] this
p a re n t [ ] a p e r s o n re sid in g with this p a re n t h a s e n g a g e d in th e c o n d u c t w hich
follows:
3
4
5
A h isto ry of a c ts of d o m e stic v io len ce a s d e fin e d in R C W 2 6 .5 0 010(1) or

an a s s a u lt o r s e x u a l a s s a u lt w hich c a u s e s g rie v o u s bodily h arm o r th e fe a r
of s u c h h arm .
6
7
8
2.2

T h e R e s p o n d e n ts in v o lv em en t or c o n d u ct m ay h a v e a n a d v e r s e effect on th e
child (ren )s b e s t in te re s ts b e c a u s e of th e e x is te n c e of th e fa c to rs w hich follow
N e g lec t o r s u b sta n tia l n o n p e rfo rm a n c e of p a re n tin g fu n ctio n s.
A lo n g -term em o tio n a l o r p h y sical im p airm en t w hich in te rfe re s with th e
p e rfo rm a n c e of p aren tin g fu n ctio n s a s d e fin e d in R C W 2 6 0 9 .0 0 4
12
13
A lo n g -term im p airm en t resulting from d ru g , alcohol, o r o th e r s u b s ta n c e

a b u s e th a t in te rfe re s with th e p e rfo rm a n c e of p a re n tin g fu n ctio n s
14
15
16
The residential schedule must set forth where the child(ren) shall reside each day of the
year, including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the child(ren) shall have with each parent
needs o f the child(ren) and individual needs o f their family. Paragraphs 3.1 through 3 9
write in your own schedule in Paragraph 3.13.
17
18
19
20
3.1
21
T h e re a re no ch ild ren u n d e r sch o o l a g e
22
23
3.2
School Schedule
U pon en ro llm e n t in sch o o l, th e child(ren) shall re s id e with th e P etitio n er/m o th er,
e x c e p t for th e following d a y s a n d tim e s w h en th e child(ren) will re s id e with or b e
with th e o th e r p a re n t:

WPF DR 01 0400 Mandatory (6/2008) - RCW 26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Cbar1ton, JoIene\Word\Pleadmgs\ProposedParenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 100th S treet SW , Suite 25
253-581-0660
4^
13195
9S12
1
2
A fter c o m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3.10, from (d ay an d

tim e)
F rid ay 7 :0 0 p m.__________ to (d ay a n d tim e)
S u n d a y 7:00 p.m .
e v e ry o th e r w e e k
Until c o m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3 10, only s u p e rv ise d

visitation with fa th e r will b e allow ed
3.3

T h e child(ren) shall r e s id e with th e P e titio n er/m o th er d u rin g w in ter vacatio n ,
e x c e p t for th e following d a y s a n d tim e s w h e n th e ch ild (ren ) will re s id e with or b e
with th e o th e r p a ren t:
7
8
9
A fter c o m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3 .1 0 , th e first d ay of

S c h o o l W in ter V a ca tio n a t 6 -00 p.m . to th e d a y a fte r C h ristm a s a t 6.0 0
p.m . e v e ry o th e r y e a r T h e d ay a fte r C h ristm a s a t 6 0 0 p m. to N ew
Y e a rs D ay a t 6 :0 0 p.m in th e altern atin g y e a r s S e e S ectio n 3 7
10
11
Until c o m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3 .1 0 , only s u p e rv ise d

visitation with fa th e r will b e allow ed.
12
13
3.4
14
T h e child(ren) shall re s id e with th e P etitio n e r/m o th er during o th e r sch o o l b re a k s

15
16
3.5
Summer Schedule
U pon co m p letio n of th e sch o o l y e ar, th e child(ren) sh all re s id e with th e
P etitio n er/m o th er, e x c e p t for th e following d a y s an d tim e s w h e n th e child(ren) will
re sid e with o r b e with th e o th e r p aren t:
17
18
19
S a m e a s s c h o o l y e a r s c h e d u le
20
A fter c o m p letio n o f th e re q u ire m e n ts in P a ra g ra p h 3 10, F a th e r to be

allow ed in ad d itio n to re g u la r ev ery o th e r w e e k e n d visit: 1 w e e k in July,
a n d 1 w e e k in A u g u st begin n in g with a Friday o f a re g u la r w e e k e n d visit
for fa th e r
21
22
Until c o m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3 10, only s u p e rv ise d

visitation with fa th e r will b e allow ed
23
24
3.6

D o es not ap p ly

WPF DR 01 0400 Mandatory (6/2008) -RCW 26.09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadmgs\Proposed Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 100th S treet S W , Suite 25
2 5 3 -5 8 1 -0 6 6 0
4^ 1
2S11
I3i9t
38124
3.7
T h e re is no H oliday s c h e d u le until a fte r th e re q u ire m e n ts in P a ra g ra p h 3 .1 0 a re

c o m p le te d .
3
4
A fter co m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3.10, th e re sid en tial s c h e d u le

for th e child(ren) for th e h o lid ay s listed belo w is a s follows
W ith P etitio n er
(S p ecify Y e ar
O d d /E v en /E v erv )
6
7
N ew Y e a rs D ay
M artin L uther King D ay
P r e s id e n ts D ay
M em orial D ay
Ju ly 4 th
L ab o r Day
V e te r a n s D ay
T h an k sg iv in g Day
C h ris tm a s E ve
C h ris tm a s D ay
E a s te r
8
9
10
11
12
13
ODD______________
OD D ______________
E very_____________
EVEN_____________
ODD______________
ODD_____________
EVEN______________
W ith R e s p o n d e n t
(S p ecify Y e a r
EVEN
EVEN
ODD
EVEN
EVEN
ODD
14
[X]
For p u rp o s e s of th is p a re n tin g plan, a holiday shall b e g in an d e n d a s

follows (s e t forth tim es): S e e S e c tio n 3 2 a b o v e W e e k e n d s m a y include
holiday M o n d ay s in w hich c a s e th e S u n d a y return tim e b e c o m e s M onday
[X]
H olidays w hich fall on a F riday o r a M o n d ay shall in clu d e S a tu rd a y an d

Sunday.
15
16
17
18
D o e s n ot include. W in ter b re a k , N ew Y e a rs D ay, C h ristm a s E ve or

C h ristm a s D ay, a s th e s e ho lid ay s h a v e s p e c ia l d e s ig n a te d tim es
See 3 3
19
20
3.8
21
22
23
24
T h e re is no S p e c ia l O c c a sio n s c h e d u le until a fte r th e re q u ire m e n ts in P a ra g ra p h

3 .1 0 a r e c o m p le te d
A fter co m p letio n of th e re q u ire m e n ts in P a ra g ra p h 3.10, th e re sid en tial s c h e d u le
for th e child(ren) for th e following s p e c ia l o c c a s io n s (for e x a m p le , b irth d ay s) is a s
follows*
With P e titio n er
W ith R e s p o n d e n t
(S pecify Y e ar
(S p ecify Y e a r
Charlton v Harrison
FAUBION, REEDER,
FRALEY & COOK, P.S.
253-581-0660
4/11/2811
33135
38125
1
2
EVERY
M others D ay
F a th e r's D ay
EVERY
3
4
3.9
D o es n o t a p p ly b e c a u s e o n e p a re n t h a s no visitation o r re stric ted visitation.
5
6
3.10
Restrictions
T h e R e s p o n d e n ts resid en tial tim e with th e children sh all b e limited b e c a u s e
th e re a r e limiting fa c to rs in p a ra g ra p h s 2 1 a n d 2 2. T h e following restrictio n s
shall ap p ly w h e n th e children s p e n d tim e with th is p a re n t
7
8
All v isitation sh all b e s u p e rv ise d by a p ro fe ssio n a l visitation su p e rv iso r (a t

R e s p o n d e n t/fa th e rs e x p e n s e ) u n le s s a n d until R e s p o n d e n t/fa th e r c o m p le te s
th e following re q u ire m e n ts:
11
a) A S ta te certified d ru g /alco h o l e v alu a tio n w hich sh all include collateral c o n tac t

with P e titio n e r/m o th er J o le n e C h arlto n a n d a n y re c o m m e n d e d follow -up
tre a tm e n t.
12
13
b) A S ta te certified d o m e stic v io len ce a s s e s s m e n t w hich sh all include co llateral
c o n ta c t with P e titio n e r/m o th er J o le n e C h arlto n a n d a n y re c o m m e n d e d
follow -up tre a tm e n t
14
15
c) A m e n ta l h e alth ev alu atio n with p a re n tin g c o m p o n e n t w hich shall include

c o llateral c o n ta c t with P etitio n e r/m o th er J o le n e C h arlto n a n d an y
re c o m m e n d e d follow-up tre a tm e n t
16
17
d) R e s p o n d e n t/fa th e r shall sign au th o rizatio n for r e le a s e of inform ation to

P e titio n e r/m o th e r J o le n e C harlton for all e v a lu a tio n s a b o v e a n d an y a n d
all tre a tm e n t p ro v id ers e n g a g e d in r e s p o n s e to e v a lu a tio n s s e t forth
above.
18
19
20
C o n ta c t sh all b e limited to visits in th e c o u n ty w h e re th e child re s id e s of no m o re

th a n 3 h o u rs p e r visit for no m o re th a n 10 v isits p e r m o n th on a s c h e d u le
a rra n g e d b e tw e e n th e su p e rv iso r a n d P e titio n e r/m o th e r J o le n e C harlton. C o s ts of
su p erv isio n sh all b e paid by R e s p o n d e n t/fa th e r C h risto p h e r H arrison
21
22
3.11
T ra n sp o rta tio n c o s ts a re included in th e Child S u p p o rt W o rk s h e e ts a n d /o r th e
O rd e r of Child S u p p o rt a n d sh o u ld n ot b e included h e re
P a r e n tin g P la n
W P F D R
01
(P P P ,
P P T ,
P P ) - P a g e
5 o f 10
0 4 0 0 M a n d a to ry ( 6 /2 0 0 8 ) - R C W
2 6 0 9 016,
181,
Charlton v Harrison
187,
194
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
4 - 'I 3 v 2 i5 li
9 0 I2 &
T ra n sp o rta tio n a rra n g e m e n ts for th e child(ren), b e tw e e n p a re n ts shall b e a s

follow s
2
3
Prior to c o m p le tio n of re q u ire m e n ts in P a r a g ra p h 3 .1 0 , visitation shall b e

a t a locatio n c h o s e n by th e m o th e r in c o n su lta tio n with th e visitation
s u p e rv is o r within r e a s o n a b le proxim ity to th e m o th e rs re s id e n c e
4
5
A fter c o m p letio n of re q u ire m e n ts in P a ra g ra p h 3 .1 0 , th e receiving p a re n t

shall p ro v id e tra n sp o rta tio n .
6
7
3.12
T he children n a m e d in th is p aren tin g plan a r e s c h e d u le d to re s id e th e m ajority of

th e tim e with th e P e titio n e r/m o th er JO L E N E CH ARLTON T h is p a re n t is
d e s ig n a te d th e c u s to d ia n of th e child(ren) solely for p u r p o s e s of all o th e r s ta te
a n d fe d e ra l s ta tu te s w hich req u ire a d e sig n a tio n o r d e te rm in a tio n of cu sto d y
This d e sig n a tio n sh all n o t affect e ith e r p a re n ts rig h ts a n d resp o n sib ilities u n d e r
this p a re n tin g p lan .
9
10
11
12
3.13
14
15
16
No tran sp o rtin g of child u n le ss a p p ro v e d driver h a s lic e n se a n d in su ran ce.

F a th e rs a u n t o r u n cle, F a th e rs M other o r S te p -F a th e r all a p p ro v e d an d o th e rs a s
m en tio n ed by M other a re ap p ro v ed .
17
18
20
Other
This p a re n tin g p la n is e n te r e d in anticipation of a n d with th e full k n o w led g e th at
th e m o th e r will s o o n b e relo catin g to Idaho s o m e tim e b e fo re S e p te m b e r 2011 A
trial h a s a lre a d y b e e n held on th e is su e of th e m o th e rs m o v e to Id ah o s o no
N otice of R elo catio n n e e d b e given w h en th e m o th e r m o v e s prior to S e p te m b e r
2011 , e x c e p t th a t th e m o th e r will provide th e fa th e r with h e r n e w resid en tial
a d d r e s s a fte r s h e m o v e s
13
19
3.14

This is a su m m a ry only F o r th e full text, p le a s e s e e R C W 2 6 0 9 .4 3 0 th ro u g h
2 6 .0 9 4 8 0
21
22
23
24
If th e p e rs o n with w h o m th e child re s id e s a m ajority of th e tim e p la n s to m ove,

th a t p e rs o n sh all g iv e n o tic e to ev ery p e rs o n entitled to co u rt o rd e re d tim e with
th e child
If th e m o v e is o u ts id e th e ch ild s sch o o l district, th e relo catin g p e rs o n m u st give
notice by p e rs o n a l s e rv ic e or by mail requiring a retu rn receip t. T his n o tice m u st
b e a t le a s t 60 d a y s b e fo re th e in ten d ed m o v e. If th e relo catin g p e rso n could not
h a v e know n a b o u t th e m o v e in tim e to give 6 0 d a y s n otice, th a t p e rs o n m u st
give n o tice within 5 d a y s a fte r learning of th e m o v e. T h e n o tice m u st co n tain th e
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadmgs\Pmposed Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660
4 ^1 1 ^2 0 1 1
13196
30127
inform ation re q u ire d in R C W 2 6 .0 9 .4 4 0 . S e e a ls o form D R P S C U 0 7 .0 5 0 0 ,

(N otice of In te n d e d R elo catio n of A Child).
If th e m o v e is w ithin th e s a m e sch o o l district, th e re lo catin g p e rs o n m u st provide

a c tu a l n o tice by a n y r e a s o n a b le m e a n s A p e rs o n en titled to tim e with th e child
m ay not o b je c t to th e m o v e bu t m ay a s k for m odification u n d e r R C W 26.0 9 2 6 0
3
4
N otice m ay b e d e la y e d for 21 d a y s if th e relo catin g p e rs o n is en terin g a d o m e stic

v io len ce s h e lte r or is m oving to avoid a clear, im m ed iate a n d u n re a s o n a b le risk
to health a n d safety .
5
6
If inform ation is p ro te c te d u n d e r a co u rt o rd e r o r th e a d d r e s s confidentiality

p rogram , it m ay b e w ith h eld from th e notice
A relocating p e rs o n m a y a s k th e court to w aiv e a n y n o tic e re q u ire m e n ts th a t m ay

put th e h e alth a n d s a fe ty of a p e rs o n or a child a t risk.
8
9
Failure to g iv e th e req u ired n o tice m ay b e g ro u n d s for s a n c tio n s , including

co n tem p t.
10
If no o bjection is filed w ithin 30 d a y s after se rv ic e of th e n o tic e of in ten d ed

relocation, th e relo catio n will b e perm itted a n d th e p ro p o s e d re v ised resid en tial
s c h e d u le m a y b e co n firm ed .
11
12
A p e rso n en titled to tim e with a child u n d e r a co u rt o rd e r c a n file a n objection to

th e childs relo catio n w h e th e r o r not h e or s h e re c e iv e d p ro p e r n o tice
13
14
An objection m ay b e filed by u sing th e m a n d a to ry p a tte rn form W P F D R PSC U

07 .0 7 0 0 , (O b jectio n to R elo catio n /P etitio n for M odification of C u sto d y
D e c re e /P a re n tin g P la n /R e sid e n tia l S c h e d u le ) T h e o b jectio n m u st b e s e rv e d on
all p e rs o n s en titled to tim e with th e child
15
16
T h e relo catin g p e rs o n sh all n ot m o v e th e child during th e tim e for objection

u n le s s ' (a) th e d e la y e d n o tic e pro v isio n s apply; o r (b) a c o u rt o rd e r allow s th e
m ove.
17
18
If th e o bjecting p e rs o n s c h e d u le s a h earin g for a d a te within 15 d a y s of timely

serv ice of th e o b jectio n , th e relocating p e rs o n shall n ot m o v e th e child b efo re th e
hearin g u n le s s th e re is a clear, im m ed iate a n d u n re a s o n a b le risk to th e health or
sa fe ty of a p e rs o n o r a child.
19
20
21
IV. Decision Making

22
4.1
23
24
E a c h p a re n t sh all m a k e d e c is io n s reg ard in g th e d a y -to -d a y c a r e a n d control of

e a c h child w hile th e child is residing with th a t p a re n t. R e g a r d le s s of th e allocation
of d ecisio n m aking in th is p aren tin g plan, e ith e r p a re n t m ay m a k e e m e rg e n c y
d e c isio n s affecting th e h e alth o r safety of th e children.
WPF DR 01.0400 Mandatory (6/2008)-RCW 26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Chartton, Jolene\Word\Pleadmgs\Proposed Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4/I1V2011
13196
9*512 E
1
2
4.2
Major Decisions
M ajor d e c is io n s re g a rd in g e a c h child shall b e m a d e a s follow s'
E d u catio n d e c is io n s
N o n -e m e rg e n c y h e a lth c a r e
R eligious u pbringing
5
6
4.3
P e titio n e r/m o th er
7
8
S o le d e cisio n m aking shall b e o rd e re d to th e P e titio n e r/m o th e r for th e following

re a s o n s :
A lim itation on th e o th e r p a re n ts d e cisio n m aking au th o rity is

m a n d a te d by R C W 2 6 .0 9 191 (S e e p a ra g ra p h 2 1).
10
O n e p a re n t is o p p o s e d to m utual d e cisio n m ak in g , a n d su ch
o p p o sitio n is re a s o n a b ly b a s e d on th e following criteria'
11
12
13
(a)
(b)
14
(c)
15
16
(d)
17
18
T h e e x is te n c e of a limitation u n d e r R C W 2 6 .0 9 .1 9 1 ,
T h e history of p articipation of e a c h p a re n t in d e c isio n m aking
in e a c h of th e a r e a s in R CW 2 6 .0 9 .1 84(4 )(a);
W h e th e r th e p a re n ts h a v e d e m o n s tra te d ability a n d d e sire to
c o o p e r a te with o n e a n o th e r in d e c isio n m aking in e a c h of th e
a r e a s in
R C W 2 6 0 9 184(4)(a); an d
T h e p a r e n ts g e o g ra p h ic proxim ity to o n e a n o th e r, to th e
e x te n t th a t it affects th eir ability to m a k e tim ely m utual
d e c is io n s .
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local court rules or the provisions o f this plan must be used before filing a petition to
modify the plan or a motion for contempt for failing to follow the plan .
No d is p u te reso lu tio n p ro c e s s , e x c e p t court action is o rd e re d
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T h e re a re th e following o th e r p ro v isio n s
Charlton v Harrison
S \CASESl\Chariton, Jolene\Word\Pleadmgs\Proposed Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 / 5 1 /2811
1
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5
1. F a th e rs altern atin g w e e k e n d sh all b e d e s ig n a te d for th e y e a r in a d v a n c e

T h e re a re no m a k e u p s a s it is an ticip ated by th e C o u rt th a t s o m e w e e k e n d visits
with F a th e r m ay no t o c cu r a n d F a th e r m u st w ait for his next w e e k e n d . T h e C ourt
b e lie v es th a t altern atin g s c h e d u le w hich in clu d es m o st M onday holidays would b e
a p p ro p ria te for F a th e rs s c h e d u le e a c h y ear.
2
T h e p a rtie s m ay alw ay s m utually a g re e to a variation in th e s c h e d u le
e sp ecially w h e n it is in th e childs b e s t in te re st
3.
If M other a s c e rta in s F a th e r h a s left or b e e n d ism isse d u n su ccessfu lly from
tre a tm e n t o r incurs a crim inal a rre st, w arran t, or c h a rg e a fte r th e d a te of this
P aren tin g P lan, in p e rs o n visits shall b e s u s p e n d e d pen d in g fu rth er co u rt action
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F a th e r shall h a v e re a s o n a b le te le p h o n e c o n ta c t with th e child. All te le p h o n e
calls b e tw e e n fa th e r a n d child m ay b e m onitored by an a d u lt in th e m o th e rs
h o u se h o ld P h o n e calls shall b e tw o calls p e r w e e k a t a s c h e d u le d tim e while th e
fa th e r is n o t w orking w h e n th e fa th e r is to initiate th e call. T h e m o th e r will h a v e
C J re a d y to a n s w e r th e call a n d talk to his fa th e r a t th e s c h e d u le d tim e s T h e
m o th e r will d e s ig n a te th e d a y s of th e w e e k a n d tim e s by te x t m e s s a g e . T h e
m o th e r will try to m a k e th e d e s ig n a tio n s long sta n d in g , s o th a t th e y d o not
c h a n g e from w e e k to w e ek , b ut th e re n e e d s to b e s o m e flexibility for s c h e d u le
c h a n g e s a n d e x tra -c u rric u la r activities th a t c h a n g e o v e r tim e
5.
F a th e r shall confirm his altern atin g w e e k e n d visitation by W e d n e s d a y at
6 0 0 p.m prior to th e w e e k e n d visit. If F a th e r fails to confirm th e visitation by this
tim e, th a t w e e k e n d visitation shall b e forfeited.
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(O nly sig n if th is is a p ro p o s e d p a re n tin g plan.) I d e c la re u n d e r p en alty of

perjury u n d e r th e law s of th e s ta te of W a sh in g to n th a t th is p la n h a s b e e n
p ro p o s e d in g o o d faith a n d th a t th e s ta te m e n ts in P a rt II of th is P lan a r e tru e a n d
co rrect.
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j/l /
itioner
D a te a n d P la c e of S ig n a tu re
R espondent
D ate a n d P la c e of S ig n a tu re
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24

Charlton v Harrison
S \CASES1\Chariton, Jo!ene\Word\P!eadings\ProposedParenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 /1 3 /2 0 1 1
1339&
98138
3
4
5
6
It is o rd e re d , a d ju d g e d a n d d e c r e e d th a t th e p a re n tin g plan s e t forth a b o v e is a d o p te d

a n d a p p ro v e d a s a n o rd e r of th is co u rt
WARNING: V iolation of re sid en tial p ro v isio n s of th is o rd e r with a c tu a l k n o w led g e of its

te rm s is p u n is h a b le by c o n te m p t of co u rt a n d m a y b e a crim inal o ffe n s e u n d e r R C W
9A 40 0 60(2 ) or 9 A .4 0 .0 7 0 (2 ). V iolation of th is o rd e r m ay s u b je c t a violator to a rre st.
W hen m utu al d e c isio n m aking is d e s ig n a te d bu t c a n n o t b e a c h ie v e d , th e p a rtie s shall
m a k e a g o o d faith effort to re so lv e th e is su e th ro u g h th e d is p u te reso lu tio n p r o c e s s
If a p a re n t fails to com p ly with a provision of th is p lan, th e o th e r p a r e n ts o b lig atio n s

u n d e r th e p lan a r e n ot a ffe cted
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11
D ated
Judge/Commissioner
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13
P re s e n te d by
& COOK, P .S .
A p p ro v ed by:
B y DANIEL N. C O O K , W SB A # 3 4 8 6 6
O f A ttorney s for P e titio n e r
C h risto p h e r L. H arrison, R e s p o n d e n t
P ro S e
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A pproved a n d a g re e d by:
A sig n atu re belo w is actu a l notice of this
order
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J o le n e C harlto n , P etitio n er/M o th er
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Charlton v Harrison
S \CASES1\Chartton, Jolene\WonfPleadings\Proposed Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4X 11^2811
1 3 3 8 1 3 3
N c o (JNryF^ S p
ERk S off ,
am
APf? n
F
P&CFr
0 8 2V
4
5
6
7
COUNTY OF PIERCE
9
In re
No. 08-3-00821-4

Child,
Notice Re: Dependent of a

Person in Military Service
(NTDMP)
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P etitioner/M other,
and
R e s p o n d e n t/F a th e r
Notice S ta te a n d fe d e ra l law pro v id e p ro tectio n s to d e f e n d a n ts /re s p o n d e n ts w ho a re on

active duty in th e m ilitary se rv ic e , a n d to th eir d e p e n d e n ts . T his n o tice only p e rta in s to a
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d e fe n d a n t/re s p o n d e n t w h o is a d e p e n d e n t of a m e m b e r of th e N ational G u ard or a military
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re s e rv e c o m p o n e n t u n d e r a call to activ e se rv ic e for a p erio d of m o re th a n thirty (30)
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c o n se c u tiv e d a y s. O th e r d e fe n d a n ts /re s p o n d e n ts in military s e rv ic e a lso h av e p ro te c tio n s

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a g a in s t defau lt ju d g m e n ts not c o v e re d by th is no tice
D e p e n d e n ts of a s e rv ic e m e m b e r a re
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th e serv ice m e m b e rs s p o u s e , a se rv ic e m e m b e rs m inor child, o r a n individual for w hom th e
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serv ice m e m b e r p ro v id ed m o re th a n o n e -h a lf of th e individuals s u p p o rt for o n e h u n d red
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eighty d a y s (180) d a y s im m ed iately p re c ed in g an ap p licatio n for relief

Notice re: Dep. of Person in Military Service (NTDMP) - Page 1 o f 2
WPF DRPSCU 01 0185 (6/2006) - Laws o f 2006, ch 80 1(3)
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Ple actingsWo tice re Military
ORIGINAL
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4^ 5 . 1 / 2 0 1 1
9013^
O n e p ro tectio n p ro v id ed is th e protection a g a in s t th e en try of a d efau lt ju d g m e n t in

2
certain c irc u m sta n c e s . If y o u a r e th e d e p e n d e n t o f a m e m b e r of th e N ational G u ard or a
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military re s e rv e c o m p o n e n t u n d e r a call to activ e s e rv ic e fo r a p erio d of m o re th a n thirty (30)

c o n se c u tiv e d a y s, you sh o u ld notify th e plaintiff/petitioner or, if th e plaintiff/petitioner is
re p re s e n te d by a n atto rn ey , th e plaintiff/petitioners a tto rn e y in writing of y o u r s ta tu s a s su ch
within tw enty (20) d a y s of th e re c e ip t of th is n otice. If you fail to d o so , th e n a court or an
ad m in istrativ e trib u n al m a y p re s u m e th a t you a re n ot a d e p e n d e n t of a n activ e duty m e m b e r
of th e N ational G u a rd o r r e s e rv e s , a n d p ro c e e d with th e e n try of a n o rd e r of d efau lt an d /o r a
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d e fa u lt ju d g m e n t w ith o u t fu rth e r p roof of y o u r s ta tu s . Y our r e s p o n s e to th e plaintiff/petitioner
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o r plaintiff/petitioners a tto rn e y a b o u t your s ta tu s d o e s n ot c o n stitu te a n a p p e a r a n c e for

jurisdictional p u rp o s e s in a n y p en d in g litigation, a w aiv er of y o u r rights or a re s p o n s e to th e
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petition, co m p lain t or o th e r ap p licatio n for relief th a t w a s filed a g a in s t you
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D ated April 7, 2 0 1 1 .
FAUBION, R E E D E R , FRALEY & C O O K P .S
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By DANIEL N CO OK , W S B A # 3 4 8 6 6
O f A tto rn ey s for P etitio n er/M o th er
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1319b
Notice re: Dep. of Person in M ilitary Service (NTDMP) - Page 2 of 2

WPF DRPSCU 01 0185 (6/2006) - Laws o f 2006, ch 80 1(3)
Charlton v Harrtson
S \CASES1\Chariton, Jolene\W ord\PieadmgsVJotice re M ilitary Dependent docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 '1 1 ^ 2 0 ii
,NC0^ i &
AM.
1313b
S&13
S0FFICE
APR 08 2011 PM
---------deputv^
7
8

COUNTY OF PIERCE
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In re:
Petitioner,
and
No. 08-3-00821-4
DECLARATION OF
JOLENE HARRISON

Respondent
f, JOLENE CHARLTON, am the Mother of CJ Harrison. I am the Petitioner in this case
and the moving party in this Petition to Modify the Parenting Plan
Christopher Harrison and I
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have one child, CJ Harrison, who is six years old
19
supervised visits and phone calls to be monitored. I make this declaration on the basis of my
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personal knowledge
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VISITATION SHOULD BE PROFESSIONALLY SUPERVISED BECAUSE THE CURRENT

PARENTING PLAN INCLUDES FINDINGS CONCERNING MR. HARRISONS PAST
CONDUCT AND POOR PARENTING AND SPECIFICALLY PROVIDES FOR
SUSPENDING VISITATION AFTER ANOTHER ARREST
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I am asking the court to order professionally
Christopher Harrison has restrictions in the Parenting Plan because of his disregard
for the law. He has been charged with DWLS/DWLR, Assault in the 4th degree with DV
REPLY DECLARATION - Page 1 o f 7
Charlton v Harrison
S \CASESl\Chariton, Jolene\Word\Pleadmgs\Declaration of Jolene Charlton re
Parenting Plan Modification' docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
ORIGINAL
4Î1'2S3I
13 I B B
''J& 1 3 4
1
e n h a n c e m e n t, Interruption of a 911 call.
H e a ls o h a s a history of m en tal h e a lth p ro b le m s
with suicidal id e atio n s, d e a th th re a ts , alcohol d e p e n d e n c y , w a rra n ts, p ro b atio n a n d a b u s e
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4
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a n d n e g le c t of his children. O n J a n u a ry 2 5 th, 2 0 1 0 , J u d g e K athryn N elso n req u ired Mr.

H arrison to b e s u p e rv is e d by a n a p p ro v e d ad u lt w h e n th e child is in his c a re . J u d g e N elson
c le a re d Ms. P erg rim a s a n a p p ro v e d ad u lt to h o st th e child a t h e r h o u s e during Mr H arriso n s
visits. S in c e th a t d a te th e re h a s b e e n s u b sta n tia l e v id e n c e to p ro v e Ms. P erg rim is not
su ita b le to b e th e su p erv isin g ad u lt th a t C h risto p h e r n e e d s for th e c a r e a n d s a fe ty of th e
child.
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T h e fa th e r is cu rren tly only allo w ed resid en tial tim e with o u r child, C J, w h e n h e is

a c c o m p a n ie d by a n a p p ro v e d third p a rty b e c a u s e restrictio n s w e re o rd e re d for C h risto p h e r
H arriso n s re sid en tial tim e b e c a u s e of:
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N eg lect o r s u b sta n tia l n o n p e rfo rm a n c e of p a re n tin g fu n ctio n s
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A lo n g -term im p airm en t from d rug, alco h o l, o r o th e r s u b s ta n c e a b u s e th at
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in te rfe re s with th e p e rfo rm a n c e of p a re n tin g fu n c tio n s

T h e s e fa c to rs w e re prior to cu rre n t 11 m o n th (a n d co n tinuing) tre a tm e n t to
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a d d r e s s d u al is s u e s of m e n ta l h ealth a n d alcohol a b u s e by fa th e r
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T h e fin d in g s a b o u t Mr H arrison a n d th e re strictio n s on his resid en tial tim e w ere
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b a s e d on m a n y th in g s, including but n o t limited to Mr. H a rriso n s history of d o m estic violence
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S o m e e x a m p le s of th e d o m e stic violence history include:
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He th rew o n e d a u g h te r s o hard a g a in s t th e c o u c h th a t h er k n ee c a p w as
dislo cated to th e s id e of h er leg.
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Charlton v Harrison
S \CASES1\Charfton, Jolene\Word\Pleadmgs\Declaration of Jolene Charlton re
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 ^1 1 ^2 0 1 1
13196
9 B I3 S
A n o th e r d a u g h te r w a s hurt on th e w o o d e n night sta n d w h e n s h e w a s y a n k ed out

2
of b ed
S h e re p o rte d th is to h e r c o u n se lo r but w h en C P S c a m e to in v estig ate s h e d e n ied it
3
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b e c a u s e s h e w a s to o afraid of h e r Dad
Mr. H arrison ran up b eh in d m e an d sh o v e d m e s o h a rd in th e b a ck th a t h e s e n t
m e flying th ro u g h th e air into th e b a ck sid e of th e box sp rin g s on th e landing below I w a s
s c ra p e d an d b ru ise d on m y a rm s a n d legs, a n d m om entarily could not s ta n d b e c a u s e I w a s
s tu n n e d an d dizzy T h e n h e violently tried to p re v e n t m e from leaving by forcing th e w indow
dow n and reach in g into th e car, Mr. H arrison y an k ed th e c a r k ey s from m y h an d , cutting my
10
fingers. In g re a t fe a r I dialed 911 only to h av e Mr. H arrison g ra b th e p h o n e from m y h an d and
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s m a s h it on th e g ro u n d . My th irteen y e a r old s o n w a s trying to help m e a n d th e o th e r children

g et aw ay, a n d all th re e of Mr. H arriso n s children (two from a n o th e r relationship a n d C J w ho
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w e h ad to g eth er) w e re hysterical a n d crying in th e c a r
Mr. H arrison w a s c h a rg e d with criminal
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d o m e sic violence, pled guilty, a n d on inform ation a n d belief h a s n ot y et co m p leted his required
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D om estic V iolence P e rp e tra to rs T re a tm e n t P rogram .

A s a re su lt of Mr. H a rriso n s p o o r p aren tin g in th e p a st, th e co u rt m a d e th e findings
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d is c u s s e d a b o v e a n d th e co u rt o rd e re d th a t C h risto p h e r H arriso n could only h a v e resid en tial
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tim e with C J with a n a p p ro v e d third party
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Mother ascertains Father has left or been dismissed unsuccessfully from treatment or
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incurs a criminal arrest, warrant, or charge after the date of this Parenting plan, in
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personal visits shall be suspended pending further court action.
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In addition, th e C o u rt specifically o rd e re d If
I h a v e no p ro o f of continuing s u c c e s s fu l tre a tm e n t.
I h a v e p e rs o n a l k n o w le d g e th a t th e fa th e r h a s b e e n c h a rg e d with a crim e
He h a s
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b e e n c h a rg e d with a violation of a d o m e stic v io len ce p ro tectio n o rd er. T h e fa th e r c o n sta n tly
Charlton v Harrison
S \CASES1\Char1ton, Jolene\Word\Pleadings\Declaratton of Jolene Charlton re
FAUBION, REEDER,
FRALEY & COOK, P.S.
TH
5 9 2 0 -1 0 0
Street SW, Ste 2 5
Lakewood, WA 9 8 4 9 9
2 5 3 -5 8 1 -0 6 6 0
'
13X9S
9& 13&
c o m p lain s th a t th e re is a n o c o n ta c t o rd e r in p la c e b e tw e e n u s (in th e crim inal c a s e th a t

2
re su lte d from his s e v e r e d o m e s tic v io len ce to w ard m e) a n d y e t a fte r o u r last court h e arin g
3
C h risto p h e r H arrison left c o u rt a n d w e n t directly to my h o u s e a n d b e g a n taking p ic tu re s a n d

4
talking to p e o p le a t m y h o u s e .
C h risto p h e r H arrison is a b so lu te ly a w a re th a t this c o n d u ct
w a s a violation of th e n o c o n ta c t ord er. At my h o u s e on th a t d a y C h risto p h e r H arrison a s k e d
w h e re is W ildo (m y h u s b a n d s n a m e is Will a n d C h risto p h e r H arriso n calls him W ildo to
d is p a ra g e him)
a b s o lu te violation of th e no c o n ta c t o rd e r an d it w a s totally u n n e c e s s a r y a n d u n re la ted in a n y
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w ay to visitation with C J.
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I re p o rte d Mr. H a rriso n s visit to my h o u s e to th e police b e c a u s e it w a s a n
H e w e n t th e re for no re a s o n o th e r th a n to h a r a s s m e a n d ta k e
p ic tu re s of m y h o u s e , y a rd a n d h u s b a n d s car. I frankly d o n ot know w hy h e w a n te d th e
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p ic tu re s of m y h o u s e , y a rd a n d h u s b a n d s c ar, but h e h a d ju s t b e e n in co u rt h o u rs b e fo re
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u sin g th e No C o n ta c t O rd e r a s a re a s o n w hy h e could n ot call C J directly. Y et only a few

14
h o u rs later h e actu ally s h o w s up in p e rs o n a t m y h o u s e
I h a v e n e v e r re p o rte d Mr H arrison
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to th e police for a n y in c id en tal c o n ta c t w hich m ay h a v e o c c u rre d w h e n it h a s b e e n re la ted to

16
C J a n d th e resid en tial s c h e d u le
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But on th a t d ay , h e w a s th e re so lely to h a r a s s m e a n d th e
th in g s h e said w hile h e w a s th e re w e re totally in ap p ro p riate.
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For all of th e s e re a s o n s , visitation sh o u ld b e p ro fessio n ally s u p e rv is e d a n d te le p h o n e
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c alls should b e m o n ito red by a n ad u lt in my h o u seh o ld
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N EW P R O B L E M S HAVE A R ISE N SIN C E ENTRY O F TH E PA R EN T IN G PLAN AND THE

A P P R O V E D PA R TY W H O IS S U P P O S E D TO BE P R E S E N T F O R VISITS IS NOT
PROVIDING A D E Q U A T E P R O T E C T IO N S
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In addition to th e a b o v e , th e following p ro b le m s h a v e a ris e n s in c e en try of th e prior

24
p aren tin g plan.

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Charlton v Harrison
S
\CASES1\Charlton, Joiene\Word\Pleadmgs\Declaration of Jolene Charlton re
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 - 1 0 0 TH Street SW, Ste 2 5
Lakewood, WA 9 8 4 9 9
2 5 3 -5 8 1 -0 6 6 0
4 '1 l'\ 2 8 ii
i3 5 %
1. C h risto p h e r H arriso n n e v e r c o m p le ted th e m a n d a to ry im p act on children s e m in a r

2
2. C h risto p h e r H arriso n h a s b e e n drinking a ro u n d th e child
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3. C h risto p h e r H arriso n h a s b e e n driving th e child e v e n th o u g h th e p aren tin g plan

d o e s n ot allow him to d o so .
4. C h risto p h e r H arriso n h a s b e e n talking n e g ativ ely (in a filthy totally in ap p ro p ria te
w ay) a b o u t m e a n d my s p o u s e in front of th e child.
A ly ssa H arriso n (C hris H arriso n s d a u g h te r) h a s told m e th a t C h risto p h e r
H arriso n calls m y s p o u s e , (Will C h arlto n ) W ildo th e D ildo in front of C J
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I fo u n d this o u t w h e n C J called m y h u s b a n d W ildo a n d w hile A lyssa w a s
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visiting a n d I a s k e d w h e re h e h ad h e a rd th at. A ly ssa told m e th a t w a s
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w h a t C hris called my h u s b a n d **
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A ly ssa a lso told m e th a t C h risto p h e r H arriso n h a s called m e C unt O n e
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a n d m y m o th e r C u n t T w o in front of C J **
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N O T E 1 **l d o n ot offer th e s e s ta te m e n ts for th e truth of th e m a tte r

a s s e r te d , b u t only for th e p u rp o s e of sh o w in g th a t th e w o rd s w e re
sp o k e n .
19
5. O n s e v e ra l o th e r o c c a s io n s C h risto p h e r H arrison h a s g o tte n violently a g g re s s iv e
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during th e child e x c h a n g e a n d th e a p p ro v e d p e rs o n w h o w a s s u p p o s e d to
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s u p e r v is e th e visits h a s s te p p e d o ut of line a s s h e yells o u t s w e a r w o rd s a n d calls
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u s filthy n a m e s from h er c a r w indow b efo re s p e e d in g off with th e child in h er c a r or
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left crying a n d u p s e t
6. My h u s b a n d a n d I h a v e w a tc h e d a s Mr. H arrison allow s th e child to g e t out of th e
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c a r a t th e g a s statio n a n d pu m p th e g a s into th e ir c a r
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadings\Dec!aration ofJofene Charlton re
In d isre g a rd for th e child's

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4/11/2811
X313&
38 I
s a fe ty th e a p p ro v e d p e rs o n w h o w a s s u p p o s e d to s u p e r v is e th e visits allow s th is
2
to h a p p e n w hile u n d e r h e r d ire c t su p erv isio n .

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7. T h e a p p ro v e d p e rs o n w ho w a s s u p p o s e d to s u p e r v is e th e visits h a s allow ed Mr
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H arriso n to ta k e C J, w ithout h e r b ein g p re s e n t, on th e b u s a n d on th e train to dow n
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tow n S e a ttle w h e re Mr H arrison le a v e s C J all d a y with s o m e w o m a n I d o not know
a n d h a s no t b e e n a p p ro v e d , w hile h e g o e s to w ork.
F or all of t h e s e r e a s o n s visitation sh o u ld b e s u s p e n d e d a n d only p ro fessionally
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su p e rv ise d visitation sh o u ld b e allow ed
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m onitored by an ad u lt in m y h o m e.
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P h o n e calls b e tw e e n C J a n d his fa th e r should a lso b e
SUPERVISED VISITATION AND THE GUARDIAN AD LITEM FEE SHOULD BE PAID BY

C h risto p h e r H arrison is m o re th a n $ 8 ,0 0 0 behind on child su p p o rt.
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n e v er paid a sin g le dollar in child su p p o rt for C J
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C h risto p h er H arriso n s n o n -p a y m e n t of su p p o rt
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good m oney
17
Mr. H arrison h a s
I h a v e b ro u g h t a m otion for co n tem p t for

C h risto p h e r H arrison is em p lo y ed a n d e a r n s
C h risto p h er H arrison s ta te d in o p e n court th a t h e m a k e s to o m u ch m o n ey to
qualify for a public d e fe n d e r th ro u g h th e D e p artm en t of A ssig n e d C o u n sel
18
B e c a u s e Mr. H arrison is m ore th a n $ 8 ,0 0 0 behind in child s u p p o rt a n d h a s m a d e no
19
attem p t to p ay this obligation, h e sh o u ld b e required to p ay all of th e G u ard ian ad Litem fe e s

20
and th e c o s t of su p e rv ise d visitation. I am willing to h a v e o n e -h a lf (50% ) of th e c o sts th at Mr.

21
H arrison p a y s for th e G u ard ian ad Litem to o p e ra te a s credit a g a in s t th e b ack child su p p o rt h e

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ow es.
S u p e rv ise d visitation c o s ts sh o u ld b e paid 100% by th e R e s p o n d e n t b e c a u s e it is his
m ental health is s u e s , p o o r p aren tin g , alcohol u se, n o n -co m p lian ce with th e court o rd e r and his
Charlton v Harrison
S \CASES1\Chartton, Jolene\Woni\Pleadmgs\DecIaration of Jolene Charlton re
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4-'
13196
9B23S
violations of the law that have required supervision at this time. All of these are preventable
2
problems but he fails to do so I am already shouldering 100% of the financial responsibility for
3
4
5
6
caring for this child on a day to day basis and Respondent should have to pay 100% of the
cost of supervised visitation which is required because of his own actions.
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Charlton v Harrison
S \CASES1\Charfton, Jolene\Word\Pleadings\Declaration of Jolene
Parenting Plan Modification docx
Charlton re
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 / i 1 /2 8 1 1
1313
3^148
Jt

COUNTY OF PIERCE
10
11
12
13
In re:
No. 08-3-00821-4

Child,
Respondents Notice of
Hearing for Adequate Cause
Determination
(NTHG)

an d
14
15

16
To the Clerk o f C ourt an d to Respondent, C hristopher Lee Harrison
18
P le a s e n o te th a t th e c o u rt will b e a s k e d to d e te rm in e if a d e q u a te c a u s e e x ists to
m odify/adjust th e c u sto d y d e c re e /p a re n tin g p la n /re sid en tia l s c h e d u le a s re q u e s te d
in th e petition filed in th is c a s e
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20
21
A h earin g h a s b e e n s e t for th e following d a te , tim e a n d p la c e

D ate:
P la c e:
22
T h u rs d a y M ay 12, 2011
9 2 0 T a c o m a A ve S , T a c o m a, WA 9 8 4 0 2
T im e 9*30 a m
R oom : TBD
23
3
24
This re q u e s t is b a s e d on th e d e cla ra tio n in th e P etition for M odification/A djustm ent

of C u sto d y D e c re e /P a re n tin g P la n /R esid en tial S c h e d u le a n d on th e additional
d e c la ra tio n s s e r v e d on th e nonm oving party
25
Petitioners Not o f Hrng (Adequate Cause) (NTHG) - Page 1 o f 2
WPF DRPSCU 07 0250 (6/2006) - RCW 26 09 260, 270, 26 10 200

Charlton v Harnson
S \CASES1\Chariton, JoIene\Word\Pleadmgs\Notice
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 ^ ii^ 2 8 il
1 3 1 9 >
S6141
> .
1
4.
You m a y s e r v e a n d file a r e s p o n s e a n d o p p o sin g d e c la ra tio n s prior to th e h earing

d a te . If th e c o u rt d e te r m in e s th a t a d e q u a te c a u s e for h e arin g th e petition is
e s ta b lis h e d by th e d e c la ra tio n s , it will s e t a d a te for h e arin g on a n o rd e r to sh o w
c a u s e w hy th e petition sh o u ld no t b e g ra n te d .
If you d o n ot file a r e s p o n s e to th e petition, o p p o sin g d e c la ra tio n s , or a no tice of

a p p e a ra n c e , a n o rd e r m a y b e e n te re d w ithout fu rth er n o tice to you finding you in
d efau lt a n d g ra n tin g th e relief re q u e s te d in th e petition
2
3
4
5
6
7
8
DATED th is
7th- d a y of April 2 0 1 1 .
FAUBION, R E E D E R , FRALEY
9
D aniel N. C ook, W SB A 3 4 8 6 6
A tto rn ey for P etitio n er/M o th er
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Petitioners Not o f Hrng (Adequate Cause) (NTHG) - Page 2 o f 2
WPF DRPSCU 07 0250 (6/2006) ~RCW 26 09 260, 270, 26 10 200

Charlton v Harrison
5
\CASES1\Cbariton, Jolenel Word\P!eadmgs\Notice of Hearing re Adequate Cause docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4 ^ I I ' 2 g i l
1 3 1 9 fc
3142
'N COUNTYFt i i R% S0FFlCE
AM.
APR 0 8 2011
PM..
IP S S S S ffiK !_C/erk
depu ty

COUNTY OF PIERCE
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11
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In re.
No. 08-3-00821-4

Child,
Ex Parte Restraining
Order/Order To Show Cause
(Parentage)
(TPROTSC/ORTSC)

an d
15
16
17

___________________ R e s p o n d e n t/F a th e r.
[] Clerks Action Required

Law Enforcement
notification, 4.1
R estrain in g O rd e r S u m m ary :
18
R estrain in g O rd e r S u m m a ry is s e t forth below
19
20
21
N am e of p e rs o n (s ) re s tra in e d ' C H R IS T O P H E R LEE H A R R ISO N

N am e of p e rs o n (s ) p ro te c te d : JO L E N E CHARLTON AND C H R IS T O P H E R LEE
H ARRISON, JR .
See paragraph 4.1____________________________________________________
22
23
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Violation o f a Restraining Order in Paragraph 4.1 below with actual knowledge of

its terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest RCW 26.26.590.
25
Ex Parte Restraining Order (TPROTSC/ORTSC) - Page 1 of 4

WPF PS 04 0170 Mandatory (6/2008) ~ CR 65(b), RCW 26 26 590
Charlton v Harrison
S \CA SES1\Chariton, Jolene\Word\Pleadings\Ex Parte Restraining Order docx
ORIGINAL

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
4/1 1/28 11
13196
9B143
I. Show Cause Order

2
3
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It is o rd e re d th a t C H R IS T O P H E R LEE HA RRISO N a p p e a r a n d sh o w c a u s e , if any, w hy

th e re stra in ts belo w s h o u ld n ot b e co n tin u ed in full fo rce a n d effe ct p en d in g final
d eterm in atio n of th is actio n a n d w hy th e o th e r relief, if an y , re q u e s te d in th e m otion
should n o t b e g ra n te d A h e a rin g h a s b e e n s e t for th e following d a te , tim e a n d place.
D ate.
P lace:
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T h u rs d a y M ay 12, 2011
9 2 0 T a c o m a A ve. S ., T a c o m a , WA 9 8 4 0 2
T im e 9:30 a m
R o o m TBD
If you disagree with any part of the motion, you must respond to the motion in
writing before the hearing and by the deadline for your county. At the hearing, the
court will consider Written sworn affidavits or declarations. Oral testimony may
Not be allowed. To respond you must: (1) file your documents with the court; (2)
provide a copy of those documents to the judge or commissioners staff; (3) serve
the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and
service of documents within the time period required by the local court rules in
effect in your county. If you need more information, you are advised to consult an
attorney or a courthouse facilitator.
Failure to appear m ay result in a Temporary Order being entered by the court

which grants the relief requested in the motion without further notice.
14
II. Basis
A m otion for a te m p o ra ry restrain in g o rd e r w ithout w ritten o r oral n o tice to
C H R IS T O P H E R LEE H A R R ISO N or th a t p arty s law yer h a s b e e n m a d e to th is court.
III. Findings
19
T h e court a d o p ts p a r a g r a p h s 2 1 ,2 2, a n d 2 4 of th e M otio n /D eclaratio n for a n Ex P a rte

R estrain in g O rd e r a n d for a n O rd e r to S h o w C a u s e (F orm W P F P S 0 4 01 5 0 ) a s its
findings, e x c e p t a s follow s:
20
IV. Order
18
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It is Ordered:
4.1
Restraining Order
Violation o f a Restraining Order in Paragraph 4.1 with actual notice of its

terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest. RCW 26.26.590.
D o e s n o t ap p ly
WPF PS 04 0170 Mandatory (6/2008) - CR 65(b), RCW 26 26 590
Charlton v Harrison
S \CA SES1\Chariton, Jolene\Word\Pleadmgs\Ex Parte Restraining Order docx

& COOK, P.S.
La kewood, WA 98499
253-581-0660
1 \ '':iv 1 5
1313b
3 S 14
1
2
3
4
5
6
Clerk's Action. T h e clerk of th e co u rt shall forw ard a co p y of th is ord er, o n o r b efore

th e n ex t judicial d ay , to (n a m e of th e a p p ro p ria te law e n fo rc e m e n t a g e n c y ) LESA
w hich sh all e n te r th is o rd e r into a n y c o m p u te r-b a s e d crim inal in tellig en ce sy ste m
av ailab le in th is s ta te u s e d by law e n fo rc e m e n t a g e n c ie s to list o u tsta n d in g
w a rra n ts (A law enforcement information sheet must be completed by the
party or the partys attorney and provided with this order before this order
will be entered into the law enforcement computer system )
Service
T h e re q u e stin g party m u st a rra n g e for serv ice of this o rd e r on th e re strain ed party
File th e original R etu rn of S erv ice with th e clerk an d provide a copy to th e law
e n fo rc e m e n t a g e n c y listed a b o v e
7
8
P u rsu a n t to 18 U S .C 22 6 5 , a court in a n y o f th e 50 s ta te s , th e District of

C olum bia, P u e rto Rico, an y United S ta te s territory, a n d a n y tribal land within th e
United S ta te s shall a cc o rd full faith a n d credit to th e order.
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4.2
13
Other Restraining Order

A s a u th o riz e d in th e J a n u a ry 25 , 2 0 1 0 , P a re n tin g P la n final o rd e r, the
re sid en tial tim e of C H R IS T O P H E R LEE H A RR ISO N is s u s p e n d e d
p e n d in g fu rth er o rd e r
14
15
T h e child sh all re s id e with JO L E N E C H ARLTO N until th e h e arin g and no

v isitation with fa th e r shall b e req u ired p e n d in g fu rth er o rd er.
16
17
18
4.3
Surrender of Deadly Weapons

D o e s not ap p ly
19
20
4.4
Expiration Date
21
T his o rd e r sh all e x p ire on th e h earin g d a te s e t forth ab o v e 0 4 4 -d ay srfto m th e
d a te of is s u a n c e , w hich e v e r is s o o n e r, a n d is h e re b y e x te n d e d by th e court.
22
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4.5
Waiver of Bond
24
D o e s no t ap p ly
25
WPF PS 04 0170 Mandatory (6/2008) - CR 65(b), RCW 26 26 590
Charlton v Harrison
S \CASES1\Chariton, Jolene \Word\PIeadtngs\Ex Parte Restraining Order docx

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
4S H S 2 B 1 1
1 3 i9 fc
9B145
E-FILED
April 12 2011 3:07 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
OECLARATSGn :COVERSHEET - Page 1of 1

Chariton v Harrison
Sr&ASESnCharfton,
C^' r / e go
FAUBION, REEDER.
FRALEY <kCOOK, P.S.
Lakewood, WA 3S49S
253-58T-0660
P&j<- 0 .)
MpriC i 2y 2011
To: Superior Court Of "Washington
Count of Tierce.
R egarding: JoCene. M arie (Harrison

M / 3C/S&. Jo fens M arie Char Cton
Tknd
C hristopher te e M ar risen
Mo, 08-3 -00821-4
To M ftmn I T M a y Concern:
1 am w orking v e r y tiggressivefkf w ith M r . and " Mrs.. "fWiCt
Chariton to -fin d them a florae, in M eridian, Idaho, I have

Been doing a g re a t d ea l o f w ork to f i n d them the rig h t
home w iin the' rig h t t etins for til em so the ho me w i Cifi t
th eir needs a n d the needs o f th eir fa m ily .
I f y ou h a ve a n y questions you w o u ld iie to askpLease

f eed free to c a d me.
Teg a y Jo rd a n
tAssoc, (Broker? Gr% Crs. & CSP
Group One T ea t (Estate
2 08 -371-3222
E-FILED
April 12 2011 3:59 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

P etitioner,
and

R e s p o n d e n t.
I, Sally D u C h arm e, am o v e r th e a g e of 18, a n d c o m p e te n t to testify in th e a b o v e
entitled c a s e .
O n April 12, 2 0 1 1 , I p la ce d in th e U .S. Mail a co p y of th e D eclaratio n of P e g g y J o rd a n
in th e a b o v e-en titled cap tio n .
S aid d o c u m e n ts w e re a d d r e s s e d to:
Christopher Harrison, 6721 Nathan Avenue
I d e c la re , u n d e r th e p en alty of perju ry a n d th e Law s of th e S ta te of W ash in g to n , th a t

th e foreg o in g is tru e a n d correct.
DATED
April 1 2 ,2 0 1 1
.,'SalTy D u G n arm e, Legal A s s is ta n t

Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\P!eadings\Declaration of Mailing, docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
E-FILED
April 13 2011 11:59 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
NO: 08-3-00821-4
Petitioner,
and
_____________________________ R esp o n d en t._________________________________
The undersigned states that I am a citizen of the United States and of the State of Washington, over the
age of eighteen years, not a party to the above entitled action, competent to be a witness therein, and
was at all times herein mention. I effected service as indicated below:
[a] Number of copies served: O ne(l)
[b] Title o f Papers served: Ex Parte Restraining Order 4/18/11, Note for Commissioners Calendar
on 5/2/11 re: Adequate Cause, Motion/Declaration for Ex Parte Restraining Order, Note for
Commissioners Calendar re: Temporary Order, Summons, Petition for Modifrcation/Adjustment o f
Custody Decree/Parenting Plan, Notice re: Military Dependent, Declaration o f Jolene Harrison,
Proposed Parenting Plan, Declaration o f Jordan Sherwood, Declaration o f Tyler Flohr, Order
Amending Case Schedule and Sealed Personal Healthcare Records.
[c] Date and Time o f Delivery:
April 10,2011 at 7:00 P.M.
[d] Person (s) to be Served:
[c] Place o f Delivery:
DECLARATION O F SERVICE
Page 1
6721 Nathan Ave. SE

Auburn, WA 98092
Service was made pursuant to Civil Rule 4(d)
[ X] By delivery to the person(s) named in paragraph (d)

[ ] By delivery to
usual abode.
, a person o f suitable age and discretion residing at the defendants
Signed at LAKEWOOD, WASHINGTON, on April 12,2011.
FLAAEN, #9270
FEES: Service $10.00 Rush: $00.00 Miles: $105.60 Misc: $14.00 TOTAL: $129.60
Page 2
E-FILED
April 15 2011 9:44 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and

Respondent.
'
............ -
........................
.............................. ....
Name: _________ _ _ _____________________ Age:

Relationship to PariyOes):_________________ ____
i THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS
CORRECT.
jf"~\
Signed at (city)
y ic U fs G -
(state) .. L. i .-bn (date)
4 _
1 .. *
v ----
Signature V':Y
DECLARATION COVERSHEET - Page 1 o! 1
Chariton v Harrison
S:\CASES1\Chamon, Jolene\Word\Pleadings\DeclaralionCoYersbeet.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98493
253-58
Daniel Cook
From:
Sent:
To:
Subject:
Wifi Charlton [willcharlton74@gmail.com]

Monday, April 11,2011 7:02 AM
Daniel Cook; Jolene Charlton
Fwd: kimberly idaho
Dan,
Here is the letter from D an that shows that m uch o f my belongings are in his possession currently awaiting my
return.
Will
-----------Forwarded m e ssag e-----------From: A lan Floyd <alanfloyd66@ m sn.com >
Date: M on, A pr 11, 2011 at 6:45 AM
Subject: kim berly Idaho
To: will charlton <w illcharlton74 @ gm ail.com>
To whom it may concern,

I met W ill Charlton the fall o f 2008 and w orked w ith him on various projects all through 2009 while
he lived in kim berly idaho. I am currently storing W ills possesions opon returning to idaho, any questions
please call me.
A lan Floyd
6208^539-1624

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION RE
SIGNATURE ON EMAILED
DOCUMENT

_______________________ Respondent.
I, Sally DuCharme, declare under penalty of perjury that the foregoing faxed
document(s) attached to this DECLARATION OF ALAN FLOYD, which consists of 3 pages
including this declaration page (but not including attachments), is a complete and legible
image that I have examined personally and that was received by me via email and
sducharme@fjr-law.com
Signed at Lakewood, W A on April 15, 2011.
J J -y
\/~W< A.
^ S a lly D u d w m e , Legal Assistant
DECL re EMAIL SIGNATURE - Page 1 o f 1
Charlton v Harrison
S:\CASES1\Charlton, JoIene\Word\Pleadings\Declaration re Email Signature.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
12845
u p e r io r
4^15^2011
180B3S
o u r t
o f the
St a
08-3-00821-4
36228583
LTR18
04-15-11
te o f
fo r
a s h in g t o n
ie r c e
o u n ty
SU PER IO R C O U R T
(253) 798-6650
334 C O U N TY-CIT Y BUILDING

930 T A C O M A A V E N U E SOUTH
TA CO M A , W A 98402-2108
April 14,2011
Dear Counsel/Litigant:
This is to confirm the following settlement conference:
Case:
Cause No.:
Before:
Date & Time:
JOLENE MARIE HARRISON VS.

08-3*00821-4
Judge BEVERLY GRANT
County-City Bldg, courtroom 202-A
July 28. 2011 at 8:15AM
The court requires all parties to:

1.
Be personally present unless excused by the Judge;
2.
Deliver the pretrial information and any supplemental information to the

department conducting the settlement conference at least two business days
before the settlement conference: and
3,
Be fully prepared, with all discovery matters completed.
Please remember that failure to supply the settlement judge with appropriate forms in a timely
manner may result in the imposition of sanctions. For complete information regarding settlement
conferences, please refer to the Pierce County Local Rules.
Sincen
J '.
Tonya S. Md
Judicial Assistant
CC:
Pierce County Clerk for Filing

Daniel Cook
TC * Jl J ' ' jJ,u j a
08-3^00821-4
36246545
^ 'Z T / J.
t)
AFR5P
IN COUNTY CL^K'S OFFICE
AM.
'APR19 m
PM
d ep u ty

County of
In re:
N.K.A. Jolene Marie Charlton
No. 08-3-00821-4
Petitioners),
and
Declaration of
_Christopher Harrison
(Optional Use)
Respondents), (DCLR)

Name:
Age:
^Christopher Lee Harrison___________________________________ _

40
____________
Respondent______________________________ ________________ _ __
/ Declare:
I was told to keep this to 10 pages so 1 will not go on to 57 pages like Jolene filed. This is suposed to be about my son and I
missing our visits together, but it has turned in to a mud slinging war. 1 feel that Jolene has brought up all these other things to
distract from the matter at hand. She clearly took matters into her own hands, changed the parenting plan, and denied my visits
with my son for no good reason.She states she told me a head o f time? No wav! Neither mv girlfriend or 1 have had a
conversation with Jolene for 2 years. And why would I give up half of mv monthly time with mv son? No way! I knew her
vacation was coming up. but I did not know the date. The only wav I knew about it because mv son talked about it. He was 5.
Jolene has brought up other things that did not bother her, until AFTER I filed for contempt. I will not sling mud, or do any
charcter bashing, there has been enough of that and it distracts from the matter at hand. During all these proceedings I have
beenn granted access to my sons grades and attendence. These are 2 valid issues that need to be addressed, because I am afraid if
they are not mv son will be left behind when his class goes on to 1st grade. To date he has missed 11 days and beed late 17 times!
Lmst dont understand that, when he only live 2 houses awav from school. If you read the teachers notes 1think they speak for
themselves. Ci is a smart kid but hes not being given the chance to thrive! I would hate to see Ci be put into remedial classes, like
Jolenes other kids. He need more than just video pames. I had been working with Ci during our visits and he was doing great! But
now his after hours has come to a halt and Ci desperatly needs it. All I want is for mv son to do well in school, and to be able to
see him on mv bi-weeklv visits. When I filed contempt against Jolene I never would have thought it would have blown up into
this. Ci is the the one that getting the worst out of all this, not only does he not get to see his father, but he also loses his tutoring
seccions.
I declare under penalty o f peijury under the laws of the state o f Washington that the foregoing is true and correct.
Signed at
Signature o f Dec!
_____________, [City]
h / A
______ [State] on
/ / ________ [Date].
fa ts
Print or Type Name
these cover sheets:
If filed separately using a coversheet, the records will be sealed to protect your privacy (although
Skyward Family Access
ll
^ 3 3 P a g e 3 lr f ^ ;
Student: CHRISTOPHER L. HARRISON
Grades I Progress Report |

Classes for: THIRD TRIMESTER (03/05/11-06/21/11)
View All Passes
Course: M US000 / 13 K M USIC
Teacher: 3 M CKINLEY
T1
Academ ic Area
M usic
Actively contributes to dass activities
P hysical Education
Effort
Teacher: D W EBER
T1
Skilts/Rtness
3
3
Sportsmanship
Course: KND050 / 03 KINDERGARTEN PT

Academic Area
Course: PE DO00 / 13 K PE
A cadem ic Area
T3
T2
T3
T2
3
3
3
Teacher: L MALONEY
T1
T2
T3
Reading
2
1
1
2
NA
NA
3
3
2
2
NA
NA
1
1
Demonstrates understanding of core content

Uses reasoning to solve problems
Communicates math knowledge and understanding
Social Studies
2
NA
NA
2
NA
2
Demonstrates an understanding of content knowledge

Writing
Writes own name
Uses words and pictures to express ideas related to one topic

Uses words in sentences
Uses detail and color in drawings
3
NA
2
2
2
1
ID's 80% of letters taught

Gives sounds for 80% of letters taught
Rhymes - recognizes rhyming words
Recognizes 80% of grade level sight words taught
Retells details by sequence, picture, or verbal response
Predicts what will happen next In a story
Decodes (sounds out words)
Blends (orally combines word parts to recognize new words)
Math
Writes left to right and top to bottom

Writes tetters reasonably dose to one another
Leaves spaces between words
Spells some high frequency one- to threeHetter words
Uses beginning and ending sounds to write words
Capitalizes first letter In first and last name
Capitalizes pronoun T
Writes with both upper and lower racp letters
Uses end marks
Sddnce
Demonstrates an understanding of content knowledge
Begins to follow the scientific inquiry process
2
NA
2
NA
NA
NA
NA
3
2
3
2
2
3
2
3
NA
NA
NA
3
2
3
NA
3
NA
https://www2.nwrdc.wa-k! 2.net/scripts/cgiip.exe/WService=wsumiiers71/sfwgrdO 1.wTTSÔ 3/31 /2 0 11
3^1
333P ^ge 2 < * 2 3 i
Develops observation stalls

Fine Motor
Uses effective pencil grip
2
2
2
2
3
Forms upper case and lower case letters correctly

Cutting Skills
Self Directed Learner
Works independently
Follows directions
Completes work on time
Stays on task
Begins to develop organizational skills
Completes and returns homework
Takes responsibility for own actions
Collaborative Worker
Works well with others
Cooperates with adults
Respects nghts and property of others
Practices self-control
Community Contributor
Participates in dass activities
Actively contributes to group projects
Takes initiative to help others
Cares for classroom and school environment
Quality Producer
Demonstrates accuracy
Produces neat work
Effective Communicator
earty communicates ideas
Contributes to discussion
Offers and accepts appropriate feedback
Complex Thinker
Self-assesses
Willingness to take risks
3
3
2
NA
2
j _____
2
2
3
2
2
1
3
3
3
3
2
3
3
3
2
3
3
3
3
2
2
2
2
2
2
NA
3
3
NA
NA
NA
NA
2
3
3
3
https://www2.nwrdc.wa-k! 2. net/scripts/cgiip.exe/WService=wsumners71/sfwgrd01.w?TS=0 3/31/2011
Grades
Class
Comments
D escrip tion
Com m ent
Grade Com m ents fo r Term 2 (1 1 /2 4 /2 0 1 0 - 0 3 /0 4 /2 0 1 1 )

KND050/03
KINDERGARTEN PT
c l's academic progress has been steady this trimester. His Kindergarten Literacy t
from 35% to 64%. This is a significant increase, but needs to reach 80% by June
reading. CTs frequent absences and tardies may hinder his academic progress, as
instruction. CJ is very good at verbalizing ideas, but struggles to get his ideas on j
pictures. How can you help at home? Writing: draw dear, detailed pictures with o
sentence about his drawings using beginnfng/ending sounds, leave space betweer
FORMATlON/neatness. Reading: producing rhyming words, identifying ail 26 krwe
sounds they make, sounding out three letter words (EX: cat, wig, pet), predicting
story, IDENTIFYING SIGHT-WORDS, read/lfsten to stories. Math: identify random
100, write numbers to 31, COUNT OBJECTS TO 31. Completing and returning hon
appreciate the work you do at home to help CJ. Hes a groat kid and fm glad he i
Grade Com m ent? fo r Term 1 (0 9 /0 7 /2 0 1 0 - 1 1 /2 3 /2 0 1 0 )

KND050/03
KINDERGARTEN PT
I am enjoying having CJ in my dassroom this year* CJ is progressing academically

home support with several skills to meet grade level expectations. CJ needs to lea
alphabet, the sound each tetter makes and rhyming. These are such important ski
writing progress' He also needs to be able to road the sight words that have been
home is needed! In writing, I'd like CJ to focus on: adding detaiis/color to his picti
his picture using beginning/ending sounds and proper letter/number formation. Y<
pay better attention during instructional times. He tends to be too social at times,
listening. CJ often rushes through his work, which doesn't reflect his ability. I look
academic and social growth for CJ. Completing and returning weekly homework vs
learning It is vital for us to work together to help CJ have the best Kindergarten t
https://www2.nwrdc.wa-kl2.net/scripts/cgiip.exe/WServicewsumncrs 71 /sfwgrd04.w
3/31/2011
Attendance
{By Day |
Date
Parent N otified
01
02
04/15/11
Fri
Yes
T-
03/24/11
Thur
No
T-
03/18/11
Fn
No
T-
03/11/11
Fri
Yes
E-HF
03/10/11
Thur
No
T-
02/25/11
Fri
Yes
E-HS
02/04/11
Fn
No
L-
01/28/11
Fri
Yes
E-ON E-ON
01/27/11
Thur
Yes
E-HO E-HO
01/21/11
Fri
Yes
T-
01/20/11
Thur
No
T-
01/14/11
Fri
No
T-
01/13/11
Thur
No
T-
01/06/11
Thur
Yes
T-
12/17/10
Fri
Yes
E-FM
E-FM
12/16/10
Thur
Yes
E-FM
E-FM
12/ 10/10
Fri
Yes
E'FM
E-FM
12/09/10
Thur
Yes
E-FM
E-FM
12/08/10
Wed
Yes
E'FM
E-FM
12/02/10
Thur
No
L'
11/19/10
Fri
No
T*
11/05/10
Fri
No
L-
11/04/10
Thur
No
L-
11/03/10
Wed
No
E-FM
10/21/10
Thur
Yes
T-
Yes
E-HC
10/14/10
Thur
10/13/10
Wed
Yes
T-
09/30/10
Thur
Yes
T-
Absence Codes
E-HF
E-HS
E-FM
E-HC
Absence Reasons
AA ALTTH AB
AN AB NOT AUTH
a CRT LEGAL
ED EARLY DIS
EE EM EXPUL
FM FAM PERSON
FT FIELD TRIP
HA ASTHMA
HB HOME BOUND
HC COLD
HD DENTAL CON/APP
HF FLU
HH HEADACHE
A.
___
https://www2.nwrdc.wa-kl2.net/scripts/cgiip.exe/WService=wsumners71/sfwatt03.w?TS=... 3/31/2011
08-3-00821-4
36246546
DCLR
hjl
*0
04-19-11
IN COUNTV CORK'S OFFICE

a m.
APR1 9
2011
PM
y m g s s w p i
( ------- deputy

County of
In re:
N.K.A. Jolene Marie Charlton
No. 08-00821-4
Petitioners),
and
Declaration of
Charlotte Pergrim

Respondents).
(Optional Use)
(DCLR)

Name:
Charlotte Pergrim
Age;
39
Relationship to the parties in this action: I am Christopher Harrrison's domestic partner o f 2+ years.
/ Declare:
My name i s .
My relationship with Jolene has been nothing less than difficult since day one. She has judged me, called me
names and slandered me before ever meeting me.
After Jolene's many repeated violations and complete disregard for the parenting plan, withholding visits
between CJ and his dad, continously restricting and controlling their phone visits the bare minimum o f an
averge o f 1 - 2 calls per week (if lucky), Chris decided that he needed to step up for his son because both of their
rights as father & son are not only being violated, but also manipulated by a person who has a history o f
compromising her kids and the relationships they have with their fathers for the next best thing, the newest man
in her life.
I could sit here and give a 75+ page account o f our negative dealings with her and her 3rd husband, William
Charlton, as Jolene has. We have had to deal with their combative, selfish, non-compliant, untouchable, "above
all" actions.
* s -h o s r? a i -i
T ' J,
This is supposed to be about CJ. Not about Jolene. Jolene has turned this into a witch hunt and a charachter
assasination against myself and Chris to divert the attention from herself. She has told lie after lie, fabricated
stories and made things up based on bits and peices o f what she thinks she knows. I could in turn tell story after
story about Jolene, her actions and choices she has made, both before & after she met her 3rd husband, William
Charlton. Jolene is not perfect and she is not a perfect mother. Jolene's 3rd husband, William Charlton falls
under the same category. And their family life is less than perfect...Far from it
I am going hold back from writing a novel and touch on just a few basic facts here. Just a few of the many.
William Charlton has layed his hands Jolene's children, more than once, as have her boyfriends past. One man
in particular, Scott, a man that she dated in between Chris and William, threw CJ against her headboard because
CJ got into bed with them and left a bruise on CJ's forehead. What did Jolene do about it? Nothing. She called
her friend several days later and asked her for advice becase she didn't know what to do about it. Her friend
personally told both me and Chris about this several months after it had happened. Jolene's parenting skills are
questionable, at best.
Jolene left all the kids home alone night after night, forcing Alyssa to be the "mother figure" making her do all
the cooking, cleaning and laundry because Jolene was not conning home until 3 - 4 am, and after finally coming
home, Jolene calling both mine and Chris's phones at all hours o f the night, night after night...calling us,
harrasing us and telling Chris on speaker to "TELL CHAR" this and "TELL CHAR" that...whatever she was
mad about at the moment Jolene made CJ call to both o f us several nights per week between the hours o f 1 - 4
am, and when I texted her back on several occaions in the morning to check on CJ she told me that CJ called on
his own and she had no idea he was calling us. What 4 or 5 year old knows not only his dad's cell number, but
also his dad's girlfriend's number and how to dial it on his own? And what 4 or 5 year old is up at these hours
anyways?
Jolene has no problem confronting us or getting in our faces when it suits her, even after we have asked and told
her and her husband repeatedly not to do so. MARCH 25, 2011, Jolene did not show up at the gas station at 8:00
pm to drop CJ off. When I called her at 8:13 to ask her if she was coming, so apologized profusely..over and
over, stating that she "spaced it out" not to keep waiting and that she would bring C J to our house in a few
minutes. She showed up at 9:08 pm and when her daughter Hannah brought CJ to the door she told Chris "My
mom said she's so sorry, she totally spaced it out." Several things wrong here. She failed to deliver C J at the
appointed time and place. The restraining order only goes one way? She has come to our door many times. Both
expected and unexpected. She is exempt from odibing by it and her harrassing US because she plays the victim
in evey scenreo? She is obviously not afraid to come to our house or knock our door, because she has pulled into
our driveway and knocked on our door many times. She had to drop CJ off on March 25th because she "spaced
out" her son's visit with his dad, yet if she is so afraid of Chris why did she send her underage daughter to our
door? And lastly, Chris missed out on one hour and 8 minutes o f time with his son and at 4 days a month every
hour counts. If it were us andf we had dropped CJ off over an hour late she would throw a fit. So this should go
both ways.
Jolene thinks that she is entitled to know every detail o f our lives, yet she flat out refuses to disclose to Chris
why her 3rd husband, William Robert Charlton, has been stripped o f all his parental rights for his own children,
K J and Austin. This is a private case, we think out o f Arizona, and is not public record. Chris's son lives in the
same house as this man and he has every right to know who his son is residing and living with, what type of
person he is and why he isn't allowed to have contact with his own children. Chris is entitled to know that his
son in a safe environement.
This is a man, who up until May o f 2009, was a stranger to Jolene when she married him. Jolene met William
Robert Charlton in late May 2009 and married him, her third husband, on August 1st, 2009.
Chris and myself are not bad people. We don't do bad things. We live your average life of working hard daily
and spending what little spare time we have with our families. We both love CJ very much and this is who this
about. The 4 days a month that we get to spend with CJ & the 1 or 2 phone calls that she (still') allows per week
are priceless, yet she still picks and choses when it is convienent for her. How is keeping CJ from his father
whom he is very close with benefiting him? It's benefiting only one person, and that is herself. Jolene has a new
husband so she thinks that means she has a new dad for CJ. Jolene is asking the courts to help facilitate her in
commuting to alienate CJ from his father.. That is obsurd. Her pattern is reckless and irresponsible.
I told Jolene a long time ago that there are so many forgotten and left behind kids out there that would do
anything to have a dad,or even a mother for that fact, that actually cared so much about them and that she should
be ashamed o f herself for thinking that her newest husband should take the place o f CJ's father, is going to love
CJ as much as Chris loves him. Her son actually has a father that cares for him, loves him, spends time with
him, and would do anything for him . Most o f the time all CJ wants to do is play video games and watch tv, and
even gets upset when we give him boundaries because he has none at home. At times we have to tell him NO on
the games and movies so that we can focus on his alphabet, matching or counting. Jolene doesnt even realize
how fortunate she is that her son has that parent in his life that cares so much about him. When I expressed my
concerns to both Jolene and William Charlton about CJ being behind where he should be in counting and the
alphabet and his colors and not being prepared for Kindergarten (he could barely count to 4 when he started
Kidergarten or say A B C with out mesing up his alphabet) they both had the gall to "explain to me that its a
proven scientific fact children who aren't "smart" get it from their dads.
Her aggresive response, her lies and her vindictive actions of retliation and false statements against both o f us
because o f Chris's right to see and talk to his son have been violated and his request from the courts to hold her
accountable for her wrong doings is charachter harassment against both o f us and she should be held
accountable for that as well. Jolene Jepson Flohr Harrison Charlton is no angel herself. She has chosen to clog
this whole thing with obstruction and has lost sight o f what and who this is really about.
I declare under penalty of peijuiy under the laws of the state of Washington that the foregoing is true and correct.
Signed at
'A
^ [City]
lO H
[State] on
H / i S l z*t(
[Date].
(L .
Signature of Declararit-)
Print or Type Name
these cover sheets:
COURT OF THE STATE OF WASHI

AND FOR PIERCE COUNTY
No 08-3-00821-4

Petitioner(s),
Memorandum o f Journal Entry
vs
Show Cause
(ADM02)
Respondent(s)
O a / \ u iiL - ( W
For Petitioner
RE C l d a r u i o d j L C j C u w L
April 20, 2011 9:30 AM
Jh n
.V
For Respondent
C m
ijA 'u p J y

WENDY ELLEN ZICHT
T . 4 I AM
Clerk
Run dale/time 04/20m 9 18
txcrtrpt pbl djoumal_entry_showcause_report
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
April 20 2011
1
KEVIN S
COUNTY
2
3
4
5
6
7
8
9
P etitioner(s),
10
Cause No. 08-3-00821-4

O rder Denying
Adequate Cause
vs.
11
12
Respondent(s)
C lerks Filing code: ORADE
13
14
15
16
proceed to trial with regard to a Petition which has been filed.
17
18
ORDERED the Show Cause hearing determining Adequate Cause is denied.
19
20
21
22
Dated this 20 day o f A p ril, 2011
23
24
25
Judge/Commissioner
2
3
08-3-00821-4
36255450
ORSC
04-20-11
FILED
am .
APR
20
^WASHINGTON
, BOUftty Clerk
pi
2011
BY.
deputy
Lf
a
COUNTY OF PIERCE
10
In re:
No. 08-3-00821-4
11

Order on Show Cause re

Contempt/Judgment
(ORCN)
Next Hearing Date:
12
Petitioner,
and
13

Respondent
14
[ ] Clerks Action Required, <j|

3.8
15
I. Judgment Summary
16
17
18
19
20
21
22
Applies as follows:
A.
B
C
D.
E.
F.
G.
H.
23
24
25
J
K
L
JO LEN E CH A R LTO N
Judgment creditor
C H R IS T O P H E R HARRISON
Judgment debtor
Principal judgment amount (back child support/medical support/other obligations/
maintenance) from (date) Oct 2008 through (date) Mar 2011 $8,232 52
Interest to date of judgment
$1,234 48
Attorney fees
$1,000.00
Costs
$75 00
Other recovery amount
$ ________________
Principal judgment shall bear interest at 12% per annum
Attorney fees, costs and other recovery amounts shall bear interest at 12% per
annum
Attorney for judgment creditor
Daniel N Cook________________
Attorney for judgment debtor
Christopher Harrison, Pro Se
Other:
Ord on Show Cause re Cntm pt/Jdgm nt (ORCN) - Page 1 of 6

WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09 160, 7 21 010
Charlton v Harrison
S \CASES1\Char1ton, Jolene\Word\Pleadmgs\Order on Our Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
El. Findings and Conclusions
This Court Finds:
2.1
Compliance With Court Order
2.2
CHRISTOPHER LEE HARRISON 4 g g ^ s f l y failed to cohapty with the Order/cf

Child Support signed by the court on October 17, 2008, in Pierce County,
t w i n JU ucl
^
Nature of Order
v*
t)
*
H
d j j l r y r f ztt t h j u & h w l t *
The order is related to child support
2.3
How the Order was Violated

This order was violated in the following manner (include dates and times, and
amounts, if any).
x
2.4
CHRISTOPHER HARRISON did not pay the order child support in the
amount of $8,232 52 plus $1,234 48 interest and $75 (est.) posts for the ^
period from October2008 through March 201L h < A *7? A
Past Ability to Comply With Order p
J j L
l n a j t fee
CHRISTOPHER HARRISON did havee the ability to comply with the order a
follows:
CHRISTOPHER HARRISON was employed and was able to pay support
for his child
2.5
Present Ability and Willingness to Comply With Order

CHRISTOPHER HARRISON does have the present ability to comply with
the order as follows
CHRISTOPHER HARRISON is employed and was able to pay
support for his child.
A
mf)'/
CHRISTOPHER HARRISON ctgpga&t have the present willingness to
comply with the order as follows:
^
/
OC
^ iP ^ ^ H R IS T O P H E R HARRISON-rcfusocrtB^ support for his child
Ord on Show Cause re Cntm pt/Jdgm nt (ORCN) - Page 2 o f 6

WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09 160; 7 21 010
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pieadmgs\Order on Our Contempt Motion doex
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
/
o
2.6
Back Child Support/Medical Support/Other Unpaid Obligations/Maintenance

C H R IS O P H E R HA RR ISO N failed to pay the other party the sum of
$8,232.52 for child support and interest to date in the amount of $ $ 1 ,234 48
for the period from October 2008 through March 2011.
2.7
Compliance With Parenting Plan

Does not apply
2.8

The attorney fees and costs awarded in paragraph 3.7 below have been incurred
and are reasonable
III. Order and Judgment
it is Ordered:
3.1
Contempt Ruling
C H R IS T O P H E R LEE H A R R IS O
3.2
rntempt of
c o l
Imprisonment
Does not apply.
3.3
Additional Residential Time

Does not apply.
3.4
Judgment for Past Child Support

JO LEN E CH AR LTO N shall have judgment against C H R IS TO P H E R HA RR ISO N in
the amount of $ $8,232.52 for unpaid child support arrearages and $1,234 48
interest and $75 (est.) costs thereon for the period from (date) October 2008
through (date) March 2011.
3.5
Judgment for Past Medical Support

Does not apply.
Ord on Show Cause re Cntm pt/Jdgm nt (ORCN) - Page 3 of 6
WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09 160,7 21 010

Charlton v Harrison
S \CASES1\Chariton,
Jolene\Word\PIeadinga\Order on Our Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste
Lakewood, WA 98499
253-581-0660
3.6
Judgment for Other Unpaid Obligations

Does not apply
3.7
Judgment for Past Maintenance

Does not apply.
3.8
Conditions for Purging the Contempt
&
[]
3.9
Does not apply.

The contemnor may purge the contempt as follows1

JO LENE C H A R LETO N shall have judgment against C H R IS T O P H E R HA RR ISO N
in the amount of $ 1,000 for attorney fees
3.10
Review Date
W
[j
Does not apply.

The court shall review this matter on (date)
at (time)
3.11
Other
3.12

This is a summary only For the full text, please see R C W 26 09 430 through
26.09.480.
If the person with whom the child resides a majority of the time plans to move,
that person shall give notice to every person entitled to court ordered time with
the child
If the move is outside the childs school district, the relocating person must give
notice by personal service or by mail requiring a return receipt. This notice must
be at least 60 days before the intended move If the relocating person could not
have known about the move in time to give 60 days notice, that person must
WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW26 09 160, 7 21 010

Charlton v Harrison
S \CASES1\Chartton, Jolene\Word\Pleadtngs\Order on Our Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste
Lakewood, WA 98499
253-581-0660
give notice within 5 days after learning of the move. The notice must contain the
information required in R C W 26.09.44 0. See also form D R P S C U 07 0500,
(Notice of Intended Relocation of A Child).
If the move is within the sam e school district, the relocating person must provide
actual notice by any reasonable means. A person entitled to time with the child
may not object to the move but may ask for modification under R C W 26 09.260.
violence shelter or is moving to avoid a clear, immediate and unreasonable risk
to health and safety.
If information is protected under a court order or the address confidentiality
program, it may be withheld from the notice.
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.
schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection to
the childs relocation whether or not he or she received proper notice
An objection may be filed by using the mandatory pattern form W P F DR PSC U
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.
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.
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.
W arning : 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 R C W
9A.40 060(2) or 9A .40.070(2) Violation of this order m&v subject aj/iolertor to arrest
Dated.
___ OW
/
f i ________
JUtftje/C
AUBION, REEDER,
ALEY & COOK, P.S.
Charlton v Harrison
ADD

S \CASES1\Chariton, Jolene\Word\Pleadmgs\Order on Our Contempt
dqftrK 2 0 t u l l
RâkewOOd, WA 98499
_____
253-581-0660
Ord on Show Cause re Cntm pt/Jdgm nt (ORCN) - Page
WPF DRPSCU 05.0200 Mandatory (10/2009) - RCW 26 01
BY__________ _________ DEPUTY
, t rS o
-j -7 7
;..s < J
l..*
2
3
4
Presented by:
FA U B IO N , R E E D E R , FRALEY,
& CO O K, P.S
Approved by.
By: DANIEL N CO O K, W S B A #3 4 8 6 6
Christopher L Harrison, Respondent

Pro Se
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WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09.160, 7 21 010

Charlton v Harrison
S \CASESi\Char1ton, Jolene\Worcf\PIeadings\Order on Our Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
i.
C'
2.3
How the Order was Violated
2
The order was not violated.
3
4
2.4
Does not apply.
5
6
2.5
2.6
9
10
Back Child Support/Medica! Support/Other Unpaid Obligations/Maintenance

Does not apply.
2.7
11
Compliance With Parenting Plan

JO LEN E CH A R LTO N has complied, and is currently willing to comply, with the
parenting plan.
12
13
Present Ability and Willingness to Comply With Order

Does not apply
7
8
Past Ability to Comply With Order
2.8
14

Does not apply
15
III. Order and Judgment
16
17
18
It is Ordered:
3.1
19
20
Pt
JO LENE CH AR LTO N [ ^ ^ i s not in contempt of court.
3.2
21
22
Contempt Ruling
Imprisonment
Does not apply.
3.3
Additional Residential Time

Does not apply.
3.4
Judgment for Past Child Support

Does not apply.
Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 2 of 5
WPF DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09 160, 7 21 010

Charlton v Harrison
S \CASES1\Charlton, Jotene\Word\Pleadmgs\Order on Their Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
4/21
'28X1
^ ^
1
2
3.5
3
4
Judgment for Past Medical Support

Does not apply.
3.6
Judgment for Other Unpaid Obligations

Does not apply.
3.7
Judgment for Past Maintenance
Does not apply

8
3.8
Conditions for Purging the Contempt
Does not apply.
10
11
3.9
Does not apply.
12
13
3.10
14
1$
Review Date
Does not apply.
3.11
0 ^
p e a u to t
Other
NOT 7 7 ) ^
16
17
18
19
20
21
22
23
24
25
V
r &ft-OQ
oof aF
3.12
F- / -
Pj\P~ /YlUOfh / fc V T // (/'
y-
&
ee iZ 'e s T & ) 8 y V > 7 ^
/c . A
flu tte r ?
This is a summary only For the full text, please see R C W 26.09 430 t h r o u g h ^ ^ J ^ ^
26.09.480
/zeU?C&C0>
the child
notice by personal service or by mail requiring a return receipt This notice must
be at least 60 days before the intended move. If the relocating person could not
information required in R C W 26.09.440. See also form D R P S C U 07 0500,
WPP DRPSCU 05 0200 Mandatory (10/2009) - RCW 26 09 160f 7 21 010
Charlton v Harrison
S \CASES1\Charfton, Jolene\Word\Pteadmgs\Order on Their Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
If the move is within the same school district, the relocating person must provide
may not object to the move but may ask for modification under R C W 26.09.260.
Notice m ay be delayed for 21 days if the relocating person is entering a domestic
program, it may be withheld from the notice.
put the health and safety of a person or a child at risk
contempt
schedule m ay be confirmed.
the childs relocation whether or not he or she received proper notice
An objection may be filed by using the mandatory pattern form W P F DR PSC U
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
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move
W arning : 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.
arrest.
Dated
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadings\Order on Their Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
* " i- W i i
1
2
Presented by:
& COOK, P S.
Approved by:
By DANIEL N. C O O K , W S B A #34 866

Ctatierfbpner L Harrison, Respondent

Pro Se
3
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7
8
9
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12
13
14
15
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22
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25
WPP DRPSCU 05 0200 Mandatory (10/2009) - RCW26 09 160, 7 21 010
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pieadtngs\Order on Their Contempt Motion docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
^ i f
3
ORDAC
08-3-00821-4
i.
4. ,
04-20-11
35255452
am.
APR 2 0 2g^
6
a^tyC/ertT
~ OEPUry
a
COUNTY OF PIERCE
9
10
In re:
11

12
No. 08-3-00821-4
Petitioner,
and
13

Respondent
14
15
16
17
I. Basis
11
A petition requesting the modification/adjustment of the custody decree/parenting

plan/residential schedule in this matter has been presented to the court.
1.2
A hearing w as held on-folatcU-22, 201
18
19
Order re Adequate Cause

(Modification/Adjustment of
Plan/Residential Schedule)
E* Denied (O R R A C D )^ 70S S S t i f f i ,
[ ] Granted (ORRACG)
p T)77o>
[ ] Hearing set (ORH)
Clerks Action Required__________
II. Findings
20
21
The Court Finds:
22
2.1
23
Jurisdiction
This court has jurisdiction over the proceeding and the parties.
24
2.2
Service on Nonmoving Party
25
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 1 of 3

WPF DRPSCU 07 0300 Mandatory (7/2007) - RCW 26 09 260, 270,
26 10 200
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadmgs\Order on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
The nonmoving party w as served with a copy of the petition for

modification/adjustment of custody decree/parenting plan/residential schedule,
summons, a proposed parenting plan, and child support worksheet, if any, on
X )
____________________ [Date]
2.3
Time Elapsed Since Service on the Nonmoving Party
&
[]
[]
2.4
The nonmoving party was served within the state of Washington and more
than 20 days have elapsed since the date of service
The nonmoving party was served outside the state of Washington and
more than 60 days have elapsed since the date of service.
The nonmoving party was served by mail and more than 90 days have
elapsed since date of mailing.
Response
The nonmoving party has responded
2.5
Adequate Cause Finding
&
[]
[]
2.6
Adequate cause for hearing the petition has not been established.
Adequate cause for hearing the petition has been established.
The parties stipulate that there is adequate cause for hearing the petition.

2.6.1
Service m em ber status It appears the nonmoving party:

is not a service member,
2.6.2
Dependent of a service member status It appears the nonmoving party;

is a National Guard m em ber or a Reservist.
III. Order
it is Ordered.
The petition is denied.
The matter is set for hearing or trial at the date or time established or to be
established.
The matter is set for hearing or trial at:

W P F
2 6
D R P S C U
0 7 0 3 0 0
M a n d a to ry
(7 /2 0 0 7 )
R C W
2 6 09 260,
10 2 0 0
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\PIeadmgs\Order on Modification docx
270,
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Date:
Place-
T im e
Room/Department:
.a m /p.m
Other
T hl
P M H T*
n e P flM O
3r
'<
7V
fS
a w n t-D
m 7&
70
S
e ta (/f* & >
O JM Y U
sm
J * .
< ****
r * lL* J* * / * * * *
7 *
P f t ^ s
eons
7
/
8
9
Dated:
10
11
12
Presented by.
FAUBION, R E ED ER , FR A LEY,
& CO O K, P.S.
Approved b y
By DANIEL N. CO O K, W S B A #34 866

Christopher L. Harrison, Respondent

Pro Se
13
14
15
16
17
18
19
20
21
22
23
24
25

26 10 200
Charlton v Harrison
S \CASES1\Charfton,
Jolene\Word\Pleadtngs\Onder on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
April 20 2011 2:42 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and

Respondent.
entitled case.
On April 15, 2011, I placed in the U.S. Mail a copy of the Declaration of Alan Floyd in
the above-entitled caption.
Said documents were addressed to:

D A TED
April 1 5 ,2 0 1 1
Sally DiaUharme,
DaOh
Sally
Legal Assistant

Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Declaration o f Mailing.docx
FAUBION, REEDER,
FR A LEY & COOK, P.S.
5920-100 Street SW Ste 25
Lakewood, W A 98499
253-581-0660
E-FILED
April 27 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

Petitioner,
and

Respondent.
entitled case.
On April 26, 2011, I placed in the U.S. Mail a copy of the Order Re Adequate Cause
entered on April 20, 2011; Order on Show Cause re Contempt/Judgment (Harrison motion)
entered on April 20, 2011; Order on Show Cause re Contempt (Charlton motion) entered on
April 20, 2011; and O rder Denying Adequate Cause in the above-entitled caption.

DA TED
April 26, 2011
Sally DuGmarme, Legal Assistant

DECL o f Mailing - Page 1 o f 1
Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Declaration o f Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
April 27 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
4
5
6
7

COUNTY OF PIERCE
In re:
No. 08-3-00821-4
12

13
and
14
11
Petitioner,
Respondent.
entitled case.
17
18
19
On April 26, 2011, I placed in the U.S. Mail a copy of the parties visitation schedule
calendar, from Decem ber 2010, to January 2012, in the above-entitled caption.

20
21
22
D A TE D
April 26, 2011
23
24
25
Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Declaration of Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
April 27 2011 2:39 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7
8
C O U N T Y OF P IE R C E
10
In re:
11
C H R IS O P H E R LEE H A R R IS O N , JR.
Child,
No. 08 -3 -0 0 8 2 1 -4
12
13
14
15
J O L E N E M A R IE H A R R IS O N ,
N /K /A JO L E N E M A R IE C H A R L T O N ,
Petitioner/Mother,
and
C O V E R S H E E T FO R
D E C L A R A T IO N O F A L Y S S A
H A R R IS O N
C H R IS T O P H E R LE E H A R R IS O N ,
Respondent/Father.
16
17
18
Please file the attached declaration of Alyssa Harrison
19
20
D A TED this
fo t day of April 2011.
FAUBIO N, R E E D E R , FR ALEY
21
22
By: Daniel N. Cook, W S B A 34866

O f Attorneys for Petitioner/Mother
23
24
25
Coversheet
Charlton v Harrison
S:\CASES1\Chartton, Jo!ene\Word\Pleadings\Coversheet.docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
COUNTY OF PIERCE
lore:
Petitioner,
and
Respondent
No. 08-3-00821-4
DECLARATION OF
ALYSSA HARRISON
l ALYSSA HARRISON, am die DAUGHTER o f Christopher Harrison. I make this
Declaration on the basis o f my personal knowledge. Due to his abusive and addictive use of
alcohol, I have not lived with my father since I was around 13 years old because I felt he is not a
suitable parent. 1 am now almost eighteen years old. His continual use of alcohol has caused
many problems and unsafe situations for me throughout my childhood and now for CJ. My father
has four children, and has custody of me and my sister Katie but has not taken care of us (we
have not resided with him) since I was under 13 years old and Katie was 11 years old. Katie is
now 16,My sister and 1 have constantly moved from house to house, including full foster care
early in our lives. The last volunteer foster parent that I stayed with while I was 17 tried to get
me medical help but my father refused to give permission. Child Protective Services were
involved because he was neglecting and ignoring my need for required care. When 1 had to leave
my last foster home my dad told me that if I came to his house he would put me back in foster
care and if I went to Jolenes house (the only mom I have known) he would call the sheriff to
come and get me. My father suffers from anger problems. He yelis and hits persons and property.
He tends to have these fits when things are not going his way. He once tried to get me arrested
because 1 did not want to live with him. When I was 11 my dad got mad at me that a pulled me
off my bunk bed and threw me down the stairs and told me to get out o f the house and he was
kicking me out (I had no shoes on either), then when 1 was down the street he came and pulled
me by the arm and took me back to the house. When I was around 9 years old, my father threw
me in the couch resulting in the dislocation o f my patella (knee cap). Due to his actions, 1 have
suffered from knee problems making it difficult to stand for long periods o f time or to do
physical activity. When I was 14 years old, my dad became so intoxicated that I was forced, by
him, to drive us to his home. Two weeks later Jolene came and took me back to her home
because my dad was picked up and taken to jail. Last year (2010), he was placed on house arrest
for non-compliance with conditions o f a prior driving under the influence (DUI) conviction and
had his license revoked. Even though I am almost 18 my dad will not allow me to get my license
because he does not have his and does not want me to get mine before him. Even though he is
court ordered not to drink alcohol, my father drinks alcohol every single day. During visits with
my father, he would even offer my brother and me alcohol and drive us places even though he
did not have his license. My father speaks inappropriately in front o f CJ. Hie calls Mrs.
Charltons spouse, (Will Charlton) Wildo the Dildo in front o f C J and me. CJ then called Mr.
Charlton Wildo in front o f Mrs. Charlton while I was visiting. Mrs. Charlton was upset about
the remark and I explained it is what my dad calls her husband. He also refers to Mrs. Charlton
and her mother (Mrs. Jepson) as in very coarse and vulgar terms that I will not repeat here, but
he says those things in front o f CJ.

Signed at
. WAon A m
Uo
2011.
ALYSSA HARRISON
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100m Street SW, Ste 25

Lakewood, WA 98499
253-581-0660
2
3
4
5
6
7
8
9
10

COUNTY OF PIERCE
11
12
13
14
15
16
17
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION RE
SIGNATURE ON FAXED
DOCUMENT

Respondent.
I, Sally DuCharm e, declare under penalty of perjury that the foregoing faxed
18
document(s) attached to this D E C LA R A TIO N O F A LYSS A H A R R IS O N , which consists of 4
19
pages including this declaration page (but not including attachments), is a complete and
20
legible image that I have examined personally and that was received by me via fax at (253)
21
22
581-0894.
24
Sally Du^narm e, Legal Assistant
25
Charlton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleadings\Declaration o f Faxed Signature.docx
FAUBION, REEDER,
FR ALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
E-FILED
April 27 2011 2:45 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:

Petitioner,
and
No. 08-3-00821-4
DECLARATION OF
JEANETTE JEPSON

_____________________________ Respondent.
My nam e is Jeanette Jepson. I am Jolenes mother and C Js grandmother. W hile
some might argue that my opinions are biased, [ feel that I come from a unique perspective
and have important information to share with the Court. I have raised ten children, taught
Sunday School and Parenting Classes, trained and worked as a counselor/advocate on a
sexual assault hotline for ten years, and have been a King Co. CA SA volunteer for the past
nine years. I do not share this information as evidence of an authoritative report, but only that
my background m akes m e uniquely qualified to see this case from a different perspective. I
am a big advocate of maintaining parental relationships, but i am equally concerned about
the safety of children.
DECLARATION - Page 1 o f 7
Charlton v Harrison
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
I have known Chris and his children from a prior relationship, Alyssa and Katie, for
seven years. W hen Jolene met Chris he presented as a divorced, recovering alcoholic who
had turned his life around and was active in church. Jolene was the first real mother Alyssa
and Katie had ever known, and to date they still call her Mom and reach out to her in times of
need. Less than a year into the marriage things began to unravel when serious unresolved
DUIs and DW LS Court issues, deceptions, uncompleted treatments, mental health, and
domestic violence issues began to surface.
I am concerned about C Js safety with Chris because he has a history of very serious
mental health problems. Chris has been hospitalized three times for suicidal ideations. (1)
Acute and em ergent voluntary, Sacred Heart Medical Center, Spokane, W A, date of
admission 03/18/2002, date of discharge 03/26/2002; (2) Suicidal with plan, Involuntary
hospitalization Lourdes Medical Center Hospital, Richland W A, date of admission
09/22/2003, date of discharge 10/01/2003; (3) Voluntary St. Joseph Hospital, Tacoma, WA,
10 days, January, 2007. Chris also had homicidal/suicidal ideations while he was
incarcerated and he was on suicide watch tank in the King County jail from November, 2008
to January, 2009. T he letters Chris wrote from jail to Jolene and Katie (one of his daughters)
in January 2009, also show that Chris has serious mental health issues. His letters tell about
Chris hearing his dead sisters voice telling him how awful he is and to do bad things to
people. H e would drink to keep from hearing her voice, and he was worried about Katie
turning out just like his sister.
I am concerned about C Js safety with Chris because he has a very extensive criminal
history. Chriss criminal history includes DUIs, DW LS, DV, Violations of No Contact Order,
and Interference with reporting Domestic Violence.
DECLARATION - Page 2 of 7
Charlton v Harrison
Chris is currently on formal Court Orders

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
put Chris on formal supervision for: (1) Case # 8 Y C 0 02932 until 01/15/2012; (2) Case
#8Y C 0 03222 until 01/15/20 15; (3) Case #7Y C 010751 until 8/15/2011. As of last summer
(2010) I am aware that he w as placed on house arrest for non-compliance with conditions of
his convictions. Chris is scheduled for trial on 6/22/2011 for recently violating a No Contact
Order. Chris is ordered to take care of a warrant from Franklin Co. (offence was in 2003) and
on information and belief I allege that in order to care of the warrant some jail time may be
required.
I was personally present to witness the following events and make observations of
how this criminal history and mental health concern has affected Chriss children:
1. Katie called m e to say that she could not reach Jolene on the cell phone and she
was very scared that her dad was going to hurt her. She said he got mad because
she had gotten the mail and she could tell by the look in his eyes that he was going
to hurt her. I could tell Katie was very, very frightened. I helped Katie with a plan
to stay safe until som eone could get there. Jolene got home shortly thereafter with
the intention of bringing Alyssa to my home to earn som e money for cleaning. The
next call I got w as from Chris. He asked if Jolene had gotten to my house yet, and
that he needed m e to come over right away. He said that he had pushed Jolene
and the police would be there soon. He needed me to come immediately or he
would be taken to jail. I told him that I needed to talk with Jolene before I could
come. Almost immediately the car drove up, and when I opened my front door
Katie and Alyssa fell into my arms sobbing. I moved us all to the couch and
comforted them the best I could, and then w ent to check on Jolene who was still in
the car. She had large bruises on both legs and arms with chunks of flesh torn out
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
of her fingers from the keys being ripped from her hand to prevent her leaving. She
described how a verbal argument had escalated out of control and when she saw
the look in his eyes decided she better just leave. She turned to go down the stairs
when she was pushed with such force from behind that she had no recollection of
touching the stairs, she just felt stunned, had a headache and hurt all over. She
picked herself up from the landing below where she had broken through the back
of a box springs that was propped against the wall. She proceeded to get the
children and herself safely aw ay from there. (August, 2007).
2. O ne night Jolene called me very upset because Chris had talked with CJ on the
phone and CJ w as telling his dad that he didnt w ant his dad to die. Jolene took
the phone to find out that Chris was suicidal with a plan. He had a shotgun and he
named his three previous employers whom he was going to kill just before he shot
himself, because they had ruined his life. Jolene and I conference called several
different agencies trying to get some mental health professionals to help Chris.
Jolene was absolute that there was not to be any report of violation of the No
Contact order. She did not petition the court for the No Contact order, but she was
grateful it was in place. Chris spent the next two plus months in suicide watch at
the King Co Jail, Seattle, W A .(2008/2009).
3. Chriss children lived with Jolene with no support of any kind from Chris. Alyssa for
almost two years, Katie for 9 months and CJ was just 2 years old. A single mother
working, caring for and supporting five children alone.
4.
Katie becam e suicidal and w as hospitalized at Fairfax Hospital the year she turned
13. Jolene and I visited Katie and emotionally supported her, but she refused to
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
1
allow her dad to see or talk to her because she was scared of him. Jolene could no
2
longer physically or financially m anage all five children by herself. Katie went to
3
4
5
6
live with a longtime family friend of ours (Katherine Ayers), who offered Chris a job
and tried to mend the breach between Katie and her dad. (April, 2008)
5. W e learned Chris had a long history of convictions for DUIs and DWLS, had not
completed the mandatory alcoholic treatment program, and was years from his
license being returned. My husband and I had to end Chriss job in the family
business because he falsely presented with having a current valid drivers license.
10
(January 2005)
11
6. I drove Chris to doctor appointments for his mental health issues, treatment
12
program, and local court hearings while Jolene was at work.
13
7. Chris totaled Jolenes car when he took it without permission and was involved in a
14
vehicle collision. (Novem ber 2005)
15
16
17
18
19
8. W e went to an attorney to hopefully get his license reinstated because of his efforts
to change, but w ere turned down by the DOL because he was a habitual offender
and needed at least one year without DW LS. (April 2 00 6)
9. I gave Jolene and the children emotional support when Chris w ent to jail for five
20
days for another case from Eastern Washington. (Buckley, W A. Jail - Summer
21
2006)
22
23
24
1 0 .1 learned that Alyssa and Katie spent two years in foster care when they were
younger.
11. It w as well known that Chris considered Katie his Bad Child, and Alyssa his
25
Good Child. I witnessed other verbally abusive comments to the children.
FAUBION, REEDER,
Charlton v Harrison
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
12. Chris was asked to leave the home until he w as willing to get help and make the
necessary changes for a healthy marriage and family. He proclaimed he was
suicidal and was taken to the ER at St. Joseph's hospital. (January 2007)
13. Chris would not allow Jolene or the children to know where he lived and almost
never communicated with the children. I was there when three year old CJ would
cry to see his dad, and the girls felt very upset, as well. Jolene would try to find him
and have the children get a visit. Jolene and Chris had a lot of tension and
frustration between them at that time.
14. The children began to come to me with past and more recent physical abuses.
One of the more recent ones that had been investigated by C P S was dropped
because the child recanted for fear of retaliation from Chris.
15. Katherine Ayers gave the Court a Declaration noting the neglect and abuse she
witnessed toward Katie from her dad. (October, 2009)
16. Chris took Alyssa to live with him when school w as out. She was texting Kim
Sherwood (Chris's girlfriend) that she felt afraid and suicidal. Chris m ade 14 year
old Alyssa drive him home because he was too drunk to drive. Jolene saw it
happen, confronted Chris then drove home. Later, Chris was stopped for drunk
driving on his w ay to Jolenes house. Chris had the police call Jolene to come and
get his stuff from the car, and asked Jolene to get Alyssa from his house and take
her to Jolenes since he was going to jail. Alyssa told me she was scared, she had
never driven a car before.
(Sum m er 2008)
17. Katherine and I helped Jolene make arrangements for CJ (3 34 years old) to have
visits with his dad. I w ent with Jolene to pick CJ up at the end of one visit, and CJ
D E C L A R A T IO N - P a g e 6 o f 7
Charlton v Harrison
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
5 9 2 0 -1 0 0 S treet S W , Ste 25
2 5 3 -5 8 1 -0 6 6 0
began telling us about taking a ride in the truck his dad was driving for work. Chris
admitted he just took CJ down the little road near where he was staying. (He did
not have a car seat for CJ, nor did he have a drivers license) 2008.
18. My daughter was stunned to learn she was not legally married because Chris was
still married to his previous wife (Janelle Harrison), Jolene had started divorce
proceedings but, was the Court later invalidated the marriage in October, 2008.
19. Chriss dual diagnoses treatm ent program was set up and he went to a clean and
sober house sometime in January of 2009. He stayed there a very short time and
moved in with his new girlfriend, Char Pergrim of Auburn, W A.
These and other personal observations and knowledge from personal experiences
lead me to believe that som e form of safe supervision needs to be in place to insure CJs
safety. Judge Nelson wrote the parenting plan for relocation in January 2010 and she
required visits to be in the presence of approved adults. She approved Ms. Pergrim as an
approved adult (as well as anyone else approved by the mother) for C Js visits with his dad.
I was hopeful this plan would work for CJ visiting his dad and still provide the necessary
safety. Ms. Pergrim has proven to be less than adequate for this supervision. I have listened
to her escalate the tension up between the parents. She allowed Chris to take CJ on the bus
and train to Chris work and leave CJ with someone unknown to Jolene, and not approved by
the court. On information and belief I allege that Chris has used Ms. Pergrim s car to drive
the CJ on multiple occasions.
Charlton v Harrison
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S treet S W , Ste 25
2 5 3 -5 8 1 -0 6 6 0
still married to his previous wife (Janelle Harrison). Jolene had started divorce
proceedings but, the Court later invalidated the marriage in October, 2008.
19. Chriss dual diagnoses treatment program was set up and he went to a clean and
moved in with his new girlfriend, Char Pergrim of Auburn, W A.
lead me to believe that som e form of safe supervision needs to be in place to insure CJs
approved adult (as well as anyone else approved by the mother) for CJs visits with his dad.
I was hopeful this plan would work for CJ visiting his dad and still provide the necessary
to her escalate the tension up between the parents. She allowed Chris to take CJ on the bus
and train to Chris work and leave CJ with someone unknown to Jolene, and not approved by
the court. On information and belief I allege that Chris has used Ms. Pergrims car to drive
CJ on multiple occasions.
I DEC LA R E U N D E R PE N A LTY O F P E R JU R Y U N D E R T H E LAWS O F TH E STA TE
O F W A S H IN G T O N T H A T T H E F O R E G O IN G IS TR U E A N D C O R R E C T .
Signed at
W A on
2011 .
JEANETTEJEPSO N
Charlton v Harrison
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 00 th S treet S W , Ste 25
Lakewood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
04/25/2011
22:49
253-896-4900
CLOSETS ETC LLC
PAGE
1
2
3
4
still married to his previous wife (Janelle Harrison). Jolene had started divorce
proceedings but
the Court later invalidated the marriage in October, 2008.
. 19. Chriss dual diagnoses treatment program was set up and he went to a clean and
moved in with his new girlfriend, Char Pergrim of Auburn, WA.
B
9
lead me to believe that some form of safe supervision needs to be in place to insure CJ's
10
11
12
13
approved adult (as well as anyone else approved by the mother) for CJs visits with his dad.
14
I was hopeful this pian would work for CJ visiting his dad and still provide the necessary
15
ie
to her escalate the tension up between the parents. She allowed Chris Lo Lake CJ on Lhe bus
17
and train tn Chris work an d leave O.J with so m eo n e unknown to Jolene, and not approved by
18
the court. On information and belief I allege that Chris has used Ms. Pergrims car to drive
19
$STCJ on multiple occasions.
20
I DECLARE UNDER PENALTY O F PERJURY UNDER THE LAWS OF THE STATE
21
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25
D EC LA R A TIO N - P age 7 o f 7
Charlton v Harrison
FA U B IO N , R EED ER ,
F R A L E Y & CO O K, P.S.
5920-1 00 th Street SW , Ste 25
Lakewood, W A 98499
253-5S1-GS60
07

COUNTY OF PIERCE
In re:
No. 08-3-00821 -4

Petitioner,
and
DECLARATION RE
SIGNATURE ON FAXED
DOCUMENT

Respondent.
I, Sally DuCharm e, declare under penalty of perjury that the foregoing faxed
document(s) attached to this DE C LA R A TIO N O F JE A N E TTE JEPSO N, which consists of 9
pages including this declaration page (but not including attachments), is a complete and
legible image that I have examined personally and that was received by me via fax at (253)
581-0894.
Sally DdCliarm e, Legal Assistant

Charlton v Harrison
S:\CASES1\CharIton, Jolene\Word\Pieadings\Declaration o f Faxed Signature.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 S tr e e t SW , S te 2 5
L akew ood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
E-FILED
April 27 2011 3:27 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
C a u s e Num ber: 0 8 -3 -0 0 8 2 1 -4
C a s e Title: JOLENE MARIE HARRISON VS. CHRISTOPHER LEE HARRISON
To All Those To Whom This Letter May Come
The Institute for Childrens Advocacy

Is pleased to announce that:
Has successfully completed a Four Hour workshop
D o n t F o rg et th e K id s
And, having such distinction and perspicacity in regard
to the course, is hereby granted this
Certificate of Completion
Dated this 25th day of April, 2011
In the City of Tacoma, State of Washington
Instructors:
S u s a n D e R o m e , M .E d .
W a i T
P e te rs e n , M . S .
E-FILED
April 29 2011 4:30 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
C
O
6
7

COUNTY OF PIERCE
8
9
In re:
No. 08-3-00821-4
10

Petitioner,
11
and
12

Respondent!
13
14
I. Sally DuCharm e, am over the age of 18, and competent to testify in the above
entitled case.
15
16
On April 27, 2011, I placed in the U.S. Mail a copy of the following documents in the
above-entitled caption:
17
1.
2.
3.
4.
18
19
20
Declaration of Alyssa Harrison;

Declaration of Jeanette Jepson;
Criminal History Records of Respondent;
Sealed Personal Healthcare Records.
SE, Auburn, W A 98092.

21
22
23
D A TE D
April 27, 2011
24
25
'
Sally Du&Frarme, Legal Assistant

Charlton v Harrison
S:\CASES1\Chariton, Jolene\Word\P!eadings\Declaration o f Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100TH Street SW Ste 25
Lakewood, W A 98499
253-581-0660
E-FILED
May 02 2011 9:26 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
C
O
6
7

COUNTY OF PIERCE
8
9
In re:
No. 08-3-00821-4
10

Petitioner,
11
and
12

Respondent!
13
14
I. Sally DuCharm e, am over the age of 18, and competent to testify in the above
entitled case.
15
16
On April 27, 2011, I placed in the U.S. Mail a copy of the following documents in the
17
1.
2.
3.
4.
18
19
20
Declaration of Alyssa Harrison;

Declaration of Jeanette Jepson;
Criminal History Records of Respondent;
Sealed Personal Healthcare Records.

21
22
23
D A TE D
April 27, 2011
24
25
'
Sally Du&Frarme, Legal Assistant

Charlton v Harrison
S:\CASES1\Chariton, Jolene\Word\P!eadings\Declaration o f Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100TH Street SW Ste 25
Lakewood, W A 98499
253-581-0660
-00821-4
36225663
PCOPC
IN COUNTV CLERKS OFFICE
05-03-11
M A Y 0 2 2011
A.M.
RM.
STOCK, County Clerk

11
-------- DEPUTY
vjm
On Â
C a s e n am es:
-a -Q Q S Z I-V
C ause Num ber
M o * ,',
e r^ > W ^ & T ^
Respond

Jo/ene. IAr Charlton.
Dont Forget the Kids

In th e City of T a c o m a , S ta te of W a s h in g to n
Instructors:
S u s a n (p etR o m e ,
W a i T . (P e tersen , CM.S-
08'3'00621
86373741
*FRSP
F I L ED
05.11^1
a.m
MAY 1 0 2011
pm.

KEVIN STOCK,
County Clerk
STO
BY
T_____________ DEPUTY

County of
In re:
Jolene Charlton
No. 08-3-00821-4
Petitioners),
and
Declaration of
_Christopher Harrison _ [Name]
(Optional Use)
Respondent(s). (DCLR)

Name:
__Christopher Harrison
___________
Age:
__41____________________________
Relationship to the parties in this action: __respondent
I Declare:
First thing I would like to address is mv daughter A lyssas declaration. She states that she chooses not to live with me Truth be
told that 1told her that either she can live with mv mother or go in to Job Corps. The reason why is she wants to hop from friend
to friend, burning bridges, and destroying the families lives she has staved with. After 1 left Jolene and Alvssa couldn't stand
living with Jolene. 1 told allowed her to stay with a friend named Kim. This was so Alvssa could stay in the same school and be
close to her friends, to allow her some stability. As time went on. come to find out that Alvssa was not getting her wav, being
very rebellious & sexually active, and getting into a lot of trouble at school. So she fabricated a story that Kim's son Jordan raped
her so that she could go live with her BFF friend at the time. Kavlee Mills. And that story went all the wav to the Pierce County
Sherrif. At which time I told her 'Thats i t vou are coming to live with me! Alvssas' reply was 1 will call the police and CPS
and tell them whatever I have to so that I don't have to come live with you... I want to live with Kavlee. Now I couldn't put the
other people in my house through that and with all this court stuff going on. if Jolene would have caught wind about it she would
have exploited it to her own interest. The same wav she is exploiting mv daughter. Alvssa is mad at me for not jumping to her
rescue when she was evicted* from the last friencTs family she staved at after they asked her to leave because she mis-behavine
and was threatening their daughter, making remarks that she was going to kill her. Jolene coerce in g Alvssa into writing a
declaration against her own father is dispicable! Alvssa was mad so she said anything and everything she thought would get me in
to trouble because I didn't give her her wav. The farthest I have driven mv son is out of the garage into the driveway then back
into the garage. And she savs that I give her and mv son alcohol then drive them around?!? The kid knows what to sav and just
how to use the system to her advantage... iust like Jolene. Jolene's feeble attempts to put doing wrong are outragous and are taking
up the court's time, time that could be spent on someone that really needs it. If you look at the attached pictures vou can see that
our son is happy when he is here and well taken care of. Jolene was not concerned that Ci went to work with me and even had a
long conversation with him about all the diffrent types of transportation he has been on, and how he's been on planes and trains
and cars and busses etc. She even knows that I took Ci to the zoo in July, and could care less. But now she has a lawyer and now
she is so concerned. It's plain to see what she's doing, she's moving away and trying to make it so I have to travel there to see mv
son, as not to inconvience her. I'm not a bad father. I take pood care o f mv son, and he loves me and he misses me. he gets sad and
savs he misses me (sounds like he is starting to cry) then savs he needs to go. But that only happens when Jolene is not next to
him coaching him. On one call with Ci he said he missed me why he can't come over to mv house anymore and when I couldn't
answer him, he asked his mother. Immediately Will (Jolenes current husband) starts veiling at Ci "If your dad wants to know why
he cant see vou, tell him to call the attorney." "Get of the phone, get off the phone, get off the phone. GET OFF THE PHONE
CJ!!!" Line goes dead. Jolene sent a text saving that mv phone schedule in Monday thru Friday at 8 pm. She refuses to let me talk
to him on the weekends. I have a class on Tuesdays and dont get home until 10 pm. Last I heard in court mv appointed phone
days are Sunday. Monday. Wednesday. Thursday. & Friday. 1 iust want to be able to talk to mv son. Jolene wants to focus on
everything I have done in the past, even things I have done before I even met her. She dosent care about what I am doing now,
and what I'm doing now is everything that I should be doing. I'm under the care o f Dr.Wavne Duran. MD, and am current on mv
Descriptions. I am in full compliance with mv domestic violence class, and am in line to graduate August 16th. I will be bringing
mv latest progress report from mv domestic violence classes to court. 1 will also bring in mv AA meeting slips for the court to see,
and I have received confirmation from King County Regional Justice Center for the parenting class that I will be attending on 518-2011 at 5pm,

I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
Signed at
Auburn
, [City]
__
WA_________ [State] on 5-9-2011________________
[Date].
______ Chris Harrison_____________________

Print or Type Name
Do n o t attach financial reco rd s , p erso n a l health care reco rd s o r co n fid en tia l reports to th is
declaration. S u ch reco rd s sh o u ld b e se rv e d on the o th e r p a rty a n d filed w ith th e co u rt u sin g one o f
th e se c o v e r sh e e ts :
1) Sealed Financial Source D ocum ents (WPF DRPSCU 09.0220) fo r financial records
2) Sealed Personal Health Care R ecords (WPF DRPSCU 09.0260) fo r health records
3) Sealed C onfidential R eport (WPF DRPSCU 09.270) fo r confidential reports
If filed sep a ra tely u sin g a c o v e r sh e e t, th e reco rd s will b e s e a le d to p ro te c t yo u r p riva cy (although
th e y will b e available to all p a rties in th e ca se, th eir a tto rn eys, co u rt p e rso n n e l a n d certain s ta te
a g en c ies a n d boards.) S e e GR 22(C)(2).
^ 3
1
For Petitioner
For Respondent
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May 12, 2011 9:30 AM
fn o W r
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rw^x a ^ _ r e i n . e ^ e d

WENDY ELLEN ZICHT
(P * S
Clerk g X c _
Courtroom number 117

Calendar C2 - SHOW CAUSE/FAMILY LAW
Ixcrtrpt pbl d_ioumaljentry_showcause_report
08-3-00821-4
36390684
PPT
05-13-11
CUNTrF
**
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,n
C O U N T Y O F P IE R C E
10
11
12
13
14
In re.
No. 08-3-008 21-4
C H R IS O P H E R LEE H A R R IS O N , JR.
Child,
TEM PO RARY
P A R E N TIN G PLAN
(PPP )
J O L E N E M A R IE H A R R IS O N ,
N /K /A JO L E N E M A R IE C H A R LTO N ,
Petitioner/Mother,
and
15
16
C H R IS T O P H E R LEE H A R R IS O N ,
Respondent/Father.
-rx s* # \/J H J r
17
18
fu )r< J
S /6 - M G Q r
IT IS H E R E B Y O R D E R E D , A D JU D G E D A N D D E C R EED .
19
20
f M 0 sS p '^ G
This parenting plan is BfQ DO sea^Lthe-PeW e n e i/M u ll lei J u L L N L Cl IAKL i U N
I. G E N E R A L IN F O R M A T IO N
This parenting plan applies to the following child.
21
N am e
C H R IS T O P H E R H A R R ISO N , JR
22
Date of Birth
02/22/2005
Age
6
23
II. BA SIS FO R R E S T R IC T IO N S
24
Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the nght to make decisions for the child.
P a r e n tin g
W P F D R
P la n
01
(P P P ,
P P T,
P P )
- Page
1 o f 10
0 4 0 0 M a n d a to ry (6 /2 0 0 8 ) - R C W
2 6 0 9 016,
181
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadmgs\Temporary Parenting Plan doc
187,
194
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 100th S treet SW , S uite 25
2 5 3 -5 8 1 -0 6 6 0
5 3 - f~2 '5 t 1 1
2.1
2
The Respondents residential time with the child(ren) shall be limited or
resolution process other than court action shall not be required, because [X] this
parent [ ] a person residing with this parent has engaged in the conduct which
follows
3
4
5
A history of acts of domestic violence as defined in R C W 26.50 010(1) or

an assault or sexual assault which causes grievous bodily harm or the fear
of such harm
6
7
2.2

The Respondents involvement or conduct m ay have an adverse effect on the
child(ren)s best interests because of the existence of the factors which follow
10
Neglect or substantial nonperformance of parenting functions
11

performance of parenting functions as defined in R C W 26 09 004
12
13

abuse that interferes with the performance of parenting functions
14
15
16
The residential schedule must set forth where the child(ren) shall reside each day of the
year, including provisions for holidays, birthdays o f family members, vacations, and
other special occasions, and what contact the child(ren) shall have with each parent
needs o f the child(ren) and individual needs o f their family. Paragraphs 3.1 through 3.9
are one way to wnte your residential schedule If you do not use these paragraphs,
17
18
19
20
3.1
21
There are no children under school age
22
23
24
3.2
School Schedule
Upon enrollment in school, the child(ren) shall reside with the Petitioner/mother,
except for the following days and times when the child(ren) will reside with or be
with the other parent

WPF DR 01 0400 Mandatory (6/2008) -RCW 26 09 016, 181, 187, 194
Charlton v Harrison
S\CASES1\Chariton, Jolene\Word\Pleadmgs\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 100th Street S W , Suite 25
2 5 3 -5 8 1 -0 6 6 0
6^
135
*1 x1 5
After completion of the requirements in Paragraph 3.10, from (day and

time)
Friday 7 00 p.m._________ to (day and time)
Sunday 7 00 p.m
every other w eek
2
3
4
Until completion of the requirements in Paragraph 3 10, only supervised

visitation with father will be allowed.
3.3

The child(ren) shall reside with the Petitioner/mother during winter vacation,
with the other parent.
8
9
After completion of the requirements in Paragraph 3 10, the first day of

School W inter Vacation at 6 00 p.m. to the day after Christmas at 6 00
p.m. every other year. The day after Christmas at 6:00 p.m to New
Year's Day at 6 00 p.m. in the alternating years. See Section 3 7
10
11

visitation with father will be allowed
12
13
3.4
14
The child(ren) shall reside with the Petitioner/mother during other school breaks
15
16
3.5
Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the
Petitioner/mother, except for the following days and times when the child(ren) will
reside with or be with the other parent.
17
18
19
S am e as school year schedule
20
After completion of the requirements in Paragraph 3 10, Father to be

allowed in addition to regular every other weekend visit 1 w eek in July,
and 1 w eek in August beginning with a Friday of a regular weekend visit
for father
21
22

visitation with father will be allowed
23
24
3.6

Does not apply.

WPF DR 01 0400 Mandatory (6/2006)-RCW 26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Charlton, Jolerte\WorcfliPleadings\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
3.7
2
There is no Holiday schedule until after the requirements in Paragraph 3 10 are
completed.
3
4
After completion of the requirements in Paragraph 3 10, the residential schedule

for the child(ren) for the holidays listed below is as follows
6
7
8
New Y e ars Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
Easter
10
11
12
13
With Petitioner
(Specify Y ear
Odd/Even/Every)
With Respondent
(Specify Y ear
O dd/Even/Every)
O DD_____________
See W eekend Schedule
S ee W eekend Schedule
See W eekend Schedule
O DD______________
S ee W eekend Schedule
Every____________
EVEN_____________
ODD______________
O DD______________
EVEN_____________
______EVEN
______________
______________
______________
______ EVEN
______________
______________
______ O DD
______ EVEN
______ EVEN
________ O DD
14
[X]
For purposes of this parenting plan, a holiday shall begin and end as
follows (set forth times) S ee Section 3.2 above W eekends may include
holiday Mondays in which case the Sunday return time becomes Monday
[X]
Holidays which fall on a Friday or a Monday shall include Saturday and

Sunday
15
16
17
18
Does not include* W inter break, New Y e ars Day, Christmas Eve or
Christmas Day, as these holidays have special designated times
See 3 3
19
20
3.8
21
22
23
24
There is no Special Occasion schedule until after the requirements in Paragraph

3 10 are completed
for the child(ren) for the following special occasions (for example, birthdays) is as
follows
With Petitioner
With Respondent
(Specify Y ear
(Specify Y ear

Charlton v Harrison
S \CASES1\Char1ton, Jolene\WorrJ\Pleadmgs\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
^ y ^
3 ** ^ * v*
1
O d d /E v en /E v ery )
EVERY
M o th ers Day
F a th e r s D ay
O d d /E v e n /E v erv )
EVERY
3
4
3.9

D o e s no t app ly b e c a u s e o n e p a re n t h a s n o visitation o r re stric ted visitation
5
6
3.10
Restrictions
T h e R e s p o n d e n ts resid en tial tim e with th e children shall b e limited b e c a u s e
th e re a re limiting fa c to rs in p a ra g ra p h s 2 1 a n d 2 2 T h e following restrictio ns
sh all apply w h e n th e children s p e n d tim e with th is p a re n t.
7
8
p i-77
All visitation sh all b e su p e rv ise d by a p ro fe ssio n a l visitation su p e rv iso r (at

R e s p o n d e n t/fa th e rs e x p e n s e ) u n le s s a n d until R e s p o n d e n t/fa th e r c o m p le te s
following re q u ire m e n ts
_ o e i& tf
10
11
\Z(S'F!9 T fort
oj<tc
C & r n p u Q r tC S MT7*
A a) A=Statexettfed d ru g /alco h o l evalt*atin w hich shall include collateral c o n ta c t

x*e?i with P etitio n e r/m o th er J o le n e C harlton an d , a n y re c o m m e n d e d follow-up
QFF/ctuZ
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15
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b) A S ta te certified d o m e stic v io len ce a s s e s s m e n t w hich shall include collateral
* c o n ta c t with P etitio n er/m o th er J o le n e C harlton an d a n y re c o m m e n d e d
follow-up tr e a tm e n t ts
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c) A m en tal h ealth e v alu atio n with p aren tin g c o m p o n e n t w hich shall include
co llateral c o n ta c t with P etitio n er/m o th er J o le n e C harlton a n d a n y
16
17
J ? n 6 L f TfiJUtfb f p f A P f t o f f a y f f E /ne&tay/TOAJf A 8 0 PA/ o p /Yit/OTflc p f p c P r /
/*
18
19
20
21
22
23
d) R e s p o n d e n t/fa th e r shall sign au th o rizatio n for r e le a s e of inform ation to

P e titio n er/m o th er J o le n e C harlton for afl e v a lu a tio n s a b o v e a n d an y a n d aftt&l
all tre a tm e n t p ro v id ers e n g a g e d in r e s p o n s e to ev a lu a tio n s s e t forth
CoH77)0r
above
A m &t
GtO!&MFrtr$
UJiTh
w o n te / l*
OP-
CAS O-M/ti/PAP
C o n ta c t shall b e limited to visits in th e co u n ty w h e re th e child re s id e s o f no m ore
th a n 3 h o u rs p e r visit for no m o re th a n 10 visits p e r m onth on a s c h e d u le
t ^ o o ^ a r r a n g e d b e tw e e n th e su p e rv iso r a n d P e titio n e r/m o th er J o le n e C harlton C o sts of
^
su p erv isio n sh all b e paid by R e s p o n d e n t/fa th e r C h risto p h e r H a r r i s o n ^
VAP co;u f>eoVcQ {T?oo?p p p & Z A / e P / f s s s r p f ^ r Q p s y / P PrtO rtss
3.11 Transportation Arrangements
8/
24
T ran sp o rta tio n c o s ts a re included in th e Child S u p p o rt W o rk s h e e ts a n d /o r th e

O rd er of Child S u p p o rt a n d sh o u ld not b e in clu d ed h ere.
W P P
D R
01
(P P P ,
P P T ,
P P ) - P a ge
5 o f 10
0 4 0 0 M a n d a to r y ( 6 /2 0 0 8 ) - R C W
26 09
016,
181,
Charlton v H a r r i s o n
S \CASES1\Char1ton, Jolene\Word\Pleadings\Temporary Parenting Plan doc
187,
194
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 100th S treet S W , Suite 2 5
2 5 3 -5 8 1 -0 6 6 0
b.-- 1 3
T ran sp o rta tio n a rra n g e m e n ts for th e child(ren), b e tw e e n p a re n ts shall b e a s

follows
Prior to co m p letio n of re q u ire m e n ts in P a ra g ra p h 3 10, visitation shall b e

a t a location c h o s e n by th e m o th er in co n su ltatio n with th e visitation
su p e rv iso r within re a s o n a b le proxim ity to th e m o th e rs re s id e n c e
A fter co m p letio n of re q u ire m e n ts in P a ra g ra p h 3 10, th e receiving p a re n t

shall provide tra n sp o rta tio n
3.12
T h e ch ild ren n a m e d in th is p a ren tin g plan a r e s c h e d u le d to re sid e th e m ajority of

th e tim e with th e P e titio n er/m o th er JO L E N E CHARLTON. T his p a re n t is
d e s ig n a te d th e c u sto d ia n of th e child(ren) solely for p u rp o s e s of all o th e r s ta te
a n d fe d e ra l s ta tu te s w hich req u ire a d e sig n a tio n or d e term in a tio n of c u sto d y
T his d e sig n a tio n sh all not affect e ith e r p a re n ts rights a n d resp o n sib ilities u n d e r
this p a re n tin g plan.
10
11
12
3.13
14
15
16
No tran sp o rtin g of child u n le ss a p p ro v ed driver h a s licen se a n d in su ra n ce

F a th e rs au n t or u n cle, F a th e rs M other or S te p -F a th e r all a p p ro v ed an d o th e rs a s
m en tio n ed by M other a re ap p ro v ed
17
18
20
Other
T his p aren tin g plan is e n te re d in anticipation of a n d with th e full kn o w led g e th a t
th e m o th e r will s o o n b e relocating to Idaho so m e tim e b e fo re S e p te m b e r 2 0 1 1 . A
trial h a s alre ad y b e e n held on th e is su e of th e m o th e rs m o v e to Idaho s o no
N otice of R elo catio n n e e d b e given w h en th e m o th e r m o v e s prior to S e p te m b e r
2 0 1 1 , e x c e p t th a t th e m o th e r will provide th e fa th e r with h e r n ew resid en tial
a d d r e s s a fte r s h e m o v e s
13
19
3.14

T his is a s u m m a ry only For th e full text, p le a s e s e e R C W 26 09 4 3 0 th ro u g h
26 09 4 8 0
21
22
23
24
If th e p e rs o n with w h o m th e child re s id e s a m ajority of th e tim e p la n s to m ove,

th a t p e rs o n shall give n o tice to ev ery p e rs o n entitled to co u rt o rd e re d tim e with
th e child
If th e m o v e is o u ts id e th e childs sch o o l district, th e relo catin g p e rs o n m u st give
notice by p e rs o n a l se rv ic e o r by mail requiring a retu rn re c eip t This n o tice m ust
b e at le a s t 60 d a y s b e fo re th e in ten d ed m o v e If th e relo catin g p e rso n could not
h a v e know n a b o u t th e m o v e in tim e to give 60 d a y s notice, th a t p e rso n m u s t
give n o tice within 5 d a y s a fte r learning of th e m o v e. T h e no tice m u st co n tain th e
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadings\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
5--*
-5j
inform ation req u ired in R CW 2 6 .0 9 4 4 0 S e e a lso form D R P S C U 0 7 .0 5 0 0 ,

(N otice of In ten d ed R elo catio n of A Child).
If th e m o v e is within th e s a m e sch o o l district, th e relo catin g p e rs o n m u st provide

a c tu a l n o tice by a n y r e a s o n a b le m e a n s A p e rs o n en titled to tim e with th e child
m ay n ot o b je ct to th e m o v e b ut m ay a s k for m odification u n d e r R C W 2 6 .0 9 .2 6 0
3
4
N otice m a y b e d e la y e d for 21 d a y s if th e relo catin g p e rs o n is en terin g a d o m e stic

v io len ce s h e lte r o r is m oving to avoid a clear, im m ed iate a n d u n re a s o n a b le risk
to h ealth a n d s a fe ty
5
6
If inform ation is p ro te c te d u n d e r a co u rt o rd e r or th e a d d r e s s confidentiality

p ro g ram , it m a y b e w ithheld from th e n o tice
A relo catin g p e rs o n m a y a s k th e co u rt to w aiv e a n y n o tice re q u ire m e n ts th a t m ay

put th e h e alth a n d s a fe ty of a p e rso n or a child a t risk
Failure to give th e req u ired notice m ay b e g ro u n d s for s a n c tio n s , including

c o n tem p t.
10
If no o bjection is filed within 30 d a y s after se rv ic e of th e n o tice of in ten d ed

relo catio n , th e relo catio n will b e perm itted a n d th e p ro p o s e d re v ised resid en tial
s c h e d u le m a y b e confirm ed
11
12
A p e rs o n entitled to tim e with a child u n d e r a co u rt o rd e r c a n file an o bjection to

th e childs relo catio n w h e th e r o r no t h e o r s h e re c e iv e d p ro p e r notice
13
14
An o bjection m ay b e filed by u sing th e m a n d ato ry p a tte rn form W P F D R P S C U

0 7 .0 7 0 0 , (O bjection to R elo catio n /P etitio n for M odification of C u sto d y
D e c re e /P a re n tin g P la n /R e sid e n tia l S c h e d u le ). T h e o b jectio n m u st b e se rv e d on
all p e rs o n s entitled to tim e with th e child
15
16
T h e relo catin g p e rs o n sh all no t m o v e th e child during th e tim e for o bjection

u n le ss: (a) th e d e la y e d n o tice p ro v isio n s apply, or (b) a co u rt o rd e r allow s th e
m ove
17
18
If th e o bjecting p e rs o n s c h e d u le s a h earin g for a d a te within 15 d a y s o f timely

serv ice of th e objection, th e relocating p e rs o n shall no t m o v e th e child b e fo re th e
hearin g u n le s s th e re is a clear, im m ed iate a n d u n re a s o n a b le risk to th e h ealth or
sa fe ty of a p e rs o n o r a child
19
20
21
IV. Decision Making

22
4.1
23
24
E ach p a re n t shall m a k e d e c isio n s reg ard in g th e d a y -to -d a y c a r e a n d control of

e a c h child w hile th e child is residing with th a t p a re n t. R e g a rd le s s of th e allocation
of d ecisio n m aking in this p aren tin g plan, e ith e r p a re n t m ay m a k e e m e rg e n c y
d e c is io n s affecting th e h ealth or s a fe ty of th e children
Charlton v Harrison
S \CASES1\Charlton, Jolene\W ord\Pleadm gs\Tem porary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
4.2
Major Decisions
M ajor d e c is io n s reg ard in g e a c h child shall b e m a d e a s follow s'
E d u catio n d e c is io n s
N o n -e m e rg e n c y h e alth c a r e
R eligious upbringing
4.3
P e titio n er/m o th er

S o le d e c isio n m aking shall b e o rd e re d to th e P e titio n e r/m o th er for th e following
reasons*
A limitation on th e o th e r p a r e n ts d e cisio n m aking au thority is
m a n d a te d by R C W 2 6 .0 9 .1 9 1 (S e e p a ra g ra p h 2.1)
O n e p a re n t is o p p o s e d to m u tu al d ecisio n m aking, a n d su ch
o p p o sitio n is re a so n a b ly b a s e d on th e following criteria.
(a)
(b)
(c)
(d)
T h e e x iste n c e of a limitation u n d e r R C W 26 0 9 .1 9 1 ,
T h e history of p articipation of e a c h p a re n t in d ecisio n m aking
in e a c h of th e a r e a s in R C W 2 6 0 9 .1 8 4 (4 )(a),
W h e th e r th e p a re n ts h a v e d e m o n s tra te d ability a n d d e s ire to
c o o p e ra te with o n e a n o th e r in d ecisio n m aking in e a c h of th e
a r e a s in
R C W 26 09 184(4)(a); a n d
T h e p a r e n ts g e o g ra p h ic proxim ity to o n e an o th er, to th e
e x te n t th a t it affects th eir ability to m a k e tim ely m utual
d e cisio n s.
carrying out this parenting plan This dispute resolution process may, and under some
local court rules o r the provisions o f this plan must be used before filing a petition to
modify the plan o r a motion for contempt for failing to follow the plan.
No d is p u te reso lu tio n p ro c e ss , e x c e p t court action is o rd e re d

T h e re a re th e following o th e r p rovisions
Parenting Ptan (PPP, PPT, PP) - Page 8 of 10

Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadtngs\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
2 5 3 -5 8 1 -0 6 6 0
1
2
1 F a th e rs altern atin g w e ek e n d shall b e d e sig n a te d for th e y e a r in a d v an c e .

T h e re a re no m a k e u p s a s it is anticipated by th e C ourt th a t s o m e w e e k e n d visits
with F a th e r m a y no t o c cu r an d F a th e r m u st w ait for his next w e ek e n d . T h e C ourt
b eliev es th a t altern atin g sc h e d u le w hich in clu d es m o st M onday holidays would b e
a p p ro p riate for F a th e rs sc h e d u le e a c h year.
2. T h e p a rtie s m ay alw ays m utually a g r e e to a variation in th e s c h e d u le

esp ecially w h e n it is in th e childs b e s t interest.
6
3 If M other a s c e rta in s F a th e r h a s left or b e e n d ism isse d u n su ccessfu lly from

tre a tm e n t o r incurs a criminal a rre st, w arran t, or c h a rg e after th e d a te of this
P aren tin g P lan, in p e rso n visits shall b e s u s p e n d e d pen d in g fu rther court action
9
10
11
12
13
14
15
4.
F a th e r shall h a v e re a so n a b le te le p h o n e c o n tac t with th e child. All te le p h o n e
calls b e tw e e n fa th e r an d child m ay b e m onitored by an adult in th e m o th e rs
h o u seh o ld . P h o n e calls shall b e tw o calls p e r w e e k a t a s c h e d u le d tim e w hile th e
fa th e r is n o t w orking w h e n th e fa th e r is to initiate th e call T h e m o th er will h a v e
C J re a d y to a n s w e r th e call a n d talk to his fa th e r a t th e s c h e d u le d tim e s T h e
m o th er will d e s ig n a te th e d a y s of th e w e e k a n d tim e s by tex t m e s s a g e T h e
m o th er will try to m a k e th e d e sig n a tio n s long stan d in g , s o th a t th e y do n o t
c h a n g e from w e e k to w eek , but th e re n e e d s to b e s o m e flexibility for s c h e d u le
c h a n g e s a n d ex tra-cu rricu lar activities th a t c h a n g e o v e r tim e
5 F a th e r shall confirm his alternating w e e k e n d visitation by W e d n e s d a y a t
6.00 p m. prior to th e w e e k e n d visit. If F a th e r fails to confirm th e visitation by this
time, th at w e e k e n d visitation shall b e forfeited
16
17
18
19
(Only sign if th is is a p ro p o se d p aren tin g plan .) I d e c la re u n d e r p en alty of

perjury u n d e r th e law s of th e s ta te of W ash in g to n th a t th is plan h a s b e e n
p ro p o se d in g o o d faith a n d th a t th e s ta te m e n ts in P a rt II of this P lan a re tru e an d
co rrect
20
21
22
P etitioner
R espondent
23
24

Charlton v Harrison
S \CASES1\Char1ton, Jolene\W orri\Pleadings\Tem porary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660

It is o rd e re d , a d ju d g e d a n d d e c r e e d th a t th e p a re n tin g plan s e t forth a b o v e is a d o p te d
and a p p ro v e d a s a n o rd e r of th is court
WARNING: V iolation of resid en tial pro v isio n s of th is o rd e r with actu a l k n o w led g e of its
te rm s is p u n is h a b le by c o n te m p t of court a n d m ay b e a crim inal o ffen se u n d e r R CW
9A.40 060(2) or 9A 4 0 0 7 0 (2 ) Violation of this o rd e r m ay s u b je c t a violator to a rre s t
W hen m utual d e cisio n m ak in g is d e sig n a te d but c a n n o t b e a c h ie v e d , th e p a rtie s shall
m ak e a go o d faith effort to re so lv e th e is su e th ro u g h th e d is p u te resolution p ro c e s s
If a p a re n t fails to com ply with a provision of this plan, th e o th e r p a re n ts oblig atio n s
u n d e r tl
D ated
P re s e n te d by.
& COOK, P S
A p p ro v ed by
Of A ttorneys for P etitio n er
P ro S e
A pproved an d a g re e d by
A sig n atu re below is actu al notice of this
order

WPF DR 01 0400 Mandatory (6/2008)- RCW 26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadings\Temporary Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
May 12 2011
1
KEVIN S
COUNTY
2
3
4
5
6
7
8
Petitioner(s),
10
Cause No.
08-3-00821-4
O rder Granting
Adequate Cause
vs.
11

12
Respondent(s)
C lerks Filing code: ORAGR
13
14
15
16
proceed to trial with regard to a Petition which has been filed.
17
18
ORDERED the Show Cause hearing determining Adequate Cause is granted.
19
20
21
22
Dated this
12 day of May, 2011
23
24
25
/S/WENDY ELLEN ZICHT

Judge/Commissioner
-00821-4
36390682
ORGAC
05-13-11
4
5
6
7
8

COUNTY OF PIERCE
10
In re.
No. 08-3-00821-4
11

Child,

(Modification/Adjustment of
Plan/Residential Schedule)
[ 1 Denied (ORRACD)
Granted (ORRACG)
[ ] Hearing set (ORH)
12

and
13
14

15
16
I. Basis
17
18
1.1
A petition re q u e stin g th e m o d ificatio n /ad ju stm en t o f th e c u sto d y d e c re e /p a re n tin g

p lan /resid en tial s c h e d u le in th is m a tte r h a s b e e n p re s e n te d to th e court
12
A h earin g w a s held on d o e s n ot apply b e c a u s e th is o rd e r is a n a g re e d o rd er
19
20
II. Findings
21
The Court Finds:
22
2.1
23
Jurisdiction
This co u rt h a s jurisdiction o v e r th e p ro c e ed in g a n d th e p arties
24
2.2
25
T h e nonm oving party w a s s e r v e d with a co p y of th e petition o r joined in th e


26 10 200
Charlton v Harrison
S \CASES1\Chadton, Jolene\Word\Pleadings\Order re Adequate Cause doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920 - 100th St SW #25
Lakewood, WA 98499
253-581-0660
petition for m o d ificatio n /ad ju stm en t of c u sto d y d e c re e /p a re n tin g p lan /resid en tial
s c h e d u le , su m m o n s, a p ro p o s e d p aren tin g plan, a n d child s u p p o rt w o rk sh ee t, if
any, on April 10, 2 0 1 1 .
2.3

T h e nonm oving p arty w a s s e r v e d (or jo in ed ) within th e s ta te of W ash in g to n a n d
m o re th a n 20 d a y s h a v e e la p s e d s in c e th e d a te of serv ice.
2.4
Response
T h e nonm oving party h a s re s p o n d e d or h a s joined in th e petition
2.5

[]
7C
[]
2.6
A d e q u a te c a u s e for h earin g th e petition h a s not b e e n e s ta b lis h e d

A d e q u a te c a u s e for h earin g th e petition h a s b e e n e s ta b lis h e d
T h e p a rtie s stip u la te th a t th e re is a d e q u a te c a u s e for h earin g th e petition

2 6.1
S erv ice m e m b e r s ta tu s It a p p e a r s th e nonm oving p arty

is n ot a se rv ic e m e m b e r,
2 6.2
D e p e n d e n t of a se rv ic e m e m b e r s ta tu s It a p p e a r s th e nonm oving party'

is not a d e p e n d e n t of a re s id e n t of W ash in g to n w ho is on activ e d u ty a n d
is a N ational G u a rd m e m b e r or a R eserv ist;
III. Order
It is Ordered
C "N T y ^ # o
U n i t 's
T h e m a tte r is s e t for h earin g or trial at*

D ate S e p te m b e r 21, 2011
P la c e P ie rc e C o unty S u p e rio r C o u rt
Tim e 9 0 0 a m
R oom /D epartm ei
D ated
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 2 o f 3

26 10 200
Charlton v Harnson
S \CASES1\Char1ton, Jolene\Word\Pleadmgs\Order re Adequate Cause doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
ofpici
P r e s e n te d by.
& CO O K , P S
A pp ro v ed b y
By DANIEL N COOK, W SB A # 3 4 8 6 6
Of A tto rn ey s for P etitio n er
Christoi
P ro S e
H arrison, R e s p o n d e n t
A pproved an d a g re e d by:
A sig n a tu re below is actu al notice of this
order.
A
- M
Jjdfifne C harlton, P etitio n er/M o th er

26 10 200
Charlton v Harrison
S \CASES1\Chadton, Jolene\Word\Pleadmgs\Order re Adequate Cause doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920 - 100m St SW #25
Lakewood, WA 98499
253-581-0660
.00821-4
36390685
tm ro
05-13-11
"
c 0 U N T y F C L E R K 'S
1 2 2011
om C B
p
5
6^
o m N cG T 0 N
7#------ D E P U T Y
7
8

COUNTY OF PIERCE
10
In re
No. 08-3-00821-4
11

Child,
Temporary Order
(TMO/TRflRO)
12

and
13
14

R e s p o n d e n t/F a th e r.
15
16
I. Judgment/Order Summaries
17
18
19
20
21
1.1
Restraining Order Summary

R estrain in g O rd e r S u m m a ry is s e t forth below.
N am e of p e rs o n (s) re stra in e d . JO L E N E HARRISON AND C J HARRISON

N am e of p e rs o n (s) p ro te c te d C J HARRISON AND JO L E N E HARRISON
See paragraph 3.1
22
23
24
Violation of a Restraining Order in paragraph 3.1 with actual notice of its terms is a
criminal offense under Chapter 26.50 RCW and will subject the violator to arrest
RCW 26.09.060.
25
Temp Order (TMO/TMRO) - Page 1 of 5
WPF DR 04 0250 Mandatory (7/2009) - RCW 26 09 060, 110, 120, 194,

300(2)
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadmgs\Temporary Order docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
1.2
Money Judgment Summary
D o es not ap p ly
3
ll. Basis
4
5
A m otion for a te m p o ra ry o rd e r w a s p re s e n te d to this co u rt a n d th e co u rt finds

re a s o n a b le c a u s e to is s u e th e order.
III. Order
It is Ordered:
3.1
9
10
Restraining Order
Previous Order
[]
11
T h e prior te m p o rary restraining o rd er d a te d April 8, 201 1 , rem ain s in full

fo rce a n d effect
T h e prior te m p o rary restraining o rd er d a te d April 8, 2011.
[ L Is te rm in a te d
te rm in ated a n d rep laced by th e following;
12
13
This o rd e r shall b e filed forthwith in th e clerk s office a n d e n te re d of record

T h e clerk of th e court shall forward a co p y of this o rd er on or b efo re the
next judicial d ay to (n am e of ap p ro p riate law e n fo rc e m e n t ag en cy ) LESA
w hich shall forthwith e n te r this o rd er into an y c o m p u te r-b a se d criminal
in telligence s y s te m availab le in this s ta te u s e d by law e n fo rc e m e n t
a g e n c ie s to list o u tstan d in g w a rra n ts
14
15
16
The protected party or the protected partys attorney must complete

a law enforcement information sheet and provide it with this order
before this order will be entered into the law enforcement computer
system .
17
18
19
20
21
22
Violation o f a Restraining Order in paragraph 3.1 with actual notice of its

terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest RCW 26.09.060.
[]
D o e s no t apply
BOTH PA R TIES a re restrain ed a n d en jo in ed from disturbing th e p e a c e of
th e o th e r party or of an y child
23
24
[sp
25
C H R IS T O P H E R HARRISON is re stra in ed a n d en jo in ed from going onto

th e g ro u n d s of or entering th e hom e, w ork p la ce o r sch o o l of th e o th er
WPF DR Q4 0250 Mandatory (7/2009) - RCW 26 09 060, 110, 120, 194,

300(2)
Charlton v Harrison
S \CASES1\Char1ton, Jolene\WonJ\Pleadings\Temporary Order docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
"z S - t
"P #5 ?
party, or th e d a y c a re or sch o o l of th e following n a m ed children.

C J HARRISO N .
C H R IS T O P H E R HARRISON is re stra in e d a n d en jo in ed from knowingly
conning within or knowingly rem aining within (d istan ce)
.^ 0 0
____________________ of th e hom e, work p la ce or
s c h o o l of th e o th e r party, or th e d a y c a r e or sch o o l of th e s e children: C J
H A RR ISO N
4
5
[]
10
11
C H R IS T O P H E R HARRISON is re stra in e d a n d enjoined from m olesting,

assa u ltin g , h a ra ssin g o r stalking (n a m e ) JO L E N E HARRISON (T he
following firearm restrictions apply if th is box is c h ec k e d an d th e p arties
a r e intim ate p a rtn e rs a s defined u n d e r fed eral law Effective im m ediately
a n d continuing a s long a s this restraining o rd e r is in effect, th e restrain ed
p e rs o n m ay no t p o s s e s s a firearm or am m unition 18 U S C. 922(g)(8)
A violation of this fed eral firearm s law carrie s a m axim um p o ssib le p en alty
of 10 y e a rs in prison a n d a $ 2 5 0 ,0 0 0 fine An ex cep tio n ex ists for law
e n fo rc e m e n t officers an d military p e rso n n e l w h e n carrying
d e p a rtm e n t/g o v e rn m e n t-issu e firearm s. 18 U S C 9 2 5 (a )(1 ))
12
Clerks Action/Law Enforcement Action
13
&
14
15
T his o rd e r shall b e filed forthwith in th e clerk s office a n d e n te re d of reco rd

T h e clerk of th e court shall forw ard a copy of this o rd er on or b efo re th e
n e x t judicial d ay to (n a m e of a p p ro p riate law e n fo rc em en t ag en cy ) LESA
w hich shall forthwith e n te r this o rd er into a n y c o m p u te r-b a se d criminal
intelligence sy ste m av ailable in this s ta te u se d by law en fo rc em en t
a g e n c ie s to list o u tstan d in g w arran ts.
16
18
The protected party or the protected partys attorney m ust complete a law
enforcement information sheet and provide it with this order before this
order will be entered into the law enforcement computer system
19
Service
17
20
J/
T h e restrain ed party or atto rn ey a p p e a re d in court or sig n ed this order;

s e rv ic e of this o rd er is not required.
[]
T h e re stra in ed party o r atto rn ey did n o t a p p e a r in court; service of this

o rd e r is required T h e req u estin g party m u st a rra n g e for serv ice of this
o rd e r on th e restrain ed party File th e original R eturn of S erv ice with th e
clerk an d provide a copy to th e law e n fo rc e m e n t a g e n c y listed ab o v e.
21
22
23
24
Expiration Date
25
T his restrain in g o rd e r will ex p ire in 12 m o n th s a n d shall b e rem o v ed from a n y


300(2)
Charlton v Harrison
S \CASES1\Chariton, Jolene \ WordP!eadtngs\ Temporary Order docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-58T0660
5? ^
23
si sr i_
iP
- cJ
y "
c o m p u te r-b a s e d criminal in tellig en ce s y s te m av ailab le in th is s ta te u s e d by law

e n fo rc e m e n t a g e n c ie s to list o u tsta n d in g w a rra n ts, u n le ss a n ew o rd e r is is su e d ,
o r u n le s s th e co u rt s e ts forth a n o th e r expiratio n d a te h ere: (m o n th /d ay /y ear)

5
P u rs u a n t to 18 U S C 2265, a court in a n y of th e 50 s ta te s , th e District of

C olum bia, P u erto Rico, an y United S ta te s territory, a n d an y tribal land within th e
U nited S ta te s shall acco rd full faith a n d cred it to th e order.
3.2
Temporary Relief
A d e q u a te c a u s e is found for hearing th e petition for modification
goocr
Both p a rtie s shall com ply with th e p aren tin g plan which is propooocKby th e ^
P etitio n er w hich includes a provision th a t th e child h a s su p erv ise d visitation only
with th e father.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
3.3
Bond or Security
24
D o es not apply
25

300(2)
Charlton v Harrison
S \CASES1\Chariton, Jolene\WonfPteadmgs\Temporary Order docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
2 5 3 -5 8 1 -0 6 6 0
f- .: 2
i d b^ /? V*'
Tlf ? (S T
3.4
Other
D o e s not apply
3
4
D ated
5
6
P r e s e n te d by
& CO OK , P S.
By D A N IE L T T C O O K , W SB A # 3 4 8 6 6
Of A tto rn ey s for P etitio n er
C h risto p h e r L H arrison, R e s p o n d e n t
P ro S e
10
11
12
A pproved a n d a g re e d by
A sig n atu re below is actu al notice of this
o rd er
13
14
H/la
1..- f t
e n e C h arito
fton,
n , Petiti
P etitio n er/M o th er
15
IN COUNTY* CLERK'S OFFICE
a.m.
MAY 1 2 2011
---------- -
------ OEPUTY
16
17
18
19
20
21
22
23
24
25
Temp Order (TMOmflRO) - Page 5 of 5
300(2)
Charlton v Harrison
S \CASES1\Chartton, Jolene\Wond\Pleadmgs\Temporary Order docx
FAUBION, REEDER.
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
May 16 2011 9:44 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4

COUNTY OF PIERCE
In re:
No. 08-3-00821-4

P etitioner,
an d
Motion and Declaration for

Default
(MTDFL)

I. Motion
P e titio n er J o le n e C h arlto n m o v e s th e co u rt for a n o rd e r of d e fa u lt a g a in s t R e s p o n d e n t
C h risto p h e r H arrison. V e n u e of th is actio n is p ro p e r a s s e t forth in th e D eclaratio n below .
D ated:.
FAUBION, R E E D E R , FRALEY, & C O OK , P .S .
DANIEL N. C O O K , W SB A # 3 4 8 6 6
O f A tto rn ey s for P etitio n er/JO L E N E CHARLTON
Mtn/Deci fo r Default (MTDFL) - Page 1 o f 4
WPF DRPSCU 03.0100 Mandatory (6/2008) - CR 55(a); RCW26.09.030

Charlton v Harrison
C:\Documents and Settings\dcook\Local Settings\Temporary Internet
F/feslContent.Outlook\13RLZYMV\Motion for Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
II. Declaration
2.1
Proper Jurisdiction and Venue

T h e co u rt h a s p ro p e r jurisdiction a n d v e n u e p u rs u a n t to th e a lle g a tio n s of th e petition
a t th e tim e of filing.
T h e p etitio n er re s id e s in P ie rc e C ounty, W ash in g to n .
T h e child(ren) re s id e (s) in P ie rc e C ounty, W ash in g to n .
R e s p o n d e n t re s id e s in King C ounty, W ash in g to n .
2.2
Jurisdiction Over the Other Party

This co u rt h a s jurisdiction o v e r th e o th e r p arty b e c a u s e :
T h e o th e r p arty is cu rren tly residing in W ash in g to n .
T h e p etitio n er a n d re s p o n d e n t lived in W a sh in g to n during th eir m a rria g e or
d o m e stic p a rtn e rs h ip a n d th e p etitio n er c o n tin u e s to re sid e , o r b e a m e m b e r of
th e a rm e d fo rc e s sta tio n e d , in th is s ta te .
T h e p e titio n er a n d re s p o n d e n t m ay h a v e c o n c e iv e d a child w hile within
W ash in g to n .
T h e o th e r p arty w a s p e rso n ally s e r v e d with s u m m o n s a n d petition within this
s ta te .
T h e o th e r p a rty e n g a g e d in s e x u a l in te rc o u rse in th e s ta te of W ash in g to n a s a
re su lt of w hich th e child m ay h a v e b e e n c o n ce iv e d .
T h e o th e r p a rty re s id e d with th e child in this s ta te .
2.3
Service on Other Party

T h e o th e r p a rty w a s s e r v e d with th e following d o c u m e n ts o n April 10, 2 0 1 1 , in King
C ounty, W ash in g to n :
1.
2.
3.
4.
5.
Ex P a r te R estrain in g O rd e r d a te d 4 /1 8 /2 0 1 1
N o te for C o m is sio n e rs C a le n d a r re: A d e q u a te C a u s e
M otio n /D eclaratio n for Ex P a rte R e stra in in g O rd e r
N o te for C o m m issio n e rs c a le n d a r re: T e m p o ra ry O rd er
Sum m ons
Mtn/Decl fo r Default (MTDFL) - Page 2 o f 4

Charlton v Harrison
/=//estContent.Outlook\13RLZYMV\Motion for Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
6. P e titio n e r for M odification/A djustm ent of C u sto d y D e c re e / P a re n tin g

P la n
7. N o tice re: Military D e p e n d e n t
8. D eclaratio n of J o le n e H arrison
9. P r o p o s e d P a ren tin g P lan
10. D e cla ra tio n of J o rd a n S h e rw o o d
11. D eclaratio n of T yler Flohr
12. O rd e r A m en d in g C a s e S c h e d u le
13. S e a le d P e rs o n a l H e a lth c a re R e c o rd s
2.4
Time Elapsed Since Service on the Other Party

T h e o th e r p a rty w a s s e rv e d within th e s ta te of W a sh in g to n a n d m o re th a n 20
d a y s h a v e e la p s e d s in c e th e d a te of s erv ice .
2.5
Appearance of the Other Party

T h e o th e r p arty h a s a p p e a re d , b ut h a s failed to re s p o n d .
2.6

2.6.1
A. S e rv ic e m e m b e r s ta tu s - C H R IS T O P H E R H A RRISO N
[ X]
is n o t a s e rv ic e m em b er;
B. F a c tu a l b a sis :
S e e th e a tta c h e d D e fe n s e M an P o w e r D a ta C e n te r R ep o rt o b ta in e d from
h ttp s ://w w w .d m d c .o sd .m il/sc ra /o w a /h o m e .
2 .6 .2 A. D e p e n d e n t o f a s e rv ic e m e m b e r s ta tu s - C H R IS T O P H E R HARRISON
[X] is n o t a d e p e n d e n t of a re s id e n t of W a sh in g to n w h o is on activ e duty a n d
is a N atio n al G u ard m e m b e r o r a R ese rv ist;
[ ] is a d e p e n d e n t of a re s id e n t of W a sh in g to n w h o is on activ e duty a n d is
a N atio n al G u ard m e m b e r o r a R ese rv ist;
[ ] l a m u n a b le to d e te rm in e w h e th e r th e o th e r p arty is a d e p e n d e n t of a
r e s id e n t o f W ash in g to n w ho is on a c tiv e d u ty a n d is a N ational G uard
m e m b e r o r a R eserv ist.
B. F a c tu a l b a s is :
T h e o th e r p arty failed to re s p o n d to a n o tic e to him o r h e r a s a
d e p e n d e n t of a p e rs o n in Military S e rv ic e th a t w a s [x ] s e rv e d on April
10, 2 0 1 1 , th e re fo re h e o r s h e sh o u ld b e p re s u m e d no t a d e p e n d e n t of a
r e s id e n t o f W a sh in g to n w h o is on a ctiv e d u ty a n d is a N ational G uard
m e m b e r o r a R eserv ist.
Mtn/Decl fo r Default (MTDFL) - Page 3 o f 4
WPF DRPSCU 03.0100 Mandatory (6/2008) - CR 55(a); RCW 26.09.030
Charlton v Harrison
F//es\Content.Outlook\13RLZYMVWlotion for Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
2.7
Other
D o es n ot apply.
4
5
I d e c la re u n d e r p e n alty o f perjury u n d e r th e law s of th e s ta te of W ash in g to n th a t th e

foregoing is tru e a n d co rrect.
D ated this
d a y of _
__ , 2 0 1 1 , a t L ak ew o o d , W ash in g to n .
7
FAUBION, R E E D E R , FRALEY, & COOK, P .S .
10
DANIEL N. CO OK , W S B A # 3 4 8 6 6
O f A tto rn ey s for P etitio n er/JO L E N E CHARLTON
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Mtn/Decl fo r Default (IWTDFL) - Page 4 o f 4

Charlton v Harrison
F//es\Content.Outlook\13RLZYMV\Motion for Default.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Page 1 o f 2
Department of Defense Manpower Data Center
May-13-2011 09:02:29
Military Status Report

Pursuant to the Service Members Civil Relief Act
Last
Name
Active Duty End

Service
Date
Agency
CHRISTOPHER Based on the information you have furnished, the DMDC does not
HARRISON
LEE
possess any information indicating the individual status.
First/Middle
Begin Date Active Duty Status
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard). HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF
DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT
THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE
OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL.
Mary M. Snavely-Dixon, Director

Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App.
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain farther verification of the persons status by contacting that person's Service via the
"defenselink.mil" URL htto://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. 521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
5/13/2011
Page 2 o f 2
contact.
M o r e in fo rm a tio n on "A c tiv e D u ty S ta tu s
"
Active duty status as reported in this certificate is defined in accordance with 10 USC 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
C o v e r a g e U n d er th e S C R A is B r o a d e r in S o m e C a se s
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
Report ID :DNEE79UONU
5/13/2011
E-FILED
May 16 2011 9:44 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
in t h e s u p e r i o r c o u r t o f t h e s t a t e o f
Wa s h in g t o n
in a n d f o r p i e r c e c o u n t y

No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)
t o t h e c l e r k o f t h e s u p e r io r c o u r t a n d t o :

Phone:
Respondent
S h o w C ause
Nature of Hearing: Other MOTION FOR DEFAULT
calen dar d ate:
Monday, June 20, 2011
9:30 AM
w o r k in g c o p ie s s h a l l b e s u b m it t e d t o c o m m is s io n e r s s e r v ic e s r o o m
before
140,
12:00 NOON TWO COURT DAYS PRIOR TO HEARING
DATED:
May 16, 2011.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
ADDRESS: 5920 100th St SW Ste 25
WSBA#:
For:
34866
1 of 1
E-FILED
May 16 2011 9:50 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)

Phone:
Respondent
Pierce County Superior Court, County-City Building - 930 Tacom a Ave S - Tacom a, W A 98402
S h o w C ause
Nature of Hearing:
Other,OTHR~Other MOTION FOR DEFAULT,MOTION FOR DEFAULT
CALENDAR DATE: Wednesday, June 22, 2011
9:30 AM
W ORKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,

BEFORE 12:00 NOON TW O COURT DAYS PRIOR TO HEARING
DATED:
May 16, 2011.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
ADDRESS: 5920 100th St SW Ste 25
W SBA#:
34866
For:
1 of 1
.
E-FILED
May 16 2011 10:19 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6

COUNTY OF PIERCE
In re:
10

Petitioner,
and
11
No. 08-3-00821-4
12
13
14

Respondent.
I, Sally D u C h arm e, am o v e r th e a g e of 18, a n d c o m p e te n t to testify in th e a b o v e
entitled c a s e .
15
16
O n M ay 13, 2 0 1 1 , I p laced in th e U.S. Mail a co p y of th e following d o c u m e n ts in th e

a b o v e-en titled caption:
17
1. In te rro g ato ries a n d R e q u e s ts for Production.

18
19
O n M ay 16, 2 0 1 1 , I p la ce d in th e U .S. Mail a co p y of th e following d o c u m e n ts in th e

a b o v e -e n title d caption:
2.
3.
4.
5.
6.
24
N o te for C o m m issio n e r's C a le n d a r on J u n e 22, 2 011;

M otion a n d D eclaratio n fo r D efault;
O rd e r re A d e q u a te C a u s e e n te r e d on M ay 12, 2011;
T e m p o ra ry P a re n tin g P lan e n te r e d on M ay 12, 2 0 1 1;and
T e m p o ra ry O rd er
S a id d o c u m e n ts w e re a d d r e s s e d to:
25
Chariton v Harrison
S:\CASES1\Charlton, Jolene\Word\Pleading$\Declaration of Mailing, docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
5 9 2 0 -1 0 0 th S t re e t S W , S t e 2 5
Lakew ood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
I d e c la re , u n d e r th e p e n alty of perjury a n d th e Law s of th e S ta te of W ash in g to n , th a t

th e forego in g is tru e a n d co rrect.
DATED
M ay 16, 2011
S ally [M C h arm e, Legal A ss is ta n t

Charlton v Harrison
S:\CASES1\CharIton, JoIene\Word\Pleadings\Declaration of Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, W A 98499
253-581-0660
**
RCOPC
-3-00821-4
fi
2 8 -v' 2 S i $
3 < *3 7
06-20-11
36623542
IN COUNTY"CLERKS OFFICE
"""
-* 1
'
rM
pl|RCE COUNTY WASHINGTON

0Y-------------V-/ ---------DEPUTY
IN RE:
/ / */ / )
\ J o l**1*-
P etitioner/P laintiff,
No.
Vs.
C ^ b /^ b p h er
day of
2007 document,coversheet. doc
'V
(D ocu m e n t T itle)
IL rt'* 0
n c \r
Respondent/Pefendant
Dated this O
O K - l -0 0 8 2 1
20 1/
^ 2 3. ~1
i c' ^ "5 V
3
4
5
6

COUNTY OF KING
9
10
NO
P etitioner(s),
11
C ER TIFIC A TE O F CO M PLETIO N
O F MANDATED SEM INAR
(C O P C )
12
13
R e s p o n d e n t(s )
14
15
16
This is to certify th a t CHRISTOPHER HARRISON c o m p le te d th e s e m in a r
17
m a n d a te d u n d e r King C o u n ty S u p e rio r C o u rt Local Fam ily Law R u le 13(c) on M ay 18th,
18
2011 .
19
20
21
22
DISTRIBUTION:
Original (W h ite) C lerk's office
Copy (G reen ) - A tten d ee
CERTIFICATE OF COMPLETION OF
MANDATED SEMINAR
Page 1
4r-
14878
For Petitioner
RE
88814
For Respondent
c ^ p O v o W ^ T 7
_ U 2 lr t U : J ^ _
. . a . . . 0 2a
n o
~ T W
^.nYesr g ,
r>r
V>____ C A o p ^ r r e -
June 22, 2011 9:30 AM
Show Cause
___________
ript.cA / t
,_____________________________________________________________
WENDY ELLEN ZICHT

U -
Clerk
_______
Courtroom number 117

Calendar C2 - SHOW CAUSE/FAMILY LAW
Ixcrtrpt pbl djoumal_entry_showcause_report
E-FILED
June 22 2011 3:32 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
7
COUNTY OF PIERCE
In re:
No. 08-3-00821-4
10

P etitioner,
and
11
12
13
14

I, Sally D u C h arm e, a m o v e r th e a g e of 18, an d c o m p e te n t to testify in th e a b o v e
entitled c a s e .
15
16
O n J u n e 22, 2 0 1 1 , I p la ce d in th e U .S. Mail a co p y o f th e following d o c u m e n ts in th e

ab o v e-en titled caption:
17
1. O rd e r is su e d 06/22/11
2. B lank R e s p o n s e form .
18
19
S a id d o c u m e n ts w e re a d d r e s s e d to:
20
21
22
I d e c la re , u n d e r th e p en alty of perjury a n d th e L aw s of th e S ta te of W ash in g to n , th a t

th e foregoing is tru e a n d co rrect.
DATED
J u n e 22, 2011
23
ally D uQ fiarm e, L egal A s s is ta n t
24
25
Charlton v Harrison
S:\CA SES1 \Charlton, Jolene\Word\Pleadings\Declaration of Mailing, docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
6 * '2 4 / 2 8 1 1
>
08-3-OOB21-4
36651/47
'N C O W
06- 23-1 1
ORRE
i4 0 T " S
0 B 0 ih
y Fc ' [ f RD K ,S o m c e
-OgPUTV
('J m e c T & rJ
O t - 3 'C 0 3 2 / -
No.
Petitioner(s),
and
ORDER
49
[ ] Clerks action required
R espondent(s).
THIS MATTER having com e before the Court upon the moving party's Motion, and the
Court having heard the argum ent of the parties and having considered the records and files
herein, it is now therefore,
ORDERED, ADJUDGED AMD DECREED___________________________________

___________
P -riT 7 Q A / ie
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Order (OR) - Page 1 of 2

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Approved for entry.
P resented by.
1N COUNTY CIERK'S OFFICE
Notice of presentation w a iv e d jy ^ j 2 2 ^ 1 1
PM
ntcori- 1 \ >urti t WASHINGTON

P KEVIN STOCK, County Clerk
\
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Signature/WSBA #
J ? flr S l C -
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Print Nam e
Signature/W SBA #
_______________
Print Name
Order (OR) - Page 2 of 2

WPF DRPSCU 01.0150 (6/2006)
F \Word\Commissioners Busrness\Ex Parte Dept\Courtroom Fonms\Blank order #2 DOC
7 ^ 2 8 ^ 2 8 1 1
1 4 5 5 1
07-27-H
Q8-3-008
^ .4
36808419
RDR
FILE D
AM JUL 27 2011 RHL
PIERCECOUNTY
k e v in s t o c k :
7
8

COUNTY OF PIERCE
9
10
In re:
No. 08-3-00821-4
11

P etitioner,
and
Order on Motion for Default

(ORDFL)
granted (ORDFL)
[ ] denied (ORDYMT)
12
13

14
15
16
I. Basis
A m otion for d efau lt h a s b e e n p re s e n te d by Petitioner, JO L E N E MARIE CHARLTON.
17
18
II. Findings
T h e court finds:
19
2.1
Proper Jurisdiction and Venue
20
T h e court h a s p ro p er jurisdiction a n d v e n u e.
21
22
23
24
25
2.2
Service on Nonrequesting Party

O n April 10, 201 1 , C H R IS T O P H E R LEE HARRISON w a s s e rv e d with
1.
2.
3.
4.
Ex P a rte R estrain in g O rd e r d a te d 4/18/2011

N ote for C o m issio n e rs C a le n d a r re: A d e q u a te C a u s e
M otion/D eclaration for Ex P a rte R estrain in g O rd er
N ote for C o m m issio n e rs c a le n d a r re: T em p o rary O rd e r
Ord of Default (ORDFL) - Page 1 o f 3
WPF DRPSCU 03 0200 Mandatory (6/2008) - CR 55(a) , RCW 26 09 020

Charlton v Harrison
S \CASES1\Chariton, Jolene\W ord\Pleadmgs\Order on Default doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
:b
7 /2 8 /2 0 .1
1 4 5 5 1
2 2 8 1 1 5
5
6
7.
8
9.
10
11.
12.
13.
2
3
4
5
6
7
2.3
Summons
Petitioner for Modification/Adjustment of Custody Decree / Parenting Plan
Notice re Military Dependent
Declaration of Jolene Harrison
Proposed Parenting Plan
Declaration of Jordan Sherwood
Declaration of Tyler Flohr
Order Amending Case Schedule
Sealed Personal Healthcare Records
Time Elapsed Since Service

The nonrequesting party was served within the state of Washington and more
than 20 days have elapsed since the date of service.
9
2.4
Appearance
10
The nonrequesting party has appeared but has failed to respond.
11
12
2.5

2.5.1 Service member status --- It appears the nonrequesting party
13
is not a service member;
14
2.5.2 Dependent of a service member status It appears the nonrequesting

party*
15
16

is a National Guard member or a Reservist;
17
18
19
20
2.6
Other
FILED
n/a
a.m.
III. Order
JUL 2 7 2011 m
PERCE COUNTY WASHINGTON

KEVIN STOCK. County Clerk
BY___________________ DEPUTY
it is Ordered:
21
22
23
[1 The motion is denied

fQ The nonrequesting party is iiîefault.
DONE IN OPEN COURT t h i s ^ f e ^ fla y
%Ui
Judê/Commissioner
Ord of Default (ORDFL) - Page 2 of 3
WPF DRPSCU 03 0200 Mandatory (6/2008) - CR 55(a), RCW 26 09 020

Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadings\Order on Default doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920 - 100th St SW #25,
Lakewood WA 98499
253-581-0660
722822811
14551
228115
^ 1
1
2
3
PRESENTED BY:
FAUBION, REEDER, FRALEY & COOK P.S.
4
5
DANIEL N. COOK, WSBA# 34866

Of Attorneys for Petitioner/Jolene Charlton
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ord of Default (ORDFL) - Page 3 of 3
WPF DRPSCU 03 0200 Mandatory (6/2008) - CR 55(a), RCW 26 09 020

Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pieadmgs\Order on Default doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
14 S S I
ZZBV17
1
07-27-11
08-3-00821-4
36838420
4
5
* C0" V W W ,CE

COUNTY OF PIERCE
10
11
12
13
14
15
16
17
18
19
20
In re:
No. 08-3-00821-4

Child,
FINAL
PARENTING PLAN
(PPT)

Petitioner/Mother,
and
Respondent/Father.
This is the final parenting plan entered with the court

IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
I. GENERAL INFORMATION
This parenting plan applies to the following child.
21
22
23
Name
CHRISTOPHER HARRISON, JR
Age
6
Date of Birth
02/22/2005
II. BASIS FOR RESTRICTIONS
Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the right to make decisions for the child.
WPP DR 01 0400 Mandatory (6/2008)-R C W 26 09.016, 181; 187, 194
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadings\Fma! Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 tOOth Street SW, Suite 25

Lakewood, WA 98499
253-581-0660
'? v 2 8 / 2 01 I. 1 4 S 5 I
220118
2.1
The Respondents residential time with the child(ren) shall be limited or

resolution process other than court action shall not be required, because [X] this
parent [ ] a person residing with this parent has engaged in the conduct which
follows:
3
4
A history of acts of domestic violence as defined in RCW 26.50.010(1) or

an assault or sexual assault which causes grievous bodily harm or the fear
of such harm.
7
8
2.2

The Respondents involvement or conduct may have an adverse effect on the
child(ren)s best interests because of the existence of the factors which follow
10
11

performance of parenting functions as defined in RCW 26.09.004
12
13

abuse that interferes with the performance of parenting functions
14
15
16
The residential schedule must set forth where the child(ren) shall reside each day o f the
year, including provisions for holidays, birthdays of family members, vacations, and
other special occasions, and what contact the child(ren) shall have with each parent.
needs o f the child(ren) and individual needs o f their family. Paragraphs 3.1 through 3.9
17
18
19
20
3.1
21
There are no children under school age
22
23
3.2
School Schedule
Upon enrollment in school, the child(ren) shall reside with the Petitioner/mother,
24
W P F D R
01
(P P P , P P T ,
P P ) - P a g e 2
o f 11
0 4 0 0 M a n d a to r y ( 6 /2 0 0 8 ) - R C W
2 6 0 9 .0 1 6 ,
Charlton v Harrison
S \CASES1\Char1ton, Jolene\Word\Pleadmgs\Fmal Parenting Plan doc
181,
187;
194
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
7SZ8SZ811
145 51
220119.
After completion of the requirements in Paragraph 3 10, from (day and

time)
Friday 7:00 p.m.________ to (day and time)
Sunday 7:00 p m.
every other week.
2
3
4

5
6
3.3

The child(ren) shall reside with the Petitioner/mother during winter vacation,
with the other parent.
7
8
After completion of the requirements in Paragraph 3 10, the first day of

School Winter Vacation at 6:00 p m. to the day after Christmas at 6:00
p.m. every other year. The day after Christmas at 6.00 p m. to New
Years Day at 6:00 p.m in the alternating years. See Section 3 7.
9
10
11
Until completion of the requirements in Paragraph 3.10, only supervised

12
13
3.4
14
The child(ren) shall reside with the Petitioner/mother during other school breaks.
15
16
3.5
Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the
Petitioner/mother, except for the following days and times when the child(ren) will
reside with or be with the other parent
17
18
19
20
After completion of the requirements in Paragraph 3.10, Father to be

allowed in addition to regular every other weekend visit 1 week in July,
and 1 week in August beginning with a Friday of a regular weekend visit
for father.
21
22
Until completion of the requirements in Paragraph 3.10, only supervised

23
24
3.6

Does not apply.

WPF DR 01 0400 Mandatory (6/2008) -R C W 26 09 016, 181, 187, 194
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadmgs\Fmal Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
1 4 5 5 1
2 2 B 1 2 B
3.7
There is no Holiday schedule until after the requirements in Paragraph 3 10 are

completed.
3
4
After completion of the requirements in Paragraph 3.10, the residential schedule

for the child(ren) for the holidays listed below is as follows:
With Mother
(Specify Year
Odd/Even/Everv)
6
7
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
Easter
8
9
10
11
12
13
ODD
See Weekend
See Weekend
See Weekend
ODD
See Weekend
Everv
EVEN
ODD
ODD
EVEN
With Father
(Specify Year
Odd/Even/Everv)
EVEN
Schedule
Schedule
Schedule
EVEN
Schedule
ODD
EVEN
EVEN
ODD
14
[X]
For purposes of this parenting plan, a holiday shall begin and end as
follows (set forth times): See Section 3.2 above. Weekends may include
holiday Mondays in which case the Sunday return time becomes Monday
[X]
Holidays which fall on a Friday or a Monday shall include Saturday and

Sunday.
15
16
17
18
Does not include: Winter break, New Years Day, Christmas Eve or
Christmas Day, as these holidays have special designated times.
See 3.3
19
20
3.8
21
22
23
24
There is no Special Occasion schedule until after the requirements in Paragraph

3.10 are completed.
for the child(ren) for the following special occasions (for example, birthdays) is as
follows1

WPF DR 01 0400 Mandatory (6/2008) -RCW 26.09 016, 181, 187, 194
Chariton v Harrison
S \CASES1\Chadton, Jolene\Word\Pleadings\Final Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
7/28''2& n
14551
.22.% 1 7.1
1
2
3
Mothers Day
Fathers Day
With Mother
(Specify Year
Odd/Even/Everv)
EVERY
With Father
(Specify Year
Odd/Even/Everv)
EVERY
4
5
3.9
Does not apply because one parent has no visitation or restricted visitation
6
7
8
9
10
11
12
13
14
3.10
Restrictions
The Respondent/fathers residential time with the children shall be limited
restrictions shall apply when the children spend time with this parent:
All visitation shall be supervised by Petitioners mother or a professional
visitation supervisor (at Respondent/fathers expense)* unless and until
Respondent/father completes the following requirements:
a) Compliance with drug/alcohol conditions of release and probation which shall
include collateral contact with Petitioner/mother Jolene Charlton and any
recommended follow-up treatment. Respondent shall provide Petitioner with
name of probation officer and copies of all documents and reports and
compliance records in his alcohol offence monitoring program.
15
16
17
18
19
20
b) A State certified domestic violence assessment which shall include collateral

contact with Petitioner/mother Jolene Charlton and any recommended
follow-up treatment if father does not provide the mother with a copy of his
DV assessment from Valley Cities/Gloria Axtel and collateral contact with
that agency.
c) Father shall provide mother proof of current mental health treatment
providers, proof he is stable, taking the appropriate prescribed
medications, and prior mental health issues are under control, after
collateral contact with mother.
21
22
23
24
d) Respondent/father shall sign authorization for release of information to

Petitioner/mother Jolene Charlton for all evaluations above and any and
all treatment providers or other individuals or case workers engaged in
response to requirements set forth above. In addition, the father will
provide the mothers attorney any drug and alcohol assessments.

Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleadings\Fmal Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
1 4 5 5 1
721VT2.
Contact shall be limited to visits in the county where the child resides of no more
than 3 hours per visit for no more than 10 visits per month on a schedule
arranged between the supervisor and Petitioner/mother Jolene Charlton. Costs of
supervision shall be paid by Respondent/father Christopher Harrison.*
3
4
* Professional supervised visitation shall be a shared expense if Father is current on

support beginning in April 2011
5
3.11
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
7
8
Transportation arrangements for the child(ren), between parents shall be as

follows:
Prior to completion of requirements in Paragraph 3.10, visitation shall be

at a location chosen by the mother in consultation with the visitation
supervisor within reasonable proximity to the mothers residence.
10
11
12
After completion of requirements in Paragraph 3 10, the receiving parent

shall provide transportation.
13
14
3.12
The children named in this parenting plan are scheduled to reside the majority of
the time with the Petitioner/mother JOLENE CHARLTON This parent is
designated the custodian of the child(ren) solely for purposes of all other state
and federal statutes which require a designation or determination of custody.
This designation shall not affect either parents rights and responsibilities under
this parenting plan.
15
16
17
18
19
20
21
22
3.13
Other
This parenting plan is entered in anticipation of and with the full knowledge that
the mother will soon be relocating to Idaho sometime before September 2011. A
trial has already been held on the issue of the mothers move to Idaho so no
Notice of Relocation need be given when the mother moves prior to September
2011, except that the mother will provide the father with her new residential
address after she moves.
23
24
No transporting of child unless approved driver has license and insurance.

Fathers aunt or uncle, Fathers Mother or Step-Father all approved and others as
mentioned by Mother are approved.

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09 016, 181, 187, 194
Charlton v Harrison
S \CASES1 \Charlton, Joiene\Worcf\Pleadings\Final Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
?72e^281X
-14 S S I
228123
3.14
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
This is a summary only For the full text, please see RCW 26.09.430 through
26.09.480.
the child.
notice by personal service or by mail requiring a return receipt. This notice must
be at least 60 days before the intended move. If the relocating person could not
information required in RCW 26 09 440. See also form DRPSCU 07.0500,
If the move is within the same school district, the relocating person must provide
may not object to the move but may ask for modification under RCW 26 09.260.
program, it may be withheld from the notice
put the health and safety of a person or a child at risk.
contempt.
schedule may be confirmed
the childs relocation whether or not he or she received proper notice.
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/Residentia! Schedule). The objection must be served on
all persons entitled to time with the child.
unless, (a) the delayed notice provisions apply, or (b) a court order allows the
move.
Charlton v Harrison
S \CASES1\Charlton, Jolene\Word\Pleadtngs\Final Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
7 - '2 8 ^ 2 0 1
!4 5 S t
2201 2 4
2
3
IV. Decision Making
4
5
4.1
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 children.
7
8
9
4.2
Major Decisions
10
11
Education decisions
12
13
14
15
16
4.3
Petitioner/mother
Petitioner/mother
Petitioner/mother

Sole decision making shall be ordered to the Petitioner/mother for the following
reasons.
A limitation on the other parents decision making authority is
mandated by RCW 26 09.191 (See paragraph 2.1)
17
18
19
20
21
One parent is opposed to mutual decision making, and such

opposition is reasonably based on the following criteria:
(a)
(b)
(c)
22
23
24
(d)

The history of participation of each parent in decision making
in each of the areas in RCW 26.09.184(4)(a),
Whether the parents have demonstrated ability and desire to
cooperate with one another in decision making in each of the
areas in
RCW 26.09.184(4)(a), and
The parents geographic proximity to one another, to the
extent that it affects their ability to make timely mutual
decisions.
Parenting Plan (PPP, PPTPP) - Page 8 of 11

Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pleading$\Fina! Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
1 1 t S S t . 2 2 0
2
3
4
5

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
12
13
14
15
16
17
18
19
20
There are the following other provisions
No one shall drive the child without a valid drive

license, insurance and appropriate child safe
restraints
Parties shall comply with all existing court orders ai
treatment requirements, if applicable, from any trib;
municipal, district, superior or federal court
1. Fathers alternating weekend shall be designated for the year in advance.

There are no make ups as it is anticipated by the Court that some weekend visits
with Father may not occur and Father must wait for his next weekend. The Court
believes that alternating schedule which includes most Monday holidays would be
appropriate for Fathers schedule each year.
2.
The parties may always mutually agree to a variation in the schedule
especially when it is in the childs best interest.
3.
If Mother ascertains Father has left or been dismissed unsuccessfully from
treatment or incurs a criminal arrest, warrant, or charge after the date of this
Parenting Plan, in person visits shall be suspended pending further court action.
4.
Father shall have reasonable telephone contact with the child. All telephone
calls between father and child may be monitored by an adult in the mothers
household. Phone calls shall be two calls per week at a scheduled time while the
father is not working when the father is to initiate the call. The mother will have
CJ ready to answer the call and talk to his father at the scheduled times. The
mother will designate the days of the week and times by text message. The
mother will try to make the designations long standing, so that they do not
change from week to week, but there needs to be some flexibility for schedule
changes and extra-curricular activities that change over time.
21
22
23
5.
Father shall confirm his alternating weekend visitation by Wednesday at
6:00 p.m. prior to the weekend visit. If Father fails to confirm the visitation by this
time, that weekend visitation shall be forfeited.
24

WPF DR 01.0400 Mandatory (6/2008) - RCW 26 09 016, 181; 187, 194
Charlton v Harrison
S \CASES1\Chartton, Jolene\Word\Pleadings\Finai Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
7 S 2 B f2 & lt
1 45?
'2 . - Z & 1 2 '.

2
(Only sign if this is a proposed parenting p la n ) I declare under penalty of

perjury under the laws of the state of Washington that this plan has been
proposed in good faith and that the statements in Part II of this Plan are true and
correct.
3
4
5
6
Petitioner
Respondent
Date and Place of S
7
8
^ 7 2011
9
deputy
10
11
12
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
13
14
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.
15
16
17
18
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 pjan^he othgr parents obligations
under the plan are not affected.
19
Dated:
20
21
22
Presented by'
FAUBION, REEDER, FRALEY,
& COOK, P.S.
Approved by:
23
24
B y DANIEL N COOK, WSBA #34866

o f'
Pro Se

WPF DR 01 0400 Mandatory (6/2008)-RC W 26 09 016, 181, 187, 194
Charlton v Harnson
S \CASES1 \Charlton, Jolene\Word\Pleadings\Ftnal Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
14551
:2 3 8 T Z 7
1
2
3
Approved and agreed by:

A signature below is actual notice of this
order.
4
5
Jolene Charlton, Petitioner/Mother
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Charlton v Harrison
S \CASES1 XChartton, Jolene\Wond\Pleadmgs\Final Parenting Plan doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
?y2S'ZQtl
13126
145S1 22B 128
5/ 3/ 2 c l1
...
filed
IN COUNTY C LER KS OFFICE
A.M. WAV' 0 2 2011
K Ev l*ySJCCK,
W ^pc County Clark
-1 1
-_ _ _ _ d e p u t y
0082) V
Cause Number
<? I s tw - f if c iic . m y ip s o n
Case names:
Petitioner
Respondent ft& fy fe e s n * --

Jolene. M[- Qharltoq

Dont Forget the Kids

In the City of Tacoma, State of Washington
Instructors- Susan (Become,
*Wai U (Petersen, *M.S.
7 2822813
1 4 S S 'l
228129
i 1 3 9 9 7 <&3&3
in
am
COUNTY CLERK'S OFFICE
JUN 17 2011 PM
SY-------- W ------ deputy
IN RE:
P*l//i'aA>l
\J o
Petitioner/PlaintifF,
No. O K - l - o o 8 2 > ' V
Vs.
/'iJa fib er
R e sp o n d e n t/D e fe n d a n t
Dated this H
day of >1Vie
2007 document covtnheeLdoc
20 / /
145S
t sZ & s2 S l1
1
2
3
4
5

COUNTY OF KING
8
9
10
NO
Petitioner(s),
11
CERTIFICATE OF COMPLETION
OF MANDATED SEMINAR
(COPC)
12
13
Respondent(s)
14
15
16
This is to certify that CHRISTOPHER HARRISON completed the seminar
17
mandated under King County Superior Court Local Family Law Rule 13(c) on May 18th,
18
2011 .
19
20
21
22
23
24
DISTRIBUTION:
25
Original (White) Clerk's office

Copy (Green) - Attendee
CERTIFICATE OF COMPLETION OF
MANDATED SEMINAR
Page 1
7 ' 2 S
1i
14551
2 2 8 1 3 -1
1
2
08-3-00821-4
36838421
orwo
07-27-11
3
4
5
,N COUNTYCLERK'S OFFICE
a.m.
JUL 27 2011
RM,
7
lDgPlffV
8

COUNTY OF PIERCE
9
10
In re*
No. 08-3-00821-4
11

Petitioner,
and
Order Re
Modification/Adjustment
Of Custody Decree/Parenting
(ORMDD/ORDYMT)
12
13
14

_______________________ Respondent.
15
16
17
I. Basis
This order is based on:
an order of default signed by the court on this date.
18
II. Findings
19
The C ourt Finds :
20
2.1 Jurisdiction
21
22
23
24
This court has jurisdiction over this proceeding for the reasons below.
This court has exclusive continuing jurisdiction. The court has previously
made a child custody, parenting plan, residential schedule or visitation
determination in this matter and retains jurisdiction under RCW 26.27.211
25
Ord Re Mod/Adj o f Parenting Pin (ORMDD, ORDYMT) - Page 1 o f 4
WPF DRPSCU 07 0400 Mandatory (6/2008) - RCW 26.09 260, 270,

26 10 200
Charlton v Harrison
S \CASES1 \Chariton, Jotene\Word\Pieadings\Order on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
20/283 1
14SSi
220132
1
2
2.2

The custody decree/parenting plan/residential schedule should be modified
because a substantial change of circumstances has occurred in the circumstances
of the children or the nonmoving party and the modification is in the best interest of
the children and is necessary to serve the best interest of the children. This finding
is based on the factors below:
3
4
5
6
The childrens environment under the custody decree/parenting

plan/residential schedule is detrimental to the childrens physical, mental or
emotional health and the harm likely to be caused by a change in
environment is outweighed by the advantage of a change to the children.
7
8
9
The following facts, supporting the requested modification, have arisen since the
decree or plan/schedule or were unknown to the court at the time of the decree or
plan/schedule:
10
11
See Declaration of Jolene Charlton, filed separately on April 8, 2011, which

is incorporated herein by this reference.
12
13
2.3
14

The custody decree/parenting plan/residential schedule should be modified
because the reduction or restriction of the residential time for the person with
whom the children do not reside a majority of the time would serve and protect the
best interests of the children using the criteria in RCW 26 09.191. The following
facts support the request for modification:
15
16
17
See Declaration of Jolene Charlton, filed separately on April 8, 2011, which

is incorporated herein by this reference.
18
19
2.4
20
21

Does not apply.
2.5
22
Does not apply.
23
24
This section only applies to a person with whom the ch ild does n o t reside a
m ajority o f the tim e who is seeking to increase residential time.
25
Ord Re Mod/Adj o f Parenting Pin (ORMDD, ORDYMT) - Page 2 o f 4

2610200
Charlton v Harrison
S \CASESl\Chartton, Jolene\Word\Pleadings\Order on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
< 7 /2 1 ? /2 8 1 !
2.5.1
i4 B 5 1
2 2 8 .1
Parent subject to limitations under RCW 26.09.191(2) or (3)

The residential time of CHRISTOPHER LEE HARRISON is subject to
limitations This parent [ ] h a s j^ p a s not demonstrated a substantial
change in circumstances specifically related to the basis for the limitations
2.5.2 Parent Required to Complete Evaluations, Treatment, Parenting or

Other Classes
CHRISTOPHER HARRISON is required by the existing Parenting
Plan/Residential Schedule to complete evaluations, treatment, parenting or
other classes. This parent HAS NOT fully complied with such requirements
as described here:
Does not apply.
2.6

The following nonresidential provisions of the parenting plan should be adjusted
because there is a substantial change of circumstances of either party or of the
children and the adjustment is in the best interest of the children:
Dispute resolution
2.7
Substantial Change in Circumstances

(Com plete this p a rt i f a m odification o r adjustm ent is based on paragraphs
2.2, 2.4, 2.5.1, 2.5.3 o r 2.6)
The requested modification or adjustment of the custody decree/parenting plan/

residential schedule is based upon the following substantial change in
circumstance:
See Declaration of Jolene Charlton, filed separately, which is incorporated
herein by this reference.
2.8
Protection Order
Does not apply.
If you need immediate protection, contact the clerk/court for RCW 26.50
Domestic Violence forms or RCW 10.14 Antiharassment forms.
Ord Re Mod/Adj o f Parenting Pin (ORMDD, ORDYMT) - Page 3 of 4

26 10 200
Charlton v Harrison
S \CASESl\Chariton, Jolene\Word\Pleadmgs\Order on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
7 /2 0 ^ 2 0 1 3
1 4SS i
2 2 ,0 1 3 4
III. Order
2
It is Ordered:
3
The petition to modify/adjust the custody decree or parenting plan/residential

schedule is granted. The custody decree or parenting plan/residential schedule
signed by the court on this date is approved and incorporated as part of this order.
This decree or parenting plan/residential schedule supersedes all previous
decrees or parenting plans/residential schedules.
4
5
6
7
8
9
Dated:
tZ /x M
z r tr fh y l/t
3 g e / C t o A m is s io n < f t C O U N T Y c
10
11
12
a.m
r k
'S O F F I C E
JUL 27 2011
Presented by:
FAUBION, REEDER, FRALEY,
& COOK, P.S.
Approved by:
By: DANIEL N. COOK, WSBA #34866


Pro Se
rm.

BY.
DEPUTY
13
s e e .
14
15
16
17
18
19
20
21
22
23
24
25
Ord Re Mod/Adj of Parenting Pin (ORMDD, ORDYMT) - Page 4 o f 4
WPF DRPSCU 07 0400 Mandatory (6/2008) - RCW 26 09.260, 270;

26.10 200
Charlton v Harrison
S \CASES1\Chariton, Jolene\Word\Pieadings\Order on Modification docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
7 ^2 0 ^2 0 1 1
-3 4 5 5 3
3B 3122
FILED
J N OPEN COURT
parte department
08-3-00821-4
36842104
CME
07-27-11
JUL 2 7 2011
r c E P j^ ( , C lerk
DEPUTY

Cause Number 0 8 -3 -0 0 8 2 1 -4
Petitioners)
vs
Page 1 of 2

Respondent(s)
Judge/Commissioner WENDY ELLEN ZICHT
Court Reporter Smart Court
Judicial Assistant/Clerk Stephanie Meelap
Daniel N Cook
HARRISON, C H R IS T O PH ER LE E
HARRISON, C H R IS T O PH E R LE E JR
Proceeding Set* Exparte Action

Proceeding Outcome Held
Outcome Date 07/27/2011 9 30
Resolution
Clerk's Scomis Code:MTHRG

Proceeding Outcome code HELD
Resolution Outcome code
Amended Resolution code
Report run date/time 07/27/11 9 35 AM
Ixcalcivtl pbl djnviljoumai_report_cover
5 14553


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page 2 of 2
Judge/Commissioner
WENDY ELLEN ZICHT
Judicial Assistant/Clerk Stephanie Meelap
Court Reporter Smart Court
July 27, 2011 09:30 AM

Atty Dan Cook appears before the Court with Orders for Default and Final Parenting Plan.
JIS ran and reviewed. Order of Default and Final Orders are signed as presented.
JUDGE/COM M ISSIONER W EN D Y ELLEN ZICHT Year 2011
E-FILED
August 01 2011 11:44 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
7
COUNTY OF PIERCE
In re:
10

Petitioner,
and
11
No. 08-3-00821-4
12
13
14

Respondent.
I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
15
16
On August 1, 2011, I placed in the U.S. Mail a copy of the following documents in the
17
1. Order re Modification;
2. Order on Motion for Default; and
3. Final Parenting Plan.
18
19
20
21
22
23

SE, A uburn, W A 98092.
C hristopher H arrison, 6721 Nathan Avenue
DATED
August 1,2011
24
Sally QafSharme, Legal Assistant

25
DECL o f M ailing - Page 1 o f 1
Charlton v Harrison
S:\CASES1\Charlton, Jo!ene\Word\Pleadings\Declaration of Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
IN
T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
KEVIN STOCK
COUNTY CLERK
No. 08-3-00821-4
June 06 2012 9:12 AM
ORDER SETTING CASE SCHEDULE
Petitioner(s)
Type o f case:
IN V
Vs.
R espondent(s)
T rack A ssignm ent:
M odification o f C ustody
A ssignm ent D epartm ent:
M ART
D ocket Code:
ORSCS
N otice o f A dequate C ause & N ote fo r C om m Cal filed w /P etition or no later th an
6/13/2012
C onfirm ation o f Service
6/27/2012
Certificate o f Parenting Class - Petitioner's (M ust be filed o n o r before)
8/8/2012
Certificate o f Parenting Class - R espondent's (M ust be filed on o r before)
8/8/2012
A dequate Cause H earing o n C om m issioner C alendar to b e held. (If this hearing is not held by this date,
p etition w ill b e dism issed)
8/8/2012
Set Settlem ent C onference D ate w ith Judge/C om m issioner V IC K I L. H O G A N
8/8/2012
PlaintifFs/Petitioner's D isclosure o f Prim ary W itnesses
10/10/2012
D efendant's/R espondent's D isclosure o f Prim ary W itnesses
10/31/2012
D isclosure o f R ebuttal W itnesses
11/14/2012
D eadline fo r F iling M otion to A djust T rial D ate
11/28/2012
W eek o f 1/9/2013
Settlem ent C onference (To be held)

D iscovery C utoff
1/16/2013
E xchange o f W itness and E xhibit L ists and D ocum entary E xhibits
1/30/2013
2/13/2013 9:00
Trial
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM on
the date of trial.
I f the case has b e e n filed, the p lain tiff shall serve a copy o f the Case Schedule o n the defendant(s) w ith the sum m ons and com plaint/
petition: P rovided th at in those cases w here service is by p u b lication the p lain tiff shall serve the Case Schedule w ith in five (5) co u rt days
o f service o f the defendant's first response/appearance. I f the case has not b e e n filed, b u t a n initial pleading is served, the Case Schedule
shall be served w ithin five (5) court days o f filing. See P C L R 3.

A ll attorneys and parties shall m ake them selves fam iliar w ith the Pierce County L ocal R ules, particularly those relating to case
scheduling. C om pliance w ith the scheduling rules is m andatory and failure to com ply shall result in sanctions appropriate to the
violation. I f a statem ent o f arbitrability is filed, P C L R 3 does n ot apply w hile the case is in arbitration.
Dated: June 6, 2012

Judge FA M IL Y C O U R T - 1
D epartm ent M A R T
E-FILED
June 06 2012 9:15 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)
Name: Daniel N Cook
Address: 5920 100th St SW Ste 25 LAKEWOOD, WA 98499-2751
Phone: (253) 581-0660

M o tio n - M o d ify Tem p O rd e r

CALENDAR DATE: Monday, July 30, 2012 9:30 AM

DATED:
June 6, 2012.
Signed:
NAME:
Phone:

AUBURN, WA 98092
WSBA#:
For:
3330742
1 of 1
i& 9 ? ? 4 & y ;? 5 S 2 Z i 8 8 4 f f ii:L E D
OB-3-00821-4
38644601

m m STOCK
CLERK OF THE SUPERIOR COURT
TACQHA HA
06-07-12
08-3-00821-9
JUN
6 2012
kept. Bate
06/06/2012
rm.

Receipt/Itea if Tran-Code
2012-05-05284/01
liQ4
Cashier: TFR
DEPUIY
bv
Act4:. Date
06/06/2012
In re: CHRISTOPHER LEE HARRISON, JR.
and

Respondent.
To
No.
0 8 -3 -0 0 8 2 1 -4
Summons{Modifi cation/
Adjustment of Custody
Decree/Parenting Plan/
Residential Schedule)
(SM)_________________
JOLENE MARIE HARRISON ( N /K /A CHARLTON)
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.
X!
[]
Docket-Code
tFFR
Paid By: Harrison, Christopher

Transaction Amount:

County of PIERCE
( N /K /A CHARLTON) Petitioner,
Time
09;li M
Temporary residential placement or custody is not being sought.

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.

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; RCW 26.09.270; 26.10.020
$56.00
J .8 9 7 4
627/2012
168847
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/Adjustmcnt of Custody Decree/Parcnting Plan/Residcntial
Schedule. This form may be obtained by contacting the clerk of the court at the address below,
by contacting the Administrative Office of the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
6.
If this action has not been tiled 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.
This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state ofrWashington.
Dated:
( g - 'Y - Z Z -
Signature of Moving Party or Lawyer/WSB A No.

C H R ISTO P H ER LEE H A R R ISO N
Print Name
File original o f y o u r r e s p o n s e with
th e clerk o f th e c o u rt a t
S e rv e a c o p y o f y o u r r e s p o n s e on:
IX Moving Party [You may list an address that is not

your residential address where you agree to accept
legal documents. Any time this address changes
while this action is pending, you must notify the
opposing patties in writing and file an updated
Confidential Information Form (WPF DRPSCU
09.0200) with the court clerk.]
[ ] Moving Partys Lawyer

C H R ISTO PH ER LEE H A R R ISO N
[Name of Court]
[Name]
930 TACOMA AVENUE SOUTH, TACOMA, WA 9 8 402B721 NATHAN AVENUE SE, AUBURN, WA 9 8 092
[Address]
[Address]
WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; RCW 26.09.270; 26.70.020
18974
08-3-00821-4
38644615
SPTMDC
6/7/2812
168848
06-07-12
FILED
AM.
J U N O 6 2012
RM.

KEVIN STOQK, County Clerk
BY-----------
______ DEPUTY

County of PIERCE
In re:
No
0 8 -3 -0 0 8 2 1 -4
CHRISTOPHER LEE HARRISON, JR.

(N /K /A CHARLTON)
Petitioner,
and
(PTMD)

__________________________Respondent.
1.1
P e titio n fo r M o d ific a tio n /

A d ju s tm e n t o f C u s to d y D e c re e /
P a re n tin g P la n /R e s id e n tia l
S c h e d u le

attached for:
Id e n tific a tio n o f R e q u e s tin g P a rty /P a rtie s
Name (firs,/las,)
Bilth dale 0 4 / 0 6 /1 9 7 0
Last known residence (county and state only) PIERCE COUNTY,WA_______ .

Name {first/lasl)____________________________________________ Birth dale
Last known residence (county and state only)______________________________
1 .2
Id e n tific a tio n o f O th e r P a rty /P a rtie s
Name (firs,/las,) JOLENE CHARLTON________________ Bilth date_ 0 7 /1 5 /1 9 7 5

Last known residence (county and state only) ADA COUNTY, IDAHO
Name (firsLIast) ___________________________________________ Birth date
Last known residence (county and state only)______________________________
Name (first/last)________________________ __Birth date________________________________
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW26.09.181; .260, .270, RCW26.26.130(7)(b)
18SJ7J
6 -/ 7 / Z 8 12
1849
Last known residence (county and state only)_______________________________

1.3
Dependent Children
Name (first/last) CHRISTOPHER LEE HARRISON, JR.
Age __ 7
Name (first/last)_____________________
Age
Name (first/last)_______________________
Age
Name (first/last)____________________________________________ Age

Name (first/last)_____________________
Age
Name (first/last)_____________________________________________ Age
II. Basis
2.1
Petition for an Order Modifying Custody Decree/Parenting Plan/Residential

Schedule
This is a petition for an order modifying the prior custody decree/parenting plan/residential
schedule/judgment establishing parentage and approving my proposed parenting plan/residential
schedule, which is filed with this petition.
f]
2.2
The court entered a judgment and order establishing parentage on

(date)___________________ at (county and state)_______________________ ___
under cause number_______________ and did not enter a Parenting Plan or Residential
Schedule at the same time. I attached a copy of the order establishing parentage if it was
filed in another county or state.
Adequate Cause
2.3
Child Support
[J
H
2.4
Does not apply.

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

The court has proper jti/vsdicfio/i and venue.
PIERCE COUNTY, WA
ADA COUNTY, IDAHO
The requesting party/parties reside(s) in (county and state only)

The children reside in (county and state only)

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181; .260; .270, RCW 26.26.130(7)(b)
The other party/parties reside(s) in (county and state only)
2.5
A D A COUNTY. IDAHO

This court has jurisdiction over this proceeding for tire reasons below:
K3
custody, parenting plan, residential schedule or visitation determination in this matter and
[]

[]
[]
[J
f]
[]
the children lived in Washington with a parent or a person acting as a parent for at
proceeding.
the children are less than six months old and have lived in Washington with a parent
or a person acting as parent since birth.
any absences from Washington have been only temporary,
Washington was the home state o f the children within six months before the
parent or person acting as a parent continues to live in this state.
The children and the parents or the children and at least one parent or a person acting as a
parent have significant connection with the state other than mere physical presence, and
substantial evidence is available in this state concerning the children's care, protection,
training and personal relationships, and:
[]
[]

The children's home state has declined to exercise jurisdiction on the ground that
this state is the more appropriate forum under RCW 26.27.261 or .271.
[]
All courts in the children's home state have declined to exercise jurisdiction on tire ground
[]
[]
emergency to protect the children because the children, or a sibling or parent o f the children
is subjected to or threatened with abuse. RCW 26.27.231.
[]

this chapter or a child custody proceeding has been commenced in a court o f a
slate having jurisdiction under RCW 26.27.201 through 26.27.221. The
requirements of RCW 26.27.231 (3) apply to this matter. This state's jurisdiction
over the children shall last until (date)__________________________________ ,

IS3?4
[|
(|
2.6
b ' ' 7 - 'b 3 1 2

this chapter and a child custody proceeding lias not been commenced in a court
action is not filed in (potential home state)_____________________________
by the time the child has been in Washington for six months,
(date)_______________________________, then Washington's jurisdiction
will be final and continuing
Other;
Name of Child
CHRISTOPHER HARRISON, JR.
Parent's Name
JOLENE HARRISON
(N/K/A CHARLTON)
Parent's Name

[]
XJ
in no place other than the state of Washington and with no person other than the requesting
party or the other party.
in the following places with the following persons (list each place the children lived,
including the state of Washington, the dates the children lived there and the names of the
persons with whom the children lived. The present addresses of those persons must be listed
in the required Confidential Information Form.):
0 7 /2 0 1 1-PRESENT 7 1 96 S. CULBERSTON WAY, BOISE ID W ITH

JOLENE HARRISON (N /K /A CHARLTON)
0 2 /2 0 0 5 -0 7 /2 0 1 1 12107 209TH AVENUE COURT E, BONNEY LAEK,
U IA
U1TTU
in i CM C
LI A D O T C O M
f M / I f / A / " 'L l A D I T A I M
|]
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.
The following persons have physical custody of, or claim to have custody or visitation rights
to, the children (list their names and the children concerned below and list their present
addresses in the Confidential Information Form. Do not list the other party.):
XI
[]
Tlie requesting party lias not been involved in any other proceeding regarding the children.
The requesting party has been involved in the following proceedings regarding the children
(list the court, the case number, and the date of the judgment or order):

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR4.1; RCW 26.09.181, .260; .270, RCW 26.26.130(7)(b)
IS 9 7 4
& ^ 7 /2 0 1 t
1 -6 8 6 5 2

M
f]
2.7
The requesting party does not know of, any other legal proceedings concerning the children,
The requesting party knows of, the following legal proceedings that concern the children (list
the children concerned, the court, the case number, and the kind of proceeding):
Custody Decree or Parenting Plan/Residential Schedule

The Custody Decree/Parenting Plan/Residential Schedule was entered on (date) 0 7 / 2 7 / 2 0 1 1 at
(county and state) P IE R C E C O U N T Y , W A _______________ . A certified copy of the
Custody Decree/Parenting Plan /Residential Schedule to be modified is filed with or attached to this
petition, if the decree or plan to be modified was entered in another county or state.
2.8
2.9

|J
Does not apply.
XI
The custody decree/parenting plan/residential schedule should be modified because a

substantial change of circumstances has occurred in the circumstances of the children or the
other party and the modification is in the best interests of the children and is necessary to
serve the best interests of the children. This request is based on the factors below.
[j
The parties agree to the modification.
[]
The children have been integrated into my family with the consent of the other party'
in substantial deviation from the decree/parenting plan/residential schedule.
SO
The childrens environment under the custody decree/parenting plan/residential

schedule is detrimental to the childrens physical, mental or emotional health and the
harm likely to be caused by a change in environment is outweighed by the
advantage of a change to the children.
[]
The other party has been found in contempt of court at least twice within three years
because the party failed to comply with the residential time provisions in the courtordered parenting plan, or the parent has been convicted of custodial interference in
the first or second degree under RCW 9A.40.060 or 9A.40.070.

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09 181; .260; .270, RCW 26.26.130(7)(b)
1 3
7 4
f e / 7 / 2 8 1 2
1 &
8 8 5 3
f]
Does not apply.
{Xj
The custody decree/parenting plan/residential schedule should be modified because the

reduction or restriction o f the residential time for the person with whom the child does not
reside a majority' of the time would serve and protect the best interests o f the child using the
criteria in R C W 26.09.191, as described here:
P E T IT IO N E R 'S CURRENT HUSBAND HAS H IS PARENTAL

R IG H TS SEVERED.
\]
2.10
2.11
The custody decree/parenting plan/residential schedule should be adjusted because the

nonresidential party has voluntarily failed to exercise residential time for one year or more
and the adjustment is in the best interest of the children.

Kl
Does not apply.
I]
The custody decree/parenting plan/residential schedule should be adjusted because a

substantial change in circumstances o f ei titer parent or o f the child has occurred and the
proposed modification to the custody decree/parenting plan/residential schedule is in the best
interest of the children and is a minor modification in die residential schedule that does not
change die residence the children are scheduled to reside in the majority of the time and:
[]
is not more than 24 full days in a calendar year; or
[]
is based on a change of residence of die parent with whom the child does not reside
a majority of the time or an involuntary change in work schedule by a party which
makes die residential schedule in the parenting plan impractical to follow.

f]
Does not apply.
This section only applies to a p erso n with w hom the child d o e s n o t resid e a m ajority
o f the time who is seekin g to increase residential time.
2.11.1
Parent subject to limitations under RCW 26.09.191(2) or (3)

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181; .260; .270, R C W 26.26.130(7)(b)
13974
[J
X]
2.12
6 /7 ^ 2 8 1 2
163854
The residential time o f (nam e)_______________________________________ _____ is not

subject to limitations.
The residential time of (name) C H R ISTO P H ER H A R R IS O N is subject to
limitations. This parent demonstrates a substantial change in circumstances specifically
related to the basis for the /imitation.
2.11.2
Parent Required to Complete Evaluations, Treatment, Parenting or Other Classes
[1
(X
(N am e)_______________________________ is not required under the existing Parenting

Plan/Residential Schedule to complete evaluations, treatment, parenting or other classes.
(Name) CHRISTOPHER HARRISON is required by the existing Parenting
Plan/Residential Schedule to complete evaluations, treatment, parenting or other classes.
This parent has fully complied with such requirements as described here:
2.11.3
Adjustment to Residential Provision Under RCW 26.09.260(5)(c)
[]
The Custody Decree/Parenting Plan/Residential Schedule should be adjusted because a

substantial change in circumstances o f (parents nam e)______________________________
or (child(ren)s nam e(s))________________________________________ ____________has
occurred. The proposed modification to the Custody Decree/Parenting Plan/Residential
Schedule is in the best interest of the children. It is a minor modification in the residential
schedule that does not change the residence the children are scheduled to reside in the
majority of the time. The increase is more than 24 full days but less than 90 overnights per
year total. The Custody Decree/Parenting Plan/Residential Schedule does not provide
reasonable time with the nonprimary residential party.

[]
Does not apply.
(X
The following nonresidential provisions o f the parenting plan should be adjusted because
there is a substantial change of circumstances of either party or o f the children and the
adjustment is in the best interest of the children:
XI Dispute resolution.
X) Decision making
X Transportation arrangements.
[ l Other:
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181; .260; .270. RCW 26.26.130(7)(b)
1G374
2.13
6 /7 /2 Q 1 2
168855
Substantial Change in Circumstance

(You m u st com plete this part if yo u re q u e st a m odification or adju stm en t in
paragraph s 28, 210, 211.1, 2.11.3 or 2.12.)
The requested modification or adjustment of the custody decree/parenting plan/residential schedule is
based upon the following substantial change in circumstance;
R E SP O N D E N T/FA TH ER HAS FULLY C O M P LIED W IT H ALL THE COURT

ORDERED R EQ UIREM ENTS. P E T IT IO N E R /M O T H E R HAS RELOCATED THE
M IN O R C H IL D TO ID A H O W H IC H MAKES R E SP O N D E N T/FA T H E R 'S
V IS IT A T IO N UNFEASIBLE. P E T IT IO N E R /M O T H E R IS CURRENLTY
M A R R IE D A N D HER HUSBAND HAD H IS PARENTAL R IG H T S SEVERED
W H IC H CAUSES GREAT CONCERN TO R E SP O N D E N T/FA TH E R . FURTHER,
THE M IN O R C H IL D FLUNKED K IN D ER G A R TEN AND IS CLOSE TO
FL U N K IN G A G A IN AND HAS S IG N IF IC A N T ABSENCES FROM SCHOOL.
2.14
Protection Order
X]
[]
Does not apply.

There is a protection order between the parties filed in case number
co u rt____________________________ , which expires on (date)
l j
The court should grant the [ ] domestic violence [ J antiharassment petition for order for
protection;
[ ] filed separately under [ ] this case number [ J case num ber_______________________ ,
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic Violence
forms or RCW 10.14 Anti harassment forms.
2.15

2 .15 .1 A. Service member status (name o f other party) JOLENE H A R R IS O N ( N / K / A
IK is not a service member;
CHARLTON 1

18974
6 /7 ^ 2 8 1 2
188^56
[ ] is on active duty in the U.S. armed forces (excluding National Guard and
reserves);
[ J is on active duty and is a National Guard member or a Reservist residing in
Washington;
[ J is not on active duty in the U.S. armed forces (excluding National Guard and
reserves);
[ J is not on active duty and is a National Guard member or a Reservist residing in
Washington;
\ ] 1 am unable to determine whether the other party is or is not on active duty in the
U.S. armed forces;
[ ] la m unable to determine whether the other party is or is not on active duty as a
National Guard member or a Reservist residing in Washington.
B. Factual basis:
[ 1 See the attached Defense Man Power Data Center Report obtained from
https://www dmdc.osd.mil/scra/owa/home.
[ ] Other factual basis:
C. [ ] As indicated above, the other party is on active duty and (check all that apply):
[ ] The other party is represented by an attorney.
[ ] The court has appointed an attorney to represent the other party.
[ ] A stay o f these proceedings [ ] has [ ] has not been entered by the court.
2.15.2 A. Dependent of a service member status (name o f other party)_________________
[ ] is a dependent o f a resident of Washington who is on active duty and is a
National Guard member or a Reservist;
[ ] is not a dependent o f a resident of Washington who is on active duty and is a
National Guard member or a Reservist;
[ ] Jam unable to determine whether the other party is a dependent o f a resident of
Washington who is on active duty and is a National Guard member or a
Reservist.
B. Factual basis:
[ J The other party failed to respond to a notice to him or her as a dependent o f a
person in Military Service that was [ ] served on [ ] mailed by first class mail on
(date)____________________________________________therefore he or she
should be presumed not a dependent of a resident o f Washington who is on
active duty and is a National Guard member or a Reservist.
| \ Other factual basis:
C. [ ] As indicated above, the nonmoving party is a dependent o f a resident of

Washington who is on active duty and is a National Guard member or a
Reservist and (check all that apply):
3.S IT ?4 : '6 / ? V .2 8 1 2
[ ] The nonmoving party is represented by an attorney.

{ ] The court has appointed an attorney to represent the nonmoving party.
[ ] A stay of these proceedings f ] has [ ] has not been entered by the court,
2.16
Other
til. Relief Requested

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.
XJ
The moving party also requests that die court:
XI
[]
[]
[1
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 tliis petition.
Enter an antiharassment protection order.
Other:
/

Date
re of Requesting Party or Lawyer/WSBA No. Print Name
Date
Signature of Requesting Party or Lawyer/WSBA No. Prim Name
l declare under penalty of perjury' under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at (city)___________________________ , (state)_____________ on (date)
Print Name

Signed at (city)
, (state)
on (date)
Print Name
[ j
Joinder
[j
I, _______________
, join in the petition. I understand that by joining in the petition,
a decree or judgment and order may be entered in accordance with the relief requested in the
p et for Mod/Adj Parenting Pin (PTMD) - Page 10 of 12

WPF DRPSCU 07.0100 Mandatory (07/2011) - CR4.1; RCW 26.09.181; .260; .270, RCW26.26.130(7)(b)
18SV4
& /7 S Z 8 1 Z
160858
petition unless, prior to the entry of the decree or judgm ent and order, a response is filed and
served.
[]
1 waive notice o f entry o f the decree.
[]
I demand notice o f all further proceedings in this matter. Further notice should be sent to
the following address (you may list an address that is not your residential address where
you agree to accept legal documents):
Any time this address changes while this action is pending, you must notify the opposing parties
in writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the
court clerk
Date
11
Signature
Print Name
I ,___________________________ , join in the petition. I understand that by joining in the petition,

petition unless, prior to the entry o f the decree or judgm ent and order, a response is filed and
served.
[]
[]
I demand notice o f all further proceedings in this matter. Further notice should be sent to
in writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the
court clerk.
Date
[]
Signature
Print Name
I ,___________________________ Jo in in the petition. 1 understand that by joining in the petition,

petition unless, prior to the entry o f the decree or judgm ent and order, a response is filed and
served.
[]
f waive notice o f entry o f the decree.
(1
1 demand notice of all further proceedings in this matter. Further notice should be sent to

lily
1 2
1 6 8 8 5 3
in writing and file an updated Confidential Information Form (WPF DRPSCU 09,0200) with the
court clerk,
Date
Signature
Print Name

18974
08-3-00B21-4
38644620
NTHG
fc/7/2812
1600&0
06-07-12
INCOUNTY ctl^K'S OFFICE

AM. JUN 0 6 2012 P.M.
COUNTY WASHINGTON
K E V IN S T O C K , C o u n ty C le rk
dY---------
---------------- DEPUTY
S uperior C ou rt o f W ashington
C ounty of PIERCE
No. 0 8 - 3 - 0 0 8 2 1 - 4
CHRISTOPHER LEE HARRISON, ]R .
JOLENE M A R IE H A R R ISO N
( N / K / A C H A R LTO N )
Petltioner,
and
C H R ISTO P H ER LEE H A R R ISO N

__________________________________________ R e s p o n d e n t.
Respondents Notice of
Hearing for Adequate Cause
Determination
(Optional Use)
(NTHG)
[ ] Clerks Action Required
To the Clerk o f Court and to:

1.
Please note that the court will be asked to determine whether 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.
Date:
7'~r\Cs~
______________________
Time;
9 /
Place:
e /r.t
OÛ^^y
Room/Department: T R - 4
3.
If the court does not find adequate cause, the petition will be denied.
Dated:
ture of Parti or Lawyer/WSBA No.
N o tic e to p a rty ; Y o u m a y list an a d d r e s s th a t is n o t y o u r
C H R IS TO P H E R LEE H A R R ISO N
r e s id e n tia l a d d r e s s w h e r e y o u a g re e to a c c e p t le g a l
d o c u m e n ts A n y tim e th is a d d re ss c h a n g e s w h ile th is
6721 NATHAN AVENUE SE, AUBURN, W A 98092
a c tio n is p e n d in g , y o u m u st n o tify th e o p p o s in g p a r tie s

in w r itin g a n d file an u p d a te d C o n fid e n tia l In fo rm a tio n
F o rm (W P F D R P S C U 0 9 0 2 0 0 ) w ith th e c o u rt c le rk .
Print or Type Name

[Address]
Respondents Not ofHrng (Adequate Cause) (NTHG) - Page 1 of 1

WPF DRPSCU 07.0255 (6/2006) - RCW 26.09.260; .270; 26.10.200
10974
08-3-00821-4
38644640
fe 7 7 /'2 B 1 2
168361
AFRSP
FILED
A.M.
JUNO6 2012
RM.
RK ^ '^ ^ l i 'ASH,NGTDN
UY------------------------- ----- DEPUTY

County of P IE R C E
In re: CHRISTOPHER LEE HARRISON,
JR.
No. 0 8 - 3 - 0 0 8 2 1 - 4
JOLENE MARIE HARRISON (N /K /A
CHARLTON)
Petitioner's),
and
Respondent(s).
Declaration of
C H R IS T O P H E R LEE
H A R R IS O N
[Name]
(Optional Use)
(DCLR)

Name:
Age:
42
Relationship to the parties in this action: RESPONDENT
I D eclare:
1. I a m the Respondent in this m atter, am over the age o f 18 and otherwise

com petent to
make this
Declaration
which
is based
on
my
personal
knowledge.
2. I am filing this Declaration in support of my position regarding the parties'
m inor child Christopher Lee Harrison, Jr. (DOB 0 2 /22 /200 5). I respectfully
subm it th a t the relief requested in this Declaration is ju s t and equitable and
in the best interest of the minor child.

WPF DRPSCU 01.0100 (6/2006)
IB S 74
SS7S2BZ2
3. There is a significant history between the parties relevant to this dispute. I

met Petitioner in March of 2004. Our relationship progressed quickly and we
were married on June 5, 2004. It is im portant to note th a t this was my
second marriage, and I had sole custody of my daughters from my first
m arriage and maintained sole custody o f them until they turned eighteen
(18).
4. Our son was born February 22, 2005. I was elated to be a father and played
an active role in our son's life. In 2005, I was in a tra ffic accident and broke 3
vertebrae and had to take a year o ff work. A t th a t tim e, I became a stay-athome father. I took care o f our son on a daily basis. I taught him to walk,
drink with a straw and various other developm ent milestones. Additionally, I
cooked, cleaned and helped my other children with th e ir hom ework and
school assignments. I made sure the children had dinner, put them to bed
and ensured th a t dinner was ready when Petitioner returned from work.
5. Our relationship began to deteriorate when Petitioner began staying o u t later
and later. Petitioner was o ff of work by 9 or 10pm; however, she did not
return home until 12:30 or la m in the m orning. This became a point of
contention between us along with some of Petitioner's other actions and I
became
suspicious
th a t
Petitioner
was
having
an
affair.
Additionally,
Petitioner wanted LASIK eye surgery. We had a discussion and I expressed

my concern due to our limited finances. Petitioner com pletely disregarded my
concerns, drained our bank account and had the surgery.
6. Petitioner and I separated on or about August 8, 2007. A fter our separation,
Petitioner and I lived approximately tw o (2) miles from each other and I was
able to see my son almost every weekend and any other tim e I wanted.
Additionally, Petitioner would frequently bring our son to my home several
nights a week and they would both stay the night at my home. Further,
Petitioner never had a problem leaving my son in my care or allowing me to
drive with my son in the car.

WPF DRPSCU 01.0100 (6/2006)
18974
7812
16S8&3
7. Petitioner and I were divorced on or about October of 2008, Through the

divorce, I was granted unsupervised visitation every other weekend.
8. Our arrangem ent was working well until I m et dom estic partner Char in
January 2009. At th a t tim e, Petitioner began to deny me access to our son
w ithout justification or good cause.
9. Petitioner m et her current husband in May of 2009 and they were m arried on
August 1, 2009. A fter Petitioner rem arried, she filed pleadings th a t required
me to have supervised visitation. I respectfully subm it th a t Petitioner and her
m other showed up at my home and told me th a t if I ever wanted to see my
son again, I had to sign the joinder. I was extrem ely naive and signed the
paperwork.
10. A fter I signed the papers, I was able to have my son every other weekend. I
took my son to the zoo and to work which Petitioner was well aware of.
Again, Petitioner had no concerns with our son in my care until I filed
contem pt charges against her.
11.Shortly after court, I w ent to our son's school to sign some papers and I saw
Petitioner's husband's car. I stopped and took a picture so th a t I could give it
to my process server so he could perform service. While I was taking a
picture Petitioner's son came home and saw me taking a picture. I t is my
understanding th a t Petitioner was contacted and inform ed th a t I was in the ir
yard, which is blatantly false. I received sixty (60) days in jail and had a
restraining order placed between me and my son.
12.Petitioner and I returned to court in July o f 2011. Petitioner intentionally and
maliciously
misled the
Honorable Court and
my visitation
was furthe r
restricted to supervised visitation until I fulfilled the court requirem ents at

which tim e I was to have visitation every other weekend from Friday at 7pm
until Sunday at 7pm, one (1) week in July, one (1) week in August, every
Father's day, New Year's Day in even years, 4th of July in even years,
Thanksgiving Day in odd years, Christmas Eve and Christmas Day in even

WPF DRPSCU01.0100 (6/2006)
18574
6 /7 /2 0 1 2
16eS4
years and Easter in odd years . Further, Petitioner was granted sole decision
making authority for our son.
13.Pursuant to paragraph 3.10 of the current order, I was required to : comply
with drug/alcohol conditions of release and probation which shall include
collateral contact with Petitioner and any recommended follow-up tre a tm e n t,
providing
Petitioner with
name
o f probation
officer and
copies o f all
documents and reports and compliance records in my alcohol m onitoring

program ; a State certified domestic violence assessment which shall include
collateral contact with Petitioner and any recommended follow-up tre a tm e n t
if I do not provide Petitioner with a copy of my DV assessment from Valley
Cities/Gloria Axtel and collateral contact with th a t agency; provide Petitioner
proof of current mental health treatm ent providers, proof th a t I am stable,
taking appropriate medications, and prior mental health issues are under
control, afte r collateral contact with Petitioner; sign authorization fo r release
of inform ation to
Petitioner for all evaluations above and any and all
tre atm e nt providers or other individuals or case workers engaged in response

to requirem ents set forth above , in addition I was to provide Petitioner's
attorney any drug and alcohol assessments.
14.1 respectfully subm it th a t I am currently enrolled in AA and will complete the
program on August 13, 2012. I respectfully subm it th a t I enrolled and
received a Certificate of Completion on January 28, 2010 in the Im pact
Treatm ent Program.
15.1 respectfully subm it th a t I have provided Petitioner's attorney with all the
documents and inform ation in possession th a t were required in paragraph
3.10 of the parties' current order. Additionally, I requested to exercise my
visitation with my son. Finally, Petitioner refused to provide me with her
home phone num ber and I only had her cell phone number. Out o f the blue, I
received an "accidental" call from the home phone num ber;
Petitioner's refuses to answer the phone when I call.

WPF DRPSCU 01.0100 (6/2006)
however,
18374
1&836S
16.1 am a loving, caring and nurturing father. My son and I have always had an
extrem ely close bond. I have always, when allowed, played an active role in
my son's developm ent and education. When my son is in my care, I ensure
th a t he has nutritious meals, has good hygiene, and maintains an age
appropriate schedule. We enjoy reading, going to the zoo, going to the park,
working in the yard, exploring the outdoors, going on adventures, visiting
friends and fam ily, and ju s t spending tim e together.
17.1 ta k e m y ro le as a fa th e r v e ry s e rio u s ly .
needs
a re
n o t ju s t
m o n e ta ry ,
I u n d e rs ta n d th a t a c h ild 's
b u t p h y s ic a l,
c o g n itiv e ,
social
and
e m o tio n a l. I have and w ill c o n tin u e to te a ch m y son th e im p o rta n c e o f

a good e d u c a tio n , m a n n e rs, re s p o n s ib ility , re s p e c t and h o n e s ty .
e n co u ra g e
him
to
becom e
w ell
ro u n d e d ,
p o s itiv e ,
I w ill
p ro d u c tiv e ,
successful y o u n g m an.
18. I provide a safe, stable and loving environm ent. I currently reside in a home
with my dom estic partner of three (3) years. Our home is located in a great
kid-friendly neighborhood where my son has his own room and his own
space. I have been employed as an assembly technician with NPI fo r the last
tw o and a half (2 V2 ) years. My jo b provides me the financial stability to
adequately provide for my son and the flexibility to be available when he
needs me.
19.1 understand the importance o f our son having both parents play an active
role in our son's life. I have and pledge to continue to facilitate a positive
relationship between
Petitioner and our son.
significant
with
concerns
our
son
in
However, I have several
Petitioner's
care.
Petitioner
has
repeatedly intentionally and maliciously misled this Honorable Court to gain

outcomes in her favor as I have never been a th re a t to my son. Petitioner
has never expressed concern for our son in my care until I became involved
in a new relationship and she remarried. Petitioner does not provide a good
environm ent fo r our son. I t is my understanding th a t even though Petitioner
is a stay-at-hom e m other; our son has excessive tardies and absences, has
Declaration (D C LR ) - Page 5 o f 7
W PF D R P S C U 01.0100 (6/2006)
1S974
fj/V/ZttlZ
1608& 6
flunked Kindergarten and is in serious danger o f flunking again this year.

Further, it is my understanding th a t Petitioner's husband had his rights to his
children from a previous relationship severed. Petitioner does not facilitate a
relationship between my son and me; constantly frustrating my telephone
access to my son and m onitoring the few phone calls she allows. Finally,
Petitioner is currently taking double the m axim um recommended dosage of
her prescription medication, W elbutrin, which leaves her comatose in bed
because she is "so tire d " and leaves my son in the care of a man who had his
parental rights term inated. I am extrem ely concerned fo r the safety and w ell
being of my son under these circumstances.
20.1 respectfully subm it th a t it is in our son's best interest th a t I have
unsupervised visitation half of w inter break every year (the first half including
Christmas Eve and Christmas Day even years and the second half in odd
years), the entire Spring Break every years, the entire Thanksgiving Break in
odd years, Sum m er Vacation from one week afte r school releases until one
week before school resumes, Father's Day every year, and the option of one
weekend per m onth if finances permit. Accordingly, since Petitioner and our
son now reside in Idaho, I request th a t the party receiving possession of our
son be solely responsible to provide and pay fo r transportation costs. Further,
I request jo in t decision making authority and access to our son's education
and medical records. Finally, I request th a t I have a set schedule, at least
three (3) days per week, where I can speak to my son w ithout being
monitored.
21.1 respectfully request th a t child support be
modified
based
upon the
modification o f custody and visitation and in accordance with state guidelines.

Further, I respectfully request th a t the parties rotate claiming our son for
federal and state tax purposes where I claim him in even years and Petitioner
claims him in odd years.
22.Based upon the to ta lity of the circumstances presented in this case, I
respectfully request th a t this Honorable Court grant the relief contained

WPF DRPSCU01.0100 (6/2006)
10974
6 /7 /2 0 1 2
168967
herein and fo r such other and further relief th a t it deems ju s t and equitable
and in the best interest of the minor child.
J declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Do not attach financial records, personal health care records o r confidential

reports to this declaration. Such records should be s e rv ed on the other p arty an d
1) Sealed Financial Source Documents (W PF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (W PF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (W PF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet , the records w ill be se ale d to protect y o u r
privacy (although they w ill be available to a ll parties in the case, their attorneys,
court personnel an d certain state agencies an d boards.) S ee G R 22(C)(2).

WPF DRPSCU 01.0100 (6/2006)
18374
08-3-00821-4
38644642
PPP
2812
168868
06-07-12

County of PIERCE
[ ] In re the Marriage of:
JOLENE M A R IE H A R R IS O N
( N / K / A C H A R LTO N )
'
* Petitioner,
and
CHRISTOPHER LEE H A R R IS O N
Respondent.
No. 0 8 - 3 - 0 0 8 2 1 - 4
Parenting Plan
H Proposed (PPP)
f J Temporary (PPT)

[]
[]
[J
M
dated________________________ .
this date or dated_________________________. which modifies a previous parenting
proposed by (name) C H R ISTO PH ER LEE HARRIS O N

Name
C H R ISTO PH ER LEE H A R R ISO N , JR.

Aue
18974
6 ^ 7 /2 8 1 2
1'& B 8& 3

contact with the children) and the right to make decisions for the child(ren).
2.1

(X|
[]
Does not apply.

The: [ ] petitioners l ] respondents residential time with the child(ren) shall be limited or
resolution process other than court action shall not be required, because [ ] this parent
[]
[]
[1
2.2

Physical, sexual ora pattern of emotional abuse of a child.
A history of acts of domestic violence as defined in RCW 26.50.010( 1) or an
harm.

()j
[]
Does not apply.

The [ ] petitioners [ ] respondents involvement or conduct may have an adverse effect
[]
[]
f]
[]
[]
[]
[]

child.
Other:

18974
6 /7 ^ 2 ^ 1 2
3.& dB 7f)

occasions, and what contact the child(ren) shall have with each parent. Parents are
encouraged to create a residential schedule that meets the developmental needs of the
child(ren) and individual needs of their family. Paragraphs 3.1 through 3.9 are one way to write
your residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
3.1

|)$
[l

Prior to enrollment in school, the child(ren) shall reside with the [ ] petitioner
from (day and time)____________________ to (day and time)___________________
[]
(]
every week [ ] every other week {] the first and third week of the month
the second and fourth week of the month [ J other:
from (day and time)

[]
[]
3.2
_____ _ _ _ _ _ _ to (day and time)___________
the second and fourth week of the month [ ] other:
School Schedule
Upon enrollment in school, the child(ren) shall reside with the Kl petitioner
[ ] respondent, except for the following days and limes when the child(ren) will reside with or be
from (day and time)______________________ to (day and tim e)_________________
[]
[]
the second and fourth week of the month X Other: TH E O P T IO N OF ONE
U N SU P E R VISE D W EEKEND PER M O N TH I F FIN A N C E S
P E R M IT FROM F R ID A Y TO SUNDAY @ 8PM .
From (day and time)_____________________ _ to (day and time)_________________

[]
[]
every week [ ] every other week (] the first and third week of the month
the second and fourth week of the month [ j other:

18974
3.3
3.4
1L3S71
The school schedule will start when each child begins jXj kindergarten [ ] first grade
[ ] other:

The child(ren) shall reside with the ^ petitioner [ ] respondent during winter vacation, except
for the following days and times when the child(rcn) will reside with or be with the other parent:
FATHER SHALL HAVE TH E M IN O R C H IL D FOR TH E F IR S T HALF OF
W IN T E R VA C A TIO N B E G IN N IN G THE DAY AFTER SCHOOL RELEASES
(IN C L U D IN G C H R IS T M A S ) U N T IL HALFW AY TH R O U G H W IN T E R BREAK
A T 8PM IN EVEN YEARS. FATHER SHALL HAVE TH E SECOND HALF OF
W IN T E R BREAK B E G IN M IN G HALFW AY THROUGH @ 8PM U N T IL THE DAY
r f f o r f ^ r H n n i r f c iim f c t n n n n v f a r c
The child(rcn) shall reside with the 0$ petitioner [ ] respondent during other school breaks,
parent pATHER SHALL HAVE TH E E N TIR E T H A N K S G IV IN G BREAK
FROM W EDNESDAY <>6PM U N T IL SUNDAY @ 6PM IN O DD
YEARS. FATHER SHALL HAVE THE E N TIR E S P R IN G BREAK
EVERY YEAR.
3.5
Summer Schedule
Upon completion of the school year, the child(ren) shall reside with the j)j petitioner
[ J respondent, except for the following days and times when the child(ren) will reside with or be
[]
M
3.6

other FATHER SHALL HAVE THE M IN O R C H IL D FROM ONE WEEK
AFTER SCHOOL RELEASES @6PM U N T IL ONE W EEK BEFORE
SCHOOL RESUMES @ 8PM.

[]
^
Does not apply.

PARENTS SHALL TAKE V A C A TIO N S D U R IN G T H E IR

POSSESSION OF THE M IN O R C H ILD .

18374
3.7
is b
T?2

With Petitioner
(Specify Year
Odd/Even/Everv)
New Year's Day
Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
3.8
EVEN
With Respondent
(Specify Year
Odd/Even/Everv)
O DD
EVERY
EVEN
ODD
ODD________
O DD
EVEN
EVEN______________
[]
times):
[]
(]
Other:

With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
Mothers Dav______________
EVERY____________ __________________
Fathers Day_______________
___________________
EVERY________
[J
Other:

18374
3.9
Does not apply because one parent lias no visitation or restricted visitation.
f]
1 winter vacation (3.3)
2 __ school breaks (3.4)
3 summer schedule (3.5)
[]
3.11
16BB73

[j
XI
3.10
6 ^7 -^2 8 1 2
4
5
6
holidays (3.7)
special occasions (3.8)
vacation with parents (3.6)
Other:
Restrictions
XI
I]
The [ ] petitioners [ ] respondents residential time with the children shall be limited
because there are limiting factors in paragraphs 2. J and 2.2. The following restrictions
shall apply when the children spend time with this parent:
[]
reasons:
Transportation costs arc included in the Child Support Worksheets and/or the Order of Child
THE PARTY RECEIVING POSSESSION OF THE MINOR CHILD W IL L BE SOLELY
RESPONSIBLE FOR THEIR RESPECTIVE TRANSPORTATION COSTS. FATHER W ILL
PAY AND PROVIDE FOR TRANSPORTATION TO BEGIN V IS ITA T IO N . MOTHER W ILL
PAY AND PROVIDE FOR TRANSPORTATION UPON CONCLUSION OF V IS ITA T IO N .

1SS
J74
3.12
7 /2 ^ 1 2
l& g g ? 4
the ^ petitioner [ | respondent. This parent is designated the custodian of the child(ren) solely
parenting plan.
3.13
Other
3.14
Summary of RCW 26.09.430 ~ .480, Regarding Relocation of a Child


WPF DR 01.0400 Mandatory (6/2008)-R C W 26.09.016, .181; 187; 194
1S974
& /7 /2 B 1 2
lb S B ? 5
confirmed.
(Objection to Relocation/Petilion for Modification of Custody Decree/Parenting Plan/Residential
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.
IV. Decision Making

4.1
children.
4.2
Major Decisions
Education decisions
[]
II
n
[]
n
n
n
u
[i
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner

f]
n
u
11
[i
n
[]
u
i]
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
;W joint
joint
u joint
n joint
joint
[3 joint
[] joint
L ] joint
:] joint
1S374
4.3
b s ? s z a 12

f]
Docs not apply because (here are no limiting factors in paragraphs 2. i and 2.2 above,
Sole decision making shall be ordered to the [ ] petitioner [ ] respondent for the following
reasons:
L]
[]
[]

(a)
(b)
(c)
(d)
| ]
The existence of a limitation under RC W 26.09.191;

RCW 26.09.184(4)(a); and
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
[]
or agency)
fJ
counseling b y ___________________________________, or
[]
mediation by ___________________________________ , if this box is checked and


WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181;. 187; .194
18374
[]
arbitration by
6 /7 /2 S 1 2
I6 7?
_____________ _____________________ .
[]
[]
f]
__________% petitioner _________% respondent.

worksheets.
The dispute resolution process shall be commenced by notifying the other party by [ 1 written
request [ ] certified mail [ j other:
(a)
(b)
(c)
(d)
(e)

Unless an emergency exists,"the parents shall use the designated process to resolve
without good reason, the court shah award attorneys1fees and financial sanctions to the
other parent.
The parties have the right of review frotn the dispute resolution process to the superior
court.

f1
JQ

FATHER SHALL CLAIM THE M IN O R C H IL D FOR FEDERAL A N D STATE

TA X PURPOSES IN EVEN YEARS B E G IN N IN G 2 0 1 2 (F IL IN G IN 2 0 1 3 )
A N D MOTHER W IL L C LA IM THE M IN O R C H IL D FOR FEDERAL AND
STATE TA X PURPOSES IN ODD YEARS.

WPF DR 01.0400 Mandatory (6/200B) - RCW 26.09.016, ,181; .187; .194
13974
^2812
168878

| J
XI
Does Hot apply.

Petitioner
Respondent

not affected.
Dated:
12Judge/Commissioner
Presented by'
Approved for entry:

C H R ISTO PH ER LEE HAR R ISO N
Print Name

Print Name

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016, .181, .187; .194
? S 2 f2 m i2
>1
17342
33S 12S
For
Charlotte Pergrim
6721 Nathan Ave SE
Auburn, WA 98092
STATE OF IDAHO
COUNTY OF ADA
ss
Received by TRI-COUNTY PROCESS SERVING LLC on June 7, 2012 to be served on JOLENE
MARIE HARRISON.
I, Antonio Roque, who being duly sworn, depose and say that on Thursday, June 7, 2012, at 8 42 PM, I
SERVED the within named person{s) by leaving a true copy of the Summons
(Modification/Adjustment of Custody Decree/Parenting Plan/Residential Schedule); Order Setting
Case Schedule; Note for Commissioner's Calendar; Declaration of Christopher Lee Harrison;
Order re Adequate Cause (Modification/Adjustment of Custody Decree/Parenting Plan/Residential
Schedule); Parenting Plan [Proposed]; Petition for Modification/Adjustment of Custody
Decree/Parenting Plan/Residential Schedule with William R. Charlton, spouse and co-resident, a
person over the age of 18 years at 7196 S. Culbertson Way, Boise, ID 83709, the usual place of abode
of Jolene Marie Harrison Said service was effected at 7196 S Culbertson Way, Boise, ID 83709
I hereby acknowledge that I am a Process Server in the county in which service was effected I am over
the age of Eighteen years and not a party to the action
Reference Number 119060
Client Reference
173*2
'330121
June 8, 2012
TRI-COUNTY PROCESS SERVING L.L.C.

P O Box 1224
Boise, ID, 83701
(208) 344*4132 Business
(208) 338-1530 Fax
Federal Tax ID 82-0348092
Invoice #119060
CHARLOTTE PERGRIM
6721 NATHAN AVE SE
AUBURN WA 98092
Reference Job #119060 when remitting.
Jolene Marie Harrison vs Christopher Lee Harrison
Case Number: 08-3-00821-4

Documents: Summons (Modification/Adjustment of Custody Decree/Parenting Plan/Residential Schedule); Order
Setting Case Schedule; Note for Commissioner's Calendar; Declaration of Christopher Lee Harrison; Order re
Adequate Cause (Modification/Adjustment of Custody Decree/Parenting Plan/Residential Schedule); Parenting
Plan [Proposed]; Petition for Modification/Adjustment of Custody Decree/Parenting Plan/Residential Schedule
Jolene Marie Harrison Served by leaving with William R Charlton
Completed on June 7, 2012

at 8.42 PM, at 7196 S. Culbertson Way, Boise, ID 83709
by Antonio Roque
Mileage Fee $18 00

Service Fee $41 00
Total: $59 00
DUE ON RECEIPT: $59.00

Thank You for Choosing
TRI-COUNTY PROCESS SERVING LLC>
E-FILED
July 12 2012 11:51 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


Petitioner(s),
vs.
NO. 08-3-00821-4

_______________ Respondent(s)
DATED: July 12, 2012
ntaprsup-0001.pdf
/s/ Daniel N Cook

Faubion, Reeder, Fraley and Cook, PS

5920 100th St SW Ste 25
(253) 581-0660
E-FILED
July 12 2012 11:53 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


Petitioner(s),
vs.
NO. 08-3-00821-4

_______________ Respondent(s)
DATED: July 12, 2012
ntaprsup-0001.pdf
/s/ Daniel N Cook

Faubion, Reeder, Fraley and Cook, PS

5920 100th St SW Ste 25
(253) 581-0660
E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHINC
July 12 2012 12:18 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7
8

9
10
11
12
13

Petitioner,
NO. 08-3-00821-4
v.
14
Respondent.
15
16
17
18
I, Amber Johnson, am over the age of 18, and competent to testify in the above
entitled case.
On July 12, 2012, I placed in the U.S. Mail a copy of the Notice of Appearance, in
the above-entitled caption.
19
20
21
22
23
Said documents were addressed to: Christopher Lee Harrison

6721 Nathan Avenue SE
Auburn, WA 98092
I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
DATED
July 12,2012
24
Ci
25
Amber Johnson, Le$a Assistant

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING'
July 23 2012 2:46 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7
8
9
10
11
12
13

HARRISON
Petitioner,
and
14
15
Respondent
16
17
To: Court and all Parties
18
I. Response
19
1.1
20
21
22
23
24
No. 07-3-01638-3
Response to Petition for
Modification/Adjustment of Custody
Decree/Parenting Plan/Residential
Schedule (RSP)
[ ] Order fo r protection UH (PTORAH)

The allegations of the petition in this matter are adm itted or denied as follows
(check only one for each paragraph):
1.1
1.2
1.3
2.1
Admitted
Admitted
Admitted
Lacks information - no boxes are checked for specific information.
25
Resp to Pet fo r M od/Adj (RSP) - Page 1 o f 4

26.10.200
Charlton v Harrison
S:\CASES1\Chariton, Jolene\DRAFTS\Pleadings\2012 Modification\Response to
Petition.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Phone: (2 5 3 ) 5 8 1 -0 6 6 0
2.2
Denied. There has been no substantial change in circumstances.

The mother lives in Idaho and the father lives in Washington. This
was a known fact at the time the prior parenting plan was entered.
See Paragraph 3.13 of the Final Parenting Plan dated July 27, 2011.
There is no basis for modification of the parenting plan.
2
3
4
In light of the distance between the parties, and the RCW 26.09.191
limiting factors against the father (history of DV; long-term mental
health issues; drug/alcohol abuse; neglect/non-performance of
parenting functions), the final parenting plan provides more than
adequate time with the father and all visitation is supervised until the
requirements of Paragraph 3.10 are met. There is no need to
change the parenting plan - the father simply needs to meet the
reguirements of the current parenting plan in order to obtain
unsupervised visitation.
5
6
7
8
9
10
There is not adequate cause for hearing the Petition for Modification
because the moving party has not met all of the requirements of the
prior final parenting plan. See Paragraph 3.10.
Paragraph 3.10
requires Christopher Harrison to, among other things, provide copies
of all documents and reports and compliance records in his alcohol
offense monitoring program.
No documents regarding follow up
treatment or reports and records from the probation officer have been
produced, nor has there been any collateral contact with the
Petitioner/mother. No drug and alcohol assessments were provided.
11
12
13
14
15
Paragraph 3.10 also requires Christopher Harrison to, among other

things, provide proof of current mental health treatment providers,
proof he is stable, taking the appropriate medications and prior mental
health issues are under control. A simple certificate of completion
with the Community Psychiatric Clinics Impact Program has been
produced by the Respondent/father. But we have absolutely no idea
what this even is.
Furthermore, no authorization for release of
information has been signed by the Respondent/father, no names of
treatment providers have been given, no proof of medication has been
provided and no clean bill of health from a physician or psychologist
has been provided.
16
17
18
19
20
21
22
Paragraph 3.10 also requires Christopher Harrison to provide proof of

DV treatment. In May 2012 he did provide to Jolene Charltons
attorney a single, one-page DV Treatment Report. But there has been
no collateral contact with the Petitioner/mother, nor has there been
any report of follow up treatments. The father still has not provided a
copy of the DV assessment by Valley Cities/Gloria Axtel.
23
24
25
Resp to Pet fo r Mod/Adj (RSP) - Page 2 o f 4

W P F D R P S C U
0 7 .0 2 0 0
M a n d a to r y (6 /2 0 0 8 ) - R C W 2 6 .0 9 .2 6 0 ; .2 7 0 ;
2 6 .1 0 .2 0 0
Charlton v Harrison
S:\CASES1\Charlton, Jolene\DRAFTS\Pleadings\2012 Modification\Response to

Petition.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
2.3
2
2.4
3
2.5
4
5
2.6
2.7
2.8
7
2.9
8
9
10
11
2.10
2.11
2.11.1
12
13
14
2.11.2
15
16
2.11.3
2.12
17
18
2.13
19
20
21
2.14
2.15
2.16
22
23
24
25
1.2
Denied. It has been less than two years since child support was last
modified and there has been no substantial change in circumstance.
Denied. Venue should be changed to Ada County, Idaho where the
child primarily resides.
Admitted; however, Washington State should decline to exercise
continuing, exclusive jurisdiction in favor of transferring this case to
Idaho now that the mother and child both reside in Idaho.
Admitted
Admitted
Denied. There is no admissibleevidence whatsoever to support the
allegation of detrimental home environment.
Denied. This statement is a legal conclusion which does not require
an answer, but the legal conclusion made by father (that his parental
rights have been severed) is patently false. The parenting plan
provides for regular visitation with the father and simply requires
supervision until such time as the father demonstrates compliance
with various safeguards which are necessary to ensure the well being
of the child.
N/A
N/A
Denied. Christopher Harrison has not complied with therequirements
of the prior parenting regarding the limitations. Christopher Harrison
has not provide any new information that was not known at the time of
entry of the prior plan to show a change in circumstance.
Denied. Christopher Harrison has submitted no proof of compliance
with two of three major requirements for evaluations, treatment or
other classes in the prior parenting plan and only partial compliance in
the third category of requirements.
N/A
Denied. There has been nochange
incircumstances to support a
change in these provisions.
Denied. These statements are false. The father has notcomplied
with the requirements of the prior parenting plan. The relocation was
known before entry of the prior parenting plan and modification of the
parenting plan will not make visitation any more feasible. The child
has not flunked any grade in school. The child is not flunking at
present and has not missed so much school so as to cause concern.
Admitted
Admitted
N/A

Notice of all further proceedings in this matter should be sent to the address below

W P F D R P S C U
0 7 .0 2 0 0
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2 6 .1 0 .2 0 0
Charlton v Harrison

Petition.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
1.3
Other
Does not apply.
4
5
II. Requests
2.1

The nonrequesting party also requests attorneys fees pursuant to RCW

26.09.260(13) in the amount of $750 which have actually been incurred and paid
for responding to this improper and bad faith petition for modification of the
parenting plan.
8
9
10
2.2
11

at a later date.
12
13
14
2.3
Protection Order
15
16
17
Does not apply.

Submitted this day
of July 2012.
18
19
Daniel N. Cook7W SBA^4866

20
21
22
23
I, THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER

THE LAWS OF THE STATE OF WASHINGTON THAT THE ATTACHED PAGES ARE
TRUE AND CORRECT.
, (state)_____ on (date)
Signed at (city)
24
25
W P F D R P S C U
0 7 .0 2 0 0
M a n d a to r y (6 /2 0 0 8 ) - R C W 2 6 .0 9 .2 6 0 ; .2 7 0 ;
2 6 .1 0 .2 0 0
Charlton v Harrison

Petition.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
L-d
1 2 : 5 8 F r o m : H e a r t la n d
P h a rm a c y
T o :12535810894
Pa9e:
1
2
1.3
Other
Does not apply.
4
5
II. Requests
2.1

The nonrequesting party also requests attorneys fees pursuant to RCW

26.09.260(13) in the amount of $750 which have actually been incurred and paid
for responding to this improper and bad faith petition for modification of the
parenting plan.
8
9
10
2.2
11

at a later date.
12
13
14
2.3
Protection Order
15
16
17
Does not apply.

Submitted this day
of July 2012.
FAUBION, REEDER, FRALEY & COOK, P.S.
18
19
Daniel N. Cook, WSBA 34866

20
21
22
23
I, THE UNDERSIGNED, DECLARE UNDER PENALTY OF PERJURY UNDER

THE LAWS OF THE STATE OF WASHINGTON THAT THE ATTACHED PAGES ARE
TRUE AND CORRECT.
Signed at (city)
^
, (state)
on (date)
? to \2
LENE CHARLTON

26.10.200
Charlton v Harrison
S;\CASS$l\Chaflton, Jolene\DRAFTS\Plescfings12012 Modlfication\Hesponse to
Petition, doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253)581-0660
1
2
3
4
5
6
7
8
9
10

COUNTY OF PIERCE
11
12
13
14
15
16
17
In re:
No. 08-3-00821-4

Petitioner,
and
DECLARATION RE
SIGNATURE ON FAXED
DOCUMENT

Respondent.
I, Sally DuCharme, declare under penalty of perjury that the foregoing faxed
18
document(s) attached to this RESPONSE TO PETITION, which consists of 6 pages including

19
this declaration page (but not including attachments), is a complete and legible image that I
20
have examined personally and that was received by me via FAX at (253) 581-0894.
21
22
Signed at Lakewood, W A on July 23, 2012.
23
Sally DuCharme, Legal Assistant
24
25
DECL re FAXED SIGNATURE - Page 1 o f 1
Charlton v Harrison
S:\CASES1\Charlton, Jolene\DRAFTS\Pleadings\2012 Modification\Declaration re Faxed
Signature.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
PIERCE COUNTY, WASHING!
July 24 2012 11:43 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7

COUNTY OF PIERCE
8
9
In re:
10

Petitioner,
and
No. 08-3-00821-4
11
12
13

Respondent.
I, Daniel N. Cook, am over the age of 18, and competent to testify in the above entitled
14
case.
15
16
On July 22, 2012, I placed in the U.S. Mail a copy of the following documents in the
17
1. Response to Petition for Modification/Adjustment of Custody Decree/Parenting

Plan/Residential Schedule.
18
19

20
21
22
DATED
July 23, 2012
23
Daniel N. Cook, WSBA 34866

Attorney for Petitioner
24
25
Charlton v Harrison
S:\CASES1\Charlton, Jolene\DRAFTS\Pleadings\2012 Modification\Declaration of

Mailing.docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
P tO
------ Cx ^C lC -
For Respondent
For Petitioner
/ ifr j> r r ^ y \
4 k C\l\$X<P-
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g t^ ^ n o U < 3 _________ f t g r f r t i o / > Q j r
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(pOcxl_ n rd k jr
/A r^ O ___ ^ fT T P r - p J ,
July 30, 2012 9:30 AM
Motion - Modify Temp Order

DAVID H. JOHNSON
Clerk:
c t e >Q>t^

Calendar:C2 - SHOW CAUSE/FAMILY LAW
txcrtrpt.pbi djoumat_entry_showcau$e_report
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IN C U N T / ^ i R K'S O F F IC E
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C o u n t y C / e rk
JUDGMENT SUWftRY
CASE H 0 % ^> ~ O O f c - l
To c o m p ly w it h R.C.W . 4 .6 4 .0 3 0 a s amended by s e c tio n 1107, Chap. 4 4 2 , Laws

erf
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O th e r R e co very Am ounts:
8.
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9.
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10. A t to r n e y f o r Judgm ent C r e d it o r :
V. p e r annum.
a ll
or
1
2
3
4
6
Cause No:
7
Petitioner
8
9
(OR)
Pm & s T W M /'M tU tC O r'

_______ Respondent____________________ ________________________________________
THIS MATTER having come before the Court upon the moving party's Motion, and the Court
laving heard the argument of the parties, and having considered the records and files herein, it is now,
12
13
ORDER
VS
10
11
ORDERED, ADJUDGED AND DECREED T r it

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22
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Attorney for Defendant/Respondent

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7.4
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1
2
3
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6
Cause No: 0 $ ' 3 - C O S ^ - f - Y
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Petitioner
ORDER
vs
(OR)
10
11
Respondent
THIS MATTER having come before the Court upon the moving partys Motion, and the Court
having heard the argument of the parties, and having considered the records and files herein, it is now,
therefore,
12
13
14
ORDERED, ADJUDGED AND DECREED

sync
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19
20
21
22
23
24
25

WSBA#

WSBA#
Pfloe. O ofH
1
2
3
4
5
6
Cause No:
7
8
9
10
11
Petitioner
o g '3 - o & U
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ORDER
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____________ Respondent_________
therefore,
12
13
ORDERED, ADJUDGED AND DECREED____________________________________________

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20
21
(A s< r
SIONER
22
23
24
25

WSBA#

WSBA#
a P
y,
1
2
3
4
5
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Cause No:
7
Petitioner
8
9
vs
(OR)
h /k s X > M /L
# * * 4 (2 0 ^
Respondent
10
11
ORDER
therefore,
12
ORDERED, ADJUDGED AND DECREED.
13
C
14
f f in m
e m /io
/?
D & O G S /q c -C O ffe c .
a y v
a c c
.________________________
15
16
17
18
J B l rS
A -m a x ^ r
C .H a e c rO rJ
o z
ir l's J
19
P tf)flc rJ fo flDATED this
20
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f g
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day of
J Q L j. 20 / 2 - r -----
Z '
------- / / ^
fiG e /i
21
JUDGEfCOMMISSIO
22
23
Attorney for Plaintiff/Petitioner O A fJl C
25
WSBA

WSBA#
pA 6

COUNTY OF PIERCE
10
11
12
13

HARRISON
Petitioner,
and
Respondent
14
16
I. Basis
1.1
A petition requesting the modification/adjustment of the custody decree/parenting

plan/residential schedule in this matter has been presented to the court.
1.2
A hearing was held on: July 30, 2012.
18
19
20

(Modification/Adjustment of Custody
Decree/Parenting Plan/Residential
Schedule)
P 4 Denied (ORRACD)
[ ] Granted (ORRACG)
[ j Hearing set (ORH)
C lerks A ction Required
15
17
08-3-OOgL2f~ V
No. PT 3 01030 y
II. Findings
The C ou rt Finds:
21
2.1
Jurisdiction
22
This court has jurisdiction over the proceeding and the parties.
23
24
25
2.2

The nonmoving party was served with a copy of the petition for modification

26.10.200
Charlton v Harrison
S:\CASES1\Char1ton, Jolene\DRAFTS\Pleactings\2012 Modtfication\Order re Adequate
Cause.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920- 1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
^ V
j 2
&'r '^
/adjustment of custody decree/parenting plan/residential schedule, summons, a

proposed parenting plan, and child support worksheet, if any, on June 7, 2012.
2.3
The nonmoving party was served outside the state of Washington and more than
60 days have NOT elapsed since the date of service.
5
6
2.4
2.5
9
10
Response
The nonmoving party has responded or has joined in the petition.
7
a

Adequate cause for hearing the petition has not been established.
2.6

2.6.1
12
Service member status It appears the nonmoving party:

is not a service member;
13
2.6.2 Dependent of a service member status It appears the nonmoving party:
14
is a National Guard member or a Reservist;
15
16
17
III. Order
it is O rdered :
54
18
[]
19
The petition is denied;
C cd/FfC /f7X /M
&
^9cso
Of f \ch
The matter is set for hearing or trial at:

Date: February 13, 2012
Time: 9:00 a.m.
Place: Pierce Co. Superior Court Room/Deuertment: TBD
20
21
22
Dated:
A o n
~ ia
Judge/Commissioner
23
IN COUN^
24
F^
25
Ord re Adequate Cause (ORRACD, ORRACG, ORH) ~ Page 2 o f 3

26.10.200
Chariton v Harrison
S\CASES1\Chariton, JoieneWRAFTS\Pleadings\2012 Modification\Orderre Adequate
Cause.doc
Lakewood, W A 98499
253-581 -0660
1
2
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
Approved by:
Daniel N.
Attorney for Petitioner

P ro S e
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26.10.200
Chariton v Harrison
S:\CASES1\Char1ton, JoteneXDRAFTS\Pleadings\2012 Modification\Order re Adequate
Cause.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
iag4g
08-
00821-4
39017560
ORDSMD
Q 7 i4 / ? g i2
S0S23
08-14-12
2
3
4
5
6
7

Case No 08-3-00821-4
10
11
12
Petitioner(s)
ORDER OF DISMISSAL
vs.
ORDSMD
Respondent(s).
13
14
15
THIS MATTER having been denied adequate cause on July 30, 2012, by
Pro Tem Commissioner David H. Johnson, Now, Therefore, it is hereby
ORDERED that the Petition for Modification of Custody filed June 6 , 2012, is hereby Dismissed
16
17
18
19
20
21
22
23
24
25
E-FILED
PIERCE COUNTY, WASHING'
August 16 2012 4:08 PM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4
3
4
5
6
7
8

County of PIERCE
9
10
In re:
11

Petitioner,
and
12
13
No. 08-3-00821-4
Return of Service
(Optional Use)
(RTS)

________________________Respondent.
14
15
I Declare:
16
1.
la m over the age of 18 years, and I am not a party to this action.
2.
I served the following documents to (name) Christopher Harrison:
17
18
1.
2.
19
20
21
22
23
3.
Order re Adequate Cause entered July 30, 2012; and

Order entered July 30, 2012.
Date: July 30. 2012_________________________Time:
Address:
930 Tacoma Avenue South. Room____________________________

Tacoma. W A 98402_________________________________________
24
25
Return o f Service (RTS) - Page 1 o f 2

S:\CASESl\Charlton, Jolene\DRAFTS\Pleadings\2012 Modification\ReturnofService.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
4.
Service was made:

3
5.
Service of Notice on Dependent of a Person in Military Service.
N/A
6.
Other:
t
10
11
Daniel N. Cook, W SBA #34866
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Return o f Service (RTS) - Page 2 o f 2

S:\CASESl\Charlton, Jolene\DRAFTS\Pleadings\2012ModiJication\Return ofService.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
April 29 2013 10:17 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


Petitioner(s),
vs.
NO. 08-3-00821-4

_______________ Respondent(s)
AND TO: Daniel N Cook, attorney for Petitioner, JOLENE MARIE HARRISON,
CHRISTOPHER LEE JR HARRISON
PLEASE TAKE NOTICE that H. GARY WALLIS, appears herein on behalf of the
Respondent(s) CHRISTOPHER LEE HARRISON and requests that all further pleadings and
DATED: April 29, 2013
ntaprsup-0001.pdf
/s/ H. GARY WALLIS

H. GARY WALLIS, #6311
Attorney for Respondent(s)
H. GARY WALLIS
9615 Bridgeport Way SW
(253)584-1110
E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, WASH
February 18 2015 11:1
KEVIN STOCK
COUNTY CLEF<
NO: 08-3-0082
3
4
5
6
7
8

County of PIERCE
9
10
In re:
11
JOLENE MARIE CHARLTON,
12
No. 0 8 - 3 - 0 0 8 2 1 -4
Petitioner,
13
and
14

Show Cause re
Contempt
(MTSC)
Respondent.
15
I. Motion
16
18
CHRISTOPHER LEE HARRISON moves the court for an order directing JOLENE MARIE
CHARLTON to appear personally before the court and show cause why an order should not be
entered:
19
1.1
17
20
21
Signed by the court on 07/25/2011, in PIERCE County, WA.
22
23
24
Finding Contempt
1.2
Does not apply.
25
WPF DRPSCU 05.0100 (10/2009) - RCW 26.09.160
L a w O ffice o f H . G ary W a llis

9615 Bridgeport W ay S W
98499
584-1110
( 253) 584-8858
L a k e w o o d , W a s h in g t o n
P h o n e : ( 253)
Fax:
FamilySoft FormPAK 2014
1.3
Granting Sanctions
Granting sanctions for contempt, including a forfeiture for each day the contempt of court
continues, and establishing conditions by which the contempt may be purged and
residential time, as may be appropriate under Chapter 7.21 RCW, Chapter 26.09 RCW,
Chapter 26.10 RCW, Chapter 26.26 RCW, and RCW 26.18.040.
3
4
5
1.4
Other
7
8
Zj
Dated:
j I S ________
ARY WALLIS
10
11
II. Declaration
12
JOLENE MARIE CHARLTON should be held in contempt for the following reasons,
13
Failure to comply with the parenting plan as follows:
14
Not allowing visitation with the respondent after he had completed all court ordered
requirements.
15
16
17
Not allowing the respondent the proper telephone time allotted to him in the Parenting
Plan.
true and correct.
18
19
Signed at
20
21
22
23
24
25
WPF DRPSCU 05.0100 (10/2009) - RCW 26.09.160

Lakewood, Washington 98499
Phone: ( 253) 584-1110
Fax: ( 253) 584-8858
E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, WASH
February 18 2015 11:1
KEVIN STOCK
COUNTY CLEFK
NO: 08-3-00811
3
4
5
6
7
8

County of PIERCE
9
10
In re:
11
12
No. 0 8 -3 - 0 0 8 21-4
Petitioner,
13
and
14
Declaration of Christopher
Harrison
Respondent.
15
16
I was contacted by Jolene on 11-21-14, w ith her saying she was going to be in tow n fo r
17
Thanksgiving and I could visit my son on Sunday the 23rd, if I had a supervisor fo r supervised
18
visits. (I had known since the end o f August th a t she was coming here fo r Thanksgiving (my
19
daughter and Jolene's niece are friends)). I explained to her th a t I had com pleted everything
20
almost a year ago and th a t I no longer had supervised visits. I w e n t on to tell her th a t had she
21
22
not been avoiding her attorney she w ould know this. I received no response from her ever on
23
the subject. On 11-19-14 my attorney mailed to her a le tte r stating th a t I w ould be in Boise on
24
12-13-14 and w anted to see my son fo r th e day, unsupervised. He enclosed the docum entation
25
showing th a t I had com pleted all o f the court's requirem ents. This was also re-sent to her
Declaration o f Christopher Harrison - Page 1 of 2

9615 Bridgeport W ay SW
98499
584-1110
( 253) 584-8858
P h o n e : ( 253)
Fax:
1
attorney. W e received no response on this subject. On 1-23-15 I texted her saying th a t I would
be in Boise, e ithe r the end o f February o r firs t o f March and I w ould like to see my son,
unsupervised. As o f 1-28-15 there has been no response. In th e spring o f 2014 my atto rn e y
contacted her a ttorney saying th a t everything has been com pleted, her attorney then relayed
th e inform ation to Jolene. Her only response was th a t she d id n 't w ant to pay fo r any o f the
transportation. We have n ot heard anything from her since then.
true and correct.
10
11
Signed at
12
Signature of Requesting Party
13
14
15
16
17
18
19
20
21
22
23
24
25
Declaration of Christopher Harrison - Page 2 of 2
Law Office o f H. Gary Wallis

9615 B ridgeport W ay S W
98499
584-1110
( 253) 584-8858
P h o n e : ( 253)
Fax:
E-FILED
February 18 2015 11:16 AM
KEVIN STOCK
COUNTY CLERK
NO: 08-3-00821-4


No. 08-3-00821-4
Petitioner(s),
vs.

Respondent(s)
Name: Daniel N Cook
Address: 5920 100th St SW Ste 25 LAKEWOOD, WA 98499-2751
Phone: (253) 581-0660

S h o w C ause
Nature of Hearing: Contempt, Parenting Plans
CALENDAR DATE: Tuesday, March 17, 2015
9:00 AM

DATED:
February 18, 2015.
Signed:
/s/ H. GARY WALLIS
NAME:
H. GARY WALLIS
Phone:
(253) 584-1110
ADDRESS: 9615 Bridgeport Way SW

WSBA#:
For:
6311
1 of
fN COUWTY CLERKS OFFICE

08-3-00821-4
44158633
MTSC
02-19-15
A-M-
V .
FEB 1 9 2015
PM
)U N T
kevin
E STOCK,
s troci
o ^ V^County
M sh ,^ gtow
r'lCvfiM
Clerk
Dr------- "
- ___DEPUTY
6
7
8

County of PIERCE
10
In re:
r\
r r
\Ar.V
12
14
3'r.
13
and
14
No. 0 8 -3 -0 0 8 2 1-4
Petitioner,

Show Cause re
Contempt
(MTSC)
Respondent.
15
16
I. Motion
17
18
CHRISTOPHER LEE HARRISON moves the court for an order directing JOLENE MARIE
CHARLTON to appear personally before the court and show cause why an order should not be
entered:
19
1.1
20
21
Signed by the court on 07/25/2011, in PIERCE County, WA.
22
23
24
Finding Contempt
1.2
Does not apply.
25
WPF DRPSCU 05.0100 (10/2009) - RCW 26.09.160
Law Office o f H. Gary Wallis

9615
B rid geport W ay SW
98499
584-1110
( 253) 584-8858
P h o n e : ( 253)
Fax:
1.3
Granting Sanctions
2
Granting sanctions for contempt, including a forfeiture for each day the contempt o f court
continues, and establishing conditions by which the contempt may be purged and
residential time, as may be appropriate under Chapter 7.21 RCW, Chapter 26.09 RCW,
Chapter 26.10 RCW, Chapter 26.26 RCW, and RCW 26.18.040.
3
4
5
1.4,
Other
6
7
8
9
Dated:
_____
7~\ ^ j I S '
I
10
'
^
signature of Requesting Party or Lawyer/WSBA No.
11
II. Declaration
12
JOLENE MARIE CHARLTON should be held in contempt for the following reasons,
13
Failure to comply with the parenting plan as follows:
14
Not allowing visitation with the respondent after he had completed all court ordered
requirements.
15
16
17
Not allowing the respondent the proper telephone time allotted to him in the Parenting
Plan.
I declare under penalty of perjury under the laws of the state of W ashington that the foregoing is
true and correct.
18
19
Signed at
20
21
22
23
24
25
WPF DRPSCU 0 5 . 0 1 0 0 ( 1 0 / 2 0 0 9 ) - RCW 2 6 . 0 9 . 1 6 0
Family Soft FormPAK 2014
L a w O ffic e o f H . G a r y W a l l i s

Lakewood, W ashington 98499
Phone: ( 253 ) 584-1110
Fax: ( 253 ) 584-8858
a .m .
FEB 1 9 201!)
P M-

K R /IN S T O C K , C o u n ty C le rk
B Y _ lJ ^ ^ = ^ D tP U T Y

County of Pierce
In re:
10
No.
JO LEN E MARIE CHARLTO N,
11
12
13
Petitioner,
and
08-3-00821-4

Contempt
(ORTSC)
C H R IS TO P H E R LEE HARRISO N
Respondent.
14
15
It is Ordered:
16
17
(Nam e of nonrequesting party) JO LEN E MARIE C H A R LTO N shall appear in person before this
court at the place and time below and show cause w hy the relief requested in the motion should
not be granted.
18
Date:
March 17, 2015
Tim e:
9:00 a.m ./p.m.
19
Place: Pierce County S uperior C ourtR oom /D epartm ent:
Com m issioner's Courtroom
20
21
22
If you fail to appear in person and defend at these proceedings the court m ay grant all o f the
relief requested and/or issue a bench w arrant fo r your arrest without further notice to you.
If im prisonm ent is requested in the m otion and you cannot afford an attorney, you may request
the court to appoint an attorney to represent you.
23
Other:
; .
24
25
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160
Law
O ffic e o f H .
G a ry W a llis
Lakewood, Washington 98499

Phone: (253 ) 584-1110
Fax: (253 ) 584-8858
1
2
3
4
5
6
FILED
8
A.M.
FEB 1 9 2015
P M-

KEViN STOCK, County Clerk
10
ry
----------------- DEPUTY
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
WPF DRPSCU 0 5 . 0 1 5 0 Mandatory ( 6 / 2 0 0 8 ) - RCW 2 6 . 0 9 . 1 6 0
L a w O f f ic e o f H . G a r y W a lli s

98499
Phone:
( 253) 584-1110
F a x : ( 253) 584-8858

Jolene Marie Harrison vs. Christopher Lee Harrison 08-3-00821-4

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Jolene Marie Harrison vs. Christopher Lee Harrison 08-3-00821-4

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E-FILED

IN COUNTY CLERK'S OFFICE

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

No. 0 8 -3-008 21-4

Friday, Ju ly 11, 2008 9:00 AM

DATED: March 7, 2008

SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

SUPERIOR COURT OF WASHINGTON COUNTY OF PIERCE

MOTION AND ORDER TO PROCEED

MOTION AND DECLARATION

lam the applicant, and I seek an order authorizing me to proceed as an indigent

The attached Financial Statement accurately describes my financial condition.

IT IS HEREBY ORDERED THAT:

This case/action may be filed without payment of the filing fee.

THE FAMILY LAW FACILITATOR SURCHARGE OF $10.00 WILL BE PAID

Pf ull Time dtpeMiw on L^PartTime

pfl Part Time

Gross pay per m o n th ^ S tlO ^ H rs per w k :3 4

Gross pay per mont h. 1

Hrs per wk:

b. Date last employed:

b. Date last employed:

c. Reason for Termination;

c. Reason for Termination:

5. OTHER SOURCES OF INCOME PER

5. OTHER SOURCES OF INCOME PER

6. MY SPOUSES MON TH LYE X ENSES

7. THE FO LLOWIN G PEOPLE LIVE

7. THEFOLLOW IN 3 PEOPLE LIVE

8. 1OWE THE FOLLOWING DEBTS

9. MY ASSETS &EQ UITY VALUES ARE:

IaX *______________________ (City & State) on 3 ~ 7 " 6 > 3

Financial Affidavit for Motion and Order to Proceed In Forma Pauperis

Superior Court of Washington

In re the Marriage of:

Jolene Marie Harrison

Petition for Dissolution of

Jolene Harrison, Birth date July 15, 1975

Christopher Harrison, Birth date April 16, 1970

Last known residence

Pierce County, Washington State [county and state],

Children of the Marriage Dependent Upon Either or Both Spouses

Name (first/last)______________________________________________________A ge______

Name (first/last)_____________________________________________ ________ Age

________________________________ Age 14 years

Name (first/last) Kathrina Jean Harrison_________________________________ Age

Name (first/last) Hannah Marie Flohr___________________________________ Age

Allegation Regarding Marriage

Date and Place of Marriage

The parties were married on June 5, 2004 at Bonney Lake, Washington.

Husband and wife are not separated.

This court has jurisdiction over the respondent because:

This court does not have jurisdiction over the respondent.

Pet for Disso of Marriage (PTDSS) - Page 2 o f 10

The division of property should be determined by the court at a later date.

Pet for Disso of Marriage (PTDSS) ~ Page 3 of 10

Debts and Liabilities

The parties have no debts and liabilities.

The petitioner should be ordered to pay the following debts and

The respondent should be ordered to pay the following debts and

Each party should pay their debts incurred since separation.

Spousal maintenance should not be ordered.

Pet for Disso o f Marriage (PTDSS) - Page 4 o f 10

Continuing Restraining Order

Name (first/last)________________________________________________A ge

Name (first/last)_____________________________________ Age

BY V-j DEPUTY

__ 50% mother_ 50% father.