Professional Documents
Culture Documents
I1\11\11 \\\\\\\II \Ill\ 111111\\1\ \\Ill \\Ill Ill\\ Ill\\ \Ill Ill\
CL 13739785
No. 10 2 00156 3
Petitioner Petition for Order for Protection
12~6;. vs. (PTORPRT)
VE.VIII,\ Of'?\..IE= 0!?pA.1U I
Respondent
p( ~
1
Restrain respondent from causing any physical harm, bodily injury, assault,
including sexual assault, and from molesting, harassing, threatening, or stalking
D me 1)!1.the minors named in paragraph S above D these minors only:
(If the court orders this relief, and the respondent is your spouse or former spouse,
the parent of a common child, or a current or former cohabitant as intimate partner,
including a current or former registered domestic partner, the respondent will be
prohibited from possessing a firearm or ammunition under federal law for the
duration of this order. An exception exists for law enforcement officers and
military personnel when carrying department/governmen~issued firearms. 18
U.S.C. § 92S(a)(l).)
~ ~
2
Restrain respondent from coming near and from having any contact whatsoever,
in person or through others, by phone, mail, or any ~ans, directly or indirectly,
except for mailing of court documents, with D me the minors named in
paragraph S above, subject to any court-ordered visitation D these minors only,
subject to any court-ordered visitation: l?\1oyt.
..
CO~ O\l.al:i_~
lh_ - :.;.· _;_. ..& •• 4 .- -
~ ~
3
Exclude respondent from Dour shared residence D my residence .
D my workplace D my school ~the day care or school o~ the minors named in
paragraph S above D these minors only:
D other:
( ~
5
Prohibit respondent from knowingly coming within, or knowingly remaining
within ((J()~ (distance) ofD our shared residence D my residence
D my workplace D mycool ~th~ day care or school of'R the minors named in
paragraph S above. D these minors only:
D other:
7
D D Grant me use of the following vehicle:
Year, Make & Model License No. -
8
D D 0ther:
NIA D 13
Prohibit respondent from interfering with my efforts to remove the pet(s) named
above.
14
NIA D Prohibit respondent from knowingly coming within, or knowingly remaining
within (distance) of the following locations where the pet(s) are
regularly found:
D petitioner's residence (You have a right to keep your residential address
confidential.) D Park
D other:
..
Ch~~k the following only if yciu ~e r~questing piotection lliv~l~ing a niinor: ·
~ubject to any court-ordered visitation, Grant me the care, custody and control of
he minors named in paragraph 5 above D these minors only: .
16
Restrain respondent from interfering with my physical or legal custody of
~the minors named in paragraph 5 above D these minors only:
17
Restrain the respondent from removing from the state:JC( the minors named in
paragraph 5 above D these minors only:
D Custody ofD the minors named in paragraph 5 above D these minors only (if applicable):
"Domestic violence" means physical harm, bodily injury, assault, including sexual assault,
stalking, Or inflicting fear of imminent physical harm, bodily injury or assault between family or
household members.
Statement: The respondent has committed acts of domestic violence as follows. (Describe specific
acts of domestic violence and their approximate dates, beginning with the most recent act. You may
want to include police responses.)
Describe the most recent incident or threat of violence and date: P\et1<=e,
""ef", <ltta\rhecJ
~-
s;;;e;:: NO~~~~
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Describe the past incidents where you experienced violence, where you were afraid of injury or where
the respondent threatened to harm or kill you: Pie ax.
see. a.ttn-h:::Y!ed ~ rvvi:Vl't.
Taylor sustained over 21 bruises on her body including her face, cuts on her shoulder and
shins, a green-stick fracture in her finger and other injuries. During the altercation Kevin
took her cell phone and broke it into 3 pieces and confiscated her brother's cell phone.
They were left with no way to call for help since there is not a landline in that house.
Kevin was arrested for this incident on January 21, 20 I 0 at the Bothell Police Station
after giving a full statement to Officer Kerzman.
Kevin has anger management issues and this is not the first time he has become
physically violent. I was made aware of an incident with our son. He beat him with a belt
so severely that David wet himself. He was 13 years old at the time. In May 2002 the
Bothell Police removed him from our home after throwing me down the stairs and
slamming me into a wall. I have requested a copy of the report from their response to our
home.
I am afraid for the safety and well being of our children. He is showing signs of drug use
and has become increasingly volatile.
Bothell Municipal Court issued a No-Contact Order for our daughter Taylor Cheyenne
Brown on January 22, 2010. I have requested all the documentation from the case as well.
D. D (Pretrial RCW 9.41.800 findings made) Obtaining or possessing a firearm, other dangerous weapon or
concealed pistol license.
D (Conviction of offense listed in RCW 9.41.040(2)) Obtaining, owning, possessing or controlling a firearm.
It is Further Ordered:
~
Warnings to the Defendant: Violation of the provisions of this order with actual notice of its terms is a criminal
offense under chapter 26.50 RCW and will subject a violator to arrest; any assault, drive-by shooting, or reckless
endan erment that is a violation of this order is a felon .
0
.
. ~.
. .
··-·- ··-.
Willful violation ofthisorder is punishable under RCW 26.50.110. Violation of this order is a gross misdemeanor
unless one of the following conditions apply: Any assault that is a violation of this order and that does not amount to
assault in.the first degree or second degree under RCW 9A.36 .011or9A.36.021 is a class C felony. Any conduct in
violation of this order that is reckless and creates a substantial risk of death or serious physical injury to another person
is a class C felony. Also, a violation of this order is a class C felony if the defendant has at least 2 previous convictions
for violating a protection order issued under Titles 7, 10, 26 or 74.
If the violation of the protection order involves travel across a state line or the boundary of a tribal jurisdiction, or .
involves conduct within the special maritime and territorial jurisdiction of the United States, which includes tribal
lands, the defendant may be subject to criminal prosecution in federal court under 18 U.S.C. § 2261, 2261 A, or 2262.
In addition to the state and federal prohibitions against possessing a firearm upon conviction of a felony or a qualifying
misdemeanor, upon the court issuing a no-contact order after a hearing at which the defendant had an opportunity to
participate, the defendant, if a spouse or former spouse, a parent of a common child, or a current or former cohabitant
as intimate partner of a person protected by this order, may not possess a firearm or ammunition for as long as the ncr
contact order is in effect. 18 U.S.C. § 922(g). 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 canying department/government-issued firearms. 18 U.S.C. § 925(a)(l). If the defendant is convicted
of an offen<e of domestic violence, the defendant will be forbidden for life from possessing a firearm or ammunition.
18 U.S.C. § 922(g)(9); RCW 9.41.040.
You Can Be Arrested Even ff the Person or Persons Protected by This Order Invite or Allow You
to Violate the Order's Prohibitions. You have the sole responsibility to avoid or refrain from violating the
order's provisions. Only the court can change the order upon written application.
Pursuant to 18 U.S.C. § 2265, a court in any of the 50 states, the District of Columbia, Puerto Rico, any United States
territorv and anv tribal land within the United States shall accord full faith and credit to the order.
It is further ordered that IP• c{erk of the court shall forward a copy of this order on or b*re the next judicial day
to: 'bo-11,..e\ · D County Sheriff's Office Police Department where the
above-named protected person(s) lives, which shall enter it in a computer-based crimin I intelligence system available
in this state used bv law enforcement to list outstanding warrants. ;-__ \,, '" A ~1_;. ,. 1 1 v. (2,,r'Lt .1 n to rf J..[ .~ 1\-:·"'-~
_V: REMOVAL OF ITEMS/STANDBY ASSISTANCE AUTHORIZED: To remove necessary personal effects ("..~. · , dd . -'>A
from the defendant's residence, the defendant may request law enforcement stand-by assistance.
-see Page One for the Expiration Date of This No-Contact Order.***
Done in open court in the presence of the defendant this date: _ __,__2._~_,__
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ormation
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Request
.. made by: .Phone.---- Mail'----"-"-
.. Person ---- Fali. ·~--- Other --~-~--
If you are requesting that the protection order lasts longer than one year, describe the reasons why:
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Other:
-----------------------------------~
A. Do the child(ren) listed in Paragraph 5 of the petition currently live with you? If not, ~Yes DNo
with whom do th~ child(ren) currently live?
B. Do you know ofl!!!Y other court cases involving the child(ren)? If known, list: DYes ~No
the court the case number the kind of case
c. Have you been involved in l!!!Y other litigation concerning custody or visitation with DYes ~No
the child(ren) in this or any other state? If known, list the court, the case number and
the date the parenting plan, residential schedule, visitation schedule or custody decree
was entered:
the court the case number the date
D. Do you know of any persons, other than you and the respondent, who claims rights of DYes ~No
custody or visitation with, the child(ren)? If known, list their names in the space
provided below and their present addresses in the Confidential Information Form:
Name
Name
Name
E. List the places where the children have lived during the past five years, the dates they lived there and the
persons with whom they lived. (The present addresses of those persons must be listed in the required
Confidential Information Form.)
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This court has jurisdiction over this proceeding for the reasons below: [Check all the boxes that apply to
your case.]
D This court has exclusive continuing jurisdiction. The court has made a child custody, parenting
plan, residential schedule or visitation determination in this matter before and retains jurisdiction
under RCW 26.27.211.
This.state is the home state of the children because:
'54-
~ the children lived in Washington with a parent or a person acting as a parent for at least six
consecutive months immediately befor~ the beginning of this proceeding.
D the children are less than six months old and have lived in Washington with a parent or a
person acting as parent since birth.
D any absences from Washington have been only temporary.
D Washington was the home state of the children within six months before the beginning 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.
D The children and the parents, or the children and at least one parent or a person acting as a parent,
have significant connections with this 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
D the children have no home state elsewhere.
D 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.
D 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.
D No other state has jurisdiction.
D 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.
1 certify under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
'*
First Middle Last Age
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0?Wff. t.Ja<M.ll2!ZA 12K'r'~ ~9~- Respondent's Distinguishing Features:
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~::.. · Caution: Access to weapons: Dyes D no D unknown
The Court Finds:
The court has jurisdiction over the parties, the minors, and the subject matter. The respondent will be served notice
of his or her opportunity to be heard at the scheduled hearing. RCW 26.50.070. For good cause shown, the court
finds that an emergency exists and that a Temporary Protection Order should be issued without notice to the
respondent to avoid irreparable harm.
The Court Orders:
~ 1. Respondent is Restrained from causing petitioner physical harm, bodily injury, assault, including sexual
assault, and from molesting, harassing, threatening, or stalking jiiif petitioner ~he minors named in the
table above D these minors only:
~ 2. Respondent is Restrained from coming near and from having any contact whatsoever, in person or
through others, by phone, mail, or any means, directly or indirectly, except for mailing or service of process
of court documents by a 3"' party or contact by respondent's lawyer(s) with (g"petitioner b e minors
named in the table above D these minors only:
Temp Ord for Protection/NI of Hrg (TMORPRT) - Page 1of3 {f)J1 f/)l r; ~
WPFDV-2.015Mandatory(712007)-RCW26.50.030 {( . ~{, ~
S:\FORMS\FCOURTSERVICES\MasterForms\Temporary Protection Order.doc· , I: '.
, ... )
Respondent is Restrained from going onto the grounds of or entering petitioner's ~esidence
D workplace D school µlthe day care or school of81' the minors named in the table above
D these minors only:
D other:
D Petitioner's address is confidential.~ Petitioner waives confidentiality of the address which is:
\ eo ?\... 9N ~\l'+JOOO 'f<Jf:l.. ~1
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D 4. Petiti exclusive right to the residence petitioner and respondent share. The respondent
shall immediately Vaca the residence. The respondent may take respondent's personal clothing
and respondent's tools ade from the residence while a law enforcement officer is present. D This
address is confidential. Petitioner waives confidentiality of this address which is:
Qrs. Respondent is Prohibited from knowingly coming within, or knowingly remaining within
I 00 ';i'P'f>
(distance) of: petitioner's l8l residence D workplace D school IR'the day
care or schoo1 of~ e mmors named in the table above D these minors only:
D other:
D 6. Petitioner shall e possession of essential personal belongings, including the following:
D 7. Petitioner is granted u
Year, Make & Model License No., _ _ _ _ __
~8.
a minor:
~ 12. Petitioner is Granted the temporary care, custody, and control o~he minors named in the table
above
D these minors only:
13. Respondent is Restrained from interfering with petitioner's physical or legal custody of the
~ minors named in the table above D these minors only:
14. Respondent is Restrained from removing from the state ~the minors named in the table above D
""'g2. these minors only:
The respondent is directed to appear and show cause why this temporary order should not be made effective for
one year or more and why the court should not order the relief requested by the petitioner or other relief which
may include electronic monitoring, payment of costs, and treatment. Failure to Appear at the Hearing
May Result in the Court Granting Such Relief. The Next Hearing Date is Shown on
Page One.
2010 JAN 29 PH 2: 19
SOllYA KRASK1
CGUNTY CLERK
SNOHOMISH CO. WASH
I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\
CL 13454326 __ _
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I. My name is ]). &/\>-.> lh'VI • ,J . I am ISL! a peace officer ~ 18 years of age m older and
not the petitioner.
2. D I was unable to make personal service on the respondent.DI have notified the petitioner that
respondent was not served.
D Personal service was attempted on the following date(s) _ _ _ _ _ _ _ _ _ __
·•
,
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4. I served these documents on I
---.~-~--~
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--~------
at this
(date) (time)
I certify under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Fees: Service - - - - - -
Mileage _ _ _ _ __
Total
DOCUMENTS FILED:
ORDERS ENTERED: REISSUANCE OF TEMPORARY ORDER FOR PROTECTION AND NOTICE OF HEARING
ENTERED, TO BE FILED BY THE FACILITATOR
1 MINUTE ENTRY
•'
IOFEB-8 PH 1=29
r \ ~\ \ \i\niCL~\ \'13743617
\~i\~\\\"~i~\~\ \ ~~ r:
SONYA KRASKI
COUNTY CLERK
,"NOHOMISH CO. WASH
\
0 Other: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The clerk of the court shall forward a copy of this order on or ~re the next judicial day to the
D County Sheritrs Ollie~ Sno CQ1V) Police
Department where petitioner lives which shall enter this order in any compute>based criminal intelligence
system available in this state used by law enforcement to list outstanding warrants.
D The clerk of the court shall also forward a copy of this order on or before the next judicial day to
0 County Sheritrs OfficeO Police
Department where respondent lives which shall personally serve the respondent with a copy of this order,
the Temporary Order, and the Petition, and shall promptly complete and return to this court proof of
service. ""'Q;;ltf.'M '~•• •• ~..;
Petitiu11e1 ltas 111ade -~Fi\ ·at~ BffilRge1HeRts fer sePt·ise sf tftis 01 dc1. ~j
DATEDf-EB - - 8 ZBf6at / ~/ t{ a@
Prese~Wby:CT. COMM. .' a~f.o~wledgeJe:r;:a copy ;ji";/r7~
4:M /j4{L!dt,Jm~) 2/e /UJ IV
Pet1t1oner ~ Date Ri!}U
-~---"=--------''-
....,--'-Tf.-rH'
t Date
REISS OF TEMP ORD FOR PROTECTION/NT HRG (ORRTPO)- Page I of I
WPF DV-5.0IO (9/2000)- RCW 26.50.060(3) I.
S:IFORMSIFCOURTSERVICES\Mastcr Forms\ReissuanceDV.doc
.·
vs. COVERSHEET
Respondent/Defendant(s).
Case
Offenses
Subjects
Arrests
Property
Date Code Type Make Model Description Tag No. Item No.
01/21/2010 Evidence CD/For Evidence co:R containing photos of victim's 1a.1680 1
injuries -EV~
0269-01
Suspect Vehicles
No. Vehicle Type Year Make Model Color License Plate State
On 01-21-10 at about 1919 hours Bothell Officers responded to the Bothell Police Department to take a front counter
contact regarding a juvenile problem. Upon arrival I contacted a Kevin Brown who wanted to speak about some issues
he had been having with his 16 year old daughter Taylor Brown.
Page: 1of5
Case Report
Summary
I invited Kevin to come into the station office so I could speak with him in private. Once inside the office Kevin said that
on late Tuesday night 01-19-10 he had found his son text messaging on his phone. He said he took his son into his
bedroom and was speaking with him about it During the conversation he was informed that his daughter Taylor had
been kissing a boy over the weekend. Kevin said this made him upset because Taylor had just recently spoken to him
about dating. He said he went up to Taylor's room to see if she was still awake so he could speak with her. Kevin said
when he went into her bedroom Taylor was talking on the phone to a boy named Jordan and he said he asked her to
come down to his room so he could speak with her. Kevin said they went down to his bedroom and sat on the bed with
his 14 year old boy.
Kevin said he began to speak with Taylor about the kissing incident and her being on the phone at late hours. He said
Taylor was being very respectful to him at which time he asked her to call Jordan so he could speak with him. He said he
wanted to talk to Jordan about keeping her awake at such late hours, which was effecting her school habits. Kevin said
Taylor refused to call Jordan so he asked for her phone so he could call him. Kevin said he got her phone from her and
began to try and call Jordan at which time Taylor said "I fucking hate you" and punched him four to five times on the back.
Kevin said this made him extremely upset because he had never had any type of issue like this with Taylor. He said he
immediately slapped her on the face with an open hand and said she fell backwards onto a table in the bedroom. Kevin
said Taylor tried to get her phone back from him and they began to wresUe for it. He said he grabbed his belt and was
going to spank her with it but indicated Taylor tried to grab the belt away from him. Kevin said he was able to get the belt
and then began to spank Taylor with it several times.
Kevin said after the spanking took place he tried to speak with Taylor about what she had said and what her issues were
but she wouldn't talk about anything. Kevin said Taylor again tried to take her phone and leave the room but he said he
was able to get the phone back. Kevin said he was so upset with Taylor's behavior he smashed her telephone against
the wall causing it to break. At this time Kevin said Taylor went up to her bedroom and started to get dressed. He said
he was worried that Taylor may possibly try to runaway so he woke the other kids up in the house. Kevin said he called
Taylor's mother Lisa Ugalde-Soros and told her he was bringing Taylor to her house because he was having issues with
her. Kevin said he gathered all the kids up and then drove Taylor to Lisa's house in Lynnwood. Once he got to Lisa's
house he said Taylor went inside and he stood and spoke with Lisa and her husband about what had occurred. At this
time I informed Kevin that based on the information he had provided me it appeared to be criminal with how he disciplined
Taylor. I advised Kevin of his Constitutional Rights and Waiver, which he said he understood. Kevin said he didn't want
to talk with me about anything further. I asked him to wait in the interview room while I went to speak with my supervisor.
After speaking with my supervisor I contacted Lisa by telephone and explained why I was calling. Lisa said she had just
left Children's Hospital with Taylor. She further said that she took Taylor to her pediatrician today because of the injuries
she had received from Kevin. Lisa said the pediatrician referred them to Children's Hospital in SeatUe. Once she arrived
at Children's Hospital they evaluated Taylor and brought in a Social Worker who spoke with them. The Social Worker
said a CPS worker would be contacting them for further information. I asked Lisa if she would be willing to come to the
Bothell Police Department with Taylor so I could obtain a statement and she agreed to.
I went back out and re-contacted Kevin at which time I told him he was under arrest for assault I properly placed
handcuffs on Kevin and searched him incident to arrest I escorted Kevin down to the booking area and then removed
his handcuffs from him. I photographed Kevin and he requested to speak with a public defender. I contacted James
Feldman and Kevin spoke to him over the phone. At the completion of the phone conversation I spoke with James again
at which time he said Kevin wouldn't be answering any further questions. I then placed Kevin in a holding cell.
A short time later I was informed that Lisa and T ayfor had arrived at the police department Officer Smith took both of
them into the female's locker room and photographed Taylor's injuries. She also obtained a signed medical release form
from Lisa and Taylor. Please refer to Officer Smith's report for further details.
At the completion of the photographs I took Lisa and Taylor into the office so I could interview them. I handed Lisa a
statement form and asked her if she would provide a written statement regarding her knowledge of the incident, which
she did. In Lisa's statement she talks about how she received a phone call from Kevin in the early hours of Wednesday
January 20, 2010. Lisa said Kevin informed her he was bringing Taylor to her house and that Taylor could no longer live
Page: 2 of 5
Print Datemme: 011291201016:08 Bothell Police Department
Login ID: merrittj ORI Number: WA0170300
Case Number: 2010-00001680
with him.
Lisa said when Kevin arrived Taylor was crying and went inside the house. She said she stayed outside with her
husband to speak with Kevin. She said Kevin explained the phone issues and the information he had gotten about
Taylor's boyfriend. Lisa said Kevin told her he brought Taylor down to his room to speak with her. She said Kevin told
her he was irri1ated because all Taylor does is sleep and doesn't do work around the house but instead stays up late
hours and talks on the phone. Lisa said Kevin told her there was a discussion abou1 another boy and he wanted Taylor
to get Jordan on the phone but she refused. Kevin told Lisa the situation escalated at which time he pushed Taylor and
she fell into a table in the bedroom. After Taylor got up Lisa said according to Kevin she began punching him and saying
she hated him. Kevin told Lisa he threw Taylor on the bed and used his belt to hit her and Kevin said "she took the
whooping like a man". According to Lisa they was a struggle between Kevin and Taylor over the cell phone and then
Kevin ended up breaking it in three pieces. Lisa also talks about how Kevin told her he slapped Taylor in the face
because she referenced some things about his personal life. Please refer to Lisa's statement for further details.
I asked Taylor if she would be willing to provide me with a written statement and she agreed. I told Taylor I would write
the statement for her if she told me what exactly happened. Taylor said on January 19th at about 2330 hours her dad
Kevin asked her to come down to his bedroom. Taylor said once in the bedroom Kevin started to speak with her about
being on the phone late at night. Taylor said he then started asking her about having eating issues, which she denied.
She said Kevin then became really upset abou1 her boyfriend Jordan who lives in Kentucky. He was not happy because
he thinks she spends to much time on the phone with Jordan. Taylor said Kevin wanted her to call Jordan so he could
speak with him but she refused. She said Kevin told her he was going to take the phone away from her so she left it and
began to walk out of the room. Taylor said Kevin then started to push her back into the bedroom until she fell onto a
table. She said when she got up off the ground she began to punch Kevin with a closed fist about four to five times in the
left chest area. She said Kevin then pushed her onto the bed and held her legs down. Taylor said Kevin then removed
his belt from his pants and made it into a loop. Taylor said he swung the belt at her striking her in the left part of her
stomach. She said Kevin then hit her about eight more times in the area of her left leg and while doing so he said he
would teach her to "fuckin hate me". She said at the completion of being hit by the belt Kevin hit her with an open hand to
the face.
Taylor said when Kevin stopped hitting her she sat up on the edge of the bed and he tried talking with her. Taylor said
she wouldn't talked to him about anything and then he told her she would never be allowed to use her phone at his house
again. Taylor said she picked up her cell phone and tried to walk out of the bedroom but she said Kevin pushed her back
onto the bed. She said they began to struggle over her cell phone until he was able to get it out of her hands. Once he
got the phone she said he smashed on the wall breaking it. Taylor said she became very upset and started to scream at
Kevin before leaving the room. She said she went up to her room and started to get dressed. She said he followed her
to her room and then woke up her brothers and sisters. Taylor said Kevin told her he was taking her to her mother's
house. Taylor said she finished grabbing some personal belongings and then got into the car. She said he drover her to
her mom's house at which time she went inside while he stayed outside and talk to her mom Lisa.
Taylor said she went to bed that night and woke up later in the morning to go to school. She said when she woke up she
felt pain in the areas Kevin had hit her. She said she also noticed redness and welts down her left leg from where she
was hit with the bell Taylor also said she had a scratch on her left shoulder and right shin but wasn't sure how she got
them. She said she went to school for the day and when she returned home she showed Lisa her injuries. Lisa decided
to make an appointment to see her doctor. On Thursday January 21, 2010 she took Taylor to see Dr. Sahs and was
referred to Children's Hospital in Seattle. Taylor said they went to Children's Emergency and she was seen by staff there.
She said the doctors looked at her injuries and photographed them. She also said she spoke to a Social Worker who
said this incident would be referred to Child Protective Services. Please refer to Taylor's statement for further details.
I asked Taylor if her father had ever done anything like this before and she said no. She said she was scared and
shocked that he was doing it to her when he did. I informed Taylor and Lisa that Kevin would be booked into jail for
assault and would go to court tomorrow. I provided them with my business card and case number at which time they left.
I mailed Taylor a domestic violence card via the postal service.
I completed a domestic violence supplemental form and Snohomish County Superform. I requested the Snohomish
Page: 3 of 5
Case Report
Summary
On 01121/10 at approximately 2100 hours Sgt Strong asked me to assist Ofc. Kerzman with an assault case.
Ofc. Kerzman informed me that Kevin R. Brown, 06/03/66, had come to the department seeking advice on how to deal
with his sixteen year-old daughter, Taylor C. Brown, 09/05/93. Brown told Ofc. Kerzman that on 01/19/10 he and Taylor
had gotten into an argument that led to a physical.altercation. Brown admitted to striking Taylor which caused her to fall
into a table and onto the floor. Ofc. Kerzman said that Taylor and her mother, Lisa A Ugalde-Soros, 09/01/68, were on
their way to the police department for Taylor to give a written statement Ofc. Kerzman asked if I would assist him by
taking photographs and documenting Taylo(s injuries.
When they arrived, I contacted Taylor and Ugalde-Soros and escorted them into the women's locker room. Taylor
showed me the bruises and scrapes that she received during the incident with Brown.
Taylor first showed me the bump on the side of her face. This bump was located directly above her right cheek bone
approximately one inch to the left of her right eye and was approximately one inch in diameter. I asked Taylor how she
got this bump and she said, "I got this bump when my dad hit me". I asked Taylor to tell me how Brown had hit her and
Taylor said, "He hit me with his hand. It wasn't a closed fist, more open. His fingers were curled". I asked Taylor what
part of Brown's hand had made contact with her face and Taylor said, "It was the knuckles of his curled fingers".
Taylor then pointed to the bruise and scratch on her left shoulder. This bruise was approximately two inches from the top
of Taylo(s shoulder and two inches from the edge of her shoulder. The scratch was located in the center of the bruise, it
was approximately one and one-half inches long, and the skin was broken. I asked Taylor if she remembered how she
got this abrasion and Taylor said, "I don't remember how I got it. All I know is that I was 'scratch-free' before and now I
have a bruise and a scratch".
Taylor then raised her !-shirt to show me her stomach. Ugalde-Soros pointed to the immediate left side of Taylo(s belly
button where there was a round bump approximately three inches in diameter. I asked Taylor how she got this bump and
she said, "From the belf'. I asked Taylor how Brown had held the belt and she said, "He held the belt in his right hand". I
asked Taylor if it was the end, middle, or buckle of the belt that had come in contact with her skin and Taylor said, "It was
the middle of the belt because he had folded the belt in half. You know, looped it together. He folded it in half and held
onto the end and the buckle parf'.
The next area Taylor pointed to was on her lower back. There was a bump located approximately one inch left of Taylo(s
spine and approximately two inches up from her waist The bump was approximately three inches in diameter. I asked
Taylor if she knew how she acquired this bump and Taylor said, "I believe it was when I fell onto the table and then fell on
the floor. I think it was when I hit the table".
I then asked Taylor about the bruises in two different areas of Taylo(s upper left thigh. The first bruise was approximately
three inches below her hip bone and measured approximately two inches by three inches. There was also a red mark
just below this bruise that was approximately two inches in diameter. The second area of bruises began approximately
five inches below her hip bone and continued down her thigh, stopping approximately four inches up from her knee.
There were five separate bruises in this area and they ranged in size from half an inch in diameter to one and one-half
inches in diameter. I asked Taylor how she got these bruises and she said, "From the belf'.
Paga: 4 of 5
Case Report
Summary
Taylor pointed to a bruise on her left ankle. This bruise was approximately two inches in diameter and approximately one
inch above her ankle bone. I asked Taylor how she thought that she got this bruise and she said, "I think I got this one
when my dad was pulling me back into his bedroom and I was kicking my feet and I think I kicked the door".
Taylor then showed me her right leg and pointed to her shin. Approximately five inches up from her ankle was a scratch
that was approximately two inches long. I asked Taylor how she got this scratch and she said, "I think I got this one when
I was getting up after I fell onto the table".
I asked Taylor if she was in any pain and she said, "I'm sore from the bruises and my chest is kind of sore where my dad
pushed me". I asked Taylor If there were any injuries to her private areas or to her head that might be hard to see
because of her hair and Taylor said "No".
I took photographs of each of Taylor's injuries and later transferred the photographs to two CD-Rs. I booked one into
evidence and submitted the other with this case report.
I then escorted Taylor and Ugalde-Soros to the interview room in the front lobby and was present while they were
interviewed by Ofc. Kerzman.
This concluded my involvement in this incident.
On 01-25-10 at about 1830 hours I made contact with David Brown at the police department regarding him witnessing the
assault on Taylor Brown. I asked David if lie would be willing to give a written statement pertaining to what he witnessed
and he agreed.
David said he saw Taylor throw her phone on their dad's bed (Kevin). He said Taylor then tried to leave the room but
Kevin closed the bedroom door at which lime it struck Taylor in the chest David said Kevin then grabbed Taylor by the
arms and threw her into a table causing it to fall over. He said Taylor got up and started yelling at Kevin and began to
punch him in the chest David said Kevin told him to leave the bedroom, which he did and he said Kevin shut the
bedroom door behind him. David said he stood in the hall and listened to what was occurring. He said he heard both of
them yelling at one another and then heard someone getting spanked with a belt David said he heard more yelling
between the two of them and then said Taylor tried to leave the bedroom again. He said Kevin closed the door again,
which hit Taylor again. Please refer to David's statement for further details.
David signed the statement under penalty of perjury and this ended my contact with him.
Routing:
Page: 5 of 5
01-22-10/1400 HOURS
CPS /ASSAULT 4 DV #10-1680
23112 19'" Ave SE
DET.BUENDIA #0099
SUPP-2
ASSIGNMENT:
On 01-22-10 at about 1130 hours, I was assigned to follow up on a CPS referral that was sent to records
via facsimile.
On 01-21-10at1406 hours, (V) Taylor BROWN reported abuse by herfather (S) Kevin BROWN. (V)
Taylor was seen by doctors at Children's Hospital.
RELATED REPORT:
On 01-21-10 at about 1919 hours, (S) Kevin BROWN came into BPD to report a juvenile incident on her
daughter (V) Taylor BROWN. (S) Kevin was interviewed by Ofc. KERZMAN. He was later taken into
custody by Ofc. KERZMAN for Assault 4/DV on (V) Taylor.
At about 1130 hours, I made contact with CPS case worker Sandra LOPEZ and informed her that I would
send a copy of BPD reports via facsimile.
DISPOSITION:
CASE NUMBER
Time:
Date:
l·.l.(/!-/0
Place:
/]o7(.f.€t {,.
STATEMENT OF
Name: bftv#) /), 13 IZow QJ
0.0.B. Employed:
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I cef1ily (or declare) under penalty of perjury under lhe laws of lhe State of Washington lhal lhe loregoing is true and correcl
I hereby agree lo appear in Coo and leslify to the (acls contained in this slalemenl should such leslimony be necessal} tor
prosecution.
-~
8011-IELL
. ) POLICE DEPARTMENT \
I
CASE NUMBER
ff5~tbB~
Time:
~lo/&.
Date:
oi-- J.1- 1 0
Place:
fl,. rtJ.eu~ f'.l:r.C.& l)Ef'T·
STATEMENT OF
Name: TA~ldl c. 1fk111J Address:
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I certify (or declare) under penally or perjury under lhe laws or the Slate of Washinglon lhal lhe foregoing is true and correct
I hereby agree lo ap r in Court and leslify lo Ifie facts conlained in !his slatement should such lesliriiony be necessary lor
prosecution.
·'
POLICE DEPARTMENT
Statementof . //J '/to /l ~~t<l~ (continued)
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· 1cel1ify (or declare) under penally or !Jerjury under the laws of the State of Washington .that lhe foregoing is true and correct
I hereby agree to appear in Co rt and testify to the facts contained in this statement should such testimony be necessary fo1
prosecution.
Witnessed:_.-A,J':..L..--ft'A---~~-Q-C)_·_ _ _ _ _ _ Sign~:~ ~AA(')
Page-~- of J~ Pages
.... :i
: .,. __ /
BOTHELL
POLICE DEPARTMENT
Statement of '//l'/ltlt'l
.412&tvA.i . (continued)
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I certify (or declare) under penalty of perjury under the laws of the Slate of Washington that the foregoing is
. true and correct.
>hereby agree to appear i Court and testify to the facts contained in this statement should such testimony
be necessary for pros ulion.
BOTHELL
. DUCE DEPARTMENT '
,. .
CASE NUMBER.
/o- iu
lime:
Date:
/-· ,,z & - /0
Place;
/]oTfl4t t- flot.-.r:cc Uf'/7.
STATEMENT OF
0.0.B. _l_I-_0_:9_--"-9_c;;-
___ Employed:
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I certify (or declare} under penalty of perjury under lhe laws of lhe Stale ol Washington !hat the foregoing is true and correct
I hereby agree lo appear in Cou and lestify lo !he facls conlained in this slatement should such lestimooy be necessary for
prosecution.
Page_t_ol_ /-Pages
, BOTHtLL
: _1 POLICE DEPARTMENT
CASE NUMBER
Time:
Date: 0
vi -i?I- /
Place:
4or#&lv /lo~c:£ DcPI.
STATEMENT OF
Name:
l 1sci L~alde ftxos Address: L\-OC'.?'?J rl'3n:i PIC!Ce; SV'J
L-~rw1 woa::::\ , wA. C\<OO::>:i\
91 \ 101¢ Employed: IM\?. 5ero1\'XJ,YS Tel: '20(? :2\0 3'QB \ ·
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. ~
l certify (or declare) under penalty of perjury under lhe laws of the Slate of Washington thal the foregoing is true and co11ecl."
I hereby agree to appear · ourt and testify to the facts contained in this statement should such testimony be necessary for
prosecution.
...
BOlltELb: ..
POLICE DEPARTMENT
~;;~'.b'=t!:~\!~~r;:;a!~m!1~J~~~~anm;¥~
tt11nqs XXX"-\O..lotn0J -to bis yer9Jm\ li\<=1 tei-s\app::c\ \r)fKQfxnss, -rye.
I-
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1
1certify (or declare) under penalty of perjury under the laws of the Stale ol Washington. that the foregoing is true and
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5 SONYA r\Rf\Sr(I
6 I Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll COUNTY CLERK
CL 14069856 SNOHOMISH CO. \'l,~,SH
7
8
9
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11
12 Superior Court of Washington
13 County of
14
In re:
15
16 This declaration is made by:
17
18 Name: Lisa Ann Ugalde Soros
19 Age: 41
20 Relationship to the parties in this action: Petitioner
21
22 I Declare:
23 LISA ANN UGALDE SOROS, Petitioner herein, declares as follows in response to the declaration of the
24 Respondent:
25 I have read Mr. Brown's response. I am saddened that he has chosen this path of attacks, lies and half-
26 truths to paint me as less of a mother and caregiver than I am to our children. Through the attached
27 documents and declarations you will learn that Mr. Brown has lied in his statement in an attempt to
28 persuade the court from entering a Permanent Restraining Order. This fact coupled with Mr. Brown's
29 DV-4 conviction on March 2, 20 I 0 make it very clear that he should no longer have custody or unfettered
30 access to our four children. ( See Exhibit A: Post Conviction No Contact Order)
children's current teacher's. I am a member of the PTA at Sheltonview Elementary School where our two
2 youngest girls attend and I have volunteered in all of the children's classrooms ever since they began
3 school and still have friendships with teachers from years past.
4
5 Last year when our son David was having great difficulties in school I went to school with him 3 days a
6 week for 3 weeks to each of his classes. I worked diligently with David, his teacher's, and school
7 Administration (See Declaration of Dr. Derek Tucci). After each and every conference or meeting I
8 would call Mr. Brown and pass along the information to him so that we could parent from the same page.
9 I have been ·very involved in the. sports lives of my children, coaching Taylor, Spero and Anthony (my
10 step-sons) for 3 seasons in volleyball and cheering for our children on the sidelines in basketball and
11 soccer. (See Declarations - Paul Anthony: Basketball Coach) I have also been an active parent at the
12 Alderwood Boys and Girls Club. (See Declaration - Paul Keen: Athletic Director ABGC)
13
14 Mr. Brown is concerned in his response about absences from school. After the physical abuse Taylor
15 received from Mr. Brown on January 20,20 IO, Taylor and her younger sisters began having nightmares
16 each and every night. They would sleep for a few hours after being comforted and then wake again from
17 another nightmare. By morning they were physically and emotionally exhausted. I chose to let them sleep
18 a couple more hours and then go to school more refreshed. I spoke with the Principal and their teachers
19 and informed them of the circumstances. We came up with a plan of action so they would not get behind
20 in their work.
21 In addition to the school front I made sure Sarah began seeing a counselor to help her process the feelings
22 that she has about this entire situation. Taylor and Sarah are still under a counselor's care.
23 ( See Exhibit F - Letter from Counselor)
24
25 Referring to the letter Mr. Brown mentions in his statement, he is confused as to what the letter is talking
26 about in reference to our son David's course failure. David failed several classes in his 7"' grade year,
27 which ended June 2009. The letter was to notify parents that one of the courses he failed is a graduation
28 requirement for High School and at some point before graduation in 2014 he will need to make that
29 course up either at summer school or online school. I have already enrolled him in the online course,
30 which will be completed this summer. Currently his grades are all C's and above and he has not failed
31 one class during his 8"' grade year.
17
18 (Attach Additional Pages if Necessary and Number Them.)
19
20 I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
21 correct.
22
23 [City] WA.. [State] on Atzc1l '2..1, '2.o\0 [Date].
24
25
26 1,l· aa Cl.nn l.J~a.RdL8tuo~
27 Signatu~e of Declarant Print or Type Name
28
29 Do not attach financial records, personal health care records or confidential
30 reports to this declaration. Such records should be served on the other party and
31 filed with the court using one of these cover sheets:
32 1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
33 2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
34 3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
35 If filed separately using a cover sheet, the records will be sealed to protect your
36 privacy (although they will be available to all parties in the case, their attorneys,
37 court personnel and certain state agencies and boards.) See GR 22(C)(2).
I Illlllll llllll Ill lllll lllll lllll lllll lllll lllll lllll llll llll IOf1PR27 PH 3=20
CL 14069857 SONYA KR!\Sl\I
COUNTY CLERK
SNOHOMISH CO. Vlil.SH
Name:
Age:
Relationship to the parties in this action: _Friend_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
I Declare:
I have known Lisa Soros for just over 4 years. The capacity of our relationship is through youth sports in
which I would say I have seen Lisa and her kids 35-45 times a year. Lisa is always outgoing and
pleasant. She is a joy to be around each and every time I see her. Lisa Soros is always the one to bring
her kids to and from the club where I work. She helps them in practice. makes sure they are on time and
does a great job of showing them their role in the community.
~-.
Signature afl)ecfarant
~ul Le.q
Print or Type Name
Age: ~ 3 r{ 1J..
Relationship to the parties in this action: CCM C e,,y >'U' d yOUJt.,. &.s l::e,f fu.1 I
. {,oCto4
I Declare:
We have been involved with coaching youth basketball for several years. For the last four years David
Brown has been on our team. David is a great young man with a huge heart. We have witnessed David's
mother Lisa at just about every game encouraging and cheering on David and the rest of the team. Lisa
or her husband Phil have consistently provided transportation for David to and from practices or games.
if there was ever a conflict with a siblings practice or game time they would always communicate in
advance to make other arrangements for David.
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Age:
Relationship to the parties in this action: Vice Principal - Canyon Park Jr. High
I Declare:
I am writing this declaration for Lisa Ugalde Soros. As Assistant Principal at Canyon Park
Junior High School, I have had the opportunity to interact with Lisa during the past four
years. Two of her children, Taylor and David Brown, have attended Canyon Parle Junior
High during this time.
Other than passing pleasantries, I didn't have many interactions with Lisa regarding her
daughter, Taylor Brown, during her time at Canyon Park. In the one instance in three years
that Taylor received school discipline, Lisa was there to work with Taylor and myself to
learn from the mistake and get back on track. Taylor now attends Bothell High School and
has had no further incidents.
Lisa's son, David Brown, attends Canyon Park as an 8th grader. David had a tough
uansition to junior high and started out 7th grade receiving multiple disciplines. During
that time. Lisa has worked with the school to develop strategies to help her son move in the
right direction. She has continued consistent communication when she stops by to pick up
Apr 27 10 07:45a
p.2
her son or when l sec her supporting her son at sporting events. We hope that this
continued collaboration helps David grow as a young man.
Lisa has had many opporrunities to interact with teachers, counselors, and administration
during my time at Canyon Park. In all interactions with the school, Lisa has been cordial
and pleasant to work with, while looking out for the well being of her kids. She is the type
of parent that we like to work wilh in education.
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
______Gk f? ~k Tw;<..l
al( 61 N P<l-
1 family. I have taught the children the moral responsibility to spend time with their elders. 1 have always
3
5 paid for medical insurance for them. When the children are sick, 1 take off from work and take them to
7
9 the doctor and care for them at home until they are well again. I do their laundry and take care of every
1I
13 possible need they may have.
15
17 Renee, who is nine, and I sometimes spend time at Barnes and Nobles reading and looking for
19
21 stimulating reading materials. She likes books about animals, foreign countries and loves cooking the
23
25 meals with me every day. The two of us watch "l love Lucy" all the time.
27
29 Sarah, who is twelve, and I entertain conversations, in which she discloses her thoughts and
31
33 dreams. She likes to express her point of view, especially when she sits in the front seat of the car. She is
35
37 a helper and tries to assist all of us with the daily activities. She is a natural performer, very theatrical
39
41 oriented. 1 am her audience and get to see her gymnastic routines first hand.
43
45 David, fourteen years old, and I share jokes all the time and discuss his academic future and
47
49 positive life expectations. 1 advice him to be a responsible young man that respects himself and others.
51
53 We have quality football time, and 1 attended all of his soccer and basketball matches.
55
57 Taylor, the oldest, enjoys scary movies and although I am not a fan, I try to meet her half the way
59
61 with a few choices 1 could watch. She is an excellent volleyball player and coach, and she is also a natural
63
65 performer. 1 have attended all the plays she has been in.
67
69 Up until recently, their mother Lisa Soros has not been very interested in the children and their
71
73 lives. She has consistently avoided paying child support until the court ordered it. However, she begged
75
77 me to get back to court to decrease the pay from $900 to $500. I did it to help her and the court ordered
79
I
3
S allows Taylor to indulge herself in over- the-counter medications. Overall, she looks at her relationship
7
9 with Taylor as one of mother and friend instead of mother and daughter. She is not able to engage in the
11
13 adequate parental relationship that will allow our daughter and the other three children to grow up to be
IS
17 responsible citizens.
19
21 I was notified by the school that after the incident took place· and the children were staying with
23
2S Lisa that the children had numerous unexcused absences. The school has also notified me of excessive
27
29 unexcused tardies since Lisa has been driving them to school. Academic wise, I received school
31
33 documents stating that my son David has failed two classes during the third term, which will affect his
3S
37 graduation and class status. The school is now recommending that he enroll in Summer school. I t is my
39
41 belief looking at her historical court ordered payments and her lack of interest for the children that she
43
4S might be inclined to show care for them due to expecting to collect the financial gains associated with
47
49 state benefits and/or receive child support from me. I do not believe the children are safe and taken care
SI
S3 of with Lisa.
SS
S7 The younger three children are much better off at home with me than with Lisa. I do not have
S9
61 any of the conflict issues with the younger children, and they are primarily bonded to me, not Lisa.
63
6S In my home there is much love and appropriate boundaries. My children earn their rewards and I do not
67
69 compromise high expectations. Since they were born I immediately bonded with them by taking
71
73 maternity/ family leave. I have been in their lives every step of the way and nurtured them from babies to
7S
77 the great kids that they are now. I take them to church and enjoy much familial ties. Sometimes I am a bit
79
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7
IN THE SUPERIOR COURT OF WASHINGTON
IN ANO FOR SNOHOMISH COUNTY
19
Name Age
2ll Taylor Cheyenne Brown I0
David Anthony Brown 8
21 Sarah Michelle Brown 6
Renee Alexander Brown 3
22
6 These provisions set forth where the children shall reside each day of the year and what contact
7
the children shall have with each parent.
Prior to enrollment in school in September 2004, Renee will reside with the Father.
except for the following days and times when Renee will reside or be with the Mother.
Every Wednesday from 8:00 a.m. to Thursday evening at 7:30 p.m. Additionally, the
Mother will have the children every other week from Wednesday from 8:00am until
Sunday evening at 7:30 p.m ..
SCHOOL SCHEDULE.
School schedule is already in effect for Taylor, David and Sarah. The children shall
reside with the Father, except for the following days and times when the children will
reside or be with the Mother:
Every Wednesday from 8:00 a.m. to Thursday evening at 7:30 p.m. Additionally. the
Mother will have the children every other week commencing Wednesday from 8:QOam
until Sunday evening at 7:30 p.m ..
Unless otherwise agreed upon. the children shall reside with the Father during winter
vacations, except for the following days and times when the children will reside or be
with the Mother:
Winter Vacation schedule will remain the same as School Schedule excluding holidays
which are addressed in paragraph 3.7.
2 Unless 01herwise agreed upon. the children shall reside with 1he Fa1her during winter
vacations. except for the following days and times when the children will reside or be
J
with the Mother:
4
Spring Vacation schedule will remain the same as School Schedule excluding holidays,
5 which are addressed in paragraph 3.7.
x Upon completion of the school year, lhe children will reside with the Father, except for
the days and times when 1he children will reside or be with the Molher:
'J
Summer Vacation schedule will remain the same as School Schedule excluding holidays,
IO
which are addressed in paragraph 3.7.
II
3.6 VACATION WITH PARENTS.
12
A parent's request for additional time during the summer/year shall not be unreasonably
IJ denied by the other parent. Each parent is to provide the other parent with a travel
itinerary and whenever reasonably possible, telephone numbers where the children can be
14
reached.
15
Each parent shall be entitled a minimum of two weeks ( 17 days) uninterrupted vacation
I(, time with the children. Vacation time will be as follows:
20
3.7 SCHEDULE FOR HOLIDAYS.
21
The residential schedule for the children for the holidays listed below is as follows:
22
5
For purposes of this Parenting Plan, a holiday shall begin and end as follows:
6
• New Year's Eve/Day shall be form Noon on New Year's Eve until Noon on
7 1
January 2"' .
K • Memorial Day and Labor Day shall be from Monday 8:00am until Monday
S:OOpm.
')
• July 4'" will correspond with the vacation schedule above (Mother in odd-
numbered years and Father in even-numbered years).
111
• Thanksgiving shall be from Wednesday al 7:30 pm until Friday morning at the
II start of the regular weekend schedule.
• Christmas Eve shall be from noon Christmas Eve until noon Christmas Day.
12 • Christmas Day shall be from noon Christmas Day until noon December 26"'.
1.1
15 The residential schedule for the children for 1he following special occasions shall be as
follows:
11.
With Mother With Father
I7
Mother's Day Every
IX Father's Day Every
19 Special Occasions shall be from 9:00am until 7:00pm. The children shall spend their
bi11hdays with whichever parent is scheduled to have the children under the "normal"
20 residential schedule.
21
3.9 PRIORITIES UNDER THE RESIDENTIAL SCHEDULE.
22
Does not apply.
2J
24
25
I. Neither parent shall provide administer any over the counter medication to the
children without notifying the other parent verbally by voice mail or speaking directly to
5 the other parent.
2. Neither parent shall be intoxicated during residential time with the children.
6 3. Mother shall not drive the children while under the influence of prescribed narcotic
7
medication.
Ill The receiving parent shall provide necessary transponation. Either parent may arrange
transponation be provided by another family member or suitable adult known to the
II
children.
12
14 The children named in this Parenting Plan are scheduled to reside the majority of the time
with the Father. This parent is designated the custodian of the children solely for
1.5
purposes of all other state and federal statutes which require a designation or
I(, determination of custody. This designation shall not affect either parent's rights and
responsibilities under this Parenting Plan.
17
3.13 OTHER
19
20 3.13.1 Telephone Access. When a child of the panies isn't residing with a given parent
that parenI shall be permined unimpeded and unmonitored telephone access with
21 the child of not less than two calls per week at reasonable times and for
reasonable durations.
22
3.13.2 Residential Schedule. Any residential periods which are made by election of one
23
of the panies shall be reasonable and proposed in good faith. In the event a parent
24 elects a residential schedule which the other parent asserts is unreasonable. the
disputed schedule shall be subject to the dispute resolution process provided in
25 this Parenting Plan.
. "I
3.13.3 Activities. Each parent shall have the right and responsibility to ensure that the
children attend school and other scheduled activities while in that parent's care.
2 Activities shall not be scheduled to unreasonably interfere with the other parent's
residential time with the children.
3
3. 13 .4 Change of Address. Each parent shall provide the other with the address and
phone number of their residence and update such information promptly whenever
5 it changes.
6 3.13.5 Affections. Each parelll agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the children and the
7
other parent, and !Cl promote the emotions of affection, love and respect between
the children and the other parent. Each parent agrees to refrain from words or
conduct, and tl1rther agrees to discourage other persons from uttering words or
engaging in conduct, which would have a tendency to estrange the children from
the other parent, to damage the opinion of the children as to the other parent, or
Ill which would impair the natural development of the children's love and respect for
11
the other parent.
12 3.13.6 Enrichment Activities. Each parent shall be responsible for keeping themselves
advised of athletic and social events in which the children participate. Both
IJ parents may pa11icipate in school activities for the children regardless of the
residential schedule.
14
15
3.13. 7 Children's Welfare. Each 11arent shall have an independent right to receive any
signiticant information regarding the welfari:: of the children, including physical
16 and menial health, performance in school, extracurricular activities, etc.
17 Both parents' shall be listed at school, for sports activities, summer camps, etc as
the primary emergency contacts for the benefit of the children. Both parents shall
IX
be indicated at the children's school for emergency purposes as well as
19
information purposes.
Children wilt be taken 11.1 alt medical appointments by either rhe Father or the
Mother unless and emergency situation arises. If the residential parent is unable
21 10 accompany the child, the non-residential parent will be given the first chance to
take them. The non-residential parent will notify of any appointments made for
the children.
23
3. 13.8 Residential Absence. Each parent shall inform the other when that parent plans to
24 be away from his or her residence with the children for more than two nights.
The information to be provided shall include duration of the period, the
25 di::stinations and destination telephone numbers.
6 3.13.10 Primarv Residence. Neither parent shall encourage the children to change their
primary residence or encourage 1he children to believe it is their choice 10 do so.
7
It is a choice that will be made by the parents or, if they cannol agree, the
x courts.
9 3. 13. I I Derogatorv Comments. Neither parent shall make derogatory commenls about
the other parenl or allow anyone else to do the same in the children's presence.
10 Neither parent shall allow or encourage 1he children to make derogatory
II
comments about the other parent.
12
3.14 SUMMARY OF Ch. 21 laws 2000 §§5-10, REGARDING RELOCATION OF A
IJ CHILD
I
I·
14
This is a summary only. For the full text, please see Ch. 21 Laws 2000.
'
15
lf1he person wilh whom the child resides a majorily of1he time plans to move, that
16 person shall give notice to every person entitled to court ordered time wilh the child.
17 If the move is oulside lhe child's school dis1rict, lhe relocating person must give
notice by personal service or by mail requiring a relurn receipt. This notice must be
IX
al least 60 days before the inlended move. lflhe relocating person could not have
19 known aboul lhe move in time to give 60 days' notice, lhat person must give notice
within 5 clays atler learning of1he move. The notice musl contain the information
20 required in Ch. 21 Laws 2000 § 6. See also form DR 07.0500 (Notice of intended
Relocation of A Child.)
21
If the move is wi1hin the same school dis1rict, the relocating person must provide
22
actual notice by any reasonable means. A person entitled to time with the child may
23 not object to 1he move but may ask for modification under RCW 26.09.260.
24 Notice may be delayed for 12 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to
25 health and safoty.
L
.·.· .:J
If informal ion is prolected under a court order or 1he address confidentiality program,
ii may be withheld from the notice.
2
A relocating person may ask the court to waive any notice requirements that may put
3
the health and safety of a person or a child al risk.
4
Failure to give the required notice may be grounds for sanctions. including contempt.
5
If no objection is tiled within 30 days after seivice of the notice of intended
6 relocation, the relocation will be permitted and the proposed revised residential
7
schedule may be confirmed.
x A person entitled to time with a child under a court order can file an <'bjection to the
child's relocation whether or not he or she received proper notice.
~
An objection may be tiled by using the mandatory panern form WPF DR 07.0700,
Ill (Objection to Relocation/Motion for Modification of Custody Decree/Parenting
Plan/Residential Schedule (Relocation)}. The objection must be seived on all persons
II
entitled to time wi1h the child.
12
The n:locating person shall not move the child during the time for objection unless:
D (a} the delayed notice provisions apply: or (b) a court order allows the move.
14 If the objecting person schedules a hearing for a date within 15 days of timely seivice
15 of the objection, the rdocating per~on shall not move the child before the hearing
unless there is a clear, immediate and unreasonable risk to the health or safely ofa
person or a child.
"'
17
IV. DECISION MAKING
IX
20 Either parent may make emergency decisions affecting the health or safoty of the
children. Decisions regarding the day-lo-day care and control of the children shall be
21 made by the parent having residential care at the time in question.
22
23
24
2.5
'
MAJOR DECISIONS.
Each parent should have the right to include the children in their own religious activities.
12
V. DISPUTE RESOLUTION
13
Disputes between the parties. other than child suppo11 disputes, shall be submitted to (lisl person
14
or agency):
17 The cost of this process shall be allocated between the parties as follows:
IK
50% mother 50% father.
19
The counseling, mediation or arbitra1ion process shall be commenced by notifying the other
20 party by writte11 request and/or e-mail:
(d) If the Court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys' fees and
2 financial sanctions to the other parent.
(e) The parties have the right of review from the dispute resolution process to
3
the Superior Court.
4
It is hereby ORDERED. ADJUDGED AND DECREED that the Parenting Plan set forth above
is adopted and approved as an order of this Court.
10
WARNING: Violation of residential provisions of this order with actual knowledge of its terms
11
is punishable by contempt of cou11 and may be a criminal offense under RCW 9A.40.070(2).
12 Violation of this order may subject a violator to arrest.
When mutual decision making is designated but cannot be achieved. the parties shall make a
good faith t:lfon to resolvt: the issue 1hrough the dispute resolution process.
14
15
lfa part:nt fails to comply with a provision of this plan. the other parent's obligations under the
Plan are not affected.
16
The Parenting Plan set forth above is adopted and approved as an Order of this Court.
t7
18
,W;,_. 0 4 2004
19 Date-------
211
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24 LISA BRO~\
2.5
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13:11 F~Piorra Llaner Mart 208-361-148~ T-503 P.003/003 F-368
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LAW OfFIC!!S
PPMANEN'f l'A.JlRl'ITDIG l'l.AN HANSEil ~& l'EJ.U(JlllNI ru.c
wPf' Ptt D1.0400 (04/02)
/il.CW 26.09.181: 1117; I ~4 !al THIRD ST1<EET
MAR't'llVIWI. W...-TOH oat10
Pa;c-11 ( 0 0 0 ) - • P""""""' pSll) 111"'112
OAPR30 PH 2:42
SUPERIOR COURT OF
WASHINGTON SONYJ\ l\f~.L\Sl\I
COUNTY CLER!\
FOR SNOHOMISH COUNTY ;;inunMISH co. WASH
DOCUMENTS FILED:
ORDERS ENTERED: ORDER FOR PROTECTION (FOUR MONTHS) ENTERED, TO BE FILED BY THE
FACILITATOR
PROCEEDINGS/COURT'S FINDINGS:
THE COURT FINDS BY A PREPONDERANCE OF THE EVIDENCE THAT AN ACT OF
DOMESTIC VIOLENCE HAS OCCURRED. THE PETITIONER HAS MET HER BURDEN OF PROOF AND
THE COURT GRANTS THE ORDER FOR PROTECTION. THE PETITIONER rs INFORMED THAT THE
DOMESTIC VIOLENCE ARENA rs NOT PROPER TO MODIFY THE PARENTING PLAN. THE
PROTECTION ORDER WILL ENTER FOR A LIMITED AMOUNT OF TIME ONLY AND SHALL BE
SUBJECT TO ANY MODIFICATION ACTION. THE RESPONDENT SHALL HAVE VISITATION EVERY
SUNDAY FROM NOON TO 6 : 0 0 P. M. THE CHILDREN SHALL HAVE UNRESTRICTED PHONE
CONTACT WITH THE RESPONDENT, UNINHIBITED BY THE PETITIONER, SUCH AS
THE CALLS BE ON SPEAKERPHONE.
REQm~
~
1 MINUTE ENTRY
•
'
' ·'
This order is issued in accordance with the Full Faith and Credit provisions of VA WA: 18 U.S.C. § 2265.
Re~p_£l)dent's relationship to the petitioner is:
~ spouse or former spouse D current or former dating relationship D in-law D parent or child
D parent of a common child D stepparent or stepchild D blood relation other than parent or child
D current or former cohabitant as intimate partner, D current or former cohabitant as roommate
including current or former registered domestic partner
Respondent committed domestic violence as defined in RCW 26.50.010 and represents a credible threat to the
physical safety of petitioner; the court concludes as a matter oflaw the relief below shall be granted.
Courl Order Summary:
~ Respondent is restrained from committing acts of abuse as listed in restraint provision I, on page 2.
x No-contact provisions apply as set forth on the following pages.
x Additional provisions are listed on the following pages.
The terms of this order shall be effective immediately and for one year from today's date,
unless stated otherwise here (date): ~A\A~ ~O ~( Q µ,,6J' (
Order for Protection (ORPRT) - Page 1 o 5
WPF DV-3.015 Mandatory (712009) - RCW 26.50.060
S:\FORMS\FCOURTSERVICES\Master Forms\One Year Protection Order.doc
'
.. ,,,· ..
Ordered:
Respondent is Restrained from causing physical harm, bodily injury, assault, including sexual
assault, and from molesting, harassing, threatening, or stalking BJ petitioner r9. the minors
named in the table above D these minors only:
(If the respondent's relationship to the petitioner is that of spouse or former spouse, parent ofa common
child, or former or current cohabitant as intimate partner, including current or former registered domestic
partner, then effective immediately, and continuing as long as this protection order is in effect, the
respondent may not possess a firearm or ammunition. 18 U.S.C. § 922(g)(8). A violation of this
federal fuearms law carries a maximum possible penalty of I 0 years in prison and a $250,000 fme. An
exception exists for law enforcement officers and military personnel when carrying
de artment/ overrunent-issued firearms. 18 U.S.C. 925 a I .
Respondent is Restrained from coming near and from having any contact whatsoeverAin
person or through others, by phone, mail, or any means, directly or indirectly, except for ovJ
mailing or service of process of court documents by a 3'd party or contact by Respondent's
lawyer(s) with IE petitioner ~the minors named in the table above D these minors o~ly: ti
~ ·~ c.v\,.l~, ~~(_h S.htUL V\.l)f- ~ ~ ~ 4.
If both pa 1es · e location, respondent shall leave e.tc:..e. fi>Y ~
3. Respondent is Excluded from petitioner's re c
or school of~the minors named in the table above D these minors only:
perso is
present.
D This addre ential. D Petih
G
counseling at: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
parenting classes at: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
drug/alcohol treatment at: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
other: Pt>r ~e.(A ~ti C:l) ~ D~, ~cor:el~ sl!aU Joe ~
lf-=-~__c~~__;.c_'-'-=-.:..=_i_:=--::~-=..::-=----m1>1rtfbtk--+n-Mt~I~
D I 0. Petitioner is granted judgment against respondent for$
D 11. Parties shall return to court on , at .m. for review.
Complete only if the protection ordered involves pets:
D 12. Petitioner shall have exclusive custody and control of the following pet(s) owned, possessed,
leased, kept, or held by petitioner, respondent, or a minor child residing with either the
petitioner or the respondent. (Specify name of pet and type of animal.):
D 13. Respondent is Prohibited from interfering with the protected person's efforts to remove the
pet(s) named above.
D 14. Respondent is Prohibited from knowingly coming within, or knowingly remaining within
_ _ _ _ _ _ _ (distance) of the following locations where the pet(s) are regularly found:
D petitioner's residence (You have a right to keep your residential address confidential.)
D Park
D other:
omplete only·ifthe protection ordered involves minors:. This state has exclusive continuing
urj~dictifu1;' D is th,e h!)me. state; D h~ tetnpcir_a.6, eme~gencyjll\:isdiction D that m~y.become final ..·
ju'"sdiCtion urider RCW26.27.i31(2); ;[]other:' . . . . . .••. . .. . . . . . ..,~ . .
5. Petitioner is Grantedthe temporary care, custody, and control oft.8.the minors named in the
table above D these minors only:
7. Respondent is Restrained from removing from the state ~ the m · ors named in the t
above Dthese minors only: SV~E'C.T To f!f.f'I O~D0t-1N
I C C 1lON
Petitioner may request modification of visitation if respondent fails to comply with treatme
counselin as ordered b the court.
If the person with whom the child resides a majority of the time plans to relocate the child, that
person must comply with the notice requirements of the Child Relocation Act. Persons entitled
to time with the child under a court order may object to the proposed relocation. See
RCW 26.09, RCW 26.10 or RCW 26.26 for more information.
Warnings to the Respondent: A violation of provisions 1 through 5 of this order with actual notice of its
terms is a criminal offense under chapter 26.50 RCW and will subject you to arrest. If the violation of the protection
order involves travel across a state line or the boundary of a tribal jurisdiction. or involves conduct within the special
maritime and territorial jurisdiction of the United States, which inclµdes tribal lands,you may be subject to criminal
prosecution in federal court under 18 U.S.C. §§ 2261, 226IA, or 2262.
A violation of provisions I through 5, 13, or 14 of this order is a gross misdemeanor unless one of the following
conditions apply: Any assault that is a violation of this order and that does not amount to assault in the first degree or
second degree under RCW 9A.36.0l l or 9A.36.021 is a class C felony. Any conduct in violation of this order that is
reckless and creates a substantial risk of death or serious physical injury to another person is a class C felony. Also, a
violation of this order is a class C felony if you have at least two previous convictions for violating a protection order
issued under Titles 7, 10, 26 or 74 RCW.
If you are co'nvicted of an offense of domestic violence, you will be forbidden for life from possessing a firearm or
ammunition. 18 U.S.C. § 922(g)(9); RCW 9.41.040.
You Can Be Arrested Even if the Person or Persons Who Obtained the Order Invite or
Allow You to Violate the Order's Prohibitions. You have the sole responsibility to avoid or refrain
from violating the order's provisions. Only the court can change the order upon written application.
Pursuant to 18 U.S.C. § 2265, a court in any of the 50 states, the District of Columbia, Puerto Rico, any United States
territorv, and anv tribal land within the United States shall accord full faith and credit to the order.
It is further ordered that the clerk of th'.3ourt shall forward a copy of this order on or before the ~
judicial day to NO CO Iv\ D County Sheriffs Office
Police Department Where Petitioner Lives which shall enter it in a computer-based criminal
intelligence system available in this state used by law enforcement to list outstanding warrants .
. Service
D The clerk of the court shall also forward a copy of this order on or before the next judicial day to
D County Sheriffs Office D Police
Department Where Respondent Lives which shall personally serve the respondent with a copy
of this order and shall promptly complete and return to this court proof of service.
D Petitioner shall serve this order by D mail D publication.
D Petitioner shall make private arrangements for service of this order.
~ .Plf Respondent appeared and was informed of the order by the court; further service is not required.
u
D Law enforcement shall assist petitioner in obtaining:
D Possession of petitioner's D residence D personal belongings located at: D the shared
residence D respondent's residence D other:
D Custody of the above-named minors, including taking physical custody for delivery to
petitioner.
D Possession of the vehicle designated in paragraph 7, above.
D Other:
D Other:
Presented by:
. ( =~-~~~
0commissione~ /F
21:lo:~!e r~=~ ~{ ~~
L~·40. \l~aJwfu-oy-4:r~o110 ~
Petitioner Date Respondent
~~..O;jl)i~
Date
The petitioner or petitioner's lawyer must complete a Law Enforcement Information Sheet
LEIS.
9 In re: )
Lisa Ann Ugalde Soros ) Cause No. I 0-2-00156-3
10 )
Petitioner, ) NOTICE OF APPEARANCE
11 And )
Kevin Rene Brown )
12
)
)
13
Respondent
14
15
TO: Clerk of the above-entitled Court
16 ANDTO: Sherrie Bennet, Attorney for the Respondent
17 YOU AND EACH OF YOU please take notice that Veronica Freitas, of Shapiro & Freitas, PS,
hereby appears in the above-captioned cause, requesting that all further papers and pleadings herein,
18
except original process, be served upon the undersigned attorney at the address stated below.
19
PLEASE NOTE: We do not accept service by fax unless agreed by prior arrangement.
20
DATED May 10,2010.
21
Respectfully submitted,
22
_,
?'
/\~--
24 VERONICA FREITAS, WSBA #19405
Counsel for Lisa Ann Ugalde Soros. Petitioner
25
26
27
28
\oFEB 24 PM I: 29
I Illlllll llllll Ill lllll l l l lllll lllll l l l lllll lllll llll llll SUPERIOR COURT OF
I CL 13905720 . WASHINGTON SONYA \\RASl'd
FOR SNOHOMISH COUNTY COUH!_'( ~L,.,E~~ c:~
DOCUMENTS FILED:
ORDERS ENTERED: REISSUANCE OF TEMPORARY ORDER FOR PROTECTION AND NOTICE OF HEARING
ENTERED, TO BE FILED BY THE FACILITATOR
PROCEEDINGS/COURT'S FINDINGS:
1 MINUTE ENTRY
I 0 FEB 24 PH I: 2 1
~he Temporary Order for Protection issued on ;;;? , '(-- /O /- is hereby extended
through the new court hearing date on this matter on -L'fb='-t..-:~t"".l.llt.L(date)
at 1:00 pm (time) at 3000 Rockefeller Avenue, 1" floor Dept. B C
The cler of the court shall forward a copy of is order on or ~re the next j ici day to the
D County Sheriffs Off~ 5fo, ) <:!! CQ,1\ 0
Police
Department where petitioner lives which shall enter this order many co'iTiputeF-based criminal intelligence
system available in this state used by law enforcement to list outstanding warrants.
D The clerk of the court shall also forward a copy of this order on or before the next judicial day to
D County. Sheriffs OfticeO Police
Department where respondent lives which shall personally serve the respondent with a copy of this order,
the Temporary Order, and the Petition, and shall promptly complete and return to this court proof of
~ ~ lacknowledgereceiptofacopyofthisOrder.
~=
Pctitionc1 ~"f'OlJ~..,- Date
tt·,aa liaald115'4do4-:;'J
Rep ndentpfi Date
REISS OF TEMP ORD FOR PROTECTION/NT HRG (ORRTPO)- Page I of I
WPF DV-5.010 (9/2000) • RCW 26.50.060(3)
S:\FORMSIFCOURTSERVICES\Master Forms\ReissuanceDV.doc
1
I F~L.f Q
2
3
. I l~l l
Ill/I/I Illlllllllllllllll
CL14114312
~Il I/IllI/IllIll/I~1 1 1 ZOIOFEB23 PM 2:51
SONYA f\RASKI
4 COUNTY CLERI\
2fWHOMISH CO. WASH
5
7
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
8 IN AND FOR SNOHOMISH COUNTY
9 In re:
16
PLEASE TAKE NOTICE that the undersigned attorney represents the
17
Respondent, Kevin Brown, in the above referenced case. All pleadings and papers,
18 excluding original service of process, should be served upon the undersigned attorney
20
DATED this 23rd day of February, 2010.
21
22
23 ?.}FfttoE~ ~"#33679
Attorney for Respondent
24
25
NOTICE OF APPEARANCE
Page 1of1 Goldberg Jones
1200 Westlake Ave. N
Suite 700
Seattle, WA 98109
T: 206-448-1010 F: 206-448-0736
OORIGINAL
Apr 22 10 05: 11 p Express Oil Change 770-433-0296 p.2
04/22/2010 13:04 2064400736 GCLDBERG ~ JOHE5£L PAGE l:j:l/1::1~
·-
3
5
Illlllll llll~~~l~~l~~I~~!1111111111111
7
9 Superior Court of Washington
11 County of SNOHOMISH
13
15 In re:
17 No. 10-2-00156·3
19 USA ANN UGALDE SOROS,
21 DECLARATION OF
23
25 Petitioner, KIMBERLY YONTZ
27 and
29
31 KEVIN RENE BROWN.
35
33 11------------~:::i::::.;;.:;:;;.;: Res onde11t._ _.__ _ _ _ _ _ _ _ _ _ _ _ _ _-I
37
39 This declaration is made by:
41
43 Name:
45
47 Age:
49
51
Relationship to the parties in this action: _______________
_"',$("'"'-s."'...·re_·.;;;...~
53 t DECLARE that:
55
57
59 I am writing this li:ner on behalf of my brother Kevin R. Brown. Our parents divorced when
61
63 Kevin and I where around ten and fourteen years of age. I can remember how my brother was forced to
65
67 become the head of the house hold, and take en the role of being the father. As I reflect back, Kevin foun
69
71 out that I did not pass my math coorsc that I nectlcd in order to receive my diploma from my
73
75 undergraduate degree. Instead of him showing disappcintment, he encouraged me to take a class close to
77
79 : an hour away from where he li•ed. He took me cvciy moming, even though he had been up all night wilh
his elde~ daughter (Taylor). With Kevin's guidance 1 was able to achieve my academic goals beyond mx
\~
Express Oil Change 770-433-0296
Apr2210 05:11p GOLDBERG AND JONES~L
04/2212010 13:02 206448073&
-- .
J wildest imagination. I now have my Bachelors in Criminal Justice, Musters in Education, and I'm
3
5 currently working towards my Doctorate in Educatiar..
i
9 Ever since my brother became a father. it has been a nonstop adventure. Between gymnastics,
11
IJ soccer, volley ball, and homework, Kevin is always engaged with the kids. I have seen him practice doing
15
17 hair on a doll, in order to make his girls look beautiful. Kc~in volunteers for his kids classrooms. One day
19
21 my mother went to the school to observe in the classroom, and the secretary said, "What is the key to
23
25 raising such respectful children?" my mother said, "Prayer is the key, and having a dedicated father in the
27
29 home, makes the diffe""1ce". After working in the cla.<0room for the last I() years, I have found that one
31
33 of the missing Jinks ro student academic success is tile lack of parent involvement.
35
37 Kevin models the imponance of creating an environment that believes in academic prosperity,
39
41 respect, love, and the family unit built in Christ Jesus.
43
45 From t'ie time the kids were born, Kevin has played such an important role in their lives. Mold in
47
49 them and caring for them, often reminding himself that he is raising iomeonc else's mother, wife, father,
5)
53 and husband. [find Kevin to be one of lhe best fathers I have ever known. Nat just beoause he is my
55
57 brother, but because he raised me.
59
61 l declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
63 correct
65
67
69
71
7J
75
77
79
DECLARATION (OClR)
WPP DRPSCU()l.0/00 (7/200J)
Pag• 2
IOAPR 27 PM 3: 20
SONYA ~;RASi(I
COUNTY CLERi\
SNOHOMISH CO. WASH
vs. COVERSHEET
Respondent!Defendant(s).
S:IFORMSIFCOURTSERVICES\Mastcr Fonns\Comshec1.doc
Bothell Municipal_ Court of Washington
~fo~r~K~i~n~nC~o~u~n~•tvz.-~~~~~~~~~~~~--1 No.20777BC
Domestic Violence
No-Contact Order
"'C"-IT.._,_Y-'0=-F_,,B""O~T,,_H=E~L~L,__ _ _ _ _ _ _ _ _ _ Plaintiff (Misdemeanor)
vs. D Pre-trial
~ Post conviction
,_,K..E...,Vc..:I"-N'-'R.=B=R.,.O"'W=N,___ _ _ _ _ _ _ _ _ _ Defendant X Clerk's action required.
SID:
If no SID, use DOB:
I. Based upon the certificate of probable cause and/or other documents contained in the case record, testimony,
and the statements of counsel, the court finds that the defendant has been charged with, arrested for, or convicted of a
domestic violence offense, and further finds that to prevent possible recurrence of violence, this Domestic Violence
No-Contact Order shall be entered pursuant to chapter 10.99 RCW. This order protects (Name):
,,,~, P.·,,. .. 1 Vl ~,r.f,
2. The court further finds tli'ai the defendant's relationship to a person protected by this order is: D current or
former spouse D parent of a common child D current or former cohabitant as intimate partner _P'l other family or
household member as defined in RCW 10.99.
3. D (Pretrial order) The court makes the following findings pursuant to RCW 9.41.800: D the defendant used,
displayed, or threatened to use a firearm or other dangerous weapon in a felony; D the defendant previously
committed an offense that makes him or her ineligible to possess a firearm under the provisions ofRCW 9.41.040; or
D possession of a firearm or other dangerous weapon by the defendant presents a serious and imminent threat to
public health or safety, or to the health or safety of any individual.
( It is Ordered:
D This No-Contact Order expires on:-------------,.--,---~-·
5,1' This No-Contact Order expires 2 years from today's date: ---~»~1~-~:o.~/~::;i~'-=)~/~±~----
Defendant is Prohibited from:
A. Causing or attempting to cause physical harm, bodily injury, assault, including sexual assault, and from
molesting, harassing, threatening, or stalking the protected person(s).
B. Coming near and from having any contact whatsoever, in person or through others, by phone, mail or any
means, directly or indirectly, except for mailing or service of process of court documents by a 3•• party or
contact by defendant's lawyers with the protected person(s).
C. Entering or knowingly coming within or knowingly remaining within -~!~(~)(~/(~-.J~_p_,__·_.(distance) of the
protected person(s)'s 0 residenc<}!IJ school.El workplace.El other: .,.~~·_·,~,_··~··~··~·- - - - - - - - - -
D. D (Pretrial RCW 9.41.800 findings made) Obtaining or possessing a firearm, other dangerous weapon or
concealed pistol license.
D (Conviction ofoffense listed in RCW 9.41.040(2)) Obtaining, owning, possessing or controlling a firearm.
It is Further Ordered:
D (Pretrial Order) The defendant shall immediately surrender all firearms and other dangerous weapons within
the defendant's possession or control and any concealed pistol license to:
[narnenaw enforcement agency).
Warnings to the Defendant: Violation of the provisions of this order with actual notice of its tenns is a criminal
offense under chapter 26.50 RCW and will subject a violator to arrest; any assault, drive-by shooting, or reckless
endan ennent that is a violation of this order is a felon .
Willful violation of this order is punishable under RCW 26.50.11 Q_ Violation of this order is a gross misdemeanor
unless one of the following conditions apply: Any assault that is a violation of this order and that does not amount to
assault in the first degree or second degree under RCW 9A.36 .011or9A-36_021 is a class C felony. Any conduct in
violation of this order that is reckless and creates a substantial risk of death or serious physical injury to another person
is a class C felony. Also, a violation of this order is a class C felony if the defendant has at least 2 previous convictions
for violating a protection order issued under Titles 7, 10, 26 or 74.
If the violation of the protection order involves travel across a state line or the boundary of a tribal jurisdiction, or
involves conduct within the special maritime and territorial jurisdiction of the United States, which includes tribal
lands, the defendant may be subject to criminal prosecution in federal court under 18 U.S.C. § 2261, 2261A, or 2262_
In addition to the state and federal prohibitions against possessing a firea.nn upon conviction ofa felony or a qualifying
misdemeanor, upon the court issuing a no-contact order after a hearing at which the defendant had an opportunity to
participate, the defendant, if a spouse or former spouse, a parent of a common child, or a current or former cohabitant
as intimate partner of a person protected by this order, may not possess a firearm or ammunition for as long as the no-
contact order is in effect. 18 U.S.C. § 922(g). 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/government-issued firearms. 18 U.S.C § 925(a)(l). If the defendant is convicted
of an offense of domestic violence, the defendant will be forbidden for life from possessing a firearm or ammunition.
18 U.S.C § 922(g)(9); RCW 9.41.040.
You Can Be Arrested Even if the Person or Persons Protected by This Order Invite or Allow You
to Violate the Order's Prohibitions. You have the sole responsibility to avoid or refrain from violating the
order's provisions. Only the court can change the order upon written application.
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.
It is further ordered that the clerk of the court shall forward a copy of this order on or before the next judicial day
to: Bo IAe J / J?
D County Sheriff's Office Police Department where the
above-named protected person(s) lives, which shall enter it in a computer-based criminal intelligence system available
in this state used by law enforcement to list outstanding warrants.
_ _REMOVAL OF ITEMS/STANDBY ASSISTANCE AUTHAURIZED: To remove necessary personal effects
from the defendant's residence, the defendant may request law enforcement stand-by assistance.
-see Page One for the Expiration Date of This No-Contact Order. -
--~)-->,/~;:7-::_ -----
~-""'--'-~~~~~~~~-0:~~--
Rhonda Giger,~W BA No_ 28322 Attorney for Defendant Defendant
Paul Byrne, WSBA No_ 41650 WSBANo.
Assistant City Attorney Print Name:
7 8 9 10 11 12 13
Labor Day
~
14 16 17 18 19 20
~~·
(
----'--~
- .
21
-\C 11
-i • ,/
22 23 24
..
25 26
- . --..
27
-
.
28 29 30
-·
•
MEDI 02.08·2010 020810F136368 RB 497.73 0.00 0.00 o.oo 0.00 0.00 0.00 0.00 49.77 497.73
TANF-. o:llli': , .Q.00 "· 0:00
- .'.". ." ,•OioD.". .. . ·11 .00.. ''491'.7~ . ·:1,
... ·. 01.o&.'iQ.1Q:
.. ,· ·.· 0108"10F683163
. . . . RB 49.7.73 .' O.Qq a.oil O,IJ:O· ,,_,.,,.... .· .
TANF 12·07·2009 120709F1813BO RB 497.73 . 0.00 0.00 o.oo o.oo 0.00 0.00 0.00 0.00 497.73
··1V1~1·,n~~qq~ 1fo&otF7"'381a Ra·
....
4?7.7.3.... ,, 0;00 o:oij oJW. .o.lio 0.00 ·... o,~o ·.. "•:2~.pli:~·:i'•:· 49)7 : ..
. 48i.73
·:· ,...
MEDI 10.o&-2009 100809F300411 R8 497.73 0.00 0.00 O.DO o.oo· 0.00 0.00 0.00 49.77 497.73
·NA . . -.119.iJB-@09
. .; . ·.. 090B09F814404.
.. .. Ra" 497.73 ' o:Oo· · Q.00 0.00 o;oo. o.oo· ci:li'O· .. •~.~. < 41litl " . ~7;_-7.iJ . I
NA 08~·20119 080609F411757 R8 497.73 0.00 0.00 0.00 o.oo 0.00 0.00 o_oo 49.77 497.73
. NA.·.. lif.07-2009 O'i'0709F969048 .RB· . 4!t7.73 o:oo O.Qll: . 0.0() O.DO o.oci o· Olf •
• 4 •
O·OO-
• • ·.·:,, .: • • ~; ••• , · • ·;
0.00 "497:7~
IJl
NA 06.08-2009 060809F525394 RB 497.73 0.00 0.00 0.00 0.00 0.00 0.00 o_oo 0.00 497.73
u NA" .05~"" 050609'F0681170. R8 ·497.73 o:oo 0.00 0.00. 0.00 0.00 O-ilO .. · . 00
· : ."'O' ..
·- .
.... : " 0:00 . 497.73
.....
......"' NA 04-06-2009 040609F609136 RB 497.73 0.00 o.oo 0.00 0.00 0.00 0.00 o.oo 0.00
·
497.73
w
Cl'.
.NA· . 03,05-2009 030~9F129a6i Re 497.73 11.00. 0.00". O,oO . o.• OI) o.oo· .. o.oo .. ·.·?loo- 0;00 .·.,497,13
.... ' .. ...
w NA 02.05-2009 020509F739944 RB 497.73 0.00 o.oo o.oo 0.00 0.00 0.00 0.00 0.00 497.73
::> .
w
NA'" 01'46'-2009 01Q60BF33150i' RB. .'497.73' o.oo .. 0.00 . 0".00 .. o.oo. 0.00 · .o,_oo· . ·. ii:ciir
...... O;OO..
. . ,.
... 497,l3
. ;:.· . '
'
NA 12.05-200B 120508F902906 RB 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
NA 11'1l7·2DOB 11D708F563978 · R8 497.73 O;Op ... 0.00 0.00 Q.Oji j).00 0'.00· 25.00
... o.oo .
". ·49:; 73
. . . fl· • .
NA 10'1>7·200B 10070BF133373 R4 497_73 o_oo 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
"'!A . 09~9-200f oto908Fl55301. R4 Q.00 o.oo .. 0.00 0.00 Ii.~ . 497.73 ·.~·fri3
"'"'ro NA 09-44-2008 090408F705142 RB 497_73 0.00 0.00 0.00
0.00
0.00
497.73
0.27 0.00
.. 0,1!41.
0.00 0.27 49B.00
tSl
'·NA ·oB-18~ oa'Q408S012735 G1 -497.73 · qiOO' a.oil 0.00 . o. oo· -G.27 .Q.~D .'ii,ilo -498,~0 •oo
tSl
~
NA 08.05-200& 080508F33330B RB 0.00 0.00 0.00 0.00 D.00 497.46 0.00 0.00 497.46 497.46
tSl NA 08-44-2008 080408S012735 A9 . 497.73 -o,iiO 0.00 o.oo o.oo 0.27 0:0o. 0:00 0.27 '.498.oo·-
"''"'
I
NA 06.03~008 060308F469186 RB 497.73 D.00 0.00 0.00 o.oo 0.00 0.00 0.00 0.00 497.73
"'Cl'.
I
& Page: 1
0 \0 · '1..-D::vO<.<> • 3
al al
~
IL
IL ...<i.
~~
!'<IA 05-02~008 O~~~FO&Q317·' ~·,: • 497;73. 0.00 ... ·. ·0.00 . o.oo. o.oo:· .,0.00
.. O,Oll o:QJi a.oo ,. <1&1.1~ .
~
.· r.· '
NA 04-G2·2008 040208F&52057 RB 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
" NA 03.03"2008 . .. . . . . RB '
03o3o'aF-19&779 .497,73 0.00 o.~· ·. 0.00 o.oo·• C!;QO . 0;00 0.QO:. 0.0.ti . . 497. 73
Ill NA 02.01·2008 020108F804282 RI · 497.73 0.00 0.00 0.00 o.oo 0.00 0.00 0.00 0.00 497.73
" NA 0.1.Q2-20o8 o102118F401li34
. 'RB·
. . . ... ·.• "49t:n·
. . . o~oo· ;·o:Oif . 0.00 a.op . , ·0.00. .. >·0.00 · o~oli . o;oo·· 481:73
cy Total 11 ,945.52 0.00 0.00 0.00 o.iio 995.4& 0.00 50.00 746.58 12,940.98
CJ)
g
......
~
~
g;
~
co
~
Ft]
I
"'
N
I
[
er Page:2
--
ISi
'
State of Washington
Division of Child Support
Case Payment History
8+\'\"e?\"f (_ -it10-'2• 001%-3
412612010 8:44:17 AM-3060 -
ISi
.a.
ISi
a. NCP: UGALDE, LISA ANN
.'I-
<i.
CFO: Everett
CP: BROWN, _KEVIN R IV-0 Case#: 1757166 I::?
CD Monthly Child Support: 497.73 DSH$ArJS: 0.00 Curr Support Due: 497.73
<1l
a> Monthly Medical Support: 0.00 DSHS Med Arrs: 0.00 Curr Medical Due: 0.00
"'
CD
l"l
TempArrs: . 0.00
Monthly Order Amt: 497.73
"'
If)
Annual Fee Due: 0.00
CPArrs:
CP Medical ArJS:
497.73
0.00
Disbursed:
Retained:
30,635.15
N 995.46
"' Annual Fee Paid: 25.00 Retained: Medical: 0.00
Case Receipt Payment Current Current DSHS DSHS TEMP CP CP Annual Total
Type Date Number Type Payment Medical Arrears Med Am Arrears Arreara Med Am Fee . Rec:v Payment
NA 12--03-2007 12030TFD23939 RB 497.73 O.DD 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
NA 11--02-2007 1102D7F694626 RB 491.13 ·o.oo 0.00 0.00- .o.oo o.oo 0.00 25.00 0.00 497.13
NA 1D-02-2007 100207F306424 R8 . 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
NA . 09-D4-2007 090407F91 BCH>6 RB 497.73 0.00 0.00 0.00 o.oo 0.00 D.DD 0.00 0.00 497.13
NA 08--02·2007 OB0207F544095 R8 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
NA 07~2·2007 070207F126134 R8 497.73 0.00 0.00 0.00 o.oo 0.00 0.00 0.00 o.oo 497.13
NA 06--01-2007 0601 D7F749495 RB 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 o.oo 497.73
NA 05--01-2007 050107F366120 RB 497.73 0.00 O.DD 0.00 . 0.00 0.00 0.00 0.00 0.00. 497.73
04-17-2007 041707F194277 RB 497.73 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 497.73
en INA
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Q Total 4,479.57 0.00 0.00 0.00 0.00 0.00 0.00 25.00 0.00 4,479.57
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Total Case Payments printed for IVD # 1757166 : 9
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I Date Range requested - From: 01101/2007 To: 12/31/2007
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From: "Cati Sandoval" <cati@northseattleortho.com>
Subject: Taylor Brown
Date: April 26, 2010 11 :11 :50 AM PDT
To: <lisa.soros@comcast.net>
I> 2 Attachments, 472 KB
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Cati Sandoval
North Seattle Orthodontics
cati@northseattleortho.com
206-523-1047
... , ............. . .
.All.Dares,~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
OrtftoTracSoftware ....,,_,
North Seattle Orthodontics, Ors Lyons and Gunsolus
Seattle Monday, Aoril 26, 2010 11:06 AM
Ledger Copy Taylor Brown (080037)
By Patient for Responsible Party: Assurant/Bill Pierre
Taylor Brown
3/26/2009 Assurant 100 116 SS Full Tx - Contract 1,000.00 0.0D !,ODO.OD
4/27/2009 Assurant 100 116 Ins Ck: Mar Assurant #0021496463 -500.DO -50D.OO -50D.OO 500.00
5/1/2009 Assurant 100 116 SS Full Tx - Contract Charge 200.00 200.00 -300.00 500.00
5/26/2009 Assurant 100 116 Ins Ck: Apr Assurant #0021632778 -300.00 -300.00 -600.00 200.00
8/1/2009 Assurant 100 116 SS Full Tx - Contract Charge 200.00 200.00 -400.00 200.00
10/20/2009 Assurant 100 116 Ins Ck: July Assurant #0022471708 -300.00 -300.00 -700.00 -100.00
10/20/2009 Assurant 100 116 Adjust Balance 600.00 600.00 -100.00 -100.00
11/3/2009 Assurant 100 116 Insurance to Resp Party 100.00 100.00 o.oo 0.00
• B!LtEVUE OFFICE • i100 NORTHUP WAY • BELLEY'UE, WASHINGTON !16004-1461 • (l2)) 1127~00 ·FAX ('2.$} BZl-2256
PINE lAKE OFFICE • 22717 S.E. 29TH 5T. • SAMMAM15H. WASHINGTOrt 98075 • (42S) 391-7337 • FAX {425) 3'1·3915
FACTORIA OFFICE • 412:2 ~ IID'U. S.E.• 1101 • BELlE\IVE, WASHINGTON 8500' • (425) 747-72m. ·FAX (425) 643-0635
REDMOND Off/CE· A011G1ST AVENUE N.f..1202 ·REDMOND, WASHINGTON U052 • {'2S) 885-ml · FAK (~} 815wt106
A!DMOND ROOEOFFl:E • Z2lJ.lSNE MAAKET PLACE OhPJE. 1120 ·REOMOM>, ~IHGTON 9IOS3 • (~) 97408 ·liU ('25)8'98·7409
SAMU.WISH' OFFICE· 22603 N.! IMGl.E'oVIXX> HU RD., .im> ·SAMMAMISH. WASHl~N 99074 · {'425)836-640'7 • fAX f42.5} 8lU557
TOTEM LAKE OFFICE • 13030 121ST WAY N.E.. 1100 • KIRKL,M'O, WASHINGTON taos.t • (425) 814-5170 ·FAX(£~) 823-5826
Taylor Brown. has been in treatment with me since Februmy 2, 2010. She CB!lle to my office seeking help
.dealing witl\,panic attacks,.acute.anxiety,,11ightmares, inaliiliLy to concentraie,_and loss ofinterest in
activities she used to enjoy. After scvc:ral sessions I determined that Taylor was suffering from Post
Traumatic Stress Syndrome, acute; triggered by a severe beating she endured at the hands of her
biological father. Subsequently the diagnosis has been updatt:d to Post Traumatic Stress Syndrome,
chronic, and Major Depressive Disorder has been added.
Taylor is struggling with several functional challenges as a re!!Ult of her condition. She does not sleep well
and caTJnot go back to sleep after awakening in the night If she awakens in the dark she is paralyzed with
fear. She ha.< become sleep deprived as a result and fmds it very difficult to silly awake in school. She
keeps up with school work through sheer determination, but has been robbed of the motivation she once
felt. She is extremely vigilant and sensitive to adults, especially ones that are prone to anger and
aggression which is also impacting her school work and family life. lier ability to go places on her own is
restricted as s.he suffers panic attBcks when seeing reminders of her father, like a car that is similar to his,
or going to places that she knows he vi!rits. She is ~fied to walk past his house in case he is home and
the one time she tried the terror Wt1S so great that she had to retreat to a distant place to call for help. By
far the worse consequence ofthl< experience has been the shattering of a young person's trust in the basic
safety and goodness of her world.
The prognosis for a full recovery is fair to good. She is young, resilient 8Jld resourceful. FurtheJ111ore, she
benefits from the love, understanding and support of her mother, siblings and, step family. This highly
supportive family system, one free from violence and abuse, is the most important factor in Taylor's
recovery.
Respectfully,
-~ i\6.-~J. 1114
Steve Ham mil, M.A.
Mental Hea Ith Counsc.lor
OU~ HOMS
0
'-\Oo6 \1°?12.D F'L. SVV
L-'i~l-..l\NOOC>, WA '380"!>(
Public Schools - www.QueenEthelburgas.edu - Boys & Girls For Ages 5-19yrs Order A Prospec
Work History
Total Motion Release Seminars: Raleigh, NC - 2006 - Present
Seminar Coordinator
Thomas H. D'Alonzo Baker - Owner
Education
Hawaii Loa College, Kaneohe, HI - BS Economics and International Business
January 1989 - December 1991
'FILED
2
lOIO OCT -7 PH 2: 30
3
SONYA KRASKI
4 COUNTY CLERK
SNOHOMISH CO. WASH
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
7 FOR SNOHOMISH COUNTY
8
In re the Marriage of: )
9 LISA ANN UGALDE SOROS, )
Petitioner, ) CASE NO: 10-2-00156-3
10 and )
)
II KEVIN RENE BROWN, ) NOTICE OF APPEARANCE
COUNSEL
Respondent )
12 )
13
20 Respectfully submitted,
21
22
VERONICA FREITAS, WSBA #19405
Counsel for Lisa Soros
23
24
25
26
27
28
2
ZOIO SEP 30 a!'l g: 41
3
/I/~lllll/111//I
SllH 'l'A KRASKI
4 Il//l//llll/1 //111/ll/I/II/I/II/I/I/ll/1 COUNTY CLERK
~NOllOMISH CO. WASH
I
5
CL14442446
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
7 FOR SNOHOMISH COUNTY
8
In re the Marriage of: )
9 LISA ANN UGALDE SOROS, )
Petitioner, ) CASE NO: 10-2-00156-3
10 and )
)
11 KEVIN RENE BROWN, ) NOTICE OF APPEARANCE
Respondent )
COUNSEL
12
)
13
20 Respectfully submitted,
21
22
VERONICA FREITAS, WSBA #19405
Counsel for Lisa Soros
23
24
25
26
27
28
; ..
Patient Name: ~nR.Brown .... CliUnt DOB:
Start Date: 4i<912oio . CurrO<ht TX Modality: Phase II Group
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