You are on page 1of 99

1

I1\11\11 \\\\\\\II \Ill\ 111111\\1\ \\Ill \\Ill Ill\\ Ill\\ \Ill Ill\
CL 13739785

Superior Court of Washington


For Snohomish County

No. 10 2 00156 3
Petitioner Petition for Order for Protection
12~6;. vs. (PTORPRT)
VE.VIII,\ Of'?\..IE= 0!?pA.1U I

Respondent

1. DI am ~A member of my family or household is the 3. My age is:


victim of domestic violence committed by the D Under 16 D 16 or 17 IS?'fg or over
respondent as described in the statement below.
2. 511"'! live in this county. Respondent's age is:
D I left my residence because of abuse and this is the D Under 16 D 16 or 17 5'18 or over
county of my new or former residence.
4. ~ relationship with the respondent is: D current or former dating Din-law
• 11 former spouse relationship D parent or child
Q.£arent of a common child - '-\'· - D stepparent or stepchild D blood relation other
D current or former cohabitant a, intimate D current or former than parent or child
partner, including current or former cohabitant as roommate
registered domestic partner
5. Identification of Minors (if applicable) D No Minors involved.
Name How Related to Resides
(First, Middle Initial, Last) Age Race Sex Petitioner Resoondent with

t>IW\t:) ~'4· e.aDwo.l. \4. ~ t.A ~lo.l ~'-l ~

~ II " M\GL\i;I l "=> - - I


,.., ..... l.L.. F D.t!.Ub· n.&..... •• • ••
,,.,,~ . ... . ., •• •• ••
t'?-. - - - . . ~
c:::
. ..
T~l.012.
..
·~ - \IA Cl.I " - F'
I'

SCOMIS SEAJCH: C'e" Typ~


1. V 2._ _ J._ _ s. __
Petition for Order for Protection (PTORPR7) • Pago 1 of 5
WPF DV-1.015 Mandatory (712009). RCW 26.50.030
S:\FORMS\FCOURTSERVICES\Mastor Fonns\Potition for Order for Protection.doc
7. _ _..r-8.~ By:~
..

the respondent: -(!'M~


..
6 Other court cases or other restraining , protection or no-contact orders involving me , the minors and
~
-~""
Case Name / I Plo/701.AI ~ vi(c tt
Case Number \0-\(o9n '2-0111 o~-~-oo?~~-8'
Court/County .._
rJ1" ...
. ,_
~L,L
·-
- . • • ..::. I j) if ISr-i·O'b.-l':rLJ
Check the box for each type of relief you are requesting, for each type of order you need.
Temp: I Request a Temporary Order for Protection, effective until the hearing, because an
Emergency Exists as described in the statement below. A temporary protection order should
be issued immediately without notice to the respondent, to avoid irreparable injury.
Full: I Request a "full" Order for Protection, following a hearing.
Temp Full
l l

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:

You have a right to keep your residential address confidential.


4
D D Direct respondent to vacate our shared residence and restore it to me.

( ~
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:

Petition for Order for Protection (PTORPRT) - Paga 2 of 5


WPF DV-1.015 Mandatory (712009) - RCW 26.50.030
S:\FORMS\FCOURTSERVtCES\Mastar Forms\Patition for Order for Protection.doc
Temp Full Temporary Order, effective until a heari.ng. Full Order, effective following a hearing.
! !
6
D D Grant me possession of essential personal belongings, including the following:

7
D D Grant me use of the following vehicle:
Year, Make & Model License No. -
8
D D 0ther:

NIA ~ 'Direct the respondent to participate in appropriate treatment or counseling


services.
10
NIA D Require the respondent to pay the fees and costs of this action.
NIA ~
11
Remain Effective longer than one year because respondent is likely to resume
acts of domestic violence against me ifthe order expires in a year.
Check the following only if you are requesting protection involving pets.
NIA
~
12
Grant me exclusive custody and control of the followingpet(s) owned,
possessed, leased, kept, or held by me, respondent, or a minor child residing with
either me or the respondent. (Specify name of pet and type of animal.):

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:

Petition for Order for Protection (PTORPRT) - Paga 3 of 5


WPF DV-1.015 Mandetory (712009). RCW 26.50.030
S:\FORMS\FCOURTSERVICES\Master Forms\Petition for Order for Protection.doc
Request for Special Assistance From Law Enforcement Agencies:
I request the court order the appropriate law enforcement agency to assist me in obtaining:
D Possession ofp;i,y residence. D Possession of the vehicle designated above.
gi Possession of'aWkBflfl¥i personal belongings at D the shared residence ~respondent's residence
D other location ~~~~~~~~~~~~~~~~~~~~~~~~~·

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~~~~
$;~f:- ~ ~.. p,~
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.

Petition for Order for Protection (PTORPRT) • Page 4 of 5


WPF DV-1.015 Mandatory (712009). RCW 26.50.030
5:\FORMS\FCOURTSERVICES\Master Forms\Petition for Order for Protection.doc
I am requesting a Protection Order for our children:
David Anthony Brown 14 November 9, 1995
Sarah Michelle Brown I2 October 18, I 997
Renee Alexandra Brown 9 May 8, 2000
-fA'\l.OIZ C.~t.IG> ~ \ID ~v.tx" \IO, IOf\~
Late evening ( approx. 11 :00 pm ) January 20, 20 I 0 her father Kevin Rene Brown beat
Taylor Cheyenne Brown. He did this in response to a verbal argument with her. Our other
three children witnessed this altercation and do not feel safe with him.

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 brought Taylor to me at 1 o'clock in the morning on January 21, 2010. He


explained what had happened to my husband ( Phil C. Soros ) and me. During his
recitation of the events he showed absolutely no remorse. When I stopped him and asked
what he was thinking when he took the belt to our daughter he told me " Don't judge
me! ".He also said that Taylor was" Fine", and that she" took that whoopin' like a
man. " He also said that had she been a boy he would have "whooped" her like that a
long time ago but since she is a girl he hasn't. These statements along with many others
and his actions have required me to seek this Protection Order for our children.

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.

0·A.a IJ/bl.JdJ &->o~


Lisa Ugaid1s~r~s-
.,. . '•
0 O
'
' ;
:::
"
.
'

Bothell Municipal_Court of Washington


._f:..:o:..:r....:K.!:l.:..:n..__,aC:..:o:..:u:..:n'-'1tv,__ _ _ _ _ _ _ _ _ _ _ _~ No.
Domestic Violence
No-Contact Order
_,,C'""IT......_Y_,O"'F'-"'B"'O"'T"'H""E"'L"'L"---------- Plaintiff (Misdemeanor)
vs. [ll Pre-trial
ti Post conviction
¥.etJ;N ~~
~S~ID-:--~~-~---------
Defendant X Clerk's action required.

lf no SID, use DOB: (i,. °3- ' ~ &


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 en ere~ pursuant to chapter 10.99 RCW. This order protects (Name):
~I - 9i3 ~
2. The court further finds that e 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~ 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 of RCW 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 This No-Contact Order expires 2 years from today's date: _ ___.I_·'2.~'1-·_'~0~-----­
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 knowingl:t fOming within or know·gly remaining within -~l~frf1~·~-µ'!'-"~--<distance) of the
protected person(s)'s Iii residence Mschool workplace D other: _ _ _ _ _ _\~--------
!' )"t'

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 .

Domestic Violence No-Contact Order (NOCONIORNC) - Page 1 of 2


CrRLJ 07.0900- (612006) RCW 10.99.040, .045, .050
. .,
0
.

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._~_,__
<_0 _1_0_ _ _ __

- _:1

Domestic Violence No-Contact Order (NOCONIORNC) - Page 2 of 2


CrRW 07.0900- (612006) RCW 10.99.040, .045, .050
• I

-. }
..
..
,•
"l

...
..
.. . ....
. ~ • .• *:~ .• '~ •. • ..• •....... *· -~-·. *
,.
. . .. ·• -· ....... .
·:·
. ·· '· '-· . .', -
Processingl~f
.. . .
ormation
.
·. · .::~

: ly .- ' -' • •

Request
.. made by: .Phone.---- Mail'----"-"-
.. Person ---- Fali. ·~--- Other --~-~--

Req~est to be: Mailed_._ _ _ _ Picke~Up_,:~·.,,·-~-- F~~~·~~----'--~-


"
Paid by _ _ _ _ _ _ _ _ Receipi# _ _ _~~-----

Request Proi:essed By _ _ _ _ _ _ _ _ _ _-'---'----~--------

-;. ;-, .· .• • - :'•. •t , . - ·.• ...:__ ·.:... . :-.~- ~- .: . . . :.... ..


Describe any violence or threats towards children: f le-Jlc,p-, ~ Gtttntr\ned·

Describe medical treatment you received and for what:\t


Describe any threats of suicide or suicidal behavior by the respondent: _ _,t..""""}a....,WE:""""''~-------

Does the respondent own or possess firearms? D Yes ~No


Does the respondent use firearms, weapons or objects to threaten or harm you? Please describe:

If you are requesting that the protection order lasts longer than one year, describe the reasons why:
l beheV'e, \l.e:.V\V\ ~0.s 'O'\/ -r~etxtr\\evtr ().nd Y"I '"""' o• 1± -ll'lo7\=
'M1 cn\\rlre.V\ W\\\ rot \?e. ~ .

Other:
-----------------------------------~

(continue on separate page if necessary)


Check box if substance abuse is involved: D alcohol }(drugs D other
D Personal service cannot be made upon respondent within the state of Washington.
I certify under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Dated: \ /'2!2 f '2.0ID at ~ , Washington.

U'AA l~aJdL &o~

Petition for Order for Protection (PTORPRT) - Paga 5 of 5


WPF DV-1.015 Mandatory (712009) - RCW 26.50.030
S:\FORMS\FCOURTSERVICES\Master Fonns\Petition for Order for Protection.doc
10 2 00156 3
CHILD CUSTODY INFORMATION SHEET
If you are seeking protection for your child(ren) from domestic violence or are requesting custody of
your child(ren), please answer the questions and provide the information requested in paragraphs A -E
below and check the boxes about the court's jurisdiction that apply to your case:

Information for the courts:

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.)
12>\\'1. e, H Ave, ':'E. ~\\, """" ~fll">'.2.~ - ~\~ ~ e.ao.ut-1
• •• t ••1'.l.t..1.•••11on ·~•l>c 'iSo'2.\ • I\""-" •"-•• _, ~,.,
"t:' \- "'"""'

CHILD CUSTODY INFORMATION SHEET- Page I of2


WPF DV-1.030 (9/2001)- RCW 26.050.030, 26.27.201- .29I
CLERK'S OFFICE: S:IFORMSIFCOURTSERVICES\Master Forms\Child Information Sheet.doc
..
Jurisdiction:

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.

Dated \ /'25 /'2D\O at el~ Washington

CHILD CUSTODY INFORMATION SHEET- Page 2 of2


WPF DV-1.030 (9/200I) - RCW 26.050.030, 26.27.20I - .29I
CLERK'S OFFICE: S:\FORMSIFCOURTSERVICES\Master Forrns\Child Information Sheet.doc
F\LED
I\ \ \ \ \ \ \ \CL13739786
\ \ \ \ \ \ \ \ \ \ \ ~\ \ \\\i\\\i\\\\ ' -10 J~N 25 PM ~: 00
sot-IYA KRAS\'\\
coutnY CU~RK
SNOHOMISH CO. WASH

Superior Court of Washington


For Snohomish County No.
10 2 00156 3
~,..i Temporary Order for Protection and
\fA u~rei ~
LPetitioner "''DOBJlpf, Notice of Hearing (TMORPRT)
vs. (Clerk's Action Required) {
Next Hearing DatefTime: 2Jt IV @ 1:00 PM
"61\11.\ ~ ~
Respondent
1,g/3/(pl,,o
DOB
At: Snohomish County Courthouse, 1•1 floor
3000 Rockefeller Avenue, Everett, WA 98201
Department ~ B [ I C

Names of Minors: D No Minors Involved Res ondent Identifiers

'*
First Middle Last Age

hl\V\t> ~ l"o..n...\ .
.,,.,,,.\\ uw..1ppe. 1"NJ™nl 1'2..
0?Wff. t.Ja<M.ll2!ZA 12K'r'~ ~9~- Respondent's Distinguishing Features:
~ ~\\lb ~ \l,o
~::.. · 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:

Additional no contact provisions are on the next page.


The terms of this order shall be effective until the end of the hearing, noted above.

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
i..;
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.

Temp Ord for Protection!Nt of Hrg (TMORPRT) - Page 2 of 3


WPF DV-2. 015 Mandatory (712007) - RCW 26. 50. 030
S:\FORMS\FCOURTSERVICES\Master Forms\ Temporary Protection Order. doc
Warnings to 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 includes tribal lands, you may
be subject to criminal prosecution in federal court under 18 U.S.C. § 2261, 2261A, or 2262.
A violation of provisions 1 through 5 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.36.0I ! or 9A.36.02 I 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 the court issues a final protection order, and your relationship to the petitioner is that of spouse or former
spouse, parent of a conunon child, or former or current cohabitant as intimate partner, you may not possess a
firearm or ammunition for as long as that final protection order is in effect. 18 U.S.C. § 922(g)(8). A violation of
this federal firearms law carries a maximum possible penalty of 10 years in prison and a $250,000 fine. An
exception exists for law enforcement officers and military personnel when carrying department/goverrunent-issued
firearms. 18 U.S.C. § 925(a)(I). If you are convicted 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 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 cou~l.l forward a copy of this order on or before the next judicial day
to ~t\..10 ·
fv') D County Shenffs Office D Pohce
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.
D The clerk of the court shall ~o -forward
l
a cop~this order on or before the next judicial day to
,,.-__.f
.,. n , • D County Sheriffs Office
tAPolice 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 has made private arrangements for service of this order.
J<i Law enforcement shall assist petitioner in obtai~~
~Possession of petitioner's D residence 'l5ZJ pe e ongings located at: D the shared residence
;@ '£respondent's residence D other:
D ustody of the above-named minors, including taking physical custody for delivery to petitioner (if
applicable).
DOther:
,,.,:-
t55'3 \ \I-;/
)
Dated: .!AN 2 5 2010 at _ _ a.m./p.m. .
Jud~ pmmissioner
Presented b y : \
A Law Enforcement Information Sheet (LEIS)
lr'44 14:J4Mdnob
Petitioner
must be completed.

Temp Ord for Protection/NI of Hrg (TMORPRT) - Page 3 of 3


WPF DV-2.015 Mandatory (712007) - RCW 26.50.030
S:\FORMS\FCOURTSERVICES\Master Forms\ Temporary Protection Order.doc
i
..
• .FILED
/o-;;J.olS

2010 JAN 29 PH 2: 19
SOllYA KRASK1
CGUNTY CLERK
SNOHOMISH CO. WASH
I\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\
CL 13454326 __ _
\

SUPERIOR COURT OF WASHING TON


FOR SNOHOMISH COUNTY 10 2 00156 3
NO.
L"'2-'l?..,>Aci.__._\40V:..,.,"'~""'"'""""-~-"""''-="-""---'' Petitioner,
vs. RETURN OF SERVICE
(RTS)

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) _ _ _ _ _ _ _ _ _ __

D No service was attempted b e c a u s e - - - - - - - - - - - - - - - - - -

3. I served _~\te=~>l~\~N~~f2f14E2~=~~0W>~~~W~~~---- with the following documents:


(name of person served)

Temporary Order for Protection and D Motion to Modify Temporary Order


Notice of Hearing
D Order Modifying Temporary Order
Petition for Order for Protection
D Order Terminating/Dismissing
Reissuance of Temporary Order for
Protection and Notice of Hearing D Petition for Renewal

D Order for Protection D Other:


-----------~

D Motion to Modify Order for


Protection
D Order Modifying Order for
Protection

S:\FORMS\FCOURTSERVlCES\Master Forms\Retum ofServiceDV.doc- Page I of2


WPF DV-4.020 (6/2002) • RCW 26.50.090
((ii'?) 1~ ,~
'
, ..

·•
,
\
'
r•

• •
4. I served these documents on I
---.~-~--~
/;;.u / / 0 at I~)</
--~------
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.

DA TED --~1+-/_1-_lt~/~1~0_ _ _ _ at --~/3'"""'dfl-d!~--------' Washington.

Fees: Service - - - - - -
Mileage _ _ _ _ __

Total

Please return completed form to:

Snohomish County Clerks Office


Court Services Division MIS 605
3000 Rockefeller Ave
Everett, WA 98201

S:\FORMS\FCOURTSERVJCES\Master Forms\Retum of ServiceDV.doc- Page I of2


WPF DV-4.020 (6/2002) - RCW 26.50.090
r.=~~~~~~~~~~~=;i
F. tLED
fEB-8 Pli \:30
SUPERIOR COURT OF I
WASHINGTON SOHYA KRASKI
FOR SNOHOMISH COUNTY coutnX t;\E~~ "µ
..)IOVI I V • ' •

LISA ANN UGALDE SOROS CAUSE NO.: 10-2-00156-3


(PETITIONER) COMMISSIONER: SUSAN C. GAER
AND CLERK: PATRICIA BUNDY
KEVIN RENE BROWN DATE: 02-08-10 @ 1:00 P.M.
(RESPONDENT) DIGITALLY RECORDED

THIS MATTER CAME ON FOR: DOMESTIC VIOLENCE HEARING


CONTINUED DATE/TIME/CALENDAR AND CONTINUANCE CODE:
HEARING DATE SET/TIME/CALENDAR CODE:
ACTION:
HEARING STRICKEN/CODE:
PETITIONER APPEARED: YES COUNSEL: PRO SE
RESPONDENT APPEARED: YES COUNSEL: ROBERT JEFFREY WADE
GUARDIAN AD LITEM APPEARED: NOT PRESENT
FACILITATOR PRESENT: YES

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:RESPONDENT REQUESTS THAT THE TEMPORARY ORDER BE


ISSUED TO ALLOW HIM MORE TIME TO REVIEW THE POLICE REPORTS, AND RESPOND TO THE
NEW MATERIALS.

1 MINUTE ENTRY
•'

IOFEB-8 PH 1=29

r \ ~\ \ \i\niCL~\ \'13743617
\~i\~\\\"~i~\~\ \ ~~ r:
SONYA KRASKI
COUNTY CLERK
,"NOHOMISH CO. WASH
\

SUPERIOR COURT OF WASHINGTON


FOR SNOHOMISH COUNTY -
c:t111i..e NO. 2 00156 3
\...~~~ w...~~
Petitioner (first,middle,last) DOB REISSUANCE OF TEMPORARY
vs. ORDER FOR PROTECTION AND
\LEN~:::>o<.:~'~=--2-~""""l!?~·~~""""'"""""-"-~~~'~'~v NOTICEOF HEARING (ORRTPO)
Respondent (first,middle,last) DOB (Clerk's Action Required)

M The Temporary Order for Protection issued on \-d,~-10 is hereby extended


through the new court hearing date on this matter on J. ·2. L/ -/ 0 (date)
at 1:00 pm (time) at 3000 Rockefeller Avenue, l" floor Dept~ Everett, WA 98201 (location).

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

, I1\\\\\1111\11\\III\\\ 11111\1\\1\\Ill \1\1\\\\\\\\Ill\\\\\\\\


,
~
CL13454264 '

SUPERIOR COURT OF WASHING TON


FOR SNOHOMISH COUNTY
1SG -'3
NO. \0 2 00 l'?b O
Peti tioner/Plainti ff(s),

vs. COVERSHEET

Respondent/Defendant(s).

ATTACHED HERETO IS:

'' '' L1-sA Lk::aN&E; 'S?eos

S:\FORMS\FCOURTSER VICES\Mastcr Forms\Covershce1.doc


Case Report
Summary

Print DatefTime: 01/2912010 16:08 Bothell Police Department


Login ID: merrittj ORI Number: WA0170300
Case Number: 2010-00001680

Case

Case Number: 2010-00001680 Incident Type: Assautt


Location: 23112 19TH AVE SE Occurred From: 0111912010 23:45
Bothell, WA 98021 Occurred Thru: 011191201 o 23:45
Reporting Officer ID: 0300 - Kerzman Disposition:
Disposition Date:
Reported Date: 0112112010 18:53 Thursday

Offenses

No. Group/ORI Crime Code Statute Description Counts


1 Stale 13B 9A.36.041.DV ASSAULT 4TH DEGREE DV

Subjects

Type No.Name Address Phone Race Sex DOB


Subject 1 Ugalde-Soros, Lisa Ann 4008 173RD PL SW (206)91a.3581 Blad< Femate 09/01/1968
LYNNWOOD, WA 98037
Suspect 1 Brown, Kevin Rene 23112 19TH AVE SE (206)898-9966 Blad< Male 06/03/1966
Bothell, WA 98021
Victim Brown, Taylor Cheyenne 4008 173RD PL SW (425)442-9009 Blad< Female 09/1511993
LYNNWOOD, WA 98037

Arrests

Arrest No. Name Address Date/Time Type


7958A Brown, Kevin Rene 2311219TH AVE SE Bothell, 0111912010 23:45 Taken into Custody
WA98021

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

OfficerlD: Kerzmans, Case Summary


Bothell Officers investigated an assault report between a father and daughter. The father was arrested for assaulting his
juvenile daughter and booked into Snohomish County Jail

OfficerlD: Kerzmans, Case Narrative


01-21-1011853 hours
Assault 4th DV/10-1680
23112 19th Ave SE
Officer Kerzman/0300

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

Print Date/Time: 0112912010 16:08 Bothell Police Department


Login ID: merrittj ORI Number: WA0170300
Case Number: 201<Hl0001680

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

Print Dateffime: 0112912010 16:08 Bothell Police Department


Login ID: merrittj ORI Number: WA0170300
Case Number: 201°'°°°01680.
County Jail Transport Unit to come take custody of Kevin. The Transport Unit arrived and took custody of Kevin,
transporting him to Snohomish County JaiL

I cleared the incident with no further action.

OfficerlD: Smithr, Case Supplemental Narrative


01-21-10 / 1919 HRS
Assault 4 DV / 10-1680
23112 19th Ave SE
R. Smith I 0269

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

Print Date!Time: 0112912010 16:08 Bothell Police Department


Login ID: menj.!lj ORI Number: WA0170300
Case Num6er: 2010:.00001680
Taylor then pointed to the shin of her left leg where there was a bruise one inch in diameter and a two-inch long scrape.
The bruise and scrape were located approximately five inches above her ankle on the front of her shin. I asked Taylor
how she got this bruise and scrape and she said, "I think it was when my dad and I were fighting and I was kicking my
legs. I was kicking my legs a Jot."

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.

OfficerlD: Kerzmans, Case Supplemental Narrative


01-26-10/0356 hours
Assault 4th/10-1680
18410 101st Ave NE
Officer Kerzman/0300

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.

No further action taken at this lime.

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.

REFERRAL #2179436 REVIEWED:

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.

For further facts refer to his initial report.

REPORT SENT TO CPS:

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:

This concludes my involvement.


BOTHELL
(_-'DUCE DEPARTMENT ; '

I/o - HatD I
'

CASE NUMBER

Time:
Date:
l·.l.(/!-/0
Place:
/]o7(.f.€t {,.

STATEMENT OF
Name: bftv#) /), 13 IZow QJ
0.0.B. Employed:
------
~
--KE!J 6Z-v-D 7:#'.e.v r,,.zy r-,yG d@..q,,."az. //-..> r~
77.J &.Cdve
t'Y#J t...64...-r~C.. ~y ~4)> S:#'"<-.r- 7"tY~ 4~()/'Zoacn -'°~"''?.·
///Nu# />'-z:r- ,,,-vz 7 S::r$"7.c;(__ T/V /4c/1 C#£s-T 4' ?"' !) AIJ ,/2f6A/
~/l4~~cl'/ ,,.,,,,Y fe>:r..£4 & d.£/2. ~...> dtvo r#n~...._, .:T~:rc:>
# ..r"96'U C#-,,_,.s~,? ;;z::.;;r- .7e> ,L42c_/ &//,&/? ;HY <rf76'/Z ~
v/? / fr#a.r.-:oa ~--??z-...-v.? 4 ;;r- ;ny tJ#O / ,:r/,c~,,,.._r
#.c.,,.....- //z:-.;?? ~
//~£ C/r:es?>- -4 &e<&ef ,,w~~ # //#/n,47,e:=,n ,Lz../7. ,d1Y' /J/lfJ
T""?/) J.'Yt£ 70 f,,,£.l)lvJE- Co z:;:.- ?V6,/'l/°r z:?'VTe:> 7/IL-6 #4"??.- A.Nb
(1-6. >Alur -r;..l,f tf[el)~_,.,.., IJ.P"7/k d'.e#;;qv!) .flt~ WllE.v .Z. J!lv/f'S" :r-J
UV? #4t-C:.. z;;= C<!?<"-'C:..?J /k~ 7#e,rl-7 &;--;,¥ l/G,?'.?z;-/V,;:::. 4?- ~c,p-
,ty/ff/?, :Z: ~,v /164,,e.{) W-t,L4;r Sd'a.,.,,f).6tJ ?z:;t.c S7P-..-,<..erv&i W?72,,,_,.,,;:.
5/?,4/V,l£.p Pk'/-lf"= A- q7c,c;;r 7 //e.441 tn?dE 01"U.vv? @r--eq,./ T/K&
T>Vo ,_,,;: nl-/"::E? ( <f£:r--"'n he c...c._4p<ft Z.#-£ 4.,,..,"""?
~4;:.,./ "' r- I' 4 C.t::.o 12 d Af £ /(_ /'f V-4z:;rv
t!F~c&4 iuu?l114N vvtturr; Tt'tr> >rr?-re.nu;,;v-r- ,Lori.. "'1ef'

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:
fco 'i5 !75(ll) Pt >tJ L YN,.,/.JJPOI), Wfl 981'.?7

Q2-t5"-q3 Employed: /J, Ti-I!/,( lfrW Sc/looL Tel: 'l,;~-'/'lt?-f~t7 £

tfJ/f/ T(/-E ~Nt" ?-¢7£ //r ,,v;,j//,T, #1/ /)#-{) T.#EAI .>r.4.£7Z/) /1.>Kr,;v~
Mr£- .z:.r z: 1v/Js dk'e;;tN? f/1-r~/Vfe- 7>su/;; tf#t> .z /IJ?b #z--"n z
Dz:t>"1'-r ,4&11e. t4,v j'. de T#bv S-rl'f/2,r.eo 7i> 'lft,L- d :r Lt?£ #e?~u ;r
/11 i /.3,ty,C/Z>L'PD W/Z{)AN tNdo t:,z:p~f 7/1./ /f::E;vrvr,::,e~ 11£ //"'11:5

"T!UP'HoNr!: t?N~ >AJD H[ t71/;7-;>J7,t;/) Cl) 741,,,i To #rn,, :.z;. Ti'c.b 1/.7//7
F h~N 'r W&c>z dZ-W] ?-o c&-t.-1.-- /f::z::-?1 Ar .w/Jl-rc.1/- r>=,....,e //e nic..1>
M£ 'ft2 0c,C- 7°'/t.1:>19-r'> ()t'l t/'*'- f'..+..z:-o #,,:- . ef-Vi"f-> tf&.::z.-v? TO rctk-:E ,-ny
fJll~e. :r. UPr 771-e fl«or-tt::' Alvo 777/a.rG.D ?"O t-£4o1c /I-:& s- ~ct>l(.dOl?'J

/?t.1flfTN(r /Hvt. .:r: ev~rv..4-(,,t- '{ f'f.t,L oAJ'7..,, & r,t/IJU r~ HZf t5et>/Zo1J,.,-,
:r: WT <Af" t'~P r,;J£.. (//lpl,{;V~ l/;vb r: ::;r.#lf:,.r,<;.t> ,r..,,, /-7u.,vcif ,,...y 4,14 w.z:r#
UP>£t> J'O:z=s-r-s :;-10 J-1-:zos. ?£t=r c#c.: r /l/ZE..A. ;r; r!'l.r/Vfe ~ r.Lz:r Irr/>?
11/!~flL/ '/- r r-..mt:s ~~4e. II~ ,,clm/t£// h-1<£.. (:P.,,..,.rru r~ ~- .t:' wlJS
tAt:uvfr l?;V hl'f 41-c.i &/V N;;:...s ,({,t;IJ g,.vt> i+r: ~s tlDt;vFa 'b\J(.,... cvce
fr/£. l/1Jt-0:yv I.>- /'Yl.'f ?.;!' ~s {)0!-0N. mv /.Jiff) nok- 11~$ 4c£...T c>1-i.:r, ,c
;-/J; 5 174 /VT$ /fJN t:> m ~be.. :z::. -r z:_-,,__,,-o fl WP . Ht? f'WuN t- 7, £ ,tff6t.-;r
/lrJ!J -""£ IP/V r11t &ePr /J?tl...r .c /J1. '/ >7"ZJr1?'9cf/. Ml./ />Ab -rwE.AJ

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.

Witnessed.:,., Yt;lf----1/-i~----=~_:_(J:.._(/_ _ _ _ _ _ _ _ _ Signed~


Page_t_ot _J.Pages
)· BOTHELL·..
. .' . ·i . ;

·'
POLICE DEPARTMENT
Statementof . //J '/to /l ~~t<l~ (continued)

UPr ?Ct-. fVl/rt..c. /'YIY /:JAtl .,v.q s. /l.zrr.;zrv?- m€ #&' .>lf?Jb r/6. .Nt?iu:.1.
-r.r: ;L!-c/.1- /1'1e TO 11 /Kck:r::,N ./14-:r£ me _'', -;;: Tf/.c(J ;:47 17,V 7dL Et>t,..£ o;;C
f1k 4ctJ lf..;vD !It tM45 /liy~/vtr ro z4-d- -rv ,me 4u:r :z;. ,,,,,'7,.?i).N';
>?»V -lft'o\}lt-/-z:t-..JG. !ht rt9;._6. Mt!! z;. .w/JS /V&i/€../Z- ;:)~?t/c/J /.:J ltSf:
/11'/ j/;/t1.Nt lf.;r N'.;c_s /ku.>c #£.~=,,._,, z: ~c/t.e() KP fV''/ cec.L- />lbt
!WD >7(112...,.tE.fi 7D t.-12/11/r- ,.cf.z~ /f?G.!JfUJO/'YJ, ;-1~ f'u51fl!() /ht /JrJc,i: ~/Vro
/lxs &:D J >-rM,cD ro T/2.f · ~6 · 6£r- 71/£ /;/£;/Ve Mt?/17 /J?t!. /YI'/
f>!l-D f':J:rvlf.a·I . 6lflT 7¥€. /?U&/Vc t9?t-r &E ,,nv ,.<//JAJ!'JS ,4.AJt.::, ?-,¢£A)
~1'1119?1/C/) :CT IA,# 11 ~Z-.r-'7'-> r- Tt'-A5 W/?~ #/VD d.e Pk..6.-- 7 7 ' :r
5°YIJ/l..rtl) /o .>c/ZHJ.i'V! fl..7 J/.7M /Jsk-z:yvtf-. IVflf 11£ Wt!tlt/> /.>lJ ?"//.#r
J1/v[) ·µ /JZ-btv ·-, >IJ.i A/V </ 7/./.7/1./t:f .. .z:.. r/'/.f",,,._} U,.cr /IN/) "'-'w..,.._
-r= .my /Jfel)/Zeo;n, :Z: {-,:N?-6-tl r rr:;={ft~'/ r#r 4_/re/Z. ,>ny iJ,¢L)
;::'z;vz.5~£0 hh::.r;r:z:.A.J(,.. n?,f W7:-T/I- A~/£ r#'£?7'" 116 MT .n?€ ;,vz;.7/-f
4f\J &ffuJ f/-4tUb 70 7 f/6 /l:f6U-r <;;~LJ/f! .9,t:r- /J.-, V #'&C-/1. !"9Pr£A .Z::
,,vf/V-r TTJ ,vvt.f ~M ~ .>T,4/Z.-7'€,t) 7-c:> ther tl.4:-.>5£/.> rl-..Np /'l-1 c/ /,)~!>
f'oUp{,A<fD IP!L- ,,,,,.'/ IJ4PJ T#c,,U /WtlKc uJ?fi'ly' -s A'4P.T/,L-&:; /

p/cuv(;.._ rv1e.. /e> M '/ IY!c;/'VJ'.s /-/o~ S/-. ;:;:;::: /7/\/7.>NFf; ~'-'#EtZ-::rNC- ·
fh.L/ 711-r:~~s Mt> rw.lf DA~ 1JfZ.6 v£ mt!- 7~ frl;t' @IJ~ .s: &a>.£.:. ,::N.z:/.H
1

1)1,l/ >t:Jg l-#'ll ~ 5 , #8 ,f)tZo /?f'co m c. o// / #'.G/Z..6 nt4t?u--;r- ~:Pt'J /l/rl
t/.fe{)fVt.> 'b~Y (Yl;;;t..tvx:JV6 . -:r. w~-r -re 13e.i,,, .$1.tvl:::,. ~tLe.. i<..P Z-ih-£«- ::i:!W
/Hf, (hu/2.N-xr0 G- -ro 0-€...r 12-£.AC>'I forL SU/ooL. fl1'1 .tP:-r S:-ffeut~f-4. LJ?wf".~
· IM£,k, !f-;vb l-t../:r t-e k: f/o/ctZ.~ ltt!l/lt i./ · '> t?tt.t /!f't,,,.,,, ;-vtfµcl' .M'/ t>llFJ l.f:z.:r,
;:t:' fVdrzcEt> ~ llllD /2£().()(VfSS -4Nb/Nt.t-rj 06'.WAJ ~y tt!./r t:-c? ~m
(nl/ /)II-(>. #;;I tne
/ltfffit2f. pr. rt/ /,¢£ /JUr Z:- '4C..5 iJ p//1() /?. R44Jcd
t?;i/ fYlY tUr 7f/:l!lu.t.Pel'Z · ~N /lrtr!fr- 5//-.zN 4ur- Tm /V~T fr~ //;IV'~
· 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)

~qr.:..z?f{/!!:.......Wl!.!t.! .....:r......tlflnf......llf!t!.£ ....E!1.~~-...f (;±~-~... ~~....0::.~f..~!:f~~-'(. ...............


k .... f..1.P..?!!.f:..~ ........ 0.:.Y....... /J:!.P../.?::!..........0..V .....!!.:!:'f!.'!/2:...i:.?..£..:.... P.!.~ ...... P..f...t;:;~!?.E.!>.. ...... ..!?lt?..?.:.....~...............
...f.(/q_tj_(.~....... f!.!.......1.:??........C.!.(.f::.......'?!!. ~!.".'!.~ .:~..... z:P..... -~?........ ~!/.F.1.1. ......~!?. ..... f.::..f. ......(!!-:f..fJ..4........d.:r.i/........
.ft!?~?:!::.!:~€:.:.:7.:.... :::..~.1::. .... .!?!~.1.E.{).(.!:_/, ..........................................................................,................................................. .

:P.:;1:;;:::::::r..:::::;.--;.;;:r.:::::~;.:;::::::i&.:;J:::::::::~1:;::::f..~""/!d..:::::i.:i.P.:~::::::1!!..~:::j::-;;f::::::::zf.~:~4:::::::::::::
...~i!.t.l!. ...... r.z!!..~.....1.'.~~-~?..?.;.........1?..t!..~ ... ~.4_.'!.:~ .....?.~.T.......(!l..f:........T.P....... C.!.!::~..~:!?.. ~.~-~---!..................... .
...d.'?.?.f.E.!Jl: ~--· .... ;F./.Y. ........?..f::!!. ?:.~~ff..: ....... !!:!:.'!........ fr.1.P.!>?. ....... ;,?. !f/~4. ..... rl.~-· .l>.f?. ~!::!........!...~......................
.ll!::F.t..Pf!::f(':!...'?.........!.h. . q!.F..~1:.1:........ €.m.f.!f.t?:C.tY..~.Y. .....~q/!7 .....:z.'.~ .....;E"_?..~.T..?:~.£ ......:£ ................ .
... ~w....... !..lf.fL.. PP..<:.zq/!...?.. ...... 4~.Q ....'!?f.f.'/.......f..&J.iYff)._ ....tJ:z:. .. .f.11.Y....7.:.-"YZ.«4.r.ff..~....&Y.r>.....~q-~····
...... E~.?.:"~.IJ.:.€:.?...!. .....£ .....1.1.c..?..12...... z.l.'f.~~---····r<:?. ........tl: ... 2.<R.~~--·····w.i?.4.A.~~--····4..lf..a.......<...f.?.:.P.. .... .
.. f..f.:-:?........W.P..1:1:?.!?........ t:.P.~!77:.~z .........n.?. ...... ?./.?:.~: ......111. 'i. ......!>.. ~ '?. ........ !f.1.?.'....../!!.f...!'.&!-........ f.!..~ ~€. ..........
.. ~~-'/..!?!Fe-!. /.t:..... Id::~§. ..... l:/!.:!:.~ .... .. ?.P......!.?l.f:: .. ./~f!e !:?.£. .... :>..~ ...E ....P.v..'.!.:?.. ...?.?..'1::~?..0. ...... f.!:~.0. ......................
...'?..t.l.i:?.~l~.-.·............................................................................................................................................................................................. .

::;:~;;:::::E.~!?:i~~;;;:::::;;;;j:;:::::::~:~;;~;;:::::&""fi:;:::&~::::d.v.::::~/if.~~::::.::""4.¥.:.:~ii..;;;;;J:::::
..~P .... ?:..~ .....~~!!..t:;.;.....!!.!":(/?. ....?..f.~.f..f-."L.....?.P. .... r.!#.:.....-2'#..~r. .....c:>.-:=:..... ~..Y.. ... ~~-q;_.~4<?..f..... .......... .

(~·····················································································································································--·························································
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:

~ ".f€ll ,6Z..ND c#.b<V 7'7?/ 72> e,/:·.<ve T#G ,4'60/.2,,-a42. #..> .r~
;t>V,11-J l.-- £,4.rr/V t',.. ~y IJ·.4,! !('#"£.r- -r,y,c- /.:?e!J/Z.uo en /./ tP.,,. ;z,
VVffU// 1>1-.r.r ;rzy S:;->'T.c~ TM ~/1 C#e.s=/ ,,,;,,/ (JAi) ,:;:feN
(}-/244'~€'~ ,,.,,_,y fr>"r.bZ 4Y /(£/2. ~....J d/v() r,l/n£,,_,. :z:-,,....,.7<:::>
d: .r~Afu C #14 s.~.? ;;z::.-:;r- -72" ,;C°'--??/ ~//,£/2 !1'1Y <.:c.s-refi ,t:.,,,,-
v/l I
fr,¢ar.£a ,vc-="z:/V? 4 ;:r- ,#'?y' aM / ///,,:-_,-
#'..c.r //c,,?? ~
77-/£ C/:/e<;;r- ..4 O.ere".e::6 tfe/-c~ £- //AZ/."?.-??.c/Z ,,C.z-../7". ,d?f/ tJ;Jf)
TeJ-o "'1/l& To f~U& s:=o .z::- tY.6,-vr Z:-/VT<P µe; #ef24,c... A.NI)
('/£ £$.r r& @6~_., IJeJ?.:>/k -::f'e#~/J me; tA(/16/ ;z; ~/f:":; :;r,J
7ff6 //4t.c z:: ct?vz<::.?J /hi?~ r#.&m &rd "/~C:.t::Z/V'.& -f?"' ~c?"
Qll!f/?, Z T#y./ .-'/6""41) a/(,l-4;r 5t1>a,.v[),6tJ .?:z:,f.c >f~<-e--i.uC: W?7.z,,-v
S""ffe,..,,eE?! Pnr?? &: 4£c,r. 7 /le.4/z.o tn:;74E y&uz-..v? #c.:Vc,,,.;,,v' T/K;
7-/..Lbif Mt' ('££;;-~11. 7=.o C,C4Pdt ;r~ d"'.rh?

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 \ ·

~~d-Ei·==~~'rff,~
;~~;;g~v0V)\~=~=]=:0Jg~~~\v7:Dm ID O\hr bouc;ez.
_&.V1Vl _b\d m>2 -mtt ~ had ffre:, into QAvids rrom a.rd cn1 ~ Yiivn

_j2,j~][XL_s:a~~.:__1:t.L:tr2k:L\l)leLmckth0--i2!w:b'.~l\X--Lmd~~J..ill~,
. ~
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-
prosecutK>n.
w.1nes~: ~
1
1certify (or declare) under penalty of perjury under the laws of the Stale ol Washington. that the foregoing is true and
"'""kl ·
Coort '"' lo>tify Wtire '"""'""""" ;, ~• '"'''"'"' """'~ """ to;t;mooy be """"""' ti

0'9fl>· ·. · .signedXl, M UrjaUr Snoh


f
~:

,,, '
··:<. "'~
2
3 IOAPR21PM3=20
4
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
IO
11
12 Superior Court of Washington
13 County of
14
In re:

Lisa Ann Ugalde Soros No. 10-2-00156-3


Petitioner( s),
and RESPONSE DECLARATION OF
PETITIONER
Kevin Rene Brown
Respondent(s). Lisa Ann Ugalde Soros

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)

Declaration (DCLR) - Page 1 of .fi_


WPF DRPSCU 01.0100 (612006)
The Parenting Plan entered on May 4, 2004 for our 4 children Taylor, David, Sarah and Renee was very
2 near 50%-50% between us. The children resided with their father every Monday and Tuesday, they
3 resided with me every Thursday and Friday and we alternated weekends. (See Exhibit B ). For the entire
4 year of 2009 Mr. Brown and I operated on a mutually agreed modified schedule. The children returned to
5 Mr. Brown from school on his residential Friday or Monday instead of Thursday or Sunday evening. The
6 Parenting Plan in no way required nor allowed Mr. Brown to be "the children's Jul/time residential
7 parent". In his statement Mr. Brown purported that he has "been the parent responsible for caring for
8 all the children's needs , basic, emotional and physical''. Despite paying Child Support to Mr. Brown
9 regularly (See Exhibit C - Payment History from DCS 1/1/2007 to 4/26/2010) he has not paid for his
10 portion for clothing, sports (equipment, uniforms, team photos, etc.), orthodontia (See Exhibit D -
11 Payment History from North Seattle Ortho), driver's education, school fees, school pictures, and many
12 other things that fall under the banner of children's needs. He states that he "or.ranged their schedules
. 13 and taken them to activities". My current husband, Phil C. Soros and I did the transportation to a
14 majority of these appointments, games, and school outings. I am not saying that Mr. Brown did not do
15 any of the transportation but we did much more than he did by far. The simple reason for this is because
16 Mr. Brown's job at Bill Pierre Money Mart had him working weekends when _most of their games took
17 place. He could neither attend nor get them there often due to his schedule. Because of Mr. Brown's
18 work schedule Phil and I mad_e sure we were available to transport the children on our non-residential
19 weekends.
20
21 Mr. Brown states in his sworn declaration that "when the children are sick, I take offfrom work and
22 take them to the doctor and care for them at home until they are well again." This is a bit of a truth
23 stretch. Mr. Brown's work schedule was Wednesday through Sunday; however he usually went it on
24 Monday and Tuesday also. If Taylor or David were home sick from school Mr. Brown allowed them to
25 stay home while he went to work. If either Sarah or Renee was home sick and Mr. Brown needed to work
26 they came to my house because my job enables me to work from home. I do not deny that Mr. Brown has
27 taken the children to the hospital/doctor's office for illnesses but his implication that he has been the sole
28 parent responsible for that task is far from the truth. (See Exhibit E- Declaration of Dr. Jean Sahs)
29
30 Mr. Brown states that I "have not been very interested in the children and their lives". Once again, Mr.
31 Brown has chosen to paint me, as he would hope you would see me. The truth of the matter is that I am
32 extremely involved in my children's lives and always have been. I have relationships with all 16 of my
Declaration (DCLR) - Page 2 of _b_
WPF DRPSCU 01.0100 (612006)
•,

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.

Declaration (DCLR) - Page 3 of JQ__


WPF DRPSCU 01.0100 (612006)
Mr. Brown states that I "consistently avoided paying child support". I have not missed a payment to Mr.
2 Brown in over 3 years. (See Exhibit C - Payment History from DCS 111/2007 to 4/26/2010) The
3 Modification to the Child Support Payment was due to the fact that I went from making $15/hr to $8/hr.
4 That reduction was not an agreement from Mr. Brown rather a decision made by a Commissioner. Mr.
5 Brown states, "recently she has made only partial payments". I paid Child Support through February of
6 this year. I have not paid him for March or April because the children are not residing with him at all
7 right now. DCS has received the paperwork from this case.
8
9 Mr. Brown makes a point to say in his sworn statement that I "was thrown in jail as she still did not
IO comply with the now reduced payment". That is incorrect. I was arrested after a traffic accident that took
11 place in Lynnwood, WA in May 2007. I had an unpaid ticket from 2004 on my record and it had caused
12 my license to be suspended. I had not at the time turned in a change of address to the DOL and did not
13 know of the suspension. The arrest had nothing whatsoever to do with Child Support. As you can see
14 from the Child Support Payment records I was completely current at the time of the accident.
15
16 Mr. Brown's concerns about the children's well-being and safety with me are disingenuous at best. I have
17 attached an aerial photo (See Exhibit 6- Google Map of Spruce Elementary). When Mr. Brown says I
18 "allow Renee and Sarah to leave home and walk for miles unattended" he is exaggerating
19 considerably. I have marked our home and the 'park'.
20
21 Mr. Brown states that I "have not attempted to find and/or sustain a job to provide for her children
22 since they were born". (See Exhibit ti - Work History) I work for Total Motion Release Seminars now
23 and have been in their employ since October 2006. The company is located in Raleigh, North Carolina.
24 The position I hold allows me to have a flexible schedule and be available for the children. Before this
25 position I commuted from Lynnwood to Issaquah while working at AAA of Washington in their travel
26 department. When 1 was laid-off my current husband and I decided that I would stay home so I could be
27 available to attend the needs of the children.
28
29 ·Mr. Brown has described the children and given a small picture of his relationship with his children. 1 am
30 glad that Mr. Brown has had good times with the children, but that is simply not the issue at hand. The
31 issue is the fact that Kevin Rene Brown on January 20, 2010 flew into an out of control rage with our 16-
32 year-old daughter. He beat her severely with a belt, shoved her into a desk, slapped her face so hard he
Declaration (DCLR) - Page 4 of -'2._
WPF DRPSCU 01.0100 (612006)
caused swelling and a lump on the side of her head, gave her over 21 bruises between her stomach and
2 ankles, and broke her finger. He has caused great harm to her emotionally and physically. The aftermath
3 has been heart breaking. She has been diagnosed with Post Traumatic Stress Disorder because of the
4 altercation with her father (See Exhibit f'i' - Letter from Steve Hammil: Counselor). In his response he
5 speaks of Taylor "assaulting" him. His language in the statement gives the impression that he actually
6 blames his daughter for his physical abuse of her.
7
8 The CPS Safety Assessment included in Mr. Brown's response is actually the Safety Assessment done by
9 Ms. Lopez in regards to our household and me during my face-to-face interview on February 3, 20 l 0.
IO Mr. Brown's interview did not take place until February 4, 2010. I have verified this information with
11 Kody, a Case Worker Supervisor at the Alderwood CSO. The case opened to investigate the Domestic
12 Violence charges has been closed with a finding of FOUNDED. A letter was mailed to Mr. Brown on
13 March l, 2010 by Registered Certified mail. (See Sealed Confidential Reports) There have been two (2)
14 attempts made to deliver the letter but Mr. Brown has not been home to sign for the document nor has he
15 taken the call slip to the Post Office to pick it up at a more convenient time.
16
17 Mr. Brown also attached paperwork that was used to start CPS investigations on me in 2002 and 2003.
18 He neglected however to also attach the findings from those cases. They were designated UNFOUNDED.
19 (See Sealed Confidential Reports)
20
21 Mr. Brown's statements have been crafted to be extremely self-serving but do not stand up under the
22 light of scrutiny and compared to documented fact. They are lies from a desperate man trying to avoid
23 owning up to the fact that he has done a terrible thing to his children.
24
25 I would like to see the children re-establish a relationship with their father. That will take time. They are
26 all afraid of Mr. Brown after seeing and hearing the altercation between him and our daughter Taylor.
27 David, our son, fears retribution from his father because he made a statement to the police. Sarah is
28 scared of and disappointed with her father. Renee misses her dad and wants to see him again but wants
29 him to get help with his anger.
30
31 I have used the time during the continuance Mr. Brown requested in February to research Domestic
32 Violence, obtain professional help for my children and have them assessed. My intention is to move
Declaration (DCLR) - Page 5 of_£_
WPF DRPSCU 01.0100 (612006)
forward with the emotional and physical health of my children as my Priority. Mr. Brown having custody
2 and/or unfettered access to them is not in their best interests.
3
4 I am requesting that the Restraining Order go into effect with visitation allowed every other Sunday from
5 12pm - 3pm while the Custody Modification and Parenting Plan is heard in Snohomish Superior Court. I
6 would ask that Mr. Brown have another agreed upon adult during his first three (3) visits with the
7 children so that they feel at ease and have a buffer during those visits. I will bring the children to him
8 since he is restrained by the No Contact Order issued in Bothell Municipal from coming within 1000 ft of
9 Taylor. I would ask that the children not be required to go with their father if they do not want to on that
IO Sunday. The phone contact that court has allowed works well for the children. If Mr. Brown would like
11 to have a specific time for phone contact I am not opposed. I would also ask that that be voluntary for the
12 children also and restricted to my phone number only. I am also not opposed to Mr. Brown and the
13 children using Skype to communicate once in a while if that service is available to Mr. Brown. I would
14 also ask that the court amend the parameters of the Restraining Order for me so Mr. Brown and I can
15 exchange the children without violating the Order.
. 16

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).

Declaration (DCLR) - Page 6 ofJ2.._


WPF DRPSCU 01.0100 (612006)

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

Superior Court of Washington


County of
In re:

Lisa Ann Ugalde Soros No. 10-2-00156-3


Petitioner(s),
and
Declaration of
Kevin Rene Brown
Paul G. Keen
Respondent(s). [Name)
(Optional Use)
DCLR

· This declaration is made by:

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.

Declaration (DCLR) - Page 1 of __


WPF DRPSCU 01.0100 (6/2006)
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.

s;.,.... L 1~ , [City] ___,Lu"""-'Au__ [State] on Apr; / ,JLJ; AQI{) [Date].

~-.
Signature afl)ecfarant
~ul Le.q
Print or Type Name

Do not attach financial records, personal health care records or confidential


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

Declaration (DCLR) - Page 2 of _ _


WPF DRPSCU 01.0100 (612006)
Superior Court of Washington
County of
In re:

Lisa Ann Ugalde Soros No. 10-2-00156-3


Petitioner(s ),
and Declaration of
Paul Anthony
Kevin Rene Brown
April Anthony

This declaration is made by:

Name: Paul and April Anthony

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.

Declaration (DCLR) - Page 1 of __


WPF DRPSCU 01.0100 (612006)
(Attach Additional Pages if Necessary and Number Them.)

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

Signed at Bo-lk.t_ ll [City] W R [State] on 1 / d-(,,, / tD [Date].

fL_.e, b~ f?ctu..J B . JM '#1011.'1


~f d)-araEiJ.t-Jh4W;!- Print"~ Na'i). -Artfhu)/t.0j
Do not attach financial recoriJs, personal health care records or confidenti'a/
reports to this declaration. Such records should be served on the other party and
filed with the court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records will be sealed to protect your
privacy (although they will be available to all parties in the case, their attorneys,
court personnel and certain state agencies and boards.) See GR 22(C)(2).

Declaration (DCLR) - Page 3 of __


WPF DRPSCU 01.0100 (612006)
Apr 27 10 07:45a
p.1

Superior Court of Washington


County of
In re:

Lisa Aon Ugalde Soros .. ( ) No. 10-2-001 56-3


Peuuoner s , .
and ;
' Declaration of
Kevin Rene Brown i Dr. Derek Tucci
. _ .. ·-'-'-~~~~~~?.t(s) j _...... .
This declaration is made by:

Name: Dr. Derek Tucci

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.

(Attach Additional Pages if Necessary and Number Them.)

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

Signed at ------~~!.! ____________ , [City] ----~'.'.! ______ (State] on


'"i /::i.ro / 10 [Date].

______Gk f? ~k Tw;<..l

Signature of Declarant Print or Type Name

Do not attach financial records, personal health care records or confidential


reports to this declaration. Such records should be served on the other
party and filed with the court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial
records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health
records
3) Sealed Confidential Report (WPF DRPSCU 09.270) tor confidential reports
If filed separately using a cover sheet, the records will be sealed to protect
your privacy (although they will be available to all parties in the case, their
attorneys, court personnel and certain state agencies and boards.) See GR
22(C)(2).
FILED
Illf/ / ~/ fIll /If/ //If /llll lllllllllllll
IlllllllllllllCL14102435 ID APR 23 AH 9: 44
SONYA KRASKI
COUNTY CLERK
I SNOHOMISH CO. WASH
3
s
7
9 Superior Court of Washington
II County of Snohomish
13
IS
17
19 No. 10-2-00156-3
21 LISA SOROS,
23 Petitioner,
2S RESPONSE DECLARATION OF
27 and RESPONDENT
29 (DCLR)
31 KEVIN RENE BROWN,
33 Respondent.
3S
37
39
41
43 KEVIN BROWN, Respondent herein, declares as follows m response to the declaration of th
4S
47 Petitioner:
49
SI The Petitioner Lisa Soros and I were divorced in 2003, when our four children ranged in age from
S3
SS ten down to three years old. Since that time, I have been the childrens' fulltime residential parent, by
S7
S9 agreement, with Lisa seeing them alternating extended weekends. See courtesy copy of agreed parenting
61
63 plan, attached as Exhibit A.
6S
67 Since 2003, I have been the parent responsible for caring for all the childrens' needs, basic,
69
71 emotional and physical. I have raised the children serving in the capacity of father and mother. I have
73
7S nurtured, cooked, cleaned, arranged their schedules and taken them to activities such as sporting events,
77
79 school events, social age-appropriate events and surrounded them with the presence of a caring extended

DECLARATION (DCLR) GOLDBl:RG & .JONES. PLLC


Altorneys at Law
WPF DRPSCU 01.0/00 (712003) 1200 Westlake Ave. N., Suite 700
Page I Seattle, WA 98109
206.448.1010

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

DECLARATION (DCLR) GOLDBERG & JONl:S, PLLC


Attorneys ut Luw
WPF DRPSCU 01.0100 (712003) 1200 \Vestlake Ave. N., Suite 700
Page 2 Seattle. WA 98109
206.448.1010
1 the new amount. According to Lisa Soros, she was thrown in jail as she still did not comply with the now
3
5 reduced payments. Recently, she has made only partial payments causing me bank penalties. She has not
7
9 attempted to find and or sustain a job to provide for her children since they were born. It is not redundant
I1
13 to state that Ms. Soros Jost the custody of her four children due to abandonment and neglect.
15
17 Lisa has recently manipulated Taylor, attempting to alienate Taylor from me and undermine my
19
21 discipline with all the children. It doesn't help matters that Taylor is now seventeen and of course has a
23
25 mind of her own like all teenage girls. Lisa provided the two oldest children with cell phones without my
27
29 consent, undermining my parental authority and my household rules to provide my children with
31
33 sufficient rest time at night to perform effectively at school.
35
37 On the night of January 20th, 1 got up to go the bathroom at 1 I :45 P.M. I noticed my son David
39
41 was up and texting on his phone. David has a texting curfew of no later than 9:00 P.M. So I decided to
43
45 confiscate the phone as it is the logical consequence, especially during a school night. After I went to my
47
49 bedroom, I read the text and it contained inappropriate conversations with his peers at school. One boy
51
53 and two girls were also texting him. I also read another text from David to his sister Taylor stating that he
55
57 should have told her boyfriend that she was making out with their cousin from the stepfather's family side
59
61 at their mother's house. At that time, I called David to my room and discussed with him how serious it
63
65 was to send text messages to other girls and how it could result in school disciplinary offenses, not to
67
69 mention demeaning to her.
71
73 Then, I looked at Taylor's room to see if she was awake and noticed that she was using her cell
75
77 phone at midnight (that afternoon, Taylor arrived from school and went directly to bed. I had to wake her
79
up for dinner time). I asked her to come to my bedroom as to not wake up her sisters. She did so and once

DECLARATION (DCLR) GOLDBERG & JONES, PLLC


Attorneys al Law
WPF DRPSCU 01.0100 (712003) 1200 Westlake Ave. N.. Suite 700
Page 3 Seanle, WA 98109
206.448. JO I0
I in my bedroom I asked her why she was using the phone so late in a school night and related it to her
3
5 being always so tired after school. I inquired about the text from David to her in regard making out with
7
9 the boy at her mother's house. She responded" I don't know". I told Taylor that I was going to call her
11
13 boyfriend to request explanations as to why he is talking to her in such inadequate hours and give him
15
17 parameters of adequate times to call her. I asked her to dial the number three times and she denied the
19
21 request. At that point, I told her to hand me the phone and gave her five days of restriction from the phone
23
25 usage and seeing her girlfriends. She immediately assaulted me. She hit me four times in my back and
27
29 yelled at the top of her lungs: "I fucking hate you''. We then got into a physical altercation which ended in
31
33 me calling Ms. Soros and taking Taylor to Ms. Soros' house about I :00 A.M.
35
37 As a result of the incident, I was charged with fourth degree assault and entered into an agreemen
39
41 with the Municipal Court of Bothell to go to domestic violence treatment/classes. I have included proof
43
45 of my participation separately under seal. I know that it was not right of me to get into a physical
47
49 altercation with Taylor, even though she hit me physically. I am the parent and should have reacted bette
51
53 than I did. I cannot imagine reacting the same way again in any similar circumstance.
55
57 While I understand that Taylor currently wants to live with her mother, I am very concerned
59
61 about the other children and the environment at Lisa's home. There are two other eighteen-year-old boys
63
65 living there (my childrens' stepbrothers.) One of them verbally and racially harassed my son David by
67
69 calling him the derogatory name "Nigger". There were not consequences for the young man, other than to
71
73 say he was sorry. David's home should be his safety zone and he should not be ridiculed or made to feel
75
77 inferior at his own home. Lisa also allows Renee and Sarah to leave the home and walk for miles
79
unattended. She puts too much faith on giving them a cell phone versus transporting them to the park. She

DECLARATION (DCLR) GOLDBERG & JONES. Pl.LC


Attorneys at Law
WPF DRPSCU 01.0100 (712003) 1200 Westlake Ave. N., Suite 700
Page4 Seattle, WA 98109
206.448.1010
0

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

DECLARA T!ON (DCLR) GOLDBERG & JONES. Pl.l.C


Attorneys at Law
WPF DRPSCU 01.0100 (712003) 1200 Westlake Ave. N., Suite 700
Page S Seattle. WA 98109
206.448.1010
I overprotective, but it is always thinking of safety first. I love and adore my children and this brief
3
5 separation has broken my heart.
7
9
II
I3 I am asking that the Court order the three younger children returned to me, and that Lisa be
15
I7 required to file a Petition for Modification of the parenting plan, so that we can address these issues in the
19
2I proper place and time.
23
25
27 I declare under penalty of perjury under the laws of the state of Washington that the foregoing i
29
3I true and correct.
33
35
37 Signed at Seattle, WA on April d(.,g_, 20 I 0.
39
41
43
45
47 Respondent
49
51
53
55
57
59
61
63
65
67
69
71
73
75
77
79

DECLARATION (DCLR) GOLDBERG & JONES, PLLC


Allomeys ut Law
WPF DRPSCU 01.0100 (712003) 1200 Westlake Ave. N., Suite 700
Page6 Seattle, WA 981 09
206.448.1010
...

( .,:, /
e
F ILED
'-
2
.. ~· 200~ HAY -4 PH 3: 48
~AM l. [)ANif:LS
3 f.OUNTY Cl f:R''
4 03-3-00314-1 84
• r
· "110Ho1·11su co.
i-ti:sH.
5

7
IN THE SUPERIOR COURT OF WASHINGTON
IN ANO FOR SNOHOMISH COUNTY

\I ln re the Marriage of: )


)
10 ) NO. 03-3-00364-8
USA ANN BROWN.
)
11
Petitioner, ) PARENTING PLAN
12 )
and )
13 )
KEVIN RENE BROWN, )
14 Respondent. )
)
15
1--~~~~~~~~~~~~~)
16
I. GENERAL lNFORMATION
17
This Parenting Plan applies to the following children:

19
Name Age
2ll Taylor Cheyenne Brown I0
David Anthony Brown 8
21 Sarah Michelle Brown 6
Renee Alexander Brown 3
22

23 II. BASIS FOR RESTRlCTIONS

24 2.1 PARENTAL CONDUCT (RCW 26.09.191(l), (2)).

25 Do.:s not apply.

PERMANENT l'ARENTING PLAN Lii W OFFICES


WPF DR II 1.0400 (04/U2) HAi'ISeN M1.-CONNJ:tL &. PELl.IXif(INI 1'1.1.C

RCW 2C>.09. IX I: I X7: 194 1636 THIRD STREET


Pilgc- I MARYSVILLE. WASHINGTON 98270

.ORIGINAL (360) 658-6580 •FACSIMILE (360) 651.e762


l

2 2.2 OTHER FACTORS (RCW 26.09. 191 (3)).


3
Does not apply.
4

5 IU. RESIDENTIAL SCHEDULE

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.

SCHEDULE FOR CHILDREN UNDER SCHOOL AGE.

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 ..

SCHEDULE FOR WINTER VACATION.

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.

PERMANENT PARENTING PLAN LAW OFFICES


WPF DR \I 1.1141111 (04/02) HANSC:N McCONN~LL & l'f.Ll.E<iKINI 1'1.LC.'
RCW 2r•. o•J.IXI: IX7: l'l4 1636 THIRD STREET
Page- 2 MARYSVILLE. WASHINGTON &8270
(360) 658-6580 •FACSIMILE ~60) 651.6762
3.4 SCHEDULE FOR SPRING VACATION (Following published school calendar)

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.

7 3.5 SUMMER SCHEDULE.

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:

I7 With Mother Wi1h Father

rn July Vacation Odd Even


19 August Vacation Even Odd

20
3.7 SCHEDULE FOR HOLIDAYS.
21
The residential schedule for the children for the holidays listed below is as follows:
22

2J With Mother With Father


New Year's Eve Odd Even
24 New Year's Day Even Odd
Memorial Day Odd Even
July 4th Odd Even
Labor Day Odd Even
PERMANENT PARENTING PLAN LAW OFFICES
WPF DR II 1.114011 (04/ll2) HA.'JSEN McCONNELi. &. rELLEGRINI l'Ll.C

RCW 26.09.IXJ: IX7: 194 1636 THIRD STREET


Page· J MARYSVILLE, WASHINGTON 98270
(360) 658-6580 •FACSIMILE (360) 651-8762
Thanksgiving Day Odd Even
Christmas Eve Odd Even
2 Christmas Day Even Odd
.1

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

14 3.8 SCHEDULE FOR SPECIAL OCCASIONS.

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

PERMANENT PARENTING PLAN LAWOFFtCES


WPF DR II 1.114011 (04/02) HANSEN M<CONNELL & PELLEGRINI Pl.LC
RCW 26.0'J.IKI: IX7: 1~4 1636 THIRD STREET
Page- 4 MARYSVtLLE, WASHlNGTON 88270
(360) 658-6580 •FACSIMILE (360) 651-6762
3.10 RESTRICTIONS.
2
The following restrictions apply:
3

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.

x 3.11 TRANSPORTATION ARRANGEMENTS.

9 Transponation arrang.:mems for the children between parents shall be as follows:

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

13 3.12 DESIGNATION OF CUSTODIAN.

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.

PERMANt:rn PARENTING PLAN LAW OFFICES


WPF DR 111.1141111 (114/112) HANSEN McCONNJ-:LL & l'F.Ltf-:(iNINI l'IJ.C
RCW 26.ll'J. I KI: I K7: I '!4 1636 THIRD STREET
Page- 5 MARYSVll.LE, WASHINGTON 98270
(360) 65a-6SBO •FACSIMILE (360) 651-6762
------

. "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.

PERMANENT PARENTING PLAN I-AW OFFICE~


HANSl~N M1..-C<lNNELL & rEl.tEGR1:-.:1 rttc
WPF DR 0 t.04011 (114/02)
RCW 26.09. IX I: I X7: l'l4 1636 THIRD STREET
P:igc· 6 MARYSVILLE. WASHINGTON 98270
(360) 658-6530 •FACSIMILE (360) 651·6762
3.13.9 Children's Involvement. Neither parent shall ask the children to make decisions
or requests involving the residential schedule. Neither parent shall discuss the
2 residential schedule with the children except for plans, which have already been
agreed to by both parents in advance. Neither parent shall advise the children of
3
the status of child support payments or other legal matters regarding the parents' .
4 relationship. Neither parent shall use the children, directly or indirectly, to
gather information about the other parent or take verbal messages to the other
5 parent.

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

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.

PERMANENT PARENTING PLAN I AW OFFICES


WPF DR 01.0400 (04/02)
RCW 26.09.IXI: IX7: 194 1636 THIRD STREET
Page- 7 MARYSVILLE. WASHINGTON 98270
(360) 656-6580 •FACSIMILE (360) 651-6762

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

19 4.1 DAY TO DAY DECISIONS.

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

PERMANENT PARENTING PLAN I.fl W Ol'FJCES


WPF DR 01.0400 (04/02)
RCW2<>.09.IXI; IX7: 1~4 1636 THIRD SlREET
Page· 8 MARVSVILLe. WASHINGTON 98270
(360) 6S8-6$80 •FACSIMILE (360) 651.6762
...

'

MAJOR DECISIONS.

Major decisions regarding each child shall be made as follows:

Educa1ion decisions Joint


Non-emergency health care Joint
Religious upbringing Joint
Body piercing, tattoos
and extreme hair cuts Joint
Sports/Ext racurri cu Iar
Activities Joint

Each parent should have the right to include the children in their own religious activities.

RESTRICTIONS IN DECISION MAKING.

Does not apply.

12
V. DISPUTE RESOLUTION
13
Disputes between the parties. other than child suppo11 disputes, shall be submitted to (lisl person
14
or agency):

111ediation by Snoho111ish County Center for Conflict Resolution, or such other


16 mediator as the parties mutually agree to in writing:

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:

21 In the dispute resolution process:


22
(a) Preference shall be given 10 carrying out this Parenting Plan.
23 (b) Unless an emergency exists, the parents shall use the designated process to
resolve disputes relating to implementation of the Plan, except those
24 related to financial support.
(c) A written record shall be prepared of any agreement reached in counseling
25 or mediation and of each arbitration award and shall be provided to each
party.
PEKMANENT l'AKENTING PLAN I.AW OFFICES
WPF DR 01.0400 (04/02) HANSEN M~-CONNELL &. l'~LLEGRINI I'll.('
RCW 26.09. I KI: I K7; 194 1636 THIRD STREET
P;1gc- 9 MARYSVILLE, WASHlNGTON 98270
(360) 658-6580 •FACSIMILE (360) 651-6762
--- - · - - - - - - - --··-· - - ·-----
''• I -• •

(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

5 VI. OTHER PROVISIONS

6 Does not apply.


7

. VU. ORDER BYIHE COURT

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

21

22

23

24 LISA BRO~\
2.5

PERMANENT PARENTING PLAN I.AW OFFICES


WPF DR 111.1141111 (114/112) HANSEN Mr..-CONNlil.I. R J•EL.tJlGRINI l'Ll..C:
RCW 26.ll'J. IX I: I X7: f >14 1636 THIRD STREET
Page- Ill MARYSVILLE, WASHINGTON 98270
(350) 658.6580 •FACSIMILE (360) 651-6762
• -'. ·AP~le-04

-
13:11 F~Piorra Llaner Mart 208-361-148~ T-503 P.003/003 F-368
. .. ·.
ll •••.•

l CopY Received. Approved for Enay and


Notice of Pm;entation Waived by:
:z
3
MICHliLSON. WSBA#ll239
4
1me;1£..10r Respondent
s
6

IU

ll
12

13

14

lS
16
11

18
111

20

:ZI

22

23

24

25

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

LISA ANN UGALDE SOROS CAUSE NO.: 10-2-00156-3


(PETITIONER) PRO TEM COMM: LAURA CHRISTENSEN COLBERG
AND CLERK: HOLLY M. BEAL
KEVIN RENE BROWN DATE: 04-30-10 ® 1:00 P.M.
(RESPONDENT) DIGITALLY RECORDED

THIS MATTER CAME ON FOR: DOMESTIC VIOLENCE HEARING


CONTINUED DATE/TIME/CALENDAR AND CONTINUANCE CODE:
HEARING DATE SET/TIME/CALENDAR CODE:
ACTION:
HEARING STRICKEN/CODE:
. PETITIONER APPEARED: YES COUNSEL: PRO SE
RESPONDENT APPEARED: YES COUNSEL: SHERRIE BENNETT
GUARDIAN AD LITEM APPEARED: NOT PRESENT
FACILITATOR PRESENT: YES

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

'
' ·'

Superior Court of Washington Order for Protection


For Snohomish County
~-----------I
N
o.
10 2 O0 1 5 6
L\"5/.. Ml" I \t1MN?SDP«S q{\ Ira!> Court Address: 3
Petitioner (First, Middle, Last Name) DOB 3000 Rockefeller Ave., Everett, WA 98201
vs. Telephone Number:(425) 388-3638
l<af\ ~ Q.Et..\E:. 10'20~ 1o l3LILM (Clerk's Action Required) (ORPRT)
Res ondent (First, Middle, Last Name) DOB
Names of Minors: D No Minors Involved Res ondent Identifiers
First Middle Last Age Race Hair
QMl\t? M'1WM\l Q?~ 'Ir-

Caution: Access to weapons: Dyes~ no D unknown


'"'
The Coult Finds Based Upon the Courl Record:
The court has jurisdiction over the parties, the minors, and the subject matter and respondent has been provided with
~onable notice and an opportunity to be heard. Notice of this hearing was served on the respondent by
jS.personal service D service by mail pursuant to court order D service by publication pursuant to court order
D other ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-

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

Respondent is Prohibited from knowingly coming within, or knowingly remaining within


I
00~ D/ (distance) of: petitioner's -2Sl'residence D workplace
D school; !&the day care or school of~ the minors named in the table on page one
D these minors only:
DOther:
9. Respondent shall participate in treatment and counseling as follows:
domestic violence perpetrator treatment program approved under RCW 26.50.150 or

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:

6. Respondent is Restrained from interfering with petitioner's physical or legal custody of


Sthe 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:

Order for Protection (ORPRT) - Page 4 of 5


WPF DV-3.015 Mandatory (712009) - RCW 26.50.060
S:\FORMS\FCOURTSERVICES\Master Forms\One Year Protection Order.doc
This Order is in Effect Until the Expiration Date on Page One.
If the duration of this order exceeds one year, the court finds that an order of one year or less will be
insufficient to prevent further acts of domestic violence.

Dated: . . L~~~Oy1_'2.~D~l~O____ at _ _ _-i~:_1_0_ _ _ _ a.mEJ


---"A. . . f>~P-~I

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.

Order for Protection (ORPRT) - Page 5 of 5


WPF DV-3.015 Mandatory (712009) - RCW 26.50.060
S:\FORMS\FCOURTSERVICES\Master Forms\One Year Protection Order.doc
FILED
2 IO MA~ 14 Pt'! 3: 20
3 SONYA KRASKI
COUNTY CLERK
SNOHOMISH CO. WASH
5

7 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


FOR SNOHOMISH COUNTY
8

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

NOTICE OF APPEARANCE SHAPIRO & FREITAS


210 Summit Avenue E
Seattle, Washington 98102
(206) 328-7362
F~LED
'

\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:~

LISA A. UGALDE SOROS CAUSE NO.: 10-2-00156-3


(PETITIONER) COMMISSIONER: SUSAN C. GAER
AND CLERK: P.GORDON/P.BUNDY
KEVIN R. BROWN DATE: 2-24-10 @ 1:00 P.M.
(RESPONDENT) DIGITALLY RECORDED

THIS MATTER CAME ON FOR: DOMESTIC VIOLENCE HEARING


CONTINUED DATE/TIME/CALENDAR AND CONTINUANCE CODE: 4-30-10 @ 1:00 P.M. (VP)
HEARING DATE SET/TIME/CALENDAR CODE:

ACTION: DOMESTIC VIOLENCE HEARING


HEARING STRICKEN/CODE:

PETITIONER APPEARED: YES COUNSEL: PRO SE


RESPONDENT APPEARED: YES COUNSEL: JEFF WADE
GUARDIAN AD LITEM APPEARED: NO
FACILITATOR PRESENT: YES

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:

REISSUANCE OF TEMPORARY ORDER ENTERED AT THE REQUEST OF THE RESPONDENT.


THE COURT WILL ALLOW RESPONDENT TO HAVE SUPERVISED TELEPHONIC CONTACT
WITH THE CHILDREN THROUGH A THIRD PARTY.

1 MINUTE ENTRY
I 0 FEB 24 PH I: 2 1

i, I111111111111111111111111111111111111 \ll\l l\1\111111 Ill\ \Ill


CL13742600
SONYA KRASKI
COUNTY CLERK
SNOHOMISH CO. WASH
\_ -

SUPERIOR COURT OF WASHING TON


FOR SNOHOMISH COUNTY
~-I- i:;; ~
)_ JSA 4&:W' u ~.4( l\r -S c:ilf;o s.
Petitioner (first,middle,last) DOB REISSUANCE OF TEMPORARY
vs. G - 3-(;,b ORDER FOR PROTECTION AND
ket>/A/ &eVe BIPd.JA)....___ NOTICE OF HEARING (ORRTPO)
Respondent (first,middle,last) DOB (Clerk's Action Required)

~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

D ;::~:~~J?slm~~ic;e ~~fthis order.


DATED c;z/d-'f/lo at I: ('3 a.__-

~ ~ 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:

10 LISA ANN UGALDE SOROS, NO. 10-2-00156-3


Petitioner,
11
and
12 NOTICE OF APPEARANCE
KEVIN BROWN,
13
Res ondent.
14
TO: The Clerk of the Superior Court of Snohomish County:
15 AND TO: Lisa Ann Ugalde Soros.

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

19 at 1200 Westlake Ave. N, Suite 700, Seattle, WA 98109.

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

DECLARA TlON (DClRJ


WPF DRPSCUOl.0100 (712003)
Page 1

\~
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

SUPERIOR COURT OF WASHINGTON


FOR SNOHOMISH COUNTY

NO. \0 - '2... - 00 \IQ{O - 3


L1c;:,t>. Ai-.i"1 Ue::iM....-cE:..>~t20s
Petitioner/Plaintiff(s),

vs. COVERSHEET

Respondent!Defendant(s).

AlTACHED HERETO IS:

Cproeehc.. V10\en:.c.- !\lo -(,_q)tac.t Orde..'(' : ?a*, <CY1v1ct10n

Pl.2: C.o.<Se Po.~ ~~ . \an. '2001- ~


5tam ot, INO.-s\tli°..gton
\.Joe-\¥\~ ffiyv?c\ootvs: l ~r ?;rert ~I. frD.90
~a\eyyent q Dr.1..lea.n 5:?.\rez

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 .

Domestic Violence No-Contact Order (NOCON/ORNC) - Page 1 of 2


CrRLJ 07.0900 - (6/2006) RCW 10.99.040, .045, .050
Ex~ll?JIT A
~\0-'2-00 \5':>-3

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. -

Done in open court in the presence of the defendant this date:_~)~·~/~;::i~·-·~-/~·?_·0_·'~/~(~)______

Judge Michelle K.--Gehlsen / /

--~)-->,/~;:7-::_ -----
~-""'--'-~~~~~~~~-0:~~--
Rhonda Giger,~W BA No_ 28322 Attorney for Defendant Defendant
Paul Byrne, WSBA No_ 41650 WSBANo.
Assistant City Attorney Print Name:

Domestic Violence No-Contact Order (NOCONIORNC) - Page 2 of 2


CrRLJ 07.0900 - (6i2006) RCW 10.99.040, .045, .050
~0(1 e.
~ \0-2- OO\t;;{e.-3
September 2009
Mon Tue Wed Thu Fri Sat Sun
~ 1 2 3 4 5 6
L~~ r: - - Be.<0r o~_ _61<01~~
1;-0.-:-: ~ ~ -_q:: Sc\-\COL- QE:~L-
,, A

.-. .. ~-- .....~-·-'- t)- - ~V\6\fJ~ BTW~


~ Ll? \\-\-- • - '

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


l<eS\~-kL = \..A~ __,_.


(~loeWJ~___::_:E~--- - - J
You'll get more great calendars (and this notice disappears) with CalendarsThatWork.com Full Access.
-,-001~-3'.
"''
tSl
~
State of Washington
Division of Child Support
Case Payment History 4126/2010 8:22:45 tw. - 4724
tSl
n. NCP: UGALDE, LISA ANN CFO: Everett
CP: BROWN, KEVIN R IV-D Case#: 1757166
ro Monthly Child Support: 497.73 DSHSAm;: o.oo CUIT Support 01.ie: 497.73
'"'
""'roM
Monthly Medical Support: o.oo OSHS Med Arrs: o.oo Cu!T Medical Due: 0.00
TempArrs: o.oo
Monthly Order Ami: 497.73
"Lil CPArrs: 497.73 .. Disbursed: 30,635.15
Annual Fee Due:
"'" Annual Fee Paid:
0.00
25.00
CP Medical AITS: 0.00 Retained:
Retained: Medical:
995.46
0.00

Receivable: 184.18 Total Owed: 995.48 Total Amount Paid: 31,630.61

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

Total Case Payments printed for IVD # 1757166: 28


Date Range requested· From: 01/01/2008 To: 04/26/2010

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

Receivable: 1B4.1B Total Owed: 995.48 Tolal Amount Paid: 31,630.61

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
u
Q Total 4,479.57 0.00 0.00 0.00 0.00 0.00 0.00 25.00 0.00 4,479.57
I-
I-
Total Case Payments printed for IVD # 1757166 : 9
UJ

"':::>
UJ
UJ
I Date Range requested - From: 01101/2007 To: 12/31/2007

If)

"'
~

-
ISi

~I
<1l
N
I

& Page:~
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
._GX\-\\0\:f_ Q~
:i:l-10 -:2.- 00\5(p - ~

Cati Sandoval
North Seattle Orthodontics
cati@northseattleortho.com
206-523-1047

North Seattle Orthodontics, Ors Lyons and Gunsolus


Seattl.=e---------------------------"M,,,o,,,nd,,.,ay,_1\oril 26,~11:04 AM
Ledger Copy Taylor Brown (080037)
By Responsible Party for Responsible Party: Lisa Ugalde Soros

Date Patient Dr Cl Descriet1on of Service Amount Cha!Jles Paxments Current Total


Usa Ugalde Soros
3/18/2009 Taylor 100 116 Credit Card -300.00 -300.00 -300.00 -300.00
3/26/2009 Taylor 100 116 SS Full Tx - Contract 4,750.00 -300.00 4,450.00
3/26/2009 Taylor 100 116 SS Full Tx - Initial Fee (Contract) 300.00 300.00 0.00 4,450.00
3/26/2009 Taylor 100 116 Courtesy Discount -100.00 0.00 4,350.00
4/112009 Taylor 100 116 SS Full Tx - Contract Charge 300.00 300.00 300.00 4,350.00
4/14/2009 Taylor 100 116 Credit Card: CC 10th -300.00 -300.00 0.00 4,050.00
5/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 300.00 300.00 300.00 4,050.00
5/11/2009 Taylor 100 116 Credit Card: cc 10th -300.00 -300.00 o.oo 3,750.00
6/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 300.00 300.00 300.00 3,750.00
6/11/2009 Taylor 100 116 Credit Card: CC 10th -300.00 -300.00 0.00 3,450.00
7/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 300.00 300.00 300.00 3,450.00
7/13/2009 Taylor 100 116 Credit Card: cc 10th -300.00 -300.00 0.00 3, 150.00
8/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 3,150.00
8/11/2009 Taylor 100 116 Credit Card: CC 10th -210.00 -210.00 0.00 2,940.00
9/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 2,940.00
9/14/2009 Taylor 100 116 Credit Card: cc 10th -210.00 -210.00 0.00 2, 730.00
10/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 2, 730.00
10/12/2009 Taylor 100 116 Credit Card: CC 10th -210.00 -210.00 0.00 2,520.00
11/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 2,520.00
11/3/2009 Taylor 100 116 Insurance to Resp Party -100.00 210.00 2,420.00
ll/ 11/2009 Taylor 100 116 Credit Card: cc 10th -210.00 -210.00 0.00 2,210.00
12/1/2009 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 2,210.00
12/14/2009 Taylor 100 116 Credit Card: cc 10th -210.00 -210.00 0.00 2,000.00
1/1/2010 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 2,000.00
1/11/2010 Taylor 100 116 Credit Card: CC 10th -210.00 -210.00 0.00 1,790.00
2/1/2010 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 1,790.00
2/11/2010 Taylor 100 116 Credit Card: CC 10th -210.00 -210.00 0.00 1,580.00
3/1/2010 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 l,S80.00
3/11/2010 Taylor 100 116 Credit Card: CC 10th -210.00 -210.00 0.00 1,370.00
4/1/2010 Taylor 100 116 SS Full Tx - Contract Charge 210.00 210.00 210.00 1,370.00
41111Jn1n Trivlnr 1nn 111; rrMit r;:11m· rr 1nth -J1n nn -J10M n.nn 1 u;n nn
6)(~1?>\\ 0
~ \0-2.-cx:nlO<o- ~

... , ............. . .

Ledger Totals as of 4/26/2010 3,390.00 -3,39D.OO 0.00 1,160.DD

.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

Date Rese Dr Cl Descrtetion of Service Amount Cha!:Bes Pai:ments Current Total

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

Ledger Totals as of 4/26/2010 1,100.00 -1,100.00 0.00 0.00


APR/25/2010/SUN 04:51 PM PED. ASSOC. BELLEVUE FAX No. 425-828-2256 P. 002
EX\-\\~rr E::-
q.Jedi ii.c df.1-1.ociale.1-, flnc., q.J_~,..., 10- -i. -001 rsio - 3
www MyPediatricAssociates.com

• 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

. [, wV\.CJVI;\ l f µ""') Uvt62vv\ '.

Tk-1 s <s to v..wi ~ ~ 7. , ~ s;"" t-.s Lib,


~ '1etvl ~ pYi~p~aM,~T~tgV
Cil (q /qs), ~
(()obVi.{cr;;/o,?::>), !MVid
(Oob i?(f?(cw)~ <;a.v.d-i {10(<8/ct+) SW!~~
~ ~0'1wvi<; J • p.ev ~ lk..L£l ( ~; ~

CJN- l~ L1ave. ~ ~LJ- ~ 0J ~


~) !rt<;""' ~.wos er ~r-}'"' ~, at
• '1~°'-<.S ~ -fW ~ ·, (( •./1 .,..,:TI ~
IA:'Q.t -d;.JJ dAodLUf.r •

PA-118 REV. 01/09


04/26/2010 14:30 2065460572 AVENUE COPY CENTER PAGE 02
EJ(.\tt~tT F-
Steve Hammil Counseling ~ID - 2-- 00\S<o- o
1314 NE 43'" St. Ste. ll3
Seattle, WA 98105
206-501-3920

April 20, 2010

To Whom It .May Concern,

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

::ffet {. ~"It' cf;(, t,,,t'le--


Flora Ostrow, M.ED., .LMHC
Supervisor
~-H1 !?IT <':::f
lO -'2.- 001% -3

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

Spi2Uce, SLE.M6i-ITAc\2:'\ (.'· F'~~'?.")


flA"\&iQOU~O ~ -F-\cl-0
0(-tt\0rl 1-\-
10- '2-- oO\SIP- 3

Lisa A. Ugalde Soros

Work History
Total Motion Release Seminars: Raleigh, NC - 2006 - Present
Seminar Coordinator
Thomas H. D'Alonzo Baker - Owner

AAA of Washington: Issaquah, WA 2005 - 2006


Travel Specialist
4008 173rd Place SW
Lynnwood, WA 98037 Linda Allen - Manager
T 206.910.3581
F 425.361.1149 Paper Zone: Shoreline, WA 2004 - 2005
lisa@totalmotionrelease.com Sales Associate
www.totalmotionrelease.com
Demonstrator
Terri Geraurd - Manager

The Home Depot ( #4706 ): Seattle, WA 2003 - 2004


Pro Desk Sales Associate
Mark Dillingham - Pro Desk Supervisor

Crafts Galore: Chehalis, WA May 2003 - August 2003


Sales Associate
Susan Cumberland - Manager

Travel One Cruises & Tours: Redmond, WA 1999 - 2001


Travel Specialist
Office Manager
Robert Neal - Owner

L. Brown Consulting: Bothell, WA 1998 - 2000


Computer Consultant
Travel Systems Specialist ( Delta Airlines & United Airlines )

Mercer Island Travel: Mercer Island, WA 1996 - 1998


Head Corporate Travel Agent
Linda Allen - Manager
EXHietT It-
-:& \0-'2..-00\'5fo-3

Education
Hawaii Loa College, Kaneohe, HI - BS Economics and International Business
January 1989 - December 1991

Traveler's Choice Vocational School, Honolulu, HI - Certified Travel Agent


September 1987 - December 1987

4000 173rd Place SW


Lynnwood, WA. 98037 Sorbonne University, Paris, FRANCE - Semester Abroad French Language Studies
T 206. 910. 3501 January 1987 - June 1987
F 425.361.1149
lisa@totalmotionrelease.com
www.totalmotionrelease.com
Whitworth College, Spokane, WA- Freshman & Sophomore Years: Political Science/Pre-
Med September 1985 - December 1986

Pacific Lutheran University, Tacoma, WA - College Transition Summer Term


June1985

Kalaheo High School, Kaneohe, HI - High School Diploma


June1985
'" ' ..... :::::. ••• i,.

'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

14 TO: Clerk of the above-entitled Comt and


TO: Sherrie Bennett, Attorney for Respondent
15
YOU AND EACH OF YOU please take notice that Veronica Freitas, Attorney for Petitioner,
16 hereby appears in the above-captioned cause, requesting that all fmther papers and pleadings herein,
except original process, be served upon the undersigned attorney at the address stated below.
17
PLEASE NOTE: We do not accept service by fax unless agreed by prior arrangement.
18

19 DATED September 29, 2010.

20 Respectfully submitted,

21

22
VERONICA FREITAS, WSBA #19405
Counsel for Lisa Soros
23

24

25

26

27

28

NOTICE OF APPEARANCE V.FREITAS LAW,PLLC


210 Summit Avenue E
Seattle, Washington 98102
(206) 328-7362
,.,

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

14 TO: Clerk of the above-entitled Court and


TO: Sherrie Bennett, Attorney for Respondent
15
YOU AND EACH OF YOU please take notice that Veronica Freitas, Attorney for Petitioner,
16
hereby appears in the above-captioned cause, requesting that all further papers and pleadings herein,
except original process, be served upon the undersigned attorney at the address stated below.
17
PLEASE NOTE: We do not accept service by fax unless agreed by prior arrangement.
18

19 DATED September 29, 2010.

20 Respectfully submitted,

21

22
VERONICA FREITAS, WSBA #19405
Counsel for Lisa Soros
23

24

25

26

27

28

NOTICE OF APPEARANCE V. FREITAS LAW, PLLC


210 Summit Avenue E
Seattle, Washington 98102
(206) 328-7362
Sno Co Evorott Dist Court 4253.883912 .... P.01/01 '
DEC-15-2010 12:.49
'.. 4U2KL../.Yll.
--11--.-v'.· ' "
MONTH:. .NOVEMBER2010
Program:T~: ··~ifo vio1ence' MONTHLY STATUS REPORT ·
.
Branch LoaitiOn:. North seaine · . ':
·r· ."' , ... '
ea.a#: ";· '~ '.
.
' Cl'eete1f on': "
Repol1ing To: Superior Court of :.Vashlngt°" Snoholfish Co1J1t)'
·30!\0 t:iockeletler Avo,:~is 602 ·
Everett.Washington 982Q1 .··

; ..
Patient Name: ~nR.Brown .... CliUnt DOB:
Start Date: 4i<912oio . CurrO<ht TX Modality: Phase II Group
-- . . . . ·. .
- - - - - ; - -··---' ·..

., " ·~ .. ''
i\ttendance and Part!C'P'31lm:·"
' .
1.,· ·.: . .
Coinpliant

• D•tcs of Setvice foc. Curren! Montti:



. '• ' I. :
.:
'.
DV Phase !Group: 1.11512010, 11112'2010, '1111.912010
. , . ' ' . ; . '· .. ' ,,
'. '

• Overall.COmpliance:' _Compliant_ _ .-~.,-,-.-~-


'.
Adtlitional Comments: •
Mr. er°"" Is near the end.of.Ptiase 11 .. He repOiiS' he is now hell!lllr. rramed tin hes oo.golrlg problems with hi& ex-wife; .;,,,o
seems ro enJ0y,Stia.ving up ar. th& i:tuldren's SJJ0111ng ~<e!1ts on ~is ~ot< end );~its •nd he has IO leave. His ollfi '8id·."lt\Js lo
gOOd luck because man onlyaimos to tllegameswl'.en ~ore herel'. Thecllffa,ras no Idea why dad'""""• and does!)' · ...
come back until EhQ game is (jl/et. He states hi' ex--wll'e has beef\ re-rl"Qn1ed fOr a !Mtile now so ne c8nnoc figure out wtty she ,
does 11\IS.' In ;·January he wiii't>o al1lendmg monthiY·.gro.11i sesstoris. : ·' . . . · , '.
,. ;
.,
If you have any ciusstions or ooncems please contnct the ~unselor(s)'liSted below.
t '·

r • I • J, •
.. I· '" ..
1 1_,.
Case M~er. Cheri ShoeCraft, LCC, DVaT C!>:lun9elof : ' Supe!Vfsor.
. ' ·1 ' ' ,.

·· - - - - -- - - - - - - - . - - - - . - - A£i-f'Ad,,";;-i;;., - -- - - - - - - - - - - - .. - -. .· - - . .. '
~
• • '!
u;.,-0~~
l i
~
I;'
'~
"'1"'
.\ '
'' l, I =-~~' J ' ~ ' ' •\ "I • 0
l.
!hat tho aboYQ infomuraon haa bc-::n f"lilv ..,Yed and GQntlnned wilh the case~ ta be~ . ., ,
. . ; \ . ' l ' ,, ,•. ' . ' f
'"
I!•,
I , • •,'
•'" . 't1
''
Teta I.ff! Rote. ASHAdrrtni!ilrBtive Dlreclor · - KareyKing.'BVOP.;_a>~·, ·. "
~ ~ Spanis/1A'J,,~n1,s1mtor _ c~~nMxfwrh.N~~~~~
' •. '! "
I'
1·~ Hl~, ~'3n6v.=~nyLsa:J
-',•I•.''• '-· ,
Jason All>k>, A"'1-.iror , ,.
·- .\I ' • ,

--··----·--""':ABH:Nortils~9ti~:72111 N":'N"~ith9;1;~:&i-irn21272;2-s;;-tt1.;-w;.;9s133-- ~-;;---- ...,


•:,. l
. . Phone.(20Ef) 781-2661 ·, Faii (206) 781-~749 . . . . . . .· , , .. ,
··· . --·---..-'-·~.-.. ----·--·~·-.···.--- .... ~~~--··----:..-~r--·-:---·-·· --·--·-- ··-.-······ -.. - .. ·1·~-- .. -·-· - - · 't.·•

Thi, compliance~ rvta&?11y.t'?_tres~ ~~:>!' ~~~HC. ~-egetiq innoWllt'j~detennlne Olm~ 11 ., . •


ou\side ol lhl• agency. 'TN$ inronMtion ""? bcen iliscl"*" "you fronlteoords wno.., oonlidontlallty <S prototted by-al low~,,Fed«ol
«guJatlons (4~ CFR PART2) prohibit \'OUflan ma1an1 eny lunh"'dsdo&wol h 1\111\ou! lhe Spoc:illc Wlfaal """""" ollhe pe1501 !O·.: ''
whom it pottafns, au o1ho!wloe- by Sodl mp.._. A~ l!IJlhoriz<nion fl>' hn!I°""' o< medcOI O' Olhet inbmo<lorilo'
.· .. ' ~' · ' not'sumdentfotthi,purµQse.1 · .. ·.- 1··:
; I· ' • ·~ ' :, '• ' I:
I "1
.. '.··· ·'.'
,'j '

..
,

'··
''
.; .. ~ '.
•J '

·'
"' :. ! .•• ·; .

'" ''
'I )

'·.
'"
Copyright 1-:J 201u· As~~l!l;f BeMviorui l+?Slth cure. lr.c. All Tights r~
'"
' ,. I I

"
"

"
.., '

You might also like