Court Date Set

Court papers were filed today, May 1, 1998 and Keith and the ex will be going to court June 19, 1998.

This time Keith has an attorney.

“Regarding Child visitation: checked OTHER: Specific (see Declaration), modify existing order filed on 11/29/90. Ordering: A. Mutually agreed upon B. Not to remove the minor children from the State of CA. (See declaration)

Regarding Child Support: Checked Modify existing order: date filed 12/21/95. Ordering: $350 per month per child.

Regarding Spousal Support: Terminate existing order. Modify existing order filed on 11/29/30 ordering: reserve jurisdiction.

Attorney FEES and COSTS: $2000.

RESTRAINT ON PERSONAL CONDUCT: PETITIONER (EX)

a. shall not molest, strike, threaten, sexually or otherwise assault, or otherwise disturb the peace of the other party

b. shall not contact or telephone the other party

c. except that peaceful contacts relating to minor children of the parties shall be permitted.

OTHER RELIEF: See Declaration

FACTS IN SUPPORT of relief requested and change of circumstances for any modification are: contained in the attached declaration.

RE: VISITATION: That notwithstanding the terms and conditions of the Judgment of Dissolution filed with this Court on November 29, 1990, Petitioner, without m y verbal or written consent, in or about February of 1993, moved to the State of WA with our minor children. Because I was without funds at the time, nor was I represented by counsel, I was without the necessary funds to do anything about Petitioner’s unlawful move.

That, the Judgment of Dissolution states in substance with regard to this issue that your Declarant’s visitation with the children would be consistent with mutual agreement. The unfortunate fact of the matter is, visitation is in accordance with Petitioner’s dictates. I am allowed visitation only when Petitioner says so, for so long as Petitioner says and only if your Declarant pays for all costs of visitation.

That, your Declarant requests the following visitation with our minor children:

a. one half of the summer vacation;

b. Every Spring (Easter) vacation;

c. Every Father’s Day weekend;

d. The children’s birthday weekends in ever even numbered year (that is, the first weekend after the children’s birthday from the applicable Friday to the following Sunday);

e. Christmas vacation (of approximately two weeks in every odd numbered year, and,

f. Alternating major holiday weekends.

Additionally, I am requesting that I have daily unobstructed telephone contact with our minor children.

That, regarding the costs of transporting the children, I am requesting this Court make the orders discussed below.

REGARDING CHILD SUPPORT: That, I request this Court order guideline in accordance with my actual income (including the FAMILY CODE hardship deductions to which I am entitled) and Petitioner’s actual income or imputed income. Additionally, I request that this court terminate the wage assignment deduction for child care, as our children have not had child care for some years.

REGARDING SPOUSAL SUPPORT: that, as Petitioner has remarried, I request that this Court terminate the Court’s jurisdiction over the issue of Spousal Support.

REGARDING ATTORNEY FEES/COSTS: That, this OSC only becomes necessary as a direct result of Petitioner’s unlawful move, her lack of dealing with your Declarant in good faith as it relates to visitation, telephone contact with our minor children, child care costs, child support, or the requested restraining orders as set forth below. Accordingly, it is requested that this Court order Petitioner to contribute to my attorney’s fees of two thousand dollars and my actual costs.

REGARDING RESTRAINT ON PERSONAL CONDUCT: That, it is requested that this Court enjoin and restrain Petitioner from contacting your Declarant for any reason other than regarding necessary contacts regarding our minor children (i.e.: emergencies, visitation, travel plans regarding our minor children, etc.) Unfortunately, Petitioner calls your Declarant and upsets my entire household with her mean comments;

REGARDING OTHER RELIEF: That, because of Petitioner’s unlawful move out of state, it is requested that this court order Petitioner to incur the costs of all transportation;

That, this Court order your Declarant and Petitioner to each maintain our minor children on policies of medical/dental insurance, and to each pay an equal share of any uncovered medical/dental costs regarding care and treatment to our minor children. Additionally, it is requested that this Court order each party to contact the other regarding any non-emergency medical care and treatment prior to any such treatment (other than normal check ups and treatment for common medical conditions) if contribution from the other is contemplated. Petitioner will typically incur certain costs without the courtesy of an explanation or a copy of the billing or proof of payment;

That, this Court enjoin and restrain Petitioner from interfering with my mailings to our children. Unfortunately, Petitioner will intercept letters, cards and gifts that I have mailed to our children and return same or discard same. It is important for our minor children and certainly in their best interest to know that their father is thinking of them, and it is cruel for Petitioner to interfere with that aspect of my relationship with our children;

That, it is requested that this Court enjoin and restrain Petitioner from making any disparaging comments about your Declarant (or my wife) in the presence of our minor children. Unfortunately, Petitioner speaks very badly about your Declarant in the presence of our children and I am requesting that this Court put a stop to that conduct; and,

That, it is requested that this Court order Petitioner to transport the minor children to the applicable airport (or other location of commercial transportation) as such time(s) as it becomes necessary regarding your Declarants visitation rights. Petitioner has threatened in the past not to take the children to the nearest airport unless I pay for her gasoline (this demand coming from the very person who violated the Judgment of Dissolution by moving out of state- a move which has substantially interfered with my relationship with the minor children.

I have read this Declaration and affirm to the truth and accuracy of the content. My signature under penalty of perjury appears on the Application For Order and Supporting Declaration filed with this declaration.