Date: 06-16-2015

Case Style: In re the Marriage of: TLM and JWM

Case Number: FD-2014-*

Judge: Stephen Clark

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: John M. Eagleton

Defendant's Attorney: Bradley Gundy

Description: Tulsa, OK - In re the Marriage of: TLM and JWM - (Family and Domestic: DIVORCE WITH MINOR CHILDREN)

PETITION FOR DISSOLUTION OF MARRIAGE
COMES NOW the Petitioner, TLM, for cause of action against the Respondent, JWM, alleges and states that:
1. Residency. Petitioner is now and has been for more than six (6) months preceding the filing of the Petition herein an actual resident, in good faith, of the State of Oklahoma, and a resident of Tulsa County, for thirty (30) days at the time this Petition is filed.
2. Date of Marriage. The parties were married on *, *, at Tulsa, Oklahon and have been since that time and are at the present time husband and wife.
3. Children. Of this marriage there are two (2) minor children, namely:
a. B.W.M, born *; and,
b. C.D.M, born *.
4. Wife is not now pregnant.
Attached and made a part of by this reference is Petitioner’s Affidavit in compliance with the requirements of the Uniform Child Custody Jurisdiction and Enforcement Act.
5. Grounds. As grounds for Dissolution of Marriage, the Petitioner alleges that a state of complete and irreconcilable incompatibility has arisen between the parties which has completely destroyed the legitimate aims of the marriage of the parties and rendered its continuation impossible, by reason of which the Petitioner is entitled to a decree of Dissolution of Marriage from the Respondent.
6. Custody and Visitation. The Petitioner is a fit and proper person to have custody of the minor children of the parties and that custody of said children should be awarded to the Petitioner, subject to the right of the Respondent to visit with the children at reasonable times and places.
7. Child Support. The Respondent should be ordered to pay child support in accordance with the child support guidelines.
8. Alimony. The Respondent should be ordered to pay alimony for support to the Petitioner.
9. Separate Property. Prior to the marriage, Petitioner and Respondent owned property which property should be set aside to them respectively.
10. Marital Property. During the marriage, the parties have acquired certain property, which the Petitioner asks be divided equitably between the parties.
11. Debts. During the marriage, the parties have acquired certain debts which the Petitioner asks be divided equitably between the parties.
12. DHS. Petitioner has received no payments from the Department of Human Services (DHS) and, to the best of Petitioner’s knowledge; the Respondent has received no payments from DHS.
13. Attorney’s Fees. The Respondent should be required to pay the Petitioner’s attorney’s fees.
14. Temporary Order. By separate Application, the Petitioner seeks a Temporary Order granting her temporary relief in addition to the Automatic Temporary Injunction provisions.
WHEREFORE, premises considered, the Petitioner prays that upon hearing this cause the Court grant and award to the Petitioner:
a. A decree of Dissolution of Marriage;
b. Custody of the minor children, with specified reasonable visitation privileges to the Respondent;
c. All separate property acquired by her prior to marriage;
d. A fair and equitable division and distribution of the property accumulated by the parties;
e. Child support;
f. Alimony for support;
g. Attorney’s fees; and,
h. Such other and further relief to which Petitioner may be entitled.

APPLICATION FOR TEMPORARY ORDER
Comes now TLM, Petitioner, and for her Application for Temporary irder she states as follows:
1. Reference is made to Petitioner’s Petition filed contemporaneously herewith. All allegations contained therein are adopted hereby and are incorporated herein by reference.
2. AUTOMATIC TEMPORARY INJUNCTION ORDERS. The orders contained within the Automatic Temporary Injunction Notice herein should all remain in full force and effect, to wit: Both parties should continue to be restrained, enjoined and prohibited from:
A. Molesting or disturbing the peace of the other party or the children of the marriage.
B. Disrupting or withdrawing the children of this marriage from an educational facility, program, or day-care where the children historically have been enrolled.
C. Hiding or secreting the children of this marriage from the other party.
D. Removing any children of this marriage beyond the jurisdiction of the State of Oklahoma, acting directly or in concert with others, except for vacations of two (2) weeks or less duration, without the prior written consent of the other party, which shall not be unreasonably withheld.
E. Selling, mortgaging, encumbering, transferring, loaning, giving away, concealing or in any way disposing of, without the written consent of the other party or an order of the Court, any marital property, except:
(1) in the usual course of operating a business;
(2) for the purpose of retaining an attorney for the case; or
(3) for the necessities of life.
Each party shall notify the other party of any proposed other expenditures, and shall account to the court for all such expenditures made after this injunction went into effect.
F. Intentionally or knowingly damaging or destroying the tangible property of the parties, or either of them, including, but not limited to, any document that represents or embodies anything of value.
G. Making a withdrawal for any purpose from any retirement, profit-sharing, pension, death, or other employee benefit plan or employee savings plan or from any individual retirement account or Keogh account.
H. Withdrawing or borrowing in any manner all or any part of the cash surrender value of life insurance policies on either party or their children.
I. Changing or in any manner altering the beneficiary designation on any life insurance policies of either party or any policy of their children.
J. Canceling, altering, or in any manner affecting any casualty, automobile, homeowners’, or health insurance policies insuring the parties’ property or persons.
K. Opening or diverting mail addressed to the other party.
L. Signing or endorsing the other party’s name on any negotiable instrument, check, or draft, such as tax refunds, insurance payments, and dividends, or attempting to negotiate any negotiable instruments payable to either party without the personal signature of the other party.
M. Regarding insurance, both parties are ordered to maintain and keep in force all presently existing health, property, vehicle, homeowners’, life and other insurance which you are presently carrying on any member of this family unit, or property or vehicle, and to cooperate as necessary in the filing and processing of claims. Any employer provided health insurance currently in existence shall remain in full force and effect for all family members.
3. ADDITIONAL TEMPORARY ORDERS REQUESTED. In addition to the aforesaid Automatic Temporary Injunction Orders, Petitioner requests entry of the following temporary orders, to wit:
4. Temporary custody of the said minor children should be awarded to Petitioner and Respondent should be awarded standard visitation with them.
5. For purposes of computing child support under 43 O.S. Section 118 and 119, Petitioner earns or should be attributed gross monthly income of $* and Respondent ears or should be attributed gross monthly income of $*, which combined parental income is *% and Respondent’s is *%. At present, work related child care expense the Child Support Computation form attached hereto Child health insurance does not presently exist for the children. Respondent should be ordered to pay to Petitioner child support in accordance with the attached Child Support Computation for and all the orders contained in said Child Support Computation form should be entered as temporary orders of the Court.
6. Each party should be restrained and prohibited from disposing of or encumbering any interest in property during the pendence of this action, whether such disposition be by sale, gift, encumbrance or otherwise, unless expressly agreed to by the parties or unless expressly ordered by the Court.

7. Each party should be restrained and prohibited from incurring any new debt which would add to the marital debt of the parties and/or which would increase the debt associated with any security interest upon any existing property of the parties. In the event that either party makes any new debt hereafter, the same should be the separate debt of the party incurring the same.

8. Each party should be restrained and prohibited from altering and/or encumbering or otherwise dealing with any existing policy of insurance, whether such insurance be health, life, property, automobile, casualty or otherwise, and the policy/certificate owner should be required to maintain such insurance during the pendency of this action.

9. Petitioner should be awarded possession and use of the marital residence and the property located therein and thereon, except the items of property which are specifically awarded to Respondent's possession. Each party should be awarded all his or her clothing and personal effects.

10. Other than as is otherwise stated herein, each party should be awarded possession and use of the personal property in his or her present respective possession.

11. Respondent should be ordered to pay, indemnify and hold Petitioner from the following debts, to wit: one-half (1/2) of all joint debt and his living expenses; Petitioner should be ordered to pay, indemnify and hold Respondent harmless from the following debts, to-wit: one-half (1/2) of all joint debt and her living expeneses; all until the futhrer order of the Court.

12. Respondent should be ordered to pay Petitioner temporary spousal support in the amount of $2,500.00 per month with the first such payment ordered to be made on the date that hearing be held on this application and on the first day of each month thereafter.

13. Each party should be ordered to preserve, keep and maintain all documents which presently exist or which come in exist during the pendency of this action concerning the financial, property, expense and/or business affairs adn records of the parties, including but not limited to all tax returns and support documentation, bank or other depository statements, deposit receipts, canceled checks, credit card statements and pay check vouchers or memoranda. In the event that a party does not do so and the other party incurs expense to obtain the same through discovery, that expense should be paid by the party who failed to maintain such records.

WHEREFORE, Petitioner requests that the Court issue its Order Setting Hearing upon said application; that, upon such hearing being conducted, the Court issue the temporary orders above requested; and that Petitioner be granted all further ancillary and proper relief as is warranted by the evidence and circumstances

Attorney for Petitioner

Request to Set and Notice of Parenting Plan Conference

Comes now the (Petitioner or RespondentO and requests the Court to set the above-styled case for conference on the Court's docket.

Petitioner (pro se) and/or Petitioner's attorney (names and addresses)

Repondent (pro se) and/or Respondent's attorney (names and addresses)

NOTICE OF PARENTING PLAN CONFERENCE

Upon request of Petitiner/Responent, notice is hereby given that the above case is set for conference before Judge * on the * day of *, 201*, AT * *.m. in room *, Tulsa County Courthouse, Tulsa, Oklahoma.

Dated this * day of *, 201*.

Sally How Smith, Court Clerk

JOINT STIPULATIONS
The parties stipulate and agree as follows:
1. That the Court has jurisdiction over the parties and the subject matter of tlj
action, and venue is proper in Tulsa County, State of Oklahoma for all issue.
2. That the parties will have Joint legal custody of the parties’ minor children
3. That the parties shall give advance notice when traveling out of state with theq
children, including destination, mode of travel, lodging arrangements, and
contact information.
4. That the parties shall maintain current contact information with addresses and telephone numbers for each party.
5. That the custodian parent shall immediately notify other party of any illness, medical problem or emergency that may arise while children are in his/her custody.
6. That the parties shall jointly decide medical and dental care for the children and will consult with each other in advance before authorizing non-routine or elective medical or dental procedures.
7. That Father shall maintain health insurance for the children. In the event Father loses insurance coverage through his employer, Mother shall provide the health insurance for the children at Father’s expense. Out of pocket medical/dental/vision expenses will be paid by the parties on a pro rata basis.
8. That the children shall remain at Wee Preschool for a minimum of three (3) days per week to be paid by the parties on a pro rata basis.
9. That if either parent is out of town or unable to provide care for the children, this parent will give the other parent the right of first refusal to care for the children.
10. That for the child support calculation, Petitioner’s monthly income is $* and Respondent’s monthly income is $*.
11. That Respondent shall be awarded the personal property contained on the attached Exhibit A.
12. That Petitioner will be awarded all personal property not specifically awarded to the Respondent in paragraph 11 above stated.
13. That Petitioner shall be awarded the * (describe the vehicle). Petitioner shall refinance the loan on said vehicle within thirty (30) days after filing of the Decree of Dissolution of Marriage, provided the interest rate in no greater than *%.
14. That Petitioner shall be awarded the marital residence. Petitioner shall refinance the mortgage on said residence within ninety (90) days after filing of the Decree of Dissolution of Marriage. If Petitioner does not obtain financing for the residence within ninety (90) days then the residence shall be listed for sale, and the proceeds of said sale shall be awarded to Petitioner. In the event the sale of the marital residence results in a loss, that loss shall be awarded to Petitioner.

AGREED DECREE OF DISSOLUTION OF MARRIAGE
NOW on this * day of *, 2015, this matter comes on for entry of this consent decree in lieu of further proceedings herein; Petitioner, TLM (“Petitioner”), filed her Petition for Dissolution of Marriage (“Petition”) on *, 201*, and Respondent, JWM (“Respondent”), filed his Answer to Petition for Dissolution of Marriage and Counterclaim for Dissolution of Marriage on *, 201*; Petitioner, appears in person and by her attorney of record, *; Respondent, represented by his attorney of record, *, appears not, but has executed this Agreed Decree of Dissolution of Marriage (“Decree”); and the Court having heard the oral testimony of Petitioner, sworn and examined, having received evidence and stipulations of the parties, and being fully advised in the premises, makes the following FINDINGS AND ORDERS:
1. THE COURT FINDS that it has jurisdiction over the parties, both parties having entered their appearance herein, and that Petitioner was a resident of the State of Oklahoma for more than six (6) months preceding the filing of the Petition and a resident of Tulsa County for more than thirty (30) days preceding the filing of the Petition.
2. THE COURT FURTHER FINDS that, except with respect to this Court’s jurisdiction over the parties and their minor children, the subject matter of this action, and the venue of this action, this is a consent decree, i.e., the parties have agreed to the terms of this journal entry as evidenced by their signatures hereon in agreement with the terms hereof and have asked that their agreement embodied in this journal entry is made the order and judgment of this Court.
3. THE COURT FURTHER FINDS that Petitioner and Respondent were legally married on *, 200*, at Tulsa, Oklahoma, and have been and now are husband and wife; that of said marriage, two children were born, namely, B.W.M., born * 201*, and C.D.M., born * 201*; and that Petitioner is not now pregnant.
4. THE COURT FURTHER FINDS that the State of Oklahoma is the minor children’s home state. The minor children and the parties have the closest significant contacts and connections with this state, and the evidence adduced herein shows substantial evidence in this state concerning the minor children’s past, present and future care, protection and training in personal relationships. No other state would have jurisdiction under prerequisites substantially in accordance with the above findings of jurisdictional fact. The Court, having heard evidence, concludes that no custody proceedings are pending in any other county, state or jurisdiction. No persons other than the parties hereto claim the right to custody or visitation with the minor children, and neither of the parties to this action, any third party, nor the minor children have participated as a party, as a witness, or in any other capacity in litigation concerning the minor children in this county, state or any other jurisdiction. Further, the minor children are not Indian children as defined by the provisions of 25 U.S.C.A. Section 1901 et seq., or 10 0. S. Section 40 et seq. Therefore, the District Court, State of Oklahoma, in compliance with 43 O.S. Section 551-101 et seq., is the appropriate forum and has full jurisdiction to enter a custody determination by decree concerning the minor children.
5. THE COURT FURTHER FINDS that a state of irreconcilable incompatibility has arisen between the parties hereto that has completely destroyed the aims and purposes of the marriage and that Petitioner shall be awarded a Decree of Dissolution of Marriage on the grounds of incompatibility, and Respondent shall be granted a Decree of Dissolution of Marriage on the grounds of incompatibility.
6. THE COURT FURTHER FINDS that Petitioner and Respondent are fit and proper persons to have joint custody of their minor children, and at this time, it is in the best interests of the minor children that their custody is awarded jointly to Petitioner and Respondent, subject to the Joint Child Custody Plan (“Plan”) entered simultaneously herewith, which is made the order and judgment of the Court.
7. THE COURT FURTHER FINDS that both parties have completed the Helping Children Cope with Divorce Program.
8. THE COURT FURTHER FINDS that pursuant to the Child Support Computation, attached hereto as Exhibit A (“Computation”), which is in accordance with the Oklahoma Child Support Guidelines (“Guidelines”), Respondent shall pay child support to Petitioner in the amount of $705.96 per month, due on the first of each month beginning on *, 2015, and each month thereafter through June 2016. Provided that the parenting coordinator approves the transition to a 2-2-5-5 visitation schedule (in accordance with the Plan and the Order Appointing Parenting Coordinator filed contemporaneously herewith), Respondent shall pay child support to Petitioner in the amount of $* per month, as set forth on Exhibit B hereto, in accordance with the Child Support Guidelines attached hereto, beginning on *, 2016, and continuing until the children reach eighteen (18) years of age. If the children are regularly enrolled in and attending high school, as set forth in Section 11-103.6 of Title 70 of the Oklahoma Statues, other means of high school education, or an alterantive high school education program as full-time students, the children shall be entitield to support by the parents until the children graduates from high school or until the age of twenty (20) years, whichever occurs first. Full-time attendance shall include regulary scheduled breaks from the school year. No hearing or further order is required ot extend support pursuant to this subsectiom after the children reach the age of eighteen (18) years. If the parenting coordinator does not approve transition to the 2-2-5-5 schedule , then child support set forth on Exhibit A shall remain in full force and effect.
9. THE COURT FURTHER FINDS Respondent shall maintain health insurance for the minor children, file all claims, and pay all insurance premiums until such time as the children are no longer eligible for child support. In the event Respondent loses insurance coverage through his employer, Petitioner shall provide health insurance for the children through her employer at Respondent’s sole expense. Respondent shall provide Petitioner with proof of enrollment, insurance cards, policy information, policy number, and any other documents necessary for the minor children to use the insurance while they are in Petitioner’s care. The parties shall exchange any information necessary to secure dependent health insurance enrollment. The parties shall further furnish each other with timely written documentation of any change in health insurance within thirty (30) days of the date of said change.
10. THE COURT FURTHER FINDS that all reasonable and necessary medical, dental, orthodontic, optometric, psychological, or any other physical or mental health expenses of the minor children incurred by either parent, which are not covered by insurance, shall be allocated and divided between the parties as set forth in the Computation, with Petitioner paying thirty-six percent (36%), and Respondent paying sixty-four percent (64%), of said expenses. The party incurring such expense shall deliver a copy of a receipt or similar documentation via email of said expense to the other party within thirty (30) days of receiving proof of said expense, and reimbursement shall be made within forty-five (45) days of receipt of proof of payment.
11. THE COURT FURTHER FINDS that Petitioner shall be responsible for thirty-six percent (36%), and Respondent shall be responsible for sixty-four percent (64%), of agreed upon work or school-related childcare expenses incurred on behalf of the minor children in accordance with the Guidelines and the Computation attached hereto. The parties shall pay their percentage share of said expenses directly to the childcare facility.
12. THE COURT FURTHER FINDS that in addition to the foregoing child support provisions, the parties shall divide costs associated with agreed upon extracurricular activities of the minor children, with Petitioner paying thirty-six percent (36%), and Respondent paying sixty-four percent (64%), of such expenses, unless the parties agree in writing, dated and signed by both parties, to a different arrangement. Agreement for the children to participate in extra-curricular activities shall not be unreasonably withheld. Once the parties transition to equal time with the minor children, each party will pay an equal share of said expenses. If one party desires to enroll the minor children
in an extra-curricular activity and the other party does not agree, the party enrolling the minor child shall bear the entire expense for that activity.
13. THE COURT FURTHER FINDS that the foregoing child support orders shall remain in full force and effect until the minor children reach the age of majority or until further order of the Court; provided, however, that if either of the minor children is continuously enrolled in high school at the age of majority, then the parties shall pay child support through the month of graduation from high school, or to the age of twenty (20) years, whichever occurs first.
14. THE COURT FURTHER FINDS that if any party to this action, (“the relocating party”) intends to move his or her primary residence or intends to move the minor children’s primary residence over seventy-five (75) miles for a period of sixty (60) days or more when such move is not a temporary absence from the children’s principal residence, such move is governed by the provisions of Title 43, Section 112.3 of the Oklahoma Statutes, as now existing, or as hereafter amended, which is incorporated herein by reference. This law, and THIS ORDER OF THE COURT REQUIRE among other things:
A. The relocating party shall mail (or serve in the manner provided for service of summons) a Notice of Intent to Relocate containing the following information in writing to the other party, and any other person entitled to visitation with the children, on the terms set out herein:
(i.) The intended new address, including the specific address, if known;
(ii.) The new mailing address, if not the same;
(iii.) The home telephone number, if known;
(iv.) The date of the intended move or proposed relocation;
(v.) A brief statement of the specific reasons for the proposed relocation of the children, if applicable; and
(vi.) A proposed revised visitation schedule with the children, if any.
B. The relocating party shall give notice of the proposed relocation of the children or the proposed change of the party’s residence address to the other party on or before the sixtieth (60th) day before the proposed change. If the relocating party did not know and could not have reasonably known of the change in sufficient time to provide a sixty (60) day notice, then such party shall give notice of the change on or before the tenth (1 0th) day after the date that he or she knows of the change.
C. The obligation of a party to give the notices and to provide the information set out herein shall continue so long as that party is entitled to custody of, or visitation with, a child covered by this order.
D. The failure of a party to give the notices and to provide the information set out herein may result in further litigation to enforce the order, including contempt of court. A copy of the notice with proof of service on the other party should be filed in this case with the Court Clerk.
E. The failure of a party to notify of a relocation of the children may be taken into account in a modification of custody of, visitation with, possession of, or access to, the children. The Court may assess reasonable attorney fees and costs against a party who fails to give the required notice.
F. If a party who receives notice of the intent of the other party to relocate the residence of the children does not file, within thirty (30) days after receipt of such notice, a proceeding seeking a temporary or permanent order to prevent the relocation, the relocation is authorized.
15. THE COURT FURTHER FINDS that Stephen Hale, Esq. should be appointed as the parenting coordinator in this case to decide issues specifically set forth in the Order Appointing Parenting Coordinator, which is filed concurrently herewith.
16. THE COURT FURTHER FINDS that, as a division of the parties’ property and debts, Petitioner shall be awarded her separate property acquired by her prior to the parties’ marriage or after the parties’ separation or acquired by her by gift or inheritance during the parties’ marriage, free and clear of any right, claim, and interest of Respondent, and the following jointly-acquired property and debts acquired by the parties during the marriage and before their separation, free and clear of any right, claim, and interest of Respondent:
A. The marital residence and its contents located at 3501 South 18th Street, Broken Arrow, Oklahoma, further described as follows:

*

Subject to the Bank of America indebtedness thereon. Petitioner shall refinance the mortgage on said residence within ninety (90) days after filing of this Decree. If Petitioner does not obtain financing for the residence within ninety (90) days, then the residence shall be listed for sale, and the proceeds of said sale shall be awarded to Petitioner. In the event the sale of the marital residence results in a loss, that loss shall be awarded to Petitioner.
saEED22l
B 201* GMC Yukon, VTN __________, subject to any and all indebtedness owed thereon. Petitioner shall refinance the loan on said vehicle within thirty (30) days after filing of the Decree, provided the interest rate is no greater than *%.
C. All personal property in her possession, custody, or control.
D. All financial accounts held in Petitioner’s name.
E. The following indebtedness:
(i.) All debt incurred by her since the filing of this case, which Petitioner assumes and agrees to pay and further agrees to hold Respondent harmless therefrom; and
(ii.) All indebtedness related to each of the above-described awards of marital and separate property, holding
Respondent harmless therefrom.
17. THE COURT FURTHER FINDS that, as a division of the parties’ property and debts, Respondent shall be awarded his separate property acquired by him prior to the parties’ marriage or after the parties’ separation or acquired by him by gift or inheritance during the parties’ marriage, free and clear of any right, claim, and interest of Petitioner, and the following jointly-acquired property and debts acquired by the parties during the marriage and before their separation, free and clear of any right, claim, and interest of Petitioner:
A. * boat, VIN ___________
B. 2005 * pickup, VIN ___________
C. The following personal property which Respondent has removed from the marital residence and/or has in his possession:
1. Queen bed — frame/headboard upstairs to go with mattress/box springs he is currently using from marital
estate;
2. Maroon queen bedding to go with bed;
3. Nightstand that matches the queen bed upstairs;
4. Armoire that is upstairs with queen bed;
5. Lamps upstairs and in attic;
6. TV stand upstairs;
7. Panasonic 40” plasma TV upstairs;
8. Outside Insignia TV and TV bracket;
9. Coffee table trunk upstairs;
10. End table upstairs;
11. 2 couches upstairs;
12. The following upstairs artwork: oars, plane propeller, boat pictures and other pictures upstairs;
13. Copies of all camcorder kids video and photos taken up to January 2014. Respondent is responsible for making all
copies and returning originals to Petitioner;
14. 1/2 of the towels;
15. 1/2 of the dishes/pots/pans;
16. Set of silverware;
17. Tools;
18. Lawn tractor, bagger, lawn trailer;
19. Push mower;
20. Bagger;
21. Blower;
22. Weed trimmer and all attachments;
23. Flat table (now in master bedroom that was in living room);
24. High top bar table and two bar stools from patio;
25. Breakfast nook table, table leaf and matching chairs;
26. Charbroil grill and boat grill;
27. 9mm pistol in possession of Respondent’s former attorney;
28. Respondent’s personal Christmas ornaments;
29. Garage refrigerator; and
30. Canon digital camera.
D. All bank accounts held in Respondent’s name.
E. All personal property currently in his possession, custody, or control.
F. The following indebtedness:
(i.) All debt incurred by him since the filing of this case, which Respondent assumes and agrees to pay and further agrees to hold Petitioner harmless therefrom; and
(ii.) All indebtedness related to each of the above-described awards of marital and separate property, holding Petitioner harmless therefrom.
17. THE COURT FURTHER FINDS that as further division of property Petitioner is hereby awarded a judgment of $7,500.00, which Respondent shall pay within ninety (90) days of the entry of this Decree.
18. THE COURT FURTHER FINDS that beginning with 2014, Petitioner shall be entitled to claim B.W.M., born March 2012, and Respondent shall be entitled to claim C.D.M., born March 2012, as a dependent for income tax purposes. At such time that one of the children no longer qualifies as a dependent, then Petitioner shall be entitled to claim the remaining child as a dependent for all future years that he continues to qualify as a dependent.
19. THE COURT FURTHER FINDS that neither party has been a debtor in any bankruptcy proceeding throughout the pendency of this action.
20. THE COURT FURTHER FINDS that both parties are hereby apprised that pursuant to Title 43, Section 123 of the Oklahoma Statutes, it is unlawful for either party to this divorce action to marry anyone in Oklahoma, other than the opposing party in this action, within six (6) months from the date this decree is granted or to cohabit with a new spouse in Oklahoma during such six (6) month period, if the marriage hereafter takes place in another state.
21. THE COURT FURTHER FINDS that Petitioner and Respondent shall pay their respective attorneys’ fees and costs incurred herein.
IT IS THEREFORE ORDERED, ADJUDGED AND DECREED by this Court that Petitioner and Respondent hereby are granted a full, final and complete Decree of Dissolution of Marriage from the other upon the grounds of incompatibility, and that the bonds of matrimony heretofore existing between them be and hereby are set aside and

Judge of the District Court
Date: *

JOINT CHILD CUSTODY PLAN
COMES NOW Petitioner, Terie Lee Matthews (“Petitioner”), and Respondent, Jonathan Wade Matthews (“Respondent”), jointly, and respectfully submit this Joint Child Custody Plan (“Plan”) agreed upon by and between the parties hereto with supporting affidavits for the Court’s consideration and state as follows: That the terms and provisions of said Plan are in the best interests of the minor children of the parties hereto, namely, B.W.M., born March 2012, and C.D.M., born March 2012; that both of said parties hereto are fit and proper persons and parents, physically and psychologically, to be granted physical and legal care, custody and control of said minor children; that said parties hereto respectfully pray the Court to approve and adopt this Plan as the Court’s order for the exercise of joint child care, custody and control of said minor children by said parties hereto, all pursuant to Title 43, Section 109 of the Oklahoma Statutes, alleging and stating further as follows:
1. Both parties hereto shall have equal rights and responsibilities to said minor children, and neither party’s rights shall be superior.
2. Both parties hereto shall reasonably confer with one another by the most reasonable and appropriate method and shall share decision-making authority as to important decisions affecting the physical, mental, and moral welfare and upbringing of said minor children to arrive at decisions promoting said minor children’s best interests.
3. Both parties hereto shall decide jointly the following matters, to-wit:
A. Medical, dental and healthcare said minor children should or shall receive;
B. Schools which said minor children should or shall attend, including college;
C. Religious instruction the minor children should and shall receive;
D. Summer camps and/or classes which said minor children should or shall attend;
E. Fashion and manner in which said minor children should or shall be disciplined;
F. Extent of any travel of said minor children away from home, including purpose, duration, mode, chaperon, etc.; and
G. Such other areas requiring decisions affecting the growth and development of said minor children.
4. The parties shall maintain current contact information with addresses and telephone numbers for each party.
5. Petitioner shall have primary physical custody of the minor children and shall have physical custody of the minor children at all other times not specifically awarded to Respondent hereinafter. Respondent shall have visitation as follows:
A. From June 2015 to May 31, 2016: Every other weekend from Friday after school/daycare to Monday morning before school/daycare, and every Wednesday after school/daycare to Thursday morning before school daycare (with Respondent picking up and dropping off at school/daycare);
B. Beginning with 2016-2017 academic year and continuing each year thereafter: Subject to approval of the parenting coordinator, the parties shall follow a 2-2-5-5 visitation schedule, with exchanges to take place before and after school/daycare; and C. Summer 2016 (June 1-August 15) and each subsequent summer thereafter: Every other week with exchanges to take place on Sunday at 6:00 p.m.
6. For the summer of 2015, each party shall have physical custody of the minor children for at least one (1) uninterrupted week in each month of July, August, and September, which shall begin with their regularly-scheduled weekend visitation set forth above. Each party shall submit their preferred weeks to the other by July 1. Neither party’s selected weeks may interfere with, or trump, the holiday schedule set forth below.
7. The parties shall rotate the following holiday/summer visitation schedule with the children as follows:
Occurrence
Petitioner
Respondent
Memorial Day: 6:00 p.m. Friday preceding
Memorial Day until 6:00 p.m. Memorial Day
Even-numbered years
Odd-numbered years
July 4: 6:00 p.m. July 3 until 6:00 p.m. on July 5
Odd-numbered years
Even-numbered years
Labor Day: 6:00 p.m. Friday preceding Labor Day until 6:00 p.m. Labor Day
Even-numbered years
Odd-numbered years
Fall Break (applies only in grades K-12):
6:00 p.m. the day school is dismissed for Fall
Break until 6:00 p.m. the Sunday before
school resumes
Odd-numbered years
Even-numbered years
Thanksgiving: 6:00 p.m. Wednesday
preceding Thanksgiving until 6:00 p.m. Friday
Even-numbered years
Odd-numbered years
Christmas: 6:00 p.m. December 23 until 12:00 noon December 25
In grades K-12: 6:00 p.m. December 21 until 12:00 p.m. December 25
Odd-numbered years
Even-numbered years
Christmas: 12:00 noon December 25 until 6:00 p.m. December 26
In grades K-12: 12:00 p.m. December 25 until 6:00 p.m. December 29
Even-numbered years
Odd-numbered years
Occurrence
Petitioner
Respondent
Children’ Birthdays: 9:00 a.m. March 23 until 9:00 a.m. March 24
Odd-numbered years
Even-numbered years
Easter: 6:00 p.m. Friday preceding Easter until 6:00 p.m. Sunday
Even-numbered years
Odd-numbered years
Spring Break (applies only in grades K-12):
6:00 p.m. the day school is dismissed for
Spring Break until 6:00 p.m. Sunday before
school resumes
Odd-numbered years
Even-numbered years
Mother’s Day and Petitioner’s birthday: 9:00 a.m. on Mother’s Day and Petitioner’s birthday until 9:00 a.m. the following day
Every year
N/A
Father’s Day and Respondent’s birthday:
9:00 a.m. on Father’s Day and Respondent’s birthday until 9:00 a.m. the following day
N/A
Ever 3d year
8. Both parties shall be mindful and considerate of said children’s school activities, sports activities, and peer activities and associations, and, in the event of conflict respecting the foregoing custody/visitation schedule, the parties shall work together reasonably in advance to arrange for alternate custody.
9. Both Petitioner and Respondent shall immediately notify each other of any medical or dental problem regarding the parties’ minor children requiring medical attention, and the parties shall consult with each other in advance before authorizing non-routine or elective medical or dental procedures.
10. If either party is out of town for business or pleasure or unable to provide physical care of the minor children during his or her designated time of physical custody, separate from employment in-town, for a period of three (3) hours or more then that party shall contact the other parent to provide that care. If the parent elects to exercise his or her right to first refusal, then he or she shall be responsible for all transportation associated with
exercising same. If a parent exercising his or her first right of refusal has the children past 8:00 p.m., the children shall remain with that parent until the next morning when the children will be transported to school or, if school is not in session, then until the following morning at 10:00 a.m.
11. Each parent shall immediately furnish the other parent a complete copy of any and all report cards or other school notices, current school calendars, and/or schedules for any extracurricular activities for the benefit of the parties’ minor children.
12. During the period each of them has physical custody of the children, that parent shall decide all normal, regular, and routine matters concerning said children’s welfare, and each parent shall cooperate with the other in maintaining a mutually supportive arrangement regarding such normal, regular, and routine matters.
13. Both parties shall give advance notice to the other parent when traveling out of state with the children, including destination, mode of travel, lodging arrangements, and contact information.
14. *, Esq., is appointed parenting coordinator by mutual agreement of the parties herein. The costs of the parenting coordinator shall be allocated as set forth in the Order Appointing Parenting Coordinator. The parenting coordinator has the authority to recommend reallocation of his costs.
15. Both parties agree not to consume alcohol during times the children are in their physical custody for a period of one (1) year from the date this Plan is filed. This prohibition shall expire after one (1) year from the date of the entry of this Decree provided it may be reviewed by the Court upon application or by the Parenting Coordinator.
exercising same. If a parent exercising his or her first right of refusal has the children past 8:00 p.m., the children shall remain with that parent until the next morning when the children will be transported to school or, if school is not in session, then until the following morning at 10:00 a.m.
11. Each parent shall immediately furnish the other parent a complete copy of any and all report cards or other school notices, current school calendars, and/or schedules for any extracurricular activities for the benefit of the parties’ minor children.
12. During the period each of them has physical custody of the children, that parent shall decide all normal, regular, and routine matters concerning said children’s welfare, and each parent shall cooperate with the other in maintaining a mutually supportive arrangement regarding such normal, regular, and routine matters.
13. Both parties shall give advance notice to the other parent when traveling out of state with the children, including destination, mode of travel, lodging arrangements, and contact information.
14. *, Esq., is appointed parenting coordinator by mutual agreement of the parties herein. The costs of the parenting coordinator shall be allocated as set forth in the Order Appointing Parenting Coordinator. The parenting coordinator has the authority to recommend reallocation of his costs.
15. Both parties agree not to consume alcohol during times the children are in their physical custody for a period of one (1) year from the date this Plan is filed. This prohibition shall expire after one (1) year from the date of the entry of this Decree provided it may be reviewed by the Court upon application or by the Parenting Coordinator.
21. The parties agree that each shall ensure that the children take all medications in the appropriate dosage and at the appropriate time during their custodial periods and follow the recommendations and instructions of medical professionals treating the children. The medication prescribed and dosage recommended to be given to the children shall be mutual obligations of each party-parent to provide the other.
22. The parties shall each be responsible to maintain clothing for the children and other necessities the children may need while residing at each parent’s respective residences. Further, it shall be the responsibility of the parties to make sure that the children return to the other parent’s home with all clothing and belongings which were brought with the children at the commencement of their custodial periods.
23. The parties shall take such action as may be necessary with school authorities or other persons of authority charged with the care of the children to list the other parent as a parent of the children and to provide such authority with the parent’s address and phone number and to advise such authorities that the other parent is a person that can and should be contacted in the case of an emergency involving the children.
24. In the event of the untimely death of either party prior to the minor children reaching the age of majority, then, the surviving party shall facilitate and encourage the minor children to have continued common, normal contact with the deceased party’s family, including, but not limited to, grandparents, parents, aunts, uncles, nieces, nephews and other related kindred.
WHEREFORE, Petitioner, *, and Respondent, *, jointly move the Court to approve the above and foregoing Plan in the best interests of the parties’ minor children.

ORDER APPOINTING PARENTING COORDINATOR
Now on this /(j1day of , 2015, this matter comes before the undersigned Judge of the District Court pursuant to Title 43, Section 120.1 et seq. of the Oklahoma Statutes. The Court, having reviewed the file and considered the premises FINDS AND ORDERS as follows:
1. Existing Order.
The parties are currently operating under the Agreed Decree of Dissolution of Marriage (“Decree”) and Joint Child Custody Plan entered and filed of record on the I day of ____________,2015. The children involved in this proceeding are: B.W.M, born March 2012, and C.D.M., born March 2012.
2. Jurisdiction.
A. This court has jurisdiction over child custody and parenting time issues pursuant to 43 O.S. § 551-101 et seq. because the Court’s current child custody determination was consistent with the provisions of the UCCJEA.
B. The Court finds and the parties agree that appointment of a parenting coordinator is necessary to assist the parents in making joint decisions as set forth herein.
Pursuant to 43 0.S. § 120.3(a) and (b), this Court has the requisite authority to enter this Order in that the parties agree to the entry of this Order.
C. The Court finds that the parties have the means to pay the fees of the parenting coordinator. $ 43 0.5. 2006. § 120.5(A)(1).
3. Parenting Coordinator.
The parties have agreed that Stephen Hale, Esq. (“Parenting Coordinator”) should be appointed as the Parenting Coordinator herein. Such person is qualified to serve as a parenting coordinator pursuant to the local rules of this judicial district governing the qualifications of a parenting coordinator and is a licensed professional with experience in family and children’s services. (S 43 0.S. 2006, § 120.6). The parties shall cooperate with the Parenting Coordinator and follow the terms specified in this order.
4. Term/Succession.
The term of the Parenting Coordinator’s service shall be for three (3) years. This Court reserves the right to remove the Parenting Coordinator at any time in its own discretion and may remove the Parenting Coordinator upon the request and agreement of both parties or upon motion of either party with good cause shown. ($ç 43 0.5. 2006, § 120.3(G)).
5. Limitations on Parenting Coordinator’s Authority.
Pursuant to 43 O.S. § 120.3(C), the authority of the Parenting Coordinator is limited to matters that will aid the parties in:
(a) Identifying disputed issues;
(b) Reducing misunderstandings,
(c) Clarifying priorities;
(d) Exploring possibilities for compromise,
(e) Developing methods of collaboration in parenting, and
(f) Complying with the Custody Order.
No decision issued by the Parenting Coordinator may divest this Court of its exclusive jurisdiction to determine the fundamental issues of custody, visitation, and child support, or this Court’s authority to exercise management and control of the case. Further, no decision issued by the Parenting Coordinator may modify any order, judgment or decree; however, the Parenting Coordinator may allow the parties to make minor temporary departures from a parenting plan if expressly authorized by this Court to do so.
6. Issues subject to Parent Coordination.
A. Decision-Making Power. Subject to the limitations to the Parenting Coordinator’s authority set forth in this order, the following specific matters are hereby submitted to the Parenting Coordinator for determination in the event of a dispute between the parties:
(1) Approving the transition to a 2-2-5-5 visitation schedule, beginning with the 2016-2017 academic year;
(2) Recommending appropriate childcare for the children in the absence of an agreement of the parties; and
(3) Recommending whether the one (1) year prohibition against consuming alcohol when the children are in their custody shall continue to remain in full force and effect.
B. Limits to Power. No decision issued by the Parenting Coordinator may divest this Court of its exclusive jurisdiction to determine the fundamental issues of custody, visitation, and child support, or this Court’s authority to exercise management and control of the case. Further, no decision issued by the Parenting Coordinator may modify any order, judgment or decree; however, the Parenting Coordinator may allow the parties to make minor temporary departures from a parenting plan if expressly authorized by this Court to do so.
7. Role of Parenting Coordinator.
A. Decisions: If the parties are unable to reach an agreement respect to the issues set forth in Paragraphtereof, the Parenting Coordinator shall decide such unsettled issue within the scope of his authority by any appropriate dispute-resolution method. Unless otherwise indicated above, a decision by the Parenting Coordinator in resolution of a dispute concerning a matter subject to his decision-making authority shall be immediately effective, binding on the parties, and enforceable by compulsory process until further order of the Court.
B. Resolutions: The primary role of the Parenting Coordinator is to assist the parties in working out disagreements regarding the minor children as set forth herein. If the parties are able to resolve any such matters through mutual agreement, the Parenting Coordinator shall adopt that resolution as a recommendationldecision.
8. Appointments with the Parenting Coordinator.
A. The Parenting Coordinator may set a time and place for a brief informational meeting within twenty (20) days of this Order if requested by either party.
B. Future appointments with the Parenting Coordinator may be scheduled at the request of either parent by telephone or in person with no written notice required. Each parent shall make a good faith effort to be available for appointments when requested by the other parent or the Parenting Coordinator.
C. The Parenting Coordinator shall notify the Court, with copies to the parties or their attorneys, if either party refuses to cooperate.
9. Decision-Making Process.
A. Both parents shall abide by rules and procedures set forth by the Parenting Coordinator for conducting meetings. The Parenting Coordinator shall investigate and decide matters which are submitted to him and within his authority, by meeting with the parents, reviewing written materials submitted to him, and considering any other information relevant to the matter to be decided. Meetings may be held with both parents present or by meeting with one parent at a time. The Parenting Coordinator has discretion to allow either parent to appear by telephone.
B. Subject to the valid assertion of a confidential privilege, e.g. physician- patient privilege, etc., the Parenting Coordinator may consult with professionals, family members and others who have information about the parents or children, such as therapists, custody evaluators, school teachers, etc., and may consider that information in making a decision, as allowed by law. The Parenting Coordinator shall have the authority to determine the protocol of all interviews and sessions including, in the case of meetings with the parents, the power to determine who attends such meetings.
C. The parents shall provide all records, documentation and information requested by the Parenting Coordinator within fifteen (15) calendar days of the request. The Parenting Coordinator may not request material subject to attorney/client privilege and may not require the release of documents protected by law except upon proper consent and release by the parties or by order of the Court.
10. Communication.
A. The parents and their attorneys, if they are represented, may communicate with the Parenting Coordinator ex parte (without the other parent present). This applies to oral
communications and any written documentation or communication submitted to the Parenting Coordinator.
B. The Parenting Coordinator may communicate ex parte with the parents and their attorneys, and other professionals involved in the case. This applies to both written and oral communications. The Parenting Coordinator may talk with each parent without the presence of either counsel.
C. The Parenting Coordinator shall not communicate ex parte with the Judge assigned to the case.
11. Report to the Court.
A. A report of the decisions and recommendations made by the Parenting Coordinator shall be filed with the Court within twenty (20) days of the Parenting Coordinator’s announcement of his decision(s) and/or recommendation(s). The report shall be in writing and shall specifically address the matters submitted to the Parenting Coordinator for determination. The Parenting Coordinator’s report shall distinguish between any “decisions” and “recommendations.” The Parenting Coordinator shall state the reasoning or rationale for each decision or recommendation not agreed to by the parties.
B. Any decisions made by the parenting coordinator authorized by the court order and issued pursuant to the provisions of the Parenting Coordinator Act shall be binding on the parties until further order of the court.
C. The Parenting Coordinator shall send a copy of this written report with the decision/recommendation to both parties and any attorneys involved in the case.
D. Any party may file with the Court and serve on the Parenting Coordinator and all other parties a written objection to the Parenting Coordinator’s report within ten (10) days
after the Parenting Coordinator provides the report to the parties. Responses to the objection shall be filed with the Court and served on the Parenting Coordinator and all other parties within ten (10) days after the objection is served. The Court should set the matter for hearing on the objection and notice provided to all parties and the Parenting Coordinator, and thereafter enter appropriate orders.
E. If no objection is filed on a recommendation, then the Court may adopt it in its own discretion. Any action by the Court must be mailed to the attorneys/parties and the Parenting Coordinator.
F. It is not the duty of the Parenting Coordinator or the Court to prepare the journal entry adopting the Parenting Coordinator’s decision.
G. If the Parenting Coordinator finds that there are actions by one or both parties which should be brought to the attention of the Court, such as one parent’s noncooperative behavior or failure to appear at appointments, then the Parenting Coordinator may send notification to the Court in the same manner as set forth above.
12. Confidentiality.
A. There is no confidentiality concerning communications between the parents and the Parenting Coordinator. As required by the Court, the Parenting Coordinator may communicate with custody evaluators, therapists or other individuals investigating the issues. The Parenting Coordinator shall comply with the law to report child abuse and threats of abuse against another person. In cases involving domestic violence, the Parenting Coordinator and legal counsel (or the parents themselves, if not represented) shall address to the Court any safety concerns, subject to the prohibition against ex parte communication.
B. By signing this Order each party agrees to allow the Parenting Coordinator to review documentation filed with the Court or received into evidence, voluntarily released by the parties, or released by order of the Court about him or her and their children from the physician(s), therapist(s), teacher(s), mediator(s), evaluator(s) and other professionals involved in this case (except for the attorney representing him or her). Each party also agrees to allow the Parenting Coordinator to discuss issues contained in such files with the professional who keeps the file. The Parenting Coordinator however, is not authorized to share the materials or discuss confidential information with anyone outside the case. This waiver does not extend to other privileges recognized by law.
13. Involvement of Parenting Coordinator in Litigation.
Before any party or party’s attorney may employ discovery requests of a Parenting Coordinator, permission must be given by the Court that such specific discovery requests may issue, including subpoenas for documents or for deposition. If either parent wishes the Parenting Coordinator to testify at a hearing or deposition other than to give a report on findings, the parent will be required to deposit in advance a reasonable fee to cover the hourly rate of the Parenting Coordinator.
14. Quasi-Judicial Immunity.
The Parenting Coordinator acts as a quasi-judicial officer in his capacity pursuant to this Order, and, as such, has immunity consistent with Oklahoma law as to all actions undertaken pursuant to the Court appointment and this order. This immunity applies to all acts done by the Parenting Coordinator during the appointment and until the Parenting Coordinator is given notice of his termination. The immunity continues to apply to acts required by the Court to conclude the Parenting Coordinator’s duty after termination.
15. Fees.
A. The Court finds that the parents have the financial capacity to pay for the Parenting Coordinator. The parties shall pay the Parenting Coordinator for all of his time and costs incurred in processing the case. This includes time spent reviewing documents and correspondence, meetings and telephone calls with parents, attorneys, and other professionals involved in the case, and deliberation and issuance of decisions. Costs shall include long distance telephone calls, copies, fax charges, and all other similar costs incurred by the Parenting Coordinator pursuant to this order. In addition, the parents shall pay for time spent by the Parenting Coordinator in any hearing, settlement conference, report writing, or other court appearance that the Parenting Coordinator’s presence is requested or required. Nonpayment of fees may subject the nonpaying parent to prosecution for indirect contempt of court for failure to abide by the order. Prior to the first appointment, the parents shall provide the Parenting Coordinator with any retainer required by the Parenting Coordinator.
B. The Parenting Coordinator’s hourly fee shall be paid as follows:
Fees will be allocated on a pro rata basis based set forth in Exhibit A to the Decree. The Parenting Coordinator may modify this allocation, or may recommend to the Court that the allocation be modified, if the Parenting Coordinator finds that one parent is using his services unnecessarily and, as a result, is causing the other parent greater expense; or if one parent is acting in bad faith. Ultimately, the Court shall determine the proper allocation of fees between the parents and may require reimbursement by one parent to the other parent for any payment made to the Parenting Coordinator. Either parent may request the fees be reallocated at any time during the Parenting Coordinator’s term of appointment, unless good cause is shown for failing to appear at the appointment. ($çç 43 OS. 2006, § 120.5).
15. Fees.
A. The Court finds that the parents have the financial capacity to pay for the Parenting Coordinator. The parties shall pay the Parenting Coordinator for all of his time and costs incurred in processing the case. This includes time spent reviewing documents and correspondence, meetings and telephone calls with parents, attorneys, and other professionals involved in the case, and deliberation and issuance of decisions. Costs shall include long distance telephone calls, copies, fax charges, and all other similar costs incurred by the Parenting Coordinator pursuant to this order. In addition, the parents shall pay for time spent by the Parenting Coordinator in any hearing, settlement conference, report writing, or other court appearance that the Parenting Coordinator’s presence is requested or required. Nonpayment of fees may subject the nonpaying parent to prosecution for indirect contempt of court for failure to abide by the order. Prior to the first appointment, the parents shall provide the Parenting Coordinator with any retainer required by the Parenting Coordinator.
B. The Parenting Coordinator’s hourly fee shall be paid as follows:
Fees will be allocated on a pro rata basis based set forth in Exhibit A to the Decree. The Parenting Coordinator may modify this allocation, or may recommend to the Court that the allocation be modified, if the Parenting Coordinator finds that one parent is using his services unnecessarily and, as a result, is causing the other parent greater expense; or if one parent is acting in bad faith. Ultimately, the Court shall determine the proper allocation of fees between the parents and may require reimbursement by one parent to the other parent for any payment made to the Parenting Coordinator. Either parent may request the fees be reallocated at any time during the Parenting Coordinator’s term of appointment, unless good cause is shown for failing to appear at the appointment. ($çç 43 OS. 2006, § 120.5).
C. If one parent pays 100% of the Parenting Coordinator’s fee, then that party has absolute right of indemnification against the other parent up to the percentage allocation for which the other parent was responsible. This reimbursement may be enforced by contempt.
16. Grievances.
A. The Parenting Coordinator may be disqualified or terminated during his terms on any of the grounds applicable to a judge or arbitrator. Any grievance from either parent regarding the performance or actions of the Parenting Coordinator shall be dealt with in the following manner.
B. A person with a grievance shall discuss the matter with the Parenting Coordinator in person before pursuing it in any other manner.
C. If, after discussion, the parent decides to pursue a complaint, s/he must then submit a written letter detailing the complaint to the Parenting Coordinator, to the other parent, and any attorneys representing the parents and/or children. The Parenting Coordinator shall provide a written response to the parents and the attorneys within thirty (30) days.
D. The Parenting Coordinator will then meet with the complaining parent and his/her attorney (if any), to discuss the matter.
E. If the complaint is not resolved after this meeting, the complaining party may file a motion with the Court for removal of the Parenting Coordinator. Notice shall be given to the Parenting Coordinator, with an opportunity to be heard.
F. The Court shall reserve jurisdiction to determine if either or both parents and/or the Parenting Coordinator shall ultimately be responsible for any portions or all of the Parenting Coordinator’s time and costs spent in responding to the grievance and the Parenting Coordinator’s attorney’s fees, if any.

Dated this * day of * ,201*

Outcome: Divorce

Plaintiff's Experts:

Defendant's Experts:

Comments: