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FILED

Supu-ior Com of Cuufumia


Counw of Los Angelo:

Michael Lockwood J UL 2 3 2020


23679 Calabasas Road #203
Calabasas, California 91302 Sherri R. Carter. Executive Officer/Clcrk
(323) 702-7087 phone Deputy
By ,

MichaelLockwoodGDmacom Charlene Andrews

in pro per,

SUPERIOR COURT OF THE STATE OF CALIFORNIA


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FOR THE COUNTY OF LOS ANGELES


CENTRAL DISTRICT
DEPARTMENT 35
Case No. BD642436
IN THE MATTER OF:
—_
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PETITIONER: LISA MARIE PRESLEY RESPONDENT’S TRIAL BRIEF
and Date: August 3, 2020
Time: 8:30 A.M.
RESPONDENT: MICHAEL LOCKWOOD Location: Department 35
Hon. Diana Gould—Saltman

FILED UNDER SEAL


To: The Court 1n the above-entntled matter and to Llsa Marie Presley, Petltloner:

NH—H——H—~ I. STATISTICAL FACTS


Date of marriage: January 22, 2006

Date of separation: June 24, 2016

Length of Marriage: IO years, 5 months

Children: Finley and Harper (twin girls), both born October 7 , 2008, age l 1
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Current custodial schedule: Respondent, Tuesday and Wednesday 3-7PM; Sunday l-

7PM. All other times with Petitioner.

II. BRIEF SUMMARY OF THE CASE


DCFS opened an investigation into sexual abuse allegations against Mother and

Father after Petitioner filed for dissolution on June 24, 2016. Both children were

interviewed on July l, 2016. The children were placed with their Grandmother. DCFS
filed a WIC 300 petition on July 7, 2016. Both parents were allowed monitored visits until

June 28, 2017 when Judge Draper issued a Minute Order which gave the parents equal
l

Respondent’s Trial Brief Marriage of Presley and Lockwood BD642436


custodial time (each with 2 '/z days at a time) unmonitored for both parents, although

Father’s overnights at the home of Maternal Grandmother (with her consent). Mother
entered a rehabilitation facility for 90 days on July 15, 2016. DCFS moved to dismiss the
petition in its entirety in May 20 l 7 and the court granted the motion on June 28, 20 l 7. The

court issued a written Statement of Decision on July l9, 2017. Minors’ Counsel and
\DOOQGthri—I

Mother appealed the dismissal of allegations against Respondent on July 28, 2017. The

Court of Appeal issued a writ of Supersedeas on July 6, 2017 which stayed the

Dependency Court Order dismissing charges against Father pending appeal. This resulted

in the continuation of monitored visits for Father and less custodial time for Father than

Mother (only 21 hours per week for Father with no ovemights). The Court of Appeals
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affirmed Judge Draper’s dismissal of charges against Father on August 27, 2018 and

Remittitur was issued on October 29, 2018, and this would have permitted Father’s

overnight visits. However, on October 10, 2018, Mother filed an RFO seeking physical

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custody and monitored visits for Father. DCFS opened another investigation into the

dismissed allegations against Respondent on November 27, 201 8. Consequently, Father


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had to have monitored visits again. On or about December l9, 2018, Respondent’s legal

counsel withdrew from representing Respondent because Respondent could no longer

afford to pay him. Respondent has appeared in propria personae since then. 0n March 27,
2019, DCFS closed its investigation as inconclusive of the November 201 8 abuse report.

In April 20 l 9, Vikki Hakkinen, who served as a volunteer monitor for Father’s visits with

0 the children free of charge, quit due to Mother’s excessive criticism and interference
(by

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this time Hakkinen had taken professional monitor training and became a professional

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w monitor). Thus, from mid—April through June 20] 9, Father had no visits with the children

24 because he could not afford to pay a monitor. Hakkinen returned as monitor in June 20 l9.

Respondent sought a continuance ofthc trial because he lacked essential evidence and

counsel via ex parte motion in Department 35 on June 30, 2020, and ex parte relief was

denied without a stated reason for denial. Respondent filed a Request for Order for

Petitioner to pay Respondent’s legal costs and fees so that Respondent may be represented

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


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by counsel at trial on July 2, 2020 and the RFO is due to be heard in Department 83 on

October 6, 2020. Due to the pending motion, Respondent again sought a continuance of

the trial via ex parte motion in Department 2 on July 7, 2020. The motion was denied

without a stated reason for denial.

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III. SETTLED ISSUES:
No Jurisdiction issues as California is deemed the “home state.”

IV. ISSUES TO BE LITIGATED AT TRIAL


Physical/legal custody and child support, decree of dissolution.

V. PROPOSAL FOR RESOLUTION OF ISSUES:


Joint physical and legal custody pursuant to Family Code Sections 3002 and 3003.

Compliance with most of the recommendations of court appointed evaluators, Dr. Mary

Lund and Dr. Meesha Ellis (“Lund Report”). However, Respondent proposes 50% physical

and legal custody and 50% physical and legal custody to Petitioner (one week on, one week

off), both parties unmonitored, however with a transition phase similar to that

recommended by the evaluators but at a more accelerated pace.

Respondent agrees with the evaluators that it is probably in the best interests of the

children for there to be transition phases until full 50% custody is reached, but Respondent
asserts that Respondent should have a greater time share than the 21 hours currently

allotted to him by court order in phase one. Due to the current Covid-l 9 precautions, it is

apparent that the children’s school will not be requiring physical attendance in the fall, thus

the children could do their home schooling with Respondent, which would be in accord

with Dr. Lund’s findings as to Respondent’s helpfulness with the children's schoolwork.

As a result, Respondent proposes three eight hour days (the six hour school day plus an

hour before and after school) and one eight hour visit on the weekend, unmonitored, and

at Respondent’s home, drop off at Petitioner’s home (Petitioner shall drop offthc children

at Respondent’s home). This totals 32 hours per week, which is incrementally larger than

Respondent’s current allotted time. This also gives Respondent greater time to address

school issues with the girls (the evaluators noted that the children are behind in school).

Respondent’s Trial Brief Marriage of Presley and Lockwood 80642436


As in the evaluators‘ recommendation, Respondent’s fiancee shall avoid interaction with

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the girls during the proposed phase one visits. Finally, child support subject to calculation

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based on Petitioner’s income information but no less than approximately $9500 per month

(with Petitioner paying for all therapy expenses, all insurance expenses, all school expenses

and all extracurricular expenses). (See attached calculation as Exhibit l)'

In phase two ofthe transition period, again under current Covid- l 9 plans, Respondent

should be permitted three eight hour days per week and one overnight
\DOOQONUIh

visit (a period of

twenty four hours) at Respondent’s home, drop off at Petitioner’s home (again Petitioner
shall deliver the children to Respondent). This totals 48 hours per week, which is

incrementally larger than Respondent’s phase one time, but not even 30% of the week.

During this phase, as per the recommendation of the evaluators, Respondent’s fiancee

should be part of family therapy sessions and should be introduced into visits (and

additional custodial time may be required to attend therapy). Child support subject to

calculation with Petitioner’s income information but no less than approximately $ 14,324

per month (with Petitioner paying for all therapy expenses, all insurance expenses, all

school expenses and all extracurricular expenses). (See attached calculation as Exhibit 2)

In phase three of the transition period, Respondent accepts the evaluators’

recommended one overnight during the week and one 36 hour period on the weekend
(however, evaluators’ recommendation is not clear as to whether the 36 hour period is

every week). Ifthe 36 hour period on the weekend is not every week, then additional hours

should be permitted to Respondent so that he is allowed no less than 60 hours per week.

To the extent the Covid-l9 precautions remain in effect, then this adjustment is easily

achieved by adjusting the schedule to allow the children to engage in online school with

Respondent. This totals approximately 60 hours per week, or approximately 35% of the

time. Child support subject to calculation with Petitioner’s income information but no less

Petitioner has not provided a complete PDD in this action, even at this late date and has
'

refused repeated requests to provide a complete PDD. Therefore, her income is estimated for the
purposes of child support calculation.
4

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


than approximately $ 1 8,248 per month (with Petitioner paying for all therapy expenses, all

insurance expenses, all school expenses and all extracurricular expenses). (See attached

calculation as Exhibit 3)

In phase four 0f the transition period, Respondent requests two months of 4-3-3-4

alternating ovemights. After that, Respondent requests one week on, one week off, 50%
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timeshare. Child support subject to calculation with Petitioner’s income information but

no less than approximately $29,328 per month (with Petitioner paying for all therapy

expenses, all insurance expenses, all school expenses and all extracurricular expenses).

(See attached calculation as Exhibit 4) Respondent proposes that each phase last two

months, rather than the three months recommended by the evaluators.

The remainder ofthe evaluators’ recommendations are accepted: alternating years for

holidays for each parent plus some time on Christmas day for the parent not in custody on

that day, each parent gets their birthday with the children and father’s or mother’s day as
HHHH———t—_‘

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applicable, each parent gets two weeks vacation with the children, all major holidays

should be equally divided between the parties, school holidays shall be spent in the custody

of the parent during whose custodial time such holidays fall, permission ofthe other parent

required for a parent to take children outside California, with notice of destination, return

date, and contact information for such destination provided). All decisions shall be made

jointly regarding the health education and welfare ofthe children including, but not limited

to, schools the children attend; tutors (if needed); summer camps; non—emergency medical
or dental treatment; psychological evaluation, care and treatment (including choice of

therapist, if any); mobile phone and device usage by the children; and place of residence

of the children. The Court may need to appoint one parent as the responsible decision

maker regarding choice of school because currently, there is a difference of opinion

between the parents (Respondent favors keeping the girls in their current school for

stability, while Petitioner favors changing schools). The evaluators recommend that the

parent who engages the children psychological testing make the decision, and currently

Respondent favors such testing while Petitioner opposes it, however Respondent lacks
5

Respondent's Trial Brief Marriage of Presley and ankwood BD642436


funds to pay for such testing. The parties will meet and confer regarding any vacation time

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or holidays not accounted for within this section, and the Court will retain jurisdiction to

settle any disputes between the parties.

Because of her history of abuse, and because sobriety does not last forever in the vast

majority ofcases, to insure the safety of the children Petitioner should be tested randomly

for drugs and alcohol until the children reach the age of majority at Petitioner’s expense.
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Although Respondent has never been addicted to drugs or alcohol, and there is no evidence
that Respondent drinks to excess, to the extent Petitioner insists on similar testing for

Respondent, if Petitioner is willing to pay for such testing, Respondent is willing to submit

to similar testing, but only for a limited time (one year).

All medical insurance, unreimbursed medical expenses, dental or orthodontia

expenses, vision expenses, pharmaceutical expenses, psychological/psychiatric or therapy

expenses, and extracurricular school activities should be paid for by Petitioner because

Petitioner has ample means to pay while Respondent lacks the means to pay such expenses

without child support from Petitioner at this time.

VI. SUMMARY 0F ANY EXPERT REPORTS OR TESTIMONY TO BE OFFERED


Respondent cannot afford his own expert, so has not engaged his own expert.

Dr. Mary Lund and Dr. Meesha Ellis, the evaluators, recommendedjoint physical and

legal custody. Lund found the allegations against Father not very credible. But Lund added,

“Nevertheless, after Mother and Minor‘s Counsel (sic) concern about their the children’s)
welfare with Father, havin only monitored contact with Father for overt ree years, and
the repeated interviewing afiout Father being sexually inappro riatc with them, Harper a_nd
Finley themselves ap ear now to believe that Father did touc them sexually and ls a nsk

to them in the future. Lund Report, page 120.

Consequently, Lund and Dr. Ellis recommended joint physical and legal custody be

stepped up gradually for a fifteen month period, but less than a 50/50 split.

VII. LEGAL ARGUMENTS TO BE RELIED UPON


This trial should be continued due to Respondent’s pending motion in Department 83

for legal costs and fees due to be heard October 6, 2020. Respondent is currently

unrepresented by counsel because he cannot afford counsel and Family Code Sections
6

Respondent’s Trial Brief Marriage of Presley and Lockwood BD642436


2030 and 2032 express a strong preference for both parties to have equal access to legal

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representation. In addition, Respondent lacks certain deposition transcripts because he

cannot afford them, thus California Rules of Court, Rule 3. 1 332 requires continuance. In

addition, a significant event occurred after the evaluation was submitted and therefore the

evaluators should be permitted to alter their recommendations ifthey choose based on that

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event

The bottom line (“overarching”) consideration in adjudicating contested custody is

the child's “best interests.” Family.Code. §§ 30] l, 3020, 3040, 304 l Montenegro v. Diaz
;

(2001 ) 26 Cal. 4th 249, 255. Indeed, the Code vests trial courts with the “widest discretion”

to choose a parenting plan that is in the child's best interests; and the tn'al court's decision

will be upheld on appeal so long as it reasonably can be concluded that the order advances

the child's best interests, consistent with Fam. C. §§ 301 l, 3020 and 3040. Fam. C. §

3040(3), (d) (amended Stats. 2019, Ch. 55 l , eff. 1/1/20); Marriage ofLaMusga (2004) 32

Cal. 4th 1072, 1087. The Court may make an order for the custody of a child during

minority “that seems necessary or proper.” Fam.C. § 3022. However, in exercising their

discretion under that broad umbrella, courts must be guided by several basic statutory

principles:

a. Three critical policy directives: In fashioning suitable child custody and visitation orders

consistent with the child's best interests, courts must consider, and effectuate, three critical

public policies (Fam.C. § 3020):

(l) “Primary concern” for child's health, safety, welfare; child abuse and domestic

violence “detrimental”: The court's “primary concern” is to assure the child's health, safety

and wcifarc. This codified policy is a companion to the Legislature's express finding and

declaration that “children have the right to be safe and free from abuse, and that the

pcrpctration of child abuse or domestic violence in a household where a child resides is

detrimental to the health, safety, and welfare of the child.” Fam.C. § 3020(a); see also

Fam.C. § 3044.

(2) “Frequent and continuing contact” with both parents and shared parenting: Further, an

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


appropriate custody/visitation award must take into account the codified policy “to ensure

l0
that children have frequent and continuing contact with both parents after the parents have

separated or dissolved their marriage, or ended their relationship, and to encourage parents

to share the rights and responsibilities of child rearing in order to effect this policy”

except when the contact would not be in the child's best interests pursuant to Fam.C. §

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3020(a), § 3020(c), and Fam.C. § 301 l. Fam.C. § 3020(b).

(3) Secondary to child/family safety concern: Where there is no threat of child

endangerment, the § 3020(3) and § 3020(b) policies are on an equal footing. But where the

policies conflict (e.g., because domestic violence evidence shows contact with a parent

could jeopardize the child's safety), a custody or visitation order “shall be made in a

manner” that ensures the child's health, safety and welfare and the safety of all family

members. Fam.C. § 3020(c).

Because Petitioner’s allegations of Respondent’s sexual abuse of the children have

been reviewed and dismissed by the DCFS (twice), this Court and the Court of Appeals,

there should now be no issue regarding the children’s safety during visits with Respondent.

It is surprising that the evaluators recommended less than fifty percent custody for

Respondent in light of the Family Code’s stated preference for “frequent and continuing

contact" with both parents. For an unexplained reason, the evaluators’ recommendation

penalizes Respondent unduly for the significant harm done to his relationship with the

children due to Petitioner’s false allegations and her alienation of the children, and the

protracted period of litigation (now the third time these allegations have been litigated) of

those allegations because the evaluators’ recommendation suggests a more than one year
period of transition to ease the transition for thc children and less than fifty percent

custodial share.

Petitioner’s unsubstantiated allegations in 2016 began a period which deprived

Respondent of physical custody of the children for a significant amount of time. Since

2017, Respondent has only been permitted 2| hours per week in monitored visits.

Therefore, Respondent has been already been deprived of almost four years of physical

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


custody and parenting time because of unsubstantiated allegations which are now being

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litigated for the third time (and reviewed for the fourth time). Also, the evaluators

recommend a first phase transition which actually gives Respondent l_e_sg time with the

children than he is ‘currently allowed, which is completely without justification. The

children are now 11 years old, and if they go away to college, they will likely only have

seven years more living with their parents and Respondent has already been deprived of
\Dmflmmhm

significant time with the children. Therefore, it is manifestly unfair to further deprive

Respondent of parenting time without some greater justification than alienation due to

unsubstantiated allegations.

Moreover, there is a new and significant concern since the submission of the

evaluators’ report which must b'e evaluated as directed by Family Code Section 3020. 0n
July 12, 2020, Petitioner’s son shot and killed himself in Petitioner’s home (although

Petitioner was not there at the time). With all due sympathy and respect, this creates a new
and unaddressed twofold problem: the safety of the children and the greater likelihood of

Petitioner to relapse into drug or alcohol dependency.

The children told Respondent that Petitioner walked around the house with a gun in

her hand in 20] 7. There was at least one gun on the premises of Petitioner‘s home at the

time of her son’s suicide and it is unclear where the gun was kept or whether Finley and/or
Harper might have had access to this gun or others. Thus, there is significant high risk to

the safety of the children which would ordinarily justify 100% physical custody to

Respondent at this time in such circumstances.

In addition there is a greater possibility that the children might think about suicide or

attempt it, in light oftheir halfbrother’s suicide. Greater therapy should be required for the

children than that recommended by the evaluators as a result and also serious observation

of the children is now required, which Petitioner may not bc capable of doing due to her

mindset and grief.

Moreover, in light of such a tragic and devastating event, it would not be surprising

for Petitioner to relapse into drug or alcohol use despite her alleged three years sober. The
9

Respondent's Trial Brief Marriage 0f Presley and Lockwood 30642436


death of a child is among life’s most traumatic events, and Petitioner’s son’s suicide, in

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addition to this impending trial, have no doubt caused Petitioner all kinds of previously

unexperienced stress.

As a result ofthese new factors, not contemplated within the evaluators’ report, there

is significant question as to whether the evaluators’ recommendation is actually in the best

©00QOM¥b3
interests of the children at this time. Because there is no corroborating evidence of

Petitioner’s allegations against Respondent and thus no credible threat to the children’s

safety when they are with Respondent, and because of Petitioner’s history of drug and

alcohol abuse, possibility of relapse, and her son’s suicide in her home, there is a strong

argument for 100% custody to Respondent right now. Moreover, the children are behind

at school, have incomplete assignments, are frequently late or absent, one has not had

psychoeducational testing recommended by their school, and the other has a previously

undetected learning disabilities. All of these issues have arisen since Respondent has not

had a significant share of physical custody and has been limited to monitored visits.

Consequently, it may very well be in the best interests of the children for Respondent to

have 100% physical custody.

However, it is likely that the children would benefit far more from a return to some
sort ofnormalcy in spending equal time with both parents and ending this family law battle

between the parents. Judge Draper ordered custodial time to be split evenly in 201 7. Yet,

at the same time, there is also merit to the evaluators’ transition recommendation for the

benefit ofthe girls feeling ofsafcty, mental health and adjustment after such a long period

without ovemights with Respondent. As a result, Respondent seeks joint physical and

legal custody with a short transition period (six months).

The strong preference of the law and the prior order of Judge Draper should be

respected and joint physical and legal custody should be attained as soon as possible,

despite the issues and concerns cited regarding Petitioner. After all this time and legal

wrangling, the children need some semblance of normalcy (and time with both parents).

Consequently, Respondent has proposed a shorter transition period, with faster incremental

10

Respondent's Tn'al Brief Marriage of Presley and Lockwood 30642436


increases ofhis custodial time. Furthermore, Respondent believes that 100% custodial time
for him at this time might confuse the girls more and might also upset them and lead to

new problems, in spite of the significant safety concerns Respondent has regarding

Petitioner. An order of 100% custodial time at this time might also upset Petitioner at a

particularly volatile time for her and lead to relapse.


\GOOHJOU‘IAUJNt—

That said, Dr. Lund stated that Petitioner “has a history of seeing herself as a victim.”

Lund Report, page 104. Lund continued,

“It is likely that in her interactions with others, she continually looks for somethin
the do that hurts her feelings and then concludes she has been victimized, misunderstoo
an mistreated. She appears to be easily hurt and angered.” Lund Rerport, Ibid.

5 Dr. Lund stated that “there is clear information that Mother had attempted in 20 l 6 to

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get the children to make statements supporting her suspicions about Father’s behavior.”

Lzmd Report, page 111. Thus, in the absence of any corroboration of Petitioner’s

allegations regarding Respondent, the only possible conclusion is that Petitioner’s

allegations are false allegations concocted in an attempt to not only make Petitioner a

“victim” but also to diminish Respondent’s custodial time (in part because Respondent

can’t afford to fully litigate all matters as Petitioner can and has) and in order to avoid child

support payments if R65pondent were to have physical custody? “Thus, when


allegations of child abuse or neglect arise, before making a custody determination, the

court must necessarily determine the veracity of such allegations to ensure that it is acting

in the ‘best interest’ ofthe child." RobertJ. v. Carllerine D. (2009) 171 Cal.App. 4th 1500,

1514-1515; see also A.G. v. C.S. (2016) 246 Cal.App.4th 1269, 1285—no error in

awarding Father sole custody where substantial evidence supported court's implied finding

that it considered abuse allegations against children and “found them (the allegation)

1
The court may order supervised visitation or limit a parent's custody or visitation if it finds
substantial evidence that the parent, with intent to interfere with the other parent's lawful contact
with the child, made a report of child sexual abuse, during a custody proceeding or any other time,
that the reporting parent knew was false when made. [Fam.C. § 3027.5(b) (amended Stats. 2019, Ch.
115, eff. lll/20)] Respondent requests that the Court consider this in light of the false allegations
brought by Petitioner against Respondent, now for the fourth time.
ll

Respondent's Trial Brief Maniagc of Presley and Lockwood BD642436


wanting.” Petitioner is still asserting these same allegations despite both the Dependency

l0
Court’s, DCFS’ and the Court oprpeals’ dismissal ofthem, and the evaluators’ inability

to find any corroborative evidence. Petitioner now re-litigates these allegations for a fourth

bite at the apple. Petitioner’s credibility and motive must be questioned at this point. In the

absence of any corroborative evidence, Petitioner‘s allegations should be disregarded as

©00~JQUI#UJ prejudicial without probative value.

While Petitioner may argue that there is a question of safety of the children with

Respondent, in light ofPetitioner’s son’s suicide in her home, there is a far greater question

ofsafety ofthe children with Petitioner than Respondent. Petitioner has sobriety issues, has

a problem with substance and alcohol abuse, kept at least one firearm in the house where

her son had access to it and used it to kilI himself, carried a handgun in front of the

children during 2017 at home’, and thus Petitioner is a far greater risk to the children’s

safety than Respondent.

In addition, Petitioner attempted to alienate the children from Respondent (as

evidenced by the video recording of Petitioner coaching them regarding baseless

allegations against Respondent, bad mouthing Respondent to the children and using the

baseless allegations against Respondent to limit Respondent’s custodial time to 2|

monitored hours per week, thus firmly driving a wedge between the children and

Respondent). Petitioner was raised as a Scientologist and continues to employ a central

principle of Scientology: “Fair Game” or “Fair Gaming.” Scientologists employ this tactic
against perceived enemies to punish and harass them by any means possible (Wikipedia

defines “Fair Game” as private investigations, character assassination, and legal action

against perceived enemies and states that it is “a core religious practice” of the church)“.

3
At the time, Petitioner had two ovcmights with the children each week, the children stayed
the rest of the nights with Petitioner’s mother.

4
Scientology founder L. Ron Hubbard stated in 1955, "The purpose of the suit is to harass
and discourage rather than The law can be used easily to harass, and enough harassment on
to win.
somebody who is simply on the thin edge anyway, well knowing that he is not authorized, will
generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly".
12

Respondent‘s Trial Brief Marriage of Presley and Lockwood 80642436


Petitioner responded to a text message from her older daughter in May 2016 referring to
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Respondent as an “SP” (according to Wikipedia, a “Suppressive Person”) by saying “I’ve

known this all along I just need to make absolutely sure he won’t get to take ur (sic) sisters

every other week n (sic) get joint custody which courts automatically grant! That’s what

I’ve been doing all this time.” (Respondent’s Exhibit 1). Various Petitioner’s text

messages talk about “a plan.” Consequently, Respondent was followed by private


\DOO‘JO‘UILDJ

investigators and surveiled, as well as maiigned in the previous DCFS investigation and
Dependency Court proceeding without any legitimate basis, and Petitioner continues to

assert these debunked allegations.

Nevertheless, Respondent respects the statutory preference for “frequent and

continuing contact” and believes it is important for both parents and the childxen, provided

the safety of the children is maintainedS, for joint physical and legal custody without

monitors, with random drug and alcohol testing. Respondent does not oppose attending

therapy with the children and/or the children attending therapy with Respondent’s fiancee,

however Respondent lacks the means to pay for such therapy at the moment. Respondent

asks this Court to order Petitioner to engage in therapy indefinitely, at her own cost to

maintain sobriety. After the rancor and proceedings of the past few years, a great deal of

repair to their relationships with their children will need to be done by both parties.

In the best interests of the children as well as Petitioner, regular random drug testing

should also be required. “The plain language of [Fam C. § 3041.5] permits the family

See. The Scientologist - A Manual an the Dissemination ofMaten'al, reprinted in Hubbard, L. R.


(1976). The Technical Bulletins of Dianetics and Scientology. II. Copenhagen: Scientology
Publications.ISBN 0-685-04188-3. quoted in Lane, Jodi M.; Kent. Stephen A. (January 30, 2008).
"Malignant Narcissism, L. Ron Hubbard, and Scientology's Policies of Narcissistic Rage" (PDF):
24. Retrieved December S, 2009. published
, in French as Lane, Jodi M.; Kent, Stephen A. (2008).
"Politiques de rage et narcissisme malin". Criminologie. Les Presses de l'Universite’ dc Montréal.
41 (2): 117—155.

5
Respondent currently lives with his fiancee and his mother, so even ifthere were any safety
concerns in leaving thc children with him, he would seldom be alone with them cvcn at his home.

13

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


court to order any person who is seeking custody of, or visitation with, a child to

undergo testing for the illegal use ofcontrolled substances and the use ofalcohol . .. [and]

[n]othing in the statute limits the family court to ordering drug testing for a fixed period
oftime." Heidi S. v. DavidH, l Cal.App. 5th 1150 at 1172-1 173.

Petitioner has been in rehabilitation facilities for drug or alcohol issues at least five
\oooqaan-hww._

times and attended outpatient rehabilitation until 20 l 8, but has not participated in a twelve

step program. Petitioner admitted that as recently as October 2016 she took 20 to 80

Oxycodone tablets My, then used cocaine in order to stop using Oxycodone.

Respondent does not know whether Petitioner is sober at this time, but photographs in the

media indicate that Petitioner has smoked marijuana and drank beer since her last

rehabilitation stint (see Respondent’s Exhibits 64, 56-63) and the strong possibility of

relapse exists, especially in light of the most recent events. A common alcoholics

anonymous adage is “Relapse is part of recovery” and although Petitioner professes to be

sober, relapse is likely statistically and even a greater possibility in reaction to her son’s

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suicide. Thus, there is no guarantee that if Petitioner is currently sober that Petitioner will

remain sober, and therefore there is significant risk to the safety of the children without

drug and alcohol testing for Petitioner and a twelve step program. In addition, Ms.

McCormick, who lives with Petitioner, is employed by her, and may be romantically

388§B~_ommqougum_o
involved with her, previously obtained drugs and alcohol for Petitioner and thus serves as

an enabler. The power imbalance between Petitioner and Ms. McCormick force Ms.

McCormick to do what Petitioner demands. Consequently, her continued presence on the

premises of Petitioner enhances the risk to Petitioner’s sobriety.

In contrast, Dr. Ellis stated in her deposition that she believes that Respondent creates

a very low risk for the children. [Ellis Deposition, 172:25—17425]. In light of the recent

suicide of Petitioner’s son, Respondent seeks a greater custodial share than recommended
by Dr. Lund in order to provide a more safe, stable, guiding influence for the children.

Joint legal custody means that both parents share the right and responsibility to make
decisions regarding the child's health, education and welfare. [Fam.C. Marriage
IQ m § 3003;

l4

Respondent's Trial Brief Marriage of Presley and Lockwood 30642436


ofBurgess (1996) l3 Cal. 4th 25, 29] Respondent’s stable input is required here as is joint

legal custody.

Respondent hopes that Petitioner will stay sober and get back to a normal life.

Between Petitioner’s sobriety issues and Petitioner’s possession and handling of guns,
\OMQGUI#WNn—-

Respondent believes that anything more than 50% physical custody to Petitioner beyond
a transition period is not in the best interest of the children. Furthermore, it rewards

Petitioner for alienating the children and turning them against Respondent, while

penalizing Respondent for having less contact with the children by court order. For the

aforementioned reasons, 50% physical custody for Petitioner may not even be in the best

interest of the children at this time, however Respondent respects the strong preference of
how
HO
the law forjoint custody. Respondent also seeks periodic random drug and alcohol testing

-_.
IQ
of Petitioner for a long period of time and if Petitioner tests positive, physical custody

H DJ percentage for Petitioner shall be diminished. Although he has no addiction problem,

-—
h Respondent is willing to also submit to random drug and alcohol testing, if Petitioner so

requests and the court deems it necessary, as long as Respondent does not have to

U’l
pay for

— Q
such testing (because he cannot afford to do so) and provided Petitioner is subject to

H q similar testing. A strong well worded court order is needed because Petitioner has the

— m means to relentlessly litigate, while Respondent lacks the means to enforce any court order

t—I
\D
at this time.

No Finally, Petitioner seeks the equitable intervention of this Court while Petitioner has

I0 .—
failed to provide a complete Preliminary Declaration of Disclosure (PDD) even at this late

date. Petitioner has failed and refuses to comply with Family Code Section 2 l 00 and thus

Petitioner should be denied any equitable relief because of her “unclean hands.”

In the end, the goal is what is really best for the children. As in many divorces, to

paraphrase former Israeli Prime Minister Golda Meir, there will bc peace only when

Petitioner loves her children more than she hates Respondent. It is long past time to put the

bickering to rest and undo the damage to the children from the last few years, and both

parents will need to do that in cooperation.

15

Respondent’s Trial Brief Marriage of Presley and Lockwood 80642436


VIII. ATTACHMENTS AND EXHIBITS
IQ
a. CSSD child support calculations (Exhibits 1-4)

Dated: July 23, 2020 Respectfully submitted,

©00~IGUI$M

s/ Michael Lockwood

Michael Lockwood
In pro per

10

ll

13

14

15

16

17

18

19

20

21

22

23

24

26

27

28
16

Respondent‘s Trial Brief Marriage 01' Presley and Lockwood 80642436


RESPONDENTS TRIAL BRIEF BD642436

EXHIBIT 1

l7

Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


7/20/2020 Calculatlan Results Summary and Deiail

Calculalion Results Summary

Chiid
Child

Chlld Care

rave!

School
HealIh
Arrears
S Amounl
Information Year: 2020) Plum 1
Net Income
Taxable a Non-Taxable Gross Income
Taxabia Gross Income
Non-Taxabie Gross
Gross Income
Taxable
Income 4
Tax Filing Status MARRIED
SEPARATELY (N 0T
PARENT

SAME AS
(State

Liabimias
Tax Liabilities

andlor Medicare
Tax

Assistance
Iommy
Paid
Un1on Dues
Retirement
Related Expenses 8. Spousal Support Other

Insurance
DeductiOn Amount
Deduction
Health

Monthly Suppon Amounts Per Child 'l. Time 1 Farm! Parom


with Add- 1 1 Tom 2 Add- 2
Parent 1 On: Om
20 0.00 0.00 0 .00 0. 1787
20. 0 O. 0.00 D

3’. Time with Parent 1

PARENT 2 is required to pay PARENT 1 84765.00 In CURRENT SUPPORT

Tom Child Support Amer: Per Child


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Respondent‘s Trial Brief Maniagc of Presley and Lockwood BD642436


712012020 Calculation Results Summaty and Detail

Chlld Name Prlor Potlod Date Range Parent 1 Parent 1 Parent 1 Pamm 2 Panm 2 Parent 2
Add-Ona Support Total Add-Ons Sunken Total

FIRST~BORN Not Applicabie 0.00 0.00] 0.00 0.00. 0.00}


.SECOND-BORN Nol Applicable

Guideline Caicuiafion Results Deni]

Tax Information

Tax

FICA
Medicare
Income Credh
Savar‘s Credit
ol Children for Child Care Credits
of Children for Earned Income Ctedits
cl Children lor Child Tax Credits
o! tor Tax Credits
is Blind

is 65 0t OIder

ls Blind

is 65 or Older

Filing Sepatately. Lived with Spouse Part of the

‘I’ax

California Slate Income Taxes


California Siale Insurance
Credit for
Jount Head ot Household Ctedit

Calfiomia Renters Cred-‘I

Calflomia Earned Income Tax Credit


Cafltomia Child Tax Cmdlt
Number of Children lor Child Tax Credits
Other State Income Taxes
Other Slate Tax Rate
Othet State Tax Amount
type when Parent 1 and Parent 2 are Married

Monthly Income Intommlon


Parent 1| Pam: 2
WageslSalary I 2000.00] 190000.00
jaunt 1: Based on eamad income: $2000.00 MONTHLY
Parent 2: Based on earned Income: 319000000 MONTHLY
Solf-Employmont income o.col 0.0m
[Unemploylmm Compensation 0.00] 0.00I

[mummy (7mm) om] o.oo|


l
19 I I

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Respondent's Triai Brief Marriage 01' Presley and Lockwood BD642436
70M020 Cahllnfnn Results Summary and Data]

Other Taxable income


Income
Income (Retirement.
Losses. elc)
Term Capilal Gains

Term Capital Gains


4e 1mm IRS Form 4952
Secton 1250 Gains
Dividends
Dividends
Received

Income
Taxabh Income
Other Non-Taxablo Income
Non-Taxable Income
Income Taxable
Interest

Received Other
Assistance and Chlld
Assislance
Support Received
Income 8 Doduclions

Income
Income (Taxable
Income Taxable
Taxable Income
I Pald Other
ISupporl Paid Other Marrzage (Non-Tax

Contflbuu'on if to Income
Union Dues
Job—Related

Deduction Information
Parent 1 Paton!
Paid Relations!“
Pnld This
Tax
Inumt
Bunlnm lncomo
nomlzod Deductions
Medical
Interns!

Deduction
and Loca Sales ax
ltemlzed
Union Dues
Health Insurance Premium
hllpsdfgc cu.nagoWChlldSuppomcsolguIdols'MCaICumomlowGuidofinoc:NumSumryAMDauflFomWesullepc-Goucunvjdfiulaotlnocm. . 3M
Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
7'20I2020 Calculator: Results Summary and Detail

Insurance Tax
Insurance (Post-Tax
Deducfion Tax
Deduction
Contributions
Retirement
Retirement (Non-
Retirement
Reurement Non-
Guldolinu Deductions
Parinar Support Paid Other Ralalimship
uctible

Panner Suppon Paud Olher Relallonship


Tax Daducfiblo
Job-Related

Io Income
to Itemized Deductions
Deduction
Deduction Amount
Deduction Children
Deduction
Health
Losses
Tax Deductions
la Income
Deductions
Mlnlmum Tax Information
Interest on Home
Interest

1986 Depreciation
Gain or Loss
Stalk
Activities

and T Schedule K-1


Interest Ftom Private Bond
Preferences
Mlnirnurn Tax Loss Deduclion

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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
RESPONDENT'S TRIAL BRIEF BD642436

EXHIBIT 2
22

Respondent's Trial Brief Marriage 0f Presley and Lockwood BD642436


?IZOROZO Calculation Results Summary and Daka'd

Calculation Results Summary

Futon! 1 Paton!
Child‘ Amount 71

Chitd Amount 71
Add-Ons Amount
Chfld Care
Vlsits/Travel Expenses
School
ninsured Haallh
Meals Amount
Spousal Amounl
Taxflncomo Informatlon Year: Parent
Income
Taxable 8. Non-Taxable Gross Income
Taxable Gross Income
Non-Taxable Gross Income
Gross Income 2000.
T Income 171 7.
Income Aflar ‘8537
Tax Filing Status
PARATELY (WFTH

of Tax

Tax Smtus
of ax (Slate
Liabilities

Tax Liabilities

andlor Medicare
Tax
I

Assistance
Deduction Toma Parent 1

Paid 0.

Union Dues
Retirement
Relaled Expenses 5 Spousal Suppon Olher

Insurance Premium
Deduction Amount
Deduction Chiidren
Health
Losses
Monthly Amounts Child Time Pannt 1 Parent Parent Panm Parent Pam“
with Add. 1 1 Total 2 Add- 2 2 foul
Parent 1 Ons On:
-80RN 0‘ 0. 0. o 2886. 2685.
29 0 0 4478 4476.

% Time with Pam! 1 29

PARENT 2 is tequired to pay PARENT 1 $7162.00 in CURRENT SUPPORT

tom Child Support Amen Per Child


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Respondent‘s Trial Brief Marriage 01' Presley and Lockwood 50642436


7120,2020 Calculamn Rasulu Summary and Betas!

Child Name Prior Period Data Range Parent 1 Parum 1 Parent 1 Parent 2 Pamm 2 Parent z
Add-Ons Support Toul Add-Ons Support Total
FIRST-BORN Not Applicable 0.00 0.00] 0.00 0.00 0.00 0.00
SECOND-BORN Not Applicable 0.00 0.00 0.00 0.00 0.00 0.00

0.00 0.00 0.00 0. 0.00 0.00

Guideline Calculation Results Detall

Tax
Paton! 1

Tax

FICA and Mediate


Medicare
Income Credil
Savers Credit
of Children for Child Care Credits
of Children tor Earned Income Credits
ot Children tor Chlld Tax Credits

of for Tax Credits


is Blind

Is 65 or Older
is Blind

Is 65 or Older
Filing Separately. Lived with Spouse Pan of the

Tax
Calilomia Sme Income Taxes
California State Insurance
Cradil for
Joint Head o! Household Credit
California Renter‘s Credit

California Earned Income Tax Credi1


California Child Tax Credit

Number of Children for Child Tax Credits


Other Stale Income Taxes
Olhe: Slate Tax Rate
Other Slate Tax Amount
type when Parent 1 and Parent 2 are Married

Monthly Income Intommlon


Parent 1| Paton! 2
IWagouSamy | zooo.oo| 190900.00:
Pawn! 1: Based on earned income: $2000.00 MONTHLY
Pawn! 2: Based on earned income; 519000000 MONTHLY
|soif-Employmom lneomn 0.00} 0.09]
IUnomploymont Compensatlon 0.00] 0340'

[mummy trauma} n.oo| o.col


|
24
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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436


7/2012020 Calculation Rana: Summary and Data!
Other Taxable Income
Income
Income (Retirement. Annuity.SS Other Rel.
Losses.
Term Capital Gains
Tenn Gains
4e from IRS Faun 4952
Socion 1250 Gains
Dividends
Dividends
Received

Income
Taxabie Income
Other Non-‘l’axablo Income
Non-Taxable Income
Income Taxable
Interest

Received Other
Asslszanco and Chm Renewed
Assismnce
Received
Income a Deductions

Income
Income
Income Taxable
Taxable Income
Paid Other
Suppon Pabd Other Marriage (Non-Tax

Contribution if Io Income
Union Dues
Job-Relatad

Deduction Informmlon
Parent 1 Paront
Pald
Paid This
Tax
Interest
Business Income
numbed Daductions
Medical
Interest Expenses
Deduction
and Local Sales Tax
Itemized
Union Dues
Health lmumnce Premium
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Respondent's Trial Brief Marriage of Presley and Lockwood 30642436
712012020 Calculation Result: Summary and Detaul

Insurance
Insurance
Deduction
Deduction
Contributions
Retirement
Retirement (Non-
Reflrement (Tax
RelIremant
Guldelinn Deductions
Penner Support Paid Other Relationship

Panner Suppon Pald Othet Relationship


Tax Deductible
Job- Ramed

to Income
to Itemized Deductions
Hardlhlp Duduction
Deduction Amount
Deducfion Children
Daductlan
Health
Losses
Tax Doductions
Io Income
Deductions
Mlnlmum Tax informaflorl
Interest on Home
Interns!

1986
Gain or Loss
Stock
Activities

and Trusts. Schedule K-1


Interest From Private

Preferences
Minimum Tax

26
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Respondent's Trial Brief Marriage of Presley nnd Lockwood BD642436


RESPONDENT'S TRIAL. BRIEF 30642436

EXHIBIT 3
27

Respondent's Trial Brief Man'ingc of Presley and Lockwood BD642436


7I2012020 Calculalion Reaulis Summary and Dela]

Calculation Results Summary

Total: Plum
Child Amount 91
Amounl 91
Add-Ons Amount
Child Care

mvel
School
Uninsured Heaith
Arrears Amounl
Spousal Amount
axllncome You: Parent 1
Disposable Income 1

Taxable & Non-Taxablc Gross


axable Gross Income
Non-Taxable Gross Income
Gross Income
Taxable Income
Income
Tax Fling Status
TELY (WITH

0t Tax
Tax

Tax Liabililiea

Tax Liabilities

andlor Medlcare
Tax

Assistance

Paid
Union
Retirement
Relaled Expenses

Insurance Premium
Deduction Amount
Deduction Children
Health
Losses
Montmy Amounts Pet Chud Tim ParanI Parent
with 1 Total 2 Add-
Parent 1 On:
.BORN 0.00 0
35 0.00 0

PARENT 2 is required to pay PARENT 1 $91 24.00 in CURRENT SUPPORT

Total Child Support Arrears Per Child

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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
”200020 Calculauon Results Summary and Detail

Child Name Prlot Period Data Range Parent 1 Parent 1 Parent 1 Pawn: 2 Patent 2 Parent 2
Add-Onl Support Total Add-Om Support Total
FlRST-EORN Not Applicable 0.00 0.00 0.00 0.00! 0.00 0.00
sECOND-BORN Not Appucabla 0.00 0.00 o. 0.00 0.00 0.00

0.00 0.00 0.00 0.00 0.00 0.

Guideline Calculation Results Detail

Tax
Parent 1

Tax
Indude Taxes
Include FICA and Medicare
Include Medicare

Income Credlt
Savers Credit
Number 01' Chlldren for Child Cara Credits
Number oi Children for Earned Income Credits
oi Children [or Child Tax Credits
umber oi for F Tax Credits
ls Blind

is 85 or Older
is Bllnd

is 65 or Older
Filing Separately. Lived with Spouse Par! cf the

Tax
Include California Sula Income Taxes
California Stale Insurance
Dependency Credit fat s)
Joint Head of Househoid Credit
California Rentefs Credit
California Earned Income Tax Cred]!
Calilomla Chiid Tax Cred“
Number of Children Ior Child Tax Cradils
Other State Income Taxes
Other Slate Tax Rale
Other Stale Tax Amount
type when Parent 1 and Parent 2 are Married

Monthly Income lnfurmatlon


Pannt 1| Parent 2
IWagosISaIary | znno.uol_ 190000.00
jaunt 1: Based on earned income. $2000.00 MONTHLY
Parent 2: Based on earned Income: 519000030 MONTHLY
SoIf-Employmont Income 0.00] 3.00]
Unemployment Compensation 0.001 0.00]

mnbmty (Taxable) o.uo| 0.1m]


19— I I

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Respondent's Trial Brief Marriage ol' Presley and Lockwood BD642436


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Insurance Pre-Tax 0. D.

Insurance
Deduction Pre-Tax)
Deduction -Tax)
lerement Contributions
Retirement
Retirement (Nun-Tax-Deferrad
Retirement
Retirement Tax
Guldellne Deductions
Partner Support Paid Other Relations?! p

Panner Support Paid Other Relationship


Tax Deductible
an-Ralatad

lo Income
to Itemized Deductions

Deduction
Deduction Amount
Deduction Children
Deductlon Expnnus
Health
Losses
Tax Deductions
lo Income
Daduciions
Minimum Ta: Informatlon
Interest on Horne
Interest

1986
Galn or Loss
Stock
Activities

and Trusls. Schedule K-1


Interest From Private Bond
Preferences
Minimum Tax Loss Deduction

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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
RESPON DENT’S TRIAL BRIEF 30642436

EXHIBIT 4
32

Respondent's Trial Brief Mnm’agc of Presley and Lockwood 80642436


7I20l2020 Calculation Resulls Summary and Dolall

Calculation Results Summary

Totals
Child Amount
Child Amount
Add-Ons Amount
Child Care
Visitsn'raval

School
Uninsured Health
Arrears Support Amount
Amount
Taxllncomo lntormatlon Year:
Net Income
Taxable a Non-Taxabla Gross Income
Taxable Gtosa Income
Non-Taxable Gross
Gross Income 2000.
Taxable Income 1717
Income Afler 1

Tax Filing MARRIED F


SEPARATELY (WITH

ol Tax
Tax SAME AS

Tax Liabilities

Tax Liabilities

andlor Madlcare
Tax

Msistance
Doduction Total!
Paid (Other
Union Dues
Retirement
Related Expenses Suppon Other

Insurance Premium
Deduction Amount
Deduction
Heath
Losses
Monthly Support Amounts Parent Pannt Parent 2 Pmm 1
with 1 Add- 1 ‘l'oul 2 Add- Support Total
Parent 1 On: 0m
-BORN 50.0 . 0.00 5499.
D 91

$6 11am wlth Parent 1

PARENT 2 Is required lo pay PARENT 1 514664.00 in CURRENT SUPPORT

olal Child Support Arman Pat Child

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Respondent‘s Trial Brief Marriage of Presley and Lockwood BD642436
"2012020 Calculation Results Summary and Damn
Child Name Prior Period Date Range Farm! 1 Parent 1 Parent 1 Pawn 2 Parent 2 Parent 2
Add-Ons Suppon Total Add-Ons Suppon Ton!
FIRST-BORN Not Applicable 0.00 0.00 0.00 0.00 0.00| 0.

SECOND-BORN NotAppllcable 0.00 0.00 0.00 0.00 0.00 0.

0.00 0.00 0.00 0.00 0.00 0.00

Guideline Calculation Results Detail

Tax Information
Parent 1
Tax

FICA
Medicate
Income Credit
Savers Cmdk
of Children for Child Care Credits
of Chlldren for Earned Income Credits
ot Children for Child Tax Oredlts
o! for Tax Credils
is Blind

is 65 or Oldet
ls Blind

is 65 or Older
Filing Separately. Lived with Spouse Part of the

Tax
California Stale Income Taxes
California State Insurance
Credit tor
Joint Head oi Household Credit
Califomla Renler‘s Credit
Caufomia Earned Income Tax Credit
Calélomla Child Tax Crack
Number of Children for Chlid Tax Credits
Other State Income Taxes
Other State Tax Rate
Other Slate Tax Amount
type when Parent1 and Paranl 2 are Mamed

Monthly Income Information


Penn! 1| Parent 2
wageslsmuy I 2000.00] 1 mono.»
Parent 1: Based on earned income: $2000.00 MONTHLY
Parent 2: Based on earned Income; 519000090 MONTHLY
Sclf-Employmnt Income 0.00] 0.00
[Unemployment Compensation 0.00] 0.00]
Warmly (1mm) moo] o.oo|
I
34 I l

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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
7120mm Catcutaflon Results Summary and Delait

Other 'I’axlblo Income


Income
Income (Refiremenl. Annuity.SS Other Rei,
Losses. etc
Term Caputnl Gains
Term Gains
49 tram IRS Form 4952
Secton 1250 Gains
Dividends
Dividends
Received

Income
Taxable Income
Other Non-‘l’axablo Income
Non-Taxable tncorne
Income Taxabie
Exempt lnteresi

Received Olhet
Assistance and Child Received
Assistanw
Suppon Received
Income a Deductions

Income
Income
Income Taxable
Taxable Income
Paid 01m!
Suppofl Paid Other Matriage (Non-Tax

Contribution it to Income
Union Dues
Job-Relaied

Deductlon information
Parent 1

Paid
Paid Thls
Tax
Iniomst
Business Income
Itomizad Deductions
Medical Expenses
Interesl

Deduction
and Local Sales Tax
Itemized

Unlon Duos
flealth lnsunnco anlum
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Respondent's Trial Brief Marriage of Presley and Lockwaod BD642436


712012020 Ca1wlatmn Results Summary and Detail

Insurance Tax
Insurance Tax
Deduction
Deauclbn Tax
Contributions
Relirement
Retirement Tax-Defarred)
Raliramanl
Retiremenl (Non-
Guldallne Deductions
Partner Suppon Pald Other Relationship

Partner Suppon Paid Other Relationship


Tax Dlduclible
Job-Related
ushnoms
to Income
to Itemized Deductions

Deduction
Deduction Amou nt
Deduction Chlldren
Dcducxlon
Health
'

Losses
Tax Deductions
Io Income
Deduaions
Minimum Tax lnformatlon
Interest on Home
Interesl

1986
Gain or Loss
Stock
Activities

and Tmsls. Schedufe K-1


Inlerest From Private Bond
Preferences
Minimum Tax Loss Deduction

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Respondent's Trial Brief Marriage of Presley and Lockwood BD642436
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Respondent's Trial Brief Marriage 0f Presley and Lockwood 30642436