7 Twila Markham V Gerald Markham RES Declaration-Reply 13-3-08383-7 SEA

FILED
13 O C T 16 PM 3:52
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K IN G C O U N TY
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HONORABLE SUSAN AMINI
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR KING COUNTY
In re the Marriage of
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a
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No. 13-3-08383 SEA
TWILA MARKHAM
Petitioner
) Reply to Petitioners Response to

) Respondents October 4. 2013 Motion
)toDismiss for lack of Washington Civil
) Rule 12(b)(1)
jurisdiction over the subject matter
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GERALD WAYNE MARKHAM
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Respondent
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PRELIMINARY REPLY TO PETITIONERS FACTUAL
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CLAIMS
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Petitioner (Twila) responds to Respondent (Jerry)s good faith 12(b)(1)
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Motion to dismiss by essentially improperly attempting this courts attention from
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the events of their 33 year Alaskan marriage to the events of one unfortunate
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evening of April 24, 2013. Whereas his motion is amply supported by Twilas
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clear April 15, 2013 sworn admissions to a Kodiak domicile (which is clearly
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contrary to the interests she claims here) which is independently corroborated in a

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recorded statement to police on that unfortunate night when she called them to the
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house the parties maintain at 810 NE 58th Seattle for the times when they stay
there. On this occasion they were in Seattle on a layover on a through Alaska
airlines through ticket from Tucson to Kodiak which started on April 9, 2013.123*
Twila's counsel seeks to misdirect the focus of this court by attaching an
irrelevant and (conspicuously) incomplete , unverified police report of that one
1 EX A Alaska Airlines receipt for Jerry (Twila possesses records showing she
traveled on an identical itinerary). Jerry7had previously been in Kodiak until
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December 21,2012, then Seattle for 10 days and on to Tucson on December 31,
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2013. He was joined there by Twila on January 6.2013. There they stayed in a
house they own in Green Valley (20 miles south of Tucson). Jerry stayed there
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continuously December 31,2012 - April 9,2013. Twila returned to Seattle on
12 about January 1$ to be with the parties sick dog planning to return with him in a
week, however concerns about his recovery delayed that until about February714,
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2013 when his vet felt it safe for him to travel. The parties then left Tucson
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together with their dog on April 9,2013 stopping in Seattle on their through tickets
back to Kodiak.
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2 See EX C the omitted first pages of said report which shows investigating
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officers corroborated Jerrys claims that Twila was highly intoxicated (and that he
17 was sober and calm). Furthermore Twila and her sons affidavits conspicuously
ornit (but the police car video tapes of this incident reflect) he voluntarily reported
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to police that his actions (which did not amount to an assault) were motivated by
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his extreme concern for Twila w?hose levels of intoxication (with no threat of
2C violence on his part whatsoever) just four days before prompted his 911 call for
her care and resulted in an EMT response leading to her ambulance transport to
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Virginia Mason Hospital. EX D. This relapse into intoxication Jerry asserts her
22 psychological and medical records will show* have been recent and motivated by a
combination of the serious illness of the parties dog, the friction that exists
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between Jerry and her relatively recently divorced and more recently unemployed
son, and the lingering last illness of a close friend in Tucson who died on May 31,
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2013. In deference to his concerns for Tw7ilas privacy no further explanation will
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be offered until the hearing but in view of her recent allegations unless she is much
more forthcoming at the scheduled hearing (which she may wish to have in
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camera) Jerry will be forced to seek both the EMT and medical records
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surrounding this April 19, 2013 incident (EX D) as well as her psychotherapy
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records and medical records for the proceeding years to refute her recent charges
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1 unfortunate evening which shows the parties had very different views of the
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events. Nevertheless published the Seattle Municipal police policy (EX B) that
dictates that a response to a 911 call alleging domestic violence will result in an
arrest (despite the lack of any physical evidence of serious abuse here) lead to
Jerry's arrest and a misdemeanor DV charge. Twilas counsel then improperly
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attempts to draw inferences from his agreement to a stipulated order of

continuance3 of that charge that by its own terms (Twilas EX 2 pg. 1 ^ 4) reflects:
by entering in the agreement he or she is not admitting guilt
and that no determination has been made by the judge as to whether
this evidence is sufficient to support a finding of guilty
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Then predicated on nothing more than this one unproven charge and her
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(financially motivate) declaration and that of her (similarly motivated) 42 year old
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son (by an earlier marriage) she claims Jerry s allegedly browbeat and berated to
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executed her April 15, 2013 affidavit fraudulently against her will? This claim is
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simply incredulous as it was drafted and independently notarized well before this
one allegation of domestic violence even arose.
Jerry will respond by establishing that Twila has a Bachelors degree in
psychology and credits toward her masters and that she has in the past spent time
in his office assisting him in litigation both with and against other attorney's many
of whom (including a Senior US District Judge) are her close friends. Moreover
that from his hard labors in his law practice he has amply provided the funds to
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enabling her to purchase unencumbered stocks and bonds which she holds in her
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26 of domestic abuse prior to this one April 24,2013 incident (devoid of evidence of
serious harm). Specifically in their 33 year long marriage there has not been one a
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police call for a domestic disturbance nor had Twilas ever spoken to a physician
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or therapist claiming Jerrys domestic physical violence.___________________________
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own exclusive brokerage accounts (accessible with passwords unknown to Jerry)
having a net value of over $1.5 Million dollars!34
Moreover during the very times she alleges she was being coerced by him,
these brokerage accounts will conclusively demonstrate she was exclusively
actively managing and trading those stocks and bonds online (without the
involvement of a broker or Jerry) in her sole name as well as managing numerous
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other financial affairs. Additionally Jerry used his own separate funds to acquire to
three separate fully paid for homes in Anchorage, Seattle and near Tucson
respectively which he put in joint tenancy with her (in addition to making vast
improvements to another fully paid for Seattle home titled in her sole name).
The labors of his law practice also provided the funds to put her son (by a
prior marriage) through seven years of college (where he performed poorly barely
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managing a BS degree in English with a 2.0 GPA after those 7 years) and that
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thereafter he has since frequently had long period of unemployed (most recently
for about three years starting in 2010 and previously for almost five starting in
2001). And finally Jerry will prove that he has fully supported Twila throughout
their 33 years marriage and since their separation (as she was not employed outside
of the home) and her son as she raised him as well as putting him through college
without benefit of any financial aide. And later (as her declarations allege) he
helped her son now age 42 buy his home which is effectively virtually next door
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3Which Jerry will establish he wras induced to enter by the written representations
of Twilas attorney that by doing so the parties could reunite and he could save
their marriage.EXE.
4 Jerry had possession of the statements from one of these accounts (showing a
balance of almost $1.1 Million) because she receives it (and all of her mail) at the
parties 211 Mill Bay residence in Kodiak. He does not have a copy of her second
(Ameritrade) account but has recently seen it in connection with preparing the
parties 2013 tax returns and will testify it exceeds $400K. Said accounts should be
viewed in camera and copies filed under seal.___________________________________
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1 to the house they maintain in Seattle. Unfortunately though Jerry1 has raised
2 Twilas son Adam and loved him as his own since he was seven years old taking
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him fishing and hunting and trying to expose him to the wonders of Alaska, Adam
never really hook to Alaska or his step-father and his marginal performance in
school and in the work force to date coupled with his proximity to Twila and Jerry
when they are in Seattle has occasioned a good deal of friction between he and
Jerry over the last several years during which Adam both underwent a divorce of
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his own and more recently lost his job. And this friction has in turn occasioned a
great deal of consternation between Twila and Jerry'.
As her declaration at pg. 2 f 3 reflects Twila dearly loves her son and
enjoys having him nearby as she perceives he
is a great help to me. But
likewise his (out of work) availability, proximity, 42 year old age, size and strength
strongly mitigates against any claim that she was physically coerced into signing
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her April 15, 2013 affidavit (or describing her Alaskan domicile in her statements
to and while in the protection of the police on the night of April 24,2013). On the
contrary as she further admits in her declaration at pg. 3 f 6 Jerry1insisted we be
domiciled on paper in Alaska! Selfish (or not when one understands the both
financial and wilderness benefits of an Alaskan domicile) this admission indicates
her awareness that in acceding to Jerrys (reasonable) wish she made a voluntary7
choice to an Alaskan domicile. See legal discussion infra. In point of fact, both
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through her involvement in his law7 office and through Jerry, Twila w7as clearly
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made aware o f the effect of claiming an Alaskan domicile as clearly evidenced
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when over twenty years before she responded to another suit in which she and
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Jerry7 raised their Alaskan domicile to defeat Washington jurisdiction over a suit
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against them. EX F.
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Respondent will close this description of the facts with a brief word
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regarding Twilas counsel incredulous attempt to bolster her claim to a
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Washington domicile by attacking Jerrys claim to being an Alaskan based on the

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greater number of days he has been present in Washington and that his doctors are
all in Alaska, and that under his stipulated order of
continuance he is (effectively) compelled to spend a minimum of 26 weekly
sessions of DV treatment here in her efforts to have this court ignore both o f their
substantial badges of domicile (of choice) and their mutual strong physical
connection with Alaska where Jem7 was bom, raised, returned immediately after
law school to practice Maritime personal injury7 law for now over 40 yearn and
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J The pleading served on J e m s counsel didnt include his interrogatory answers

referred to as EX 1 to Twilas declaration. If the Courts also did not. It should not
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rely on her interested description of them, First because Interrogatory No 3 is
12 loaded (statistically) for failing to ask the days Jerry7spent in their Arizona
house or elsewhere which when added to his Alaska time nearly equals the time he
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spent in Washington and by failing to ask the reasons for his travel. Domicile
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determination is never a day count (see legal discussion infra),
6And in this regard Petitioners attorneys simply show their ignorance of the law
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of domicile (and further warp the irrelevant day count they attempt to obtain in
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their Interrogatory No 3), Had they looked at the law regarding absence for
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medical treatment and presence under (legal or other) compulsion set forth in the
Restatement of Conflicts 2nd 17 (1972) cited repeatedly in In re Wavs1Marriage.
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85 Wn.2d 693, 538 P.2d 1225 (Wash. 1975) as well as 25 AM Jur 2d 26 (2012)
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they would have seen as this court clearly will that both Jerry and Twilas presence
in Washington to receive medical treatment for their respective heart disease
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(treatment for which is unavailable in Kodiak) is no evidence whatsoever of a
'?1 change In their domicile even though their days spent in Seattle may be long and
even though either is aware that their illness may even totally prevent their return
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to Kodiak. The relevant facts here are that after both parties (and their then young
23 doggy) spent the entire year 2002-2003 living in Alaska while Jerry was working
24 in the Anchorage Municipal Attorneys to vest the fifth year of his Alaska PERS
retirement entitling both he and Twila to full Alaska State medical insurance
25 benefits (and a small retirement pension) for the rest of their lives and that almost
immediately thereafter first Twila in 2004 and Jerry in 2006 developed very
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serious heart conditions and that the non-existence of a cardiology clinic in Kodiak
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thereafter necessitated Twilas emergency air medivace on one occasion in 2007
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and has limited their ability to return to Kodiak as much as they might like.______
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from where (despite Twilas protests that he works too hard and will make himself
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ill) he continues to do so for the simple reason that he can not immediately give up
on his duty to his deserving (seriously injured) clients to finish the cases he has
4 begun for them and to the extent that he is drawn to entertain thoughts of
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continuing to do so. his love of a profession in which he excels and is not easy to
quit!
Suffice it to say Jerry documentation in that regard speaks louder then

words and his evidence is not merely on paper.7 For example due to a lack of
paperwork presently in his possession Jerry is unable to establish that he holds an

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Alaska subsistence fishing license available only to Alaskan rural (i.e. Kodiak
and similar small city) residents which he has regularly held since he w?as in high
school and that when they married he listed Twila (and when he lived with them
her son) as a resident beneficiaiy on that license thereby allowing him to gill net
any species of salmon and fish by any means for Alaskan Tanner crab and herring
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' And these are only the badges that Jerry had on his possession at the time of his
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arrest and what he had access in the meager records that he maintained in the
home the parties maintained in Friday Harbor (as the one trip he has been able to
make to Kodiak was made during the period that he was led to believe Twila
IS sought to reconcile hence he sought no need to obtain more). See EX E. One of the
20 biggest impediments to his prosecution of this motion (and this case in general) is
that as a result of the DV charge and resulting NO CONTACT ORDER Jem'
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has been denied access to a substantial volume of the documents (including both
closed and open client files) that w7ould support this claim with him in the house
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the parties maintain in Seattle wrhen he was arrested. Even if this court is
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convinced by the documentation so far produced that Twila is an Alaskan
domiciliary, Jerry requests this court enter an order in the furtherance of its
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determination allowing Jerry to lav the fullest record possible in support of his
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claim to subject matter jurisdiction at the conclusion of this hearing by directing
26 Twila to permit him accompanied by his attorney to enter the home the parties
maintain at 810 NE 58th and inspect and copy any and all documents there as they
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are at the very least jointly his (and may well be the property of his clients) in
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recognition of Twilas potential appeal of this issue.
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(all unlimited in number) as he deems necessary for Jerry and Twilas subsistence
2 needs. He has been further unable to obtain proof that both he and Twila are
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similarly current holders of a US National Marine Fisheries rural subsistence
Halibut permit that allow them to take an similar unlimited number of Halibut and
other ground fish by way of a multi-hook subsistence ground line (or skate)* Or
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that now that they have turned 65 they need not even personally catch those fish
but may designate others to catch them for them. Or that Twila has been the
recipient of those subsistence caught fish as recently as this summer!
But what paper he has is damning. First (in no particular order of
importance) he has responded to jury service in Kodiak (as has Twila) EX G. He
holds an Alaskan drivers license. EX H (as does Twila). He obtained resident tags
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to hunted deer in Alaska in 2012 (as has Twila in the recent past). EX L He is
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registered to vote there (as is Twila) and did vote absentee in the last Kodiak
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Borough election on October L 2013 (as typically has Twila). EX J He is an

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Alaskan Air Cargo known shipper from Kodiak, EX K, He is a member of the

Kodiak senior center (as is Twila) and typically receives a birthday wish from its
members as he did this year (as does Twila). EX L. His aircraft despite long being
operated in Washington was duly registered with the FAA as being home based
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in Jerry domicile of Kodiak and as a result duly subject to the Kodiak Island
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Borough personal property tax.. Jerry duly paid that tax until it was repealed in
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2006. EX M. And shortly before Twilas Affidavit of April 15, 2013 declaring her
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domicile, residence and permanent place of abode to be their large 11 bedroom
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home in downtown Kodiak (where they raised their family) we see Jerry on March
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2, 2013 similarly signing an affidavit (while he and Twila were together in Arizona
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and she was well aware he was doing so) claiming an over the age of 65 Alaskan
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residence (while fully disclosing to Alaska DMV that their small pickup truck was
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in Arizona which nevertheless under Alaska law entitled them to registered this
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truck titled in their joint names) tree of Alaskas significant fee, Twila shortly
thereafter accepted the benefit of that act by frequently driving that truck in
Arizona after receiving their free 2013 registration tabs well aware of how it was
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obtained. See EX N. And certainly not least in Jerry paper documentation has
long been an active member of the Alaska Pioneers Kodiak Igloo # 17 an
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organization which requires its members have a minimum of 25 years of Alaska

residence! (including helping it with its legal affairs pro bono.) EX O.
EX P further reflects (from left to right) that Jerry hold an Alaska Safeway
Club Card (as does Twila), had been approved to receive the Kodiak Senior
Citizen sales tax exemption (Twila turned 65 just days before Jerrys DV arrest
and hence didnt go to Alaska to get hers but is due one), holds a Kodiak library
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card (as does Twila), his pilots license show his residence to be Kodiak, he
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receives his Medical insurance (as a state of Alaska PERS retiree) from Alaska
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Care (as does Twila), is a member of the Alaska Airlines 49er Club allowing
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Alaska residents discount on flights which he has obtained (as is Twila and as she
likewise has), is a member of the Kodiak Post of the American Legion (as is
Twila), holds a Kodiak hunting license (as has Twila), participates in the Alaska
Organ Donor registry (as does Twila), purchased at 2013 Alaska King Salmon tag,
is registered with Wal-Mart Kodiak as having tax exempt senior status and of
course is an active member of the Alaska Bar Association (and was invited to
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speak at the Alaska Admiralty Bar Association 2012 CLE on injured Seamans
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rights to maintenance and cure) and regularly appears in Alaskan Courts.8
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8Which is not to suggest he remotely agrees with the derogatory assertions her
counsel has clearly drafted into Twilas declaration that she would (somehow):be
at a substantial disadvantage if wre had to litigate this divorce in Alaska. Jerry was
a prominent attorney in the town where we lived and was a former Assistant
Attorney General for the State of Alaska. This remark is a slap in the face of the
judiciary everywhere. It assumes (without proof) that Alaskan attorneys receive________
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II. PROCEDURAL POSTURE
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Twilas response is essentially a plea to this courts equity when In re

Marriage of Robinson. 159 Wn.App. 162, 248 P.3d 532 (Wash. App. Div. 3 2010)
makes clear a factual determination to the central Issue of this courts subject
matter jurisdiction is one o f law preliminary to any exercise of its equitable
6 authority. She does this because she has no credible defense on the law under
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these fact. And her improper efforts go far beyond that by attempting to offer
inadmissihle evidence irrelevant to their adjudication.
Jerry will address the
admissible relevant evidence further in the course of discussing the applicable law
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III. APPLICABLE LAW

Twila begins the legal discussion of her reasons for her Response at pg, 3
by erroneously relying on LCR 7(b)(5)(B)(iv) to make a technical argument
(akin to Robinson at 170) asserting Jerrys meritorious 12(b)(1) Motion should be
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dismissed for not specifying with particularity the evidence on which he seeks to
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rely? However the balance of that rule (which she quotes) makes clear that it refers
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judicial favoritism and that one who briefly worked in its State Attorney Generals
Office for the first four years or his career (?) would receive more. When the
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reality is that while attorneys and non-attorneys are in theory entitled to receive
equal justice under the law the fact is that every'jurist will review every'
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attorneys actions more closely to see that he took no unfair advantage of his
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spouse even though his wife (as Twila) may have worked in his law office and
know a great deal about the practice law? But the facts here will clearly show that
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Twila voluntarily long chose the benefits of living with Jerry in Alaska and as a
23 result chose an Alaskan domicile but now seeks to enforce her claims against
property' in Alaska in Jerrys sole name that as recently as her April 15,2013
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affidavit, she unequivocally asserted (prior to and ind ependent of these divorce
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proceedings) she had no legal interest in? And in that connection she now clearly
wishes to subject Jerry and that property' to the laws of Washington before a jurist
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who is likely to be unfamiliar with the laws of Alaska law where it is located and
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which has the most interest in it and the parties relationship. See Rest. Conflicts 2nd
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only to documents (police tapes arent documents and in any event are very brief).
2 Moreover any reading of that rule must be in connection with the paramount
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commands of this states appellate courts regarding the proper procedure to be
followed regarding the burden of going forward when addressing this central issue
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at the outset of a divorce action in which it is raised. This procedure is clearly set
out in the very modem case of In re Marriage of Robinson at pg. 168 supra
principally relied on in Jerrys motion which Twila conspicuously ignores holding:
Once acquired, domicile is presumed to continue until
changed."9 The burden o f proving a change in domicile rests upon
the one who asserts it, and the change in domicile must he shown
by substantial evidence.
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Jerrys burden of going forward in Robinson and LCR 7(b)(5)(B)(iv) is
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satisfied by Twilas affidavit attached to his 12(b)(1) motion clearly establishing
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his wife acknowledged on April 15, 2013 that her:
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domicile, residence and principal place of abode is with my

husband at 211 Mill Bay Road in Kodiak and has been since we have
been marriedt\
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And as particularly noted in Strohmaier at 17:

The indispensable elements of domicile are residence in fact
coupled with the intent to make a place of residence one's home. In
re Estate ofL assia 33 Wash.2d 163, 165-66, 204 P.2d 1071(1949).
[T]he intention to make a home must be an intention to make a
home at the moment, not to make a home in the future ,"
Intent regarding domicile is generally determined by
objective events, not the party's subjective state o f mind. Stevens,
supra at 82, 480 P.2d 238. A proper subject o f inquiry is whether the
facts support the self-serving declaration o f intent in such a way that
the intent can be said to be genuine. In re Mullins. 26 Wash.2d 419,
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^Quoting In re Marriage of Strohmaier. 34 Wash.App. 14, 17, 659 P.2d 534(1983)

(quoting In re Estate ofLassia 33 Wash,2d 163, 167, 204 P,2d 1071 (1949).
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445, 174 P.2d 790 (1946). In determining the sufficiency of the

proof, the good faith of the party asserting the change in domicile
should he considered, particularly in regard to his declarations of
intent Sasse v. Sasse, 41 Wash.2d 363, 366, 249 P.2d 380 (1952).
Sasse at pg. 365-66 [249 P.2d 381-81] also confirmed the long established
law that:
A legally competent person may choose his domicile. To
acquire a domicile of choice, he must establish a dwelling place with
the intention of making it his home.
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Having satisfied his burden of going forward with the admissions to an
.10 Alaskan domicile found in her April 15, 2013 affidavit, the burden then shifts to
Twila to counter that evidence (and if she offers same then an opportunity must in
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turn be allowed Jerry to offer evidence contrary to her claims of a Washington
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domicile in rebuttal (as he will do at the evidentiary hearing as he has described
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here). Then this court must decide whether Twila carried her ultimate burden of
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persuasion on this issue. This court can clearly see based on the verified
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documents on file that there exists (at least) a dispute of fact as to the true nature of
1?
at least Twilas domicile as set forth in the objective evidence in her April 15,
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2013 affidavit to a domicile in the family home at 211 Mill Bay Rd in Kodiak
IS
(corroborate by her statements to the police) and now her admissions to (still)
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having an Alaskan drivers license and voter registration and claims to substantial
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Alaskan property7ownership in her October 4, 2013 self self-serving declaration
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(despite her self serving claims to a "Washington domicile).
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involves an adjudication of her intent which her own pleading at pg. 5 H. 15-16
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admit Strohmaier at 16 holds the parties may provide testimony and evidence
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surrounding. Hence clearly this is not a summary7 proceedings such as is
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contemplated by LCR 7(b)(5)(B)(iv) to be adjudicated by reference to affidavits
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and documents but by adjudicating the facts and credibility of the parties.
Accordingly this
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Twila seeks to carry her burden by her self serving October 4, 2013
declaration (given in her efforts to escape her earlier admission) pg. 3
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the same time admitting that her sworn declaration of her domicile*residence and
permanent place of abode is 211 Mill
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Bay Rd. Kodiak, Alaska in her earlier April 15, 2013 affidavit to her husbands
motion was prepared and filed in attempt to obtain a senior property tax exemption
on that residence. 10 Moreover that affidavit further declares this property was
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10 Which was hardly fraudulent as her attorney drafts her declaration to recklessly
claim. Jerrys claim to that entitlement was based on his claim that the 211 Mill
Bay Road home was his an Alaskan primary residence and permanent place of
abode or domicile. AS 29.45.030(e) entitles real property so owned and
occupied by a resident who is 65 years of age or older to an automatic $150,000
property tax exemption (regardless of income) and speaks in terms synonymous
with domicile See Blacks Law dictionary defining residence, domicile, dwelling
and permanent place of abode. 3 AAC 135.085 and 3 AAC 135.120 (4) also
addressing this entitlement also defines permanent place of abode as used in AS
29.45.030(e) as a dwelling (i.e. domicile) this administrative interpretation too
is entitled to great weight. The Kodiak Island Borough instead denied Jerrys
claim based on its claim to have adopted an optional requirement found in. AS
29.45.030(f) that a claimant also meet the qualifications for the Alaska Permanent
fund or specifically a 185 day durational residence (or more accurately
presence in Alaska) test or justify his failure for absences pursuant to the
requirements of a complex set of regulation. Jerry never contended he met the 185
day durational presence test and both Jerry and Twila have found the effort
necessary' to justify their absences not worth the relatively small reward (under
$1000). This (suspect) test (wThich is vastly different from a determination of
domicile) permits a State to allocate its State resources and benefits under
circumstances that do not restrict its citizens US Constitutional right to travel.
29
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owned solely by Respondent acquired before their marriage and that she had no
2 ownership interest in it hence this earlier affidavits declaration as to her domicile

3
was clearly not self-serving? Equally clearly it was also against her interests with
reference to the issue of jurisdiction. Compare In re Marriage of Robinson supra
157 Wash. App 162. 169; 248 P3d 532, 535.
Her actions in executing this
affidavit11 (before the alleged grounds for this divorce even occurred) is then one
8
9
10
11
12
13
14
15
16
17
18
19
20
See Zobel v. Williams. 457 U.S. 55, 102 S.Ct. 2309, 72 L.Ed.2d 672 (1982). Jerry
responded by claiming the Kodiak Island Borough had not validly adopt the
requirements of AS 29.45,030(1). The Borough disagreed and applied that 185 day
test and denied Jerry the exemption. Jerry has appealed that denial to the Alaska
Superior Court. Markham v. Kodiak island Borough 3AN-13-07658 where the
case awaits a ruling on some procedural motions prior to briefing. As noted in In re
Marriage of Robinson supra, the Superior Courts found that a wifes similar claim
at pg, 166 that her signature had been forced or coerced did not satisfy
Washingtons nine elements of fraud was pg. 167. As described in Angelo v.
Angelo. 142 Wn.App. 622, 6431106 175 P.3d 1096 (Wash.App. Div. 2 2008)
those nine elements of fraud are (1) representation of an existing fact, (2)
materiality of the fact, (3) falsity of the fact (4) the speaker's knowledge of the
falsity of the fact, (5) the speaker's intent that the fact should be acted on by the
person to whom the fact was represented, (6) ignorance of the facts falsity on the
part of the person to whom it is represented, (7) reliance on the truth of the factual
representation, (8) the right of the person to rely on the factual representation, and
(9) the person's consequent damage from the false factual representation, Twila
fails to satisfy al least 4-9.
21
28
11 Which Jerry will establish she freely did (totally outside of his presence or
influence before Richard Lee Rehm a public notary7(unknown to him) located in
the UPS Office atl037 65& St. in Seattle! His Notary book also reflects she signed
it as well presenting her Alaska drivers license for ID and listing her address as
211 Mill Bay Rd. Kodiak. EX Q Moreover later when on April 24, 2013 Jerry1wras
arrested and barred by court order from contacting Twila or being at her habitation
at 810 NE 58th (but before she filed this divorce action), despite her current claims
to signing against my will (see discussion infra) she then nevertheless assisted
her (big hurley) 42 year old son Adam Logghe in locating and delivering the
original of that affidavit to 66 year old Jerry who suffers from a serious heart_____
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of the most credible of objective events to which Strohmaier supra speaks! Other
objective events are further found in her admissions in her recently filed
declaration Id. ^ 6 to an Alaska drivers license
despite the intervention of over 5 months since the filing of her May 9, 2013
Petition for divorce her recent declaration further concedes she has yet to even
and voter registration
which
6 began to change. Rather she merely states: I do intend to change these? However
7
8
9
10
11
12
13
this, and her further declaration: I do not intend to reside in Alaska in the future
fail to pass the Strohmaier/Lassen test that:
,r[T]he intention to make a home must be an intention to make a
home at the moment, not to make a home in the future ."
The same may be said of Twilas claim that Jerry now resides in Friday
Harbor. The evidence in that regard was that Jerry commissioned the building of a
home on property he owned there in his sole name with the intent on retiring there
14
at some unspecified time in the future. But that time has simply not yet come.
15
Meanwhile he has maintained that home primarily as a place where he and his wife
16
17
18
19
20
to extend their otherwise brief Alaskan summer. The same may be said of their
Arizona house which allows them to escape both the depth of the Alaskan winter
and the Seattles cold rain. These parties present the (formerly) unusual situation
described in the Restatement of Torts 2nd 20 of having not merely two but*123
21
28
condition under circumstances when he was clearly could have had no physical or
psychological compulsion over her or her son whatsoever. See EX R.
12Also conspiously omitting in 2003 she practiced, tested for and received and
since renewed her Alaska permit to carry a concealed handgun requiring she be a
resident AS 18.65.705.
13And that she has regularly cast her vote for President and Alaskas Senator and
Representative in all National elections (including the last) and numerous Kodiak
Borough and City Elections in Kodiak for the entire period of the parties marriage!
Fiske v. Fiske. 48 Wn.2d 69, 290 P.2d 725 (Wash. 1955) holds voting is a major
consideration._____________________________________________________________
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multiple houses (Kodiak, Anchorage, Friday Harbor, Seattle and Arizona). As that
authority describes the task for this court is deciding which of their many
residences is their domicile which the law expressly permits they may chose
but that they may only have one!
Jerry has already generally addressed in passing at fh. 6 supra the Twila"s
counsel"s erroneous claim that he (now) lacks of medical treatment in Alaska14 and
that all of his recent medical treatment has been in Washington supports her claim
that he too is a Washington resident but nothing could be further from the truth.
Similar law pertains to his recent presence in Washington to attend court hearing
1.0
on his domestic violence charge and more recently to meet the requirement he
11
attend 26 weeks of anger management treatment and 6 months of follow up. O f
12
course he was acting under order of compulsion when he was ordered to be in
13
Seattle for several court hearing only being allowed by the court in May to be
represented by counsel in his absence at one (following which he went to Kodiak,

15
Alaska) but he was required to return in August. Thereafter to avoid the stress on
16
his wife of a trial (and with the promise of reconciliation if her underwent anger
17
management EX E) he entered the stipulated Order of continuance which in
18
addition to the 26 weeks or treatment (according to his probation officer) require
19
20
him to report to her every 30 days (and be out of state no more than 45).
21
Accordingly this period of Washington presence in takes on aspects of both
22
treatment" and compulsion both addressed by the Restatement 17 and neither
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28
j
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14 Jerrys long treating doctor (Halter) retired in 2007 and Kodiak has neither a
cardiology unit, an orthopedic surgeon or virtually any other specialists to treat his
or Twilas serious medical conditions. As a result its not uncommon for virtually
all rural Alaskans to travel to Seattle which is know to be far more competent and
virtually no less inconvenient than the relatively smaller city of Anchorage to
receive their specialized care. And this is the major reason that the parties maintain
a (second) home in Seattle.
REPLY OF RESPONDENT
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(206) 542-4066
of which is evidence of domicile. Hence clearly Twila can not support her
claims by this.
Petitioners fall back defense is to assert that even if she was not a
domiciliary of this state (and her statement in her Petition for dissolution to the
contrary was false) even if this court had no jurisdiction at that time it can
7
8
9
10
nevertheless acquire it if she becomes a domiciliary during the pendency of these

divorce proceedings? In Re Marriage of Robinson does contain literal language to
that effect at 168. but as Twilas response at pg. 5-6 is compelled to point out it
was merely quoting In re Marriage of Wavs 85 Wash. 2d 693. 700; 538 P2d 1225
(1975). But as applied in Robinson that quote is just dicta in as much as it went on
11
to point out at 169-170. 248 P2d 532. 535 If 20 Mr. Robinson made no such
12
argument that he had an intention make Washington his home! For this court to
13
then blindly apply this dicta in Robinson out of the context in which it was made In
14
re Marriage of Ways1516as Twila urges will lead it to err!

15
16
i, /
18
19
For such a claim is not only contrary to the law generally but Washingtons
specifically. As stated in 24 Am Jur 2nd Divorce and Separation 174 b, Domicile
and Residence pg. 379-80:
i if
The jurisdiction is determined at the time the suit is filed.
Thus, where the family domicile is in Greece, the mother leaves
20
22
28
15Wavs was addressing the controversial issue of whether and under what
circumstances a state might permit a non-domiciliary to divorce specifically then
RCW 26.09.030 which permitted a nondomiciliary member of the armed forces
stationed in Washington to obtain a dissolution of marri age which it further
determined meant he must be stationed here for 90 days after the filing of his
petition.
16See for example Cook v. Mayfield. 886 S.W.2d 840 (Tex.App. Waco 1994)
holding in the face of a claim that by the time the matter might be decided the
residency requirement would be met and the claim would be moot, that such a
result would deny any adequate remedy at law and encourage forum shopping.
Twila has clearly not satisfied this states domiciliary requirement and despite her
29
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1
2
Greece with her two children and seven days after arrival in
Washington state, she files a petition for dissolution of marriage and
for custody of the children, the Washington court lacks jurisdiction.
ATTORNEY FEES
4
5
Ms. Markham offers no authority that Jerry should be assessed her
attorneys fees in bringing this motion and for that reason alone it should be
dismissed. He relied on her clear voluntary sworn admission that she was an
Alaskan domiciliary and countless additional evidence to that effect. It is her
declaration to a Washington domicile that is false. Having made it in the face of
10
his evidence if fees are to be awarded they should be award to him!
11
12
13
14
CONCLUSION
For the reasons stated herein after an evidentiary hearing on this
issue Twila Markhams Petition for dissolution should be dismissed.
15
16
Respectfully submitted this 16th day of October, 2013
17
18
19
ANTHONY M
20
WSBA#11711
21
22
23
24
28
representation there is no proof here that she ever will. On the contrary because her
presence has been compelled by her treatment for her heart condition it is
debatable whether she even can. This is not a harsh result. She purposefully chose
an Alaskan domicile and freely maintained that choice both immediately prior and
long after this suit was filed through to the present. If there are any allegations in
this matter that are fraudulent, they are those in her petition for divorce!___________ _ _
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C E R T IF IC A T E O F S E R V IC E
3
4
I h e r e b y d e c la r e u n d e r th e p e n a lt y o f p e r ju r y u n d e r t h e la w s o f th e S ta te o f
W a s h in g t o n th a t I h a v e s e r v e d a t r u e a n d c o r r e c t c o p y o f th e fo r e g o in g , e x c e p t w h e r e
n o t e d , u p o n th e in d iv id u a l( s ) lis t e d b y th e f o llo w in g m e a n s :
5
R E P L Y O F R E S P O N D E N T
6
8
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f ]
[ X
[
[ X
[
[X ]
C o u n s e l fo r D e fe n d a n t
K a m r a Z a ik e
11300 R o o s e v e l t W Ta y N E
S u i t e 300
S e a t t l e W A 98125
U .S . P o s t a l S e r v ic e ( F ir s t C la s s )
] F a c s i m i l e t o 206- 363-8067
] U .S . P o s ta l S e r v ic e E x p r e s s M a il
] H a n d D e liv e r y
] V ia L e g a l M e s s e n g e r f o r s e r v ic e b y
V ia e m a il: k a n n a @ la w g a t e .n e t
!
1
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D a t e d : O c t o b e r 16, 2013
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T it le : A t t o r n e y f o r P la in t if f
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Z1
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18130 Midvale Ave IMSte A

(206) 542-4066
EXHIBIT A
Mr GERALD MARKHAM: #8634194 A val. Miles 152,504

C hanges R eservation
Travelers
Gera id Markham
Request Itin e ra ry Changes
Make changes to tills trip
r Use the value o f this trip to purchase a new trip
------ ^ T h is part o f your trip has already been flown or ts not eligible for changes:
AS 641
Tue, Apr 9
Tucson (TUS) to Seattle (SEA)
These flights are eligible for changes:

D eparting F lights
Keep F light
jchange F lig h t
?C ancel F lig h t
F light
D eparts
A rrive s
Alaska 113
First
Seattle (SEA)
10:30 am Fri, Nov 1
Anchorage (ANC)
1:05 pm Fri, Nov 1
1ft>>ÎPin
. . . . .
0>wy*
ijfJ*1, ; 1^
15K Iff#!,>t jS L K J S K tf J 'i
**f
W 5?
'
Keep F light
C hange F lig h t
; Cancel F lig h t
F lig h t
Departs
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First
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3:25 pm Fri, Nov 1
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EXHIBIT B
Departments J Services [ S ta ff D irectory j My.Seattle.Gov
r ~ ..........................................i
g S e atll'e.gov /D ThisD epaffi^
m m s m i cm m m
m axm ?m m
::-Sfit)
'Sugel;;!
aig?MJ^Lee::
SPD Home / Police Work / Dome site Violence Unit

Police Work Home
DOMESTIC VIOLENCE UNIT
Police Personnel
I
How Seattle is patrolled
Precincts & Police Locations
Patrol W ork
l {205j 684-0330 MONDAY - FRIDAY SAM - 5PM

| D omestic Violence Unit personnel conduct follow-up investigations based on police reports com pieied by patrol
j officers. They can provide you with information regarding the status o f yo ur case to indude if the case has been
\ ; assigned to a detective, if an advocate will be assigned and if a felony o r m isdem eanor charges will be filed. If
possible, ptease provide the police incident report number (or easier reference when calling,
~1
!
\ M ore in fo rm a tio n fo r D o m e s tic V iofe nce V ic tim s
|
J
9-1-1 Center
!
Crisis Intervention Team
In ve stig a tio n s
| INFORMATION FOR DOMESTIC VIOLENCE VICTIMS
Homicide & Cold Cases
Forensics
5
Narcotics
THE HISTORY OF DOMESTIC VIOLENCE LAW
Domestic Violence
Sexual Assault and Child Abuse
om estic violence situations pose particularly com piex challenges fo r law enforcem ent. F o ra variety o f reasons
ij Dstem
m ing from fear, dependence, embarrassment o r self-blame, many dom estic violence victims fail to report abuse, to
Vice and High Risk Victims
take preventative measures, or to follow' up on actions against th e perpetrators. Until the 1980s, police responding to
- dom estic violence scenes handled them with mediation and In fo rm s w arnings, but after a 1984 M inneapolis study
showed that arrests of abusers led to a significant drop In post-charge violence, slate laws were changed to make
arrests m andatory fo r dom estic violence assaults. After the law was changed, ttfef Departm ent went from 386 dom estic
> violence arrests in 1984 lo an average of 2,700 per year.
Internet Crimes Against ChSdren

Traffic Enforcement
Parking Enforcement
Harbor Patrol
Canine Unit
SWAT
THE SEATTLE POLICE DEPARTMENT DOMESTIC VIOLENCE

UNIT
The Seattle Police Departm ent established its D om estic Violence Unit in 1994, with a focus on both victim safety and
offender accountability. Since then it has been a regional and national leader in the law enforcem ent community in
developing innovative approaches and responses to dom estic violence. Through dedicating internal resources and
securing external grant funding, the Department has consistently been on the cutting e dge of dom estic violence issues
and re-assesses its response to the problem frequently.
O ver the last decade, the Departm ent has developed specialized expertise in the areas o f stalking, elder abuse,
i custodial interference, and abuse in the homeless and sexual m inority communities. Recognizing the correlation
I
between dom estic violence and animat abuse, the DV Unit established a partnership with Animal Control to ensure
\ mutual notification of re c o v e re d abuse, VST and ail precincts have anim al carriers to remove anim als from situations as
|
needed. Anim al control will keep these anim als free o f charge fo r up to tw o w eeks,
j
;
j
I
j
i Partnerships have also been created with the victim outreach com m unity, local hospitals, prosecutive agencies and
j: business com m unities. One very successful partnership effort is through the V ictim Support Team (VST) program that
f w orks directly w ith citizen volunteers. VST volunteers work as a team of tw o and are trained to respond after a dom estic
j violence scene has been secured to provide crisis intervention, and em ergency resources referrals to domestic violence
; victims. Through VST, the Department created the Safety inn program to provide hotel and motel rooms to victims when
; shelters are full, and a partnership with Verizon W ireless recycles donated cellphones programmed to have im m ediate
; access to emergency hotlines.
I
j
jj
I
I
j
ii
|
|
;;
In 2005 the Department worked w ith the Municipal C ourt and the City Attorney's Office to implement a Domestic
Violence Firearms Project, increasing police officers attention to firearm s at the scene of a dom estic violence incident,
Site Disclaimer: The Seattle Police Department's website was developed to provide general information. Data
contained at this location is -generally not reviewed for legal sufficiency, SPD documents displayed are for
reference purposes only. Their completeness or currency are not guaranteed. Links or references to other
information or organizations are for reference only and do not constitute art endorsement.
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10/15,'13 11:59 A
EXHIBIT C
-- j
Ik
S E A TTLE
PO LIC E
D EPARTM EN T
GENERAL OFFENSE #
13-137730
NAME {LAST, FIRST MIDDLE)
RACE/SEX/DO& -
jiim f r
WEIGHT
BUILD
Markham, Twila Y
W/F/04-22-1948
|5*02"
170
medium
.... " - P
P 'C A U v f
...........T O R A I D .................
(CHECK A lp 1 \
APPLIC ABlspoXES)
H Y S TE R IC A L
Victim Inform ation
6>% q
D o m e s t ic V io l e n c e In c id e n t
S upplem ental R e po r t
IF YES, DESCRIBE ON INCIDENT

REPORT AND MARK ON DIAGRAM
PHOTOS OF INJURIES TAKEN
TREATMENT
m N O N E I R E FU S E D
YES
UNDER THE INFLUENCE O f DRUGS )

ALCOHOL
S Y es
U no/
D unk
PREGNANT
N /A
NO
YES
- H f H E S IT A N T ........................
C O N FU S E D .......
OTHER
NERVOUS
NO
P A T SCENE
w r it t e n s t a t e m e n t o b t a in e d
O YES
PUNK
O P E R S O N A L P H Y S IC IA N
D T R A N S P O R TE D T O HOSPITAL
VICTIM WHO. BE STAYING AT TEMPORARY ADDRESS/ PHONE
m YES
NO
NO
IF Y E S , ATTACH MEMO
EMERGENCY CONTACT PERSON FOR VICTIM {NAME & PHONE OF SOMEONE WHO PREFERABLY DOES NOT LIVE WITH THE VICTIM)
SUSPECT CONTACTED MIRANDA WARNINGS GIVEN BY OFFICER
NAME (LAST, FIRST MIDDLE)
Suspect inform ation
Markham, Gerald W
SUSPECT AERg
^ ED
(CHECK A ty r A
APPLICABLE Si JXES)
SUSPECT IN id *ED
_
U -*S Y E S
...... T ? 3
ANGRY
IR R A TIO N A L
R elationship
NO
w-r S
/*
N ERVO US
IF YES, DESCRIBE ON INCIDENT

ON DIAGRAM
H UPSET
NO
UNK
RELATIONSHIP
^ T s p OUSS(Check All
Q FORMER RESIDING
Applicable Boxes)
YES
DYES
JmSSTS*ENT
NO
WRITTEN STATEMENT OBTAINED
D IS T A N T HYSTERICAL
VI OL ENT
POTHER
N O N E /R E F U S E D
P E R S O N A L PHYSICIAN
A T SCENE
YES
[ DAT1NG1ENGAGED
I C H ID IN COMMON
D FORMER SPOUSE
RESIDING TOGETHER
UNIT
6910
r f C R Y IN G
PREVIOUS DV ARREST
E l NO
SERIAL
SaaM igB <.
g ] C O N TR O LLIN G
PHOTOS OF INJURIES TAW0IP-
UNDER THE INFLUENCE OF DRUGS i ALCOHOL

YES
CAt J &
- O APO LO G ET76
TR A N S P O R TE D TO HOSPITAL
CITY/STATE
S NO
PARENT/CHIU>
ESTRANGED SPOUSE
FORMER DATING
OTHER (Describe)
I HISTORY OF DOLCSTIC VIOLENCE
LENGTH OF RELATIONSHIP
35 years
1
13 TE S
_________________ i_________________________________________
NO
O UNK
IF V A U D N C O /S E R V E D PR O TE C TIO N ORDER EXISTS, PO S S E S S IO N O F F IR E A R M S BY R E S P O N D E N T IS PR O HIBITED U N D E R FE D E R A L LAW.

1. D oes m e su spe ct possess, o w n . o r have access to firearm s? { ^ Y E S
NO
UNK
Firearm
2. W h e re a re the fire arm s located? (resWericeWehicte/suspeci) ^
S fc-1-
3. H as th e suspect used , d isp la yed o r threatened to use firearm s a g a in s t y o u o r o th e rs in th is instance?
YES
NO
to p a s t In s ta n c e s ? Y E S ] f NO
I f Y e s ', describe;
A, If y e s to # 3 , and th e fjreem ns(s) Is {a re ) present and under toe vksilms c o n tra , d o you w ant S P P to rem ove th e fifeao3{s)? D Y E S
F ire an n (s) taken? Y E S
NO
STATEMENT {$} TAKEN FROM WITNESS {$>

YES-
0N O
STATEMENT ($} TAKEN FROM CHILD (REN)
Q N /A
YES
C h ild ren /W itne sses
CHILD (REMS) NAME (LAST. FIRST MIDDLE)
sex
DOB
NO
CHILD PRESENT
DURING INCIDENT?
m N /A
DOSS THE CHILD HAVE USABLE
TESTIMONY?
CHILD'S INJURIES?
C .
YES
NO
YES;
NO
YES
ONO
YES
NO
YES
ONO
YES
NO
CHILDREN LEFT IN CUSTODY OF
CURRENT COURT ORDER EXISTS
Court
NQ
, ^
yes
TYPE OF
O R D ER S)
'
E 3no
RESPONDENT SERVED
{H
unk
ri
N 0 C O N T A C T O R D ER
O T H ER (D escrib e)
yes
ISSUING AGENCY AND COURT ORDER NUMBER (IF KNOWN)
NO
PR O TEC TIO N O R D E R
R E S TR A IN IN G O R D ER
Q A N T I-H A R A S S M E N T ORDER
SEATTLE
PO LICE
DEPARTM ENT
D o m e s t ic Vi o l e n c e In c id e n t
S upplem ental R e po r t
GENERAL OFFENSE
13-137730
AUTHORIZATION TO DISCLOSE PROTECTED HEALTH INFORMATION

________________________ as (check one): PATIENT PARENT/LEGAL GUARDIAN LEGAL NEXT OF KIN
hereby authorize
to release the follow ing m edical records inform ation of:
_____________________________________ .
ending
(bom
), for the tim e period beginning
and
1 understand that the purpose o f th is disclosure is to assist in a crim inal investigation and/or
prosecution.
73
INFORMATION TO BE RELEASED
SU M M AR Y O F M E D IC A L H IS T O R Y /T R E A T M E N T
P N U R S E /D O C T O R N O T E S .....
E M E R G E N C Y R O O M R EC O R D S
l
Q R A D IO LO G Y R E C O R D S / FILM S
Q T T ^ m iA G N O S T iC S T E S T S -------------------------- "O T H E R --------- . --------------------------
SOCIAL WORKER NOTES
7/
I understand that th e inform ation in m y health record may indude inform ation relating to sexually transmitted disease, acquired immunodeficiency syndrome
(AIDS), or human immunodeficiency virus (HiV). M y health record may also include inform ation about behavioral o r mental health services and treatmentfor
alcohol and drug abuse. By checking the box at the end of this sentence, I choose to exclude the more sensitive inform ation about behavioral or m ental health
services-and treatm ent fo r alcohol and drug abuse. I understand th a t} m ay be charged an additional fee to rem ove this inform ation. D
Health inform ation sha ll be released to the Seattle Police Departm ent In addition, m edical facility sta ff may discuss my m edical condition and any treatm ent with
the assigned detective Or th e ir designee. 1 understand that this authorization expires in ninety (90) days unless otherwise specified and that the disclosed
inform ation is protected under State and Federal Law (42 CFR Part 2 and RO W 70.24). Please be aware that once the Health Care Provider named above
discloses hea&h care inform ation pe r your instructions the inform ation is subject to re-disclosure and m ay no longer be protected. I reserve the right to revoke
authorization (in w riting) at any tin e prior to the ninety (90) day period expiration, except to the extent that the fa cility which is to release information has already
taken action in accordance w ith 1 I understand I do not have to sign this authorization in order to obtain health care benefits (treatm ent, payment or enrollment).
Signature of P atient
Reporting O fficer
!
Signature of Person Other Than Patient / Relationship to Patient
S e ria l/U n it'
Signature o f W itness / Interpreter
'
Date
FOR POLICE USE ONLY
Mark the location of any visible injuries. Use arrows to point to areas of non-vistbte injury or complaints of pain.
Use additional Supplemental Reports to document injuries if more than two persons are injured.
Victim injuries
Suspect injuries
EXHIBIT D
Seattle Fire Department
MewSearch[SFDHune
Emergency Incident Report Detail
Incident Number: 130037534

Incident Date: 04/19/2013
A d d re s s :
tvt;
Alarm Level:
610 Ne 58th St, Seattle

MED
Company Officer ID: rVa

Dispatcher ID: 2069
Unites)
D ispatched
Arrived
In-Service
E16
M16
18:56
18:56
19 :0 )
19:00
19:21
1926
BVDOP REPORT
Page 1 of 1
Incident Report
Incident Report
IN C ID EN T# F130037534
INCIDENT DATE: 4/19/2013
Agency SFD
Jurisdiction: SFD
18:55:38 hrs
Incident Overview
In itia l L o ca tio n :
Same as Final
F inal L o ca tio n :
810 Ne 58th St
C ity:
Seattle. WA 98105
in itia l P roblem
Type:
MED - Medic Response
F inal Problem
Type:
MED - Medic Response
In itia l A larm
Level:
F inal Alarm
Level:
U nits A ssig n e d :
E16M 16
Response A rea:
Battalion 6
D is p o sitio n :
Call Completed
Taken By:
Alm ond, Jr, Hifton R
Location Information
Location Name:
Map R eference:
24C
C ross S treets:
8TH AV NE/ROQSEVELT WAY NE
C all Back
Phone:
(206)-528-0648
Call-Taking Info
Taken By:
Tim e P hone P ickup
Tim e C all Entered Queue
Term inal
EMD
18:55:38
18:56:12
SP102
14/2
Dispatcher Comments
1. 64 YOFEMALE CP
Units Assigned
18:56:13
E16
m
a
( * Primary Unit)
U n it A ssigned
A rrive d
T ra n sp o rt Trans.
C om plete
C om plete
C ancel ETA
Reason
18:56:18
18:57:08
19:00:06
1921:08
2:28
M16* 18:56:18
18:56:55
19:00:08
19:2823
2:06
D isp. Almond,
By: Jr, Hilton
R
VisiNetM obiieInterface VisrNetM obiieinterface
Visi NetMobi tel nterface
Unit Line-Up Info

U n it
SFD ID Name
Rank
E16
1365
Forslund. Gregg D
FF
E16
1580
Jindrich, Heidi G
LT
E16
1202
Leach tenauer, Paul C
FF
FF
E16
1461
Owen, Jill L
M16
0812
Sprague Jr, A lbert T
FF
M16
2097
W allace, Michael B
FF
*****
END OF REPORT
*****
http://sfdcadweb2/CADview/incidentDetailReportasp?id=l 162123
08/12/2013
EXHIBIT E
| 11300 RooseveltWayNortheast, Suite300

| Seatm,Washington98125
I Pi206.365.5500 F: 206.363^067
of
mfo@kwgate.net
Attorneys
Michael'SBugni
Nathan Cuber
lmOS3TEfSRNCoiB={ffi
Daria J.O khjs

Margaret DoyleFnafSRKX
J E 5 8 3 F .L U R 0
Kpj$nmM.lARc
CaRLsasEA. Maows
JsfW
.NfifF
YvetteSam-OConnell
LuAnhePerry
May 13,2013
BnxSOLTO5'Qt.MAff.
Da'pnSyk '
KarmaL & jke
Mr. Gerald W. Markham

810 NE 58* St,
Seattle, WA 98105
Dear Mr. Markham:
Your wife has asked me to file a Petition tor Dissolution of Marriage in King Count)'
Superior Court. The reason for filing is that its clear that neither of you has real control
of the current criminal action. By filing this action she hopes that to bring clarity to
matters of her personal safety and the health and wellbeing of both of you. This can best
be resolved by having the two of you at the table and represented by counsel. She
hopes to resol ve all issues amicably, using the services of a mediator if necessary. The
first step, however, is for each side to retain legal counsel.
There are three goals that she wishes to achieve:
Firstly is that the no-contact order be maintained.
Secondly that you have regular contact with a counselor to resolve the issues that
caused this action in the first place. I understand that you have had several
sessions with Dr. Roland Maiuro, occurring before and after your arrest. A
domestic violence assessment will need to be conducted in the course of your
dissolution proceeding. Given Dr. Maiuros familiarity with the issues in your
family, it makes sense for him to conduct the evaluation. Until this task is
complete, you will not be allowed to return to the family home.
Thirdly there is the maintenance of your joint homes and properties. This is a
time-sensitive issue which has brought this about, in that T w i l a . m o n t h l y
deposits which you normally make into the household financial account have
dwindled lately and she is concerned that you will not make a sufficient deposit
into the joint account for the rest of May and June. We need an interim
commitment from you that the family finances will remain status quo until we
Mr. Markham
May 13,2013
Page 2
can arrange a four-way meeting (parties and their lawyers) and hopefully agree
upon the terms of separation at that time. Specifically, you need to deposit
sufficient funds into the joint account, per normal, as the account will drop
dangerously low after this month's payment of joint credit card bills and
household expenses.
If the finances do not remain status quo pending a fair negotiation of the issues, then I
will have to address the i ssue of temporary attorney fees and temporary spousal
maintenance by way of a hearing in late May. I am hoping to avoid that expense and
keep the costs down for both sides.
I look forward to working cooperatively with you and your counsel toward a swift and
acceptable resolution of the issues.
Yours truly.
Karma L, Zaike
KLZ:nkb
Enclosures
CC: Client
EXHIBIT F
W PP
07
'
1
2
THE
SEATTLE
KING
D I S T R I C T COURT FOR
COUNTY, WASHINGTON
3
TRANSWORLD SYSTEMS ,
NO,
IN C .,
32 03841
4
P lain tiff,
6
7
COMPLAINT
v s .,
GERALD MARKHAM a n d JAKE DOE MARKHAM, )
h is w ife,
D efen d an ts,
1.
The D e fe n d a n t(s)
a t a l l tim es r e le v a n t h e re to have been
resid en ts o f
. KING _____________ __ _______ _ __C o u n t y , W a s h i n g t o n .
2.
P l a i n t i f f has p aid a l l
fe e s due th e S ta te ?
and i s d u ly
l i c e n s e d a n d b o n d e d , a s r e q u i r e d b y ROW 1 9 , 1 6 . 2 6 0 .
3.
The C la im l i s t e d below i s d u e and ow ing t o t h e P l a i n t i f f f o r
P R I N T I N G OF LEGAL DOCUMENTS
___ ____________ , w h i c h r e m a i n s u n p a i d i n
t h e a m o u n t o f
.......~
4.
The above ci.aim has been du 1y ass>igned to Plaintiff for
c o l l e c t i o n , by
COCKLE P R I N T ING CO.________ _ ___ ,__ ______ ______,__ , a n d a c o p y
o f s a id assig n m en t is a tta c h e d h e re to .
WHEREFORE, Plaintiff demands judgment, against the Defendant (s) in

u lu s
in te re s t
2 1.3. y9
w ith
t h e sum o f $ 5 / 0 2 8 . 4 6
?o sts, and r e a s o n a b le a t t o r n e y 's
fees.
A t 1 o r n e y T ? o r P l a i n t i f f ( s )
D i n a L , Y u n k e r , .,,16 889
STATE OF WASHINGTON)
)ss
COUNTY OF KING
)
20
oa f h
___ DINA L . YUNKEk ________ __________ _ __ ___, b e i n g f i r s t d u l y s w o r n o n o,
d e p o s e s and s a y s :
2 am t h e A t t o r n e y f o r t h e P l a i n t i f f ; I h a v e r e a d
t h e f o r e g o i n g c o m p l a i n t , know t h e c o n t e n t s t h e r e o f , a n d b e l i e v e t h e
sam e t o be t r u e and c o r r e c t .
a
21!
22
SUBSCRIBED AND SWORN t o

1 9 92 .
before
me
th is
1s
y! )
23
L?t,h
d '*V o t
J
v/
(
a
M arch
:
t.
N o t a r y P u b l i c ia and :or
the S t a t e ot tûsh i not on,
r e s i d i n g at B*a I Xe v u e
Expires:
6/9 3
24
25
26
VOttTMAN A HUNSUVIN
27
Dux; {'ojyniû Cwr>icf

?Oj r'iih.\vcno
sV;i?;K'VvA(Si(k
{Ttfi Ul'-'.iSv
28
< /-/?
i. i\ . i I t x ?jU s ij S15
THE SEATTLE D I S T R I C T COURT,
FOR KING COUNTY,
WASHINGTON
4
TRANSWORLD SYSTEMS,
IN C .,
)
}
)
)
5
P la in tiff,
6
92-03841
vs.
7
ANSWER
}
)
)
)
GERALD MARKHAM a n d JANE DOE

MARKHAM,
h is w ife,
8
9
No.
!
... j
)
10
COME
11
12
i M arkham,
co m p lain t),
14
tio n
15
1992,
as
D efendants,
G erald
W.
M arkham,
and
T w ila
( e r r o n e o u s l y d e s i g n a t e d J a n e D oe M a r k h a m i n P l a i n t i f f ' s
13
and
NOW
pro
to
per,
answ er
and
to
sp ecially
P la in tiff's
appear
to
co m p lain t
co n test
dated
ju risd icM arch
fo llo w s:
16
1.
Para.
17
2.
D e f e n d a n t s h av e no k n o w le d g e o f t h i s a l l e g a t i o n
P ara.
18
1 is
denied.
3.
Para
20
4.
D e f e n d a n t s h a v e no k n o w le d g e o f t h e a l l e g a t i o n s
para.
i/*) tX^2 2
Attorney At law
424 Marine VV*> ?<205
was
2'i ^
W * ^ ^ 2 3
m *; 1^ TO
^
-X
s r 24
,. C
O w
C w>.
2 5
'v
^
26
4.
3 is
attach ed
alleg atio n s
to
th e
copy
atten tio n .
in
th is
30
of
th e
in
no c o p y o f t h e a s s i g n m e n t
co m p lain ts
A cco rd in g ly ,
th a t
came
to
D efendants
deny
th e
affirm ativ e
defenses:
paragraph.
AFFIRMATIVE DEFENSES
D efendants a lle g e
1.
F ailu re
2.
L atches.
29
d enied.
C o n trary to th e a lle g a tio n s ,
D efendants'
27
28
in
2, a n d t h e r e f o r e d e n y s a m e .
19
21
17,
of
th e
fo llo w in g
co n sid eratio n .
Vi
th is
3.
M istak e.
4.
Im proper
5.
In su fficien cy
of
P rocess.
6.
In su fficien cy
of
S ervice
7.
Lack
Venue.
of
Ju risd ictio n
of
over
Process.
th e
S u b ject
m atter
of
su it.
8.
Lack
of
ju risd ictio n
over
th e
person
of
th e
be d i s m i s s e d ,
and
D efen d an ts.
9.
Forum n o n - c o n v e n i e n s .
WHEREFORE D e f e n d a n t s p r a y
th at
th ey
be
fees
allo w ed
aw arded
them
at
th e ir
law o r
R esp ectfu lly
co sts
in
th is
and
\c n u rc h il\a n s w e r. coc
PAGE 2 - Answer to Complaint
by
reasonable
th is
/ 3-
th is
.. C - i- V
G e r a l d W. M a r k h a m , p r o p e r
w ho may b e s e r v e d w i t h
f u r t h e r p le a d in g s in t h i s
m a t t e r a t PO Bo x B 0 6 ,
K o d ia k , Ak.
99615
any
eq u ity
S ubm itted
su it
-;.
day
atto rn ey
C ourt.
of
A p ril,
.....
1992.
T w ila M arkham, p r o p e r
who may b e s e r v e d w i t h f u r t h e r
p le a d in g s in t h i s m a tte r a t
PO Box 8 0 6 , K o d i a k , A k . 9 9 6 1 5
EXHIBIT G
GERALD W. MARKHAM
ATTORNEY AT LAW
Practice lojaited to Maritime personal Injury
and Wrongful Death and other personal injuries
or Wrongful Death Occurring in Alaska
Jury Clerk
Alaska Trial Court
204 Mission Road
Kodiak, Ak 99615
Seattle, Wa 98105
(206) 527-1485
Fax (206)52?~01Q1\
(907) 486-4194
Fax (907) 486-5822
2201 Romig PI* Ho.205
Anchorage, Ak. 99503
(907) 276-0336
Fax (907) 276-4681
198 Journey's End

Friday Harbor,
Wa. 98250
(360)378-2873
Fax (360)378-2047
Re: Jury Service Summons
Pear Madam Clerk

I recently received your Summons directing that X call for
Jury service beginning on May 31st for the month of June. However
Magistrate Cole recently excused my service through I believe
June 3rd (a Friday)? I have temporarily misplaced that letter but
I believe that is the date. This excuse was granted in response
to my request (from Arizona) indicating that before I received
your summons my wife and I had already left Kodiak and purchased
tickets that had us returning to Alaska Sunday June 5th which
could only be changed with penalty.
Unfortunately when I wrote that letter, I did not have the
actual tickets in hand. When I recently arrived in Seattle and
studied them, X learned that while they do in fact have us
leaving Seattle for Alaska on June 5th, my wife also scheduled an
Anchorage stopover that we had forgotten about when I wrote my
request to be partly excused. As a result we are not scheduled
to arrive in Kodiak until June 7th at 3:45 PM. This stopover too
can't be rescheduled without penalty* Xn fact as it is turning
out I now need to be in Anchorage on June 6-7 to attend an
important conference that is now being scheduled during that
stopover in a case I'm handling*
Accordingly I must request and additional excuse until the
evening of June 7tl1 and a first report date of June 81*.
Sincerely,
THIRD JUDICIAL DISTRICT

204 Mission Road
Kodiak, AK 99615-9987
** jy sx summons **
GERALD MARKHAM
518 MARIKE WAY #205
KODIAK, AK 99615
JURY CALL-IN NUMBER:
YOUR GROUP NUMBER:
486*1601
2S.
YOU ARE HEREBY SUMMONED to serve as a juror in thefcrinl courts for the State of Alaska, in the City of Kodiak, beginning the
FIRST day of JUNE 2005. Please follow the directions below before
coming to court.
5/6/2005
Tami Starr
JURY CLERK
DIRECTIONS
This court uses a "call-in* system to inform jurors when their
services will be required,
You must do the following if this
system is to work;
1,
Each
juror
must
cal 1
the
telephone
beginning the evening of KAY 31.
2 0 05
number noted
above
after 5:30 p.n. and at
other times as directed.

You can expect to receive a
recorded message such as "Petit jury group # 29 will be
needed Monday at 8:00 a.m,
Please check in at the Clerk's
Office,"
2,
If you are excused from service on that date, you should not
come in.
However, call the number again when instructed to
do so.
3,
If you fail to make the required phone calls or to attend

court as required by this summons, you may be found in
contempt, of court and punished accordingly, unless you are
excused or your service is deferred by the court.
4,
If you have moved out of this judicial service area, or if

you are physically unable to attend court at the time and
place specified, you should immediately notify the court in
writing, giving a full statement of the facts.
5,
Except in circumstances described in paragraph No. 4 above,

no request to be excused or deferred from service will be
considered unless presented in open court at the time and
place where you are directed to appear or presented to the
court by mail prior to that time,
YOU MUST ATTEND as
directed by this summons unless you receive communicatlone
from the court excusing you from service.
EXHIBIT H
EXHIBIT I
PRSTSTD
Alaska Department of Fish and Game

333 Raspberry Road
Anchorage, AK 99518
U ,$ . Postage
PAID
perm it #106
Anchorage, AK
000004 0001068 5-DIGIT99615

GERALD W MARKHAM
211 MILL BAYRD
KODIAK, AK 99615-6334
Alaska Departm ent of Fish and Game (ADFG) General Season Deer
Harvest Report Reminder
EVEN i f YOU DID NOT HUNT, O ur records indicate w e have not

received your general season harvest re port fo r deer,
* The inform ation you provide helps us estim ate changes in areaspecific deer harvest and hunting effort, m o n ito r populations, and
recommend appropriate seasons and bag lim its.
DO NOT REPORT deer hunting o r harvests th a t you conducted fo r

someone else as a proxy o r federally designated hunter, if
somepne^slse hunted fo r you in this regard, YOU are required to
s u b m it^ K ia fo rm a tio n on yo u r report.
Deer h 'fa fiiq jir r t- may be subm itted eith e r by using th e paper
re port cartffntz received w ith you r deer harvest tickets o r by
reporting-ettfide using th e re p o rtin g nu m ber listed a t the end o f
this lette r. Report online at: h ttp ://h u n t.a ia ska .g o v
THANKS FOR YOUR HELP!

ADFG
Your Hunt info rm atio n:
Hunt: GD000
Year: 2012
Reporting No. 0414551
EXHIBIT J
7 M
t'p M ?
O F F IC IA L A B S E N T E E B A L L O T
TO BE O PENED O NLY BY
REVIEW BOARD
KODIAK ISLAND BOROUGH

OFFICE OF THE BOROUGH CLERK
710 MILL BAY ROAD
KODIAK AK 99615
Additional
Postage
Required
VOTER CERTIFICATE and IDENTIFICATION

By lawy our ballot cannot be counted unless you Include your signature, have It witnessed, and provide an identifier.
I declare that I am a citizen of the United States and th a t! have been a resident ofAlaska and the Kodiak Island Borough ter at feast 30 days. ! have not requested a ballot from any other
state and am not /cling In any other manner in this election, if t had this certification attested by witnesses other than an authorised official, It was because no official empowered to
administer an oatt was reasonably avatiabfe. i^ y t h a t the to n in g is Sue and accurate.
...
VOTERS S,fONATURE:
VOTERS tn ENTiFIER;
Voter Number
>T/OAf / - WITNESSING AFFIDAVIT

ized to adm inister an oath or Postal Official, Notary
ssioned Officer, Municipal Clerk, or Election Official.
3 SWOR& TQ'BEFQRE ME: .

{
(City and State or Country)
afurs:
' ft
-i/.r-., ft.
|2 E ?
ZZZ
v -;
r ji Markham
G erald
1981) oum ey's End W ay

Friddy Harbor, W A 98250
*? y
.OR.
YOUR
SIGNATURE
MUST BE
WITNESSED
BY ONE (1)
OPTION
PROVIDED
Date of Birth
Last 4 Digits of Soc. Sec. No.
OPTION II - WITNESSING AFFIDAVIT

If no authorized official is available, your certificate MUST be
witnessed by two (2) persons over the age of 18.
Witness Signature:___________________________________
W/mess Signature: ______________________________ '
City, State:
[ ]Purged
m
\
Sp%
%
%
>
>
O ii
_Zl L Z
.OR
( | Count Full
[ J No Count
Coimiente;___
Date:
Review Board Use Only
Voter#,,
Reg. DlstfPrec..
.Balks Issued: B
__
__
__
TUESDAY, OCTOBER 1, 2013

KODIAK ISLAND BOROUGH
MUNICIPAL ELECTION
OFFICIAL
ELECTION PAMPHLET
The po lls w ill be open
7 a.m . to 8 p.m.
Published by the Kodiak Island Borough Clerk's Office

710 Mill Bay Road, Kodiak
Phone: 486-9310 Fax: 486-9391
O F F IC IA L E LE C TIO N
P AM PH LE T
CITY OF KODIAK
MUNICIPAL ELECTION
OCTOBER 1, 2013
The polls w ill be open
7 a.m. to 8 p.m.
P ublished b y the
K odiak C ity C le rk's O ffice
710 M ill Bay R oad , Rm. 216/217
Kodiak, A la ska 99615
EXHIBIT K
TSA Known Shipper

July 16, 2013
Gerald Markham
211 Mill Bay Road
Kodiak, AK 99615
Thank you for applying to become a Known Shipper with Alaska Airlines/Horizon Air. Your
name and address was approved through the TSAs Known Shipper database (KSMS)**, therefore
we were able to add you to our Alaska Airlines Known Shipper database.
Your Customer ID Number is; 43286
On your air waybills, please indicate your name and physical address as shown below;
Gerald Markham - C1D 43286
211 Mill Bay Road
Kodiak, AK 99615
907-486-4602
If your name, address or phone number changes, U.S. guidelines require you notify us in writing.
Please refer to the Known Shipper application instructions located on our website
www.alaskacargo.com for details or contact us at your convenience.
*At anytime the TSA may remove your known shipper status from their database. In the
case your known shipper status has been revoked in their database, your known shipper
status will have to be removed from our database as well.
Thank you for choosing AlaskaTiorizon Air Cargo.
Sincerely,
Carol Arnold
(800) 225-2752, Prompt 4
www.alaskacanio.com
Alaska / Horizon Cargo Customer Support and Claims - SEAFI
PO Box 68900 Seattle, WA 98168-0900
EXHIBIT L
W ishingyou birthday
cheer a n d a successfulyear.
Jerry Markham
211 Mill Bay Road
Kodiak AK 99615
09/09
EXHIBIT M
t 'c . c
*o & -~
v * *
k p i
I 'ln r . r . n
r i
r*r r
i u r v < ib
Kodiak Island Borough

710 Mill Buy Rd, Kodiak, Alaska 99615
PHONE (907^486-9353 PAX (907) 486-9395
ti-n-ait'. drtppeyfff'k!b.c<i-fcdiak,ak,us
2005 AIRCRAFT FILING FORM

N#: 7998L
GERALD W MARKHAM
51? MARINE WAY, #205
KODLAK, AK 99615
Dear Aircraft Owner;

Current information obtained by our office indicates that you have an airplane in the Kodiak Island Borough. Because
this aircraft is taxable within the Kodiak Island Borough, you are required by law ter complete a filing form and return it to the
Assessing office each year.
Below is a listing o f the information on your aircraft feat we c u rre n tly have on file Please make any corrections to the
listing re fleeting the value and condition o f the aircraft on January 1,2005. Venn estimate of the aircrafts value as of January 1,
2005 will assist us in valuing your property, A valid filing requires your signature and date, and the form must be received in our
office by Feb. 15, 2005, in order to escape late filing penalties. Please call or write our office if you have any questions or need
further assistance, Please list any comments you have that you wish us to consider in piecing a value on your aircraft such as
condition or engine time.
IF YOU ARE NO LONGER THE OWNER O F THIS AIR C R AFT

IN ORDER TO RELEASE YOU FROM FURTHER TAX LIABILITY
A COPY OF THE BILL OF SALE OR TRANSFER DOCUMENT MUST BE SUBMITTED WITH THIS FILING.
AIRCRAFT DATA
Manufacturer: BEECH
Jurisdictiott/TCA: ^ l ____
SMOH:
Price Paid: $0
! Model: A23
| # Engines: J_ _
! TBO:
New/Used;
My Estimate o f the Value of this Aircraft on 1/1/2005 is;
: Year New: 1966

Condition: A
: Horsepower: 180
! Purchase Date: 00/00/00
__ ________'
..
..... -...
s & IT ,O 0O ____\Jqjbd^
Comments:
. (date)
:_________
L (signature)
DO SOLEMNLY
SWEAR THa TTHJS STPWERENT IS?X COMPLETE1'LI SI NG OF THE PERSONAL PROPERTY OWNED OR HELD BY
ME. AS OF JANUARY 1, 200$. I AM AWARE THAT FAILURE TO PROPERLY LIST MY ASSETS AND FILE BY THE
DEADLINE MAY SUBJECT ME TO PENALTIES AS PROVIDED FOR IN STATE LAW,
EXHIBIT N
STATE OF ALASKA
DIVISION OF MOTOR VEHICLES
SENIOR CITIZEN EXEMPT AFFIDAVIT
ERX552
1FTCR14U7RPC38650
Alaska License Plate Num ber
Serial Number (V?N)
1994
FORD_________
Year
Make
COURIER
Model
I,_________________ G&ra\d WAYNE
PK________________
TEA
Body Style
Color
MARKHAM_______ _________ state that I am art Alaskan resident 65 years of
(Print Your Full Legal Name)
age or older as o f January 1st o f th is year and I am applying fo r a tax exemption for one m otor vehicle subject to
registration, per Alaska Statute 28.10.411, J am the registered owner, either solely or joirrtJy, o f the vehicle described
above. I understand that this exemption may be used on o n ly one vehicle a t a tim e and that I have no other vehicles
registered with this exemption.
My date o f birth is:
SEPTEMBER 9,1947
M y
Alaska Drivers License or State ID Number is
0184904
I sweanundfir the penalty of perjury that the statements above are true.
(SEAL)
-3 /z /jf*
Signature [Sign in front of
Representative o r Notary}
me this
SubscribecLaod sworn to
Date
s?cf
,2Q/-S
dayof /2 m J L
M onth
Jean M. McGaughey
Notary Public - Arizona
Pima County
My Commission Expires
June as, 2016
Year
My Com m ission E xpires
Alaska.gov/dmv
Form 807 (R ev. 10/2009)
Additional Information:
* if you have claimed a senior citizen exemption on another vehicle, you are not eligible for a
second one.
* You must have been 65 on January 151of this year to qualify for this exemption.
* ORIGINAL requests for senior exemptions cannot be processed over the internet. You will be
able to renew your registration using this service.
* When requesting the exemption through the mail, you MUST have your signature witnessed by
a notary or a DMV representative.
> ^
/ A
P U ^ -
Items to mail:
* * :f * * * ^
senior exemption form

Pre-bill or copy of last registration
r
Mail to:------:
State of Alaska
Division of Motor Vehicles
ATTN: MAI LOUTS
1300 W Benson Boulevard STE 200
Anchorage AK 99503-3600
Z
r Z fe
j-o r
lJ * 4
( /^ e/7 i j o
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7
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f le i& L .
-------------------------- ,
C K r f ' / i ^ . S '* A *
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ve.
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k a ,c i# /f & f/d n ieW . c X _ 4 , ^ l
r sAlaska.g
. z
C / cj
/>*
A ir
/W ^v Te eV/ JV/bc'e
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_______STATE OF ALASKA - VEHICLE REGISTRATION

IDENTIFICATION NUMBER
LICENSE
ERX552
READ INSTRUCTIONS ON REVERSE SIDE
BODY
COL(
WEIGHT
PK
TE
3000
AFTER PAYMENT OF FEES, THIS REGISTRATION

EXPIRES ON THE LAST DAY OF:
FEB 2015
OW NER
S IG N
v
41
UNIT NO-
MODEL
MAKE
1994
FORD
HO
EMISSION INSPECTION REQUIRED
OWNER
GERALD WAYNE MARKHAM OR TWILA

YVONNE MARKHAM
MAIL
ADDRESS
211 MILL BAY RD

KODIAK, AK 99615-6334
REGISTRATION
(A$28.10.421)
$180.00
TAX
$40.00
(AS38.10.431)
INDICATE
CHANGED
ADDRESS
HERE
PLATE RENEWAL FEE

(as z f - . m
RESIDENT
ADDRESS
211 MILL BAY RD

KODIAK, AK 99615
$0.00
zm )
TOTAL FEE DUE*
1111
The owner certifies that there is a liability insurance policy for this
vehicle if required by AS 28.22.011 and this policy wilt be maintained
during the entire registration period; the address shown is my true legal
address; if this is a commercial motor vehicle, I certify that I am fam iliar
with and haw knowledge of the Federal Motor Carrier Safety Regulations,
Federal Hazardous Material Regulations and Alaska Administrative Code
17 AAC 25,200; and all information is hue and correct.
YEAR
CLASS
1FTCR14D7RPC38650
$220.00
* An additional $10 registration fee will

be charged if renewing In person at a
State DMV office. AS 2S.t0.4Zl(aX2}
LIENHOLDER
B 1 5 ffc K T A F V B /2 0 1 2
Please provide the driver license number for ail registered owners o f this vehicle. This information will
allow DMV to more efficiently update future address changes.---- --------- - -------------
tfkk* * * * * * * * * <* * * * * 4 4 4 * 4 4 iu ftw 5'DIGiT 99615

GERALD WAYNE MARKHAM OR TWILA YVONNE MARKHAM
211 MILL BAY FID
KODIAK, AK 99615-6334
STATE OF ALASKA - VEHICLE REGISTRATION

L viv,
RRN: 29761876
LICENSE
BODY
READ INSTRUCTIONS ON REVERSE SIDE
IDENTIFICATION NUMBER
ERX552
PK
COLOR
FEB 2015
WEIGHT
TEA
AFTER PAYMENT OF FEES, THIS REGISTRATION

EXPIRES ON THE LAST DAY OF:
CLASS
1FTCR14U7RPC38650
add r ess
YEAR
MAKE
1994
FORD
EMISSION INSPECTION REQUIRED
UNIT NO.
3000
OWNER
41
MODEL
WO
GERALD WAYNE MARKHAM OR TWILA

YVONNE MARKHAM
REGISTRATION
211 MILL BAY RD

KODIAK, AK 99615-6334
INDICATE
CHANGED
ADDRESS
HERE
- -
{AS38.10.421)
fc.-i-RT i t -
$180.00
TAX
,
(ASZ8.1G.431)
$40.00
PLATE RENEWAL FEE
r v w (AS28.10.421id>)
$0.00
S i t ? 211 MILL BAY RD

ADDRESS KODIAK, AK 99615
TOTAL FEE DUE*
INDICATE ^
CHANGED ADDRESS
HERE-.
* An additional $10 registration fee w il

be charged if renewing in person at a
State DMV office. AS 28.10.421(61(2)
LIEN HOLDER
$220.00
EXHIBIT 0
From :
S u b je ct:
Date:
To:
Cc:
Jay Barrett <3hejaybob@ icloud.com >
Be: E-mail Updates?

September 11,201 3 5:38:25 PM PDT
Gerald Markham <gm arkham @ nwlink.com >
Pam Murray < pam m urray@ gci.net>
Hi Jerry,
Diane Fogler is our membership person theses days, but Hi be darned if I cans her email right at the m om ent i'i! pass
your questions on to her and Pam Murray, the treasurer who should be able to answer your dues question.
Thanks for the other info. Hope aii is well with you.
Cheers,
Jay
Sent from m y iPhone
On Sep 11, 2013, at 6:44 AM, Gerald Markham < Qmarkham@nwgink.com> wrote:
Dear Jay:
Darlene W ilson is my cousin. Her phone # is 907-486*6217. I spoke to here several tim es this summer and she often
answers it but messages are not often returned. She may also be reached through her daughter and son in law Geti
and Kevin Arndt 486-5556 (hom e); 486*3755 (work), 539-2500 Cei). She lives next door to them and they are helping
her with her affairs.
Also does the Pioneers issue m em bership cards? I've lost m ine? if so could you mail another to me at 198 Journeys
End way, Friday Harbor, 98250 where I plan to be through December?
if not could you please send an emai! reflecting how long I've been a member. Finally are my dues current and if not
where do l send them now that our faithful Micky is gone to O regon?
Thanks
Jerry Markham
On Sep 2, 2013, at 1:49 PM, Jay Barrett wrote:

Thank you for the responses to the e-m aii question. Sad to hear Annie Koppang has passed away.
Begin forwarded message:
From: Jay Barrett < theiavbob@ icloud.com >

Subject: E-mail Updates?
Date: Septem ber 2, 2013 1 1 :49:50 AM AKDT
To: Jay Barrett < thejaybob@ gm aii.com >
Hello again fellow Pioneers,
I received three e-m ail bounce-backs when i sent out the request for newsletter Items.
if you know these folks' current e-m ail addresses, please let me know, thanks!
Mona Johnson;
Darlene Wilson; and
Annie Koppang.
Thanks!
Jay
p.s. If you would rather not receive e-m ails about Kodiak Pioneers, just reply with remove.
N ew sletter Vahime XUT Issue No. 6
Septem ber 2013
Kodiak Igloos ly & 18
. r'onw,? p:nt <1nd
.''tA-. i^ f n i u . t v r.h,5ro bi-ad:- o f jo y
^n",ra our ^ oat during this

j' A J: y e a r ' s Kodiak Crab Festij;'
vn] parade. O ur King and
Q J en were Walt and
Kate Loewen.
Pioneers o f Alaska, Kodiak igloos 17 & 18
G r a n d I g l o o K o d ia k is
JUST ONE-YEAR AWAY!
As we enter our fall-winterspring meeting season, we also
start the one-year countdown to
hosting the Grand Igloo Conven' tion in 2014. Igloo IS President
Walt Loewen put it best at the last
jm eeting when he said we will all
need to pitch in to make the event
a success. Several members are
already elbow-deep in preplan
ning, and I hope all of us will be
rieck deep in it one year from
now. We have members at the
G rand Igloo in Juneau this
m onth, who will surely bring
Iback ideas for our convention, I
;.look forward to hearing them
and planning our event.
/s
We lost two Kodiak Pioneers

this summer; Sister Pioneer
f&
i Thelma Johnson and Brother
i. t
V / Pioneer Richard Heglin. Sev I N/f era^ members shared touching
\ Vs /
memories to honor them at
toOillS'
ur last meeting.
May they Rest in Peace,
e
A cco u n t B alances as of 10 S ept 2013

General Fund
$1,864.83
Convention Fund
$1,988.40
Above Combined
$3,853,23
Pull Tab Fund
$19,875,95
Edward Jones Account
$24,637,63
1
N ew sletter Volume XJV Issue No. 6
September 2013
T ickets are A vailable for O ur C ar R a ffle !

Thanks to Louise and Stormy Stutcs, our Igloos of the Pioneers of
Alaska will have a pretty sport}' item to raffle off during our December
meeting: a 1993 Volkswagen Corrodo! All proceeds go to our Grand
Igloo Statewide
Convention in 2014!
Newsletter Volume XIV Issue No. 6
September 2013
Kodiak Igloos - Pioneers of Alaska

P.O. Box 684
Kodiak. Alaska 99615
FIRST CLASS MAIL

A ddress Correction
& Return Service
Requested
Pioneers of ftteska, Kodiak igksos 17 & 18
EXHIBIT P
'mmm
CITY OF KOOfAK
SENIOR CITIZEN
SALES TAX EXEMPTION
-:-.. Its
Gerald Markham
W h o s e p ic tu re is a ffix e d h e re to is
v?
e x e m p t fro m p a y m e n t o f s a le s ta x
o n re n ts , re ta il p u rc h a s e s a n d
s e rv ic e
**-X\,1.V . ;--V'. Vi
, .W
S.- ; yK^:
illilll1111,1IJilf
^ :'-M:;
N il 1 111 1 l& l 1:1 If I I 111
Mmi
f.lir 5t
. *.
\ '
V:
jj.
****
K-Stifff
. .V\
.....
.vf. ; v'
. . x
'
a^R/iLD w
:
'S IJ-CEh .0^.1984
8'634 i 94 ;
:
M ile a g e P ly i f
To participate in the Alaska Donor Registry

program contact:
Alaska Donor Registry
Life Alaska Transplant
P.O. Box 231809
Anchorage, Alaska 99523-1Q09,
1 (907) 562-5433 or
1 (600) 719-5433
www.ilfeajaska.org
Thank your fo r your willingness to help others

through transplant.
'rT ?.' " .... ... ......... -
G erald W. M arkham
A ctive MEMBER 2013
* Present your card each tim e yon check out items.

* Report address change or lost card promptly.
* There are charges for late, lost or dam aged m aterials and
to replace library cards.
* Library privileges m ay b e revoked for violation o f library rules.
* T he undersigned (or parent/guardian) assum es responsibility fo r
m aterials selected and borrow ed with this card.
1
Authorized Signature
Your WanlMifshiuCSrd is accepted at pitf-clpaiing Saleway inc. and Cans stores.
This card baiongsto Safeway !i>?. and must to EsriwAMd on ><% *&- By ustnu It'Scaidiftar^M
umW^chttis tawL Pbmm* it# Jm or MU! M <Hrtk>to aw*.***-
Carrs Plus/Satoway CltUj

SatBway Inc.
lilH
PC Box 89
Pleasanton. CA 5458B
Your Card Number Is...
I ii
46010327078
UA PATWI(5A>1A ,
Adm inistered by HeaithSm art Benefit S olutions

MEMBERS AMO PROVIDERS: If you have questions regarding
benefits and health claims or need confidential assistance with
healthcare questions or help selecting a provider call 1-877-517-6370,
PRE-CERTIFICATION IS REQUIRED: Please call the AtaskaCare
Service Center at 1-877-517-6370 before all non-emergency inpatient
admissions or within 48 hours after emergency admissions.
SUBMIT ALU CLAIMS TO;
CUSTOMER SERVICE'1-877-517-637l>
HEAITHSMART BENEFIT SOLUTIONS CUSTOMER SERVICE TOO; 1-877-617-8418
PO BOX 990W
24 HOUR NURSE LINE';
1-655-356*2071
ANCHORAGE, AK S3309
www.alsskacare.gov
EDI # 87815
And Affiliated Natwarks:
- ,
rahoaks ) IMrl
"
'KfATiD
ftZ
ia
L
A
,
*ir
Nd,
w
W
W
VV
AttuLTlPJJVKHETWCRK
Ikt&L
O ppo
Out of
Club 49 benefits offered

only to Alaska residents.
2 free checked h a g s - Whan flying to or from
the stale of Alaska on Alaska Airlines flights,
Travel Now discountTwo annual one-way certificates

for 30% off YAS fa re s when flying to, from or within Alaska
on Alaska Airlines. Booked within four days of departure.
W eekly fare s a le s - Receive exclusive emails
featuring new deals every week,
tBBrti more at our silo especlally te Alaska maldenm: a ta tk s ^f^^w c Ifib M
i t i t
f i J ). i i
[i.' i i
Preamble to the Constitution

State of AtasH *-'
UNIFORM DONOR CARD

Of
r / </ //?* jÂ'X-
Ftint name of donor

I hereby make this anatomical gift to take effect
ugpn my death. 1 wish to donate the following:
^ Anv needed organs or tissues
____ Only the following:..
Department of Fish & Game
. \
I hereby certify (hat all of the iiifcrraalion on the reverse side is true anti cor
rect. f further certify that 1 meet the provisions of the applicable, Alaska Stat
utes, AS 16.05.400(b) or AS 16,05.341. 1 understand this information is
subject to public disclosure^
Signature:
Conor Signature
This card rairit'bc in vour possession while engaging in the authorized activi
ties is described on the front. This card is not valid if residency requirements
per AS. 16j05,940 and AS 16,05,415, and veteran requirements, if
applicable, per AS 16.05.341, are not maintained.
T s s A w w te w w iriiiiw # ' tTpUtonsite 1ST
Its own laws regarding tax exempt organizations. An exempt organization
Ipis
f it f lf
can be Codes SI, 3 ,4 , or 5 .
js i
A business (Coda 1) may purchase tax exempt tom s only lor RESALE.
State Law requires ua to collect Sales Tax on supplies and other Items that
ere used In the business.
'
P ro u d p o s s e s s o rs o f a p ric e le s s h e rita g e , w o m a le d e sce n d a n ts

o f v e te ra n s o f th e G re a t W a rs , associa te o u rs e lv e s to g e th e r as
"S o n s o f T h e A m e ric a n L e g io n 1' f o r th e fo llo w in g p u rp o s e s :
To u p h o ld a n d d e fe n d th e C o n s titu tio n o f th e U n ite d S ta te s o f
A m e ric a : to m a in ta in Saw a n d o rd e r; to fo s te r a n d p e rp e tu a te a
tr u e s p ir it o f A m e ric a m am ; to p re s e rv e th e m e rn o rte s o f o u r
fo r m e r m e m b e rs a nd th e a s s o c ia tio n s o f o u r m e m o s rs a n d o u r
fo re fa th e rs in th e G re a t W a rs ; to in c u lc a te a se nse o f 'n d iv -d u a !
o b lig a tio n to th e c o m m u n ity , s ta te and n a tio n ; to c o m b a t th e
a u to c ra c y o f b o th th e p a s s e s a n d the m a s s e s ; to m a ke r ig h t th e
m a s te r o f m ig h t; to p ro m o te peace and g o o d w ilt o n e arth , to
s a fe g u a rd a n d tra n s m it to p o s te rity th e p r in c ip le s o f ju s tic e ,
fre e d o m a n d d e m o c ra c y ; to c o n s e c ra te a n d s a n c tify o u r
t
frie n d s h ip b y o u r de votion to m u tu a l h e lp fu ln e s s ; m a d o p t m
1
* , . h c n ir it All o f th e g re a t p rin c ip le s fo r w fo c h T h e A m e n ^ n
It is the responsibility of each m em ber to promptly inform

the offices o f the Bar Association of any change m his or her
address or telephone number.
A request for transfer from active to inactive membership status
is accomplished annually anti must be made no Uter than
January 1st o f each applicable year. Detailed information is
available on the Bars websile or from foe Bar Office for those
seeking a change in their membership status.
3: Improper use ol this card m y baa vtefctton of state criminal and

tax laws and subject the offending party to penalties of perjury in addition to
tav rjanalhi a n rl In^n> m fennwriwA*
AI-ASitA RAItASSOCIATION CO, BOX 100279 ANCHORAGE, AK 49510
Plieue (907) 272-7468
fax (907) 272*2935
EXHIBIT Q
D E m tH O ID EN TIFICATIO N O F IN D IVID U AL
NOTARY
FEE
FINGERPRINT AND OTHER INFORMATION
$
2
$
12
14
EXHIBIT R
from:
G erald M arkham < gm arkham @ nwlink.Gom >
Subject: Re: mail, checks

M ay 3, 2013 4:20:41 PM PDT
Tot Adam Logghe < adam @ devtty.net>
Need the G reen A m eritrade checkbook on my desk and m y traveling office
And m y airplane gate key w ith m y picture on it that is in i think in th e headboard o f th e bed or the draw er o f th e china
cabinet and The "blue key set
A lso there is an A ffidavit th a t your m om signed about a w eek ago that w a s n l in the P roperty tax file Pearly delivered to
me. Ken A rndt is going to handle the appeal fo r m e o f so 1 d o n l have to go to K odiak this w eek as i have to ju s t turn
around and be back on the 13th. f faxed the borough the affidavit but they have to have the original.
My pack m ight be in your m others car. I had it when I w ent to the PO.
There is also a sm all paper file w ith som e letterhead paper and stam ps that l took to the PO w ith me to file the brief
the night this all happened. W here ever that ftie is th e pack should be.
M ight have ended up in the back seat?
Thanks you fo r your help. I'll call C hris and see if he can com e over now ?
On M ay 3, 2013, at 3:38 PM, Adam Logghe w rote:
l can give C hris these...
Ken Britain check
Farley G raves
Jam es C Egan
No purse a t 810.
W hat checkbook are you w anting?
Adam

7 Twila Markham V Gerald Markham RES Declaration-Reply 13-3-08383-7 SEA

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7 Twila Markham V Gerald Markham RES Declaration-Reply 13-3-08383-7 SEA

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FILED

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

No. 13-3-08383 SEA

) Reply to Petitioners Response to

GERALD WAYNE MARKHAM

PRELIMINARY REPLY TO PETITIONERS FACTUAL

Petitioner (Twila) responds to Respondent (Jerry)s good faith 12(b)(1)

Motion to dismiss by essentially improperly attempting this courts attention from

contrary to the interests she claims here) which is independently corroborated in a

La TO ffic eso f A nthony M . U r ie , PLLC

18130 Midvale Ave N Ste A

there. On this occasion they were in Seattle on a layover on a through Alaska

irrelevant and (conspicuously) incomplete , unverified police report of that one

18i30 Midvale Ave N Ste A

attempts to draw inferences from his agreement to a stipulated order of

Law O ffices of A nthony M. U r ie , PLLC

18130 Hidvale Ave N Ste A

own exclusive brokerage accounts (accessible with passwords unknown to Jerry)

having a net value of over $1.5 Million dollars!34

these brokerage accounts will conclusively demonstrate she was exclusively

involvement of a broker or Jerry) in her sole name as well as managing numerous

L aw O ffices of A ntho ny M. Urie, PLLC

18130 Midvale Ave N Ste A

is a great help to me. But

made aware o f the effect of claiming an Alaskan domicile as clearly evidenced

regarding Twilas counsel incredulous attempt to bolster her claim to a

L aw O ffices of A nthony M .U r ie , PLLC

18130 Midvale Ave N Ste A

Washington domicile by attacking Jerrys claim to being an Alaskan based on the

all in Alaska, and that under his stipulated order of

continuance he is (effectively) compelled to spend a minimum of 26 weekly

J The pleading served on J e m s counsel didnt include his interrogatory answers

L aw O ffices of A nthony M . U r ie , PLLC

18130 Midvale Ave N Ste A

Suffice it to say Jerry documentation in that regard speaks louder then

paperwork presently in his possession Jerry is unable to establish that he holds an

L aw O ffices of A nthony M* U rje, p L l c

18130 Midvale Ave N Ste A

similarly current holders of a US National Marine Fisheries rural subsistence

Borough election on October L 2013 (as typically has Twila). EX J He is an

Alaskan Air Cargo known shipper from Kodiak, EX K, He is a member of the

domicile, residence and permanent place of abode to be their large 11 bedroom

Law O ffices of A ntho ny M . U r ie , PLLC

18130 Midvale Ave N Ste A

long been an active member of the Alaska Pioneers Kodiak Igloo # 17 an

organization which requires its members have a minimum of 25 years of Alaska

rights to maintenance and cure) and regularly appears in Alaskan Courts.8

Law O ffices of A ntho ny Ml. U r ie , PLLC

1S130 Midvale Ave N Ste A

II. PROCEDURAL POSTURE

Twilas response is essentially a plea to this courts equity when In re

matter jurisdiction is one o f law preliminary to any exercise of its equitable

Jerry will address the

III. APPLICABLE LAW

Law O ffices of A ntho ny M. U r ie , PLLC

18130 Midvale Ave N Ste A

commands of this states appellate courts regarding the proper procedure to be

Jerrys burden of going forward in Robinson and LCR 7(b)(5)(B)(iv) is

satisfied by Twilas affidavit attached to his 12(b)(1) motion clearly establishing

his wife acknowledged on April 15, 2013 that her:

domicile, residence and principal place of abode is with my

And as particularly noted in Strohmaier at 17:

^Quoting In re Marriage of Strohmaier. 34 Wash.App. 14, 17, 659 P.2d 534(1983)