Stipulated Judgment for Dissolution of Marriage — Cassie Will-Darnall and Sheri Darnall (Document 104-6)

Summary

This is a Stipulated Judgment for Dissolution of Marriage between Petitioner Cassie Will-Darnall and Respondent Sheri Darnall, both In Pro Per, attached to Document 104-6 in Case 5:24-cr-00292-PCP. It states the parties married on April 22, 2012, separated as of January 20, 2016, and have one minor child, and that Case No. 15FL177208 is pending in the Santa Clara County superior court. The parties agree to joint legal and joint physical custody, to joint and equal interests in Soda Springs LLC, and that debts in Cassie's name, including all loans from Sandra Will, are assigned to Cassie. It says neither party retained an attorney and that both jointly retained Monica J. Asplund to help prepare the judgment. The signature block names Cassie Will-Darnall, with a note referring to an attached notary form.

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Case 5:24-cr-00292-PCP Document 104-6 Filed 11/11/25 Page 4 of 41 zc

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STIPULATED JUDGMENT FOR DISSOLUTION OF MARRIAGE i

The parties, Petitioner, CASSIE WILL-DARNALL, also referred to herein as “Cassie”

who is In Pro Per, and Respondent, SHERI DARNALL, also referred to herein as “Sheri,” who i
In Pro Per, agree to the following stipulations:

1. ‘The parties were married on April 22, 2012 then became registered domestic
partners with the State of California as of November 13, 2012. The parties separated as of
January 20, 2016, after being married for 3 years and 9 months. The parties have one minor

child, —— born on a. who is 2 years old.

2. By this Agreément the parties. desire to effect a recitation of their respective
separation property, fo complete a final and equitable division of their community property, apd
to provide for and define their-support obligations to each othér.

3. A proceeding for dissolution of marriage, Case No. 15FL177208, is now pending
in the Superior Court of the State of California, in and for the County of Santa Clara, wherein
Cassie is the Petitioner and Sheri is the Respondent.

4, Child Custody & Visitation: The parties shall share joint legal and joint physical
custody of their son, A copy of the Stipulation and
Order Ré Child Custody & Visitation fi Jed on February 15, 2017 is attached hereto and
incorporated herein as Exhibit 1. Said Stipulation reflects the parenting time and other parenting ©
rights agreed to between the parties, The parties agree to participate in co-parent counseling with ;
their selected therapist, Trudy, at montually agreed upon times and frequency,

In addition, the parties agree that if the custodial parent is unable te care for the child for
a period of three hours or more, not including their normal work day, then the other parent shail
be given the first right to care for Nicholas during the custodial parent’s unavailability. i

The parties agree that this shall bea permanent custody order and shail constitute a finpl
judicial determination as to custody within the meaning of Monteriegro v. Diaz (2001) 26 Cal 4h
249, The parties have the right to switch days or make minor modifications to the schedule by
agreement. However, thesparties understarid that there shal] be no permanent or binding changes 2 |
to the agreement absent a formal stipulation and order or order of the court. pA

Pursuant to Family Code Section 3048, the parties agree that California is the home stdte i
of the child, and there are.no other states that have assumed jurisdiction or are the Z ui
home states of the child. The child habitually resides in the United States of America, Any
violation of this order may result in civil of criminal penalties or both. The child custody and
visitation rights.of each party are set forth herein. a

Judgment for Dissolution of Mariage } i

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5, Child Support: The issue-of child support is reserved, The parties are in dispute
as to their respective incomes and the inputs for a Dissomaster calculation. Attached as Exhibit
2 is a Dissomaster calculation based upon the parties’ previously exchanged Income and Exp pose
Deciarations, although the Cassie believes that the amount stated in her Income and Expense
Declaration is not consistent with her actual net business income after expenses. The attachett
Dissomaster is without prejudice as to either parties’ positions regarding their respective incomes
or their understanding as to the other parent's income. The parties understand and agree that
their desire is to complete all ather aspects of the dissolution is without prejudice to either
parties’ position or claims regarding child support. Sheri shall have the right to claim head of
household with the child as a dependent for income tax purposes in even numbed years; and
Cassie shall have the right to claim head of houschold with the child as a dependent on her tax
returns in odd numbered years, The-parties understand that the court shall retain jurisdiction bver
the issue of chtid support until the child marries, dies, is emancipated, reaches the age of 19, or
reaches age 18 and is not a full-time bigh school student, whichever occurs first. Since health
insurance is available through Sheri’s employer, she shall maintain the child on her health
insurance plan so long as it continues to be available to her at same or similar cost. The parti¢s
shall share equally al! uninsured health, vision, dental, orthodontist, and therapy expenses for {the
child.

The partics acknowledge-that they are fully informed of their rights conceming child
support, and that this child support provision is being agreed to without coercion or duress. The
parties further agree. that this agreement is ia the best interest of the child and that the needs of
the child will be adequately met by the stipulated amount. The parties acknowledge that the right
to support has not been assigned to the county pursuant to Section 11477 of the Welfare and
Institutions Code and that no public assistance application is pending, No change of
circumstance need be shown for the court to make a guideline support order.

A Notice of Rights and Responsibilities and Information Sheet on Changing a Child
Support Order is attached hereto as Exhibit 3.

6. Spousal Support: Neither party has requested, nor is paying, spousal support ¢
the other, Both parties are healthy and employed. In consideration of the other terms and
conditions stated herein, each party waives any aud all right to claim spousal support from the
other now and forever. Both parties understand that a waiver‘of spousal support and a
termination of the court’s jurisdiction to award spousal support is permanent in nature, Under no
circumstances, regardless of any change in the parties’ lives in the future, will! either party have
the ability to seek spousal support from the other. Both parties understand that the court is taking
away its current and future ability to award support, or even to consider it. The court shall anc
does hereby terminate its jurisdiction over the issue of spousal support payable to either party.

7. Real Property: The patties acknowledge and agree that they have already reached
an agreement and completed the division of their respective interests in the former family
residence located at 11] Belwood Gateway, Los Gatos, CA 95032. Cassie is awarded the rea

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Judgment for Dissolution of Marriage 2

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property located at 111 Belwood Gateway, Los’ Gatos, CA 95032, and shall be solely respontbl

for any and all debts, encumbrances and lisns of any kind associated with said property. She
has received a buy-out from Cassie as to her interest in the Belwood Gateway property and h

acquired real property in her name located at ME. San Jose, CA 95124. Confirm

to Sheri as her sole and separate property is the real property located a San
Jose, GA 95124, and she shall be solely responsible for any ‘and all debts, encumbrances and
lieus of any kind associated with said property. Both parties waive any and all tights, title an
interest that they may have had in the property awarded to the other party. Both parties
knowingly waive any and all rights that they may have to claim any further payment or inter
the peep awarded to the other party. ©

During.the parties’ marriage, they acquired a condominium located at
, which is used arental property. There is no outstanding

to have a 50% equal interest in Seda. Springs LLC, which maintains the property, collects the
rents, and pays the expenses of the Las Vegas property. Both parties shall continue to abide by
the terms of the LLC and agree that there’shall be no withdrawals from the Soda Springs LLO-
bank account absent a mutual agreement of the parties. At this time, the parties anticipate

continuing to receive periodic, equal distributions from the bank account. The parties will me et

and confer as to.the amounts and frequency of the distributions. The court shal! continue-to
maintain jurisdiction to. make any orders’ associated with this property that are not inconsistent
with the terms’of the parties’ agr eement(s).

Confirmed to Cassie as her sole and separate property is the real property located at i
, which was received as an inheritance prior to the parties’

marriage. Also confirmed: to Cassie as het sole and separate property is the lot located.at Pine
Mountain Lake, California, which was purchased after separation. Sheri waives any and all
rights, title or interest that she may have had i in both of these properties.

Each party agrees to indemnify and hold-the other harinless from any and all debts,
liabilities, and encumbrances of any kind associated with the real properties awarded to them

herein. The parties acknowledge that all transfer deeds have already been signed; however, both

parties shall promptly execute any other documents necessary to effectuate the rights, interests
and obligations of the party’s real property consistent with the division-set forth herein,

8. Forniture/Furnishings: The parties have already agreed upon a division of the
community furniture and furnishings. Awarded to each party are the furniture, furnishings,
jewelry, collectibles, tools and appliances in his/her current possession.

9, Vehicles: The 201 5 Range Rover, which is leased through Cassie's business,
and the 2014 Jeep Wrangler, are confirmed'to Cassie as-her sole and separate property, along

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Judgmént for Dissolution of Marriage 3

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mortgage/loan associated with this property The parties wil] continue to own the property equally!
and agree that each shall maintain a 50% interest in said property. The parties shall also continue

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with any and all debts, liabilities. and encumbrances, The 2013 Ford Explorer is confirmed ta
Sheri as her sole and separate property, along with any and all debts, liabilities and
encumbrances. Each'‘party waives any and all rights, title or interest that. they may have in the

vehicles awarded to the other party. Each party agrees to indemnify and hold the other harmless

from the debts, liabilities and encumbrances on the vehicles awarded to her.

10. Bank Accounts: Cassie is awarded any and all bank accounts in her name,
including but not limited to the following; .

Wells Fargo business savings account;

Wells Fargo business savings account

Wells Fargo business savings account ending 7528;
Wells Fargo business checking account ending 6807;
Wells Fargo personal checking account ending 0781,

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Sheri is awarded. any and all bank acbounts in her name, including but not limited to h
Wells Fargo checking account ending 2329 and savings account.ending 0498,

The parties acknowledge that they still have two joint bank accounts open with Wells

Fargo Bank, a savings and checking account, The parties agree that there is approximately $300

in the savings account and $400 im the. checking account, Each party shall contimie to have the
right to deposit money into either account. They further apree that no withdrawals from the
accounts shall be made absent an agreement between them in writing (an ¢-mail confirmationlis

sufficient) or as otherwise specific in this provision. The parties-agree that the accounts shail pe
maintained to pay agreed upon expenses on behalf of their son or as otherwise agreed to between
them in writing (an e-mail confirmation is sufficient). If at any time either party wishes to close

an account, she shall provide a minimum of thirty (30) days written notice to the other party

along with her proposal for division of the funds i in the account. Unless there is an e-tmail or other

writing reflecting an agreement as to division of the funds, then the proceeds that are on deposit
shall be divided equally regardless of which party deposited the funds. However, there is an
exception: if either party deposits funds that‘have not been in the account for at least thirty (34)
days, then the depositor shall have the right to a refund of their deposit(s) up to the amount of'
their verifiable deposit(s), and that any fonds remaining thereafter shall be divided equally. The
parties understand that regardless of which party deposited the funds, ihe funds that are in the

account at the time that a party exercises their right to close the account, shall be divided equally

provided: that the funds have been in the account for at least thirty (30) days.

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With the exception of the jointly held accounts, each party waives any and all rights, title

and interest that he/she may have in the bank accounts. set forth above that are in the other
person’s name,

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9, Life Insurance Policies: There are no known life insurance policies with cash

value. Awarded to each party are the term life insurance policies through his/her place of
employment, Each party has the right to change the beneficiaries on his/her own policy.

10. Stocks/Stock Options: Cassie is awarded. any and all stocks and stock accounts i

her namé, incliding all stocks held in the E*Trade account in Cassie’s name which are estim

by Cassie to be about $10,000 in value. ‘Sheri waives any and all rights, title or interest that
may have in these stocks/accounts-

I]. Retirement, Pension and Deferred Compensation Accounts: Cassie is awarde
the Citibank Roth IRA in her name, Cassie is unaware of any other plansinhernameorin |
which she may have intérest. Sheri is awarded the San Jose Market Pension Plan, Good.

Samaritan HCA 401 (k) Plan, and any other retirement/deferred compensation plan acquired pri
to marriage.or through hér employment with Good Samaritan Hospital. Each party waives. any

and al] rights, title or interest that they may have in the accounts awarded to the other party.

12. Business Interest: The businesses known as Rosswood Properties & Associated
Assets and the business known as: Rosswood LLC and Associated Assets, along with any andiall |

assets, debts and Ijabilities is confirmed to Cassie as her sole and separate property, Sheri wa yes.
and all interest she may have acquired during marriageto any of these properties. Cassie agrees

to indemnify and hold Sheri harmless from any and all debts, liabilities and encumbrances

aSSOCI ated with these businesses.

The business known as Soda Springs LLC shall be govemed by the company agreement

and bylaws. Each party shall continue to lave joint and equal interests in Soda Springs LLC.

13. Inheritance: The patties agree and understand that Cassie has acquired some of
her assets and property through an inheritance, including some of her business{es). Unless
otherwise set forth herein, Sheri knowingly. waives any and all rights, title and interest.in any:
asset that Cassie has acquired through inheritance,

Mt. Debts: There are no known community debts outstanding,

Aby and al] debts, loans and liabilities i in Cassie’s name shall be assigned-to her as her
sole and separate debts, including but not limited to all Joans from Sandra Will. Any and all

debts, loans, and liabilities in Sheri’s name shall be assigned to her as his sole and separate debis.
Any and all debts arising out of any community filed tax return or community real property'shpll

be shared equally between the parties. Each party shall assume any debt or liability currently in
his/her name-and agrees to indemnify and hold the other patty harmless therefrom.

15. Health Insurance: The. parties understand that upon completion of the dissolutipn,

she will no longer be eligible for health insurance under the other’s medica! plan through her

Judgment for Dissolution of Marriage Ss

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place of employment. Each party understands and agrees that when the dissolution ig complete,
she will be responsible for obtaining and paying for her own health insurance. If either partylis
eligible for COBRA insurance through the others existing plan, each party agrees to cooperate to
allow the other to take advantage of this opportunity so long as it is available. Both parties
understand and agree that the other pasty shall not have any financial obligation toward COB RA
or other substitute obligation elected by the other party, and that this will be the sole and separate
debt or obligation of the party who elects the COBRA.

16. Attomey Fees & Costs; Each party shall pay his/her own attorney fees, paralegal
fees, or other legal fees incurred until the date the Judgment is filed.

, 17, Claims.ofReimbursement: Both parties have claims of reimbursement, credi
and claims against cach other associated with the payment. of community obligations, rental value
of the residence, division of the property, and various claims and counter-claims regarding f
payments for ongoing community expenses. However, the parties have negotiated this |
agreement, including the division of the property and waiver of spousal support, in consideration
of all of these claims and counter-claims, The parties recognize these reimbursement claims and
agres that the division of the community assets and debts set forth herein have taken these clams
into accdunt. Both parties waive any further requests for reimbursement or claims of credit o
any Claims whatsoever against the other in consideration of the terms and conditions set forth

18 Representation By Counsel: Neither party has retained an attorney in negotiating
this settlement. Both parties have jointly retained Monica J. Asplund to assist them in prepari
this Stipulated Judgment and accompatiying pleadings. The parties acknowledge that Monica
Asplund is not representing either party and has not given any apinions or legal advice regarding
the parties’ agreement, Both parties understand that they have the right, and are encouraged, to
take this agreement to an attomey of their choice to discuss any questions that they may have or
to explain its terms and consequences, Each party further acknowledges that he and she has
entered into this Agreement and signed it voluntarily, and that she waives any right to rescind br
set asidethe Agreement, except upon a finding that there has beeri an actual misrepresentation,
knowingly made with intent to defraud.

“CASSIE WILL-DARNALL
Petitioner

Date; 4fsliq | apes

SHERT DARNALL

Respondent SEE ATTACHED
: FROM NOTARY

Indgment for Dissohition of Marriage «6

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