Judge Taki Flevaris - Superior Court

General Information

Unified Family Court

Judge Flevaris is currently assigned to Unified Family Court, presiding over family law cases involving children. This includes dissolutions of marriage, petitions for parenting plans and child support, and modifications of existing family law orders, among other family law matters.

Department Schedule

In Department 38, Trials are conducted Monday through Wednesday and Thursday mornings; Pretrial Conferences are held Thursday afternoons; and Motions Hearings are generally held on Fridays.

The normal trial day in Department 38 runs from 9:00 am to 4:00 pm, with a mid-morning recess (15 minutes), a midday recess (90 minutes), and a mid-afternoon recess (15 minutes).

Personal Pronouns

Consistent with General Rule 43, any and all participants in court proceedings before Department 38 are encouraged to inform the Bailiff of their personal pronouns, to indicate the same within any written submissions, and for virtual proceedings to indicate the same within their Zoom name (as Judge Flevaris does). The Court wishes to respect the identity and dignity of all who come before the Court, including how they are addressed and recognized.

Virtual Proceedings

Per local rules and standing orders, all proceedings in Unified Family Court are presumptively virtual, held via the Zoom platform. Before entering, each Participant should set their name within Zoom according to the following conventions:

• PET: First and Last Name (she/her)
• P/C: First Last (they/their)
• RSP: First Last (etc.)
• R/C: First Last
• WTN: First Last
• Observer: First Last

Each participant should confirm in advance sufficient hardware and internet connection to appear remotely, including speed of at least 2 Mbps for download and 2 Mbps for upload (which may be confirmed using speed test sites such as “www.speedtest.net” or by typing “speed test” into your internet search engine). Participants must be in a distraction-free setting. Appearing while driving is NOT allowed.

Communicating with the Court

Parties must comply with the Court's email policy when contacting the Court. Per the policy, the only address to be used by attorneys, unrepresented litigants, or others who need to communicate with the Bailiff about a case is the courtroom email address. All other parties to the case must be copied on such communications. The Judge’s individual address is not to be used absent express invitation. Phone should not be used unless there is no other available means of communication, and in that instance, the case number should be clearly identified at the outset of any call or voicemail.

Key Information for Unrepresented Parties

Unrepresented litigants should consider seeking assistance by setting up an appointment with the Family Law Facilitators. For useful information, unrepresented parties may also review the Family Law Instructions or the reference website WashingtonLawHelp.org.

All Parties are expected to follow the King County Local Family Law Rules and the Case Schedule for their case, which may include deadlines for attending the Court’s Parenting Seminar (for cases involving child custody) and Family Law Orientation (for unrepresented litigants), both of which may be completed virtually.

Parties must diligently litigate their case. This includes filing necessary pleadings using applicable Court Forms (see “Family Law” section for key case types). Any special relief from the Court—whether in discovery, for the appointment of a guardian ad litem, or otherwise—should be sought timely via written motion with supporting materials.

Written Submissions

Basic Standards

All written submissions to this Department are expected to conform to the following basic standards. Adherence to these standards—separate from applicable state and local court rules—will not be required for any submission assigned to this Department after filing.

References to parties or others: To promote clarity and ease of comprehension in briefing, declarations, and other written submissions, Parties and other persons should be regularly referred to by individualized name or other unique identifier rather than only generic role (e.g., “Petitioner Smith” rather than just “Petitioner”). Reference by first name may be necessary where the Parties share last name; this will not be taken as a sign of disrespect and no disclaimer to that effect is needed. Any person’s disclosed or otherwise known personal pronouns should be respected.

Citations: The use of clear, specific citations is of utmost importance in written submissions to the Court. Parties cannot and should not rely on the Court to pore over the record to confirm their assertions. Instead, any disputed, material assertions should be supported with a particularized citation to supporting materials. This should include a specific page number, section, or paragraph for each citation. References to prior filings should be supported with particularized citation to the docket (referenced as “Dkt.,” “Sub No.,” or equivalent) that indicates the specific docket number and specific page (e.g., “Dkt. 1 at 22”). Any disputed or distinctive legal propositions should be supported with citation to legal authority, including a pincite (page number), and when not already apparent, a parenthetical briefly describing the holding or significance of the cited authority. Legal citations need not include parallel citation to regional reporters or the like; citation to the Washington reporter or the U.S. reporter is sufficient and preferred.

Supporting declarations: Factual declarations submitted in support of motions or other briefing should meet the requirements of General Rule 13 (certification), Local Civil Rule 7(b)(5)(B) (form), and Evidence Rule 701 (lay opinion). To promote clarity and compliance with attestation requirements, factual declarations should NOT be combined with legal argument. Instead, whatever a witness is attesting to must be set forth separately and distinctly. Legal argument should then cite (with particularity) to the attested facts in support.

Motions for Revision

All parties moving for revision of a Commissioner’s order will be held to the requirement under Local Rule 7(b)(8)(A) that the motion “shall only identify the error(s) claimed.”

Consistent with the above standard, and given that revision must be based only on the issues and evidence before the Commissioner, the motion should only: (1) provide the hearing information required by LCR 7(b)(8)(B)(iii); (2) identify the error(s) claimed; (3) specify where exactly in the record the issue was argued below; and (4) specify all evidence in the record relevant to the issue (whether in support or opposition). The Court will then determine whether or not to call for supplemental briefing or argument.

For the purpose of identifying the error(s) claimed, which is subject to de novo review, the moving party should present a single, separate concise statement for each error akin to an assignment of error on appeal. Each statement should be no more than a few sentences long.

Citations to the record should specify the specific docket number and page range for each portion of relevant argument or evidence (e.g., “Dkt. 12 at 15-17”), and nothing more.

The moving party is urged to use this Department’s Revision Form for the purpose of meeting the above standards. Otherwise, the Court may ask the moving party to fill out the Sheet as a supplement to their motion.

The motion should NOT present further argument or factual assertions, which generally will be disregarded. The opposing party need not submit a motion to strike such extraneous information and is urged not to do so; such a motion itself will likely be struck as moot. If an opposing party believes the moving party’s citations to the record are materially incomplete, they may file and serve a supplemental Revision Sheet with additional citations and nothing more.

The need for or usefulness of oral argument will be determined based on a review of the revision motion and cited materials. Unless this Department’s Bailiff reaches out to the Parties to schedule oral argument, it should be considered stricken. See LCR 7(b)(3)(A)(ii).

Any Party may request an exception from the above standards based on a showing of need particular to the case.

Proposed Final Orders of Zero Child Support or Equivalent

Any agreed orders noted before this Department that propose a minimal child support transfer (of zero dollars or a comparably low figure) should be supported by sworn explanatory statements contained within the Child Support Worksheet or other relevant proposed orders.

If the proposed transfer amount is based on a party having little to no income, the issue of voluntary under- or un-employment must be addressed under RCW 26.19.071. If the proposed transfer amount is based on a deviation from the standard calculation, the basis and propriety of the deviation must be addressed under RCW 26.19.075.

Absent an appropriate explanation, the Court may direct the parties to correct and resubmit their proposed orders, call for a hearing, or reject the proposed orders.

Motions for a Trial Continuance

Parties should proceed diligently in accordance with the case schedule. A continuance of the trial date generally requires showing good cause, including both diligence and need. The motion should be accompanied by a showing of what discovery and trial preparation have already been completed, what remains to be accomplished, and why the case could not have been completed within the original schedule. The mere assertion that more time is needed for discovery or negotiation, without more, will not usually constitute good cause.

Parties should also heed the deadline to move for a trial continuance as set forth in the Case Schedule. Local Civil Rule 40(e)(2) provides that motions filed after that deadline “will not be granted except under extraordinary circumstances where there is no alternative means of preventing a substantial injustice.” The motion should demonstrate this standard is met, otherwise it will likely be denied.

Even when a motion for a continuance is agreed, the parties should make a basic showing that satisfies the applicable standard.

Stipulated Motions and Orders

Stipulated motions may be noted for consideration two judicial days after filing. See LCR 7(b)(4)(H). To maintain a clear and appropriate record, the motion itself should be filed separately into the docket, and the Parties’ proposed order should be presented separately to this Department for review. The proposed orders should comply with the standards set forth above for such submissions.

Motions for Expedited Review

Motions to shorten time are strongly disfavored, and should only be used in extraordinary circumstances. If a party wishes the Court to consider a motion on shortened time, the underlying motion must be noted in the regular course, and a separate motion to shorten time should be submitted. Unless and until the Court grants the motion to shorten time, all responses and replies should be submitted as though the motion is to be considered on the presumptive, default timeline.

Requests for Attorney Fees

Any request for attorney fees must specify the legal grounds for the requested award, and usually should be accompanied by a fee declaration explaining counsel’s relevant experience and rates, with a log of time entries indicating tasks performed and time spent on each. The fee declaration should also indicate whether or not the time entries were created contemporaneously, and whether or not the entries have actually been or will be paid.

Sealing Court Filings

The use of form cover sheets to seal filings as authorized under General Rule 22 should be used only to seal filings that satisfy the particular standards set forth in the relevant cover sheet and General Rule 22, and the contents of the cover sheet should not be altered when filling out the form. Otherwise, a party must move to seal any given record pursuant to General Rule 15 and Local General Rule 15.

Motions to seal must comply with General Rule 15, Local General Rule 15, and controlling caselaw.  Agreement of the parties is not a sufficient basis for the sealing or redaction of court records. The moving party should provide a proposed order that includes the required findings.

Proposed Orders

Parties should submit proposed orders via Working Copies that make clear precisely what the Party is asking the Court to do. Whenever possible, the proposed order should be submitted in editable Word (.doc) format, with the proponent’s signature included in electronic format—whether a digitally certified signature, “s/” signature, or electronic image of the person’s signature. See General Rule 30; RCW 1.80.010(10). For joint motions, signatures from each and every proponent should be included.

Discovery

In discovery, lawyers and parties should abide by their obligations as reflected in the Civil Rules and the Rules of Professional Conduct. This generally means following a “Golden Rule” of discovery: seek only what you would consider reasonable if you were on the other side, and answer as you would expect had you promulgated the requests. Discovery should be reasonable, cooperative, and reciprocal. Zealous advocacy should make use of the fruits of discovery; it should not be employed to seek unreasonable discovery or to avoid reasonable discovery.

Early judicial involvement in discovery can often avoid disputes or expedite resolution of them. Judge Flevaris encourages the parties to request a pretrial conference under CR 16 or CR 26(f) to consider matters such as: (1) the scope and timing of discovery; (2) limitations of discovery requests and depositions; (3) procedures and protocols for electronic discovery; (4) expert witness disclosures and discovery; and (5) anything else that would promote the efficient resolution of the case.

Parties must pay careful attention to the “meet and confer” requirement of Civil Rule 26(i). The conference must consist of contemporaneous communication, whether in-person, virtual, or by telephone. Email is not a substitute for a dialogue on disputed issues. A certification by counsel that the conference requirement has been met is required, and should set out with particularity the time, nature, and extent of the conference.

If a discovery dispute remains after conferencing, the Parties are urged to consider whether a short virtual or telephonic conference with the Court could help resolve or at least narrow the remaining issues without need for a formal motion. Any Party may email this Department’s Bailiff, copying all counsel and unrepresented parties, to arrange such a conference. The email should describe the nature of the discovery dispute briefly (1-2 sentences per issue), in neutral terms, and without argument; and must confirm that the meet-and-confer requirement has already been met. The opposing party may then identify, also briefly and in neutral terms, any additional issues to be addressed. Such a conference usually will be scheduled for 10 to 20 minutes. If scheduled, the Parties should come to the conference prepared to discuss all identified issues and potential solutions.

Preparing for Trial

Pretrial Conferences

Pretrial Conferences are held approximately 4-6 weeks before Trial. Parties should proceed diligently in accordance with the Case Schedule, take whatever steps are necessary to prepare their case, and come to the Pretrial Conference ready to discuss the specifics of trial, including format (formal or informal), duration (number of days), witnesses, and exhibits. Parties should file timely motions and not wait until the Pretrial Conference to seek any relief from the Court in advance of trial.

On trial format, the Parties must agree in order to proceed with an informal trial. In a traditional trial, the Rules of Evidence are applied and the Parties question witnesses. In contrast, in an informal trial the Rules of Evidence are waived (including as to written statements from third parties), the only testifying witnesses are the Parties themselves and any experts, and the Court questions the witnesses (with input from the Parties). For more information about trial format, Parties may refer to Washington General Rule 40, Local Family Law Rule 23, and the Court’s webpage addressing Family Law Trials in King County.

Orders from Pretrial Conference

Based on the discussion and input from the Parties at the Pretrial Conference, the Court will issue an Order from Pretrial Conference setting forth a number of deadlines and steps for the Parties to take in preparation for Trial. All Parties must pay close attention to the terms of the Order, and closely follow all the directions leading up to Trial.

Motions in Limine

If the Parties are aware of any significant legal determinations that will need to be made at Trial, they should raise those issues through Motions in Limine. This should take the form of a single written submission noted for consideration on the Trial Date and timely prepared, filed, served, and answered in accordance with the requirements of Local Civil Rule 7. Issues raised in this manner usually will be addressed and resolved at the outset of Trial.

Departmental Assignment for Trial

A case assigned to this Department may be assigned to another judge at the time of trial. Such assignments generally take place on Thursday afternoon prior to trial. Parties must still comply with all court rules and the Order on Pretrial Conference regarding pretrial submissions and deadlines. All submissions will be provided to the newly assigned trial judge. This Department’s Bailiff will notify parties of trial assignment status on the Thursday afternoon before the trial date, or a party may determine which judge has been assigned by checking the Civil Standby Calendar, which will be updated on Thursday afternoon and is continuously updated (as needed) at other times.

(Last revised September 26, 2023.)