In re the Marriage of Renata Sitko and Harlan Aldergrove

CASE-FILE DOCUMENT · PETITION DISSOLUTION

Exhibit m09.exh.001 — Petition for Dissolution of Marriage

``` STATE OF MERIDIAN DISTRICT COURT — FAMILY DIVISION COUNTY OF HALDEN FIRST JUDICIAL DISTRICT

In re the Marriage of:

Renata Sitko, Petitioner, and Court File No. 27-FA-26-1841

Harlan Aldergrove, Respondent.

PETITION FOR DISSOLUTION OF MARRIAGE (WITH MINOR CHILDREN) ```

Petitioner Renata Sitko, for her Petition for Dissolution of Marriage, states and alleges as follows:

1. Residence. Petitioner has resided in Halden County, State of Meridian, for more than 180 days immediately preceding the filing of this Petition.

1. Marriage. Petitioner and Respondent were married on June 11, 2011, in Norsholm, Halden County, Meridian.

1. Children. Two minor children were born of the marriage: Theodore Aldergrove, born March 2, 2014; and Juniper Aldergrove, born September 19, 2017. Petitioner is not now pregnant.

1. Grounds. There has been an irretrievable breakdown of the marriage relationship. The parties separated on or about November 15, 2025, when Respondent moved from the marital home to a separate residence.

1. Legal and Physical Custody. Petitioner requests that the parties be awarded joint legal custody of the minor children and that Petitioner be awarded sole physical custody, subject to a schedule of parenting time for Respondent that serves the children's best interests and accommodates the parties' work schedules.

1. Child Support. Petitioner requests that child support be set in accordance with the parties' respective incomes and the parenting-time schedule ultimately ordered.

1. Marital Home. The parties own real property at 214 Birchmere Lane, Norsholm, Halden County. Petitioner requests that she be awarded the marital home, subject to the mortgage, so that the children may remain in their current school, with an equitable offset to Respondent for his share of the equity.

1. Business Interest. Respondent owns and operates Aldergrove Remodeling & Restoration LLC, a marital asset. Petitioner requests that the business, including its vehicles, equipment, and goodwill, be valued and equitably divided.

1. Other Property and Debts. Petitioner requests an equitable division of the parties' remaining real and personal property, accounts, and debts.

1. Spousal Maintenance. Petitioner requests that the Court determine spousal maintenance, if any, based on the parties' respective incomes, needs, and contributions to the marriage.

1. Attorney's Fees. Petitioner requests such contribution to attorney's fees and costs as the Court deems equitable.

WHEREFORE, Petitioner requests a decree dissolving the marriage and granting the relief set forth above, together with such other relief as the Court deems just and equitable.

``` Dated: March 4, 2026 ELLINGBOE & RAVNDAL LLP

/s/ Amara Ellingboe Amara Ellingboe (MER-204118) Attorney for Petitioner Norsholm, Meridian ```

Verification and Confidential Information Form filed under separate cover.

CASE-FILE DOCUMENT · MARITAL HOME RECORDS

Exhibit m09.exh.002 — Marital Home Records (Appraisal & Mortgage Statement)

Property: 214 Birchmere Lane, Norsholm, Halden County, Meridian Owners of record: Renata Sitko and Harlan Aldergrove, as joint tenants Acquired: 2014

A. Residential Appraisal Summary

Prepared by an independent licensed appraiser at the parties' joint request; full report available on file.

• Effective date of value: April 3, 2026
• Property type: Two-story single-family residence, four bedrooms, two-and-a-half baths, attached garage; approximately 2,180 finished square feet plus a finished basement.
• Opinion of market value: $385,000
• Notable value contributors: Fully remodeled kitchen (updated within the last six years), finished basement with egress, newer fiber-cement siding, and a fenced yard. The appraiser noted the interior finish quality as "above typical for the neighborhood."
• Appraiser comment: Improvements appear to be recent and of good workmanship; the appraisal reflects market value as improved and does not separately quantify the source of the labor.

B. Mortgage Statement (Excerpt)

C. Equity Snapshot

Notes for the file:

• Petitioner seeks to be awarded the home subject to the mortgage, with an equitable offset to Respondent for his share of the equity, so the children can remain at Verdant Shore Elementary.
• Respondent contends that his personal labor on the kitchen, basement, and siding added value beyond what a market appraisal captures and should be credited to him in the division.
• A refinance pre-qualification for Petitioner (to remove Respondent from the loan) is pending and will be added to the file when received.

CASE-FILE DOCUMENT · BUSINESS FINANCIAL SUMMARY

Exhibit m09.exh.003 — Aldergrove Remodeling & Restoration LLC Financial Summary

Entity: Aldergrove Remodeling & Restoration LLC (single-member LLC) Owner: Harlan Aldergrove Formed: 2016 Prepared from: Company books and joint tax returns (2023–2025), compiled by Warren Kilbane, accountant

This summary is a factual compilation for the parties' use. It is not a formal business appraisal; the parties dispute the appropriate valuation method.

A. Net Earnings to Owner (last three years)

Income is markedly seasonal: the spring-through-fall months carry the year; winter is thin.

B. Business-Titled Assets

C. Intangibles (disputed)

• Established local business name and website.
• A backlog of jobs booked months ahead (Respondent has not produced the full schedule).
• Repeat-customer relationships and referral pipeline.

D. Competing Positions

• Petitioner's position: The business is a marital asset. When the truck, trailer, tool inventory, account balance, and goodwill are counted, its fair value is materially higher than Respondent concedes.
• Respondent's position: The business is inseparable from his personal labor. Absent him, it is "a used truck and a pile of tools." He resists any goodwill figure and characterizes the enterprise as worth little as a going concern without him.

E. Open Question Flagged for the File

The accountant has stated he cannot confirm that all cash receipts historically passed through the business account, nor that they did not, and that resolving that question would require a separate forensic engagement that has not been undertaken.

CASE-FILE DOCUMENT · PARENTING JOURNAL

Exhibit m09.exh.004 — Renata Sitko's Parenting-Time Journal (Excerpts)

A running log Renata kept after the separation, at the firm's suggestion, to document the informal parenting schedule and hand-off issues. Excerpts below; full log on file. Entries are Renata's contemporaneous notes.

Sun, Jan 4, 2026 — My weekend. Took Theo to hockey at 7:30 a.m., Junie to swim make-up at 11. Harlan texted at 9 asking to "swap" so he could take Theo to a tournament next weekend. Said fine. Trying to be flexible.

Wed, Jan 14, 2026 — Pickup mix-up at Lakeside. I thought it was his day, he thought it was mine. Ms. Yamada called me at work. I left the floor covered and got there at 5:50. Junie was crying. We need this in writing.

Fri, Jan 23, 2026 — On call this weekend. Harlan has the kids. He's good with them — Theo said they made pancakes. I don't dispute he's a loving dad. I dispute that "equal time" works with my rotating shifts.

Tue, Feb 10, 2026 — Junie's teacher emailed: Junie asked her twice today "is it mom's night or dad's night." She's anxious about the schedule. This is what the uncertainty does to her.

Sat, Mar 7, 2026 — Handed the kids off in the Verdant Shore parking lot per usual. Harlan brought up the maintenance thing again in front of Theo. Asked him not to talk about money in front of them. He walked off.

Thu, Apr 2, 2026 — Parent-teacher conferences. I scheduled them, I went to both. Harlan came to Theo's. Civil. Theo's grades slipping a little — his teacher thinks it's the home stress.

Mon, Apr 20, 2026 — Went to the pediatrician for Junie's checkup — I made the appointment, I took her. Updated her forms. These are the things that have always been mine to carry.

Wed, May 13, 2026 — Mediation is next week. I want to settle the property if we can just fix the schedule. I keep telling myself: the kids need us to stop keeping score. I'm trying.

Note: The after-school program's sign-in/sign-out logs (kept by Colette Yamada) corroborate the January 14 pickup issue and the general pickup pattern.

CASE-FILE DOCUMENT · TEXT MESSAGES

Exhibit m09.exh.005 — Co-Parenting Text-Message Thread (Excerpts)

Excerpts from text messages between Renata Sitko (RS) and Harlan Aldergrove (HA), produced from Renata's phone. Timestamps as shown on the device. Reproduced for the file; the full export is available.

Jan 14, 2026

• 5:41 p.m. RS: Lakeside just called me — I thought you had them today??
• 5:42 p.m. HA: No that's your Wednesday. I've got a job in Brightwater till 6.
• 5:43 p.m. RS: We literally agreed odd weeks you have Weds. I'm leaving work now. Junie's upset.
• 5:44 p.m. HA: We never agreed that. This is why we need it written down.
• 5:58 p.m. RS: Got her. We have to put this on paper. I can't keep leaving the floor.

Feb 2, 2026

• 8:12 p.m. HA: I want real 50/50. I'm not being the every-other-weekend guy. I'm their dad every day.
• 8:20 p.m. RS: I'm not trying to cut you out. My shifts rotate. Week on/week off doesn't fit call weekends.
• 8:22 p.m. HA: So we figure it out. But it starts from equal, not from you getting them and me getting scraps.

Mar 7, 2026

• 10:03 a.m. HA: And I'm going to ask for maintenance. You make way more than me and it's steady. That's fair after everything I put into this family.
• 10:05 a.m. RS: Please don't do this in front of Theo like you did at drop-off. Money talk is not for the kids.
• 10:06 a.m. HA: Fine. But I'm not backing off it.

Apr 22, 2026

• 6:30 p.m. RS: Theo has a dentist appt Thursday 3:30. I made it, I'll take him. Just letting you know.
• 6:41 p.m. HA: Ok. Thanks for telling me. I do want to be kept in the loop on that stuff.
• 6:42 p.m. RS: I always keep you in the loop. That's kind of the point.

May 20, 2026

• 9:15 p.m. HA: For what it's worth, I don't want a trial either. Kids don't need that. If we can fix the schedule I'll work with you on the house.
• 9:22 p.m. RS: Agreed. Let's actually try at mediation. For them.

Note: The February 2025 argument referenced elsewhere in the file predates this text thread and is not contained in these messages.

CASE-FILE DOCUMENT · INCOME BENEFITS SUMMARY

Exhibit m09.exh.006 — Income & Benefits Summary (Both Parties)

A factual side-by-side compiled from pay records, tax returns, and the parties' financial affidavits. Supporting documents (pay stubs, W-2s, returns) are on file.

Petitioner — Renata Sitko

Respondent — Harlan Aldergrove

Comparative Snapshot

Points flagged for the file:

• Renata's higher, steadier income is the basis for Respondent's spousal-maintenance request.
• Respondent's greater weekday availability in the off-season is the basis for his equal-parenting-time request.
• Childcare cost, benefit coverage, and the parenting schedule are interdependent and will drive both child support and any maintenance determination.

CASE-FILE DOCUMENT · PHOTOGRAPHS EXHIBIT

Exhibit m09.exh.007 — Photographs of the Marital Home (Described)

Photographs produced in discovery, described here for the packet. The image files are held in the matter file. Descriptions are neutral records of what each photograph depicts.

Photo 1 — Front elevation (dated Apr. 2026). The two-story marital home at 214 Birchmere Lane from the street. Newer fiber-cement siding in a slate-gray tone, attached two-car garage, fenced front yard. A youth hockey net is visible in the driveway.

Photo 2 — Remodeled kitchen (dated Apr. 2026). Interior kitchen with updated cabinetry, quartz-style countertops, tile backsplash, and an island. Respondent identifies this as work he performed himself. Finish quality is consistent with the appraiser's "above typical" notation.

Photo 3 — Finished basement (dated Apr. 2026). A carpeted lower level with an egress window, drywalled and painted, used as a family/play room. Children's toys and a small bookshelf are visible.

Photo 4 — Hallway wall (two photos, dated Apr. 2026). Two photographs of the upstairs hallway wall. In the first, the wall appears uniformly painted. In the second, taken in raking light, a rectangular patched area is faintly visible where drywall was repaired and repainted. Petitioner identifies this as the location of the February 2025 incident in which Respondent punched the wall; Respondent acknowledges patching the wall.

Photo 5 — Children's rooms (two photos, dated Apr. 2026). Theo's and Junie's bedrooms in the marital home, each personalized (hockey posters in one; art supplies and stuffed animals in the other). Offered to show the children's established setting in the home.

Photo 6 — Respondent's apartment (dated May 2026). The children's shared bedroom at Respondent's two-bedroom rental apartment, with two beds and their belongings, offered by Respondent to show the children have an established space at his residence as well.

Note: No photograph depicts any person. The photographs are offered on the questions of the home's value and the children's living arrangements, not to prove any disputed event by itself.

CASE FILE · WITNESS STATEMENT FERREIRA

Witness Statement — Marisol Ferreira

Witness ID: m09.wit.ferreira Relationship: Younger sister of Renata Sitko; sister-in-law of Harlan Aldergrove Taken: May 6, 2026, at the offices of Ellingboe & Ravndal LLP, Norsholm

My name is Marisol Ferreira. I'm thirty-seven and I work as a dental hygienist here in Norsholm. Renata is my older sister. I live about fifteen minutes from her house and I've been in and out of that family's life for years — babysitting the kids, holidays, birthdays, the whole thing. I love those kids like my own.

If you ask me who runs the day-to-day for Theo and Junie, it's Renata, and it always has been. She's the one who books the dentist and the pediatrician, who signs the school forms, who has dinner on the table on a weeknight after a twelve-hour shift. I've watched her do it for years. Harlan works hard too, don't get me wrong, but the household calendar has always lived in Renata's head.

That said, I'm not going to sit here and tell you Harlan is a bad father, because he isn't. Those kids adore him. Theo especially — the boy lights up the second his dad walks in. Harlan coaches Theo's hockey, he's at the games, he does the goofy weekend stuff. When people say he's just a paycheck, that's not the man I know.

I do know he's got a temper when money's tight. I've seen him get short and loud. Renata told me about the night last winter when they were fighting about the business being slow and he punched a hole in the hallway wall and stood in the doorway for a second so she couldn't get past. I saw the patch later — he'd spackled it and painted over it, but you could still see where it was if you knew to look. Renata was shaken when she told me. But I want to be fair: she also told me, clearly, that he never put a hand on her. He scared her, but he didn't hit her.

The kids were home that night, upstairs. I don't think they saw it, but Renata said they heard the yelling. Junie was clingy for a while after, is what I remember.

Since Harlan moved out in the fall, the hand-offs have gotten tense. I've been in the middle of a couple of pickup mix-ups where each of them thought it was the other's day. It's not good for the kids. Both of them love those children, and both of them are so scared of losing time that they've started keeping score.

I don't know anything about the money side — what the house is worth, what his business is worth. I stay out of that. You'd have to ask somebody who's actually seen their books. I just know Renata's the steady one and Harlan's the fun one, and the kids need both of them to stop fighting.

I signed this because it's true and I'd say the same thing to either of their lawyers.

— Marisol Ferreira

CASE FILE · WITNESS STATEMENT KILBANE

Witness Statement — Warren Kilbane

Witness ID: m09.wit.kilbane Relationship: Accountant/bookkeeper for Aldergrove Remodeling & Restoration LLC and preparer of the parties' joint tax returns Taken: May 19, 2026, by telephone, memorialized at Ellingboe & Ravndal LLP

I'm Warren Kilbane. I run a small accounting practice in Norsholm and I've done the books for Aldergrove Remodeling & Restoration since about 2018, along with Harlan and Renata's joint tax returns for those same years. I'm speaking generally here; the actual returns and the QuickBooks file will show the specifics.

The business is a single-member LLC. It's essentially Harlan and his tools. In a typical year the company grosses somewhere in the low-to-mid six figures on jobs, but after materials, subcontractors, the truck, insurance, fuel, and the rest, the net that flows to Harlan lands in the range of roughly fifty-eight to seventy-two thousand over the last three years. It's a seasonal business — the spring-through-fall months carry the year, and winter is thin.

On the asset side, the company owns a 2019 work truck, an enclosed job trailer, and a substantial amount of tools and equipment. Those are real, titled or inventoried assets with real resale value. There's also the intangible side — the business name is known locally, there's a website, and Harlan generally has jobs booked out ahead. Whether and how you put a dollar figure on that goodwill is exactly the kind of thing the two sides are going to argue about, and honestly it's above my pay grade to opine on a valuation for a court. I keep the books; I don't do business appraisals.

I'll say this carefully because I know it matters. Not every dollar in a business like this necessarily runs through the business checking account. In the construction trades, cash payments happen. I record what I'm given and what shows up in the account. I'm not in a position to tell you that everything Harlan ever collected passed through the books, and I'm not in a position to tell you it didn't. If someone wants that question answered, that's a forensic engagement, and it isn't one I've been asked to do.

Renata was never very involved in the business's day-to-day finances that I saw. She'd sign the joint return each year, but Harlan was the one who dealt with me on the company side.

That's the honest picture as I know it from the books in front of me.

— Warren Kilbane

CASE FILE · WITNESS STATEMENT YAMADA

Witness Statement — Colette Yamada

Witness ID: m09.wit.yamada Relationship: Director of the Lakeside After-School Program attended by Theo and Junie Aldergrove Taken: May 12, 2026, at the Lakeside After-School Program, Norsholm

My name is Colette Yamada. I've directed the Lakeside After-School Program for six years. Both Aldergrove children — Theo and Junie — have been enrolled with us since they started at Verdant Shore Elementary. I see them almost every school day until a parent picks them up, so I know their routines and their moods pretty well.

They're good kids. Theo is responsible for an eleven-year-old — he keeps an eye on his little sister here. Junie is more sensitive; she needs a predictable routine and she notices when things at home are unsettled.

On pickups: for most of the time I've known the family, Renata was the parent I dealt with. She's the one who filled out the enrollment forms, updated the emergency contacts, and usually did the pickup, though her work schedule clearly moved around — some days it was earlier, some days right at our six o'clock close, and once in a while she'd call ahead flustered because a shift ran long. Harlan picked up too, more so in the last year, and he's friendly and easy with the staff. Since around last fall, the pickups have been split more evenly between the two of them, and I've been given a written schedule of who has the kids which days — which, frankly, has helped, because before that there were a couple of afternoons where neither parent came at the expected time and we had to make calls.

I want to be fair to both of them. Neither has ever been what I'd call neglectful with us. The kids are always fed, clothed, have their backpacks. When there's been a late pickup it's been the exception, and a parent always answered the phone.

The one thing I'd flag, because you asked, is that Junie has seemed more anxious this school year — a few tearful afternoons, asking whether it was "mom's night or dad's night." That's not unusual for a child whose parents have separated, in my experience, but it's real and I've noticed it.

I keep our sign-in and sign-out logs, and those would show the actual pickup times and which parent, if the court needs them.

That's what I know from my end.

— Colette Yamada, Director, Lakeside After-School Program

CASE-FILE DOCUMENT · GAL PRELIMINARY REPORT

Case-File Document — Guardian ad Litem Preliminary Report

Guardian ad Litem: Nadia Bempah (witness ID m09.wit.bempah) Appointed by: Family Division of the Meridian District Court, Halden County Date of preliminary report: June 8, 2026 Children: Theodore Aldergrove (11) and Juniper Aldergrove (8)

This is a preliminary report reflecting initial observations. A full best-interests evaluation is ongoing. Nothing here is a recommendation of ultimate custody.

I was appointed to represent the best interests of the two minor children. To date I have met with each child individually twice, observed each parent with the children once in their respective homes, and interviewed both parents, the maternal aunt, and the after-school program director.

Initial impressions.

Both children are healthy, articulate, and clearly attached to both parents. Neither expressed fear of either parent. Theo, the older child, is protective of his sister and aware of the conflict; he told me he "just wants them to stop being mad." Junie is more anxious and has repeatedly asked adults to clarify whose "night" it is; her after-school director and her mother's journal both note this anxiety, which I observed as well.

Parenting roles. The record and my observations are consistent: the mother has historically carried the logistical parenting load (appointments, school, meals), while the father is highly engaged in activities and shares a strong bond with both children, particularly through Theo's hockey, which he assistant-coaches. Both homes are safe and appropriate. Each parent has provided the children an established bedroom.

The February 2025 incident. Both parents independently described an argument in early 2025 in which the father, during a dispute about finances, punched a hole in a wall and briefly blocked the mother in a doorway. Both agree no one was struck and no law-enforcement contact occurred. The father expressed genuine remorse and characterized it as isolated; the mother corroborated that he has not been physically aggressive toward her before or since. I flag it because a single incident of this kind is relevant to the parenting analysis and warrants continued attention, not because the present record establishes a pattern.

Schedule. The central obstacle to settlement is the parenting schedule. The mother's rotating hospital shifts and one-in-three on-call weekends complicate a strict week-on/week-off arrangement, which the father seeks. The children would benefit from a predictable, written schedule regardless of the ultimate custody label; the current informal arrangement has produced avoidable hand-off conflicts that upset the children.

Next steps. I will complete home studies, obtain the after-school sign-in logs and school records, and speak with the children's teachers before issuing recommendations.

Respectfully submitted, Nadia Bempah, Guardian ad Litem

BUSINESS EXHIBIT · ENGAGEMENT LETTER

Engagement Letter

ELLINGBOE & RAVNDAL LLP Attorneys at Law · Norsholm, Meridian

February 18, 2026

Renata Sitko 214 Birchmere Lane Norsholm, Meridian

Re: Legal Representation — Dissolution of Marriage (Sitko / Aldergrove)

Dear Ms. Sitko:

Thank you for retaining Ellingboe & Ravndal LLP. This letter sets out the terms of our engagement.

Scope of Representation. We will represent you as Petitioner in the dissolution of your marriage to Harlan Aldergrove, including matters of legal and physical custody and parenting time for your two children, child support, division of the marital home and of Mr. Aldergrove's business, allocation of other property and debts, and any claim for spousal maintenance. This engagement does not include any appeal, enforcement, or post-decree modification, which would require a separate agreement.

Your Attorneys. Amara Ellingboe (senior attorney, $250/hour) will be primarily responsible for your matter, assisted by Marcus Ravndal (associate attorney, $225/hour). Paralegal time, when used, is billed at $120/hour. We staff each task at the most efficient appropriate level.

Retainer. You have deposited an advance fee retainer of $8,500, which we will hold in our client trust account. We will bill against the retainer as fees and costs are incurred and will provide you with itemized statements. This is an evergreen retainer: when the trust balance is drawn down by a billing, you agree to replenish it so that the balance is restored to $8,500 while the matter is active. Any unearned balance remaining at the conclusion of the representation will be refunded to you.

Billing. We bill in one-tenth-of-an-hour increments. Statements are issued periodically and are payable from the trust account; we will apply trust funds to a statement only after it is issued to you. Costs such as filing fees, service fees, and any appraiser or evaluator charges are billed as incurred.

Confidentiality. Everything you tell us in the course of this representation is protected by the attorney-client privilege and our duty of confidentiality. Please be candid with us, including about facts you find difficult; we can only protect your interests if we know the full picture.

Cooperation and Communication. You agree to provide requested documents promptly, to keep us informed, and to make the final decisions on the objectives of the representation after our advice. We agree to keep you reasonably informed and to explain matters so you can make informed decisions.

If these terms are acceptable, please sign below and return one copy.

Sincerely,

/s/ Amara Ellingboe Amara Ellingboe, for Ellingboe & Ravndal LLP

Agreed and accepted:

______________________________ Date: ____________ Renata Sitko

BUSINESS EXHIBIT · INTAKE & CONFLICTS

Intake (2026-02-12). Petitioner in a marriage dissolution with two minor children; disputes over custody and parenting schedule, the marital home, valuation and division of the respondent's remodeling business, and the respondent's spousal-maintenance claim.

Conflicts check (2026-02-13) — CLEAR. No prior or current representation of Harlan Aldergrove, his business, or any adverse party. Firm has not represented the marital business. No personal relationships identified between the firm's attorneys and the parties or witnesses.

BUSINESS EXHIBIT · BILLING STATEMENT (16 TIME ENTRIES)

BUSINESS EXHIBIT · INVOICES

BUSINESS EXHIBIT · CLIENT TRUST LEDGER

Client money is not firm money: every deposit and disbursement must reconcile to the penny.