IN THE
CIRCUIT COURT OF JASPER COUNTY, MISSOURI
AT SPRINGFIELD
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In Re the Marriage of: |
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Julie Marie Taylor, |
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SSN: 487-88-8888, |
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Petitioner, |
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vs. |
) Case No. 01CV154654 |
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Brad Micheal Taylor, |
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SSN: 488-77-7777, |
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Respondent. |
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Serve at: 206 Walnut, Hollywood, California 57899
PETITION FOR DISSOLUTION OF MARRIAGE
Comes now the Petitioner, Julie Marie Taylor, and for her cause of action, states to the Court as follows:
1. Petitioner has been a resident of the State of Missouri for 14 years 2 months immediately preceding the filing of this Petition for Dissolution, and has been a resident of Greene County, Missouri, for 14 years 0 month immediately preceding the filing of this Petition for Dissolution.
2. Respondent has been a resident of the State of California for 3 years 1 month immediately preceding the filing of this Petition for Dissolution, and has been a resident of Orange County, California, for 3 years 1 month immediately preceding the filing of this Petition for Dissolution.
3. Petitioner is currently residing at 311 Carthage, Springfield, Greene County, Missouri. Petitioner is currently employed by MCI Worldcom and her Social Security Number is 487-88-8888.
4. Respondent is currently residing at 206 Walnut, Xx, Hollywood, Orange County, California. Respondent is currently employed by Hollywood Studios and his Social Security Number is 488-77-7777.
5. Petitioner states that the parties were married on July 15, 1992, in Joplin, Jasper County, Missouri, and that said marriage was registered in Carthage, Missouri.
6. Petitioner states that the parties separated on or about May 30, 2001.
7. Petitioner states that neither Petitioner nor Respondent are members of the armed forces of the United States of America on active duty and are not entitled to any benefits or immunities of the Soldiers and Sailors Relief Act.
8. Petitioner states that there is no reasonable likelihood that the marriage can be preserved and, therefore, the marriage is irretrievably broken.
9. Petitioner and Respondent have acquired certain property and certain debts during the marriage but have not yet entered into a property settlement agreement.
10. Petitioner states that there are 2 unemancipated children born of this marriage, to-wit:
Cooper Frederick Taylor, DOB: 10-11-1994, SSN: 487-11-9082
Ronnie Thomas Taylor, DOB: 10/11/1994, SSN: 487-84-7788
11. That Petitioner is not now pregnant.
12. Petitioner states that she desires her former name of Smith to be legally restored.
13. For sixty days immediately preceding the filing of the Petition for Dissolution of Marriage, the minor children of the parties resided with Petitioner at 311 Carthage, Springfield, Greene County, Missouri.
14. The Petitioner requests that the Court award the parties joint care and custody of the minor children with the children’s principle residence being with Petitioner.
15. There have been no arrangements made as to the custody and support of the parties' children.
16. The Petitioner has not participated in any capacity in any other litigation concerning the custody of the children in this or any other state; Petitioner has no information of any custody proceeding concerning the children pending in a court of this or any other state; and Petitioner knows of no person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children.
17. That Petitioner lacks sufficient property and income to provide for her reasonable needs and there have been no arrangements made as to maintenance to be paid to the Petitioner.
18. That Petitioner is without funds or assets with which to pay the costs and attorney fees herein.
WHEREFORE, Petitioner prays for a Judgment dissolving the marriage of the parties; that the Court set aside to Petitioner and Respondent their separate non-marital property; that the marital property and marital debts be divided in a fair and equitable manner; that the Court award custody of the minor children as stated above; that the Court order child support pursuant to Rule 88.01 retroactive to the date of filing; that Respondent be ordered to pay to Petitioner a reasonable sum as and for Petitioner's maintenance retroactive to the date of filing; that Respondent be ordered to pay Petitioner's reasonable attorneys fees, suit monies and the court costs of this proceeding; for an order restoring Petitioner's name to Smith; and for further and different relief as this Court deems just and proper in the premises.
Smith Price & Cline, P.C.
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Robert Smith, Esq.
Bar Number #123456
Attorney at Law
1105 E. 45th
Joplin, Missouri 64804
Telephone: 417-123-4567
Fax: 417-545-4321
ATTORNEY FOR PETITIONER
STATE OF __________
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COUNTY OF __________ )
Comes now Julie Marie Taylor, Petitioner, being first duly sworn according to law, and states that she has read the foregoing Petition For Dissolution of Marriage and states that the facts contained therein are true and correct according to her best knowledge, information and belief.
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Julie Marie Taylor
Subscribed and sworn to before me this _____ day of April, 2002.
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Notary Public
My commission expires: