FORMER WIFE’S VERIFIED MOTION FOR TEMPORARY ATTORNEY’S FEES, SUIT MONIES AND COSTS PENDENTE LITE
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
In Re: The Former Marriage of Case Number:
JAMIE CROWN,
Petitioner/Former Wife,
and
JACK KING,
Respondent/Former Husband.
_____________________________________/
FORMER WIFE’S VERIFIED MOTION FOR TEMPORARY ATTORNEY’S FEES, SUIT MONIES AND COSTS PENDENTE LITE
The Former Wife, JAMIE CROWN, by and through her undersigned counsel, hereby moves this Honorable Court for the entry of an Order awarding her temporary attorney’s fees, suit monies and costs, and as grounds therefore states the following:
- There is currently pending a Petition for Modification of Shared Parental Responsibility to Sole Parental Responsibility and Petition for Modification of Child Support and Enforcement of Child Support currently before the Court.
- The Former Wife urgently in need of an immediate award of temporary attorney’s fees, suit monies and costs which the Former Husband has the manifest ability to pay for, minimally for the following reasons:
- There is a substantial disparity in income. The Former Husband is a Manager for Dade County Parks and Recreation and the Former Wife is employed as an Office Manager. The Father should be ordered to pay 100% of the Wife’s attorney fees and costs pursuant to Florida Statutes 61.16.
- Florida law mandates that this Court should take all reasonable and necessary steps to insure that the Mother is able to retain the counsel of her choice and not be precluded from doing so because of financial inability when the Former Husband has the ability to be able to pay for the Former Wife’s counsel. Wherever and whenever necessary, as is the case here, the Court must “level the playing field” so that the Mother is not disadvantaged, or in other words, the Former Husband is not able to take unfair advantage in the litigation because of his unlimited financial resources. Nichols v. Nichols, 519 So. 2d 620 (Fla. 1988); Robbie v. Robbie, 591 So. 2d 1006 (Fla. 4DCA 1991).
- With regard to additional or future professional services that the undersigned reasonably anticipates will be needed in this action, the undersigned attaches hereto and incorporates by reference her affidavit setting forth a schedule of contemplated professional activity and expenses most likely to be incurred.
WHEREFORE, the Former Wife prays this Court will enter an Order immediately awarding temporary attorney’s fees, suit monies and costs as requested herein and otherwise, and for all other relief as may be deemed just and proper.
___________________________
JAMIE CROWN
STATE OF FLORIDA )
) SS
COUNTY OF BROWARD )
BEFORE ME. the undersigned authority, personally appeared JAMIE CROWN, known to me or who produced ___________________________ as identification, under penalties of perjury and having been sworn under oath, verifies that the above contents and information is true and correct to the best of her personal knowledge and that she executed this document this ___ day of __________, 20__.
IN WITNESS WHEREOF I have hereunto set my official hand and seal.
____________________________
NOTARY PUBLIC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been provided to Jack King, Former Husband, by personal service.
LAW OFFICES OF LARRY D. SCHOTT
Attorneys for Former Wife
By:___________________________
LARRY D. SCHOTT
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