HUSBAND’S PETITION FOR DISSOLUTION OF MARRIAGE GENERAL ALLEGATIONS
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
In Re: The Marriage of Case Number:
HUSBAND’S PETITION FOR DISSOLUTION OF MARRIAGE GENERAL ALLEGATIONS
- Action for Dissolution of Marriage. This is a Petition for Dissolution of Marriage between the Petitioner/Husband, JACK KING, (hereinafter referred to as the “Husband”), and the Respondent/Wife, JAMIE CROWN, (hereinafter referred to as the “Wife”).
- Residency and Jurisdiction as to Husband. Both parties have been residents of Miami-Dade County, Florida for more than six months next before filing this petition.
- Marriage of the Parties. The parties were married to each other in XXXXXX 20__ in Miami-Dade County, Florida. The parties separated in XXXXXX 20__.
- Irretrievably Broken. The marriage between the parties is irretrievably broken.
- Non-Military Affidavit. Neither party is in the military service of the United States or any of its allies.
- Minor Children. There was one (1) child born of the marriage to wit:
JSK, born on xx/xx/20__
- Husband’s Employment – The Husband is employed at Warren Henry
Auto Group as a salesman.
- Wife’s Employment – The Wife is employed at Pro Cargo Express, Inc.
- Shared Parental Responsibility/Parenting Plan.
It would be in the best interest of the minor children for the parties to have shared parental responsibility of the minor child. The Husband should be permitted to have reasonable timesharing, including holidays and the Court should approve a parenting plan pursuant to Florida Statutes.
10. Parenting Plan: The Court should establish a parenting plan considering the following statutory factors:
- The demonstrated capacity and disposition of each parent to facilitate and encourage a close and continuing parent child relationship.
- The anticipated division of parental responsibility after the litigation.
- Demonstrated capacity and disposition of each parent to consider and act upon the needs of the child as opposed to the needs and desires of that parent.
- The length of time the child has lived in a stable and satisfactory environment.
- Geographic viability of the plan.
- The moral fitness of the parents.
- The mental and physical health of the parents.
- The home, school, and community records of the child.
- The reasonable preference of the child.
- The demonstrated knowledge, capacity, and disposition of each parent to be informed about the child.
- The demonstrated capacity and disposition of each parent to provide consistent routine for the child.
- The demonstrated capacity of each parent to communicate with and keep the other parent informed regarding issues and activities, regarding the minor child and the willingness of each parent to adopt a unified front as to all major issues when dealing with the child.
- Domestic violence and other abuse and knowledge about false information to the court regarding domestic violence and other abuse.
- The parent who has provided false information to the court.
- The parenting tasks historically performed by each parent and the division of parental responsibilities.
- The demonstrated capacity and disposition of each parent to participate and be involved in the children’s school and extra curricular activities.
- Substance abuse of the parties.
- The capacity and disposition of each parent to protect the child from the ongoing litigation as demonstrated by not discussing the litigation with the child, not sharing documents, electronic media, etc.
- The developmental stages and needs of the child and demonstrated capacity and disposition of each party to meet the child’s development needs.
- Any other factor that is relevant.
11. Timesharing. The Wife should be awarded the majority of the timesharing subject to the Husband’s reasonable and liberal timesharing.
- Child Support. Both parties should contribute to the child support pursuant to the child support guidelines including health insurance, aftercare, and extra curricular activities.
13 Health Insurance. Both parties should contribute to the minor children’s health insurance costs, including uncovered medical expenses, dental expenses and orthodontist expenses.
- Alimony. Neither party should receive alimony from the other.
- Equitable Distribution. The Husband is entitled to fifty percent (50%) of the assets acquired and/or enhanced in value during the marriage, including, but not limited to the following:
Motor vehicles, bank accounts, IRA’s, pensions, other retirement plans, other financial accounts, life insurance policies, personal property and other assets.
- Financial or Retirement Accounts. The Husband is unaware of any substantial marital financial or retirement accounts but seeks equitable distribution thereof.
- Debts. The parties have incurred credit card debt and other debt that should be equitable distributed.
- Attorney’s Fees and Costs. The Husband has retained the undersigned law firm to represent him in this action. The Wife has a responsibility to keep the fees and costs down and act reasonably in these proceedings. Both parties should be responsible for their own attorneys fees and costs.
- Dissolution of Marriage. The Husband states that the parties marriage is irretrievably broken and seeks a dissolution of same.
WHEREFORE, the Petitioner/Husband, JACK KING, prays this Honorable Court will:
- Assume jurisdiction of the parties hereto and the subject matter hereof.
- Upon final hearing in this cause, dissolve the parties’ marriage a vinculo matrimonii.
- Equitably divide all marital financial accounts awarding the parties 50/50.
- Equitably divide all marital retirement accounts.
- Equitably divide the parties’ personal property.
F Award shared parental responsibility with the Wife having the majority of the timesharing and the Husband having reasonable and liberal timesharing..
G Enter a parenting plan that establishes the status quo and that considers the best interests of the children.
H Award child support pursuant to child support guidelines.
- Order the parties to equally be responsible for the parties debts.
- Grant such other and further relief this Honorable Court deems just and proper.
K Reserve jurisdiction over the parties for purposes of enforcement hereof.
The Petitioner/Husband, JACK KING, verifies that all of the foregoing information is true and correct to the best of his personal knowledge.
STATE OF FLORIDA )
COUNTY OF BROWARD )
BEFORE ME, the undersigned authority, duly authorized in the State and County aforesaid to take acknowledgments, personally appeared, JACK KING, who produced _____________________ as identification, after first being duly sworn upon oath, deposes and says that she has read the allegations contained herein, that the information contained herein is true and correct, and that he executed this document.
WITNESS my hand and seal in the County and State aforesaid this ___ day of _________________, 20__.
Notary Public, State of Florida
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to: JAMIE CROWN, Wife, by personal service.
LAW OFFICES OF LARRY D. SCHOTT
Attorney for Husband
LARRY D. SCHOTT
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