WIFE’S MOTION FOR EXCLUSIVE USE AND POSSESSION OF HOME
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
In Re: The Marriage of Case Number:
JAMIE CROWN,
Petitioner/Wife,
and
JACK KING,
Respondent/Husband.
_________________________/
WIFE’S MOTION FOR EXCLUSIVE USE AND POSSESSION OF HOME
The Petitioner/Wife, JAMIE CROWN, through her undersigned attorney, files this Verified Motion for Temporary Relief Including Temporary Alimony and Exclusive Use and Possession of Home, and further states the following:
- There is presently pending a Petition for Dissolution of Marriage.
- The Wife is requesting exclusive use and possession of the marital home pending this litigation and thereafter.
- The Husband has filed and obtained a fraudulent Domestic Violence Injunction temporarily in Case Number: XXXXXX awarding him 100% timesharing so as to gain an unfair advantage in these divorce proceedings. The Wife was out and away from the small child for 15 days until the court hearing. The Court dismissed the Husband’s domestic violence injunction on XXXXXX XX, 20__ (copy attached hereto) finding there was insufficient evidence. The Wife is back in the home. The Husband’s conduct should be considered in the divorce case.
- On XXXXX XX, 20__ the Wife went home to find the Husband had taken off all the entry doors in the marital residence and had poured water all over the carpet.
- The Wife called the police and a police report will be provided upon receipt of same.
- Due to the Husband previously filing a fraudulent Domestic Violence Injunction the Wife and child are not staying at the marital home so as to eliminate any further incidents between the parties in front of the minor child. The child is a three (3) year old toddler who needs to be living at his home.
- The Wife requests that she be awarded exclusive use and possession of the marital residence.
- Additionally, the Husband hardly works, as he continually calls out of work and does not have the financial ability to pay for the marital residence, including the mortgage and other household bills.
- The Wife is employed as a Registered Nurse who pays a majority of the marital residence expenses herself. Additionally, she is in School studying to be a nurse practitioner. She has the ability to pay the mortgage while she is in the home with the child.
WHEREFORE, the Wife respectfully requests the relief requested in this cause.
Under penalties of perjury I declare that I have read the foregoing petition and that the facts stated in it are true to the best of my knowledge and belief.
______________________________
JAMIE CROWN
STATE OF FLORIDA )
)§:
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 his/her personal knowledge and that he/she executed this document this ____day of ____________ 20__.
WITNESS my hand and seal in the State and County aforesaid this _______day
of ___________, 20__.
___________________________
NOTARY PUBLIC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been provided to Jack King, XXXXXXXXXXXXXXXX on this _____day of XXXXXX 20__.
LAW OFFICES OF LARRY D. SCHOTT
Attorney for Wife
By:_____________________________
LARRY D. SCHOTT
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