WIFE’S PETITION FOR DISSOLUTION OF MARRIAGE
(One Child – Wife Seeks Exclusive Possession of Marital Home)
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
In Re: The Marriage of Case Number:
WIFE’S PETITION FOR DISSOLUTION OF MARRIAGE
The Petitioner/Wife, JAMIE CROWN, through her undersigned attorney
files this her Petition for Dissolution of Marriage and states as follows:
- Action for Dissolution of Marriage. This is a action for dissolution of marriage between the Petitioner/Wife, JAMIE CROWN, and the Respondent/Husband, JACK KING.
- Residency and Jurisdiction as to Wife. The Petitioner/Wife has been a resident of Broward County, Florida for more than six months next before filing this petition.
- Marriage of the Parties. The parties were married to each other on XXXXXXXX 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 Child. There was one child born of the marriage to wit: XX, born on xx/xx/20__. No other children are anticipated or expected.
- Husband’s Employment: The Husband has been unemployed and/or underemployed most of the marriage. He is lazy and lives off the Wife.
- Wife’s Employment. The Wife is employed as a Registered Nurse. Additionally, she is also in School studying to be a nurse practitioner.
- 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.
10. Timesharing. The Wife should be awarded the majority of the timesharing which has been the status quo. 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 Court dismissed the Husband’s domestic violence injunction on XXXXXXX XX, 20__ (copy attached hereto) finding there was insufficient evidence. The Husband’s conduct should be considered in the divorce case.
11. Child Support. The Court should award the Wife child support pursuant to the child support guidelines.
12. Alimony. Neither party should receive alimony from the other.
- Real Property. The parties acquired property during the marriage in the Wife’s sole name located in Fort Lauderdale at: XXXXXXXXXXXX, Florida, legally described as:
XXXXXXXXXXXXXXXXXX. The Wife requests exclusive use and possession of the home and an award of same as and for equitable distribution. The Husband has stated that he doesn’t want the property.
- Personal Property. The parties acquired various items of personal property, including vehicles, furniture and home furnishings during the marriage for which the Wife seeks equitable distribution.
- Financial Accounts. The Wife is unaware of any substantial marital financial accounts but seeks equitable distribution thereof.
- Debts. The parties should be responsible for all marital debts.
- Attorney’s Fees and Costs. Each party should be responsible for their own attorneys fees and costs.
WHEREFORE, the Petitioner/Wife, JAMIE CROWN, prays this Honorable Court will:
- Dissolve the marriage of the parties;
- Award shared parental responsibility with the Wife having the majority of the timesharing as has been the status quo and is in the child’s best interests;
- Enter a parenting plan that establishes the status quo and that considers the best interest of the child;
- Award child support pursuant to child support guidelines;
- Award the Wife exclusive use and possession of the marital home;
- Award the Wife the marital home as and for equitable distribution;
- Grant such other and further relief as may be deemed just and proper.
The Petitioner/Wife, JAMIE CROWN, 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, JAMIE CROWN, who produced _____________________ as identification, after first being duly sworn upon oath, deposes and says that he 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 Sate 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: Jack King, Husband, by personal service
LARRY D. SCHOTT
Attorney for Wife
LARRY D. SCHOTT
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