Family Law Assignment

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,

IN AND FOR MARION COUNTY, FLORIDA

CASE NO.: 42-2019-DR-______________

IN RE: The Marriage of

HS,

Husband,

and

WF,

Wife.

___________________________________/

PETITION FOR DISSOLUTION OF MARRIAGE AND OTHER RELIEF

H/W, HS/WF, by and through his/her undersigned counsel, files this Petition for Dissolution of Marriage and Other Relief and states:

1. This is an action for dissolution of marriage between the parties.

2. The Husband/Wife has been a resident of Florida for six (6) months prior to the filing of this petition.

3. The parties were married to each other on __________, ____, in ______ County, Florida. The parties last resided together as Husband and Wife in Marion County, Florida until their final separation on _________________.

4. The marriage of the parties is irretrievably broken.

5. Both parties are over the age of eighteen, and neither is nor has been within a period of thirty (30) days immediately prior to this date, a person in the military of the United States, as defined by the Servicemembers Civil Relief Act of 2003. Furthermore, neither party is mentally incompetent.

6. There are no children born of this marriage and none are contemplated.

7. There is/are ____ child(ren) born of this marriage and subject to this proceeding, to wit: (CHILD’S INITIALS ONLY), a male/female child born in 20_____.

8. It is in the best interest of the minor child that the family be ordered to comply with a parenting plan that includes a time sharing schedule where the minor child spends fifty percent of the time with each parent/the majority of the time with the H/W.

9. Each party has the financial ability to contribute to the support of the minor child.

10. The H/W requests that the Court award child support as determined by Florida’s Child Support Guidelines.

11. The H/W currently pays for health insurance coverage for the minor child and should be required to continue to do so as long as it is reasonably available to the H/W.

12. The H/W requests that the Court determine each party’s share of the cost of health insurance and any non-covered medical, dental, and prescription medication expenses of the minor child.

13. During the course of the marriage, the parties acquired certain real property located at _______. The Husband/Wife is entitled to an equitable distribution of the equity in the marital home. The Husband/Wife needs the exclusive use and possession of the marital home for the benefit of the Husband/Wife and minor children.

14. During the course of the marriage, the parties acquired certain items of personal property, either in their names individually or jointly. The Husband/Wife is entitled to and requests an equitable division of said joint personal property taking into consideration each party’s contributions to the acquisition of said personal property.

15. All items of personal property have been divided prior to the filing of this petition.

16. During the course of the marriage, the parties incurred certain debts and obligations to third parties. The Husband/Wife is entitled to and requests an equitable distribution of these debts and obligations.

17. The Husband/Wife owns pre-marital property, including, but not limited to:_____. The Husband/Wife should retain sole possession and ownership of said pre-marital property, free from any claim of the Wife/Husband.

18. The Husband/Wife is able-bodied and capable of contributing temporary, durational, rehabilitative, bridge-the-gap or permanent alimony to the Wife/Husband. The Wife is in need of and the Husband has the ability to contribute to the support of the Wife taking into consideration the standard of living established during the marriage as well as the other factors as contained in section 61.08 Fla. Stat. (2018).

19. The Husband has learned that the Wife has listed the marital home for sale to third parties and has removed all items of personal property from the marital home. The Husband fears that the Wife will attempt to dispose of marital assets to the detriment of the Husband. The Husband will be harmed if the Wife is allowed to dispose of marital assets and dissipate the proceeds therefrom. The Husband does not have the ability to post bond for a temporary injunction to prevent the disposal of marital assets.

20. The Husband/Wife has retained the Law Office of Melissa K. Hancock, P.A. to represent him/her in this action and is obligated to pay a reasonable fee for services rendered and for costs associated with this action for which the Husband/Wife should be responsible pursuant to Chapter 61, Fla. Stat. (2018).

WHEREFORE, the Husband/Wife, HS/WF, respectfully requests this Court to take jurisdiction over the subject matter hereof and parties hereto and enter its Order:

a. Awarding the Husband/Wife a dissolution of the bonds of marriage between the parties.

b. Ordering the Wife/Husband to pay alimony to the Husband/Wife, either temporary, rehabilitative, durational, bridge-the-gap or permanent.

c. Establishing a Parenting Plan that contains provisions for parental responsibility and timesharing for the minor child temporarily and permanently.

d. Establishing each party’s child support obligation, including medical/dental insurance coverage for the minor child and each party’s share of non-covered medical expenses for the minor child temporarily and permanently.

e. Awarding the Husband/Wife an equitable distribution of the joint assets and liabilities of the parties taking into consideration each party’s contributions to the acquisition of such assets and liabilities.

f. Temporarily restraining and enjoining each party from secreting or disposing of any marital assets during the pendency of this action.

g. Awarding the Husband/Wife attorney’s fees and costs.

h. Awarding such other relief as the Court deems just and proper.

_______________________________________

HS/WF

STATE OF FLORIDA

COUNTY OF MARION

BEFORE ME, the undersigned authority, personally appeared HS/WF, who, after being first duly sworn, states that he is the Husband/she is the Wife in the foregoing Petition for Dissolution of Marriage and Other Relief, and has personal knowledge of the facts and matters set forth and alleged therein; that each of these facts and matters are true and correct to the best of his/her knowledge, information and belief.

WITNESS my hand and official seal in the State and County aforesaid this _______ day of _________________, 2019.

________________________________________

Notary Public, State of Florida

My commission expires:

Personally known _______ OR Produced I.D. ________

Type of Identification Produced: ___________________

LAW OFFICE OF

By___________________________________________