STATE OF TEXAS
COUNTY OF HARRIS
JENNY A. JONES CASE NO: 96-45554-DM
VS JUDGE: NORMAN MAILER
JOHN B.JONES COMPLAINT FOR DIVORCE
---------------------------
James Whalen
2467 E. Hill Rd.
Houston, TX. 77001
TX: 713-695-6950
Attorney For Plaintiff
--------------------------
Now comes the Plaintiff, Jenny Jones, who, first being duly sworn, represents to this Court the following:
1. That, prior to filing this Complaint for Divorce, the Plaintiff was a resident of the State of Texas for more than six months, and a resident of the County of Haris for more than 10 days.
2. That the Plaintiff lives in the City of Houston, in Harris County, and that the Defendant, John Jones, lives in the City of Houston, in Harris County, and that venue and jurisdiction are proper in this Court.
3. That the parties were married on July 4th, 1976, in Austin, Texas, and the parties lived together as man and wife until on or about October 16th, 2018, when they separated, and further, that the name of the Plaintiff, immediately prior to the marriage, was Jenny A. Kevorkian.
4. That, during the marriage, the parties had two children:
MARTY ALLAN JONES, dob 7/4/88 and
STEVEN PAUL JONES, dob 9/1/90
and further, that the parties adopted no other children, and that the Plaintiff is not now pregnant.
5. That the parties accumulated property during the marriage, which needs to be divided by this Court, including:
a. The marital home, located at 144 Shady Lane, Houston, TX.
b. Two automobiles, one titled to the Plaintiff, with loan, and the other titled to Defendant, with loan, and
c. Miscellaneous personal property and furniture and personal effects, which are likely to be divided between the parties prior to trial, and
d. The pension from General Motors Corporation, based upon Defendant’s employment there, during the marriage, of some eighteen years.
6. That FURTHER, Plaintiff affirmatively alleges that, during the separation of the parties, she met and befriended one Gladys Howell, entered into a beauty shop business with her, and established, as Plaintiff’s SEPARATE property, the business known as “HEAD FIRST”, on Saginaw Road, in Houston, Texas.
7. That there has been a breakdown in the marriage relationship to the extent that the objects of matrimony have been destroyed, and, further, there remains no reasonable likelihood that this marriage can be preserved.
8. That your Plaintiff will be unable to maintain or defend this action for divorce without an award of attorney’s fees from the Defendant, who is gainfully employed at General Motors Corporation.
9. That your Plaintiff is perfectly suited to be the primary physical custodial parent of the minor children of the parties, and both parties are perfectly suited to be awarded joint legal custody of the children, and that this Court should enter an Order of joint legal custody, with physical custody to the Plaintiff mother (both temporarily and permanently), and with reasonable visitation to the Defendant, John Jones, with the attendant order of support for the minor children, directing the Defendant, John Jones, to pay support for the children in an amount recommended by the Texas Child Support Guidelines, based upon the income of each party.
WHEREFORE, Plaintiff prays that this Honorable Court will:
1. Enter an Order of temporary physical custody of the minor children in favor of your Plaintiff, with joint legal custody of the children, and
2. Enter an Order of support of the children, in the manner provided by law, and
3. Equitably divide the marital property of the parties, and
4. Rule that the business of the Plaintiff is her sole, separate property, not subject to division, and
5. Enter an Order directing that the Defendant pay a portion of the attorneys fees of the Plaintiff, and
6. Provide your Plaintiff with such other, and further, relief, as your Plaintiff may show herself entitled to same.
Further, Plaintiff prays not.
[signature]: Jenny Alice Jones