Please Note: This is a *sample* Complaint for Divorce created for a course assignment.

The client names and facts contained herein were provided as part of a hypothetical case and do not represent actual parties.

STATE OF MICHIGAN IN THE 30th CIRCUIT COURT FOR THE COUNTY OF INGHAM FAMILY COURT DIVISION

IDA B. MEAN, Plaintiff, vs. IZZY U . MEAN, Defendant. / ATTORNEYS FOR THE PLAINTIFF: THE EATON & ASSOCIATES LAW FIRM, P.L.C. NANCY R. EATON (P76191) 1808 Davis Avenue Lansing, MI 48910 (517) 507-1476 ________________________________________/ VERIFIED COMPLAINT FOR DIVORCE NOW COMES Plaintiff, IDA B. MEAN, by and through her attorney, NANCY R. EATON of EATON & ASSOCIATES LAW FIRM, P.L.C. and for her Complaint for Divorce, states as follows: 1. That Plaintiff, IDA B. MEAN, is a resident of Ingham County, residing at 1234 Senate Road, Lansing, Michigan 48910. 2. That Plaintiff, IDA B. MEAN, has resided in the state of Michigan for at least one hundred eighty (180) days immediately preceding the commencement of this action, and has been a resident of the county of Ingham for at least ten (10) days prior to the filing of this Complaint. File No: 09-12345678-DM HON. ROSEMARIE AQUILINA VERIFIED COMPLAINT FOR DIVORCE

3. That Defendant, IZZY U. MEAN, resides at 1234 Senate Road, Lansing, Michigan 48910. 4. That Defendant, IZZY U MEAN, has resided in the state of Michigan for at least one hundred eighty (180) days immediately preceding the commencement of this action, and has been a resident of the county of Ingham for at least ten (10) days prior to the filing of this Complaint. 5. That the parities were duly and legally married in East Lansing, Michigan, on January 1, 1998, by a minister, a person duly authorized by the state of Michigan to perform marriages. 6. That the parties have been married for approximately fourteen (14) years. 7. That Plaintiffs name before the marriage was IDA B. SINGLE and her name presently is IDA B. MEAN. 8. That Defendants name before the marriage was IZZY U. MEAN and his name is presently IZZY U. MEAN. 9. That Plaintiff, IDA B. MEAN, and Defendant, IZZY U. MEAN, separated in or about December 2011 and are no longer residing as husband and wife. 10. That there were four (4) children born to the parties hereto during the marriage, to wit: SAMANTHA Y. MEAN, Born October 31, 1998, age 13; and SAMUEL I. MEAN, Born December 27, 1999, age 12; and WENDY Y. MEAN, Born April 25, 2003, age 9; and her twin WILLIAM I. MEAN, Born April 25, 2003, age 9. 11. That Plaintiff IDA B. MEAN, is not pregnant at this time. 12. That no other Michigan court has prior continuing jurisdiction of said minor children.

13. That there has been a breakdown in the marriage relationship to the extent that the objects of matrimony have been destroyed and there remains no reasonable likelihood that the marriage can be preserved. 14. That during the course of said marriage, the parties accumulated certain real property and personal property, which has not yet been divided and which property should be divided in a fair manner. 15. That Plaintiff, IDA B. MEAN, believes that there were marital debts incurred prior to the filing of this Complaint. 16. That Plaintiff, IDA B. MEAN, believes that the marital debts were incurred prior to the filing of this Complaint for Divorce relate primarily to debts upon the real property, outstanding loans, lines of credit, credit cards, private schooling expenses for the minor children, and other household and family expenses. 17. That Plaintiff, IDA B. MEAN, believes that the parties should share medical bills related to the children and that any debt created after the date of separation should belong solely to the person creating the debt, including any uninsured medical expenses. 18. That it is in the best interest of equity and the parties involved, that nay debt created after the filing of this Complaint for Divorce be the sole responsibility of the party creating said new debt unless otherwise agreed in writing by the parties. 19. That it is in the best interest of the parties minor children that they continue to reside with Plaintiff, IDA B. MEAN, in their current residence for stability and continuity so that the children can continue to enjoy the consistency of care that they now receive from Plaintiff, IDA B. MEAN, and their live-in au pair, Imma Caregiver.

20. That all of the minor children, SAMANTHA Y. MEAN, SAMUEL I. MEAN, WENDY Y. MEAN, and WILLIAM I. MEAN, should remain in the care, custody, and control of the Plaintiff, IDA B. MEAN, and that it is within the best interest of the minor children. 21. That it is in the best interests of the four (4) minor children for them to remain with Plaintiff, IDA B. MEAN, so they may remain in the only home they have known with their caregivers Plaintiff, IDA B. MEAN, and their live-in au pair, Imma Caregiver, providing them with as much consistency as possible. 22. That Plaintiff, IDA B. MEAN has, concurrent with this Complaint for Divorce, filed a Petition for Appointment of Guardian of a Minor with the Ingham County Probate Court, File No: 09-1234-GD. 23. That Plaintiff, IDA B. MEAN, believes that Defendant, IZZY U. MEAN, is having an ongoing affair with a female coworker and believes that it is in the best interest of the parties minor children that the children do not spend any overnight periods with the Defendant, IZZY U. MEAN, in the presence of his mistress/sexual partner. 24. That Plaintiff, IDA B. MEAN, believes that Defendant, IZZY U. MEAN, has had prior affairs throughout the course of the marriage, starting in or about 2003 and continuing through the present day. 25. That Plaintiff, IDA B. MEAN, is a well and able bodied person, mentally, emotionally and physically capable of caring for a having sole physical custody of the parties minor children, and believes that she should have sole physical custody of all four (4) minor children, with both parties sharing joint legal custody.

26. That Defendant, IZZY U. MEAN, should only enjoy parenting time with the minor children, but that said parenting time should only allowed outside of the presence of his mistress/sexual partner. 27. That Defendant, IZZY U. MEAN, is a well and able bodied person, physically capable of gainful employment and paying Child Support. 28. That Defendant, IZZY U. MEAN, is a well and able bodied person, physically capable of gainful employment and paying Spousal Support. 29. That Defendant, IZZY U. MEAN, is the President of MoreMoney Bank and earns a base salary of approximately $625,000.00 per year, not including bonuses or other benefits. In addition, Defendant IZZY U. MEAN, has an Lesko benefits of 365 unused, paid sick days, which are valued at one years salary ($625,000.00), and should be imputed to Defendants income. 30. That it is in the best of the parties and the minor children that Defendant, IZZY U. MEAN, pay child support, both interim and permanently. 31. That Plaintiff, IDA B. MEAN, is employed as a Registered Nurse (R.N.) in Lansing, Michigan. 32. That Plaintiff, IDA B. MEAN, earns approximately $87,000.00 per year, with occasional overtime and holiday pay, which are not guaranteed. Additionally, that Plaintiff receives no Lesko benefits from her employer. 33. That Plaintiff, IDA B. MEAN, should be allowed to claim all four (4) children as tax deductions for 2011. 34. That, based on the circumstances of the parties and their current living conditions, the parties should file separate taxes for the year of 2011.

35. That Defendant, IZZY U. MEANs actions, which include continued infidelities and affairs with his coworker, have caused the breakdown of the marital relationship and Plaintiff, IDA B. MEAN, filing this Complaint of Divorce. FRIEND OF THE COURT INVESTIGATION 36. That it is in the best interest of the parties that the Ingham County Friend of the Court conduct and investigation and make a recommendation pertaining to interim and permanent child support, child care expense, medical expenses, custody of all four (4) minor children and parenting time and that interim and retroactive child support be recommended and immediately ordered. WHEREFORE, Plaintiff, IDA B. MEAN, respectfully requests the following: A. That Defendant, IZZY U. MEAN, herein may answer this Complaint for Divorce. B. That the marriage between Plaintiff, IDA B. MEAN, and Defendant, IZZY U. MEAN, may be dissolved and divorce from the bonds of matrimony decreed to this Plaintiff, IDA B. MEAN, according to the statues in such cases ad made and provided. C. That the parties be restrained from disposing, selling, assigning, encumbering or destroying any of the property or assets of the parties without mutual consent and signatures of both parties hereto. D. That Plaintiff, IDA B. MEAN, and Defendant, IZZY U. MEAN, be required to pay the costs associated with maintenance of the current residence, including but not limited to mortgage payments, taxes, insurance, heating, gas, electric, water, and the like, keeping the status

quo during the pendency of this divorce action or until further Order of this Honorable Court. E. That Plaintiff, IDA B. MEAN, be awarded sole physical custody of the four (4) minor children and that Plaintiff, IDA B. MEAN, and Defendant, IZZY U. MEAN, continue to share joint legal custody of the parties minor children during the pendency of this case and permanently. F. That Defendant, IZZY U. MEAN, be given reasonable parenting time with the minor children, with the exception that Defendant IZZY U MEANs parenting time be limited to non-overnight parenting time so long as he is continuing his affair with his mistress/sexual partner. G. That the four (4) minor children continue to reside with Plaintiff, IDA B. MEAN, until further order of this Honorable Court. H. That Defendant, IZZY U. MEAN, be required to pay a reasonable amount of child support for the care, education and maintenance of said minor children of the parties. I. That the Ingham County Friend of the Court conduct an investigation and make a recommendation pertaining to the custody of the four (4) minor children, child support and parenting time, in addition to interim and retroactive child support. J. That Defendant, IZZY U. MEAN, be required to pay an all of Plaintiff, IDA B. MEANs expenses related to this divorce, including

but not limited to, actual attorney fees, interest, court costs, filing fees and the like. K. That the parties continue to pay all insurance, including but not limited to, all reasonable and necessary medical, dental, orthodontic, optical, hospital, psychiatric and pharmaceutical expenses, keeping the status quo. L. That each party be ordered to individually pay and be responsible for any newly created debt after the filing of this Complaint for Divorce. M. That the parties be required to pay the bills acquired as a result of the marriage, in a equitable amount and in keeping the status quo. N. That the parties equally be responsible for the childrens uninsured medical expenses and that they be solely responsible for their own uninsured medical expenses since the date of the parties separation. O. That Plaintiff, IDA B. MEAN, retains possession of her personal vehicle. P. That Defendant, IZZY U. MEAN, be ordered to provide to Plaintiff, IDA B. MEAN, with his financial records, including but not limited to employment records, benefits records (including Lesko benefits), tax records, pension/retirement records, bank account records (including ATM withdraw records), assets, titles to automobiles and deeds and other assets, regardless of where the item is situated.

Q. That Plaintiff, IDA B. MEAN, may have such further and other relief as the nature of this case, equity, and the ends of justice so dictate and require.

I DECLARE THAT THE STATEMENTS CONTAINED HEREIN ARE TRUE TO THE BEST OF MY INFORMATION, KNOWLEDGE, AND BELIEF.

Dated:

January 13, 2012

Ida B. Mean_______
IDA B. MEAN Plaintiff

STATE OF MICHIGAN COUNTY OF INGHAM

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Sworn and subscribed to before me this ____ day of January, 2012.

________________________________ Ima Notary, Notary Public County of Ingham, Michigan My commission expires: 1/1/2014

THE EATON & ASSOCIATES LAW FIRM, P.L.C.

Dated: __________________, 2012

_______________________________ NANCY R. EATON (P76191) Attorney for the Plaintiff