STATE OF NORTH CAROLINA
‘IN THE GENERAL COURT OF JUSTICE,
vin vp 0 oq DISTRICT COURT DIVISION
COUNTY OF MECKLENBURG 7 ~* 'FELBNO:10-CVD- [W371 PEW
PAULA S. COOK,
Plaintiff, )
5}----COMPLAINT FOR CHILD CUSTODY,
i) ‘CHILD SUPPORT, POSTSEPARATION
vs. } SUPPORT, ALIMONY, EQUITABLE
} DISTRIBUTION, AND ATTORNEY'S FEES
)
ANTWAUN COOK, )
Defendant. )
)
NOW COMES, Plaintiff, Paula S. Cook, by and through her undersigned counsel complaining
of Defendant, who alleges and says:
PARTIES, CAPACITY, JURISDICTION AND VENUE
Plaintiff, Paula S. Cook, (hereinafter referred to as “Plaintifi/Wife”), is a citizen and
resident of Charlotte, Mecklenburg County, North Carolina, and has been such for six (6)
months next preceding the institution of this action.
Upon information and belief, Defendant, Antwaun Cook, (hereinafter referred to as
“Defendant/Husband”), is a citizen and resident of Charlotte, Mecklenburg County,
North Carolina.
Plaintiff/Wife and Defendant/Husband were lawfully married to each other on or about
October 1, 2005, and as of the date of the filing of these claims, continue to be husband
and wife.
Plaintiff/Wife and Defendant/Husband have lived separate and apart from each other
since on or about June 16, 2010 and have not resumed the marital relationship since that
time.
‘There were two (2) minor children born to the marriage of the parties, namely; Christian
Cook (hereinafter referred to as “Christian”) bom July 2, 2004 and Jackson Cook
(hereinafter referred to as “Jackson”) born June 23, 2008 (collectively referred to as the
“minor children”).
Plaintifi/Wife is a natural person under no legal disability, over the age of eighteen (18)
years, and seeks:10.
WL
12.
13.
a. Child Custody and Support, including temporary and permanent custody and
support, pursuant to North Carolina General Statutes Section 50-13.1 er seq. and
North Carolina General Statutes Section 50A-201(a) (1);
b. Sequestration of the former marital residence locateds
Charlotte, Mecklenburg County, North Carolina 28278 and the 2000 Lexus
RX300 driven by Plaintifi/ Wife incident to child custody and child support claims
pursuant to North Carolina General Statutes Section 50-13.4(¢);
c. Postseparation Support pursuant to North Carolina General Statutes Section 50-
16.24 et seq.;
4. Alimony pursuant to North Carolina General Statutes Section 50-16.34 ef seq.s
¢. Equitable Distribution of marital and divisible property, pursuant North Carolina
General Statutes Section 50-20 et seq.; and
£ Atiomey’s fees, pursuant to North Carolina General Statutes Section 50-13.6 and
50-16.4 ef seg.
‘Venue of this action is proper in Mecklenburg County, North Carolina, the residence of
Plaintiff Wife, Defendant/Fiusband and the minor children.
‘The Court has subject matter jurisdiction over the claims asserted herein.
“The Court has personal jurisdiction over the parties and the minor children.
The District Court (Family Court) is the proper division of the General Court of Justice
for the trial of this family law case.
FACTUAL ALLEGATIONS
Plaintiff” Wife hereby repeats and realleges the allegations set forth in paragraphs one (1)
through ten (10) of Plaintifi7Wife’s Complaint for Child Custody, Child Suppor,
Postseparation Support, Alimony, Equitable Distribution, and Attorney's Fees, and
incorporates them by reference as though fally set forth herein,
Plaintiff” Wife and Defendant/Husband lived together in a residence, owned as tenants by
the entirety, located at