Maria P; Stein. Esq. State No. 009568 STEIN and STEIN, P.C.
1 2826 south Carriage Lane VSuite 100
1 Mesa, Arizona_ 85202 (602) 820-1421
Attorneys for Petitioner
IN THE SUPERIOR COURT FOR THE 8131. O? AIIIOIR IN AND FOR THE COUNTY OF HRIICDRB In Re the marriage of: SUSAN H. SELL, Petitioner, *and
PETITION FOR DISSOLUTHN‘ OF MARRIAGE
(with Children)
RONALD J. SELL,
Respondent.
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Petitioner. SUSAN H. SELL, by and through her counsel, Maria 9. Stein of 3mm and swam, P.C. , hereby alleges as f llows:
1. Petitioner is, 39- years ‘of £93. her ‘ ~-
address is 2494 NOrth El Dorado Circle, Chandler, Agizaugs“
Petitioner is a homemaker. > i _ > 23”».Respondent is 38 Years of age ané his Illiyh, address is 2494 Nbrth El Dorado.Circ1e, Chandler; Arizona 87 Respondent’s occupation is a physician. 7‘ ~f3r . The parties hereto Here harried on or aboute¥> .11, ‘1979-7inv Greenville, Pennsylvania, and ever since that ‘
been and are now husband and uifegtr’v4. Respondent is not pregnant. 5. Respondent is not in the military service ‘ United States of America.
~ Themarriag‘ebetween the-pan“ <~ r v
i : broken and there is no reasonable prolpcct for
conciliation provisions of 33.8. 15481.09 It lug. Oi ‘ apply or have been met.‘
7. .-Petitioner and lie-pendent have boon ’ Maricopa County,r~Arizona,, for more than ninety (90) d!!! ‘ the filing of this Petition.
8. The parties [have four minor childron m the :,parties} namely: RYAN’P. SELL, born June 4. 1986, ‘ born June 4, 1986,‘ ADAM’SELL, born November 15. 1997 and SELL, born September 4, 1990. I V
I The Court has jurisdiction I has ”
‘ decide child custody matters because the minor
domiciled in Arizona and Arizona is ’11:!» state“ children. _ L V ‘ 1C2 Petitioner should be awarded sole custody
minor children; Respondent should have reasonable 1 the children pursuant to: visitation v’ ‘Maricopa County Domestic Relations I; 11. ‘ Respondent, should pay cayreasonabile amount child support consistentwith Child, I n _.and..A.R..s..5259320,.W.melamunt of shim support should be {as each, child turns (V18),years of age, and if
Vi- reaches the age: of majority the child is attendinéschool, child.- suppert should continue to be ,meperiod,which the child is actually.attand1ng high schoolr .A;
. < Assignment for such amount should inane. _
, Rewmt..’h6u1d, m .. I tr dental insurance for the minor children and aha-11¢! I ELPercent, (1.040%) of all medical and dental W i‘children. ‘ ‘ 1
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,13.‘ ‘The parties should file joint federal income tax returns for the year of 1994 and equallyvinflthereceipt of any refunds p
1‘ obligation owed.
a _» : v 1.4…Petitioner is without I aufficient fund. support and. is temporarily unable to obtain I V’fRespondent is in control of the bulk of the ecnlunity earning sufficient sums of money from euployuent and sufficient suns of money from investments and should be
a pay a reasonable sum as and for spousal uaintenanoet;
. V . :15. v Respondent should maintain Petitioner irrevocable-beneficiary on a life insurance policy i life in sumsflenfficient to cover any remaining at: rmimzenanee and child support for so long as V
2i and child support are owed. ‘ i
_ , I. x 16.: Petitioner shouldrbe awarded the mid-act
12494 7-31,: Dorado Circle, Chamiler, Arizona 3-52ng
-?§ ~:’ ..»a~~11m¢¢Duringlflutmarr1398,«flutpartieslunNhacquireQT ‘J’Ointpcomon; and community property all of axial: equitably divide; During the marriage, theincurred: joint ,‘ common, and comunity liabilities should equitably divide. ‘ i 18. Petitioner has certain property the marriage and/b: “du’fifi”g'” thaterrfiée. “as ’a” f, _ inheritance, which should be affirmed as her ‘mlof and
property .
19-” ‘1‘“? Personal property. including m
accounts, which were acquired or established for the ciao: of the parties, should remain the property. of _
9 children– arid- should notfbe comingled with ath at
parties. y ‘ ‘ 7 ~20. . Petitioner is without sufficient financier/l to» pay for beret-attorney’s fees (other than. initial.
‘fee) and court1costs ,., accountant’s fees and appraisal Respondent”. should be. ordered to e reasoxiablc contribution to these costs .7 V
21,. The parties have not entered into an oral WHEREFORE. Petitioner prays that- this Court will ‘7 the following Orders: ‘5 L in “1., 1 Entera Decree of Dissolution of ‘ 2.: waardin’gzto the Petitioner sole custody of ”
children ‘ of thiammarriage subject to Petitioner?s iv 7
visitationi-rights-pursuant to the visitation guidel’ihes is
the’Maricopa _- County Don‘testic Relations Handbook; Requiring,.Respondent and for; child“suPPOI-it.consistent with the Axizoua”5Child ‘
Guidelines and ‘A’.R~.S.~_§25-320. A Wage Assignmentflfor such:~
4should issue.
4. Requiring Respondent to pay for and
and dental insurance for the minor children and that , , “‘s‘hOUTd”paY*One Hundred Percent (moir’af ‘ Vdental expenses for the minor children.
5. Ordering the parties to file joint federal and income tax returns_for the year of 199‘ and they Ibflfili”“§ ,equally in the ..-receipt i of any refund. and the
«one ave-a. 3’»- u to
obligation owed.
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w-fi. v Requiring Respondent to pay a reasonable sun as fifié
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for spousal maintenance.
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7. Requiring Respondent to maintain Petitioner ijiflfi
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irrevocable beneficiary on a life insurance policy on
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~1ife in sums sufficient to cover remaining suns owed an
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.maintenance and child support for so long as spousal an n J
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and child support are owed.
8. Ordering the payment of connunity debts and £33
it ~a
equitable division of community property of the parties as Ode
forth herein cove.
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9. Ordering *that‘yRespondentr be ordered to p:y~»
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,reasonahle amount as contribution to the costs of Petitioner1 rattorneyis fees (other than her initial retainer fee). and coat:
rcosts, accountant’s fees and appraisal fees.
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V lSTATE 01″. A3120“ ,.
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‘ County of Maricopa I,;. ’SUSANH’. SELL, Petitioner in the foregoing glha-ve read the foregoing r-Petition for Dissolution of Herring. ml kntwthev matters set: forth therein to be true to bolt (l _khew1edge,-ex¢ept those matters alleged upon information “V V I “7: ,Ia’ncri, as to such matters, they are believed ta be
4 DATED this m day of February, 1995. ‘
SUBSCRIBED AND ‘SWORN to-before- this of
” ‘_ February, 1995 .
Commissi n Expires: ‘ ‘ ‘ .v fll’ozwdasaexdxsuommam
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