Jane Anderson (9876)

Law Office of Jane Anderson, P.L.L.C.

Riverwoods Office Park
525 North Riverwoods Dr., Suite 123
Provo, Utah 84604
Telephone: (801) 224-5000
Facsimile: (801) 224-6000
Attorney for Petitioner

IN THE FOURTH JUDICIAL DISTRICT COURT

125 North 100 West, Provo
UTAH COUNTY, STATE OF UTAH

PAUL JONES AFFIDAVIT IN SUPPORT OF

Petitioner, MOTION TO MODIFY SPOUSAL
v. MAINTENANCE

LACK Case No. 12345678

Respondent,
Judge: Carl Kerrick

STATE OF UTAH )
§
COUNTY OF UTAH )

PAUL JONES, being first duly sworn upon oath, deposes and states:

1. I am over 21 years of age and in all respects have knowledge of the contents

herein and I am competent to make this affidavit.

2. The Petitioner requests a change in the existing spousal support order due to a

substantial increase of monthly medical expenses over the next three years and a

decrease of income.

3. A final divorce decree was entered by this court on June 1, 2007, where I was

ordered to pay spousal support to Jenny Jones (former spouse) for ten years in the

amount of $500 per month.

4. I married, Sue Spielman-Jones, on July 1, 2007. We had a child J.J. born to us on

May 1, 2008. The non-joint child was born prematurely and suffers from many

medical health complications.

5. The Petitioner’s income has substantially decreased due to these extraordinary

medical expenses. The additional medical cost is estimated at $1000 minimum per

month for the next three years (See attached Exhibit A: Monthly medical bills).

6. At the time the existing order was issued, I was employed at ACME Car Care as a

mechanic earning $15 per hour with a monthly gross income of $2,400 per month and

my former spouse, Jenny Jones, was an unemployed full-time student.

7. I have maintained my employment with ACME Car Care and have a salary of

$16.50 per hour with a monthly gross income of $2,640 per month.
8. Jenny Jones has graduated with a Bachelor of Science Degree in Tax Accounting.

The Respondent holds a CPA license. To the best of my knowledge, the Respondent

is employed by the Thompson Accounting Firm with an annual gross salary of

$30,000. She is unmarried and has no children to support.

9. The Petitioner supports, J.J., a non-joint child and spouse, Sue Spielman-Jones,

who is currently unemployed due to the birth of our child and his medical

complications.

10. Sue collects unemployment in the amount of $600 per month gross. The benefit

expires on September 15th (See attached Exhibit B: Department of Labor Letter)

11. My Joint Monthly expenses at the present time are as follows:

Monthly Expenses

Monthly Rent $ 950.00

Automobile Insurance $ 80.00
Life $ 35.00
Utilities: (Average Monthly Amount)
Gas $ 40.00
Electricity $ 75.00
Telephone and Internet $ 62.00
Water and garbage $ 58.00
Satellite TV $ 45.00
Food $ 250.00
Clothing $ 120.00
Laundry/dry cleaning $ 30.00
Personal allowances and incidentals $ 150.00
Uninsured / unreimbursed medical expenses $1025.00
 Child care expenses $ 100.00
Spousal Support (monthly) $ 500.00
Transportation expenses:
Automobile payments $ 325.00
Gasoline $ 150.00
Recreation/Entertainment $ 200.00
Charge accounts and loans: (monthly payments)

Sears Card $ 65.00

Visa Card $ 40.00

TOTAL MONTHLY EXPENSES: $3275.00

TOTAL MONTHLY INCOME: $3240.00

UNDER PENALTY OF PERJURY, I SWEAR THAT THE ABOVE STATEMENTS

ARE TRUE TO THE BEST OF MY OWN KNOWLEDGE, INFORMATION, AND

BELIEF.

Dated this 12th day of August 2008.

PAUL JONES

Acknowledgment Certificate

State of Utah )
§
County of Utah )

On this 12th day of August, in the year 2008, before me a notary public, personally
appeared, PAUL JONES, who proved on the basis of satisfactory evidence to be the
person whose name is subscribed to this instrument, and acknowledged she executed the
same. Witness my hand and official seal.
 _________________________
NOTARY PUBLIC

Mailing Certificate

I hereby certify that on this 12th day of August 2008 a true and correct copy of the
foregoing document has been mailed, postage prepaid, to the following:

Russell Stevens
Attorney for Respondent
190 S. 300 E. #100
Salt Lake City, UT 8410

___________________________
Sandra Black-OR, Paralegal

.
LA265 Family Law Unit 5 Assignment
August 21, 2010
EXHIBIT A
EXHIBIT B