1] Bruce D. Brown, #00 BROWN FAMILY LAW G! 2] 9201 Avenue, Ste. 250 Phoenix, AZ 85021 3} (602) 589-5110 5 | 7 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 8 IN AND FOR THE COUNTY OF MARICOPA 9 “ 1 FC2016-009166 . 1} Ne. 2 }_BETITION FOR DISSOLUTION L ) OF A NON-COVENANT MARRIAGE | (DIVORCE) WITH CETEDREN 14 ) 16 NOW Petitioner, by and through her below signed 17} counsel, and alleges as folloi 1 name is Jordan W. 20] and 21] Chandler, and Respond 85224; that Respondent's date of birth10 11 12 13 14 15 16 v7 18 19 20 22 23 24 25 the the Respondent is tary. LE parties were married on F bruary 21, 2014 i nat Petitioner herein alleges that the marriage of the parties is irretrievably broken and there is no reasonable Prospect of reconcilia’ on; the conciliation provisions of A.R.S Section 25-381.09 either do not apply, or have been met v That the parties have three children common to this b. is October ©, to wit: Ayvah M. Neighbors, date 20, 2009 born in Oregon. Jocelyn 0. Neighbors, date of bir September 10, 2012 born in Arizona. Oliver J. Neighbors, date of birth July 28, 2015 born in Arizona. Respondent is not pregnant. @ parties should have Joint Legal De: on Making as well as frequent and continuing parenting time Neither party is entitled to Spousal Mm: eves that this Court has jurisdiction to decide custody matters because Arizona w the domicile of the parents and the minor child commencement of this proceeding; it is in the best interests of of ld the minor c a Court this State assume jurisdiction lover the m: Iconnectionns connection with this State, and there is substantial evidence lavailable in this State concerning the minor child's current land/or future care, protec n, training and personal relationships. Ix. Petitioner has not part ipated, as a party, witness or in any other capacity, in any igation concerning the custody of the minor child in this or any other state Petitioner knows of no other proceedings, concerning che child, pending in a court of this or any other state. Petitioner knows of no other person, not a pi ty to s proceeding, who has physical custody of the child or claims to have physical custody or visitation rights with respect to the child. That by zr child ated to support the. land, as such, the Arizona Child Support Guidelines should be nild should plemented. Similarly, the tax exemption for the Ibe divided according to Arizona Child Support xI. That both parents are obligated to support the: land, as such, that all health plans for the minor child need to be researched to determine is the best for the least lcost for the parties. The Pet: oner alleges herein that the p acquired various items of community property, in residence, retirement accout e and have inci d communitydebts, an vequest is hereby made that this Court equitably divide the community property neluding any retirement accounts, 401(k)‘s, etc.) and equitably assign the community debts Petitioner further alleges that each party retains his or her separate debt. XIII. After the Judge or Commissioner signs the Decree of Dissolution of Mar: ge, the parties should pay federal and state taxes as £ llows: For previous years (the years the parties were 10 married, not including the year the Decree was signed), the lijparties will either file joint or separately federal and state 12 [income tax returns. In addition, for previous calendar years. i3]poth parties will pay and hold the other harmless from one-half 14]fof all additional income her costs, and each any, and o 15 will share equally in any refunds. For the calendar year 16 n the Decree is signed and al: ture calendar years, eac! 17 foarty will file separate f deral and state come tax returns. 18 Hach party will give the other party all necessary documentation 19 to do so. 20 WHEREFORE, Petitioner prays that this Court enter the 21]following orders: 22 1. Dissolve the marriage and return each party to the 23 status 24 2. Award decision making of the parties’ minor 25 chi dren 26 3. That a reasonable parenting time plan be established as 27 well as a sum per month as and for child support in 28 accordance with the Statewide Child Support Guidelinesa should be ordered; that all child support payments should be made through the Support Payment Clearinghouse and should be accompanied by the fees required by A.R.S. Section 554(A) (11). As well as the tax exemption and education expenses; 4, That the party with the best health insurance including costs and available coverage should be ordered to pay for the health, medical and dental nsurar e coverage for the child common to the parties and under the age of 18 years, and that the ies should pay for all reasonable un-reimbursed medical, dental and healt! related expenses incurred for the child in proportion to their respective incomes; + Equitably divide the co: ity property, including retirement accounts, community residence, etc y divide the commun: 6. Equital y debts; 7. Award to each party their separate propert! 8. ard to each party their separate debts; 9. If the Respondent unreasonably contests this action order the Respondent to pay in full or a portion of the asonable attorney's fees and cos incurred in this dissolution; and, 10. For such other and further re f as this Court deems the premises. LLY SUBMITTED PLC Broun Attorney for Pet. oner