233-555238-14
CAUSE NO. 233-555238-14 IN THE MATTER OF THE MARRIAGE OF BROOKE POWELL AND CORI JO LONG
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FILED TARRANT COUNTY 5/13/2014 3:53:51 PM THOMAS A. WILDER DISTRICT CLERK
IN THE DISTRICT COURT 233RD JUDICIAL DISTRICT TARRANT COUNTY, TEXAS
ORIGINAL COUNTERPETITION FOR DIVORCE
1.
Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas
Rules of Civil Procedure. 2.
Objection to Assignment of Case to Associate Judge Counterpetitioner objects to the assignment of this matter to an associate judge for a trial
on the merits or presiding at a jury trial. 3.
Parties This suit is brought by CORI JO LONG, Counterpetitioner. The last three numbers of
CORI JO LONG's driver's license number are 983. The last three numbers of CORI JO LONG's Social Security number are 735. BROOKE POWELL is Counterrespondent. 4.
Domicile Counterpetitioner has been a domiciliary of Texas for the preceding six-month period and
a resident of this county for the preceding ninety-day period.
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5.
Service Service of this document may be had in accordance with Rule 21a, Texas Rules of Civil
Procedure, by serving Counterrespondent's attorney of record, Susan F. Smith, Varghese & Smith, PLLC, 420 Throckmorton, Ste. 200, Fort Worth, Texas 76102;
[email protected]. 6.
Protective Order Statement No protective order under title 4 of the Texas Family Code is in effect, and no application
for a protective order is pending with regard to the parties to this suit. 7.
Dates of Marriage and Separation The parties were legally married on or about June 9, 2010 in New Hampshire and ceased
to live together as wife and wife on or about June 1, 2013. 8.
Grounds for Divorce The marriage has become insupportable because of discord or conflict of personalities
between Counterpetitioner and Counterrespondent that destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation of reconciliation. 9.
Child of the Marriage There is no child born of this marriage and none is expected. Counterpetitioner, CORI
JO LONG, adopted a child during the marriage. Counterrespondent did not adopt the child and therefore has no legal relationship to the child. 10.
Division of Community Property Counterpetitioner requests the Court to divide the estate of Counterpetitioner and
Counterrespondent in a manner that the Court deems just and right, as provided by law. 11.
Attorney's Fees, Expenses, Costs, and Interest It was necessary for Counterpetitioner to secure the services of Sonya R. Carrillo, a
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licensed attorney, to prepare and prosecute this suit. To effect an equitable division of the estate of the parties and as a part of the division, judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Counterrespondent and in favor of Counterpetitioner for the use and benefit of Counterpetitioner's attorney; or, in the alternative, Counterpetitioner requests that reasonable attorney's fees, expenses, and costs through trial and appeal be taxed as costs and be ordered paid directly to Counterpetitioner's attorney, who may enforce the order in the attorney's own name. Counterpetitioner requests postjudgment interest as allowed by law. 12.
Prayer Counterpetitioner prays that citation and notice issue as required by law and that the
Court grant a divorce and all other relief requested in this counterpetition. Counterpetitioner prays for attorney's fees, expenses, costs, and interest as requested above. Counterpetitioner prays for general relief. Respectfully submitted, NUNNELEY FAMILY LAW CENTER 1845 Precinct Line Road, Suite 100 Hurst, TX 76054-3109 Tel: (817) 485-6431 Fax: (817) 577-9899
By: SONYA R. CARRILLO State Bar No. 24078317 E-Mail:
[email protected] Attorney for Counterpetitioner, CORI JO LONG
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Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on May 13, 2014.
SONYA R. CARRILLO Attorney for Counterpetitioner, CORI JO LONG
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