FAYETTE CIRCUIT COURT
CIVIL BRANCH
5 DIVISION
CIVIL ACTION NO 92-CI-2852
IN RE THE MARRIAGE OF: [stamp AUG 13 1992]
THOMAS C. PADGETT PETITIONER
AND MOTION FOR TEMPORARY CUSTODY, CHILD SUPPORT,
AN ORDER REQUIRING RESPONDENT TO MAINTAIN
AND NOT DESTORY MARITAL ASSETS AND TO PREVENT
RESPONDENT FROM TAKING ADDITIONAL ASSETS FROM
THE MARITAL RESIDENCE.
LAURA KAY PADGETT RESPONDENT
Comes now the Petitioner, THOMAS C. PADGETT, by and through
counsel, and respectfully moves this Court for an Order granting
him temporary custody and child support of the parties' minor
children. An order that Respondent be required to keep safe and
not destroy or sale the parties' assets removed from the marital
residence on Sunday, August 9, 1992. Additionally, Petitioner
request that Respondent be prevented from taking the few remaining
assets from the marital residence. An affidavit in support of this
motion has been attached.
NOTICE
Please take notice that the foregoing Motion will be
brought on for hearing before the Fayette Circuit Court
on Friday, August 28 , 1992 at the hour of 1:00 p.m.
soon thereafter as counsel may be heard.
[signature Lola Lewis, Padgett's attorney]
LOLA PHILPOT LEWIS
177 NORTH LIMESTONE
LEXINGTON, KENTUCKY 40507
(606) 281-1313
-2-
COMMONWEALTH OF KENTUCKY
FAYETTE COUNTY COURT
CASE NO. 92CI2652
92CI2852
IN RE: THE MARRIAGE OF
THOMAS C. PADGETT AUG 13 1992 PETITIONER
AND AFFIDAVIT
LAURA KAY PADGETT RESPONDENT
******************************
Comes now the Petitioner, THOMAS C. PADGETT, after being duly
sworn and states as follows:
1. He is the Petitioner in the above styled matter;
2. The Respondent and he with their children lived at the
marital residence of 2272 Abbeywood Road, Lexington, Kentucky until
Sunday, August 9, 1992. On that date, Respondent moved all of the
parties possessions from the home and took the children and went to
Madisonville, Kentucky without notifying Petitioner of her
intentions;
3. Petitioner has been working in Southfield, Michigan for
the past months and has only been able to come home every two or
three weeks. However, the children have also been with him in
Southfield during the past months;
4. Petitioner is the fit and proper person to have custody
and control of the parties' minor children, Julie born January 20,
1980 and Beau, born October 21, 1984;
5. Respondent took almost all of the parties furnishings and
vacated the marital residence without notice to Petitioner leaving
the home vacant and in bad condition. Petitioner would request
that Respondent be ordered to maintain and keep safe the parties'
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property which she took since this is primarily all of the parties'
possessions.
Further Affiant Sayeth Naught.
[SIGNATURE]
THOMAS C. PADGETT
State of Kentucky
Countyof Fayette
Subscribed and sworn to me before by THOMAS C. PADGETT on this
11th day of August, 1992.
My Commission Expires: 1/12/94
[signature]
NOTARY PUBLIC, STATE AT LARGE,
-4-
FAYETTE CIRCUIT COURT
CIVIL BRANCH
5 DIVISION
[stamp] AUG 13 199Z
IN RE THE MARRAIGE OF:
THOMAS C. PADGETT PETITIONER
AND VERRIFIED PETITION FOR
DISSOLUTION OF MARRIAGE 92-CI-2852
LAURA KAY PADGETT RESPONDENT
1. This proceeding is initiated by the petition of the
husband.
2. The relevant information concerning the husband is:
(a) Name: THOMAS PADGETT
(b) Present address: 2272 Abbeywood Road
Lexington, Kentucky 40515
(c) Age: 42 years Date of birth: 11/16/49
(d) Occupation: Hotel Operations
(e) Length of residence in Kentucky: more than 180 days
(f) Prior marriages: 1
'
(g) How terminated: divorce
3. The relevant information concerning the wife is:
(a) Name: LAURA KAY PADGETT
(b) Present address: 608 Suthard Drive
Madisonville, Kentucky 42431
(c) Age: 42 years Date of birth: 10/28/49
(d) Occupation: Speech Pathologist
(e) Length of residence in Kentucky: more than 180 days
(f) Prior marriages: 0
(g) How terminated: N/A
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4. The parties were married on June 30, 1979 and the marriage
is registered in Baton Rouge, Louisiana
5. The parties separated on July 24, 1992, and they have
lived separate and apart since that date.
6. There are two (2) minor children of the parties marriage,
Julie, born January 20, 1980 and Beau, born October 21, 1984. The
children have resided with the parties for their entire lives and
for the past years at the marital residence of 2272 Abbywood Road,
Lexington, Kentucky. The children have not been the subject of a
previous custody proceeding in this or any other state, and there
is no such custody proceeding pending.
7. The Respondent is not pregnant.
8. The marriage is irretrievably broken.
9. There is property and debts subject to disposition by the
Court.
WHEREFORE, the Petitioner prays the Court to:
Enter a Decree of Dissolution of the marriage existing between
the parties; award temporary and permanent custody and child
support of the parties' children to Petitioner; distribution of
non-marital and marital property and debts; award Petitioner
attorney fees, approve any Separation Agreement herewith filed and
incorporated into the Decree of Dissolution; and makee other such
orders as may be just, applicable and appropriate.
[signature]
LOLA PHILPOT LEWIS
177 North Limestone
Lexington, Kentucky 40507
(606) 281-1313 Phone
(606) 254-8096 Fax
-6-
I have read the foregoing petition and the facts stated
hrein are true and correct to the best of my knowledge and
belief
[signature]
THOMAS C. PADGETT, PETITIONER
STATE OF Kentucky
COUNTY OF Lafayette
Subscribed and sworn to before me by Thomas C. Padgett,, on
this 11th day of August, 1992.
My Commission Expiress 1/12/94
[signature]
NOTARY PUBLIC, STATE AT LARGE
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