Tom Padgett's Divorce and Child Support Cases
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Motions by Laura, 10/13/92

By October 1992, Tom Padgett has already begun to play tricks with his income . This motion is to order him to produce financial records, as well as to pay the insurance on the Eagle vehicle that Laura has been allowed to use.

It's especially cynical of Tom Padgett not to readily produce his financial records so that Laura may complete her income tax returns. Later, in another harassing event Tom Padgett attempts the have the Special Master Commisioner order Laura to file joint returns with Tom for 1991 and 1992.

Yet another example of many of Tom Padgett being harassive in his litigation.

The images for this document are here.

 

                  COMMONWEALTH OF KENTUCKY 
                    HOPKINS CIRCUIT COURT 
               MADISONVILLE, KENTUCKY 42431
                  ACTION NO. 92-CI-00444


IN RE:  MARRIAGE OF LAURA VANNOY PADGETT, PETITIONER, 
        AND THOMAS CARTER PADGETT, RESPONDENT.
		

        AND
		

IN RE:  THE CUSTODY AND SUPPORT OF JULIE ELIZABETH PADGETT, 
        AND BEAU GRANVILLE PADGETT, MINOR CHILDREN. 
		

                          MOTION

Comes now the Petitioner, by counsel, and moves this 
Court to hold the Respondent in contempt of this Court's Pendente 
Lite Order of October 1, 1992, because said Respondent has failed 
to furnish the insurance required of him for the parties' Eagle 
automobile and to enter its order requiring the Respondent to 
immediately furnish the Petitioner all of the Petitioner's 
business and financial records for the years 1988, 1989, 1990, 
1991 and 1992 in order that said Petitioner can prepare and file 
her 1991 income tax returns.

In support of the foregoing motion the Petitioner 
states that the vast majority of her business and financial 
records for the above years are in the possession of the Respon-
dent and that the Respondent has delayed furnishing same to 
accountant Jeff Linden of Lexington, Kentucky, in order that said 
accountant could timely prepare income tax returns for the 
parties. Because of the delays by the Respondent, the Petitioner 
has employed the services of accountant Janet Berry of 

-2-

Madisonville, Kentucky, to prepare her 1991 income tax returns.
through communication with accountant Jeff Linden it was learned
that as of October 12, 1992, the Respondent had not furnished 
said accountant the necessary tax information in order for the 
1991 income tax returns to be filed by the extended deadline of 
October 15, 1992. Said date is the maximum extension allowable 
without penalty.

Further the Petitioner requests the Court to enter its 
order requiring the Respondent to be solely responsible for any 
interest or penalty required to be paid by the Petitioner for her 
1991 income taxes.

Further the Petitioner requests the Court to enter its 
order requiring the Respondent to pay to Michael D. Hallyburton a 
reasonable fee for his services concerning this motion.

This the 13th day of October, 1992.




                                [signature]
                             Michael D Hallyburton 
                             Attorney for Petitioner 
                             54 South Main Street 
                             Madisonville, KY 42431
                             (502) 825-2915 

                     NOTICE

Please take notice that the foregoing Motion will be 
brought on for hearing before Honorable Charles W. Boteler, Jr.,
Judge, on Monday, October 19, 1992, at 10:30 a.m., or as soon
thereafter as counsel may be heard in the Circuit Courtroom,
Hopkins County Courthouse, Madisonville, Kentucky.

 


 

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