COMMONWEALTH OF KENTUCKY
HOPKINS CIRCUIT COURT
MADISONVILLE, KENTUCKY 42431
CIVIL ACTION NO. 92-CI-00444
IN RE: THE 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.
PETITION FOR DISSOLUTION OF MARRIAGE
Comes now the Petitioner, Laura Vannoy Padgett,
and for
her cause of action herein states as follows:
1. The Petitioner is forty-two years of age, presently
resides at 608 Suthard Drive, Madisonville, Hopkins County, Ken-
tucky, has been a resident of the Commonwealth of Kentucky for
more than 180 days next preceding the filing of this petition,
and is presently employed as a speech pathologist by Swigert &
1
Associates, Lexington, Kentucky.
2. The Respondent, Thomas Carter Padgett, is forty-two
years of age, presently resides at Radisson Plaza at Town Center,
1500 Town Center, Southfield, Michigan 48075, and is presently
employed as hotel general manager for Radisson Plaza Hotel,
Southfield, Michigan.
3. The Petitioner and Respondent were married
on the
30th day of June, 1979, in Baton Rouge, East Baton Rouge Parish,
Louisiana, where their marriage is registered.
4. The Petitioner and Respondent are separated,
having
been separated since July 25, 1992.
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5. The parties have two minor children, namely
Julie
Elizabeth Padgett, born January 20, 1980, and Beau Granville
Padgett, born September 21, 1984.
6. The Petitioner is the proper person to have
the
temporary and permanent care, custody and control of the parties'
minor children.
7. The Petitioner is not now pregnant.
8. The marriage between the parties is irretrievably
broken without any reasonable prospect of reconciliation.
9. The parties accumulated certain property during
the
course of their marriage and an equitable division of same should
be ordered by this Court.
10. The parties have incurred certain debts and
an
equitable division of payment of said debts should be ordered.
11. The Respondent should be required to pay all
costs
concerning this action, including a reasonable fee for the
Petitioner's attorney.
12. The Respondent should be required to pay to
the
Petitioner a reasonable sum for the support of the parties' minor
children and maintenance for the Petitioner.
WHEREFORE, the Petitioner respectfully requests
the
Court to enter its orders:
A. Dissolving the marriage between the parties;
B. Awarding the Petitioner the temporary and permanent
care, custody and control of the parties' minor children;
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C. Requiring the Respondent to pay to the Petitioner
a
reasonable sum for the support of the parties' minor children
and
maintenance for the Petitioner;
D. Equitably dividing the marital property;
E. Equitably distributing the parties' debts;
F. Requiring the Respondent to pay all costs concern-
ing this action, including a reasonable fee for the Petitioner's
attorney, and;
G. Awarding the Petitioner all other relief to
which
she is entitled.
[Signature]
Michael Hallyburton
Attorney for Petitioner
54 South Main Street
Madisonville, KY 42431
(502) 825-2915
Petitioner, Laura Vannoy Padgett, states that she
has
read the statements contained in the Petition before signing
same, and that all statements contained therein are true to the
best of her knowledge and belief.
[Signature]
Laura Vannoy Padgett,Petitioner
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