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Mark Willis, (1234)

Law Office of Mark Willis, P.L.L.C.


Riverwoods Office Park
525 North Riverwoods Dr., Suite 123
Provo, Utah 84604
Telephone: (801) 224-5000
Facsimile: (801) 224-6000
Attorney for Petitioner

IN THE FOURTH JUDICIAL DISTRICT COURT


125 North 100 West, Provo
UTAH COUNTY, STATE OF UTAH

JANE LOUISE ANDERSON-DIXON PETITION FOR DIVORCE


a.k.a. JANE DIXON
Petitioner, Case No.
v.
Commissioner: Jones
PAUL JACOB DIXON Judge:
Respondent.

COMES NOW the Petitioner, Jane Anderson, by and through her attorney, Mark

Willis, and alleges and petitions the court as follows:

1. Residency. Petitioner is bonafide resident of Utah County, State of Utah,

and has been for three months immediately prior to the filing of this action.

2. Petitioner’s Residence. Petitioner resides at 123 Elmwood Street, Spanish

Fork, UT 84650, and has been a resident of the State of Utah for her entire life.
3. Respondent’s Residence. Respondent resides at 500 Eagle Lane, St. Paul,

Ramsey County, Minnesota 55123, and has been a resident of the State of Minnesota for

six months.

4. Marriage Statistics. The Petitioner and Respondent were married on

January 15, 2005, Provo, Utah County, State of Utah, and are presently married.

5. Jurisdiction. This Court is that of proper jurisdiction to hear this cause.

The Defendant has agreed to file an Affidavit of Consent in this cause. Neither the

Plaintiff nor Defendant has been involved in any litigation or other proceeding involving

the other party in this or any other jurisdiction with respect to their marriage or any other

domestic matter.

6. Grounds. For many months past, there have been numerous and

substantial irreconcilable differences that have arisen between the parties for which

Petitioner is entitled to a decree of divorce.

7. Children. There were no children born or adopted into this marriage.

8. Personal Property. The parties have acquired personal property. The use

of the personal property should be awarded as the parties have already divided it.

9. Vehicles. The Petitioner should be awarded the 2001 Honda Civic and

will hold the Respondent harmless from any obligations or encumbrances on the vehicle.
The Respondent should be awarded the 2003 Toyota Tundra and will hold the Petitioner

harmless from any obligations or encumbrances on the vehicle.

10. Debt. The parties acquired debts during the marriage. Each party will

assume, and hold the other harmless from liability on each and every debt incurred

solely in his or her own name. The Respondent will pay the jointly held credit card

debt acquired after the separation.

11. Savings and Checking Accounts. The Petitioner and Respondent own a

savings account. The Petitioner should be awarded a greater proportion of this asset

due to the fault of the Respondent for the divorce action.

12. Marital Settlement Agreement. Petitioner and Respondent have not

entered into a Marital Settlement Agreement that formalizes an allocation of their

property and finances.

13. Attorney Fees and Costs. Due to the Respondents ability to pay, the

Respondent will reimburse the Petitioner for all her reasonable attorney's fees and

court costs incurred in this action.

Dated this 4th day of December 2005

______________________________
Mark Willis, Attorney for Petitioner
NOW, THEREFORE, Petitioner requests that the court order a DECREE OF

DIVORCE and such further relief as Plaintiff may have requested herein.

Verification

I, Jane Louise Anderson-Dixon, affirm under penalty of perjury that I am the Petitioner in

the foregoing COMPLAINT FOR DIVORCE and that all statements in this Petition are

accurate to the best of my knowledge. I have filed this Complaint in good faith and have

not colluded with anyone in relation to it.

________________
_____________________________________________
_
Petitioner's Signature Date

LA265 Family Law Unit 6 Assignment


August 29, 2010
Mark Willis, (1234)
Law Office of Mark Willis, P.L.L.C.
Riverwoods Office Park
525 North Riverwoods Dr., Suite 123
Provo, Utah 84604
Telephone: (801) 224-5000
Facsimile: (801) 224-6000
Attorney for Petitioner

IN THE FOURTH JUDICIAL DISTRICT COURT


125 North 100 West, Provo
UTAH COUNTY, STATE OF UTAH

JANE LOUISE ANDERSON-DIXON FINANCIAL DECLARATION


a.k.a. JANE DIXON
Petitioner, Case No.
v.
Judge:
PAUL JACOB DIXON
Respondent. Commissioner: Jones

Husband: Paul Jacob Dixon Wife: Jane Dixon


Address: 500 Eagle Lane 123 Elmwood Street
St. Paul, MN 55123 Spanish Fork, UT 84650
Birth Date: January13, 1982 August 13, 1983
Social Security: 123-45-9876 123-45-6789
Occupation: Contractor Cashier
Employer: Getz Construction Sam’s Club

NOTE: THIS DECLARATION MUST BE FILED WITH THE DOMESTIC CALENDAR


CLERK 5 DAYS PRIOR TO THE PRE-TRIAL HEARING. FAILURE BY EITHER
PARTY TO COMPLETE, PRESENT OR FILE THIS FORM AS REQUIRED WILL
AUTHORIZE THE COURT TO ACCEPT THE STATEMENT OF THE OTHER PARTY
AS THE BASIS FOR ITS DECISION.
ANY FALSE STATEMENT MADE HEREON SHALL SUBJECT YOU TO THE
PENALTY FOR PERJURY AND MAY BE CONSIDERED A FRAUD UPON THE
COURT.

(1) STATEMENT OF INCOME Husband Wife

1. Gross Monthly income from: $2,000 1,700


Salary and wages, including commissions & bonuses
Overtime (not guaranteed)
Pension and Retirement
Social Security
All other sources: (specify)
1099 (25% TAX)
TOTAL MONTHLY GROSS INCOME $2,000 1,700

2. Itemize monthly deductions from gross income:


Federal incomes taxes 120 100
State withholding taxes 60 50
Social Security 120 100
Medicare Tax
Medical or other insurance
Retirement of pension fund
savings plans, credit union
other: specify
CURRENT CHILD SUPPORT

TOTAL MONTHLY DEDUCTIONS: 300 250

NET MONTHLY INCOME – TAKE HOME $1,700 1,450


(2) FINANCIAL OBLIGATIONS
3. DEBTS AND OBLIGATIONS:
Creditors Name For Balance Monthly Payment/Due Date
Citibank MasterCard Joint $2,000 $25 (min)

(3) PROPERTY / ASSETS APPROXIMATE VALUE


(A) Household furnishings, furniture, appliances, equipment: $ 3,000

(B) Automobiles (Year, Make and Model)


2001 Honda Civic 13,000
2003 Toyota Tundra 15,000

(C) Securities, stocks, bonds

(D) Cash and Deposit Accounts (banks, savings, loans, 5,000


credit unions, checking)

Wells Fargo Bank

(E) Life Insurance: Name of Company and Policy No.

(F) Profit Sharing or Retirement accounts

(G) Other personal property and Assets

(H) Real Estate: Type of Property: Date of Acquisition:

Address: Original Cost: Total Present Value:

Cost of Additions: Mortgage Balance: Other liens:

Total Cost Taxes: Equity:


JANE LOUISE ANDERSON-DIXON, THE AFFIANT, BEING FIRST DULY
SWORN AND UNDER OATH, DEPOSES AND SAYS THAT AFFIANT IS THE
PETITIONER IN THIS ACTION, THAT AFFIANT HAS READ THIS DOCUMENT
AND UNDERSTANDS THE CONTENTS, AND THE SAME IS TRUE OF
AFFIANT’S OWN PERSONAL KNOWLEDGE, UNLESS AN ALLEGATION HAS
BEEN MADE ON INFORMATION AND BELIEF.

Dated this 4th day of December 2005.

Jane Louise Anderson-Dixon

Acknowledgment Certificate

State of Utah )
§
County of Utah )

On this 4th day of December, in the year 2005, before me a notary public, personally
appeared Jane Louise Anderson-Dixon, who proved on the basis of satisfactory
evidence to be the person whose name is subscribed to this instrument, and
acknowledged (she) executed the same. Witness my hand and official seal.

_________________________
NOTARY PUBLIC