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IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
Stanley Michael Williams
CAFN
Petitioner
20FM5772-2
Vv.
Sara Rebecca Cauthen Williams
Respondent
PRE TRIAL ORDER
The following constitutes a Pre Trial Order entered in the above styled case after
conference with counsel for the parties:
(1) The name, address and phone number of the attorneys who will conduct the trial are
as follows:
Petitioner: Michael O’Hagan
O’Hagan Law Firm LLC
P.O. Box 1543
Buford, GA 30515
(404) 403-9711
ohaganmj@yahoo.com
Respondent: Gregory D. Golden
Kupferman & Golden
200 Ashford Center North
Suite 325
Atlanta, GA 30338
(404) 924-2400
greg@kqfamilylaw.com
Other: Heather Wright (Guardian ad Litem)
Hastings Shadmehry Wright LLC
3650 Mansell Road, Suite 475
Alpharetta, Georgia 30022
Main office number: 770.641.8200
Fax: 770.641.8203
heather@hswlegalteam.com
(2) The estimated time required for trial is: Petitioner: 1 day; Respondent: 1 day.
(3) There are no motions or other matters pending for consideration by the court except
as follows: None from Petitioner. None for the Respondent.
(4) The jury will be qualified as to relationship with the following: N/A
(5) a. All discovery has been completed, unless otherwise noted, and the court will not
consider any further motions to compel discovery except for good cause shown. The
parties, however, shall be permitted to take depositions of any person(s) for the
preservation of evidence for use at trial.
Petitioner: Discovery is ongoing; both Parties have filed requesting that the other
supplement their discovery responses.
b. Unless otherwise noted, the names of the parties as shown in the caption to this order
are correct and complete and there is no question by any party as to the misjoinder or
nonjoinder of any parties.
(6) The following is the Petitioner's brief and succinct outline of the case and contentions:
The Parties were married on or about May 26, 2012, separated on or about
November 5, 2016, and have remained in a bona fide state of separation since that time.
All real property owed by the Parties is separate property, except Petitioner requests
$50,000.00 from Respondent as reimbursement for funds paid for the improvement of
commercial real estate owned by Respondent.
The Parties are the legal parents of one (1) Minor Child, Roman Michael Williams,
male, year of birth 2013, age nine (9).
Petitioner requests joint physical and joint legal custody of the Parties Minor Child;
Petitioner is willing to relocate to Florida for purposes of 50/50 custody. Petitioner has
extended family (to include sisters in Augusta/Columbus GA, the Minor Child’s cousins,
and the Minor Child’s two [2] best friends). Should joint physical custody not be awarded,
Petitioner requests joint legal custody with secondary physical custody of the Minor Child,
and parenting time as follows: one (1) weekend per month (preferably any three {3] or
more day weekends), rotating/split (Christmas) holidays, and during the summer break
from school from the first Sunday following the release from school until the last Sunday
before the resumption of school (within one [1] week of the return to school). Petitioner
requests that Respondent be Ordered to do the majority of the traveling or bear the
majority of any transportation costs as it was Respondent that moved the Minor Child to
Florida.
Petitioner requests the payment of child support in the sum pursuant to the Georgia
Child Support Guidelines, with any out-of-pocket medical expenses to be divided pro rata
per the income of the Parties; Petitioner is currently not employed. Petitioner requests
that the cost of any private schoo! tuition be paid by the Respondent.
As both Parties are able-bodied adults capable of gainful employment, neither
Party should be entitled to the payment of alimony from one to the other, except where it
may pertain to the payment of attorney’s fees.
Petitioner requests that Respondent be responsible for the payment of attorney’s
fees (sum to be determined at the conclusion of any hearing) and that Respondent be
responsible for the payment of any outstanding fees owed to the Guardian ad Litem.
Petitioner avers that while this matter was pending, Respondent and the Minor
Child relocated to Florida in January 2021, on a temporary basis for a period of one (1)
year of less; said one (1) year temporary move was nothing more than a rouse by
Respondent to remove the Minor Child from Petitioner's life as Petitioner has taken up
permanent residency in Florida (violation of Standing Order; no Order in place permitting
Respondent and the Minor Child to relocate to Florida). For that reason, and as stated
above, Petitioner requests that Respondent be Ordered to do the majority of the traveling
or the majority of any costs associated with travel as it was Respondent that moved the
Minor Child to Florida.
Due to the length of separation between the Parties, all debts held in the name of
each Party shall be paid by that Party, with the exception of Petitioner's request for the
payment of attorney's fees and Guardian ad Litem.
(7) The following is the Respondent's brief_and succinct outline of the case and
contentions:
On or about May 26, 2012, the parties were married. There is one (1) minor child
as a result of this marriage, to-wit! ROMAN MICHAEL WILLIAMS, born in 2013. The
parties have been separated since November 2016; since that time, the Defendant has
been the primary caretaker of the minor child.
On or about August 13, 2020, the Plaintiff filed the above-styled divorce action.
During the pendency of this litigation, the Defendant was offered an employment
opportunity in the State of Florida. The parties agreed that the Defendant could re-locate
to the State of Florida with the minor child, and allow regular contact between the Plaintiff
and the minor child. In January 2021, the Defendant and the minor child re-located to the
State of Florida; subsequently, the Defendant has purchased a home in Punta Gorda,
Florida.
Following the parties’ unsuccessful mediation in October 2021, the Plaintiff
asserted a claim for primary custody of the minor child. Subsequently, on or about
December 21, 2021, this Honorable Court issued its ORDER APPOINTING GUARDIAN
AD LITEM, in which Heather Wright was appointed, by agreement of counsel, as the
Guardian ad Litem for the minor child (hereinafter sometimes referred to as the
“Guardian’”). The Guardian completed an extensive investigation which included meeting
with the parties, interviews with witnesses, home visits with each party (in the States of
Georgia and Florida), observations of each party with the minor child, and a review of
numerous documents. On or about May 3, 2022, the Guardian issued her findings and
recommendations to the parties’ counsel. In pertinent part, the Guardian ad Litem found,
. That the Defendant’s relocation to the State of Florida was not based on
any intent to limit the Plaintiff's parenting time or to harm the Plaintiff's relationship with
minor child.
. That the Plaintiff has demonstrated a lot of anger and animosity toward the
Defendant, which is entirely misplaced as the Defendant has made a sound decision to
improve her life and financial circumstances.
. That with regard to the Defendant's living arrangements, the house is nice
and acceptable for the minor child’s residence. The minor child attends a good school
and has a good nanny, who helps with after school care and on the weekends when the
Defendant is required to work.
. That the Plaintiff has been very difficult, argumentative, and has a high level
of anger and animosity toward the Defendant that he shows to the minor child. The
Plaintiff has mentioned conversations with the minor child that involve matters regarding
the custody case that he should not be having with the minor child.
. That with regard to the Plaintiff's living arrangements, the Plaintiff's current
living situation is wholly unsuitable for the minor child. The Plaintiff has a makeshift “loft”
in the basement of an industrial building. The minor child does not have his own room or
space, sleeping in the same full/queen bed with the Plaintiff. The finished space (drywall
and drop ceiling) opens into an industrial storage area full of tools and other equipment
that is stored on the property. The entire “loft” spells like gasoline and other chemicals.
. That the Plaintiff is actually doing the actions necessary to care for minor
child.
. That the Defendant needs to make some hard decisions about his living
arrangements and his attitude toward the Plaintiff.
. That the Plaintiff's bitterness towards the Defendant is not healthy for the
minor child.
The Defendant is employed as a restaurant manager with the restaurant group,
Universal Joint Holdings, L.L.C. Currently, she makes approximately $120,000.00 on an
annual basis; this income has varied over the past twelve (12) months as the area in
which she works/lives sustained severe damage due to recent hurricanes. The Father
was working at the DeKalb Farmer's Market but allegedly quit his position during the
pendency of this litigation; it is unknown as to his current employment or income.
Each party has separate, real property that is not subject to equitable division.
(8) The issues for determination by the Court are as follows:
Custody;
Parenting time;
Child Support;
Equitable division of marital property (where applicable);
Petitioner's request for attorney's fees and re-apportionment of Guardian
ad Litem fees; and
Respondent's request for attorney’s fees and re-apportionment of Guardian
ad Litem fees.
(9) Petitioner and Respondent, through their respective attorneys of record, shall
exchange their updated financial affidavits five (5) days prior to trial.
(10) The following facts are stipulated:
- Date of marriage — May 26, 2021;
= There is one (1) minor child as a result of this marriage, Roman Michael
Williams, male, year of birth 2013.
There is no issue as to an equitable division of personal, tangible property
(except where Petitioner has asked for reimbursement for funds paid
towards the improvement of Respondent’s real property) and each party
shall retain what is in his/her current possession.
(11) The following is a list of all documentary and physical evidence that will be tendered
at the trial by the Petitioner or Respondent. Unless noted, the parties have stipulated as
to the authenticity of the documents listed and the exhibits listed may be admitted without
further proof of authenticity. All exhibits shall be marked by counsel prior to trial so as not
to delay the trial before the jury.
a. By the Petitioner: As discovery is ongoing and both Parties have requested
supplemental discovery, this list may be updated. However, documents from
Petitioner to be used as evidence will likely consist of the following:
Texts and/or emails between Parties;
Banking Records (Petitioner's or Respondent's);
Tax Records (Petitioner's or Respondent's);
Photographs;
Attorney billing records, supporting documents regarding requests for
attorney’s fees;
Any and all documents as listed by Respondent;
Petitioner reserves the right to amend his portion of the Pre-Trial Order by
providing copies of documentary evidence not listed to the opposing party
sufficiently prior to trial so as not to delay trial;
Counsel for Petitioner will consult with counsel for Respondent during the
exchange of updated documents in an attempt to resolve any issues
concerning evidentiary issues (foundation, etc.) prior to any hearing in this
matter.
b. By the Respondent:
Respondent's Domestic Relations Financial Affidavit and any amendments
thereto;
Petitioner's Domestic Relations Financial Affidavit and any amendments thereto;
Letter from Petitioner to Respondent's employer, dated on or about May 16, 2022;
Correspondence from the Petitioner to the minor child’s school;
All Federal and state tax returns filed during the marriage of the Parties, together
with all schedules, attachments and working papers;
Wage and income statements for the parties including but not limited to pay stubs,
W-2 forms, 1099 forms, K-1 forms, etc.;
Records from and for all banking, savings, credit union, money market, brokerage
and investment accounts previously and presently maintained by the parties
(whether individually or jointly), including but not limited to bank statements,
checkbook ledgers, canceled checks, transactions registers,
Real estate sales contracts, purchase contracts, closing/settlement statements,
deeds of conveyance, deeds to secure debt, deeds of trust or mortgage,
photographs, videos for any real property owned by either of the parties;
Credit card invoices and itemized statements
Letters, emails, text messages, Facebook and other correspondence between the
parties
Discovery requests and responses between the parties:
Documents and other tangible things responsive to discovery exchanged between
the parties
The Defendant reserves the right to add additional items to his respective list prior
to trial, upon giving the other party reasonable notice thereof and an opportunity to
examine and copy said items
The Defendant reserves the right to amend her portion of the Pre-Trial Order by
providing copies of documentary evidence not listed to the opposing party
sufficiently prior to trial so as not to delay trial; and
Statement of Gregory D. Golden Regarding Defendant's Prayer for Attorney's
Fees and Expenses of Litigation, with attached billing statements
(12) Special authorities relied upon by Petitioner relating to peculiar evidentiary or other
legal questions are as follows: None by Petitioner.
(13) Special authorities relied upon by Respondent relating to peculiar evidentiary or other
legal questions are as follows: None at this time by Respondent.
(14) The testimony of the following persons may be introduced by depositions:
None from Petitioner. None from Respondent.
Any objection to the depositions or questions or arguments in the depositions shall be
called to the attention of the court prior to trial
(15) The following are lists of witnesses the:
a. Petitioner will have present at trial: Petitioner.
b. Petitioner may have present at trial: Virginia Carter (Petitioner’s sister), Rebecca
O'Kelley (Petitioner’s sister). Leigh and Brad Webb, 678-494-6076. Counsel for Petitioner
will duly notify counsel for Respondent about any additional witnesses that come to light.
c. Respondent will have present at trial: Respondent.
d. Respondent may have present at trial: Heather Wright, Cheryl Delzell, Elizabeth
Overlund, Mousa Hamad, Dennis Thomas, Nancy McCloskey, Alison Bondell, Robin
Swinks, and Michael Brennan
Opposing counsel may rely on representation that the designated party will have a
witness present unless notice to the contrary is given in sufficient time prior to trial to allow
the other party to subpoena the witness or obtain his testimony by other means
)
)
M/THIS SPACE INTENTIONALLY LEFT BLANK//
Stanley Williams v. Sara Williams
Superior Court of DeKalb County
Pretrial Order
CAFN: 20FM5772
(16)
a. The possibilities of settling the case are: Poor;
b. The parties do want the case reported;
c. The cost of take-down will be paid by: Shared.
d. Other matters:
= As the Respondent resides in the State of Florida, it is requested tha this
trial take place via www.zoom.us, or be specially scheduled for a specific
date
The Parties were scheduled to mediate on April 17, 2023, but were unable
to do so as the mediator had to cancel due to illness;
The Petitioner's counsel has a leave of absence from May 24, 2023 through
June 6, 2023. The Respondent's counsel has a leave of absence from May
24, 2023 through June 5, 2023.
Submitted by:
/s/ Michael O'Hagan /s/ Gregory D. Golden
Michael O’Hagan Gregory D. Golden
GA Bar No. 550599 GA Bar No. 299542
Attorney for Petitioner Attorney for Respondent
IT IS HEREBY ORDERED that the foregoing, including the attachments thereto,
constitutes the PRE TRIAL ORDER in the above case and supersedes the pleadings
which may not be further amended except by order of the court to prevent manifest
injustice.
This day of April, 2023.
Honorable Asha F. Jackson
Chief Judge, DeKalb County Superior Court
Preview
IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA Stanley Michael Williams CAFN Petitioner 20FM5772-2 Vv. Sara Rebecca Cauthen Williams Respondent PRE TRIAL ORDER The following constitutes a Pre Trial Order entered in the above styled case after conference with counsel for the parties: (1) The name, address and phone number of the attorneys who will conduct the trial are as follows: Petitioner: Michael O’Hagan O’Hagan Law Firm LLC P.O. Box 1543 Buford, GA 30515 (404) 403-9711 ohaganmj@yahoo.com Respondent: Gregory D. Golden Kupferman & Golden 200 Ashford Center North Suite 325 Atlanta, GA 30338 (404) 924-2400 greg@kqfamilylaw.com Other: Heather Wright (Guardian ad Litem) Hastings Shadmehry Wright LLC 3650 Mansell Road, Suite 475 Alpharetta, Georgia 30022 Main office number: 770.641.8200 Fax: 770.641.8203 heather@hswlegalteam.com (2) The estimated time required for trial is: Petitioner: 1 day; Respondent: 1 day. (3) There are no motions or other matters pending for consideration by the court except as follows: None from Petitioner. None for the Respondent. (4) The jury will be qualified as to relationship with the following: N/A (5) a. All discovery has been completed, unless otherwise noted, and the court will not consider any further motions to compel discovery except for good cause shown. The parties, however, shall be permitted to take depositions of any person(s) for the preservation of evidence for use at trial. Petitioner: Discovery is ongoing; both Parties have filed requesting that the other supplement their discovery responses. b. Unless otherwise noted, the names of the parties as shown in the caption to this order are correct and complete and there is no question by any party as to the misjoinder or nonjoinder of any parties. (6) The following is the Petitioner's brief and succinct outline of the case and contentions: The Parties were married on or about May 26, 2012, separated on or about November 5, 2016, and have remained in a bona fide state of separation since that time. All real property owed by the Parties is separate property, except Petitioner requests $50,000.00 from Respondent as reimbursement for funds paid for the improvement of commercial real estate owned by Respondent. The Parties are the legal parents of one (1) Minor Child, Roman Michael Williams, male, year of birth 2013, age nine (9). Petitioner requests joint physical and joint legal custody of the Parties Minor Child; Petitioner is willing to relocate to Florida for purposes of 50/50 custody. Petitioner has extended family (to include sisters in Augusta/Columbus GA, the Minor Child’s cousins, and the Minor Child’s two [2] best friends). Should joint physical custody not be awarded, Petitioner requests joint legal custody with secondary physical custody of the Minor Child, and parenting time as follows: one (1) weekend per month (preferably any three {3] or more day weekends), rotating/split (Christmas) holidays, and during the summer break from school from the first Sunday following the release from school until the last Sunday before the resumption of school (within one [1] week of the return to school). Petitioner requests that Respondent be Ordered to do the majority of the traveling or bear the majority of any transportation costs as it was Respondent that moved the Minor Child to Florida. Petitioner requests the payment of child support in the sum pursuant to the Georgia Child Support Guidelines, with any out-of-pocket medical expenses to be divided pro rata per the income of the Parties; Petitioner is currently not employed. Petitioner requests that the cost of any private schoo! tuition be paid by the Respondent. As both Parties are able-bodied adults capable of gainful employment, neither Party should be entitled to the payment of alimony from one to the other, except where it may pertain to the payment of attorney’s fees. Petitioner requests that Respondent be responsible for the payment of attorney’s fees (sum to be determined at the conclusion of any hearing) and that Respondent be responsible for the payment of any outstanding fees owed to the Guardian ad Litem. Petitioner avers that while this matter was pending, Respondent and the Minor Child relocated to Florida in January 2021, on a temporary basis for a period of one (1) year of less; said one (1) year temporary move was nothing more than a rouse by Respondent to remove the Minor Child from Petitioner's life as Petitioner has taken up permanent residency in Florida (violation of Standing Order; no Order in place permitting Respondent and the Minor Child to relocate to Florida). For that reason, and as stated above, Petitioner requests that Respondent be Ordered to do the majority of the traveling or the majority of any costs associated with travel as it was Respondent that moved the Minor Child to Florida. Due to the length of separation between the Parties, all debts held in the name of each Party shall be paid by that Party, with the exception of Petitioner's request for the payment of attorney's fees and Guardian ad Litem. (7) The following is the Respondent's brief_and succinct outline of the case and contentions: On or about May 26, 2012, the parties were married. There is one (1) minor child as a result of this marriage, to-wit! ROMAN MICHAEL WILLIAMS, born in 2013. The parties have been separated since November 2016; since that time, the Defendant has been the primary caretaker of the minor child. On or about August 13, 2020, the Plaintiff filed the above-styled divorce action. During the pendency of this litigation, the Defendant was offered an employment opportunity in the State of Florida. The parties agreed that the Defendant could re-locate to the State of Florida with the minor child, and allow regular contact between the Plaintiff and the minor child. In January 2021, the Defendant and the minor child re-located to the State of Florida; subsequently, the Defendant has purchased a home in Punta Gorda, Florida. Following the parties’ unsuccessful mediation in October 2021, the Plaintiff asserted a claim for primary custody of the minor child. Subsequently, on or about December 21, 2021, this Honorable Court issued its ORDER APPOINTING GUARDIAN AD LITEM, in which Heather Wright was appointed, by agreement of counsel, as the Guardian ad Litem for the minor child (hereinafter sometimes referred to as the “Guardian’”). The Guardian completed an extensive investigation which included meeting with the parties, interviews with witnesses, home visits with each party (in the States of Georgia and Florida), observations of each party with the minor child, and a review of numerous documents. On or about May 3, 2022, the Guardian issued her findings and recommendations to the parties’ counsel. In pertinent part, the Guardian ad Litem found, . That the Defendant’s relocation to the State of Florida was not based on any intent to limit the Plaintiff's parenting time or to harm the Plaintiff's relationship with minor child. . That the Plaintiff has demonstrated a lot of anger and animosity toward the Defendant, which is entirely misplaced as the Defendant has made a sound decision to improve her life and financial circumstances. . That with regard to the Defendant's living arrangements, the house is nice and acceptable for the minor child’s residence. The minor child attends a good school and has a good nanny, who helps with after school care and on the weekends when the Defendant is required to work. . That the Plaintiff has been very difficult, argumentative, and has a high level of anger and animosity toward the Defendant that he shows to the minor child. The Plaintiff has mentioned conversations with the minor child that involve matters regarding the custody case that he should not be having with the minor child. . That with regard to the Plaintiff's living arrangements, the Plaintiff's current living situation is wholly unsuitable for the minor child. The Plaintiff has a makeshift “loft” in the basement of an industrial building. The minor child does not have his own room or space, sleeping in the same full/queen bed with the Plaintiff. The finished space (drywall and drop ceiling) opens into an industrial storage area full of tools and other equipment that is stored on the property. The entire “loft” spells like gasoline and other chemicals. . That the Plaintiff is actually doing the actions necessary to care for minor child. . That the Defendant needs to make some hard decisions about his living arrangements and his attitude toward the Plaintiff. . That the Plaintiff's bitterness towards the Defendant is not healthy for the minor child. The Defendant is employed as a restaurant manager with the restaurant group, Universal Joint Holdings, L.L.C. Currently, she makes approximately $120,000.00 on an annual basis; this income has varied over the past twelve (12) months as the area in which she works/lives sustained severe damage due to recent hurricanes. The Father was working at the DeKalb Farmer's Market but allegedly quit his position during the pendency of this litigation; it is unknown as to his current employment or income. Each party has separate, real property that is not subject to equitable division. (8) The issues for determination by the Court are as follows: Custody; Parenting time; Child Support; Equitable division of marital property (where applicable); Petitioner's request for attorney's fees and re-apportionment of Guardian ad Litem fees; and Respondent's request for attorney’s fees and re-apportionment of Guardian ad Litem fees. (9) Petitioner and Respondent, through their respective attorneys of record, shall exchange their updated financial affidavits five (5) days prior to trial. (10) The following facts are stipulated: - Date of marriage — May 26, 2021; = There is one (1) minor child as a result of this marriage, Roman Michael Williams, male, year of birth 2013. There is no issue as to an equitable division of personal, tangible property (except where Petitioner has asked for reimbursement for funds paid towards the improvement of Respondent’s real property) and each party shall retain what is in his/her current possession. (11) The following is a list of all documentary and physical evidence that will be tendered at the trial by the Petitioner or Respondent. Unless noted, the parties have stipulated as to the authenticity of the documents listed and the exhibits listed may be admitted without further proof of authenticity. All exhibits shall be marked by counsel prior to trial so as not to delay the trial before the jury. a. By the Petitioner: As discovery is ongoing and both Parties have requested supplemental discovery, this list may be updated. However, documents from Petitioner to be used as evidence will likely consist of the following: Texts and/or emails between Parties; Banking Records (Petitioner's or Respondent's); Tax Records (Petitioner's or Respondent's); Photographs; Attorney billing records, supporting documents regarding requests for attorney’s fees; Any and all documents as listed by Respondent; Petitioner reserves the right to amend his portion of the Pre-Trial Order by providing copies of documentary evidence not listed to the opposing party sufficiently prior to trial so as not to delay trial; Counsel for Petitioner will consult with counsel for Respondent during the exchange of updated documents in an attempt to resolve any issues concerning evidentiary issues (foundation, etc.) prior to any hearing in this matter. b. By the Respondent: Respondent's Domestic Relations Financial Affidavit and any amendments thereto; Petitioner's Domestic Relations Financial Affidavit and any amendments thereto; Letter from Petitioner to Respondent's employer, dated on or about May 16, 2022; Correspondence from the Petitioner to the minor child’s school; All Federal and state tax returns filed during the marriage of the Parties, together with all schedules, attachments and working papers; Wage and income statements for the parties including but not limited to pay stubs, W-2 forms, 1099 forms, K-1 forms, etc.; Records from and for all banking, savings, credit union, money market, brokerage and investment accounts previously and presently maintained by the parties (whether individually or jointly), including but not limited to bank statements, checkbook ledgers, canceled checks, transactions registers, Real estate sales contracts, purchase contracts, closing/settlement statements, deeds of conveyance, deeds to secure debt, deeds of trust or mortgage, photographs, videos for any real property owned by either of the parties; Credit card invoices and itemized statements Letters, emails, text messages, Facebook and other correspondence between the parties Discovery requests and responses between the parties: Documents and other tangible things responsive to discovery exchanged between the parties The Defendant reserves the right to add additional items to his respective list prior to trial, upon giving the other party reasonable notice thereof and an opportunity to examine and copy said items The Defendant reserves the right to amend her portion of the Pre-Trial Order by providing copies of documentary evidence not listed to the opposing party sufficiently prior to trial so as not to delay trial; and Statement of Gregory D. Golden Regarding Defendant's Prayer for Attorney's Fees and Expenses of Litigation, with attached billing statements (12) Special authorities relied upon by Petitioner relating to peculiar evidentiary or other legal questions are as follows: None by Petitioner. (13) Special authorities relied upon by Respondent relating to peculiar evidentiary or other legal questions are as follows: None at this time by Respondent. (14) The testimony of the following persons may be introduced by depositions: None from Petitioner. None from Respondent. Any objection to the depositions or questions or arguments in the depositions shall be called to the attention of the court prior to trial (15) The following are lists of witnesses the: a. Petitioner will have present at trial: Petitioner. b. Petitioner may have present at trial: Virginia Carter (Petitioner’s sister), Rebecca O'Kelley (Petitioner’s sister). Leigh and Brad Webb, 678-494-6076. Counsel for Petitioner will duly notify counsel for Respondent about any additional witnesses that come to light. c. Respondent will have present at trial: Respondent. d. Respondent may have present at trial: Heather Wright, Cheryl Delzell, Elizabeth Overlund, Mousa Hamad, Dennis Thomas, Nancy McCloskey, Alison Bondell, Robin Swinks, and Michael Brennan Opposing counsel may rely on representation that the designated party will have a witness present unless notice to the contrary is given in sufficient time prior to trial to allow the other party to subpoena the witness or obtain his testimony by other means ) ) M/THIS SPACE INTENTIONALLY LEFT BLANK// Stanley Williams v. Sara Williams Superior Court of DeKalb County Pretrial Order CAFN: 20FM5772 (16) a. The possibilities of settling the case are: Poor; b. The parties do want the case reported; c. The cost of take-down will be paid by: Shared. d. Other matters: = As the Respondent resides in the State of Florida, it is requested tha this trial take place via www.zoom.us, or be specially scheduled for a specific date The Parties were scheduled to mediate on April 17, 2023, but were unable to do so as the mediator had to cancel due to illness; The Petitioner's counsel has a leave of absence from May 24, 2023 through June 6, 2023. The Respondent's counsel has a leave of absence from May 24, 2023 through June 5, 2023. Submitted by: /s/ Michael O'Hagan /s/ Gregory D. Golden Michael O’Hagan Gregory D. Golden GA Bar No. 550599 GA Bar No. 299542 Attorney for Petitioner Attorney for Respondent IT IS HEREBY ORDERED that the foregoing, including the attachments thereto, constitutes the PRE TRIAL ORDER in the above case and supersedes the pleadings which may not be further amended except by order of the court to prevent manifest injustice. This day of April, 2023. Honorable Asha F. Jackson Chief Judge, DeKalb County Superior Court