On June 07, 2023 a
Complaint,Petition
was filed
involving a dispute between
Britton, Paula Beth,
and
Morgan, Richard Leigh,
for Divorce - No Children
in the District Court of Fort Bend County.
Preview
Filed
6/7/2023 4:39 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Jeanette Puga
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
NO. _ 23-DCV-304817
IN THE MATTER OF IN THE DISTRICT COURT OF
THE MARRIAGE OF
FORT BEND COUNTY, TEXAS
PAULA BETH BRITTON
AND Fort Bend County - 328th Judicial District Court
RICHARD LEIGH MORGAN TH JUDICIAL DISTRICT
ORIGINAL PETITION FOR DIVORCE
1 Discovery Level
Discovery in this case is intended to be conducted under level 2 of rule 190 of the
Texas Rules of Civil Procedure.
2 Objection to Assignment of Case to Associate Judge
Petitioner objects to the assignment of this matter to an associate judge for a trial
on the merits or presiding at a jury trial.
3 Parties
This suit is brought by PAULA BETH BRITTON, Petitioner. The last three numbers
of Petitioner's driver's license number arelfllli’he last three numbers of Petitioner's
Social Security number are
RICHARD LEIGH MORGAN is Respondent.
4. Domicile
Petitioner has been a domiciliary of Texas for the preceding six-month period and
a resident of this county for the preceding ninety-day period.
5. Service
No service on Respondent is necessary at this time.
Protective Order Statement
No protective order under title 4 of the Texas Family Code, protective order under
subchapter A of chapter 7B of the Texas Code of Criminal Procedure, or order for
emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in
effect in regard to a party to this suit or a child of a party to this suit, and no application
BRITTON* Original Petition for Divorce Page 1 of 3
for any such order is pending.
7 Dates of Marriage and Separation
The parties were married on or about September 15, 2018 and ceased to live
together as spouses on or about April 1, 2023.
8 Grounds for Divorce
The marriage has become insupportable because of discord or conflict of
personalities between Petitioner and Respondent that destroys the legitimate ends of the
marriage relationship and prevents any reasonable expectation of reconciliation.
9 Children of the Marriage
There is no child born or adopted of this marriage, and none is expected.
10. Division of Community Property
Petitioner believes Petitioner and Respondent will enter into an agreement for the
division of their estate. If such an agreement is made, Petitioner requests the Court to
approve the agreement and divide their estate in a manner consistent with the agreement.
If such an agreement is not made, Petitioner requests the Court to divide their estate in a
manner that the Court deems just and right, as provided by law.
11. Separate Property
Petitioner owns certain separate property that is not part of the community estate
of the parties, and Petitioner requests the Court to confirm that separate property as
Petitioner's separate property and estate.
12. Attorney’s Fees, Expenses, Costs, and Interest
It was necessary for Petitioner to secure the services of Susan Myres, Myres &
Associates, PLLC, a licensed attorney, to prepare and prosecute this suit. In the event
the parties cannot reach an agreement on the terms of divorce and judgment for
attorney's fees, expenses, and costs through trial and appeal should be granted against
Respondent and in favor of Petitioner for the use and benefit of Petitioner's attorney; or,
in the alternative, Petitioner requests that reasonable attorney's fees, expenses, and
costs through trial and appeal be taxed as costs and be ordered paid directly to
Petitioner's attorney, who may enforce the order in the attorney's own name. Petitioner
requests postjudgment interest as allowed by law.
BRITTON* Original Petition for Divorce Page 2 of 3
13. Prayer
Petitioner prays that citation and notice issue as required by law and that the Court
grant a divorce and all other relief requested in this petition.
Petitioner prays for attorney's fees, expenses, costs, and interest as requested
above.
Petitioner prays for general relief.
MYRES & AS TES, PLLC
ve o
a 7o _— re
ee
AN MYRES
e Bar No. 1476680!
ine Greenway Plaza, Ste. 450
Houston, TX 77046
Tel: 713-622-1600
Fax: 713-622-1610
service@myresfamilylaw.com (E-Service Only)
smyres@myresfamilylaw.com (Non-Service
Emails Only)
BRITTON* Original Petition for Divorce Page 3 of 3
Document Filed Date
June 07, 2023
Case Filing Date
June 07, 2023
Category
Divorce - No Children
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Filed 6/7/2023 4:39 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Jeanette Puga NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. _ 23-DCV-304817 IN THE MATTER OF IN THE DISTRICT COURT OF THE MARRIAGE OF FORT BEND COUNTY, TEXAS PAULA BETH BRITTON AND Fort Bend County - 328th Judicial District Court RICHARD LEIGH MORGAN TH JUDICIAL DISTRICT ORIGINAL PETITION FOR DIVORCE 1 Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2 Objection to Assignment of Case to Associate Judge Petitioner objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. 3 Parties This suit is brought by PAULA BETH BRITTON, Petitioner. The last three numbers of Petitioner's driver's license number arelfllli’he last three numbers of Petitioner's Social Security number are RICHARD LEIGH MORGAN is Respondent. 4. Domicile Petitioner has been a domiciliary of Texas for the preceding six-month period and a resident of this county for the preceding ninety-day period. 5. Service No service on Respondent is necessary at this time. Protective Order Statement No protective order under title 4 of the Texas Family Code, protective order under subchapter A of chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party to this suit or a child of a party to this suit, and no application BRITTON* Original Petition for Divorce Page 1 of 3 for any such order is pending. 7 Dates of Marriage and Separation The parties were married on or about September 15, 2018 and ceased to live together as spouses on or about April 1, 2023. 8 Grounds for Divorce The marriage has become insupportable because of discord or conflict of personalities between Petitioner and Respondent that destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation of reconciliation. 9 Children of the Marriage There is no child born or adopted of this marriage, and none is expected. 10. Division of Community Property Petitioner believes Petitioner and Respondent will enter into an agreement for the division of their estate. If such an agreement is made, Petitioner requests the Court to approve the agreement and divide their estate in a manner consistent with the agreement. If such an agreement is not made, Petitioner requests the Court to divide their estate in a manner that the Court deems just and right, as provided by law. 11. Separate Property Petitioner owns certain separate property that is not part of the community estate of the parties, and Petitioner requests the Court to confirm that separate property as Petitioner's separate property and estate. 12. Attorney’s Fees, Expenses, Costs, and Interest It was necessary for Petitioner to secure the services of Susan Myres, Myres & Associates, PLLC, a licensed attorney, to prepare and prosecute this suit. In the event the parties cannot reach an agreement on the terms of divorce and judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Respondent and in favor of Petitioner for the use and benefit of Petitioner's attorney; or, in the alternative, Petitioner requests that reasonable attorney's fees, expenses, and costs through trial and appeal be taxed as costs and be ordered paid directly to Petitioner's attorney, who may enforce the order in the attorney's own name. Petitioner requests postjudgment interest as allowed by law. BRITTON* Original Petition for Divorce Page 2 of 3 13. Prayer Petitioner prays that citation and notice issue as required by law and that the Court grant a divorce and all other relief requested in this petition. Petitioner prays for attorney's fees, expenses, costs, and interest as requested above. Petitioner prays for general relief. MYRES & AS TES, PLLC ve o a 7o _— re ee AN MYRES e Bar No. 1476680! ine Greenway Plaza, Ste. 450 Houston, TX 77046 Tel: 713-622-1600 Fax: 713-622-1610 service@myresfamilylaw.com (E-Service Only) smyres@myresfamilylaw.com (Non-Service Emails Only) BRITTON* Original Petition for Divorce Page 3 of 3