On November 12, 2015 a
Complaint,Petition
was filed
involving a dispute between
Attorney General Of Texas,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
and
Fort Bend Independent School District,
Vingle, Lynae,
Smith, Carlos Allen,
Smith, Tamisika Kofi,
for Divorce - With Children
in the District Court of Fort Bend County.
Preview
Filed
4112/2016 1:42:10 PM
Annie Rebecca Elliott
District Clerk
Fort Bend County, Texas
Brittany Lopez
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
CAUSE NO. 15-DCV-227783
IN THE [YER OF THE IN THE DISTRICT COURT OF
MAR G OF
CAR § SMITH AND AD SIKA
SMITA
AND IN IN co FORT BEND COUNTY, TEXAS
§ 328" JUDICIAL DISTRICT COURT
FIRST AME! L PETITION FOR DIVORCE
Discovery Level
Discovery in this case is intended to be dais dt und evel 2 of rule 190 of the Texas
Rules of Civil Procedure.
2. Parties
This suit is brought by Carlos Smith, hefeinafte: imes “Petitioner”). The last three
numbers of Petitioner’s Texas driverg weense 11 ws are he last three numbers of
Petitioner’s Social Security number are amisika ith @ nafie 8 etimes “Respondent”)
is Respondent.
3. Domicile ©
Petitioner and Respondent have been a domiciliary of exasfi receding six-month
period and a resident of this county for the preceding ninety-day peri:
4
Coos
Service
Respondent made an appearance in this cause through her attorn’ pd may be
served with this petition in accordance with Rule 21 and 21a of the Texas Rule of Cr Proced
5. Dates of Marriage and Separation
The parties were married on or about May 20, 2011 and ceased to live together as husband
and wife, on or about the filing of this cause.
6. Grounds for Divorce
The ma age, as become insupportable because of discord or conflict of personalities
between Pet jong and Respondent that destroys the legitimate ends of the marriage relationship
and prevg $2 fy reasonable expectation of reconciliation.
‘otective Order S) fempnt
O\prote: € ord t under title 4 of the Texas Family Code is in effect, and no application
for a pro ctive Order8 pendipewith regard to the parties to this suit.
Children of the age
Petitioner aad Responde: s/parents of the following children of this marriage who are not
under the continuing jurisdi of any other court:
are hereinafter
Ca
referred to sometimes as “children”.
There are no court-ordered conservatorships, cot
ordered relationships affecting the children the subject of this gently
9. Medical Insurance Information Regarding the Child
dei
Information required by section 154.181(b) of the Texas Family Go avided hdrein as
follows: Private health insurance is available for the child through the Pi itil g nt and
the child is insured through said private health insurance. The cost 0 iunx for s:
insurance will be included in the parties’ financial information sheets generated or exChanged
temporary orders hearing and such is intended as a supplement hereto.
10. Children’s Property
No property of consequence is owned or possessed by the children the subject of this suit.
il. Conservatory p, Support, and Possession and Access
Petitj@her Melieves that Petitioner and Respondent will enter into a written agreement
containing provisions for conservatorship of, possession of, access to, and support of the children. If
such. agréement is not mad Petitioner requests the Court to make orders for conservatorship of,
posses sign of, access to, a &support of the children.
Petitioner tid
Respondent, on final hearing, should be appointed joint managing
conservators W e right ind duties of a parent conservator accordingly. The residence of the
children shottdé restricted toa-pa icular area- namely Fort Bend County, Texas.
12. Division of Commtunity Property
Petitioner believes Pet ong and Respondent will enter into an agreement for the division of
their estate. If such an agy de
it is nade. etitioner requests the Court to approve the agreement
and divide their estate i prannes Onsisten ‘ith the agreement. If such an agreement is not made,
Petitioner requests the Court to Aivid stat © in a mamner that the Court deems just and right,
as provided by law.
Petitioner should be awatdethad propsrtior @ parties’ estate for the following
reasons, including but not limited to
community indebtedp fd liabili
tax consequences of the divi pf propert;
increase in value of separdte prop; ‘ough community efforts by time,
talent, labor, and effort;
reimbursement;
attorney’s fees to be paid:
the size and nature of the separate estate pous rfid
8 creation of community property by the efforts. thereok\o pouses
13. Reimbursement
Petitioner requests the Court to reimburse the community estate for
by the community estate for the benefit of Respondent’s separate estate. expend
resulted in a direct benefit to Respondent’s separate estate. The community teh: been
adequately compensated for or benefited from the expenditure of those funds or asset anda failure
by the Court to allow reimbursement to the community estate will result in an unjus' ichment of
Respondent’s separate estate at the expense of the community estate.
Petitioner requests the Court to reimburse Petitioner’s separate estate for funds or assets
expended by Petitioner’s separate estate for the benefit of Respondent’s separate estate. Those
expenditures res ited, a direct benefit to Respondent’s separate estate. Petitioner’s separate estate
has not bee: ddequ fately compensated for or benefited from the expenditure of those funds or assets.
and a fa re b the Court to allow reimbursement to Petitioner’s separate estate will result in an
unjust énrj ment of Respond yt’s separate estate at the expense of Petitioner’s separate estate.
titioner requests ‘ourt to reimburse the community estate for funds or assets expended
by the\gotymunity ate Or payment of unsecured liabilities of Respondent’s separate estate. Those
expendi este ted ih a direst benefit to Respondent’s separate estate. The community estate has
not been ad cyt fy compertsated for or benefited from the expenditure of those funds or assets, and
a failure by the Co 0 2 On eq bursement to the community estate will result in an unjust
enrichment of Respofndg 8 separate ¢state at the expense of the community estate.
Petitioner requests the to reimburse Petitioner’s separate estate for funds or assets
expended by Petitioner’s eparate er payment of unsecured liabilities of Respondent’s
separate estate. Those é KD dituyes re ed a direct benefit to Respondent’s separate estate.
Petitioner’s separate estate hi been Ade\yuately compensated for or benefited from the
expenditure of those funds o} assets. and hilure by the Court to allow reimbursement to
Petitioner’s separate estate will yes It in an Us envi! me of Respondent’s separate estate at the
expense of Petitioner’s separate dxtal
The community estate has expended, or Se to ake capital improvements on
property claimed by Respondent as separa property, ing set claim for reimbursement in
favor of the community estate and against Respond S\S par ate. Those expenditures
resulted in a direct benefit to Respondent’s s pat ati cféstate. T cothmunity estate has not been
adequately compensated for or benefited from eg ‘pendity tose funds or assets, and a failure
by the Court to allow reimbursement to the community 2 ill result in an unjust enrichment of
Respondent’s separate estate at the expense of the cop ity estate
Petitioner’s separate estate has expended funds or dss¢ to make)capital improvements on
property claimed by Respondent as separate property, givif g{rise to a cla for re irsement in
favor of Petitioner’s separate estate and against Responde: separate estate, ose expenditures
resulted in a direct benefit to Respondent’s separate estate. Pé Joners sep state has not been
adequately compensated for or benefited from the expenditure of those, Or asse and a failure
by the Court to allow reimbursement to Petitioner’s separate will re ma unjust
enrichment of Respondent’s separate estate at the expense of Petition 8s parate estate
Respondent is or was obligated on debt(s) which may have he thduying the
marriage for the acquisition of, or capital improvements to, property ed by 1en(s)
property claimed by the Respondent as separate property. The community estate ‘pended
or assets for payment of those debt(s). Those expenditures have resulted in o/ reduchis the
principal of those debt(s), giving rise to a claim for reimbursement in favor of the com pity estate
and against Respondent’s separate estate. Those expenditures resulted in a die benefit to
Respondent’s separate estate. The community estate has not been adequately compensated for or
benefited from the expenditure of those funds or assets, and a failure by the Court to allow
reimbursement to the community estate will result in an unjust enrichment of Respondent’s separate
estate at the expens. gf the community estate:
Resporfde: is or was obligated on debt(s) which may been secured by a lien on property
claimed b Re pondent as separate property. Petitioner’s separate estate has expended funds or
assets or Yayment of those debt(s). Those expenditures have resulted in the reduction of the
prineypal/of those debt(s). ing rise to a claim for reimbursement in favor of Petitioner’s separate
estate and against Respofidept’s separate estate. Petitioner’s separate estate has not been adequately
compensat d forof beng ited from the expenditure of those funds or assets, and a failure by the
Court tOallov SimbufsementAo Petitioner’s separate estate will result in an unjust enrichment of
Respondent parate esta Ahe expense of Petitioner’s separate estate.
14. Notice
Notice is provided purs to Rule 193.7 of the Texas Rules of Civil Procedure that any
document produced by th ok Onde ponse to written discovery will be used at trial or any
pretrial proceeding.
15. Attorney’s Fees, Expen. es, interest
It was necessary for Pewitid 0 se ure es\of Robert D. Franks, a licensed
he Sorv
attorney, to prepare and prosecute “it. To
Document Filed Date
April 12, 2016
Case Filing Date
November 12, 2015
Category
Divorce - With Children
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Filed 4112/2016 1:42:10 PM Annie Rebecca Elliott District Clerk Fort Bend County, Texas Brittany Lopez NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSE NO. 15-DCV-227783 IN THE [YER OF THE IN THE DISTRICT COURT OF MAR G OF CAR § SMITH AND AD SIKA SMITA AND IN IN co FORT BEND COUNTY, TEXAS § 328" JUDICIAL DISTRICT COURT FIRST AME! L PETITION FOR DIVORCE Discovery Level Discovery in this case is intended to be dais dt und evel 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Parties This suit is brought by Carlos Smith, hefeinafte: imes “Petitioner”). The last three numbers of Petitioner’s Texas driverg weense 11 ws are he last three numbers of Petitioner’s Social Security number are amisika ith @ nafie 8 etimes “Respondent”) is Respondent. 3. Domicile © Petitioner and Respondent have been a domiciliary of exasfi receding six-month period and a resident of this county for the preceding ninety-day peri: 4 Coos Service Respondent made an appearance in this cause through her attorn’ pd may be served with this petition in accordance with Rule 21 and 21a of the Texas Rule of Cr Proced 5. Dates of Marriage and Separation The parties were married on or about May 20, 2011 and ceased to live together as husband and wife, on or about the filing of this cause. 6. Grounds for Divorce The ma age, as become insupportable because of discord or conflict of personalities between Pet jong and Respondent that destroys the legitimate ends of the marriage relationship and prevg $2 fy reasonable expectation of reconciliation. ‘otective Order S) fempnt O\prote: € ord t under title 4 of the Texas Family Code is in effect, and no application for a pro ctive Order8 pendipewith regard to the parties to this suit. Children of the age Petitioner aad Responde: s/parents of the following children of this marriage who are not under the continuing jurisdi of any other court: are hereinafter Ca referred to sometimes as “children”. There are no court-ordered conservatorships, cot ordered relationships affecting the children the subject of this gently 9. Medical Insurance Information Regarding the Child dei Information required by section 154.181(b) of the Texas Family Go avided hdrein as follows: Private health insurance is available for the child through the Pi itil g nt and the child is insured through said private health insurance. The cost 0 iunx for s: insurance will be included in the parties’ financial information sheets generated or exChanged temporary orders hearing and such is intended as a supplement hereto. 10. Children’s Property No property of consequence is owned or possessed by the children the subject of this suit. il. Conservatory p, Support, and Possession and Access Petitj@her Melieves that Petitioner and Respondent will enter into a written agreement containing provisions for conservatorship of, possession of, access to, and support of the children. If such. agréement is not mad Petitioner requests the Court to make orders for conservatorship of, posses sign of, access to, a &support of the children. Petitioner tid Respondent, on final hearing, should be appointed joint managing conservators W e right ind duties of a parent conservator accordingly. The residence of the children shottdé restricted toa-pa icular area- namely Fort Bend County, Texas. 12. Division of Commtunity Property Petitioner believes Pet ong and Respondent will enter into an agreement for the division of their estate. If such an agy de it is nade. etitioner requests the Court to approve the agreement and divide their estate i prannes Onsisten ‘ith the agreement. If such an agreement is not made, Petitioner requests the Court to Aivid stat © in a mamner that the Court deems just and right, as provided by law. Petitioner should be awatdethad propsrtior @ parties’ estate for the following reasons, including but not limited to community indebtedp fd liabili tax consequences of the divi pf propert; increase in value of separdte prop; ‘ough community efforts by time, talent, labor, and effort; reimbursement; attorney’s fees to be paid: the size and nature of the separate estate pous rfid 8 creation of community property by the efforts. thereok\o pouses 13. Reimbursement Petitioner requests the Court to reimburse the community estate for by the community estate for the benefit of Respondent’s separate estate. expend resulted in a direct benefit to Respondent’s separate estate. The community teh: been adequately compensated for or benefited from the expenditure of those funds or asset anda failure by the Court to allow reimbursement to the community estate will result in an unjus' ichment of Respondent’s separate estate at the expense of the community estate. Petitioner requests the Court to reimburse Petitioner’s separate estate for funds or assets expended by Petitioner’s separate estate for the benefit of Respondent’s separate estate. Those expenditures res ited, a direct benefit to Respondent’s separate estate. Petitioner’s separate estate has not bee: ddequ fately compensated for or benefited from the expenditure of those funds or assets. and a fa re b the Court to allow reimbursement to Petitioner’s separate estate will result in an unjust énrj ment of Respond yt’s separate estate at the expense of Petitioner’s separate estate. titioner requests ‘ourt to reimburse the community estate for funds or assets expended by the\gotymunity ate Or payment of unsecured liabilities of Respondent’s separate estate. Those expendi este ted ih a direst benefit to Respondent’s separate estate. The community estate has not been ad cyt fy compertsated for or benefited from the expenditure of those funds or assets, and a failure by the Co 0 2 On eq bursement to the community estate will result in an unjust enrichment of Respofndg 8 separate ¢state at the expense of the community estate. Petitioner requests the to reimburse Petitioner’s separate estate for funds or assets expended by Petitioner’s eparate er payment of unsecured liabilities of Respondent’s separate estate. Those é KD dituyes re ed a direct benefit to Respondent’s separate estate. Petitioner’s separate estate hi been Ade\yuately compensated for or benefited from the expenditure of those funds o} assets. and hilure by the Court to allow reimbursement to Petitioner’s separate estate will yes It in an Us envi! me of Respondent’s separate estate at the expense of Petitioner’s separate dxtal The community estate has expended, or Se to ake capital improvements on property claimed by Respondent as separa property, ing set claim for reimbursement in favor of the community estate and against Respond S\S par ate. Those expenditures resulted in a direct benefit to Respondent’s s pat ati cféstate. T cothmunity estate has not been adequately compensated for or benefited from eg ‘pendity tose funds or assets, and a failure by the Court to allow reimbursement to the community 2 ill result in an unjust enrichment of Respondent’s separate estate at the expense of the cop ity estate Petitioner’s separate estate has expended funds or dss¢ to make)capital improvements on property claimed by Respondent as separate property, givif g{rise to a cla for re irsement in favor of Petitioner’s separate estate and against Responde: separate estate, ose expenditures resulted in a direct benefit to Respondent’s separate estate. Pé Joners sep state has not been adequately compensated for or benefited from the expenditure of those, Or asse and a failure by the Court to allow reimbursement to Petitioner’s separate will re ma unjust enrichment of Respondent’s separate estate at the expense of Petition 8s parate estate Respondent is or was obligated on debt(s) which may have he thduying the marriage for the acquisition of, or capital improvements to, property ed by 1en(s) property claimed by the Respondent as separate property. The community estate ‘pended or assets for payment of those debt(s). Those expenditures have resulted in o/ reduchis the principal of those debt(s), giving rise to a claim for reimbursement in favor of the com pity estate and against Respondent’s separate estate. Those expenditures resulted in a die benefit to Respondent’s separate estate. The community estate has not been adequately compensated for or benefited from the expenditure of those funds or assets, and a failure by the Court to allow reimbursement to the community estate will result in an unjust enrichment of Respondent’s separate estate at the expens. gf the community estate: Resporfde: is or was obligated on debt(s) which may been secured by a lien on property claimed b Re pondent as separate property. Petitioner’s separate estate has expended funds or assets or Yayment of those debt(s). Those expenditures have resulted in the reduction of the prineypal/of those debt(s). ing rise to a claim for reimbursement in favor of Petitioner’s separate estate and against Respofidept’s separate estate. Petitioner’s separate estate has not been adequately compensat d forof beng ited from the expenditure of those funds or assets, and a failure by the Court tOallov SimbufsementAo Petitioner’s separate estate will result in an unjust enrichment of Respondent parate esta Ahe expense of Petitioner’s separate estate. 14. Notice Notice is provided purs to Rule 193.7 of the Texas Rules of Civil Procedure that any document produced by th ok Onde ponse to written discovery will be used at trial or any pretrial proceeding. 15. Attorney’s Fees, Expen. es, interest It was necessary for Pewitid 0 se ure es\of Robert D. Franks, a licensed he Sorv attorney, to prepare and prosecute “it. To