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Clark County, Ohio
FILED
MAR 22 2024
Common Pleas Court
Melissa M. Tuttle, Clerk
IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO
DOMESTIC RELATIONS DIVISION
ADULT SECTION
HEATHER E. MENDOZA Case No. 24 DR 1 2 3
204 Prentice Drive
New Carlisle, OH 45344
DOB: 01/27/1982 JUDGE THOMAS J. CAPPER
Plaintiff,
-VS-
PEDRO R. MENDOZA MOTION FOR MUTUAL
Unknown RESTRAINING ORDERS
Unknown
DOB: 06/10/1988
Defendant.
Now comes the Plaintiff, through her attorney, and hereby moves this Court for a
mutual restraining order of the following:
(1) Plaintiff and Defendant are hereby restrained from striking, abusing, harassing,
stalking, threatening, or injuring the other party.
(2) Plaintiff and Defendant are hereby restrained from damaging, moving, selling,
giving away, transferring, withdrawing, disposing of, or encumbering any interest
of either party in real property, personal property, funds, accounts, business
interests, investments, or any other asset.
(3) Plaintiff and Defendant are hereby restrained from incurring debt or making any
credit card purchases on any account in the other party's name or in the parties’
joint names.
(4) Both parties are hereby restrained from terminating, modifying or changing the
beneficiaries of any life, health, automobile, or other insurance policy covering
any party, or otherwise violating.
An Affidavit in Support is attached.
Respectfully submitted,
rmit K. Lowery, #0033002
Attorney for Plaintiff
Greater Dayton Volunteer Lawyers Project
109 North Main Street, Ste. 610
Dayton, OH 45402
(937) 266-6439
tricia@gdvip.org
AFFIDAVIT IN SUPPORT
STATE OF OHIO )
) SS:
COUNTY OF CLARK )
|, Heather E. Mendoza undersigned, having been duly sworn according to law,
hereby depose and state that | am the Plaintiff in the instant action for divorce, that | have
read and reviewed the foregoing and that the facts therein are true.
1. That | am married to Pedro R. Mendoza.
2. That! am in fear that unless restrained by an order of this Court that the
Defendant will abuse, annoy, harass, threaten, intimate, menace, stalk, or
otherwise interfere with the Plaintiff throughout the pendency of these proceedings.
3. That | am in fear that unless restrained by an order of this Court the
Defendant will sell, transfer, dispose of, hypothecate, encumber, remove from the
marital premises, or otherwise affect the value of the items of personal property
acquired by either or both of the parties and now in the possession or in the
custody, or care or control of the Defendant.
Further, Affiant saith naught
Al hein ~—
Heather E. Mendoza, Plaintiff
Sworn and subscribed to before me a Notary Public on this 215 day of March, 2024.
TRICIA GRIFFIETH
Notary Public, State of Ohio
My Commission, res:
i) July 16, 20. Netdy/ Public
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Clark County, Ohio FILED MAR 22 2024 Common Pleas Court Melissa M. Tuttle, Clerk IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO DOMESTIC RELATIONS DIVISION ADULT SECTION HEATHER E. MENDOZA Case No. 24 DR 1 2 3 204 Prentice Drive New Carlisle, OH 45344 DOB: 01/27/1982 JUDGE THOMAS J. CAPPER Plaintiff, -VS- PEDRO R. MENDOZA MOTION FOR MUTUAL Unknown RESTRAINING ORDERS Unknown DOB: 06/10/1988 Defendant. Now comes the Plaintiff, through her attorney, and hereby moves this Court for a mutual restraining order of the following: (1) Plaintiff and Defendant are hereby restrained from striking, abusing, harassing, stalking, threatening, or injuring the other party. (2) Plaintiff and Defendant are hereby restrained from damaging, moving, selling, giving away, transferring, withdrawing, disposing of, or encumbering any interest of either party in real property, personal property, funds, accounts, business interests, investments, or any other asset. (3) Plaintiff and Defendant are hereby restrained from incurring debt or making any credit card purchases on any account in the other party's name or in the parties’ joint names. (4) Both parties are hereby restrained from terminating, modifying or changing the beneficiaries of any life, health, automobile, or other insurance policy covering any party, or otherwise violating. An Affidavit in Support is attached. Respectfully submitted, rmit K. Lowery, #0033002 Attorney for Plaintiff Greater Dayton Volunteer Lawyers Project 109 North Main Street, Ste. 610 Dayton, OH 45402 (937) 266-6439 tricia@gdvip.org AFFIDAVIT IN SUPPORT STATE OF OHIO ) ) SS: COUNTY OF CLARK ) |, Heather E. Mendoza undersigned, having been duly sworn according to law, hereby depose and state that | am the Plaintiff in the instant action for divorce, that | have read and reviewed the foregoing and that the facts therein are true. 1. That | am married to Pedro R. Mendoza. 2. That! am in fear that unless restrained by an order of this Court that the Defendant will abuse, annoy, harass, threaten, intimate, menace, stalk, or otherwise interfere with the Plaintiff throughout the pendency of these proceedings. 3. That | am in fear that unless restrained by an order of this Court the Defendant will sell, transfer, dispose of, hypothecate, encumber, remove from the marital premises, or otherwise affect the value of the items of personal property acquired by either or both of the parties and now in the possession or in the custody, or care or control of the Defendant. Further, Affiant saith naught Al hein ~— Heather E. Mendoza, Plaintiff Sworn and subscribed to before me a Notary Public on this 215 day of March, 2024. TRICIA GRIFFIETH Notary Public, State of Ohio My Commission, res: i) July 16, 20. Netdy/ Public