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IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
SHAWNA LAWRENCE, )
)
Petitioner, ) CIVIL ACTION FILE NUMBER:
)
and )
)
SHAWN LAWRENCE, )
)
Respondent. )
PETITION FOR DIVORCE
COMES NOW SHAWNA LAWRENCE, Petitioner in the above-styled action (“Petitioner”), who by
and through her undersigned counsel submits this Petition for Divorce, and shows this Court the following:
1.
Petitioner is a resident of the state of Georgia and has been for more than Six (6) months prior to the
filing the instant Petition for Divorce, is sui juris, and is entitled to bring and maintain this action.
2.
Respondent is a resident of Dekalb County, Georgia, and is subject to the jurisdiction of this Court.
3.
The parties hereto are Husband and Wife, having married on or about March 16, 2013.
4.
The parties hereto separated on or about April 12, 2024, and are living in a bona fide state of
separation with no hope of reconciliation.
5.
There are no minor children born as issue of this marriage, and none are expected.
6.
Petitioner is entitled to a divorce on the grounds that the marriage is irretrievably broken as
Shawna Lawrence v. Shawn Lawrence
CAFN
Petition for Divorce
1
contemplated by O.C.G.A. §19-5-3 (13). Petitioner reserves the right to amend to add additional or alternative
grounds, should same become reasonable and appropriate.
7.
During the course of the marriage, the parties have acquired some assets, tangible and intangible
including but not limited to cash, checking savings, and various other financial accounts, cars, and personal
property, and it is right, just, and proper that same be equitably divided on a temporary and permanent basis.
8.
During the course of the marriage, the parties have acquired certain debts and obligations, both
individually and jointly, it is right, just, and proper that same be equitably apportioned on a temporary and
permanent basis.
9.
It is right, just, and proper that any pre- or otherwise non-marital property, debts, or obligations not
included in the marital estate should be recognized by the Court and assigned to the appropriate party
accordingly.
10.
Petitioner requests that her legal name be returned to her maiden/prior name, to wit: Shawna
Hunter.
11.
With regard to the transferring or other disposition of property after the filing of a petition for divorce,
Petitioner shows that O.C.G.A. § 19-5-7 provides in pertinent part:
After a petition for divorce has been filed, no transfer of property by either party, except
a bona fide transfer in payment of preexisting debts, shall pass title so as to avoid the vesting
thereof according to the final verdict of the jury in the case.
Further, O.C.G.A. § 19-6-1(e) provides as follows:
Shawna Lawrence v. Shawn Lawrence
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Petition for Divorce
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Pending final determination by the court of the right to either party to alimony, neither
party shall make any substantial change in the assets of the party’s estate except in the
course of ordinary business affairs and except for bona fide transfers of value.
Petitioner insists that each party comply with the foregoing statutes in all respects, and Respondent
is hereby specifically put on notice of such law and of the requirement of strict compliance therewith.
12.
Petitioner has retained the services of an attorney in this matter and is entitled to attorneys’ fees and
expenses related to litigation, on a temporary and permanent basis, pursuant to O.C.G.A. § 19-6-2 and other
relevant Georgia law.
13.
Petitioner shall, in good faith, attempt to reach an Agreement resolving all matters and controversies
between the parties. If properly executed by both parties, Petitioner respectfully requests that this Court
approve and make said Agreement an order of this Court.
WHEREFORE, Petitioner prays:
a) That this Petition be filed, read, and considered;
b) That the Standing Order of this Court issue, temporarily restraining and enjoining the parties and
their agents from selling, encumbering, hiding, dissipating, contracting to sell, removing from the
jurisdiction of this Court, concealing, or otherwise disposing of any of the property or assets belonging
to the parties, or either of them, except in the ordinary course of business, pending the final resolution
of this case;
c) That a Rule Nisi issue, directing and commanding the Respondent to appear and show cause why
Petitioner’s prayers for relief should not be granted;
d) That Petitioner be granted a total divorce, that is a divorce a vinculo matrimonii, from Respondent;
e) That any pre- or otherwise non-marital property be recognized and assigned to the respective party
on a temporary and permanent basis;
f) That there be an equitable division of marital property of the parties on a temporary and permanent
basis;
g) That there be an equitable allotment of the various debts of the parties on a temporary and
permanent basis;
Shawna Lawrence v. Shawn Lawrence
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h) That Petitioner be awarded reasonable attorney’s fees pursuant to O.C.G.A. § 19-6-2 and other
relevant Georgia law;
i) That any Agreement executed by the parties be incorporated into the Final Judgment of this Court;
and
j) That Petitioner have any such additional relief as the Court may find right, just, and proper.
Respectfully submitted this 15th May
day of ____________, 2024.
THE SIEMON LAW FIRM, P.C.
Corporate Square Breona J. Ward
347 Dahlonega Street Georgia Bar No. 762445
Cumming, Georgia 30040 Attorneys for Petitioner
(770) 521-4316 (t)
bward@siemonlaw.com
Shawna Lawrence v. Shawn Lawrence
CAFN
Petition for Divorce
4
Preview
IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA SHAWNA LAWRENCE, ) ) Petitioner, ) CIVIL ACTION FILE NUMBER: ) and ) ) SHAWN LAWRENCE, ) ) Respondent. ) PETITION FOR DIVORCE COMES NOW SHAWNA LAWRENCE, Petitioner in the above-styled action (“Petitioner”), who by and through her undersigned counsel submits this Petition for Divorce, and shows this Court the following: 1. Petitioner is a resident of the state of Georgia and has been for more than Six (6) months prior to the filing the instant Petition for Divorce, is sui juris, and is entitled to bring and maintain this action. 2. Respondent is a resident of Dekalb County, Georgia, and is subject to the jurisdiction of this Court. 3. The parties hereto are Husband and Wife, having married on or about March 16, 2013. 4. The parties hereto separated on or about April 12, 2024, and are living in a bona fide state of separation with no hope of reconciliation. 5. There are no minor children born as issue of this marriage, and none are expected. 6. Petitioner is entitled to a divorce on the grounds that the marriage is irretrievably broken as Shawna Lawrence v. Shawn Lawrence CAFN Petition for Divorce 1 contemplated by O.C.G.A. §19-5-3 (13). Petitioner reserves the right to amend to add additional or alternative grounds, should same become reasonable and appropriate. 7. During the course of the marriage, the parties have acquired some assets, tangible and intangible including but not limited to cash, checking savings, and various other financial accounts, cars, and personal property, and it is right, just, and proper that same be equitably divided on a temporary and permanent basis. 8. During the course of the marriage, the parties have acquired certain debts and obligations, both individually and jointly, it is right, just, and proper that same be equitably apportioned on a temporary and permanent basis. 9. It is right, just, and proper that any pre- or otherwise non-marital property, debts, or obligations not included in the marital estate should be recognized by the Court and assigned to the appropriate party accordingly. 10. Petitioner requests that her legal name be returned to her maiden/prior name, to wit: Shawna Hunter. 11. With regard to the transferring or other disposition of property after the filing of a petition for divorce, Petitioner shows that O.C.G.A. § 19-5-7 provides in pertinent part: After a petition for divorce has been filed, no transfer of property by either party, except a bona fide transfer in payment of preexisting debts, shall pass title so as to avoid the vesting thereof according to the final verdict of the jury in the case. Further, O.C.G.A. § 19-6-1(e) provides as follows: Shawna Lawrence v. Shawn Lawrence CAFN Petition for Divorce 2 Pending final determination by the court of the right to either party to alimony, neither party shall make any substantial change in the assets of the party’s estate except in the course of ordinary business affairs and except for bona fide transfers of value. Petitioner insists that each party comply with the foregoing statutes in all respects, and Respondent is hereby specifically put on notice of such law and of the requirement of strict compliance therewith. 12. Petitioner has retained the services of an attorney in this matter and is entitled to attorneys’ fees and expenses related to litigation, on a temporary and permanent basis, pursuant to O.C.G.A. § 19-6-2 and other relevant Georgia law. 13. Petitioner shall, in good faith, attempt to reach an Agreement resolving all matters and controversies between the parties. If properly executed by both parties, Petitioner respectfully requests that this Court approve and make said Agreement an order of this Court. WHEREFORE, Petitioner prays: a) That this Petition be filed, read, and considered; b) That the Standing Order of this Court issue, temporarily restraining and enjoining the parties and their agents from selling, encumbering, hiding, dissipating, contracting to sell, removing from the jurisdiction of this Court, concealing, or otherwise disposing of any of the property or assets belonging to the parties, or either of them, except in the ordinary course of business, pending the final resolution of this case; c) That a Rule Nisi issue, directing and commanding the Respondent to appear and show cause why Petitioner’s prayers for relief should not be granted; d) That Petitioner be granted a total divorce, that is a divorce a vinculo matrimonii, from Respondent; e) That any pre- or otherwise non-marital property be recognized and assigned to the respective party on a temporary and permanent basis; f) That there be an equitable division of marital property of the parties on a temporary and permanent basis; g) That there be an equitable allotment of the various debts of the parties on a temporary and permanent basis; Shawna Lawrence v. Shawn Lawrence CAFN Petition for Divorce 3 h) That Petitioner be awarded reasonable attorney’s fees pursuant to O.C.G.A. § 19-6-2 and other relevant Georgia law; i) That any Agreement executed by the parties be incorporated into the Final Judgment of this Court; and j) That Petitioner have any such additional relief as the Court may find right, just, and proper. Respectfully submitted this 15th May day of ____________, 2024. THE SIEMON LAW FIRM, P.C. Corporate Square Breona J. Ward 347 Dahlonega Street Georgia Bar No. 762445 Cumming, Georgia 30040 Attorneys for Petitioner (770) 521-4316 (t) bward@siemonlaw.com Shawna Lawrence v. Shawn Lawrence CAFN Petition for Divorce 4