On December 19, 2008 a
Complaint,Petition
was filed
involving a dispute between
Jorgensen, Steven Charles,
and
Talkin, Mari,
for Post Judgment Action Modification Other
in the District Court of Montgomery County.
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IN THE MATTER OF THE INTHE c- —
MARRIAGE OF
STEVEN CHARLES JORGENSEN
AND
MARI ELAINE JORGENSEN
mmmmmmwcmmmmm
COURT OF
AND IN THE INTEREST OF
HANNAH LOUISE JORGENSEN
AN D
MAXWELL THOMAS JORGENSEN,
MINOR CHILDREN MONTGOMERY COUNTY, TEXAS
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. Parties
This suit is brought by STEVEN CHARLES JORGENSEN, Petitioner. MAR]
ELAINE JORGENSEN is Respondent.
3. 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.
4. Service
No service on Respondent isnecessary at this time.
5. Protective Order Statement
No protective order under title 4 of the Texas Family Code is in effect, and no application
for a protective order is pending with regard to the parties to this suit.
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6. Dates of Marriage and Separation
The parties were married on or about June 13, 1992 and ceased to live together as
husband and wife on or about May 28, 2008.
7. 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.
8. Children of the Marriage
Petitioner and Respondent are parents of the following children of this marriage who are
not under the continuing jurisdiction ol‘any other court:
Name: Hannah Louise Jorgensen
Sex: Female
Birth date: February 15, 1998
Name: Maxwell 'l'homas Jorgensen
Sex: Male
Birth date: May 5, 2002
There are no court-ordered conservatorships, court-ordered guardianships, or other court-
ordered relationships affecting the children the subject of this suit.
The children are presently covered under a health insurance policy issued through
Petitioner’s employment.
No property of consequence is owned or possessed by the children the subject of this suit.
Petitioner believes that Petitioner and Respondent will enter into a written agreement
containing provisions for conservatorship and support ofthe children. lfsuch an agreement is not
made, Petitioner requests the Court to make orders for conservatorship and support of the
children
Petitioner and Respondent. on final hearing. should be appointed joint managing
conservators, with all the rights and duties of a parent conservator.
9. Division of(.‘ommunity Properly
Petitioner believes Petitioner and Respondent will enter into an agreement for the
division of their estate. If such an agreement ismade, 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 deemsjust and right. as provided by law.
10 Prayer
Petitioner prays that the Court grant a divorce and all other relief requested in this
petition.
Steven .
arles Jorgensen
Pro Se
99 Sunlit Grove Street
The Woodlands, TX 77382
Home: 280-298-5396
Work: 281-719-4525
To the best of my knowledge. Respondent is not represented by counsel in the matter
made the basis of this suit.
~
E
Steven Charles Jorgensigq
Document Filed Date
December 19, 2008
Case Filing Date
December 19, 2008
Category
Post Judgment Action Modification Other
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