On October 30, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Mcconnell, Carrie Ann,
and
Mcconnell, Stephen Lee,
for Divorce without Children
in the District Court of Denton County.
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On January 2, 2018, this Court held a hearing on temporary orders. At the hearing,
Stephen Lee McConnnell, Respondent, represented that he paid debts with $66,000.00
that he removed from the parties’ joint accounts at the time this proceeding was filed
This Court ordered Mr. McConnell to return funds that were in his possession, which
was approximately $30,000.00. The funds were restricted and to be only used to pay
Throughout this divorce proceeding, Mr. McConnell has represented that he has limited
income and that there are no available funds to pay attorney’s fees. In fact, he ha
On or about August 27, 2018, Mr. McConnell produced previous undisclosed bank
records. These records suggest that Mr. McConnell is misrepresenting his income and
January 1, 2018, Mr. McConnell has income in the approximate amount of
$89,000.00. Ms. McConnell works 35 hours per week for Frisco ISD at a rate of $10.00
has insufficient funds to pay both her monthly living expenses and also pay
torney’s fees in her ongoing representation.
Petitioner has had to borrow funds in order to pay her attorney’s fees. Through July
31, 2018, Mr. McConnell has paid his attorneys approximately $35,000.00. Ms.
McConnell has paid her attorney approximately $
Petitioner needs to take the Responden s deposition, but does not have the funds to
pay the attorney and court reporter. Respondent has had the opportunity to depose
Petitioner.
Significant and reasonable fees and expenses have been and will continue to be incurred
in representing Petitioner’s interest. Petitioner requests that Respondent be required to
pay attorney’s fees to Counsel for Petition equal to those paid by Respondent to his
attorney of record.
Petitioner request that Respondent be ordered to pay Petitioner’s attorney the sum of
$13,600.00, which is the differences of the fees as of July 31, 2018 that each party has
incurred. Further, Petitioner requests that for each payment made by Respondent to his
attorney of record after July 31, 2018, a contemporaneous and equal amount be made
by Respondent to Petitioner’s attorney of record.
Petitioner prays that the Court grant this Motion and for such other and further relief to
which Petitioner may be entitled.
Respectfully submitted,
Law Office of Stephen E. Dubner
2785 Rockbrook Dr., Suite 205
Lewisville, TX 75067
Tel: (940) 239
Fax: (866) 611
/s/ Stephen E. Dubner
Stephen E. Dubner
State Bar No. 24031592
steve@dubnerlaw.com
Attorney for Petitioner
Certificate of Conference
I certify that a reasonable effort has been made to resolve th dispute without the necessity
of court intervention and has failed.
Stephen E. Dubner
Stephen E. Dubner
Attorney for Carrie Ann McConnell
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure on September
Stephen E. Dubner
Stephen E. Dubner
Attorney for Petitioner
Document Filed Date
September 28, 2018
Case Filing Date
October 30, 2017
Category
Divorce without Children
Status
Inactive: Disposed
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On January 2, 2018, this Court held a hearing on temporary orders. At the hearing, Stephen Lee McConnnell, Respondent, represented that he paid debts with $66,000.00 that he removed from the parties’ joint accounts at the time this proceeding was filed This Court ordered Mr. McConnell to return funds that were in his possession, which was approximately $30,000.00. The funds were restricted and to be only used to pay Throughout this divorce proceeding, Mr. McConnell has represented that he has limited income and that there are no available funds to pay attorney’s fees. In fact, he ha On or about August 27, 2018, Mr. McConnell produced previous undisclosed bank records. These records suggest that Mr. McConnell is misrepresenting his income and January 1, 2018, Mr. McConnell has income in the approximate amount of $89,000.00. Ms. McConnell works 35 hours per week for Frisco ISD at a rate of $10.00 has insufficient funds to pay both her monthly living expenses and also pay torney’s fees in her ongoing representation. Petitioner has had to borrow funds in order to pay her attorney’s fees. Through July 31, 2018, Mr. McConnell has paid his attorneys approximately $35,000.00. Ms. McConnell has paid her attorney approximately $ Petitioner needs to take the Responden s deposition, but does not have the funds to pay the attorney and court reporter. Respondent has had the opportunity to depose Petitioner. Significant and reasonable fees and expenses have been and will continue to be incurred in representing Petitioner’s interest. Petitioner requests that Respondent be required to pay attorney’s fees to Counsel for Petition equal to those paid by Respondent to his attorney of record. Petitioner request that Respondent be ordered to pay Petitioner’s attorney the sum of $13,600.00, which is the differences of the fees as of July 31, 2018 that each party has incurred. Further, Petitioner requests that for each payment made by Respondent to his attorney of record after July 31, 2018, a contemporaneous and equal amount be made by Respondent to Petitioner’s attorney of record. Petitioner prays that the Court grant this Motion and for such other and further relief to which Petitioner may be entitled. Respectfully submitted, Law Office of Stephen E. Dubner 2785 Rockbrook Dr., Suite 205 Lewisville, TX 75067 Tel: (940) 239 Fax: (866) 611 /s/ Stephen E. Dubner Stephen E. Dubner State Bar No. 24031592 steve@dubnerlaw.com Attorney for Petitioner Certificate of Conference I certify that a reasonable effort has been made to resolve th dispute without the necessity of court intervention and has failed. Stephen E. Dubner Stephen E. Dubner Attorney for Carrie Ann McConnell Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on September Stephen E. Dubner Stephen E. Dubner Attorney for Petitioner