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NO. 18-5535-362
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
HASKELL GLEN STRICKLEN § 362ND JUDICIAL DISTRICT
AND
KRISTA BROWN STRICKLEN § DENTON COUNTY, TEXAS
MOTION TO ENTER
NOW COME, Krista Stricklen, Movant herein, and Petitioner in the above-styled
and numbered cause and files this Motion to Enter final decree of divorce. Movant
request the Court to sign the Final Decree of Divorce in the form attached to this motion
as Exhibit eAz
Respectfully submitted,
YALE LAW
1417 E. McKinney St., Ste. 220
Denton Texas 76209
Tel. (940) 891-4800
/s/ Roger M. Yale
Roger M. Yale
Texas State Bar No. 00789959
roger@yalelawgroup.com
Brittany A. Weaver
Texas State Bar No. 24092577
brittan alelawgroup.com
Jennifer K. Yates
Texas State Bar No. 24089853
jennifer@yalelawgroup.com
Jeremy Tufnell
Texas State Bar No. 24091812
jeremy@yalelawgroup.com
Attorneys for Krista Stricklen, Respondent
MOTION TO ENTER - PAGE 1
CERTIFICATE OF SERVICE
| hereby certify that a true and correct copy of the foregoing document has been
served on this April 30, 2018 via:
{] First Class Mail
(] Facsimile
{] Hand Delivery
poy EfileTexas.gov
TO Timothy Alexander
2920 W. Southlake Bivd., Suite 140
Southlake, Texas 76092
texfile@dfwdivorce.com
Attomey for Petitioner
John M. Rogers
Rogers, LLP
409 West 4" Street, Ste. 102
Weatherford, TX 76086
John.rogers@rogersllp.com
Attomey for Intervenors
/s/ Roger M. Yale
Roger M. Yale
MOTION TO ENTER- PAGE 2
NO. 18-5535-362
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
HASKELL GLEN STRICKLEN § 362ND JUDICIAL DISTRICT
AND
KRISTA BROWN STRICKLEN § DENTON COUNTY, TEXAS
FINAL DECREE OF DIVORCE
On June 25, 2019 and June 26, 2019 the Court heard this case.
Appearances
Petitioner, Haskell Glen Stricklen, appeared in person and through attorney of
record, Timothy Alexander, and announced ready for trial.
Respondent, Krista Brown Stricklen, appeared in person and through attorney of
record, Roger M. Yale, and announced ready for trial.
Record
The record of testimony was duly reported by the court reporter for the 362nd
Judicial District Court.
Jurisdiction and Domicile
The Court finds that the pleadings of Petitioner are in due form and contain all
the allegations, information, and prerequisites required by law. The Court, after
receiving evidence, finds that it has jurisdiction of this case and of all the parties and
that at least sixty days have elapsed since the date the suit was filed.
The Court further finds that, at the time this suit was filed, Petitioner had been a
domiciliary of Texas for the preceding six-month period and a resident of the county in
which this suit was filed for the preceding ninety-day period. All persons entitled to
_ — _
citation were properly cited.
FINAL DECREE OF DIVORCE - PAGE 1
Exhibit "A"
L_
Jury
A jury was waived, and questions of fact and of law were submitted to the Court.
Divorce
IT IS ORDERED AND DECREED that Haskell Glen Stricklen, Petitioner, and
Krista Brown Stricklen, Respondent, are divorced and that the marriage between them
is dissolved on the ground of insupportability.
Child of the Marriage
The Court finds that there is no child of the marriage of Petitioner and
Respondent and that none is expected.
Division of Marital Estate
The Court finds that the following is a just and right division of the parties' marital
estate, having due regard for the rights of each party.
Property to Petitione:
IT IS ORDERED AND DECREED that Petitioner, Haskell Glen Stricklen, is
awarded the following as his sole and separate property, and Respondent, Krista Brown
Stricklen, is divested of all right, title, interest, and claim in and to that property:
P-1. 1/3 interest in the following real property, including but not limited to any
escrow funds, prepaid insurance, utility deposits, keys, house plans, home security
access and code, garage door opener, warranties and service contracts, and title and
closing documents located at 1405 Park St., Commerce, Texas 75428.
P-2. All household furniture, furnishings, fixtures, goods art objects,
collectibles, appliances, and equipment as agreed by Petitioner and Respondent,
including the following awarded to Petitioner as his sole and separate property:
FINAL DECREE OF DIVORCE - PAGE 2
a Cape Buffalo Bronze Figurine
P-3. All clothing, jewelry, and personal effects as agreed by Petitioner and
Respondent.
P-4. All sums of cash in the possession of Petitioner or subject to his sole
control, including funds on deposit, together with accrued but unpaid interest, in banks,
savings institutions, or other financial institutions, which accounts stand in Petitioner's
sole name or from which Petitioner has the sole right to withdraw funds or which are
subject to Petitioner's sole control.
P-5. All policies of life insurance (including cash values) insuring Petitioner's
life.
P-6. The Labrador Retriever dog named River.
P-7. The following firearms currently in Petitioner's possession or control:
a Glock 43
b. Armalite AR 15 Rifle
Kimber Pro Carry 9mm
Beretta Shotgun
Smith & Wesson Snub Nose 38
Remington 30-06 Rifle with scope
All firearms currently held at Cash America Pawn on behalf of
Petitioner, once Petitioner has paid the debt owed to Cash America
Pawn for such firearms
Property to Respondent
IT IS ORDERED AND DECREED that Respondent, Krista Brown Stricklen, is
FINAL DECREE OF DIVORCE - PAGE 3
awarded the following as her sole and separate property, and Petitioner, Haskell Glen
Stricklen, is divested of all right, title, interest, and claim in and to that property:
R-1. All household furniture, furnishings, fixtures, goods art objects,
collectibles, appliances, and equipment as agreed by Petitioner and Respondent,
including, but not limited to the following:
a. Chair purchased on credit with Nebraska Furniture Mart
b. Apple Computer purchased on credit with Nebraska Furniture Mart
R-2 All clothing, jewelry, and personal effects as agreed by Petitioner and
Respondent, including the following awarded to Respondent as her sole
and separate property:
a Respondent's wedding ring and all diamonds in wedding ring.
R-3. All sums of cash in the possession of Respondent or subject to her sole
control, including funds on deposit, together with accrued but unpaid interest, in banks,
savings institutions, or other financial institutions, which accounts stand in Respondent's
sole name or from which Respondent has the sole right to withdraw funds or which are
subject to Respondent's sole control.
R-4. The funds on deposit, together with accrued but unpaid interest, in the
following banks, savings institutions, or other financial institutions:
a Woodforest National Bank, Account number ending in 0849
b DATCU, Account number ending in S:01
R-5. All policies of life insurance (including cash values) insuring Respondent's
life.
R-6. The 2013 Ford F-150 motor vehicle, vehicle identification number
FINAL DECREE OF DIVORCE - PAGE 4
1FTFW1CFOOKE61420, together with all prepaid insurance, keys, and title documents.
R-7. All sums, whether matured or unmatured, accrued or unaccrued, vested or
otherwise, together with all increases thereof, the proceeds therefrom, and any other
tights related to Krista Brown Stricklen’s Teacher Retirement System account existing
by reason of Respondent's past, present, or future employment.
R-8. All rings currently held at Cash America Pawn on behalf of Respondent,
once Respondent has paid the debt owed to Cash America Pawn for such rings
Division of Debt
Debts to Petitioner
IT IS ORDERED AND DECREED that Petitioner, Haskell Glen Stricklen, shall
pay, as a part of the division of the estate of the parties, and shall indemnify and hold
Respondent, Krista Brown Stricklen, and her property harmless from any failure to so
discharge, these items:
P-1. The following debts, charges, liabilities, and obligations:
a Debt owed to Cash America Pawn for firearms
P-2. All debts, charges, liabilities, and other obligations incurred solely by
Petitioner unless express provision is made in this decree to the contrary.
P-3. All encumbrances, ad valorem taxes, liens, assessments, premiums, or
other charges due or to become due on the real and personal property awarded to
Petitioner in this decree unless express provision is made in this decree to the contrary.
Debts to Respondent
IT IS ORDERED AND DECREED that Respondent, Krista Brown Stricklen, shall
pay, as a part of the division of the estate of the parties, and shall indemnify and hold
FINAL DECREE OF DIVORCE - PAGE 5
Petitioner, Haskell Glen Stricklen, and his property harmless from any failure to so
discharge, these items:
R-1. The following debts, charges, liabilities, and obligations:
a Debt owed to Nebraska Furniture Mart, Account No. ending in 2651
Approximate Balance: $1,400.00
Debt owed to Medical City
Approximate Balance: $4,000.00
Debt owed to Intervenor Kenneth Kramer
Approximate Balance: $15,757.00
Debt owed to Intervenor Charles Brown
Approximate Balance: $5,000.00
Debt owed to Intervenor Jennifer Brown
Approximate Balance: $10,637.20
f Debt owed to Cash America Pawn for rings
R-2. All debts, charges, liabilities, and other obligations incurred solely by
Respondent unless express provision is made in this decree to the contrary.
R-3. The balance due, including principal, interest, and all other charges, on
the promissory note payable to DATCU Credit Union and given as part of the purchase
price of and secured by a lien on the 2013 F150 Ford motor vehicle awarded to
Respondent.
Notice
IT IS ORDERED AND DECREED that each party shall send to the other party,
within three days of its receipt, a copy of any correspondence from a creditor or taxing
FINAL DECREE OF DIVORCE — PAGE 6
authority concerning any potential liability of the other party.
Sale of Residence
IT IS FURTHER ORDERED AND DECREED that the property and all
improvements located thereon at 408 Brent Drive, Lewisville, Texas 75057, and more
particularly described as follows:
LOT 2, BLOCK C OF LAKESIDE ESTATES, AN ADDITION TO THE CITY OF
LEWISVILLE, DENTON COUNTY, TEXAS, ACCORDING TO THE PLAT THEREOF
RECORDED IN CABINET F, PAGE 147, PLAT RECORDS, DENTON COUNTY,
TEXAS,
shall be sold under the following terms and conditions:
1 The parties shall list the property with a duly licensed real estate broker
having sales experience in the area where the property is located, provided further that
the real estate broker shall be an active member in the Multiple Listing Service with the
Texas Board of Realtors.
2 The property shall be sold for a price that is mutually agreeable to
Petitioner and Respondent. If Petitioner and Respondent are unable to agree on a
sales price, on the application of either party, the property shall be sold under terms and
conditions determined by the real estate broker.
3. Minimum repairs shall be made to market and sell the property including,
but not limited to, repairing/ replacing the roof, repairing damaged drywall, and other
repairs as agreed to by Petitioner and Respondent. The real estate broker shall have
the authority to set-up and coordinate the necessary minimum repairs.
4 Respondent shall continue to make all payments of principal, interest,
taxes, and insurance on the property during the pendency of the sale, provided that all
payments made by Respondent attributed to principal after June 26, 2019 shall be
FINAL DECREE OF DIVORCE - PAGE 7
credited to Respondent on the sale of the property. Petitioner shall vacate the property
by July 26, 2019. No later than July 26, 2019, Respondent shall have the exclusive right
to enjoy the use and possession of the premises until closing. All maintenance and
repairs necessary to keep the property in its present condition shall be paid by
Respondent.
5. The net sales proceeds (defined as the gross sales price less cost of sale
and full payment of any mortgage indebtedness or liens on the property) shall be
distributed in the following order of priority:
1 All expenses, including, but not limited to, realtor fees, closing
costs, and expenses for any repairs necessary to market and sell the
property;
2. Respondent shall be paid for any and all amounts attributed to the
reduction in principal made by Respondent after June 26, 2019;
3. $10,000.00 to Respondent;
4 Remainder proceeds shall be split 50% to Respondent and 50% to
Petitioner.
Attorney's Fees
The Court finds that Krista Brown Stricklen has incurred $13,011.57 as
reasonable attorney's fees, expenses, and costs, which were necessary as support for
Krista Brown Stricklen. IT IS ORDERED that good cause exists to award Roger M.
Yale a judgment in the amount of $3,000.00 for attorney's fees, expenses, and costs,
with interest at five percent (5%) per year compounded annually from the date this Final
Decree of Divorce is signed until paid. The judgment, for which let execution issue, is
FINAL DECREE OF DIVORCE — PAGE 8
awarded against Haskell Glen Stricklen, and Haskell Glen Stricklen is ORDERED to pay
the fees, expenses, costs, and interest to Roger M. Yale at 1417 E. McKinney Street,
Ste. 220, Denton, Texas 76209 by cash, cashier's check, or money order on or before
August 1, 2019. Roger M. Yale may enforce this judgment for fees, expenses, and
costs in the attorney's own name by any means available for the enforcement of a
judgment for debt.
Liability for Federal Income Taxes for Prior Yea
IT IS ORDERED AND DECREED that Haskell Glen Stricklen and Krista Brown
Stricklen shall be equally responsible for all federal income tax liabilities of the parties
from the date of marriage through December 31, 2018, and each party shall timely pay
50 percent of any deficiencies, assessments, penalties, or interest due thereon and
shall indemnify and hold the other party and the other party's property harmless from 50
percent of such liabilities unless such additional tax, penalty, and/or interest resulted
from a party's omission of taxable income or claim of erroneous deductions. In such
case, the portion of the tax, penalty, and/or interest relating to the omitted income or
claims of erroneous deductions shall be paid by the party who earned the omitted
income or proffered the claim for an erroneous deduction. The parties agree that
nothing contained herein shall be construed as or is intended as a waiver of any rights
that a party has under the "Innocent Spouse" provisions of the Internal Revenue Code.
Treatment/Allocation of Community Income for Year of Divorce
For the purposes of determining income tax liability, the parties agree and hereby
partition 100 percent of the income, gain, loss, and deductions attributable to a party
from that party's individual labor, that party's individual efforts, or the property awarded
FINAL DECREE OF DIVORCE - PAGE 9
in this agreement to that party, as that party's sole and separate property, as if that party
had been single and unmarried from January 1, 2019, through the date of divorce. The
partition further assigns to a party any exemptions, exclusions, estimated tax payments,
and withholdings made by that party or for the other party's benefit from January 1,
2019, through the date of divorce, as if the same were that party's separate property.
The parties agree and IT IS ORDERED AND DECREED that, for purposes of
determining income tax liability, any property awarded to a party in this decree shall be
deemed to be partitioned to that party and have been that party's separate property as
of January 1, 2019, and thereafter. The parties further agree and IT IS ORDERED AND
DECREED that any tax payments and any payments that are tax deductible are
assigned to the party who made those payments.
IT IS ORDERED AND DECREED that for the calendar year 2019, each party will
file an individual income tax return in accordance with the Internal Revenue Code.
IT IS ORDERED AND DECREED that Haskell Glen Stricklen shall report 100
percent of his income, withholding, prepayments, and deductions and none of Krista
Brown Stricklen's income, withholding, prepayments, and deductions. Haskell Glen
Stricklen shall be entitled to receive 100 percent of any refund for which he might be
entitled on his 2019 federal income tax return. Haskell Glen Stricklen shall pay 100
percent of any liability shown on his 2019 federal income tax return.
IT IS ORDERED AND DECREED that Krista Brown Stricklen shall report 100
percent of her income, withholding, prepayments, and deductions and none of Haskell
Glen Stricklen's income, withholding, prepayments, and deductions. Krista Brown
Stricklen shall be entitled to receive 100 percent of any refund for which she might be
FINAL DECREE OF DIVORCE — PAGE 10
entitled on her 2019 federal income tax return. Krista Brown Stricklen shall pay 100
percent of any liability shown on her 2019 federal income tax return.
IT IS ORDERED AND DECREED that for calendar year 2019, each party shall
indemnify and hold the other party and the other party's property harmless from any tax
liability associated with the reporting party's individual tax return for that year unless the
parties have agreed to allocate their tax liability in a manner different from that reflected
on their returns.
IT IS ORDERED AND DECREED that each party shall furnish such information
to the other party as is requested to prepare federal income tax returns for 2019 within
thirty days of receipt of a written request for the information, and in no event shall the
available information be exchanged later than March 1, 2020. As requested information
becomes available after that date, it shall be provided within ten days of receipt.
IT IS ORDERED AND DECREED that all payments made to the other party in
accordance with the allocation provisions for payment of federal income taxes contained
in this Final Decree of Divorce are not deemed income to the party receiving those
payments but are part of the property division and necessary for a just and right division
of the parties' estate.
Confirmation of Separate Property
IT IS ORDERED AND DECREED that the following described property is
confirmed as the separate property of Haskell Glen Stricklen:
1. The following furniture, furnishings, fixtures, goods art objects, collectibles,
appliances, and equipment
a. Bedroom set;
FINAL DECREE OF DIVORCE - PAGE 11
Dining room set;
Office chair;
Entryway table;
Antique sewing machine cabinet;
Antique glass bar cabinet;
Cedar chest;
Glass top folding table;
chest of drawers;
tv stand;
queen ann table;
hand tools;
m Antique belt buckle set; and
n Fish and bobber
2. The funds on deposit, together with accrued but unpaid interest, in the
following banks, savings institutions, or other financial institutions:
a. Bank of America, Account No. ending in 8808
All sums, whether matured or unmatured, accrued or unaccrued, vested or
otherwise, together with all increases thereof, the proceeds therefrom, and
any other rights related to Haskell Glen Stricklen’s Allstate Pension account
existing by reason of Petitioner's past, present, or future employment.
IT IS ORDERED AND DECREED that the following described property is
confirmed as the separate property of Krista Brown Stricklen:
1 Respondent’s wedding ring and the stones included therein.
FINAL DECREE OF DIVORCE - PAGE 12
Transfer and Delivery of Property
Termination of Health Insurance Coverag
IT IS ORDERED that Krista Brown Stricklen shall be relieved of the obligation to
pay the health insurance premiums for Haskell Glen Stricklen as of June 26, 2019 and
Krista Brown Stricklen may terminate Haskell Glen Stricklen’s health insurance as of
June 26, 2019.
Change of Petitioner's Name
IT lS ORDERED AND DECREED that Krista Brown Stricklen's name is changed
to Krista Lynne Brown.
Court Costs
IT IS ORDERED AND DECREED that costs of court are to be borne by the party
who incurred them.
Resolution of Temporary Orders
IT IS ORDERED AND DECREED that Petitioner and Respondent are discharged
from all further liabilities and obligations imposed by the temporary order(s) of this
Court.
Discharge from Discovery Retention Requirement
IT IS ORDERED AND DECREED that the parties and their respective attorneys
are discharged from the requirement of keeping and storing the documents produced in
this case in accordance with rule 191.4(d) of the Texas Rules of Civil Procedure.
Decree Acknowledgment
Petitioner, Haskell Glen Stricklen, and Respondent, Krista Brown Stricklen, each
acknowledge that before signing this Final Decree of Divorce they have read this Final
FINAL DECREE OF DIVORCE - PAGE 13
Decree of Divorce fully and completely, have had the opportunity to ask any questions
regarding the same, and fully understand that the contents of this Final Decree of
Divorce constitute a full and complete resolution of this case. Petitioner and
Respondent acknowledge that they have voluntarily affixed their signatures to this Final
Decree of Divorce, believing this agreement to be a just and right division of the marital
debt and assets, and state that they have not signed by virtue of any coercion, any
duress, or any agreement other than those specifically set forth in this Final Decree of
Divorce.
Indemnification
Each party represents and warrants that he or she has not incurred any
outstanding debt, obligation, or other liability on which the other party is or may be
liable, other than those described in this decree. Each party agrees and IT IS
ORDERED that if any claim, action, or proceeding is hereafter initiated seeking to hold
the party not assuming a debt, an obligation, a liability, an act, or an omission of the
other party liable for such debt, obligation, liability, act or omission of the other party,
that other party will, at that other party's sole expense, defend the party not assuming
the debt, obligation, liability, act, or omission of the other party against any such claim or
demand, whether or not well founded, and will indemnify the party not assuming the
debt, obligation, liability, act, or omission of the other party and hold him or her harmless
from all damages resulting from the claim or demand.
Damages, as used in this provision, includes any reasonable loss, cost, expense,
penalty, and other damage, including without limitation attorney's fees and other costs
and expenses reasonably and necessarily incurred in enforcing this indemnity.
FINAL DECREE OF DIVORCE - PAGE 14
IT IS ORDERED that the indemnifying party will reimburse the indemnified party,
on demand, for any payment made by the indemnified party at any time after the entry
of the divorce decree to satisfy any judgment of any court of competent jurisdiction or in
accordance with a bona fide compromise or settlement of claims, demands, or actions
for any damages to which this indemnity relates.
The parties agree and IT IS ORDERED that each party will give the other party
prompt written notice of any litigation threatened or instituted against either party that
might constitute the basis of a claim for indemnity under this decree.
Clarifying Orders
Without affecting the finality of this Final Decree of Divorce, this Court expressly
reserves the right to make orders necessary to clarify and enforce this decree.
Relief Not Granted
IT IS ORDERED AND DECREED that all relief requested in this case and not
expressly granted is denied. This is a final judgment, for which let execution and all
writs and processes necessary to enforce this judgment issue. This judgment finally
disposes of all claims and all parties and is appealable.
Date of Judgment
This divorce judicially PRONOUNCED AND RENDERED in court in Denton
County, Texas, on June 26, 2019 and further noted on the court's docket sheet on the
same date, but signed on
JUDGE PRESIDING
FINAL DECREE OF DIVORCE — PAGE 15
APPROVED AS TO FORM ONLY:
By:
Roger M. Yale
Attorney for Respondent
B
“Timothy Alexander
Attorney for Petitioner
APPROVED AND CONSENTED TO AS TO BOTH FORM AND SUBSTANCE:
Haskell Glen Stricklen, Petitioner
Krista Brown Stricklen, Respondent
FINAL DECREE OF DIVORCE - PAGE 16
Preview
NO. 18-5535-362 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § HASKELL GLEN STRICKLEN § 362ND JUDICIAL DISTRICT AND KRISTA BROWN STRICKLEN § DENTON COUNTY, TEXAS MOTION TO ENTER NOW COME, Krista Stricklen, Movant herein, and Petitioner in the above-styled and numbered cause and files this Motion to Enter final decree of divorce. Movant request the Court to sign the Final Decree of Divorce in the form attached to this motion as Exhibit eAz Respectfully submitted, YALE LAW 1417 E. McKinney St., Ste. 220 Denton Texas 76209 Tel. (940) 891-4800 /s/ Roger M. Yale Roger M. Yale Texas State Bar No. 00789959 roger@yalelawgroup.com Brittany A. Weaver Texas State Bar No. 24092577 brittan alelawgroup.com Jennifer K. Yates Texas State Bar No. 24089853 jennifer@yalelawgroup.com Jeremy Tufnell Texas State Bar No. 24091812 jeremy@yalelawgroup.com Attorneys for Krista Stricklen, Respondent MOTION TO ENTER - PAGE 1 CERTIFICATE OF SERVICE | hereby certify that a true and correct copy of the foregoing document has been served on this April 30, 2018 via: {] First Class Mail (] Facsimile {] Hand Delivery poy EfileTexas.gov TO Timothy Alexander 2920 W. Southlake Bivd., Suite 140 Southlake, Texas 76092 texfile@dfwdivorce.com Attomey for Petitioner John M. Rogers Rogers, LLP 409 West 4" Street, Ste. 102 Weatherford, TX 76086 John.rogers@rogersllp.com Attomey for Intervenors /s/ Roger M. Yale Roger M. Yale MOTION TO ENTER- PAGE 2 NO. 18-5535-362 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § HASKELL GLEN STRICKLEN § 362ND JUDICIAL DISTRICT AND KRISTA BROWN STRICKLEN § DENTON COUNTY, TEXAS FINAL DECREE OF DIVORCE On June 25, 2019 and June 26, 2019 the Court heard this case. Appearances Petitioner, Haskell Glen Stricklen, appeared in person and through attorney of record, Timothy Alexander, and announced ready for trial. Respondent, Krista Brown Stricklen, appeared in person and through attorney of record, Roger M. Yale, and announced ready for trial. Record The record of testimony was duly reported by the court reporter for the 362nd Judicial District Court. Jurisdiction and Domicile The Court finds that the pleadings of Petitioner are in due form and contain all the allegations, information, and prerequisites required by law. The Court, after receiving evidence, finds that it has jurisdiction of this case and of all the parties and that at least sixty days have elapsed since the date the suit was filed. The Court further finds that, at the time this suit was filed, Petitioner had been a domiciliary of Texas for the preceding six-month period and a resident of the county in which this suit was filed for the preceding ninety-day period. All persons entitled to _ — _ citation were properly cited. FINAL DECREE OF DIVORCE - PAGE 1 Exhibit "A" L_ Jury A jury was waived, and questions of fact and of law were submitted to the Court. Divorce IT IS ORDERED AND DECREED that Haskell Glen Stricklen, Petitioner, and Krista Brown Stricklen, Respondent, are divorced and that the marriage between them is dissolved on the ground of insupportability. Child of the Marriage The Court finds that there is no child of the marriage of Petitioner and Respondent and that none is expected. Division of Marital Estate The Court finds that the following is a just and right division of the parties' marital estate, having due regard for the rights of each party. Property to Petitione: IT IS ORDERED AND DECREED that Petitioner, Haskell Glen Stricklen, is awarded the following as his sole and separate property, and Respondent, Krista Brown Stricklen, is divested of all right, title, interest, and claim in and to that property: P-1. 1/3 interest in the following real property, including but not limited to any escrow funds, prepaid insurance, utility deposits, keys, house plans, home security access and code, garage door opener, warranties and service contracts, and title and closing documents located at 1405 Park St., Commerce, Texas 75428. P-2. All household furniture, furnishings, fixtures, goods art objects, collectibles, appliances, and equipment as agreed by Petitioner and Respondent, including the following awarded to Petitioner as his sole and separate property: FINAL DECREE OF DIVORCE - PAGE 2 a Cape Buffalo Bronze Figurine P-3. All clothing, jewelry, and personal effects as agreed by Petitioner and Respondent. P-4. All sums of cash in the possession of Petitioner or subject to his sole control, including funds on deposit, together with accrued but unpaid interest, in banks, savings institutions, or other financial institutions, which accounts stand in Petitioner's sole name or from which Petitioner has the sole right to withdraw funds or which are subject to Petitioner's sole control. P-5. All policies of life insurance (including cash values) insuring Petitioner's life. P-6. The Labrador Retriever dog named River. P-7. The following firearms currently in Petitioner's possession or control: a Glock 43 b. Armalite AR 15 Rifle Kimber Pro Carry 9mm Beretta Shotgun Smith & Wesson Snub Nose 38 Remington 30-06 Rifle with scope All firearms currently held at Cash America Pawn on behalf of Petitioner, once Petitioner has paid the debt owed to Cash America Pawn for such firearms Property to Respondent IT IS ORDERED AND DECREED that Respondent, Krista Brown Stricklen, is FINAL DECREE OF DIVORCE - PAGE 3 awarded the following as her sole and separate property, and Petitioner, Haskell Glen Stricklen, is divested of all right, title, interest, and claim in and to that property: R-1. All household furniture, furnishings, fixtures, goods art objects, collectibles, appliances, and equipment as agreed by Petitioner and Respondent, including, but not limited to the following: a. Chair purchased on credit with Nebraska Furniture Mart b. Apple Computer purchased on credit with Nebraska Furniture Mart R-2 All clothing, jewelry, and personal effects as agreed by Petitioner and Respondent, including the following awarded to Respondent as her sole and separate property: a Respondent's wedding ring and all diamonds in wedding ring. R-3. All sums of cash in the possession of Respondent or subject to her sole control, including funds on deposit, together with accrued but unpaid interest, in banks, savings institutions, or other financial institutions, which accounts stand in Respondent's sole name or from which Respondent has the sole right to withdraw funds or which are subject to Respondent's sole control. R-4. The funds on deposit, together with accrued but unpaid interest, in the following banks, savings institutions, or other financial institutions: a Woodforest National Bank, Account number ending in 0849 b DATCU, Account number ending in S:01 R-5. All policies of life insurance (including cash values) insuring Respondent's life. R-6. The 2013 Ford F-150 motor vehicle, vehicle identification number FINAL DECREE OF DIVORCE - PAGE 4 1FTFW1CFOOKE61420, together with all prepaid insurance, keys, and title documents. R-7. All sums, whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with all increases thereof, the proceeds therefrom, and any other tights related to Krista Brown Stricklen’s Teacher Retirement System account existing by reason of Respondent's past, present, or future employment. R-8. All rings currently held at Cash America Pawn on behalf of Respondent, once Respondent has paid the debt owed to Cash America Pawn for such rings Division of Debt Debts to Petitioner IT IS ORDERED AND DECREED that Petitioner, Haskell Glen Stricklen, shall pay, as a part of the division of the estate of the parties, and shall indemnify and hold Respondent, Krista Brown Stricklen, and her property harmless from any failure to so discharge, these items: P-1. The following debts, charges, liabilities, and obligations: a Debt owed to Cash America Pawn for firearms P-2. All debts, charges, liabilities, and other obligations incurred solely by Petitioner unless express provision is made in this decree to the contrary. P-3. All encumbrances, ad valorem taxes, liens, assessments, premiums, or other charges due or to become due on the real and personal property awarded to Petitioner in this decree unless express provision is made in this decree to the contrary. Debts to Respondent IT IS ORDERED AND DECREED that Respondent, Krista Brown Stricklen, shall pay, as a part of the division of the estate of the parties, and shall indemnify and hold FINAL DECREE OF DIVORCE - PAGE 5 Petitioner, Haskell Glen Stricklen, and his property harmless from any failure to so discharge, these items: R-1. The following debts, charges, liabilities, and obligations: a Debt owed to Nebraska Furniture Mart, Account No. ending in 2651 Approximate Balance: $1,400.00 Debt owed to Medical City Approximate Balance: $4,000.00 Debt owed to Intervenor Kenneth Kramer Approximate Balance: $15,757.00 Debt owed to Intervenor Charles Brown Approximate Balance: $5,000.00 Debt owed to Intervenor Jennifer Brown Approximate Balance: $10,637.20 f Debt owed to Cash America Pawn for rings R-2. All debts, charges, liabilities, and other obligations incurred solely by Respondent unless express provision is made in this decree to the contrary. R-3. The balance due, including principal, interest, and all other charges, on the promissory note payable to DATCU Credit Union and given as part of the purchase price of and secured by a lien on the 2013 F150 Ford motor vehicle awarded to Respondent. Notice IT IS ORDERED AND DECREED that each party shall send to the other party, within three days of its receipt, a copy of any correspondence from a creditor or taxing FINAL DECREE OF DIVORCE — PAGE 6 authority concerning any potential liability of the other party. Sale of Residence IT IS FURTHER ORDERED AND DECREED that the property and all improvements located thereon at 408 Brent Drive, Lewisville, Texas 75057, and more particularly described as follows: LOT 2, BLOCK C OF LAKESIDE ESTATES, AN ADDITION TO THE CITY OF LEWISVILLE, DENTON COUNTY, TEXAS, ACCORDING TO THE PLAT THEREOF RECORDED IN CABINET F, PAGE 147, PLAT RECORDS, DENTON COUNTY, TEXAS, shall be sold under the following terms and conditions: 1 The parties shall list the property with a duly licensed real estate broker having sales experience in the area where the property is located, provided further that the real estate broker shall be an active member in the Multiple Listing Service with the Texas Board of Realtors. 2 The property shall be sold for a price that is mutually agreeable to Petitioner and Respondent. If Petitioner and Respondent are unable to agree on a sales price, on the application of either party, the property shall be sold under terms and conditions determined by the real estate broker. 3. Minimum repairs shall be made to market and sell the property including, but not limited to, repairing/ replacing the roof, repairing damaged drywall, and other repairs as agreed to by Petitioner and Respondent. The real estate broker shall have the authority to set-up and coordinate the necessary minimum repairs. 4 Respondent shall continue to make all payments of principal, interest, taxes, and insurance on the property during the pendency of the sale, provided that all payments made by Respondent attributed to principal after June 26, 2019 shall be FINAL DECREE OF DIVORCE - PAGE 7 credited to Respondent on the sale of the property. Petitioner shall vacate the property by July 26, 2019. No later than July 26, 2019, Respondent shall have the exclusive right to enjoy the use and possession of the premises until closing. All maintenance and repairs necessary to keep the property in its present condition shall be paid by Respondent. 5. The net sales proceeds (defined as the gross sales price less cost of sale and full payment of any mortgage indebtedness or liens on the property) shall be distributed in the following order of priority: 1 All expenses, including, but not limited to, realtor fees, closing costs, and expenses for any repairs necessary to market and sell the property; 2. Respondent shall be paid for any and all amounts attributed to the reduction in principal made by Respondent after June 26, 2019; 3. $10,000.00 to Respondent; 4 Remainder proceeds shall be split 50% to Respondent and 50% to Petitioner. Attorney's Fees The Court finds that Krista Brown Stricklen has incurred $13,011.57 as reasonable attorney's fees, expenses, and costs, which were necessary as support for Krista Brown Stricklen. IT IS ORDERED that good cause exists to award Roger M. Yale a judgment in the amount of $3,000.00 for attorney's fees, expenses, and costs, with interest at five percent (5%) per year compounded annually from the date this Final Decree of Divorce is signed until paid. The judgment, for which let execution issue, is FINAL DECREE OF DIVORCE — PAGE 8 awarded against Haskell Glen Stricklen, and Haskell Glen Stricklen is ORDERED to pay the fees, expenses, costs, and interest to Roger M. Yale at 1417 E. McKinney Street, Ste. 220, Denton, Texas 76209 by cash, cashier's check, or money order on or before August 1, 2019. Roger M. Yale may enforce this judgment for fees, expenses, and costs in the attorney's own name by any means available for the enforcement of a judgment for debt. Liability for Federal Income Taxes for Prior Yea IT IS ORDERED AND DECREED that Haskell Glen Stricklen and Krista Brown Stricklen shall be equally responsible for all federal income tax liabilities of the parties from the date of marriage through December 31, 2018, and each party shall timely pay 50 percent of any deficiencies, assessments, penalties, or interest due thereon and shall indemnify and hold the other party and the other party's property harmless from 50 percent of such liabilities unless such additional tax, penalty, and/or interest resulted from a party's omission of taxable income or claim of erroneous deductions. In such case, the portion of the tax, penalty, and/or interest relating to the omitted income or claims of erroneous deductions shall be paid by the party who earned the omitted income or proffered the claim for an erroneous deduction. The parties agree that nothing contained herein shall be construed as or is intended as a waiver of any rights that a party has under the "Innocent Spouse" provisions of the Internal Revenue Code. Treatment/Allocation of Community Income for Year of Divorce For the purposes of determining income tax liability, the parties agree and hereby partition 100 percent of the income, gain, loss, and deductions attributable to a party from that party's individual labor, that party's individual efforts, or the property awarded FINAL DECREE OF DIVORCE - PAGE 9 in this agreement to that party, as that party's sole and separate property, as if that party had been single and unmarried from January 1, 2019, through the date of divorce. The partition further assigns to a party any exemptions, exclusions, estimated tax payments, and withholdings made by that party or for the other party's benefit from January 1, 2019, through the date of divorce, as if the same were that party's separate property. The parties agree and IT IS ORDERED AND DECREED that, for purposes of determining income tax liability, any property awarded to a party in this decree shall be deemed to be partitioned to that party and have been that party's separate property as of January 1, 2019, and thereafter. The parties further agree and IT IS ORDERED AND DECREED that any tax payments and any payments that are tax deductible are assigned to the party who made those payments. IT IS ORDERED AND DECREED that for the calendar year 2019, each party will file an individual income tax return in accordance with the Internal Revenue Code. IT IS ORDERED AND DECREED that Haskell Glen Stricklen shall report 100 percent of his income, withholding, prepayments, and deductions and none of Krista Brown Stricklen's income, withholding, prepayments, and deductions. Haskell Glen Stricklen shall be entitled to receive 100 percent of any refund for which he might be entitled on his 2019 federal income tax return. Haskell Glen Stricklen shall pay 100 percent of any liability shown on his 2019 federal income tax return. IT IS ORDERED AND DECREED that Krista Brown Stricklen shall report 100 percent of her income, withholding, prepayments, and deductions and none of Haskell Glen Stricklen's income, withholding, prepayments, and deductions. Krista Brown Stricklen shall be entitled to receive 100 percent of any refund for which she might be FINAL DECREE OF DIVORCE — PAGE 10 entitled on her 2019 federal income tax return. Krista Brown Stricklen shall pay 100 percent of any liability shown on her 2019 federal income tax return. IT IS ORDERED AND DECREED that for calendar year 2019, each party shall indemnify and hold the other party and the other party's property harmless from any tax liability associated with the reporting party's individual tax return for that year unless the parties have agreed to allocate their tax liability in a manner different from that reflected on their returns. IT IS ORDERED AND DECREED that each party shall furnish such information to the other party as is requested to prepare federal income tax returns for 2019 within thirty days of receipt of a written request for the information, and in no event shall the available information be exchanged later than March 1, 2020. As requested information becomes available after that date, it shall be provided within ten days of receipt. IT IS ORDERED AND DECREED that all payments made to the other party in accordance with the allocation provisions for payment of federal income taxes contained in this Final Decree of Divorce are not deemed income to the party receiving those payments but are part of the property division and necessary for a just and right division of the parties' estate. Confirmation of Separate Property IT IS ORDERED AND DECREED that the following described property is confirmed as the separate property of Haskell Glen Stricklen: 1. The following furniture, furnishings, fixtures, goods art objects, collectibles, appliances, and equipment a. Bedroom set; FINAL DECREE OF DIVORCE - PAGE 11 Dining room set; Office chair; Entryway table; Antique sewing machine cabinet; Antique glass bar cabinet; Cedar chest; Glass top folding table; chest of drawers; tv stand; queen ann table; hand tools; m Antique belt buckle set; and n Fish and bobber 2. The funds on deposit, together with accrued but unpaid interest, in the following banks, savings institutions, or other financial institutions: a. Bank of America, Account No. ending in 8808 All sums, whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with all increases thereof, the proceeds therefrom, and any other rights related to Haskell Glen Stricklen’s Allstate Pension account existing by reason of Petitioner's past, present, or future employment. IT IS ORDERED AND DECREED that the following described property is confirmed as the separate property of Krista Brown Stricklen: 1 Respondent’s wedding ring and the stones included therein. FINAL DECREE OF DIVORCE - PAGE 12 Transfer and Delivery of Property Termination of Health Insurance Coverag IT IS ORDERED that Krista Brown Stricklen shall be relieved of the obligation to pay the health insurance premiums for Haskell Glen Stricklen as of June 26, 2019 and Krista Brown Stricklen may terminate Haskell Glen Stricklen’s health insurance as of June 26, 2019. Change of Petitioner's Name IT lS ORDERED AND DECREED that Krista Brown Stricklen's name is changed to Krista Lynne Brown. Court Costs IT IS ORDERED AND DECREED that costs of court are to be borne by the party who incurred them. Resolution of Temporary Orders IT IS ORDERED AND DECREED that Petitioner and Respondent are discharged from all further liabilities and obligations imposed by the temporary order(s) of this Court. Discharge from Discovery Retention Requirement IT IS ORDERED AND DECREED that the parties and their respective attorneys are discharged from the requirement of keeping and storing the documents produced in this case in accordance with rule 191.4(d) of the Texas Rules of Civil Procedure. Decree Acknowledgment Petitioner, Haskell Glen Stricklen, and Respondent, Krista Brown Stricklen, each acknowledge that before signing this Final Decree of Divorce they have read this Final FINAL DECREE OF DIVORCE - PAGE 13 Decree of Divorce fully and completely, have had the opportunity to ask any questions regarding the same, and fully understand that the contents of this Final Decree of Divorce constitute a full and complete resolution of this case. Petitioner and Respondent acknowledge that they have voluntarily affixed their signatures to this Final Decree of Divorce, believing this agreement to be a just and right division of the marital debt and assets, and state that they have not signed by virtue of any coercion, any duress, or any agreement other than those specifically set forth in this Final Decree of Divorce. Indemnification Each party represents and warrants that he or she has not incurred any outstanding debt, obligation, or other liability on which the other party is or may be liable, other than those described in this decree. Each party agrees and IT IS ORDERED that if any claim, action, or proceeding is hereafter initiated seeking to hold the party not assuming a debt, an obligation, a liability, an act, or an omission of the other party liable for such debt, obligation, liability, act or omission of the other party, that other party will, at that other party's sole expense, defend the party not assuming the debt, obligation, liability, act, or omission of the other party against any such claim or demand, whether or not well founded, and will indemnify the party not assuming the debt, obligation, liability, act, or omission of the other party and hold him or her harmless from all damages resulting from the claim or demand. Damages, as used in this provision, includes any reasonable loss, cost, expense, penalty, and other damage, including without limitation attorney's fees and other costs and expenses reasonably and necessarily incurred in enforcing this indemnity. FINAL DECREE OF DIVORCE - PAGE 14 IT IS ORDERED that the indemnifying party will reimburse the indemnified party, on demand, for any payment made by the indemnified party at any time after the entry of the divorce decree to satisfy any judgment of any court of competent jurisdiction or in accordance with a bona fide compromise or settlement of claims, demands, or actions for any damages to which this indemnity relates. The parties agree and IT IS ORDERED that each party will give the other party prompt written notice of any litigation threatened or instituted against either party that might constitute the basis of a claim for indemnity under this decree. Clarifying Orders Without affecting the finality of this Final Decree of Divorce, this Court expressly reserves the right to make orders necessary to clarify and enforce this decree. Relief Not Granted IT IS ORDERED AND DECREED that all relief requested in this case and not expressly granted is denied. This is a final judgment, for which let execution and all writs and processes necessary to enforce this judgment issue. This judgment finally disposes of all claims and all parties and is appealable. Date of Judgment This divorce judicially PRONOUNCED AND RENDERED in court in Denton County, Texas, on June 26, 2019 and further noted on the court's docket sheet on the same date, but signed on JUDGE PRESIDING FINAL DECREE OF DIVORCE — PAGE 15 APPROVED AS TO FORM ONLY: By: Roger M. Yale Attorney for Respondent B “Timothy Alexander Attorney for Petitioner APPROVED AND CONSENTED TO AS TO BOTH FORM AND SUBSTANCE: Haskell Glen Stricklen, Petitioner Krista Brown Stricklen, Respondent FINAL DECREE OF DIVORCE - PAGE 16