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DOMESTIC RECAHONS COURT
TID APR -9 AM 9: Sh
Bl
of COURTS
MaMTGOMERY C0. OHIO
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
DIVISION OF DOMESTIC RELATIONS
MERCEDES C. CULP LUCAS caseno. 10 DR 4 ] 1
Confidential Address 4
SSN:
DOB: 06/07/1982 non. Hon. DENISE L. CROSS
Plaintiff,
VS.
LEO C. LUCAS, II
4325 St. Johns Avenue AFFIDAVIT IN SUPPORT OF
Dayton, Ohio 45406 PLAINTIFF’S MOTION FOR
SSN: TEMPORARY RESTRAINING
DOB: 12/20/1979 ORDER
Defendant.
I, Mercedes C. Culp Lucas, being first duly cautioned and swom, depose and say:
1, Lam the Plaintiff in the above-captioned action.
2. I currently reside at an address in Montgomery County, which is currently
being held confidential.
3. Imoved out of the marital residence on approximately April 1, 2009 and several
months later Defendant leased an apartment for me located at 2308 Wayne Avenue #16,
Dayton, OH 45420. Defendant initially remained at the marital residence located at 4325 St.
Page |Johns Avenue, Dayton, OH 45406 (property owned by Defendant’s parents); however,
began living at the apartment for three-fourths of the month. Defendant ceased living at the
apartment towards the end of December 2009. I have since moved from this apartment.
4. Since ceasing to live in the apartment located at 2308 Wayne Avenue #16,
Dayton, OH 45420, Defendant has on several occasions entered this residence without my
permission.
5. 1 fear that unless restrained Defendant will enter my residence without my
consent and remove or destroy my property to which I have an interest (including my 1994
Dodge Intrepid located on the marital property) and/or cause harm to me, our son or my
other minor child.
6. 1 fear that unless restrained Defendant will enter my storage unit without my
consent and remove or destroy property to which I have an interest.
7. 1 fear that unless restrained Defendant will distribute or share with a third party,
person or entity photographs or videos of a private and intimate nature depicting me alone or
jointly with Defendant.
8. Defendant and I were martied at New Lebanon, Ohio on April 13, 2006 and we
have one (1) minor child. I am not now pregnant. I have one child from a prior relationship
living with me full time, namely: Jaydon C. Culp-Bishop born May 9, 2000, which
Defendant cares for as his son. They refer to each other as father and son and Jaydon is
covered on Defendant’s health insurance. I do receive child support from Jaydon’s father:
however, he does not otherwise participate in Jaydon’s life on any regular basis. Defendant
has one child from a prior relationship, namely: I’Bria A. Lucas, born October 30, 2004. We
refer to these three children as “our” children.
Page 29. I fear that unless restrained Defendant may attempt to dispose of assets in which
Ihave an interest.
10. I fear that unless restrained Defendant will dispose of, attempt to dispose of,
move, damage, or encumber either party's or both parties' property, real or personal, tangible
or intangible wherever located.
11. I fear that unless restrained Defendant will secrete or sequester any and all
assets, accounts, and deposits either individually held or jointly held with me.
12. I fear that unless restrained Defendant will remove me as the beneficiary of life
insurance policies or incur debt on life insurance policies, all to my detriment.
13. I fear that unless restrained Defendant will change my coverage under any
policy of insurance, including health, dental, vision, prescription and automobile
insurance.
14. I fear that unless restrained Defendant will incur debt and make credit card
purchases on accounts in either my name or our joint names.
15. I fear that unless restrained Defendant will claim our son as a dependent on any
Federal, State or Local tax return.
16. I fear that unless restrained Defendant will withdraw funds from accounts being
held for the benefit of our minor child.
17. I fear that unless restrained Defendant will use marital funds to purchase items
for a paramour, exotic dancers, prostitutes, or other professional sexual services of that
nature,
18. I fear that unless restrained Defendant wil] use marital funds for the purpose of
drug use (whether legal or illegal) except as prescribed by a physician and/or excessive
alcohol usage.
Page 319. I fear that unless restrained Defendant will molest, harass, and abuse me.
20. Further, Affiant sayeth naught.
STATE OF OHIO )
)SS
COUNTY OF HAMILTON )
Plaintiff herein, being first duly sworn, says that the facts stated herein are true
as she verily believes,
fie Sip of ON
Notary Public, State.
: ission Has No Expiration
J ooalen 447.03 RC.
Page 4
Preview
Redacted by Clerk of Court DOMESTIC RECAHONS COURT TID APR -9 AM 9: Sh Bl of COURTS MaMTGOMERY C0. OHIO IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO DIVISION OF DOMESTIC RELATIONS MERCEDES C. CULP LUCAS caseno. 10 DR 4 ] 1 Confidential Address 4 SSN: DOB: 06/07/1982 non. Hon. DENISE L. CROSS Plaintiff, VS. LEO C. LUCAS, II 4325 St. Johns Avenue AFFIDAVIT IN SUPPORT OF Dayton, Ohio 45406 PLAINTIFF’S MOTION FOR SSN: TEMPORARY RESTRAINING DOB: 12/20/1979 ORDER Defendant. I, Mercedes C. Culp Lucas, being first duly cautioned and swom, depose and say: 1, Lam the Plaintiff in the above-captioned action. 2. I currently reside at an address in Montgomery County, which is currently being held confidential. 3. Imoved out of the marital residence on approximately April 1, 2009 and several months later Defendant leased an apartment for me located at 2308 Wayne Avenue #16, Dayton, OH 45420. Defendant initially remained at the marital residence located at 4325 St. Page |Johns Avenue, Dayton, OH 45406 (property owned by Defendant’s parents); however, began living at the apartment for three-fourths of the month. Defendant ceased living at the apartment towards the end of December 2009. I have since moved from this apartment. 4. Since ceasing to live in the apartment located at 2308 Wayne Avenue #16, Dayton, OH 45420, Defendant has on several occasions entered this residence without my permission. 5. 1 fear that unless restrained Defendant will enter my residence without my consent and remove or destroy my property to which I have an interest (including my 1994 Dodge Intrepid located on the marital property) and/or cause harm to me, our son or my other minor child. 6. 1 fear that unless restrained Defendant will enter my storage unit without my consent and remove or destroy property to which I have an interest. 7. 1 fear that unless restrained Defendant will distribute or share with a third party, person or entity photographs or videos of a private and intimate nature depicting me alone or jointly with Defendant. 8. Defendant and I were martied at New Lebanon, Ohio on April 13, 2006 and we have one (1) minor child. I am not now pregnant. I have one child from a prior relationship living with me full time, namely: Jaydon C. Culp-Bishop born May 9, 2000, which Defendant cares for as his son. They refer to each other as father and son and Jaydon is covered on Defendant’s health insurance. I do receive child support from Jaydon’s father: however, he does not otherwise participate in Jaydon’s life on any regular basis. Defendant has one child from a prior relationship, namely: I’Bria A. Lucas, born October 30, 2004. We refer to these three children as “our” children. Page 29. I fear that unless restrained Defendant may attempt to dispose of assets in which Ihave an interest. 10. I fear that unless restrained Defendant will dispose of, attempt to dispose of, move, damage, or encumber either party's or both parties' property, real or personal, tangible or intangible wherever located. 11. I fear that unless restrained Defendant will secrete or sequester any and all assets, accounts, and deposits either individually held or jointly held with me. 12. I fear that unless restrained Defendant will remove me as the beneficiary of life insurance policies or incur debt on life insurance policies, all to my detriment. 13. I fear that unless restrained Defendant will change my coverage under any policy of insurance, including health, dental, vision, prescription and automobile insurance. 14. I fear that unless restrained Defendant will incur debt and make credit card purchases on accounts in either my name or our joint names. 15. I fear that unless restrained Defendant will claim our son as a dependent on any Federal, State or Local tax return. 16. I fear that unless restrained Defendant will withdraw funds from accounts being held for the benefit of our minor child. 17. I fear that unless restrained Defendant will use marital funds to purchase items for a paramour, exotic dancers, prostitutes, or other professional sexual services of that nature, 18. I fear that unless restrained Defendant wil] use marital funds for the purpose of drug use (whether legal or illegal) except as prescribed by a physician and/or excessive alcohol usage. Page 319. I fear that unless restrained Defendant will molest, harass, and abuse me. 20. Further, Affiant sayeth naught. STATE OF OHIO ) )SS COUNTY OF HAMILTON ) Plaintiff herein, being first duly sworn, says that the facts stated herein are true as she verily believes, fie Sip of ON Notary Public, State. : ission Has No Expiration J ooalen 447.03 RC. Page 4