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  • IMM MCCARTY DIVORCE WAIVER W/CHILD (FAMILY LAW) document preview
  • IMM MCCARTY DIVORCE WAIVER W/CHILD (FAMILY LAW) document preview
  • IMM MCCARTY DIVORCE WAIVER W/CHILD (FAMILY LAW) document preview
						
                                

Preview

Filed 11 December 29 A11:45 Amalia Rodriguez-Mendoza District Clerk Travis District D-1-FM-11-007073 Cause No. IN THE MATTER OF IN THE DISTRICT COURT THE MARRIAGE OF Shannon McCarty PETITIONER JUDICIAL DISTRICT AND Matthew Todd McCarty RESPONDENT TRAVIS COUNTY, TEXAS AND IN THE INTEREST OF Riley Cary McCarty , A CHILD Tess Jordan McCarty , A CHILD Tabitha Claire McCarty, A CHILD ORIGINAL PETITION FOR DIVORCE Petitioner and Respondent have accumulated a marital estate which is valued at more than $50,000.00 and have children of the marriage under the age of 18. Petitioner requests that discovery in this case proceed under Level 2 of Rule 190 of the Texas Rules of Civil Procedure. This suit is brought by Petitioner, Shannon McCarty, age 41, who resides at 7205 Chimney Corners, Austin, Texas in Travis County, Texas. Respondent is Matthew Todd McCarty, age 42, who resides at 7204 Lamplight Ln, Austin, Texas in Travis County, Texas. Page 1 of 3Petitioner has been a domiciliary of the State of Texas for the preceding six months and a resident of Travis County for the preceding ninety days. i No service of citation upon Respondent is necessary at this time. iil Petitioner and Respondent were married on or about August 13, 1994. On or about December 1, 2011 the parties separated or ceased marital relations. IV The marriage has become insupportable because of discord or conflict of personality which destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation of reconciliation. Vv The following children, now under 18 years of age, were born to or adopted by the parties to this marriage. Riley Cary McCarty, a male, born on November 30, 1998 in Plano, Texas. Tess Jordan McCarty, a female, born on February 16, 2000 in Austin, Texas. Tabitha Claire McCarty, a female, born on February 16, 2000 in Austin, Texas. The children currently reside at 7204 Lamplight Lane, Austin, Texas. No other Court has continuing, exclusive jurisdiction over these children and no previous Court ordered relationships between these children and any other party exist. No other party is entitled to notice or citation of this suit. No property is owned or possessed by these children. VI Page 2 of 3Petitioner and Respondent should be appointed Joint Managing Conservators of the children and Petitioner should have the right to establish the primary residence of the children Petitioner proposes that Petitioner shall establish or maintain in effect health care coverage for the parties children. Respondent should be accorded liberal and specified visitation privileges. VIL Certain community property has been accumulated during the course of the marriage. Petitioner proposes that she be awarded 50% of all property and possessions. xX No protective order has been issued or is pending in this case. PRAYER Petitioner prays that the Court grant a divorce and decree such other relief as requested by this Petition. Petitioner prays for any and all relief to which Petitioner may be entitled. SHANNON MCCARTY PETITIONER, PRO SE December 29, 2011 Page 3 of 3