STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR CALHOUN COUNTY

FAMILY DIVISON

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NOW COMES the Plaintiff, WILMA JEAN FLINTSTONE, who first being duly sworn, states:

1. There is no other pending or resolved action within the jurisdiction of the Circuit Court's Family Division involving the family or any family members of the person who is subject of the Complaint.
   
2. There is no other pending or resolved civil action arising out of the transaction or occurrence alleged in the Complaint.
   
3. The Plaintiff and Defendant have been residents of Michigan for at least 180 days and of Calhoun_. County for at least ten (10) days immediately preceding the filing of this Complaint.
   
4. On May 29, 1995, the parties were legally married in the City of Sandstone, Calhoun County, Michigan by a priest at St. Paul's Cathedral.
   

1. Prior to the marriage, the Plaintiff's name was Wilma Jean Lightrock and is Wilma Jean Flintstone; that prior to this marriage the Defendant's name was Frederick Flint Flintstone and is Frederick Flint Flintstone. There was one child born of this marriage: Pebbles Alecia Flintstone, born March 15, 2002, Social Security Number 371-04-5589.
   
   1. During the past five years, the minor child, Pebbles Alecia Flintstone, has resided with both parents at 711 South Gravel Drive in the City of Sandstone, Calhoun County, Michigan.
      
   2. That although Defendant has participated in raising the minor child, Plaintiff has been the primary caretaker for the parties' minor child since her birth.
      
   3. Plaintiff has not participated in any capacity in any litigation in this or any other jurisdiction concerning the custody of said minor child.
      
   4. Plaintiff has no knowledge of any person not a party to this proceeding who has physical custody, claims to have physical custody, or has visitation rights with respect to the parties' minor child.
      
   5. The Plaintiff is not pregnant.
      
   6. The parties have acquired martial assets and debts during this marriage to be divided by this Court.
      
   7. There has been a breakdown in the marriage relationship to the extent that the objects of matrimony have been destroyed and there remains no reasonable likelihood that the marriage can be preserved.
      

   WHEREFORE, Plaintiff requests this Court to:
   

   1. grant a judgment of divorce;
      
   1. grant both parties joint legal custody of the minor child;
      
   2. grant Plaintiff physical custody of the minor child;
      
   3. grant an equitable division of martial assets;
      
   4. grant an equitable division of martial debts; and
      
      1. grant Plaintiff any such other and further relief in the premises as is agreeable to equity and good conscience.
         

         
          

The statements made herein are true to the best of my knowledge, information and belief.

Dated: November 29^th 2010

Wilma Jean Flintstone

STATE OF MICHIGAN

COUNTY OF CALHOUN

Subscribed and sworn to before me on this 29th day of November, 2010 by

 

WILMA JEAN FLINTSTONE, Plaintiff herein.

 

 

Eddie D. Egghead Jr.

Notary Public, Calhoun County

My commission expires: 10/25/2012

Prepared by:

Chrinchutton Cheeturn (P01010)

Attorney for Plaintiff

1500 Sabortooth Tiger Boulevard

Sandstone, MI 49099-7990

(269) 777-1111

 

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR CALHOUN COUNTY

FAMILY DIVISON

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FIRST INTERROGATORIES AND

REQUESTS FOR THE PRODUCTION OF DOCUMENTS.

Pursuant to MCR 2.309 and MCR 2.310, WILMA JEAN FLINTSTONE, by and through her attorneys, requests that FREDERICK FLINT FLINTSTONE prepare answers separately and fully in writing and under oath to the following interrogatories, produce the requested documents, and serve a copy of the answers and documents on attorneys for WILMA JEAN FLINTSTONE within the time frame allowed by applicable court rules.

Each of the following interrogatories and requests for the production of documents is deemed continuing in accordance with the parameters in MCR 2.302(E).

DEFINITIONS

As used in these interrogatories, the following terms have the following meanings:

1. Plaintiff refers to WILMA JEAN FLINTSTONE
   
2. Defendant refers to FREDERICK FLINT FLINTSTONE.
   

   C.'    Document means, without limitation, any written, printed, typed, or other graphic matter of any kind or nature or any writing, drawing, graph, chart, photograph, photo record, tape recording, or other data compilation from which information can be or could have been obtained and also means all copies of documents by whatever means made.
   

   D.    Person includes, without limitation, any natural person, proprietorship, firm, association, partnership, corporation, joint venture, government, or other entity and all affiliates, present or former agents, sureties, indemnitors, servants, employees, representatives, and all other persons acting on behalf or in the interest of the person.
   

   E.    Identify means the following:
   

   1. when used in reference to a natural person, to state his or her full name, address, business address, employer, and position
      
   2. when used in reference to someone other than a natural person, to state its full name, type of entity, address, nature of business, and the person in charge of the principal office
      
   1. when used in reference to a document, to state the type of document, its date, its author, its addressee, and the person who presently has possession or control of it (As an alternative to such identification, you may produce documents for inspection and copying when you file answers to these interrogatories; however, all documents produced will be segregated and identified by the interrogatory to which they are primarily responsive.)
      
      1. when used in reference to an event or occurrence, to state the date and location, a description, and the names and addresses of those involved, if known.
         

   F.    When requested to state the factual basis of any allegation, identify each occurrence,
   

   incident, or fact on which you rely to support the allegation, including the date, place, and substance of each occurrence, incident, and fact and the source of your knowledge.
   

   G.
   If any of these interrogatories or requests for production cannot be answered in full, you are to answer to the extent and in the manner possible; estimates should be identified as such.
   

   
    

   INTERROGATORIES
   

   1.    For each and every employment of any kind you have had during the past five years, state:
   

   1. THE
      name and last known address of each employer;
      
   1. the inclusive dates of each employment;
      
      1. gross annual income from each employment in each year (including income of any kind, whether wage, commission, bonus, or other);
         
      2. monthly gross income from each employment this year, itemizing the amount and nature of deductions;
         
      3. commissions and bonuses anticipated in the next 12 months, specifying whether the compensation is earned or unearned at this time; and
         
      4. a brief description of your duties.
         

      Attach to your answers all proof of income you received to date this year from any source (for example, pay stubs for the last three months).
      

   2    Attach a complete copy of each income tax return you filed during the past five years.
   

   Do you have any passive carryover that you are cur^rently claiming or to which you will be entitled in the foreseeable future?
   

   3.    For each interest you have in any annuity, pension, profit-sharing, retirement, stock purchase, individual retirement account, 401 K, or other deferred benefit plan, state
   

   1. The type of plan (for example, annuity, stock savings, etc.);
      
   1. the date your interest began;
      
      1. your total contributions in each plan as of the date of these interrogatories (list each separately);
         
      2. as of the date of these interrogatories, all contributions to each plan made on your behalf other than those listed in your preceding answer;
         
      3. a current inventory of all assets in your account in each plan;
         
      1. the present-value of your interest in each plan and the method used to ascertain present value;
         
      2. the name, last known address, and telephone number of the plan administrator of each plan;
         
         1. your vested percentage in each plan;
            
            1. your years of credited service in each plan; and
               

      j.    the total amount of accrued benefits in each plan.
      

   Attach a written copy of each plan, a summary plan description, and a copy of the most recent statement relating to your interest in each plan.
   

   
    

       4.    For each debtor who owes you money on any notes, mortgages, land contracts, loans, or otherwise, state
   

   1. the debtor's name and last known address;
      
   2. the current amount owed;
      
   3. the original amount of the obligation;
      
   4. the form of the obligation;
      
   5. the date the obligation was incurred;
      
   6. the date the obligation becomes due and owing;
      
   7. the conditions for payment of the obligation; and
      
   8. the consideration given for the obligation.
      

   Attach copies of all documentation in your possession regarding each indebtedness.
   

       5.    For each motor vehicle you have an interest in, state
   

   1. its year, make, model, and vehicle identification number;
      
   1. the name and address of the registered owner;
      
   2. the name of the primary driver;
      
   3. the value of the vehicle; and
      
      1. the amount owing on the vehicle, to whom, account number, balance due, and the minimum monthly payment.
         

          6.    For any equipment, machines, furniture, furnishings, or other personal property you have had an interest in during the past year with a value in excess of $500, including the personal property located at [Plaintiff's (Defendant's] residence, state
      

   4. a complete description;
      
   5. the date of purchase;
      
   6. the estimated present market value;
      
   7. the amount owed on the property and to whom it is owed;
      
   8. the property's present location; and
      
   9. if the property has been sold or otherwise disposed of,
      

      i    the date of the sale,
      

      1. the name and last known address of the recipient,
         
      1. how it was disposed of, and
         
         1. what you received in exchange for the property (for example, money, other property, services, etc.).
            

          7.    Give a complete description and state the present value of any collections you own such
      as stamps, coins, paintings, antiques, etc.
      

       8.    If, during the past four years, you have been an officer, a director, or a consultant to any
   corporation, partnership, joint venture, or other entity, identify that relationship.
   

       9.    If, during the past four years, you purchased or had an ownership interest in any securities, including stocks, bonds, debentures, or mortgages, state
   

   1. the name of the corporation or entity,
      
   2. the type and number of shares,
      
   3. the type of ownership,
      
   4. the date of acquisition,
      
   5. the purchase price,
      
   6. the present market value, and
      
   7. the amount owed, if any.
      

       10.    If, during the past four years, you have sold any securities, state
   

   1. the type and number of securities sold,
      
   2. the name of the security,
      
   3. the date of the sale,
      
   4. the sale price,
      
   5. the net gain or loss resulting from the sale, and
      
   6. the name and last known address of the purchaser.
      

          11.    If, during the past four years, you have had any savings or checking accounts in your name, solely or jointly with others, with any bank, stock broker, or other financial institution, state
      

   7. the name and address of the institution,
      
   8. the type of account,
      
   9. the names on the account and the type of ownership,
      
   10. the persons authorized to draw on the account,
       
   11. the date the account was opened,
       
   12. the date the account was closed,
       

       g,    the account number,
       

   13. the balance on deposit 30 days before this lawsuit was commenced,
       
   14. the balance on the date of these interrogatories, and
       

       j,    the present balance, if any, or the balance when the account was closed.
       

       Please provide copies of the monthly statements for each account for six months preceding the filing of this lawsuit and for every month after the suit was filed.
       

       
        

       12.    If, during the past four years, there have been any bank accounts on which your name did not appear in which you either deposited or withdrew any money, state
       

       1. the name and address of the bank,
          
       2. the name on the account at the time of each deposit or withdrawal,
          
       3. the account number,
          
       4. the date and amount of each deposit and withdrawal you made, and
          
       5. the reason for the deposit or withdrawal.
          

   13.    If there are any safe deposit boxes, vaults, safes, or other places of deposit and safekeeping in which you deposited or had on deposit any money, documents, or other items of personal property during the past three years, or to which you have a right of access, state
   

   1. the name and address of the location,
      
   2. the number or other means of identification,
      
   3. the name and last known address of each person authorized to enter it,
      
   4. the date you obtained rights to deposit assets at the location,
      
   5. the contents presently contained there, and
      
   6. an inventory of all contents removed since this lawsuit commenced.
      

      
       

       14.    If you have had any interest in any real property during the past four years (including
   property in which your interest is a reversion, remainder, or contingent), state
   

   1. the address and legal description,
      
   2. a description of the property,
      
   3. the conditions and terms tinder which it is held,
      
   4. the present market value of the property and your interest in it, and
      
   5. the date that interest began.
      

      Attach all agreements that contain any of the terms by which the property is being held for your. benefit.
      

       15.    If you hold property for the benefit of another person in trust or otherwise, state
   

   1. the name and last known address of the beneficial owner,
      
   2. a description of the property,
      
   3. the present market value of the property,
      
   4. the current amount of any liens or encumbrances on it,
      
   5. the conditions and terms under which it is held, and
      
   1. the date the interest began.
      

      
      Attach all agreements that contain any of the terms by which you are holding the property
      for the benefit of another.
      

   16 If, during the past four years, you owned or had an interest in any life insurance or
   
   

   1. the name and address of the insurance company,
      
   2. the number of the policy,
      
   3. the type of the policy (for example, term, whole life, etc.),
      
   4. the, face value of the policy,
      
   5. the amount of the annual premium,
      
   6. the name and last known address of each beneficiary named in the policy,
      
   7. the name and last known address of each owner of the policy,
      
   8. the amount and date of each loan on the policy during the past three years,
      
   9. the current loan balance, and
      
   10. the present cash surrender value including dividends.
       
   1. List in detail any benefits that you receive or to which you
      are entitled, together with their actual or estimated value, from any association, employer (past or present), or other entity, including but not limited to automobile, travel, and entertainment expenses; bonuses; and health, accident, and hospitalization insurance.
      
   2. List all sources of income you have had during the last four years not referred to in the
      

      preceding interrogatories, together with the gross amount received from each source and the approximate dates you received them.
      

   1. If you own or have an interest in any personal property, real property, or stun of money that you claim your spouse has no interest in, state
      
      1. A description of the property,
         
      2. the location of the property,
         
      3. the present value of the property,
         
      4. the date and method of acquisition of the property,
         
      5. the source of funds used to acquire the property,
         
      6. the name of each owner of the property and his or her ownership interest, and
         
      7. the reason you claim that your spouse has no interest in the property.
         
      1. If you have any outstanding obligations (not referred to above), including but not limited to mortgages, conditional sales contract obligations, promissory notes, or charge or credit
         
         1. accounts, state
            
         2. the name and address of the creditor,
            
         3. the form of the obligation,
            
         4. the date the obligation was incurred,
            
         5. what you received in exchange for the obligation,
            
         6. a description of any security given for the obligation,
            
         7. the amount of the original obligation,
            
         8. the rate of interest on the obligation,
            
         9. the present unpaid balance on the obligation,
            
         10. the date and amount of installment repayment,
             
         11. whether each obligation is current or delinquent and, if delinquent, for how long, and
             
         12. the names and addresses of any codebtors,
             

       21.    What loans have been repaid by you or on your behalf during the past year?
   

       22.    If you transferred property of any nature to others in trust, by gift, by loan, or otherwise during the past four years having an aggregate value in excess of $500, state
   

   1. a description of the property,
      
   2. the name and last known address of the party to whom a transfer was made,
      
   3. what you received in exchange for the transfer,
      
   4. the value of the property at the time of the transfer,
      
   5. the present value of the property,
      
   6. the present Location of the property, and
      
   7. the exact details of the transfer. Attach copies of any writing that contains information regarding the transaction.
      

      
       

      23.    If, during the past five years, you have prepared, signed, or submitted any financial statement for any purpose whatsoever, state
      

      1. the date of each statement;
         
      2. the name, last known address, and telephone number of the person or entity who prepared each statement;
         

         c,    the name, last known address, and telephone number of the person or entity to whom each statement was submitted;
         

      3. the purpose of preparation; and
         
      4. the name, last known address, and telephone number of each person or entity that has a copy of the statement.
         

   Attach a copy of each statement.
   

   24.    If, other than this lawsuit, you have any interest in or are a party to any other action now pending or in which there is an unsatisfied judgment in any court, administrative agency, etc., state
   

   1. the nature of the interest;
      
   2. the nature of the case
      
   3. the court, the title, and the docket number; and
      

      d.    the amount of any unsatisfied judgment, together with the name and address of the obligor and the obligee.
      

   25.    If you own or have an interest in any property of any nature not referred to above, state
   

   a.    a complete description of the property;
   

   b.    the present Location of the property;
   

   c.    the estimated present market value of the property;
   

   1. the indebtedness now owing on the property and the name and address of the party to whom it is owed; and
      
   2. the name, last known address, and telephone number of every other person with an ownership interest in the property, indicating the nature and extent of each person's interest.
      

       26.    Have you been a party to any agreement in which you granted an option to anyone to purchase any of your assets during the past five years? If so, please specify the terms of that option agreement.
   

       27.    If, during the past three years, you offered to sell or anyone offered to purchase any of the property in which you currently have an interest, state
   

   1. the name and last known address of the offerer,
      
   1. the name and last known address of the offeree,
      
   2. the property subject to the offer,
      
   3. the date of the offer,
      
   4. the amount of the offer,
      
   5. the offeree's
      response to the offer,
      
   6. whether the offer was oral or written, and
      
      1. the name and last known address of each party who has a copy of the offer or the reply to it.
         

      Attach a copy of the offer and responses to the offer,
      

          28.    If any of the assets mentioned in your answers to interrogatories have been appraised or evaluated during the past three years, state
      

      1. the name, last known address, and telephone number of the party who made the appraisal or evaluation;
         
      2. the name, last known address, and telephone number of the employer of each person mentioned in your answer to the prior interrogatory;
         
      3. the purpose for which it was made;
         
      4. the date it was made; and
         
      5. the appraised value.
         

         
          

   29.    What is your date of birth?
   

   1. What is your Social Security number?
      
   1. What is you driver's license number?
      
   2. State the name, last known address, and telephone number of each person you may call on to testify at the trial of this cause and indicate the specific nature of each person's anticipated testimony.
      
3. Attach to your answers to these interrogatories copies of anything you may introduce as an exhibit at the trial.
   
4. Identify each and every educational institution you attended since and including high school and for each such institution state
   
   1. its name and address,
      
   2. your dates of attendance,
      
   3. your areas of study, and
      
   4. the degree or certificate you acquired.
      

      
       

   1.     Do you have any cash
      in excess of $500 in your custody, or does anyone else hold any cash for you? If so, specify the amount of the cash in U.S. currency equivalent and its location. If someone else has custody of this money, state the name, address, and telephone number of this person.
      

   
    

   Cheetum, Dewey & Howe
   

   
   By ____________________________________
   

   
    

   CHRINCHUTTON CHEETUM (P01010)
   

   Attorney for Plaintiff
   

   1500 Sabertooth Tiger Boulevard
   

   Sandstone, MI 49099
   

   (269) 777-1111
   

   
    

   
    

   
    

   
    

   Dated:__________________________________