State of Tennessee) 9) OF 1100 iG OCT 21 PHI2:43 IN THE CIRCUIT COURT OF HAMILTON COUNTY LARRY L- HENRY, CLERK ROBERT STONE Y Plaintiff v. No. 2 OVS LACIE STONE Defendant SUMMONS ‘TO: LACIE STONE. PLAINTIFF'S ATTORNEY WILL SERVE Defendant “Address Defendant ‘Address Defendant ‘Address You are hereby summoned to answer and make defense toa bill of complaint which has been filed in the Circuit Court of Hamilton County, Tennessee in the above styled ease. Your defense to this complaint must be filed in the office ofthe Cireuit Court Clerk of Hamilton County, Tennessee on oF before thirty (30) days after service of this summons upon you. 1 f you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. WITNESSED and Issued this day of »20__. Larry Henry, Circuit Court Clerk By Deputy Circuit Court Clerk Attomeys for Plaintiff _Jillyn O'Shaughnessy & Katherine Lentz, Esq. Grant, Konvalinka & Harrison, P.C. 633 Chestnut Street, Suite 900, Chattanooga, TN_ 37450; 423-756-8400 Address Plaintiff's Address Received this day of 20. 1S! Deputy SheriffIN THE CIRCUIT COURT OF HAMILTON COUNTY, TENNESSEE!!! (95° jj; 2016 Oct 2] ROBERT STONE, ) . PH l2: 43 Plaintiff, } NO. wes uscenel Hi esi - ; Division —_ SI LACIE STONE, } Defendar } COMPLAL Comes now the Plaintiff, ROBERT STONE, by and through counsel, Grant, Konvalinka & Harrison, P.C,, and files this Complaint for Divorce against Defendant, LACIE STONE. Plaintiff states as follows: lL. Robert Stone (hereinafter, “Plaintiff”) and Lacie Stone (hereinafter, “Defendant”) are residents of Chattanooga, Hamilton County, Tennessee and have been residents of Tennessee for at least six whole months prior to the filing of this Complaint, making jurisdiction and venue proper in this Court. 2. ‘The statistical information required by Tennessee Code Annotated §36-4-106 to be included in a divorce complaint is attached hereto as Exhibit 1 to this Complaint and is hereby incorporated herein by reference. 3. The parties’ mailing addresses and social security numbers are filed as a separate document in a sealed envelope with the office of the Circuit Court Clerk as required T.C.A. § 36- 4-106(b)(1). 4. ‘The parties participated in a marriage ceremony on November 13, 2008 in Jost Van Dyke in the Territory of the British Virgin Islands. Upon information and belief, if certain requirements were satisfied, the marriage would be recognized in the State of Tennessee. Nochildren have been born of this union and no children are expected. As grounds for divorce, the Defendant committed adultery, thereby constituting grounds for divorce pursuant to the provisions of T.C.A. §36-4-101(3). Plaintiff requests that a divorce be granted on said grounds, or in the alternative, on the grounds of inappropriate marital conduct pursuant to §36-4-101(11) or irreconcilable differences pursuant to §36-4-101(14). 6. The parties may have accumulated certain assets and liabilities during the marriage which constitute marital property. However, Plaintiff has significant value of separate property which is not subject to any equitable distribution other than to Plaintiff. The parties therein may enter into and present to the Court for approval and ratification a written notarized marital dissolution agreement providing for an equitable settlement of any property rights and liabilities accumulated during the marriage. However, if the parties are unable to come to an agreement then Plaintiff asks this Court to come to a fair and equitable settlement of the parties’ property rights and liabilities. 7. Notice to parties required by T.C.A. §36-4-106(d) is attached to this Complaint and incorporated herein as Exhibit 2. WHEREFORE, Plaintiff demands: a. ‘That process issue and be served upon Defendant, requiring her to appear and answer, b. That at the hearing of this cause, Plaintiff be granted an absolute divorce from Defendant and that the parties be restored to all of the rights and privileges of unmarried persons. c. That the Court make an equitable division and distribution of the marital property owned by the parties, and make a reasonable allocation of the liabilities accrued during this marriage, or in the event that the parties are able to enter into a marital dissolution agreementresolving those matters of equitable division of marital property, and allocation of liabilities, that the Court approve such agreement. d. That Plaintiff have such other and further relief to which he may be entitled, including but not limited to his attorney’s fees and costs, Respectfully submitted, GRANT, KONVALINKA & HARRISON, P.C. By: .(O’Shaughnessy (BPR #024832) Kaihdlin#H. Lentz (BPR #023687) Attorneys for Plaintiff 633 Chestnut Street, Suite 900 Chattanooga, TN 37450-0900 (423) 756-8400/(423) 756-6518DM OF VERIFICATION OFFICE STATE OF TENNESSEE: @MISCCT 21 PHI2: 43 COUNTY OF HAMILTON: 1, ROBERT STONE, after first being duly sworn, do hereby make soieiin-oath thatthe. _p¢ statements contained in the foregoing complaint are true to the best of my knowledge, information and belief; that my complaint is not made out of levity or by collusion with the Defendant, but in sincerity and truth for the causes mentioned in the bill; that I am informed and verily believe that the Defendant is not a member“ofAhe Armed Forces of the United States of America. ROBERT STONE. SWORN TO AND SUBSCRIBED before me this My commission expires:PUBLIC ACTS, 2001 CHAPTER NO. 280 HOUSE BILL NO. 1136 VE OF Fi BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF TENN@RMEBET 21 PH 12: 43 Section 36-4-106, is amended) Valdingl iRY foll6Wing as a new SECTION 1. Tennessee Code Annotated, subsection (d): (2) Upon the filing of a petition for divorce or legal separation, and Upow personal Service of the complaint and summons on the respondent or upon waiver and acceptance of service by the respondent, the following temporary injunctions shall be in effect against both parties until the final decree of divorce or order of Tegal separation is entered, the petition is dismissed, the parties reach agreement, or until the court modifies or dissolves the injunction, written notice of which shall be served with the complaint: (QA) An injunction restraining and enjoining both parties from transferring, assigning, borrowing against, concealing or in any way dissipating or disposing, without the consent of the other party or an otder of the court, of any marital property. Nothing herein is intended to preclude either of the parties from seeking broader injunctive relief from the court. (B) Expenditures from current income to maintain the marital standard of living and the usual and ordinary costs of operating a business are not restricted by this injunction. Each party shall maintain records of all expenditures, copies of which shall be available to the other party upon request. (2) An injunction restraining and enjoining both parties from voluntarily canceling, modifying, terminating, assigning, or allowing to lapse for nonpayment of premiums, any insurance policy, including, but not limited to, life, health, disability, homeowners, renters, and automobile, where such insurance policy provides coverage to either of the parties or the children, or that names either of the parties or the children as beneficiaries without the consent of the other party or an order of the court "Modifying" includes any change in beneficiary status (3) An injunction restraining both parties from harassing, threatening, assauiting or abusing the other and from making disparaging remarks about the other to or in the presence of any children of the parties or to either party's employer. (4) An injunction restraining and enjoining both parties from hiding, destroying or spoiling, in whole or in part, any evidence electronically stored or on computer hard drives or other memory storage devices (5) An injunction restraining both parties from relocating any children of the parties outside the state of Tennessee, or more than one hundred (100) miles from the marital home, without the permission of the other party or an order of the court, except in the case of a removal based upon a well-founded fear of physical abuse against either the fleeing parent or the child, In such cases, upon request of the non- relocating parent, the court will conduct an expedited hearing, by phone conference if appropriate, to determine the reasonableness of the relocation and to make such other orders as appropriate. (6) The provisions of these injunctions shall be attached to the summons and the complaint and shall be served with the complaint. The injunetions shall become an order of the court upon fulfillment of the requirements of this subsection (4). However, nothing in this subsection (d) shall preclude either party from applying to the court for further temporary orders, an expanded temporary injunction, or modification or revocation of this temporary injunction, (1) The temporary injunctions provided in this section shall only apply to the spousal parties named in the petition and shall not apply to any third party named in the petition; provided, however, that nothing in this subsection (d) shall preclude any party from applying to the court for an order of injunetive or extraordinary relief against any other party named in any petition as provided by law or rule.