SUPERIOR COURT OF THE DISTRICT OF COLUMBIA FAMILY COURT DOMESTIC RELATIONS BRANCH SANDRA S. JACKSON 2034 O Street, NW Washington, D.C. 20036 Plaintiff, : CASENO: /0D€6 fz ve : JESSE JACKSON, JR. 2034 O Street, NW Washington, D.C. 20036 Defendant. COMPLAINT FOR LEGAL SEPARATION, ABSOLUTE DIVORCE, CHILD CUSTODY, CHILD SUPPORT, ALIMONY, SUIT MONEY AND OTHER RELIEF (ACTION INVOLVING CHILD SUPPORT) Plaintiff Sandra S. Jackson, by and through counsel, LAW OFFICES OF CHANDRA WALKER HOLLOWAY, P.C. hereby files her Complaint for Legal Separation, Absolute Divorce, Child Custody, Child Support, Alimony, Suit Money and Other Relief, and in support thereof states as follows: JURISDICTION 1. This Court has jurisdiction pursuant to D.C. Code § 11-1101, § 16-4602.01 and § 16-901 et seq. 2. The Plaintiff is an adult ci en of the United States and has been a resident of the District of Columbia for more than six months immediately preceding the filing of the Complaint. TOpOMED AON ST.3. The Defendant Jesse Jackson, Jr. is an adult citizen of the United States and a resident of District of Columbia for more than six months immediately preceding the filing of the Complaint. 4, The parties were lawfully married on June 1, 1991 in Chicago, Illinois. 5. There were two children bor of the marriage, namely J.D.J, born March 13, 2000 and J.LJ., born September 19, 2003 (“minor children"). Pursuant to D.C. Code 16-4602.01, the District of Columbia is the home state of the minor children as they have resided in Washington, D.C. for at least six (6) months immediately prior to the filing of this Complaint. The minor children have always resided and attended school in the District of Columbia, 6. The parties last cohabitated as husband and wife at 2034 O Street, NW, Washington, DC 20036. GROUNDS FOR DIVORCE 7. The parties separated in spring 2016 and the separation has continued uninterruptedly without cohabitation as of the date of the filing of this Complaint. ‘There is no reasonable expectation of reconciliation between the parties, (CHILD Custopy 8. Plaintiff has a close bond with the minor children and has spent a significant amount of time caring for, teaching, and rearing the minor children. Plaintiff is a fit and proper person to have sole physical and legal custody of the minor children; Plaintiff requests sole physical and legal custody of the minor children, 9. Defendant should pay child support in an amount required by the District of Columbia Child Support Guidelines for support of the minor children.MARITAL PROPERTY 10. The parties acquired real property, retirement accounts, bank accounts, brokerage accounts, furniture, furnishings and the like. All property and/or debts acquired during the marriage deemed to be marital should be equitably divided and distributed between the parties. ALIMONY 11. The Plaintiff's monetary and non-monetary contributions to the well-being of the family throughout the marriage of the parties have been substantial; the Plaintiff contributed to the well-being of the family by working outside of the home and by being a caretaker of the home and the minor children. 12, The Plaintiff does not have the ability to be fully self-supporting and is entitled to alimony. The Defendant has the ability to pay alimony to the Plaintiff. 13, Plaintiff has not participated as a witness, or in any other capacity, in any other proceeding conceming the custody of, or visitation with the minor children, other than being named as a respondent filed in a praecipe filed with the Circuit Court of Cook County, Illinois in Case No. 16 D 6506, for which a motion to dismiss will be filed for lack of personal and subject ‘matter jurisdiction. No cause of action for divorce, custody or any other relief has been filed with the Circuit Court of Cook County, Illinois. Plaintiff does not know of any person not a party to these proceedings who has physical custody of the minor children, or claims rights to legal custody or physical custody of, or visitation with the minor children. WHEREFORE, Plaintiff Sandra S. Jackson, requests that the Court grant the following relief: A. That Plaintiff be awarded a Legal Separation from Defendant, with it being enlarged to an Absolute Divorce upon the expiration of the applicable time period;B. That Plaintiff be awarded sole legal and sole physical custody of the minor children, pendent lite and permanently; C. That Plaintiff be awarded alimony, pendente lite and permanently; D. That Plaintiff be awarded child support, pendente lite and permanently; E. That Plaintiff be awarded exclusive use and possession of the parties’ real property located at 2034 O. Street, NW, Washington, D.C. 20036, and that Defendant be ordered to pay the mortgage together with real estate taxes, insurance and other expenses in connection with the property and utilities, pendente lite; F. That the Court determine the legal title, ownership and value of all property of the parties, ascertaining which is separate and which is marital property; that the marital property be awarded to Plaintiff as her legal and equitable interests may dictate; that the Plaintiff be awarded all property that is her separate property as her legal and equitable interests may dictate, and that the property included in the marital estate be awarded to Plaintiff as her legal and equitable interests may dictate; G. That pending a final determination of support and property issues, the Defendant be restrained and enjoined from selling, secreting, giving away, or otherwise disposing of or encumbering any assets, whether held jointly with Plaintiff, individually by Defendant, or jointly by Defendant and any third party or entity, that he be ordered to refrain from use of any credit on which Plaintiff is obligated, and that he be ordered to obtain and the full financial disclosure as requested; and that the Court order Defendant to account for any assets liquidated, invested, sold, transferred, gifted or otherwise disposed of during the parties” marriage to the date of trial, and that any improper transfers or conveyances of marital property be set aside or that a constructive trust be imposed;H. That the Court determine debts which were incurred prior to the dissolution of the marriage, and for entry of an Order apportioning the debts between the parties, taking into consideration who is primarily responsible for incurring said debts, and/or ordering the payment of said debts as the Court may deem appropriate upon consideration of the various factors as necessary by law; 1. That the Court grant the Plaintiff a monetary award as an adjustment of equities including the amount and method of payment, taking into account any sums that Defendant has dissipated from the parties’ marital assets; J That this Court enter an Order requiring the Defendant to pay the Plaintiff a reasonable sum as and for attorney's fees, suit money, costs, and expert fees for these proceedings; K. That the Court order that no assets or property be dissipated, transferred, liquidated or otherwise disposed of by the Defendant, pendente lite; and L. __ Forsuch other and further relief that this Honorable Court deems just and proper. VERIFICATION I, SANDRA S. JACKSON, HEREBY AFFIRM THAT THE FOREGOING STATEMENTS ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION, AND BELIEF.Respectfully submitted, LAW OFFICES OF 8701 Georgia Avenue Silver Spring, Maryland 20910 (301) 587-8722 ewh@hollowaylawoffice.com