foe FILED ae AUG 13 Motus 2 ivtararcurr OpgH ge cousty oF rarmeak™ M0 Ae: s¢ cope oe oh mumcna voce, “‘Weeeeet cull aa bi Givil Action No._10= (8706 STEPHEN K, MOORE, Defendant. ce Falls Church, VA 22043 AMENDED COMPLAINT FOR DIVORCE ‘COMES NOW the Plaintif, ALLISON M, MOORE (hereinafter the “Plant”, bby Counsel and files this, her Amended Complaint for Divorce. In support thereof, the Plaintiff states as follows 1. Plaintiff and Defendant, STEPHEN K. MOORE (hereinafter the “Defendant” ‘were lawfully maried on July 7, 1990, n Winnetka, nos. 2. Plaintiff hasbeen for a period f at last six (6) months preceding the institution of this cause. a hon fe resident and domiciliary of the Commonvveath of Virginia 3. The parties are both over the age of eighteen (18) years and neither on active duty inthe armed forces ofthe United States. 4. There were three (3) children born of the marriage, namely Moore, born July 27, 1991, Moore, born March 11,1993, and MIMoore, born Apel 2001. There were no children adopted during the marriage eet ae eae Trix County Cit Cow ree Comite5. Theparties last cohabit as husband and ie EAI ts Church, Virginia 2083 COUNT ADULTERY 6 Onorbefore December 19, 2009, Defendant Stephen K. Moore ereated to diferent Match.com accounts, the sole purpose of which was to connect romantically ‘with other women. After meeting and dating at leastone other woman through these accounts, by February 2010, Defendant, by his own admission, commenced a romani, adulterous relationship with Sherti Wallmark. Defendant is and has been neither discreet nor inconspicuous with his, selatonship with Ms, Wallmark in fact, he tastelssly and openly spoke wit Plant ‘on several occasions about plans and events he was atending with Ms, Wallmark. On cone such occasion, Defendant sid tothe parties hire in font of Plant at their son's graduation ceremony, “I have two women and what's really bad is when they fight over you.” In addition, Defendant left several documents in the marital home relating to Ms, Wallmark and his affair with he, including, but nat limited to, bills showing extravagant dinners, bills showing Defendant purchasing gasoline a station bear Mf, Wallmark’s home very early inthe morning ils showing an airplane ticket purchased by Defendant with “Sheri Wallmark" listed as the passenger, a printout of Mapquest dections to Ms. Wallmark’s home, and a tshirt Defendant bought for Ms Wallmark with » Nike logo tha eads, “Doing I.” Defendant told Plant that he was planning on ending the relationship with Ms. Wallmark; however, he has not dane so. As recently as June 23, 2010, Defendant admitted that he had sexual relations with Ms. ,-). Htc Copa BoreWallmarke in an emai to her in which he stated, “I sil can believe [had the awesome good luck to. sleep with you and hold you." 8 Defendant committed adulterous ats with Ms. Wallmarkon several occasions at her home, including, but ot limited to, thefllowing approximate dates: March 26,2010, Apri 11,2010, May 29,2010, June 5, 2010, and June 19,2010. In addition, Defendant committed adulterous acts with Ms, Wallmark during multiple trips that he took with her, including, but not limited toa trip to Denver on or about February 27,2010, fo which he purchased an airline tcketin her mame, and a tp to Cambridge, Maryland on or about the weekend of May 8, 2010 9. Since the commencement of Defendant’ adultery, it has been neither procured by the connivance ofthe Plaintiff nor been condoned by her. 10. Pini hasbeen a good ant dutifl wife to Defendant She has sulfered emotional and paychotogical abuse by Defetant throughout thele mariage yet as lays been faithful to Defendant. In the Fall of 2008, Plaintiff had no other option but to leave the marta home with the youngest minor child to protect herself an her son from Defendant and Defendant's influence on the partes’ two oder children Plants intention for leaving was to provide space for Defendant to allow him to get help and to change his behavior. She di so with the hope that ime apart would allow the parties to reconcile ata later date. Since then, Defendant has neither altered his behavior towards Plaintiff nor ended his adulterous afar. 11. Plaintiff has been the primary caretaker and role mode! for the partis’ children. She quit her job to devote her time to raising their children. By contrast, Defendant has recently acted indifferent towards ther children. Defendant provides ee Fs County Cit ‘owe Compl for aged