STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF MACOMB LISA KINDRED, vs. Plaintiff, Case No. 98- es DM Hon. ee MACERONI VEL Defendant. ARDO, SUGAMELI & OLSON, P.L.C. ALFREDO CASAB, P-53699 P-16922 ‘Attomeys for Plaintiff 3150 Livernois, Suite 103 ‘Troy, Michigan 48083-5000 248/528-3380 ws is arising out of the same transactions or occurrence #& Tepe ins compaint pending ia ths cout, nor has may such action ben previously fled and dsmisnd aiebet Faved afer having boen asigned ta judge, nor do Iknow of anyother civil action, not between sss Sees aiing oat ofthe sae transaction or occtrrence as alged in his complaint that is ether pening ya previously fed and cmised,teanfered, or otherwise disposed of eer having boon signed 102 {judge in this court. COMPLAINT FOR DIVORCE = Lisa Kindred, by and through her undersigned attomeys, and for her ‘There is no other civil ation between these part 7-53 98F ‘NOW COMES Pl Complaint for Divorce states as follows: 1 Plaintiff is, and has been, continuous resident of the State of Michigan for at least one ‘hundred eighty (180) days and in ‘the County of Macomb for at least ten (10) days immediately preceding the filing of this Complaint. : (On or about August 2, 1996, the parties were duly and legally married Roseville, County of Macomb, State of Michigan. ‘The parties separated on or about February 3, 1998. 52 ERS Plainti?’s complete name now is Lisa Caron Kindred, Plaintiff's complete name prior to the EXVA BIT kK10. ML 12. marriage wes Lisa Caron Hughes. Defendant's complete aame is William Kindred ‘The parties are the parents of one minor child together: Shelby Lyne Kindred, d/ofb 3/2897. Plaintiff is not pregnant at this time, “There has been a breakdown of the marital relationship to the exteat that the objects of snstrimony have been destroyed and there remains no reasonable likelihood that the mariage can be preserved. ‘The parties are possessed of both reel and personal property to be divided. ‘The minor child is residing with Plaintiff's relative at the home of Plaintiff's relative, pursuant t an order of the Macomb County Juvenile Coust. ‘The minor child's best interests will be served by an order awarding the Plaintiff legal and physical custody after the matter before the Macomb Juvenile Court is completed, and thereafter until such child reaches the age of majority or until further order of the court. ‘That Defendant is gainfully employed and has significant earnings and assets available to assist Paintiffin maintaining adequate support end maintenance for herself and the child and in the payment of her attomey fees and expenses as authorized by MCR 3.206. ‘That the Plaintiff is in need of Defendant's continued payments of medical, hospital, dental and optical expenses not covered by insurance; as well as continued insurance coverage for same, and the continned payment of mortgage, taxes, insurance, utilities and repairs with respect to the maritel home. Based upon the fuct that Plsintiff has decided to insite divorce proceedings, she is apprehensive that immediate and ieparsble injury, loss or damage will result to the Paint from the delay required to effect notice or from the risk that notice itself will precipitate adverse action before an order can be issued and that the Defendant will transfer, sell, encumber, conceal and somehow dispose of the assets and property of the parties so as to1B. place such assets beyond the reach of the Court. More specifically, Defendant has engaged in the following behavior which reasonably makes Plaintiff apprehensive: a. _ Onorabout June, 1997, Defendant beat Plaintiff's son (Charmous Skinner - currently age 7), with a belt, leaving marks all over the minor child’s body. Defendant was arrested, charged and convicted of child abuse. b. On or about February 3, 1998, Defendant again assaulted Plaintiff's son (Charmous Skinner - currently age 7), by chocking him herd enough to burst blood vessels in the ‘minor child’s face, ‘The minor child’s school contacted the police and Defendant was arrested, with charges now pending for child abuse - second offense, as well as ‘violation of probation with respect to the first incident, c. Throughout the duration of the parties’ marriage, Defendant has verbally, physically ‘and emotionally abused Plaintiff and Plaintiff's son (Charmous Skinner - currently age 7). 4 Defendant is currently free on bond, awaiting trial. Pursuant to the requirements of Act 297, P.A. 1975, Plaintiff states the following: 2, The minor child resides with a relative of Plaintiff pursuant to an order of the Macomb Juvenile Court b. Plaintiff has, and is, participating in tigation concerning the custody of the child in the Macomb Juvenile Court. c. Plaintiff has no information regarding any other proceeding conceming the custody of the minor child other than a matter pending belore the Macomb Juvenile Court. 4 Other than Plaintiff’ relative who bas temporary custody of the minor child pursuant to the order of the Macomb Juvenile Court, Plaintiff does not know of any person notparty to these proceedings who has physical custody ofthe child, or claims custody or parenting time rights to the child, - WHEREFORE, Plaintiff prays that this Honoreble Court grant her the following relief a. That a judgment of divorce be entered dissolving the bonds of matrimony between Plaintiff and Defendant. b. That the marital property and debt be equitably and fairly divided between the Plaintiff and Defendant. ¢. That this Court enter an Ex Parte Order concerning the care, custody and support of the minor child and awarding Plaintiff the exclusive use of the marital home, da ‘That this Court enter an Ex Parte Mutual Restraining Order, restraining either of the parties ftom transfering, selling, encumbering, concealing or somehow disposing of the assets and property of the parties. e. That this Court grant such other and further relief as shall be agreeable to equity and good conscience,1 DECLARE THAT THE STATEMENTS ABOVE ARE TRUE TO THE BEST OF MY INFORMATION, KNOWLEDGE AND BELIEF. LISA Gait laintift State of Michigan) dss County of Macomb) On tis 19th day of February, 1998, before me personally appeared Lisa Kindred who made ‘oath that she has read the foregoing, ‘Complaint by her ‘subscribed, knows the contents thereof, and that the same is true of her knowledge, except as to those matters therein stated to be upon inforgnation and belief, a as to those matters, she believes them to-be true, gHizp r= < 5 Macomb County, Michigan ‘My commission expires: 2A A/ B. Respectfully submitted, ‘VELARDO, SUGAMELI & OLSON, PLC, ore BY: ALFREDO CASAB, P-53699 ‘Attorneys for Plaintiff 3150 Livernois, Suite 103 ‘Troy, Michigan 48083 Date: 22 -/9- 7 248/528-3380mGHeA Berea PETITION FOR T caout cout No PERSONAL PROTECTION o e o ORDER | mi oa ia " ne Respondentename, adres and phere | AGS Lise Ainares : | ISFHO LAD Udine Kenele ROUEH, mn Moor ANS 2s sf pees fos) fa Barred AAMrZO2® 4 OAT ® 1. Respondent: fs a spouse; 0 is a former spouse; Dhas echt jin common with me; O has or had @ dating relatlonstiip with me, C resides in the same housefiold; or, © is @ Perseh stalking me. ©2. There wre Care not any other actions Ps ending between petiiongr and respondent. If so, alyyea5> number(s) and court(s): AB- 45,518 bt op mernul Cece oO sili 3. | request that be appointed my next friend. Helshe is an adult and is not disqualified by statute, 4, 3 Respondent is required to carry a firearm in the course of hisyher employment, © Unknown. ®5. | need a personel protection order because respondent: 1D Entered onto my property. 1 Assaulted, atacked, boat, molested, or wounded me. ‘3 Threatened to kl or physially injure me. © Bpoved mina cen cal ine eng opal caso oth chien without beng authori by cour ode. frterfered with me at my job oris threatening my job. se fe ne move my chen or personal roperty fom respondents Pr & lh lng ioe wh alae a ‘Mevoreuith my freedom} pene low es nny av course of ending repeated ot conte ra would sgaged "Sng ne ange erat, estan, hresed of moles fh HY caused cae eeecrorel fightoned, nimidated, threatened, harassed or molosid), : - EXPLAIN WKIAT HAPPENED, WHEN TT HAPPENED AND HOW MANY TINES IT HAPPENED: ON 2 FADO iiviaen Dame bo i ‘Opis axvtl x LU a on 4 rely adqfional c aded, attach sheet) ~ (atiach any Soype da aarti elanep you roy upon. acral spane le need Neda tego \ SA oe Ost Gs. 4 task WaSse be Soest who n hide to respondent and without @ hearing ("ex parte") becalise the following specific facts show immediate and irreparable injury, loss or damage will result from the delay required to ‘effectuate notice or that notice itself will precipitate adverse action before @ personal protection order can be issued on notice: EYANG. y (attach any pctres, aides or dacumentary @ VERIFICATION UNDER MOR 2.14(2() deca that he stators shove re tue f the Pst fy and belie ; oareo: OLSENAS. aver “Signet of poten EXHIBIT L