FCG21st JUDICIAL DISTRICT COURT

PARISH OF TANGHIPAHOA
STATE OF LOUISIANA

NO. 2021-0002385 DIVISON: K

JEREMIAH A. HARVEY

VERSUS

AMANDA M. BROWN-HARVEY

FILED: __________________ DEPUTY CLERK: __________________

ANSWER AND RECONVENTIONAL DEMAND

NOW INTO COURT, through undersigned counsel, comes Defendant/ Petitioner,

in Reconvention Amanda Brown Harvey who respectfully Avers as follows:

1. The allegations of paragraph one of the petition are admitted;

2. The allegations of paragraph two of the petition are admitted;

3. The allegations of paragraph three of the petition are admitted;

4. The allegations of paragraph four of the petition are admitted;

5. The allegations of paragraph five of the petition are admitted;

6. The allegations of paragraph six of the petition are admitted;

7. The allegations of paragraph seven of the petition are admitted;

8. The allegations of paragraph eight of the petition merely state conclusions of

law and, as such, require no answer. Insofar as any answer may deemed

required the allegations of paragraph 9 of the petition are admitted;

9. The allegations of paragraph nine of the petition are admitted;

10. The allegations of paragraph 10 of the petition merely state conclusions of law

and as such require no answer. Insofar as any answer and he's required the

allegations of paragraph 10 the petition is denied.

AND NOW, assuming the role of petitioner in reconvention, Amanda Brown

Harvey avers as follows:

1. Petitioner in Reconvention has always been a good and dutiful wife and given

her husband no reason to be displeased with her. She is in necessitous

 circumstances and requires spousal support on an interim basis and thereafter

permanent alimony;

2. Petitioner in reconvention fears that during the pendency these proceedings that

the defendant and reconvention may alienate encumber or dispose of items

constituting the community regime heretofore existing between the parties.

Accordingly, she requests this Court issue Temporary Restraining Order in the

form of a preliminary injunction, without bond, and thereafter permanent

injunction, prohibiting the defendant and reconvention from alienating and

covering or otherwise disposing of any items belonging to the former marital

regime;

3. Petitioner in Reconvention desires to return to her maiden name following the

judgment of divorce in these proceedings;

WHEREFORE, after all legal delays in due proceedings had, Defendant/

Petitioner in Reconvention Amanda Brown Harvey prays that her answer be deemed good

and sufficient and that the petition of Jeremiah A. Harvey be dismissed at his cost;

Defendant/ Petitioner in Reconvention further prays that the demands of her

petitioner in reconvention be granted and that this Court issue immediately and without

bond the Temporary Restraining Order in the form of a Preliminary Injunction and

thereafter permanent injunction prohibiting the defendant and reconvention Jeremiah A.

Harvey from alienating encumbering or otherwise disposing of any items belonging to the

former community regime.

Defendant/ Petitioner Reconvention further prays for any and all other legal or

equitable relief which this Court may deem just.

Respectfully submitted

______________________________
Russell Stegeman #08224
506 Water Street
Madisonville, Louisiana 70447
Phone: (985) 800-2001
Email: russell@theshark.us
 ORDER

CONSIDERING THE FOREGOING, it is hereby ordered that a Temporary

Restraining Order issue herein in the form of a preliminary injunction prohibiting the

defendant Jeremiah A. Harvey from alienating encumbering or otherwise disposing of any

items belonging to the former community regime heretofore existing between the parties;

IT IS HEREBY FURTHER ORDERED, that the defendant, Jeremiah A Harvey,

show cause on the ____ day of __________________ 20____ at _____o'clock ____. M.

why interim spousal support and thereafter permanent alimony should not be granted to the

petitioner in reconvention, Amanda Brown Harvey;

IT IS HEREBY FURTHER ORDERED, that the defendant in reconvention,

Jeremiah A. Harvey, show cause on ____day of _________ 20____ at ____ o'clock

____.M why the Temporary Restraining Order issued herein should not be maintained in

the form of a preliminary and thereafter permanent injunction prohibiting the defendant in

reconvention, Jeremiah A. Harvey from alienating encumbering or otherwise disposing of

items formerly belonging to the marital regime heretofore existing between the parties.

Thus, done and signed this ____ day of ___________________, 20 ____,

Amite, Louisiana.

_________________________
DISTRICT JUDGE

PLEASE SERVE:
Jeremiah A. Harvey
Through his counsel of record
Erik Noland
604 Saint Ferdinand St
Baton Rouge, Louisiana 70802