Timothy Baker vs Mindy Baker Maricopa County Family Court

timothy_baker_vs_mindy_baker_maricopa

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Thomas J. Griggs (LD. No.006690)

LAW OFFICES Killian, Nicholas, Fischer,

Wirken, Cook & Pew, P.L.C.

SUITE 200 40 NORTH CENTER STREET no. BOX 1467 MESA, ARIZONA 85211 (602) 461-4600

Attomeysfor Petitioner

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

In re the marriage of TIMOTHY P. BAKER

Petitioner, PETITION FOR DISSOLUTION OF MARRIAGE With Children)

and

MINDY K. BAKER

Respondent.

Petitioner, TIMOTHY P. BAKER, by his undersigned attorneys, for his Petition

for Dissolution of Marriage, alleges as follows:

I That the petitioner’s true name is TIMOTHY P. BAKER, that petitioner’s birthdate is June 6, 1963, that petitioner’s address is 11625 South Appaloosa, Phoenix, Arizona 85044; that petitioner’s occupation is medical doctor; that the respondent’s true name is MINDY K. BAKER, that respondent’s birthdate is September 20, 1963, that respondent’s address is 3935 East Park Avenue, Phoenix, Arizona 85044; that Respondent is presently

unemployed, but is employable. Respondent is not pregnant at this time.

WIOSQ 01II That the petitioner and respondent have been domiciled in the State of Arizona for period of ninety (90) days prior to the filing of this Petition. III That the petitioner and respondent were married on or about the 11th day of June, 1983 in Phoenix, Arizona, and ever since that time have been and now are husband and wife. IV That the marriage between the petitioner and respondent is irretrievably broken and there is no reasonable prospect of reconciliation. V That the conciliation provisions ofA.R.S. § 25-38109 either do not apply or have been met. VI That there have been born as issue of this marriage two children, both of whom are minors, namely: GARRETT R. date of birth October 19, 1991; and EMILY S. date of birth April 30 1993; and within the last five years have lived with both Petitioner and Respondent at the 11625 South Appaloosa, Phoenix, Arizona address and prior to that at 4831 East Boston Street, Chandler, Arizona 85226. That there shall be a sole custody order issued in this case with Respondent/Wife as the custodial parent for the parties’ minor children. Petitioner has not participated as a party, witness, or in any other capacity, in any other litigation, concerning the custody of the minor children in this or any other State, has no information of any custody proceedings concerning the minor children pending in a court of this or any other state, and knows of no person not a party to these proceedings who has physical custody of the minor children or claims to have

custody or visitation rights with respect to the minor children.

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VII That the Petitioner is an able-bodied man currently employed and capable of paying a reasonable amount as and for child support both pendente lite and permanently; that the petitioner lacks sufficient funds and property to provide for these matters and is

unable to support herself and the minor children of the parties. Therefore, Petitioner

alleges that he has committed to the Respondent that he should also pay Spousal

maintenance. VIII

That there are no written agreements between the parties as to support, custody and visitation of the children and maintenance of either spouse. The parties have had

discussions which Petitioner believes will result in written agreements.

IX That the parties hereto have acquired community, joint and common property, and

joint, common and community debt. There should be an equitable division of joint,

common and community property and debt. X

That each party shall be. responsible to pay his or her own attorneys fees and costs

incurred in this matter. WHEREFORE, the petitioner requests as follows: 1. That the Court order a Decree of Dissolution of Marriage, dissolving the

marriage existing between the parties and that the parties be restored to the status of

single persons; 2. That there be a sole custody order issued in this case with regard to the

custody of the minor children with Respondent/Wife being the custodial parent in this

case, subject to guideline access for the Father as a minimum;

ODWSGZDI3. That the Petitioner be ordered and required to pay to the petitioner a reasonable amount to be determined by the Court as and for child support for the benefit of the parties’ minor children;

4. That Petitioner shall pay to the Respondent spousal maintenance to be allocated in this matter;

5. That the Court fix its order equitably ordering the payment and discharge of the community obligations of the parties;

6. That the Court fix its order equitably dividing the property acquired by the parties during their marriage;

7. That the Court affirm to the parties their sole and separate property, if any;

8. For such other and further relief as the Court may deem just and proper in

the law.

9. That each party be responsible to pay his or her attorneys fees and costs

incurred in this matter.

DATED this [2: day of . , 1994.

KILLIAN, NICHOLAS, FISCHER, WIRKEN, COOK & FEW, P.L.C.

Attorneys For Petitioner

omosazm ’4’STATE OF ARIZONA ) County of Maricopa SS-

TIMOTHY P. BAKER, being first duly sworn upon his oath, deposes and says that he is the Petitioner in the foregoing Petition for Dissolution of Marriage; that he has read the foregoing instrument and knows the contents thereof; that the facts alleged therein are

true except those alleged upon information and belief and as to those, he believes them to be true. % . B R

SUBSCRIBED AND SWORN to before me this [,2 day of

m m, [M 1 , 1994, by TIMOTHY P. BAKER.

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