Preview
COMMON. eB cours’
MUSKINGUM CO. OHIO
13 AUG -8 P >I
IN THE COURT OF COMMON PLEAS OF MUSKINGUM COUNT
DOMESTIC RELATIONS DIVISION W AFT sow ERS
ROY DIXON
CASE NO. DA2023-0435
PLAINTIFF,
JUDGE KALIS
vs.
AMANDA DIXON
DEFENDANT.
DEFENDANT’S MOTION FOR CHANGE OF VENUE/JURISDICTION
REGARDING ALLOCATION OF RIGHTS AND
RESPONSIBILITIES FOR CHILDREN
Now comes the Defendant, Amanda Dixon, by and through counsel, and moves
the Court for a change of venue regarding the allocation of rights and responsibilities for
the parties’ children, Dillon Dixon and Ava Dixon. The Defendant states that the Court
having jurisdiction and appropriate venue to hear the children’s issues is the Wayne
County, Michigan Circuit Court. Additional detail is contained in the Memorandum in
Support below.
Respectfully submitted,
Stacey Cv Ja 22.18)
Attomey for Defendant
45 N. Fourth Street
Zanesville, OH 43701
(740) 297-7768
Stacey@lawyerzanesville.com
MEMORANDUM IN SUPPORT
The Defendant moved to Michigan on May 26, 2023 with the parties’ minor
children. She filed for allocation of parental rights and responsibilities on June 22, 2023
in Wayne County, Michigan Circuit Court in regards to the minor child, Ava Dixon.
There has already been one court hearing in this case and another is set for September 6.
Previously there were court orders issued regarding parental rights and responsibilities
for the minor child, Dillon Dixon, in this same Court that the Defendant’s Michigan
counsel has advised are still in effect as the Court has continuing jurisdiction over the
child. Please see the attached court documents regarding these 2 cases. Since the
children are not residing in Muskingum County, or even in Ohio, and are not even
traveling to Ohio to see the Plaintiff at this time, the Court with jurisdiction and proper
venue to hear issues related to the children is where the Mother resides in Wayne County,
Michigan, where there are already cases filed.
Wherefore, the Defendant moves the Court to grant her the requested relief.
VERIFICATION
STATE OF OHIO )
COUNTY OF MUSKINGUM ) SS:
Defendant Amanda Dixon hereby states that the above statements contained in the
Motion are true and accurate to the best of her knowledge and belief.
Franole. Mie Orn
Amanda Dixon
Sworn to before me and subscribed in my presence this {day of August 2023.
this bana i
Notary Publi
awn 18H,
=
STACEY L. JAMES
Attomey At Law
Notary Public, State of Ohio
‘My commission has no expiration date
Sec, 147.03 RC
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STATE OF MICHIGAN
Tas COURT
INTHE 3 CIRCUIT COURT FOR THE COUNTY ORE: U MCO, OHIO
AMANDA JADE DIXON 103 AUG -8 PP 342
Plaintiff, WENDY L. SOWERS
23-1066:
Vv. CASE NO. 23-*-DG
HON.. MARY BETH KELLY
ROY RAYMOND DIXON,
Defendant
THE LAW FIRM OF VICTORIA, P.&.
DENNIS ZAMPLAS (P24637)
ERIN B. ELLIS (P68825).
Attorneys-for Plaintiff
772. East Maple Road
Birmingham, Ml 48009
(248) 723-1600
éallis Tialan rm.com
woodland@victorialawfirm.com
i
Ar action within the jurisdiction of the family. division of the
circuit court involving the family of the. persons who are the
subject of this Complaint has been previously filed in-this Court,
where it was given docket number 10-106244-DM and, is
assigned to Judge Mary Beth Kelly. The.action is no longer:
pending
VERIFIED COMPLAINT FOR CUSTODY, PARENTING TIME AND CHILD SUPPORT
NOW COMES Plaintiff, Amanda Dixon, by arid through her attorneys at The“Law
Firm of Victoria, P.C., and. states to this Honorable Court as follows:
1 Plaintiff'is a resident.of Wayne County, Michigan. Although Plaintiff has not
contiriudusly resided in’ thé State of Michigan for more than one hundred
eighty (180) days immediately preceding the filing of this Complaint
a eee
Michigan has.“significant.connection jurisdiction” because no other’state has
“home state" jurisdiction.
The child resided in Michigan from bith until December 22; 2022, and the
to, reside in Michigan on May 26,2023.
child returned The. parties were
previously married and divorced in Wayne County, Michigan-and this Court
retains Jurisdiction of the minor child’in the divorce action, as. the court has
continuing jurisdiction over the parties’ eldest child until he. reaches the age
of majority.
and Defendant were. married forthe second time. in Las
Here, the Plaintiff
Megas, Nevadaon April.20, 2022,
Two (2) minor children were born to the parties as a result of their
telatiénship. However, only one minor-child is the subject of this Complaint.
The. complete name and age of the-minor child is set forth on the Addendum
to Protected Personal Identifying Information.
Pursuant to MCL 722.1209, Pidintiff states:
a. That the minor ‘child resides’ at 27522 Ann Aibor Trail, Westland, MI
48185 with Plaintiff.
b. Plaintiffhas not participated in any.capacity in other litigation. concerning
the custody of said minor child in this or any‘other state.
c. Plaintiff has no ‘information ofa custody proteeding.concerning the miner
child pending in a court of this or any other state.
ee eee =
d. Plaintiff does not know of any person, not a party to these. proceddings
whe. has physical custody or claims:custody or ‘parenting time fights with
thé minor child.
Plaintiff is,-and has been the sole caretaker of the. minor child; and she is and
has been responsible for providing all. of her day-to-day needs and. care.
Plaintiff is-a fit ‘arid proper person to have ‘and maintain the care, custody,
ahd contro! of the minor child.
The child's best interést would be best servedby awarding the: parties joint
legal custody.and Plaintiff sole physical custody of the child.
Defendant:should be awarded reasonable parenting time with the minor child
during and after this action.
10 The minor child's best interest will be setved by awarding Defendant
parenting time as. set forth in the Ex Parte Order for Intérint Gustody,
Parenting Time-and Child Support.
11 Defendant is employed. and he is edpable of paying child support, as: well as
contributing towards, payrient ef uninsured health care expenses incurred: on
behalf of thé child th accordance with the. Michigan Child Support Formula.
WHEREFORE, Plaintiff prays. as follows:
a. The. Court-grarit the parties joint legal custody and. Plaintiff sole physical
custody of the thinor child; and order Defendant to pay child support, child
caré, and health care expenses incurred on behalf of the child in
accordance withthe Michigan Child Support Formula.
Award’ Defendant: reasonable. parenting’ time. withthe: minor ‘child during
and after this action
Enter the Ex Parte Order for Interim Custody, Rarentifig Time and Child
Support, which is in the child's best interést:
The: Plaintiff have such other and further relief-as may be agreeable to
equity.and good conscience.
|-declare that the statements above are-true to ‘the best of my information,
knowledge and belief.
AMANDA JADE IXON
Respectfully submitted
THE LAW FIRM OF VICTORIA, P.C.
BY: pa
ERIN B. ELLIS (P68825)
Attorneys for Plaintiff
772 East Maple Road
Birmingham, Ml 48009
(248) 723-1600."
Dated june | , 2023
FASérverlVIGTORIA FILESW2023 CASE FILES\20-047, Dion, AmaridalPLEADINGSIGom
plain tor Custody.doc.
STATE-OF MICHIGAN CASE NO. and JUDGE
3RD JUDICIAL CIRCUIT UNIFORM CHILD CUSTODY 23-+-DC 23-106659-DC
PROBATE COURT JURISDICTION
COUNTY ENFORCEMENT ACT AFFIDAVIT HON, MARY'BETH KELLY
WAYNE
Court address Court telephone rio.
2 WOODWARD. AVENUE, DETROIT, MI 48226 (313)'224-5260
Platntifi’s name, Defendant's name
AMANDA JADE DIXON. Vv /ROY RAYMOND DIXON
4. The-name-and. present-address of each child'(under 18) in this case is?
AVA DIXON, 27522 ANN ARBOR TRAIL, WESTLAND; MI 48185
2. The Cities/States/Countries
the: dren) have lived in-during. the last 5 years along with the dates the child(ren) lived
there (include.addresses if avaitabfe):
20211 WEYNER; LIVONIA, MI 48152 (6/12/2014- 12/14/2022)
2245, IRISH RIDGE ROAD, PHILO, GH 43771 (12/15/2022.- 5/25/2023)
27522 ANN ARBOR TRAIL: WESTLAND; MI 48185 (5/26/2023- Preserit)
3. The fiame(s) and present address(es) of custodians with whom the child{rert) has/have Iived within the last ‘5 years are:
AMANDA-JADE DIXON, 27522 ANN ARBOR TRAIL, WESTLAND; MI 48185
ROY RAYMOND DIXON, 2245 JRISH RIDGE ROAD, PHILO, OH 43771
Ido not-know af, ‘and have not participated (as-a party, witness,.or ih any other-capatity) i in any other court-decision
order;-or proceé ig (including divorce, separate’ maintenance, separation, Veglect,. abuse, dép ndehcy, guardian ip,
paternity, termination: of parental-rights, and protection from domestic violence) Conceming the.custody or parenting time
of the child(ren), ini this state or any other state, except: Specify casename and riumber, court: name-and a is, and date of child
custody determiriation, if qne.
Approved, SCAO Distrbute form ta:
Form MC. 416, Rev, 6/22 Court
MCL 722:1208, MCL 722:1208 FOC: (if applicable)
Page 10f2 DefendanvRespondent
PiaintiffPetitionar
Case No.
:23-4-DC 23-106659-DC
Uniform. Child Custody Jurisdiction Enforcement Act Affidavit: .(6/22)
Page 2 of 2
proceeding
5, | do not.know of any pending proceeding that could affect the current child.custody proceeding, including.a
parental rights, or
for enforcement-or a proceeding relating to: domestic violence, a protective order, termination of
and nature of the proceeding.
adoption, in this state or any: other state, except: Specify case namie arid number, court name and address,
That proceeding Olis continuing. Dhas been stayed by the court.
Temporary action by this court is necessary to protect the-child(ren) because the child(ren) has/have been subjected
to or'threatened with mistreatment or abuse or is/are otherwise neglected or dependent, Attach explanation
6. | do not know of any person who isnot already a party to this:proceeding who has physical custody of, or who claims
tights of legal or physical custody of,or parenting time with, the child(ren), except: Statenamie(s) aiid address(es) of each person.
NONE . “See definition of “home state” below.
7. The child(ren)'s “home state” is.
O18. | state that a party’s.or child's health, safety, or {iberty: would be put ‘atrisk by the-disclosure of this identifying
information.
| have filled this form out:completely, and'l. acknowledge:a continuing duty to-advise this.court.of any proceeding in this state
or any other state that could affect the current child-custody proceeding.
CL AMANDA JADE.DIXON 27522 Ann Arbor Trl, Westland, Mr4gi8s
Address of affiant
jignature of affiant Name.of affiant (lype,or printy
:
Subscribed and swom to before:me on Ol ot / [9083
Coan nT
‘clerkiNotary pi signature
My commission expires on 08 fal9007 . “ Z lnR1A:
Name ‘(type-or print)
Gkante
Notary public, State of Michigan, County of _¢ _.DAéting in the County of Catiaad
O This notarial act was performed using an electronic notarization system‘or a femoté-@lectronic notarization platform:
“Home state” means the state in which the child(ren) lived with a parent or a péfsonactifig as a parent for atleast 6 cofsecutive months
immediately before the commencement of a child-custody proceeding: In the:case-of a child less than 6 months of age, the term means
the state in which the child lived from birth with a parent or person acting as‘a parent.A period of temporary absence of a parent or person
acting.as a parént is included as part of the period. MCL 722.1102(g).
Original - Court 2nd Copy - Plaintiff
1st Copy- Defendant 3rd Copy -Return
STATE OF MICHIGAN CASE NO.
THIRD JUDICIAL CIRCUIT SUMMONS 23-106659-DC
WAYNE COUNTY Hon.Mary Beth Kelly
Court telephone no.: 313-224-0892
Plaintiff's name(s), address(es), and telephone no(s) Defendant's name(s), address(es), and telephone no(s).
DIXON, AMANDA JADE DIXON, ROY RAYMOND
Plaintiff's attorney, bar no., address, and telephone no
Erin Brett Ellis 68825
772 E Maple Rd
Birmingham, MI 48009-6334
Instructions: Check the items below that apply to you and provide any required information. Submit this form to the court clerk along with
your complaint and, if necessary, a case inventory addendum (form MC 21}. The summons section will be completed by the court clerk.
Domestic Relations Case
1 There are no pending or resolved cases within the jurisdiction of the family division of the circuit court involving the family or family
members of the person(s) who are the subject of the complaint.
O There is one or more pending or resolved cases within the jurisdiction of the family division of the circuit court involving the family or
family members of the person(s) who are the subject of the complaint. | have separately filed a completed confidential case inventory
(form MC 21) listing those cases,
1 itis unknown if there are pending or resolved cases within the Jurisdiction of the family division of the circuit court involving the family
or family members of the person(s) who are the subject of the complaint.
Civil Case
1 This is a business case in which all or part of the acticn includes a business or commercial dispute under MCL 600.8035
CO MDHHS and a contracted health plan may have a right to recover expenses in this case. I certify that notice and a copy of the
complaint will be pravided to MDHHS and (if applicable) the contracted health plan in accordance with MCL. 400.106(4).
O There is no other pending or resolved civil action arising out of the same transaction or occurrence as alleged In the complaint.
CT. Acivil action between these parties or other parties arising out of the transaction or occurrence alleged in the complaint has been
previously filed in CJ this court, 0 Court, where it was given case
number and assigned to Judge
The action 0 remains [2 isno longer pending.
Summons section completed by court clerk,
NOTICE TO THE DEFENDANT: In the name of the people of the State of Michigan you are notifted:
1. You are being sued.
2. YOU HAVE 21 DAYS after receiving this summons and a copy of the complaint to file a written answer with the court and serve a
copy on the other party or take other lawful action with the court (28 days if you were served by mail or you were served outside this
state).
8. !f you do not answeror take other action within the time allowed, judgment may be entered against you for the relief demanded in the
complaint.
. If you require special accommodations to use the court because of a disability or if you require a foreign language interpreter to help
you fully participate in court proceedings, please contact the court immediately to make arrangements.
Issue date Expiration date” Court clerk
6/22/2028 9/21/2023 Brenda Scales
Cathy M. Garrett- Wayne County Clerk.
“This summons is invalid unless served on or before its expiration date. This document must be sealed by the seal of the court.
MC 01 (3/23) SUMMONS MCR 1.109(D), MCR 2.102(B), MCR 2.103, MCR 2.104, MCR 2.105
Sialae
a
ici”
SUMMONS
Case No: ; 23-108659-DC
PROOF OF SERVICE
TO PROCESS SERVER: You must serve the summons and complaint and file proof of service with the court clerk before the
expiration date on the summons. If you are unable to complete service you must return this original and all copies to the court clerk.
CERTIFICATE OF SERVICE / NONSERVICE
Oserved O personaity C1 by registered or certified mail , return receipt requested, and delivery restricted to the addressee(copy
of return receipt attached) a copy of the summons and the complaint, together with the attachments listed below, on:
O11 have attempted to serve a copy of the summons and complaint, together with the attachments listed below, and have been unable
‘to complete service on:
Name Date and time of service
Place or address of service
Attachments (ifany)
C1 ama sheriff,deputy sheriff, bailiff, appointed court officer or attorney for a party.
O11 am a legally competent adult who is not a party or an officer of a corporate party. | declare under the penalties of perjury that this
certificate of service has been examined by me and that its contents are true to the best of my information, knowledge, and belief.
Service fee Miles traveled Fee Signature
Incorrect address fee |Miles traveled Fee Total fee Name (type or print)
$s
ACKNOWLEDGMENT OF SERVICE
| acknowledge that | have received service of the summons and complaint, together with
on
Attachments (if any) Date and time
on behalt of
Signature
MCL 600.1910, MCR 2.104, MCR 2.105
CHILD CUSTODY ACTION -DC
STATE OF MICHIGAN CASE NO.23. 106659
THIRD JUDICIAL CIRCUIT
COVER SHEET
‘TO BE.SUBMITTED FOR ALL CHILD HON. MARY BETH.KELLY
WAYNE COUNTY CUSTODY MATTERS
(Including. UCCJEA Determination):
=
COLEMAN A, YOUNG MUNICIPAL CENTER, TWO, WOODWARD AVENUE, DETROIT, MICHIGAN 38226:
Please print neatly or type.
PETITIONER name, address, phone #, and ¢-mail: RESPONDENT name, address, phone #,-and e-mail:
AMANDA JADE DIXON ROY RAYMOND DIXON
27522 Ann Arbor Trail, Westland, Mi 48185 2245 Irish Ridge Road, Philo, OH 43771
(734) 772-4958 (734) 968-0705:
TD Address/phone.no. are not provided due to domestic
violence concerns (See atlached Affidavit, UCCJEA Form 11)
PETITIONER atiomey name/bar #, address. phone #, and e-mail; RESPONDENT attorney name/bar #; address, plione #. und e-mail:
ERIN B, ELLIS (P68825)
772 E. Maple Road, Birmingham, MI 48009
(248) 723-1600
NOW COMES PETITIONER, and states as follows:
| Is there a previous child custody’ cast:or order regarding the child(ren) whosé custody is at issue'in'this case?
© a: No. If youhave checked.this response, STOP! Answer no further questions,
1 b. Yes, in thig State (includes:parenting time.and-juvenile-court child protective proceedings), as listed in SCAO Form MC 21
previous
Confidential Case Inventory. If you have-checked this response, also.comiplete section (1)(c¢) below. If you have no
child custody cases or orders in another state, STOP!
Oc. Yes, in another state. or in‘a'foreign country.
State-or-country: ‘Court:
Case Number: Judge:
IF, AND ONLY IF, Box (1)(C) 18 CHECKED ABOVE, CONTINUE TO QUESTION 2.
2. Ifyou wantthis Court to take, action regarding, another state or country’s:child:custody order, please carefully mark the checkbox
for the ONE option you seck.
Ea. REGISTRATIONof another state or country’s-existing child custod; der by this Court. 1 do not wish to enforce or
modify the custody order.at this time. A verified registration petiti CCIEA Forin !) must be attached.
Ob. IMMEDIATE ENFORGEMENT (without prior-or simultaneous: registration) of another state or country’s-existing child
custody order by this Court. T'do not wish to modify the existing custody order at this time, NOTE: This option
requires payment of a motion fee..A verified petition for immediate enforcement (UCCJEA Form 9) must be attached.
¥#If'you are trying to enforcean Order Confirming Registration that was previously etitered by this Court, DO NOT
submit this form; instead, please complete and file. a Verified Petition for Enforcement after Entryof Order Confirming
Registration under the UCCJEA (UCCJEA Form 9a) using the registration case number.**
Oc MODIFICATION of another state or country’s existing child custody-order by this Court. NOTE: This-option requires
piyment-of a new case filing fee and a-custédy and parenting time fee. 4, complaint establishing this Court's
jurisdiction to modify the foreign custody order inust be attached:
I deelare that the statements made‘above are true to the'best of my belief and knowledge.
DATE: (y: 20: 2% c 1 havc Oneo2
Petitions! st SIGN)
vare._Colat | ar “Attorney for Petitioner
Me): MCL 722.1209(5)
UCCJEA FORM 10°(rev. 3/4/2022) “MCR 3:214(D): MCR 2.119(G)2 MCI. 600.2529(1)(a); MCL, (600:2529(1}(d)ti; MCL. 600.2529{1
STATE-‘OF MICHIGAN CASE NO. 23- -DC 23-106659-DC
3RD CONFIDENTIAL CASE INVENTORY
CIRCUIT COURT.- FAMILY DIVISION
COUNTY {DOMESTIC RELATIONS: PETITION NO.
WAYNE
‘AND JUVENILE:CODE) JUDGE MARY BETH KELLY
Plaintif's name [Defendant's name:
AMANDA JADE DIXON V_|ROY RAYMOND DIXON.
In the matter of
in the
instructions: List any known pending or resolved family division or tribal court cases involving the person(s) named
complaint or petition or family members of the person(s) named in the.complaint or petition. File the completed form with the
complaint or petition, but do not attach or staple together. Complete and file-additiona! sheets if necessary.
Examples of family-division cases include personal protection orders, divorce, Gustody, paternity, child support, juvenile
delinquency, and child protective proceedings, See MCL 600.1021 for a:complete list.
Note: This formis confidential and nat to be served on other parties in this case.
Court information (name, number, and-county/state)
This court O Other court or tribunal:
Case name. Case/Fite no;
AMANDA JADE DIXON V. ROY RAYMOND DIXON 10-106244-DM:
Assigned judge Case status Are support or custody/parenting time orders in effect?|
MARY BETH KELLY. Cl Pending Resolved ‘Support Custody/Parenting Time.
(Court information (name, number, and-county/state)
C This court Dlother cout or tribunal:
Case name [Case/File no.
\Assigned judge (Case status Are support or custody/parenting time orders in-effect?
(Pending Oo Resolved OC Support C] custody/Parenting Time
[Court information (name, number, ang county/state)
This court other court or tribunal:
[Case name GasefFileno.
Assigned judge Case status (Are support or custody/parenting time ordersin effect?!
OPending qo Resolved Osupport’ TC) Custody/Parenting Time’
Court information (name, number, and county/state)
DO This court C1other court or tribunal:
Gase name Case/File no.
[Assigned judge
a
(Case status Are support of cust (parenting time orders in effect? |
CPending Oo Resolved Support Custody/Parenting Time
ff LLD a
£L, ‘awl Oexc2?
4i _/ Banaue
5 ee
Approved, SCAO
Form MC 21, Rey, 12/22
MCR 3.206, MCR 3.931, MCR 3.961
Page 1 of t
ber B'
ee
~
ws ‘ COMMON PLEAS COUR
MUSKINGUM CO. OHIO
STATE OF MICIIIGAN
FOR THE C OUNTY OF WAH AUG -8 P 3 42
IN THE CIRCUIT COURT
WERDY SOWERS
AMANDA JADE DIXON,
Plaintiff,
10-106244 DM
JOG:DEBORAH Ai
oss abana
“Vg- DIXON AMAHOR “anya Lua Wa aa
OND
DIXON ROY RAYM
ROY RAYMOND DIXON, >
Defendant,
John P, Herzog (P43789)
PILED
CATHY ML, GARRETT
Attorney for Plaintiff CRaRTT/ OLERK
23290 Farmington Road, P.O. Box 321 NOV G9 2010
a
Farmington, MI 48332 te te
(248) 474-00 15 ly
Ty ‘ Alshoe
Roy Raymond Dixon
In propria persona: Os
1564 Helen
Garden City, MI 48135
-
oF
JUDGMENT OF DIVORCE
‘At ssion of said Court
“"" held ia the City of Detroit
County of Wayne, Michigan on
© wovo 9 2010;
PRESENT: HON DEBORAH ROSS ADAMS CIRCUIT COURT J UDG EB
wae ~~
“This cause having come on to be heafd and the parties and Plaintiff's
couns el-having appeared and having reached an agreement whichfullywasadvised
placed on
and
the record, and t he Defendant having been present in court and
the Plaintiff having presented her proof in open Court that the material facts - .
alleged in the Complaint are true, and that there has been a breakdown in the
marriage relationship to the extent that the objects of matrimony have been
destroyed and there remains no reasonable likelihood that the marriage can be
preserved;
On motion of John P. Herzog, Autorney tor Plaintiff;
Se -
,
by
~ASOLArrE DIVORCE
IT1S HEREBY ORDERED AND ADJUDGED that the marriage between
the said Plaintiff, AMANDA JADE DIXON and Defendant, ROY RAYMOND
DIXON, and the same hereby is dissolved, and a Divoree trom the bonds of
matrimony between said parties is hercb y adjudged, according to the Statute in
such case made and provided,
PARTIES’ ADDRESS,
IT1S FURTHER ORDERED AND ADJUDGED that the Plaintiff presently
residing at 27522 Ann Arbor Trail, Westland, Michigan 48185 and the Defe ndant,
presently residing at 1564 Helen, Garden City, Michigan 48135, shall notify the
Wayne County Friend of the Court, Detroit, Michigan, of any change of residential
address after the date the support provision is operative, or until the further Order
of this Honorable Court.
oe
cusTopy oF MINOR CHILD
IIs FURTHER ORDERED AND ADJUDGRD that the Plaintiff and
Defendant are awarded joint, legal custody of the minor child of the parties; to wit
DILLON ROY DIXON bors June.19, 2008, with physical custody to Plaintiff
AMANDA.JADE DIXON, until said child attain the age of majority or until the
further Order of this Honorable Court,
SUPPORT Or MINOR ‘CHILD
IT I$ FURTHER ORDERED AND ADIUDGED that the Defendant pay
through the Office of the Friend of the Court per week as child support for
or
1,08 BO
Danes y-four
ON commencing date of Judgment of Divorce as follows:
) Dollars until said child attains the age of eighteen (18) or
graduates from high school whichever is later, but not beyond nineteen (19) years
and six months, as provided - by MCL 552,605b, or as olherwise ordered by the
Court.
IT IS FURTHER ORDERED AND ADJUDGED that the matter of child
support shall be referred back {o the Friend of the Court for reinvestigation
annually to determine Delendant's future weekly chi 1 d Support obligation.
i -
ia
RETROACTIVE MODIFICATIONOF SUPPORT
ITLs FURTHE R ORDERED AND ADJUDGED that except as otherwise
provided in sectio
n 3 of the support and visitation enforcement act. Act No. 295
of the Public A) cts of 1982
being section $ 52.603 as amended by Act No. 25 of the Public Acts of 1996,
of the Michigan Compiled I @ support order that is part
ofa judeme nt or is an order in a domestic retations Laws,
matter as ¢ hat term ig defined
in section 31 of the Friend of the Court act. Act No, 294 of the Public Acts of
1982 » being section 582.531 of the Michigan Compiled Laws, is a judgment on
and alter the d ate of cach support paymen
t is du ¢, with the full force, effect, and
attributes of a
judgement of this state, and is not, on and after the date it is duc,
Subject to retr ‘oaclive modification
.
SERVICE FER
ITIS FURTHER ORDERED AND ADIUDGED that the Defendant shall
pay to the Wayne County Friend of the Court, Detroit, Michigan, the sum of Three
Dollars and fifty cents ($3.50) per month, hereafter while the Order for Support is
operative, Initial payments for the next regular due date shall be made forthwith.
* LEIS FURTHER ORDERED AND ADJUDGED that any Child Support °
Arrearage due and owing to the State or otherwise due is expressly preserved, and
:
payable forthwith through. the Office of the Friend of the Court, :
‘
INCOME WITHHOLDING »
IT IS FURTHER ORDERED AND ADJUDGED that pursuant to MCL
522.604 an immediate order of income withholding shail issue, and that the payor
shall make all payments to the Office of the Friend of the Court until said order of
income withholding is effectuated by the payor’s source of income.
ITIS FURTHER ORDERED AND ADJUDGED that the Plai
+
ntiff and the
Defendant shall immediately give to the Office of the Friend of the Court the name
and address ofhis/her current or subsequent e. mployer or other source(s) of - --
income.
MEDIC A L DENT: A L AND HOSPITAL EXPENSES
——
~ HPIS FURTHER ORDERED AND ADIUDGED that both the Plaintiff and
the Defendant shall obtain or maintain any health care coverage that is available to
them, ata reasonable cost, as a benefit of emp loyment, for the benefit of the child
who is/are the subject of this Order. 1
ITTS FURTHER ORDERED AND ADJUDGED that the Defendant pay
40% of any uninsured medical, dental, hospitalization, or other health care
expenses of the minor child and Plaintiff pay 60% of any uninsured medical,
dental, hospitalization, or other health care expenscs of the minor child,
VISITATION PRIVILEGES
ps “TTIS FURTHER ORDERED AND ADJUDGED that the Defendant shall
be granted reasonable visitation privileges with the minor child of the parties
hereto, namely: DILLON ROY DIXON, until said child attain the age of majority
or graduates from high school, whichever is later, or until the further Order of this
'
Court,
!
DOMICILE PROVISION
IT IS FURTHER ORDERED AND ADJUDGED that the Legal custodian of
the minor child of the parties notify the Wayne County Friend of the Court,
Detroit, Michigan, of any change of residence address of the minor child presently
/ residing at 27522 Ann Arbor Trail, Westland, Michigan 48185, and that the
domicile or residence of said minor child shall not be removed from the State of
Michigan without prior approval of this Court.
§
ALIMONY/SPOUSAL SUPPORT
irs FURTHER ORDERED AND ADJUDGED that no alimony or spousal
support be granted to eithe r party, and that al imony or spousal support is
‘permanently barred. .
|
MUTUAL DOWER RELEASE
/ ITI§ FURTHER ORDERED AND ADJUDGED that any tights of either
Plaintiffor Defendant in any lands held by the other shall be hereby extinguished. *
Further, that each shall hereafter hold his or her remaining lands free, clear and
discharged from any such dower right or claim that the other may have jn any =
property which each may own or.may hereafter own, or in which each has or may
hereatter have any interest. Gr Peres og Wi MoO Pfitt (ESTATE. ted ay
_ O- TUE OTL C5 CELRIGED |
VRE we é
Lael
PERSONAL PROPERTY
ITIS FURTHER ORDERED AND ADJUDGED that each of the parties
retain the personal property, bank accounts and retirement accounts presently in
their respective possessions. Any arrearage or balance in the Co-Op Credit Union
account number 297084-6-0 shall be awarded to or the responsibility of
Defendant, .
4
4 ‘
4. a DEC re Peavecnd
17 1 FUR ThR CRDERED Awa ROTUDGED TET THE Prerres
OTETE 1 TUE EIA Of THR OTHEL.,
gir Pisces’ yl
ok.
IRY INSURANCE PROVISION
, ITIS FURTHER ORDERED AND ADJUDGED that any rights of either
Party in any policy or contract of life, endowment or annuity insurance of the other
as beneficiar ry are hereby extinguished, unless specifically Preserved by this .
Judgment.
o
Gy
Pyainuift
4
4 JADE DIXON,
JOHN APERZOG.
Y for Plaintiff |
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RO¥RAYMOND DIXON.
Defendant
. ERGW CHOLAGE: We (
ne cuP NrE
Circuit Court p?
GAR erik
at col uN
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a
ERTIFIC. E] E
A copy of the foregoing Answer, Motion for Change of Venue/Jurisdiction and
Motion for Temporary Orders was sent on this 7th day of August 2023 by mail to Roy
Dixon, Plaintiff, 2245 Irish Ridge Road, Philo, OH 43771.
pss Keay Mh
Stacey (0 18)
Preview
COMMON. eB cours’ MUSKINGUM CO. OHIO 13 AUG -8 P >I IN THE COURT OF COMMON PLEAS OF MUSKINGUM COUNT DOMESTIC RELATIONS DIVISION W AFT sow ERS ROY DIXON CASE NO. DA2023-0435 PLAINTIFF, JUDGE KALIS vs. AMANDA DIXON DEFENDANT. DEFENDANT’S MOTION FOR CHANGE OF VENUE/JURISDICTION REGARDING ALLOCATION OF RIGHTS AND RESPONSIBILITIES FOR CHILDREN Now comes the Defendant, Amanda Dixon, by and through counsel, and moves the Court for a change of venue regarding the allocation of rights and responsibilities for the parties’ children, Dillon Dixon and Ava Dixon. The Defendant states that the Court having jurisdiction and appropriate venue to hear the children’s issues is the Wayne County, Michigan Circuit Court. Additional detail is contained in the Memorandum in Support below. Respectfully submitted, Stacey Cv Ja 22.18) Attomey for Defendant 45 N. Fourth Street Zanesville, OH 43701 (740) 297-7768 Stacey@lawyerzanesville.com MEMORANDUM IN SUPPORT The Defendant moved to Michigan on May 26, 2023 with the parties’ minor children. She filed for allocation of parental rights and responsibilities on June 22, 2023 in Wayne County, Michigan Circuit Court in regards to the minor child, Ava Dixon. There has already been one court hearing in this case and another is set for September 6. Previously there were court orders issued regarding parental rights and responsibilities for the minor child, Dillon Dixon, in this same Court that the Defendant’s Michigan counsel has advised are still in effect as the Court has continuing jurisdiction over the child. Please see the attached court documents regarding these 2 cases. Since the children are not residing in Muskingum County, or even in Ohio, and are not even traveling to Ohio to see the Plaintiff at this time, the Court with jurisdiction and proper venue to hear issues related to the children is where the Mother resides in Wayne County, Michigan, where there are already cases filed. Wherefore, the Defendant moves the Court to grant her the requested relief. VERIFICATION STATE OF OHIO ) COUNTY OF MUSKINGUM ) SS: Defendant Amanda Dixon hereby states that the above statements contained in the Motion are true and accurate to the best of her knowledge and belief. Franole. Mie Orn Amanda Dixon Sworn to before me and subscribed in my presence this {day of August 2023. this bana i Notary Publi awn 18H, = STACEY L. JAMES Attomey At Law Notary Public, State of Ohio ‘My commission has no expiration date Sec, 147.03 RC rai ZO cs nS aS So 22m o< Te Cur Bun Ro of zc =~ om Exh ib “4 4 STATE OF MICHIGAN Tas COURT INTHE 3 CIRCUIT COURT FOR THE COUNTY ORE: U MCO, OHIO AMANDA JADE DIXON 103 AUG -8 PP 342 Plaintiff, WENDY L. SOWERS 23-1066: Vv. CASE NO. 23-*-DG HON.. MARY BETH KELLY ROY RAYMOND DIXON, Defendant THE LAW FIRM OF VICTORIA, P.&. DENNIS ZAMPLAS (P24637) ERIN B. ELLIS (P68825). Attorneys-for Plaintiff 772. East Maple Road Birmingham, Ml 48009 (248) 723-1600 éallis Tialan rm.com woodland@victorialawfirm.com i Ar action within the jurisdiction of the family. division of the circuit court involving the family of the. persons who are the subject of this Complaint has been previously filed in-this Court, where it was given docket number 10-106244-DM and, is assigned to Judge Mary Beth Kelly. The.action is no longer: pending VERIFIED COMPLAINT FOR CUSTODY, PARENTING TIME AND CHILD SUPPORT NOW COMES Plaintiff, Amanda Dixon, by arid through her attorneys at The“Law Firm of Victoria, P.C., and. states to this Honorable Court as follows: 1 Plaintiff'is a resident.of Wayne County, Michigan. Although Plaintiff has not contiriudusly resided in’ thé State of Michigan for more than one hundred eighty (180) days immediately preceding the filing of this Complaint a eee Michigan has.“significant.connection jurisdiction” because no other’state has “home state" jurisdiction. The child resided in Michigan from bith until December 22; 2022, and the to, reside in Michigan on May 26,2023. child returned The. parties were previously married and divorced in Wayne County, Michigan-and this Court retains Jurisdiction of the minor child’in the divorce action, as. the court has continuing jurisdiction over the parties’ eldest child until he. reaches the age of majority. and Defendant were. married forthe second time. in Las Here, the Plaintiff Megas, Nevadaon April.20, 2022, Two (2) minor children were born to the parties as a result of their telatiénship. However, only one minor-child is the subject of this Complaint. The. complete name and age of the-minor child is set forth on the Addendum to Protected Personal Identifying Information. Pursuant to MCL 722.1209, Pidintiff states: a. That the minor ‘child resides’ at 27522 Ann Aibor Trail, Westland, MI 48185 with Plaintiff. b. Plaintiffhas not participated in any.capacity in other litigation. concerning the custody of said minor child in this or any‘other state. c. Plaintiff has no ‘information ofa custody proteeding.concerning the miner child pending in a court of this or any other state. ee eee = d. Plaintiff does not know of any person, not a party to these. proceddings whe. has physical custody or claims:custody or ‘parenting time fights with thé minor child. Plaintiff is,-and has been the sole caretaker of the. minor child; and she is and has been responsible for providing all. of her day-to-day needs and. care. Plaintiff is-a fit ‘arid proper person to have ‘and maintain the care, custody, ahd contro! of the minor child. The child's best interést would be best servedby awarding the: parties joint legal custody.and Plaintiff sole physical custody of the child. Defendant:should be awarded reasonable parenting time with the minor child during and after this action. 10 The minor child's best interest will be setved by awarding Defendant parenting time as. set forth in the Ex Parte Order for Intérint Gustody, Parenting Time-and Child Support. 11 Defendant is employed. and he is edpable of paying child support, as: well as contributing towards, payrient ef uninsured health care expenses incurred: on behalf of thé child th accordance with the. Michigan Child Support Formula. WHEREFORE, Plaintiff prays. as follows: a. The. Court-grarit the parties joint legal custody and. Plaintiff sole physical custody of the thinor child; and order Defendant to pay child support, child caré, and health care expenses incurred on behalf of the child in accordance withthe Michigan Child Support Formula. Award’ Defendant: reasonable. parenting’ time. withthe: minor ‘child during and after this action Enter the Ex Parte Order for Interim Custody, Rarentifig Time and Child Support, which is in the child's best interést: The: Plaintiff have such other and further relief-as may be agreeable to equity.and good conscience. |-declare that the statements above are-true to ‘the best of my information, knowledge and belief. AMANDA JADE IXON Respectfully submitted THE LAW FIRM OF VICTORIA, P.C. BY: pa ERIN B. ELLIS (P68825) Attorneys for Plaintiff 772 East Maple Road Birmingham, Ml 48009 (248) 723-1600." Dated june | , 2023 FASérverlVIGTORIA FILESW2023 CASE FILES\20-047, Dion, AmaridalPLEADINGSIGom plain tor Custody.doc. STATE-OF MICHIGAN CASE NO. and JUDGE 3RD JUDICIAL CIRCUIT UNIFORM CHILD CUSTODY 23-+-DC 23-106659-DC PROBATE COURT JURISDICTION COUNTY ENFORCEMENT ACT AFFIDAVIT HON, MARY'BETH KELLY WAYNE Court address Court telephone rio. 2 WOODWARD. AVENUE, DETROIT, MI 48226 (313)'224-5260 Platntifi’s name, Defendant's name AMANDA JADE DIXON. Vv /ROY RAYMOND DIXON 4. The-name-and. present-address of each child'(under 18) in this case is? AVA DIXON, 27522 ANN ARBOR TRAIL, WESTLAND; MI 48185 2. The Cities/States/Countries the: dren) have lived in-during. the last 5 years along with the dates the child(ren) lived there (include.addresses if avaitabfe): 20211 WEYNER; LIVONIA, MI 48152 (6/12/2014- 12/14/2022) 2245, IRISH RIDGE ROAD, PHILO, GH 43771 (12/15/2022.- 5/25/2023) 27522 ANN ARBOR TRAIL: WESTLAND; MI 48185 (5/26/2023- Preserit) 3. The fiame(s) and present address(es) of custodians with whom the child{rert) has/have Iived within the last ‘5 years are: AMANDA-JADE DIXON, 27522 ANN ARBOR TRAIL, WESTLAND; MI 48185 ROY RAYMOND DIXON, 2245 JRISH RIDGE ROAD, PHILO, OH 43771 Ido not-know af, ‘and have not participated (as-a party, witness,.or ih any other-capatity) i in any other court-decision order;-or proceé ig (including divorce, separate’ maintenance, separation, Veglect,. abuse, dép ndehcy, guardian ip, paternity, termination: of parental-rights, and protection from domestic violence) Conceming the.custody or parenting time of the child(ren), ini this state or any other state, except: Specify casename and riumber, court: name-and a is, and date of child custody determiriation, if qne. Approved, SCAO Distrbute form ta: Form MC. 416, Rev, 6/22 Court MCL 722:1208, MCL 722:1208 FOC: (if applicable) Page 10f2 DefendanvRespondent PiaintiffPetitionar Case No. :23-4-DC 23-106659-DC Uniform. Child Custody Jurisdiction Enforcement Act Affidavit: .(6/22) Page 2 of 2 proceeding 5, | do not.know of any pending proceeding that could affect the current child.custody proceeding, including.a parental rights, or for enforcement-or a proceeding relating to: domestic violence, a protective order, termination of and nature of the proceeding. adoption, in this state or any: other state, except: Specify case namie arid number, court name and address, That proceeding Olis continuing. Dhas been stayed by the court. Temporary action by this court is necessary to protect the-child(ren) because the child(ren) has/have been subjected to or'threatened with mistreatment or abuse or is/are otherwise neglected or dependent, Attach explanation 6. | do not know of any person who isnot already a party to this:proceeding who has physical custody of, or who claims tights of legal or physical custody of,or parenting time with, the child(ren), except: Statenamie(s) aiid address(es) of each person. NONE . “See definition of “home state” below. 7. The child(ren)'s “home state” is. O18. | state that a party’s.or child's health, safety, or {iberty: would be put ‘atrisk by the-disclosure of this identifying information. | have filled this form out:completely, and'l. acknowledge:a continuing duty to-advise this.court.of any proceeding in this state or any other state that could affect the current child-custody proceeding. CL AMANDA JADE.DIXON 27522 Ann Arbor Trl, Westland, Mr4gi8s Address of affiant jignature of affiant Name.of affiant (lype,or printy : Subscribed and swom to before:me on Ol ot / [9083 Coan nT ‘clerkiNotary pi signature My commission expires on 08 fal9007 . “ Z lnR1A: Name ‘(type-or print) Gkante Notary public, State of Michigan, County of _¢ _.DAéting in the County of Catiaad O This notarial act was performed using an electronic notarization system‘or a femoté-@lectronic notarization platform: “Home state” means the state in which the child(ren) lived with a parent or a péfsonactifig as a parent for atleast 6 cofsecutive months immediately before the commencement of a child-custody proceeding: In the:case-of a child less than 6 months of age, the term means the state in which the child lived from birth with a parent or person acting as‘a parent.A period of temporary absence of a parent or person acting.as a parént is included as part of the period. MCL 722.1102(g). Original - Court 2nd Copy - Plaintiff 1st Copy- Defendant 3rd Copy -Return STATE OF MICHIGAN CASE NO. THIRD JUDICIAL CIRCUIT SUMMONS 23-106659-DC WAYNE COUNTY Hon.Mary Beth Kelly Court telephone no.: 313-224-0892 Plaintiff's name(s), address(es), and telephone no(s) Defendant's name(s), address(es), and telephone no(s). DIXON, AMANDA JADE DIXON, ROY RAYMOND Plaintiff's attorney, bar no., address, and telephone no Erin Brett Ellis 68825 772 E Maple Rd Birmingham, MI 48009-6334 Instructions: Check the items below that apply to you and provide any required information. Submit this form to the court clerk along with your complaint and, if necessary, a case inventory addendum (form MC 21}. The summons section will be completed by the court clerk. Domestic Relations Case 1 There are no pending or resolved cases within the jurisdiction of the family division of the circuit court involving the family or family members of the person(s) who are the subject of the complaint. O There is one or more pending or resolved cases within the jurisdiction of the family division of the circuit court involving the family or family members of the person(s) who are the subject of the complaint. | have separately filed a completed confidential case inventory (form MC 21) listing those cases, 1 itis unknown if there are pending or resolved cases within the Jurisdiction of the family division of the circuit court involving the family or family members of the person(s) who are the subject of the complaint. Civil Case 1 This is a business case in which all or part of the acticn includes a business or commercial dispute under MCL 600.8035 CO MDHHS and a contracted health plan may have a right to recover expenses in this case. I certify that notice and a copy of the complaint will be pravided to MDHHS and (if applicable) the contracted health plan in accordance with MCL. 400.106(4). O There is no other pending or resolved civil action arising out of the same transaction or occurrence as alleged In the complaint. CT. Acivil action between these parties or other parties arising out of the transaction or occurrence alleged in the complaint has been previously filed in CJ this court, 0 Court, where it was given case number and assigned to Judge The action 0 remains [2 isno longer pending. Summons section completed by court clerk, NOTICE TO THE DEFENDANT: In the name of the people of the State of Michigan you are notifted: 1. You are being sued. 2. YOU HAVE 21 DAYS after receiving this summons and a copy of the complaint to file a written answer with the court and serve a copy on the other party or take other lawful action with the court (28 days if you were served by mail or you were served outside this state). 8. !f you do not answeror take other action within the time allowed, judgment may be entered against you for the relief demanded in the complaint. . If you require special accommodations to use the court because of a disability or if you require a foreign language interpreter to help you fully participate in court proceedings, please contact the court immediately to make arrangements. Issue date Expiration date” Court clerk 6/22/2028 9/21/2023 Brenda Scales Cathy M. Garrett- Wayne County Clerk. “This summons is invalid unless served on or before its expiration date. This document must be sealed by the seal of the court. MC 01 (3/23) SUMMONS MCR 1.109(D), MCR 2.102(B), MCR 2.103, MCR 2.104, MCR 2.105 Sialae a ici” SUMMONS Case No: ; 23-108659-DC PROOF OF SERVICE TO PROCESS SERVER: You must serve the summons and complaint and file proof of service with the court clerk before the expiration date on the summons. If you are unable to complete service you must return this original and all copies to the court clerk. CERTIFICATE OF SERVICE / NONSERVICE Oserved O personaity C1 by registered or certified mail , return receipt requested, and delivery restricted to the addressee(copy of return receipt attached) a copy of the summons and the complaint, together with the attachments listed below, on: O11 have attempted to serve a copy of the summons and complaint, together with the attachments listed below, and have been unable ‘to complete service on: Name Date and time of service Place or address of service Attachments (ifany) C1 ama sheriff,deputy sheriff, bailiff, appointed court officer or attorney for a party. O11 am a legally competent adult who is not a party or an officer of a corporate party. | declare under the penalties of perjury that this certificate of service has been examined by me and that its contents are true to the best of my information, knowledge, and belief. Service fee Miles traveled Fee Signature Incorrect address fee |Miles traveled Fee Total fee Name (type or print) $s ACKNOWLEDGMENT OF SERVICE | acknowledge that | have received service of the summons and complaint, together with on Attachments (if any) Date and time on behalt of Signature MCL 600.1910, MCR 2.104, MCR 2.105 CHILD CUSTODY ACTION -DC STATE OF MICHIGAN CASE NO.23. 106659 THIRD JUDICIAL CIRCUIT COVER SHEET ‘TO BE.SUBMITTED FOR ALL CHILD HON. MARY BETH.KELLY WAYNE COUNTY CUSTODY MATTERS (Including. UCCJEA Determination): = COLEMAN A, YOUNG MUNICIPAL CENTER, TWO, WOODWARD AVENUE, DETROIT, MICHIGAN 38226: Please print neatly or type. PETITIONER name, address, phone #, and ¢-mail: RESPONDENT name, address, phone #,-and e-mail: AMANDA JADE DIXON ROY RAYMOND DIXON 27522 Ann Arbor Trail, Westland, Mi 48185 2245 Irish Ridge Road, Philo, OH 43771 (734) 772-4958 (734) 968-0705: TD Address/phone.no. are not provided due to domestic violence concerns (See atlached Affidavit, UCCJEA Form 11) PETITIONER atiomey name/bar #, address. phone #, and e-mail; RESPONDENT attorney name/bar #; address, plione #. und e-mail: ERIN B, ELLIS (P68825) 772 E. Maple Road, Birmingham, MI 48009 (248) 723-1600 NOW COMES PETITIONER, and states as follows: | Is there a previous child custody’ cast:or order regarding the child(ren) whosé custody is at issue'in'this case? © a: No. If youhave checked.this response, STOP! Answer no further questions, 1 b. Yes, in thig State (includes:parenting time.and-juvenile-court child protective proceedings), as listed in SCAO Form MC 21 previous Confidential Case Inventory. If you have-checked this response, also.comiplete section (1)(c¢) below. If you have no child custody cases or orders in another state, STOP! Oc. Yes, in another state. or in‘a'foreign country. State-or-country: ‘Court: Case Number: Judge: IF, AND ONLY IF, Box (1)(C) 18 CHECKED ABOVE, CONTINUE TO QUESTION 2. 2. Ifyou wantthis Court to take, action regarding, another state or country’s:child:custody order, please carefully mark the checkbox for the ONE option you seck. Ea. REGISTRATIONof another state or country’s-existing child custod; der by this Court. 1 do not wish to enforce or modify the custody order.at this time. A verified registration petiti CCIEA Forin !) must be attached. Ob. IMMEDIATE ENFORGEMENT (without prior-or simultaneous: registration) of another state or country’s-existing child custody order by this Court. T'do not wish to modify the existing custody order at this time, NOTE: This option requires payment of a motion fee..A verified petition for immediate enforcement (UCCJEA Form 9) must be attached. ¥#If'you are trying to enforcean Order Confirming Registration that was previously etitered by this Court, DO NOT submit this form; instead, please complete and file. a Verified Petition for Enforcement after Entryof Order Confirming Registration under the UCCJEA (UCCJEA Form 9a) using the registration case number.** Oc MODIFICATION of another state or country’s existing child custody-order by this Court. NOTE: This-option requires piyment-of a new case filing fee and a-custédy and parenting time fee. 4, complaint establishing this Court's jurisdiction to modify the foreign custody order inust be attached: I deelare that the statements made‘above are true to the'best of my belief and knowledge. DATE: (y: 20: 2% c 1 havc Oneo2 Petitions! st SIGN) vare._Colat | ar “Attorney for Petitioner Me): MCL 722.1209(5) UCCJEA FORM 10°(rev. 3/4/2022) “MCR 3:214(D): MCR 2.119(G)2 MCI. 600.2529(1)(a); MCL, (600:2529(1}(d)ti; MCL. 600.2529{1 STATE-‘OF MICHIGAN CASE NO. 23- -DC 23-106659-DC 3RD CONFIDENTIAL CASE INVENTORY CIRCUIT COURT.- FAMILY DIVISION COUNTY {DOMESTIC RELATIONS: PETITION NO. WAYNE ‘AND JUVENILE:CODE) JUDGE MARY BETH KELLY Plaintif's name [Defendant's name: AMANDA JADE DIXON V_|ROY RAYMOND DIXON. In the matter of in the instructions: List any known pending or resolved family division or tribal court cases involving the person(s) named complaint or petition or family members of the person(s) named in the.complaint or petition. File the completed form with the complaint or petition, but do not attach or staple together. Complete and file-additiona! sheets if necessary. Examples of family-division cases include personal protection orders, divorce, Gustody, paternity, child support, juvenile delinquency, and child protective proceedings, See MCL 600.1021 for a:complete list. Note: This formis confidential and nat to be served on other parties in this case. Court information (name, number, and-county/state) This court O Other court or tribunal: Case name. Case/Fite no; AMANDA JADE DIXON V. ROY RAYMOND DIXON 10-106244-DM: Assigned judge Case status Are support or custody/parenting time orders in effect?| MARY BETH KELLY. Cl Pending Resolved ‘Support Custody/Parenting Time. (Court information (name, number, and-county/state) C This court Dlother cout or tribunal: Case name [Case/File no. \Assigned judge (Case status Are support or custody/parenting time orders in-effect? (Pending Oo Resolved OC Support C] custody/Parenting Time [Court information (name, number, ang county/state) This court other court or tribunal: [Case name GasefFileno. Assigned judge Case status (Are support or custody/parenting time ordersin effect?! OPending qo Resolved Osupport’ TC) Custody/Parenting Time’ Court information (name, number, and county/state) DO This court C1other court or tribunal: Gase name Case/File no. [Assigned judge a (Case status Are support of cust (parenting time orders in effect? | CPending Oo Resolved Support Custody/Parenting Time ff LLD a £L, ‘awl Oexc2? 4i _/ Banaue 5 ee Approved, SCAO Form MC 21, Rey, 12/22 MCR 3.206, MCR 3.931, MCR 3.961 Page 1 of t ber B' ee ~ ws ‘ COMMON PLEAS COUR MUSKINGUM CO. OHIO STATE OF MICIIIGAN FOR THE C OUNTY OF WAH AUG -8 P 3 42 IN THE CIRCUIT COURT WERDY SOWERS AMANDA JADE DIXON, Plaintiff, 10-106244 DM JOG:DEBORAH Ai oss abana “Vg- DIXON AMAHOR “anya Lua Wa aa OND DIXON ROY RAYM ROY RAYMOND DIXON, > Defendant, John P, Herzog (P43789) PILED CATHY ML, GARRETT Attorney for Plaintiff CRaRTT/ OLERK 23290 Farmington Road, P.O. Box 321 NOV G9 2010 a Farmington, MI 48332 te te (248) 474-00 15 ly Ty ‘ Alshoe Roy Raymond Dixon In propria persona: Os 1564 Helen Garden City, MI 48135 - oF JUDGMENT OF DIVORCE ‘At ssion of said Court “"" held ia the City of Detroit County of Wayne, Michigan on © wovo 9 2010; PRESENT: HON DEBORAH ROSS ADAMS CIRCUIT COURT J UDG EB wae ~~ “This cause having come on to be heafd and the parties and Plaintiff's couns el-having appeared and having reached an agreement whichfullywasadvised placed on and the record, and t he Defendant having been present in court and the Plaintiff having presented her proof in open Court that the material facts - . alleged in the Complaint are true, and that there has been a breakdown in the marriage relationship to the extent that the objects of matrimony have been destroyed and there remains no reasonable likelihood that the marriage can be preserved; On motion of John P. Herzog, Autorney tor Plaintiff; Se - , by ~ASOLArrE DIVORCE IT1S HEREBY ORDERED AND ADJUDGED that the marriage between the said Plaintiff, AMANDA JADE DIXON and Defendant, ROY RAYMOND DIXON, and the same hereby is dissolved, and a Divoree trom the bonds of matrimony between said parties is hercb y adjudged, according to the Statute in such case made and provided, PARTIES’ ADDRESS, IT1S FURTHER ORDERED AND ADJUDGED that the Plaintiff presently residing at 27522 Ann Arbor Trail, Westland, Michigan 48185 and the Defe ndant, presently residing at 1564 Helen, Garden City, Michigan 48135, shall notify the Wayne County Friend of the Court, Detroit, Michigan, of any change of residential address after the date the support provision is operative, or until the further Order of this Honorable Court. oe cusTopy oF MINOR CHILD IIs FURTHER ORDERED AND ADJUDGRD that the Plaintiff and Defendant are awarded joint, legal custody of the minor child of the parties; to wit DILLON ROY DIXON bors June.19, 2008, with physical custody to Plaintiff AMANDA.JADE DIXON, until said child attain the age of majority or until the further Order of this Honorable Court, SUPPORT Or MINOR ‘CHILD IT I$ FURTHER ORDERED AND ADIUDGED that the Defendant pay through the Office of the Friend of the Court per week as child support for or 1,08 BO Danes y-four ON commencing date of Judgment of Divorce as follows: ) Dollars until said child attains the age of eighteen (18) or graduates from high school whichever is later, but not beyond nineteen (19) years and six months, as provided - by MCL 552,605b, or as olherwise ordered by the Court. IT IS FURTHER ORDERED AND ADJUDGED that the matter of child support shall be referred back {o the Friend of the Court for reinvestigation annually to determine Delendant's future weekly chi 1 d Support obligation. i - ia RETROACTIVE MODIFICATIONOF SUPPORT ITLs FURTHE R ORDERED AND ADJUDGED that except as otherwise provided in sectio n 3 of the support and visitation enforcement act. Act No. 295 of the Public A) cts of 1982 being section $ 52.603 as amended by Act No. 25 of the Public Acts of 1996, of the Michigan Compiled I @ support order that is part ofa judeme nt or is an order in a domestic retations Laws, matter as ¢ hat term ig defined in section 31 of the Friend of the Court act. Act No, 294 of the Public Acts of 1982 » being section 582.531 of the Michigan Compiled Laws, is a judgment on and alter the d ate of cach support paymen t is du ¢, with the full force, effect, and attributes of a judgement of this state, and is not, on and after the date it is duc, Subject to retr ‘oaclive modification . SERVICE FER ITIS FURTHER ORDERED AND ADIUDGED that the Defendant shall pay to the Wayne County Friend of the Court, Detroit, Michigan, the sum of Three Dollars and fifty cents ($3.50) per month, hereafter while the Order for Support is operative, Initial payments for the next regular due date shall be made forthwith. * LEIS FURTHER ORDERED AND ADJUDGED that any Child Support ° Arrearage due and owing to the State or otherwise due is expressly preserved, and : payable forthwith through. the Office of the Friend of the Court, : ‘ INCOME WITHHOLDING » IT IS FURTHER ORDERED AND ADJUDGED that pursuant to MCL 522.604 an immediate order of income withholding shail issue, and that the payor shall make all payments to the Office of the Friend of the Court until said order of income withholding is effectuated by the payor’s source of income. ITIS FURTHER ORDERED AND ADJUDGED that the Plai + ntiff and the Defendant shall immediately give to the Office of the Friend of the Court the name and address ofhis/her current or subsequent e. mployer or other source(s) of - -- income. MEDIC A L DENT: A L AND HOSPITAL EXPENSES —— ~ HPIS FURTHER ORDERED AND ADIUDGED that both the Plaintiff and the Defendant shall obtain or maintain any health care coverage that is available to them, ata reasonable cost, as a benefit of emp loyment, for the benefit of the child who is/are the subject of this Order. 1 ITTS FURTHER ORDERED AND ADJUDGED that the Defendant pay 40% of any uninsured medical, dental, hospitalization, or other health care expenses of the minor child and Plaintiff pay 60% of any uninsured medical, dental, hospitalization, or other health care expenscs of the minor child, VISITATION PRIVILEGES ps “TTIS FURTHER ORDERED AND ADJUDGED that the Defendant shall be granted reasonable visitation privileges with the minor child of the parties hereto, namely: DILLON ROY DIXON, until said child attain the age of majority or graduates from high school, whichever is later, or until the further Order of this ' Court, ! DOMICILE PROVISION IT IS FURTHER ORDERED AND ADJUDGED that the Legal custodian of the minor child of the parties notify the Wayne County Friend of the Court, Detroit, Michigan, of any change of residence address of the minor child presently / residing at 27522 Ann Arbor Trail, Westland, Michigan 48185, and that the domicile or residence of said minor child shall not be removed from the State of Michigan without prior approval of this Court. § ALIMONY/SPOUSAL SUPPORT irs FURTHER ORDERED AND ADJUDGED that no alimony or spousal support be granted to eithe r party, and that al imony or spousal support is ‘permanently barred. . | MUTUAL DOWER RELEASE / ITI§ FURTHER ORDERED AND ADJUDGED that any tights of either Plaintiffor Defendant in any lands held by the other shall be hereby extinguished. * Further, that each shall hereafter hold his or her remaining lands free, clear and discharged from any such dower right or claim that the other may have jn any = property which each may own or.may hereafter own, or in which each has or may hereatter have any interest. Gr Peres og Wi MoO Pfitt (ESTATE. ted ay _ O- TUE OTL C5 CELRIGED | VRE we é Lael PERSONAL PROPERTY ITIS FURTHER ORDERED AND ADJUDGED that each of the parties retain the personal property, bank accounts and retirement accounts presently in their respective possessions. Any arrearage or balance in the Co-Op Credit Union account number 297084-6-0 shall be awarded to or the responsibility of Defendant, . 4 4 ‘ 4. a DEC re Peavecnd 17 1 FUR ThR CRDERED Awa ROTUDGED TET THE Prerres OTETE 1 TUE EIA Of THR OTHEL., gir Pisces’ yl ok. IRY INSURANCE PROVISION , ITIS FURTHER ORDERED AND ADJUDGED that any rights of either Party in any policy or contract of life, endowment or annuity insurance of the other as beneficiar ry are hereby extinguished, unless specifically Preserved by this . Judgment. o Gy Pyainuift 4 4 JADE DIXON, JOHN APERZOG. Y for Plaintiff | — e - a RO¥RAYMOND DIXON. Defendant . ERGW CHOLAGE: We ( ne cuP NrE Circuit Court p? GAR erik at col uN LM ae a ERTIFIC. E] E A copy of the foregoing Answer, Motion for Change of Venue/Jurisdiction and Motion for Temporary Orders was sent on this 7th day of August 2023 by mail to Roy Dixon, Plaintiff, 2245 Irish Ridge Road, Philo, OH 43771. pss Keay Mh Stacey (0 18)