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Clark County, Ohio
FILED
APR 18 2024
Common Pleas Court
Melissa M. Tuttle, Clerk
IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO
DOMESTIC RELATIONS DIVISION
AMANDA M. BOWERS CASE NO. 4 BR 1 5 7
720 Bellows Dr.
New Carlisle, Ohio 45344 JUDGE:
Plaintiff MAGISTRATE:
-Vs-
DUSTIN M. BOWERS
720 Bellows Dr.
New Carlisle, Ohio 45344
and
BOWERS LAWN MAINTENANCE LLC
c/o Dustin Marc Bowers
720 Bellows Dr.
New Carlisle, Ohio 45344
and
BOWERS CHIMNEY SERVICES, LLC
c/o Richard E. Zerner
5045 Cartagena Drive
Toledo, Ohio 43623
COMPLAINT FOR DIVORCE
Defendants, WITH CHILD
1 Plaintiff, Amanda M. Bowers, has been a resident of the State of Ohio for
at least six (6) months immediately before filing of this Complaint for Divorce as required by
Section § 3105.03 of the Ohio Revised Code.
2. Plaintiff has been a resident of Clark County for at least ninety (90) days
immediately before filing of this Complaint for Divorce as required by Rule 3 of the Ohio Rules
of Civil Procedure.
3 The Plaintiff and Defendant, Dustin M. Bowers, were married on the 27th
day of October, 2017 in Springfield, Ohio.
4 Plaintiff, Wife, is not currently pregnant.
5 There have been one (1) minor child born as issue of the marriage, to wit:
Brooke L. Bowers, born June 6, 2012.
6 Neither Plaintiff nor Defendant is an active-duty servicemember of the
United States Military.
7
Plaintiff has been a respectful, faithful and supportive spouse as required of
her in § 3103.01 of the Ohio Revised Code, however differences have arisen to the extent that the
parties are no longer compatible and for this reason and for the other statutory reasons set forth in
Ohio Revised Code §3105.01 the parties are hereby entitled to a divorce based upon one or several
grounds contained therein.
8 Plaintiff and Defendant have proprietary interests in real property,
automobiles, household goods and furnishings, bank accounts, and other interests.
9. Defendant, Dustin M. Bowers, is currently employed by and/or is an owner,
shareholder, and/or has a financial and/or equitable interest in certain business, corporations,
entities, enterprises, partnerships or associations including but not limited to Defendant Bowers
Lawn Maintenance LLC (hereinafter “Defendant Lawn Maintenance”), Defendant Bowers
Chimney Services, LLC (hereinafter “Defendant Chimney Services”), and others currently
unknown to Plaintiff, and that unless the Defendant, Dustin M. Bowers, and the two
aforementioned Defendants are restrained, Defendant, Dustin M. Bowers, will week to sell,
dispose, conceal, alienate, encumber, transfer or otherwise hypothecate his interest in said
corporations, companies, businesses, partnerships, including but not limited to common stock,
assets, goodwill, bank accounts, deferred income plans, governance and any pension plans and/or
retirement plans, in order to defeat Plaintiff’s right therein, all to her irreparable injury for which
she has no adequate remedy at law, and that unless likewise restrained, Defendant Lawn
Maintenance, Defendant Chimney Services and all other corporate interests that Defendant, Dustin
M. Bowers, may have an interest in, will allow Defendant, Dustin M. Bowers, to so act, all to
Plaintiff's irreparable harm for which she has no adequate remedy at law;
WHEREFORE, Plaintiff demands:
A A Judgment Decree of Divorce from the Defendant;
B That she be designated the temporary and permanent residential parent and
legal custodian of the parties’ minor child, or in the alternative, the parties be granted a shared
parenting plan;
Cc Defendant pay temporary and permanent child support, cash medical
support, health care expenses and other expenses of the parties’ minor child;
D. Defendant pay temporary and permanent spousal support;
E. An equitable distribution of the real and personal property of the parties;
F, A temporary restraining order prohibiting the Defendant, Dustin M.
Bowers, Defendant Bowers Lawn Maintenance LLC and Defendant Bowers Chimney Services,
LLC from transferring, selling, encumbering and/or disposing of any property in which Plaintiff
may have or claim an interest;
G A temporary restraining order prohibiting the Defendant from abusing,
interfering with, molesting, harassing, and/or bothering the Plaintiff, at any time or place by any
manner or means;
H. An award for Plaintiff's costs and attorney fees expended herein;
I Defendant be ordered to pay the Court costs of the proceeding;
J Such other and further relief as the Court may deem just and proper.
ha SEVERT (#0060076)
SEVERT & PRATT CO.
Water Street
Troy, Ohio 45373
Phone: (937) 552-5056
Fax: (937) 339-6446
Email: tds@Isplaw.org
Attorney for Plaintiff, Amanda M. Bowers
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Clark County, Ohio FILED APR 18 2024 Common Pleas Court Melissa M. Tuttle, Clerk IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO DOMESTIC RELATIONS DIVISION AMANDA M. BOWERS CASE NO. 4 BR 1 5 7 720 Bellows Dr. New Carlisle, Ohio 45344 JUDGE: Plaintiff MAGISTRATE: -Vs- DUSTIN M. BOWERS 720 Bellows Dr. New Carlisle, Ohio 45344 and BOWERS LAWN MAINTENANCE LLC c/o Dustin Marc Bowers 720 Bellows Dr. New Carlisle, Ohio 45344 and BOWERS CHIMNEY SERVICES, LLC c/o Richard E. Zerner 5045 Cartagena Drive Toledo, Ohio 43623 COMPLAINT FOR DIVORCE Defendants, WITH CHILD 1 Plaintiff, Amanda M. Bowers, has been a resident of the State of Ohio for at least six (6) months immediately before filing of this Complaint for Divorce as required by Section § 3105.03 of the Ohio Revised Code. 2. Plaintiff has been a resident of Clark County for at least ninety (90) days immediately before filing of this Complaint for Divorce as required by Rule 3 of the Ohio Rules of Civil Procedure. 3 The Plaintiff and Defendant, Dustin M. Bowers, were married on the 27th day of October, 2017 in Springfield, Ohio. 4 Plaintiff, Wife, is not currently pregnant. 5 There have been one (1) minor child born as issue of the marriage, to wit: Brooke L. Bowers, born June 6, 2012. 6 Neither Plaintiff nor Defendant is an active-duty servicemember of the United States Military. 7 Plaintiff has been a respectful, faithful and supportive spouse as required of her in § 3103.01 of the Ohio Revised Code, however differences have arisen to the extent that the parties are no longer compatible and for this reason and for the other statutory reasons set forth in Ohio Revised Code §3105.01 the parties are hereby entitled to a divorce based upon one or several grounds contained therein. 8 Plaintiff and Defendant have proprietary interests in real property, automobiles, household goods and furnishings, bank accounts, and other interests. 9. Defendant, Dustin M. Bowers, is currently employed by and/or is an owner, shareholder, and/or has a financial and/or equitable interest in certain business, corporations, entities, enterprises, partnerships or associations including but not limited to Defendant Bowers Lawn Maintenance LLC (hereinafter “Defendant Lawn Maintenance”), Defendant Bowers Chimney Services, LLC (hereinafter “Defendant Chimney Services”), and others currently unknown to Plaintiff, and that unless the Defendant, Dustin M. Bowers, and the two aforementioned Defendants are restrained, Defendant, Dustin M. Bowers, will week to sell, dispose, conceal, alienate, encumber, transfer or otherwise hypothecate his interest in said corporations, companies, businesses, partnerships, including but not limited to common stock, assets, goodwill, bank accounts, deferred income plans, governance and any pension plans and/or retirement plans, in order to defeat Plaintiff’s right therein, all to her irreparable injury for which she has no adequate remedy at law, and that unless likewise restrained, Defendant Lawn Maintenance, Defendant Chimney Services and all other corporate interests that Defendant, Dustin M. Bowers, may have an interest in, will allow Defendant, Dustin M. Bowers, to so act, all to Plaintiff's irreparable harm for which she has no adequate remedy at law; WHEREFORE, Plaintiff demands: A A Judgment Decree of Divorce from the Defendant; B That she be designated the temporary and permanent residential parent and legal custodian of the parties’ minor child, or in the alternative, the parties be granted a shared parenting plan; Cc Defendant pay temporary and permanent child support, cash medical support, health care expenses and other expenses of the parties’ minor child; D. Defendant pay temporary and permanent spousal support; E. An equitable distribution of the real and personal property of the parties; F, A temporary restraining order prohibiting the Defendant, Dustin M. Bowers, Defendant Bowers Lawn Maintenance LLC and Defendant Bowers Chimney Services, LLC from transferring, selling, encumbering and/or disposing of any property in which Plaintiff may have or claim an interest; G A temporary restraining order prohibiting the Defendant from abusing, interfering with, molesting, harassing, and/or bothering the Plaintiff, at any time or place by any manner or means; H. An award for Plaintiff's costs and attorney fees expended herein; I Defendant be ordered to pay the Court costs of the proceeding; J Such other and further relief as the Court may deem just and proper. ha SEVERT (#0060076) SEVERT & PRATT CO. Water Street Troy, Ohio 45373 Phone: (937) 552-5056 Fax: (937) 339-6446 Email: tds@Isplaw.org Attorney for Plaintiff, Amanda M. Bowers