IN THE SUPERIOR COURT OF FULT STATE OF GEORGIA FAMILY DIVISION JILL T. CONNORS, Petitioner, CIVIL ACTION FILE v NO. 20156V264720 DR. JOHN P. CONNORS, 111, Respondent. PETITIONER'S MOTION FOR TEMPORARY HEARING ON EXPEDITED BASIS TO ADDRESS URGENT ISSUES, COMES NOW, Petitioner, JILL T. CONNORS, and files this Motion for Temporary Hearing on An Expedited Basis to Address Urgent Issues, and respectfully requests this Court hold a temporary hearing as soon as reasonably possible to determine urgent issues facing this family, including temporary custody of the Parties’ minor children, temporary support for the minor children and Petitioner, use of the marital residence and temporary attomey’s es. In support of her motion, Petitioner shows the Honorable Court the following: 1 ‘The above-styled Complaint for Divorce was filed on August 19, 2015. The Parties bave three (3) minor children: Jameson P, Connors, born in 2004; Aidan P. Connors, bom in 2005; and Carson B. Connors, bom in 2007 (hereinafter the “minor children”). 2 Petitioner was the primary, if not sole care provider for the Parties’ three (3) sons during the marriage. Respondent is a highly regarded plastic surgeon, who, while very successful in his career, played a limited parenting role during the marriage.3 The Parties were involved in an altercation at the marital residence on August 13, 2015. Petitioner was arrested and removed from the matital residence. A criminal action is pending regarding that altercation, styled: State of Georgia v. Jill Connors, Magistrate Court of Fulton County, Warrant No. 1SMAGC06479, Respondent has also filed a family violence action regarding the altercation, styled: John Connors v. Jill Connors, Superior Court of Fulton County, Civil Action File No.: 2015CV264592. 4 ‘The Magistrate Court entered an Order which allows Petitioner to have visitation and phone contact with the minor children, See Order, attached hereto as Exhibit “A,” 5. Despite the Order and repeated requests through counsel, Respondent has denied Petitioner any and all contact with the minor children since August 13, 2015. Respondent ‘has even refused to arrange for Petitioner and the minor children to have telephone contact with each other. Respondent is not providing any information to Petitioner even indirectly regarding the children’s well-being, education or extracurricular activities. Upon information and belief, Respondent is relying heavily upon a third-party caregiver to care for the minor children during this time. 6 Petitioner shows the court that she is a fit and proper custodian of the minor children, Petitioner requests that she be awarded temporary joint legal and primary physical custody of the minor children of the Parties. Pursuant to 0.C.G.A. § 19-9-3, thisCourt has the authority to enter a temporary parenting plan consistent with the best interests of the minor children. 7. Respondent further shows the Court that despite her best efforts, she and the minor children are completely and solely dependent on Petitioner for their support. Specifically, Petitioner shows the Court as follows: (@) Petitioner does not have any income, Most recently during the marriage, Petitioner ws employed as the office manager at Respondent's medical practice. As a result of the pending action before the Magistrate Court, she is presently unable to work with the Respondent; (b) Respondent has sole contro! over all the marital assets and accounts. Petitioner does not have access to any marital property, other then a limited amount of cash that she presently has on hand; and (©) Petitioner does not have any separate property that she can use to support herself or the minor children on a temporary basis. 8. Conversely, Petitioner shows the Court that Respondent’s income is significant and that he controls all of the marital assets. Moreover, Respondent unilaterally removed Two Hundred and Fifty Thousand Dollars ($250,000) from the Parties’ joint account into an account in his sole name the same day as the parties’ altercation.9. Accordingly, pursuant to O.C.G.A. § 19-6-14 and O.C.G.A. § 19-6-3 respectively, Petitioner requests that Respondent be ordered to pay temporary child support on behalf of the Parties’ three (3) sons, as well as temporary support for Petitioner, 10. Petitioner shows the Court that she is currently residing with friends, as she does not have an income nor sufficient credit history to rent an apartment. Petitioner has no access to the funds necessary for the costs and expenses to secure and maintain a separate residence. Petitioner requests that she be granted sole and exclusive use of the marital residence on a temporary basis. 1 Petitioner currently does not have access to her car and is dependent on friends for transportation. Petitioner shows the Court that through counsel, she has requested that she be able to retrieve her car, to no avail. Petitioner requests that Respondent be ordered to make Petitioner's cat available to her on an immediate basis. 12, Petitioner currently only has access to limited personal effects, including her clothing. Petitioner shows the Court that through counsel, she has requested that she be able to retrieve her personal items, to no avail. Petitioner requests that Respondent be ordered fo make Petitioner's clothing and personal effects available to her on an immediate basis.1B. Additionally, Petitioner does not have the resources to pay for legal counsel in the divorce action. Petitioner is in need of an interim award of attorney’s fees and expenses of litigation in order to ensure her effective representation. Without such an award, Petitioner will be unfairly disadvantaged by the disparity in income between the Parties and Respondent’s total control of the marital assets during the pendency of this litigation. The present action has been pending for less than one (1) week and Respondent has already attempted to use the Parties’ disparity in income as leverage in the present action, depriving Petitioner of any access to her children, housing and transportation, Pursuant to O.C.G.A. § 19-6-2, this Court may award attorney's fees “at any time during the pendency of this litigation” and such an award is within the “sound discretion of the Court.” 14, Petitioner further shows the Court that through counsel, she has proposed mediation of the temporary issues, but that Respondent is unwilling to even schedule ‘mediation at this time. WHEREFORE, Petitioner respectfully requests the Court award her the following relief: a, That a Rule Nisi issue setting this matter for a Temporary Hearing on an immediate basis; b. That Respondent be required to appear and show cause as to why the relief requested herein should not be awarded; c. That Petitioner be awarded joint legal and primary physical custody of the minor children on a temporary basis; d. That Respondent be ordered to pay Petitioner child support on a temporary basis for the support of the minor children;¢. That Respondent be ordered fo pay temporary support to Petitioners f. That Petitioner be granted sole and exclusive use of the marital residence on a temporary basis; g. That Petitioner be awarded temporary attorney’s fees so that she can pursue and defend her claims and interests in this action; and h. For such other and further relief as this Court finds necessary and appropriate, Respectfully submitted, this 24th day of August, 2015. ISSA DAVIS STRICKLAND ‘gia Bar No. 212039 Attorneys for Petitioner One Securities Centre 3490 Piedmont Road, N.E. Suite 1150 Atlante, Georgia 30305 (404)237-5700 llevine@Isswiaw.comIN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA FAMILY DIVISION JILL T. CONNORS, Petitioner, CIVIL ACTION FILE y. NO. 2015CV264720 DR. JOHN P. CONNORS, III, Respondent. CERTIFICATE OF SERVICE This is to certify that I have served a true and correct copy of the foregoing Motion ‘for Temporary Hearing on An Expedited Basis to Address Urgent Issues, to Respondent and Debbie C. Pelerose, sq., addressed as follows: Dr. John P. Connors, I] 755 Mt. Vernon Highway, NE,, Suite 250 Atlanta, Georgia 30327 Via Hand Delivery Debbie C, Pelerose, Esq Debbie Crosby Pelerose, P.C. 170 Anderson Street Marietta, GA 30060 ‘Via E-mail and U.S. Mail‘This 24th day of August, 2015. ‘One Securities Centre 3490 Piedmont Road, N.E. Suite 1150 Atlanta, Georgia 30305 (404)237-5700 jlevine@Isswlaw.com sa Bar No, 212039 Arfomeys for Petitioner