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IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN AND FOR ESCAMBIA COUNTY, FLORIDA

RE: THE MARRIAGE OF: JACKIE R. CAMERON Petitioner/Husband, CASE NO: 2012-DR-1993 and CHRISTINE S. CAMERON Respondent/Wife. ________________________________ RESPONDENTS MOTION FOR LEAVE TO AMEND VERIFIED COUNTER PETITION FOR DISSOLUTION OF MARRIAGE COMES NOW, Respondent, by and through Christine Sue Cook, LLC, and moves this Court for an order permitting her to amend her Counter Petition for Dissolution of Marriage filed on August 31, 2012, and in support thereof states: 1. 2. This is an action for dissolution of marriage filed on May 23, 2012. Former counsel to Respondent, Ann E. Meador, filed Respondents Counter

Petition for Dissolution of Marriage and Relocation with Minor Child on August 31, 2012. 3. A stipulation for substitution of counsel was executed by former counsel and the

undersigned on December 10, 2012, and ordered on December 14, 2012, by Judge Thomas R. Santurri. 4. It has become clear to the undersigned that the Counter Petition for Dissolution of Marriage and Relocation with Minor Child needs to be amended to include indispensable parties to wit: a. J. R. Cameron, LLC, d/b/a J. Rod Cameron, PL, a/k/a The Law Office of J. Rod Cameron (hereinafter J. R. Cameron, LLC or the Company) is joined as an

b.

c.

d.

e.

indispensable and necessary party to this action because J. R. Cameron, LLC is the alter-ego of Petitioner, Jackie Rogene Cameron, and as such, to adequately address the financial liabilities of the Parties, J. R. Cameron, LLC must be named as a party. J. R. Cameron, LLC is the Petitioners company and Petitioner Jackie Rogene Cameron, who is the sole manager of the Company, handles all financial matters of the same. Petitioner, prior to, throughout the marriage and beyond, has co-mingled personal and Company funds, paying for rent, groceries, baby items, etc. with the same. Furthermore, J. R. Cameron, LLC, is the holder of marital and non-marital assets and has been a source of income to Respondent and the marriage. J. R. Cameron, LLC is an indispensable and necessary because Respondents automobile is titled in her and the Companys names, and for the Court to award said automobile to Respondent/Wife, the company must be joined. (Noe v. Noe, 431 So.2d 657 (Fla. 2d DCA 1983). HOT ROD INVESTMENTS, LLC (hereinafter HRI, LLC) is joined as an indispensable and necessary party to this action because HRI, LLC is the alterego of Petitioner, Jackie Rogene Cameron, and as such, to adequately address the financial liabilities of the Parties, HRI, LLC must be named as a party. HRI, LLC is the Petitioners company and Petitioner Jackie Rogene Cameron (a/k/a J. Rod Cameron, Registered Agent), who is the sole manager of the Company, handles all financial matters of the same. Petitioner, prior to, throughout the marriage and beyond, has co-mingled personal and Company funds and martial and non-marital assets, paying for rent, groceries, baby items, etc. with the same. Furthermore, HRI, LLC, is the holder of marital and non-marital assets and has been a source of income to the marriage.

WHEREFORE, Respondent respectfully prays this Court enter an order permitting Respondent leave to amend the Counter Petition to Dissolution of Marriage and Relocation with Minor Child to include Count III Joinder of Indispensable Parties. I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to Jackie R. Cameron, Petitioner, via email at jrod@jrodcameron.com and liz@jrodcameron.com on this 2 day of January 2013.
nd

/s/ Christine S. Cook


CHRISTINE S. COOK, ESQ. CHRISTINE SUE COOK, LLC FLA Bar No: 0528439 890 South Palafox Street - Suite 109 Pensacola, FL 32502 (850) 572-7159 / (877) 249-6279 fax christine@christinescook.com Attorney for Respondent