STATE OF TEXAS COUNTY OF HARRIS JENNY A. JONES CASE NO:95-45554-DM VS JUDGE: NORMAN MAILER JOHN B.JONES ANSWER TO COMPLAINT ---------------------- John Jones 2467 E Hill Rd Houston, TX. 77001 TX: 713-695-6950 Attorney For Plaintiff ---------------------- Jenny R. Joplin 8221 Longstreet Houston, TX 77002 TX: 713-234-1212 Attorney For Defendant -----------------------
Now comes the Defendant, John B. Jones, who answers Plaintiff’s Complaint for Divorce as follows:
6. NEITHER ADMITTED NOR DENIED, as your Defendant does not have sufficient knowledge to admit or deny this statement.
8. DENIED, for the reason that the statement is untrue: The Plaintiff is gainfully employed, and/or owns a business, as described in Plaintiff’s paragraph 6 of her complaint, and Plaintiff has sufficient income to pay her own attorneys fees.
9. ADMITTED IN PART, AND DENIED IN PART: Your Defendant is just as qualified as the Plaintiff to be the primary physical custodian of the minor children of the parties.
Further, Defendant agrees that the provisions of the Michigan Child Support Guidelines control the support to be paid between the parties, based upon the factors expressed therein.
WHEREFORE, Your Defendant prays that this Honorable Court will:
1. Equitably divide the property of the parties, and
2. Provide for the minor children of the parties, in a joint physical custody arrangement, with support according to the Texas Child Support Guidelines, and
3. Deny Plaintiff’s request for attorneys fees, and
4. Enter a judgment of divorce, and
5. Provide your Defendant such other, and further, relief, as your Defendant may show himself entitled to same.
Further, Defendant prays not.
[signature]John B. Jones.
>> Look At the Sample Complaint again