Deters Divorce Answer and Counterclaim

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0104682777

COURT OF COMMON PLEAS


DIVISION OF DOMESTIC RELATIONS
HAMILTON COUNTY, OHIO

Case No. DR1302234

MELISSA HENDON DETERS

Plaintiff

Judge: Lewis
Magistrate:

-vsJOSEPH THEODORE DETERS

DEFENDANT'S ANSWER
AND COUNTERCLAIM

Defendant

Comes now the Defendant, by and through his undersigned counsel, and . for his ~,..,.
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response to Plaintiffs

Complaint, avers and states as follows:

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I. Defendant admits the allegations contained in Paragraphs 1 and 2]J.thc


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Complaint.
2.

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Defendant admits the parties arc incompatible, but denies the remaining

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allegation of Paragraph No.3 of the Complaint.


COUNTERCLAIM

3. Defendant has been a resident of the State of Ohio for at least six (6) months
and a resident of Hamilton County for at least 90 days immediately preceding the filing of
Plaintiffs Complaint.
4. Defendant and Plaintiff were married on September 7, 1985, in Cincinnati,
Ohio, and there have been four children born issue of this marriage, namely: Joseph S.

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or.J1

Deters. born January

25, 1989, Jonathan

Deters, born October

5, 1993,

T. Deters, born July 7, 1990, Mary Elyse H.

and Patrick J. Deters, born May 8, 2004. All of the

children, except Patrick, are emancipated.


5.

Defendant states that the parties are incompatible, but if PIa inti ff denies

this, then the Plaintiff is guilty of gross neglect of duty, and by reason thereof Defendant
is entitled to a divorce.

WHEREFORE, Defendant prays for the judgment of the Court as follows:


(A)

That Defendant be granted a decree of divorce from Plaintiff on his

Counterclaim;
(B)

That the Court order an equitable division of the marital property and

award each party's separate property to the appropriate party;


(C)

That the Court aiiocate parenting on the basis of shared parenting.

(D)

That the Court award him reasonable legal fees and expenses incurred

herein; and
(E)
be

That the Defendant be granted such other and further relief to which he may

entitled at law or in equity.

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Gregory L. Adams (0025975)


Attorney for Defendant
Croswell & Adams Co., L.P.A.
1208 Sycamore Street
Cincinnati, Ohio 45210
(Sf3) 241-5670
(513) 9293473

facsimile
[email protected]

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CERTIFICATE

20

OF SERVICE

1 hereby certify that a copy of the foregoing was sent to all counsel of record this
day of December, 2013, by depositing it into the Regular U.S. Mail, postage prepaid.

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Gregory L. Adams

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