Suit
Content
s
.•
DANNYE WAYNE MALONE VERSUS MONTINA HARRIS MALONE PERMANENT ASSIGNMENT :
NUMBER 531,409 FIRST JUDICIAL DISTRICT COURT CADDO PARISH, LOUISIANA SECTION E (JUDGE WADDELL)
RECONVENTIONAL DEMAND l ue
NOW INTO COURT, through undersigned counsel, comes MONTINA HARRIS MALONE, who appears herein for purpose of filing a Reconventional Demand in response to the Petition for Divorce filed herein by DANNYE WAYNE MALONE on May 28, 2009, and respectfully shows that: I. Made defendant-in-reconvention herein is DANNYE WAYNE MALONE, a major resident and domiciliary of Shreveport, Caddo Parish, Louisiana, who may be personally served with notice through his attorney of record herein, Ms. Katherine Clark Dorroh, 3000 Fairfield
Ave., Suite B, Shreveport, Louisiana.
2.
-
- ---
Plaintiff-in-reconvention shows that the defendant-in-reconvention, DANNYE WAYNE MALONE, filed a Petition for divorce on May 28, 2009. 3. This,Coun has jurisdiction over this proceeding pursuant to the provisions of Louisiana
Code of Civil Procedure,
Article 10(a)(7), in that this is a suit for divorce and matters incidental
thereto, and both of the spouses are domiciled in this State. 4. Venue for this action is proper in this Court pursuant to the provisions of Louisiana
Code of Civil Procedure,
Article 3941, as Caddo Parish is the parish where both of the parties
are domiciled and it is the parish of the last matrimonial domicile. 5, No children have been born issue of the marriage between the parties hereto nor have any children been adopted by the parties.
PGSpEXHJ NUN CC CP MArtP-14-N/J_____ IND X REC FAX W/D DOC CERT SERVICE /tor Ply, 44 Into-
sz;ei FILED
SEP 0 4 7009
roam_
nr .A16:::: -4' .
TL E00 06 00 ZO T60 O akibl UDS
INTERROGATORY NUMBER 29:
At–any–point–i • uring your marriage to MONTINA HARRIS MALONE did you
consume, ingest and/or smoke marijuana in the matrimonial domicile? If you admit this fact, please answer the following:
(A) Was MONTI:NA HARRIS MALONE or the minor child of MONTiliA HARRIS
MALONE present when you consumed, ingested and/or smoked marijuana? (B) Do you deny that MONTINA HARRIS MALONE expressed to you her complaint, dissatisfaction and objection to you and your colleagues consuming, ingesting and/or smoking marijuana in the matrimonial domicile where MONTINA HARRIS MALONE and her minor child resided with you? Do you deny that you broughtnLizaga into the matrimonial domicile to consume, ingest and/or smoke marijuana with you? Do you deny that you have consumed, ingested and/or smoked marijuana in the matrimonial domicile with Cedric Glover and Dale Sibley? Do you deny that third persons, including, but not limited to, Dale Sibley, came to the matrimonial domicile on numerous occasions for the purpose of taking possession of a package of marijuana? If you admit this fact, was the package of marijuana the subject of a sale or was the illegal contraband donated by you to the person or persons? —
(C)
(D D
(
INTERROGATORY NUMBER 30:
Please identify each and every person who is provided coverage in connection with the policy of medical insurance coverage that you have procured with/through Blue Cross Blue Shield.
INTERROGATORY NUMBER 31:
Do you deny or dispute that MONTINA IIARR1S MALONE traded in her separate property vehicle in connection with the purchase of your Toyota Highlander vehicle and that the trade-in value of her vehicle was $3,000.00? Do you dispute or deny that the Toyota Highlander vehicle is your separate property?
INTERROGATORY NUMBER 32:
Do you deny or dispute that you and other members of Monk.house Seafood Diner have sat at a table in the matrimonial domicile and divided up cash receipts of the business, which cash receipts were never accounted for from the standpoint of taxable income of the business enterprise?
'6 00 Z0T6 003.1\114 t13.5
O GO
.•
DANNYE WAYNE MALONE VERSUS MONTINA HARRIS MALONE PERMANENT ASSIGNMENT :
NUMBER 531,409 FIRST JUDICIAL DISTRICT COURT CADDO PARISH, LOUISIANA SECTION E (JUDGE WADDELL)
RECONVENTIONAL DEMAND l ue
NOW INTO COURT, through undersigned counsel, comes MONTINA HARRIS MALONE, who appears herein for purpose of filing a Reconventional Demand in response to the Petition for Divorce filed herein by DANNYE WAYNE MALONE on May 28, 2009, and respectfully shows that: I. Made defendant-in-reconvention herein is DANNYE WAYNE MALONE, a major resident and domiciliary of Shreveport, Caddo Parish, Louisiana, who may be personally served with notice through his attorney of record herein, Ms. Katherine Clark Dorroh, 3000 Fairfield
Ave., Suite B, Shreveport, Louisiana.
2.
-
- ---
Plaintiff-in-reconvention shows that the defendant-in-reconvention, DANNYE WAYNE MALONE, filed a Petition for divorce on May 28, 2009. 3. This,Coun has jurisdiction over this proceeding pursuant to the provisions of Louisiana
Code of Civil Procedure,
Article 10(a)(7), in that this is a suit for divorce and matters incidental
thereto, and both of the spouses are domiciled in this State. 4. Venue for this action is proper in this Court pursuant to the provisions of Louisiana
Code of Civil Procedure,
Article 3941, as Caddo Parish is the parish where both of the parties
are domiciled and it is the parish of the last matrimonial domicile. 5, No children have been born issue of the marriage between the parties hereto nor have any children been adopted by the parties.
PGSpEXHJ NUN CC CP MArtP-14-N/J_____ IND X REC FAX W/D DOC CERT SERVICE /tor Ply, 44 Into-
sz;ei FILED
SEP 0 4 7009
roam_
nr .A16:::: -4' .
TL E00 06 00 ZO T60 O akibl UDS
INTERROGATORY NUMBER 29:
At–any–point–i • uring your marriage to MONTINA HARRIS MALONE did you
consume, ingest and/or smoke marijuana in the matrimonial domicile? If you admit this fact, please answer the following:
(A) Was MONTI:NA HARRIS MALONE or the minor child of MONTiliA HARRIS
MALONE present when you consumed, ingested and/or smoked marijuana? (B) Do you deny that MONTINA HARRIS MALONE expressed to you her complaint, dissatisfaction and objection to you and your colleagues consuming, ingesting and/or smoking marijuana in the matrimonial domicile where MONTINA HARRIS MALONE and her minor child resided with you? Do you deny that you broughtnLizaga into the matrimonial domicile to consume, ingest and/or smoke marijuana with you? Do you deny that you have consumed, ingested and/or smoked marijuana in the matrimonial domicile with Cedric Glover and Dale Sibley? Do you deny that third persons, including, but not limited to, Dale Sibley, came to the matrimonial domicile on numerous occasions for the purpose of taking possession of a package of marijuana? If you admit this fact, was the package of marijuana the subject of a sale or was the illegal contraband donated by you to the person or persons? —
(C)
(D D
(
INTERROGATORY NUMBER 30:
Please identify each and every person who is provided coverage in connection with the policy of medical insurance coverage that you have procured with/through Blue Cross Blue Shield.
INTERROGATORY NUMBER 31:
Do you deny or dispute that MONTINA IIARR1S MALONE traded in her separate property vehicle in connection with the purchase of your Toyota Highlander vehicle and that the trade-in value of her vehicle was $3,000.00? Do you dispute or deny that the Toyota Highlander vehicle is your separate property?
INTERROGATORY NUMBER 32:
Do you deny or dispute that you and other members of Monk.house Seafood Diner have sat at a table in the matrimonial domicile and divided up cash receipts of the business, which cash receipts were never accounted for from the standpoint of taxable income of the business enterprise?
'6 00 Z0T6 003.1\114 t13.5
O GO
