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4682777

COURT OF COMMON PLEAS

DIVISION OF DOMESTIC RELATIONS

HAMILTON COUNTY, OHIO

MELISSA HENDON DETERS

C ase N o.

DR1302234

Plaintiff Judge: Lew is

Magistrate:

-vs-

JOSEPH THEODORE DETERS DEFENDANT S ANSWER

AND COUNTERCLAIM

Defendant

C om es n ow the D efen dan t,

by

and through his undersigned counsel, and for his

. ~

drc: I

response to Plaintiffs Complaint, avers and states as follows: ~ ': .:.~~-;

a

I. \~ 1

,) .A-

I. Defendant adm its the allegations contained in Paragraphs 1 and 2]J.thc ~

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\ c.-

r

Complaint. '

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2. Defendant adm its the parties arc incompatible, but denies the remaining ~ ~

allegation of Paragraph N o.3 of the C om plaint.

COUNTERCLAIM

3. Defendant has been a resident of the State of Ohio for at least six (6) months

and a resident of H am ilton County for at least 90 days im mediately preceding the filing of

P la in tif fs Compla in t.

4. D efendant and Plaintiff w ere m arried on Septem ber 7, 1985, in Cincinnati,

O hio, and there have been four children born issue of this m arriage, nam ely: Joseph S.

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Deters. born January 25, 1989, Jonathan T. Deters, born July 7, 1990, Mary Elyse H.

Deters, born October

1993, an d Patrick J. Deters, born May 8, 2004. All of the

c hild re n, e xc ep t P atric k, a re emanc ip ate d.

5. D efendant states that the parties are incom patible, but if PIa in ti

ff

denies

this, then the Plaintiff is guilty of gross neglect of duty, and by reason thereof D efendant

is en titled to a d ivo rce.

WHEREFORE ,

Defendant prays for the judgment of the Court as follows:

A) T hat D efendant be granted

a

decree of divorce from Plaintiff on his

Counterclaim;

B That the Court order an equitable division of the m arital property and

aw ard each party's separate property to the appropriate party;

(C) That the Court aiiocate parenting on the basis of shared parenting.

D

T hat the C ourt aw ard him reasonable legal fees and expenses incurred

h ere in ; a nd

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

be entitled at law or i n equi ty .

~,1-~

G regory L. A dam s (0025975)

A tto rn ey fo r Defe nd an t

Croswell

A dam s Co., L.P.A .

12 08 S ycamore S treet

Cincinnati, O hio 45210

Sf3) 241-5670

513) 929 3473 facsimile

gdams@crosweIJadams.com

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CERTIFICATE OF SERVICE

1 h ereby certify th at

a

copy of the foregoing w as

sent

to all counsel of record this

da y

o f December,

2013, by

depositing it into th e R eg ular

U.S.

Mail,

post age p repa id .

~~

Gregory

L.

Adams

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