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SECOND AMENDED
PETITION FOR DIVORCE
(MINOR CHILDREN)
CIRCUIT COURT
FAMILY COURT BRANCH
STATE OF WISCONSIN
MILWAUKEE COUNTY
Case No.: 19-FA-000046
Case Code: 40101
In re the marriage of:
LAURA PARGE
2773 N. 87TH ST.
MILWAUKEE, WI 53222,
Petitioner -and-
CHRISTOPHER PARGE
2316 CAMDEN VIEW DRIVE # 304
BRANDON, FL 33510 (LAST KNOWN),
Respondent
1. The petitioner, Laura Parge, born December 5, 1973, currently resides at 2773 N. 87th Street, in the City of Milwaukee, County of Milwaukee, Wisconsin 53222; and is currently unemployed.
2. The respondent, Christopher Parge, born September 5, 1972. Respondent's last known address is 2316 Camden View Drive, #304, in the City of Brandon, County of Hillsborough, Florida and is unemployed.
3. The parties were married on June 7, 2002 at Milwaukee, Wisconsin.
4. Petitioner has been a bona fide resident of Milwaukee County for more than 30 days immediately preceding the commencement of this action and of the State of Wisconsin for more than six months immediately preceding the commencement of this action.
5. a. The name and birthdate of the minor child of the parties are as follows:
Name Birthdate
Andrew Parge 03/04/03
b. No other children have been born to the wife during this marriage.
6. Upon information and belief the wife is not pregnant.
7. The marriage is irretrievably broken.
8. No other action for divorce, annulment, or legal separation by either of the parties has been at any time commenced or is now pending in any other court or before any judge thereof in this state or elsewhere.
9. Neither party was previously married.
10. The parties have not entered into any written agreements as to support, legal custody, physical placement, visitation of the children, maintenance or property division.
11. Pursuant to Wis. Stat. § 840.10, this action does not affect real property.
12. The following custody information is given in compliance with Wis. Stat. §822.29.
(a) The minor child named above presently resides in Bradenton, Florida, with his legal guardian pursuant to a Milwaukee County guardianship action, case number unknown.
(b) Within the last five years, the minor child has lived at in Bradenton, Florida, with his legal guardian pursuant to a Milwaukee County guardianship action, case number unknown.
(c) Both parties have previously participated as a party, witness, or in any other capacity in other litigation concerning the custody of the above-named minor child in this or any other state pursuant to guardian pursuant to Milwaukee County guardianship action, case number unknown.
(d) With the exception of the Milwaukee County guardianship matter, the Petitioner is unaware of any other custody proceedings concerning the above-named minor child pending in a court of this or any other state.
(e) With the exception of Milwaukee County guardianship matter, the Petitioner knows of no person not a party to this action who has physical custody of the minor child or claims to have legal custody, physical placement, or visitation rights with respect to the minor child.
(f) The Petitioner understands that as a party to this action, she has a continuing duty to inform this Court of any custody proceedings brought concerning the child in this or any other state of which the Petitioner obtains information during this proceeding.
THE PETITIONER REQUESTS THE FOLLOWING RELIEF:
A. Judgment of Divorce
B. Orders regarding custody and placement pursuant to a Milwaukee County Guardianship, case number unknown.
C. Property and Debt division
D. Attorney fees and costs
E. Restoration of legal surname
F. Such other relief as is appropriate
YOU ARE HEREBY NOTIFIED that pursuant to Wis. Stat. § 767.117, during the pendency of this action both parties are prohibited from and may be held in contempt of court for:
1. harassing, intimidating, physically abusing, or imposing any restraint on the personal liberty of the other party or a minor child of either of the parties;
2. encumbering, concealing, damaging, destroying, transferring, or otherwise disposing of property owned by either or both of the parties, without the consent of the other party or an order of the court, except in the usual course of business, in order to secure necessities, or in order to pay reasonable costs and expenses of the action, including attorney fees;
3. establishing a residence with a minor child of the parties outside the state of Wisconsin or more than 150 miles from the residence of the other party within the state without the consent of the other party or an order of the court or circuit court commissioner;
4. removing a minor child of the parties from the state of Wisconsin for more than 90 consecutive days without the consent of the other party or an order of the court or circuit court commissioner; or
5. concealing a minor child of the parties from the other party without the consent of the other party or an order of the court or circuit court commissioner; except that a violation of paragraphs 3., 4., or 5. above is not a contempt of court if the court finds that the action was taken to protect a party or a minor child of the parties from physical abuse by the other party and that there was no reasonable opportunity under the circumstances for the party to obtain an order authorizing the action.
These restraining orders apply until the action is dismissed, a final judgment in the action is entered, or the court orders otherwise.
A VIOLATION OF THE ABOVE RESTRAINING ORDERS MAY RESULT IN PUNISHMENT FOR CONTEMPT, WHICH MAY INCLUDE MONETARY PENALTIES, IMPRISONMENT, AND OTHER SANCTIONS AS PROVIDED FOR IN WIS. STAT. § 785.04.
Dated this 26 day of February, 2019.
LAURA PARGE
PROBST LAW OFFICES, S.C.
Attorney for Petitioner
By: LINDSEY M. WHITE
State Bar No. 1088716
Subscribed and sworn to before me
this 26 day of February, 2019
LINDSEY M. WHITE
NOTARY PUBLIC
STATE OF WISCONSIN
Notary Public, State of Wisconsin
My commission expires permanent.
Probst Law Offices, S.C.
1011 N. Mayfair Rd.,
Ste. 203
Wauwatosa, Wisconsin 53226
Telephone: (414) 210-3135
Fax: (414) 210-3218
March 8, 15, 22, 2019 19-01199H