IN THE CIRCUIT COURT OF THE COUNTY OF ST. LOUIS
STATE OF MISSOURI
In re the Marriage of:Sharon Gayle Jeep, () Petitioner, and David Gerard Jeep, () Respondent )))))))))))) Case No.: No.
Respondent's Motion for Temporary Joint Custody While a Suit is Pending And Affidavit in Support Thereof And a Motion to recover Personal Item
COMES NOW Respondent, David G. Jeep, and moves this Court to make and enter its Order While a Suit is Pending awarding unto Petitioner and Respondent temporary joint physical and legal custody of the minor child born of the marriage pending the litigation, and for an Order directing Petitioner to return to Respondent a certain personal item, and in support of his motion
Respondent states as follows:
1. A petition for Dissolution of Marriage has hereto been filed in the above entitled cause.
2. One child was born of the marriage, namely: Patrick Brandon Jeep Born December 22, 1994, SSN XXX-XX-XXX
3. That for the minor child’s entire life he has seen his father virtually every day. To now as has been the practice in the recent past to only allow the FATHER very limited access is unlawful in that the respondent is his father. The Respondent, the FATHER was not given visitation on Thanksgiving of this year, nor the child’s birthday 12/22/2003 nor Christmas of 2003.
4. Furthermore for the twenty months directly prior to November 3, 2003 the Respondent was his primary care giver dressing him in the morning, feeding him breakfast, watching him at home during school vacations, feeding him his meals, putting him on the bus during school, being there for him when he got off the bus in the afternoon.
5. Both the Petitioner and the Respondent are currently residing within the limits of the minor child’s school district. Furthermore his current day care, Kindercare at Lake Chesterfield could be an easy exchange point.
6. Respondent is willing to split the cost of said day care with the Petitioner.
7. Respondent proposes a revolving 3 day, 4 day rotation of custody.
8. That pending the litigation, the best interests of the minor child would be served by his joint physical and legal custody being awarded unto Petitioner and Respondent.
9. That Respondent has moved from the marital residence, pursuant to this Court’s Order of Protection entered November 20, 2003 in Cause Number O3FC-10670, and requires the return of his personal computer, which is in the custody of Petitioner and which, Respondent believes, Petitioner has removed from the marital home.
10. Said personal computer has information contained in its hard drive which is immediately essential for Respondent to recover, for his defense in the misdemeanor case of State of Missouri vs. David Jeep, currently pending in the Circuit Court of Camden County. Time is of the essence here in that the court date is currently scheduled for February 2, 2004.
11. That Petitioner currently resides in the marital home.
WHEREFORE, Respondent prays that this Court make and enter its order pending the litigation awarding unto Petitioner and Respondent temporary joint physical and legal custody of the parties’ minor child; ordering Petitioner to return to Respondent the personal computer used by Respondent prior to November 3, 2003; and, for such other and further orders as to this Court seem meet and proper in the premises.
David G. Jeep, Respondent
Dated this 29th day of January, 2004