3 DAVIDSON COUNTY, TENNESSEE AT NASHVILLE "6 14100 Plainlifl, ,y w. Docket Nu. PENNY GENELLE NELSON FORREST, ROBERT DOWNS FORREST, JR. Defendam. COMPLAINT FOR DIVORCE 1, Plaintiffi Penny Genelle Nelson Forrest. (heromal'ICr called is married to Dcl'cndanl. Kobcrl Downs Forrest, .er (heremafler called "Husband"). The following is slalislical informanon pcnuining said panics rcquircd b} ?35+106: Wll'L': Full maian name of Wife: l'enm Genelle Nelson bv Race: Caucasian 7 c. Reade-we address: d. ofrcsidence at above address: Mora lh mon ev Dalcand placcofbinh: --Nashv11k TN r, I\umber ot'prenous marriages: None Member ofthe Armed Scrviccs oflhc United Slates" No by Employcd: -- HUSBAN i. Full name ol'llusband: Robert Downs Jr. Race: Caucasian Rcsidcnce address -- Length an above address. More lhan month m, Dalcandplaccofbinh' NM Numberofpreviousmarriagcs: )gnc 0. Member oflhc Armed Services ol'lhe Uniwd sums? 7N0 p. Employed. 712mm 77 mm: mm; usan q. Date and place of marriage of the parties: May 21, 1988: Mt. Juliet, Wilson County, TN r. Date ofseparation ofthe parties: February 1, 2013 5. Residence of the parties at the time of their separation: -- Minor children born of this marriage and their dates of birth: None u. Grounds for divorce relied on by Plaintiff: h-reconcilable Differences; Inappropriate Marital Conduct vi Description of any other litigation concerning the custody of these children in this or any other state in which either party has participated: Nm applicable w, Do you currently have an Order of Protection in force in the Circuit Court for Davidson County, Tennessee: No 2. Wife alleges there are such irreconcilable differences between the parties as would entitle her to an absolute divorce in the event the parties are able to reach a written Marital Dissolution Agreement. Wife anticipates the parties will sign a Marital Dissolution Agreement that provides for an equitable division of the parties' assets and apportions responsibility for payment of debts. 3, Wife alleges that the parties have no minor children and none are expected. 4. Wife would show that the parties have acquired certain assets and incurred responsibility for payment of certain debts during the maniage. They also each have separate property owned by them prior to the marriage or inherited by or gified to them during the maniage. Wife will hereinafier ask the Coun to award each person his or her separate property and make an equitable division of the parties' assets and apportion responsibility for payment of the parties' debts as it deems appropriate based on the facts and circumstances of the case. 5. Wife would Show that Husband has been guilty of such inappropriate marital conduct as to render further cohabitation unsafe and improper and as would entitle Wife to an absolute divorce. 2mm Isooxz Izsasro NASHVILLE 6. Wife would show that she has been a good Wife to Husband. She would show that although she is employed outside the home Husband is the primary wage earner and Wife?s income is not suf?cient to support herself. She will hereinafter ask the Court to award her alimony, both pendente lite and permanent, and in futuro, in solido, transitional, rehabilitative, and/or any other form of alimony or spousal support. PREMISES CONSIDERED, Wife prays: 1. That proper process issue and be served on Husband. 2. That Wife be awarded an absolute divorce from Husband on the ground of irreconcilable differences or inappropriate martial conduct, and restored to all the rights and privileges of an unmarried person. 3. That the Court ratify and con?rm any Marital Dissolution Agreement which may hereafter be executed by the parties and that the Agreement be incorporated into the Final Decree of Divorce. 4. That in the event the parties are unable to reach a written Marital Dissolution Agreement, the Court award each party his or her separate property and make such division of the parties? marital assets and apportion responsibility for paying the parties? marital debts as it deems equitable under the circumstances of the case as presented. 5. That Wife be awarded reasonable alimony to be paid to her by Husband, both pendente lite and permanent, and in futuro, in solido, transitional, rehabilitative, and/or any other form of alimony or spousal support. 6. That the Court issue the statutory injunction pursuant to T.C.A. 7. That Wife be awarded her attorney fees and expenses incurred in these proceedings. 3 21277N: 180083: 1269684: 1 STATE OF TENNESSEE COUNTY or @4505 1, Penny Genelle Nelson Forrest, after being first duly sworn according to law, do make oath and affirm that I am the Plaintiff in the foregoing Complaint for Absolute Divorce, that the facts and matters alleged therein are true and correct to the best of my knowledge, information, and belief, and that said allegations are not made out of levity or by collusion with Defendant, but in sincerity and truth and for the causes set forth herein. Penny GenKeltl}: Nelson Forrest Sworn to and subscribed before me, this the 9g dayof ,2018. 3 . ?94 "57% i 64? U3 7? Wm 3:144, E?ilook?s EfoExpires277N: 180083: 1269677: 1 8. That Wife be granted such further, other, different and general relief as to which she may be deemed entitled. 2l277N: 180083: 1269684: I Respectfully sub itted, Greg6ry D. mMpilt. No. 011684) Brenton H. Lankford (Sup. Ct. No. 030223) STITES HARBISON, PLLC 401 Commerce Street, Suite 800 Nashville, TN 37219-2376 Telephone: (615) 782-2200 Attorneys for Plaintiff/ Wife, Penny Genelle Nelson Forrest NOTICE OF STATUTORY INJUNCTION PURSUANT TO TCA You are hereby noti?ed that upon personal service, or waiver or acceptance ofservice by the respondent, both parties are bound to abide by the provisions of the law as set forth?ve?rbanm below. Violation of this statute may result 1n a ?nding of contempt of court. 231;? ?73 23 1.1: TCA 36-4-106(d) Upon the ?ling of a petition for divorce or legal separation d?ru upo personal service of the complaint and summons on the respondent or upon waiver and resp the following temporary injunctions shall be in effect against both parties until the final decree ?Ref ivorce or order of legal separation is entered, the petition is dismissed, the parties reach agreement or until the court modifies or dissolves the injunction, written notice of which shall be served with the complaint: An injunction restraining and enjoining both parties from transferring, assigning, borrowing against, concealing or in any way dissipating or disposing, without the consent of the other party or an order ofthe court, of any marital property. Nothing herein is intended to preclude either of the parties from seeking broader injunctive relief from the court. (B) Expenditures from current income to maintain the marital standard of living and the usual and ordinary costs of operating a business are not restricted by this injunction. Each party shall maintain records of all expenditures, copies of which shall be available to the other party upon request. (2) An injunction restraining and enjoining both parties from voluntarily canceling, modifying, terminating, assigning or allowing to lapse for nonpayment of premiums, any insurance policy, including but not limited to life, health, disability, homeowners, renters and automobile, where such insurance policy provides coverage to either of the parties or the children, or that names either of the parties or the children as bene?ciaries without the consent of the other party or an order of the court. ?Modifying? includes any change in bene?ciary status. (3) An injunction restraining both parties from harassing, threatening, assaulting or abusing the other and from making disparaging remarks about the other to or in the presence of any children of the parties or to either party's employer. (4) An injunction restraining and enjoining both parties from hiding, destroying or spoiling, in whole or in part, any evidence electronically stored or on computer hard drives or other memory storage devices. (5) An Injunction restraining both parties from relocating any children of the parties outside the state of Tennessee, or more than fifty (50) miles from the marital home, without the permission of the other party or an order of the court, except in the case of a removal based upon a well-founded fear of physical abuse against either the fleeing parent or the child. In such cases, upon request ofthe non-relocating parent, the court will conduct an expedited hearing, by phone conference if appropriate, to determine the reasonableness of the relocation and to make such other orders as appropriate. (6) The provisions of these injunctions shall be attached to the summons and the complaint and shall be served with the complaint. The injunctions shall become an order ofthe court upon ful?llment of the requirements of subsection of this action. However, nothing in this subsection shall preclude either party from applying to the court for further temporaly orders, an expanded temporary injunction or modi?cation or revocation of this temporary injunction. 2 1277N: 180083: 1269684: 1 PENNY GENELLE NELSON FORREST, Plaintiff, v. NO. 18D310 ROBERT DOWNS FORREST, JR., Defendant. ORDER For good cause shown, the Fourth Circuit Court recuses itself from the trial of this matter. ENTERED this 26th day of February, 2018. smut: . SMITH, JUDGE cc: Gregory D. Smith Brenton H. Lankford Attorneys for Plaintiff STITES HARBISON, PLLC 401 Commerce Street, Suite 800 Nashville, Tennessee 37219?2376 Robert Downs Forrest, Jr. Defendant 4349 Oakcrest Lane Hermitage, Tennessee 37076 Honorable David R. Kennedy Civil Transfer Judge ii i350 IN THE FOURTH CIRCUIT COURT FOR DAVIDSON 2018 FEB 26 AH 9= 35 EitiihKT-J Fl. FiCUriEii.