SUPERIOR COURT OF THE DISTRICT OF COLUMBIA DOMESTIC RELATIONS BRANCH FAMILY COURT BETH MYNETT Plaintiff, v. TIMOTHY MYNETT Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.9l>fff Dlll.3 .. 3033 �'. S-5 COMPLAINT FOR LEGAL SEPARATION, CUSTODY, CHILD SUPPORT, EQUITABLE DISTRIBUTION OF PROPERTY, AND OTHER RELATED RELIEF Plaintiff, Beth Mynett (hereinafter "Plaintiff'), by and through her attorneys, Jonathan M. Dana, Jennifer A. Davison, and Feldesman Tucker Leifer Fidell LLP, states as follows in support of her Complaint for Legal Separation, Custody, Child Support, Equitable Distribution of Property, and Other Related Relief (hereinafter "Complaint"): 1. Plaintiff is an adult citizen of the United States who presently is and, ___ij2_ LlF FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Sulte400 Washington, DC 20036 202.466.8960 for more than six months next preceding the filing of this Complaint, has been a bona fide resident of the District of Columbia, having resided at the above-captioned address since 2006. 2. Defendant is an adult citizen of the United States and is a bona fide resident of the District of Columbia. FELDES MAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Suite 400 Washington, DC 20036 202.466.8960 3. The Parties have been living together as a family since January 2006 and were married on June 21, 2012 in the District of Columbia. 4. The Parties have a thirteen year old son,? born February 8, 2006. He is in the primary custody-of hismother, who is a ?t and proper person to have custody. I I 5. The parties physically Separated on or about April 7, 2019 when 7 Defendant told Plaintiff that he was romantically involved with and in love with another woman, Ilhan Omar, who serves asia US. .Representative from Minnesota (hereafter Rep. Omar). Defendant met Rep. Omar while working for her. Although devastated by the betrayal and deceit that preceded his abrupt declaration, Plaintiff toldDefendant that she loved him and was willing to ?ght for the marriage. Defendant-?however, told her that was not an option forlhim. He. provided no other explanation for his sudden change of heart nor had he discussed being unhappy with their marriage. Defendant then physically moved from the marital home on April 8, 2019. 6. It is clear to Plaintiff that her marriage to- Defendant is over and that there is no hope of reconciliation. Accordingly, the separation is now mutual and voluntary. 7. As required by D..C Code (2006 Repl.), Plaintiff states the following: i I (1) Plaintiff has not participated, as a party or witness or in any other capacity, in any other proceeding concerning the custody of or visitation with the minor child. FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Sulte 400 Washington, DC 20036 202.466.8960 (2) Plaintiff knows of no other proceeding that could affect the current proceeding, including proceedings for enforcement and proceedings relating to domestic violence, protective orders, termination of parental rights, or adoptions. (3) Plaintiff knows of no other-person not a party to this proceeding who has physical custody of the children or claims rights of legal custody or physical custody, or visitation with the minor child. (4) - Plaintiff and the minor child continue to reside in the marital residence located at ?Washington, DC. 20011. Since the Parties? separation, the minor child had?spent some time with Defendant at?Washin'gton, DC 20011.1 8. Plaintiff is and has always been the primary caregiver to the parties? son and is intimately involved in every aspect of their son?s life. As between the parties, Plaintiff is the parent who has historically been responsible for the child?s day-to-day care and for payment of and handling the vast majority of responsibilities related to his school, medical care, and extracurricular activities. 9. In contrast, Defendant?s involvement with the minor child has been sporadic due to his extensive travel and long work hours (on re?ection, Defendant?s more recent travel and long work hours now appear to be more - related to his affair with: Rep. Omar than with his actual work commitments, averaging 12 days per month away from home over the past year). More recently, even when Defendant was not traveling: and was home with the family, he was preoccupied and emotionally volatile. rt 7. a? 10. Plaintiff has signi?cant reservations about Defendant?s judgment and ability to care for their son on a consistent basis. By way of example, days FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Sulte 400 Washington, Dc 20036 202.465.8960 prior to Defendant?s devastating and shocking declaration of love for Rep. Omar and his admission of their affair, he and?Rep. Omar took the parties? son to dinner to formally meet for the first time at the family?s favorite neighborhood restaurant while Plaintiff was out of town. Rep. Omar gave the parties? son a gift and the Defendant later brought-her back inside the family?s home. The following evening, againw'hile Plaintiff was away, Defendant told-he was going to an event with Rep. Omar and, upon information and belief, never came home that night. 11. Defendant?s lack of judgment is troubling on many levels. Most . concerning is that Defendant put his son in'harm?s way by taking him out in public with Rep. Omar who at that time had garnered a plethora of media attention along with death threats, one rising to the level of arresting the knoWn would be assassin that same week. i I 12. Defendant has a history of emotional volatility, that can cause him to become easily angered and rageful, making it difficult to live with him at times. In contrast, Defendant has described Plaintiff as ?stable and trustworthy.? I 13. It is in the minor-child?s best intereSt to-remain in his mother?s primary custody and care. Plaintiff has a very close and loving relationship with her, son, and she is a, fit and proper personito have primary custody of - Defendant should have reasonable access to the parties? son, taking into consideration- safety and best interests. FELDESMAN TUCKER LEIF ER FIDELL LLP 1129 20th Street, NW Sulte 400 DC 20036 202.466.8960 14. Plaintiff is 55 years old and is employed as the Medical Director and Health Services Administrator of the DC. Department of Corrections. Defendant is 38 years. old and is a political strategist and Partner at Street Group Consulting, a successful political consulting firm herecently founded. Upon information and belief, Defendant?s current income is comparable to Plaintiffs income,_ with a. strong potential for much higher earnings in the very near future (2020).. Defendant is well able'to contribute to the support of . his minor son. I I 1 I 15. Plaintiff has been a devoted and loving partner and wife to Defendant throughout the parties? fourteen-year relationship. She has been unwavering in her support of Defendant?s career and. his-recent efforts to launch his business; Street Group Consulting; Defendant recently acknowledged to others that Plaintiff has ?i?igiven me everything I needed to succeed.? Defendant is choosing toend the marriage at a time when he is poised to enter his highest earning. years, and to abandon, his wife, who is much closer to the end-of her professional career and is left to face a ?nancially insecure future as a result of Defendant?s unilateral decision. 16. The Parties acquired their family home together in 2006, prior to their marriage. Plaintiff used her funds-for theolosing costs to purchase the home; It was also her income which paid the majority of the mortgage and. maintenance and- renovationicosts, the latter of which Defendant has refused to fully contribute to, despite his promises to the contrary. Defendant?s FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Suite 400 DC 20036 202.466.8960 actions have created ?nancial uncertainty for Plaintiff and she should be awarded the home, and all of the'equity therein. 17. During the marriage the Parties. acquired various tangible and intangible property, including bank and cash accounts, retirement assets, automobiles, furniture,furnishings, which are all marital assets subject to equitable division by. thismcourt. Plaintiff Was the primary breadwinner for theifamily during the majority of the Parties.? years together. Plaintiff made very substantial monetary contributions to the acquisition, preservation, and appreciation in value of-the Parties? estate.? 18. Defendant was able to develop a successful career and high earning potential during the-parties? long-term relationship. From the very beginning of their relationship until just before he left the marital home, Defendant took advantage of Plaintiffs network. 0f professional and personal contacts to help launch and grow his career. as apoliticalconsultant. His ability to pursue his. prOfessional ambitions was only possible because of Plaintiffs unconditional willingness to assume the lion?s share of ?nancial and day to day responsibilities for the parties? son and. the family household (in addition to her role as the primary earner for the family). 19. Plaintiff worked arduously before ?ling this Complaint to try to achieve an amicable settlement with her husband. Defendant refused, and instead threatened to malign. her and ruin her career if she sought assistance of the Court. Inthe face of the Plaintiffs difficult decision to seek assistance FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th street, NW Suite 400 Washington, DC 20036 202.466.8960 from the Court, Defendant has also begun'threatening not to pay for his sharel'of their joint financial responSibilities, conveniently asserting after their separation that he is nearly broke, and his business is ?oundering. Defendant?s bullying tactics are disappointing, but not surprising. 20. In deciding the equities of this case, the-court should take into considerationPlaintiff?s very significant non-monetary contributions to Defendant?s career success and the-well-being of the family unit. 7 WHEREFORE Plaintiff respectfully requests that this Court: 1. Grant Plaintiff a legal separation from Defendant on the ground of a mutual and voluntary separation without cohabitation; 2. Award the Parties joint legal custody of the minor child; 3. Award Plaintiff primary physical Custody of the minor child, with liberal access to Defendant; 4.. Establishan access schedule in the best interest and safety of the minor child; 5. A Order Defendant to contribute towards the support of the minor child in accordance with the best intereSts Of the child and prior family 1 experience and commensurate with the proportion of time that -is in each parent?s care; 6. Award Plaintiff her sole and separate property; - Award Plaintiff the marital home (and take into consideration that Defendant owes Plaintiff money for agreed-to renovation costs); FELDESMAN TUCKER LEIFER FIDELL LLP 1129 20th Street, NW Sulte 400 Washington, DC 20036 202.466.8960 8. Identify-value, and equitably distribute the parties? marital property after full consideratiOn of all relevant statutoryfactors, giving particular Weight to Plaintiff s?substantial contributions to the acquisition and appreciation in value of such property; 9. Award Plaintiff her reasonable attorneys? fees and costs incurred in connection with-this action; 10. Grant such other and furtherrelief as the nature of this case requires. Respectfully submitted, ?z?than M. Dana, #384622 nifer A. Davison, #984154 eldesman Tucker Leifer idell, LLP 1129 20th Street, .N.W., Suite 400 Washington, DC. 2003.6 Phone: (202) 466-8960 Facsimile: (202) 293-8103 Attorneys for Plaintiff I 1;;3 INFORMATION AND BELIEF 1 - ITUCKER FIDELL LLP 1129 20th Street, NW Suite 400 Washington, 20036.: .202.- 466. 8960. .. . . I DO SOLEMNLY SWEAR AND AFFIRM UNDER PENALTY OF 571': PERJURY THAT THE CONTENTS OE THE FOREGOING COMPLAINT LEGAL SEPARATION, CUSTWODY SUPPORT, DISTRIBUTION OF AND OTHER RELATED RELIEF ARE a TRUE AND GORREOT TO THE REST OE MY KNOWLEDGE