Anagnostou v. Anagnostou
Case No. 2017-017244 FC 12
Husband’s Answer to Wife’s Amended Verified Counter- Petition for Dissolution of Marriage
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
IN RE: THE MARRIAGE OF: FAMILY DIVISION CASE NO. 2017-017244 FC 12
GEORGE ANAGNOSTOU,
Husband,
And,
KATE LEANN ANAGNOSTOU,
Wife.
_____________________________/
HUSBAND’S ANSWER TO WIFE’S AMENDED VERIFIED PETITION FOR DISSOLUTION OF MARRIAGE, RELOCATION AND OTHER RELIEF
COMES NOW the Husband, GEORGE ANAGNOSTOU, by and through his undersigned counsel and hereby files this Answer to Wife’s Amended Verified Counter-Petition for Dissolution of Marriage, Relocation and Other Relief …show more content…
The Husband admits the allegations contained in paragraph 6(a) of the Wife’s Amended Counter-Petition insofar as the parties should be awarded shared parental responsibility; that the parties should endeavor to agree upon a parenting plan and that, if the parties cannot agree, that the Court should determine issues regarding the children; however, the Husband denies all remaining allegations contained in this paragraph. The Husband affirmatively avers that no special circumstances exist that would substantiate an award of ultimate decision-making authority to the Wife. It is public policy in state of Florida for parents to share the rights, responsibilities and obligations of child-rearing; however, in the case sub judice, the Wife seems to believe that she is the sole parent of the children and should be entitled to make all decisions with regard to the children as evidenced by her failed attempt to unilaterally relocate the children to Texas without even obtaining proper consent of the Husband or this Court. It is important to note that the Wife also believes that she should determine when and how the Husband should exercise time-sharing with the children. For instance, the Wife has kept the children from the Husband on two different occasions for approximately one month each time. Most recently, the Husband has filed an Urgent Motion for Pick-Up Order of Children and Motion for Contempt Against Wife for Her Interference with Husband’s Time-Sharing and Her Failure to Comply with the Agreed Order Establishing Temporary Parenting Plan and Time-Sharing on October 12, 2017 as the Wife has kept the children in Texas and away from the Husband for one
Case No. 2017-017244 FC 12
Husband’s Answer to Wife’s Amended Verified Counter- Petition for Dissolution of Marriage
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
IN RE: THE MARRIAGE OF: FAMILY DIVISION CASE NO. 2017-017244 FC 12
GEORGE ANAGNOSTOU,
Husband,
And,
KATE LEANN ANAGNOSTOU,
Wife.
_____________________________/
HUSBAND’S ANSWER TO WIFE’S AMENDED VERIFIED PETITION FOR DISSOLUTION OF MARRIAGE, RELOCATION AND OTHER RELIEF
COMES NOW the Husband, GEORGE ANAGNOSTOU, by and through his undersigned counsel and hereby files this Answer to Wife’s Amended Verified Counter-Petition for Dissolution of Marriage, Relocation and Other Relief …show more content…
The Husband admits the allegations contained in paragraph 6(a) of the Wife’s Amended Counter-Petition insofar as the parties should be awarded shared parental responsibility; that the parties should endeavor to agree upon a parenting plan and that, if the parties cannot agree, that the Court should determine issues regarding the children; however, the Husband denies all remaining allegations contained in this paragraph. The Husband affirmatively avers that no special circumstances exist that would substantiate an award of ultimate decision-making authority to the Wife. It is public policy in state of Florida for parents to share the rights, responsibilities and obligations of child-rearing; however, in the case sub judice, the Wife seems to believe that she is the sole parent of the children and should be entitled to make all decisions with regard to the children as evidenced by her failed attempt to unilaterally relocate the children to Texas without even obtaining proper consent of the Husband or this Court. It is important to note that the Wife also believes that she should determine when and how the Husband should exercise time-sharing with the children. For instance, the Wife has kept the children from the Husband on two different occasions for approximately one month each time. Most recently, the Husband has filed an Urgent Motion for Pick-Up Order of Children and Motion for Contempt Against Wife for Her Interference with Husband’s Time-Sharing and Her Failure to Comply with the Agreed Order Establishing Temporary Parenting Plan and Time-Sharing on October 12, 2017 as the Wife has kept the children in Texas and away from the Husband for one