Petitioner Case Study

AMENDED COUNTER PETITION
FOR DISSOLUTION OF MARRIAGE AND RELATED RELIEF

COMES NOW Petitioner/Wife, Yan Fen NG (hereinafter “Petitioner” or "Wife"), by and through undersigned counsel, and files this Answer to Respondent/Husband 's "Amended Counter Petition For Dissolution of Marriage and Related Relief" (“Amended Count Petition”) and, in support thereof, Petitioner asserts as follows: 1. Respondent admits the allegations set forth in Paragraph 1-8 of the Petition. 2. Respondent denies the allegations set forth in Paragraph 9 of the Petition. Petitioner seeks for bridge and permanent alimony.
3. Petitioner admits to the part of "The parties have acquired marital assets." and denies the rest allegation for want knowledge set forth in Paragraph 10 of the Petition. Petitioner strongly disagrees with Respondent’s claim to the marital residence. To this end, it is undisputed that marital funds were used to pay down the mortgage, and thus any appreciation in value is a marital asset subject to equitable distribution. Kaaa v. Kaaa, 58 So.3d 867 (Fla. 2010), Alternatively, even if there was no appreciation in value, when marital funds are used during the marriage to reduce the mortgage on non-marital property, the increase in

Petitioner denies the allegations for want knowledge set forth in Paragraph 11 of the Petition. Petitioner had no bank account until 2015. During the course of the parties’ 28-year marriage, Petitioner saved $85,000.00 in cash which she placed under her bed to keep it from being stolen. The marital home is a natural place for Respondent to keep her belongings. Contrary to Respondent’s assertions, the existence of this money was never “concealed” because the parties’ children were fully aware of the money. In addition, on the other hand, Respondent 's bank accounts contain several hundred thousands of dollars, which are marital assets and are subject to equitable distribution; while Petitioner never touched those