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Lamberson - Draft Motion For Rule To Show Cause Why Divorce Should Not Be Granted
Lamberson - Draft Motion For Rule To Show Cause Why Divorce Should Not Be Granted
PARISH OF TANGIPAHOA
STATE OF LOUISIANA
JAMIE LAMBERSON
VERSUS
NOW INTO COURT, through undersigned counsel, comes Mover, JAMIE LAMBERSON, a
competent person, domiciled in the Parish of Tangipahoa, State of Louisiana, who respectfully
represents as follows:
I.
A Petition for Divorce was filed in the above captioned matter on March 16,
2022, in the 21st Judicial District Court for the Parish of Tangipahoa. Defendant in rule,
FREDERICK ESTES, JR. was served through a curator. The Defendant was served through a
II.
To date, Defendant in Rule, FREDERICK ESTES, JR., did not file an Answer
III.
This rule was filed on (Date we will file it), and thus more than one hundred
eighty (180) days have elapsed between the date service of process was made on the Defendant
IV.
Mover, JAIME LAMBERSON, and Defendant in Rule, FREDERICK ESTES, JR. have
lived separate and apart continuously and without reconciliation for more than one hundred and
eighty (180) days prior to the filing of this rule, being separated since June 1, 2012, and continue
to live separate and apart. There has been no reconciliation between the parties.
V.
Mover desires a divorce from Defendant in Rule, FREDERICK ESTES, JR.,
under the provisions of La. C.C. Art. 102, and therefore requests that a rule to show cause issue
in the above captioned matter directed to FREDERICK ESTES, JR. to show cause on a date and
time fixed by this Court why a judgment of divorce should not be granted.
A Rule to Show Cause issue in the above captioned matter, ordering Defendant-in-Rule,
FREDERICK ESTES, JR. to appear and show cause, on the date and at the time fixed by this
Honorable Court, why a judgment of divorce should not be granted; that Defendant in rule be
given notice as required by La. R.S. 13:3492; and Mover further prays that after hearing, a
Respectfully submitted,
______________________________
RUSSELL S. STEGEMAN #8224
506 Water Street
Madisonville, LA 70447
Phone: (985) 800-2001
Email: russell@theshark.us
Counsel for Mover, Jaime Lamberson
21st JUDICIAL DISTRICT COURT
PARISH OF TANGIPAHOA
STATE OF LOUISIANA
JAMIE LAMBERSON
VERSUS
______________________
ORDER
IT IS HEREBY ORDERED that a Rule to Show Cause be issued in the above captioned
matter directed to FREDERICK ESTES, JR. to show cause, on the ______ day of
____________, 2022 at _______________ o’clock ___.m., why Judgment of Divorce should not
be granted.
__________________________________
DISTRICT JUDGE
PLEASE SERVE:
Court Appointed Curator
Indigo Diekmann
106 South Magnolia Street
Hammond, Louisiana