Case 2020FA000100 Document 15 Filed 09-09-2020 Page 1 of 3

FILED
09-09-2020
Clerk of Circuit Court
Pierce County, WI
STATE OF WISCONSIN CIRCUIT COURT PIERCE COUNTY
2020FA000100
BRANCH I
___________________________________________________________

JONATHAN A. PAUL,
Petitioner,

v. HON. JOSEPH D. BOLES

Case #: 20-FA-100
AMANDA J. PAUL, Classification Code: 40101
Respondent.
______________________________________________________________________
Loberg Law Office, LLP Waters Legal Services, LLC
Attorney for Petitioner Attorney for Respondent
By: Lars H. Loberg (1070880) By: Daryl R. Waters (1095037)
359 West Main Street PO Box 140
Ellsworth, WI 54011 Florence, WI 54121
(715) 273-5072 (715) 997-8170/FAX (715) 997-8171

______________________________________________________________________
RESPONDEN S ANSWER TO PETITION FOR DIVORCE
AND COUNTERCLAIM
______________________________________________________________________

NOW COMES, the Respondent, Amanda J. Paul, by and through Daryl R. Waters
of Waters Legal Services, LLC and offers the following Answer Pe e Pe f
Divorce states as follows:

A.
1. Admits.
2. Admits.
3. Admits.
B
1. Admits.
2. Denies allegations. The Respondent resides at 1231 Main Street #101,
Norway, Michigan 49870.
3. Admits.
C.
1. Admits.
2. Admits.
3. Admits.
4. Admits.
5. Admits.
6. Admits.
D.
1. Admits.
2. Admits.
 Case 2020FA000100 Document 15 Filed 09-09-2020 Page 2 of 3

3. Admits.

COUNTERCLAIM

NOW COMES, the Respondent, Amanda J. Paul, by and through Daryl R. Waters
of Waters Legal Services, LLC and hereby complins and alleges against the Petitioner,
Jonathan A. Paul and states as follows:

1. The Respondent realleges paragraphs A 1, 2 & 3; B 1, & 3; C 1, 2, 3, 4, 5 & 6 and

D 1, 2 & 3 her responses to the Pe i ione Pe i ion fo Di o ce.

2. The Pe i ione da e of bi h i A g 7, 1970 and he i 49 ea old.

3. The Petitioner has lived in the state of Wisconsin for more than six (6) months and
has lived in Pierce County for more than thirty (30) days.

4. The Re ponden da e of bi h i Ma ch 5, 1980 and he i 40 ea old.

5. The Re ponden e ide in Dickin on Co n , Michigan. The Re ponden

current address is 1231 Main Street #101, Norway, Michigan 49870.

6. The Respondent is not in the Armed Forces of the United States of America or its
Allies.

7. The parties were married on June 22, 2013.

8. The parties were married in Dickinson County, Michigan.

9. There has been a breakdown of the marriage relationship to the extent that the
objects of matrimony have been destroyed and the marriage is irretrievably broken.

10. This is the first time that either the Petitioner or Respondent have filed for divorce
or legal separation from each other in Wisconsin or any other state.

11. Thi i he Pe i ione econd ma iage. The Pe i ione a p e io l ma ied o

Lisa Paul. That marriage was terminated by divorce on August 8, 2010 in Pierce
County, Wisconsin.

12. Thi i he Re ponden econd ma iage. The Re ponden a p e io l

married to Eric Allison. That marriage was terminated by divorce in 2006 in
Dickinson County, Michigan.

13. There are no minor children (age seventeen (17) or younger) born or adopted by
the Petitioner and Respondent.

2
 Case 2020FA000100 Document 15 Filed 09-09-2020 Page 3 of 3

14. During this marriage there were no children born by Respondent.

15. The Respondent is not currently pregnant.

16. The parties purchased property during the marriage that needs to be divided.

17. The Respondent incurred medical debt due to domestic violence by the Petitioner
that needs to be allocated.

18. The Respondent is in need of maintenance from the Petitioner.

19. The Respondent is in need of attorney fees and costs from the Petitioner to pursue
this action.

The Respondent, Amanda J. Paul respectfully requests the Court enter the following
orders:
A. Divorce.
B. Division of assets of the parties.
C. Division of real property purchased during the marriage.
D. Division of debt of the parties.
E. Award of specific medical bills which occurred from domestic violence.
F. Respondent be awarded a reasonable amount of maintenance from the
Petitioner.
G. Respondent be awarded an appropriate amount of attorney fees and costs to
pursue and defend in this action.
H. Such other just and equitable relief.

Waters Legal Services, LLC

Attorney for Amanda J. Paul

Dated: September 9, 2020

Daryl R. Waters (1095037)
PO Box 140
Florence, WI 54121
(715) 997-8170/FAX (715) 997-8171