HomeMy WebLinkAboutCC 4 CLAIM #85-44 11-04-85OATE: lO/l'7/85 Inter-Corn
TO:
FROM:
SUBJECT:
HONORABLE ~3%YOR AND CITY COUNCIL//
JAMES G. ROURKE, CITY ATTORNEY
CLAIMANT: SCHROEDER, ERNEST WILLIAM; D/L: 3/15/84;
DATE FILED W/CITY: 10/3/85; CLAIM NO: 85-44; CARL
WARREN FILE NO: Unknown
After investigation and review it is recommended that the above-
referenced claim be rejected and the City Clerk directed to give
proper notice of the rejection to the claimant and to the
claimant's attorney.
JGR(F4.se)
Enclosure:
Copy of Claim
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CLAIM FOR INDEMNITY AND CONTRIBUTION
ERNEST WILLIAM SCNROEDER hereby makes claim against the City
of Tustin, by way of indemnity and contribution:
1. Claimant's address is
2. Notices concerning the claim should be sent to Dimino &
Card, Attorneys at Law, for Claimant, 1633 East Fourth Street,
Suite 120, Santa Ana, California, at the attention Magdalena
Lona-Wiant.
3. The date and place of the occurrence giving rise to this
Claim was March 15, 1984, at the intersection of McFadden Avenue
and Myrtle, in the City of Tustin, California.
4. The circumstances giving rise to the claim are such that
the above-described intersection represents a dangerous condition
of public property, thereby causing an automobile v. pedestrian
accident.
5. On or about March 15, 1984, at or near the intersection
of McFadden Avenue and Myrtle, in the City of Tustin, California,
the City of Tustin, its agents, employees and contractors, and
each of them, so recklessly, carelessly and negligentlY omitted
and failed to provide adefluate warning signals, personnel,
officers, markings, or other devices and safeguards, which it
knew, or should have known, created an unreasonable risk of harm
to the public and a dangerous condition, and said condition
proximately caused the automobile versus pedestrian accident
described above. The facts of the occurrence, and the dangerous
condition of the aforesaid intersection are further set forth in
Police Report ~84-02387, attached hereto as Exhibit "A".
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6. As a result of the aforementioned accident, an action
entitled Kristie Fillippini, a minor by Kathleen Fillippini her
Guardian Ad Litem; Kathleen Fillippini; Robert Charles Fillippini,
v. Ernest William Schroeder; the City of Tustin, a municipal
corporation; et al., Case No. 43-73-37, was filed on August 27,
1984, in the Orange County Superior Court.
7. Ernest William Schroeder was served with a copy of the
Summons and Complaint by mail, on July 17, 1985.- Ah Acknowledge-
ment of Receipt was signed on August l&, 198&. A copy of the
Summons and Complaint and Acknowledgement of Receipt are attached
hereto as Exhibits "B", "C" and "D", respectively.
8. Claimant's injuries are undetermined in tha~ this claim
is based on indemnity.
/
DIMINO & CARD
Ma~d~i cna ~na-Wi'a~ r
-2-
· . 'TUSTIN i'~LICE DE'r~J'-~T~ENT
TRAFFIC COLLISION REPORT ,,- / o, ~/
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5/731
?-T.._ t,",-'"-. : A A A,
TUSTIN P,..,LICE DEPA.~:TMENT
TRAFFIC COLLISION REPORT .... "~ ....
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o_ ', I I 3022
,~U P PL E:~ LNT.I,L
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~EETC~ · N^,ERATIYE CONTINUATION I'~ I
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S U M M O N S
fc/7'4czo/v
NOTICE TO DEFENDANT: (Aviso a Acusado)
ER:!. ST WILLI~M $CHROEDER;
the City of TUST!N,
a municipal corporation;
and DOES 1%hrcugh 100, inclusive,
YOU ARE BEING SUED BY PLAINTIFF:
(AUd. le est~ dern.~ndnndo)
;CRISTZE FILL!PPINi, a Minor,
bv i~ATHLEEN FILLIPPINI her Guardian
(kTHLEEN F!LLIPP!NI: ROBERT CHARLES
ad '~'= ;
FiLLi?P INI,
You have 30 CALF, NDAR DAYS after this sum-
mons is served on you to file a tyDewrirten re-
sponse at this court.
A Jerter or phone call wHI not Orotect you: your
typewritten response must be in proper legal
form if you wan~ the 'court tO hear your case.
If you do not file your response on time, you may
lose the case. and your wages, money and pro-
party may be taken without further warning from
~he court.
There are other legal requirements. You may
want to call an attorney right away. If you do not
know an attorney, you may call an attorney refer-
ral service or a legal aid office (listed in the phone
book).
Despu~s de qua le entre~,uen esta citaddn judicial usted
tiene un plazo de 30 DIAS CALENDARIOS para presentar
una respuesta escr~ta a m,~quina en esta cone.
Una c,~na o un~ ]lamada tetef6nica no le ofrece~
ptotecd6n; su respuesta escrita a mdquina fiene que
cumplir con las formaiidades legales apropladas si usted
quiere quo la cone escuche su caso.
Si usted no presenta su resouesta a tiempo, puede petder
el caso, y le pu~en qultar su salar(o, su dinero y o~ cosas
de su propiedad sin aviso adicional pot pane de la cone.
Existen otro~ requisitos legales. Puede quo usted quie~
llamar a un abogado inmediatamente. 5i no conoco a un
abo~do, puede llamat a un serwdo de referencia de
abo~odos o a una ofidna de ayuda le~l (yea el dire~orio'
leJe~6nico).
The name and adCress of ~e court is: (£1 hombre y direcctdn de ia torte
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE
?00 Civic Center Orive West
RD. Box 838
San[a Ana. CA E2702-0838
I~] hombre. I,] direccion y el nomero de fei~tOno del abo~ado
RONALD W. CHP,!SLIP (714) 547-0!97
A=tcrney at Law
1505 N. Broadway
Santa Aha, CA 92706
' , ~.,-,.I ~U~ Clerk. by
DATE: AUG 2
NOTICE TO THE PERSON SERVED: You are served
1. ; ,1 as an individual defendant
2. ', :, as me ~erson sued unaer the fic:i:rous name of l.~Oecl'/y):
3. ' i on behalf of
uneer: : CC.: ,.;1~.i0 I:orcorauom
I' t C~? 415.20 ~cefunc: corPoratiOn
I._~i CT? 415.70 Ic:nservates~
i ' CC.= J, 18.90 :lnalvlCual)
SUMMONS
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RONALD W. CHRISLIP
A~o~ney at Law
1505 N. Broadway
Santa Aha, CA 92706
(714) 547-0197
Attorney for P!ain~i£f
FILED
AUG 2 7 1~$4
LEE A. BRANCH. Coun,,'y Clerk
By
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF ORANGE
K~ZSTIE FILLIPPINI, a
Minor, by KATHLEEN
FILLIPPINI her Guardian ad
Litam; KATHLEEN F!LLIPPINI;
ROBERT CHARLES FILLIPPiNI,
vs.
Plaintiffs,
~.RNEST WILLIAm4 SCHROEDER;
the Ci:y of TUSTIN,
a municipa! corpora%ion;
and DOES 1 through 100,
inclusive,
Defendants.
COM2LAINT FOR DAMAGES'
(Negligence)
FIRST ~ ~c~
~AU_- OF ACTION
Plaintiff, Y~RISTIE FILLIPPINI, through her guardian ad !item
alleges as follows:
1. KATHLEEN FILLIPPINI and ROBERT CHA_RLES FILLiPPINI, are
the parents of KRISTiE FILLIPPINI, who is their legitimaue
unmarried minor child. For the purpose of this action, i~%THLEEN
FILL!PPINI, was duly appoin~ad by the above-entiu!ed ccur5 on
, and she is now the guardian ad li%em for said
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2. Plain:iff is informed and believes and %hereon aile~es
that defendant ERNEST WiLLi~_~ SCHROEDER, was and and now is, and
at all times herein me;~tioned, a resident cf Orange County,
California.
3. The true names or capacities, whether individual,
corporate, associate or otherwise, of defendants ECE ! through
DOE !00, inclusive, is unknown to plaintiff who sue said
defendants by such ficmi:ious names; plaintiff is informed and
believes, and thereon alleges, that each cf said defendants are
negligently responsible in some manner for the occurrences herein
alleged, and that plaintiff's injuries as herein alleged were
proximately caused by said negligence. Plaintiff will amend this
complaint if necessary to show their true names and capacities
when the same have been ascertained.
4. At alt times herein mentioned, defendants DOE i through
DOE 100, and each of the remaining defendants, were the agentst
servants, and ~mptoyees of each of their co-defendants, and in
doing the things hereinafter mentioned were acting within the
scope ~f their authority as such agents, servants and employees,
and with the permission, consent and knowledge cf their
co-defendants.
5. Plaintiff is informed and believes and thereon alleges
that at all times- herein mentioned defendants LRNEST ~iLLi~
SCHROEDER, and Does 1 through !0, and each cf them, were the
legal owners of that certain 1964 Rolls Royce au%omcbiie bearing
Ca!ilfornia license number ONCLDiC, ~hich was involved in the
hereinafter described accident.
6. Plaintiff is informed and believes and thereon alleges
~h&t ac &!l times herein mentioned, '~ ~ ' ERNEST WiLLi~
SCHROEDER, and Does 1! ~hrough 20, we~= cperatinc ~' ~ =~
1964 Rolls Royce vehicle a= the location hereinafter described,
with the knowledge, permission and consent of the co-defendants,
and each of them, and cf each other, when said vehicle was
involved in the accident herein alleged.
7. At all times herein mentioned McFadden Ave. and Hyrt!e
Street, were and are public streets and highways within
Corporate limits of the C{tv_ . of" '' County of Orange,
California.
n_.a~n mentioned, oiain ''= ~R!£T~?
FILLIPPINI was a pedestrian crossing McFadden Ave., in the
of Tusin, Ca!ilfornia.
9. On or about March !5, !984 at cr near McFadden Ave., and
Myrtle Street defendants, and each cf them, so recklessly,
care!assly and neg!igen~!y owned, entrusted, managed, inspected,
maintained, equipped, repaired, loaded, operated and connro!led
their vehicle, so as to cause said vehicle to forcibly strike the
minor plaintiff, proximately causing plaintiff to sustain the
injuries and damages hereinafter alleged.
10. As a proximate result cf the conduct of %he defendanns,
and each of them, plain%iff KRIS'fIE FILLiPP!NI has sustained
=~ ~ and permanen~ physical and emotional injury =~ =
has caused and will continue ~o cause mental, phys{c:~ and
nervous pain and suffering; plaintiff is informed and
and thereon alleges, that some of said injuries wi!! ~e cf a
permanent nature, and wLl! --=' ~ in some ~ermanent ~<=:~ ....
5he minor ~_-~aint~r2, %ne ~:'.'~-~_ ..... nature and extent cf ',,'r~tch -re
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unknown ~o plaintiff, but all of which will entitle the plain:iff
herein to general damages in a sum to be established according to
proof.
Il. As a further proximate result of the conduct of the
defendants, and each of them, plaintiff was required to and did
employ physicians, surgeons and hospitals to examine, treat and
care for the minor plaintiff, and did incur, and will in the
future incur, medical and other related expenses in connection
therewith. The a>:act ~mount of such present and future expense
is unknown to plaintiff at this time and therefore plaintiff ask
leave uo prove and, if required by court, to amend this complaint
to show the reasonable value of such medical services at the time
of trial.
12. As a further proximabe result of the conduct cf the
defendants, and each of them, plaintiff is informed and believes,
and thereon alleges, that by reason of said injuries herein
alleged, the minor plain%iff has suffered, and will in the future
suffer, a loss of earning capacity. The exact amount cf such
!css is unknown to p!ain%iff at this time, and therefore
plaintiff ask leave uo prove and, if required by court, to ~mend
this complaint tc show the reasonable value of such loss cf
earning capaci5y at the time of trial.
W~{EREFORE, olaintiffs prays for judgment against the defendants
and each of them as hereinafter set forth.
SECO~ID CAUSE OF ACTION
For a Second Cause cf Ac=ion Plain=ills ~ATHL£EN F!LLiP?!~i
and ROBERT' CH~=%LE£ FiLL!PP!Ni a!iages:
!3. ?!ain~iffs hereby refer to paragraphs ! through !2,
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inclusive, of the Firs% Cause of Action and incorporates these
paragraphs herein by this reference.
14. As a proximate of said injuries to K~ISTiE FiLLZP?INZ,
plaintiffs have incurred expenses for medical and surgical
attendance, hospital bills and nursing care of said child in that
they were required to'and did amp!oy physicians, surgeons and
examine, treat and care for her, and did incur, and will in %he
future incur, medical and other related expanses in connection
therewith. The exact amount of such present and future expense
is unknown %0 plaintiffs at this time and therefore ~laintiff$
ask leave to prove and, if required by court, to amend this
complaint to show the reasonable value of such medical services
at the time of
W~EREFOKE, plaintiffs prays for judgment against the defendants
and each of them as hereinafter set forth.
THirD CAUSE OF ACTION
For a Third Cause of Action Plaintiffs alleges:
15. Plaintiffs hereby refer to paragraphs 1 through .12,
inclusive, of the First Cause of Action and paragraphs 13 and !4,
inclusive, cf %he Second Cause cf Acuion and incorporates these
paragraphs herein by this reference.
16. At all times herein mentioned, defendan: CITY OF TUSTZN,
was and is a municipal corporation existing under and by viruue
of the laws of the Sta~e of California.
17. At all times herein mentioned, F~cFadden Ave. and
Street were and are, public strea~s within the corporate
of the CITY OF TUSTIN, County cf Orange, Suaze cf Ca!ifcrnia.
18. Au al! times herein mentioned, defenda~% CiTY CF
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its agents, servants and employees had ~he control and duty cf
placement and maintenance cf proper, safe and visible warnings,
traffic controls and lights, personnel, officers, visible road
markings and crossing lane stripes cr other pro,active devices on
its public streets and~...-~-~ .... ~nc., maintaining, reoairing, and
keeping in a safe condition, the oublic streets and. highways
within its corporate limits.
19. At all times herein mentioned, defendants 2! through
ag_n~s or servants of the
!00, inclusive, were employees, ~ ~
defendant CiTY OF' TUSTIN, .and in doing the things hereinafter
described, acted within
~n_ course and scope of their agency or
emp!o_vment.
20 At said time and olace, and D~o- thereto, defendants
CITY OF TUSTiN, by and through its agents, servants and
employees, while carrying on its duties, as hereinabove
described, did so negligently and carelessly fail to post
adequaue signals, signs, personnel, officers, markings or
.Protective devices at or n=._a-~ the intersection of ~' ~= Ave.
and M,;~t!e Stree~ to warn one coerating a motor v=hic~ cr
pedestrian thereon of -~=~._ dangerous condition, atthou~h~ the
condition endangered the safe movement cf pedestrain traffic and
would not be reasonably apparent to, and ccuSd not be anticipated
by, a person walking or traveling at said !ocs%ion, with
reasonableca--=,~ in a ..... ~,~=,,._~ manner.
21. On March 15, ~984, and *~;c" thereto, Defendants Does
_n~lu_~v_, within 5he scooe, of th=~ ~mD_O = ] ,;m_.~="'_
through !00, ~ ~ '=' '= ..... . . ,
do sc, failed to .... ~=~=~%.~ said intersection for ~he .Purpose. cf
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ae~_.m_n-ng whether ~h~ : .... -'-"' in a dangercus
condition.
22. As a proximate result of the negligence and
carelessness of defendant CITY OF TUSTIN, and DOES 21 through
!00, inclusive, plain%iff ~R!STIE F!LLIPPINI was struck by that
certain !964 Rolls Royce automobile, owned by defendants LRNEST
WILL!~ SCHROEDER and DOES 1 through 10, inclusive, and operated
by defendants LR~S. WILL!A~ SCEROEDER and DOES ll %brough 20,
inclusive, while said vehicle was traveling eastbound cn McFadden
Ave. in the vicinity of the intersec%ion of McFadden Ave. and
Myrtle S~raets, said ccl!ision causing the plaintiff to be
violently thrown to the ground and suffer the hereinabove
described injuries and damages.
23. At all times herein mentioned, defendants, and eech cf
them, had notice of the dangerous condition of the said
intersection at said location in that said condition had exisled
. ~_~_naan~$, in the exercise of du= care,
for a long period and '~:= ' ~ ' -
should have discovered the condition and it's dangerous
character.
24. Defendants, and each of them, had the authority and ~he
{ =~{ -= ilable to them to have
funds and other means _m.m___a._ly ava
placed and maintained proper warnings, signals, signs, personnel,
officers, markings cr other protective devices n_._ssa_~ :o warn
of or prevent said dangerous condition.
25. On or abcu~ !.lay ~, ~984, plain:iff 5LRiSTiE
duly presented ~o defendant CITY OF TUSTIN, a claim in the
cf $!00,000.00 in c~=-~._.._.__ damaces, suec{:~. _ damaces, and ~.-=ec%
injury unkno%'n an this %i~e, fer %he damages sou~n5
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A true and correct copy of ~he claim is attached hereto, marked
~xhibit "A" and incorporated herein by this reference. 26. On cr
about,-.~aS-~said defendant rejected ~aid claim in it's
entirety.
WHEREFORE, plaintiffs pray judgment against defendants, and each
of them, as follows:
FOR THE FIRST CAUSE OF ACTION:
For general damages according to proof;
For medical and incidental expenses according to proof;
For loss of earnings and earning capacity according to
proof;
4.
and
5.
For costs cf suit and attorney's fees ln~u,_ed herein;
For prejudgment interest pursuant to Civil Code Section
3291 at %he rate of tan (I0%) percen~per annum ct-an amount set
by !aw.
6. For such other and further relief as the Court may deem
just and proper.
FOR THE SECOND CAUSE OF ACTION:
1. For general damages according 5o proof;
For medical and incidental expenses acccrdin9 %0 proof;
For costs of suit and attorney's fees incurred herein;
and
4.
For prejudgment interest pursuant ~o Civil Code Section
3291 at the rata of ten (10%) percent per annum cr an ~r. oun% set
~ mc- such o~h=? and further -=~ ;el as ~= Court -=" ~==-
just and proper.
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FOR THE THZRD CAUSE OF AC~,ON:
1. For general damages according to proo,;
For medical and incidental expenses' according to proof;
For loss of earnings and earning capacity according to
proof;
4.
For costs of suit and attorney's fees incurred herein;
5. For prejudgment interest pursuant to Civil Code Section
329[ at the rata of ten
by law.
6. For such other and further relief as the Court may deem
just and proper.
.D~D: July 31,
~ONALD W. CHR[SL[?
Attorney for Plaintiffs
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2S
1505 N. ~
Santa Aha
(714) 547
~ - ,V
,'I
.... CITY OF TUCmrN
NOTICE OF CLAIM n=n~NST ---
~R!STIE MICHELLE FILLiP?INi, a minor, by and through her
Attorney, RONALD W. CHRISLIP hereby presents her claim to the
City cf Tustin pursuant to Section 910 cf the California
Government Code.
!. The name and post-office address of i~K!ST!E M!CHELLE
FILLiPPIN! is as follows:
2. The post-office address to which claimant desire notices
to be sent is as follows:
RON~.=D W. CHRiSL!P
Attorney at Law
1505 n. Broadway
Santa .~J.a, CA
3. On or about biarch !5, 1984 at cr near ~cFadden Ave. and
Myrtle Street, in the City of TustLn, Coun~-y of Orange,
C~ ~;ornia, claimant ~=~ =' personal in~ --'==
following cirum~trances:
Ciaiman% a minor, was a pedestrian crossing ~='~ '~
~-.=~sec=icn ~/iuh Mvr~ in ~' ~ c~'/ of ~"s':~ when she
was s=ruck by a vehicle driven by Ernest ~,~i!!iam
c~' ~-~'=~ thi~-ebv CZUStng her to sustain serious and
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injuzies. Claimant is informed and believes %hat the sole or
- .US~_N s
contributing cause .c said accident was the CiTY OF
failure to provide adequate warnings, signals, personnel,
officers, markings, or other devices and safeguards at said place
to allow for the safe movement of pedestrain traffic.
4. On or about said date at cr near the !ccation aforesaid,
the City cf 'Tus%in, ~%s agents, employees, and contractors, and
each of %hem, so recklesslyr carelessly and negligently omitted
and failed to provide adequate warnings signals, p~rsonne!,
officers, markings, cr other devices and safeguards, which
knew, cr should have known, created unreasonable risk of harm and
danger to perscnsr including claimant herein, crossing .the
intersection at said location, and did proximat!ey cause injuries
and damages to claimant as hereinafter alleged.
5. So far as it is known to AONALD W. CERISL!? at the date
of filing this claim, the claimant has suffered injuries to
=~ . ex~_n~ of which
various parts of h_~ bodvr the extact nature and
has not been fully ascertained at this time.
6. The names cf the employees causing said injuries are
unknown to claimant a~ this time and are referred herein to as
DOES i through 50, inclusive.
7. ~ the time cf orasentation of this ~
.._ _ c~a_m, K~ZSTZE
MZCHELLE~r~rr~rxzm-~-z-,.~, claims damages in %he amount cf $!00,000.00
including a~mroximatalv SS0r0~0.00 dollars due to
injury and damages, computed cn the basis of ~he following:
Fuuure Medical ='.-D=nces;
(c) Loss of earning capacity;
{d) Pain and suffering, Dsvcho!cgica! and physical.
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8. The undersigned, is %he au%orney for the aforesaid
claimant and hereby present these claims on her behalf.
Dated: kay 24, 1983 ,,.
RONALD W. CHR~iP
RC.L~LD W. CHKISLTP (
!~
70441
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE
P, O. ~OX 8"'8
700 CWIC ~NT~R DR.
~ANTA ANA, CA
K?~STIE FILLIPPIN~
E~EST W. SCHROEDER
NOTICE AND ACKNOWLaDGMENT OF RECEIPT c~,e ~u~:,~ 43- 73-37
TO: ER-N~ST W. $CHRO"-DER
This summons anti other Oocurnent(`:) indicated below are being served ~ursuant to Section 41~.30 of the California
CoOe ol Civil Procedure. Your failure to complete this form and return it to me within 20 rays may'suDject you (or
the pa~ on whose DenaU you are Doing
summons on you in any other manner permi~ed by
If you are being served on behalf of a ocr:oration, unincorporated association (incl~ding.a pa~nership), or other
entity, this form must be signed Dy you in the name of such entity or by a person authoriz--.cl to receive ':er,ice of
process on behalf of such entity, in all other cases, this form must be signed by you personally or by a person authorized
by you to acknowiectge receipt of summons. Section 415.30 provides that this summons anc~ other clocument(a)
deemeci servec~ on the ~,ate you sign the Acknowledgment of Receipt below. U you return this form to me.
ACKNOWLEDGMENT OF RECEIPT
This acknowleCges recei:t of: ('To De completecl Dy sender before mailing) 1. ~ A cody of the summons and of the complaint.
2. ~'--~A copy ct the summons and of lhe Petition (Marriage) ancO:
! ~ Blank C~nfi~ential Counseling Statement (M~rriage)
['---]'Oroer to Show Cause (Marriage)
~ Blank Responsive Declaration
~ ~lank Financial Declaration
L_~ Other: (Specify)
NOTICE AND ACXNOWL---DG?/.--?~T OF RECE3PT