`COURT OF COMMON PLEAS
`Wednesday, August 10, 2022 10:44:10 AM
`CASE NUMBER: 2022 DR 00573 Docket ID: 36520358
`MIKE FOLEY
`CLERK OF COURTS MONTGOMERY COUNTY OHIO
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`IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
`DIVISION OF DOMESTIC RELATIONS
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`Case No. 2022 DR 573
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`JUDGE CROSS
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`MAGISTRATE
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`MOTION FOR TEMPORARY
`RESTRAINING ORDER
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`Miranda Gail Stamper
`8890 Davidgate Dr.
`Dayton, Ohio 45424
`DOB: November 11, 1985,
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`Plaintiff,
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`vs.
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`Rodney Stamper
`8890 Davidgate Dr.
`Dayton, Ohio 45424
`DOB: December 20, 1974,
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`Defendant.
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`Now comes the Plaintiff, Miranda Stamper, by and through her Counsel, Charlyne
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`Adams of BARR, JONES & ASSOCIATES, LLP., and hereby Moves this Court for a
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`Temporary Restraining Order pursuant to Rule 75(I) of the Ohio Rules of Civil Procedure,
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`restraining Defendant from:
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`1. Selling, transferring, encumbering, concealing, damaging, gifting, disposing of,
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`and/or secreting any asset whether tangible or intangible and wherever located, and/or
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`changing life insurance beneficiaries, removing Plaintiff as beneficiary of any asset,
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`plan, policy or benefit, or otherwise dissipating any assets, properties, or funds or any
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`part thereof whether separate, marital, or mixed, so as to defeat Plaintiff’s right in
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`obtaining spousal or other support.
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`2. Incurring debt on Plaintiff’s credit, and from causing any debt for which Plaintiff
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`would have any obligation whatsoever; and
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`3. Causing or threatening harm, physical and/or verbal abuse, emotional abuse,
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`annoyance, intimidation, harassment, molestation, or bodily injury upon Plaintiff or
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`the parties’ children.
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`4. This Restraining Order shall not prevent the payment of ordinary and necessary
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`business and living expenses consistent with the practice of the parties during the
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`marriage. Plaintiff requests this Court to issue said Temporary Restraining Order
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`without requirement of bond.
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`Respectfully submitted,
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`_/S/ Charlyne Adams______________
`Charlyne Adams (#0100338)
`Barr, Jones & Associates, LLP
`Attorney for Defendant
`301 W. 1st Street, Second Floor
`Dayton, Ohio 45402
`(937) 202-4222
`(937) 660-6832 (Fax)
`cadams@barrjoneslegal.com
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