Law Office of Janet Langjahr
Boynton Beach Divorce Lawyer serving
Fort Lauderdale Broward and West Palm Beach County
and, with our network, all of Florida
Attorney licensed in FL, NY, NJ

Boynton Beach, Florida divorce and child custody attorney Janet Langjahr helps you win back control of your lives in family and domestic violence court

Helping You Win Back Control of Your
Lives with a Secure Divorce SM

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FACTS SUPPORTING WIFE'S MOTION

  1. Husband, a career law enforcement officer, i) suffers from long-term chronic depression for which Husband is required to take medication on a daily basis; ii) suffers from alcoholism; and iii) manages anger very poorly when depressed and / or intoxicated.

  2. During the marriage, Husband, formerly a _________ City police officer, simultaneously possessed as many as four different handguns.

  3. While simultaneously shouting at Wife, Husband conspicuously fidgeted with one of Husband's revolvers throughout an argument in the marital home ("Home") one evening during the summer of ____.

  4. Since the summer of ____, Husband telephones Wife at all hours of the day and night.

  5. During some of those calls, Husband warns Wife that Husband now has nothing to lose and nothing to live for.

  6. During many of those calls, Husband shouts profanities at Wife.

  7. During some of those calls, Husband plays recordings of private telephone conversations that Wife had with third parties and outside of Husband’s presence.

  8. During some of those calls, Husband discusses details of private telephone conversations that Wife had with third parties and outside of Husband’s presence.

  9. Husband confessed to Wife that Husband wire-tapped Wife’s telephone.

  10. Without authorization from Wife, Husband, upon information and belief, used Wife’s social security number to gain access via the internet to Wife’s cellular telephone call account records listing the telephone numbers of Wife’s associates.

  11. Husband repeatedly threatens Wife that Husband will to go to Wife's workplace ("School"), an elementary school, and cause an embarrassing scene that will jeopardize Wife’s employment.

  12. On at least one occasion, Husband went, uninvited, to School and needlessly drove Husband’s car past a particular co-worker ("Friend") of Wife's several different times.

  13. Wife, concerned for her students and co-workers at School and despite her deep embarrassment, had no choice but to report Husband's threats and alarming behavior to her superiors and to security personnel at School.

  14. Husband repeatedly threatens to call Wife's co-workers and administrators at School and to make allegations of a personal nature about Wife to them.

  15. Husband repeatedly threatens to write letters to Wife's co-workers at School and to make allegations of a personal nature about Wife to them.

  16. Husband telephoned one of Wife's co-workers at School and told Friend that Husband "has a bullet with [Friend’s] name on it." Husband also warned Friend against continuing to associate with Wife.

  17. Husband telephoned another one of Wife’s co-workers at home to discuss Wife’s private life and to disparage Wife.

  18. On April 10, ____, Husband called School and asked for yet another co-worker of Wife, falsely identifying himself as the boyfriend of the co-worker. This particular co-worker has daily contact with virtually everyone in the School. During the call, Husband bombarded the co-worker with profanity and allegations of a personal nature concerning Wife. Predictably, the co-worker told others at School about the frightening incident.

  19. On or about the evening of November 9, ____, Husband went to the residence of Friend and tampered with the contents of Friend’s vehicle’s gas tank. Upon information and belief, Husband pleaded guilty to criminal charges arising from that conduct.

  20. Husband, at that time a __________ County School police officer, confessed to Wife that Husband had used school computer systems to obtain the license plate identifying Friend’s vehicle.

  21. Husband repeatedly threatens to call Wife’s friends from Wife’s gym and make allegations of a personal nature about Wife to them.

  22. Husband tricked Wife into meeting with him on the pretext of transferring health insurance for their ______ year old daughter ("Child") to Wife's policy after Husband was asked to resign from his job.

  23. On April 10th, after the incident described in paragraph 18, Wife’s counsel contacted Husband’s counsel to request that Husband refrain from further harassing Wife. After speaking with Husband, Husband’s counsel reported to Wife's counsel that Husband had said that Husband “will behave himself”.

  24. Husband telephones Child's cellular phone and leaves message after message after message if Child fails immediately to return Husband's calls.

  25. Husband repeatedly discusses with Child financial aspects of the divorce that are not appropriate to discuss with Child.

  26. At a dinner with Child and the adult daughter ("Daughter") of the marriage (Child and Daughter, together, "Girls" and each, a "Girl"), Husband went out of his way to tell Child that he would not sign any document requiring him to support Child beyond the minimum legal requirement.

  27. On April 9, ____, at a meeting of the parties with their respective attorneys, Wife’s attorney and Wife requested that Husband refrain from discussing the details of the divorce with the children of the marriage, particularly Child. Husband’s counsel confirmed to Husband that such conduct was unacceptable.

  28. On the evening of April 10, ____, Child found a message from Husband on Child's cellular phone stating that Wife has everything and Husband has nothing and, therefore, if Child did not understand Husband's anger, Child need not ever call Husband again.

  29. Husband, while alone in Husband's automobile with Child one evening, suddenly and without warning or provocation, exclaimed profanity and then interrogated the Child about Wife’s strategy in these proceedings.

  30. Husband regularly disparages Wife to both Child and Daughter.

  31. Husband, despite Daughter’s repeated refusals to discuss financial or other aspects of the parties' divorce, advised Daughter that Husband had to "take care of [my]self".

  32. One evening, the Girls made plans to have dinner with Husband at a time when Wife is known to habitually go to Wife's gym. The gym is adjacent to the development containing the Home. At the last minute, Husband asked Daughter to pick Child up at Home because Husband was behind schedule. Yet immediately after leaving the Home together, the Girls sighted Husband’s automobile in the parking lot at Wife’s gym near Home.

  33. In December of ____, Husband purposefully alienated the adult son (“Son”) of the marriage from Wife by discussing with Son various aspects of the divorce that were not appropriate to discuss with Son.

  34. Since the summer of ____, Husband has engaged in an ongoing pattern of conduct constituting willful molestation and harassment of the Wife, the Child and the Daughter.

  35. Husband has expressed and implied various threats, has carried out several of those threats, and has the apparent ability to carry out all of those threats.

  36. Husband's conduct has subjected and continues to subject each of the Wife, Child and Daughter to substantial emotional distress, substantial fear of imminent danger to herself and to the other two, and to other immediate and irreparable harm for which there is no adequate remedy at law.

The Law Office of Janet Langjahr PA
Divorce Law · Child Custody Law · Domestic Violence Law
3330 S. Federal Highway, Suite 208
1 Mile South of Woolbright Road at Bamboo Lane on the northbound side of US 1
Boynton Beach, FL 33435
Voice (561) 424-9001
Fax (561) 892-8442
info@fla-divorcelaw.com
www.FLA-DivorceLaw.com
Licensed in Florida, New Jersey and New York (since 1988)
Serving West Palm Beach County and Fort Lauderdale Broward County, Florida
and, with our network, all of Florida

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