IN THE COURT OF COMMON PLEAS
COUNTY OF GEAUGA, OHIO
MAURICE E. BRAHIER : CASE NO. 91 DC000792
DEFENDANT : JUDGE HANS R. VEIT
vs. : AFFIDAVIT IN SUPPORT
OF MOTION FOR ADDIT-
IONAL GAINFUL EMPLOY
GAIL S. BRAHIER
State of Ohio
ss
County of Geauga
MAURICE E. BRAHIER, being first duly sworn, according to law, deposes
and states that:
1. He is the defendant in the within action.
2. He and the plaintiff were married on or about April 26, 1982, in
Richmond, Kentucky.
3. He and the plaintiff are the natural parents of two (2) minor
children, daughter {name removed by request}, born November 24, 1987, and son [name removed]
Brahier, born December 14, 1987.
4. Affiant states that it is in the best interest of the children for
plaintiff to obtain additional gainful employ.
5. Affiant states that plaintiff willfully and with fore knowledge
did cause this family extreme financial hardship.
6. Affiant states that plaintiff had full knowledge of the extent of
hardship that would be caused by accepting the job for Lake Metro Parks
District.
7. Affiant states that the plaintiff and he set a minimum starting
salary for a move from plaintiff's Kentucky State Park system employ at
$30,000.00 to a southern state.
8. Affiant states plaintiff's starting salary was $24,900.00
(supplied by plaintiff).
9. Affiant states that he did not state, nor imply that the
plaintiff's move to Ohio would be acceptable, because of the massive loss
to the childrens and family financial position.
10. Affiant states that plaintiff accepted this job without his
consent either implied or stated.
11. Affiant states plaintiff, of her own volition, accepted this
job for a substantial monetary loss.
12. Affiant states that plaintiff's initial loss upon employ here was
an unacceptable amount.
13. Affiant states that plaintiff's salary is still a substantial
loss in family finances.
14. Affiant states that plaintiff's move brought an additional minimum
$1,000.00 per month in bills to family during winter months.
15. Affiant states that plaintiff should be ordered to cover
additional family loss.
AFFIANT FURTHER SAYETH NAUGHT.
_______________________
MAURICE E. BRAHIER
Sworn to be fore me and subscribed in my presence this _______ day of
__________________, 1991. __________________________
NOTARY PUBLIC
PREPARED BY:
MAURICE E. BRAHIER
11654 Claridon-Troy Rd.
Chardon, Ohio 44024
(216) 635-0361
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