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 

      next page please if applicable        page no. 2




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