IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CASE NO.: 2013-DR-817 Family Division: IN RE: THE MARRIAGE OF: ANGELA MARIE CEGNAR, Petitioner/Wife, And STANISLAV CEGNAR, Responden/Husband PETITION FOR DISSOLUTION OF MARRIAGE The Wife, ANGELA MARIE CEGNAR, files this Counter Petition for Dissolution of Marriage and says: 1.This is a Petition to dissolve the marriage between the Wife, ANGELA MARIE CEGNAR, and the Husband, STANISLAV CEGNAR. 2.The parties were married on December 29, 2001 at Ft. Lauderdale, Florida. 3.The Wife has been a resident of the State of Florida for at least 6 months prior to the filing of this Petition for Dissolution of Marriage. 4.The marriage between the parties is irretrievably broken. 5.No children have been born of the marriage and no children are contemplated. 6.The parties have acquired marital property and obligations through the course of the marriage and such property and obligations need to be equitably distributed by the Court. 7.The Wife should be entitled to an unequal distribution of marital assets due to her extraordinary contribution to the acquisition of such assets and the Husband should be required to take a majority of the liabilities incurred during the marriage becau se his spendthrift ways led to the acquisition of the debt. The Husband has also secreted and hidden assets in an attempt to thwart the equitable distribution process. 8.The Wife has non-marital property that needs to be set aside by the Court. 9.The Wife needs and the Husband has the ability to pay support in the forms including but not limited to temporary, durational, bridge the gap, permanent and lump sum alimony. 10.The Husband should be required to maintain a policy of life insurance as security for any alimony obligation. 11.The Wife needs and the Husband has the ability to pay the Wife's attorney's fees and costs incurred in this action. 12.The Wife has retained the Law Firm of Janella K. Leibovitz, P.L. and has obligated herself to pay a reasonable fee. WHEREFORE, the Wife requests that this Court enter its order dissolving the marriage of the parties, equitably distributing the martial assets and liabilities, granting the Wife an unequal distribution of marital assets and liabilities, setting aside the Wife's non-marital property, granting the Wife support in the forms including but not limited to temporary, durational, bridge the gap, permanent and lump sum alimony, ordering the Husband to maintain a policy of life insurance as security for any alimo ny obligation, ordering the Husband to pay the Wife's attorneys' fees and costs and granting the Wife such other relief as the Court deems just and proper. Law Office of Janella K. Leibovitz, P . L. Attorney for the Wife 2014 Fourth Street Sarasota, Florida 34237 (941) 362-3355/(941) 362-3366 Fax jleibovitzlaw@aol.com By: Janella K. Leibovitz Fla. Bar No. 0194824 Date of pub: April 16, 23, 30; May 7, 2013
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