STATE OF MICHIGAN
COUNTY OF GENESEE
JENNY A. JONES CASE NO:95-45554-DM
VS JUDGE: NORMAN MAILER
JOHN B. JONES ANSWER TO REQUEST
FOR INJUNCTION
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James Whalen
1184 W. Bristol Rd.
Flint, Mi. 48507
TX: 810-239-5000
Attorney For Plaintiff
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Janis R. Joplin
8221 Longstreet
Flint, Mi. 48501
TX: 810-234-1212
Attorney For Defendant
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Now comes the Defendant, John Jones, by and through his attorney, Janis R. Joplin, who answers the Request for Injunction (Personal Protection Order) as follows:
1. Admitted, that the recitation of Plaintiff's residence is accurate.
2. Admitted, that the parties have cooperated in the matter of visitation, at least in the past. Defendant affirmatively asserts that he has never missed a visitation period, nor even been late for same.
3. Admitted, that the Defendant returned the children at the agreed-upon time, which the Defendant has always done.
4. Denied, as to each of the factual averments in Plaintiff's paragraph 4, because each of them are untrue. In fact, Plaintiff provoked an argument with your Defendant, which your Defendant attempted to ignore, with no success. Plaintiff repeatedly taunted your Defendant, and insisted that she was going to court in the near future, and was going to "take you for everything you've got", and "it used to be YOUR house, but now it's MY house", and other such statements, and the only time your Defendant raised his voice was about the third time that your Defendant told the Plaintiff to leave him alone, and let him leave the premises peaceably.
5. Admitted that the Flint Police Department arrested your Defendant, however, that arrest was unlawful, was without cause, and litigation for false arrest has been instituted against the officers and the police department involved.
6. Defendant neither admits nor denies that the Plaintiff is in fear, as Defendant has no knowledge of same, however, if Plaintiff is in fear of your Defendant, said fear is irrational, and without any cause by conduct of your Defendant, as your Defendant has always maintained himself in an appropriate manner while in the presence of the Plaintiff and the minor children.
7. That the claim by the Plaintiff that she needs protection of a court order is outlandish and outrageous, and Defendant affirmatively states, and demands a reply prior to the hearing, each of the following facts:
a. Defendant has never struck the Plaintiff with his hand, or any other object, even during the duration of the marriage.
b. Defendant has not, since the separation of the parties, set foot upon the business premises of the Plaintiff, except for the one occasion that he was invited, in advance, by the Plaintiff.
c. Defendant has never missed a visitation period with the children, nor been late for same, and has attended each of the children's school conferences, and has paid the sum of two hundred dollars per week to the Plaintiff, for the benefit of the children each week since the separation of the parties, even though there is no Order of this Court directing same.
d. The terms of the injuction/personal protection order as requested by the Plaintiff would effectively prohibit the Defendant from visiting his children.
Wherefore, your Defendand prays that this Honorable Court will, after a hearing, DISMISS the Plaintiff's petition, and DENY Plaintiff's request for an injunction against your Defendant, and further, provide your Defendant to such other and further relief, as Defendant may show himself entitled.
Further, Defendant prays not.
(signed) John Jones