Type:   WO
Party:   Timothy D. Williams
County:   Pulaski
Case Number:   60DR-18-4183
Attorney:   Timothy Williams

IN THE CIRCUIT COURT OF PULASKI COUNTY, ARKANSAS HON. CATHLEEN V COMPTON - 3RD DIVISION 6TH CIRCUIT TIMOTHY D. WILLIAMS V DANIELLE Y. CHEEKS-WILLIAMS 60DR-18-4183 SUMMONS THE STATE OF ARKANSAS TO DEFENDANT: DANIELLE YVONNE CHEEKS-WILLIAMS 59 MAYPOP LANE DECATUR, GA 30035 A lawsuit has been filed against you. The relief demanded is stated in the attached complaint. Within 30 days after service of this summons on you (not counting the day you received it) - or 60 days if you are incarcerated in any jail, penitentiary, or other correctional facility in Arkansas - you must file with the clerk of this court a written answer to the complaint or a motion under Rule 12 of the Arkansas Rules of Civil Procedure. The answer or motion must also be served on the plaintiff or plaintiff's attorney, whose name and address are: TIMOTHY DARYL WILLIAMS 8205 W. 46TH ST Little Rock, AR 72204 If you fail to respond within the applicable time period, judgment by default may be entered against you for the relief demanded in the complaint. Additional notices: -Notice of Right to Consent to Disposition of Case by a State District Court Judge CLERK OF COURT Latanya Christopher, DC Date: 11/07/2018 Address of Clerks Office LARRY CRANE, CIRCUIT CLERK CIRCUIT COURT OF PULASKI COUNTY 401 W. MARKHAM LITTLE ROCK, AR 72201 IN THE CIRCUIT COURT OF Pulaski COUNTY, ARKANSAS 3rd DIVISION Timothy Daryl Williams 8205 West 46th Street, Little Rock, AR 72204, PLAINTIFF VS. CAUSE No. 60DR-4183 Danielle Yvonne Cheeks-Williams 59 Maypop Lane, Decatur, GA 30035, DEFENDANT COMPLAINT Comes now the Plaintiff, Timothy Daryl Williams, and for the Plaintiff's cause of action against the Defendant states and alleges as follows, to-wit: I. The Plaintiff is a citizen and resident of the State of Arkansas, County of Pulaski and has been such for more than sixty (60) days prior to filing this Complaint. The Defendant is a citizen and resident of the State of Arkansas. The Court has jurisdiction of the parties and subject matter hereto. II. That the parties were married on or about the 17th day of January, 2014, and lived as Husband and Wife until they separated on or about the 26th day of December, 2014. They have lived separate and apart from and since that date. III. Plaintiff is entitled to a divorce on the grounds of (Check appropriate box): Living separate and apart from each other for eighteen continuous months without cohabitation, regardless of fault or reason. Defendant has treated the Plaintiff with such personal indignities, habitually, systematically and persistently pursued in such a manner as to make the Plaintiffs condition in life intolerable. IV. Check all that apply: There are no minor children of said marriage, and the wife is not now pregnant. All children of the marriage are over the age of twenty-one (21) and emancipated. VI. All matters involving property of the marriage, both real and personal, have been resolved and the terms agreed to in the Separation and Property Settlement Agreement mentioned below and attached hereto. All debts have likewise been resolved by the parties in the Separation and Property Settlement Agreement attached herein as Exhibit “A”. VII. Wife does not request restoration of her former name, Cheeks. This request is not made for any illegal or fraudulent reason. VIII. The Plaintiff further states that no other cases in the State of Arkansas or any state or territory involve the same claim or subject matter as this case. WHEREFORE, PREMISES CONSIDERED, Plaintiff, requests against Defendant, the following relief: (a) A Decree of Divorce dissolving the bonds of matrimony between the parties based the grounds of living separate and apart from each other for eighteen continuous months without cohabitation, regardless of fault or reason. (b) That the Separation and Property Settlement Agreement attached hereto as Exhibit “A” be incorporated herein by reference and have the same force as if stated herein in full. (c) For judgment and relief as set forth in this Petition. (d) For such other relief and judgment as is just and equitable in the premises. Respectfully submitted, Signature of Plaintiff Timothy Daryl Williams DR2T-3/5,3/12/19