STATE OF NORTH CAROLIN* F THE GENERAL COURT OF JUSTICE

DISTRICT COURT DIVISION

COUNTY OF NEW HANOVER 22 CvD 2696

JULIA BOSEMAN,

Plaintiff,DEFENDANT'S MOTION
FOR
INTERIM DISTRIBUTION AND
PRELIMINARY INJUNCTION

ANGELA OLSON-BOSEMAN,

Defendant.

NOW COMES the Defendant, and moves the Court for an Order of Interim Distribution

pursuant to N.C.G.S. 50-20 (i 1), and a Preliminary Injunction pursuant to G.S. IA-I, Rule 65 and

G.S. 50-20(i) against the Plaintiff and alleges and says as follows:

1. A Complaint was filed by Plaintiff on August 3, 2022 alleging that the parties separated

on July 25, 2022. Said Complaint included a claim for equitable

distribution.

2. The Defendant intends to file a counterclaim for equitable distribution within her time

to do so.

3. On July 25, 2022, the Plaintiff secretly and unilaterally withdrew funds in the amount

of $118,000.00 from the parties' joint marital bank account at First National Bank

("FNB") and caused said funds to be transferred into an account identified only as

"Business Checking XXXXXX5509". Defendant had no prior knowledge of said

business account until she obtained a bank statement from FNB on August 9, 2022.
 The Plaintiffs withdrawal of marital funds on July 25, 2022 was without the consent

or prior knowledge of the Defendant. The Plaintiff barred Defendant from having

access to the withdrawn funds. The Defendant has been injured by Plaintiffs actions.

4. Defendant is in need of an Order of Preliminary Injunction requiring Plaintiff to

account for all such withdrawn funds and preventing the further disappearance, waste

or conversion of said funds by the Plaintiff during the pendency of this litigation and

such order is needed to protect the Defendant's rights during the course of this litigation

and prevent further irreparable harm to the Defendant.

5. Immediately prior to and immediately following the date of separation, the Plaintiff

used credit cards in the name of the Defendant to make purchases, and allowed third

parties to make purchases, totaling the approximate amount of

$26,000.00. The Plaintiff was an "authorized user" on said credit card accounts but

not authorized by Defendant to make charges for Plaintiffs separate and non-marital

purposes nor was any third-party associate of the Plaintiff authorized by Defendant to

make charges on Defendant's credit card. Defendant is informed and believe and

therefore alleges that said third party is still physical possession of Defendant's credit

card.

6. Subsequent to the date of separation, the parties sold a boat, which was marital

property, and the net proceeds were disbursed in the form of a bank check payable to

Plaintiff and Defendant that, upon information and belief, is currently in the

Plaintiffs possession.

2
 7. The Defendant is in need of an Order making an interim distribution of 100% of the

boat proceeds to Defendant subject to an accounting of said distribution in

equitable distribution. Said proceeds will be used in part by the Defendant to pay the

credit card charges referenced above subject to the Court's classification and

distribution of said debts in final equitable distribution.

WHEREFORE, the Defendant prays the Court as follows:

1. That the Coult enter of an Order of Preliminary Injunction requiring

Plaintiff to account for all funds withdrawn from the joint FNB bank account and

preventing the further disappearance, waste or conversion of said funds by the Plaintiff

during the pendency of this litigation. In the alternative, that the Court make an interim

distribution of said withdrawn funds by awarding 50% to each party subject to an

accounting of said distribution in equitable distribution.

2. For entry of an Order of Interim Distribution of 100% of the boat sale funds
to

Defendant.

3. For such other and further relief as to the Court seems just and proper.

This the 1 Oh day of August 2022.

LORI W. ROSBRUGH
Attorney for Defendant
N.C. State Bar. No.: 24989
P.O. Box 217
Wrightsville Beach, North Carolina 28480
Phone: (910) 256-6808 [email protected]

3
 CERTIFICATE OF SERVICE

I, Lori W. Rosbrugh, do hereby certify that I have this day forwarded a copy of the
foregoing document to the addressee(s) named below, as follows:

Sending a copy hereof via confirmed facsimile transmission for receipt by 5:00
p.m. EST on a regular business day to the following: 888-814-5455

By hand delivering a copy of same to the office of:

(X) By depositing via U.S. Mail postage paid addressed as follows:

By U. S. Certified Mail Return Receipt Requested, post paid as follows:

Chris Johnson
3807 Wrightsville Avenue, Suite 20
Wilmington, NC 28403

This the 10TH day of August 2022.

LORI W. ROSBRUGH

4
 STATE OF NORTH CAROLINA

COUNTY OF NEW HANOVER

VERIFICATION

ANGELA OLSON-BOSEMAN, Defendant herein, being first duly sworn, deposes and
says that she is the Defendant in the foregoing action; that she has read the foregoing Motion and
knows the contents thereof; that the same is true of her own knowledge except as to those matters
therein stated upon information and belief, and as to those, she believes them to be true.

ANGEL OLSON-BOSEMAN

1 cenify that ANGELA OLSON-BOSEMAN personally

appeared before me and that

[ I-PIThave personal knowledge of the identity of the principal;

or

This the 10 day of August 2022.

Co e (2-osßgcu
Print

IN THE GENERAL COURT OF JUSTICE DISTRICT COURT DIVISION FILE 22

CVD 2696

Julia Boseman
Attorney: Chris Johnson
 STATE OF NORTH CAROLINA

COUNTY OF NEW HANOVER

1 PlaintiffJUDICIAL
ASSIGNMENT
10
P b AND/OR
NOTICE OF SCHEDULING
Angela Olson-Boseman
Attorney: Lori Rosbrugh
Defendant
1. The District Court Judge assigned to this action is OUT OF COUNTY JUDGE
SUANN N. BECHTEL, Case Coordinator (910) 772-7102

2 This case is set for the followin pur oses: APPLIES

ONLY TO THE BOXES THAT ARE CHECKED
Type of Hearing Date Time Location

C] Custody Mediation 1:00 PM ZOOM

Orientation is set for: Online Zoom Class
Datea Timer ZOOM
Custody Mediation is set for:
Online Zoom Mediation
Child Support Hearing COURTROOM here.
9:30 New Hanover Count
AM Courthouse
O Temporary Custody or C] Date. COURTROOM
9:30
Temporary New Hanover County
AM
Visitation Hearin Courthouse
ÜPermanent Custody or Date. COURTROOM
Permanent 9:30 AM New Hanover County
Visitation Hearin Courthouse
ÜPostseparation Support or Date, COURTROOM
9:30
Alimony New Hanover County
AM
Hearin Courthouse
Equitable Daten SUITE 419
Distribution/Alimony Status 2:00 New Hanover County
Conference PM Courthouse
13 Interim Distribution or Date COURTROOM here.
Equitable 9:30 New Hanover County
Distribution Hearin AM Courthouse
Other: Def, 08/15122 9:30 COURTROOM OJJ - B
TROIPreliminary Inj- AM New Hanover County
Courthouse
 STATE OF NORTH CAROLINA

COUNTY OF NEW HANOVER

NOTICE TO PARTIES: YOU ARE DIRECTED TO APPEAR AS SCHEDULED ABOVE THIS
SCHEDULING ORDER IS ENTERED PURSUANT TO THE CASE MANAGEMENT PLAN OF THE LOCAL
RULES FOR THIS DISTRICT. A FAILURE TO
APPEAR AS DIRECTED MAY SUBJECT YOU TO
SANCTIONS BY THE COURT.

FAMILY COORDINAT
DATED:

The party for whom this "Judicial Assignment andlor Notice of Scheduling" is issued MUST
serve a copy of this Judicial Assignment and/or Notice of Schedulin u on all arties.

CONTACT LORI WAINRIGHT AT (910) 772-7114 FOR QUESTIONS CONCERNING CUSTODY ORIENTATION OR MEDIATION
DATES
Ar b THE GENERAL COURT OF JUSTICE
DISTRICT COURT DIVISION
22 CvD 2696

10 P
JULIA BOSEMAN,

Plaintiff, DEFENDANT'S MOTION TO

DISMISS NCRCP

ANGELA OLSON-BOSEMAN,

Defendant.

NOW COMES the undersigned attorney, on behalf of the Defendant in this matter, and

hereby moves this Court to dismiss Plaintiffs claim for Temporary Restraining Order pursuant

to N.C. Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be

granted.

This the 1 Oh day of August 2022.

STATE OF NORTH CAROLINA

COUNTY OF NEW HANOVER

LORI W. ROSBRUGH
Attorney for Defendant
N.C. State Bar. No.: 24989
P.O. Box 217
Wrightsville Beach, North Carolina 28480
Phone: (910) 256-6808 [email protected]
 CERTIFICATE OF SERVICE

I, Lori W. Rosbrugh, do hereby certify that I have this day forwarded a copy of the
foregoing document to the addressee(s) named below, as follows:

Sending a copy hereof via confirmed facsimile transmission for receipt by 5:00
p.m. EST on a regular business day to the following: 888-8145455

By hand delivering a copy of same to the office of:

By depositing via U.S. Mail postage paid addressed as follows:

By U. S. Certified Mail Return Receipt Requested, post paid as follows:

Chris Johnson
3807 Wrightsville Avenue, Suite 20
Wilmington, NC 28403

This the 10TH day of August 2022.

LORI W. ROSBRUGH
 2
STATE OF NORTH CAROLINA VERIFICATION

COUNTY OF NEW HANOVER

ANGELA OLSON-BOSEMAN, Defendant herein, being first duly sworn, deposes and
says that she is the Defendant in the foregoing action; that she has read the foregoing Motion and
knows the contents thereof; that the same is true of her own knowledge except as to those matters
therein stated upon information and belief, and as to those, she believes them to be true.

ANG

1 certify that ANGELA OLSON-BOSEMAN personally

appeared before me and that

I have personal knowledge of the identity of the principal; or

This the
10 day of
August
2022.

Notary Public Print My commission expires:

 3
STATE OF NORTH IN THE GENERAL COURT OF
CAROLINA JUSTICE DISTRICT COURT
DIVISION FILE 22 CVD 2696

COUNTY OF NEW HANOVER

Julia Boseman
Attorney: Chris
Johnson
PlaintiffJUDICIAL ASSIGNMENT
AND/OR
NOTICE OF SCHEDULING
Angela Olson-Boseman
Attorney: Lori Rosbrug}yDe
f endant
1. The District Court Judge assigned to this action is OUT OF COUNTY JUDGE
SUANN N. BECHTEL, Case Coordinator (910) 772-7102

2. This case is set for the followin urposes: APPLIES

ONLY To THE BOXES THAT ARE CHECKED
Type of Hearing Date Time Location

C] Custody Mediation Datem 1:00 ZOOM

Orientation is set for: PM Online Zoom Class
Dates ZOOM
C] Custody Mediation is set for:
Online Zoom Mediation
Child Support Hearing COURTROOM
9:30 AM New Hanover Count
Courthouse
OTemporary Custody or Date. COURTROOM
Temporary 9:30 AM New Hanover County
Visitation Hearin Courthouse
ÜPermanent Custody or [3 Dätex COURTROOM
9:30
Permanent New Hanover County
AM
Visitation Hearin Courthouse
ÜPostseparation Support or COURTROOM
Aimony Hearin 9:30 AM New Hanover County
Courthouse
Equitable Date. SUITE 419
Distribution/Alimony Status 2:00 New Hanover County
Conference PM Courthouse
 COURTROOM here.
C] Interim Distribution or 9:30 New Hanover County
Equitable Distribution Hearin AM Courthouse
Other: Def. Motion to 08/15122 9:30 COURTROOM OJJ - B
Dismiss AM New Hanover County
Courthouse

NOTICE TO PARTIES: YOU ARE DIRECTED TO APPEAR AS SCHEDULED ABOVE. THIS

SCHEDULING ORDER IS ENTERED PURSUANT
TO THE CASE MANAGEMENT PLAN OF THE
LOCAL RULES FOR THIS DISTRICT. A
FAILURE TO APPEAR AS DIRECTED MAY
SUBJECT YOU TO SANCTIONS BY THE COURT.

DATED: 9029
The party for whom this "Judicial Assignment and/or Notice of Scheduling" is issued MUST
serve a copy of this Judicial Assignment and/or Notice of Schedulin u on all arties.

CONTACT LORI WAINRIGHT AT (910) 772-7114 FOR QUESTIONS CONCERNING CUSTODY ORIENTATION OR MEDIATION
DATES

File No.

STATE OF NORTH CAROLINA In The General Court Of

NEW HANOVER Justice
County District Superior Court
Division
Name Of Plaintiff

JULIA BOSEMAN
Address CIVIL SUMMONS
3807 WRIGHTSVILLE AVE, STE 20 ALIAS AND PLURIES SUMMONS
City, State, Zip
(ASSESS FEE)
WILMINGTON NC 28403
VERSUS G.$. IA-I, Rules 3 and 4
Name Of Defendant(s) Date Original Summons Issued
ANGELA OLSON-BOSEMAN

Date(s) Subsequent Summons(es) Issued

To Each Of The Defendant(s) Named Below:
Name And Address Of Defendant
ANGELA OLSON-BOSEMAN
914 TARPON DRIVE
Name And Address Of Defendant 2
WILMINGTON NC 28409
 IMPORTANT! You have been sued! These papers are legal documents, DO NOT
throw these papers out! You have to respond within 30 days. You
may want to talk with a lawyer about your case as soon as possible,
and, if needed, speak with someone who reads English and can
translate these papers!
ilMPORTANTE! iSe ha entablado un proceso civil en su contra! Estos papeles
son documentos legales„ iN0 TIRE estos papeles!
Tiene que contestar a rnäs tardar en 30 dias. iPuede querer
consultar con un abogado 10 antes posible acerca de su caso y, de
ser necesario, hablar con alguien que lea inglés y que pueda
traducir estos documentos!
A Civil Action Has Been Commenced Against You!
You are notified to appear and answer the complaint of the plaintiff as follows:
1. Serve a copy of your written answer to the complaint upon the plaintiff or plaintiff's attorney
within thirty (30) days after you have been served. You may serve your answer by delivering a
copy to the plaintiff or by mailing it to the plaintiffs last known address, and
2. File the original of the written answer with the Clerk of Superior Court of the county named
above.
If you fail to answer the complaint, the plaintiff will apply to the Court for the relief demanded
in the complaint.
Name And Address Of Plaintiff's Attorney (if none, Address Of Plaintiff) Date Issued
Time
CHRISTOPHER DEAN JOHNSON
3807 WRIGHTSVILLE AVE
SUITE 20
WILMINGTON NC 28403
Deputy CSC [3 Assistant CSC Clerk Of Superior Court

C] ENDORSEMENT (ASSESS FEE) Date Of Endorsement Time

This Summons was originally issued on

the date indicated above and returned Signature
not served. At the request of the
plaintiff, the time within which this
Summons must be served is extended Deputy CSC Assistant CSC E] Clerk Of Superior Court
sixty (60) days.
prograrns in which most cases where the amount in
controversy is $25,000 or will be notified if this case is assigned
NOTE TO PARTIES: Many counties have MANDATORYARBITRATION for mandatory arbitration, and, if
less are heard by an arbitrator before a trial. The parties
so, what procedure is to be followed.

(Over)
AOC-CV-IOO, Rev. 4/18
0 2018 Administrative Office of the Courts
 22
File No.

STATE OF NORTH CAROLINA

NEW HANOVER In The General Court
County Of Justice District
Court Division
Name And Address Of Plaintiff 1
JULIA BOSEMAN -3 P 2: 5b DOMESTIC
3807 WRIGHTSVILLE AVE, SUITE 20 ACTION COVER
WILMINGTON NC 28 SHEET
Name And Address Of Plaintiff 2 L FILING
SUBSEQUENT FILING
Rules of Practice For
Superior and District
Courts
VERSUS Ju Demanded In Pleadin ? C] Yes
Name Of Defendant 1 Name And Address Of Attorney Or Party, If Not Represented (complete for initial
appearance or change of address) CHRISTOPHER JOHNSON
ANGELA OLSOvBOSEMAN
3807 WRIGHTSVILLE AVE, SUITE 20
914 TARPON DRIVE

WILMINGTON NC 28409
Summons Submitted WILMINGTON NC 28409
Yes O No
Name Of Defendant 2 Telephone No. Cellular Telephone No. 9108590707

9102100655
NC Attomey Bar No. Attomey E-Mail Address
30628 [email protected]
Initial Appearance in Case C] Change of
Address
Summons Submitted Name Of Firm
Yes C] No
Counsel for JOHNSON LAW
All Plaintiffs All Defendants Only (List party(ies) FAX No.
represented)
8888145455
TYPE OF PLEADING CLAIMS FOR
RELIEF
 (check all that apply) (check afl that apply)
Amended Answer/RepIy (AMND-Response) Alimony (ALIM)
C] Amended Complaint (AMND) C] Annulment (ANUL)
Answer/Reply (ANSW-Response) Child Support (CSUP)
Complaint (COMP) Cl Custody (CUST)
Confession Of Judgment (CNFJ) Divorce (DVR)
C] Contempt (CNTP) Cl Divorce From Bed And Board (DIVB)
Continue (CNTN) Domestic Violence (DOME)
C] Compel (CMPL) [S Equitable Distribution (EQUD)
C] Counterclaim vs. (CTCL) Assess Counterclaim [3 Medical Coverage (MEDC)
Costs C] Paternity (PATR)
[3 Extend Time For An Answer (MEOT-Response) [3 Possession Of Personal Property (POPP)
Modification Of Alimony (MALI) Post Separation Support (PSSU)
IA Modification Of Custody (MCUS) C] [3 Reimbursement For Public
Modification Of Support in non„lV-D Assistance (RPPA) C] Visitation
cases (MSUP) (VIST)
[A Modification Of Visitation (MVIS) Other: (specify and list separately)
C] Rule 12 Motion In Lieu Of Answer (MDLA) ATTORNEY FEES, INTERIM DISTRIBUTION, TRO
C] Sanctions (SANC)
[3 Show Cause (SHOW)
Cl Transfer (TRFR)
[3 Vacate/Modify Judgment or Order
(VCMD) Cl Other (OTHR):

Date Signature

08/03/2022
NOTE: All filings in civil actions shall include as the first page of the filing a cover sheet summa Ing the critical
elements of the filing in a format prescribed by the Administrative Office of the Courts and the Clerk of Superior Court shall require a party
to refile a filing which does not include the required cover sheet. For subsequent filings in civil actions, the filing party must include
a Domestic (AOC-CV-750), Motions (AOC-CV-752), or Court Action (AOC-CV-753) cover sheet.
AOC-CV-750, Rev. 1/14
0 2014 Administrative Office of the Courts
STATE OF NORTH CAROLINA
22 00269
COUNTY OF NEW HANOVER
6
JULIA BOSEMAN,
IN THE GENERAL COURT OF JUSTICE
Plaintiff,
t: DISTRICT COURT DIVISION
vs.

couvp{cs-c
COMPLAINT FOR •OST SEPARATION
SUPPORT, ALIMONY, EQUITABLE
DISTRIBUTION, ATTORNEY FEES, AND
TEMPORARY RESTRAINING ORDER

NOW COMES the Plaintiff, complaining of Defendant, alleges and says as follows:

JURISDICTIONAL ALLEGATIONS

1. The Plaintiff is a citizen and resident of New Hanover County, North Carolina and
has been a resident of the State of North Carolina for more than six months next
preceding the filing of this action.

2. That Defendant is a citizen and resident of New Hanover County, North Carolina
and has been a resident of North Carolina for over six months.

3. Plaintiff and Defendant were married on January 21, 2017 in Wilmington, North
Carolina. The parties separated on July 25, 2022.

4. There were no children born to the marriage.

FIRST CLAIM FOR RELIEF POST

SEPARATION SUPPORT

5. Paragraphs one through 4 above are specifically incorporated by reference as

though fully set forth herein.

1
6. Plaintiff is a "dependent spouse" within the meaning of N.C.G.S. 50-16. IA etseq.,
in that:

a. That Plaintiff is actually substantially dependent upon the Defendant for her
maintenance and support;
b. That the Plaintiff's gross monthly income is substantially less than that of
Defendant's gross monthly income;

c. That the Plaintiff is without sufficient fimds to subsist during and after the
pendency of this action and to defray the necessary legal expenses of this
action;

d. That the Defendant has the ability to contribute to the support of the
Plaintiff so that the Plaintiff can meet her reasonable needs and maintain a
lifestyle she enjoyed prior to the date of separation; and

7. That Defendant is a "supporting spouse" within the meaning of N.C.G.S.

16.1 A seq.

8. That the Plaintiff is entitled to an award of Post Separation Support from Defendant.

SECOND CLAIM FOR RELIEF

ALIMONY

9. Paragraphs one through 8 above are specifically incorporated by reference as

though fully set forth herein.

10. That, during the course of the marriage between Plaintiff and Defendant, the
Defendant, without just cause, excuse or provocation, and despite Plaintiff's efforts
to live with the Defendant in peace and harmony, has engaged in acts of marital
misconduct, as defined by the terms and provisions contained in N.C.G.S.
50-16. IA during the marriage, prior to, and on the date of separation, which
disrupted and then destroyed the marriage, in that the Defendant has offered such
indignities to the person of Plaintiff so as to render her condition intolerable and
her life burdensome, in that, upon information and belief, the Defendant:

i. The Defendant abandoned the Plaintiff; ii. Ignoring the

emotional needs of the Plaintiff; iii. Withdrawing her love

and affection from the Plaintiff; iv. That the Defendant

frequently abused alcohol;

2
 v. That the Defendant frequently used abusive language and berated the
Plaintiff; and, vi. engaging in other conduct in ways to be shown at trial.

I l. That the Plaintiff has at all times been a faithful and dutiful spouse, contributing
her efforts and income for the benefit of the family, and Defendant's marital
misconduct set forth above has been without cause or provocation by the Plaintiff.
12. Based upon all relevant factors pursuant to N.C.G.S. 50-16.3(A), the Plaintiff is
entitled to an award of alimony from the Defendant. An award of alimony to
Plaintiff is equitable, based upon all relevant factors.

THIRD CLAIM FOR RELIEF EOUITABLE

DISTRIBUTION

13. Paragraphs one through 12 above are specifically incorporated by reference as

though fully set forth herein.

14. That during the course of marriage, the parties have acquired certain property
which qualifies as "marital property" as defined by N.C.G.S. 50-20 et seq.

15. That an unequal distribution in favor of the Plaintiff would be fair and equitable in
this case.

FOURTH CLAIM FOR RELIEF

ATTORNEY FEES

16. Paragraphs one through 15 above are specifically incorporated by reference as

though fully set forth herein.

17. That the Plaintiff has insufficient means with which to defray the costs, expenses
and counsel fees as a result of this action brought in good faith by the Plaintiff, and
is therefore entitled to reasonable counsel fees, costs and expenses, pursuant to
North Carolina General Statutes.

FIFTH CLAIM FOR RELIEF

TEMPORARY RESTRAINING ORDER (RULE
65)

18. Paragraphs one through 17 above are specifically incorporated by reference as

though fully set forth herein.

19. That during the course of marriage, the parties have acquired certain property which
qualifies as "marital property" as defined by N.C.G.S. 50-20 et seq.

3
 20. That the parties are the owners of real property located at 914 Tarpon Drive,
Wilmington, NC 28409.

21. It is necessary for this Court to make an interim determination concerning said
property pending a final equitable distribution.

22. That the Plaintiff demonstrates a substantial likelihood of success on the merits and
that balancing of the equity favors the issuance of a temporary restraining order
against the Defendant and Defendants agents, prohibiting them from interfering
with the marital property. Further the Plaintiff fears that Defendant may dispose of
or hide separate property of the Plaintiff as well.

23. That in the absence of an Order, as a direct and proximate result of the Defendant's
willful, purposeful, malicious and unlawful conduct, Plaintiff has suffered, and will
continue to suffer, real and substantial damages in the loss of her ability to ensure
that the parties investment in the real property is protected.

WHEREFORE, the Plaintiff respectfully prays of this Honorable Court the following:

l . That this verified Complaint be allowed and taken as an affidavit upon which the
Court may base all of its Orders in this case;

2. That the Plaintiff be awarded Post-Separation Support for the maintenance and
support of the Plaintiff pending the final determination and adjudication or merits
of this action, the same to be allotted, paid and secured from the property, earnings
and estate of Defendant;

3. That the Plaintiff be awarded permanent Alimony for the maintenance and support
of Plaintiff, the same to be allotted, paid and secured from the property, earnings,
and estate of Defendant;

4. That the Court make an unequal distribution of all marital property in favor of the
Plaintiff;

5. That the Court order that Defendant shall be restrained and enjoined from acts of
diminution, depreciation and disposal of any and all kinds and classes of marital
properties until such time as a hearing can be held by this Court wherein equitable
distribution can properly be determined by this Court;

4
 6. That the Plaintiff be awarded a reasonable sum from the Defendant to defray the
attorney's fees, costs and expenses incurred through and including the final hearing
of these proceedings;

7. That this Honorable Court grant any such other and further relief as it may deem
just and proper in this case.

This '3 day of August, 2022

C Isto er D. Johnson
Counsel for Plaintiff
3807 Wrightsville Ave, Ste 20
Wilmington, NC 28403
Tel.: (910) 210-0655
Fax: (888) 814-5455
NC Bar #30628

5
 CERTIFICATE OF SERVICE

1, CHRISTOPHER DEAN JOHNSON, hereby certify that on this date 1 served the
foregoing Complaint upon all interested parties via certified mail, by depositing a copy
thereof in the custody of New Hanover County Sheriff, fees prepaid and addressed as
follows

Angela Olson-Boseman
914 Tarpon Drive
Wilmington, NC 28409

This@day of August, 2022

C •stopher D. Johnson
Counsel for Plaintiff
3807 Wrightsville Ave, Ste 20
Wilmington, NC 28403
Tel.: (910) 210-0655
Fax: (888) 814-5455
NC Bar #30628

6
 STATE OF NORTH CAROLINA VERIFICATION COUNTY OF NEW HANOVER

JULIA BOSEMAN, being first and duly sworn, deposes and says:

That this affiant is the Plaintiff in the above-entitled action; that this affiant has read the
foregoing Complaint and knows the contents thereof; and that the same is true of this affiant's
own knowledge, except as to those matters therein set out upon information and belief, and as to
those rnatters, this affiant believes them to be true.

Plaintiff

SWORN TO and Subscribed before me This

the 3 day of August, 2022.
Kimberly S Small
Notary Pubtic
New Hanover County
North Carolina
My Commission Ex ires 2.02—2F
Notary Public,'

My Commission expires: 202-åy

STATE OF NORTH 2 2
CAROLINA
THE GENERAL CuURT OF
JUSTICE DISTRICT COURT
COUNTY OF NEW HANOVER
DIVISION FILE 22cvd

Attorney: Christopher Johnson

Plaintiff JUDICIAL ASSIGmfENT AND/OR

SCHEDULING
Angela OlsonÆoseman
Attorney: Click here to enter text.
De f endant
1. The District Court Judge assigned to this action is 04
SUANN BECHTEL, case Coordinator (910) 772-7102

2. This case is set for the following purposes:

APPLIES ONLY TO THE BOXES THAT ARE CHECKED
Type of Hearing Date Time Location

[3 Custody Mediation Date 1:00 Online zoom class

Orientation is set for: PM

C] Custody Mediation is set for:

Dateø Time. Online zoom mediation

Date COURTROOM here.

Child Support Hearing 9:30 New Hanover Coun
AM Courthouse
Temporary Custody or COURTROOM 301
9:30
Temporary New Hanover County
AM
Visitation Hearin Courthouse
O Permanent Custody or C] Date, COURTROOM
9:30
Permanent New Hanover County
AM
Visitation Hearin Courthouse
Postseparation Support or TBD COURTROOM
9:30
Alimony Hearin New Hanover County
AM
Courthouse
Equitable TBD SUITE 300
Distribution/Alimony Status 9:30 New Hanover County
Conference AM Courthouse
Date, COURTROOM
9:30
Interim Distribution or Cl New Hanover County
AM
Equitable Distribution Hearin Courthouse
Other interim 8115122 9:30 COURTROOM OJJ BLDG
distribution, TRO AM New Hanover County
Courthouse

NOTICE TO PARTIES: YOU ARE DIRECTED TO APPEAR AS SCHEDULED ABOVE. THIS-SCHEDULING

ORDER IS ENTERED PURSUANT TO THE CASE
MANAGEMENT PLAN OF THE LOCAL RULES FOR THIS
DISTRICT. A FAILURE TO APPEAR AS DIRECTED MAY
SUBJECT YOU TO SANCTIONS BY THE COURT.

FAMILVCOUR%CASCOOR INATOR
DATED:
The party for whom this "Judicial Assignment and/or Notice of Scheduling" is issued MUST
serve a copy of this Judicial Assignment and/or Notice of Schedulin u on all arties.
CONTACT LORI WAINRIGHT AT (910) 772-7114 FOR QUESTIONS CONCERNING CUSTODY
ORIENTATION OR MEDIATION DATES