Laurie Baird Gaffney, ISB #5981

Tracy W. Gorman, ISB #7776

Challis Allen McNally, ISB #9558
GAFFNEY & GORMAN
591 Park Avenue, Suite 202
Idaho Falls, Idaho 83402
Telephone: (208) 524-6655
Facsimile: (208) 524-6301
Attorney for Petitioner

DISTRICT COURT SIXTH JUDICIAL DISTRICT

BANNOCK COUNTY IDAHO
JAMES KEITH GUTHRIE, JR.,
Petitioner,

Case No.: CV-15-

vs.
SUMMONS
BARBARA ANN GUTHRIE
Respondent.
NOTICE: YOU HAVE BEEN SUED BY THE ABOVE-NAMED PETITIONER.
THE COURT MAY ENTER JUDGMENT AGAINST YOU WITHOUT FURTHER
NOTICE UNLESS YOU RESPOND WITHIN TWENTY (20) DAYS. READ THE
INFORMATION BELOW.
TO: BARBARA ANN GUTHRIE
You are hereby notified that in order to defend this lawsuit, an appropriate written
response must be filed with the above designated court 624 E Center, Pocatello, ID 83201
and (208) 236-7333 within 20 days after service of this Summons on you. If you fail to
so respond the court may enter judgment against you as demanded by the Petitioner in the
Petition.
A copy of the Petition is served with this Summons. If you wish to seek the
advice of or representation by an attorney in this matter, you should do so promptly so
that your written response, if any, may be filed in time and other legal rights protected.

Summons

An appropriate written response requires compliance with Rule 10(a)(l) and other
Idaho Rules of Civil Procedure and shall also include:
a) The title and number of this case.
b) If your response is an Answer to the Petition, it must contain admissions or
denials of the separate allegations of the Petition and other defenses you may
claim.
c) Your signature, mailing address and telephone number, or the signature,
mailing address and telephone of your attorney.
d) Proof of mailing or delivery of a copy of your response to Petitioner's
attorney, as designated above.
To determine whether you must pay a filing fee with your response, contact the
Clerk of the above-named court.
Dated this"^ day of August, 2015.

Court

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Summons

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Laurie Baird Gaffney, ISB #5981

Tracy W. Gorman, ISB #7776
Challis Allen McNally, ISB #9558
GAFFNEY & GORMAN
591 Park Avenue, Suite 202
Idaho Falls, Idaho 83402
Telephone: (208) 524-6655
Facsimile: (208) 524-6301

2515 AL'G b /

Steve

Attorney for Petitioner

DISTRICT COURT SIXTH JUDICIAL DISTRICT

BANNOCK COUNTY IDAHO
JAMES KEITH GUTHRIE, JR.,
Petitioner,
vs.

PETITION FOR DIVORCE

BARBARA ANN GUTHRIE

Fee Category: Bl
Filing Fee: $207.00

Respondent.
Petitioner, through counsel of record, Laurie Baird Gaffney, petitions of
Respondent as follows:
1.

That Petitioner and Respondent are now and have been, for more than six

weeks preceding the commencement of this action, bona-fide residents and inhabitants of
the State of Idaho.
2.

That Petitioner and Respondent married on November 13,1976, in

McCammon, Idaho and ever since said date have been and now are husband and wife.
3.

That Petitioner and Respondent are not members of the United States

Armed Forces.
4.

That grounds for divorce exist based upon Idaho Code 32-616,

Irreconcilable Differences, so as to make it necessary that said marriage not be continued,

but that instead it should be dissolved for the interest of the Petitioner.
5.

That there are no minor children born of this marriage.

Petition for Divorce

6.

That the parties should be awarded and confirmed his or her separate

property.
7.

That during the parties' marriage they have acquired community property,

which should be equally divided between the parties.

8.

That during the parties' marriage they have acquired community debt; and

that debt should be equally divided between the parties. Any debts incurred after
separation should be assigned to the party who incurred it.
9.

The Petitioner requests attorney's fees and costs from the Respondent,

pursuant to Idaho Code 32-704, 32-705, 12-120, 12-121 and I.R.C.R 54 et seq., if
this matter is contested.
PRAYER FOR RELIEF
WHEREFORE, Petitioner prays for the Judgment of this court as follows:
1.

For an Order granting the Petitioner a divorce against Respondent on

grounds of Irreconcilable Differences.

2.

For an Order awarding the parties his or her separate property.

3.

For an Order awarding the parties his or her share of the community

property.
4.

For an Order awarding the parties his or her share of the community debt

acquired.
5.

For an Order requiring Respondent to pay Petitioner's attorney fees and

costs incurred in bringing this matter, pursuant to Idaho Code 32-704, 32-705, 12120, 12-121 and I.R.C.P. 54 et seq., if this matter is contested.
6.

For such other relief as the Court deems just and equitable.

Dated this ^f day of August, 2015.

{LLULL

aurpe Baird Carney, ISB*5981

'GAFFNEY & GORMAN
Attorney for Petitioner
Petition for Divorce