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Internal Memo of Law

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Internal Memo of Law
MEMORANDUM

TO: Yvonne Willams
FROM: Matthew Carothers
DATE: April 18, 2013
RE: Lisa Bergan: Analysis of Credible Spousal Support and Divorce (our file 99/1278)

Issue

Is Lisa Bergan entitled to temporary spousal support while a hearing is convened? under Texas Law, considering Patrick Bergan actions to threat with the intent to inflict malicious harm, harass, or alarm and inflict undue duress on his wife, Lisa Bergan, when he emptied all their joint accounts of $250,000 and cancelled all the credit cards with an available balance of
$50,000; leaving her penniless and in care of support of their two minor children?

Brief Answer
Yes. Because Patrick Bergan took such actions against Lisa Bergan, Mrs. Bergan should be issued orders awarding temporary spousal because she is currently unemployed, and for all practicality insolvent because the actions of Patrick Bergan. Mr. Bergan is a wealthy businessmen with assets of over $750,000 There are guidelines for temporary spousal support, which she has demonstrated in the provided financial statement.

Facts
Our client, Lisa Bergan, has accused her husband, Patrick Bergan, of grievous acts on April 5, Patrick Bergan took possession of the entire matrimonial estate leaving Lisa Bergan without any financial means. Her marriage to Patrick Bergan has been for a period of fifteen years. Lisa Bergan stayed at home limiting her career opportunities while performing all the duties and responsibilities of a “stay at home mom.”Mrs. Bergan has been forced to move her sisters and brother-in-law’s residence with her two minor children because of the actions of Patrick Bergan. Lisa Bergan is seeking an immediate divorce. Mrs. Bergan alleged that, over a five-year period, Patrick Bergan abused her emotionally and verbally and recently brought charges against him for domestic violence on April 1, 2013. Mrs. Bergan's family and friends witnessed the alleged abuse. Lisa Bergan has been diagnosed

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