That Defendant has changed the locks to said business and has effectively ejected Plaintiff from her own business. Inventory is being removed by way of sale, yet no deposits are being made, nor records kept. That Defendant is living in the store and Plaintiff is informed and believes that she is entitled to this Court's Order requiring Defendant to remove himself from the store and to provide a full accounting to Plaintiff of all transactions, and to provide Plaintiff with all business and tax records, and to deliver to Plaintiff all money and other assets of the business, and restrain Defendant from returning to or interfering with the store, pendente lite and permanently. That Defendant has been diagnosed as bi-polar and pyscho genetic excoriation disorder. Defendant is also willfully refusing to take the medication prescribed by his doctor.
Defendant is in a manic episode with paranoid ideations.
Plaintiff seeks an equitable allocation, division, and distribution of all marital property and debts, both pendente lite and permanently. That Plaintiff is informed and believes that each party should be solely responsible for that debt acquired by each individual party after the commencement of this action, both pendente lite and permanently. That Plaintiff is employed, however, she has had the full expense of the household bills and the care of the parties' minor child since Defendant departed from the marital home and she is without funds to pay her attorney and seeks an award of attorney fees and the costs of this action from the Defendant and that he be ordered and required by this Court to pay all of the Plaintiffs attorney's fees and lawsuit costs and expenses, pendente lite and permanently. That Plaintiff seeks an order granting discovery in this matter. For an equitable division of all property and debt of the parties as outlined hereinabove, further, that both parties be restrained and enjoined from disposing of any of the marital assets, pendente lite and permanently.