IN THE CHANCERY COURT FOR KNOX COUNTY, TENNESSEE

TODD BIBLE,

Petitioner/Counter-Respondent,

v. Docket No. 147098-1

TCSES No. 000870974
KIMBERLY MAPLES,

Respondent/Counter-Petitioner.

ANSWER TO PETITION AND COUNTER-PETITION

Comes now the Respondent, Kimberly Maples, by and through

counsel, and for her Answer to the Petition to Modify Child Support would say as

follows:

1. The allegations contained in paragraph 1 are admitted;

2. The allegations contained in paragraph 2 are denied and strict proof is

demanded;

3. The allegations contained in paragraph 3 are denied and strict proof is

demanded;

4. The allegations contained in paragraph 4 are denied, and strict proof is

demanded;

5. The allegations contained in paragraph 5 are denied and strict proof is

demanded; and

6. All other allegations not heretofore answered, explained or denied, are

hereby denied.

NOW, having fully answered, the Respondent, as Counter-Petitioner,

would show as follows:

 1. The Counter-Respondent owes the Counter-Petitioner child support of

at least $27,980.00, plus interest.

2. The Counter-Respondent owes the Counter-Petitioner for health

insurance premiums and doctor bills for the parties’ minor children.

3. The Counter-Respondent is willfully and voluntarily under-employed

and has the ability to earn more money than he presently earns.

4. There has been a material change in circumstances which requires an

increase in child support.

5. The Counter-Petitioner is in contempt for his failure to pay child

support and perform other obligations under the Final Decree and Permanent

Parenting Plan entered in this cause.

WHEREFORE, RESPONDENT/COUNTER-PETITIONER PRAYS

THAT:

A. The Complaint filed by the Petitioner be dismissed;

B. The Counter-Petitioner be awarded a judgment against the Counter-

Respondent in the amount of child support in arrears, plus interest on that amount;

C. The Counter-Petitioner be awarded a judgment against the Counter-

Respondent in the amount of insurance premiums and doctor bills in arrears;

D. The Counter-Respondent be held in civil contempt of Court and

incarcerated until the amount of child support that is in arrears, plus interest, is

paid in full to the Counter-Petitioner;

 E. In the alternative, the Counter-Respondent be held in criminal contempt

of Court and incarcerated for the maximum period of time allowed by Tennessee

law;

F. The Court impute a higher income to the Counter-Respondent and the

Counter-Petitioner be awarded an increase in child support;

G. That Court award the Counter-Petitioner attorney fees; and

H. That the Court award the Counter-Petitioner such other, further, general

and special relief to which she may be entitled.

This the day of , 2009.

KIMBERLY MAPLES

JUDKINS LAW FIRM

_______________________________
BY: JOE R. JUDKINS (BPR No. 005548)
Attorney for Respondent
1143 Oak Ridge Turnpike, Suite 202
Oak Ridge, Tennessee 37830
(865) 482-7877

OATH
STATE OF TENNESSEE
COUNTY OF ANDERSON

Kimberly Maples, first being duly sworn, says that she has read the
foregoing Answer to Petition and Counter-Petition and knows the contents
thereof, and that the same are true of her own knowledge, except as to those
matters therein stated to be on information and belief, which she believes to be
true.

___________________________________
KIMBERLY MAPLES

SUBSCRIBED AND SWORN to before me this the ________ day of

_______________________, 2009.

NOTARY PUBLIC
My Commission Expires: . SEAL

CERTIFICATE OF SERVICE
The undersigned attorney hereby certifies that this is a true and exact copy
of the Answer to Petition and Counter-Petition has been served upon T.Scott
Jones, Attorney for the Petitioner, Suite 210, Regas Building, 318 Gay Street,
Knoxville, Tennessee 37917, by first class United States mail, postage prepaid.
This the ________ day of __________________, 2009.

______________________________
JOE R. JUDKINS
Attorney for Respondent