Dan McClain, Episcopal dirtbag, faces civil contempt charges

ELECTRONICALLY FILED COURT OF COMMON PLEAS Monday, December 11, 2023 5:46:03 AM CASE NUMBER: 2022 DR 00353 Docket ID: 616902895 Mike Foley CLERK OF COURTS MONTGOMERY COUNTY OHIO

ELECTRONICALLY FILED COURT OF COMMON PLEAS Monday, November 27, 2023 3:12:18 PM CASE NUMBER: 2022 DR 00353 Docket ID: 803536904 Mike Foley CLERK OF COURTS MONTGOMERY COUNTY OHIO

IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY,OHIO DIVISION OF DOMESTIC RELATIONS

KATHERINE McCLAIN 502 Shiloh Drive

:

Dayton, OH 45415

:

Plaintiff,

:

CASE NO.2022 DR 00353 SETS NO. 7130915221 JUDGE DENISE L. CROSS

MAGISTRATE NICHOLAS SYLVAIN

vs.

:

DANIEL McCLAIN c/o 33 W.Dixon Avenue

:

Dayton, OH 45419

: CHILD SUPPORT AND VIOLATING

MOTION TO SHOW CAUSE FOR FAILURE TO PAY TEMPORARY TEMPORARY RESTRAINING ORDER

Defendant.

:

Now comes the Plaintiff, Katherine McClain, by and through counsel, and hereby moves the Court as follows: BRANCH I

(Failure to Pay Temporary Child Support)

I. For an Order finding the Defendant, Daniel McClain, in contempt ofthis Court for his failure to pay the temporary child support as Ordered by this Court.

BRANCH H

(Violation of Temporary Restraining Orders)

II. For an Order finding the Defendant, Daniel McClaim,in contempt ofthis Court for violating the Temporary Restraining Orders issued June 16,2022 by changing and/or cancelling the homeowners and auto insurance.

BRANCH III

(Violation of Temporary Restraining Order)

III.

For an Order finding the Defendant, Daniel McClaim,in contempt ofthis Court

for violating the Temporary Restraining Orders issued June 16,2022 by incurring debt in the name ofthe Plaintiff.

BRANCHIV

(Request for Attorney Fees and Court Costs)

IV.

Plaintiff further seeks an Order of reasonable attorney fees and court costs

associated with the filing ofthis action.

BRANCH V

(Other Relief)

V.

For such other and further relief to which the Plaintiff may be entitled to in law

and/or equity.

Respectfully submitted, /s/ Trisha M. Duif

Trisha M. Duff(0052147) BIESER, GREER & LANDIS,LLP 6 N. Main Street, Ste. 400 Dayton, OH 45402 (937)223-3277 Phone (937)223-6339 Fax

tmd@biesergreer.com Attorneyfor Plaintiff, Katherine McClain

CERTIFICATE OF SERVICE

I hereby certify that on November,^^ ,2023,this document was electronically served upon the following: Adam R. Mesaros

MESAROS LAW OFFICE,LLC 7051 Clyo Road Centerville, OH 45459

arm@mesaroslaw.com Attorneyfor Defendant, Daniel McClain

/s/ Trisha M. Duff

Trisha M. Duff(0052147) Attorneyfor Plaintiff Katherine McClain

4861-9396-6480, v. 1

AFFIDAVIT

STATE OF OHIO

COUNTY OF MONTGOMERY)SS:

I, Katherine McCIain, the Afliant in the action herein, state that I have read the

accompanying pleadings and find them to be true to the best ofmy knowledge and belief.

Katherine McCiain

Sworn to before me and subscribed in my presence by the said Katherine McClain,this day ofNovember,2023.

Notary Public M. DUFF, Attorney at Law

HQtary Public, Stats of Ohio My Commlesion hat no expiration date.

Section

0. R. C.