Asking for a Payment Schedule

Looking for some reasonableness, finding none ...

If anyone out there cares to send the judge you comments about this, his address and phone numbers are:

Judge Paul McGhee
P.O. Box 426
Dexter Mo. 63841
314-624-2101

            IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI
                         FAMILY COURT DIVISION

VICKI LORRAINE PERKEL,               )
                                     )
                 Petitioner,         )  Case No. 194DR3198
vs.                                  )
                                     )
MARC PERKEL                          )
                                     )
                 Respondent,         )


                    MOTION TO SUPPLEMENT JUDGEMENT
                    ------------------------------

COMES NOW, Respondent Marc Perkel and asks the Court to supplement the
final divorce order to add a payment schedule for the $60,000 to the
Petitioner and the $12,500 to Petitioner's attorneys.


1) At trial, Respondent's records indicated that his cash assets were
   only a few thousand dollars and Petitioner didn't dispute this.
   Respondent's assets are all tied up in various loans and respondent
   does not have the ability to borrow the money to pay the judgement.
   Petitioner did not dispute at trial Respondents testimony that
   Respondent does not have the ability to borrow money.

   Without a payment schedule, the Respondent would be forced to take
   bankruptcy. Assuming that this is not the intent of the Court it is
   only reasonable that a payment schedule be required.

2) If the Petitioner disputes a payment schedule, Petitioner should have
   to state that Respondent has concealed $72,500 of liquid assets from
   the Court or that Respondent concealed he had the ability to borrow
   $72,500. If the Petitioner isn't willing to make these accusations on
   the record, Petitioner should not be allowed to dispute the request
   for a payment schedule.

3) Respondent's income tax statements indicated that his 1994 and 1995
   before tax income was about $50,000 each year. Petitioner did not
   dispute these tax returns. Respondent at trial provided evidence
   that his income was projected to drop 20% this year and Petitioner
   did not dispute this. Respondent therefore requests the Court to set
   a payment schedule that is affordable to Respondent based on his
   income tax returns presented at trial.

4) In light of the $1000 per month maintenance order, Respondent request
   the Court to start the payment schedule on September 1, 1997.


WHEREFORE, Respondent prays the Court will grant the Respondent a
payment schedule that he can realistically comply with considering
Respondents income and expenses.



---------------------------------------
Marc Perkel * Respondent