IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

T.S., :
:
Petitioner, : CIVIL ACTION
: FILE NO.: 2023CV374532
v. :
:
I.S., :
:
Respondent. :

PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT

FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER

COMES NOW, Petitioner, T.S., hereinafter referred to as (“Petitioner”), and files this her,

URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT FOR VIOLATION OF AUTOMATIC

DOMESTIC STANDING ORDER, showing this Honorable Court as follows:

1.

This matter is before this Honorable Court on Petitioner’s Complaint for Divorce filed on

January 5, 2023.

2.

The parties’ two (2) minor children reside with the Petitioner in the parties’ marital

residence. The Respondent vacated the marital residence by his own choice in October 2023, and

began living primarily in his hometown of Chicago, Illinois1. Since leaving the marital residence,

the Respondent has not paid one cent (1¢) of child support to the Petitioner or paid for anything

1The Respondent has been exercising his parenting time with the parties’ minor children in another residence acquired
by the parties in Georgia, which is fundamentally unfurnished.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 1 of 12
for the minor children such as food, clothing, shoes, grooming, extracurricular activities, or

anything else, other than the oldest minor child’s tuition. In addition, when the Respondent left the

marital residence in October 2023, there were several ongoing construction projects at said home.

The marital residence was purchased years ago for a great deal, and the parties were aware that

major renovations were needed. The Respondent was in the process of renovating the master

bedroom, master bathroom, master closet, and the main kitchen on the main floor of the residence.

Those projects were started by the Respondent three (3) years before he left the marital home in

October 2023. Those projects were pending when this divorce action was filed.

The gate at the marital residence was broken in September, 2023. The Respondent said he

would get the gate repaired, but with no regard for the safety of the Petitioner and the parties’

minor children, when the Respondent left the marital residence in October 2023, he left the gate

unrepaired. In fact, when the Respondent left the marital home where the parties’ children reside,

he left over TWO HUNDRED THOUSAND AND 00/100 DOLLARS ($200,000.00) in renovations

incomplete. After October 2023, the Petitioner began receiving requests for payment directly from

contractors hired by the Respondent.

With respect to the other renovations needed at the marital residence, because the

Respondent was purportedly “tied up with investments”, he told the Petitioner to pay for the

additional renovations, and he would reimburse her for the costs later. Consequently, the Petitioner

paid as much money as the Respondent paid and still owes for renovation projects at the marital

home. Beginning in June 2023, the Petitioner has paid for renovations to four (4) bedrooms,

including both girls’ bedrooms, the in-law suite, the entire basement, the other five (5) bathrooms,

and the Respondent’s “man cave.” Also, before the Respondent moved out of the marital residence

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 2 of 12
in October 2023, the Petitioner finished paying for the renovation to the driveway at the marital

home. The Petitioner has also paid to add an elevator installed in the residence three (3) years ago.

All of the Respondent’s renovations were started three (3) years ago, before this divorce

action was filed. The Petitioner has maintained the status quo and paid for all projects commenced

by her since June, 2023. Conversely, the Respondent has violated the STANDING ORDER and has

left all of the renovations that he started unpaid. The Respondent has not paid any amount for the

construction projects that he started years ago when he left the marital residence where the minor

children reside in October 2023.

3.

The Petitioner found it odd that the Respondent demanded parenting time at the November

30, 2023, 120-Day Status Conference. The Respondent did not spend significant time with the

parties’ minor children when the Respondent lived in the marital residence with the Petitioner and

the girls. The Petitioner had already offered the Respondent more parenting time than the Court

awarded on November 30, 20232, such as asking the Respondent to spend time with the minor

children during Thanksgiving, Christmas, and the oldest daughter’s birthday. The Petitioner

always initiated opportunities for the girls to spend time with their father.

2 The Court may recall that the Respondent insisted on having the minor children with him during the weekend of
December 1-3, 2023, claiming that he had made plans for the parties’ minor children. The Petitioner had already purchased
first-class airline tickets for herself and the parties’ minor child in the approximate amount of $8,000 for the minor children
to attend an event with their mother where the Petitioner was being honored for her work. The Court decided that the
Respondent could have the children with him since his lawyer represented that Respondent had made plans for the girls.
In actuality, when the Petitioner FaceTimed the parties’ minor children over that first weekend in December 2023, the
minor children were jumping up and down on a brand-new air mattress, watching a brand-new television in one of the
other residences purchased during the parties’ marriage. Said residence was fully renovated but had no furniture because
the Petitioner’s parents had recently relocated from the property, and they removed their personal furniture and furnishings
when they moved out. The Respondent had no plans for the girls. Instead, the Respondent intentionally misrepresented
to the Court that he had plans for the minor children during the weekend of December 1-3, 2023, so that the children
would not have the opportunity to witness their mother receiving an award.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 3 of 12
 Despite the Respondent’s insistence on having an Order entered for alternating weekend

parenting time at the 120-Day Status Conference, the Petitioner did not demand child support from

the Respondent at that same 120-Day Status Conference because the Petitioner had sincerely hoped

that the parties would be able to resolve this divorce matter before December 31, 2023. A Consent

Order was entered on November 30, 2023 pertaining to Respondent’s temporary parenting time

with the parties’ minor children. Much to the Petitioner’s dismay, the Respondent appears to want

to drag out this case through trial instead of working to resolve the divorce amicably with the

Petitioner.

4.

In paragraph 6 of the AUTOMATIC DOMESTIC STANDING ORDER of this Court, it states that,

“The parties to a divorce or separate maintenance action are prohibited from disconnecting, or

causing the disconnection of water, gas, electricity or any other utility services from the marital

residence.” See, Exhibit “A” (Standing Order) attached hereto and incorporated herein by this

reference.

5.

The Summons, Complaint for Divorce, and AUTOMATIC DOMESTIC STANDING ORDER were

all emailed to the Respondent by counsel for the Petitioner on January 11, 2023. See, Exhibit “B”

(e-mail to Respondent) attached hereto and incorporated herein by this reference.

6.

The Respondent’s Acknowledgement of Service was filed with the Clerk of the Court on

January 14, 2023. See, Exhibit “C” (Acknowledgement of Service) attached hereto and

incorporated herein by this reference.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 4 of 12
 7.

On or about October 30, 2023, the Respondent’s brother notified the Petitioner’s CPA via

text message that the Respondent would be disconnecting all utility services from the marital

residence. Immediately, the Petitioner’s CPA responded via text message that based upon the

Petitioner’s information and belief, the utility services at the marital residence were not supposed

to be disconnected until the divorce was finalized.

8.

On December 3, 2023, the Respondent’s brother notified the Petitioner’s CPA again via

text message that the Respondent will be disconnecting all utility services from the marital

residence after January 1.

9.

Not knowing the law, on December 5, 2023, Petitioner’s CPA asked Respondent’s brother

which utilities at the marital residence would be disconnected, and Respondent’s brother provided

a list.

10.

On December 6, 2023, Petitioner’s attorney sent an e-mail to Respondent’s attorney to

remind his client that the Respondent has to continue to pay for all of the marital expenses that he

was paying when this divorce was filed, and that it would be a violation of the STANDING ORDER

if he does not pay. See, Exhibit “D” (e-mail to Respondent’s attorney) attached hereto and

incorporated herein by this reference.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 5 of 12
 11.

After January 1, 2024, Petitioner thought that the Respondent was at least going to continue

to pay for all utility services at the marital residence per the STANDING ORDER. However, on

January 23, 2023, the Petitioner discovered that the cable and Wi-Fi at the marital residence was

no longer working. Petitioner attempted to obtain additional information from the cable and Wi-

Fi service provider regarding this matter, but to no avail as the account is listed in Respondent’s

name. Then, on the morning of January 24, 2024, the parties’ minor children discovered that the

water had been disconnected at the marital residence.

12.

The minor children receive private, on location education in Atlanta and in Los Angeles.

When the minor children are in Atlanta (or Los Angeles), the teacher comes to the marital

residence to teach the children their school lessons each day. Consequently, on January 24, 2024,

the Petitioner and the parties’ minor children had to travel to the Petitioner’s mother’s residence

in order to bathe, eat breakfast, and get ready for the minor children to receive their private school

lessons for the day. Later that day, the Petitioner paid to have the water utility service restored.

However, as of the date of the filing of this Motion, water service has not been physically restored

by the service provider yet. The Petitioner also discovered on January 24, 2024, that the

Respondent had not paid the water bill at the marital residence for several months.

13.

Upon discovering that the Wi-Fi and cable were inoperable, and the water had been

disconnected, the Petitioner’s CPA texted Respondent’s brother3 on January 24, 2024, to advise

3 The Respondent’s brother handles much of the Respondent’s personal affairs on Respondent’s behalf.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 6 of 12
that the water at the marital residence was disconnected. Respondent’s brother responded that the

Respondent advised him to transfer everything to Petitioner’s name as of January 1, 2024, which

is a clear and direct violation of the AUTOMATIC DOMESTIC STANDING ORDER. See Exhibit “E”

(text message to Respondent’s brother) attached hereto and incorporated herein by this reference.

14.

The Respondent received an e-filed copy of the AUTOMATIC DOMESTIC STANDING ORDER

on January 11, 2023, directly from Petitioner’s counsel. See, Exhibits “A” and “B.” The

Respondent was put on notice again about this Court’s AUTOMATIC DOMESTIC STANDING ORDER

on December 6, 2023, when the Petitioner’s counsel sent an e-mail to Respondent’s attorney

reminding him that there is an AUTOMATIC DOMESTIC STANDING ORDER in this case. See, Exhibit

“D.” Nonetheless, the Respondent has willfully and with no regard for the parties’ minor children,

violated said STANDING ORDER by causing the disconnection of water, cable and Wi-Fi at the

marital residence where the minor children reside. The Petitioner anticipates that the gas and

electricity at the marital residence will be disconnected next by the Respondent.

15.

It is critical to note that the Respondent elected to leave the marital residence, where the

minor children reside, on his own volition in October, 2023, and then complained of a lack of

parenting time at the 120-Day Status Conference held on November 30, 2023. Petitioner suspects

that the utilities have not been disconnected where the Respondent is currently living; yet, the

Respondent has no regard for the living conditions of the parties’ minor children.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 7 of 12
 16.

Additionally, on some of the occasions when the Petitioner has offered the Respondent

extra parenting time with the parties’ minor children that over and above what is outlined in the

Consent Order in this case, the Respondent has accepted. On other times when the Petitioner has

offered the Respondent extra parenting time with the parties’ minor children, the Respondent has

either accepted the extra parenting time, and then failed to show up, or the Respondent made

excuses as to why he could not see the minor children. The fact that the Respondent intentionally

caused the water service to be disconnected at the marital residence where the parties’ minor

children reside is reprehensible, especially since the Respondent does not pay any amount

whatsoever for child support for the parties’ minor children.

17.

The Respondent is required to abide by the AUTOMATIC DOMESTIC STANDING ORDER of

this Court; yet Respondent believes the rules of this Court simply do not apply to him. Respondent

is in willful contempt of said STANDING ORDER by “causing the disconnection of water… or any

other utility services from the marital residence.” The Respondent clearly is not concerned about

the well-being of the parties’ minor children; otherwise, he would not have blatantly violated the

Court’s STANDING ORDER.

18.

Furthermore, Paragraph 4 of the AUTOMATIC DOMESTIC STANDING ORDER specifically

states, “Each party is hereby enjoined and restrained from doing any act injuring, maltreating,

vilifying, threatening, molesting, or harassing the adverse party, the child(ren)of the parties, or a

family member of the adverse party.” (Emphasis added.).

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 8 of 12
 19.

On January 24, 2024, for no apparent reason, the Respondent made an unprovoked subliminal

post on his Instagram story which stated “10 TOES CHIN UP. YOU AIN’T THE FIRST OR LAST

SHORDY”. (Emphasis added). See, Exhibit “F” attached hereto and incorporated herein by this

reference. Petitioner is aware that these subliminal social media postings are indirectly related to

Petitioner and the parties’ ongoing divorce litigation. Since the Respondent made the parties’ divorce

public in November 2023, he has intentionally posted other subliminal messages about either the

Petitioner or this divorce action on his social media pages and stories knowing that the blogs will pick

up and report the Respondent’s posts immediately. The Respondent, who has 2.4 million followers

himself, has purposefully posted these messages to vilify the Petitioner so that the posts will get picked

up by the social media blogs.

In fact on January 24, 2024, the social media blog, The Shade Room (@theshaderoom), which

has 28.9 million followers, reposted Respondent’s Instagram story, and almost 125,000 of their

followers liked the repost. See, Exhibit “G” (The Shade Room repost) attached hereto and

incorporated herein by this reference. Respondent’s post went viral just. There were negative

comments about the Petitioner made, after the Shade Room reposted the Respondent’s story. If the

Respondent was not directing his Instagram story at the Petitioner, he should have cleared up any

ambiguity instead of allowing his Instagram story to go viral.

Further, on January 24, 2024, 19 minutes after the Shade Room repost, the Respondent

posted another unprovoked subliminal message on Twitter (“X”) and reposted the message in his

Instagram story, which stated “There’s no peace till after the war- Kobe Bryant.” See, Exhibit “H”

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 9 of 12
attached hereto and incorporated herein by this reference. Clearly, the Respondent enjoys publicly

treating the Petitioner cruelly.

20.

Respondent’s constant vilification of Petitioner on his social media platform is a blatant

attempt to publicly slander, defame and harass Petitioner, which is in clear violation of this Court’s

STANDING ORDER. Respondent’s actions were unwarranted and unprovoked, further evidencing

Respondent’s vindictive nature.

21.

Although both parties are public figures, the Petitioner has worked aimlessly to resolve this

matter as amicably and as privately as possible to protect the parties’ minor children. The Petitioner

has shown the Respondent much grace throughout this entire litigation process. However, the grace

extended by the Petitioner to Respondent has been thwarted by the Respondent’s intentional and

malicious efforts to vilify the Petitioner, and diminish her name, reputation, and brand, which are all

in direct violation of the AUTOMATIC DOMESTIC STANDING ORDER. The Petitioner does not deserve

to have her private life splattered publicly all over the social media blogs by the Respondent.

22.

Petitioner further shows this Honorable Court that Georgia law gives trial courts the power to

inflict punishment for contempt of court when a person’s misbehavior obstructs the administration of

justice. O.C.G.A. § 15-1-4(a)(1). Further, courts of this State may hold a person in contempt when

they disobey an order of the court. O.C.G.A. § 15-1-4(a)(3). Moreover, trial courts can impose fines

of up to ONE THOUSAND AND 00/100 DOLLARS ($1,000.00) and imprisonment for up to twenty (20)

days for each violation of a court order. O.C.G.A. § 15-6-8(5).

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 10 of 12
 23.

Because of Respondent’s failure to comply with this Court’s AUTOMATIC DOMESTIC

STANDING ORDER, this Honorable Court should find Respondent in willful contempt. The Petitioner

will change all of the household utilities into her name since the Respondent has already violated the

STANDING ORDER. Petitioner moves this Honorable Court to order that Respondent purge himself of

contempt immediately by requiring the Respondent to start paying monthly child support for the

support and maintenance of the parties’ minor children beginning on February 1, 2024, in the amount

to be determined by this Honorable Court since the Respondent has (1) abandoned his requirement to

maintain the utilities at the marital residence, (2) failed to maintain the status quo with respect to the

previously started constructions projects at the marital home, and (3) continued to post on social media

about the Petitioner and this divorce action.

24.

Petitioner moves this Honorable Court to fine Respondent One Thousand And 00/100 Dollars

($1,000.00) for each of his three (3) violations of this Court’s AUTOMATIC DOMESTIC STANDING

ORDER as a punishment for Respondent’s contemptuous behavior as permitted by O.C.G.A. § 15-6-

8(5).

25.

Petitioner moves this Honorable Court to award any and all necessary and reasonable

attorney’s fees and costs of litigation incurred by Petitioner in an amount to be proven at a hearing on

this matter pursuant to O.C.G.A. §§ 19-6-2, 9-15-14(b), and any other applicable statute.

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 11 of 12
 26.

Petitioner hereby reserves the right to amend this URGENT MOTION FOR CONTEMPT AGAINST

RESPONDENT FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER based upon

Respondent’s further willful contempt of this Court’s AUTOMATIC DOMESTIC STANDING ORDER.

WHEREFORE, Petitioner prays that:

(a) Process issue;

(b) A hearing is set;

(c) Respondent is found in willful contempt of this Court’s AUTOMATIC DOMESTIC

STANDING ORDER;

(d) This Honorable Court order the Respondent to immediately purge himself of his
contempt by requiring the Respondent to start paying monthly child support for the
support and maintenance of the parties’ minor children beginning February 1, 2024, in the
amount to be determined by this Honorable Court.;

(e) This Honorable Court fine Respondent ONE THOUSAND AND 00/100 DOLLARS
($1,000.00) as a punishment for each contempt of this Honorable Court’s AUTOMATIC
DOMESTIC STANDING ORDER as permitted by O.C.G.A. § 15-6-8(5);

(f) This Honorable Court order Respondent to pay any and all necessary and reasonable
attorney’s fees and costs of litigation incurred by Petitioner, pursuant to O.C.G.A. §§ 19-
6-2, 9-15-14(b) and any other applicable statute in an amount to be proven at a hearing on
this matter; and

(g) This Honorable Court award Petitioner such other and further relief as it may deem just
and equitable.

RESPECTFULLY SUBMITTED, this 26th day of January, 2024.

3212 Northlake Parkway, N.E., THE LAW OFFICE OF

Box 450929 TANYA MITCHELL GRAHAM, P.C.
Atlanta, GA 31145 Attorneys for Petitioner
770.492.9013 Telephone
770.492.9017 Facsimile

_____________________________
Tanya Mitchell Graham, Esquire
Georgia Bar No. 513595

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER
Page 12 of 12
Exhibit “A”
 Fulton County Superior Court
***EFILED***LW
Date: 1/5/2023 4:39 PM
Cathelene Robinson, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
FAMILY DIVSION

T.S.
Civil Action 2023CV374532
No.
Petitioner
FILED JN OFFICE
and
I.S.
———
Aye
DEPUTYCLERK, SUPERIOR COURT
Respondent FULTON COUNTY, GA

A080 - Ex-OUUIO
AUTOMATIC DOMESTIC STANDING ORDER

1.

This order applies to all cases which are filed in the Family Division ofthe Superior
Court of Fulton County and shall remain in effect up through the entry of the Final Order in this
case. This Order contains provisionsthat regulate the parties’ conduct during the pendency of
this case. The parties shall not act in a manner that would violate any provisionsset out in this
Order. Theparties shall further be prohibited from instructing, encouraging, or causingothers to
act in a manner that wouldviolate the termsandspirit of this Standing Order.

Eachparty is hereby required to complete the Domestic Intake Worksheet andto bringit
to the 30-day status conference.

3.

All parties to a case involving a question of custody of minor child(ren) (excluding

contemptor modification actions) are hereby enjoined and restrained from causing or permitting
the minor child(ren) ofthe parties to be removed from the State of Georgia. The only exception
to this prohibition shall be for vacations or excursions outside of the State of Georgia for a period
not to exceed fourteen (14) days. During the above referenced fourteen (14) day period the
child(ren) shall not be removed from the United States. Customary activities/events, such as
campattendance or boarding schoolshall also serve as exceptionsto the restraints concerning the
removal ofthe children from the State of Georgia. In the event the child(ren) are removed from
the State of Georgia in accordance with the terms of this paragraph advanced written notice must
be provided to the opposingparty outlining the dates oftravel, the travel destination(s), and
contact number(s) where the child(ren) will be staying.
 4.

Each party is hereby enjoined and restrained from doing anyactinjuring, maltreating,
vilifying, threatening, molesting, or harassing the adverseparty,the child(ren)ofthe parties, or a
family memberof the adverse party.

5.

Each party to a divorce or separate maintenance action is hereby enjoined and restrained
from selling, encumbering,trading, contractingto sell, or otherwise disposing or removing from
Fulton County, and of the property belongingto the parties except in the ordinary course of
business.

6.

Theparties to a divorce or separate maintenanceaction are prohibited from

disconnecting, or causing the disconnection of water,gas,electricity or any otherutility services
from the marital residence.

Te

Eachparty to a divorce,initial custody determination or separate maintenanceaction is

hereby enjoined and restrained from altering, suspending or terminating any insurance coverage
in effect as of thedate of the filing of this action, including, but not limited to, health insurance,
supplemental health insurance, dental insurance, vision insurance, automobile insurance, long
term disability insurance, short term disability insurance,life insurance (whole life and/or term),
and/or changing any beneficiary designations on anylife insurance policy(ies).

8.

Eachparty to a case involving a question of custodyorvisitation of minor child(ren) (not

contempt or uncontested modification actions) is required to attend the “Families in Transition”
Seminar. Failure to complete the seminar in a timely manner may subject the party to contempt
or other sanctions.

9.

Whena civil action is assigned to the Family Division of the Superior Court of Fulton
County with an Acknowledgmentof Service, the Docket Clerk will attach a copy of this Order to
the original Petition, give or mail a copy of this Orderto the attorney or personfiling the Petition
and provide a second copy to the attorney or person filing the Petition with instructions to serve
the Respondent with the copy. Note: The Standing Order should beattachedtoallinitial filings
(except contempt and post judgment matters).
 10.

All attorneys entering an appearancein the Family Division of the Superior Court of
Fulton County shall attend at least one seminar which has been authorized by this Court as a
sufficient informational seminar or shall observeat least one authorized reproduction of the same
orshall read the entire materials from such a seminar.

11.

All parties and attorneys entering an appearancein the Family Division of the Superior
Court shall abide by the rules of the Family Division as promulgated by this Court. Said rules
are available on the Family Division website: www.fultoncourt.org/family. A hard copy ofall
such rules shall be madeavailable by the Clerk upon request.

12,

This Order shall apply to all domestic civil actions (as defined by O.C.G.A. § 19-1-1)
whichare assigned to the Family Division of the Superior Court of Fulton County and shall be
the Standing Order until further order of this Court.

13.

Failure to follow a Court order, unless substantially justified, may result in sanctions or
penalties as provided bystatute, rule or authority of the Court, including a finding of contempt
by the Court; taxation of costs or attorneys’ fees; and/or the imposition of monetary or other
sanctions.

So ordered the 4 Au, of eae 2020.

Honorable Christopher S. Brasher, Chief Judge

Atlanta Judicial Circuit
Exhibit “B”
1/24/24, 12 29 PM The Law Office of Tanya Mitchell Graham, P C Mail T S v I S , Fulton County Superior Court, CAFN 2023CV374532

7 attachments
2022 Complaint for Divorce.pdf
461K
2022 Verification (Wife to sign).pdf
148K
SUMMONS.pdf
143K
General-Civil-and-Domestic-Relations-Filing-Information-Form.pdf
123K
Automatic Domestic Standing Order (Revised 2020).pdf
859K
2023 - Acknowledgement of Service.pdf
32K
01-11-2023 - 550 Letter to Iman Shumpert.pdf
121K

https //mail google com/mail/u/1/?ik 35ec5148bf&view pt&search all&permmsgid msg a r302927602032334128&simpl msg a r302927602032334128 2/2
Exhibit “C”
 CLERK OF SUPERIOR COURT
FULTON COUNTY, GEORGIA
2023CV374532
JAN 14, 2023 06:05 PM

14th January

14th
January

, DeKalb County
My Commission expires on 01-24-2026
Exhibit “D”
1/23/24, 10 11 PM The Law Office of Tanya Mitchell Graham, P C Mail Latest Article Teyana Taylor’s Estranged Ex Iman Shumpert Awarded Tem

Tanya Mitchell Graham, Esquire

Latest Article - Teyana Taylor’s Estranged Ex Iman Shumpert Awarded Temporary

Parenting Time With Their Daughters
Tanya Mitchell Graham, Esquire Wed, Dec 6, 2023 at 6:23 PM
To: "Stephen C. Steele"
Cc: Alicia Holiday , Attorney Kamali Thompson >, Carolyn Faison
, Karchona Johnson JD , Lisa Belcher >, Marissa Denson
< , "Mikayla T. Ross" >, "Monique B. Shackleford" >,
"Shantanece L. Ellis, Esquire" , Susan Tibbitts

Greetings.

Sorry for the late reply. I’ve been in court and mediation.

We are trying to put together another settlement offer to present to your client. In the meantime, please kindly your client
that he has to continue to pay for all of the marital expenses that he was paying when this divorce was filed.

Mr. Shumpert has informed our Client’s CPA that he will no longer pay for the taxes on the Miami condo. That would be a
violation of the Standing Order if he does not pay.

Hopefully; we can arrive at a full settlement before the end of the year and this divorce can be finalized before December
31st.
[Quoted te t hidden]

https //mail google com/mail/u/1/?ik 35ec5148bf&view pt&search all&permmsgid msg a r861301643962515812&simpl msg a r861301643962515812 1/1
Exhibit “E”
Exhibit “F”
Exhibit “G”
Exhibit “H”
 IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA

T.S., :
:
Petitioner, : CIVIL ACTION
: FILE NO.: 2023CV374532
v. :
:
I.S., :
:
Respondent. :

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing with a copy of the foregoing
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT FOR VIOLATION OF

AUTOMATIC DOMESTIC STANDING ORDER via statutory electronic service, pursuant to O.C.G.A.
Section 9-11-5(b) as follows:
STEPHEN C. STEELE, ESQ.
326 Roswell Street, Suite 100
Marietta, GA 30060
[email protected]

This 26th day of January, 2024.

3212 Northlake Parkway, N.E. THE LAW OFFICE OF

Box 450929 TANYA MITCHELL GRAHAM, P.C.
Atlanta, GA 31145 Attorneys for Petitioner
770.492.9013 Telephone
770.492.9017 Facsimile

___________________________________
Tanya Mitchell Graham, Esquire
Georgia Bar No. 513595

T.S. v. I.S.
CAFN: 2023CV374532
Fulton County Superior Court
Certificate of Service
PETITIONER’S URGENT MOTION FOR CONTEMPT AGAINST RESPONDENT
FOR VIOLATION OF AUTOMATIC DOMESTIC STANDING ORDER