IN THE ALABAMA COURT OF CIVIL APPEALS CASE NO. CIV. 2114 MAUREENE BASS DEES, Appellant -vs- MORRIS S. DEES, Appellee. ON APPEAL FROM THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA
BRIEF OF APPELLANT
MAURY SMITH JULIA S. WATERS CHARLES M. CROOK Attorneys for the Appellant
OF COUNSEL: SMITH, BOWMAN, THAGARD, CROOK & CULPEPPER P.O. Box 78 Montgomery, Al 36101 Telephone: (205) 834-6500
ORAL ARGUMENT REQUESTED
TABLE OF CONTENTS
STATEMENT OF THE CASE THE ISSUES STATEMENT OF THE FACTS A. Morris’ Financial Condition B. The Cause Of The Breakup; Vicki Booker McGaha C. The Reconciliation D. Morris Can’t Give Up His Mistress E. Maureene Is Compelled To Seek Divorce F. Morris Sets A Trap G. Morris’ Trap Works: The Hotel Room Agreement H. Morris’ Sexual Appetite A. Dianne Hicks B. Cathy Bennett C. Judith Rogers D. Deborah Levy E. Pamela Horowitz F. Charlie Springman G. Morris’ Stepdaughter H. Morris’ Future Daughter-in-law
At the time of the divorce, Morris’ net worth, based upon his own calculations, was $3,876,029 (R. 1252, et. seq; Def. Ex. 86-87; Stipulation, R. 231). His annual income exceeds $230,000 (Def. Ex. 76-79), of which more than $160,000 annually is derived from municipal bonds upon which Morris pays no income tax (Def. Ex. 28).
B. The Cause Of The Breakup: Vicki Booker McGaha
Although Maureene was subjected to a number of degrading sexual episodes by Morris during the marriage which will be discussed hereafter, neither Morris nor Maureene ever wanted or sought a divorce until Morris established his permanent relationship with Vicki Booker McGaha in August of 1977. It was Morris’ absolute refusal to give up his mistress, whom he was supporting and whom he had made pregnant, that directly caused termination of Maureene’s marriage and forced her to institute these divorce proceedings.
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