2. Both Plaintiff and Respondent have employment scheduled in Washington DC, and cannot miss this work without serious financial consequences and costs.  Each hearing in Iowa requires taking at least two days off from work, and round trip flight expenses costing hundreds of dollars. 

3. Travel to Iowa causes hardship to both parties, and jeopardizes their jobs.  A major reason for the divorce filed in September 2009 was the previous lack of employment, resulting in financial and emotional stress.  Fortunately, both parties now have steady jobs in DC.

4. A typical flight from Washington DC to Cedar Rapids airport takes about seven hours including layover time in Chicago, and the 1.5 hour drive to Fairfield.  Then there are hotel expenses.  The trip is physically exhausting.  Both parties would not be at their most alert and cooperative state during important meetings in Iowa.

5. Respondent has never been able to attend any hearings in this matter so far, and cannot attend the next hearing nor any foreseeable hearings. 

6. Neither side can afford to exercise their right to bring any potential witnesses to an Iowa hearing, to testify regarding relevant evidence or financial records.  Iowa is a therefore a forum non conveniens.

7. Plaintiff and Respondent have filed their tax return on April 14, 2010 as "Married - Filing Jointly" for the Internal Revenue Service, listing their address Washington, DC.  They are citizens of the District of Columbia, and pay taxes to the DC Government for public services.

8. Plaintiff and Respondent both have Washington DC Drivers Licenses.  They are no longer citizens of Iowa.  Therefore the Iowa Court, nor the Iowa tax payers, should not be burdened by this matter of non-citizens. 

9. The most appropriate jurisdiction for this matter would be Washington DC, where the plaintiff and respondent reside and pay taxes.  The DC Family Court House is well equipped and staffed to handle such matters.  It would be a convenient location for both parties, for divorce hearings, negotiation meetings, or counseling sessions.  A DC hearing would be easy and inexpensive for them to attend, requiring only a few hours off from work, and a short taxi ride, or subway to the Court House Metro Stop.