Preview
Filed in The District Court
of Travis County, Texas
Cause No. -FN-04-¢ Ma eit wv
M.
Velva L. Price, District Clerk
IN THE INTEREST OF § IN THE DISTRICT COURT
§
SHEA LILY MARIE COLIN § 353" JUDICIAL DISTRICT
i.
A CHILD §
§
TRAVIS COUNTY, TEXAS
ORIGINAL PETITION TO MODIFY THE PARENT-CHILD RELATIONSHIP
1. Discovery Level
Discovery in this case, if needed, is Level 2.
2: Objection to Assignment of Case to Associate Judge
Petitioner objects to the assignment of this matter to an associate judge for a trial on the
merits or presiding at a jury trial.
3. Jurisdiction
This Court has continuing, exclusive jurisdiction of this case.
4. Child
The child the subject of this suit is:
Name: SHEA LILY MARIE COLIN
Sex: Female
Birth date: October 12, 1999
Home state: Texas
Social Security number: XXX-XX-9002
There has been no significant change to the child’s property.os Parties and Order to Be Modified
My name is JESSICA MEREDITH ANN CONN. I am the Petitioner, the person asking
the Court to change the order listed below. I have been issued a Texas drivers license ending in
the numbers 331. The last three numbers of my Social Security number is 087. [live at 2011 E.
6" St., Apartment 1312, Austin, Texas 78702. I am the mother, and Joint Managing Conservator
of the child and have standing to bring this suit. The requested modification will be in the best
interest of the child.
Respondent's name is DEVON SHEA COLIN. Respondent lives at 4700 E. Riverside
Dr. (Apartment number is unknown.), Austin, Texas 78741. Respondent is the father, and Joint
Managing Conservator of the child. I will have a sheriff, constable, or process server give a copy
of this Petition to the Respondent at the Respondent’s place of business: Pok-e-Jo’s BBQ, 1000
E. 41" Street, Austin, Texas 78751. I ask the clerk to issue the citation of service. I understand
that I will need to pay the fee and arrange for service.
The order to be modified is entitled Final Decree of Divorce and was rendered on
November 30, 2010.
6. Modifications Requested
The circumstances of the child, a conservator, or other party affected by the order or
orders to be modified have materially and substantially changed since the judge announced the
prior order or orders.
The requested modifications are in the best interest of the child.
The requested modifications will change the following parts of the current orders:
6a. Changes to Conservatorship
I ask the Court to change the conservatorship orders as follows:
I ask the Court to change the conservatorship order to name me, the Petitioner, Sole
Managing Conservator, (Home-Parent);and name Respondent, Possessory Conservator, (Co-Parent).
6b. Changes to Rights and Duties
I ask the Court to change orders regarding parental rights and duties to the following:
Petitioner should have the exclusive right to
1. Make decisions concerning the child’s education.
2. Consent to major medical dental, and surgical treatment for the child.
3. Consent to psychological and psychiatric treatment for the child.
4. Consent to the child’s marriage
5. Consent to the child enlisting in the U.S. Armed Forces.
6. Manage or control the earnings or services of a child who works.
7. Represent the child in a legal action and make important legal decisions that affect the
child.
8. Make decisions for the child about their estates if required by law (unless the child
has a guardian ad litem or guardian of the estate).
9. Manage the child’s estate if created by the parent’s community or joint property.
6c. Changes to Possession or Access
I ask the Court to change the possession and access orders to the following:
Limited Visitation Orders, limiting Respondent’s access to the child to only supervised
contact.
6d. Changes to Child Support
I ask the Court to change the child support orders as follows:
Increasing the amount of child support Respondent pays each month.
6e. Changes to Medical Support
I do not want to change medical support orders.Zs Child’s Health Insurance
Private Health Insurance is NOT in effect:
The child receives medical assistance through Medicaid. It is unknown whether health
insurance is available to the person who pays child support at a reasonable cost.
8. Information Required By Section 105.006
I will include in the final Order, the current addresses, and phone numbers for each party
and child who is subject to this suit, as required by section 105.006 of the Texas Family Code.
9. Request for Temporary Orders
Petitioner requests the Court, after notice and hearing, to make temporary orders for the
safety and welfare of the child, including but not limited to the following:
Appointing Petitioner Sole Managing Conservator (Home-parent) and Respondent
Possessory Conservator (Co-parent).
Ordering Respondent to pay child support while this case is pending.
With regard to the requested temporary order for managing conservatorship, Petitioner
would show the Court the following:
These temporary orders are necessary because the child’s present circumstances would
significantly impair the child’s physical health and emotional development, and the requested
temporary order is in the best interest of the child.
10. Temporary Restraining Order
Petitioner requests the Court to dispense with the necessity of a bond, and Petitioner
requests that Respondent be temporarily restrained, immediately, without hearing, and after
notice and hearing be temporarily enjoined, pending the further order of this Court, from:
Committing acts of family violence as family violence is defined by Section 71.004,
Texas Family Code.Communicating in a threatening or harassing manner with the child or person who is a
member of the family or household.
Communicating a threat through any person to the child or person who is a member of
the family or household.
Injuring, harassing, threatening or harming the child or person who is a member of the
family or household.
Engaging in conduct directed specifically toward the child, or person who is a member of
the family or household, including following the person, that is reasonably likely to harass,
alarm, abuse, torment, or embarrass that person, or stalking the child or person who is a member
of the family or household, as stalking is defined by Section 42.072, Texas Penal Code.
Removing the child from the jurisdiction of the Court.
Interfering in any way with the mental health treatment of the child, including
medication, as recommended by her psychiatrist.
Disturbing the peace of the child or of a person who is a member of the family or
household.
Withdrawing the child from enrollment in the school or day-care facility where the child
is presently enrolled.
Hiding the child from the Petitioner.
Making disparaging remarks regarding the other party or the other party’s family in the
presence or within the hearing of the child.
Drinking alcohol or consuming controlled substances within 12 hours before or during a
period of possession or access to the children.
ii. Prayer
Petitioner prays that citation and notice issue as required by law and that the Court enter
its orders in accordance with the allegations contained in this petition.Petitioner prays that the Court immediately grant a temporary restraining order
restraining Respondent, in conformity with the allegations of this petition, from the acts set forth
above, and Petitioner prays that, after notice and hearing, this temporary restraining order be
made a temporary injunction.
Petitioner prays for general relief.
Respectfully Submitted,
By: Oyen COone—
J ecsicall teredith Ann Conn
Petitioner, Pro Se
Name: Jessica Meredith Ann Conn Telephone: 512-680-2973
Mailing Address: 2011 E. 6 St., Apartment 1312, Austin, Texas 78702
Email Address: jconn @txstate.eduS6SuLES9T
“TRAVIS COUNTY: DISTRICT CLERK’S,
» “ FILENO. 121,012
qocaL RULES AND GENERAL ORDERS)
TRAVIS COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY AND
“CONDUCT OF THE PARTIES
’
No party to this lawsuit has requested this order. Rather, this order j is a standing order of
_ the Travis County District Courts that applies in every divorce suit and every suit affecting the
parent-child relationship filed in Travis County. The District Courts of Travis County. have
adopted this order because the parties and their children.should be protected and their property
Preserved mnie! hie lawsuit i is Pending before the court, Therefore, it is ORDERED:
1, NO DISRUPTION OF CHILDREN. Both parties are ORDERED to refrain from
"doing the following acts concerning any children who are subjects of this case:
1.1 Removing the children from the State of Texas, acting directly or in concert with
. others, without the written agreement of both parties or an order of this Court.
1.2 Disrupting or withdrawing the children from the school or day-care facility where
the children are presently enrolled, ad the written agreement of both parents
or an order of this Court, °
- 13 Hiding-or secreting the children from the other parent or changing the children’s
current place of abode, without the written agreement of both parents or an order
~ of this Court. .
14 Disturbing the peace of the children, a >
2 CONDUCT OF THE PARTIES DURING THE CASE, Both parties are fe ORDERED!
to refrain from doing the following acts:
2.1 Using vulgar, profane, obscene, or indecent language, or a coarse or offensive
manner, to communicate with the other party, whether in person, by telephone, or
in writing.
2.2 Threatening the other party in person, by telephone, or in writing to take unlawful
action against any person.
2.3. Placing one or more telephone calls, at an unreasonable hour, in an offensive or
repetitious manner, without a legitimate purpose . of commumication, or
anonymously,
2.4 Opening or diverting mail addressed to the other party.
3. PRESERVATI F_ PROPERTY AND USE OF D GD IRC.
CASE, If this is a divorce case, both parties to the marriage are ORDERED to refrain from doing
the foll following acts:
3.1 Destroying, removing, concealing, encumbering, transferring, or otherwise
harming or reducing the value of the property of one or both of the parties,
FILED
OW OEG 17 AR 22
Orie Font » Ireamatipee
TR ET AS3.2
3.3
3.4
3.5
_ 36
3.7
3.8
3.9
“3.10
» 3.1L
3.12
3.13
3.14
Misrepresenting or refusing toidisclose to the other party or to the Court, on
proper request, the existence, amount, or location a any property of one or both
of the parties,
Damaging or destroying the tangible property of one or both of the parties,
including any document that represents ot embodies anything 'of value,
Tampering with the tangible property of one or both of the parties, including any
document that represents or cenbaties anything of value, and ane pecuniary
._ loss to the other party.
" Selling, transferring, a mortgaging, encumbering, or in any other manner
. alienating any of the:property of either party, whether personal property or real
estate. property, and -whether separate or community, ‘except as specifically
authorized by this order. why
Incurring any indebtedness, other than legal expensea in connection an this suit,
~~ exceptas specifically authorized |
Making withdrawals from any checking or savings account 4 in any. financial
institution for any purpose, except.as specifically autharized by this order.
Spending any sum of cash in either party’s possession or subject to either party’s
control for any purpose, except as specifically authorized by this order.
Withdrawing or borrowing i in any manner for any purpose from any retirement,
profit-sharing, pension,... death, or. other-.employee...benefit- plan . or..employee .
savings plan or from any individual retirement account or Keogh account, except
—as-specifieally-authorized by-this order ——
Signing or endorsing the other party’s name on any negotiable instrument, check,
or draft, such as tax refunds, insurance payments, and.dividends, or attempting to
negotiate any negotiable instrument payable to the other party without the
personal signature of the other party. -. +
Taking any action to terminate or limit ciedit or charge cards in ‘the name of the
other party.
Entering, operating, or. exercising control over the motor vehicle in the possession
of the other party.
Discontinuing or redusing the withholding for ier income taxes on wages or
salary while this suit is pending.
Terminating or in any manner affecting the service of water, electricity, gas,
telephone, cable television, or other contractual services, such as security, pest
. control, landscaping, or yard maintenance at the other party’ 's residence or in any
manner attempting to withdraw any deposits for service in connection with such
services,
4. PERSONAL AND BUSINESS RECORDS IN DIVORCE CASE, If this is a divorce
case, both parties to the marriage are ORDERED to refrain from doing the following acts:
4.1
4.2
4.3
Concealing or destroying any family records, property records, financial records,
business records or any records of income, debts, or other obligations.
Falsifying any writing or record relating to the property of either party.
“Records” include e-mail or other digital or electronic data, whether stored on a
computer hard drive, diskette or other electronic storage device,
Page 2 of 45. «. INSURANCE IN DIVORCE CASE, If this is a divorce-case, both parties to the
marriage are ORDERED to refrain from doing the following acts: o
5.1 Withdrawing or borrowing in any manner all or any part of the cash surrender
value of life insurance policies on the life of either Party, except as specifically
. .» authorized by this order, tay CG peat
5.2 Changing or in any manner altering the beneficiary designation. on any life
insurance, on the life of either party or the parties’ children. -
5.3 Canceling, altering, or in any manner affecting any casualty, automobile, or health
insurance policies insuring the parties’ property of persons including the parties’
minor children... Ns
‘ - : re .
6. __ SPECIFIC AUTHORIZATIONS IN DIVORCE CASE, If this is a divorce case, both
- Parties to the marriage are specifically guthorized to do the following: .
6.1 To engage in acts, reasonable and necessary to the conduct of that party’s usual
business and occupation: : . .
6.2 To\ make expenditures and incur indebtedness for reasonable attorey’s fees and
. expenses in cotihection with this suit. 4 ond
6.3 To make expenditures and incur indebtedness for reasonable and necessary living
. expenses for food, clothing, shelter, transportation and medical care.
6.4 To make withdrawals from accounts in financial institutions only for the purposes
authorized by this order. . . ;
: ste
7. SERVICE AND APPLICATION OF THIS ORDER. 1
7.1” The Petitioner shall attach a copy of this order to the original petition and to each
copy of the petition. At the time the petition is filed, if the Petitioner has failed to
attach a copy of this order to the petition and any copy of the petition, the Clerk
shall ensure that a copy of this order is attached to the petition and every copy of
the petition presented.: » ~: “ ee es eel
7.2 This order is effective upon the filing of the original petition and shall remain in
full force and effect as a temporary restraining order for fourteen days after the
date of the ‘filing of the original petition. If no party contests this order by
presenting evidence at a hearirig on or before fourteen days after the date of the
filing of the original pétition, this order shall continue in full force and effect as a
temporary injunction until further order of the court. This entire order will
terminate and will no longer be effective once the court signs a final order.
8. EFFECT OF OTHER COURT ORDERS. If any part of this order is different from
any part of a protective order that has already been entered or is later entered, the
protective order provisions prevail. - Any part of this order not changed by some later order
remains in full force and effect until the court signs a final decree.
9. P. 'S ENCO' ‘D TO MED: . The parties are encouraged to settle their
disputes amicably without court intervention. The parties are encouraged to use alternative
Page 3 of 4dispute resolution methods, such as mediation, fo resolve the conflicts that may arise in
this lawsuit. ,
THIS TRAVIS COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY
AND CONDUCT OF THE PARTIES SHALL BECOME EFFECTIVE ON JANUARY 1,
2005. .
inGs BOB PE
331" Disteiot Court’(CAUSE NUMBER (FOR CLERK USE ONLY):
STYLED
Civit CASE INFORMATION SHEET
(COURT (FOR CLERK USE ONLY):
the time of filin;
(eg, John Smith v. All American Insurance Co; In re Mary Ann Jones; In the Matter of the Estate of George Jackson)
A civil case information sheet must be completed and submitted when an original petition or application is filed to initiate a new civil, family law, probate, or mental
health case or when a post-judgment petition for modification or motion for enforcement is filed in a family law case. The information should be the best available at
a —-.
1. Contact information for person completing case information sheet: Names of parties in case: erson or entity c¢ ng shes
LJAttorney for PlaintifiiPetitioner
Name: . Email Plaintifi('s)/Petitioner(s) ‘i 2 Plaintifi/Petitioner
i P rs Diitle 1V-D Agenc;
| Jessica Conn {conn é tise Jessica Eloiter *
Address: Telephone Aw nu Conhr
1 p| E ins fe HI 5 | Ll 80 a 1413 Additional Parties in Child Support Case:
TT Defendant(s)/Respondent(s) Custodial Parent:
City/State/Zip: . Fax:
“0 fusha Kage ae
Non-Custodial Parent
Signature: State Bar No
Presumed Father:
{Attach additional page as necessary to ist all parties]
2. Initicate case type, or identify the most important issue in the case (select only 1): |
Civil Family Law
Contraet Injury or Damage Real Property Marriage Relationship
Debi/Contract DaAssaulvBattery Eminent Domain/ DAnnulment DJEnfgrcement
(DConsumer/DTPA DConstruction Condemnation (Declare Marriage Void [Bbat@tiication—Custody
(Deby Contract (Defamation Partition Divorce OModification—Other
CiFraud/Misrepresentation | Malpractice Duiet Title QWith Children Title 1V-D
Other Debt/Contract: DaAccounting LDiTrespass to Try Title No Children TEnforcement/Modification
Degal Clother Property Eppaternity
Foreclosure OMedical iReciprocals (UIFSA)
Home Equity—Expedited Dlother Professional Cisupport Order
Other Foreclosure Liability
Franchise Related to Criminal
Dinsurance (Motor Vehicle Accident Matters Other Family Law Parent-Child Relationship 4
(Landlord/Tenant OPremises TExpunction Enforce Foreign DJAdoption/Adoption with
(Non-Competition Product Liability CQudgment Nisi Judgment ‘Termination
Oartnership DAsbestos/Silica (Non-Disclosure (Habeas Corpus (child Protection
other Contract Dlother Product Liability DSeizure/Forfeiture (Name Change OChild Support
List Product: COwrit of Habeas Corpus— DProtective Order COcustody or Visitation
Pre-indictment (Removal of Disabilities (Gestational Parenting
(other Injury or Damage: Dotter: of Minority (Grandparent Access
DOther: CParentage/Paternity
DiTermination of Parental
Rights
Employment Other Civil Dlother Parent-Child
Discrimination DAdministrative Appeal (DLawyer Discipline
D)Retaliation DAntitrusUnfair CiPerpetuate Testimony
Termination Competition D2Securities/Stock
(Q)Workers’ Compensation (Code Violations DiTortious Interference
(Other Employment: Foreign Judgment CDOther:
intellectual Property
Ir
Tax Probate & Mental Health
DTax Appraisal Probate/Wills/Intestate Administration UGuardianship—Adult
(Tax Delinquency (Dependent Administration (Guardianship—Minor
Dother Tax Diindependent Administration venta! Health
Daother Estate Proceedings Loother:
Indicate procedure or remedy, if applicable (may select more than 1):
Appeal from Municipal or Justice Court DDeclaratory Judgment LiPrejudgment Remedy
Qaarbitration-related OGarnishment CDoProtective Order
Dattachment Diinterpleader DReceiver
DBBill of Review DLicense Dsequestration
OCertiorari (Mandamus (Temporary Restraining Order/Injunction
|, (class Action CoPost-judgment OTurnover
4. Indicate damages sought (do not select ifit is a family law case):
TiLess than $100,000, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees
D1Less than $100,000 and non-monetary relief
Dover $100, 000 but not more than $200,000
Cover $200,000 but not more than $1,000,000
Dover $1,000,000
—Rev 2/1