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NCPName: ALLAN RAY BROWN
F!L~D
CPName: LAQUOYA L GIBSON
OAGNumber: 0591206251
LAC: MENF ;15 ' ' 5,61•1 ®Sl lJOq Nov 30
CAUSE NUMBER 976724 i(AAE:N C {:) ]: 2/
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IN TilE INTEREST OF § IN THE !70TH DI~~ b7Jl .
ALLAN RAY BROWN JR § 0~ .
A MINOR CHILD § MCLENNANCOUNfY, TEXAS
MOTION FOR ENFORCEMENT OF CHILD SUPPORT ORDER
I. The Office of the Attorney General, pursuant to Texas Family Code Chapter 231, files this pleading for which
discovery is intended to be conducted lUlder Level2 of Rule 190, Texas Rules of Civil Procedure.
JURISDICTION
2. This Court has continuing jurisdiction of the child the subject of this suit because of prior proceedings.
CHILDREN
3. The following child is the subject of this suit:
Name DOB Birthplace
ALLAN RAY BROWN JR M !110/1996 WACO, TX
No property, other than personal effects, is owned by any child the subject of this suit.
PERSONS ENTITLED TO NOTICE
4. The child resides with LAQUOYA L GIBSON, the mother of the child. The Office of the Attorney General
requests the issuance and service of process on this person in accordance with the attached service information sheet.
5. ALLAN RAY BROWN is the father of the child. The Office of the Attorney General requests the issuance and
service of process on this person in accordance with the attached service infmmation sheet.
PRIOR ORDER
1. On 6/411997 the Court ordered ALLAN RAY BROWN to pay current child support of$145.00 monthly, beginning
6/15/1997, and monthly thereafter. The amount and frequency of ALLAN RAY BROWNs child support obligation
remains Wlchanged.
CHILD SUPPORT ARREARAGE
2. ALLAN RAY BROWN failed to pay court ordered child support as follows:
a. Prior arrears as of 3/3112001 $6,723.50
b. Support accrued since 3/3112001 $5,945.00
c. Interest accrued since 313112001 $3,309.37
d. Support paid since 3/3112001 $0.00 93 :'J ~:d OS T~O SOGZ
e. Total arrearage as of 813112004 $15,977.87
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Exhibit A, which is attached and incorporated by reference, is a true and correct copy of a payment record
indicating the occasions Obligor violated the above-referenced order and committed a separate act of contempt by each
indicated failure to pay support in full on or before its due date.
3. ALLAN RAY BROWN has repeatedly violated the child support order and the Office oftheAttomeyGeneral
anticipates that he will similarly continue to violate the order.
CONTEMPT
4. The Court should hold ALLAN RAY BROWN in contempt and punish him by a fine of not more than $500.00
and/or by commitment to the county jail for not more than six months.
Additionally, the Court should order ALLAN RAY BROWN committed to the county jail until he pays the child
support arrearage, accrued interest, reasonable attorney fees, and court costs.
JUDGMENT ON ARREARS
5. The Court should confirm and enter judgment for the child support arrearage and accrued interest as of the
hearing date. The Court should order payment and income withholding to liquidate the judgment pursuant to Texas
Family Code Chapters 157 and 158.
WITHHOLDING FROM EARNINGS FOR SUPPORT
6. The Court should order all support withheld from disposable earnings pursuant to Texas Family Code§ 158.006.
The Court should order all payments of support processed pursuant to Texas Family Code Chapter 231 for distribution
according to law.
REQUEST FOR PRODUCTION OF DOCUMENTS
7. ALLAN RAY BROWN has in his possession documents that will show the nature and extent of his ability to pay
child support, The Office of the Attorney General, pursuant to Rule 196, Texas Rules of Civil Procedure, requests him to
produce and pe:nnit the Office of the Attorney General to inspect and copy the originals, or true copies, of the following
documents in his possession, custody or control: (a) his IRS federal tax returns for the past two years, (b) all payroll
stubs, vouchers, records of cormnissions and all other written records or evidence of income received by him within the
last six months, (c) the most recent Social Security Administration Fonn SSA-7005, showing his income history, sent to
him three months before his last birthday, (d) statements of accounts for all checking or saving accounts in which he has
held an interest within the last six months, (e) all evidence (policies, premiwn schedules, records of premiums paid, etc.)
of health insurance available at his place of employment that may provide coverage for dependent children, (f) copies of
loan applications made within the last six months, (g) current statement of benefits and account balances for all
retirement, pension, or profit -sharing plans in which the respondent has accrued or may accrue benefits, regardless if such
benefits have vested, including but not limited to employer- or union-sponsored defined benefit or defined contribution
plans and individual retirement accounts (IRAs), and (h) sununaty plan description of all retirement, pension, or profit-
sharing plans in which the respondent has accrued or may accrue benefits, regardless if such benefits have vested, The
Office of the Attorney General requests production of the specified documents at:
The Office of the Attorney General
POBOX 1969
Waco, TX 76703-1969
on or before 3:00 p.m. on the 50th day following the date of service of this request.
ATTORNEY FEES AND COSTS
8. The Court should order ALLAN RAY BROWN to pay reasonable attorney fees and all other costs of this
proceeding.
PRAYER
The Office of the Attorney General prays that the Court grant all relief requested herein. The Office of the
Attorney General prays for general relief.
Respectfully submitted,
GREG ABBOTT
Attorney General of Texas
BARRY R. McBEE
First Assistant Attorney General
R S- SBN: 24000061
e .Miller-SBN: 14114400
Re na- SBN: 16794795
Manit Keathley- SBN: 00792828
Assistant Attorney General
Child Support Division
POBOX 1969
Waco TX 76703-1969
Telephone No. (254)754-5402
Fax No. (254)752-1864
AC0410R1 OFFICE OF THE ATTORNEY GENERAL
,,
CHILD SUPPORT ENFORCEMENT DIVISION Page #: 1
FINANCIAL ACTIVITY REPORT
CASE ID: 0591206251 CAUSE NUMBER: 976724
NCP: BROWN, ALLAN RAY CP: GIBSON, LAQUOYA L
ORDERED
TRANS TRANSACTION ACCRUAL PAYMENT ON RECEIPT AMOUNT
DATE TYPE AMOUNT ARREARS AMOUNT APPLIED BALANCE
======== ============== ========== ========== ========== ========== ===========
03/31/01 cs Judgment 6723 '50 6723 '50
04/15/01 Regular CS 145,00 6868,50
04/30/01 CS Interest 67,24 6935,74
05/15/01 Regular CS 145.00 7080,74
05/15/01 CS Arrears 60,00
05/31/01 CS Interest 67.24 7147.98
06/15/01 Regular CS 145.00 7292,98
06/15/01 cs Arrears 60,00
06/30/01 cs Interest 67.24 7360,22
07/15/01 Regular CS 145' 00 7505,22
07/15/01 CS Arrears 60.00
07/31/01 CS Interest 68.69 7573.91
08/15/01 Regular CS 145,00 7718,91
08/15/01 CS Arrears 60.00
08/31/01 CS Interest 70.14 7789,05
09/15/01 Regular CS 145,00 7934.05
09/15/01 CS Arrears 60.00
09/30/01 CS Interest 71.59 8005,64
10/15/01 Regular cs 145.00 8150,64
10/15/01 CS Arrears 60.00
10/31/01 CS Interest 73.04 8223,68
11/15/01 Regular cs 145.00 8368,68
11/15/01 CS Arrears 60,00
11/30/01 cs Interest 74,49 8443,17
12/15/01 Regular cs 145,00 8588,17
12/15/01 cs Arrears 60,00
12/31/01 cs Interest 75.94 8664,11
01/15/02 Regular cs 145.00 8809' 11
01/15/02 cs Arrears 60.00
01/31/02 CS Interest 72.32 8881.43
02/15/02 Regular cs 145.00 9026,43
02/15/02 CS Arrears 60,00
02/28/02 CS Interest 73.04 9099 .4 7
03/15/02 Regular CS 145.00 9244,47
03/15/02 cs Arrears 60,00
03/31/02 CS Interest 73.77 9318,24
04/15/02 Regular CS 145.00 9463,24
04/15/02 CS Arrears 60.00
04/30/02 CS Interest 74.49 9537' 73
05/15/02 Regular CS 145.00 9682.73
05/15/02 CS Arrears 60,00
05/31/02 CS Interest 75.22 9757.95
06/15/02 Regular CS 145.00 9902,95
06/15/02 cs Arrears 60,00
EXHIBIT A
AC0410R1 OFFICE OF THE ATTORNEY GENERAL
· .. CHILD SUPPORT ENFORCEMENT DIVISION Page #: 2
FINANCIAL ACTIVITY REPORT
CASE ID, 0591206251 CAUSE NUMBER' 976724
NCP' BROWN, ALLAN RAY CP: GIBSON, LAQUOYA L
ORDERED
TRANS TRANSACTION ACCRUAL PAYMENT ON RECEIPT AMOUNT
DATE TYPE AMOUNT ARREARS AMOUNT APPLIED BALANCE
======== ============== ========== =====,==="" ========== ========== ===========
06/30/02 cs Interest 75.94 9978.89
07/15/02 Regular cs 145.00 10123.89
07/15/02 CS Arrears 60.00
07/31/02 cs Interest 76.67 10200.56
08/15/02 Regular CS 145.00 10345.56
08/15/02 CS Arrears 60.00
08/31/02 cs Interest 77.39 10422.95
09/15/02 Regular CS 145.00 10567.95
09/15/02 CS Arrears 60.00
09/30/02 cs Interest 78.12 10646.07
10/15/02 Regular CS 145.00 10791.07
10/15/02 CS Arrears 60.00
10/31/02 cs Interest 78.84 10869.91
11/15/02 Regular CS 145.00 11014.91
11/15/02 cs Arrears 60.00
11/30/02 cs Interest 79.57 11094.48
12/15/02 Regular CS 145.00 11239.48
12/15/02 cs Arrears 60.00
12/31/02 cs Interest 80.29 11319.77
01/15/03 Regular cs 145.00 11464.77
01/15/03 CS Arrears 60.00
01/31/03 cs Interest 81.02 11545.79
02/15/03 Regular CS 145.00 11690.79
02/15/03 cs Arrears 60.00
02/28/03 cs Interest 81.74 11772.53
03/15/03 Regular CS 145.00 11917.53
03/15/03 CS Arrears 60.00
03/31/03 cs Interest 82.47 12000.00
04/15/03 Regular CS 145.00 12145.00
04/15/03 CS Arrears 60.00
04/30/03 cs Interest 83.19 12228.19
05/15/03 Regular CS 145.00 12373.19
05/15/03 CS Arrears 60.00
05/31/03 cs Interest 83.92 12457.11
06/15/03 Regular CS 145.00 12602.11
06/15/03 CS Arrears 60.00
06/30/03 cs Interest 84.64 12686.75
07/15/03 Regular CS 145.00 12831.75
07/15/03 CS Arrears 60.00
07/31/03 cs Interest 85.37 12917.12
08/15/03 Regular cs 145.00 13062.12
08/15/03 CS Arrears 60.00
08/31/03 cs Interest 86.09 13148.21
09/15/03 Regular cs 145.00 13293.21
AC0410Rl OFFICE OF THE ATTORNEY GENERAL
'. ' CHILD SUPPORT ENFORCEMENT DIVISION Page #o 3
FINANCIAL ACTIVITY REPORT
CASE IDo 0591206251 CAUSE NUMBERo 976724
NCPo BROWN, ALLAN RAY CPo GIBSON, LAQUOYA L
ORDERED
TRANS TRANSACTION ACCRUAL PAYMENT ON RECEIPT AMOUNT
DATE TYPE AMOUNT ARREARS AMOUNT APPLIED BALANCE
======== ============== ========== ========== ========== ========== ===========
09/15/03 CS Arrears 60.00
09/30/03 CS Interest 86.82 13380.03
10/15/03 Regular CS 145.00 13525.03
10/15/03 CS Arrears 60.00
10/31/03 CS Interest 87.54 13612.57
11/15/03 Regular CS 145.00 13757.57
11/15/03 CS Arrears 60.00
11/30/03 CS Interest 88.27 13845.84
12/15/03 Regular CS 145.00 13990.84
12/15/03 cs Arrears 60.00
12/31/03 CS Interest 88.99 14079.83
01/15/04 Regular CS 145.00 14224.83
01/15/04 CS Arrears 60.00
01/31/04 CS Interest 89.72 14314.55
02/15/04 Regular CS 145.00 14459.55
02/15/04 CS Arrears 60.00
02/29/04 CS Interest 90.44 14549.99
03/15/04 Regular cs 145.00 14694.99
03/15/04 CS Arrears 60.00
03/31/04 CS Interest 91.17 14786.16
04/15/04 Regular CS 145.00 14931.16
04/15/04 CS Arrears 60.00
04/30/04 CS Interest 91.89 15023.05
05/15/04 Regular CS 145.00 15168.05
05/15/04 CS Arrears 60.00
05/31/04 cs Interest 92.62 15260.67
06/15/04 Regular cs 145.00 15405.67
06/15/04 CS Arrears 60.00
06/30/04 CS Interest 93.34 15499.01
07/15/04 Regular CS 145.00 15644.01
07/15/04 CS Arrears 60.00
07/31/04 cs Interest 94.07 15738.08
08/15/04 Regular cs 145.00 15883.08
08/15/04 CS Arrears 60.00
08/31/04 CS Interest 94.79 15977.87
Totals: 15977.87 2400.00 0.00 0.00 15977.87
Total Due:
08/31/04 15977.87 0.00 0.00 15977.87