Complaint,Petition: FP-2017-00026

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                                FILED
BRYAN COUNTY, OKLAHOMA

__ DISTRICT COURT CLERK
IN THE DISTRICT COURT OF BRYAN COUNTY
STATE OF OKLAHOMA JUN 22 2017
DONNA ALEXAND
1. GCOURT CLERK ER
JIMMY LEE DELOZIER ) BY. ¢ bepu
Plaintiff, ) uty
)
vs. ) CaseNo. FP-2017-2
)
HALLIE MCCOY, )
Defendant. )
PETITION

COMES NOW, Plaintiff, Jimmy Lee Delozier, and for her cause of action against the
Defendant alleges and states as follows:

1. That prior to the filing of this Petition, the Plaintiff and Defendant have been
residents in good faith of Bryan County and State of Oklahoma; and

2. That the parties entered into a relationship, and of that relationship, one (1) child was
born, namely Gunner Delozier date of birth January 4, 2017; and

3. That the Plaintiff is the father of said child; that a judicial determination should be
made that the Plaintiff is the father of said child; and

5. That the Plaintiff herein should be granted full custody of the minor child of the
parties, subject to the reasonable visitation of the Defendant, as directed by DHS; and

6. That this Court has jurisdiction to determine custody of the above-named minor child
pursuant to 10 O.S. Section 1601 et seq., in that:

a. this state has been the "home state" of the minor child within six (6) months

before commencement of these proceedings; and

b. the child and at least one contestant have significant connections with thisstate, and there is available in this state substantial evidence concerning the child's present or future
care, protection, training and personal relationships; and
c. no other state would have jurisdiction under the prerequisites of 43 O.S.

section 505 (A), 1, 2 or 3 and it is in the best interest of the child that this state assume jurisdiction;
and

7. That the Federal Indian Child Welfare Act, 25 U.S.C. Section 1901 et seq., does not
apply to these proceedings; and

8. That the Defendant is financially able to provide reasonable support and maintenance
for the minor child of the parties; and

WHEREFORE, Plaintiff prays for a judicial determination that Plaintiff, Jimmy Lee
Delozier, is the father of the minor child of said relationship, custody and child support, and any such
other relief as Plaintiff may be entitled.

Respectfully submitted,

~ ELLIOTT
325 West Evergreen
Durant OK 74701
(580) 924-7878
Attorney for PlaintiffVERIFICATION
STATE OF OKLAHOMA )
COUNTY OF BRYAN ) *
JIMMY LEE DELOZIER, being first duly sworn upon oath says: that he is the Plaintiff

above named, that he has read the foregoing Counterclaim and knows the contents thereof and that

the facts therein set forth are true and correct.

0 oO
'Y LEEDELOZIE!

   
   
  

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Subscribed and sworn to before me this_(4 day of , 2017.

NOTARY

  

My Commission Expires: Commission NO.

 
     
  

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