On April 22, 2014 a
Request,Application
was filed
involving a dispute between
and
for MODIFICATION-OTHER
in the District Court of Tarrant County.
Preview
325-555760-14 FILED
TARRANT COUNTY
4/13/2022 11:43 AM
NO. 325-555760-14 THOMAS A. WILDER
DISTRICT CLERK
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ALIA G. HAIDER, § 325TH JUDICIAL DISTRICT
§
A CHILD § TARRANT COUNTY, TEXAS
RESPONDENT’S REQUESTS FOR RELIEF
TO THE HONORABLE JUDGE OF THIS COURT:
Now comes Respondent, Shabbab Haider, who makes the following requests for relief for
temporary orders:
I. Child
A. Conservatorship
Respondent requests that the parties remain Joint Managing Conservators with all
the rights and duties as set forth in the Order in Suit to Modify the Parent Child Relationship
dated November 9, 2017.
B. Possession
Respondent requests that the parties will have possession of Alia G. Haider at all times
as they may mutually agree, and failing mutual agreement as follows:
Respondent further requests that Petition have the right to possession of Alia G.
Haider pursuant to an expanded standard possession schedule, except that Petitioner’s
Thursday periods of possession begin at the time school is dismissed and end that same day
at 8:00 p.m.
C. Child Support
Respondent requests that Petitioner pay child support in accordance with the
guidelines. Respondent requests that a wage withholding order be entered and served on
Petitioner’s employer.
D. Medical Support
Respondent requests that he continue to provide health insurance and dental
insurance through a plan offered by his employer.
Father requests that each party pay 50% of all uninsured medical and dental
expenses for the child not covered by insurance.
Respondent’s Requests for Relief – Haider Page 1 of 3
E. Passport
Respondent requests that he be permitted to hold and have possession of the child’s
passport.
F. Injunction
Respondent requests that the injunction contained in the Order in Suit to Modify the
Parent Child Relationship dated November 9, 2017 remain in full force and effect.
Respectfully submitted,
KELLY DECKER LAW, PLLC
6300 Ridglea Place, Suite 101
Fort Worth, Texas 76116
T: (817) 348-9060
F: (817) 348-9070
By:
Martha Akers Freeman
State Bar No. 12849400
marcy@kellydeckerlaw.com
Kelly W. Decker
State Bar No. 24048427
Kelly@kellydeckerlaw.com
Attorneys for Respondent
Respondent’s Requests for Relief – Haider Page 2 of 3
CERTIFICATE OF SERVICE
I certify that a true copy of the above was served in accordance with the Texas Rules
of Civil Procedure on April 13, 2022 on the following:
Mary Holland via e-service filing manager
.
Martha Akers Freeman
Respondent’s Requests for Relief – Haider Page 3 of 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Suzie Waldon on behalf of Martha Freeman
Bar No. 12849400
suzie@deckerpoole.com
Envelope ID: 63535299
Status as of 4/13/2022 1:12 PM CST
Associated Case Party: SHABBABHAIDER
Name BarNumber Email TimestampSubmitted Status
Martha AkersFreeman kelly@kellydeckerlaw.com 4/13/2022 11:43:45 AM SENT
Associated Case Party: COURTNEYAMBERHALDER-HUSSIEN
Name BarNumber Email TimestampSubmitted Status
Mary Holland 9850700 mary@hollandmcgill.com 4/13/2022 11:43:45 AM SENT
Document Filed Date
April 13, 2022
Case Filing Date
April 22, 2014
Category
MODIFICATION-OTHER
Status
FINAL JUDGMENT AFTER NON-JURY TRIAL
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325-555760-14 FILED TARRANT COUNTY 4/13/2022 11:43 AM NO. 325-555760-14 THOMAS A. WILDER DISTRICT CLERK IN THE INTEREST OF § IN THE DISTRICT COURT § ALIA G. HAIDER, § 325TH JUDICIAL DISTRICT § A CHILD § TARRANT COUNTY, TEXAS RESPONDENT’S REQUESTS FOR RELIEF TO THE HONORABLE JUDGE OF THIS COURT: Now comes Respondent, Shabbab Haider, who makes the following requests for relief for temporary orders: I. Child A. Conservatorship Respondent requests that the parties remain Joint Managing Conservators with all the rights and duties as set forth in the Order in Suit to Modify the Parent Child Relationship dated November 9, 2017. B. Possession Respondent requests that the parties will have possession of Alia G. Haider at all times as they may mutually agree, and failing mutual agreement as follows: Respondent further requests that Petition have the right to possession of Alia G. Haider pursuant to an expanded standard possession schedule, except that Petitioner’s Thursday periods of possession begin at the time school is dismissed and end that same day at 8:00 p.m. C. Child Support Respondent requests that Petitioner pay child support in accordance with the guidelines. Respondent requests that a wage withholding order be entered and served on Petitioner’s employer. D. Medical Support Respondent requests that he continue to provide health insurance and dental insurance through a plan offered by his employer. Father requests that each party pay 50% of all uninsured medical and dental expenses for the child not covered by insurance. Respondent’s Requests for Relief – Haider Page 1 of 3 E. Passport Respondent requests that he be permitted to hold and have possession of the child’s passport. F. Injunction Respondent requests that the injunction contained in the Order in Suit to Modify the Parent Child Relationship dated November 9, 2017 remain in full force and effect. Respectfully submitted, KELLY DECKER LAW, PLLC 6300 Ridglea Place, Suite 101 Fort Worth, Texas 76116 T: (817) 348-9060 F: (817) 348-9070 By: Martha Akers Freeman State Bar No. 12849400 marcy@kellydeckerlaw.com Kelly W. Decker State Bar No. 24048427 Kelly@kellydeckerlaw.com Attorneys for Respondent Respondent’s Requests for Relief – Haider Page 2 of 3 CERTIFICATE OF SERVICE I certify that a true copy of the above was served in accordance with the Texas Rules of Civil Procedure on April 13, 2022 on the following: Mary Holland via e-service filing manager . Martha Akers Freeman Respondent’s Requests for Relief – Haider Page 3 of 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Suzie Waldon on behalf of Martha Freeman Bar No. 12849400 suzie@deckerpoole.com Envelope ID: 63535299 Status as of 4/13/2022 1:12 PM CST Associated Case Party: SHABBABHAIDER Name BarNumber Email TimestampSubmitted Status Martha AkersFreeman kelly@kellydeckerlaw.com 4/13/2022 11:43:45 AM SENT Associated Case Party: COURTNEYAMBERHALDER-HUSSIEN Name BarNumber Email TimestampSubmitted Status Mary Holland 9850700 mary@hollandmcgill.com 4/13/2022 11:43:45 AM SENT