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IN THE SUPERIOR COURT OF GWINNETT 111COUNTY
STATE OF GEORGIA
LAUREN ASHLEY PAYNE,
PETITIONER, CIVIL ACTION FILE NUMBER
V. 21-A-08580-9
CHAD ELLIS TAYLOR,
RESPONDENT.
RESPONDENT’S MOTION FOR CONTINUANCE OF OCTOBER 10, 2022 HEARING
COME NOW CHAD ELLIS TAYLOR, Respondent in the above-styled case, by and
through his undersigned counsel, file this, his Respondent’s Motion for Continuance of October
10, 2022 Hearing, respectfully showing the court as follows:
1. The Petition for Registration of Foreign Child Custody Determination, Petition to
Modify Custody and Support, and Petition to Change name of Minor Child, to wit,
Colton Ellis Taylor (born 2010) was filed on November 2, 2021. Petitioner seeks to
retain sole legal and physical custody of the child while further curtailing Respondent’s
ability to have visitation with the minor child, changing the child’s name to remove
Respondent’s surname, while requiring Respondent to pay child support. In doing so,
Petitioner has made a series of intentionally vague, ambiguous, and spurious allegations
intended to cast Respondent in the most negative light possible.
2. The parties have two (2) non-marital children to wit, Colton Ellis Taylor (born 2010)
and Cache Elliott Taylor (Born 2017).
3. Respondent seeks to establish Legitimacy as to the second child, Cache Elliott Taylor
and to have liberal visitation with both children pursuant to a parenting plan, having
Lauren Ashley Payne v Chad Ellis Taylor
Superior Court Gwinnett County, CAFN: 21-A-08580-9
Respondent’s Motion for Continuance of October 10, 2022 Hearing
Page 1 of 4
also established child support pursuant to Georgia law.
4. Respondent was served with the Petition on March 1, 2022, and an Affidavit of Service
was field on March 18, 2022.
5. Respondent, Pro Se, filed his Answer on April 7, 2022. His pro se Answer
inadvertently omitted any counterclaim.
6. On August 15, 2022, the Court entered a Mediation Order directing the parties to
participate in mediation within forty-five (45) days of the Order.
7. Mediation was originally scheduled for August 24, 2022. Due to the mediator being
sick, however, the parties met informally, without the mediator, to discuss possible
settlement. Representing himself pro se, Respondent felt that excessive pressure was
being put on him to reach an agreement that he was not comfortable making and
settlement negotiations ended.
8. On or about September 15, 2022, Respondent retained undersigned counsel.
9. Undersigned counsel entered an appearance on September 22, 2022.
10. Respondent filed his Amended Answer and Counterclaim on September 26, 2022.
11. The facts and evidence that will be developed through discovery and at a continued
trial, will show that (1) over many years Petitioner and Respondent had an on-again,
off again, relationship that resulted in two (2) non-marital children—both of whom are
at issue here; (2) Respondent dutifully followed Petitioner all over the country as she
continued to take jobs and job training courses in Utah, Wyoming, Florida, Maine, and
Georgia; (3) Petitioner just expected Respondent to pivot, adjust and provide for the
family financially every time she moved the family for her own career (4) Respondent
was sometimes forced to take jobs that required him to live apart from the family in
Lauren Ashley Payne v Chad Ellis Taylor
Superior Court Gwinnett County, CAFN: 21-A-08580-9
Respondent’s Motion for Continuance of October 10, 2022 Hearing
Page 2 of 4
order to contribute the family financially (5) Petitioner has (“naturally”) blamed
Respondent for, at times, not being able to find work to support the family (6) After the
birth of the parties’ first, non-marital child, Colton Ellis Taylor but before the birth of
their second, non-marital child Colton Ellis Taylor, Petitioner married and divorced a
man by the name of DJ Hill (7) in 2018 the parties to this litigation were engaged to be
married (8) Respondent desires to be an engaged father and to have a close relationship
with his sons Colton Ellis and Cache Elliott and has moved closer to them
geographically to facilitate visitation (8) Respondent should have liberal visitation with
his boys and there is no reason to remove his surname “Taylor” from the boys’ names.
12. Neither party has engaged in discovery, formal or otherwise and Respondent should
be permitted to take written discovery and deposition testimony of plaintiff to ascertain
the full and complete basis for her apparent desire as pled to effectively erase the
children’s biological father Mr. Taylor from her sons’ lives while collecting child
support.
13. Respondent requests that he be permitted time to meet and consult with his new
attorney of record, to conduct discovery, to potentially engage in informal settlement
discussions through his counsel to ensure that his legal right and interests are protected,
and to have the opportunity to select a mutually agreed upon mediator through counsel
before prior to a hearing in this matter.
WHEREFORE, for the reasons set forth above, Respondent respectfully request:
A) That this case be continued off the trial calendar commencing on October 10,
2022 to permit the parties to conduct in discovery in preparation for trial; and
B) That he be granted such other and further relief as the court in its discretion deems
Lauren Ashley Payne v Chad Ellis Taylor
Superior Court Gwinnett County, CAFN: 21-A-08580-9
Respondent’s Motion for Continuance of October 10, 2022 Hearing
Page 3 of 4
just and proper.
This 26th day of September 2022.
RESPECTFULLY SUBMITTED,
HOBSON & HOBSON, P.C
Geoff Wolfe
____________________________
Geoff Wolfe, Esq.
Georgia Bar No.: 142130
Attorneys for the Respondent
136 Fairground St. NE
Marietta, Georgia 30060
770.425.3373
geoff@hobsonlegal.com
Lauren Ashley Payne v Chad Ellis Taylor
Superior Court Gwinnett County, CAFN: 21-A-08580-9
Respondent’s Motion for Continuance of October 10, 2022 Hearing
Page 4 of 4
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IN THE SUPERIOR COURT OF GWINNETT 111COUNTY STATE OF GEORGIA LAUREN ASHLEY PAYNE, PETITIONER, CIVIL ACTION FILE NUMBER V. 21-A-08580-9 CHAD ELLIS TAYLOR, RESPONDENT. RESPONDENT’S MOTION FOR CONTINUANCE OF OCTOBER 10, 2022 HEARING COME NOW CHAD ELLIS TAYLOR, Respondent in the above-styled case, by and through his undersigned counsel, file this, his Respondent’s Motion for Continuance of October 10, 2022 Hearing, respectfully showing the court as follows: 1. The Petition for Registration of Foreign Child Custody Determination, Petition to Modify Custody and Support, and Petition to Change name of Minor Child, to wit, Colton Ellis Taylor (born 2010) was filed on November 2, 2021. Petitioner seeks to retain sole legal and physical custody of the child while further curtailing Respondent’s ability to have visitation with the minor child, changing the child’s name to remove Respondent’s surname, while requiring Respondent to pay child support. In doing so, Petitioner has made a series of intentionally vague, ambiguous, and spurious allegations intended to cast Respondent in the most negative light possible. 2. The parties have two (2) non-marital children to wit, Colton Ellis Taylor (born 2010) and Cache Elliott Taylor (Born 2017). 3. Respondent seeks to establish Legitimacy as to the second child, Cache Elliott Taylor and to have liberal visitation with both children pursuant to a parenting plan, having Lauren Ashley Payne v Chad Ellis Taylor Superior Court Gwinnett County, CAFN: 21-A-08580-9 Respondent’s Motion for Continuance of October 10, 2022 Hearing Page 1 of 4 also established child support pursuant to Georgia law. 4. Respondent was served with the Petition on March 1, 2022, and an Affidavit of Service was field on March 18, 2022. 5. Respondent, Pro Se, filed his Answer on April 7, 2022. His pro se Answer inadvertently omitted any counterclaim. 6. On August 15, 2022, the Court entered a Mediation Order directing the parties to participate in mediation within forty-five (45) days of the Order. 7. Mediation was originally scheduled for August 24, 2022. Due to the mediator being sick, however, the parties met informally, without the mediator, to discuss possible settlement. Representing himself pro se, Respondent felt that excessive pressure was being put on him to reach an agreement that he was not comfortable making and settlement negotiations ended. 8. On or about September 15, 2022, Respondent retained undersigned counsel. 9. Undersigned counsel entered an appearance on September 22, 2022. 10. Respondent filed his Amended Answer and Counterclaim on September 26, 2022. 11. The facts and evidence that will be developed through discovery and at a continued trial, will show that (1) over many years Petitioner and Respondent had an on-again, off again, relationship that resulted in two (2) non-marital children—both of whom are at issue here; (2) Respondent dutifully followed Petitioner all over the country as she continued to take jobs and job training courses in Utah, Wyoming, Florida, Maine, and Georgia; (3) Petitioner just expected Respondent to pivot, adjust and provide for the family financially every time she moved the family for her own career (4) Respondent was sometimes forced to take jobs that required him to live apart from the family in Lauren Ashley Payne v Chad Ellis Taylor Superior Court Gwinnett County, CAFN: 21-A-08580-9 Respondent’s Motion for Continuance of October 10, 2022 Hearing Page 2 of 4 order to contribute the family financially (5) Petitioner has (“naturally”) blamed Respondent for, at times, not being able to find work to support the family (6) After the birth of the parties’ first, non-marital child, Colton Ellis Taylor but before the birth of their second, non-marital child Colton Ellis Taylor, Petitioner married and divorced a man by the name of DJ Hill (7) in 2018 the parties to this litigation were engaged to be married (8) Respondent desires to be an engaged father and to have a close relationship with his sons Colton Ellis and Cache Elliott and has moved closer to them geographically to facilitate visitation (8) Respondent should have liberal visitation with his boys and there is no reason to remove his surname “Taylor” from the boys’ names. 12. Neither party has engaged in discovery, formal or otherwise and Respondent should be permitted to take written discovery and deposition testimony of plaintiff to ascertain the full and complete basis for her apparent desire as pled to effectively erase the children’s biological father Mr. Taylor from her sons’ lives while collecting child support. 13. Respondent requests that he be permitted time to meet and consult with his new attorney of record, to conduct discovery, to potentially engage in informal settlement discussions through his counsel to ensure that his legal right and interests are protected, and to have the opportunity to select a mutually agreed upon mediator through counsel before prior to a hearing in this matter. WHEREFORE, for the reasons set forth above, Respondent respectfully request: A) That this case be continued off the trial calendar commencing on October 10, 2022 to permit the parties to conduct in discovery in preparation for trial; and B) That he be granted such other and further relief as the court in its discretion deems Lauren Ashley Payne v Chad Ellis Taylor Superior Court Gwinnett County, CAFN: 21-A-08580-9 Respondent’s Motion for Continuance of October 10, 2022 Hearing Page 3 of 4 just and proper. This 26th day of September 2022. RESPECTFULLY SUBMITTED, HOBSON & HOBSON, P.C Geoff Wolfe ____________________________ Geoff Wolfe, Esq. Georgia Bar No.: 142130 Attorneys for the Respondent 136 Fairground St. NE Marietta, Georgia 30060 770.425.3373 geoff@hobsonlegal.com Lauren Ashley Payne v Chad Ellis Taylor Superior Court Gwinnett County, CAFN: 21-A-08580-9 Respondent’s Motion for Continuance of October 10, 2022 Hearing Page 4 of 4