Answer: In the Interest of Alessandria Cannon,Eve Cannon,Leland Cannon, child(ren)

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                                Received and E-Filed for Record
                                                                                                                     6/27/2016 12:23:08 PM
                                                                                                                     Barbara Gladden Adamick
                                                                                                                     District Clerk
                                                                                                                     Montgomery County, Texas


                  NOTICE: THIS DOCUMENT
                  CONTAINS SENSITIVE DATA
                                                             CAUSE NO. 13-12-13598

                  IN THE MATTER OF                                      §                           IN THE DISTRICT COURT
                  THE MARRIAGE OF                                       §
                                                                        §
                  KATHERINE MARIE CANNON                                §
                  AND                                                   §
                  LELAND DAVID CANNON                                   §                MONTGOMERY COUNTY, TEXAS
                                                                        §
                  AND IN THE INTEREST OF                                §
                  ALESSANDRIA CANNON,                                   §
                  EVE CANNON, AND                                       §
                  LELAND COOPER CANNON                                  §
                  CHILDREN                                              §                            410th JUDICIAL DISTRICT

                                             AMICUS ATTORNEY’s ORIGINAL ANSWER

                  TO THE HONORABLE K. MICHAEL MAYES:

                           Kristin Bays, Amicus Attorney for the Children (the “Children”), files this Original Answer,

                  and, in support, shows as follows:

                                                                   General Denial

                  1.       Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Kristin Bays, Amicus Attorney

                  for the Children generally denies all of the allegations, and demands strict proof of each allegation.

                                                            Best Interest of Children

                  2.       Amicus Attorney requests that the following factors be considered in determining the best

                  interest of the Children:

                           !        the desires of the Children;

                           !        the emotional and physical needs of the Children now and in the future;

                           !        any emotional and physical danger to the Children now and in the future;

                           !        the  parenting    ability  of  each   person   seeking    managing     conservatorship     of  the

                  Original Answer                                                                                            Page 1 of 3
                                    Children;

                           !        the programs available to assist each person seeking managing conservatorship of the
                                    Children in promoting the best interest of the Children;

                           !        the plans for the Children of each person seeking managing conservatorship of the
                                    Children;

                           !        the stability of the home of each person seeking managing conservatorship of the
                                    Children;

                           !        the  acts  or  omissions    of  each   person   seeking   managing     conservatorship     of  the
                                    Children; and

                           !        any   excuse     for  the   acts   or   omissions     of  each    person    seeking    managing
                                    conservatorship of the Children.

                                                                 Fees and Expenses

                  3.       It was necessary to render services to represent the Children.           The parties should be ordered

                  to pay reasonable fees and expenses, and judgment should be rendered against the parties and in

                  favor of the Amicus Attorney as to same.

                                                                  CONCLUSION

                  4.       Kristin Bays, Amicus Attorney for the Children, respectfully requests that the Court consider

                  the best interests of the Children, award fees and expenses to her, and that the Court grant to her such

                  other relief to which she may show herself justly entitled.

                                                                        Respectfully submitted,
                                                                        BAYS & BAYS
                                                                        1503 Hailey
                                                                        Conroe, Texas 77301
                                                                        Phone: (936) 760-7670
                                                                        Fax: (936) 760-7671
                                                                                 /s/ Kristin Bays
                                                                        Kristin Bays
                                                                        State Bar No. 00787914
                                                                        kristin@baysandbays.com
                                                                        AMICUS ATTORNEY FOR THE CHILDREN

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                                                         CERTIFICATE OF SERVICE
                           This is to certify that a true and correct copy of the foregoing Original Answer has been
                  delivered to the following counsel of record by eservice on June 27, 2016 pursuant to Texas Rules
                  of Civil Procedure 21 and 21a:
                           Jennifer Casey                                            By Email jennifer@jcaseylawfirm.com
                           THE LAW OFFICE OF JENNIFER CASEY
                           9595 Six Pines Drive, Suite 8210
                           The Woodlands, Texas 77380

                           Dustan Neyland                                           By Email dneyland@greconeyland.com
                           GRECO NEYLAND, PC
                           900 Rockmead, Suite 132
                           Kingwood, Texas 77339                                          /s/ Kristin Bays
                                                                                          Kristin Bays




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