Document for Department of Human Services, ex rel., VS SHONTAY THOMAS

• 
• 
• 
• 

						
                                
Preview
                                IN THE SUPERIOR COURT OF DEKALB COUNTY
                                STATE OF GEORGIA
GEORGIA DEPARTMENT OF                   *
HUMAN SERVICES, ex rel.,                * CIVIL ACTION FILE
ISRAEL LEE THOMAS, JUDAH LEE THOMAS, *
GENESIS LEAH THOMAS ,                   *
PLAINTIFF                               * NO.: ______________________
  v.                                    *
                                        *
SHONTAY THOMAS                          *
DEFENDANT                               *


                         COMPLAINT FOR RECOVERY OF CHILD SUPPORT
       Comes Now Plaintiff on behalf of the above-named minor child(ren), and shows the following to this
Honorable Court:

       1.      Defendant has submitted to or is subject to the jurisdiction and venue of this Court.

       2.      Defendant is the parent of the following named minor child(ren):

      Child's Name                                           Child's Birth Year
       ISRAEL LEE THOMAS                                     XX-XX-2017
       JUDAH LEE THOMAS                                      XX-XX-2018
       GENESIS LEAH THOMAS                                   XX-XX-2020

       3. NOORA MOHAMMAD , is the custodian of the above-named child(ren), who is/are in need of and
entitled to support from Defendant. Defendant is able-bodied and capable of earning sufficient monies with
which to support the child(ren).

       4. The custodian applied to Plaintiff for assistance in establishing a child support order and has
authorized Plaintiff to collect any support which may be ordered by this court.

       5. Defendant is obligated to provide for the future support of the minor child(ren) as Defendant’s ability
permits, and pursuant to O.C.G.A. § 19-11-26, should provide accident and sickness coverage for the child(ren)
and/or health insurance pursuant to O.C.G.A. § 19-6-15, if the Court finds that coverage is available at a
reasonable cost.
       6. This case is subject to the mandatory income deduction provisions of O.C.G.A. § 19-6-30 et seq.

   WHEREFORE, PLAINTIFF prays:
   a) For an order requiring Defendant to pay a reasonable amount for the support of the above-named minor
      child(ren) in accordance with the guidelines of O.C.G.A. § 19-6-15;
   b) Defendant be ordered to secure and maintain accident and sickness insurance coverage on behalf of the
      child(ren) at all times such coverage is reasonably available as provided by law;
   c) The Court order Division of Child Support Services to issue an income deduction order issue pursuant to
      O.C.G.A. § 19-6-29 through § 19-6-33;

FORMCAF $tars Re-Write                       DCSS Case No: 360030307                Fall 2018
    d) That if Defendant is unsure of or denies paternity or there is evidence to rebut any presumption of
       paternity that this Court order Defendant to undergo testing through the State of Georgia, unless there
       has been a prior adjudication of paternity.
    e) That all costs be assessed against Defendant; and
    f) For such other and further relief as the Court deems just and proper.

        This the 5th day of February 2023.



                                                            Erica Arena-Camarillo/s/
                                                            Attorney for Child Support Services
Prepared by: Division of Child Support Services             Special Assistant Attorney General
2910 Miller Road, Suite #100                              Erica.Arena-Camarillo@dhs.ga.gov
Decatur, Georgia 30035-4037                               ( ) Ladonya.Horton         Ga Bar No 461350
Tele: (877) 423-4746                                      ( ) Andre Johnson          Ga Bar No 392226
Fax: (770) 593-6985                                       ( ) Jean.Carson            Ga Bar No 002880
                                                          (X) Erica.Arena-Camarillo Ga Bar No 056616


CHRISTOPHER M. CARR          112505          SHALEN S. NELSON 636575
Attorney General                             Senior Assistant Attorney General
BRYAN K. WEBB                743580          JASON S. NAUNAS 142051
Deputy Attorney General                      Assistant Attorney General



KEARRIA DAVIS




FORMCAF $tars Re-Write                       DCSS Case No: 360030307               Fall 2018