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

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                                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                               *


                                       REQUEST FOR ADMISSIONS

Pursuant to O.C.G.A. § 9-11-36, Plaintiff hereby requests that Defendant respond to the following Requests for
Admission of Facts:

That each of the following statements is true:

1.     Defendant is the natural parent of each and every child listed in Plaintiff's complaint.
2.     Defendant is subject to the venue and jurisdiction of this Court.
3.     The custodian named in the petition has actual custody of the child(ren) named therein either because
       Defendant has no custodial rights under the law, or with permission or consent of Defendant, or pursuant
       to a valid court order.
4.     Defendant has the capability of paying, and it is fair and reasonable for Defendant to pay current child
       support.
5.     Defendant has the capability of obtaining accident and sickness insurance and/or health insurance for the
       minor children at a reasonable cost.
6.     Defendant has no court ordered visitation in excess of 90 days.

        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




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