Preview
Filed
9/19/2023 11:50 AM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Christina Haddox
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
NG DCV-308870
IN THE INTEREST OF IN THE DISTRICT COURT
Fort Bend County - 328th Judicial District Court
| JUDICIAL DISTRICT
A CHILD FORT BEND COUNTY, TEXAS
ORIGINAL PETITION IN SUIT AFFECTING THE
PARENT-CHILD RELATIONSHIP, REQUEST FOR TEMPORARY ORDERS,
REQUEST FOR EXTRAORDINARY RELIEF, AND APPLICATION FOR WRIT
OF ATTACHMENT
1 Discovery Level
Discovery in this case is intended to be conducted under level 2 of rule 190 of the
Texas Rules of Civil Procedure.
2. Objection to Assignment of Case to Associate Judge
Petitioner objects to the assignment of this matter to an associate judge for a trial
on the merits or presiding at a jury trial.
3. Parties
This suit is brought by xxxxxx xxxx, Petitioner. The last three numbers of xxxxxx
xxxx's driver's license number are 893 and the last three numbers of his Social Security
number are 400.
Respondent is xxxxxxx xxxx, the child’s mother.
Petitioner is the father of the child the subject of this suit.
Petitioner has standing to bring this suit in that he is the biological father of the
child. Further, Petitioner has executed a valid Acknowledgment of Paternity that is
attached hereto as Exhibit “A”.
xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request
for
Extraordinary Relief, and Applicationfor Writ of Attachment
Page 1 of 5
Jurisdiction
No court has continuing jurisdiction of this suit or of the child the subject of this
suit.
Child
The following child is the subject of this suit:
Name:
Sex Male
Birth date:
County of Residence: Fort Bend County
Person Entitled to Citation
Process should be served on the mother of the child, xxxxxxx xxxx, at 7622 Butler
Lakes Ct., Rosenberg, Texas 77469, or wherever she may be found.
There are no court-ordered conservatorships, court-ordered guardianships, or other
court-ordered relationships affecting the child the subject of this suit.
7. Insurance Information
Information required by section 154.181(b) and section 154.1815(c) of the Texas
Family Code will be provided before a trial on the merits.
8. Property
No property of consequence is owned or possessed by the child the subject of this
suit.
9. Protective Order Statement
No protective order under title 4 of the Texas Family Code, protective order under
subchapter A, chapter 7B of the Texas Code of Criminal Procedure, or order for
emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in
effect in regard to a party to this suit or a child of a party to this suit, and no application
for any such order is pending.
xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for
Extraordinary Relief, and Application for Writ of Attachment
Page 2 of 5
10. Conservatorship
The parents of the child are or will be separated. Petitioner believes that the
parties will enter into a written agreement containing provisions for conservatorship of,
possession of, and access to the child. If such an agreement is not made, Petitioner
requests the Court to make orders for conservatorship of, possession of, and access to the
child.
Respondent’s mental health and well-being is at issue, such that the present
circumstances would significantly impair the child’s physical health or emotional
development. Petitioner requests the Court render a possession order designed to protect
the safety and well-being of the child, including but not limited to ordering Respondent’s
periods of access be continuously supervised by a person chosen by the Court.
11. Support
Petitioner requests that Respondent be ordered to provide support for the child,
including the payment of child support and medical and dental support, in the manner
specified by the Court. Petitioner requests that the payments for the support of the child
survive the death of Respondent and become the obligations of Respondent's estate.
12. Request for Temporary Orders
Petitioner requests the Court, after notice and hearing, to make temporary orders
for the safety and welfare of the child, including but not limited to the following:
Appointing Petitioner and xxxxxxx xxxx temporary joint managing conservators
and designating Petitioner as the conservator who has the exclusive right to designate the
primary residence of the child. Petitioner requests the Court to apportion the rights and
duties of a parent set out in section 153.132 of the Texas Family Code.
Ordering Respondent to provide support for the child, including the payment of
child support and medical and dental support in the manner specified by the Court, while
this case is pending.
Awarding Petitioner the exclusive right to enroll the child in school or daycare.
Respondent’s mental health and well-being is at issue, such that the present
circumstances would significantly impair the child’s physical health or emotional
development. Petitioner requests the Court render a possession order designed to protect
xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for
Extraordinary Relief, and Application for Writ of Attachment
Page 3 of 5
the safety and well-being of the child, including but not limited to ordering Respondent’s
periods of access be continuously supervised by a person chosen by the Court.
13. Request for Extraordinary Relief and Application for Writ of Attachment
As the basis for the extraordinary relief and application for writ of attachment
requested below, Petitioner would show that before the filing of this petition Respondent
has engaged in the conduct stated in the affidavit attached as Exhibit “B”. Based on that
affidavit, Petitioner requests the Court to grant the following relief:
1 Issue an order taking the child, nto possession of
Petitioner.
2. Issue_an_ order excluding Respondent from possession of or access to
the child,
3. Issue and order temporarily enjoining Respondent from removing the
hr from the possession of Petitioner, xxxxxx xxxx.
This request for extraordinary relief is for the safety and welfare of the child and is
necessary because the child’s present circumstances with Respondent would significantly
impair the child’s physical health or emotional well-being.
14, Standing Injunctions
On January 4, 2021, the 328", 387", and 505" Judicial District Courts issued the
Standing Order Regarding Temporary Injunctions for the 328", 387", and 505" District
Court. This order applies in every suit affecting the parent-child relationship filed in Fort
Bend County, Texas. A true and correct copy of the order is attached hereto as Exhibit
“C” and is incorporated herein by reference for all intents and purposes.
15. Request for Attorney’s Fees, Expenses, Costs, and Interest
It was necessary for Petitioner to secure the services of Stephanie Kay Dromgoole,
a licensed attorney, to preserve and protect the child's rights. Respondent should be
ordered to pay reasonable attorney's fees, expenses, and costs through trial and appeal,
and a judgment should be rendered in favor of this attorney and against Respondent and
be ordered paid directly to Petitioner's attorney, who may enforce the judgment in the
attorney's own name. Petitioner requests postjudgment interest as allowed by law.
xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request
for
Extraordinary Relief, and Application for Writ of Attachment
Page 4 of 5
16. Prayer
Petitioner prays that citation and notice issue as required by law and that the Court
enter its orders in accordance with the allegations contained in this petition.
Petitioner prays that the Court immediately grant a temporary restraining order
restraining Respondent, in conformity with the allegations of this petition, from the acts
set forth above, and Petitioner prays that, after notice and hearing, this temporary
restraining order be made a temporary injunction.
Petitioner prays the Court grant the Application for Writ of Attachment.
Petitioner prays for attorney's fees, expenses, costs, and interest as requested
above.
Petitioner prays for general relief.
Respectfully submitted,
DIGGS & SADLER
[ili al
Stephanie Kay Dromgoole
State Bar No. 24105821
Eservice:sdromgoole@texasadvocates.com
5300 Memorial Drive, Suite 900
Houston, Texas 77007
Tel: (713) 802-1777
Fax: (713) 802-1779
Attorney for Petitioner,
xxxxxx xxxx
xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for
Extraordinary Relief, and Application for Writ of Attachment
Page 5 of 5
DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D
oFov
fdBye. STATE OF TEXAS
i
ACKNOWLEDGMENT OF PATERNITY
This is a legal document. Type or Print in black ink. Parents are to be given a copy of this completed document.
We declare under penalty of perjury that xxxxxx xxxxx xxxx
Biological Father's first widdle Tast name
is the biological father of ra
k's Fiest middle last name
born on La
7m ad yyy
———EEEEe
ily
ree
county state
|
to xxxxxxx LAKSHMI xxxx xxxx
Mother's first middle Tast name maiden name if different
a 815 SOUTH LITTLEFIELD RD MOUNT PLESEANT MICHIGAN 48858
Father's date of birth soc security qumber address city state 2ip code
= 5455 RICHMOND AVE 3027 HOUSTON TEXAS 77056
Mother's date of birth social security number address city state zip code
We further declare under penalty of perjury that:
© We have been given written and oral notice of: the benefits of having paternity established; the availability of
paternity establishment and child support services; and the legal consequences of, the rights and responsibilities
of, and the alternative to signing this Acknowledgment.
3 * No other Acknowledgment of Paternity form naming another man as the biological father of this child has been filed.
© There is no court order naming another man as the biological father of this child.
« A genetic test has not determined that another man is the biological father of this child.
Fill one circle by the correct statement from EACH of the following:
There has not been genetic testing of the man listed © Genetic testing has determined that the man listed above is the
above to determine if he is the biological father of this child. OF biological father of this child.
3
x
‘The ¢ mother was not married to someone other than the ‘© The mother was married to someone other than the biological
biological father at the time of the child's birth or within father at the time of the child's birth or during the 300 days
100 days prior to the child's date of birth, or there is a court r before the child's birth or during the first two years of the child's
order that states that the man the mother was married to is life, a man continuously lived with the child and represented the
not the father ‘of the child, and during the first two years of child as his own; and that man has completed the Denial of
the child's life, no man continuously lived with the child Paternity below or has a Denial of Paternity filed with the Vital
and represented the child as his own. Statistics Unit.
C Deceit
- FIL. / 5/13/2023
Full Signature of Biological Father date Full Signature of Mother date
FOI FOIE III TOR ICT ISI ITED JOR JOTI TI IOS ISE JE IOI oI oI Io IgE Ta In inn In gf ink ink tok tok
Denial of Paternity (onty required if “mother was married to someone other than the biological father or if, during the child's first wo
years of life, a man continuously lived with the child and represented the child as his own" is checked.)
We declare under penalty of perjury that
Presumed Father's first middle ast name
the presumed father of the child, is not the biological father. We understand that filing of this denial with an acknowledgment
se removes the presumed father's legal duty to support the child and terminates his right of custody or visitation with the child.
Full Signature of Presumed Father date Full Signature of Mother date
1 t -
Presumed Father's date of birth saclal Seouriy number Presumed Father's address city state zip code
Entity Code 311
5130 Ex]
‘Texas Department of State Health Services
Vital Statistics Unit
VS-159.1M_ Revised 9/2011
DocuSign Envelope ID: E825D136-62FD-4C00-9DD5-66BDE4C50A5D
This is a legal document. if you are not sure that the man named in this Acknowledgment is the biological
father of the child, you should NOT sign this dacument. You may want to get a genetic test. The biological father
who signs this Acknowledgment becomes the legal father of the child when this document is filed with the
Department of State Health Services, Texas Vital Statistics
Signing this legal document gives you certain rights and responsibilities. Signing this document is voluntary. You
should consult an attorney if you have any concerns about signing this document. This document requires an
Entity Code completed in the lower right corner by an individual certified by the Office of the Attorney General to
administer Acknowledgments of Paternity.
Benefits, Right, and Responsibilities of Paternity
Establishing parentage makes It easier for a child to receive benefits such as social security, military and veteran's
benefits, health care coverage and life insurance, as well as inheritance.
This Acknowledgment has the same effect as a court order establishing paternity. Both parents have parental
right and duties as provided by state law. Either parent has the right to seek primary custody of the child. A
parent not living with the child may have the right to visit and maintain a relationship with the child, either as both
parents agree or as ordered by a court, By signing this Acknowledgment, you may be ordered to pay child support
and medical support.
This document may be completed before the birth of the child, at the time of birth, or at any time after the birth of
the child prior to any court hearing in a proceeding involving
the child. If this document is signed before the birth
of the child, it is binding for any child born no later than 300 days after the signature date on this document.
When this Acknowledgment is properly filed with Texas Vital Statistics, it creates a parent-child relationship
between the man and child. Establishment of paternity is required for a father's name to be entered ona birth
certificate.
Child Support services can be obtained through the Office of the Attorney General,
Child Support Division or by hiring an attorney.
Denial of Paternity
{fa child's mother is married to a man other than the biological father at the time of birth or within 300 days of the
ending of a marriage (by a finalized divorce,} the (ex) husband is presumed to be the legal father. To complete this
document for a child that has a presumed father, the presumed father must deny paternity by completing the
Denial of Paternity section. The mother must agree that the presumed father is not the biological father by also
signing the denial section. The acknowledgment section must also be completed by the biological father and
mother, or the denial will not be accepted. Upon the filing of this document, the presumed father is legally
determined not to be the father of the child. His legal duty to support the child is removed. Likewtse, his legal
right of custody or visitation with the child isterminated.
hange of Mind
If any party to this document changes his/her mind about acknowledging or denying paternity, he/she may file a
Rescission of Acknowledgment of Paternity (VS-158) to rescind this document. The Resclssion of
Acknowledgment of Paternity must be filed within sixty (60) days after this legal document is filed with Texas Vital
Statistics or before the date a proceeding related to the child is initiated, whichever occurs first. After sixty (60)
days, or the date a proceeding for the child was initiated, a lawsuit is required to challenge this document. Fraud,
duress, or material mistake of fact in signing this form must be proven during the lawsuit.
If a Party is a Minor
Minors are authorized to complete the Acknowledgment of Paternity without parental consent. Minors are
allowed to rescind or challenge this document in the same procedures as persons eighteen (18) or older.
All parties must receive oral notice of the above information before completing this Acknowledgment. You can
receive oral notice of the information by calling 1-866-255-2006 and selecting option 1, "Notice of Rights and
Responsibilities of a Parent."
If you have questions, you may call the Paternity Opportunity Program at 1-866-255-2006.
September 2011
DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D
English
RNEY PARENT SURVEY ON THE ACKNOWLEDGEMENT OF PATERNITY (AOP)
Mandated By Law
ie
This Survey should be completed after the AOP has been signed or a person has declined
to sign the AOP,
5130
Hospital/Entity Name & Location: THE WOMAN'S HOSPITAL OF TEXAS Entity Code:
Child’s Name: Date of Birth}
Please read and INITIAL the following:
[want to sign AOP.
STATEMENTS MOTHER FATHER
1._I was given the opportunity to sign an Acknowledgment of Paternity. PY
2. [choose NOT to complete an Acknowledgment of Paternity
If vou initial #2, please skip questions 3 through 8.
3,_Lwas made aware that I could have a DNA test done before I signed the AOP. pty
fv
4. Iwas given written and oral information regarding the benefits, rights and responsibilities of an
AOP, an explanation ofthose rights and responsibilities, and information about child support.
5. The biological father who signed this AOP will have all legal rights and duties of a parent. This
may include the legal responsibility for financial and medical support of the child named in this
AOP.
6, If I change my mind, a Rescission of Acknowledgment of Paternity (VS-158) must be filed within
the earlier of 60 days of signing the Acknowledgment of Paternity or the date a proceeding
involving the child is initiated before a court.
Chy
7. After 60 days, I may challenge the AOP in court and must prove fraud, duress, or material mistake
of fact. ey
8. 1 was given a completed copy of the AOP with the benefits, rights, and responsibilities on the
back. Cy
Mother’s Printed Name: ID Type:
Mother’s Signature: Phone Number:
Father's Printed Name: xxxxxx xxxxx xxxx UNITED STATES PASSPORT
ID Type:
eset Zba
Father's Signature: a Z; Phone Number: 313-580-3870
mata
Certified Staff Signature: LA WREMDESSON Date: 5/15/2023
Cente,
Presumed Father: (After you read the Denial of Paternity and Change of Mind sections of the rights and
responsibilities, please read the statement below and initial.)
After I have signed the Denial of Paternity and it has been filed with the Vital Statistics Unit, my legal rights and
responsibilities to this child will be terminated, If I change my mind, a Rescission of Acknowledgment of Paternity (VS-
158) can be filed within the earlier of 60 days of signing the Acknowledgment of Paternity or the date a proceeding involving
the child is initiated before a court. After 60 days, I may challenge the AOP in court and must prove fraud, duress, or
material mistake of fact.
Initial Here:
Presumed Father's Printed Name: ID Type:
Presumed Father's Signature: Phone Number:
Certified Stalf Signature: Date:
Jamuary 2015 Father Email: VOLZMARTIN@GMAIL.COM 1798
DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D
NEY ENCUESTA SOBRE EL RECONOCIMIENTO DE PATERNIDAD(AOP)
ue YSh Ordenada en Conformidad con la Ley
Rs Y
yy
Esta encuesta debe ser llenada después de que el Reconocimiento de Paternidad (AOP) ha
Oe
sido firmado o después de que una persona se ha negado a firmarto,
a7)
THE WOMAN'S HOSPITAL OF TEXAS
Hospital/Entidad Nombre y Ubicacién: Cédigo de la Entidad 5130
Nombre del Nifio(a): Fecha de Necimient(
Favor de leer y poner sus INICIALES en las siguientes declaracioncs:
DECLARACIONES MAMA PAPA
1. Me dieron la oportunidad de firmar un formulario de Reconocimiento de Parternidad (Acknowledgment of
Patemity, AOP, en inglés)...
‘Tomo la opicién de NO Hlenar un Reconocimiento de Patemtidad (AOP).
Si Pone sus iniciales en #2, por favor ignore las preguntas3 a 8.
3. Me han informado que me puedo someter a una prueba genética de ADN (DNA)antes de firmar of
Reconocimiento de Paternidad (AOP)
Me dieron informacién por escrito y oralmente con respecio a fos beneficios, derechos y responsabilidades
de un AOP, una explicacién de tales derechos y responsabilidades e informacién sobre la manutencién de
niftos,
El padre biolégico que firmé este AOP tendré todos los derechos y deberes legales de un padre. Esto puede
incluir la responsabilidad legal de manutencién econdmica y manutencién médica del nifio nombrado en este
AOP.,
Si cambio de opinién, una Anulacién de Reconocimiento (VS-158) debe ser presentada ya sea dentro de 60
dias de haber firmado el AOP o antes de la fecha en que inicie un procedimiento refacionado con el nifio ante
Ja corte, lo que ocurra primero.
Después de 60 dias, puedo desafiar e! AOP ante la corte y debo comprobar fraude, coaccién, o error material
de un hecho,
Me dieron una copia del AOP Ilenado, con los beneficios, derechos, y responsabilidades en la parte posterior..
Nombre de la Mama en letra de molde: Identificacién:
Firma de fa Mama:: Numero de teléfono:,
Nombre del Papa en letra de mode ldentificacién: _ UNITED STATES PASSPORT
Firma del Papa ‘Numero de teléfono: 313-580-3870
ett
Firma del Personal Certificado- (rot werdeesow Fecha: 5/15/2023
El Presunto Papa: (Después de leer las secciones: Negacién de Paternidad (Denial of Paternity) y Cambio de Opinién (Change of Mind), en los
Derechos y Responsabilidades, por favor tea la siguiente declaracién y ponga sus iniciales.)
Después de que yo haya firmado la Negacién de Paternidad y sea presentada ante la Unidad de Estadisticas Vitales (Vital
Statistics Unit), mis derechos y responsabilidades legales hacia este nifio seran terminados, Si cambio de opinién, se puede
presentar una Anulacién del Reconocimiento de Paternidad (VS-158) ya sea dentro de 60 dias de haber firmado el AOP o antes
de la fecha en que inicie un procedimiento relacionado con el nifio ante fa corte, lo que ocurra primero. Después de 60 dias, puedo
desafiar el AOP ante la corte y debo comprobar fraude, coaccién, o error material de un hecho.
Iniciales aqui:
‘Nombre del Presunto Papa en letra de molde: Identificacién,
Finma de! Presunto Papa: Numero de teléfono:
Firma del Personal Certificado: Fecha:
January 2015 1798
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
NO.
IN THE INTEREST OF IN THE DISTRICT COURT
>ae JUDICIAL DISTRICT
A CHILD FORT BEND COUNTY, TEXAS
DECLARATION OF xxxxxx xxxx
1. My name is xxxxxx xxxx. I am over the age of twenty-one (21) years and am fully
competent to make this declaration. My date of birth is y work
address is 440 Louisiana Street, Houston, Texas 77002. I declare, certify, verify, and
state under penalty of perjury that the following is true and correct and is based on my
personal knowledge and my review of relevant records and communications.
I am the father o: ineeta xxxx is nother. lam
writing this declaration to ask the Court to restrict xxxxxxx’s access to [and prevent
xxxxxxx from removing tom my possession until we can have a hearing. I am
deeply concerned about xxxxxxx’s mental health and iii safety while he is in her
care at this time. xxxxxxx has a history of attempted suicide and depression. In
September of 2022, xxxxxxx attempted suicide and was sent to treatment for two weeks.
xxxxxxx was pregnant wit at the time she tried to take her life. For the past few
i“
weeks, xxxxxxx has sterically almost every day. She has admitted depression to
me, She has pulled out of daycare and has threatened to throw away|
belongings.
On September 8, 2023, I informed xxxxxxx xxxx that I was going to move out of the
home where I, xxxxxxx and our son. lived beginning in July 2023. Based on
how xxxxxxx would react when I told her that I wished to leave on prior conversations
I recorded the incident. During the course of almost two hours xxxxxxx proceeded to
prevent me from leaving the home by shouting, crying, physically preventing me from
moving, blocking the door and locking the door. She repeatedly grabbed my arms
refusing to let go, which caused me pain. ecame upset due to the crying and
screaming. I tried to soothe him and calm him down as well as xxxxxxx. During this
incident, xxxxxxx repeated the same things over and over and over again. There were
times when she started to hyperventilate. Being worried for ny and safety Thad
to leave the home. I offered to take with me or to take| to xxxxxxx’s parent’s
home, but xxxxxxx would not let me. Based on xxxxxxx already assaulting me and doing
everything in her power to keep me from leaving the house, I did not feel like I could
safely get out of the home with me.
4
-
T believe that xxxxxxx is not mentally stable. Because of the tender age of mi I
am fearful that xxxxxxx may cause harm t lor unwittingly allo to be hurt while
-_
in her custody. I am fearful that xxxxxxx may attempt to harm herself. I am fearful that
xxxxxxx’s current depression may result it not getting the daily care he needs such
as feeding, diaper changes, and baths.
5 Since J left the house on September 8, 2023, xxxxxxx has sent me dozens and dozens
of text messages that I believe further evidence her mental instability.
6 It is evident that xxxxxxx does not see that she is mentally unstable. For
safety and well-being, I believe it is imperative that xxxxxxx seek mental health treatment
and be required to follow the recommendations of her mental health providers.
a Based on the mental instability that xxxxxxx has evidenced over the past few weeks,
coupled with her previous attempted suicide and admission of depression, I respectfully
request the Court to place into my immediate possession and order that xxxxxxx not
remove, from my possession.
Signed on September 19, 2023, in Harris County, Texas.
Signed:
xxxxxx xxxx, Declarant
CAUSE NO ( \
IN THE INTEREST OF IN THE DISTRICT COURT.
TH JUDICIA aS a ?
MINOR CHILD(REN) FORT ) counfy
SUIT AFFECTING PARENT CHILD Re ‘TIONS Lo)
STANDING TEMPORARY MUTUAL INJ NCTIONS
THE PARTIES TO THE ABOVE PENDING LAWSUI ARE ORDERED TO COMPLY
WITH THE FOLLOWING ORDERS OF THE COURT’ WHILETHE’LAWSUIT IS
PENDING. THE TEMPORARY INJUNCTION APPLIES LO THE PETITIONER AND
RESPONDENT AND IS EFFECTIVE IMMROIATELY.
\
NO DISRUPTION OF A CHILD Hols THE.
TH SUBJEC
All parties are ORDERED to eft na doing! the igllowing acts concerning
any child who is the si We ject o ‘a,case ‘without a Written agreement of all
parties or an order of tl © oun f
Arata:
~
Removing a child fri the Ss! ate of Texas. eB the purpose of changing the
residence of the child dr evading. the jurisdiction of the Court, acting
directly or in concert with others.
Disrupting or withdrawing a child TRadine school or day-care facility where
a child is preserttly énrolted.
Hiding or secreting a.child from/the other parent or changing the child’
current place of bode.
defz
Disturbi fg the peace of the ‘child or the other party.
na iri paragina.s renparks regarding the other party or the other party's
ily i in uth presence or within the hearing of a child.
( \
U. Conner or THE! Jarctcs DURING THE CASE.
oS parties ar€\ORIDERED to refrain from doing the following acts:
“Intentidnajly communicating in person or in any other manner, including by
telephony or another electronic voice transmission, video chat, in writing, or
electronic messaging, with the other party by use of vulgar, profane,
Exhibit “C”
obscene or indecent language or in a coarse or o} nsive manner, with
Sp
intent to annoy or alarm the other party;
Threatening another party in person or in any other manner, iheluding b!
telephone or another electronic voice transmission, video Gtrat, in writing,
electronic messaging, to take unlawful action against Any personwinten
by this action to annoy or alarm the other party;
Placing a telephone cali, anonymously, nN unréasonabl ui , in an
e
offensive and repetitious manner, or legitimate purpose of
communication with the intent to annoy or alarm tlhe r party;
c
Intentionally, knowingly, or recklessly causit dily infui to the other party
or to a child of either party;
Threatening the other party
injury. OF hild of\eithér.pai wh imminent bodily
SIGNED this_Y“* dayof CZ)
iow, 2004
a he 4)
>~fIMNKA INE, UAAA
Walter Armatys Ja it Heppard
Presiding Judge siding Judge
Hed Mon O
Kali Morgan
Presiding Judge
FILED
1 JAN PH 3: Why
N'sbe. Valley
CLERK DISTRICT COURT
FORT BEND CO. Tx
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Filed 9/19/2023 11:50 AM Beverley McGrew Walker District Clerk Fort Bend County, Texas Christina Haddox NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NG DCV-308870 IN THE INTEREST OF IN THE DISTRICT COURT Fort Bend County - 328th Judicial District Court | JUDICIAL DISTRICT A CHILD FORT BEND COUNTY, TEXAS ORIGINAL PETITION IN SUIT AFFECTING THE PARENT-CHILD RELATIONSHIP, REQUEST FOR TEMPORARY ORDERS, REQUEST FOR EXTRAORDINARY RELIEF, AND APPLICATION FOR WRIT OF ATTACHMENT 1 Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Objection to Assignment of Case to Associate Judge Petitioner objects to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. 3. Parties This suit is brought by xxxxxx xxxx, Petitioner. The last three numbers of xxxxxx xxxx's driver's license number are 893 and the last three numbers of his Social Security number are 400. Respondent is xxxxxxx xxxx, the child’s mother. Petitioner is the father of the child the subject of this suit. Petitioner has standing to bring this suit in that he is the biological father of the child. Further, Petitioner has executed a valid Acknowledgment of Paternity that is attached hereto as Exhibit “A”. xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for Extraordinary Relief, and Applicationfor Writ of Attachment Page 1 of 5 Jurisdiction No court has continuing jurisdiction of this suit or of the child the subject of this suit. Child The following child is the subject of this suit: Name: Sex Male Birth date: County of Residence: Fort Bend County Person Entitled to Citation Process should be served on the mother of the child, xxxxxxx xxxx, at 7622 Butler Lakes Ct., Rosenberg, Texas 77469, or wherever she may be found. There are no court-ordered conservatorships, court-ordered guardianships, or other court-ordered relationships affecting the child the subject of this suit. 7. Insurance Information Information required by section 154.181(b) and section 154.1815(c) of the Texas Family Code will be provided before a trial on the merits. 8. Property No property of consequence is owned or possessed by the child the subject of this suit. 9. Protective Order Statement No protective order under title 4 of the Texas Family Code, protective order under subchapter A, chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party to this suit or a child of a party to this suit, and no application for any such order is pending. xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for Extraordinary Relief, and Application for Writ of Attachment Page 2 of 5 10. Conservatorship The parents of the child are or will be separated. Petitioner believes that the parties will enter into a written agreement containing provisions for conservatorship of, possession of, and access to the child. If such an agreement is not made, Petitioner requests the Court to make orders for conservatorship of, possession of, and access to the child. Respondent’s mental health and well-being is at issue, such that the present circumstances would significantly impair the child’s physical health or emotional development. Petitioner requests the Court render a possession order designed to protect the safety and well-being of the child, including but not limited to ordering Respondent’s periods of access be continuously supervised by a person chosen by the Court. 11. Support Petitioner requests that Respondent be ordered to provide support for the child, including the payment of child support and medical and dental support, in the manner specified by the Court. Petitioner requests that the payments for the support of the child survive the death of Respondent and become the obligations of Respondent's estate. 12. Request for Temporary Orders Petitioner requests the Court, after notice and hearing, to make temporary orders for the safety and welfare of the child, including but not limited to the following: Appointing Petitioner and xxxxxxx xxxx temporary joint managing conservators and designating Petitioner as the conservator who has the exclusive right to designate the primary residence of the child. Petitioner requests the Court to apportion the rights and duties of a parent set out in section 153.132 of the Texas Family Code. Ordering Respondent to provide support for the child, including the payment of child support and medical and dental support in the manner specified by the Court, while this case is pending. Awarding Petitioner the exclusive right to enroll the child in school or daycare. Respondent’s mental health and well-being is at issue, such that the present circumstances would significantly impair the child’s physical health or emotional development. Petitioner requests the Court render a possession order designed to protect xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for Extraordinary Relief, and Application for Writ of Attachment Page 3 of 5 the safety and well-being of the child, including but not limited to ordering Respondent’s periods of access be continuously supervised by a person chosen by the Court. 13. Request for Extraordinary Relief and Application for Writ of Attachment As the basis for the extraordinary relief and application for writ of attachment requested below, Petitioner would show that before the filing of this petition Respondent has engaged in the conduct stated in the affidavit attached as Exhibit “B”. Based on that affidavit, Petitioner requests the Court to grant the following relief: 1 Issue an order taking the child, nto possession of Petitioner. 2. Issue_an_ order excluding Respondent from possession of or access to the child, 3. Issue and order temporarily enjoining Respondent from removing the hr from the possession of Petitioner, xxxxxx xxxx. This request for extraordinary relief is for the safety and welfare of the child and is necessary because the child’s present circumstances with Respondent would significantly impair the child’s physical health or emotional well-being. 14, Standing Injunctions On January 4, 2021, the 328", 387", and 505" Judicial District Courts issued the Standing Order Regarding Temporary Injunctions for the 328", 387", and 505" District Court. This order applies in every suit affecting the parent-child relationship filed in Fort Bend County, Texas. A true and correct copy of the order is attached hereto as Exhibit “C” and is incorporated herein by reference for all intents and purposes. 15. Request for Attorney’s Fees, Expenses, Costs, and Interest It was necessary for Petitioner to secure the services of Stephanie Kay Dromgoole, a licensed attorney, to preserve and protect the child's rights. Respondent should be ordered to pay reasonable attorney's fees, expenses, and costs through trial and appeal, and a judgment should be rendered in favor of this attorney and against Respondent and be ordered paid directly to Petitioner's attorney, who may enforce the judgment in the attorney's own name. Petitioner requests postjudgment interest as allowed by law. xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for Extraordinary Relief, and Application for Writ of Attachment Page 4 of 5 16. Prayer Petitioner prays that citation and notice issue as required by law and that the Court enter its orders in accordance with the allegations contained in this petition. Petitioner prays that the Court immediately grant a temporary restraining order restraining Respondent, in conformity with the allegations of this petition, from the acts set forth above, and Petitioner prays that, after notice and hearing, this temporary restraining order be made a temporary injunction. Petitioner prays the Court grant the Application for Writ of Attachment. Petitioner prays for attorney's fees, expenses, costs, and interest as requested above. Petitioner prays for general relief. Respectfully submitted, DIGGS & SADLER [ili al Stephanie Kay Dromgoole State Bar No. 24105821 Eservice:sdromgoole@texasadvocates.com 5300 Memorial Drive, Suite 900 Houston, Texas 77007 Tel: (713) 802-1777 Fax: (713) 802-1779 Attorney for Petitioner, xxxxxx xxxx xxxx —Original Petition in Suit Affecting the Parent-Child Relationship, Request for Temporary Orders, Request for Extraordinary Relief, and Application for Writ of Attachment Page 5 of 5 DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D oFov fdBye. STATE OF TEXAS i ACKNOWLEDGMENT OF PATERNITY This is a legal document. Type or Print in black ink. Parents are to be given a copy of this completed document. We declare under penalty of perjury that xxxxxx xxxxx xxxx Biological Father's first widdle Tast name is the biological father of ra k's Fiest middle last name born on La 7m ad yyy ———EEEEe ily ree county state | to xxxxxxx LAKSHMI xxxx xxxx Mother's first middle Tast name maiden name if different a 815 SOUTH LITTLEFIELD RD MOUNT PLESEANT MICHIGAN 48858 Father's date of birth soc security qumber address city state 2ip code = 5455 RICHMOND AVE 3027 HOUSTON TEXAS 77056 Mother's date of birth social security number address city state zip code We further declare under penalty of perjury that: © We have been given written and oral notice of: the benefits of having paternity established; the availability of paternity establishment and child support services; and the legal consequences of, the rights and responsibilities of, and the alternative to signing this Acknowledgment. 3 * No other Acknowledgment of Paternity form naming another man as the biological father of this child has been filed. © There is no court order naming another man as the biological father of this child. « A genetic test has not determined that another man is the biological father of this child. Fill one circle by the correct statement from EACH of the following: There has not been genetic testing of the man listed © Genetic testing has determined that the man listed above is the above to determine if he is the biological father of this child. OF biological father of this child. 3 x ‘The ¢ mother was not married to someone other than the ‘© The mother was married to someone other than the biological biological father at the time of the child's birth or within father at the time of the child's birth or during the 300 days 100 days prior to the child's date of birth, or there is a court r before the child's birth or during the first two years of the child's order that states that the man the mother was married to is life, a man continuously lived with the child and represented the not the father ‘of the child, and during the first two years of child as his own; and that man has completed the Denial of the child's life, no man continuously lived with the child Paternity below or has a Denial of Paternity filed with the Vital and represented the child as his own. Statistics Unit. C Deceit - FIL. / 5/13/2023 Full Signature of Biological Father date Full Signature of Mother date FOI FOIE III TOR ICT ISI ITED JOR JOTI TI IOS ISE JE IOI oI oI Io IgE Ta In inn In gf ink ink tok tok Denial of Paternity (onty required if “mother was married to someone other than the biological father or if, during the child's first wo years of life, a man continuously lived with the child and represented the child as his own" is checked.) We declare under penalty of perjury that Presumed Father's first middle ast name the presumed father of the child, is not the biological father. We understand that filing of this denial with an acknowledgment se removes the presumed father's legal duty to support the child and terminates his right of custody or visitation with the child. Full Signature of Presumed Father date Full Signature of Mother date 1 t - Presumed Father's date of birth saclal Seouriy number Presumed Father's address city state zip code Entity Code 311 5130 Ex] ‘Texas Department of State Health Services Vital Statistics Unit VS-159.1M_ Revised 9/2011 DocuSign Envelope ID: E825D136-62FD-4C00-9DD5-66BDE4C50A5D This is a legal document. if you are not sure that the man named in this Acknowledgment is the biological father of the child, you should NOT sign this dacument. You may want to get a genetic test. The biological father who signs this Acknowledgment becomes the legal father of the child when this document is filed with the Department of State Health Services, Texas Vital Statistics Signing this legal document gives you certain rights and responsibilities. Signing this document is voluntary. You should consult an attorney if you have any concerns about signing this document. This document requires an Entity Code completed in the lower right corner by an individual certified by the Office of the Attorney General to administer Acknowledgments of Paternity. Benefits, Right, and Responsibilities of Paternity Establishing parentage makes It easier for a child to receive benefits such as social security, military and veteran's benefits, health care coverage and life insurance, as well as inheritance. This Acknowledgment has the same effect as a court order establishing paternity. Both parents have parental right and duties as provided by state law. Either parent has the right to seek primary custody of the child. A parent not living with the child may have the right to visit and maintain a relationship with the child, either as both parents agree or as ordered by a court, By signing this Acknowledgment, you may be ordered to pay child support and medical support. This document may be completed before the birth of the child, at the time of birth, or at any time after the birth of the child prior to any court hearing in a proceeding involving the child. If this document is signed before the birth of the child, it is binding for any child born no later than 300 days after the signature date on this document. When this Acknowledgment is properly filed with Texas Vital Statistics, it creates a parent-child relationship between the man and child. Establishment of paternity is required for a father's name to be entered ona birth certificate. Child Support services can be obtained through the Office of the Attorney General, Child Support Division or by hiring an attorney. Denial of Paternity {fa child's mother is married to a man other than the biological father at the time of birth or within 300 days of the ending of a marriage (by a finalized divorce,} the (ex) husband is presumed to be the legal father. To complete this document for a child that has a presumed father, the presumed father must deny paternity by completing the Denial of Paternity section. The mother must agree that the presumed father is not the biological father by also signing the denial section. The acknowledgment section must also be completed by the biological father and mother, or the denial will not be accepted. Upon the filing of this document, the presumed father is legally determined not to be the father of the child. His legal duty to support the child is removed. Likewtse, his legal right of custody or visitation with the child isterminated. hange of Mind If any party to this document changes his/her mind about acknowledging or denying paternity, he/she may file a Rescission of Acknowledgment of Paternity (VS-158) to rescind this document. The Resclssion of Acknowledgment of Paternity must be filed within sixty (60) days after this legal document is filed with Texas Vital Statistics or before the date a proceeding related to the child is initiated, whichever occurs first. After sixty (60) days, or the date a proceeding for the child was initiated, a lawsuit is required to challenge this document. Fraud, duress, or material mistake of fact in signing this form must be proven during the lawsuit. If a Party is a Minor Minors are authorized to complete the Acknowledgment of Paternity without parental consent. Minors are allowed to rescind or challenge this document in the same procedures as persons eighteen (18) or older. All parties must receive oral notice of the above information before completing this Acknowledgment. You can receive oral notice of the information by calling 1-866-255-2006 and selecting option 1, "Notice of Rights and Responsibilities of a Parent." If you have questions, you may call the Paternity Opportunity Program at 1-866-255-2006. September 2011 DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D English RNEY PARENT SURVEY ON THE ACKNOWLEDGEMENT OF PATERNITY (AOP) Mandated By Law ie This Survey should be completed after the AOP has been signed or a person has declined to sign the AOP, 5130 Hospital/Entity Name & Location: THE WOMAN'S HOSPITAL OF TEXAS Entity Code: Child’s Name: Date of Birth} Please read and INITIAL the following: [want to sign AOP. STATEMENTS MOTHER FATHER 1._I was given the opportunity to sign an Acknowledgment of Paternity. PY 2. [choose NOT to complete an Acknowledgment of Paternity If vou initial #2, please skip questions 3 through 8. 3,_Lwas made aware that I could have a DNA test done before I signed the AOP. pty fv 4. Iwas given written and oral information regarding the benefits, rights and responsibilities of an AOP, an explanation ofthose rights and responsibilities, and information about child support. 5. The biological father who signed this AOP will have all legal rights and duties of a parent. This may include the legal responsibility for financial and medical support of the child named in this AOP. 6, If I change my mind, a Rescission of Acknowledgment of Paternity (VS-158) must be filed within the earlier of 60 days of signing the Acknowledgment of Paternity or the date a proceeding involving the child is initiated before a court. Chy 7. After 60 days, I may challenge the AOP in court and must prove fraud, duress, or material mistake of fact. ey 8. 1 was given a completed copy of the AOP with the benefits, rights, and responsibilities on the back. Cy Mother’s Printed Name: ID Type: Mother’s Signature: Phone Number: Father's Printed Name: xxxxxx xxxxx xxxx UNITED STATES PASSPORT ID Type: eset Zba Father's Signature: a Z; Phone Number: 313-580-3870 mata Certified Staff Signature: LA WREMDESSON Date: 5/15/2023 Cente, Presumed Father: (After you read the Denial of Paternity and Change of Mind sections of the rights and responsibilities, please read the statement below and initial.) After I have signed the Denial of Paternity and it has been filed with the Vital Statistics Unit, my legal rights and responsibilities to this child will be terminated, If I change my mind, a Rescission of Acknowledgment of Paternity (VS- 158) can be filed within the earlier of 60 days of signing the Acknowledgment of Paternity or the date a proceeding involving the child is initiated before a court. After 60 days, I may challenge the AOP in court and must prove fraud, duress, or material mistake of fact. Initial Here: Presumed Father's Printed Name: ID Type: Presumed Father's Signature: Phone Number: Certified Stalf Signature: Date: Jamuary 2015 Father Email: VOLZMARTIN@GMAIL.COM 1798 DocuSign Envelope ID: EB25D136-62FD-4C00-9DD5-66BDE4C50A5D NEY ENCUESTA SOBRE EL RECONOCIMIENTO DE PATERNIDAD(AOP) ue YSh Ordenada en Conformidad con la Ley Rs Y yy Esta encuesta debe ser llenada después de que el Reconocimiento de Paternidad (AOP) ha Oe sido firmado o después de que una persona se ha negado a firmarto, a7) THE WOMAN'S HOSPITAL OF TEXAS Hospital/Entidad Nombre y Ubicacién: Cédigo de la Entidad 5130 Nombre del Nifio(a): Fecha de Necimient( Favor de leer y poner sus INICIALES en las siguientes declaracioncs: DECLARACIONES MAMA PAPA 1. Me dieron la oportunidad de firmar un formulario de Reconocimiento de Parternidad (Acknowledgment of Patemity, AOP, en inglés)... ‘Tomo la opicién de NO Hlenar un Reconocimiento de Patemtidad (AOP). Si Pone sus iniciales en #2, por favor ignore las preguntas3 a 8. 3. Me han informado que me puedo someter a una prueba genética de ADN (DNA)antes de firmar of Reconocimiento de Paternidad (AOP) Me dieron informacién por escrito y oralmente con respecio a fos beneficios, derechos y responsabilidades de un AOP, una explicacién de tales derechos y responsabilidades e informacién sobre la manutencién de niftos, El padre biolégico que firmé este AOP tendré todos los derechos y deberes legales de un padre. Esto puede incluir la responsabilidad legal de manutencién econdmica y manutencién médica del nifio nombrado en este AOP., Si cambio de opinién, una Anulacién de Reconocimiento (VS-158) debe ser presentada ya sea dentro de 60 dias de haber firmado el AOP o antes de la fecha en que inicie un procedimiento refacionado con el nifio ante Ja corte, lo que ocurra primero. Después de 60 dias, puedo desafiar e! AOP ante la corte y debo comprobar fraude, coaccién, o error material de un hecho, Me dieron una copia del AOP Ilenado, con los beneficios, derechos, y responsabilidades en la parte posterior.. Nombre de la Mama en letra de molde: Identificacién: Firma de fa Mama:: Numero de teléfono:, Nombre del Papa en letra de mode ldentificacién: _ UNITED STATES PASSPORT Firma del Papa ‘Numero de teléfono: 313-580-3870 ett Firma del Personal Certificado- (rot werdeesow Fecha: 5/15/2023 El Presunto Papa: (Después de leer las secciones: Negacién de Paternidad (Denial of Paternity) y Cambio de Opinién (Change of Mind), en los Derechos y Responsabilidades, por favor tea la siguiente declaracién y ponga sus iniciales.) Después de que yo haya firmado la Negacién de Paternidad y sea presentada ante la Unidad de Estadisticas Vitales (Vital Statistics Unit), mis derechos y responsabilidades legales hacia este nifio seran terminados, Si cambio de opinién, se puede presentar una Anulacién del Reconocimiento de Paternidad (VS-158) ya sea dentro de 60 dias de haber firmado el AOP o antes de la fecha en que inicie un procedimiento relacionado con el nifio ante fa corte, lo que ocurra primero. Después de 60 dias, puedo desafiar el AOP ante la corte y debo comprobar fraude, coaccién, o error material de un hecho. Iniciales aqui: ‘Nombre del Presunto Papa en letra de molde: Identificacién, Finma de! Presunto Papa: Numero de teléfono: Firma del Personal Certificado: Fecha: January 2015 1798 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. IN THE INTEREST OF IN THE DISTRICT COURT >ae JUDICIAL DISTRICT A CHILD FORT BEND COUNTY, TEXAS DECLARATION OF xxxxxx xxxx 1. My name is xxxxxx xxxx. I am over the age of twenty-one (21) years and am fully competent to make this declaration. My date of birth is y work address is 440 Louisiana Street, Houston, Texas 77002. I declare, certify, verify, and state under penalty of perjury that the following is true and correct and is based on my personal knowledge and my review of relevant records and communications. I am the father o: ineeta xxxx is nother. lam writing this declaration to ask the Court to restrict xxxxxxx’s access to [and prevent xxxxxxx from removing tom my possession until we can have a hearing. I am deeply concerned about xxxxxxx’s mental health and iii safety while he is in her care at this time. xxxxxxx has a history of attempted suicide and depression. In September of 2022, xxxxxxx attempted suicide and was sent to treatment for two weeks. xxxxxxx was pregnant wit at the time she tried to take her life. For the past few i“ weeks, xxxxxxx has sterically almost every day. She has admitted depression to me, She has pulled out of daycare and has threatened to throw away| belongings. On September 8, 2023, I informed xxxxxxx xxxx that I was going to move out of the home where I, xxxxxxx and our son. lived beginning in July 2023. Based on how xxxxxxx would react when I told her that I wished to leave on prior conversations I recorded the incident. During the course of almost two hours xxxxxxx proceeded to prevent me from leaving the home by shouting, crying, physically preventing me from moving, blocking the door and locking the door. She repeatedly grabbed my arms refusing to let go, which caused me pain. ecame upset due to the crying and screaming. I tried to soothe him and calm him down as well as xxxxxxx. During this incident, xxxxxxx repeated the same things over and over and over again. There were times when she started to hyperventilate. Being worried for ny and safety Thad to leave the home. I offered to take with me or to take| to xxxxxxx’s parent’s home, but xxxxxxx would not let me. Based on xxxxxxx already assaulting me and doing everything in her power to keep me from leaving the house, I did not feel like I could safely get out of the home with me. 4 - T believe that xxxxxxx is not mentally stable. Because of the tender age of mi I am fearful that xxxxxxx may cause harm t lor unwittingly allo to be hurt while -_ in her custody. I am fearful that xxxxxxx may attempt to harm herself. I am fearful that xxxxxxx’s current depression may result it not getting the daily care he needs such as feeding, diaper changes, and baths. 5 Since J left the house on September 8, 2023, xxxxxxx has sent me dozens and dozens of text messages that I believe further evidence her mental instability. 6 It is evident that xxxxxxx does not see that she is mentally unstable. For safety and well-being, I believe it is imperative that xxxxxxx seek mental health treatment and be required to follow the recommendations of her mental health providers. a Based on the mental instability that xxxxxxx has evidenced over the past few weeks, coupled with her previous attempted suicide and admission of depression, I respectfully request the Court to place into my immediate possession and order that xxxxxxx not remove, from my possession. Signed on September 19, 2023, in Harris County, Texas. Signed: xxxxxx xxxx, Declarant CAUSE NO ( \ IN THE INTEREST OF IN THE DISTRICT COURT. TH JUDICIA aS a ? MINOR CHILD(REN) FORT ) counfy SUIT AFFECTING PARENT CHILD Re ‘TIONS Lo) STANDING TEMPORARY MUTUAL INJ NCTIONS THE PARTIES TO THE ABOVE PENDING LAWSUI ARE ORDERED TO COMPLY WITH THE FOLLOWING ORDERS OF THE COURT’ WHILETHE’LAWSUIT IS PENDING. THE TEMPORARY INJUNCTION APPLIES LO THE PETITIONER AND RESPONDENT AND IS EFFECTIVE IMMROIATELY. \ NO DISRUPTION OF A CHILD Hols THE. TH SUBJEC All parties are ORDERED to eft na doing! the igllowing acts concerning any child who is the si We ject o ‘a,case ‘without a Written agreement of all parties or an order of tl © oun f Arata: ~ Removing a child fri the Ss! ate of Texas. eB the purpose of changing the residence of the child dr evading. the jurisdiction of the Court, acting directly or in concert with others. Disrupting or withdrawing a child TRadine school or day-care facility where a child is preserttly énrolted. Hiding or secreting a.child from/the other parent or changing the child’ current place of bode. defz Disturbi fg the peace of the ‘child or the other party. na iri paragina.s renparks regarding the other party or the other party's ily i in uth presence or within the hearing of a child. ( \ U. Conner or THE! Jarctcs DURING THE CASE. oS parties ar€\ORIDERED to refrain from doing the following acts: “Intentidnajly communicating in person or in any other manner, including by telephony or another electronic voice transmission, video chat, in writing, or electronic messaging, with the other party by use of vulgar, profane, Exhibit “C” obscene or indecent language or in a coarse or o} nsive manner, with Sp intent to annoy or alarm the other party; Threatening another party in person or in any other manner, iheluding b! telephone or another electronic voice transmission, video Gtrat, in writing, electronic messaging, to take unlawful action against Any personwinten by this action to annoy or alarm the other party; Placing a telephone cali, anonymously, nN unréasonabl ui , in an e offensive and repetitious manner, or legitimate purpose of communication with the intent to annoy or alarm tlhe r party; c Intentionally, knowingly, or recklessly causit dily infui to the other party or to a child of either party; Threatening the other party injury. OF hild of\eithér.pai wh imminent bodily SIGNED this_Y“* dayof CZ) iow, 2004 a he 4) >~fIMNKA INE, UAAA Walter Armatys Ja it Heppard Presiding Judge siding Judge Hed Mon O Kali Morgan Presiding Judge FILED 1 JAN PH 3: Why N'sbe. Valley CLERK DISTRICT COURT FORT BEND CO. Tx