On September 19, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Xxxx, Xxxxxx Xxxxx,
and
Xxxx, Xxxxxxx,
for Parent-Child - No Divorce
in the District Court of Fort Bend County.
Preview
Filed
9/26/2023 2:17 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Janae Sutton
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
NO. 23-DCV-308870
IN THE INTEREST OF IN THE DISTRICT COURT
a 328TH JUDICIAL DISTRICT
A CHILD FORT BEND COUNTY, TEXAS
MOTION TO DISMISS WRIT OF ATTACHEMENT
This Motion to Dismiss Writ of Attachment is brought by xxxxxxx xxxx, Respondent, who
shows in support:
1 xxxxxxx xxxx is the mother of the child the subject of this suit.
2 Petitioner forfeited any possession periods due to Petitioner moving out of Fort
Bend County, leaving child with Respondent, and refusing visitation due to Respondent’s child
support request.
3. Petitioner has yet to provide any evidence that there is a serious, immediate threat to
the child’s physical or emotional well-being while in the care of Respondent, since the birth of
the child 7
4. Petitioner has yet to have a consistent, permanent address since the birth of the child of
this suit in
5. Petitioner has a history of illegal drug and substance abuse since the birth of the child
of this suit.
6. Respondent has not been voluntarily and/or involuntarily placed under mental health
confinement as is of sound mind.
xxxxxxx xxxx prays that the Court dismiss this Writ of Attachment without prejudice as
provided for by section 155.102 of the Texas Family Code.
QC 09/28/23 w
ROUTED TO COURT 9/26/2023 JS
RT'D TO D. CLERK 9/27/23 DD
Respectfully submitted,
EATON LAW FIRM, LLC
1105 Yale St.
Houston, Texas 77008
Tel: 281-969-4860
Fax: 281-941-5178
By: /s/ Zachary G. Sanders
Zachary G. Sanders
State Bar No. 24118522
eatonfamilylawgroup@gmail.com
Attorney for xxxxxxx xxxx
Notice of Hearing
The above matter is set for hearing on October 4, 2023 at 8:30a_. M. in
1422 Eugene Heimann Circle, Richmond, Texas 77469. The contact information for the court is
phone number 281-341-4406 or 328th@fbctx.gov.
YOU MUST PARTICIPATE IN THE HEARING BY APPEARING IN-PERSON
AT THE COURTHOUSE.
TO APPEAR IN PERSON: At the designated time above, report in-person at the above
location.
If you plan to introduce documents and evidence during your hearing, you must be
prepared to share them with the clerk and other parties at laest two days proior to any hearing or
trial. Exhibits shall be pre-marked , exchanged and copies provided to all counsel and self-
represented litigants at least two days prior to any hearing or trial. Exhibits should be pre-marked
identifying the offering party (Petitioner, Respondent, Intervenor, etc.) and using numbers only.
For example, "Petitioner Ex. I" but not "Petitioner Ex. A."
9/27/2023
SIGNED on
Judge or Clerk
Certificate of Service
I certify that a true copy of this Motion to Dismiss Writ of Attachment was served in
accordance with rule 21a of the Texas Rules of Civil Procedure on the following on September
26, 2023:
Stephanie Dromgoole by electronic filing manager.
/s/ Zachary G. Sanders
Zachary G. Sanders
Attorney for xxxxxx xxxxx xxxx
Document Filed Date
September 26, 2023
Case Filing Date
September 19, 2023
Category
Parent-Child - No Divorce
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Filed 9/26/2023 2:17 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Janae Sutton NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA NO. 23-DCV-308870 IN THE INTEREST OF IN THE DISTRICT COURT a 328TH JUDICIAL DISTRICT A CHILD FORT BEND COUNTY, TEXAS MOTION TO DISMISS WRIT OF ATTACHEMENT This Motion to Dismiss Writ of Attachment is brought by xxxxxxx xxxx, Respondent, who shows in support: 1 xxxxxxx xxxx is the mother of the child the subject of this suit. 2 Petitioner forfeited any possession periods due to Petitioner moving out of Fort Bend County, leaving child with Respondent, and refusing visitation due to Respondent’s child support request. 3. Petitioner has yet to provide any evidence that there is a serious, immediate threat to the child’s physical or emotional well-being while in the care of Respondent, since the birth of the child 7 4. Petitioner has yet to have a consistent, permanent address since the birth of the child of this suit in 5. Petitioner has a history of illegal drug and substance abuse since the birth of the child of this suit. 6. Respondent has not been voluntarily and/or involuntarily placed under mental health confinement as is of sound mind. xxxxxxx xxxx prays that the Court dismiss this Writ of Attachment without prejudice as provided for by section 155.102 of the Texas Family Code. QC 09/28/23 w ROUTED TO COURT 9/26/2023 JS RT'D TO D. CLERK 9/27/23 DD Respectfully submitted, EATON LAW FIRM, LLC 1105 Yale St. Houston, Texas 77008 Tel: 281-969-4860 Fax: 281-941-5178 By: /s/ Zachary G. Sanders Zachary G. Sanders State Bar No. 24118522 eatonfamilylawgroup@gmail.com Attorney for xxxxxxx xxxx Notice of Hearing The above matter is set for hearing on October 4, 2023 at 8:30a_. M. in 1422 Eugene Heimann Circle, Richmond, Texas 77469. The contact information for the court is phone number 281-341-4406 or 328th@fbctx.gov. YOU MUST PARTICIPATE IN THE HEARING BY APPEARING IN-PERSON AT THE COURTHOUSE. TO APPEAR IN PERSON: At the designated time above, report in-person at the above location. If you plan to introduce documents and evidence during your hearing, you must be prepared to share them with the clerk and other parties at laest two days proior to any hearing or trial. Exhibits shall be pre-marked , exchanged and copies provided to all counsel and self- represented litigants at least two days prior to any hearing or trial. Exhibits should be pre-marked identifying the offering party (Petitioner, Respondent, Intervenor, etc.) and using numbers only. For example, "Petitioner Ex. I" but not "Petitioner Ex. A." 9/27/2023 SIGNED on Judge or Clerk Certificate of Service I certify that a true copy of this Motion to Dismiss Writ of Attachment was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on September 26, 2023: Stephanie Dromgoole by electronic filing manager. /s/ Zachary G. Sanders Zachary G. Sanders Attorney for xxxxxx xxxxx xxxx