On November 20, 2023 a
Complaint,Petition
was filed
involving a dispute between
Georgia Department Of Human Services,
Paulo, Jace,
Paulo, Jupiter,
The Georgia Department Of Human Services, Ex. Rel.,,
and
Paulo, Tristan,
for Support Enforcement*
in the District Court of Lowndes County.
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LOWNDES COUNTY, GEORGIA
Lowndes County - Superior Court
2023UR2043
11/20/2023 10:32 AM
Beth C. Greene
Clerk of Superior State Juvenile Courts
Reviewed by: Arianna Holmes
IN THE SUPERIOR COURT OF LOWNDES COUNTY
STATE OF GEORGIA
GEORGIA DEPARTMENT OF HUMAN CIVIL ACTION
SERVICES, ex. rel., 2023UR2043
FILE NO. _________
JUPITER PAULO
JACE PAULO
PLAINTIFF
v.
TRISTAN M PAULO
DEFENDANT
COMPLAINT FOR RECOVERY OF CHILD SUPPORT
COMES NOW, Georgia Department of Human Services, 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(REN)'S NAME(S) CHILD(REN)'S BIRTHDATE(S)
JUPITER PAULO XX-XX-2020
JACE PAULO XX-XX-2022
3. HENRY HARRIS PHILLIPS is the parent, custodian, or legal guardian of the above
named child(ren) who are in need of and entitled to support from Defendant. Defendant is able-
bodied and capable of earning sufficient monies with which to support said child(ren).
4. HENRY HARRIS PHILLIPS has 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 said minor child(ren) as his/
her 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, when such
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) That process issue as provided by law.
DCSS Case No.: 200030484
FormCAS Revised Fall/2019
b) That if Defendant denies or is unsure of the paternity of any of the above children or if
there is evidence to rebut any presumption of paternity, he be ordered to submit to genetic
testing through the State of Georgia unless there has been a prior adjudication of
paternity.
c) That Defendant be ordered to pay a reasonable amount of child support for the support
of said child(ren) in accordance with the guidelines of O.C.G.A. § 19-6-15 and that said
payments shall be paid through the Family Support Registry.
d) That Defendant be ordered to secure and maintain accident and sickness and/or health
insurance for said child(ren) when such is available at a reasonable cost.
e) That the Court order Plaintiff to issue an income deduction order pursuant to O.C.G.A.
§ 19-6-29 et seq.
f) That Court costs be assessed against Defendant herein; and
g) That the Court grant such other and further relief as it may deem just and appropriate.
This the 20th day of November, 2023.
__________________________________
Attorney for Child Support Services
Julia A. Baun/Margaret L. Chapura
Assistant District Attorney
Prepared by:
Julia A. Baun/Margaret L. Chapura
Assistant District Attorney
Division of Child Support Services
1730 Norman Drive
Valdosta, GA 31601
844-694-2347
Ga. State Bar No: 594630/121495
DCSS Case No.: 200030484
DCSS Case No.: 200030484
FormCAS Revised Fall/2019
Document Filed Date
November 20, 2023
Case Filing Date
November 20, 2023
Category
Support Enforcement*
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LOWNDES COUNTY, GEORGIA Lowndes County - Superior Court 2023UR2043 11/20/2023 10:32 AM Beth C. Greene Clerk of Superior State Juvenile Courts Reviewed by: Arianna Holmes IN THE SUPERIOR COURT OF LOWNDES COUNTY STATE OF GEORGIA GEORGIA DEPARTMENT OF HUMAN CIVIL ACTION SERVICES, ex. rel., 2023UR2043 FILE NO. _________ JUPITER PAULO JACE PAULO PLAINTIFF v. TRISTAN M PAULO DEFENDANT COMPLAINT FOR RECOVERY OF CHILD SUPPORT COMES NOW, Georgia Department of Human Services, 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(REN)'S NAME(S) CHILD(REN)'S BIRTHDATE(S) JUPITER PAULO XX-XX-2020 JACE PAULO XX-XX-2022 3. HENRY HARRIS PHILLIPS is the parent, custodian, or legal guardian of the above named child(ren) who are in need of and entitled to support from Defendant. Defendant is able- bodied and capable of earning sufficient monies with which to support said child(ren). 4. HENRY HARRIS PHILLIPS has 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 said minor child(ren) as his/ her 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, when such 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) That process issue as provided by law. DCSS Case No.: 200030484 FormCAS Revised Fall/2019 b) That if Defendant denies or is unsure of the paternity of any of the above children or if there is evidence to rebut any presumption of paternity, he be ordered to submit to genetic testing through the State of Georgia unless there has been a prior adjudication of paternity. c) That Defendant be ordered to pay a reasonable amount of child support for the support of said child(ren) in accordance with the guidelines of O.C.G.A. § 19-6-15 and that said payments shall be paid through the Family Support Registry. d) That Defendant be ordered to secure and maintain accident and sickness and/or health insurance for said child(ren) when such is available at a reasonable cost. e) That the Court order Plaintiff to issue an income deduction order pursuant to O.C.G.A. § 19-6-29 et seq. f) That Court costs be assessed against Defendant herein; and g) That the Court grant such other and further relief as it may deem just and appropriate. This the 20th day of November, 2023. __________________________________ Attorney for Child Support Services Julia A. Baun/Margaret L. Chapura Assistant District Attorney Prepared by: Julia A. Baun/Margaret L. Chapura Assistant District Attorney Division of Child Support Services 1730 Norman Drive Valdosta, GA 31601 844-694-2347 Ga. State Bar No: 594630/121495 DCSS Case No.: 200030484 DCSS Case No.: 200030484 FormCAS Revised Fall/2019