Document for In the Matter of the Marriage of Carlos Smith and Tamiskia Smith and in the Interest of Minor Child(ren)

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                                JOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA


                                        NO. 15-DCV-227783

IN THE INTEREST OF                                                         IN THE DISTRICT COURT

T.S., C.S. AND C.S.                                                      328TH JUDICIAL DISTRICT

CHILDREN                                                              FORT BEND COUNTY, TEXAS


           MOTION FOR POSSESSION AND ACCESS WITH MINOR CHILDREN

       This Motion for Enforcement of Possession and Access with Minor Children is brought
by CARLOS A. SMITH, Movant, who is the father of the children the subject of this suit who
would show the Court the following:

        Movant will be reporting to the Oakdale Unit 2 Federal Detention Center located in
Oakdale, Louisianna on October 1, 2019, to begin serving his 18 month sentence. This facility is
considered to be a low security federal correctional institution. The Oakdale facility is located in
central Louisiana fifty-eight miles north of Lake Charles, Louisiana.      This facility affords its
occupants liberal telephone access between the hours of 6:00 a.m. and 9:00 p.m., seven (7)
days a week, with phone calls limited to fifteen (15) minutes each.

        Movant is requesting telephone access to his children during this period of incarceration
and is requesting the Court award him such periods and further, to order Respondent, Tamiska
Smith, to make the children available during certain hours of the day or early evening so
Movant can continue to speak with his children during this time period.

        Movant also believes that he will be afforded the opportunity to have the use of
electronic devices so that he is able to Skype with the children at some point in the future.
Movant is requesting the Court award him such periods and further, to order Respondent,
Tamiskia Smith, to make the children available during certain hours of the day or early evening
so Movant can utilitize the Skype feature in order to speak with his children during this time
period.

        The request for this access would be not only in the best interest of the minor children
but would be beneficial to Movant in his efforts to keep into place, a consistent, on-going
relationship with his children.




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Movant    prays the Court grant this Motion for Possession and Access with the Minor
Children     and    for such   other   and   further   relief Movant        may      be        entitled,   both   special   and
general.
                                                       Respectfully submitted:
                                                       ZINSMEISTER LAW FIRM, P.C.




                                                                      fs
                                                       Maren ZINSIV ISTER
                                                       TBA# 2227)
                                                       106 Guent    Street
                                                       Sugar Land, Texas 77478
                                                       (281) 265-4111 - Office
                                                       Email: mz@mzfamily.com
                                                       Attorney for Respondent
                                                       CARLOS SMITH

                                                 NOTICE OF HEARING

           IT 1s ORDERED       that the hearing on the above Motion is set for hearing         on

            i                   2019, at £8 a.m. in the 328" Judicial District Court of Fort Bend
County, Texas.


                                                                      Jf]    ister
                                                       Marlene Zins|

                                                 CERTIFICATE OF SERVIC!

         | hereby certify that a true and correct copy of the foregoing instrument has been served in accordance
with the Texas RULES OF CIVIL PROCEDURE as indicated below on the      day of September 2019:

           Mr. Jeremy B. DuCote                                                                                       Via E-Serve
           Attorney at Law
           The Love DuCote Law Firm LLC
           1650 Highway 6, Suite 420
           Sugar Land, Texas 77478

           Ms. Lori Kern                                                                                              Via E-Serve
           Attorney at Law
           Kern Law
           22310 Grand Corner Drive, Suite 200
           Katy, Texas 77494



                                                                  MARLENE ZINSI           ER




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