On March 09, 2015 a
Complaint,Petition
was filed
involving a dispute between
Tennant, Jr., David Randall,
and
Tennant, Monica Adell,
for Divorce - Children
in the District Court of Smith County.
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Electronically Filed
3/9/2015 11:58:24 AM
Lois Rogers, Smith County District Clerk
Reviewed By: Lora Rhodes
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
15-0525-D
CAUSE NO. _____________
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
DAVID RANDALL TENNANT, JR. §
AND § SMITH COUNTY, TEXAS
MONICA ADELL TENNANT §
§
AND IN THE INTEREST OF §
R.M.T. AND C.C.T., CHILDREN § _____ JUDICIAL DISTRICT
ORIGINAL PETITION FOR DIVORCE
1. Discovery Level
Discovery in this case is intended to be conducted under level 3 of rule 190 of the Texas
Rules of Civil Procedure.
2. Parties
This suit is brought by DAVID RANDALL TENNANT, JR., Petitioner. The last three
numbers of DAVID RANDALL TENNANT, JR.'S driver's license number are 246. The last
three numbers of DAVID RANDALL TENNANT, JR.'S Social Security number are 543.
Monica Adell Tennant is Respondent.
3. Domicile
Petitioner has been a domiciliary of Texas for the preceding six-month period and a
resident of this county for the preceding ninety-day period.
4. Service
No service on Respondent is necessary at this time.
Petitioner’s Original Petition for Divorce- Page |1
5. Protective Order Statement
No protective order under title 4 of the Texas Family Code is in effect, and no application
for a protective order is pending with regard to the parties to this suit.
6. Dates of Marriage and Separation
The parties were married on or about February 18, 2006 and ceased to live together as
husband and wife on or about February 25, 2015.
7. Grounds for Divorce
The marriage has become insupportable because of discord or conflict of personalities
between Petitioner and Respondent that destroys the legitimate ends of the marriage relationship
and prevents any reasonable expectation of reconciliation.
8. Children of the Marriage
Petitioner and Respondent are parents of the following children of this marriage who are
not under the continuing jurisdiction of any other court:
Name: Riley Madison Tennant
Sex: Female
Birth date: October 31, 2006
Name: Cambridge Claire Tannant
Sex: Female
Birth date: July 29, 2010
There are no court-ordered conservatorships, court-ordered guardianships, or other
court-ordered relationships affecting the children the subject of this suit.
The information required by section 154.181(b) of the Texas Family Code is as follows:
Insurance Company: Healthfirst
Petitioner’s Original Petition for Divorce- Page |2
Policy No.: 0070041
The Father/Petitioner is responsible for payment of the premiums in the amount of
$170.99 every two weeks for both children. The insurance is provided through the
Father/Petitioner’s employment at Access located in Jacksonville, Texas
No property of consequence is owned or possessed by the children the subject of this suit.
The appointment of Petitioner and Respondent as joint managing conservators would not
be in the best interest of the children. Petitioner, on final hearing, should be appointed sole
managing conservator, with all the rights and duties of a parent sole managing conservator, and
Respondent should not be ordered to make payments for the support of the children and to
provide medical child support in the manner specified by the Court.
9. Division of Community Property
Petitioner believes Petitioner and Respondent will enter into an agreement for the
division of their estate. If such an agreement is made, Petitioner requests the Court to approve
the agreement and divide their estate in a manner consistent with the agreement. If such an
agreement is not made, Petitioner requests the Court to divide their estate in a manner that the
Court deems just and right, as provided by law.
10. Prayer
Petitioner prays that citation and notice issue as required by law and that the Court grant a
divorce and all other relief requested in this petition.
Petitioner prays for general relief.
Petitioner’s Original Petition for Divorce- Page |3
Respectfully submitted,
Foley & Colley, PC
1310 ESE Loop 323
Tyler, Texas 75701
Tel: (903) 593-8883
Fax: (903) 593-1099
By: ____/s/Susan J. Colley
SUSAN J. COLLEY
Texas Bar No. 13805700
colleys@tyler.net
Attorney for Petitioner
Petitioner’s Original Petition for Divorce- Page |4
Document Filed Date
March 09, 2015
Case Filing Date
March 09, 2015
Category
Divorce - Children
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Electronically Filed 3/9/2015 11:58:24 AM Lois Rogers, Smith County District Clerk Reviewed By: Lora Rhodes NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA 15-0525-D CAUSE NO. _____________ IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § DAVID RANDALL TENNANT, JR. § AND § SMITH COUNTY, TEXAS MONICA ADELL TENNANT § § AND IN THE INTEREST OF § R.M.T. AND C.C.T., CHILDREN § _____ JUDICIAL DISTRICT ORIGINAL PETITION FOR DIVORCE 1. Discovery Level Discovery in this case is intended to be conducted under level 3 of rule 190 of the Texas Rules of Civil Procedure. 2. Parties This suit is brought by DAVID RANDALL TENNANT, JR., Petitioner. The last three numbers of DAVID RANDALL TENNANT, JR.'S driver's license number are 246. The last three numbers of DAVID RANDALL TENNANT, JR.'S Social Security number are 543. Monica Adell Tennant is Respondent. 3. Domicile Petitioner has been a domiciliary of Texas for the preceding six-month period and a resident of this county for the preceding ninety-day period. 4. Service No service on Respondent is necessary at this time. Petitioner’s Original Petition for Divorce- Page |1 5. Protective Order Statement No protective order under title 4 of the Texas Family Code is in effect, and no application for a protective order is pending with regard to the parties to this suit. 6. Dates of Marriage and Separation The parties were married on or about February 18, 2006 and ceased to live together as husband and wife on or about February 25, 2015. 7. Grounds for Divorce The marriage has become insupportable because of discord or conflict of personalities between Petitioner and Respondent that destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation of reconciliation. 8. Children of the Marriage Petitioner and Respondent are parents of the following children of this marriage who are not under the continuing jurisdiction of any other court: Name: Riley Madison Tennant Sex: Female Birth date: October 31, 2006 Name: Cambridge Claire Tannant Sex: Female Birth date: July 29, 2010 There are no court-ordered conservatorships, court-ordered guardianships, or other court-ordered relationships affecting the children the subject of this suit. The information required by section 154.181(b) of the Texas Family Code is as follows: Insurance Company: Healthfirst Petitioner’s Original Petition for Divorce- Page |2 Policy No.: 0070041 The Father/Petitioner is responsible for payment of the premiums in the amount of $170.99 every two weeks for both children. The insurance is provided through the Father/Petitioner’s employment at Access located in Jacksonville, Texas No property of consequence is owned or possessed by the children the subject of this suit. The appointment of Petitioner and Respondent as joint managing conservators would not be in the best interest of the children. Petitioner, on final hearing, should be appointed sole managing conservator, with all the rights and duties of a parent sole managing conservator, and Respondent should not be ordered to make payments for the support of the children and to provide medical child support in the manner specified by the Court. 9. Division of Community Property Petitioner believes Petitioner and Respondent will enter into an agreement for the division of their estate. If such an agreement is made, Petitioner requests the Court to approve the agreement and divide their estate in a manner consistent with the agreement. If such an agreement is not made, Petitioner requests the Court to divide their estate in a manner that the Court deems just and right, as provided by law. 10. Prayer Petitioner prays that citation and notice issue as required by law and that the Court grant a divorce and all other relief requested in this petition. Petitioner prays for general relief. Petitioner’s Original Petition for Divorce- Page |3 Respectfully submitted, Foley & Colley, PC 1310 ESE Loop 323 Tyler, Texas 75701 Tel: (903) 593-8883 Fax: (903) 593-1099 By: ____/s/Susan J. Colley SUSAN J. COLLEY Texas Bar No. 13805700 colleys@tyler.net Attorney for Petitioner Petitioner’s Original Petition for Divorce- Page |4