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  • In the Interest of: Jackson Keith Dotter,Audrey Claire DotterPost Judgment Actions Enforcement document preview
  • In the Interest of: Jackson Keith Dotter,Audrey Claire DotterPost Judgment Actions Enforcement document preview
  • In the Interest of: Jackson Keith Dotter,Audrey Claire DotterPost Judgment Actions Enforcement document preview
  • In the Interest of: Jackson Keith Dotter,Audrey Claire DotterPost Judgment Actions Enforcement document preview
						
                                

Preview

Received and E-Filed for Record 1/15/2019 8:07 AM Melisa Miller District Clerk Montgomery County, Texas NOTICE: TI-Ils DOCUMENT CONTAINS SENSITIVE DATA 19-01-00677 CAUSE N0. IN THE MATTER OF IN THE DISTRICT COURT THE MARRIAGE 0F Montgomery County - 410th Judicial District Court ANGELA DEANN DOTI'ER AND JUDICIAL DISTRICT JAMES BRANDON mmmmmw‘lmmww DOTI'ER AND IN THE INTEREST 0F JACKSON KEITH DOTI'ER AND AUDREY CLAIRE DOTI'ER, CHILDREN § MONTGOMERY COUNTY, TEXAS MQTION T0 SEAL COURT RECORDS This Motion to Seal Court Records is brought by ANGELA DEANN DOTTER, Applicant, who shows in support: 1. This is an action originally arising out of the Texas Family Code. and the documents filed in this case are not subject to the standards for sealing court records set forth in rule 763 of the Texas Rules of Civil Procedure. 2. The specific facts and circumstances of this case. as more specifically the attached hereto as Exhin “A”, present a serious and described in affidavit substantial interest which clearly outweighs the presumption of openness or any probable adverse effect that sealing wili have upon the general public health and safety. Movant would further show unto the Court that no less restrictive means than sealing records will adequame and effectively protect the safety of Movant. 3. Movant requests that the Court temporarily seal the records in this case and would further show that Movant will suffer immediate and irreparable injury before notice can be posted and a hearing held. ANGELA DEANN DOTTER requests that the records in this case be sealed, as requested. ANGELA DEANN DOTTER prays that the Court grant the Motion to Seal Court Records. MOTION TO SEAL COURT RECORDS 1 Resp llysubmitted, LYNN E. mé ESPOSITO T SBN: 06667690 26000 Budde Road The Woodlands, Texas 77380 Tel: (281) 362-1191 Fax: (281) 292-7041 Email: lynn@woodlandsfamilylaw.com eservioeesposito@woodlandsfamilylaw.com Attorney for Petitioner NOTICE OF HEARING The above motion is set for hearing on at _.M. in the SIGNED on Judge or Clerk MOTION TO SEAL COURT RECORDS 2 ‘Nonce: THIS DOCUMENT CONTAINS SENsrrIvE DATA CAUSE NO. IN THE PROTECTION OF IN THE DISTRICT COURT ANGELA DEANN DOTTER, Applicant VS. WWWWWWWWWW) JUD!ClAL DISTRICT JAMES BRANDON DOTI'ER, Respondent AND FOR THE PROTECTION OF AUDREY CLAIRE DO'I'I'ER, CHILD § MONTGOMERY COUNTY, TEXAS AFFIDAVIT IN SUPPORT OF PROTECTIVE ORDER I,ANGELA DEANN DOTTER am the applicant in the above Application for a Protective Order. I am over the age of 18 and am fully capable of making this affidavit. The facts and circumstances alleged are true to the best of my knowledge and belief. “I am currently married to JAMES BRANDON DOTTER and we have two (2) children from this relationship under the age of 18. Jackson Keith Dotter is 17 years of age and Audrey Claire Dotter is 10 years of age. "For the last four months Respondent has been harassing me through text message and phone calls. I have received over one hundred text messages from Respondent in one day. A lot of the text messages are sexualty explicit He states that "He will have sex with me the next time he sees me even if l don’t want to". I have asked him not to talk to me that way and he continues. He has said numerous times that "He was going to take our daughter from school and keep her for six (6) months", a time equal to the time that Ihave been moved out of our home. Our daughter is afraid that Respondent will kidnap her and not allow her to see me. She does not want to visit him unless itis at his parent's home and they are present. Respondent told me that "He will not stop the harassment until he is happy". Our reconciiiation is the only thing that he says will make him happy. He has told me that "If lever have another relationship with another man that he will killhim". Respondent insists that | go to church and repent and also see a doctor and get on medication. Respondent has stated that he will not accept a divorce or a broken family. "On January 14. 2019. when I left my apartment on my way to work, Respondent was waiting for me and would not let me pass. When I would move forward, he would move fowvard and try to block me more. I was able to pass him and he followed me. | turned left and he turned [efl and was behind me again. He came up next to me on the dn'ver's side of the oar and he was driving EXHIBIT “All in the left hand turn lane. l kept on going straight and he did not follow me. Our daughter was in the wr with me and she was video tapping the incident. "0n or about January 8, 2019, Respondent called and accused me of purposely saying things so he would get pissed off and hold that against him. He said "Don't ever F*king tell me we are getting a divorce and have a broken family. Don't ever say that again in your P‘king I'rfe.I don‘t care how mad you are you will be mad when | get a hold of you. You are going to be pissed when you find out what is going to P’king happen. You better go to the hospital or church to get some F*king help. You better go ask for forgiveness". He said "I dare you to F*king send me those papers and lie to me about bu||s**t one more time. l will not have a broken family. I don't give a f'*k what happens. l looked at the Montgomery County website and nothing has been filed. You better pray you fix this. Don't ever say another disrespectful thing to me. You have murdered my heart the last ten (10) months". l said "I want a divorce. The relationship is not good for me". He said "You will never be with anyone else. The minute I find out you are talking to anyone, I will end it right there. Do you understand that? I will end them. End every single thing. Trust me. End everyming right there. l swear to God 'rf | find out your talking to anyone now. l will end that s**t too. Let me find out that you're playing bulls“t games. We are not going to get a divorce. I'm pissed off at the world. If you even get with Tommy, | will F*king murder both of y'all. Did you hear me cleaer I will f'*king murder both of y'all. If you think you're going to P’king hurt me....cal| Lynn and tell her we are going to reconcile, go to church and P'king marriage counseling. I will not accept this. There is no way. I will not live the future like this. Itwill be f**king awful. We are not getting a divorce. | don't care if you hate me. We are going to f*"k evidentially. Trust me. You're not going to have sex with anyone else that's for sure. Ever. I wiil be dead by then. Do not talk to me about a divorce. We are not getting a divorce. He continued to tell me "I'm not going to the courthouse. Audrey is going to stay with me. When l get Audrey...Audrey is going to say with me. Audrey is not staying with you. I will force her to go with me. Next time she is at your office, I can come in mere and take her". | said "You can't come into my office". He said "Yes | can my daughter is ‘rf in there". l said 'That is pn'vate property". He said "My daughter is my private property". I told him "I would not do that ifI was you". He replied "I don't care. I will bring a gun too. Don't worry. I'm going to come get Audrey. When I get Audrey, I'm going to take her from you and you are going to know how it feels. You will F*king cry Iike a b**ch. I'm hurt ba I told him | had to go and he said ”No. I will come over there, kick the f"*king door down and get Audrey myserf. l swear to God I'm going to come kick the door down with some people and take Audrey from you. You call the police. Actually, | will bring the police. Tell Audrey I'm coming to get her tomorrow. You will never f“king keep her another F**king night. Audrey will do what | say. | am the father. I am so pissed off right now. I'm going to f“king do it tonight". I tried to explain to him that Audrey does her homework at my office. He said "You can't you're so busy you can't talk to your husband. No, I'm coming to get Audrey. Let me talk to Audrey. Listen Cameron told me you cannot keep f"’king Audrey from me. Legally, I can come get her even if she doesn‘t want to come". I told him that he made Audrey afraid of him because he acm like this in front of her. l told him i did not tell her anything. | tried to explain to him that when he pulled up in his parent's driveway on Monday, January 7, 2019, that Audrey said "lock the doors Mom and don't roll down the windows". As soon as he pulled in his parent’s driveway, Audrey was scared of him. He said "Stop talking to me about....| will get my daughter and my wife". | said "Not happening". He said "It will. i'm coming over to get Audrey right now". "On or about January 7. 201 9, Respondent called and said he was waiting for me and wanted to know why I was stiilat work at 5:30 p.m. l asked him to stop harassing me. He said 'We are not getting a divorce. I'm in the neighborhood waiting on you. We are not getting a divorce or broken home. You took everything from me and I'm about to take evetything from you. I'm about to get really pissed off. l am going to your F**king aparh'nent tonight. Just wait until Icome in your P‘king apartment and do what I want to do. I'm going to make another key to your apartment and I'm going to go over there while you are sleeping. Watch this shit. | don't care. |promise you will never disrespect me or degrade our kids ever again". He also said "I don't care what you want. You will never get it. I promise you over my dead body. You are not going to be with anyone else period." He said "If you fall in love with someone itwill be your worst F*king mistake. I will never accept this s**t from your mouth ever again. I could not respond to anything he was saying because he kept talking over me. He said "I don't care how mad you are, you haven't seen ”king crazy yet. i'm going to take everything from you. What you love, I willtake, you watch and see it's coming. What's going to be nice, is what I'm going to get from you in a few minutes." He continued to say "I'm not going to sign anything ever in my life. We are not going to get a divorce. We will never have a broken home. l want to see you. I'm not accepting this, it'snot going to happen." He stated again "You are not going to be with anybody else. I control you. You will never be with another man. |already have that set in stone. I promise you. We are not going to be a broken family or accept a divorce. Don't ever talk to me about a divorce again". I told him I did not want to talk to him. He said "You are going to speak to me. Get over it. I'm surprised I'm not dead. I have to cope with alcohol and drink till the sun comes up. Idon't like to drink heavily like that". We discussed when his wr would be fixed. He said "I wrecked my car. I don‘t remember what happened. |made a mistake. | was F*ked up. The tow truck dn'ver told me to get in the truck that the cops were coming and | smelled like alcohol. It was my fault, my mistake. |was drunk as f**k. I hit some concrete and blew out a tire. I kept driving on it to a safe spot. |don't remember after that". He said "I love you, you are my wife. I'm sorry". |said "I told you I did not want to be in a relationship anymore. Our marriage is stressful for me. Nothing has changed in the Iast eight (8) years. It's too late". He said "I'm waiting for you". I said "I don't want to see you." He replied "Call Lynn and tell her we are reconciling. You know what is about to happen to you? How are they delivering papers to me? l have a torch. That lady comes to the house. lwill torch that paperwork and set it on fire and laugh at her. Watch and see. You better hope to God I don't get them anytime soon. I'm about to see you right now and this shit is about to get P‘king nasty. You just really P‘ked up by telling me that." I said 'Why?" He replied "I don't care. I'm not F'king signing s"'t. Stay away from F**king Audrey. You better pray to God l don't get any papers in January 2019. You better start praying now. I'm sitting in front of your office waiting on you". l said "Go away.” He said ”Come outside." I told him I would cell the police. He said "Stop threatening me. You will never speak to me like this. Angie, you better pray to f"*king God. Audrey is not going to that school and unis is not going to happen. You better pray to God this doesn't happen. You will not pick up Audrey at all. Next time you block me. I swear I'm going to kick that door down and take Audrey. You F*ked up by saying some negative things to me. Do you know what is going to happen tomorrow? The worse thing ever. I'm not f‘king playing right now. I'm almost to the point, lhate to F*king say this, but to snap. There is no control of this anymore". He continued to say "You have dug yourself a hole and I will never ever have a broken family. You will not do this to me or my kids. _You will never take F*cking Audrey from me. ever. I'm going to teach you a lesson tomorrow. You watch and see. Tomorrow, I 'm taking Audrey from you aflet school. Audrey will never step foot in your apartment again. ever, over my dead. body will she go back into that apartment. Now that you have blocked me and don't answer your phone. I'm going to teach you a lesson tomorrow. You have F*ked up your whole family". He said "You biook me again and I will bust that door down and bring people with me that don't like you. Trust me. Be careful walking out of your apartment. l dare you to block ma one more time. We are done w'rth this argument and bulls**t. Don't ever talk to me again like you did today. Stop lying to our kids or Iwill F*king destroy you and everything you have. I'm going to cross the line right there. I dare you to piss me off one more time. I'm F*king raging". He said "l will see you in the morning and the nighunare for you just began. You will apologize for what you did. We will not have a broken family. This s"‘t has to stop or there is going to be devastation, awful. I'm very pissed off. i'm not accepting this. My family will not be broken. I don't care what is happening. I'm not going to accept anything at all. lalready have a torch for your friend. I bought it for that. just to prove a point. If you thought 2018 was bad for me (laughs)". I said "Goodbye" and he said "Don't hang up on me answer the question". me that he ' "On or about December 20. 2018. Respondent called and told had wrecked his car the night before after he had been drinking. He said he hit something in the road and then parked behind a Kroger store and slept in the war after the accident and the car was towed to a repair shop. “0n or about December 10, 2018, Respondent followed me in his car for several hours. Our daughter was with me and she was terrified. He was able to get into my apartment complex several times uninvited in order to intimidate me. He has knocked on my door and covered the peep hole so that I can’t see him. “On or about December 1, 2018. Respondent called me at 4:45 a.m. and he was intoxicated. He was using a phone from a hotel lobby and said that he was lost in downtown Houston. l told him he should get a hotel room and stay the night or call his parenb. "0n or about September 30, 2018, Respondent told me during a phone conversation that "He was going to kiil himself and me ifl ignore him". He told me he had been using cocaine and hanging out with a biker gang. "0n or about September 14, 201 8, afier his brother’s funeral he was angry with me because l did not sit next to him during the service. He toid me that afternoon that "He was going to take my face off and hang me from my parent’s porch". "On or about the morning of October 16, 2016, Respondent told me "If I went behind his back and hired an attorney to file for divorce that he would start blowing things up". He insinuated that he would blow up my parents' home. When I said "Then you will be in prison", he said "Ifl am going to be underground then you would also and my parents would have custody of our daughter, Audrey". "On or about Friday. October 14. 2016. Respondent and | were arguing about me going to work and he put his hands around my neck and pushed me against the wall. "On or about October 6, 2016, Respondent sent me text messages that stated "Don't bother with getting Audrey from school..l will pick her up today and take her to my parents house. And don't come here or it will be a bad ending....that's all I'm saying". He also sent me a text message that stated "Go eat a bullet and ”“9 kill yourself..Audrey will hate you and you have trained her to hate people in my family..well you tried.." "On or about August 30, 2016, Respondent sent me a text message that stated "Go to your parents house and stay away from me or I'm going to jail. I'm not joking either..100% your fault what's wrong with our kids and relationship..it‘s "I all your fautt and my parents think it'syour fault too". hate you." "In December 2015, Respondent and | were at a party with our children. When we left the party, Respondent was very agitated and arguing with me and our oldest son. Andrew. When we got home, Respondent went to the safe like he was going to get the gun out. Andrew was so afraid of Respondent that he ieft the residence. "In August 2012, Respondent came home and was very angry with me. He forwd me to our bedroom where he ripped off my shirt and bra tearing mmma‘m memwm. mmmmmngrfiymummommmm ?WMWMM. Wmm.wwtmmmm ldonatremumhandmdu 'lmmmhrmymwmomyofmymaMlk HMMdm-cm Immdwmtimd WMMW! “mumbbm.mmydafldmnvflnnhehmwmo