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
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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
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