On December 31, 2015 a
!MTN:MODIFY,REDUCE,ENFOR,CONTE
was filed
involving a dispute between
Xxxxxxx , Xxxxx,
and
Kinnaman , Joel,
for REGISTER FOREIGN JUDGMENT (FAMILY LAW)
in the District Court of Travis County.
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NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
L.B.K., L.A.K. AND R.P.K. 419TH JUDICIAL DISTRICT
TRAVIS COUNTY, TEXAS
FIRST AMENDED
TO MODIFY PARENTCHILD RELATI
Discovery in this case is intended to be conducted under level 2 of rule 190 of the
Objection to Assignment of Case to Associate Judge
Counterpetitioner objects to the assignment of this matter to an associate judge
Parties and Order to Be Modified
This suit to modify a prior order is brought by JOEL KINNAMAN,
Counterpetitioner. The last three numbers of JOEL KINNAMAN's driver's license
number are 776. The last three numbers of JOEL KINNAMAN's Social Security number
are 050. Counterpetitioner is the father of the children and has standing to bring this
The order to be modified is entitled Agreed Order in Suit Affecting the Parent
Child Relationship Modifying A Foreign Judgment and was rendered on February 27,
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page of
Jurisdiction
This Court has continuing, exclusive jurisdiction of this suit.
Children
The following children are the subject of this suit:
Logan Blake Kinnaman
Sex:
Birth date:
County of residence: Travis
Logan Alexander Kinnaman
Sex:
Birth dat
County of residence: Travis
Ramona Paz xxxxxxx Kinnaman
Sex: Female
Birth date:
County of residence: Travis
Parties Affected
The following parties may be affected by this suit:
xxxxx xxxxxxx
Relationship:
Service of this document may be had in accordance with Rule 21a, Texas Rules
of Civil Procedure, by serving Counterrespondent's attorney of record, Courtney
Hatchett, Thompson Salinas Londergan, 8140 N. Mopac Expressway, Westpark 4,
Suite 250, Austin, Texas 78759. Service shall be conducted the e file service FileTime.
Health Insurance Information
Information required by section 154.181(b) of the Texas Family Code will be
provided.
Children's Property
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page of
There has been no change of consequence in the status of the children's
property since the prior order was rendered.
Protective Order Statement
A protective order was issued under title 4 of the Texas Family Code was
rendered on February 27, 2017, under cause number D
Modification of Possession and Access
The order to be modified is not based on a mediated or collaborative law
settlement agreement. The circumstances of the children, a conservator, or other party
affected by the order to be modified have materially and substantially changed since the
date of rendition of the order to be modified.
Counterpetitioner requests that the terms and conditions for access to or
possession of the children be modified to provide as follows:
Due to Counterrespondent’s behavior in this case the existing possession
schedule is unworkable and endangers the child’s welfare. Counterrespondent must
have access to Ramona Kinnaman xxxxxxx as recommended by a parental alienation
professional only.
Counterpetitioner requests that the Court render a possession order that is
designed to protect the safety and well being of Ramona Kinnaman xxxxxxx, including
but not limited to order that Counterrespondent have no possession of or access to the
Ramona Kinnaman until such time it is recommended by a parental alienation
professional.
The requested modification is in the best interest of the children.
Support
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page of
The order to be modified is not based on a mediated or collaborative law
settlement agreement. The circumstances of the children or a person affected by the
order have materially and substantially changed since the date of the rendition of the
order to be modified, and the support payments previously ordered should be
decreased. Counterpetitioner requests that any decrease be made retroactive to the
earlier of the time of service of citation on Counterrespondent or the appearance of
Counterrespondent in this modification action.
The requested modification is in the best interest of the children.
Request for Temporary Orders
Counterpetitioner requests the Court, after notice and hearing, to make
temporary orders for the safety and welfare of the children, including but not limited to
Ordering the preparation of an alienation assessment of Ramona Kinnaman
at the sole cost of xxxxx xxxxxxx;
Ordering JOEL KINNAMAN and xxxxx xxxxxxx temporary possession of
or access to the child based on the child s best interests
Reducing JOEL KINNAMAN’s monthly child suppor
Ordering xxxxx xxxxxxx to pay reasonable interim attorney’s fees and
expenses necessary for the safety and welfare of the children; and
Scheduling a review hearing upon the Court s receipt of the Parent
Alienation Assessment.
Travis County Standing Order
Travis County Standing Order is attached hereto as Exhibit “A” and
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page of
incorporated herein for all purposes.
Request for Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Counterpetitioner to secure the services of Samuel N.
Solodar, a licensed attorney, to preserve and protect the children's rights.
Counterrespondent should be ordered to pay reasonable attorney's fees, expenses, and
costs through trial and appeal, and a judgment should be rendered in favor of this
attorney and against Counterrespondent and be ordered paid directly to
Counterpetitioner's attorney, who may enforce the judgment in the attorney's own name.
Counterpetitioner requests postjudgment interest as allowed by law.
Prayer
Counterpetitioner prays that citation and notice issue as required by law and that
the Court enter its orders in accordance with the allegations contained in this
counterpetition.
Counterpetitioner prays for attorney's fees, expenses, costs, and interest as
requested above.
Counterpetitioner prays for general relief.
Respectfully submitted,
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page 5 of 6
The above mentioned is set for hearing on Marc
Travis Courthouse, 1000 Guadalupe Street, Austin, Texas 78701.
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or
party in accordance with the Texas Rules of Civil Procedure on March 1
ITI Kinnaman
irst Amended Counterpetition to Modify Parent Child Relationship
Page 6 of 6
Document Filed Date
March 01, 2018
Case Filing Date
December 31, 2015
Category
REGISTER FOREIGN JUDGMENT (FAMILY LAW)
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NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA L.B.K., L.A.K. AND R.P.K. 419TH JUDICIAL DISTRICT TRAVIS COUNTY, TEXAS FIRST AMENDED TO MODIFY PARENTCHILD RELATI Discovery in this case is intended to be conducted under level 2 of rule 190 of the Objection to Assignment of Case to Associate Judge Counterpetitioner objects to the assignment of this matter to an associate judge Parties and Order to Be Modified This suit to modify a prior order is brought by JOEL KINNAMAN, Counterpetitioner. The last three numbers of JOEL KINNAMAN's driver's license number are 776. The last three numbers of JOEL KINNAMAN's Social Security number are 050. Counterpetitioner is the father of the children and has standing to bring this The order to be modified is entitled Agreed Order in Suit Affecting the Parent Child Relationship Modifying A Foreign Judgment and was rendered on February 27, ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page of Jurisdiction This Court has continuing, exclusive jurisdiction of this suit. Children The following children are the subject of this suit: Logan Blake Kinnaman Sex: Birth date: County of residence: Travis Logan Alexander Kinnaman Sex: Birth dat County of residence: Travis Ramona Paz xxxxxxx Kinnaman Sex: Female Birth date: County of residence: Travis Parties Affected The following parties may be affected by this suit: xxxxx xxxxxxx Relationship: Service of this document may be had in accordance with Rule 21a, Texas Rules of Civil Procedure, by serving Counterrespondent's attorney of record, Courtney Hatchett, Thompson Salinas Londergan, 8140 N. Mopac Expressway, Westpark 4, Suite 250, Austin, Texas 78759. Service shall be conducted the e file service FileTime. Health Insurance Information Information required by section 154.181(b) of the Texas Family Code will be provided. Children's Property ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page of There has been no change of consequence in the status of the children's property since the prior order was rendered. Protective Order Statement A protective order was issued under title 4 of the Texas Family Code was rendered on February 27, 2017, under cause number D Modification of Possession and Access The order to be modified is not based on a mediated or collaborative law settlement agreement. The circumstances of the children, a conservator, or other party affected by the order to be modified have materially and substantially changed since the date of rendition of the order to be modified. Counterpetitioner requests that the terms and conditions for access to or possession of the children be modified to provide as follows: Due to Counterrespondent’s behavior in this case the existing possession schedule is unworkable and endangers the child’s welfare. Counterrespondent must have access to Ramona Kinnaman xxxxxxx as recommended by a parental alienation professional only. Counterpetitioner requests that the Court render a possession order that is designed to protect the safety and well being of Ramona Kinnaman xxxxxxx, including but not limited to order that Counterrespondent have no possession of or access to the Ramona Kinnaman until such time it is recommended by a parental alienation professional. The requested modification is in the best interest of the children. Support ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page of The order to be modified is not based on a mediated or collaborative law settlement agreement. The circumstances of the children or a person affected by the order have materially and substantially changed since the date of the rendition of the order to be modified, and the support payments previously ordered should be decreased. Counterpetitioner requests that any decrease be made retroactive to the earlier of the time of service of citation on Counterrespondent or the appearance of Counterrespondent in this modification action. The requested modification is in the best interest of the children. Request for Temporary Orders Counterpetitioner requests the Court, after notice and hearing, to make temporary orders for the safety and welfare of the children, including but not limited to Ordering the preparation of an alienation assessment of Ramona Kinnaman at the sole cost of xxxxx xxxxxxx; Ordering JOEL KINNAMAN and xxxxx xxxxxxx temporary possession of or access to the child based on the child s best interests Reducing JOEL KINNAMAN’s monthly child suppor Ordering xxxxx xxxxxxx to pay reasonable interim attorney’s fees and expenses necessary for the safety and welfare of the children; and Scheduling a review hearing upon the Court s receipt of the Parent Alienation Assessment. Travis County Standing Order Travis County Standing Order is attached hereto as Exhibit “A” and ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page of incorporated herein for all purposes. Request for Attorney's Fees, Expenses, Costs, and Interest It was necessary for Counterpetitioner to secure the services of Samuel N. Solodar, a licensed attorney, to preserve and protect the children's rights. Counterrespondent should be ordered to pay reasonable attorney's fees, expenses, and costs through trial and appeal, and a judgment should be rendered in favor of this attorney and against Counterrespondent and be ordered paid directly to Counterpetitioner's attorney, who may enforce the judgment in the attorney's own name. Counterpetitioner requests postjudgment interest as allowed by law. Prayer Counterpetitioner prays that citation and notice issue as required by law and that the Court enter its orders in accordance with the allegations contained in this counterpetition. Counterpetitioner prays for attorney's fees, expenses, costs, and interest as requested above. Counterpetitioner prays for general relief. Respectfully submitted, ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page 5 of 6 The above mentioned is set for hearing on Marc Travis Courthouse, 1000 Guadalupe Street, Austin, Texas 78701. Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on March 1 ITI Kinnaman irst Amended Counterpetition to Modify Parent Child Relationship Page 6 of 6