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360-610158-16 FILED
TARRANT COUNTY
5/10/2018 8:04 AM
THOMAS A. WILDER
CAUSE NO. 360-610158-16 DISTRICT CLERK
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ISABELLA MARIE GUZMAN § 360TH JUDICIAL DISTRICT
§
A CHILD § TARRANT COUNTY, TEXAS
MOTION FOR ALTERNATIVE SERVICE
This Motion for Alternative Service is brought by Michael Todd Lee and
Tina Marie Lee, Petitioners, who show in support:
1. Service has been attempted unsuccessfully on Noe Luz Guzman, as
shown in the affidavit of Angela Austin attached hereto as Exhibit “A,” the person
who attempted service by personal delivery to Noe Luz Guzman.
2. Reasonably effective notice of the suit may be given to Noe Luz
Guzman by having notice posted by leaving a copy with anyone over 16 years of
age or by securely attaching to the front door.
Michael Todd Lee and Tina Marie Lee pray that the Court grant this Motion
for Alternative Service.
Respectfully submitted,
By: _____________________________
Theresa Y. Copeland
State Bar No. 24050448
Theresa Y. Copeland, Attorney at
Law
1602 West Business 380, Suite 900
Decatur, Texas 76234
(817) 541-7071 Telephone
MOTION FOR ALTERNATIVE SERVICE PAGE 1
FC:\Lee, Mike\SAPCR\Alt Serv Motion
(817) 394-1592 Facsimile
theresa@theresacopelandlaw.com
By: _____________________________
Lori E. Reeves
State Bar No. 24032952
Attorney at Law
1602 West Business 380, Suite 100
Decatur, Texas 76234
(940) 627-5800 Telephone
(940) 626-4446 Facsimile
reeveslawyer@hotmail.com
MOTION FOR ALTERNATIVE SERVICE PAGE 2
FC:\Lee, Mike\SAPCR\Alt Serv Motion
Lori E. Reeves
Attorney at Law
EXHIBIT “A”
CAUSE NO. 360-610158-16
IN THE INTEREST OF § IN THE DISTRICT COURT
§
ISABELLA MARIE GUZMAN § 360TH JUDICIAL DISTRICT
A CHILD : TARRANT COUNTY, TEXAS
AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE
I, Angela Austin, attest that the following statements are true and correct to
the best of my knowledge:
"The following came into hand on April 26, 2018 being the "Original
Petition in Suit Affecting the Parent-Child Relationship and Temporary
Restraining Order and Order Setting Hearing for Temporary Orders" for delivery
to Noe Luz Guzman, Respondent.
"My first unsuccessful attempt was May 3, 2018 at 10:17 a.m. at 809 Keli
Court, Azle, Texas. I spoke with an adult female, Ashley, who answered the door.
Asked for Mr. Guzman and was told he was not home. I left my business card with
Ashley.
"My second unsuccessful attempt was May 8, 2018 at 6:48 p.m. I knocked
on the door and was greeted by a male who identified himself as being Mr.
Guzman's brother. I was told that Noe Guzman does come to their house
periodically and was asked to come back. I left my business card with the brother
AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE PAGE 1
FC:\Lee, Mike\SAPCR\Pleadings\Affidavit for Alternative Service
to give to Noe Guzman to make contact.
"My third unsuccessful attempt was May 9, 2018. I knocked on door several
( a.* 1 :31 P.I\'\)
times and did not receive a response. However, there was an SUV parked in the
driveway. I left my business card on the door again.
"I have made diligent efforts to deliver said papers to Noe Luz Guzman at
known address. I believe an efficient way to effectively serve Mr. Guzman is by
leaving a copy with anyone over sixteen (16) years of age or by securely attaching
the Citation, with "Plaintiffs Original Petition in Suit Affecting the Parent-Child
Relationship and Temporary Restraining Order and Order Setting Hearing for
Temporary Orders" attached, with tape to the front door of Noe Luz Guzman's
residence, where it is sure to be seen by someone at the residence, or in any other
manner the affidavit or evidence before the Court shows will be reasonably
effective to give the respondent notice of suit.
"I am a person over eighteen (18) years of age and I am competent to make
this affidavit. I am a resident of the State of Texas. I am familiar with the Texas
Rules of Civil Procedure as they apply to service of Process. I am not a party to
this suit nor related or affiliated with any herein, and have no interest in the
outcome of the suit. I have never been convicted of a felony or of a misdemeanor
involving moral turpitude. I have personal knowledge of the facts stated herein and
they are true and correct."
AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE PAGE2
FC:\Lee, Mikc\.SAPCR\Plcadings\Affidavit for Alternative Service
l.
Angela Austin .::ZZ,$1...SCIr/~
Process Service Q',-J ?/31/2-0
BEFORE ME, a Notary Public, on this day personally appeared Angela
Austin, known to me to be the person whose name is subscribed to the foregoing
document and, being by me first duly sworn, declared that the statements therein
contained are within his or her personal knowledge and are true and correct.
SUBSCRIBED AND SWORN TO I\1E this 9th day of May 2018.
..~~Wf,,,. TIFFANI BEARDEN
~·~
N-Ota.rJhlk:State of Texas
§)-: :t;-~ Notarv. Public, State of Texas
s;:., 11iT..,Ji.ff ,Comm. Expires 06-22-2021
~im;:,,,,~ Notary ID 124876884
AFFIDAVIT IN S UPPORT OF A LTERNATIVE SERVICE
FC:\Lee, Mlke\SAPCR\Ple1dings\Affid11vil for Alternative Service PAGE3
Preview
360-610158-16 FILED TARRANT COUNTY 5/10/2018 8:04 AM THOMAS A. WILDER CAUSE NO. 360-610158-16 DISTRICT CLERK IN THE INTEREST OF § IN THE DISTRICT COURT § ISABELLA MARIE GUZMAN § 360TH JUDICIAL DISTRICT § A CHILD § TARRANT COUNTY, TEXAS MOTION FOR ALTERNATIVE SERVICE This Motion for Alternative Service is brought by Michael Todd Lee and Tina Marie Lee, Petitioners, who show in support: 1. Service has been attempted unsuccessfully on Noe Luz Guzman, as shown in the affidavit of Angela Austin attached hereto as Exhibit “A,” the person who attempted service by personal delivery to Noe Luz Guzman. 2. Reasonably effective notice of the suit may be given to Noe Luz Guzman by having notice posted by leaving a copy with anyone over 16 years of age or by securely attaching to the front door. Michael Todd Lee and Tina Marie Lee pray that the Court grant this Motion for Alternative Service. Respectfully submitted, By: _____________________________ Theresa Y. Copeland State Bar No. 24050448 Theresa Y. Copeland, Attorney at Law 1602 West Business 380, Suite 900 Decatur, Texas 76234 (817) 541-7071 Telephone MOTION FOR ALTERNATIVE SERVICE PAGE 1 FC:\Lee, Mike\SAPCR\Alt Serv Motion (817) 394-1592 Facsimile theresa@theresacopelandlaw.com By: _____________________________ Lori E. Reeves State Bar No. 24032952 Attorney at Law 1602 West Business 380, Suite 100 Decatur, Texas 76234 (940) 627-5800 Telephone (940) 626-4446 Facsimile reeveslawyer@hotmail.com MOTION FOR ALTERNATIVE SERVICE PAGE 2 FC:\Lee, Mike\SAPCR\Alt Serv Motion Lori E. Reeves Attorney at Law EXHIBIT “A” CAUSE NO. 360-610158-16 IN THE INTEREST OF § IN THE DISTRICT COURT § ISABELLA MARIE GUZMAN § 360TH JUDICIAL DISTRICT A CHILD : TARRANT COUNTY, TEXAS AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE I, Angela Austin, attest that the following statements are true and correct to the best of my knowledge: "The following came into hand on April 26, 2018 being the "Original Petition in Suit Affecting the Parent-Child Relationship and Temporary Restraining Order and Order Setting Hearing for Temporary Orders" for delivery to Noe Luz Guzman, Respondent. "My first unsuccessful attempt was May 3, 2018 at 10:17 a.m. at 809 Keli Court, Azle, Texas. I spoke with an adult female, Ashley, who answered the door. Asked for Mr. Guzman and was told he was not home. I left my business card with Ashley. "My second unsuccessful attempt was May 8, 2018 at 6:48 p.m. I knocked on the door and was greeted by a male who identified himself as being Mr. Guzman's brother. I was told that Noe Guzman does come to their house periodically and was asked to come back. I left my business card with the brother AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE PAGE 1 FC:\Lee, Mike\SAPCR\Pleadings\Affidavit for Alternative Service to give to Noe Guzman to make contact. "My third unsuccessful attempt was May 9, 2018. I knocked on door several ( a.* 1 :31 P.I\'\) times and did not receive a response. However, there was an SUV parked in the driveway. I left my business card on the door again. "I have made diligent efforts to deliver said papers to Noe Luz Guzman at known address. I believe an efficient way to effectively serve Mr. Guzman is by leaving a copy with anyone over sixteen (16) years of age or by securely attaching the Citation, with "Plaintiffs Original Petition in Suit Affecting the Parent-Child Relationship and Temporary Restraining Order and Order Setting Hearing for Temporary Orders" attached, with tape to the front door of Noe Luz Guzman's residence, where it is sure to be seen by someone at the residence, or in any other manner the affidavit or evidence before the Court shows will be reasonably effective to give the respondent notice of suit. "I am a person over eighteen (18) years of age and I am competent to make this affidavit. I am a resident of the State of Texas. I am familiar with the Texas Rules of Civil Procedure as they apply to service of Process. I am not a party to this suit nor related or affiliated with any herein, and have no interest in the outcome of the suit. I have never been convicted of a felony or of a misdemeanor involving moral turpitude. I have personal knowledge of the facts stated herein and they are true and correct." AFFIDAVIT IN SUPPORT OF ALTERNATIVE SERVICE PAGE2 FC:\Lee, Mikc\.SAPCR\Plcadings\Affidavit for Alternative Service l. Angela Austin .::ZZ,$1...SCIr/~ Process Service Q',-J ?/31/2-0 BEFORE ME, a Notary Public, on this day personally appeared Angela Austin, known to me to be the person whose name is subscribed to the foregoing document and, being by me first duly sworn, declared that the statements therein contained are within his or her personal knowledge and are true and correct. SUBSCRIBED AND SWORN TO I\1E this 9th day of May 2018. ..~~Wf,,,. TIFFANI BEARDEN ~·~ N-Ota.rJhlk:State of Texas §)-: :t;-~ Notarv. Public, State of Texas s;:., 11iT..,Ji.ff ,Comm. Expires 06-22-2021 ~im;:,,,,~ Notary ID 124876884 AFFIDAVIT IN S UPPORT OF A LTERNATIVE SERVICE FC:\Lee, Mlke\SAPCR\Ple1dings\Affid11vil for Alternative Service PAGE3