On June 23, 2015 a
Complaint,Petition
was filed
involving a dispute between
Brewer, Robert Louis, Jr.,
and
Wells, Vashti Savannah,
for Post Judgment Action Modification Custody
in the District Court of Montgomery County.
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Received and E-Filed for Record
8/24/2015 12:00:00 AM
Barbara Gladden Adamick
District Clerk
Montgomery County, Texas
NO. 15-06-06423
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
ROBERT LOUIS BREWER, JR §
AND § 418th JUDICIAL DISTRICT
VASHTI SAVANNAH BREWER §
§
AND IN THE INTEREST OF §
ROBERT LEWIS BREWER III, A § MONTGOMERY COUNTY, TEXAS
CHILD §
FIRST AMENDED PETITION FOR DIVORCE
1. Discovery Level
Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas
Rules of Civil Procedure.
2. Parties
This suit is brought by Robert Louis Brewer, Jr, Petitioner. The last three numbers of
Robert Louis Brewer, Jr's driver's license number are 601. The last three numbers of Robert
Louis Brewer, Jr's Social Security number are 486.
Vashti Savannah Brewer 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
Process should be served on Respondent at 19950 Mercedell Dr., Porter, Texas, 77365.
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 02/15/2008 and ceased to live together as husband
and wife on or about 02/28/2015.
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 child of this marriage who is not
under the continuing jurisdiction of any other court:
Name: Robert Lewis Brewer III
Sex: Male
Birth date: August 24, 2009
There are no court-ordered conservatorships, court-ordered guardianships, or other court-
ordered relationships affecting the child the subject of this suit.
Information required by section 154.181(b) of the Texas Family Code is provided in the
statement attached as Exhibit 08/24/2009.
No property of consequence is owned or possessed by the child the subject of this suit.
Petitioner and Respondent, on final hearing, should be appointed joint managing
conservators, with all the rights and duties of a parent conservator.
Petitioner should be designated as the conservator who has the exclusive right to
designate the primary residence of the child. The residence of the child should be restricted to
Montgomery County, Texas. Respondent should be ordered to make payments for the support of
the child and to provide medical child support in the manner specified by the Court. Petitioner
requests that the payments for the support of the child survive the death of Respondent and
become the obligations of Respondent's estate.
Respondent has a history or pattern of neglectfully endangering the wellbeing of the
child. If the Court finds that awarding Respondent access to the child would not endanger the
child's physical health or emotional welfare and would be in the best interest of the child,
Petitioner requests that the Court render a possession order that is designed to protect the safety
and well-being of the child including but not limited to ordering that the periods of access be
continuously supervised by an entity or person chosen by the Court.
9. Division of Community Property
Petitioner requests the Court to divide the estate of Petitioner and Respondent in a manner that
the Court deems just and right, as provided by law.
10. Postdivorce Maintenance
Petitioner requests the Court to order that Petitioner be paid postdivorce maintenance for
a reasonable period in accordance with chapter 8 of the Texas Family Code.
11. 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.
Respectfully submitted,
BAYLEY LAW FIRM
3730 KIRBY DRIVE, SUITE 1200
HOUSTON, TX 77098
Tel: (713) 383 8887
Fax: (832)415 0385
By:/s/ Andrew Bayley ____________________
Andrew Bayley
State Bar No. 20471501
andrew@bayleylawfirm.com
Attorney for Petitioner
Document Filed Date
August 24, 2015
Case Filing Date
June 23, 2015
Category
Post Judgment Action Modification Custody
Status
Pending - Inactive
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Received and E-Filed for Record 8/24/2015 12:00:00 AM Barbara Gladden Adamick District Clerk Montgomery County, Texas NO. 15-06-06423 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § ROBERT LOUIS BREWER, JR § AND § 418th JUDICIAL DISTRICT VASHTI SAVANNAH BREWER § § AND IN THE INTEREST OF § ROBERT LEWIS BREWER III, A § MONTGOMERY COUNTY, TEXAS CHILD § FIRST AMENDED PETITION FOR DIVORCE 1. Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Parties This suit is brought by Robert Louis Brewer, Jr, Petitioner. The last three numbers of Robert Louis Brewer, Jr's driver's license number are 601. The last three numbers of Robert Louis Brewer, Jr's Social Security number are 486. Vashti Savannah Brewer 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 Process should be served on Respondent at 19950 Mercedell Dr., Porter, Texas, 77365. 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 02/15/2008 and ceased to live together as husband and wife on or about 02/28/2015. 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 child of this marriage who is not under the continuing jurisdiction of any other court: Name: Robert Lewis Brewer III Sex: Male Birth date: August 24, 2009 There are no court-ordered conservatorships, court-ordered guardianships, or other court- ordered relationships affecting the child the subject of this suit. Information required by section 154.181(b) of the Texas Family Code is provided in the statement attached as Exhibit 08/24/2009. No property of consequence is owned or possessed by the child the subject of this suit. Petitioner and Respondent, on final hearing, should be appointed joint managing conservators, with all the rights and duties of a parent conservator. Petitioner should be designated as the conservator who has the exclusive right to designate the primary residence of the child. The residence of the child should be restricted to Montgomery County, Texas. Respondent should be ordered to make payments for the support of the child and to provide medical child support in the manner specified by the Court. Petitioner requests that the payments for the support of the child survive the death of Respondent and become the obligations of Respondent's estate. Respondent has a history or pattern of neglectfully endangering the wellbeing of the child. If the Court finds that awarding Respondent access to the child would not endanger the child's physical health or emotional welfare and would be in the best interest of the child, Petitioner requests that the Court render a possession order that is designed to protect the safety and well-being of the child including but not limited to ordering that the periods of access be continuously supervised by an entity or person chosen by the Court. 9. Division of Community Property Petitioner requests the Court to divide the estate of Petitioner and Respondent in a manner that the Court deems just and right, as provided by law. 10. Postdivorce Maintenance Petitioner requests the Court to order that Petitioner be paid postdivorce maintenance for a reasonable period in accordance with chapter 8 of the Texas Family Code. 11. 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. Respectfully submitted, BAYLEY LAW FIRM 3730 KIRBY DRIVE, SUITE 1200 HOUSTON, TX 77098 Tel: (713) 383 8887 Fax: (832)415 0385 By:/s/ Andrew Bayley ____________________ Andrew Bayley State Bar No. 20471501 andrew@bayleylawfirm.com Attorney for Petitioner