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No.

IN THE INTEREST OF JOSE JUAN REYNOSO A CHILD IN THE DISTRICT COURT _____ JUDICIAL DISTRICT BEXAR COUNTY, TEXAS

ORIGINAL PETITION FOR TERMINATION AND ADOPTION OF STEPCHILD TO THE HONORABLE JUDGE OF THE COURT: NOW COMES, MARIA ISABEL MARTINEZ DE LA FUENTE and LEE DE LA FUENTE, Petitioners herein, by and through his attorney of record, Manuel V. Rodriguez, Jr., who files this their Original Petition for Termination and Adoption of Stepchild, and for cause of action would respectfully show the following: I. DISCOVERY CONTROL PLAN 1.1 Petitioners designates this case as a Level 2 case. II. PETITIONER 2.1 This suit is brought by MARIA ISABEL MARTINEZ DE LA FUENTE and LEE DE LA FUENTE, who are husband and wife. 2.2 Petitioner MARIA ISABEL MARTINEZ DE LA FUENTE is the natural mother of the child the subject of this suit. 2.3 Petitioner LEE DE LA FUENTE is the stepfather of the child the subject of this suit.

Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee

2.4

The last three numbers of Petitioner MARIA ISABEL MARTINEZ DE LA FUENTES drivers license number are xxxxx274. The last three numbers of her social security number are xxx-xx-x849.

2.5

The last three numbers of Petitioner LEE DE LA FUENTES drivers license number are xxxxxx364. The last three numbers of her social security number are xxx-xx-x482. III. JURISDICTION

3.1

This Court has jurisdiction of this suit and of the child the subject of this suit as a result of the fact that both the Petitioners and the child the subject of this suit reside in Bexar County, Texas. IV. INTERSTATE PLACEMENT INFORMATION

4.1

There is no need for a verified allegation or statement complying with section 162.002 of the Texas Family Code because this is not an interstate placement of the child. This is an adoption by a stepparent. V. CHILD

5.1

The following child is the subject of this suit: Name: Sex: Birthdate: Jose Juan Reynoso Male 01/30/2000

Adoption by Petitioner LEE DE LA FUENTE is in the best interest of the child.

Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee

VI. PERSON ENTITLED TO CITATION 6.1 Persons having a court-ordered relationship with the child the subject of this suit are: Name: CARLOS FELIX REYNOSO Relationship: Father Process should be served on Respondent at 8904 Violet Orchid Trail S.W., Albuquerque, New Mexico 87121 VII. PROPERTY 7.1.1 No property of consequence is owned or possessed by the child the subject of this suit. VIII. TERMINATION SOUGHT 8.1 Termination of the parent-child relationship between CARLOS FELIX REYNOSO and the child the subject of this suit is in the best interest of the child, and such termination is requested. 8.2 It is anticipated that CARLOS FELIX REYNOSO will execute an unrevokeable or irrevocable affidavit of relinquishment of parental rights as provided for by Chapter 161 of the Texas Family Code. 8.3 The parent-child relationship between the child the subject of this suit and CARLOS FELIX REYNOSO does not exist in fact. If any parent-child

relationship does exist, has ever existed or could ever exist between CARLOS FELIX REYNOSO and the child the subject of this suit, which is not admitted but

Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee

is denied, it is in the best interest of the child that the relationship be terminated, and such termination is requested. IX. ADOPTIONS SOUGHT 9.1 It is in the best interest of the child the subject of this suit to be adopted by LEE DE LA FUENTE, and adoption of the child is sought. X. RESIDENCE WITH PETITIONERS 10.1 The child the subject of this suit will have lived in the home with Petitioners for at least six months when this case is heard. XI. CHILDS NAME 11.1 Petitioners request that the name of the child. Jose Juan Reynoso be changed to Jose Juan De La Fuente. XII. SOCIAL STUDY 12.1 Petitioners affirmatively state that there is no reason for the Court to order the preparation of pre-adoptive and post-placement social studies as required by the Texas Family Code in that the subject adoption is by a stepparent.

Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee

XIII. ATTORNEYS FEES, EXPENSES, COSTS AND INTEREST 13.1 It was necessary for Petitioners to secure the services of Manuel V. Rodriguez, Jr., a licensed attorney, to preserve and protect the childs rights. Respondent, CARLOS FELIX REYNOSO should be ordered to pay reasonable attorneys fees, expenses and costs through trial and appeal, and a judgment should be rendered in favor of this attorney against Respondent and be ordered paid directly to the undersigned attorney, who may enforce the judgment in the attorneys own name. Petitioners request postjudgment interest as allowed by law.

XIV. MEDICAL HISTORY REPORT 14.1 Petitioners request the Court to CARLOS FELIX REYNOSO to provide information regarding the medical history of his mother and father and their ancestors. XV. SEALING OF RECORDS 15.1 Petitioners request the Court to order the sealing of the file and the minutes of the Court. PRAYER WHEREFORE PREMISES CONSIDERED, Petitioners pray that citation and notice issue as required by law. Petitioners pray that the Court enter its order in

accordance with the allegations of this petition. Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee 5

Petitioners further pray for post-judgment interest at the legal rate, attorneys fees, litigation and investigation expenses, witness fees, deposition fees, costs of court, and such other relief, at law and in equity, to which the Petitioners is justly entitled. Petitioners pray for general relief.

Respectfully submitted, Law offices of MANUEL V. RODRIGUEZ, JR. 879 W. Southcross Blvd. San Antonio, Texas 78211 Tel. 210-924-2494 Fax. 210-858-5734

____________________________________ Manuel V. Rodriguez, Jr. Attorney at Law State Bar No. 17147550

Original Petition For Termination and Adoption of a Stepchild De La Fuente, Maria & Lee

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