PEOPLE'S LEGAL FRONT

IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI

DIVISION IV

IN RE MARRIAGE OF:                                                    )

SE   DT and                                                                       )

REN DT                                                                             )

)

)

SE  DT,                                                                              )

PETITIONER                                                                    )

)

and                                                                                      )     CASE NO.

)

RE  L, NEE, DT,                                                                )

RESPONDENT                                                                 )

PETITION FOR ORDER TO MODIFY CHILD CUSTODY

COMES NOW Petitioner, Se Dt, and petitions this Court to modify its initial decree of September 30, 1996, as to paragraph eight (8), regarding the custody of his children and as to paragraph nine (9), regarding child support payments to respondent and for his petition states to the Court as follows:  There is adequate cause for this court to cause a modification of its initial decree in the above-captioned cause. The conditions upon which the court ordered and issued its initial decree have substantially changed in that the children of the parties, ______________________ , D.O.B. September 4, 1989 and ______________________, D.O.B.. December 22, 1991, have been subjected to mistreatment, abuse and neglect by respondent and respondent’s paramours and roomates; which mistreatment, abuse and neglect is currently under investigation by the Missouri Division of Family Services and the State of Missouri child abuse and neglect agency, by and through Ms. Lisa H and Ms. Carolyn Mc.

1. Initial decree was handed down by this court on September 30, 1996, as to paragraph eight (8), placing ________________________________________________, into joint custody of the parties with respondent having primary physical custody.
2. The children of the parties are now residents of the State of Missouri and have been residents of the State of Missouri and physically present in the State of Missouri since the initial decree.
3. The children of the parties are presently in the physical custody of petitioner, respondent having relinquished to petitioner the physical custody of ___________________________________________ the parties’ children, since December 8, 1998.
4. Petitioner is and has been a resident of the State of Missouri continuously since the court’s initial decree, and is now and has been a resident of Greene County for the past two years, currently residing at _____________, Springfield, MO 65803.
5. Respondent is a resident of Webster County at Marshfield, Missouri.
6. Petitioner has not participated in any capacity in any other litigation concerning the custody of his children in this or any other state.
7. Petitioner has no information of any custody proceeding concerning these children pending in any court of this or any other state.
8. Petitioner’s spouse, _____________________, shares actual physical custody of the petitioner’s children in their home at _____________, Springfield, MO 65803.

Wherefore, petitioner requests that the court finds that there is adequate cause for hearing this petition and enter an order modifying the initial decree of joint custody of the parties to grant sole custody of ____________________to petitioner, Se Dt, with respondent, Re  L, to receive appropriate visitation rights as the court deems in the best interest of these children. Petitioner further prays this court, upon so modifying its initial decree as to paragraph eight (8), to also modify its initial decree as to paragraph nine (9) and suspend any further obligation of petitioner to make child support payment to respondent.

Respectfully submitted,
 
 

______________________________

Se  Dt, Petitioner
 
 

AFFIDAVIT

Upon my oath and affirmation, I, Se Dt, the undersigned, do swear before this court that the foregoing petition is true and correct to the best of my knowledge, information, and belief

So Sworn: ________________________________

Se Dt, Petitioner

NOTARY SIGNATURE______________________________DATED________________

My Commission Expires: ____________________
 
 

CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the foregoing petition and affidavit was served upon Re  L at ____________, Marshfield, Webster County, Missouri ____________, by depositing same in a postage paid envelope with the United States Post Office.

So certified: _________________________________

Se Dt
 
 

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