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CAUSE NO. ____________

IN THE INTEREST OF IN THE DISTRICT COURT

KID DOE 256TH JUDICIAL DISTRICT

A CHILD DALLAS COUNTY, TEXAS

Origina !"#i#i$n %$r T"r&ina#i$n an' A'$(#i$n $% S#"()*i'

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. Objection to Assignment of Case to Associate Judge

Petitioners object to the assignent of this atter to an associate judge or visiting judge

for a trial on the erits or !residing at a jury trial.

3. Petitioners

This suit is brought by D"#$% D&'( and )*) D&'(+ Petitioners+ ,ho are husband

and ,ife.

Petitioner D"#$% D&'( is the other of the child the subject of this suit.

Petitioner )*) D&'(

is the ste!father of the child the subject of this suit.

The last three nubers of D"#$% D&'(-s driver-s license nuber are 90. The last three

nubers of D"#$% D&'(-s $ocial $ecurity nuber are //. The last three nubers of )*)

D&'(-s driver-s license nuber are 0. The last three nubers of )*) D&'(-s $ocial

$ecurity nuber are 1.

. Jurisdiction

This Court has acuired and retains continuing+ exclusive jurisdiction of this suit and of

the child the subject of this suit as a result of !rior !roceedings. Petitioner ,ould sho, there ,as

a inal *rder in a $uit "ffecting the Parent3Child Relationshi! dated "!ril 4+ 200/.

!. C"ild

The follo,ing child is the subject of this suit5

6ae5 '%D D*(

$ex5 7ale

*riginal Petition for Terination and "do!tion of $te!child 8 Page 1

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)irth date5 une 1/+ 200:

#. Person $ntitled to Citation

The other of the child the subject of this suit is+ Petitioner+ D"#$% D&'(.

6o service is necessary.

Persons having a court3ordered relationshi! ,ith the child the subject of this suit are5

6ae5 *( D*(

Relationshi!5 )iological ather;Res!ondent

Ci#a#i$n + (-+i)a#i$n $r $#*"r -+#i#-#"' "r/i)" i n")"ar %$r #*" r"a$n

#a#"' in #*" a%%i'a/i# a##a)*"' a E0*i+i# A.

%. Pro&erty

6o !ro!erty of conseuence is o,ned or !ossessed by the child the subject of this suit.

'. (ermination )oug"t

Terination of the !arent3child relationshi! bet,een *( D*( and the child the subject

of this suit is in the best interest of the child+ and such terination is reuested.

"s grounds for terination+ Petitioners allege that this !arent has

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bet,een the father and the child the subject of this suit+ it is in the best interest of the child that

the relationshi! be terinated+ and such terination is reuested.

*. Attorney ad Litem

Petitioners reuest the Court to a!!oint an "ttorney ad @ite to !rovide legal services

necessary to assist the Court in !rotecting the interests of the biological father+ *( D*(.

Petitioners reuest the Court to find that the interests of the child the subject of this suit

,ill be re!resented adeuately by Petitioners+ ,hose interests are not in conflict ,ith the child-s

interests. %n su!!ort thereof Petitioner attaches her "ffidavit in $u!!ort of Citation by

Publication.

*ne or ore !ersons entitled to citation ust be cited by !ublication+ and Petitioners

reuest the Court to a!!oint an attorney ad lite for any !arty so cited ,ho ay default or fail to

a!!ear.

1+. Ado&tion )oug"t

%t is in the best interest of the child the subject of this suit to be ado!ted by )*) D&'(+

ste!!arent+ and ado!tion of the child is sought.

11. ,esidence -it" Petitioners

The child the subject of this suit has lived in the hoe of Petitioners for six onths and

ore.

12. Consent

The ,ritten consent of the anaging conservator is not reuired+ because the anaging

conservator is one of the Petitioners.

13. C"ilds /ame

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%t ,as necessary for Petitioners to secure the services of R"6D# . ($$(6)&RB+ a

licensed attorney+ to !reserve and !rotect the child-s rights. Res!ondent+ *( D*(+ should be

ordered to !ay reasonable attorney-s fees+ ex!enses+ and costs through trial and a!!eal+ and a

judgent should be rendered in favor of this attorney and against Res!ondent and be ordered

!aid directly to the undersigned attorney+ ,ho ay enforce the judgent in the attorney-s o,n

nae. Petitioners reuest !ostjudgent interest as allo,ed by la,.

1#. )ealing of ,ecords

Petitioners reuest the Court to order the sealing of the file and the inutes of the Court.

1%. Prayer

Petitioners !ray that citation and notice issue as reuired by la,. Petitioners !ray that the

Court enter its order in accordance ,ith the allegations of this !etition.

Petitioners !ray for attorney-s fees+ ex!enses+ costs+ and interest as reuested above.

Petitioners !ray for general relief.