VERIFIED COMPLAINT TO DETERMINE PATERNITY, SOLE PARENTAL RESPONSIBILITY, SUPERVISED AND RESTRICTED TIMESHARING, PARENTING PLAN, CHILD SUPPORT AND OTHER RELIEF

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IN THE CIRCUIT COURT OF THE 17^TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

In Re: The Matter of                                                            Case Number:

 

JACK KING,

 

Petitioner/Father,

and

 

JAMIE CROWN,

 

Respondent/Mother.

________________________/

VERIFIED COMPLAINT TO DETERMINE PATERNITY, SOLE PARENTAL RESPONSIBILITY, SUPERVISED AND RESTRICTED TIMESHARING, PARENTING PLAN, CHILD SUPPORT AND OTHER RELIEF 

 The Petitioner/Father, JACK KING, by and through undersigned counsel, files this his Verified Complaint to Determine Paternity, Sole Parental Responsibility, Supervised and Restricted Time Sharing, Parenting Plan, Child Support and Other Relief and states as follows:

COUNT I

GENERAL FACTUAL ALLEGATIONS

1. This is an action to establish paternity, establish sole parental responsibility, Supervised and Restricted Timesharing, Parenting Plan, Child Support and other relief.
2. This Court has personal jurisdiction of the Mother, JAMIE CROWN, in that she is currently or was prior to the commencement of this action, a resident of the State of Florida.
3. The Father and minor child reside in Florida. The Mother previously resided in Florida prior to the commencement of this action but now resides in Pennsylvania.
4. That the Father is over eighteen (18) years of age and is not a member of the Armed Forces of the United States or its allies.
5. That the Mother and the Father engaged in sexual intercourse in the which resulted in the conception and subsequent birth of one child, to-wit:

JM born on xx/xx/20__ in Florida

COUNT 2

PATERNITY 

Paragraphs 1 through 5 of Count 1are realleged as though herein set out in full.

6. That the Mother and Father engaged in sexual intercourse which resulted in the conception and subsequent birth of one child, to-wit:

JM born on xx/xx/20__ in Florida

7. That the Petitioner is the biological father of the child and the child has his last name.
8. That the Petitioner and Respondent have never been married.

COUNT 3

SOLE PARENTAL RESPONSIBILITY/RESTRICTED TIMESHARING AND PARENTING PLAN

Paragraphs 1 through 5 of Count 1, paragraph 6 thorough 8 of Count 2 are realleged as though herein set out in full.

9. Sole Parental Responsibility/Restricted Timesharing/Parenting Plan.

It would be in the best interest of the minor child for the Father to have sole parental responsibility of the minor child.  The Mother should be permitted to have restricted timesharing after completion of alcohol and drug rehabilitation and substance abuse evaluation and the Court should approve a parenting plan pursuant to Florida Statutes.

10. Parenting Plan: The Court should establish a parenting plan considering

the following statutory factors:

• The demonstrated capacity and disposition of each parent to facilitate and encourage a close and continuing parent child relationship.
• The anticipated division of parental responsibility after the litigation.
• Demonstrated capacity and disposition of each parent to consider and act upon the needs of the child as opposed to the needs and desires of that parent.
• The length of time the child has lived in a stable and satisfactory environment.
• Geographic viability of the plan.
• The moral fitness of the parents.
• The mental and physical health of the parents.
• The home, school, and community records of the child.
• The reasonable preference of the child.
• The demonstrated knowledge, capacity, and disposition of each parent to be informed about the child.
• The demonstrated capacity and disposition of each parent to provide consistent routine for the child.
• The demonstrated capacity of each parent to communicate with and keep the other parent informed regarding issues and activities, regarding the minor child and the willingness of each parent to adopt a unified front as to all major issues when dealing with the child.
• Domestic violence and other abuse and knowledge about false information to the court regarding domestic violence and other abuse.
• The parent who has provided false information to the court.
• The parenting tasks historically performed by each parent and the division of parental responsibilities.
• The demonstrated capacity and disposition of each parent to participate and be involved in the children’s school and extra curricular activities.
• Substance abuse of the parties.
• The capacity and disposition of each parent to protect the child from the ongoing litigation as demonstrated by not discussing the litigation with the child, not sharing documents, electronic media, etc.
• The developmental stages and needs of the child and demonstrated capacity and disposition of each party to meet the child’s development needs.
• Any other factor that is relevant.

11. Supervised and Restricted Timesharing. The Father should be awarded 100% timesharing.  The Mother’s timesharing should be supervised and restricted pending alcohol and drug testing and substance abuse evaluation.  The child has been residing with the Father for the last four (4) years and is an “A” student.  The Mother hardly sees the child and moved out of State to Pennsylvania.

COUNT 4

CHILD SUPPORT AND OTHER RELIEF

Paragraphs 1 through 5 of Count 1, paragraph 6 thorough 8 of Count 2, and 10 through 11 of Count 3 are realleged as though herein set out in full.

12. Child Support. The Father seeks child support for the parties minor

Child, including retro-active child support.

13. Dependency Exemption. The Father requests the dependency

exemption be awarded to him annually.

14. Attorney Fees. The Father has incurred attorneys fees in having to

enforce her child support and file this Petition.

WHEREFORE, the Petitioner/Father prays this Honorable Court to:

1. Enter an order determining the Petitioner to be the legal father of the child.
2. Enter an order for sole parental responsibility of the minor child and for a parenting plant to be implemented and award the Father 100% timesharing with the child, including weekends, holidays and summers;
3. Order the Mother to submit to a substance abuse evaluation and drug testing.
4. Grant any such other and further relief as this Court deems just and proper.

 

Under penalties of perjury I declare that I have read the foregoing petition and that the facts stated in it are true to the best of my knowledge and belief.

_______________________________

JACK KING

STATE OF FLORIDA         )

)§:

COUNTY OF BROWARD )

BEFORE ME, the undersigned authority, personally appeared JACK KING, who is known to me or who produced a Florida Driver’s License as identification, under penalties of perjury and having been sworn under oath, verifies that the above contents and information is true and correct to the best of his personal knowledge and that he executed this document this _____ day of ________________20__.

 

_________________________

NOTARY PUBLIC

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY, that a true and correct copy of the foregoing was provided to: Jamie Crown, Mother, by personal service.

 

LARRY D. SCHOTT

Attorneys for Father                                    

By:_____________________________

LARRY D. SCHOTT

 

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