Citation/Notice Text :

Filed 6/9/2020 11:50 AM Patti Flores District Clerk Wichita County, Texas CCL1-FM2020-1199 Katarzyna Nickell NO. IN THE INTEREST OF § IN THE § KENYON DESHAWN YARBROUGH AND KENDRON DETAVIOUS § OF WORTHY § CHILDREN § WICHITA COUNTY, TEXAS ORIGINAL PETITION FOR TERMINATION AND ADOPTION OF CHILD Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. Objection to Assignment of Case to Associate Judge Petitioners object to the assignment of this matter to an associate judge for a trial on the merits or presiding at a jury trial. Petitioner This suit is brought by Patricia Byrd, Petitioner. Petitioner Patricia Byrd has resided with the children for at least six months. The last three numbers of Patricia Byrd’s driver's license number are 510. The last three numbers of Patricia Byrd’s Social Security number are 182. Jurisdiction No court has continuing jurisdiction of this suit or of the children the subject of this suit. Interstate Placement Information A verified allegation or statement complying with section 162.002 of the Texas Family Code is requested to be waived. Children The following children are the subject of this suit: Name: Kenyon DeShawn Yarbrough Sex: Male Birth date: July 7, 2009 Name: Ken’dron DeTavious Worthy Sex: Male Birth date: September 27, 2006 Person Entitled to Citation The father of the children the subject of this suit is John Patrick Worthy. Process should be served on Respondent at 2735 Roanoke, Wichita Falls, Texas or at his place of employment at Alsco Linen, 2816 Central Fwy., Wichita Falls, Texas. The mother of the children the subject of this suit is Latavia Yarbrough. Process should be served on Respondent by publication or posting. There are no court-ordered conservatorships, court-ordered guardianships, or other court- ordered relationships affecting the children the subject of this suit. Property No property of consequence is owned or possessed by the children the subject of this suit. Protective Order Statement No protective order under title 4 of the Texas Family Code, under Chapter 7A of the Texas Code of Criminal Procedure, or an order for emergency protection under Article 17.292 of the Texas Code of Criminal Procedure is in effect, and no application for a protective order is pending with regard to the parties to this suit or the children of the parties to this suit. Termination Sought A. Mother Termination of the parent-child relationship between Latavia Yarbrough and the child the subject of this suit is in the best interest of the child, and such termination is requested. As grounds for termination, Petitioner alleges that before this case is heard this parent will have- a. failed to support the child in accordance with his ability during a period of one year ending within six months of the date of the filing of this petition and Waiver Requested Petitioners request the Court to find that the interests of the children the subject of this suit will be represented adequately by Petitioner, whose interests are not in conflict with the children's interests. Adoption Sought It is in the best interest of the children the subject of this suit to be adopted by Petitioner, and adoption of the children is sought. Residence with Petitioner The children the subject of this suit will have lived in the home of Petitioner for at least six months when this case is heard. Children's Names Petitioner requests that the name of the children be changed. Adoption Evaluation Petitioner requests the Court to order that an adoption evaluation be performed as required by the Texas Family Code. Medical History Report Petitioner requests the Court to order Latavia Yarbrough to provide information regarding the medical history of the child and the child's ancestors. Prayer Petitioner prays 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. Petitioners pray for general relief. AMMONS & AMMONS LAW OFFICE 1010 Tenth Street WICHITA FALLS, TX 76301 Tel: (940) 322-2155 Fax: (940) 322-9071 By: Jeff D. Ammons State Bar No. 24055101 ammonsandammons@yahoo.com Attorney for Petitioner