Victoria Simmons 0

PETITION FOR ORDER TERMINATING PARENTAL RIGHTS OF NATURAL FATHER

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TO: THE HONERABLE EIGHTH JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA, IN AND FOR THE COUNTY OF CLARK. That pursuant to the Chapter 128 of the Nevada Revised Statutes, the petition of VICTORIA M. SIMMONS respectfully shows: 1. There resides within Clark County, State of Nevada, Chance Rylee Shiflet, born September 08, 2008, the issue of the relationship between Petitioner, Victoria M. Simmons, the natural mother and Donald L. Moody, the natural father. 2. Said minor child is neglected within the purview of section 128.014 of Nevada Revised Statutes, in that the natural father has failed, neglected and refused to provide proper or necessary subsistence for the support and maintenence of the said minor child, having failed to pay any child support for the first (2) two years of said minor childs life, and only (5) five months worth in the third year of the minor childs life in the amount of $500.00 US dollars set at the statutory minimum of $100.00 per month as ordered in current Child Support Order through the courts ordered on June 16, 2011 Dept. D Case#11-443534-P. Donald L. Moody has failed, neglected and refused to correspond or communicate with said minor child on a regular basis prior to this petition, and after Court Ordered visitation. On the June 16, 2011 hearing Donald L. Moody was ordered into Domestic Violence/Alcohol/Drug Abuse treatment programs and has failed to any as ordered by Courts to even receive visitation with minor child. Donald L. Moody has also failed to exercise his visitation in Clark County as per the current Child Custody/Visitation Order, and has stated the "He will not visit minor child in Clark Co. due to the visit having to be supervised". 3. That Donald L. Moody resides in Hawthorne, Nevada and has his entire life with his parents and fails to maintain steady employment if any, and has failed to provide any Medical coverage for minor child. That Donald is a known prescription pill/marijuana user, and a known methamphetamine dealer, and that petitioner has learned that it led him to the lose of his 1999 Power Stroke p/u truck over a methamphetamine drug deal where the other drug dealer came to his residence in the middle of the night and took p/u truck as payment all while minor child was present in the residence. The last time Donald has seen the minor childwas in early November 2011 while petitioner was up in Northeren Nevada taking care of legal issues of her own. Petitioner informed Donald via telephone and text message December 2011 and January 2012 to inform him that she intendes to file a petition to terminate his parental rights with regards to minor child. 4. That the full name and residence of the minor child is: Chance Rylee Shiflet 2050 S. Magic Way SPC 289 Henderson, Nevada 89002 5. That the names and addresses of natural parents are: Natural Mother: Victoria M. Simmons 2050 S. Magic Waya SPC 289 Henderson, Nevada 89002 Natural Father: Donald L. Moody 575 L. St. BOX 338 Hawthorne, Nevada 89415 6. That the names and addresses of persons having custody and control of minor child are as follows: Victoria Simmons (natural mother) Joseph Simmons (step father ) 2050 S. Magic Way SPC 289 Henderson, Nevada 89002 7. That the names and addresses of the minor childs other relatives are: Maternal Grandmother: Debra Shiflet 1230 N. Fir Villa Rd. Dallas, Oregon 97338 Maternal Grandfather: Deceased Paternal Grandparents: Steven and Shiella Moody 575 L. St. BOX 338 Hawthorne, Nevada 89415 WHEREFORE, Petitioner prays that an order be made and entered declaring that said Chance Rylee Shiflet to be a neglected child as to the natural father, and that the parental rights of said natural father, Donald L. Moody, in and to said minor child be terminated, and for such other and further relief as the court may deem proper. DATED this______day of January, 2012.

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