Public Notice Published In THE...
Public Notice Published In THE...
Public Notice Published In THE CLAREMORE DAILY PROGRESS, Claremore, Rogers County, Oklahoma, July 24, 31&August 7, 2024. IN THE DISTRICT COURT IN AND FOR ROGERS COUNTY STATE OF OKLAHOMA IN RE THE MATTER OF: AMBER M. NEVEL, PETITIONER, AND ERIC RYAN MURRAY, RESPONDENT. CASE NO. FP-2015-67 HONORABLE JUDGE CHILDERS MOTION TO MODIFY CUSTODY, VISITATION, AND CHILD SUPPORT COMES NOW, Petitioner, Amber Never, now Williams, by and through her attorneys of record, Isaiah Parsons, Charles Graham&Matthew Day of Parsons, Graham&Day, LLC, and for her Motion to Modify Custody, Visitation, and Child Support states and alleges as follows: 1. On February 2, 2021, this Court entered a Consent Order of Modification. 2. The parties are the parents of one (1) child, to-wit: A.L.N.M., born July 12, 2011. 3. This Court has continuing exclusive jurisdiction over the parties and subject matter. 4. Pursuant to Gibbons v. Gibbons, 1968 OK 77, 442 P.2d 482, Petitioner informs the Court that a permanent, substantial, and material change in circumstances directly relating to the best interest of the child has occurred. As a result of the changed circumstances the minor child would be substantially better off with a modified custody and visitation schedule. Specific changes include, but are not limited to: a. That the Respondent has a history of illegal drug use. The Respondent has admitted to using illegal drugs recently. Additionally, the Respondent recently attempted to complete a drug addiction program. b. That Respondent does not maintain a constant schedule to see the minor child. c. That the Respondent has made comments about moving to Oklahoma City which would warrant a substantial change in Visitation, Custody, and Child Support. d. That the minor child would like a changed custody and visitation schedule. e. Petitioner reserves the right to additional changes discovered during litigation. 5. Petitioner requests that custody and visitation be modified due to the aforementioned change of circumstances. More specifically, Petitioner requests: a. Petitioner should be vested with sole custody of the partys minor child. b. Respondents visitation should be limited to supervised and any additional holiday and summer times, as the Court sees fit. c. Respondent should be required to pass a nailbed test. d. Child support should be modified to reflect the change in visitation. 6. The aforementioned requests reflect modifications that are in the best interest of the minor child. 7. Pursuant to Okla. Stat. Tit. 43 § 511, Respondent informs the Court as follows: a. The minor child has resided in Rogers County since birth with Petitioner and/or Respondent, and Petitioner has not participated in any proceedings beyond those referenced herein. Petitioner has not participated in any other proceedings as a party, witness, or in any other capacity, in any other litigation concerning the custody of the minor child. b. Petitioner has no information of any other custody proceedings concerning the minor child pending in a court of this state or any other action in any other state. c. Petitioner does not know of any other person not a party to this proceeding that has physical custody of the minor child or claims to have custody or visitation rights with respect to the minor child. 8. Petitioner moves this court to set a hearing on these issues at the completion of discovery and a pretrial conference order. 9. Petitioner should be awarded her reasonable attorney fees and costs in litigating this matter. WHEREFORE, Petitioner prays that upon hearing, this Court grant her the afore-requested relief, award her attorney fees and costs, and grant her such further and ancillary relief to which she is justly and equitably entitled. Respectfully submitted, s/ Isaiah Parsons Isaiah Parsons, OBA #31181Charles Graham, OBA #17286Matthew D. Day, OBA #31033Parsons, Graham&Day, LLC525 South Main StreetSuite 312Tulsa, Oklahoma 74103Telephone: (918) 307-1529Facsimile: (918) 514-8093Email: pgdokc@gmail.comAttorneys for Petitioner
Public Notice Published In THE CLAREMORE DAILY PROGRESS, Claremore, Rogers County, Oklahoma, July 24, 31&August 7, 2024. IN THE DISTRICT COURT IN AND FOR ROGERS COUNTY STATE OF OKLAHOMA IN RE THE MATTER OF: AMBER M. NEVEL, PETITIONER, AND ERIC RYAN MURRAY, RESPONDENT. CASE NO. FP-2015-67 HONORABLE JUDGE CHILDERS MOTION TO MODIFY CUSTODY, VISITATION, AND CHILD SUPPORT COMES NOW, Petitioner, Amber Never, now Williams, by and through her attorneys of record, Isaiah Parsons, Charles Graham&Matthew Day of Parsons, Graham&Day, LLC, and for her Motion to Modify Custody, Visitation, and Child Support states and alleges as follows: 1. On February 2, 2021, this Court entered a Consent Order of Modification. 2. The parties are the parents of one (1) child, to-wit: A.L.N.M., born July 12, 2011. 3. This Court has continuing exclusive jurisdiction over the parties and subject matter. 4. Pursuant to Gibbons v. Gibbons, 1968 OK 77, 442 P.2d 482, Petitioner informs the Court that a permanent, substantial, and material change in circumstances directly relating to the best interest of the child has occurred. As a result of the changed circumstances the minor child would be substantially better off with a modified custody and visitation schedule. Specific changes include, but are not limited to: a. That the Respondent has a history of illegal drug use. The Respondent has admitted to using illegal drugs recently. Additionally, the Respondent recently attempted to complete a drug addiction program. b. That Respondent does not maintain a constant schedule to see the minor child. c. That the Respondent has made comments about moving to Oklahoma City which would warrant a substantial change in Visitation, Custody, and Child Support. d. That the minor child would like a changed custody and visitation schedule. e. Petitioner reserves the right to additional changes discovered during litigation. 5. Petitioner requests that custody and visitation be modified due to the aforementioned change of circumstances. More specifically, Petitioner requests: a. Petitioner should be vested with sole custody of the partys minor child. b. Respondents visitation should be limited to supervised and any additional holiday and summer times, as the Court sees fit. c. Respondent should be required to pass a nailbed test. d. Child support should be modified to reflect the change in visitation. 6. The aforementioned requests reflect modifications that are in the best interest of the minor child. 7. Pursuant to Okla. Stat. Tit. 43 § 511, Respondent informs the Court as follows: a. The minor child has resided in Rogers County since birth with Petitioner and/or Respondent, and Petitioner has not participated in any proceedings beyond those referenced herein. Petitioner has not participated in any other proceedings as a party, witness, or in any other capacity, in any other litigation concerning the custody of the minor child. b. Petitioner has no information of any other custody proceedings concerning the minor child pending in a court of this state or any other action in any other state. c. Petitioner does not know of any other person not a party to this proceeding that has physical custody of the minor child or claims to have custody or visitation rights with respect to the minor child. 8. Petitioner moves this court to set a hearing on these issues at the completion of discovery and a pretrial conference order. 9. Petitioner should be awarded her reasonable attorney fees and costs in litigating this matter. WHEREFORE, Petitioner prays that upon hearing, this Court grant her the afore-requested relief, award her attorney fees and costs, and grant her such further and ancillary relief to which she is justly and equitably entitled. Respectfully submitted, s/ Isaiah Parsons Isaiah Parsons, OBA #31181Charles Graham, OBA #17286Matthew D. Day, OBA #31033Parsons, Graham&Day, LLC525 South Main StreetSuite 312Tulsa, Oklahoma 74103Telephone: (918) 307-1529Facsimile: (918) 514-8093Email: pgdokc@gmail.comAttorneys for Petitioner
Posted Online 81 weeks ago
