Paternity has not been formally established. Melissa RUSSELL was previously pregnant by 5 months. Minor child currently resides with her STEP FATHER at 1783 BLUE LAKE DR.,GREENWOOD, IND. 46140.
Paternity has not been formally established. Melissa RUSSELL was previously pregnant by 5 months. Minor child currently resides with her STEP FATHER at 1783 BLUE LAKE DR.,GREENWOOD, IND. 46140.
Paternity has not been formally established. Melissa RUSSELL was previously pregnant by 5 months. Minor child currently resides with her STEP FATHER at 1783 BLUE LAKE DR.,GREENWOOD, IND. 46140.
STATE OF INDIANA ) IN THE MARION SUPERIOR/CIRCIUT COURT
) SS: COUNTY OF MARION ) CAUSE NO: 49D02 14 02 DR 004863
IN RE THE PATERNITY OF ) Savannah Kay Marie Russell ) ) ) MELISSA RUSSELL & CHARLES PURNELL ) ) Petitioner, ) ) ) vs. ) ) ) ERIC RUSSELL SR. ) ) Respondent. )
VERIFIED PETITION TO ESTABLISH PATERNITY
Comes now MELISSA RUSSELL (Petitioner) and petitions the Court as follows:
1. Petitioner is an adult who believes the biological father of SAVANNAH RUSSELL (minor child). IS CHARLES DAVID PURNELL
2. Minor child was born on JANUARY 27, 2008
3. Minor child currently resides with her STEP FATHER (Respondent) at 1783 BLUE LAKE DR.,GREENWOOD, IND. 46140
4. The PARTIES ERIC & MELISSA RUSSELL WERE married Auguust 25, 2007 and that minor child was born in marriage. However melissa russell was previously pregnant by 5 months.
5. Paternity has not been formally established; however, Petitioner has held out minor child as his natural child and has established a personal, financial, and custodial relationship with minor child.
6. During the past three years, minor child has lived with the following persons, at the following places for the following periods of time:
PATERNITY With: Address: Dates: Petitioner 4529 vernon ave. Indiana From birth to JUNE 17, 2012 Respondent 1783 BLUE LK. DR. Indiana APRIL 2013 - present
7. Currently, all the parties and their child are residents of Indiana and MARION County.
8. To date, no court has officially established paternity of child/children named in Paragraph 1 above. Petitioner knows of no other litigation, past or present, concerning custody or visitation, involving minor chidren. HOWEVER THERE WAS A CHINS CASE AGAINST MR. RUSSELL AND MYSELF DURING A TIME OF INCARSERATION. On JUNE 18, 20013 they closed it sucessfully with mr. russell
9. Petitioner has been denied access to minor child since JANUARY 27, 2008
10. The parties should be awarded joint legal and physical custody. Petitioner MELISSA RUSSELL lives only one (5) mile from CHARLES DAVID PURNELL and believes that it is in the best interest of minor child to spend equal time with both parents.
WHEREFORE, Petitioner prays the Court to enter an order:
1. An Order setting this matter for hearing;
2. After a hearing, an Order finding CHARLES PURNELL to be the father of SAVANNAH RUSSELL
3. Award child custody in accordance with this Petition, with four (4) days one week and three (3) days the next week plus one day in the following week (Wednesday after school and return to school in the a.m.)
4. Declaring the following additional rights:
a. telephone and/or webcam contact with minor child;
b. one-half of all school vacations
c. one-half of summer vacation
d. alternating holidays
PATERNITY 5. Ordering parties to share equally the dependent child income tax deduction.
6. Declaring custodial parent cannot relocate without permission of the court, pursuant to Indiana Code 31-17-2.2.
7. Declaring Petitioner be given court notice of intent to relocate as set forth in Indiana Code 31-17-2.2.
8. Ordering that when RESPONDENT ERIC RUSSELL is proved through DNA that he ERIC RUSSELL be removed from SAVANNAH RUSSELLS Birth Certificate and CHARLESS PURNELL BE ADDED and his parental rights be execuded.
9. Ordering SAVANNAH RUSSELLS name be changed to her biological fathers name of SAVANNAH KAY PURNELL
I affirm, under the penalties for perjury, that the foregoing representations are true, this ________________ day of _____________, 20____.
________________________________ xxxxx
PATERNITY STATE OF INDIANA ) IN THE MARION SUPERIOR/ CIRCUIT COURT ) SS: COUNTY OF MARION ) CAUSE NO: 49DO2 14 02 DR 004863
IN RE THE PATERNITY OF ) SAVANNAH KAY MARIE RUSSELL ) ) ) MELISSA RUSSELL & Charles purnell ) ) Petitioner, ) ) vs. ) ) Eric russell ) ) Respondent. )
APPEARANCE BY PARTY IN CIVIL CASE
Party Classification: Initiating
1. I, CHARLES DAVID PURNELL now appear in this case as the alleged father of minor child SAVANNAH RUSSELL
2. Contact Information:
CHARLES DAVID PURNELL Phone: 812-599-1271 2910 N. DENNY. INDPLS IND
3. There are other party members: YES ERIC RUSSELL
4. If first initiating party filing this case,
5. I will NOT accept service by FAX.
6. This case involves support issues. YES
7. There are related cases: YES DIVORCE OF ERIC & MELISSA RUSSELL
8. This form has been served on all other parties: YES
_____________________________ xxxxx PATERNITY STATE OF INDIANA ) IN MARION SUPERIOR/CIRCUIT COURT ) SS: COUNTY OF MARION ) CAUSE NO: 49DO2 14 02DR 004863
IN RE THE PATERNITY OF ) SAVANNAH KAY MARIE RUSSELL ) ) ) MELISSA RUSSELL & CHARLES PURNELL ) Petitioner, ) ) ) vs. ) ) ) ERIC RUSSELL ) ) Respondent. )
ORDER TO APPEAR
MELISSAA RUSSELL & CHARLES PURNELL, pro se, has filed his verified Petition to Establish Paternity over minor child SAVANNAH RUSSELL. Accordingly, the parties listed below are ordered to appear before the Court for hearing in this matter, which is set for ___________________, 20__ at _______________ a.m./p.m. at the court located at _________________________________________________________. The parties may present evidence on their behalf. Failure to appear may result in matters being decided in your absence.
____________________________ ___________________________________ DATE JUDGE
DISTRIBUTION:
ERIC RUSSELL @ 1873 BLUE LAKE DR.GREENWOOD IN 46140 JOHNATHAN STWEART @ 613 N. ALABAMA ST. INDPLS, IN ( LEGAL AID SOCIETY) PATERNITY STATE OF INDIANA ) IN THE MARION SUPERIOR/CIRCUIT COURT ) SS: COUNTY OF MARION ) CAUSE NO: 49DO2 14 02 DR 004863
IN RE THE PATERNITY OF ) SAVANNAH KAY MARIE RUSSELL ) ) ) MELISSA RUSSELL & CHARLES PURNELL
) Petitioner, ) ) ) vs. ) ) ) ERIC RUSSELL ) ) Respondent. )
ORDER ON PETITION TO ESTABLISH PATERNITY
Comes now MELISSA RUSSELL & CHARLES PURNELL, who has filed his verified Petition to Establish Paternity over the minor child SAVANNAH RUSSELL, which Petition is on file with the Court and is part of the Courts records. And the Court, having examined said petition and the parties having appeared in person, hearing evidence thereon, and being fully advised in the premises, now finds:
1. xxxxx to be the father of xxxxx;
2. It is in the best interest of the minor child that Petitioner is awarded joint legal and physical custody of minor child.
3. Child custody contemplates four (4) days one week and three (3) days the next week plus one day in the following week (Wednesday after school and return to school in the a.m.)
4. That the parties are entitled to the following additional rights of parenting time:
PATERNITY a. telephone and/or webcam contact with minor child;
b. one-half of all school vacations
c. one-half of summer vacation
d. alternating holidays
5. The parties shall share equally the dependent child income tax deduction.
6. The parties cannot relocate without permission of the court, pursuant to Indiana Code 31-17-2.2.
7. The parties must give each other court notice of intent to relocate as set forth in Indiana Code 31-17-2.2.
8. That SAVANNAH RUSSELL OBTAIN HER BIOLOGICAL FATHERS NAME OF SAVANNAH KAY MARIE PURNELL AND THAT CHARLES PURNELL BE ADDED TO THE BIRTH CERTIFACTE AS HER FATHER.
IT IS SO ORDERED.
____________________________ ___________________________________ DATE JUDGE
DISTRIBUTION:
MELISSA RUSSELL @ 4529 VERNON AVE INDPLS,IN 46226 CHARLESS PURNELL@2910 N. DENNY ST. INDPLS, IND 46201 ERIC RUSSELL@ 1873 BLUE LAKE DR. GREENWOOD IN 46140 JOHNATHAN STEWART @ 613 N. ALABAMA ST. INDPLS IN (LEGAL AID SOCIETY)