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PATERNITY

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)

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