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ITIO Read Children
Petition in Intervention in Suit Affecting Parent-Child Relationship Page 1 of 7
NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA
No. 2017-525,887
IN THE INTEREST OF §
§
IN THE DISTRICT COURT
C. READ & B. READ, § 364TH JUDICIAL DISTRICT
§
CHILDREN § LUBBOCK COUNTY, TEXAS
PETITION IN INTERVENTION IN SUIT
AFFECTING THE PARENT-CHILD RELATIONSHIP
This Petition in Intervention is brought by Jennifer Read. In support, Intervenor shows:
1. Parties
Intervenor, Jennifer Read, is the stepparent of the children the subject of this suit.
Intervenor has standing to intervene in this proceeding as more fully detailed below.
This suit is brought by Jennifer Read, Intervenor. The last three numbers of Jennifer
Read's driver's license number are 995. The last three numbers of Jennifer Read's Social Security
number are 789.
Intervenor has standing to bring this suit under section 102.004(b) of the Texas Family
Code. Intervenor had substantial past contact with the children the subject of this suit, and the
appointment of a parent as a sole managing conservator or both parents as joint managing
conservators would significantly impair the child's physical health or emotional development.
Intervenor has standing to intervene in this proceeding under section 102.003(a)(9) & (11)
of the Texas Family Code. Intervenor has had actual care, control, and possession of the children
the subject of this suit for at least six months ending not more than 90 days preceding the date of
the filing of this Petition in Intervention in Suit Affecting Parent-Child Relationship. Furthermore,
Intervenor is a person with whom the children subject to this suit and the children's guardian,
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Petition in Intervention in Suit Affecting Parent-Child Relationship Page 2 of 7
managing conservator, or parent have resided for at least six months ending not more than 90 days
preceding the date of the filing of this Petition in Intervention in Suit Affecting Parent-Child
Relationship, and the children's guardian, managing conservator, or parent is deceased at the time
of the filing of this Petition.
2. Jurisdiction
This Court has acquired and retains continuing, exclusive jurisdiction of this suit and of
the children the subject of this suit as a result of prior proceedings.
3. Children
The following children are the subject of this suit:
Name: Colton Robert Read
Sex: Male
Birth date: September 21, 2012
County of Residence: Lubbock County
Name: Brady Wayne Read
Sex: Male
Birth date: May 7, 2007
County of Residence: Lubbock County
4. Mother
The mother of the children the subject of this suit is Christina Read.
Process should be served at 5902 101st Place, Lubbock, TX, or wherever she may be found.
5. Court-Ordered Relationships
There are no court-ordered conservatorships, court-ordered guardianships, or other court-
ordered relationships affecting the children the subject of this suit.
6. Insurance Information
Information required by section 154.181(b) and section 1541815 of the Texas Family Code
will be filed separately prior to a final hearing in this matter.
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7. Property
No property of consequence is owned or possessed by the children the subject of this suit.
8. Protective Order Statement
No protective order under title 4 of the Texas Family Code, protective order under
subchapter A, chapter 7B of the Texas Code of Criminal Procedure, or order for emergency
protection under article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a
party to this suit or a child of a party to this suit, and no application for any such order is pending.
9. Conservatorship
The parents of the children are or will be separated. The appointment of a parent as a sole
managing conservator or both parents as joint managing conservators would not be in the best
interest of the children. The appointment of a parent as a sole managing conservator or both
parents as joint managing conservators would significantly impair the children's physical health or
emotional development. Additionally, the appointment of a parent as a sole managing conservator
or both parents as joint managing conservators would significantly impair the children's safety.
It is in the best interest of the children that Intervenor be appointed sole managing
conservator of the children.
10. Child Over the Age of 12
Brady Wayne Read, a child the subject of this suit, is twelve years of age or older and
will express to the Court in chambers, as provided in section 153.009 of the Texas Family Code,
the name of the person who is the child's preference to have the exclusive right to designate the
primary residence of the child.
11. Request for Temporary Orders
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Intervenor requests the Court, after notice and hearing, to make temporary orders for the
safety and welfare of the children, including but not limited to the following:
Ordering Respondent, Christina Read to provide support for the children, including the
payment of child support and medical and dental support in the manner specified by the Court,
while this case is pending.
Ordering reasonable periods of electronic communication between the children and
Intervenor to supplement Intervenor's periods of possession of the children.
Appointing Intervenor as the temporary sole managing conservator of the children, and
appointing Respondent as a possessory conservator.
Awarding Intervenor the exclusive right to designate the primary residence of the
children.
Restricting Respondent’s possession of, or access to, the children so that all contact is
supervised and/or occurs in a protective setting.
Restricting the primary residence of the children to Lubbock County.
With regard to the requested temporary order for managing conservatorship, Intervenor
would show the Court the following:
These temporary orders are necessary because the children’s present circumstances would
significantly impair the children’s physical health or emotional development, and the requested
temporary order is in the best interest of the children. See the attached Affidavit of Intervenor.
12. Request for Temporary Restraining Order Granting Extraordinary Relief
This Temporary Restraining Order is necessary to protect the physical health or emotional
development of the children.
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Intervenor requests the Court to dispense with the necessity of a bond, and Intervenor
requests that Christina Read be temporarily restrained immediately, without hearing, and after
notice and hearing be temporarily enjoined, pending the further order of this Court, from:
a) Disturbing the peace of the children or of another party.
b) Withdrawing the children from enrollment in the school or day-care facility where the
children are presently enrolled.
c) Hiding or secreting the children from Intervenor.
d) Making disparaging remarks regarding Intervenor or the family of Intervenor in the
presence or within hearing of the children.
e) Consuming alcohol within the 24 hours before or during the period of possession of or
access to the children.
f) Canceling, altering, failing to renew or pay premiums on, or in any manner affecting
the level of coverage that existed at the time this suit was filed of, any health or dental
insurance policy insuring the children.
Request for Extraordinary Relief
As the basis for the extraordinary relief requested below, Intervenor would show that
before the filing of this Application, Christina Read has engaged in the conduct set forth in the
affidavit attached as Exhibit A. Christina Read’s conduct set forth in the affidavit significantly
impairs the physical health and/or emotional development of the children. Based on this affidavit,
Intervenor requests the Court to grant the following extraordinary relief:
1) Issue an order attaching the body of the children, Colton R. Read and Brady W.
Read.
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Petition in Intervention in Suit Affecting Parent-Child Relationship Page 6 of 7
2) Issue an order taking the children into the immediate possession of Intervenor,
Jennifer Read.
3) Issue an order excluding Christina Read from possession of or access to the
children, Colton R. Read and Brady W. Read.
13. Request for Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Intervenor to secure the services of Matthew L. Harris, Esq., a
licensed attorney, to preserve and protect the rights of Intervenor and of the children. Reasonable
attorney's fees, expenses, and costs should be awarded to the attorney for Intervenor and a
judgment should be rendered in favor of the attorney and against Petitioner and Respondent and
be ordered paid directly to the attorney for Intervenor, who may enforce the judgment in the
attorney's own name. Intervenor requests postjudgment interest as allowed by law.
14. Prayer
Intervenor prays for relief as requested in this petition.
Intervenor prays that the Court immediately grant a temporary restraining order restraining
Respondent, in conformity with the allegations of this petition, from the acts set forth above, and
Intervenor prays that, after notice and hearing, this temporary restraining order be made a
temporary injunction.
Intervenor prays that the Court grant his request for Extraordinary Relief, set forth above.
Intervenor prays for attorney's fees, expenses, costs, and interest as requested above.
Intervenor prays for general relief.
Respectfully submitted
MATTHEW HARRIS LAW, PLLC
1001 Main Street, Suite 200
Lubbock, Texas 79401-3309
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Tel: (806) 702-4852 | Fax: (800) 985-9479
Matthew L. Harris, Esq.
State Bar No. 24072812
Attorney for Jennifer Read
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or party in
accordance with Rule 21a of the Texas Rules of Civil Procedure on November 24, 2021 in the
manner indicated below.
Matthew L. Harris, Esq.
Attorney for Christina Read
THE FOUTS LAW FIRM
Leigh Ann Fouts
P.O. Box 5187
Lubbock, TX 79408
Tel: (806) 741-0373 | Fax: (806) 741-1491
Via E-Filing Manager
