Second JUDICIAL DISTRICT COURT
COUNTY OF Bernalillo
STATE OF NEW MEXICO
NO. DM 2015 000374
Randy L. Driskill
Petitioner,
vs.
Ashleigh J. Manning
Respondent,
and involving,
Jeremiah B. Driskill
Minor Child(ren).
PETITION TO ESTABLISH PARENTAGE, DETERMINE CUSTODY AND TIME-SHARING, AND ASSESS CHILD SUPPORT
COMES NOW, Randy L. Driskill, the Petitioner and alleges:
1. The Petitioner is a resident of Bernalillo County.
2. Ashleigh J. Manning is the mother of the minor child(ren).
3. Randy L. Driskill is the father of the minor child(ren).
4. Randy L. Driskill the Father is representing the minor child(ren) as the general guardian of said minor child(ren), there being no guardian ad litem appointed for the minor child(ren) at this time.
5. The name(s), date(s) of birth, and age(s) of the minor child(ren) is/are:
Minor Child(ren) Subject to this Proceeding:
NAME Jeremiah B. Driskill
DATE OF BIRTH 11-09-2009 AGE 5
PARENTAGE
[x] 6. Parentage has been established by:
[x] Randy L. Driskill has acknowledged his paternity of the minor child(ren) in writing filed with the Department of Vital Statistics in the State in which the child(ren) was/were born.
OR: [x] Randy L. Driskill has consented to parentage and is named as father on the minor child(ren)’s birth certificate(s).
OR: [x] Parentage of Jeremiah B. Driskill has been established by DNA TESTING w/ identaliene through saliva)
OR: [x] Randy L. Driskill has openly held out the minor child(ren) and established a personal, financial or custodial relationship with the child(ren).
MANDATORY CHILD CUSTODY JURISDICTION ALLEGATIONS
7. During the past three years, the minor child(ren) have lived with the following persons, at the following places, and for the following periods of time:
History of child(ren)’s Living Arrangements:
NAME Randy L. Driskill ADDRESS 3132 Rio San Diego Pl SW
DATES Feb 2013-current
Randy L. Driskill 3412 Gladden Ct. NE 2007-Feb-2013
[x] 8. Petitioner knows of no other litigation concerning custody of visitation involving the minor child(ren) of the parties in New Mexico or in any other state in which Petitioner has participated as a party, as a witness, or in any other capacity.
[x] 9. Petitioner has no information of any proceeding that is pending in a court in New Mexico or in any other state involving visitation or custody with the parties’ minor child(ren)
[x] 10. Petitioner knows of no persons other than the parties who have physical custody of the minor child(ren) or who claim to have custody or visitation rights to the minor child(ren).
NAME Jeremiah B. Driskill ADDRESS 3132 Rio San Diego P.l. S.W.
Albuquerque, NM 87121
CUSTODY OPTIONS
[x] 11. Randy L. Driskill should be awarded sole legal and physical custody of the minor child(ren) subject to the other parent’s reasonable rights of visitation. Sole legal and physical custody is in the best interests of the minor child(ren) because Child (Jeremiah B. Driskill) has lived with Father ( Randy L. Driskill since birth, without Mother (Ashleigh J. Manning). She has not been living in the same household for the past 5 years now nor has shown any intrest in her child. Mothers where-abouts are unknown.
CHILD SUPPORT AND LYING-IN EXPENSES
12. Child support should be set according to the New Mexico Child Support Guidelines and Ashleigh J. Manning should be ordered to pay child support in the amount as determined by the Child Support Guidelines and Worksheet included therein.
MEDICAL INSURANCE & EXPENSES
Child is covered under “Centennial Care” (medicaid) under Fathers I.S.D. case.
HCS Pub. April 22, 29, May 6, 2016
