'f is IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: Familv Division Fl Division: I LAKENYA N. CAMPBELL, Petitioner, 3-. gm- Zi?h? :13 an": and :3 If? Oer?J JANORIS J. JENKINS, Respondent mag. 7.. m. 7977 to #212 SUPPLEMENTAL PETITION FOR MODIFICATION LAKENYA N. CAMPBELL, by and through the undersigned attorney, files this Supplemental Petition for Modification and states as follows. 1. Action for Modification. This is an action to modify the Final Judgment between the parties in the above- styled cause, specifically LaKenya N. Campbell hereinafter called "Petitioner," and Completed Notice of Social Janoris J. Jenkins hereinafter called "Respondent." Security Number forms are attached or were previously filed with this Court. 2. Prior Orders. The original order sought to be modified by this petition is a judgment entitled "Agreed Final Judgment of Paternity and Direction to the Clerk to Adjust the Support Ledger and Close Support File," which was entered herein on August 27, 2013. Attached hereto as Exhibit A. 3. Jurisdiction and Venue. LaKenya N. Campbell is a resident of Florida. The Final Judgment is entered herein and Palm Beach County retains jurisdiction to modify and enter further orders, as are equitable and just. 4. Militagj Status. Both parties are over the age of eighteen (18) years and neither party is, nor within a period of thirty (30) days immediately prior to this date has been, enlisted in the military service of the United States as defined by the Servicemembers Civil Relief Act of 2003. ISSUED AND DELIVERED TO PROCESS SERVER 5. Child of the Parties. The parties have one minor child subject to this action, to wit: Name: L.J. Birth date: No other children are expected. 6. Substantial Chan?qe of Circumstances. There has been a substantial change in circumstances since entry of the Final Judgment, including, but not limited to the following: Father has had a substantial increase in income since the entry of the Final Judgment. 7. Attorney's Fees and Costs. Petitioner has employed CAMERON GONZALEZ MARRONEY PLLC to represent her in this action and has agreed to pay a reasonable attorney's fee, cost and suit money for this representation. Petitioner is unable to pay said fees and needs Respondent to pay for same. Respondent has the financial ability to pay Petitioner?s attorney?s fees and costs. 8. Relief to be Tenmorary. All appropriate relief requested in this petition should be ordered temporarily in this action. WHEREFORE, LAKENYA N. CAMPBELL, Petitioner, respectfully requests this Court modify the Final Judgment as follows: a. Modify child support consistent with the Florida guidelines including an upward deviation of 5% based upon Father?s failure to spend any time with the child; and b. Require Father to pay for private school and all related expenses for the minor child; and c. Increase the face amount of life insurance Father is required to carry to secure his child support obligation commensurate with the new child support award; and d. Adjust the responsibilities of the Parties with regard to payment of extracurricular activities and uncovered medical and dental expenses to correspond to menya N. Campbe Petitioner/Mother lye/L 4 v, STATE OF FLORIDA COUNTY OF PALM BEACH SWORN TO AND SUBSCRIBED before me, this day of April 8, 2016, by Petitioner/Mother, LAKENYA N. CAMPBELL, who is personally known to me or who has produced a Florida driver's license as identi?cation. PUBLIC SNAUQ a 6.0m? sum [Print, type or stamp commissioned name of notary or deputy clerk.] \?Km 09?. 5' a9 M: Notary Public - State of Florida - Commission FF 902108 ?o (peg-5 My Comm. Explm .nu 21.2019 5 .5 0,2? 1353.3? e. Award Petitioner her reasonable attorney?s fees and costs associated with this action for modification; and f. Such other relief which this honorable Court shall deem proper. Dated: "ll; lC?l? Respectfully submitted, CAMERON GONZALEZ MARRONEY PLLC By; QM 7? Deirdre E. Marroney, Esq. Florida Bar No. 25331 901 North Olive Avenue West Palm Beach, Florida 33401 Tel. (561) 659-5522 Fax (561) 659-9811 E-Mail: dmarroney@cgmattorneys.com Secondary E-Mail: gshaw@cgmattorneys.com Attorney for Petitioner IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: and 50201 Divisibn: Family Division LAKENYA N. CAMPBELL, Petitioner, and JANORIS J. JENKINS, Respondent. I AGREED FINAL JUDGMENT OF PATERNITYAND DIRECTION TO THE CLERK TO ADJUST THE SUPPORT LEDGER AND CLOSE SUPPORT FILE . This cause came before the Court upon Petitioner's Amended Petition for - Determination of Paternity and Petition for the Court to enter an Order Superseding the . Administrative Support Order ?led by Mother, Lakenya Campbell. The Court being advised that the respective parties have agreed to the entry of this Final Judgment and the Court being otherwise duly advised in the premises, the Court makes these findings of fact and reaches these conclusions of law: 1. TheCoun has jurisdiction of the parties and the subject matter herein. 2. I This Court has continuing jurisdiction overthe child pursuant to the applicable Florida Statutes and the Uniform Child Custody Jurisdiction and Enforcement Act. 3. Florida is the home state and the state of habitual residence of the child.. Accordingly, Florida is the sole jurisdictional state to determine child custody, parental responsibility, time-sharing, rights of custody, and rights of access concerning the child under the Parental Kidnapping Prevention Act (PKPA). under the International Child Abduction Remedies Act and under the Convention on the Civil Aspects of International Child Abduction enacted at The Hague on October 25, 1980. 4. The Court ?nds that Jenoris Jenkins, is the natural and biological father of the minor child, listed belowi Name: Legend Janarian Jenkins Birth date: August 21, 2010 5. On May 1, 2013, the parties attended mediation and resolved all issues regarding paternity, support. parental responsibility. timesharing and attomeyfees between the parties the terms of which are set forth in the attached Mediated Paternity Agreement. 6. The Mediated Paternity Agreement of the parties is incorporated herein by reference for all purposes, is approved and expressly made a part of this Final Judgment of Paternity. and all of the terms and provisions of said Agreement are CONFIRMED, and ADOPTED as Orders of this Court to the same extent and with the same force and effect as if its terms and provisions were set forth verbatim in this Final Judgment, and the parties are ORDERED to cemply with the terms and provisions of said Agreement. 7. On or about June 23, 2011, in case number an administrative order of support was entered. On or about October 4, .2012, an Agreed Order on Temporary Support was entered in the instant case. This Final Judgment- and incorporated Mediated Paternity Agreed supersede both of these previously entered Orders. . 8-. The Clerk is directed to adjust the support ledger(s) in this case and in case number should they not be one in the same, to re?ect that Father owes no obligation of support and there is no overpayment to Mother and the Clerk is further directed to?close both, support ledgers as all future support payments shall be made directly to Mother. - 9. The Court reserves jurisdiction over the subject matter and the parties to enter such further Orders as may be necessary to effectuate the intent of the parties and all future modi?cations and enforcement actions. DONE AND ORDERED on August 2013, in Palm Palm Beach County, Florida. AUG 27 2013 . CIRCUIT JUDGE JUDGE WMAR Copies to: . Deirdre E. Marroney, Esq.. 901 North Olive Avenue. West Palm Beach, Florida 33401 dmarronev@cgmattomevs.com and Adam Kenner, Esq., Wolfe Law, 175 SW 7"1 Street, Penthouse 2410. Miami, FL33130 akenner@wolfelamniami.com Campbell VS. Jenkins P809 -2 Case No.: and IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT. IN AND FOR PALM BEACH COUNTY. FLORIDA 0533 "0-1 DIVISION- LAKENYA N. CAMPBELL. Pstl?onsrililiother. and JANORIS J. JENKINS. RespmdanFather the This agreement is made and entered into by and between LEKENYA N. CAMPBELL, herelnfter referred to as MOTHER and JANORIS JENKINS. hereinafter referred to FATHER. this 1Si day ofMay. 2013: I NESSETH: WHEREAS. there is one (1) child born to the parties; to wit: LJ, whose date of birth is 2010. Paternity is hereby established. JANORIS JENKINS Is-the father of LJ. WHEREAS. said parties are desirous of entering Into an Agreement which makes full disposition of all issues relevant to the instant proceeding. and NOW THEREFORE, in consideration of the mutual agreements and covenants of the parties hereto. it is hereby agreed as follows: - ARTICLE I PARENTING PLAN 1.1 The parties agree that the provisions contained In Marital Settlement Agreement. including the Time-Sharing Schedule set forth below. constitute . a "parenting plan" Intended to govern the relationship between the parents relating to the decisions to be made regardin the child. ARTICLE II, I JURISDICTIONAL Issues 2.1 The Fifteenth Judicial Circuit in Palm Beach County. Florida has continuing Jurisdiction over the child pursuant to the applicable Florida Statutes and the Uniform Child Custody Jurisdiction and Enforcement Act. 2.2 Florida Is the home state and the state of habitual residence of the child. Accordingiy. Florida is the sole jurisdictional state to determine child custody. parental responsibility, time-sharing, rights of custody. and rights of access concerning the child under the Parental Kidnapping Prevention Act (PKPA). under the lntematlonal Child Abduction Remedies Act and under the Convention on the Civil Aspects of International Child Abduction enacted at The Hague on October 25. 1980. ARTICLE PARENTAL RESPONSIBILITY 3.1 Each party recogni the deep love. devotion, and dedication of the other to the child. Each party also recognizes that the other has a right and responsibility to participate in major matters relating to the education. health. welfare, and upbringing of the child. The parents agree to use their best efforts to cooperateln- such matters. and that any rights, duties or responsibilities set forth herein shall not exercised to frustrate or control the other parent. 3.2 W. The parties shall have shared parental responsibility and shall retain full parental rights and responsibilities with respect to the . child. 3.3 mm. It is in the best interests of the child that the parents confer and jointly make all mjor decisions affecting the welfare of the chlid. Major decisions 'lnclude. but are not limited to, decisions about the child's education. healthcare. and other responsibilities unique to this family. 3.4 M. The parents shall use all reasonable efforts to maintain free access and create a feeling of affection between themselves and between the child. Neither shall do anything to hamper the natural development of the child's love and respect for the other party. 3.5 We Unless cthennilse indicated or ordered by the Ccurt: Both parents shall have access to medical and school records pertaining to the child and shall be to independently consult with any and all professionals involved with the child. The parents shall cooperatewith each other in sharing lnfonnation related to the health, education, and welfare of the child and they shall sign any necessary documentation ensuring that both parents have access to said records. Each parent shall be responsible for obtaining records and reports directly from the school and health care providers. (0) Both parents have equal rights to inspect and receive governmental 2 agency and law enforcement records concerning the child. Both parents shall have equal and Independent authority to confer with the child's school. day care. health care providers. and other programs with regard to the child's educa?onal. emotional. and social progress. Both parents shall be listed as "emergency contacts" for the child. u' in; 9.41;. r: a Each party shall inform the other party within twenty-four hours of any illness. accident. or medical condition of the child that involves surgical intervention or hospitalization. Each parent may have reasonable and immediate access to such child _In such an event. regardless of parental responsibility or terms of any time-sharing schedule. 3.7 mm. Each parent shall make decisions regarding day- to-day care and control of each child while the child is with that parent. Regardless of the allocation of decision making In the parenting plan. either parent may make emergency decisions affectln the health or safety of the child when the child is residing with that parent. A parent who makes an emergency decision shall the decision with the other parent as soon as reasonably possible. . 3.8 ?gegigi Events. Both parents shall be entitled to participate with and- attend special events and activities in which the mild may be engaged. such as religious activities. school programs. sports events. and other extra-curricular school activities and programs and important social events In which the child may be engaed or involved. 3.9 The parents agree to the following with regard to extra-curricular activities: Either parent may register the child and allow them to participate In the activity of the child's choice while the child Is in that parent's care. The costs of the extra-curricular activities shall be paid by: Mother Father 95%. The unlforrns and equipment required for the extra-curricular activities shall be paid by. Mother Father 95%. ARTICLE IV TIME-SHARING SCHEDULE 4.1 W. The parents agree that it is in the best interest of the child for each of them to have frequent and continuing contact with the child. and 3 the parents shall spend time with the child at times they have mutually agreed to in advance. The parents shall use all efforts to communicate and cooperate with respect to the timesharlng schedule. 4.2 Transportation. All transportation and transportation costs shall be paid by Fther. ARTICLE OTHER PROVISIONS RELATING TO THE CHIL 5.1 Mmunicetion awn Parents. All communications regarding the child shall be between the parents. The parents shall not use the child as a messenger to convey information. ask questions, or set up schedule changes. The parents may communicate with each other In person. by telephone. by letter. or by email. 5.2 Communigtion Between Parent and Child. Both parents shall keep contact information current. Telephone or other electronic communication between the child and the other parent shall not be monitored by or Interrupted by the other parent. "Electronic communication" includes telephones. electronic mail or e-mall, weboems. video-conferencing equipment and software or other wired of Wireless technologies or other means of communication to supplement face to face contact. The child may have telephone and e-mall communication with the other parent anytime. 5.3 MW. Each party shall be responsible for the cost of the party's own electronic communication with the other party or with the child. 5.4 MW. Each parent shall keep the other parent informed regarding the whereabouts of the minor child. 5.5 uo Activity that Child. The parents shall refrain from engaging in any activity which may endanger the health. safety or morale of the child. 5.6 mm. For school and school district purposes, Mother?s address shall be desinated. Mother shall have sole discretion to choose the school the child shall attend. 5.7 W. The Mother shall be deemed to be the majority parent and her address shall be used as the legal address of the child. This designation does not affect either parent's rights and responsibilities under this 4 Agreement. ARTICLE VI CHILD SUPPORT Mutant of the Poms; to child Suggort 6.1 The parties agree that the amounts In the Child Support Guidelines Worksheet attached hereto are correct and should be incorporated Into the judgment of the Court as ?ndings of fact. Clue 6.2 Father shall pay to Mother child support in the amount of Four Thousand and Noi100 Dollars per mom. to be paid with the first of $4,000.00 due on June 1. 2013. and a the payment due on the 1st of each month thereafter. Father shall continue payment of child support in such manner Lmtil modi?ed by court order, or until the date of the earliest occurrence of one of the followin events: The date of the chiid's 181h birthday unless the Court finds that the child is between the ages of 18 and 19, a dependent in fact and still in high school performing in good faith with a reasonable expectation ofgraduation before the age of 19, the Court may modify this order to extend support until the child graduates from high school or attains the age of 19 years. whichever comes ?rst; the child becomes ernanclpaied; marries; the child joinsthearmed services; or thechild dies. 6.3 The Father shall pay 95% and Mother shall pay 6% of any school trips, sports or other extracurricular activities. 6.4 Father ovves Mother retroactive child support up through May 31. 2013, in the amount of $18,000.00 which shall be paid as follows: $10,000.00 on or before June 1. 2013 and the remaining balance of $8,000.00 by August 30. 2013. Other Proviione Child ?nal); 6.5 I . The parties agree that immediate income deduction shall not be implemented at this time. and that income deduction is not In the best interest of the child. Father agrees to advise Mother and the depository of any 5 change relatln to Father Including name. address, employment information, and health Insurance. 6.6 W. The prties agree that payments of child support shall be made directly by Father to Mother. instead of through a central depository. the State Disbursement Unit. or Immediate Income deduction. Payments shall be made by check or by money order. and both parties shall each keep ?'relr own records of all payments due and all payments made. - 6.7 In the event of a default in the payment of support equal to one month's obligation. either party may initiate payment of child support through an Income deduction order by ?ling an af?davit pursuant to Section of the Florida Statutes. 6.6 The Final Judgment entered herein shall supersede the administrative order for support previously enbred and direct the clerk to adjust the current child support leger to reflect no monies owed and to close the child support lager previously entered for this child. - 6.9 Father shall within 90 days obtain and continue to maintain for so long as there is an obligation of support. a llfe insurance policy in the amount of $250,000 with the child named as bene?ciary in order to provide for the child support payments-In case of his untimely death. Father shall provide proof of coverage upon obtaining said policy and each year. 6.10 On or before July 1. 2013. Mother shall set up a 5298 account for the child's college tuition or a Florida prepaid college fund. Mother shall. commencing July 1. 2013. contribute $250.00 per month to the child?s fund as aforersferenced for each month that she relves a child support payment from the Father as set forth In this agreement. White 6.11 For as long as either party has a legal duty to support the child who is the sublect of this Agreement, or until further order of the Court. Father shall provide health Insurance for the child. 6.12 As provided by Florida Statutes, Section the health immense agreed to above is reasonable in cost and accessible to the children. 6.13 Each party shall cooperate with the other in the procurement of the above- descrfoed Insurance and the ?ling of claims. The party providing an insurance policy covering the child hereunder shall submit all forms required by the insurance company for payment or rehnbursement of health or dental care incuned by either party on behalf of the child to the insurance carrier within ten days of that party's 6 receiving any form. receipt, bill. or statement re?ecting the expenses. and shall provide to the other party the following information. as applicable. no later than the thirtieth (30th) day after the date this Agreement has been signed: the name and address of the employer of the party providing insurance; whether the employer is self- insured or has health or dental insurance available; proof that such insurance has been provided for that child; and the name oi the insurance carrier. the" number of the policy. a copy of the policy and schedule of bene?ts. an insurance card. claim forms. nd any char information necessary to submit a daim or. ii the employer is self-Insured. a copy of the schedule of bene?ts. a membership card. claim forms. and any other information necessary to submit a claim. Any change in the foregoing information (Including a tenninatlon or lapse in insurance) shall be provided by the insurance to the other party within tan (10) days fter the providing party learns of such change. 6.14 "Noncovered Health Care Expenses" means all ordinary. reasonable and necessary expenses not covered by Insurance and incurred for medical. health. dental, or care on behaif of the child who is the subject of this Judgment. including but not limited to hospitalization. prescriptions. physician's. dentists. orthodontics (including braces), contact lenses and eyeglasses. examinations. and insurance copeyrnents. and Which are incurred while either party has a legal duty to support such child. 6.15 Noncovered Health Care Expenses shall be divided by the parties as follows: Father shall pay ninety five percent and Mother shall pay ?ve percent A party who pays for a Noncoversd Health Care Expense or receives notice of the same shall submit to the other party proof of payment or such notice within tifteen (15) days of payment or receipt of notice. Within ?fteen (15) days after the other party receives such noti?cation. the other party shall reimburse the paying party or pay the billing party directly for his or her share of the expense. as applicable. ARTICLE COURT COSTS AND ATTORNEYS FEES 7.1 Within 5 days of the date of this agreement Father shall pay attorney fees of $10,000.00 directly to Mother's attorney. Deirdre Marroney. Esq. at 901 North Olive Avenue. West Palm Beach. Florid 33401. I. Jenorie Jenkins. certify that I have been open and honest In entering Into this Agreement. I am with this Agreement and Intend to be bou?nd by It. Dated: (?374? A STATE OF FLORIDA COUNTY OF PALM BEACH Swom-to or af?nned and subscribed me on by Janorie JenkinsPersonally known J4 Produced identi?cation Type of identi?cation produced WWL l. Lskenye Campbell. certify that have been open end honest In enteran Into Agreement. I am satis?ed this Agreement and Intend to be bound by It. Dated: 2 7; 3 STATE OF FLORIDA COUNTY OF Palm Beach Sworn to or affirmed and subscribed befo me on M31 0x140 I by Lakenye Campbell. 0 I Printed Name of Notary Personally known . ?n . 'u noun Mu; .. energetier anuou an no sag .- . AMELIA MATIAS Notary Public - State at Florlda a 5-2: My Comm. Explras May 7. 2M5 a? 3 Commission 05? rr 79422 "If m'rl??5 Bonded Ibreugn Nahon anary Assn IN THE CIRCUIT COURT OF THE JUDICIAL IN AND FOR COUNTY. FLORIDA Mm" Division: and Respondent and; none "?ngernail". .nu .. . i. -..- .-.- -.- :j?t?i W??i's'iil'??f Worksheetlor Children Residing I A Father EMB. Mother i 1' With Lekenya i - -. Total gNo. of Children Residing With: 1 1 51. Gross Income 1 04.000 1.350 I A. LeesAllmd Deductions (35,454): (132, B. Spousal Support this . c. Other Adjuelment D. Present NotMonthiy income 3 48.548 1.213 49.704 Enter the amount from line number 27. Section I of Florida Family law Rules ?Procedure Forth 12.0020?) or (0). Financial A?idavil . .2. Basic Momnlyoulganon Using the total emulation line to. enterthe appropriate amount than the child support guidelines 13th 3. Percentol Reeponatb?lly 97.55% 2.45% 100% Dividetho mounts on line ID loreaoh parent by the totalerndunton line 10 tonellhe percentage loreeoh parent's armhole! monomer. it. Share of Basic Moan Obligation 3.341 84 Multiply the number on line 2 by the. percent for each parent on line 3 . Additional Support - Health insurance, Child Care 8. Other i 03. 850'! 1. requiredto dare trams licensed source. Bee 9 6130(1), Fie.8tel. for more i b. Total Health Insurance 0 0 Costa 3.425 3.425 [Title to only amounts actually paid for health Ineurenoe on the emotion}! - . Total Nonoovored 0 0 Medical. Dental and Prescription Medication Costs 6d. Total Child Care it Health Costa [Add linen 5e 1- 5b Bo]. 650 Florida Family Lew Ruiee of Procedure Form 12.9mm). Child Support Guidelines Worksheet (9112) Page 1 ol 2 2013 Thomson Reutere. All rights resented. 05101113 Petitioner name: Case No. .. .. . . .. Additional Support Payments 634 1B 3 Multiply the total number en mar percentage on line 3 forearm parent. . Statutory AdluetmentaiCredtte 7a. child care payments actually made 0 (850') health insurance payments 0 0 i . payments actually made for any 0 0 nonoouered medtoai. dental and prescription medication of the ohiid(ra.n) not gamed to be separately paid on a percentage I i i (See serene). FiotideStatuiee) . . Krihrally Made or (semi a (Add iinae 1a through 71:) 2 . IillNiMUllil CHILD summer oauemou . 3.915% - (use)? FOR EACH PARENT 5 [Une4pluallne6mtnuetlne8] - - SubatontieiTlme-Sharlno 1 One parent do'ee not alumina at least 20 percent at the tn the year. re. CHILD SUPPORT BEFORE em . 11. OtherMuetmente (Ha-statement?) i 5 11a. onernulmrmanrer 115. O?larAr?uutmant? I .12. CHILD eupaonr PAYMENT natal": p.975; a?l?I?n?l-?Il-II-Il ADJUSTMENTS 'ro titliDEthtES AMOUNT. It you or the other parent is requesting the Court to award a child support amount that to more or less than the child eupport guidelines. you must complete and ?le Motion to Deviete from Child Support Guidelines. Fiortde Supreme Court Approved Famiiy Law Form 12.943. one only) a. Deviation from the guidelines amount to requested. The Motion to Deviate from Child Support Guidelines. Florida Supreme Court Approved Famliy Law Form 12.943. is attached. It. Deviation treat the guideline amount to NOT requeeted. The Motion to Devlate from Chile Support Guidelines. Florida Supreme Court Approved Family Law Forr?n 12.943. to not attached. Date: Comments: Florida Famin Lew Ruleeo?i Prooedure Form manure). Child Support Guidelines Worksheet (9112} Page 2 of 2 2013 Thomson Reuters. All rights raearued. 05mm