FILED 512312017 9:41:18 AM Donna-Kay McKinney Bex-ar'CQun'ty District Clerk Accepted By: Gonzalez 70'0941'3 IN THE INTEREST or IN THE DISTRICT COURT (3.3., 131.sT JUDICIAL DISTRICT A CHILD BEXAR COUNTY, TEXAS ORIGINAL PETITION FOR. BILL OF REVIEW 1. Discovery in this case is intended to be. conducted under leVe-l. 2 of rule 190 of?the Texas Rules of Civil Procedure. This suit is brought by Akipan Ebeng Bia-sse'y, Peti-tiOne'r. Respondent-s are residents of char Connty, Texas,- and will be served a copy of this pleading through their attorney of record according to the following certi?cate of service. 3. On Mar-ch 2017 an order was rendered in this Court in Cause No. 2202] styled "In the interest of C.B., Minor Child." A certified copy of the order is attached as Exhibit A. 4, Petitioner has 110 adeCIurate legal remedy now available to avoid the effect of the. order. Despite the exercise of due. diligence, Petitioner did not discover Respondent's fraud-until more. than thirty days. a?er rendition of the judgment, The invalidity of the judgment does not appear. on the face of the record. 5. Petitioner reqLIests that the Court set aside and cancel the order rendered on March 31, 2.0.17, as detailed: in the attached Exhibits 8, C, and D. 6. Petitioner prays that citation and notice issue as required by. law, that a new trial. be granted, and that on final trial the Court order as; follows: a. Petitioner recover hiscosts of suit. Petitioner prays thrgeneral relief. Respectfully submitted, Law Offices'of Ivan Friedman 1.15 Ca-mar?on 'St. San Antonio, TX 78205 [van- Fried-man Attorney for: Akpan Ebong Bas-s'ey Texas Bar No. 00785386 Phonez'210?227?2888 "Email: -l.aw@ivanfriedman.eom Akpan- Eboing PetitiiOnet?, has sworn under oath? that the facts stated in the above- Ori'gin'al IPetitiOn for-Bill of Review- are trueand correct, as detailed in the attached Exhibit. 13. Certificate of Service. I. certify that a true and correct copy. of the above" was served on each" attorney of record- or party in accordance with. the Texas Rules of Civil Procedure on May 23', 2017. MW [van Friedman Attorney for Akpa-n Ebong? Bassey NOTECE: Tar-s DOCUMENT comm-S smm?m EMA.- ems}: N50. 20150122621 - q; 'r IN THE 01? mg} Bi?i'?l(3.3. MIN-0R. CHILE comm; 1W3 i. ?a . Date afHearing a On the, data 'indicated. ?om- agreea- ?hal Order Modify I .ParenFChiki 3 App?aragzcas I Petitioncgg, ROMAO, did. 110539968: ill-person but have agreed to the terms of this order as evidenced by'Pet'it-icnars? signatures and- the; signi?e- Z?cvaet'i?oners? attorney below. at]. Respondcm, EBONG waived. game. of-service: 9f citation by waiver ?led and, a-ftgr nut-ice did not appear, hmshas? agreed: to the? 0f ?ts-order. as .CQidanced below. Jurisdiction The urt, after *the fecord th?; (:zvidence, w?'ft?m. this?has jammy.) ems. case and. of: all the_ parties fhat other court: has contimwirg exams-?96: jmisdiction of 6332. A11 person- entitled to chat-$011 w?re pfoperty'?it'ed. J'm?y A jury Was waived, and all qges?dm; offactaand law were to the Court. mA3L'.oRi3m '12s: mag-.1 m: Recard of a record was waived by the parties the cement of the, Court; Child The Court that- the 'foBowm?g' Chiiti tube subject 5mg suit-:- Narm-u Charles. B'assey. [who is in {misty}: of the case] hereafter "Sex; Male- date: October 28, 2000 County of'rcsidence: char. Camry, Tam ?ndings" The Com-t ifmds?that Respondan AKPAN BASSEY, is- the father ofthe Child, and? cm?mly ism-s in Lag'as- Nigeria, and GRACE MFON is the m?m ofthe Child, m. is deceased. "The ?nds that. Respondent has vehmiarily mli'nquished possession. of the Child petitioners, WSSY AURIANTAL and a period .ofmore' than one year, and the Child has resided in Texas mammal-grim Petitioners du?ng this period: Agreed Parenting Pian The Court ?nds the provEsions in these a?gmcd OrderS-rela?ngzto the rights and duties of the parties relation to the Ch?d. possessibn of and access. tn the cm, child" support, J-aand optin?lizing the developmnt of a abs: and cqntinuing relatiOnshijp- between. each party-and the Parties? .agaeed parenting pm' Canservarorship Provisions - The Court ?nds that the following orders arch me best inierest ofthe ChiId?, Charles Bassey. AGREE) maggogpggimsm Arm:er NQTARY s, 911212-51. AVENUE Pam-2.95 1.6; ?a W4 IT IS that WSSY ROMAO are appokit?d S'oic Managing Camem'tors, and is appainted? Eoss'essory Comervator? Qf-th? Charles Basscy. IT IS that, at a?Il- and RQMAQ, a8" sole; maingcenservators .shalihaw Ike foliowingn?gbts: 1.. the ?ght td receive ?om any other Congeniasz Qf'thi'e Child .. the health: B?uca?on, and WOW ?fths Chad; the to conifer- with-?the other Conservators to the extent paSsibla? beibre Whig admission comet-magma health, educating andgwelare-of mama; of access to medical, demal, and educatignal records "of Ch?d; the light 10- comujt- a physician. dentist, Or.- of "the to consuit with: school of?cials comeming the Child?s- welfare and educational sums, school activities; the right to attand. .schoolanci extracurricular act-Macs; the right to be. d'csignat'ed "on tha Child?s records as a person t0 be noti?cd ill-(1338- 'Ju to consent in mdi'caL dental, and smgical. treatment an ?lvolving- danger to the health and. and the to the estate-to the ?extent the ?s'tate has bcen created by HEN-NSSY ADRIANTAL and NATE-WEE ROM-A0. IS ORDER-ED "that; at all times, AKPAN. mom BASS-BY, as pes'sesjsory conservator, sha?have the fbllowing?ghts: 1.. the right to receive Manama from any. other Comemmrs of the Ch?d conceming the beam Edi-1631i?; Wel?ze of?ie Chiid; the. right to. confer other Conservatism to the. em 'befare a decision concerning theshe'am education; and. wei?m ofthe-Ch?d; 01mgRo-Ka- .DU-kt I I 1'6. NOTARY PUBLIC - RU Flatt?: Wamwimmam pad, cuss. the right of access to medic-3L dantal, and edma?onal records of Child; ?ts right to consqu 'ay-physician. dentist, or of'the: Chiki; the right to censult. with school oi?ciais comeming- the Child? Welfare. and educasional-stam, minding-salami activities; the ??ght' to attend -$chooland the right to be desmt?d on the Ch?d?s? "records as a person "to be mti?ed in- case of-an. the right to consent to undical, de?al, and smgical mumsnt during an involvinggan Erman the and to manage 3th}: Child?s eswte to the: extant the estate bacn cmatcd by IT 38 that, at? all RQMAJO, as sole and AKPAN BESSEY, as camewatog shall each-haw .ibliowm'g duties: .1. the duty to the: ather Conservatmjsa of in a. '-n?ann??r 53f signi?cant iufamaation concert?g the heath, educatiaam and ml?rc-. of the Child; the duty to inian the other :Con?c'rviators afthe Child if the {imam resides ?x a; 16213: (30) days, marries, or #113653 to a person-whiz} the Parent knews is registered as. a sex. o?bnder under chapter 62 of the Code of Proctedurc or is 01:336me charged an o?'eme for whisk: an convib'?on the parser} would be required to register undat- cbapter. IT ORDERED That- this shall be. tendered efia notice: made as soon as pracwabic, bums: kite: I fodia?a day after the date- the Parent of the Child beg?ms. to reskle the person or on the tenthday after the date the scam-s?, as IT IS that the notice must .?ICiude a (If-the 9561st that is. the basis- of'the, person's requiramcm ta register as a sex o??ender?ap nf?tha offense with whisk the "Dempn ?3 chargad. WARNIN G: A PARENT- OFFENSE As A MISDEMEANQR IF- THE T0 Ems-4 or: 16 Nor nlx'wxn?lf" 3-CLI- Wear?m ?1.13 IT IS ORJDERED that, during: 3113i: periods of possession MIN-SSY and duties: 4. NAME ROMAO, as sole managing- canservators, shaii- Each have the. ?a?awing ma duty ofcare, comm}, .pmtec?nn, and reasonable. of'thc cm; the duty to support the Child, Excluding providing, the shaming, ?gcd, shaker, and mdi?al and dental care not prosedure; the right to Consent for the Child. to- mutinc medicai and dental care not an havasivej-smgerygand- the right to direct. the mm}. raligious: Child. IT IS gamma that, his periods af'posseassiom A-K-PAN EBQNG as possessory conservamn the f0?oW?1g=rightg and: Miss: 1. 2. 4. the duty. ofcare, contralpmtectbn, and reasonable ?fthe a the -duty to suppozt the chm, minding previdmg Chi-1d with clothing, food, shaker, and medical and dental Gare. not imrohring an invasi?rc preceding; the :to' cons-en: fair the-Chm {a 3:233 dental care- not involving an invasive surgery; and: 2 the right to d-h?cct the mm} and? religious .ofthe Child. IS that HENNSS-Y and ROMAO, as gals managi?g conservator-s, shall have the ll. 2. the tight-to designate the Wresidente-ofthesCh?d; the right to cohs?nt to m?d?za-L dcntaL and magical treatmsn: involvmg ?wasive precedmes; to consent treatment ofthe Child;- the _to mpre'sent "the Ch?d iegal' action and to make other decisions of concemi?g the -- 1'5 P332501: 16' I .. i I. the right to- consent" to wage? and to enlistment in ?le amd fewes- of Unit'cd Smw? the right to {rake decisions Ch??d?s educatibn; except as provided by sactian. of.th Texas Code, light: t9 the semes 621mm; ?fths- Child; except when" a guardian Ofthc Gh?d-?s? estate a _-guardian 91' attorney ad {item has been appeintcd :er am am, right to ac-?gt- as an agent Of'the (Shim in 3213:310an the Child's estate "Child-3s. action "required by a state, the United States, or a :f?areign. gavemrmm; and .9. the to apply fer and maintain possessiono?fthe Child?s passport Possession and Access. Provisions IT IS OWE-RED that. the shall-reside and remix} in-?m gprirmry custody and care of While the is. War the age of eighng and not otherwise: .IS FURTHER ORDERED that AKPAN BASSEY shall haw: po'ssassi?m of'aCCess to the at all times mutually agreed-- upon between "the Child, .BASSEY, and and NATHALIE Chad Supfort Pm visions IT AGREED AND ORDERED that based upon the circumstances of the. Parties and Child, no child ?upportj $11311 be paid by\or ti) any Hank-h" Insurance Provisims 1? 1-3- ORDERED that AWTAL and ROM-AG shall provide: md?c'al' Suppert and care insmamc coverage for the as set out herein below until Such tima the reaches the age" of eightieen years or graduatas ?om school, whichever occurs later. AGREED FINAL i mum maus- 5. mm. w; . mas-?rm 16' . . I Da?ni?om ?Health Emma" mans immune covemg?ai that? p?ro?dcs basic "fm3'2tIfI-carc services, inc-Whig usual physician services, ?o?ica -visi?s,- hospitalime and laboratany, X~my,_ emrgemy services, that be previded .throtigh a with mintcme organ'im?on Gr Other private or pub?c organiz??cn. ?Reasonable and mcessary he'a?carc 639811395: not paid. by immance and by or on behalf" ofa Child" include, without limitation, 531300;:an ?br- of?ce- or prescription drugs", the yearly .deduct?n'ze, if any, and medicah surgmg prescription: drug, mental heakbcam- servings, dental,- care,.ophthahnological, and o?hodmitic-?hargcs. ?anish" imam - a. to hand de?vcri the document by a- person eighteen yeazs of age or Older ei?mr t0 re?ipiem- or to a person who eighteen years of age or elder and permuth msides b. to d?livvsr: the document to the recipient by certi?ed return; receipt requested, to tht: recipients East-known orircsiden?e or c. to deliver the cinema:- to the recipient at the recipient?s. last known mailing a: res-Mensa- using any "per-san- or- en'tity Whose principal. business is that of a comic; or deliverer. pf papem or either er 'outsidc the United- States. ?Wzritt'en .fmtice" means written summation togethe: with swpor?ng docmntatian sent by or maria: by "one party it); other party through the" Us. Servica, United Posml Service, Federal Express at same. .Not??e aha-Elbe- pr'esmd to have been received by party meeiving natice Emailed. to the paws East know address by ?rst-chm or certi?ed maime mceigt requ?st'ed 'the'Ugs, i?ostal Service er delivery by. Postal- Service, Federal 0: Omar com-fiat scwise. with proof of'de?wry. PAGE: 7 OF 16 N'camm 5-. HIRE-EL AVENUE Hm '3 2.. "Findings cit-Health Emma Availability- Com; ?nds: Health insmme "is in e?bc?t'and .tmimained for the by and NAME. tiuough the baa-ma insmancc. policy provided thmugh engabyer. IS FOUND that the health?care coverage are in the best interest of the Child. 3. Provision ochaIih?Care Coverage-- HEN-NELSY and are ?to continua to {mixuain hcait?- insmance ?at the who is the subject at? suit that cams basic beam?carer services, mam-mg usua: physician services, "cm visits, Xa?ay, and antigens}! and 8-173. to maintain Such heaith h} ibrc? ga?d e??ect on Child Ixva is :t?hfe subjactm'f this sui? until such time. the Child reaChes the age inf-eighteen year's? 'orgaduatcs- from high 3511001. whichever mom's later. Pm?suant. to section- 154.183(cj of the- Texas Family'code, the. masonablc. and magma), health-care expenses of the Child that are not covered :or reimbursed hearth Minuet: are allocated as foilows: and to 1333? Ona-Hmdred pcr?cent' [100%] 017312 mimbm'sed .health-cam-axpensas ofthc These :provisiom appiy to all" hcahh~care expenses {If the Child mirsuch Child machesthe age of'eighteen years 'or graduates. ?fom school, WMCh-wer occurs iater. 4-. Sc'condary-Coverage - IT IS AGREED AND that mthing in this Under prGh?aits EBONG BASSEY from providing hea?h immune caverage {85L. 1c 2 .M 1:6 amenawa . 2x way-.4 WNW 94w? ?mmr? In the Event EBON-G chats to previdej secondary heakth 'imurance co-Varage, ROMAO shall eqaperate. ?llty with regard to- the handling and of ?it: ?smmc' {providing the coverage in? '-order if) the bene?ts available. to the Child and to 6mm that magean who pays for health-care expenses for is reimbursed this. payment mm mm whims. to? the $111331: cement 5. Comp?ance with Insurance- 'Co'rrgzany Requimmts A?Pa?im arc' ORDERED to ?confb'rm to a?nrequircmc?nts- mesed; by. terms and c'onditiOm- "cf the 6f health insurance-- (:9ch --the Child-I in order to. assufe the rmxirmzm remjm-?semm 0r payment by insurance company of the incch health?care expense, mending but not Wed 19' requiremts for. advance notice to any Carr-Ear?, Seconci- opir?ans, and the like. 6. Claims Except as proxiidedi in paragraph 111% ?n is not-canyingtiw heai?th. insurance covering the Chad is. ORDERS-ED- t?o' to the Party-carrying palicy, ??een days of recemg them, any and ail farms,- mce'iptsj, bills, and statements re?ecting {the heaith?carc expenses 3th; Fare-at not the policy incurs behaif ofthe In. ac-co rd-a-nce with section {204.251 "and IS Party wha is not camng the hcakh- mumme palicy severing the Child, at that Pays. aption, may Elf: (any c'iaitm ?at- hea?he care? cxp'emes direc?y the .mwame carrier from whom coverage is prov?cd for the bene?t of Child directiy 'ti?fom. 'immanbe company. The Party who iscaxr-yhg the health insurance policy Covering the Child to submit all ?fonm required by the company for payment or reimbm?sement- "of health?care expenses mowed by 'ci?icr Patty an behalf of the Child to the immune carrier ?fteen days 'ofthat Partj?s receiving any .fbrm, mot:in bilL or expenses. .116 META-RY PUB - etc! 5-. SIR-REL Av-2531H2u5-{4- MN Gm?mm?xmta?m ?h?h 51"? Hm 7. Consguctive. Trust ?at Emaide - that any insurance received by a Party ?bm. the "health carriar as reimbursath for heath-care expenses immed by a: on b?haff- of the: shalt bekmg- to {fatty wht) paki those? axpehses IT IS FURTHER that the E?arty- reachi?lgi?w Emma paymems is designated a to receive any Ghee-ks. or payments far baa-meme expanses paid- by I the .omcr Party, and. the the- pOl'my Shall endorse and forward the checks or payments, along any explanation of bmaf?s received, to the. (gt-heft" Party three" days Of recemg 8. - A GREEREB T0 PROVE) HEALTH WHO FAILS TO 13023.0 IS MAME ch- NECESSARYMEEIQAL r02? xmaom REGARD TO EXEENSES Wt)an Ham BEEN mm BEE-N mew-1mm ma) ma PREMIUM-829R AN-gy, PAID ON BEHALF OF CHILD. . Media! Nazy?zcarian Each Party is to the other Parties as 59011 as pegs?ale but. more than TwentyrEour [24] hours of any medical condition of?xe Child requi?ng surgical 'mtenren??n, hQSpita-Iizatiora, or both. Information Regarding Egriies The. mfcm?gn required for-each Party by sec?orjx. 195-306(3) of the Tcxz?s Code is as --foilows: . PMS 10-01?- Ki? Rom-m amt}: . Sonia! S'ecmity-Tmmber: Driver's Enema mzmber: Current residence address: 'Mai?ngaddress: Telephone mayhem .N'ame ofemp layer: Address ofempioymant; Work telephom: unmber: Name: Social Security mnber: Driver's; amber: Gwen: residmce addmm Mailing address: Tehphonc Name. of empleyer: ?ddress. of employrmm?. .Work telephanc number-z Name: Sociai Secmity- nmribcr: Driver?s license .nm'r'aber: Current residence address: Ma?ing address: Telephom- nmnhex: Name: Address Work tekphonet number: Required Nag-ices HENNS S-Y m382 327 W. No. 2104,- San Antenio, Texas 78209 '32? N0. 2 i204, San Antonio-, Texas 78209 210?508-6472 St. WnyCa?m?a Scheol 3200- McCulkjugh; San manic, Texas-7821.2 210508-6472 ROMAO mama-1:62 3'2? Sunset Road, No. 2.104, 53311 Antonio, Texas 78209 a 327 W. Simsct Road, N3. 231.04., SanAntOrxio, Texas 782091 NM NIA NM. .AKPAN HAS-SE NM NM No. I .Adcsheke Sh?eet, O'womso-ki O-??Ekore-Bus Stop, Lag'os- Nigeria No. I Admire-2kg: Street, Owomsn?ki' 03E- Ekoreilsm. Stop, Lagos 0896231 1643', 08057-675739 NZA EACH-PARTY IS. ORDERED-T0 NOTIFY EACH om PARTIES MD CHANGE IN THE CURRENT ADDRESS, - '11 ?36 wcg+qh?h jljy PUBLIC. .-. ?inns-q aim: 3.1.: ml . (7 i ADDRESS, AND TEIEPHONE THE GIVE NOTICE. AN INTENDED CHANGE ANY OF EACH 0mm PARTY AND COURT ON OR 33mm, THE 60TH DAY BEFORE INTENDED 1F mg mam NOT COULDNOTHAVEKNOWN THE CHANGE IN- SUFFICIENT "mm TO PROVIDE 60-DAY PARTY '13 ORDERED TO GIVE NOTICE OF CHANGE ON FIFTH DAY Dam-mm PARTY KNOWS OF BY A OBEYTHE ORDER QF- COURT To PRO-WEEACH 0mg: PARTY COURT INFORMATION- MAY FURTHER TO @190ch ORDER, CONTEMPT OF COURT. A FINDMG 01: CONTEMPT mm? BE PUNISHED BY co IN FOR UP TO SIX MONTHS, A FINE-I UP To $5.06 FOR EACH v10 LATION, AND A MONEY FOR MWT FEES AND COURT COSTS. Notice shall be given to each other E?arty by de?ver?xg a- cepy of the. notice to the Party by r'egTSIered or remn- receipt- rchest?cd? Notice shall be: given to the Court bydc??vermg copy of. the mticc either in parser: to the clerk of this Court or by registered or certi?ed? ma?E addressed to Clerk at .1 0-1? West vaa- 2 1-6, San Antonio, Texas. 782 NOTICE TO ANY PEACE OFFICE-R OF STATE OF YOU MAY USE REASONABLE EFFQ-RTS TO ENFORCE-THE TERMS OF SPECIFIED IN THIS ORDER, A PEACE OFFICER WHO 0N A COURT ORDER AND OFFICERS. name? ENTITLED TO THE APPLICABLE mm FINAL ORDER IN mamrmr-Cmnm . rma 12- (3F .16 . Buzz: - 0. 'am?wmr-l?xwh 2?le ANY CLAIM, CIVIL OR GOOD FAITHIACTS- OF THE IN OF ORDER 125mm ?to ANY REE-SON We mac-mam PRESENTS FOR AN 0mm IS .mvm. OR Nd LONGER EFFECT COMMITS AN: OFFENSE BE BY FQ-R AS LONG AND. A Of? as $10,000. Warnings?? Parties mas IQ ALL PARTIES: OBEY ACGURT. 0239233 MAY EN FURTHER LITIGATION PO RUE CONTEMPT OF CO A FINDING MAY BE BY IN FOR UP TO SIX MONTH-S, A FINE- OF UP TO $500 FOR EACH VIOLATION, AND A. MON-BY WMENT OF ATTORNEYS FEES AND Representatians' and. Warranties of Parties evidenced by their respective; signatutes 'belbw, each may and Warrants that; they each ha'Ve car'e??hl. read each and every page of??s Ages? Final 09%: in Suit Affecting "the Parent??hiki Rahtionship- in. its? enth?er? that they Bash 1311:" Signing this Agee?d Fina!- Order in Suit Affecting ?le Parenb?h?d Rehtionship after receiving the advise of independent- .cmmsei, that the}? each have given careful and theught to kgali a'?iec; of this. Agi?e?ed Fina-l Order in: Suit A??eC?ng- Parent-?Chad Relaticmhip, that they each- completely understand each. pro?sbn (if this Agreed Fina} Order in Suit A??c?hg the Relationship cancer-Ding" bath thu- ?subj'?ct matter the .?egal e??ct, and that they each fur-that f" 3? PUB-L115 am~. runnCl aurm?? i has 3? ack?dwledge Agreed. Firm! Order in Suit? A?'?cting Rah-50355;) not procured by fraud, duress; or and they each. agiee Agreed Fina! Order in Suit I the Pare-?t-Cl?ki .ReIat-iomhip. is in the best .intems?t of Child: Cast-s IT IS AGREED AND that 3.1108528 ofcourt, ifam in 62186 are to be. paid'by AURIANTAL and NAME ReiiefNor Granted. IT IS ORDERED that a?re?efrequested in case and. not egresst gmnted is denied. Date ofOrder SIGNED on. FRIDGE has 14. 0g? 16 LIB. PUB APPROVED AND CONSENTED AS To BOTH Foam- .- WNS-SY AURWTALV was acknomcdged befpre at . . . . AURMNT Natmfy- ubiic, ?33351-139 I. ?us. 5g??Netc?-v-Pub?jc-, same or {gases . 3 Naiow'm- 1254005a-a - mif?me?t was 8_0knDW16dg?d before me at I on . 5-7" Ab? -- . . .?ggiufm_ I. I 1 -puma.State-.of-Iews- . 410.0 5' a? Comm apnea . ?h I Ragnar-{"tmm? EBONG . was? before me BUG M. - I by 55mm BASS-BY FINAL ?13: -. mam-sax: 16 mg? 5.. main-m sag-a --La-n=n-zz {3'13 Ml,- aim i. 1:14?; I. AS TO EGRM ONLY: FULLER, 15.0. 1717 Suite 1500 Da' .-, Texas-75202 EGRTER State; Bar No. 234032962 Wkoom?i?enmm: Anomey?fer HEN-NSSY and NATHAHE RDMAQ, Patitioners pom- EXHIBIT I. A'kpan Ebeng Maria: :fkmaria ref; Thai: 1 never consented to: {ha giant of guard-ims?ig; acmss and suppm-i Sm: {Char-m Ramsay Amgmaj; and Nathalig Remain! U.) a Thai ?War ent'?md- him 3'15}; ?gf?emem Wham! verbal ?er- the guaxdianship, conservatmship of; access ?16 Q?f his. 3031 and: dates not "hope we ?511.16? i?nm my $111611a-gmarnmamiiy-lzzter da?tai' with Benn-gs? art-d Nathalaia R0 max-L - That on Janna 2m wag toe-med. ink: 33 ing- a .dacumm m. axedAmi-21ml. and- 'Na?miie Rama, and is didmt- madam-and; the; said d?eujI-ngnt, I I . $11.81?" 301%: guardiiazgz;-gf Sw?m to: at the I This 119?? ?ay-of'miay, 23-17; :3 . 2' a" . age-1' jam-4% be-if?bfta? 1th. Eg??mi ma _G?fag?dfa?a Qhariiag. Ramsey- amni- ef Magma- . 0 Lane, Bambi-n E?tate, Laggs; Nigmiay remake mm au?horig-a?wn dazed gm! 230-1 '33 earlier gig-med: me Hg?msg of I .66 Effect. Dated {fay w? 29:The fragei?g Kwea?i?. mi??icfimm me thi?-s-= 53m?- d?ay Eff "29157 EXHIBIT 22?? May, 2e17,. Cour-t. Regi?tmra Cnu?g. C1232. . . .. :3 1.09 {3910;0331, 2?13 10m, San A-n-thenioi ?28-.12-051, A . Dear LETTER. 01mm: 301m? . hereby authguri-ge Mali-Saran mix! it} take war-?1318 prose tim- United S'mtgesof? Amefi? 53(1me 1'9 act in. my Swad- -lj(:3 {CI-hams. Basgey in 3mm- fm yum-'- amt-5 Ye faithfully, ?3133 abi -- FILED. _5f'26/2Q'17 1:54:16 PM Donna Kay McKinney 'Bexar County DistrictiClerK ACc-epted By: Debra Garey Cause Number: 2017-0143941?) District Court . I . .- 2 SACZ Donna Kay Bexar County District Clerk Request for Process Request the following process: (Please check all that Apply) Ii] Citation" Notice Temporary Restraini?ngOrder D'Notice of Application for Protective Order D'Tempo. ra ry Protective Order CI Precept with hearing D'Precept without a hearing.le rit of Attachment DWrit of Habeas Corpus Writ of Garnis?h'ment SequestratiOn DCapias Other:- 0 Name: AURIANTAL Register-ed Agent/By Serv-in-U: Ad dress 327 #2104, SAN ANTONIO. TEXAS 78209 Service Type: (Check One) EPriva'te Process DShertff' DPublic'arion (Checkihia) DCammerciaI Recorder Deer Certi?ed Mail El Registered ail Out of-Comzi?y DSecretij ofState ?1 Commissioner of Insurance 2 I Nam-e: ROMAO. Registered Agent/By Serving: regs 327 SUNSET ROAD. #2104i SAN ANTONIO, TEXAS 78209 I Sen?ice Ty {Check One) Private Process CISheriff D'Publicarion One) Elmer Beer DCGIir?ionse Deer DCerrified Mai! El Registered "Mail. County DSQCI?Efafji'Ofo?te' DConimissianer ofInsumnce 3. a If} e. Registered Agent/By Sierv'ing': Address Service Type: (Check one) [IE-Private Process DSIzeri?" EIPublication (Check One} EICommercial Recorder Elma-t DCertyied ail Registered Mail [:I'O'et of Coumjz. EISecretary efState leommission er Na me: Registered Agent/By Serving: Address I Service Type: {CheckO'nej DPrimte Protess EISher-ijf DPubiication (Check One) DCemnercie! Record?r- DCern?ed Mail Registered Mail DOM of'County' DSecremry 'ofSta're- EICOMMissibner aflnsumnce Title-0f Doc-ume-n-tKPleading to bee-Attached. to Process:- ORIGINAL PETITION FORBILL Name of Attorney-[Pro Se: IVAN Bar Number: 00785835 Address; 115 CAMARON ST. Phone Numb-er: 210-227.2333 SAN ANTONIO TX 73205 Atfto'rn ey 'fOr Plaintiff Defen' d-ant Other SER VICE IS NO I PICKED UP WITHIN (114-13 USINESS SER VICE WILL BE DES-TR 0 FED M: FILED 5f24i?20'i 9:19:07" AM Denna Kay McKinney BeXar' County District. Cierk Accepted By: Marc Garcia BPOENA DT PPS SACZ DONNA KYMEKINNEY REQUEST FOR ONL Cause No. Style: Com-t 131 ST I EN THE INTEREST OF CHILD vs. Please check what applies: USproena . Subpoena DT DWithT'ender APPEAR: Date: June 2017. Time: 9:00 AM. Cour-t Room 1.31 ST .. *Requested to bring the following items or tangible things: Witness: CUStOdia Of any and all lransc?ripts. attendance records and the Department of Homeland'Security Address: 3200 McCullough Ave. Certificate of Eligibility for Citnytatej Zip: San Antonio, TX 7-8212 Student Status Form pertaining to ,1 Sheriff Private Process Charles Akemini Bassey; DOB. *R?equested to bring the following items or tangible things: Witness:- Add-ress': -City,- State, Zip: 12% Sheriff El Private Process to bring? the following items of tangible things-z Witness: Address: City?, State, Zip: El Sheriff Private Process- Name of Attorneyle se?: Wan Friedman Bar No.: 00785886 Address: 115. Cameron. St. . Phone 2104274383 San Antonio. TX 78205 Attorney'fo'r Plaintiff Defendant Other FILED. 5130/2017 12:31:09 PM Denna Kay McKinney BeX-ar County District Clerk Accepted By: Bianca Salinas- DONNA KAY MEKINNEY DISTRICT CLERK supdt pps/sac 2 REQUEST FOR ONLY Cause 2017?Cl-094?13 Style: Court 13318T IN THE OF 0.3., MINOR CHILD V's. Please check what applies: .El'Subpoena (Subpoena DT DWith Tender T0 APPEAR: Date: June Court'R-Oiom *R'eques?ted to bring the f-?e?llewing items or tangible things: Witness; Alejandro caldem?: Direcmr Of'Enrollmem any and all transcripts;attendance records and the Address:- 3200 McCullough-Ave. I I-20 Certificate of Eligibility for Nonimmigrant City! State! Zip: San Antonio, TX 78212 Student Status Form pertaining to mm. Sheri-ff 5 Private Process Charles Akemini Bassey; DOB. 10/28/2000 *Requested to bring the follo'Wing items or-tang'ible thingsr Witness: Address: City, State, Zip: ?tng El Sheriff El Private Process *R'equest'ed to [bring the following items or tangible things: Witness: Address: City, State, Zip: *lg? gg; Sheriff El Private Process- Name of Attorney/Pro se: Ivan Friedman Bar No.: 00785886 Address; 115'Camaron St. phone No': 210-227-2333 San Antonio, TX 7-8205" Attorney for Plaintiff IX Defendant Other FILE-D Donna Kay McKinney Bexar County District Clerk . Acceplted By; Lisa Morales N9. 1'3 IN INTEREST OF IN THE BISTRICT-CG URT . BEXAR CGUNT-Y, TEX-AS MOT-tow TO THE OF THIS COURT: COME-S NOW-3 Akpan Ebong ,rth'e . PBt'itiOI?l?l? . in the Above styted and numbered Cause and ?ie-S't'his motian to set this? cause for Motion for Bill of Review on the 2nd day of June. 20- 17 at 9-00 _o?cl?ock?fP.M.. ORDER The-above styi'ed and numbered cause, havinghee'n presented to me, is hereby set f0? Motion fO'r'BiH of Review on-the 211d day of June 20- 17 3f in the Civii- Presiding Courtroom of the Ben-r County, Texas. Signed this clay of 52320.1. 7' 20 Narma Gamal?s Pa?asiding Judge . . 13,19" ?igt?ct .. JUDGE Bax-a; Cgu-?tm Tie-x35. CERTIFICATE OF This is to certify that a true and correct copy of-the a have: and foregoing" MotionZOrder'tQ Set was deiivered in accordance with. the. Texas Rules of Civii Procedure, en the 23rd day of- May[Wt/m ?fede state Bar Na. 0.0785886. . Address Sh, San_Ant0n_ip_.- Phone 210?227-2888 FILED 5f26f23017 1:54:18 PM Donna Kay McKinney No. 3i .. . IN THE INTEREST OF THE DISTRICT co um 96-. C.B-., msma MINOR CHILD . mummxems MOTIGN To SET TO HONORABLE 1U DGE OF THIS COURT: COM-ES Akpan Ebong Basscy ythe i. . . . .. in-th?e Above Styled and numbered as use and ?les this Motion to Set this-cause for. Motion for Bill of Review on the . _..19th . "day of . June- 2.0 '17 at 0.00 O?clockz?PM. ORDER The. abave styled "and numbered-tame, havingfbeen presented to me, isihereby set for Motion. for Bill. of Review on-the 1'9th da of . J1me . .. .. .9:00 o?cloCkPM. in the Civil-?Presiding Courtroom 0f the Bexar County; Texas. Sigan this day 01? 05/ 26/ 2.017 20- Narma? Sam-alias: Presiding Judge '13'1?3udicial 'B'ngritt . OF SERVICE This is to. certify that'a true and correct of the a-bcve and faregomg Mbtionfor'd'er to Set was deiive're?d in 'accordance'with the Texas- Rules of Civii Procedure, on the . 26th day of .. May . .. . 2'0, .17 . A/xm wan/tan S?tate-Ba-I?No. 00785886 Address 115 Camaron San Antonio, Phone 231 0?227?28838. PRIVATE PROCESS SUBPOENA.U a; - ?qt DUCES TECUM a_ . . I f. ZOIYQAC . N0. 2.0-17-CEEHOE 3- Q3533 CHARLES BASSEY . VS- JUDICIAL. DISTRICT. 25? JUN u: 35 COUNTY, TEXAS STATE OF TO ANY CONSTABLE OF THE STATE OF TEXAS OR PERSON AUTHORIZED To SERVE. AND EXECUTE SUBPOENAS: YOU ARE HEREBY COHEANDED To sunn?om IF TO BE FOUND IN TOUR BE AND APPEAR ON DDT OE _J?n9- A.D., 201? I AT 9w00 BEFORE OUR HONORABLE DISTRICT COURT, OF THE PRESIDING JUDICIAL DISTRICT, ROOM ,192; IN AND FOR THE COUNTY OF BREAD, AT THE COURTHOUSE IN THE CITE DE SAN ANTONIO, THEN, AND THERE TO GIVE EVIDENCE IN THE STYLED-UND CASE THEREIN ON BEHALF OF THE AND THERE DAY TO AND TERM TO TERM THEREOF UNTIL DISCHARGED PROCESS OF LAN. SAID ABOVE NAMED HITNESS IS FURTHER COUUAHDED-TO PRODUCE AT SAID TIME DUO PLACE EOLLOHINO BOOKSJ PAPEEs. DOCUUENTS OR.OTUER TANGIDLE THINGS, TOFWIT: AND ALL TRANSCRIPTE.ATTEUDAUCE RECORDS AND THE DEPARTMENT OP EODELAUD SECURITT 1-20 CERTIFICATE OE ELIGIBILITY FOR NOMIUDIRENT STUDENT STATUS FORM PERTAININO To CHARLES HEREIN PAIL NOT, BUT MAKE DUE RETURNE, FAILURE ET ADEQUATE EXCUSE To OBEY A SUBPDEUD SERVED UPON THAT PERSON HAY BE DEEUED A 05 THE COURT FRON THICE THE SUBPOENA Is-IssuED OR A COURT IN THE COUNTY IN UHTCE THE SUBPOENA IS END-MAY BE PUNISHED DE 0R BOTH. DONNA.KAY CLERK OF THE DISTRICT COURTS OP TEXAS, THIS DAY.0F May .2017 Ivan FRIEDMAN DONNA KAY MCKINNEY DISTRICT CLERK OE BEXAR 00., TEXAS GONZALEZ ATTORNEY EOE .115 CAMARON ST SAN ANTONIO, 7/ I RETURN . .. 3rr . ma. 5 7 . CANE TO HAND .M-. AND THE 1 DE DELIVERING T014 bum-54:: Cc than. .IN- PERSON, A TRUE COPY OF THIS SUBPOENA UPON WHICH I ENDORSED THE DATE- OF 0F FAILURE EXECUTE SUBPOENA. IS a" TOTAL FEES: j??k Badge/PPS. 114% 142$ch COUNTY, TEX-AS BY- rut-3.27% (A CATIDN BY PEACE OFFICER) VERIFICATION OF (-IF NOT SHORE TO THIS. OF . .- '_NOI_arv Public. State O'f?fcwa l' I I I n33 puma sma 0F Em 1-2 361? .6331 ED . . ?1 533?? ill? FILED en 61201.7 3:29 PM Donna Kay" McKinney Bexar Cou nty District Clerk A'oce'pt'e'd By: AlbertoChaVez NO. IN OF IN THE DISTRICT COURT ?s CAB. DISTRICT A CHILD B-EXAR COUNTY, TEXAS MOTION TO .QUASH. AND FOR PROTECTIVE ORDER TO: THE HONORABLE U-D GE SAID NOW COME AURANTIAL, (?Moxianti? herein), and request the Court; to quash "er-subpoena. duces teeum and issue a protective. order in connection therewith, and. WOuld Show the following: I. On or? about June- 1, 2.01.7, ALEJANDRO was served with a Subpoena Duoes TeCum (attached herein and incorporated by reference as Exhibit. and referred to in this: Motion as the ?Subpoena?, by Ivan Friedman, purported counsel for Petitioner AKPAN EBONG BASSEY. The deadline Set "forth in the. Subpoena to produce the? documents and other tangible things is June l9, 20-17. Request for Production No. 1 contained in the Subpoena requests that Movant produce the following documents or other tangible thing-s: any and all transcriptspertaining C.A.B. Movant objects to said Request as follower The discovery request is overly broad, lacks de?nition Or is not reasonably limited in scope or time. This request. does not limit the date range nor scope of the documents requ'eSted. b. The disco-Very request is improper. "or not within the mom of discovery. This request is improper because the requested documents do not relate. to the? Bill of Review ti led by Petitioner. Coarse No 7-Cl?094i3: CB. To AND Foe ORDER Page 1 of. 6 c. The discovery request. is unreasonably frivolous: oppressive, or harassing. This request is ?rivo-lous' because the requested. dedumentsdo not relate to the Bill of Review ?led by Petitioner. The discovery request is an invasion of persdnal, Constitutional, or property rights. This. request Seeks documents that inVade the personal, constitutional, or property rightsofthe child CAB. e. The discovery request asks for information that is not relevant. and is not reasonably calculated to lead to the discovery of admissible- evi-d'ence. Documents responsive to this. reqjuest'are not relevant for the Bill of Review and would not lead to the discovery of admissible evidence". I'll. Request. for Production No. 2 contained in the Subpoena requests. that Mo-van't produce the fellowing documents Or other tangible things": any" and all attendance. reCords pertaining to CAB, Mov-ant objects to. said Request as follows; a. The. discovery request is. overly broad, lacks de?nition, or is not reasonably limited in scepe 'or time. This request does net limit the date. range 21101" scope. of the. documents requested. b. The disco-very request is improper or not within the scope of discovery. This request is improper because the requested documents do not relate to. the Bill of Review filed by Petition-er; c. The discovery-request is unreasonably frivolous, opprieSsive, .or' harassing. This request is frivolous because the requested documents do not relate to the Bill of Review filed by Petitioner. d. The discovery request is an invasion of personal, constitutional, or property rights. "This request-seeks documents that invade the personal, or property rights of?the child CAB. The discovery reqUestasks for information that is not relevant and is not reasonably calculated to lead to the discovery of admissible evidence. Documents responsive to. this request are not. relevant. for the Bill of Review and would not lead to the discovery of'admissible evidence. IV. Request For ProductiQn No. 3 contained in. the Subpoena requests that Mova-nt produce- Cause No. 2017-6? 13; 17.70 C. B. T-O AND FOR PROTECTIVEORDER Page-'2 of 6 the following documents or other tangible things: the Department of Homeland Security 1-20 Certi?cate of Eligibility for Non-Immigrant Student Status Form pertaining to- CAB. Movant objects "to said Request as fellows: a. The disoox'xery "request is overly bread, lacks de?nition, or is not reasonably limited in scope or time. This. request does not?limi't the date range nor scope- of the documents requested. b. The di?Scovet-y request is improper or not within "the scope --of'diseovery. This request is improper because- the requested document's donot relate to the Bill of Review ?led by Petitioner. e. The discovery request is unreasonably frivolous, oppressive, or harassing, This request" is frivolous because the requested documents do. not relate to the Bill. of Review ?led by Petitioner. d. The discovery request is an inva-siOn of personal, constitutional, :or property rights. his "request seek-s. documents that invade the. persmial, constitutional, or property rights of the child e. The discovery request asks for information that is? not relevant and is not reasonably calculated to lead. to the discovery of admissible evidence. Documents to thisrequest are; not relevant fer the Bill of Review and would not- lead to. the discovery of'admi'ss-ible evidence. V.- A trial court has broad digeretion to protect a3 party with a. protective Order. "Miovant asks- 't-he Court to exercise its 'diSCretion and grant a protective order because it is necessary to protect Movants undue burden, unnecessary expense, harassment, annoyance, 'or- invasion of personal, constitutionai,. or property rights, Vi}. .In the interest ofjustice, Movants request'that a protective'or?der be entered as fellows: a. The requested discovery not-be sought in whole or in part; b. In the alternative, if the relief requested in the paragraph above is not granted in wh-Ole, M-ova-nts request the extent and subject matter of discovery be limited. Cause No. 1970 (1.8. MOTION TO AND FOR ORDER Page 3 of 6 lf'the requested discovery is granted in parts. Movan?t requests. Petitioner limit the time and of the requests in a manner set forth by'tihe Court. e. Thedi?sc?ove?ry be undertaken only by such method or upon such terms and conditions Or at the time and place directed by the court. Any documents this Court order-s be produced. should be reviewed. ?rst by- the Court in and ?in camera? review to deter-mine the relevance, if any", of the" reqUe'sted documents and whether the. documents should be turned over- to. Petitioner. d. The results of disco-very be sealed or otherwise protected, s-ubjeetto the provisions ot?Rule 76a. PRAYER WHEREFORE, PREMISES CONSIDERED, Movants request that the C'Our-t quash the above-described subp.oena.-duees tecum, that a 'prOteetive order be. entered here-in as requested hereinabove, and for sue-h other and further 'relief'that may be awarded at law or in equity. N0. .20} [31:70 C. B. MOTION TO AND FOR PROTECTIVE ORDER Page. 4 of 6 Respectfully Submitted, THE. LAW OFFICE OF A. VANCE, RC. 407 8th St. San Antonio, Texas 78215 Tel..(251.0) 582-5887 Fax. (21-0) 582?5878 USA A. VANCE Texas Bar No. 20476500 Email: '1 i'saV'a-nce aw .eom A. JABBAR. FAHIM Tex-as Bar No. 24084183 Email: vane-elaweom Attorneys for Movant NOTICE OF- HEARING The above and foregoing Movant?s Motion to Quash and for Protective. Order is set- for hearing onJune 19,2017 at 9:00 am, in the Presiding Courtroom, Bexar County Courthouse, "100 Dolores-a, Sam AntOn-?io, Texas: 78205". 6/16/2017 Renee Yant'a Cause No, .20} 1770 C. MOTION TO QUASH AND FOR PROTECTIVE ORDER . . ?a . . A. IJ-ABB-AR FAHIM Page 5 of6 CERTIFICATE OF SERVICE I certify that on June. 16, 2017 a true and confect- "copy MotiOn to Quash and for a Protective Order was served to each person. listed below by the method indicated. A. will IVAN FRIEDMAN Attorney fer AKPAN. EBONG BASSEY Carnal-on St. San Antonio, Texas. 78205 TEL: (.210) 227-2888 FAX: (210)227?5151 Electronically through the Electronic Filing Manager SANCHEZ ESCAMILLA Attorney for ALEJANDRO CALDERON University of the Incarnate Word 4301 Broadway, CPO 302. San Antonio, Texas 7-8209 Electronically th?roUgh- the Electronic Filing Manager- Cause- No. 1770 CB. To QUAS AND FOR Page 6 of 6 FILED. 1:34? PM Donn-a Kay McKinney. Bexar County District Cierk Accepted Flores. IN THE INTEREST OF (3.3., MINOR CHILD CAUSE No. IN THE DISTRICT COURT JUDICIAL DISTRICT B-ZEXAR COUNTY, NOTICE OF NON SUIT Akpan Ebong Basscy, Petitio.ner,_ files this Notice of Nonsuit of his Original Petition for Bill "Of" Review. Akpan Ebong Basseyspetitionsthe Court to without prejudice, Law Of?ces of Ivan Friedman I 15 (lama-r011 St. San Antonio, TX 78205 Ivan Friedman Attorney for: AIkp-an Ebong B-asjsey "Texas; Bar No. 0078886 Phone: 21 0-22'7-288'8 Fax: 21 0-227?5 151 Email: .?c?om Certificate of Service I certify that a true and correct copy of the-above was serve-ci- on each attorney of reocrd- Orparty in accordance with the Texas Rules of Civil Procedure on u-ly 13, .2017. #2 [van Friedman Attorney forAkpan E-bong' Basso)! NOTICE: DATA. CAUSE -. IN THELINTEREST OF IN DISTRICT-2F COURT CB. MINOR CHILD .B EXAR AGREED FINAL ORDER IN SUIT THE RELATIONSHIP - Date of Hearing ?v .0n the; date- indicated bebw, the com signed this Agreed order? In Suit To Modify Relationship. .- Petitioners, AURLANTAL and NATHALIE ROMAO, did ddt'appdazgm but?have agreed to the "terms o_f"this- order as evidenced byLPetitioners? Signatures and the signatule efPetitioners" attorney below. Respondent, AKPAN EBONG Bass-Bit, waived Essuance _of service of citation by waiver. _duly- ?led and, after receiVing-proper notice did not otherivise appear, but has agreed. "to the term of Order-as- evidenced by ReSpondent'53 signature below. Jurisdidwn . The Court, a'?er record and the. evidence, ?nddl'tllat of case and of all the parties" and that no other ceilrt has continuing, exClusive-jm'isdiction of this case.- .1 .. All persOn' entitled 'to citation were ploperty Cited. Jury A jury-Was waiVed,- and all and law. were. submitted [tome Com. mankind}: IN 3 AFFECTING THE EMT-came RELATIONS 1le AVENUE. PAGE 1 OF 16. .YABA ISABD MM, .pi, TEL ?th?-r :3 Document 7 scanned as filed. ammey-ixNEsr?Im Iraq ?Wl?w?h- 943 ?mg Recard .LTh'e making 'ofa 'r-?ecord of: testimony Was waived by the pandas the consent of the Court. Child The Court the ?allow?ing Childis subject ofsuit: Name; Charles 'Bas'sey [who is in the style of the case] [and herea?er Itchiidlq. Sex: Male Birth date: October 28, 2000 County of residence: Bexar' County, Texas Findings" The Court Respondent. AKPAN BASSEY, is; the father of the. Child, and currently in [ages Nigeria, and. GRACE MFON is" mother of the Child, who is deceased. 'i?he Court We: ?hds that Respondent has vohmtrarily possession of the Child to Petitioners, HENNS-SY and ROMAO, for a period of more. than one year, andithe Child has. resided in Texas exclusively Petitioners duiing this period: Agreed Pawn ting-Plan The Couit ?nds-that the provisions in'these agreed orders relating-to the rights and duties of the parties with relation to the Child, possessibn of and access to the Child, child support, and optimizing the development of aelose and continuing reiatiOnShip- between each partyaand the Child constitutes the Partie5? agreed patenting plan.? Cartservatarship Provisions The" Com-t ?nds that the orders are inithe best interest of the Child, Charles Basso-y. AGREE) ORDER NOTARY PU 13-3ng 5, AVENUE . YABA SABU TEL nanmnw? amiss?tea ?h?h 933' IT IS ORDERED that AURIANTAL and N-ATHALIE Rome are appointed Sole Managing; Consenrators, and EBONG BASSEY is appointed _P05's'_esso_1fy ConservatOr of?le-follow?flg Child: Charles Bassey. IT IS ORDERED ?tat, AURIANTAL and as sole conservators shall have the following rights: 1. the ?ght toirecehre mm?on-fro?m any-other Consengators of the Child comet-ding the health, education,- and wellhre. of the Child; 2.. the to. confer "with-the "other Conservator's to the extent possible before a-decision consenting the health1 educatiOIl, and welfare of the Child"; the of access to medical, dental, and edheatlonal records of the Child; 14.. the right. to consult'wilh a phySician, dentist, or gist. of the Child; the to consult with school. o?icials concerning the Child?s welfare and educational status,- inehtding school activities; 6. the ?ght. to attend 'soheol and extracmimlla: activities; 7. the ?ght to be designated 0n the Child's rewrds- as a person to be noti?ed: in case of an emergency; 8.- the right to consent to medical, dental; and surgical teemte'nt duringfan emergency" woman-meme danger .to the health and safety ofthe Child; and I 9. the to manage. Child?s estatete. the eXtentthe estate?has been. Created by and NATHALIE ROMAO. IT IS ORDERED that", EBONG as po?ssessmy conservaton shall'have- the the ?ght "to receive ?lfonnation from any other Conservators of the concealing? the health, education, and White the right to confer with the other Comemtom to the extent possible before making decisionconeeming the-health, education, and wellhreof the Child"; ORDER IN SUIT Wn03.m_ H?d - MR . HA. N.R. A.E.B. I \7 0. Road DU - NOTARY s. AVENUE YA-BA SABO LABGS- TEL Dau32n90555 FAGES OF 16' hack-.1. ?ne-em new. the right of aCcess to mediCal, dental, and educational records of "the Child; ?ght ?3 ?ml? with atheism. dentist, 0mg cos: the right to consult With schoel' 'o?eials concerning the Child?s. Welfare and educational status, activities; the right-to attend schooland extracurricular activities; the right to be designated on. the Childls records as a person to be noti?ed in 03189. of an emergency; the right to consent to medical, dental, and surgical "treannent during an emergency invoking an immediate danger to the health and salewsofthe Child; and the right to "drama-ge- the. Child?s estate to eXtent. the estate has been created by AKPAN EBONG BASSEY. IT IS ORDERED that, at all and NAME as sole managing conservators, AKPAN EBONG BALE SEY, as- possesso'ry consemator, shall each have-the following duties: ORDER INan Asset-irritants the duty to: the other "Conservatories of the Child: In a manner of. signi?cant. information concerning the health, education?, and welfare of the. Child; . the duty to theother- Conservatoire of the. Child if the Parent resides with for at least (30) days, Harries, or intends. to marry a person who the Parent knows registel'ed as a Sex oifimder under chapter 62 of the Code of Criminal Procedure or is currently charged with an offense for which on convbtion the person would he requiredto register under that chapter; IT IS ORDERED that iilfonnation shall be tendered in the forth of ?uorine made as soon as methable, but not later than the. day-alter the date. the-"Parent of "the begins to reside with the person 'or ?on the-tenth day-alter the date the marriage occurs, as appropriate. IT IS ORDERED that the notice include a description of the offense that the basis of the person's requirement to register as .a'sex the offense which the. person. is charged. A PARENT COMMITS AN OFFENSE PUNISHABLE AS A CLASS .0 MISDEMEANOR IF THE PARENT FAILS TO PROVIDE THIS NOTICE, 'PARm-cmLD-mriomsmp - Rome-s NOTARY PUBLIC - was SABU Lass-s TEL masseuse-er 03-16. 3?Q-i ?hm ms ?mm A IT IS: ORDERED that, during "their periode of possession, AURIANTAL and NATHALIE ROMAO, as sole conservators, .shall' each have the fellow-mg lights and duties: the duty of care, control, protection, and. reasonable disc'iplhle of the Child; 2, the duty to eupport- the Child, including providing the Child food, shelter, and. medical and dental care not involving an invasive precedure; 3. the right to consent for the Child to-rout'ine medical "and dental care not invoking an invasive smgely; 4. the right to direct the mural and religious trainingoft?m Child. IT IS ORDERED that, during periods of. possession, AKPAN as possessory causewator, Shall each have the following ?ghts-and duties: 1. the duly of'care, controL' protection1 and reasonable discipline of the Child; 2. the duty to Support the Child, heading previdmg the Child with clothing, food, shelter, andmediCal and dental care not mvotving'an mvasiVe precedmfe; 3. the to toasenf foi- the- ?to rcutinie?nedical and dental care not ihvohr'ing an invasive .sqrgery; and; - 4.. the "right to direct the moral and religious ofthe Child. 11" IS that HENNSS-Y AURIANTAL and Romeo, as _sole conservators, shall have the-?) ?owing exclusive rights: the right to designate the primary'residerwe 0me Child; 2. the right to cameo: to medical, dental, and surgical teatment involving invasive procedures; "the right- to consent to and ftreatrhent of the Child; 4. the Fight to represent the in. legal action and to make other decisions of enhstantial legal sigm?cme Child; MK . PAGES OF 16 U. . NOTARY PUBLIC 5. BIRREL AVENUE YABA .3?th TEL canaacqnuca the right to consent? to and to enlistment in. the armed forces of United SEES 6. the-right to make decisions concerning the Child?s-edmation; 7. expept as previded by of the Texas-Familjil Code, the tethe- s'ervices and teaming ef?the Child; 8. except when a. guardian of.? the Child's estate or guardian Ctr-attorney ad [item has."- beenappo?inted for the Child-, the to act as an agent of'the Child in relation to the? Child?s estate if the Child?s action is required by a state, the United States, or a foreign government; and 9.. _the Light toapp'ly- fer-and'm-mtainpoesession of the Child?s paSSport'. A P03363330): and A-wess Provisions IT IS- AGREED. AND ORDERED that. the (3.th shall reside with, and. remain in the primary custody and care of and NATHALIE ROMAO While the Child is under the age of eighteen years and not otherW?ee emancipated. IT IS FURTHER AGREED ORDERED that AKPAN EBONG. shall have pessessien elf-and acCess- to the Child at all times agreed upon between the Child; BASSEY, and NATHAHE ROMAO, Child Sapient-1?. Pro visions IT IS AGREED that? based the circumstances of the Panic}: and no child guppen shall be: paid bye: to any Party. Health. Insurance Provisions 11? IS ORDERED. that AURIANTAL and. NATEALIE ROMAO shall. Provide medical Support andhea'lth care insurance- eoverage '_fer'tl1e Child as set out hex-eh. below until-such time the Child reaches the age of" eighteen years or graduates from high schooL whichevel: seems later. FINAL ORDER IN SUIT N. . EB hi5?: PAGE 6 OF 16 . RY lbw-ewe 5. AVENUE-Ls Limos TEL 03032090555- :1 . De?nitions .- "Health .InSLmanee" means insm'ance coverage that provides basic health+eare services, including usual physician services, o?ce hospitalization, and laboratory, 3 emergency services, that may be provided through a health maintcnanee organization or other private or'public organimj?Ort. ?Reasonab?leand'necessary healthacare expenses not paid by insurance and lectured by er on behalf of 3 Chi] include, without Inuitetion, anycopayments. for O?ice or prescriptioe rings, the yearly deductible, if and .medicaL. smgicaL prescription-drug; mental health?care. services, dental, care, and orthodontic. charges. "Furnish" means to hand deliVer. the document by a person eighteen years of age or older either to. the recipient or to -a person who. is eighteen years of age or. older and permanently resides with the re'cipierit; . to deliver. the document" to the recipient by certi?ed mail, return receipt requested, to. the recipient?s last. known or 'residerree' address; or to deliver the document to the recipient at "the recipient's last known mailing or residence address using. any peISOn or entity whose principal business is that of a cOurie?r or deliverer of papers or documents either or outside the United States. 'Written. notice" means written commn?cahbn together with Supporting doeumentatiOn sent by mail or coun?er by one patty to other party through the Postal Service, United; Postal Service, Federal Express or other courier service. Notice shall be presumed to hate 156611 "received by the party? receiving notice if it is mailed to the" party's last, known address by ?rst?class mail or certi?ed mail/rem reCeipt requested through the US. Postal Service or delivery by United Postal Service, Federal Eitpress .or other courier service with proof of delivery. Assist) FINAL ohms 11v amnowsmp - I if} A. B. PAGE 7 os 16 NOTARY PUBLIC a. AVENUE "ijBA sass; LAWS. TEL 88032090555 hm; 2. findings On Health Insurance Availability. The com-?nds: Health insurance is in effect and maintained tor the Child by ADRIANTAL and. NATHALIE- ROMAO though the heath insurance policy pmvided through 'erIIPIOyer. IT FOUND that the following orders regarding'health?care coverage are ?nite best ?lterest of the I 3, ProVision ofHealtitCa_re Coverage - AURIANTAL and .NATHALIE are ORDERED to continue to mintain health' insurance for the Child who is. the. subject of this suit that covers ba'sie' healthecare services, including usual physician services, .o'?ce visits, hospitalizatim, laboratory, X?ray, and emergency services.;. and ate ORDERED to- name such health insergmee in force athd e??ect on the Child ?who is the subjecttof this suit until such time the Child reaches the age of eighteen years or graduates from high sdheol. whichever oeeme later. Pm'suant to seetion of the Texas Family Code, the reasonable and necessaty. health-care expenses of the Child that are not covered or reimbursed hy health insmance are allocated as follows: AURIANTAL and are ORDERED to pay . One-Hmdred percent [100%Zl- of all tmreimbm?sed health-care expenses of the Child. These provisions apply to all imreimbmsed health?care exPenSes- of the. Child mitil?suehtime the Child reaches the age of eighteen years .or graduates from school, Whichever oCcucs later. "Secondatycovetage. IT Is AGREED AND ORDERED that nothing in this order prelubits EBONG. BASSEY item secondary-heal?l ihsuf-ane'e coverage for the AGREE) FINAL ORDER THE AMZ gr NOTARY s. B-IRREL MENU-E s-Aso LABUS TEL museum-sea. Measure '16 I In the event AKPAN EBONG BASSEY elects. to provide secondary health inserame cciveI-?age, and NATHALIE ROMAO shall cooperate fully regard to the and ?ling. of claims the insurance carrier" providing?. the coverage in order to bene?ts available to the Child to ensure-tint? the person who pays for health.? care emenses for the Child is reimbursed for. the payment from both carriers to the ?illest extent_possible.- 5. Compliance ??fth-Insurance Company Requirements .- All Parties are ORDERED to conform to'allreqtzirements imposed by the terms and conditions of the policy of health insurance. covering the: Child in order to" assure the reimbursement or direct. payment by the insurance company of the. metered. health?care expense, including but not limited to requirements foriadvancc notice. to. any carrier?, second opinions, and the like. Claims - Except as provided in paragtaph, the Party who is not-.canying the health insurance policy covering the Child is ORDERED to fumish to the Party carrying the policy, ?fteen days of receiving. them. any and all farms, receipts,- and Statements re?ecting the health-care eitpenses Parent not" the po'iiCy hic'urs- behalfof the In accordance With-section ?204.251 and 1504.055(a) ofthe Texas Insmanoe Code.le IS ORDERED that the.'Party who is not carrying insurance policy covering the Child, at that Party/s optien, may ?le I, any claims for-health-care expenses- directly the insurance cantor. with-and from whom coverage is provided for the bene?t of the Child and. receive 'pamhents directiy item the insurance -.comp_any. The "Party who Carrying the health insurance policy covering the Child. is ORDERED 'to. submit all fonns required? by: the. Tinsurame company-for payment or reimbursement of health?care. veirpenses incurred by either" Party on behalf of the Child. to the insurance carrier ?fteen days of that Partys any form, receipt, bill, or statement re?ecting. the eXpenses. mam) mtAL ORDER. INS Urr Anamoraap Worms HIP HffNOTARY 51,, SIR-REL AVENUE SAB-D mans 00032000555 on 16 constructive Trust for Received - IS ORDERED that. any [insmance- paymnis received by a Party the he'aith- insumnce carrier as reimbursement for health-care expenses incurred by or on behalf of "the Child shall belong to the Party who paid these expenses. IS FURTHER ORDERED that die'Party receiving the insurance payments is designated a cenSductive bustee "to receive any i?m?m?ncte checks (or payments for health-care. e:_cpenses paid by the other the Party policy-shallendorse and femard. the checks :or along withany explanation of bene?ts received, to the other Party three days of receiv?ag them. 3. WARNING A PARTY ORDERED To PROVIDE HEALTH. INSURANCE I WHO FAILS so LIABLE FOR. NECESSARY MEDICAL OF THE I CHILD, WITHOUT REGARD TO THE EXPENSES WOULD BEEN - PAID- IFHEALTHINSURANCE HAD BEE-N PROVIDED, AND FOR THE COST OF OR- CONTRIBUTIONS, IF PAID ON BEHALF- OF THE CHILD. . Medical Notification Each Party is: 'to the other Parties as. seen as possible but no more. 'TWenty-Four [24] hours of any medical" condition of?xe Child requiring surgical intervention, hospitalization, 01' both. Information Regarding Ferries The information required for 'ea'eh Party by section of the Texas Famin Code as follows: AGREE) FINAL ORDER INS UIT AWG RELATED .. A.-E-B, PAGE-10 on 16' . ROK. E-- - .. - 5, AVENUE Lg?ri I - I. x, ABA SABO LQBU EKim 03032090555 amateur-immerse;- 9'55 Nam: HENNS-SY SocialSecurity number: man?x8 64 Driver's ?c'ense number: W332. Current residence address: Mailingaddress: 327 W. Sunset Road,'No. 2104, San Antonio, Texas 78209 327 W. Sunset Road, No. 2104., San Antonio, Texas 78209. Telephone number: 210-508-6472 .N ame- ofemployen' St Anthony Catholic- [~th School Address- of employment: 3200 Meculloug'h', San Antonio, Texas 732-12. Work 't?lephone number: 210-608?6472 Name: NATHALIE ROMAO Social Security number: moan-x162- Drh/er?s \license-mxmber: WEE Cuzrent. residence address: 327 W. Sunset Road, No. 2104-, Antonio, Texas 73209 ?h?b aw Mailing address: W. Sunset Road, No. 2104,- San Antonio, Texas 73209 Teiephono number: 608-2 17?03 92. Nameofemployer: Address of employmeni: NIA gWor?k telephone. number: Name: EBONG BASSE Social Securin number: NIA Driver?s license number: NIA Omen: residence address: . No. '1 Adesheke OworOsoki 0E Ekore- Bus Stop, Lagos Nigeria Mailmg'address: Noni 1 Adesh'eke Street,- Oworosoki Off Ekore Bus $013.. Lagos Nigbria Telephone'number: 08062311643, 03057675789 Name of employer; Address of employment: NIA Work telephone number: Required. Notices ORDERED NOTIFY EACH OTHER PARTIES COURT OF CHANGE IN CURRENT MAILING FINAL SUIT. ING THE REL-A N. R. A. E. N-OT- RY PUBLIC 7?5. BIRREL "35mm ?sIELjauazpsass-s PAGE 1-1 0F 16 1-.V. ADDRESS, TELEPHONE NUMBER. THE PARTJES ARE ORDERED TO GIVE-NOTICE AN INTENDED- CHANGE IN OF THE REQUIRED INFORMATION TO EACH OTHER PARTY AND THE COURT ON OR BEFORE- DAY BEFORE THE INTENDED-CHANGE IF THE. PARTY DOES NOT KNOW OR-COULDNOTHAVEKNOWN OF TEE CHANGE IN SUFFICIENT TIME TO PROVJDE (SD-DAY NOTICE, PART-Y IS ORDERED TO GIVE THE CHANGE-ON: 0R BEFORE THEFIFTH DAY AFTER THE DATE TEE OF FAILURE BYA PARTY TO OBEY THE-ORDER OF THIS PROVIDE EACH THE THE REQUIRED INFORMATION MAY RESULT IN FURTHER LITIGATION TO ENFORCE THE INCLUDING .CONTEMPT OF COURT. A FINDING OF CONTEMPT MAY BE PUNISHED BY CONFINEMENT IN JAE. FOR .UP- TO SIX MONTHS, A FINE OF .UP TO $5 00 FOR EACH VIO A MONEY JUDGMENT .FORYPAYMENT OF ATTORNEYS FEES AND. Neti'ce shall be :giye? to each Other Party by delivering a "copy of the notice. to - the Party by registered or berti?ed mail, .retumrec-eipt reqUested. Nome-Shall be givenito the COurt by delivering a cepyof the. notice either in person to the clerk of Court or by: registered or certi?ed mail addressed to" the elem at 10.1 West Nueva-216, SanAntOnio, Texas NOTICE ANY PEACE OFFICER. OF THE STATE OF TEXAS: YOU MAY USE REASONABLE EFFORTS TO ENFORCETHETERMS OF CHILD CUSTODY SPECIFIED IN. THIS ORDER A PEACE OFFICER WHO RELIES ON TERMS A COURT ORDER AND THE AGENCY ENTITLED TO THE APPLICABLE AGREED ORDERIN SUIT REIA ?a . - a .. PAGE 1.2 OF 1.6 NOTARY PUBLIC 5. AVENUE-LI YABA s-Aae IAe-o-s TEL 08032093555. Wh?'?h?i mm. cam-xmm?mwarem nag-.4. AGAINST ANY CLAIM, CIVDL OR OTHERWISE, REGARDDNIG GOOD FAITH ACTS PERFORMED IN THE SCOPE OF THE DUTIES ENFORCING TERMS OF THE ORDER THAT TO CHILD CUSTODY. ANY PERSON WHO. FOR ENFORCEMENT AN ORDER. THAT IS OR NO LONGER EFFECT COMMITS AN OFFENSE THAT MAY BE PUNISI-IABLE BY CONFINEMENT LN JAIL LONG AS TWO YEARS AND A. FINE OF AS MUCH AS $10,000. Warnings to Parties INGS. ALL PARTIES: FAILURE TO OBEY A COURT ORDER MAY IN FURTHER LITIGATION TO ORDER, INCLUDING CONTEMPT OF COURT. A FINDING OF CONTEMPT MAY BE PUNISHED BY CONFINEMENT IN FOR I. UP SIX MONTHS, A FINE OF UP T023500 FOR- EACH. VIOLATION, AND A MONEY JUDGMENT. OF: ATTORNEYS FEES AND COURT cos-Ts. Representations ami- Wammtf?es ofParties As evidenced by their reSpecn'v'e signamre's bebw, each Pajty repres eets and warrants that they each have read each and every page. of this Agreed Final Order in Suit AffectEI'lg' the Parent?Ch?dReIatienship in its? entirety, ?ut- they each. are Agreed Final Order in Suit Affecting. the Parent- Ch?d Relatienship vehmtarily after reCeiving the advise of indepemient counsel, that they each have given careful and meagre mought to team and legal affect of this Agreed Final Order in? Suit A??ect?in?g- the Relationship, that they each and "completely understand each pro?Sion eff Agreed Final Order in Suit Affecting" the Parent-Ch?d ..Re1ationship concerning both the subject. matter and the legal e?eet', and that they each further ORDER IN SUIT REIATI I 1f'v; PAGE 13 OF 16 ?we NOTARY PUBLIC 5.- BIRREL. AVENUE {f?k?fAB-A SABU mess TEL (130320913555 crew-um m3 that this Agreed Final Order in Suit. A?ecting the Parent-Child Reiationship was not procured'by ?'aud, duress, or overre'aqhing, and they each agree that. Agreed Final Order in Suit" Affecting the Parerrt-Child Rela?tiotjiShip is in the best interest ofthe Child. Cost-s IT IS AGREED AND that all costs" ifany, infthis cas? are to be paid by AURIANTAL ROMAO. Relief Nat Granted IT IS ORDERED that allrelief requested in case andnot-expressly granted is denied. Date of Order . SIGNED on . ,2017. l3 JUDGE PRESIDING PAGE 14m~ 16 PUBLIC 5-. BIRREL AVENUE . SABG 0,0903 TEL 00032000555 . U. NOTARY CONSENTED AS 1.03.0111 FORM AN: 6 - TANCE: sY AWTALV Pe?tioner .P'M.dn This instrument was aclmowl?ed'gcd. before me at 24a AURMNTAL. Nullqu Wow rem-5. Notary??ubhc, State of Texas 3:53;: comm..'5xpires 08-16-2917 to 125140-3564 If! ?mm, Petitio was apknowleaged bcfc'nIERQMAO. . .. I _\iullarq,- U315 SAM-MAS *Q?E?fg?iwmow 1?me 51?73 we?: I 's'Comm. Expires Notary - ?Om, 13 125400564 AKPAN EBONG BASSEY Respondent .mug- . . - Was? adknowledged before BASSEY - - Nota-ry'Pub'lie AGREED FINAL ORDER IN SUIT. PARENFCI-HLD RELATIONS HIP PAGE IBM 16 N.--R. PUBLIC BIRRZEL AVENUE, YABA- LABDS TEL 05932099555 Lfo 95mg. .. APPROVED AS TO FORM ONLY: P.C-. 1717 McKitme'y-Avenue, Suite 1500' Da ,Texas;75202' -: 1.4-871v0196 State No. 24032962 Email: Attorney for AURIANTAL and ROMAO, Petitioners {gammy 5. BIRREL AVENUE 2 TEL [[8832098555' PAGE "1-6 on 16 grog; war-1h am. 21:, Araromi Stu, Off Molon ey Street, Onikant Lagos; - - Tet-08122330666,08099570907 'm?inmm? 08065357703, 03023141050 Email: generation Im I 44, I 20166122021 4789903 HonourableJudge Norma Gonzales l_ 1 131?1 Civil District Court, .. - . Bex?a?r County Courthouse, MAR 1- E. 2017. .100 Floor, . I gown; .Tht San Anthonio, TX 78205"; may}? 9" U.S.A. . Dear Sir, OBJECTION To THE- ORIGINAL PETITION IN SUIT AFFECTING THE PARENT-CHILD RELATIONSHIP - CHARLES B-ASSEY (WHO IS lN- STYLE THE CASE. . We are solicitors to Mr. .Akpim Ebong' Bassey (father to Charles B'assey) herein referred to? as ?Our Client?, and we. have, our said. Cl?ient?is' to Write with regards to the abhve Subject matter. i. ?xn. A Our Client is the biologiea'l father of Charles Baseey and hetnever at?any time, consented to the grant of gitar?d-ianship, tio andvsupport of his; son- (Charles B'asSEy) to the Auria?tita'l and-Natheiie- Romeo) .Our Client never entered into any agreement, whether widen or verbal for the grant of .guardianShip, conservatorship of,? "access To End Support of his son (Charles Bassey) and cities not hope to enter? into any such agreement at einyiater'date with. the Petitioner's herein. Our Client who is an illiterate and who is based 'in Nigeria was" 0115?? January, 2017.,- coerced into signing a document prepared. by the Petitioners, for whiCh he did. not. understand the implication 0f the content of the said document. Our Client was" made to signthe document which turned Out to be ?waiver of Service?" under the false representation, that same Was meant to get his son into college and nothing more, Our Client already,r executed a Power of Attorney infavodr of one Mr, Abimb?nla "John Fan'iran sometime: in the year 2015, giving him the sole-care and custody of Charles Bassey. Kindly ?nd attached a cOpy- of" the Power of Attorney which our Client executed in. favour of Mr, Abimhola 'ohn Faniran. It should also be noted that the address on the ?'Wai'x?rer of Service? is a false address and does not belong to our Client. Partners: Alolnbi Serlkl, Multan. 01:11:35! (Notary Public), Rodin] Sen-[Id DOCUMENT SCANNED AS FILED- We, hereby urge. your Lordship to? discountenance and jettison whatever applicationpendiing before the Honourable Court, which emanated from the Petitioners (Henn'ssy Auriant'al and Nathalie Romeo) in respect of Charles Bassey', as the Petitioners do not have our Client?s consent to. present such petition. Every correspondence in respect of'thi'e petition should be directed to. our-?rm at our above address. you for your anticipated't'eooperation. Yours faith-?lly, 1 .- FOR: CONNAISANCE LEGAL. PRACTITIONERS . -: . 2k? - ?ij?nw .- . I in "fxe". - . may . 9.1% .. d? His??- W?mtt Am Ml? ovtmeel. m. as. NOTARY PUBLIC a? .!--Conna-isanee La 1 gal Pratt} .i no .Armml I Tat: uses 535-? 79-3 DOCUMENT SCARNED AS- FILED ?h?lIii-qwertyu i0 1.3a Sd kl cv?lin'a; . 1191f=1r0 4 Irpa..3..1fgn1112i: 32:15:32[?10de 1? r? 3 A Imb- (D a h?ufu- Inn?i IV?v-u? raw-1 #1 yam?3 EH .. .3.) Hill 1.4{311.}31 . us . I ?In, 1? mi - 4:11; W: I. gl km}; ?u a; :11} if.) 17:1 3! up; a; 2.21.;3. DOCUMENT- SCANNED AS FI I) . 1' I POWER OF ATTORNEY ?73195 07 mom- is made the da 201.6 .. .. i State (hereinafter called the) ?Donor-9). THIS DEED WITNESSES as folloWst-K The "Donor hereby appoints MR. John A'bi'm'bol'a Faniran, of Akofa?. Sport Foundation to. be his, lawfal A?omey and to do and execute all or any of the. following acts- jin respect of my . son- name?d Charles- Akemini Bassey- (herein. referred to as ?the player?) resident in United "State of America and I, 'hereby?gra'nt him the following powers: a. littereby. grant "to .the att_orney1-in-fact all my- power?sxregardi'ng the care and custody of the above mentioned- play-er. b. The rights, power and authority- herein granted shall remain in full force from February 2016 until otherwise decided by both parties. . I c. The Attorney shall. be solely responsible to the exclusion of all others, forthe total - 1i management of the player. That every corresPondence relating. to the career or otherwise-of the above player shall be directed at the Attorney'herein, to the exclusion of every-other person. .- e. To sign. and execute any .contract or agreements in reapeet of the player until when otherwise. agreed by the player and the Attorney. To execute a-nddo all such lawful acts and things, though netherein speci?cally mentioned but which'i's' in the opinion of "the Attorney expedient, incidental or necessary to manage the player. . - DOCUMENT AS. FILED - I .. The undersigned hare-by undertake to ratify and. approve all the above Attorney shall lawfully do or cau?e to be: done, regarding management of-the' above player which though not expiessly- autho?sed. Donor has set his hand hereunto, the day and year ?rst above-Written. SIGNED, SEALED and DELIVERED by the within?named .. . (ii 2-. EDONQR: . . 2-0/5 the presence of: I - .. ,4 "Name: NH 9916 c5 . 3 .. 30::cupa1'ion: . ESignature-z Date NOTARY PUBLIC Conn'aijsance Legal 'Practiti on? 21. 'Ararumi' Sheen?-nikan. L.- m: 031m 5357- 703 magma: asz . 43' J?ml mm: Origin ID: LOSA . --speenwnv HOUSE 2: mmom OFF momma STREET, 0mm: LAGOS, NIGERIA SHIP TO: BILL SENDER JUDGE NORMA- GONZALES CIVIL DISTRICT COURT BEXER COUNTRY 100. 2ND FLOOR SAN ANTHONIO, TX 78205 us' Ship Date: 10mm 1? Achgiz?? KGMAN CAB: 106424829163Mw0350 F: 1 01 1 a. mason" LEGAL DOCUMENT- 05302: 053%; DESC-4: COUNTRY MFG: NG CARRIAGE VALUE mu CUSTOMS VALUE: 1.60 USD 170:5 17d 258465 DH: SIGN: LEGAL PRACTICNERS ENV r1: admin-elm, ?1;:le IN hm IIUW ?iml?w mnaxn'm um? mug-I drafhn . - up man nu I: hunt w?hwx??n Luanda-n1 ?ligk Wit-2.3m ?nnim'?im n3 ail q?vnm iglmu'tcu in- m1 ilui?iiu 'meul bait-nu In huh nhl? thunk-n In gnu' ?lip?u?'h galgn?tl tum. :I'mliilitma Hill!" :I'mh'mn idler painting th'?s Fab-5!: FEDEX AWE-COPY - PLACEBEHIND '1 {he p?ntcd page ?ne. 2-, mace ielm? in s?va-sg 'pou:h and af?x 5:13 your'shipmem. .9 103% m. 5046 33243947 INTL PRIORITY ?8265 XH SVZA [mun 4 'r MAR. 1 a 2317' Dom:- xM .. DOCUMENT SCANNED AS FILED W95 igs . megs: the day of February?; 2016 ya gt State (hereinafter called I THIS DEED WITNESSES as follows:- The Donor hereby appoints MR. John Abimbola Faniran, of Ako?fa Sport. Foundation to be his lawful. Attorney and" to do -.a11d eXeoute all or any of the following acts in respect of my son named Charles Akemini asse'y (herein referred to. as ?the player?) resident in United State- efAmeriee and hereby grant him the following powers:- Ihereby- grant. to the. attorneyain-?faot all my powers. regarding the care and. custody of the. 93 above mentioned player. 13. The rights, power and-authority herein granted shall. remain in full force from February? 2.016 Until o?ierwise decided. by both-patties; c. The Attorney shall: be solely res.p0nsible to the exclusion-of all others, for the total management of the player. d. That- :ev'ery eorrespondeneerrelatingto. the-career or otherwise of the above player: Shall be directed. atthe- Attorney'herein, to the exclusion of every other-person. e. To Sign and eXecute any Contract or agreements in respect of the player until when otherwise agreed by the player and the Attomey. f. To exeCute and do all such lawful acts and. things, though not herein speci?cally mentioned but Which is. in the opinion of'the' Attorney expedient,- incidentai--or'necessa1y to manage the player. The-'undersigned hereby undertake to ratify and approve all TIMT the above Attorney shall lawfully-do or cause to "be (10116, regarding management of the above" player'.whi'ch thoughnot. expressly aumorised. IN WITNESS the has set hand hereunto, the. day and year ?rst alums?Written. SIGNED, SEALED and the withinanamed DONOR: 111' this pregame-of: 1 Ave Name: Date 13(76. OLMOBI, 3% PUBLIC -- ?-onneiisame Leger Practi-tiannrq Arar'emi ?re at, an i k-a n, Vet: BSD-8 58.5? 703 f. 21, Araromi Str. SPEEBWAY HBUSE O?'Molonay'Stre'st. Oalkan, Lagos. Tai: 03065857703. 03099570907 Email: can?sancapoyathMm Honourable Judge Norma Gonzales .13. 15" Civil District] Court, Bexar. County Courthouse, 1'00 Dolor-053, 2nd San Anthoni?o, TX. 78205, U.S.A.. GWDS 31231201.? 9:32:39 "Donna Kay McKinney .Bexar County District Clerk: ReceptEd Stephanie Holman NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSE. No. 20160122021 IN THE INTEREST OF IN THE DISTRICT COURT MINOR CHILD- TEXAS MOTION- TO SEAL COURT RECORDS This Motion to Seal Court Records is brought by Movant': Who show-in support: 1-. This is-an .actionorigina?y arising out o'f?th'e Texas Family Code, and the documents- ?led in this. case:_aronot subject to tho'standards of sealing court records set'forth'in Rule 763. of the Texas: Rules of-Civil Procedure. 2; The sealing ofthe-records'h'I this actioniwill not have an adverse effect on: the. public health or safety; and the records do'no't 'involVe matters that should beava-ilable toil-1e general public. HENNS SY AURIANTAL requests that the records in caSe be sealed. SY AURIANTAL-requests-that the Court-grant. ?-Ie Motion to Seal COurt Records. Respectfully submitted, RC. 1717 McKinney Avehue, Suite 1500 Dallas, Texas 75202 Tel: (214') 8-71-2727 Fax:- 14) 871-0196 \3 VM Liz'Pofte'r State Bar No. 24032962 f?z??koms?dler. com Attorney for Petitioner MOTION TO SEAL COURT RECORDS PAGE 1 OF SERVICE. I certi?; that a true copy of the above was sewed on each attorney of record or party in accordance with the Texas Rules o'fCivilPro edure on March I ,2017. PORTER. Attorney for Petitiioner- MOTION TO. SEAL COURT RECORDS PAGE 2 FILED 9:32:39 AM Donna Kay McKinney 'Bexa?r'County District Cierk Accepted By: Stephanie Holman NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSEINO. 201.6(3122021 IN THE INTEREST OF IN DISTRICT COURT CLB. Hist JUDICIAL DISTRICT CHILI) ORDER ON MOTION ITO. SEAL COURT RECORDS On the date indicated 13:31-0me Court signed this. Order .OnMutionITo. Seal Court Records. IT IS ORDERED that-all decuments bearing-Cause No. 201 styled Interest Of 6.13., Minor Child? ape hcz?eby ORDERED sealed, andihe with such documents shall not be aper?led or released except to the parties or their attorneys record 13111653135; approP?ate {1301111 ordelz SIGNED on March 7.. JUDGE PRESIDWG ORDER ON-MOTION T0 SEALQCOURT SOLO. PAGE .?rfl'ne I1: w; Ew- news. FILED 1711901? 2:15:18 PM Donna Kay McKinney Bexar County District Clerk Accepted By: Larry Botailo Jr. CAU SE 1N T11 1-: INTEREST 01? IN THE COURT. . . (3.11. 1-3-15: JUDICIAL 1115':ch CHILD EEK-AR COUNT-Y, TEXAS AKPAN EBONG BASSEY appcamfd Err-person bail-?01131110 today and stated under-oath: AKPAN ONGIBA-SSBY, am the person named as R?'spo?n'dent in this case._ Ih?at I haw: bean provided a copy Petition in (In: Parent-Child Rela?mishfp; along with Sranding- On'z?er Regarding Property and Camhmi uf?ffge Pattie; in Divorce and Suits the ?led in this cas?; I 1mm: read the contents cfthis document. Undef?iand that the Texas Rules of Civil Procpdum require, most instances, that a patty car mpondent he. Served i?vilh citation. do wan-t? to be pcmona?y served- ?wizh citation, and I waive. the issumgcc serv'ica of.? citation. [enter my appeal-zines: in 111is (1356 for all purposcs. "z wantto be. noti?ed. (if-any hearing- or trial of [his case?- Understand that'- i. have a duty to notify aha for 'PetiLioncrs if '1 1211;11gc- my address, I understand ihat,_un1css notify the attorney {Ur- {if any such change in w-?iing! any notices 1 might be entitled to mccivc With-regard [a (lisposi'tion-cfithis wil?; be forwarded mime at the address; indicated below 1' state than lhc- following information-iscancer arm: 21131. my- Pagcl 052 WAIVER OF ERVJ Making-address is: Telephone ?ninbpr is: 3?1 .If Security number is: . lfany, Driver's licm'se-numhcr and Ewing state- are: further understand that 1 have a duty to notify the Court if my mailing address changes during {his I BASSEY SIGNED under oath before me on I 1- If NotaryPublic- OF SERVICE Page": of 2 12(28f2016 1:48:41 PM Donna'Kay McKinney Bexar Cou nty District-Clerk Accepted 83;: Laura Rodriguez NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA. CAUSE N02016CI22021 IN THE INTEREST OF IN THE DISTRICT COURT I C.B. . 1.31.8t DISTRICT . MINOR CHILD BEXAR COUNTY, TEXAS ORIGINAL. PETITION IN SUIT AFFECTING THE PARENT-CHILD RELATION-SHIP Discovenp Level Discova in is intended 21:0- hie-conducted under level 2 of rule. 190' of the Texas Rules: Of Civil Proced?ra 2. Parties This suit is jointly brought by and NATIMLIE ROM-A0, Petitioners. The last three numbers. .01? Petitioners? driver?s license numbers are 382' and 1.36., respectively. The last three number-s of .Petitit?i'ners? Social Security numbers are 864 and 162, respectively. Respondent- is AKPAN who is the biological father of the Child Who is the subject of this-suit. Respondent Currently resides atNo. 1 Ade?sheke Street, Oworosoki OffEkore?. BUS Stop, Lagos Nigeria. Petitioners'have standing-t0 bring this suit because they-have- had actual care, Control, and possession of the Child fer atleast six months ending not more t11a1190 days preceding the date-of the ?ling Of-thi's petition. Jurisdiction N0 court has. centimngjurisdiction of this suit or the-Child ithe subject of this Suit. ORIGINAL PETITION. IN SUIT AFFECTING THE LD RELATIONSHIP PAGE I 013.3 Taxman; new? 4-. Child The following Child; is the j-Subj'eet of this. suit: Name:.- 'C-haxles Bassey [who is in the style of the ease]; Sex: Male Birth date: County of residence: Bexar County, Texas- 5; Persons Entitled few-"Citation- AKPANEBONG BAS SE-Y, isthe father of the Child. GRACE MFON is the mother ofthe Chit-d, who is deceased. No service isnecess'ary at this time. There are no court-ordered conservatorships, court-ordered guardianshin or other court. ordered relationships affecting the Child the subject-of thiS'Suit. Heah?h Insurance Information Information required'by section 154.1 of the Texas Family- Code will Child 33' Preparty No property ot?consequenee is owned-or possessed by the Child the-subject. of this suit.- 8; C?onsermtorslup Petitioners believes that Petitioners and Respondent will enter into at ?mitten agreement containing provisions for eonservatorship of, possession of, ace'essfto, and support of the Child. Petitioners-requests the Court approve theagreement and; enter orders for conservatorship, support and possession "of the Child the subject of this" suit consistent With the agreement. 9. .Bexar Conn-1.3: Standing Order A copy. of the Standing-Order Regarding Prop'etty' and Conduet of Parties in Divorce and nits Affecting the Parent?Child Relationship is attached hereto as- ExhibitA. and made. ORIGINAL PETITION IN SUIT AFFECTING- TH PA RE LD RELATIONSHIP PAGE: 2 OF 3- a part-hereof as if recited: herein Verbatim. I 0. Prayer Petitioners pray that the Court enter its orders in accordance with. the allegations. contained in. this petition. and agreements reached by the parties. Petitioners prays for general relief. Respjeet?tlly submitted, KoonsFuller, RC. 1731. 73 McKinney Avenue, Suite 1 5 00 Dallas, 75.2 02 Tel: (214;) 871.2727 Fax: (214) 8771-01-96 LIZ PORTER State Bar- 'No. 24032962 Email: Iiz?k0011sft111.er.eem.. Attorney for Petitioners ORIGINAL. PETITION SUIT AFFECTING PARENT-CHILD RELATIONSHIP PAGE 3 OF ash-:1- -. m: 251?. maze": 3. {-5511 .3- NO. . IN COURT .. . JUDICIAL DISTRICT BEXAR COUNTY, TEXAS STANDING ORDER REGARDING PROPERTY- AND CONDUCT 0F warms IN DIVORGEAND- SUITS THE mum-can RELATIONSHIP 1.. No party has requested-Ma order. order-is a. standing order of the Beicar-Caunty Civil Di'strict?ourts that applies in wary diVorce Suit and every suit affecting the parent?child ra?lationship ?led in Bexar County. ?1111:: Civil District Courts of. Ecxar County'havo? adopted this order because the parties and?wir child(ten) should be pretacted and. their__pr0perty preserved. while the lawsuit is pending before the Court; - 11. NO DISRUPTION OF (m {13$ a Both parties. are ORDERED to re?ai? from doing ?ie-fol?lom?ng acts comeri??g any. chiid(ren) who are subjects of?fhis 03.32:: 2.1 Removing the the Stateof Texas, acting dimme or in can'cert- with others, Without the-mitten agreement of bothparties or an ordsr of this Cogr't. 2.2 Disrup?ngsor withdfawing the child(ran) ?'om the school or d?yucare facing;- Wham the Ef?fen) are pm?cn?y smelled, Without. $116 writtcn- agregment of both mis?g?gn .0 rder" of this .23 Hi??g-og secretth the ch?d(ren) ?omthe' other ?gmiar..uhang1ng the current residence, Without the written agreementruf both Em?ior an. order Court. i tqn'r-I- as 24' Disturbing the peace ofthe. chiid?reh). 2,5 'Makiqg disparaging rmnarksabout each other or the other-person?s to include but 11'0th limited :to the grandparents, aunts, 3316168, or 2.6 Discussing with 1:116 child (ran), 0% otharparson in the prescnca ofihe any. litigation related to the ol?ld?en) or the. oth??r'party. 2.7 Consuming any illegal Controlled Substan?c (as that term is de?ned in the Texas Con?o'?e'd Substance Act), 12 hours prior to and duringpossession of the cthd(ren). 2.3 If this is an criglnal divorce action, a-llcv'ving anyone with whom the is romantically involved, to remain over: night in the home while Overnight "is from '1 0:00 pm. that awning Until CRUD am. the next morning. Both parlics, their agents,- servants, and/or 611113103663; to refrain from doing the following acts; . 3.1 latentiona-lly communicatin'gin person 01? in manner, including by telephone. or. voice h'ansmi'ssicn, video chat, in writing, or electronic m'cssagingwith either party by use of valgar, profane, or language, or a scams or offensivc warmers 'tc - with the: other pally. 3.2 other party in person at in. any; manner, including by telephone, or in another electronic voice transmission, Video chat, in Writing 01' electronic messaging: unlawful acticn against any person, by this action to annoy 61'- .alar-m'thc other party; 3.3 Placing a telephone call, anonymously, atscn. umcascnablc- hourfin orircpetiticus manner,xw1'thcut a legitimate purpose of. ccmmunicaticn with the to annoy or alarm "the other party. 1 3.4- Intentionally, 'lmcwingly,. or; causing. bodily icjuzy to the paw-or. to a child of either party! 35 T?z'catcning the arta child ofeither party With. imminent-bodily injury. 3.6" Opening 01' or email or" any other electronic communicaticn addressed to the 6tth IV. - I S- URNGDIVORCE If this :is a case, both panics. to the marriage, their andfor employees, are ORDERED to refrain ?omdoing the. following: Destroying, Icrhoving; concealing, or otherwisc or ?rcduc?ing the value: ofthe of the parties or either party. 4.2 or refusing to disclose. to' the Othpr party or Court, on proper- rcqucs't, the: existencc, amount, orlccaticn cf any-tangible or intellectual cf the jjartics or either party, including electronically-stored or recorded 4.3 .Damagmg or destroying the tangiblcor intellectual property of the parties or either party, hicluding stored or recorded lnfon?naticn. 2: .. - 4.4 ?I'ampering with the tangible oriotellectoal prepei'ty offthe parties or either party,- including electronically stored er recorded information, and causitig pecuniary loss or echelontial inconvenience-to the other patty. 4.5- Selling, transferring, essigx?n'g'. mbligaging, encumbo?ng, in. any other manner alienating any of the property of the parties or either party, regardless of whether the property is personal pmperty, real preperty, or intellectual property "and whether separate or community, except as speci?cally authorized hy'this- order. 4.6 Incoming-any. 'indebte'dnessi other than legal expenses. incomection with this suit, except. as .- speoi?eally authorized by this order. {417' Making withdrawals from any checking or savings aocount'in any ?canciali institution for- any. purpose, except as speci?cally authorized by "this order. 4.8 Spending any money in either party?s possession or subjecf to. either_party?s control for any" pmjpose, exceptlas speci?cally authodzed by this order. I 11.9 Withdrawing or borrowing in any-manner any potpose ?om any iroth'ement, pro?t? sharing, pension, 'de'atly- or other einpl'oyee bene?t plan or- emplo'yee savings plan. of ?ow any individual retirement account of either party, except. as s'pe'cmeal'ly authorized by thisorder. 4.10 Signing or endorsing "the other party?s name on any negotiable? monument, check, 01' drs?, including a to}: refund,_insuranoe payment and dividend, or attempting" to negotiate any negotiable instrument-payable to the other party Without? the personal signature of. the other pal-w. 4.11 Taking any action to teammate or ilimit creditor charge cards-in the name cf'tlie other petty. 12 Entering, Operating, or eXetclSing. control over-the motor vehicle in the possession of {he otlier'party.' 4.13' Disooet?inuing or reducingthe for federal income taxes from either {Barty-?3 wages this suit is pending. 4.144 Terminating or-lu any manner a??eotirig the service ofwater, electricity, gas, telephone, cable television, Or other contractual services, including security, pest. control, landscaping, or yard maintenance at the residence of'e'ifher pater. er in any manner attempting to withdraw any deposits for service in connection'wi'th thoSe services. 4.15 Destroying, disposing of; or altering any e-ma?, text message, video message, or chat message or Other- electr-onic ("late or electronically store informationrelevant to the subject matter of the salt dissolution Ofm alriage, regardless o?whe'tl'xer the ?afonne?on issto'red on a. hard drive, is a removable storage device, In cloud storage, or in soother'elcetxonie storage medium. 4.16 _Modifying, merging, or altering the native format or metedsta of any electronic data. electronically stored hfonna?on relevant to the subject matter ofthe guilt for dissolution ofmarrisge, 3 .. .. .. Veilt??rerre?nwregaxdles's of Whether the informuion. is stored on a heed drive, in. a storage device, in cloud-storage, orin-eno?mez' eleoh'onie storage-medium. 4,17 Deleting any data 'or content ?om any social network pro?le useder created by either party or a child of the parties.- . 4.18 Using any _paSSerd.-or personal identi?cation umber-to gain access to the other party?s e~ mail-account, bank? account, social media account, orany other electronic 4,19. Excluding the other-pW-fmm the use and-enjoyment of-e Speci?cally identi?ed residence. of the other pa?zy. V. EERSONAL BUSWESS RECORDS IN DIVORCE CASE this- is_- a .?isroroe- case,- bot? parties to the marriage, their. agents, servanis, and/or employees,jare re?ra-in ?'om doing the following acts: 5*.1 Coocealing or destroying any. family property records, ?nancial records, business: records or enyree'ords' of income, debts, or other. obligations including e1 record's. 5,2. Falsifying any writing or record, including an electronicrecord, relating to the property of either party. A ?Records? include 89111511 or other digital or. electronic 'dete,_whether tlze?infomotion'is stored on it hard drive, in a removable. storage device, in. cloud storage, or: in another electronic Storage medium. SURANCE If this is a' diverse case, both parties to the marriage, {heir agents, servants, andfor employees, are ORDERED to re?'ein from doing the following acts: 6.1. Withdrawing or borrowing many-manner all or any port of the cash surrender. value of life insurenee policies on [the life of either pony or a chi-id of. the parties, except aespeci?eally authorized by this order, . . 62 Changing or in any matmer altering the bene?ciary designation on any ?fe insurance on the "life .ofci'ther' party-ore child of?the parties. - 6.3 Canceling, altering, failing to renew or: pey-promimns oe,.or in any manner affecting the level of sewerage that existed at fhe time the suit: Was filed of; any life, casualty, automobile, or he'aith insurancepoliey insuring the partioS" property or persons, holudi'ng a child ofth'e parties.- .Ii? this-is a divorce caste, both parties to the marriage are speci?cally autho?zed to doth-e following:- To engage in acts reasonable and necessary to "the conduct of'that party?s usual "business and occupation. . 7.2 To make GXponditures- and inonr'inclebtodhess for reasonable Bttomey?s fees and expenses in connectiOH With this suit. 73. To make? expendinu'es 'an'dlnour indebtedness for. reasonable'andneoessaty living expenses for-food, clothing; shelter, transportation and medical care. 7.4 TO-malcewi?idraWal from-"accomts in ?nancial institutions on}? Zforjho purposes authorized by this order. SERVICE APPLICAIEON OF ORDER 8.13? The Petitioner Shall attach a copy ofth?ls order to ?le?ori'glnalp'ctition and to each copy ofthe petition. At the time the petitiOn is. "?led, the Petitioner has failed to attach. a copy of this order to the .pe?tioh and any copy ofthe petition, the Clerk shall ensure that "a copy? ofthis order is attached to the petition and every copy of't'ho'pet'ition presented 3.2- order upon-the ?ling of the original petition and: shallremaln in force- and effect as temporary-restraining order. fer. fourteen days after. the-date of the ?ling ofthe original petition arid is renewed tel-subsequent periods of every fourteen days ?lereafter until a. temporary- ?ihjunetim is ordered. If n0-'party--contosts_ this. order by presenting -.evidence" at ehear?ing on or before. fom'teen days e?or the date" of the ?ling of the-original petition, this order- shall continuein full force and effect as a? temporary injunction until further order of the. entire order. will terminate and will no longer be effective once the court signs a. ?nal order. 3313611 OTHER ORDERS If any part of this order is- different from. any part. of a proactive order" that has already been entered or is later-entered, the protective order provisions, prowl]. Any pert of?this Order not changed by some later Order: remeiils in full force? also effect until the court-signs a ?nal] de.crce._ X. PARTIES ARE .COURAGBD TO WDIATE The parties are encouraged 'to' settle their diSpotes' amicably without court intewentiOn. The parties are to use? alternative dispute resolution methods, such ashmedia?on, to resolve- the oon?io'ts that may arise in this lawsuit, w. ., .. Mm, ON I WAWED Itis. ORDERED that the requiremsnt Ufa bond Waived. FAMILY STABILIZATION Passing of minor chi-Mach) are. required to attend a. family Stabilization pregmm (Helping Children Cope with Divorce) within 60 day; of the ?ling: of the Petition for Divot'ce or the Suit- Affactingihe 'Pare'rlt Child Relationship. Waixrers may be. granted Only by" order of the court; Proof of completion ofthe prugram must be provided to the court upon maa?ng so ORDERED ms 10 0F. ?zwwm . - - . . CA .1143 3-. 2-24PHANIWALSH JUDGE PETER COURT. . COURT -. . r_7- . .H .NI-A ARTEAGA 57%0?1? '00er CAME-BS . DGE MOHAEL-WRY 37m JUDGE Jeff: GABRI 131-31313 GT COUR i 40f? DISTRICT COURT JUDGE 43' 37m- DISTRICT COURT. gag-mg,