JENNIFER M.

JOYCE

CIRCUIT ATTORNEY
CIIY OF S[ LOUE

C}IILD SLPPORT L:\IT

CARr.-A.HA\ COL RTHOtiSE
lll4Market Street. Raom 755
St. Louis.

llO

631A1

(31 4) 622-4A21

FAx: (314) 622-3629

December 13.2016

Directar

John P Dockery, Jr.

Ms Sionya M Haley
Apt 205
3916 N Florissant Ave
St Louis MO 63107

Re
Dear

File No. F-190660-0

For the Support of Michael p,. Fuiiilove arrci tiireryciii

Ms

i-iale y

Haley

The Family Support Divis on Child Support Sect on has asxed us io obtarn a courl-ordered judgment for
paternity, chrld support, and medical rnsurance for MichaeLA Fuil love and Etheryah S Haley
Enclosed is the legal paperwork that must be filed with the court lt consists of an ENTRY OF APPEARANCE
for you to sign and date; a TESTIMONY form for you to fill out sign and date, an AFFIDAVIT lN SUPPORT OF
DEFAULT JUDGMENT for you to sign and date; and a PETITION UNDER THE UNIFORM PARENTAGE ACT
ior you to keep. Please check the spelling of all names, dates of birth, and social security numbers on these
papers lf there are any errors, please correct them on the TESTIMONY form. Please return the signed papers
to me in the enclosed envelope by December 18,2016.
lf you have any questions regarding these papers, you may call me at the number below. lf you do call please
have this letter and the legal paperwork with you at that time lf all the completed papers are not received by
December 18.2016 you will be in danger of being sanctioned by having your medicaid card withdrawn and your
TANF cash grant reduced ln addition we will proceed wlth legal action against you and Mr Fullilove

lf DNA testing s necessary we will notify you of the date time and location of the testtng
Please do not request the status of your case before March

Claire Wiison
Investigator
(314) 589-6439

F-190660-0 l'rlAcSS 51638271

13

2417

mAP
MISSOURI CIRCUIT COURT
TWENTY.SECOND JUDICIAL CIRCU IT
(sr. Louls clTY)

Missouri Family Support Division individually and as

the next friend of MichaelA. Fullilove, and of
Etheryah S. Haley,
Petitioners,

Cause Number

.S
:

- : :_ _ i --

Dr,,,isicn Number 14A

PETITION UNDER THE UNIFORM PARENTAGE ACT

Come now the Petitioners and for their cause of action state:
1. That the Missouri Children's Division has consented to serve and is bringing this action as the next
friend of MichaelA. Fullilove, born October 20,2009, and Etheryah S. Haley, born November 16,2013
2. That MichaelA. Fullilove may be found in Missouri.
3. That the Missouri Family Suppo( Division has standing to bring this action pursuant to Section
210.826 RSMo.
4. That Sionya M. Haley is the mother of said children.
5. That said minor children are in the custody of the Missouri Children's Division.
6. That the Missouri Children's Division is the legally appointed guardian for said minor children.
7. That said children reside in the City of St. Louis, Missouri.
8. That Michael A. Fullilove is the father of said children.
9. That to protect the interest of said children, it is necessary to have the relationship of parent and
child declared to exist between Michael A. Fullilove and said children.
10. That Michael A. Fullilove has the financial ability to pay a reasonable sum each month for the
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=-:='='\J'::== =- :.= :,:- 3:::ce'2C,2009 and Eiheryah S. Haley, born November 16,2013,
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Sicnya [4. Haley to be the mother of said children; ordering the Bureau of Vital Records to amend the
birth certificate of each such child naming Michael A. Fullilove as the father of each such child; ordering Michael
A. Fullilove to pay as and for the support of the minor children such sums as this Court may deem reasonable;
ordering that said support obligation shall be retroactive to the earlier of the date that Michael A. Fullilove was
first served with Petitioner's original petition or the date that MichaelA. Fullilove first entered his appearance in
this cause; ordering that the support for Michael A. Fullilove shall be retroactive for the five years next
preceeding the commencement of this action and shall be calculated pursuant to section 452.340.10 RSMo;
ordering that the support for Etheryah S. Haley shall be retroactive to November 16,2013, and shall be
calculated pursuant to section 452.340.10 RSMo; ordering MichaelA. Fullilove to provide for such children a
health benefit plan as described in Section 454.603 RSMo, ordering MichaelA. Fullilove to pay 50% of saidchildren's medical, dental, and hospitalization bills not covered by insurance; ordering Michael A. Fullilove to pay
all such sums to the Family Support Payment Center as Trustee for Petitioners as their interest may lie, ordering
Michael A. Fullilove to forthwith assign a part of his income to the Family Support Payment Center as Trustee
F-1

90660-0 MACSS: 51638271

12113116 1:25 PM

MISSOURI CIRCUIT COURT

TWENTY.SECOND J UDICIAL CI RCU IT
(sr. Louts ctTY)

f,l

ss:-'

iai'niry Support Division individually and as

A Fullilove, and of

the next friend of Michael

Etheryah S. Hatey,

Cause Number

VS,

It4lchael

FuI rcve and Sionya

=----

Haley

Division Number 14A

SUPPORT OF DEFAULT JUDGMENT

l, Sionya M. Haley, state as follows:

1'

That I am the mother of Michael A. Fullilove, born

october 20,2oog,and Etheryah s. Haley, born
November 16,2013.

2'
Fullilove

That between November 20,2008, and March 20,2oog,l

engaged in sexual intercourse with Michael A.
That between December 16,2012, and April 16,2013,
I engaged in sexual intercourse with Michaet A

Fullilove.

That to the best of my information and belief Michael

A. Fullilove is a civilian who is not now on active
duty in the military service of the United States.

l' Sionya M Haley, state that the foregoing statements are

true to the best of my knowtedge and belief

20-

F-1

90660-0 MACSS: 5163827

12113116 1:25 PM