!MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (2024)

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On August 24, 2018 a!MTN:MODIFY,REDUCE,ENFOR,CONTEwas filedinvolving a dispute betweenMosley , Terell D,andBedford , Lakeisha,for PARENT CHILD RELATIONSHIP (FAMILY LAW)in the District Court of Travis County.

!MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (1)

!MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (2)

  • !MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (3)
  • !MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (4)
  • !MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (5)
  • !MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (6)
 

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10/22/2018 8:00 AM Velva L. Price District Clerk Travis County Cause No. _D-1-FM-18-005235 D-1-FM-18-005235 Albert Tobeck e ic Pr IN THE INTEREST OF § IN THE DISTRICT COURT MINOR CHILDREN § L. § § a § __459th____JUDICIAL DISTRICT lv § Ve § § TRAVIS COUNTY, TEXAS k er Motion to Modify Temporary Orders Cl This Motion to Modify Temporary Orders is brought by Respondent Lakeisha Bedford ct tri 1. Petitioner was appointed Temporary Joint Managing Conservator of the children in Temporary is Orders dated September 26, 2018. Since before entry of the Temporary Orders, the following events D have occurred, which show that the previous order of the Court should be modified and Lakeisha . Co Bedford should be appointed Temporary Sole Managing Conservator: is  The Petitioner Terell D Mosley Sr. has a previous charge of Assault Causes Bodily Injury Family av Violence, Case# C-1-CR-08-501843 and he was convicted of the charge. The charge happened Tr with his oldest child's mother. The child's mother was scared to report him. Her parents saw her y op black eye so she couldn’t hide the incident and she made the report. My children and I have c experienced Domestic Family Violence from the Petitioner since 2012-2016. l ia fic  There was a CPS Case#43502466 in 2015 from the Petitioner trying to stop me from leaving the of house during one of his many fits of rage. Terell D Mosley Sr. leaped with his fist balled up to hit Un my 11 year old son. My son A’Reese Norwood was trying to stop the Petitioner from taking Legacy and Mon’Rell out their car seats. Terell D Mosley Sr. held Mon’Rell hostage and would e not let him go. ic Pr  I told the Petitioner we were moving July 2018 and he got upset and started banging his head against his steering wheel. He also started punching the steering wheel as well. My sister Tenice L. Bedford was in my car with the children as I was talking to Terell in his truck. He started talking a lv about how he can see how people do drugs now. That’s when I removed myself from the vehicle Ve before he got violent towards me. That’s when I knew I was making the best decision with k moving. Terell is not stable enough mentally to take care of my children. er Cl 2. The Temporary Orders for financial support, I Lakeisha Bedford requests that the support ct provided in the Temporary Orders be terminated for the following reasons: tri  is The Petitioner Terell D Mosley Sr. should be require to pay the Respondent Child Support. I D Lakeisha Bedford has always been the Sole Provider and Custodial Parent to Legacy and . Co Mon’Rell Mosley since their date of birth. The Petitioner chooses to sell drugs than be employed. I financially handle the children clothes, food, shelter, medical and dental since their is date of birth. I have claimed my children on my taxes every year except 2017. I allowed Terell to av Tr claim the children due to his unemployment. The reason I allowed him to claim the children was due to his financial support when he was employed. y op 3. The present orders relating to possession of and access to the children have become c unworkable and are no longer in the best interest of the children because: l ia fic  The Petitioner Terell D Mosley Sr. does not have a stable home. Terell smokes marijuana. The of Petitioner is often kicked out of his mother home due to his selling drugs and disrespect towards Un her. Terell D Mosley Sr. has not kept a stable job over the years 2010-2018. At his previous job with the City of Austin he was fired for an altercation with a co-worker. I have tried to help him e get another job numerous times. He states that he makes more money “Hustling” than on a job. ic Pr The Petitioner is a drug trafficker and will leave out of town often to do so. Terell will also ship drugs through Fedex. I know of 2 occasions when the packages were picked up by the Police. L. The Petitioner Terell D Mosley Sr. has multiple drug charges: a lv  Case# D-1-DC-09-202274 Ve  Case# C-1-CR-09-207635 k  Case# C-1-CR-11-2044678 er  Cl Case# 8392941  Case# C-1-CR-13-208197 ct tri  I the Respondent Lakeisha Bedford requests the following orders for possession of and access to is the children with Terell D Mosley Sr. be supervised visit. D  I request Sole Custody and designate the primary home of the children in Fulton County. The . Co children still sleep with me every night. I cook, bathe and do school homework on school nights is solely. Mon’Rell has nightmares off and on and wakes up in the middle of the night crying. The av children have never stayed with the Petitioner longer than a week. Tr  June 2018 when I went to Colorado and the Petitioner kept the children. He would leave them y at his mother’s home while he would stay overnight somewhere else. My children would op Facetime me because they wanted to go home. I had my sister Tenice Before pick them up for c me the next day. She called me and stated that my children smelled like “weed” and the l ia Petitioner car also had a strong smell of “weed”. I have asked the Petitioner to not have the fic children around drugs on numerous occasions. of Un I Lakeisha Bedford prays that the Court grant the Motion to Modify Temporary Orders. e ic Pr L. Lakeisha Bedford Lakeisha Bedford a lv Ve PRO- se Name k er Cl ct tri D is . Co is av Tr y op c l ia fic of Un e Certificate of Service ic Pr L. I Lakeisha Bedford hereby certify that a new true and correct copy of this document was mailed to a Petitioner Terell Mosley Sr. at 15107 MossyCup Ln Austin TX 78724, also to alternate address of 6512 lv Greensboro Dr 78723. Also to his Attorney of record on the same day this document is filed with District Ve Clerk of Travis County Court. k er Cl ct Lakeisha Bedford tri Lakeisha Bedford D is PRO- se Name . Co is av Tr y op c l ia fic of Un Cause No. _D-1-FM-18-005235 e ic Pr IN THE INTEREST OF § IN THE DISTRICT COURT MINOR CHILDREN § L. § § a § __459th____JUDICIAL DISTRICT lv § Ve § § TRAVIS COUNTY, TEXAS k er Cl TO THE JUDGE OF SAID HONORABLE COURT ct tri I Respondent Lakeisha Bedford the Mother of Legacy Mosley and Mon'Rell Mosley. I ask for your is Forgiveness for missing the court date 9/26/2018. I had no intensions on missing court and wanted to D plead my case. Unfortunately due to my safety, income and childcare I couldn’t make it. I can explain . Co why our safety is a major concern. is av The Petitioner Terell D Mosley Sr. has a previous charge of Assault Causes Bodily Injury Family Tr Violence, Case# C-1-CR-08-501843 and he was convicted of the charge. The charge happened with y his oldest child's mother. The child's mother was scared to report him as well and when her parents op saw her black eye, they made her report the incident or they would. My children and I has experienced c Domestic Family Violence from the Petitioner since 2012-2016. I was scared to report the Petitioner's l ia actions on many different events of his fits of rage from 2012-2015. He has a Criminal Mischief fic charge case# C-1-CR-05-699217. There was an incident at the hospital when I had Mon'Rell. Terell of got upset because the caseworkers in the hospital came in to get some information for paperwork. She Un was helping me with my Medicaid and Mon'Rell's birth certificate. He started yelling and asking why the information needed. He didn’t want to give it because he didn’t want to be put on child support. Terell didn’t sign Mon'Rell's birth certificate. The hospital caseworker had to step out the room e because of his aggression. Terell use to be a Coach for a little league football team called Austin ic Steelers. He got into a heated altercation with another coach in front of the children. TYFA took him Pr off the roster due to his consistent arguing in front of the children with coaches and referees. L. a lv Over the duration of our relationship he said he would change and would stop selling drugs if he gets a Ve job. I was disappointed due to for 2 years I took care of Legacy and Mon'Rell alone so he can get his k driving license cleaned and get his CDL. The Petitioner quit a job in 2013 or 2014 due to the hours er and because he made more money selling drugs than on the job. He complained about missing money Cl while at work. That put me back in the position to solely take care of my children alone again for the ct next few years. I have been working since before I had Legacy Mosley. I have kept a stable home and tri job for my children. I have received assistance from CCMS to make sure my children are in daycare or is aftercare while I work. I kept my children Medical and Dental up to date with Medicaid . D Co I started changing my lifestyle and Terell was not happy about the changes. I started going to church is more and getting my life aligned with God. There were things that happened before that I put a stop to. av I no longer wanted to deal with his street life of selling drugs or partying. I would speak up about his Tr temper and smoking marijuana. My views on life started to change and the welfare of my children y were not like his. I began thinking and working towards my career. op c In January 2015 the Petitioner went into a fit of rage due to me not agreeing to what he wanted. All 4 l ia of my children were in the home when it happened. The Petitioner started braking things in my home fic and then went to punching holes in my walls. The children were scared and crying. I ran out my home of with my children and got in my truck to leave. The Petitioner came out the house yelling "leave my Un kids Keisha" and opened the truck back door. He started trying to take Legacy and Mon'Rell out their car seats. My oldest son A'Reese Norwood who was 11 years old at the time, started grabbing them so e he couldn't take them. The Petitioner Terell D Mosley Sr. then leaped at A'Reese with his fist balled ic up to try and hit him. My son got scared and let Mon'Rell go, the Petitioner took Mo'Rell out the truck Pr and ran into the house. Terell went into the house and sat on the couch and wouldn't let Mon'Rell go. L. The Petitioner knew I will not leave anywhere without my kids. There was a CPS case due to this a lv incident case#43502466. October 2015 I had to take a Personal Leave Of Absence from my job due to Ve the Domestic Violence got so bad. I became very depressed and would have consistent panic attacks. I just wanted to be away from Terell and have a healthy lifestyle. He became very possessive and didn’t k er want any other man around me or talking to me. Cl ct November 2016 while I was going to Avenue Five Institute Beauty School at night. The routine would tri be to meet and pick up the kids from a gas station. I missed a few of his calls and when I called back is to change the pickup location he cursed me out. The Petitioner speed up and parked beside me. He D jumped out the car cursing me out and started putting the kids in my car. I tried to get away from him . Co and he chased me down in my car to get me. He blocked me in a parking spot and ran to my car and is opened my door. He started yelling and cursing about me sleeping with someone else. I got a way out av and drove off with my car door opened. The Petitioner was running with my car holding the door open Tr so it wouldn't close. I was picking up my other children from my ex-husband at the time as well. y Catrell D Clark Sr. and the other children witnessed the incident. I waited 6 months before telling the op Petitioner where I stayed due to his fits of rage he has. l c ia In 2017 there was an incident were a girl he has dating found out were I lived. The Petitioner knew she fic found out and did not tell me. She showed up to my house at 8am to bring his clothes because he of didn’t come to her house that night. She started throwing his things at my door step. I told her that it Un was no need for all that. Legacy and Mon’Rell were in the house at the time looking at the girl throw his stuff in my house. The girl wanted to fight because she thought I was with Terell. The Petitioner e and I was not together at all. The Petitioner was trying to get me back. I wouldn’t follow through with ic it because he wouldn’t stop selling drugs. The Petitioner had a job at the City during that time as well. Pr I had to call Terell to come get his stuff she left and told him what happened. He went to the girl house L. and started threatening her because she didn’t bring his drugs with his clothes. The Petitioner used the a lv girl as a place to stay due to his mother kicking him out and he had no place to stay. The girl that came Ve to my house is a State worker and told him I would report her if she comes back to my house. I moved further out Cedar Park due to the altercations Terell got into with other females when he went out k er downtown. Cl ct I have tried to give the Petitioner many opportunities to get his life together to provider for his children tri the right way. I would talk with him about getting his credit together so he can get a place of his own. is That’s part of the reason I never reported his actions. I didn’t want to hurt his background and make it D hard for him to get a job or his own place. I would encourage him to stay on his job so he can move up . Co in the company. I have spoken to the Petitioner about getting his own truck and owning his own is business. The Petitioner Terell D Mosley Sr. got a job with the City of Austin and got fired due to an av altercation with an employee. The Petitioner continued and continues to sell drugs, traffic drugs and Tr smoke marijuana. I have asked plenty of times not to have the children around it as well. There was a y time in 2014 and 2015 when he had packages of drugs shipped through Fedex. The packages were op found by a Police Officer. In 2012 he was pulled over and taken into custody. The Police confiscated c $3500 and he didn’t get it back. Terell wanted me to say it was my money from income tax so he l ia could get it back. He also has some previous Possession charges as well: fic • Case# D-1-DC-09-202274 of • Case# C-1-CR-09-207635 Un • Case# C-1-CR-11-2044678 • Case# 8392941 e • Case# C-1-CR-13-208197 ic Pr June 2018 I went to a few conferences for entrepreneurship and leadership in 2 different states. I asked L. Terell to keep Legacy and Mon'Rell while I was gone. My children continued to call me at night to a lv help them sleep. They both said Terell would leave them at night and go spend the night somewhere Ve else. My children sleep in the bed with me still so they are not use to sleeping alone. Legacy would k console Mon'Rell at night so he could sleep. I would stay on Facetime with them until they fell asleep. er I had my sister Tenice Bedford picked them up from the Petitioner and she called me while I was in Cl Colorado. She stated that Legacy and Mon'Rell smelled like marijuana and the Petitioner car also ct smelled like it as well. I asked the Petitioner to make sure he doesn’t have them around "weed" in a tri text message and he said ok. D is . I have tried to help Terell with finding a job. He had to offers for the oil field and all he needed to do Co was complete the application and turn it in. Terell complained about not being around his children if is he went to the oil field. I explained to him selling drugs is going to get you put in jail. Then you won’t av be able to see them on your own free will. Terell stated he does things the safe way and won’t get Tr caught. My old Pastor Lincoln Coffie and his wife Apryl Coffie also tried talking to him about y changing his lifestyle and getting a job. Terell said it is hard for him to stop selling drugs because he op has been doing it since he was 18. l c ia July 2018 I met the Petitioner at a gas station to get my children. My sister Tenice Bedford was with fic me. I took her cause I was scared that Terell would hit me when I spoke about the move. The of Petitioner has hit me and pushed me before in front of my children. I told him that I was moving to Un Georgia. Terell D Mosley Sr. got upset and started banging his head against his steering wheel. He also started punching the steering wheel as well. My sister Tenice Bedford was in my car with the e children as I was talking to Terell in his truck. He started talking about how he can see how people do ic drugs now. That’s when I removed myself from the vehicle before he got violent towards me. That’s Pr when I knew I was making the best decision with moving. Terell is not stable enough mentally to take L. care of my children. Terell doesn’t want to change and wants things to be easy for him. a lv Ve I allowed Terell to spend time with the kids before we moved as much as he wanted. I never tried to k keep his kids away from him. But the closer it got for us to leave he started arguments over simple er things. The week of August 20, 2018, Terell texted me to get the kids. He asked for me to get them Cl dressed and pack them some clothes to spend the night. I questioned Terell about him leaving the ct children at his mother’s house overnight as he spent the night somewhere else. I asked for him to stay tri with them at night because Mon'Rell who was 4 years old at the time would have bad dreams off and is on. He told me he was grown and could leave if he wanted too. That week I called him none stop D every day to talk with my babies. Terell wouldn’t answer or would text and say they not with him. . Co One day he was at football practice and said he would have them call me when he got home. I didn’t is hear from them until Saturday August 25, 2018. That was unusual for Legacy to not Facetime me. I av called Terell mothers phone and she didn’t answer either, I also sent her a text message. Legacy called Tr me August 25th finally and said she has been trying to call me cause her and Mon'Rell been ready to y come home. op c My lease in Texas was up August 31st and Terell knew that before he filed the Petition. He also knew l ia I had my place in Georgia before he filed the Petition. I had paid my deposits to my landlord August fic 11, 2018 and also signed my lease August 14, 2018. My caseworker in Texas and Georgia has all my of legal Government documents approving of my transfer from Texas to Georgia. Un PRAYER e ic Pr I the Respondent Lakeisha Bedford prays the court reconsiders the temporary orders filed on September 26, 2018. I pray you reconsider the Safety and Welfare of my children. I pray you reconsider the Best L. Interest of my children. I pray that you understand my intensions were not to disobey the orders by any a lv means. I am a Loving Mother wanting to provide a Safe and Better Life for her Children. Ve k I the Respondent prays that the court orders any Attorney Assistance fees, Paralegal fees, Court fees and er Court filing fees to be paid by the Petitioner Terell Mosley Sr. Cl ct tri is My contact number is 512-801-2694. My email address is Lbedford85@aol.com D Respectfully Submitted, . Co Lakeisha Bedford is av Tr y op c l ia fic of Un t^ ^X. lr.l E tl. e Aight FYI it's hard for me to say f*ck and move on ic reatty dsn't understand why it's alrTady been a Pr whote year L.

Case Info

Case No.

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Document Filed Date

October 22, 2018

Case Filing Date

August 24, 2018

County

Category

PARENT CHILD RELATIONSHIP (FAMILY LAW)

Status

PENDING BRFWRD

Parties

  • MOSLEY , TERELL DPetitioner

  • TOLBERT CHRISTOPHER LESHAWNAttorney

  • BEDFORD , LAKEISHARespondent

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!MTN:MODIFY,REDUCE,ENFOR,CONTE October 22, 2018 (2024)
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