IN THE SUPERIOR COURT OF ROCKDALE COUNTY STATE OF GEORGIA ARYANNA HARRISON Plaintiff, Vs. CHAD ONEAL PITTMAN, Defendant. CIVIL ACTION FILE NO. 2020-CV-2280 PETITION FOR CUSTODY COMES NOW, Plaintiff, ARYANNA HARRISON, in the above-styled case, and states her Petition for Custody against Defendant, CHAD ONEAL PITTMAN as follows: 1. Plaintiff is a resident of Clayton County, State Georgia. Plaintiff has been a resident of the State of Georgia for more than six (6) months immediately preceding the filing of this Complaint. Plaintiff resides at 1099 Plantation Blvd SE, Conyers, Georgia 30094. 2. Defendant is a resident of the State of Georgia. Defendant is subject to the jurisdiction and venue of this Court. Defendants address is unknown. 3. Plaintiff is the biological mother of CHAD ONEAL PITTMAN, a male, born 2010, and NYLA MARIE LEE PITTMAN, female, born 2015. 4. Plaintiff gave the children to Defendant for a visit. Defendant is now withholding the children for the Plaintiff with no legitimation Order. FILED 11/18/2020 12:04 PM Rockdale County Superior Court e-Filed Record 2020-CV-2280 PETITION FOR CUSTODY Aryanna Harrison Vs. Chad ONeal Pittman Rockdale County Superior Court Page 2 of 3 5. Defendant is now withholding any communication with the children from Plaintiff. 6. There is no child support order in place between the parties. 7. Plaintiff shows that the custody of said minor children is not being withheld from the legal custodian of said minor children in violation of any custody order, nor are any visitation rights being withheld in violation of any custody order as contemplated under the terms of the Georgia Child Custody Jurisdiction Act, Ga Laws 1978, page 1957, Official Code of Georgia Annotated, Section 19-9-20. 8. Plaintiff further shows the parties to this action have not participated as a party, witness, or in any other capacity in any other litigation concerning the children in this or in any other State. Plaintiff knows of no other person not a party to the proceedings who has physical custody of the children or claims to have visitation rights with respect to said children. 9. Plaintiff further acknowledges that she is aware that she has a continuing duty to inform the Court of any custody proceeding concerning the minor children of the parties in this or any other State of which she obtains information during the pendency of this divorce proceeding, all as provided under the provisions of the Uniform Child Custody Jurisdiction Act, Ga. Laws 1978, pp 258, 257, (Official Code of Georgia Annotated Section 19-9-40). WHEREFORE, the Plaintiff prays: A. That process issue and the Defendant be served according to law; B. That she be granted immediate temporary and permanent custody of her children; C. That the child be ordered to be brought back to the State of Georgia; PETITION FOR CUSTODY Aryanna Harrison Vs. Chad ONeal Pittman Rockdale County Superior Court Page 3 of 3 D. For any and all further legal and equitable relief which the Court deems necessary and proper. Respectfully submitted this 18th day of November, 2020. LAW OFFICE OF JUSTIN CHIN, LLC /s/ Justin Allen Chin Justin Allen Chin, Esq. Georgia Bar No.: 886274 Attorney for Plaintiff 2870 Peachtree Road #442 Atlanta, Georgia 30305 404-260-7393 (office) 866-475-0083 (facsimile) 930-27058 2/17 24 3/3 10 2021


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