IN THE IOWA DISTRICT COURT FOR APPANOOSE COUNTY NO. EQEQ001796 PETITION FOR MODIFICATION OF DECREE ESTABLISHING CUSTODY, VISITATION AND CHILD SUPPORT UPON THE PETITION OF JERRY WAYNE SPARKS, Petitioner, Vs. MELISSA A. HOPKINS, Respondent, AND CONCERNING S.L.H., A Minor Child. COMES NOW Petitioner, Jerry Wayne Sparks, by and through his counsel, Alan M. Wilson of Miles Law Firm, Corydon, Iowa and for his Petition For Modification Of Decree Establishing Custody, Visitation. And Child Support, respectfully states to the Court as follows: 1. That a Decree Establishing Custody, Visitation, and Child Support was filed of record in this matter on August 21, 2000 that provided for placement of primary physical care of the parties minor, S.L.H. with the Respondent. 2. That said Decree was modified by Order filed of record on March 10, 2010. 3. That there has been a substantial change in circumstances since the Decree Establishing Custody, Visitation, and Child Support and Modified Decree were filed in this action that warrants modification of said Decrees, said substantial change being the child moving in and living permanently with the Petitioner. 4. That the existing Decrees should be Modified to provide for transfer of primary physical care of the minor child S.L.H from the Respondent to the Petitioner with Respondent being awarded reasonable rights of visitation and Ordered to pay child support pursuant to the Iowa Supreme Court child Support Guidelines. 5. That due to the minor child residing with the Petitioner, Petitioners Child support obligation should be terminated immediately. WHEREFORE, Petitioner Jerry Wayne Sparks prays that the Court Modify the existing Decree and Modified Decree to transfer primary physical care of the parties minor child S.L.H. from the Respondent to the Petitioner, grant Respondent reasonable visitation and Order Respondent to pay child support pursuant to the Iowa Supreme Court Child Support Guidelines. PETITIONER FURTHER PRAYS that the Court Order that Petitioners child support obligation terminate effective immediately. PETITIONER FURTHER PRAYS for such other and further relief as the Court deems just and equitable in the premises. JERRY WAYNE SPARKS, Petitioner /s/ Alan M. Wilson Alan M. Wilson AT008617 Miles Law Firm P.O. Box 469 Corydon, IA 50060 Phone: 641-872-2343 FAX: 641-872-1650 mileslaw@grm.net ATTORNEY FOR PETITIONER Run 3x June 16th, 2015 June 23rd, 2015 June 30th, 2015
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