Jas&PJ

Our Story ~ My wife stood up for me and because of it WE are being PUNISHED

My mom is using my past against me.

I now will use my past against her

In the third grade, I was living in Compton California. One day there were these two boys whom one was BIGGER THAN ME, they both had always hit on me and I often would have A BLACK EYE. My dad told me I was allowed to defend myself. So the day comes where I've had enough. I FIGHT BACK. I cause one of the boys to cry. The other one was too big. After that day though, I was not bullied by those two ever again.

• After my parents separate I AM CRUSHED & when my uncle is arrested I fall into a deep sadness. (The kids at school are making fun of me and my brother for what my uncle was arrested for).

• In 3rd Grade I’m being bullied. My teacher tries to hold me down so I kicked her, I swear at her, and I throw a chair.

* My mom seems to ignore me a lot, growing up.

My mom is BITTER towards my dad.

We move to Vegas, she told my brother and I not to tell our dad.

(WHEN I CALL MY DAD HE IS MAD ABOUT NOT KNOWING.)

* My dad moves from Compton to Nevada

I am going to a different school than the year before. I’m in the seventh grade. I live with my dad and his girlfriend and it’s horrible. Every day the two would get into a fight. My dad's girlfriend would throw knives. She would also hit him. (ONE TIME SHE EVEN SLASHED HIS TIRES.) It was very hard for me to sleep at night. I HATED IT SO MUCH THAT I WOULD BEG MY MOTHER TO TAKE ME HOME

In 8th grade, I'm at a different school & I live in the HOOD.

Mom would always insinuate I WAS NEGATIVE. The fact of the matter is, The Squatters in the Alley, and the roaches and gunshots throughout the complex were half of the reason I felt like I was an emotional wreck! It didn’t take long for me to be coaxed to fit in. There were some guys from the team that were doing the graffiti and they smoked weed.

* My mom enrolls me into special ed because I CANNOT CONCENTRATE

I’M 15 AND IVE ALMOST OVERDOSED. MY MOTHER TAKES ME TO A HOSPITAL AND THE DOCTOR IS ABLE TO SAVE MY LIFE.

In March of 2008,

I AM TAKEN TO SEE A PSYCHIATRIST.

The Doctor has me write a statement about what happened and how I was feeling.

I WRITE, Last Friday I ASKED my dad for HELP because of a VIRAL INFECTION. And because HE SAYS NO I say to him, "you ain’t doing anything for me." He gets mad and Kicks me out of the house!

My dad's girlfriend has threatened me with her family. (I’m harassed)

I get resentful towards my dad. My grades start dropping

On September 15, 2008

* It’s reported I need to WORK ON MY COPING SKILLS

~I’M FEELING BOTH ANGRY AND SAD BUT I AM STAYING CLEAN.

* I TELL MY DOCTOR I HATE GOING BACK AND FORTH FROM MY DADS TO MY MOTHERS.

I want to stay with my mom, and Ill get a job!

On December 23, 2008

* I ADMIT THE DRUGS ARE NOT WORKING. I AM STILL BEING THREATENED, I CANNOT SLEEP. AND MY DADS GIRLFRIEND IS VIOLENT!

It’s been six months since my first assessment, and nothing has changed.

On January 12, 2009

* MY BEHAVIOR IS A PROBLEM ~IM HAVING MOOD SWINGS ~IVE SMOKED WEED

* IVE DRANK ONE TIME (ELEVEN BEERS)

MARCH 10, 2009

* I AM RELEASED FROM THE MONTE VISTA HOSPITAL & IM REFERRED TO A SUBSTANCE ABUSE GROUP

IN JUNE of 2009

* IM 16 & I WANT OFF MY MEDS

SEPTEMBER 25, 2009

* I REQUEST TO BE WEENED OFF THE SEROQUEL AND THE DEPAKOTE & START SOMETHING ELSE

OCTOBER 19, 2009

* IM HAVING MOOD SWINGS AND IM HAVING SEVERAL ANXIETY ATTACKS (AGAIN ITS REPORTED THAT NOTHING HAS CHANGED)

IN NOVEMBER of 2009

* I AM STILL ON MEDS AND HAVE STARTED TAKING WELLBUTRIN

FEBRUARY of 2010

* I AM GOING TO SCHOOL

IN APRIL of 2010

* MY MOMS REQUESTED TO KEEP ME ON MEDICATION. MY DIAGNOSIS IS BIPOLAR

IN JULY 2010

* I ADMIT I WANT TO GET MY DIPLOMA. AND I AM GOING TO JOB-CORE. (MY DIAGNOSIS IS STILL BIPOLAR)

In my freshmen year, I play football. My soft-more year, the Coach gets me to join the ROTC Program. & He becomes a GREAT MENTOR

My name is Jasmine Hill

I have MY SON on the 3rd of January in the year 2017, He’s born at the UMC in Las Vegas.

The day I am to be discharged, MY husband Perry has an ANXIETY ATTACK, so he leaves to get his medication. At this point, I've been in the hospital for a little over a week now.

* I need help with my baby and I’ve asked for help. My son was starting to fuss I believed he more than likely needed to have his diaper changed.

* I would have to lift him up. I had just had a C-SECTION

* I can tell the nurse (of color) is upset with me. She goes and comes back with a different nurse. The nurse then closes my door and is talking to the DOCTOR

* The following morning @ about 10 am:

I AM ACCUSED OF A LIE (MADE BY THE NURSE) WHY? BECAUSE I NEEDED HELP?

* I’d been feeding my baby. I got up from the bed and pushed my baby around to strengthen myself.

After I am discharged I call my mom and dad - they ALSO are CONFUSED. Before leaving the hospital my husband’s mom (Kimberly Collins) would help me. My parents only came to the hospital once.

* My husband's STEP DAD (Terrel Collins) has ALWAYS been DISRESPECTFUL towards My Husband (even before I conceived My Baby)

* TERREL TELLS PERRY NOT TO CALL HIS MOM FOR HELP.

My mother-in-law is coming over really early every morning unannounced. I don’t mind it tho, She’s helping me take care of my baby. At that time I was not working because of having a C-section. My husband is in between jobs, even though we were buying our house. (two bedrooms two baths. & our bills were being paid. January 2017)

Around the 22nd of January, my mother-in-law remarks that it is cold in my place. In parts of my home, it would be a different temperature than in my son's room. I made sure his room stayed warm, and my baby had everything he needed.

* The next day CPS shows up (this being my second contact) The first one was done in a different unit same complex on January 9th, 2017.

* CPS shows up, I'm feeding my baby. (My husband is asleep at this time) I’m asked if the thermostat works and I say YES * IM TOLD IF I GET ONE MORE REPORT THEY WILL BE TAKING OUR CHILD (WHAT!!??)

The same day my mother in law shows up, acting concerned. After we talk about what happened I allow my baby to go with her, Monday through Friday. That following Sunday I seem to have run out of formula, but have a gift card and just need a ride to get it.

* My husband and I are taken by surprise when we are driven to a notary at 9 pm to sign papers. My mother-in-law's husband asks as we are in the driveway if we had our IDs on us or not? (NOTHING WAS SAID PRIOR TO US ARRIVING TO THE NOTARY). (SHERECE WAS MY MOTHER-IN-LAWS FRIEND.) We get out of the car and on the trunk we are being told to sign guardianship papers.

* Questioning my parenting I felt both scared and confused. We get back in the car, no words are said. My husband is upset, asks his mom "what just happened?" He is ignored she does not say a word.

* My mother in law gives my dad’s number to her husband. I then get a call from my dad who is very upset with me. Why the papers?

* It is true we were struggling, but we never neglected our child.

* WE DID/DO NOT DRINK • WE DID/DO NOT PARTY • WE DID/DO NOT SMOKE

IN FEBRUARY MY SON IS WITH MY MOTHER-IN-LAW.

* March 2017

I KEPT CALLING FOR MY SON -DEFAULTED GUARDIANSHIP

* My husband and I were kicked off a bus for not having a transfer pass, we were on the phone with my father in law (NO ONE PICKED US UP. NO ONE WANTED TO HELP US.)

* With the default guardianship, visits will be supervised. I tell my mother in law I do not want her husband at the visits, because he and her son do not get along. HE IS ALWAYS DISRESPECTFUL

* For three months my husband and I are taking bus rides, one day my mother in laws husband yells at us. We wanted to see our son at our place. My husband is asking her why can’t we mom. She completely ignores him.

* Having no communication my husband and I decide to file to terminate the guardianship

December 2017

I am back in court-THE JUDGE IS NOT HAPPY WITH MY MOTHER-IN-LAW OR HER HUSBAND. WE TELL THE JUDGE WE HAVE NOT BEEN ALLOWED TO SEE OUR SON, SHE GOES OFF ON MY MOTHER-IN-LAWS HUSBND.

* THE JUDGE APOLOGIZES TO BOTH MY HUSBAND AND I FOR WHAT WE HAD BEEN GOING THROUGH WITH CPS (she is giving us a choice)

* I HAD JUST STARTED WORKING FOR AMAZON, THE JUDGE ASKS IF MY HUSBAND AND I WANT TO TERMINATE GUARDIANSHIP

We decide to leave him a little longer because:

* 1) We wanted to be guaranteed to get him back.

* 2) We wanted to be more financially stable, even though we were already pretty stable we wanted to be more secured where we were so we wouldn't risk losing him.

MY MOTHER IN LAW STARTED GOING OUT OF TOWN WITH MY SON WITHOUT TELLING ME ANYTHING. & THEN MY SON WOULD HAVE UNEXPLAINED MARKS/BRUISES

IN 2018 I HAD MY SON EVERY WEEKEND. ONE DAY MY HUSBAND SHOWS UP LATE. (I’m home I’ve taken the bus.) It comes up that I am still upset. My husband's stepdad interferes in the conversation. He’s cornered my husband while he is holding our son. My husband holding on tight to our son in one hand and a diaper bag in the other. He is close to some stairs. My husband is being told to put the baby down because he is wanting to fight.

* AT THIS POINT IM UPSET WITH MY MOTHER-IN-LAW FOR NOT STANDING UP FOR HER GRANDSON. HER HUSBAND FOLLOWED MY HUSBAND TO THE CAR AND STOOD THERE EGGING MY HUSBAND ON. SO WHEN I HEAR ABOUT IT I TELL HIM NOT TO GO OVER THERE AGAIN. HIS MOM IS BRINGING OVER THE CARSEAT.

My husband's dad calls wanting to know what happened even though Perry's mom and dad were not together she would call Perry's dad to complain. (My father-in-law would say he is gonna stay out of it)

* My husband calls the police, his mom is at our house and I hear her talking about the fight with my husband's dad. Her expressions seem to be weird.

* I’m fed up

* I FEEL DISRESPECTED FOR THE LAST TIME

~I TELL MY MOTHER-IN-LAW THAT HER HUSBAND IS THE PROBLEM AND I AM UPSET THAT SHE HAS TAKEN HER HUSBANDS SIDE. My Mother in law is in my face, she leaves and I tell the cops what just happened between her and I.

* The officer try’s calling my mother-in-law, but she doesn’t answer her phone

* My mother in law has agreed to give me back my son.

2019

* We go to court and Linda the Judge is NOT THE SAME JUDGE

* The judge is rude

My mother-in-law is bringing things up from my husband's past (the judge will not let my husband or myself talk.) She is frustrated with us, she says I have another case. BYE

MY MOTHER-IN-LAW DOES NOT WANT US TO HAVE UNSUPERVISED VISITS

One day her husband says he is going to bring my son over, I report that I will call the cops. The next weekend my mother-in-law-violates the order by not letting me see my baby.

* The judge tells my husband's stepfather he needs to let my husband and I see our son and it’s obvious HE AND MY MOTHER-IN-LAW ARE MAD.

* I am asked where is the child-support money (I offered it and I was told to save it)

* My mother in law says she was threatened, JUDGE STEELE says not according to the text.

Here is A List of Addresses, Jobs, and Visitation:

Addresses from January 2018- Present:

3263 Casey Dr #201 Las Vegas, Nevada 89120

4735 Deckow Lane Las Vegas, Nevada 89169

4055 Univerity Center Dr. Las Vegas, Nevada 89119

5300 E. Craig Rd. #713 Las Vegas, Nevada 89115

2500 Teddy Dr. #2500-41 Las Vegas, Nevada 89102

2625 Wyandotte St #10 Las Vegas, Nevada 89102

Employment from January 2017- Present:

Perry Hill Jr. -

Fanatic Inc
Amazon
Terribles gas station

Jasmine Hill-

Fanatics Inc
Amazon
Arizona Charles the Casino

Visitation from August 2019- Present:

The parents of Perry Hill III have been doing the visitation as of December 5th, 2017 til present. We were able to pick up our son on August 4th, 2019, at 5:30 pm. The next day (Sunday, August 5th, 2019) our car had broken down. We gave open and honest communication to Kimberly Collins that our car was in the shop and asked if she could come to meet us at our apartment to pick up our son. We did not withhold our son, the guardian agreed to come by and pick up our son at 5:30 pm with a couple of hour's notice.

The guardian picked up our son on time and there were no issues.

On the weekends of August 11th, 18th, 25th, and 31st, our car was still at the mechanic shop getting fixed. We texted the guardian, Kimberly Collins if she was willing to accommodate us by picking up and dropping off our son until our car was fixed and out of the shop. Kimberly Collins refused to help accommodate us with this request and told us we need to figure it out and find a way to come by and pick up our son. She also stated that our son was with her, and when we get our transportation sorted out we could come by and pick up our son. Our car was fixed the weekend after August 31st.

Then out of RETALIATION (Making it harder for us)

* My mother in law says there’s a problem, and asks where the child support is.

In September of 2019, it’s ordered my husband and I pay child support separately (we ask for joint child support but it gets denied)

IN 2019

IT'S ALREADY BEEN YEARS OF TENSION

* My wife and I are fed up

* WE FILE to terminate my mother-in-law's GUARDIANSHIP IN COURT:

In COURT I HAVE A REPORT FILED BY CPS (the 2nd time my mother in laws husband called CPS)

I have paid 1000 for a lawyer to represent my husband and I (Thomas Erie)

* My mother in law hires an attorney

* Our attorney files to terminate the guardianship

* My mother in law files to terminate my parental rights

* NO TIME TO RESPOND- THE JUDGE IS NOT RULING IN OUR FAVOR

* January 2020 ( SAME JUDGE, LINDA MARQUIS)

Our Court date was pushed from January 13th to February 13th.

On the 25th I file to terminate the guardianship and to file a petition for my parental rights

* Two cases in one, my mother-in-law takes the stand, my husband has his attorney and my son had his.

* I am on the stand for two hours, I am cross-examined by my mother-in-law's attorney.

I am questioned by all 3 attorneys

* I FEEL INTERROGATED BY MY MOTHER-IN-LAWS ATTORNEY

* LINDA MARQUIS IS TAKING NOTES

* I repeat the question so I can understand it, so I can give a correct answer

THE JUDGE IS WANTING TO SETTLE EVERYTHING RIGHT THEN AND THERE

* She wants my mother in law to have full custody.

My husband and I Disagree!

We have Court again.

MY HUSBANDS DADS GIRLFRIEND IS TESTIFYING FOR MY MOTHER-IN-LAW AS A WITNESS, THEN MY MOTHER IN LAW, THEN ME, THEN MY HUSBAND

* My mother-in-law is talking about her son's childhood. (the judge is encouraging her not to hold back)

* My mother-in-law is testifying that she reads the Bible and that my son calls her mommy and her husband poppy

MY TESTIMONY DID NOT MATTER (NOR DID MY HUSBANDS) I WAS UPSET ABOUT HOW MY SON WOULD HAVE MARKS ON HIS FACE AND I WAS NEVER TOLD ABOUT HOW HE WOULD GET HURT

* I AM IGNORED. MY HUSBAND IS UPSET AND THE JUDGE IS ANGRY.

Defendants' Response for Petition to Terminate Parental rights:

By: Perry and Jasmine Hill

1.) Mom and Dad were awarded unsupervised visitation of the Child in July 2019, but were not able to bring the Child back to the Guardian on August 4th, 2019, and did not exercise Visitation with the Children on the weekends of August 11th, 18th, 25th, and 31st.

Response: This is a false claim, we were awarded unsupervised visits on our very first court date to terminate the guardianship on December 5th, 2017, at 10:30 am in Courtroom 9 at Family Courts and Services Center 601 N. Pecos Rd. Las Vegas, NV 89101 case #: G-17-047527-M.

We were able to pick up our son on August 4th, 2019, at 5:30 pm. On Sunday, August 5th, 2019, our car had broken down, we gave open and honest communication to Kimberly Collins that our car was in the shop and asked if she could come to meet us at our apartment to pick up our son. We did not withhold our son, the guardian agreed to come by and pick up our son at 5:30 pm with a couple of hours notice. The guardian picked up our son on time and there were no issues. On the weekends of August 11th, 18th, 25th, and 31st, our car was still at the mechanic shop getting fixed. We texted the guardian, Kimberly Collins if she was willing to accommodate us by picking up and dropping off our son, until our car was fixed and out of the shop. Kimberly Collins refused to help accommodate us with this request, and told us we need to figure it out and find a way to come by and pick up our son, she also stated that our son was with her, and when we get our transportation sorted out we could come by and pick up our son. Our car was fixed the weekend after August 31st.

2.) Mom and Dad are not stable. Mom and Dad are always between jobs, living in weekly rentals, and unable to provide for themselves and the Child.

Response: 3 years ago, when our son was born, we were still trying to get on our feet and learn how to become independent young adults. We had our own apartment and we were there for 1 year, since January 3rd, 2016. After our son was born, we renewed our lease and resided at Promenade Apartments for another year. We were stable for 2 years, didn't have any issues paying our rent. We found a better and nicer apartment to move into, Capri Apartments. We resided there, but they were raising our rent gradually each month to where it was more challenging for us to continue residing there. We gave plenty of notice before we moved out of the complex, and left on good terms. We did live in a couple of weeklys, but still were able to pay our rent on time and still have a stable roof over our head, food, clothes, transportation, etc. We found another apartment, The Rubix Apartments, it was an uncomfortable environment for us, so we found somewhere better to stay. Now we reside in Wyandotte Apartments, we moved in October 2019, and we are still residing there. We are paying our rent each month, we still have reliable transportation, the parents have full-time employment, and able to care for themselves and their child.

3.) Paternal Grandmother filed a Petition for Guardianship on January 30th, 2017. Mom and Dad have both consented to the Guardianship on January 30th, 2017. The Guardianship was initially filed to avoid CPS removing the Child from Mom and Dad's care. Accordingly, this factor favors Paternal Grandmother.

Response: This is a false claim, the parents never consented to the Guardianship being filed. When our son was born, one of the nurses called CPS on us, because they felt like we were neglecting our child's needs, which was far from the truth. The father stayed up for 3 nights without any sleep to care for the child while the mother was resting and healing from her C-section surgery. The father did care for the child, and CPS interviewed us two days after our son was born, and addressed to CPS that the claim was false. CPS came to our apartment to inspect our unit to see if we had everything that we needed to care for our child. We had everything our child needed and showed CPS everything that was donated to us from the mother's baby shower.

CPS said that they would close the case because there was no proof of child abuse or neglect. Kimberly Collins was the only one visiting our child after she would get off of work, and made statements that it was cold in our apartment. None of our other family members came into our unit after the mother and child were released from UMC Hospital. CPS came to our door on January 30th, and told us that someone made a complaint that it was too cold in our place; we have CPS records for proof. We know that Kimberly Collins was giving information about our home to her husband, Terrell Collins; and he called CPS on us. CPS could not disclose information on who called and made a complaint, but CPS inspected our home once again, and could not prove that the claim was true.

There was no abuse or neglect once again, and CPS stated that if one more report was made against us, then they would take away our child whether the report was true or false. Kimberly and Terrell Collins had the motive to call CPS on us. They wanted to take our child away from us because they felt that we were incapable of raising our child. Kimberly Collins stated that her husband, Terrell Collins came up with the idea of watching over our son while we get on our feet. We did not come up with a decision at the moment, but Kimberly Collins was already watching over our child every weekend to allow us to rest from caring for our child.

The weekend during the CPS incident, Kimberly Collins contacted us and stated that she was coming by to pick up our child's Social Security card, and Birth Certificate in case the child needed to go to the doctor. The father texted Kimberly Collins that he was going to catch the bus to the store to get some formula for our child. Kimberly Collins told him to stay home until she and Terrell Collins arrived and she would take him to get the child formula. We gave our child's information to Kimberly and Terrell Collins in case something happened to our child on their weekend visits.

Kimberly and Terrell Collins gave the parents a ride assuming they were going to the store to get the child some formula, instead Kimberly and Terrell Collins took the parents to a notary's house and asked if they had their IDs. The parents had no clue of where they were at and what was going on, so the parents asked Kimberly and Terrell Collins what this was all about, and they did not respond. They arrived at the notary's house and the notary gave the parents some paperwork to fill out. The father refused to fill out the paperwork until he knew what was going on.

The notary stated that this was legal Guardianship papers for Kimberly Collins to become a temporary legal Guardian until the parents got on their feet. The mother was under a lot of pressure with CPS being called and was afraid that if she did not sign the paperwork, then CPS would take away our child. Kimberly Collins stated that this was only "temporary" and that they needed to become Guardians to sign the child up for daycare, take the child to his doctor's appointments, etc. The parents were convinced by Kimberly and Terrell Collin's deceitfulness and signed the temporary Guardianship papers. There was a court date on March 23, 2017, for Kimberly Collins to become a legal Guardian.

The parents realized that they did not want to go on through this, so they had the right to attend court to object against the Guardianship. The father was not able to get on the bus, because he did not have a reduced fair ID to show the bus driver, so the driver kicked the father off of the bus. The parents missed the court session due to lack of transportation, and therefore Kimberly Collins was granted legal Guardian. Kimberly Collins lied to the parents and stated that since they missed their court date, they had supervised visits at the Guardian's residence.

The father of the child and Terrell Collins have had tension since 2015, and the two were to be separated from each other for their differences. The parents did not feel comfortable with attending the Guardian's residence because of the tension that they both have with Terrell Collins. They came by and visited their child the first weekend, and Terrell Collins came off disrespectful towards the parents, and Kimberly Collins never addressed the issue to her husband. The parents felt disrespected by Terrell Collins and did not feel welcome into their home.

The parents refused to continue to enter their residence after the incident and investigated to see if the supervised visits were true. There was no confirmation that there were any supervised visits, and Kimberly Collins lied and refused to let the parents visit their child unsupervised. The parents still needed time to get on their feet, so they can retain custody of their child; it took them 9 months to start getting on their feet. The parents finally decided to Terminate the Guardianship and filled out the paperwork to file. Kimberly Collins all of a sudden wanted to come by the parent's house after she was informed by the parents that they were going to file for Termination of Guardianship. Kimberly Collins offered to have the parent visit their child unsupervised for one night, and the parents refused and decided to file the paperwork anyways.

4.) The parties were in court on June 19th, 2019. After the hearing, Mom made threats to Paternal Grandmother. Paternal Grandmother filed for Child Support, which only served to increase the level of conflict. Paternal Grandmother has only been doing what she is supposed to do as the Guardian. The conflict is coming from Mom and Dad. Accordingly, this factor favors the Guardian.

Response: This is false, we filed to terminate the Guardianship on June 19th, 2019. Before the parents filed, the father was hoping that he and his mother (who is the Guardian) could put their differences aside and work on their relationship as mother and son. He was even willing to put his differences to the side with the husband, Terrell Collins. On August 4th, 2018, the father came to the Guardian's residence and Kimberly Collins allowed him to come into her home. The father had a conversation with his mother and wanted to keep it between them.

Kimberly Collins raised her tone and was emotional during the conversation, and he was trying to explain to his mother that she needed to calm down. Terrell Collins came upstairs to see what the commotion was all about and did not like the way he was speaking to his mother. The father felt disrespected by Terrell Collins when he raised his tone at him stating he needs to calm his tone when in reality it was Kimberly Collins raising her tone during the conversation. The father stated to Terrell Collins that he needed to mind his own business and to watch his tone. Terrell got angry and threatened the father and told him to put his child down so he can get physical with the father.

The father felt threatened, and he tried walking away from Terrell Collins while carrying his child to put him in the car. Terrell Collins was preventing him from leaving the home, and still was threatening the father. The father walked around Terrell Collins and walked down the stairs to leave the residence. Terrell followed him to his car and kept getting in the father's face to provoke the father to fight him. The father put his child in the car and told the mother of the child that Terrell and his mother were not welcome to come to their residence due to the disrespect and threats from Terrell Collins.

The mother called the police after she was informed of the incident and was waiting for the cops to arrive. Kimberly Collins came to their residence after being told that she was not welcome over to their residence. Kimberly Collins lied and said she came to drop off the child's car seat, and she did not bring the car seat. The mother stated that Kimberly confronted her and got in her face threatening her. Kimberly Collins then left and did not give the parents the car seat.

On June 19th, 2019, Kimberly Collins agreed to drop off the child at the parent's residence due to a miscommunication of pick up and drop off. Terrell Collins was the only one that showed up to drop off the child, and he was told not to come to the parent's residence before Kimberly Collins agreed to drop off the child at the parent's residence. The mother reached out to Kimberly Collins and stated that her husband was not welcome over at the residence, and if he continued to come to the parent's residence, then the mother will notify the police. Kimberly Collins felt threatened and she filed a petition to modify the parent's visitation rights on July 24th, 2019.

Kimberly Collins stated to the judge that she felt threatened by the mother, and couldn't prove that there were any threats. The judge viewed the text messages of the conversation between Kimberly Collins and the father, and the judge stated that there were no threats present. Kimberly Collins's petition was denied by judge Linda Marquis, and she was upset. Her husband Terrell Collins brought up to the judge about making the parents pay child support after the denial of the petition that was made. Judge Marquis stated that she does not handle child support cases, and told Kimberly and Terrell Collins that they had to go to a different department to set up the child support.

The conflict was never started by the parents, the father tried to make peace with his mother Kimberly Collins and Terrell Collins, and Terrell Collins threatened to harm the father while the child was present, and that's when the father stopped trying to want to improve his relationship with his mother. The father felt betrayed by his mother for allowing another man to harm her son, and therefore the father doesn't want to work on improving his relationship with his mother. The father wanted to be professional and cordial and just focus on picking up and dropping off the child at the scheduled time.

5.) The parents have proven time and time again that they do not have the ability to care for the child. At the Parties' July 24th, 2019 hearing, the parents were granted Visitation with the Child every weekend. They didn't show up until September. This factor favors the Paternal Grandmother.

This is a false claim, we were awarded unsupervised visits on our very first court date to terminate the guardianship on December 5th, 2017, 10:30 am Courtroom 9 at Family Courts and Services Center 601 N. Pecos Rd. Las Vegas, NV 89101 case #: G-17-047527-M.

We were able to pick up our son on August 4th, 2019, at 5:30 pm, on Sunday, August 5th, 2019, our car had broken down, and gave open and honest communication to Kimberly Collins that our car was in the shop, if she could come to meet us at our apartment to pick up our son. We did not withhold our son, the guardian agreed to come by and pick up our son at 5:30 pm with a couple of hours of notice. The guardian picked up our son on time and there were no issues. On the weekends of August 11, 18, 25, or 31, our car was still at the mechanic shop getting fixed, and we texted the guardian, Kimberly Collins if she was willing to accommodate us by picking up and dropping off our son, until our car was fixed and out of the shop. Kimberly Collins refused to help accommodate us with this request, and told us we need to figure it out and find a way to come by and pick up our son, she also stated that our son was with her, and when we get our transportation sorted out we could come by and pick up our son. Our car was fixed the weekend after August 31st.

6.) Mom and Dad have had CPS involvement, long periods of not seeing the Child, have never paid Child Support, and have made threats against Paternal Grandmother. Accordingly, this factor weighs in Petitioner's favor.

Response: This is a false claim, the parents never consented to the Guardianship being filed. When our son was born, one of the nurses called CPS on us, because they felt like we were neglecting our child's needs, which was far from the truth. The father stayed up for 3 nights without any sleep to care for the child's needs, while the mother was resting and healing from her C-section surgery. The father did care for the child, and CPS interviewed us two days after our son was born, and addressed to CPS that the claim was false. CPS came to our apartment to inspect our unit to see if we had everything that we needed to care for our child. We had everything our child needed and showed CPS everything that donated to us from the mother's baby shower.

The parents just moved into a new apartment, both have lost jobs and were unable to pay child support. Now that the parents both have stable full-time employment, they are able to care for themselves, and the support of the child.

The Guardian refused to list the parents as emergency contacts on any of the support provided to the child.

7.) Mom and Dad have had very little Visitation with the Child since the Child's birth. Accordingly, this factor weighs in Petitioner's favor.

Response: The father of the child and Terrell Collins has had tension since 2015, and the two were to be separated from each other for their differences. The parents did not feel comfortable with attending the Guardian's residence because of the tension that they both have with Terrell Collins. They came by and visited their child the first weekend, and Terrell Collins came off disrespectful towards the parents, and Kimberly Collins never addressed the issue to her husband. The parents felt disrespected by Terrell Collins and did not feel welcome into their home.

8.) At the time of the Child's birth, there was CPS involvement. It is for this reason that the Paternal Grandmother took Guardianship of the Child. This factor favors the Petitioner.

Response: This is a false claim, the parents never consented to the Guardianship being filed. When our son was born, one of the nurses called CPS on us, because they felt like we were neglecting our child's needs, which was far from the truth. The father stayed up for 3 nights without any sleep to care for the child's needs, while the mother was resting and healing from her C-section surgery. The father did care for the child, and CPS interviewed us two days after our son was born, and addressed to CPS that the claim was false. CPS came to our apartment to inspect our unit to see if we had everything that we needed to care for our child. We had everything our child needed and showed CPS everything that donated to us from the mother's baby shower.

CPS said that they would close the case, because there was no proof of child abuse or neglect. Kimberly Collins was the only one visiting our child after she would get off of work, and made statements that it was cold in our apartment. None of our other family members came into our unit after the mother and child were released from UMC Hospital. CPS came to our door on January 30th, and told us that someone made a complaint that it was too cold in our place; we have CPS records for proof. We know that Kimberly Collins was giving information about our home to her husband, Terrell Collins; and he called CPS on us. CPS could not disclose information on who called and made a complaint, but CPS inspected our home once again, and could not prove that the claim was true

There was no abuse or neglect once again, and CPS stated that if one more report was made against us, then they would take away our child whether the report was true or false. Kimberly and Terrell Collins had the motive to call CPS on us. They wanted to take our child away from us because they felt that we were incapable of raising our child. Kimberly Collins stated that her husband, Terrell Collins came up with the idea of watching over our son while we get on our feet. We did not come up with a decision at the moment, but Kimberly Collins already was watching over our child every weekend to allow us to rest from caring for our child.

(a) Abandonment of the child; - False, never abandoned child from the day he was born and present. There is no sufficient proof showing there is abandonment. CPS case closed in 2017

(b) Neglect of the child;- False, never neglected the child's needs. The parents have everything the child needs at their current residence. There is no sufficient proof showing neglect of the child. CPS case closed in 2017.

(c) Unfitness of the parent; - False, the parents are fit to be parents. The parents are first-time parents and were raised well by both of their families. They both have never smoked or consumed any drugs, alcohol, or any abuse. They both have completed parenting class on March 27th, 2018, for Nurturing Parents and Families and have a certificate of completion for proof.

(d) Failure of parental adjustment; - False, The parents have made the adjustments on improving their financial situation to care for the child's needs. The parents have come a long way in their journey from when the child was born and present.

(e) Risk of serious physical, mental, or emotional injury to the child if he were returned to, or remains in, the home of his parent or parents; - False, The parents never physically, mentally, or emotionally injured their one and only child. They never yelled at their child, never hit their child, never abandoned their child, never neglected the child's needs; and there is no sufficient proof showing these claims. When the parents pick up the child from the Guardian, the child has bruises, scratches, black eye, etc. There is photo evidence proving this is a true statement.

(f) Only token efforts by the parent or parents; - The parents are willing to make all of the sacrifices needed to make sure that the child is taken care of, and that they can be the best young parents that they can ever be.

9.) If the parents were able to complete these tasks, the Guardian would agree to terminate the Guardianship.

Response: This is a false statement. The parents have text messages to prove that the Guardian agreed to terminate the Guardianship once the parents felt like they were ready to have the child back. On June 19th, 2019, the parents did what the Guardian requested them to do, which was to file the termination of Guardianship and the guardian would agree that the parents can retain custody of their child. Instead of agreeing to terminate the Guardianship, the Guardian objected against the parents when the judge asked the Guardian if she felt like the parents were ready to have their child back.

10.) The parents did not take the required parenting classes, did not attend parenting classes, and did not work full time.

Response: False, the parents are fit to be parents. The parents are first-time parents and were raised well by both of their families. They both have never smoked or consumed any drugs, alcohol, or any abuse. They both have completed parenting class on March 27th, 2018, for Nurturing Parents and Families and have a certificate of completion for proof. The mother and father at that time had full-time employment at Amazon Fulfillment Center making $15.00 hourly plus benefits and stocks. The mother was hired at Amazon on December 3rd, 2017, and the father was hired on October 15th, 2018. The mother was employed for 2 years, and the father was employed for 7 months due to better opportunity and better pay as a Delivery Driver for Amazon.

11.) Although Mom and Dad told the judge that they had a vehicle, they lied. The truth was, their vehicle had been repossessed.

Response: This is a false statement. The parents had 2 cars: a 2011 Honda Civic and a 2006 PT Cruiser. The Honda Civic wasn't repossessed, the parents surrendered the vehicle because the vehicle had too many issues, and it was getting costly for the parents to continue to get the vehicle fixed. The parents bought a 2006 PT Cruiser that is paid off, and had to wait to receive the title, and fix any issues that were present. The parents had family members that were giving them rides to pick up and drop off their son, however, things did not work out due to schedule reasons, and the parents had to wait until their car was finished with repairs to start picking up and dropping off their child.

We were able to pick up our son on August 4th, 2019, at 5:30 pm, on Sunday, August 5th, 2019, our car had broken down, and gave open and honest communication to Kimberly Collins that our car was in the shop, if she could come to meet us at our apartment to pick up our son. We did not withhold our son, the guardian agreed to come by and pick up our son at 5:30 pm with a couple of hour's notice. The guardian picked up our son on time and there were no issues. On the weekends of August 11th, 18th, 25th, and 31st, our car was still at the mechanic shop getting fixed, and we texted the guardian, Kimberly Collins if she was willing to accommodate us by picking up and dropping off our son, until our car was fixed and out of the shop. Kimberly Collins refused to help accommodate us with this request, and told us we need to figure it out and find a way to come by and pick up our son, she also stated that our son was with her, and when we get our transportation sorted out we could come by and pick up our son. Our car was fixed the weekend after August 31st.

12.) The Guardianship itself was granted to avoid the Child being removed from Mom and Dad from CPS due to an abuse and neglect issue they had pending at the time.

Response: This is a false claim, the parents never consented to the Guardianship being filed. When our son was born, one of the nurses called CPS on us, because they felt like we were neglecting our child's needs, which was far from the truth. The father stayed up for 3 nights without any sleep to care for the child's needs, while the mother was resting and healing from her C-section surgery. The father did care for the child, and CPS interviewed us two days after our son was born, and addressed to CPS that the claim was false. CPS came to our apartment to inspect our unit to see if we had everything that we needed to care for our child. We had everything our child needed and showed CPS everything that donated to us from the mother's baby shower.

CPS said that would close the case because there was no proof of child abuse or neglect. Kimberly Collins was the only one visiting our child after she would get off of work, and made statements that it was cold in our apartment. None of our other family members came into our unit after the mother and child were released from UMC Hospital. CPS came to our door on January 30th, and told us that someone made a complaint that it was too cold in our place; we have CPS records for proof. We know that Kimberly Collins was giving information about our home to her husband, Terrell Collins; and he called CPS on us. CPS could not disclose information on who called and made a complaint, but CPS inspected our home once again, and could not prove that the claim was true.

There was no abuse or neglect once again, and CPS stated that if one more report was made against us, then they would take away our child whether the report was true or false. Kimberly and Terrell Collins had the motive to call CPS on us. They wanted to take our child away from us because they felt that we were incapable of raising our child. Kimberly Collins stated that her husband, Terrell Collins came up with the idea of watching over our son while we get on our feet. We did not come up with a decision at the moment, but Kimberly Collins already was watching over our child every weekend to allow us to rest from caring for our child.

The father of the child and Terrell Collins has had tension since 2015, and the two were to be separated from each other for their differences. The parents did not feel comfortable with attending the Guardian's residence because of the tension that they both have with Terrell Collins. They came by and visited their child the first weekend, and Terrell Collins came off disrespectful towards the parents, and Kimberly Collins never addressed the issue to her husband. The parents felt disrespected by Terrell Collins and did not feel welcome into their home.

Jas&PJ

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