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Brandt, Ebony N vs Brock, Alexis N
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Party 1
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Party 2
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September 22, 2022

STATE OF MISSOURI SS. COUNTY OF ST. CHARLES IN THE CIRCUIT COURT OF ST. CHARLES COUNTY, MISSOURI 11TH JUDICIAL CIRCUIT JUVENILE DIVISION In Re: the Matter of EBONY N. BRANDT (SSN: XXX-XX-4470) Petitioner Regarding: DAXTEN RYAN ALEXANDER RAGAN a male minor child, born 02/14/2018 Case No. 22AD-JU00136 Division 5 v ALEXIS N. BROCK Respondent and NOLAN R. RAGAN Respondent AMENDED PETITION FOR TERMINATION OF PARENTAL RIGHTS AND PETITION FOR ADOPTION COUNT ONE - TERMINATION COMES NOW the Petitioner, EBONY N. BRANDT, and for her Petition for Termination of Parental Rights, pursuant to Section 211.447, et. seq, states to the Court as follows, to wit: 1. That Petitioner was granted Letters Of Guardianship of DAXTEN RYAN ALEXANDER RAGAN, a male minor child, on June 3, 2021; and, 2. That the said minor child was born to ALEXIS N. BROCK, the natural mother, and NOLAN R. RAGAN, the natural father; and, 3. That the facts set forth in this Petitioner's Petition For Guardianship continue, in that the natural mother has willfully abandoned the minor child and has willfully, substantially, and continuously neglected to provide the minor child with necessary care and protection for a period of at least six (6) months immediately preceding the filing of this Petition. 4. Petitioner further states that the natural father has abandoned the minor child, or has previously consented to the Petitioner being appointed Guardian of the person and the estate of the said minor child, in this Court, in Estate No. 211 1-PR00029, entered on June 3, 2021. 5. That the minor child has lived continuously with the Petitioner since September 9, 2020. 6. That the purpose of this Termination is for the Petitioner to adopt the subject minor child and Petitioner believes such adoption will promote the child' s best interests and welfare. WHEREFORE, Petitioner prays the Court conduct a Dispositional Hearing and grant Petitioner's Motion To Terminate Parental Rights of ALEXIS N. BROCK, the natural mother and NOLAN R. RAGAN, the natural father, and enter an appropriate Order, Judgment, and Decree that will allow Petitioner to proceed in Count Two, hereinafter set forth ; and, for such other and further orders as this Court would deem just and proper in the premises. COUNT TWO - ADOPTION COMES NOW the Petitioner, EBONY N. BRANDT, and for her Petition for Adoption states to the Court as follows, to wit: 1. That Petitioner desires to adopt DAXTEN RYAN ALEXANDER RAGAN, a male minor child who was born on the 14th day of February, 2018, in St. Charles County, Missouri. 2. That the minor child was born to ALEXIS N. BROCK, the natural mother, and NOLAN R. RAGAN, the natural father. 3. That the natural mother has willfully abandoned the minor child who is now age 4 and the natural mother has willfully, substantially, and continuously neglected to provide the minor child with necessary care and protection for a period of at least six (6) months immediately preceding the filing of this Petition. Petitioner further states that the natural father has abandoned the minor child, or has previously consented to the Petitioner being appointed Guardian of the person and the estate of the said minor child, in this Court, in Estate No. 2111-PR00029, entered on June 3, 2021. 4. That the minor child has lived continuously with the Petitioner since September 9, 2020. 5. That Petitioner desires to change the name of the minor child to DAXTEN RYAN ALEXANDER BRANDT. 6. That the adoption of the minor child by Petitioner will promote his best interests and welfare. WHEREFORE, Petitioner prays the Court to enter a Order, Judgment, and Decree adjudging that the minor child, DAXTEN RYAN ALEXANDER RAGAN, be adopted by the Petitioner, EBONY N. BRANDT, and that for all legal intents and purposes, the minor child be the child of the Petitioner, as fully as if born to her in lawful wedlock, and the name of the minor child, DAXTEN RYAN ALEX ANDER RAGAN, be changed to DAXTEN RYAN ALEXANDER BRANDT, and for such other and further orders as this Court would deem just and proper in the premises. Respectfully Submitted, /s/ Joel B. Eisenstein JOEL B. EISENSTEIN #21476 Attorney For Petitioner 60 Hill Pointe Court Upper Level, Suite 200 Saint Charles, Missouri 63303 Telephone: (636) 947-1000 Facsimile: (636) 946-2783 /s/ Ebony N. Brandt EBONY N. BRANDT, Petitioner 12157744 St. Charles Sep. 22, 2022

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