IN THE CIRCUIT COURT OF RALEIGH COUNTY
In Re: The Petition of DEAN RAY BAILEY for the adoption of RAELYNNE JAE JOHNSON, a child under the age of 18 years
Civil Action No:
PETITION FOR ADOPTION
I.
Petitioner, Dean Ray Bailey, whose date of birth is September 9, 1974, represents unto the Court that he is a citizen and resident of Raleigh County, West Virginia, residing in Beckley, Raleigh County, West Virginia.
II.
Petitioner states that he is seeking to adopt RaeLynn Jae Johnson who was born on June 9, 2012, in Raleigh County, West Virginia.
III.
The natural mother of RaeLynn Jae Johnson is Jennilee Lynn Johnson, whose date of birth is June 24, 1982.
IV.
The natural father of RaeLynn Jae Johnson is unknown.
V.
The minor child is currently residing with the Petitioner. Petitioner has been in the minor child’s life since birth.
VI.
The Petitioner herein, Dean Ray Bailey and the biological mother, Jennilee Lynn Johnson, have been together since April 1, 2005.
VII.
Jennilee Lynn Johnson is the biological mother and shall remain her mother for all legal purposes and consents and remains a party to this action.
VIII.
Your Petitioner says that he is more than fifteen (15) years older than said child sought to be adopted; that said child is not currently possessed of property of any kind or character; that said child has been in petitioner’s life since birth June 9, 2012; that your Petitioner is financially able and willing to provide said child with a proper home and to see to her education and welfare; that the minor child is not American Indian children as defined by statute; that your Petitioner, Dean RAy Bailey, has grown to love said child as if her were his own and he is desirous of adopting said child; and that the best interests of the said child will be materially promoted by this adoption.
It is Petitioner’s desire to change the child’s name to RaeLynn Jae Bailey.
WHEREFORE, Petitioner pray:
1) That, upon presentation of this Petition to the Court, the same be ordered filed with the clerk thereof;
2) That a day be appointed for a hearing on said Petition and for the examination under oath of the parties in interest;
3) That no home study be required;
4) That, after said hearing on the Petition so filed and the examination made, your Petitioner, Dean Ray Bailey, be allowed to adopt said infant child, and grant unto your Petitioner such other and further relief as this Honorable Court deem proper.
5) That RaeLynne Jae Johnson’s name be changed to name be changed to RaeLynne Jae Bailey.
DEAN RAY BAILEY
BY COUNSEL
WOOTON DAVIS HUSSELL & JOHNSON
BY: /s/ Christopher M. davis
CHRISTOPHER M. DAVIS (9050)
P.O. Box 2600
Beckley, WV 25802-2600
VERIFICATION
STATE OF WEST VIRGINIA,
COUNTY OF RALEIGH, TO-WIT:
I, Dean Ray Bailey, after being first duly sworn, depose and say that the facts contained in the heretofore served “Petition for Adoption” are true, except insofar as they are therein stated to be upon information and belief, and that as they are therein stated to be upon information and belief, I believe them to be true.
DEAN RAY BAILEY
Taken, subscribed and sworn to by me this 19th day of February, 2021.
Lori Hughes
Notary Public
My commission expires: Dec. 7, 2021