Sean Garrett

Fulton County Superior Court
***EFILED***MH
Date: 1/23/2017 10:44:53 AM
Cathelene Robinson, Clerk
IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
FAMILY DIVISION
G. HAMLER, :
Petitioner, : CIVIL ACTION FILE
v. : NO.: 2017CV284342
R. RILEY, :
Respondent. :
AMENDED PETITION FOR CHILD LEGITIMATION AND CHILD CUSTODY
COMES NOW, G. HAMLER, Petitioner in the above-styled matter, and pursuant to
O.C.G.A. 9-11-15(a), prior to the entry of a pretrial order, files this, his First Amended Petition
for Legitimation and Child Custody as follows:
1.
Petitioner shows the Court that the minor child of the parties, to-wit: CRUZ HAMLER, a
male child born in 2015:
(a) Presently resides with both the Petitioner and the Respondent, who live in separate
residences;
(b) Said minor child has resided with Petitioner and/or Respondent for his entire life;
(c) Neither Petitioner nor Respondent has not participated as a party, witness or in any
other capacity in any litigation concerning the custody of said minor child in
Georgia or in any other State;
(d) Petitioner has no knowledge or information of any custody proceeding concerning

said minor child pending in a Court of Georgia or any other State; and
(e) Petitioner has no knowledge or information of any person not a party to these
proceedings who had physical custody of said minor child or who claims to have
custody or parenting time rights with respect to said minor child.
C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

1/21/17
Page 1 of 5
2.
Respondent and Petitioner ended their romantic relationship in December, 2015. However,
in an effort to assist Respondent until she could establish her own residence and vehicle has
allowed Respondent to reside in his condo and drive his vehicle. Over one (1) year later,
Respondent still does not have a job, still does not have her own residence, and still does not have
her own vehicle. In fact, Respondent refuses to turn over Petitioners vehicle to him after several
demands therefor even though Petitioner offered to rent the Respondent a vehicle. Respondents
behavior is criminal.
3.
The Petitioner is an active father with the parties minor child, and has always been an
active father with his other son, who has now reached his age of majority.
4.
Pursuant to O.C.G.A. 19-9-3(a)(1), In all cases in which the custody of any child is
at issue between the parents, there shall be no prima-facie right to the custody of the child in
the father or mother. There shall be no presumption in favor of any particular form of custody,
legal or physical, nor in favor of either parent. (Emphasis added.)
5.
Pursuant to O.C.G.A. 19-9-3(a)(2), in determining to whom custody of the child
should be awarded. The duty of the judge in all such cases shall be to exercise discretion to
look to and determine solely what is for the best interest of the child and what will best
promote the child's welfare and happiness and to make his or her award accordingly.
(Emphasis added.)

1/21/17
Page 2 of 5
6.
Petitioner requests that the Court issue an order legitimating the minor child, to-wit: CRUZ
HAMLER, a male child, born in 2015, pursuant to O.C.G.A. 19-7-22. Such legitimation would
be in the best interests of said minor child.
7.
The Petitioner should be awarded joint legal custody of the parties minor child which
would also be in the best interests of the parties minor child. The Petitioner should also be
awarded final decision-making authority with respect to the minor childs education, extra-
curricular activities and non-emergency medical decisions after a good faith consultation with
Respondent.
8.
The Petitioner is a fit and capable parent, and is otherwise qualified to maintain primary
physical custody of the parties minor child, subject to the parenting time rights of the Respondent.
The Petitioner should be awarded temporary and permanent primary physical custody of the
parties minor child, which would be in the best interests of the parties minor child.
9.
Petitioner has provided for the support and maintenance of the minor child and
Respondent since the sons birth. Petitioner also provides the minor child with medical insurance
and pays for the minor childs day care. Respondent needs to start providing for her own
maintenance and support. The parties are not married, have never been married, and Petitioner has
no duty or obligation to continue to assist the Respondent with housing, transportation and a cell
phone when Respondent absolutely refuses to help herself. Petitioner has patiently waited for over
one (1) year for the Petitioner to start taking care of herself like adults are required to do, but she

1/21/17
Page 3 of 5
refuses.
10.
Petitioner shall continue to provide medical insurance for the parties minor child.
Petitioner will provide dental insurance for the minor child as well. However, Petitioner cannot
continue to finally assist Petitioner, who is a healthy adult, with a bachelors degree, capable of
working and supporting herself.
11.
Petitioner shows the Court that Respondent should be ordered to pay Petitioners
reasonable attorneys fees and expenses of litigation pursuant to O.C.G.A. 19-9-3(g) and 9-15-
14.
WHEREFORE, Petitioner prays that his Petition be granted and that he have such other
relief as follows:
a. That process issue;
b. That the minor child, to-wit: CRUZ HAMLER, a male child, born in 2015, be
legitimated under Court Order, pursuant to O.C.G.A 19-7-22;
c. That Petitioner be awarded primary physical custody and joint legal custody of the
parties minor child;
d. That Petitioner be awarded final decision-making authority with respect to the

minor childs education, extra-curricular activities and non-emergency medical
decisions after a good faith consultation with Respondent;
e. That Respondent be ordered to pay Petitioners reasonable attorneys fees and

expenses of litigation pursuant to O.C.G.A. 19-9-3(g) and 9-15-14; and
f. That this Honorable Court award such additional and further relief as it may deem
just and equitable.

1/21/17
Page 4 of 5
RESPECTFULLY SUBMITTED, this 21st day of January, 2017.
THE LAW OFFICE OF
TANYA MITCHELL GRAHAM, P.C.
Attorneys for Petitioner
3212 Northlake Parkway, N.E. Tanya Mitchell Graham, Esquire

Box 450929 Georgia Bar No.: 513595
Atlanta, Georgia 31145
770.492.9013 Telephone
770.492.9017 Facsimile

1/21/17
Page 5 of 5
STATE OF GEORGIA
FAMILY DIVISION
G. HAMLER, :
v. : NO.: 2017CV284342
R. RILEY, :
Respondent. :
CERTIFICATE OF SERVICE
I hereby certify that I have this day served
Derric Crowther, Esquire

Crowther Law Firm, P.C.
1230 Peachtree Street, N.E.
Suite 3750
in the foregoing matter with a copy of Petitioners First Amended Petition for Legitimation and
Child Custody by placing a copy of same in the U.S. Mail with adequate postage affixed thereon.
This 21st day of January, 2017.
THE LAW OFFICE OF



1/21/17
***EFILED***TMM
Date: 1/26/2017 3:13:05 PM
***EFILED***AB
Date: 1/27/2017 3:35:14 PM

STATE OF GEORGIA
G. HAMLER )
)
Petitioner, ) CIVIL ACTION FILE NO:
) 2017CV284342
v. )
)
RACHAEL RILEY )
)
)
Respondent. )
RULE 5.2 CERTIFICATE OF SERVICE
This is to certify that I have this date prepared and served the RESPONDENTS FIRST
INTERROGATORIES TO PETITIONER by service on Petitioners Counsel by depositing a
copy of same in the U.S. Mail to wit:
Ms. Tanya Mitchell Graham, Esq.

3212 Northlake Parkway N.E.
Respectfully submitted this 27th day of January, 2017.
/s/Derric Crowther___________
DERRIC CROWTHER
Georgia Bar No.: 198838
Attorney for Respondent
CROWTHER LAW FIRM, P.C.
1230 Peachtree Street, NE
Suite 3750
(404) 946-1900 Telephone
(404) 923-7475 Facsimile
dcrowther@cwlawfirm.net
STATE OF GEORGIA
G. HAMLER )
)
Petitioner, ) CIVIL ACTION FILE NO: 2017CV284342
)
v. )
)
RACHAEL RILEY )
)
)
Respondent . )
___________________________________ )_________________________________________
RULE 5.2 CERTIFICATE OF SERVICE
This is to certify that I have served RESPONDENT S REQUEST FOR

PRODUCTION OF DOCUMENTS TO PETITIONER upon Counsel of record via Facsimile
and by depositing a copy of the same in the U.S. Mail with adequate postage attached thereto as
follows:
Respectfully submitted, this 27th day of January, 2017.
DERRIC CROWTHER
Suite 3750
(404) 946-1900 Telephone
(404) 923-7475 Facsimile
***EFILED***TMM
Date: 2/6/2017 11:43:19 PM

STATE OF GEORGIA
FAMILY DIVISION
G. HAMLER, :
v. : NO.: 2017CV284342
R. RILEY, :
Respondent. :
PETITIONERS MOTION FOR PROTECTIVE ORDER
COMES NOW, G. HAMLER, Petitioner in the above-styled action, and files this, her
Motion for Protective Order pursuant to O.C.G.A. 9-11-26(c) showing this Honorable Court
as follows:
1.
Petitioner is a successful singer, songwriter and music producer. As such, Petitioner is a
public person and a celebrity.
2.
Respondent is the mother of Petitioners youngest child, who is aware of Petitioners
celebrity status.
3.
Prior to the filing of this action, Respondent had already threatened to provide the
media with private information pertaining to Petitioner.
4.
Petitioners seeks a Protective Order to maintain confidential, proprietary, trade secret,
personal and private information as confidential and to provide a mechanism by which
C:\USERS\TANYA2\DOCUMENTS\MOTION FOR PROTECTIVE ORDER.DOCX

2/6/17
Page 1 of 5
disclosure of discovery materials and things may be produced and disclosed by Parties and non-
Parties in this proceeding in a manner that protects against the risk of disclosure to persons or
entities not entitled to such information.
5.
Petitioner seeks a Protective Order from this Court that applies to and governs the
treatment of all information contained in documents, depositions (including transcripts and
videos thereof), deposition exhibits, interrogatory answers and responses to requests for
production, responses to requests for admission, responses to subpoenas, and other written,
recorded, computerized, electronic, or graphic matter, copies, excerpts, or summaries of
documents (Discovery Material) produced by either party or non-party in this litigation.
6.
Specifically, Petitioner seeks a Protective Order from this Honorable Court protecting any
and all Confidential Information which shall include:
i. Any and all information that the Designating Party (meaning the party
producing the documents and things, or providing the information) in good
faith reasonably believes will disclose confidential commercial, financial,
personal, or business information that would provide others with an unfair
competitive or improper advantage. Confidential Information also means an
individuals private or personal information which, if disclosed, would
violate the privacy rights of that individual, including but not limited to
information regarding the personal relationship between the Parties; any
purported misconduct related to the personal relationship between the
Parties; information regarding the Parties minor child; personally-

2/6/17
Page 2 of 5
identifying information regarding the Parties, including their home or
business addresses, e-mail addresses, telephone numbers, social security
numbers, taxpayer identification numbers, and financial account numbers;
and all financial documents and information regarding the Parties finances,
contractual relationships with third parties, business interests, partnership
interests, employment, investments, and assets and liabilities;
ii. Any and all summaries, writings, analyses, reports or other such documents
containing information prepared by or on behalf of either party based upon
Confidential Information;
iii. Testimony given at a deposition or hearing and the resulting transcript and
video, including exhibits;
iv. Confidential Information shall not include information that, as of the date
of this any Order by this Court, which is already in the public domain and is
produced or disclosed by either party, by third parties or by non-parties
during the course of discovery in the above-styled litigation, whether
formally or informally.
7.
Petitioner further seeks a Protective Order that Confidential Information, and the
substance, content and existence thereof, shall be held in confidence by the Parties and their
counsel and shall be used only for the purpose of preparing for, conducting, participating in the
conduct of, and prosecuting or defending this proceeding.

2/6/17
Page 3 of 5
8.
Petitioner further requests that any pleading, motion or other paper filed with this Court
disclosing the substance, content or existence of Confidential Information, shall be filed under
seal and kept under seal until further Order of said court; however, said Confidential Information
shall continue to be available to said court or to such persons permitted access to the information
under this Order.
9.
Petitioner further requests a Protective Order excluding discovery that is not relevant,
oppressive, burdensome, and instituted solely for the purpose of harassing Petitioner, as well as
requests for discovery that will not lead to discoverable information.
10.
Under O.C.G.A. 9-11-26(c), when good cause is shown, [t]he court in which [an]
action is pendingmay make any order which justice requires to protect a party or person from
annoyance, embarrassment, oppression, or undue burden or expense, including[t]hat the
discovery not be hador[t]hat certain matters not be inquired into Petitioner maintains
that the information sought by the Respondent seeks information from Petitioner as if these
parties were married, but they were not. Relevant discoverable information would be both
parties income and expenses for the minor child, not how much money Petitioner spends on
clothing or what gifts he may buy for others.
WHEREFORE, Petitioner requests that this Court grant the following relief:
a. Issue a Protective Order in this case;

2/6/17
Page 4 of 5
b. Protect the Petitioner from having to respond to any and all Discovery Requests
that are irrelevant, oppressive, burdensome, instituted solely for the purpose of
harassing Petitioner, and which will not lead to discoverable information; and
c. Grant such further relief as this Honorable Court deems just and appropriate under
the circumstances of this case.
RESPECTFULLY SUBMITTED, this 6th day of February, 2017.
THE LAW OFFICE OF



2/6/17
Page 5 of 5
STATE OF GEORGIA
FAMILY DIVISION
G. HAMLER, :
v. : NO.: 2017CV284342
R. RILEY, :
Respondent. :
I hereby certify that I have this day served
Derric Crowther, Esquire

Crowther Law Firm, P.C.
1230 Peachtree Street, N.E.
Suite 3750
in the foregoing matter with a copy of Petitioners Motion for Protective Order by placing a copy
of same in the U.S. Mail with adequate postage affixed thereon.
This 6th day of February, 2017.
THE LAW OFFICE OF



2/6/17
***EFILED***WW
Date: 2/7/2017 1:58:21 PM
***EFILED***MH
Date: 2/8/2017 8:35:18 AM
***EFILED***MH
Date: 2/8/2017 8:35:18 AM
***EFILED***QW
Date: 2/8/2017 12:47:10 PM
IN THE SUPERIOR COURT OF FULTON COUNTY Cathelene Robinson, Clerk
FAMILY LAW DIVISION
STATE OF GEORGIA
O.HAMLER,
Plaintiff, CIVIL ACTION FILE
v. NO.: 2017-CV-284342
R. RILEY,
Defendant.
FINAL ORDER ON LEGITIMATION ISSUE
The above-styled case having come before the Court on February 7, 2017 for a 30 Day
Status Conference, and the Court, having read, heard and considered the pleadings filed by both
Plaintiff and Defendant, IT IS HEREBY ORDERED AND ADJUDGED AS FOLLOWS:
FINDINGS OF FACT
1. This is an action for legitimation filed pursuant to O.C.G.A. 19-7-22 and for child
custody pursuant to O.C.G.A. 19-9-3.
2. This Court finds that jurisdiction and venue is proper.
3. The Parties are the biological parents of one (1) minor child, to wit C. HAMLER, a
male child, bom inthe year 2015 (hereinafter the "Minor Child").
4. Plaintiff, G. HAMLER (hereinafter the "Father") is the biological and legal father of
the Minor Child.
5. Defendant, R. RILEY (hereinafter the "Mother") is the biological and legal mother of
the Minor Child.
6. The Father has provided financial support for the Minor Child on a consistent basis.
7. The Father has not submitted to DNA Paternity Test, but does not contest the
paternity of the Minor Child.
CONCLUSIONS OF LAW AND ORDER OF THE COURT

In/17
Page 1 of3
8. The Father has not abandoned his opportunity interest in developing a relationship
with the Minor Child.
9. Legitimation by the Father is in the best interest of the Minor Child.
10. The Minor Child, C. HAMLER, a male child, born in the year 2015, shall be declared
the legitimate child of the Father, G. HAMLER pursuant to O.C.G.A. 19-7-22
11. The Minor Child's current surname shall remain his legal name upon the entry of this
Order.
12. The Bureau of Vital Statistics of the Georgia Department of Human Resources and all
other agencies are hereby Ordered to change their records to show the Minor Child's
legitimation by the Father.
13. The Minor Child shall be capable of inheriting from the Father in the same manner as
if born in wedlock.
14. The Father shall have all the obligations and rights to the Minor Child as the Minor
Child's legitimate Father.
15. The remaining issues in this matter shall be reserved for future determination of this
Court.
SO ORDERED, this 7th day of February. 2017.
Presented and Prepared By:

mil 1
Page 2 of3
THE LA W OFFICE OF
TANYA MITCHELL GRAHAM, P.e.
Attorneys for Plaintiff
Tanya Mitchell Graham, Esquire

Georgia Bar No. 513595
Cheryl D. Kelly, Esquire
Georgia Bar No. 390229
3212 Northlake Parkway, N.E.
Box 450929
770.492.9013
770.492.9017
Cc: Derric Crowther, Esquire

Attorney for Defendant
2/1111
Page 3 of3
***EFILED***MH
Date: 2/10/2017 4:09:54 PM

STATE OF GEORGIA
G. HAMLER )
)
Petitioner, ) CIVIL ACTION FILE NO:
) 2017CV284342
v. )
)
RACHAEL RILEY )
)
)
Respondent. )
ANSWER
COMES NOW, R. Riley, Respondent in the above styled action, and states this, her
Answer to Petitioners Petition for Child Legitimation and Child Custody as follows:
1.
ADMITS
2.
ADMITS
3.
ADMITS
4.
DENIED. The minor child resides with Respondent.
5.
ADMIT
1
6.
DENIED as to 6a and 6b. The minor child resides with Respondent. ADMIT as
to 6c,6d, and 6e.
7.
ADMIT
8.
ADMIT
9.
ADMIT
10.
DENIED. The Petitioner and respondent should have Joint Legal Custody and
the Respondent should continue having primary physical custody.
11.
DENIED. The Petitioner and respondent should have Joint Legal Custody and
the Respondent should continue having primary physical custody.
12.
DENIED
13.
ADMIT
14.
ADMIT
15.
Respondent reserves the right to amend her answer.
2
WHEREFORE, Respondent prays for relief as follows:
a. That the minor child be legitimated;
b. That the Respondent be awarded primary physical custody and the parties
have joint legal custody;
c. That the Petitioner provide support based on his true income and not the
fabricated income he lists on his child support worksheet;
d. That the Petitioner shall pay all medical and dental expenses of the
Respondent and child;
e. That the child and Respondent be allowed to remain in the family home;
f. That any parenting plan agreed upon by BOTH parties be incorporated into a
final settlement agreement; and
g. For such other and further relief as this Honorable Court may deem just and
equitable.
Respectfully submitted this 10th day of February, 2017.
DERRIC CROWTHER
Suite 3750
(404) 946-1900 Telephone
(404) 923-7475 Facsimile
3
STATE OF GEORGIA
G. HAMLER )
)
Petitioner, ) CIVIL ACTION FILE NO: 2017CV284342
)
v. )
)
RACHAEL RILEY )
)
)
Respondent . )
___________________________________ )_________________________________________
This is to certify that I have served RESPONDENT S ANSWER upon Counsel of

record via Facsimile and by depositing a copy of the same in the U.S. Mail with adequate
postage attached thereto as follows:
Respectfully submitted, this 10th day of February, 2017.
DERRIC CROWTHER
Suite 3750
(404) 946-1900 Telephone
(404) 923-7475 Facsimile

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Fulton County Superior Court

IN THE SUPERIOR COURT OF FULTON COUNTY

Petitioner, : CIVIL ACTION FILE

AMENDED PETITION FOR CHILD LEGITIMATION AND CHILD CUSTODY

COMES NOW, G. HAMLER, Petitioner in the above-styled matter, and pursuant to

for Legitimation and Child Custody as follows:

male child born in 2015:

(d) Petitioner has no knowledge or information of any custody proceeding concerning

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

legal or physical, nor in favor of either parent. (Emphasis added.)

Pursuant to O.C.G.A. 19-9-3(a)(2), in determining to whom custody of the child

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

be in the best interests of said minor child.

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

working and supporting herself.

a. That process issue;

d. That Petitioner be awarded final decision-making authority with respect to the

e. That Respondent be ordered to pay Petitioners reasonable attorneys fees and

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

3212 Northlake Parkway, N.E. Tanya Mitchell Graham, Esquire

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

Petitioner, : CIVIL ACTION FILE

I hereby certify that I have this day served

Derric Crowther, Esquire

This 21st day of January, 2017.

THE LAW OFFICE OF

3212 Northlake Parkway, N.E. Tanya Mitchell Graham, Esquire

C:\USERS\TMGESQ\DOCUMENTS\AMENDED PETITION FOR LEGITIMATION AND CHILD CUSTODY.GHAMLER.DOC

IN THE SUPERIOR COURT OF FULTON COUNTY

RULE 5.2 CERTIFICATE OF SERVICE

INTERROGATORIES TO PETITIONER by service on Petitioners Counsel by depositing a

copy of same in the U.S. Mail to wit:

Ms. Tanya Mitchell Graham, Esq.

Respectfully submitted this 27th day of January, 2017.

RULE 5.2 CERTIFICATE OF SERVICE

This is to certify that I have served RESPONDENT S REQUEST FOR

Respectfully submitted, this 27th day of January, 2017.

IN THE SUPERIOR COURT OF FULTON COUNTY

Petitioner, : CIVIL ACTION FILE

PETITIONERS MOTION FOR PROTECTIVE ORDER

Petitioner is a successful singer, songwriter and music producer. As such, Petitioner is a

public person and a celebrity.

Respondent is the mother of Petitioners youngest child, who is aware of Petitioners

media with private information pertaining to Petitioner.

Petitioners seeks a Protective Order to maintain confidential, proprietary, trade secret,

personal and private information as confidential and to provide a mechanism by which

C:\USERS\TANYA2\DOCUMENTS\MOTION FOR PROTECTIVE ORDER.DOCX

entities not entitled to such information.

treatment of all information contained in documents, depositions (including transcripts and

recorded, computerized, electronic, or graphic matter, copies, excerpts, or summaries of

documents (Discovery Material) produced by either party or non-party in this litigation.

and all Confidential Information which shall include:

producing the documents and things, or providing the information) in good

faith reasonably believes will disclose confidential commercial, financial,

personal, or business information that would provide others with an unfair

competitive or improper advantage. Confidential Information also means an

individuals private or personal information which, if disclosed, would

information regarding the personal relationship between the Parties; any

purported misconduct related to the personal relationship between the

Parties; information regarding the Parties minor child; personally-

C:\USERS\TANYA2\DOCUMENTS\MOTION FOR PROTECTIVE ORDER.DOCX

business addresses, e-mail addresses, telephone numbers, social security

numbers, taxpayer identification numbers, and financial account numbers;

contractual relationships with third parties, business interests, partnership