UNITED STATES DISTRICT COURT 2020 FEB -7 p WESTERN DISTRICT OF TEXAS 5.QJ 

AUSTIN DiVISION 

Alexander E. Jones, § 

Petitioner, § 

v. Civi1ActicAlQ:O (Wi 5 LV 

§ Removed from Travis County - Kelly R. Jones, § District Court Cause No. 

Respondent. § D-1-FM-15-oo5o3o (261st Dist). 

Kelly R. Jones' 

NOTICE OF BANKRUPTCY REMOVAL 

28 U.S.C. §1452 and Rule 9027 of the 

Federal Rules of Bankruptcy Procedure 

TO THE HONORABLE JUDGE OF SAID COURT: 

1. I, the undersigned Kelley R. Jones, Defendant/Respondent and 

Counter-petitioner to Alexander E. Jones' Petition to Modify Custody of 

three minor children R.A.J., C.A.J., and G.C.J., hereby file this my Notice of 

Bankruptcy Removal pursuant to 28 U.S.C. §1334 & 1452, as well as Rule 

9027 of the Federal Rules of Bankruptcy Procedure. 

2. This Notice of Removal is Timely because I filed my Involuntaiy 

Petition against Alexander Emric Jones on January 24, 2020. 

3. I attach the docket for 20-10118-hem (through February 4, 2020) as 

Exhibit A to this Notice of Removal. 

4. The Texas Family Code case herein removed both arises from and 

touches upon the same series of transactions & occurrences as give rise to 

Notice of Bankruptcy Removal Pursuant to 28 U.S.C. §1334 & 1452 1 

Case 1:20-cv-00151-LY Document 1 Filed 02/07/20 Page 1 of 5
my involuntary bankruptcy procedure against Alexander Emric Jones, 

arising from my acceleration of his note (See Exhibit B) and deeds of trust 

securing our divorce settlement (Exhibits C & D). 

5. Within the structure and context of the Involuntary Bankruptcy 

proceedings, I plan on foreclosing on his note and selling his houses 

pursuant to the deeds of trust. 

6. The debt constituting the basis for involuntary bankruptcy qualifies 

as a domestic relations debt for the following reasons: 

7. Under current law, a domestic support obligation is defined as a debt 

that accrues before, on or after the date of the order for relief. To qualify as 

a domestic support obligation, the debt must satisfy four requirements: 

[the debt must be] 

(A) owed to or recoverable by 

(i) a spouse, former spouse, or child of 

the debtor or such child's parent, legal 

guardian, or responsible relative; 

or 

(ii) a governmental unit 'ITI' 

(B) in the nature of alimony, maintenance, 

or support 'IT!' of such 

spouse, former spouse, or child of 

the debtor or such child's parent, 

without regard to whether such debt 

is expressly so designated: 

(C) established iTI' by reason of 'IT!' 

(i) a separation agreement, divorce 

decree, or property settlement agreement; 

(ii) an order of a court of record 'ITE 

(D) not assigned to a nongovernmental 

Notice of Bankruptcy Removal Pursuant to 28 U.S.C. §1334 & 1452 2 

Case 1:20-cv-00151-LY Document 1 Filed 02/07/20 Page 2 of 5
entity, unless ITIT assigned voluntarily 

IT[ for the purpose of collecting 

the debt. 

ii U.S.C. § lol(14A) (2006). 

8. There is absolutely no question that the obligations arising from my 

divorce from Alexander Emric Jones evidenced by the documents attached 

in Exhibits B, C, and D qualify as domestic support obligations. 

PRAYER FOR RELIEF 

9. WHEREFORE, I ask, move, and pray that this Court take notice of 

my Notice of Removal pursuant to 28 u.s.c. § 1452. 

10. I pray that this Court honor my demand for trial-by-jury in all aspects 

and elements of the case herein removed, including declaratory judgment. 

ii. I ask, move, and pray that the Court take note of the 261st Texas 

District Court's repeated denial of my equal rights to offer and present 

evidence in Court and its intentional, arbitrary, irrational and unjustified 

denial of equal access to the courts in violation of 42 U.S.C. §1981. 

12. I ask, move, and pray that this Court certify me as a "Class of One" for 

purposes of analyzing the denial of equal protection against me in the 

Travis County District Court's handling of the case of Jones v. Jones. 

13. This court should rea my present Notice of Removal in conjunction 

with my anticipated Rule 59(e) motion to amend or alter judgment, and/or 

under Rule 6o for relief from judgment, of this court's previous rotely 

Notice of Bankruptcy Removal Pursuant to 28 U.S.C. §1334 & 1452 3 

Case 1:20-cv-00151-LY Document 1 Filed 02/07/20 Page 3 of 5
written order of remand filed and entered January 15, 2020 in case i:20-cv00009-LY. 

Signed, Served, and Executed in Austin, Texas, on this Friday, 7th 

day of February, 2020. 

Respecifully Submitted, 

Kelly R. Joiés in jópria persona, 

Removing Respondent, pro se 

From Travis County 261st District Court 

Texas Civil Cause No. D-1-FM-oo5o3o 

ii6oi. Hwy 290 W. 

Suite Alol-3o7 

Austin, Texas 78737 

Designated Legal Ph# 888-995-3559 

Notice of Bankruptcy Removal Pursuant to 28 U.S.C. §1334 & 1452 4 

Case 1:20-cv-00151-LY Document 1 Filed 02/07/20 Page 4 of 5
VERIFICATION 

The undersigned states under oath: "I am the Removing Respondent 

in the above-and-foregoing Notice of Bankruptcy Removal." I have read 

and reviewed the statements contained therein, and all the facts stated 

herein are within my personal knowledge and are true and correct. 

Kelly R. Jo s, pro e 

Petitioner, in propria persona 

Notary's Jurat 

Kelly R. Jones, a person known to me and/or presenting legally 

sufficient identification, SIGNED under oath in person before me on 

y,FebruaIy7,2o. 

TIMOTHYL.STUCKEY 

Notary Public, State of Texas 

Expires SEPT 4, 2023 

ID# 1321 55086 Notary Pub ic, State o exas 

My Commission Expires: C)/0L? (z3 

Printed name of notary: 

Business address of notary: 33°° Bcc ' 

Notice of Bankruptcy Removal Pursuant to 28 U.S.C. §1334 & 1452 5 

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