IN THE SUPERIOR COURT OF NEWTON COUNTY STATE OF GEORGIA In the Interest of: a minor child Petition of MARTHA ANN KNIGHT ) Civil Action File Number: 2023-SU-AD-001 SECOND AMENDED PETITION FOR ADOPTION COMES NOW, MARTHA ANN KNIGHT, Petitioner, by and through counsel, and files this, her Second Amended Petition for the Adoption (hereinafter "Petition") of her great nephew, (hereinafter "Minor Child"), pursuant to O.C.G.A. SS 19-8-?(a) as a qualified relative of the Minor Child; and hereby respectfully shows this Honorable Court as follows: 1. This is a Petition for Adoption of the Minor Child, a male child born in Covington, Newton County, Georgia and is currently six (6) years of age. The Minor Child is a United States Citizen. 2. The Minor Child has resided with Petitioner continuously in her home and been supported by the Petitioner since the Minor Child was ten ( I0) days after birth and coming home from the hospital. 3. Petitioner, MARTHA ANN KNIGHT was born on March 22, 1965 and is presently sixty (60) years of age, widowed and unmarried. Petitioner was born in Covington, Newton County, Georgia, and now resides in Monticello, Jasper County, Georgia. Petitioner has been a resident of said State and County for more than six months prior to the date of filing this instant action. 4. Petitioner is the maternal great aunt of the Minor Child at issue. 5. A copy of the Minor Child's Birth Certificate, identifying the natural mother and father, as well as date and time of birth is attached hereto as Exhibit "A." 6. A Petition (Dependency) was filed in the Juvenile Court of Newton County, State of Georgia on April 21, 2020, in: In the Interest of: -* A child under 18 vears of age. Case Number: 107-201-0203. A true and correct copy of this Petition (Dependency) is attached hereto as Exhibit "B" and incorporated herein. An Order of Adjudication and Temporary Disposition as to the Mother was filed into the same on February 26, 2021. A true and correct copy of this Order of Adjudication and Temporary Disposition is attached hereto as Exhibit "C" and incorporated herein. A Judicial Review Order was filed into the same on October 30, 2024. A true and correct copy of this Judicial Review Order is attached hereto as Exhibit "D" and incorporated herein. A Judicial Review Order was filed into the same on April 24, 2025. A true and correct copy of this Judicial Review Order is attached hereto as Exhibit "E" and incorporated herein. (hereinafter "Juvenile Orders"). 7. A Guardian Ad Litem was appointed to the Minor Child in the above Dependency action, to wit: DeVona B. Roseberry, Esq. who filed her Guardian Ad Litem Reports on October 6, 2022 and September 26, 2023. true and correct copy of this Order of Adjudication and Temporary Disposition is attached hereto as Exhibit "F" and "G" and are incorporated herein. 8. Petitioner, being Temporary Guardian / Custodian to the Minor Child, remains the primary physical custodian as ordered by the Juvenile Court in their Juvenile Orders. Petitioner was subject to the Department of Human and Family Services inspections on a few occasions to her memory. Petitioner requests that after the Court reviews this Petition, the Court direct Petitioner if an outside home study is still needed to complete the case. If so, Petitioner will promptly schedule the same. 9. Should the adoption prayed herein ultimately be granted, the Minor Child shall have his name changed and shall further be known as with Vital Records amending his Birth Certificate to list Petitioner as his Mother and to remove any father from his Birth Certificate. Second Amended Petition for Adoption In the Interest of: a Minor Child I Petition of Martha Knight Newton County Superior Court I CAFN: 2023-SU-AD-0011 Page 2 of5 10. Said Minor Child is not possessed of any property and the only prior action concerning the custody and visitation of the Minor Child is juvenile case cited above, which is an action for Dependency of the Minor Child and has been classified as a "Non-Reunification" case. 11. Said Minor Child has two natural parents in life, the same being his natural mother, MADISON MARY TYLER (hereinafter "Biological Mother" or "Parents"), and his natural, putative, father, CASEY RHODES SEALY (hereinafter ''Putative Father" or "Parents"). 12. The biological father to the said Minor Child is still living as defined in O.C.G.A. SS 19-8-13 (a)(I)(F). 13. The natural, biological, and putative father of the Minor Child is CASEY RHODES SEALY. The original Certificate from the State of Georgia's Putative Father Registry is attached hereto as Exhibit "H." Pursuant to O.C.G.A. SS 19-8-10(d), and in lieu of attaching the Surrender of Rights, Final Release for Adoption, and Acknowledgment of Surrender of Rights, Petitioner states the following in support of tenninating the putative father's rights: (a) The natural father has not contributed to the Minor Child's mental, financial or emotional wellbeing in more than five (5) years, and (b) The natural father's whereabouts remain unknown to the Petitioner. 14. The natural mother to the Minor Child is MADISON MARY TYLER. Pursuant to O.C.G.A. SS 19-8-10(d), and in lieu of attaching the Surrender of Rights, Final Release for Adoption, and Acknowledgment of Surrender of Rights, Petitioner states the following in support of terminating the natural mother's rights: Second Amended Petition for Adoption In the Interest of:- a Minor Child I Petition of Martha Knight Newton County Superior Court I CAFN: 2023-SU-AD-001l Page 3 ofS (a) The natural mother has not contributed to the Minor Child's mental, financial or emotional wellbeing in more than five (5) years, and (b) The natural father's whereabouts remain unknown to the Petitioner. 15. Petitioner requests that Service by Publication be completed pursuant to O.C.G.A. SS 19-8-10(c) will be published in the Covington News, the official organ of Newton County, State of Georgia. Newton County being the county of the filing of this Petition and being the county of the last known addresses of both the natural mother and the natural father. Petitioner's Motion for Service by Publication is being filed contemporaneously herewith. Once the Affidavit of Publication is received from the Covington News, it shall be promptly filed with the Clerk of Court and provided to the Court. 16. Petitioner has no information of any past or present proceeding, other than those referenced herein, that could affect the current proceeding including proceedings for enforcement and proceedings relating to family violence, protective orders, termination of parental rights, or adoptions concerning this child which is now pending or has previously been pending in this state or in any other state. 17. A completed form containing Background Information regarding the child to be adopted, which has been completed to the best of Petitioner's ability and is attached hereto and incorporated herein as Exhibit "I," in accordance with O.C.G.A. SS 19-8-13(a)(4)(G). 18. Petitioner respectfully shows that she is financia]]y, physically, and morally fit, as well as mentaJly able to assume the full responsibility of permanent custody of the Minor Child. Petitioner prays for the completion of this adoption by virtue of her love and affection for said child and out of her desire to contribute to the preparation of said child for the requirements oflife. The Petitioner's Verification verifying the truth of the contents of this Petition is being filed contemporaneously with this Petition. Second Amended Petition for Adoption In the Interest of-: a Minor Child I Petition of Martha Knight Newton County Superior Court I CAFN: 2023-SU-AD-00l l Page 4 ofS WHEREFORE, the Petitioner respectfully prays: (a) That this Honorable Court issue an Order for Publication for service of process and Summons by publication; and (b) That the Court grant unto the Plaintiff such additional relief as it deems just and necessary under the circumstances. Respectfully submitted this 2nd day of April, 2026 THE FROST FIRM 2115 Usher Street. N.W. Covington, Georgia 30014 Telephone: (678) 625-1994 Bryan@TheFrostFirm.net Chelsea@TheFrostFirm.net Sarah@TheFrostFinn.net Attorney for petitioner Georgia Bar No. 278274 PUBLIC NOTICE #704013 4/19,26,5/3,10