IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA | DC Y RE THE MARRIAGE OF C ih DISTRI gues Petill ee 26 and — Case Ro: FD) 2 017-7 44 MAR 1 ve ANDREW BRAME, FD Docket A RRA HER) cot APPLICATION FOR TEMPORARY ORDERS COMES NOW Petitioner, Abigail Brame, and in support of this Application for Temporary Orders, alleges and states that: 1 Petit n. The verified Petition for Decree of Dissolution of Marriage of the Petitioner was filed with this Court on or before the date of filing this Application, 2. Temporary Orders. Petitioner seeks a Temporary Order under 43 O.S. §110 granting temporary relief during the pendency of this action. = Summons With Autom: Temporary Injunction. The provisions of the Automatic Temporary Injunction in effect herein should remain in effect except as they may be specifically modified by the Court, ‘The relief sought in this Application is in addition to the relief granted by those provisions. 4 Custody. Petitioner seeks the following Orders with respect to the custody of the parties’ minor child, namely: R.C.B. born April 22, 2013 a, The Petitioner requests temporary joint care and custody of the minor child, with Petit mer designated as the primary custodial parent. b. The parties should be awarded equal visitation with the minor child. 15. Child Support. Each party should be required to contribute to the support of the minor children as required by law. 2. Marital Property. The parties have not agreed on the use of property, payment of debts, and access to funds. The Petitioner seeks Orders granting to her temporary exclusive possession of the following items of property during the pendency of this action: a. Petitioner: i, All personal property acquired by her prior to marriage; fi, All separate property acquired by her since the date of separation; iii, All marital property currently in her possession, including, but not limited to: (1) Petitioner’s car. 6. — Marital Debts. The Petitioner seeks an Order that the Respondent pay the following marital debts during the pendency of this action: a. Half of all marital debts including but not limited to credit card debt. 7. Respondent should be ordered to pay Petitioner’s reasonable attorney's fees. WHEREFORE, the Petitioner respectfully requests the Court to issue a Temporary Order granting the above relief and all such other and further relief as may be just and equitable, Respectfully Submitted, CLLhhiam LlenconBryan Stratton, OBA #21550 William Duncan, OBA#32610 Bryan Stratton, PC 7136 South Yale Avenue Suite 300 Tulsa, OK 74136 Tel. 918-779-3715 Counsel for Abigail Brame ATTORNEY’S LIEN CLAIMED NOTICE OF HEARING Hearing is scheduled upon the Application for Temporary Order Hearing in the ‘Tulsa County Courthouse in Tulsa, Oklahoma on the day of 52017 at before Judge - Ifyou do not appear at the scheduled hearing, judgment may be rendered for the Petitioner for the relief sought in her Application.VERIFICATION STATE OF OKLAHOMA. ss. COUNTY OF TULSA 1, Abigail Brame, being of sound mind and legal age do hereby swear and state as follows: 1, Ihave read the above and forgoing Application for Temporary Orders, know the contents thereof, and state that the same is true and correct to the best of my knowledge. Subseribed and sworn to before me this | day of MO p17 Deltora Notary Public “ASHLEY We NOTARY PUBLIC SSTATE OF OKTAROMA. TULA COUNTY “COMMISSION NG, 4011880IN THE DISTRICT COURT IN AND FOR TULSA COUNTY “STATE OF OKLAHOMA 54 In Re the Marriage of ) Sur ae aorenes 12 PM Su 2 58 a Se gf Petitioner, ) Case No. FD-2017-744 = ee ) BEB and } ED Docket A ay gs Judge Clifford Smith ge ANDREW BRAME, ) & Respondent. ) CUSTODY ORDER PETITIONER'S APPLICATION FOR EMERGENCY EX PARTE. cones NOW the Pion AEM Mose" sa fr ber pptieaton states and alleges as follows: Emergency Ex Parte Custody Order, 1. Petitioner filed a Petition for Dissolution of ‘Marriage on March 17, 2017. 3, The patties are the parents of five year old child, RC .B, born in April 2013. 5, This Court has continuing jurisdiction over the Divorce, and UCCJEA jurisdiction of the child as the child has and continues to reside in Tulsa County. The child is not of Native “American descent and ICWA does not apply. 4. The parties reached an agreement for joint custody and 50/50 visitation, but did not agree as to the choice of school. 5, Trial was held on July 13, 2018 on the school issue only. At that time Judge ‘Anthony Miller ruled that Mother should be primary custodian with the right to choose the school. Counsel for Mother drafted a proposed Decree of Dissolution and Joint Custody Plan 1, Jonathan Nation some time ago. To date the Deeree has and sent them to Respondent's couns' oo —-__—-* 6. “ibekaownst to Moher, Respondent Tae” had pening xn carss st “getine tin Ts Coty CM 2018252, Tate tls Pon_ctmetanpean, pergola spring ote mF 9 Se these pending charges to Mother ot the Cour 7. On November 5, 2018 Father entered a plea of guilty as to all the charges, and. was given a one year deferred sentence by Judge April Siebert. 8. Less than one month: later, on November 27, 2018, the District Attorney’s office filed a Motion to ‘Accelerate based on an arrest and charge for ‘Assault and Battery, occurring on November 23, 2018, City of Tulsa case number 704118. See, Application to Accelerate, attached as Exhibit A. 9, Then within 2 days of the filing of the Application to Accelerate, and week after the assault and battery incident, Father was again arrested for possession: of methamphetamine on November 29, 2018 and charged in Tulsa County Case (CM-18-5761 on December 4th. 10. i. Father has started a YouTube channel, Not Now Maybe Later, {[htips://www. youtube. com/channel/UCT? ‘Zheal 6NjPvWxh1 S2syWwivideos} in which Father ‘has posted over 51 videos in the last month in which Father goes into various municipal police departments including the Bixby Police Department, the City of Glenpool Police Department, ‘The City of Okmulgee Police ‘Department, Okmulgee County Sheriff's Department, Sapulpa Police Department, among others, and videotapes them in an apparent effort to provoke a response and confrontation. He has done the same thing with libraries, including videotaping at the Central Libre rrr—-—“=éee_ library, causing concern and then ultimately escalating into conflict as worried seourity guards ask him to stop filming them and customers and ask him to leave.12, Petitioner appears to engage in these filmed provocations as a nearly full-time activity. Styling himself as a sort of crusader, he has started a Go Fund me account in order to fund this. Https:/hvww gofundme.com/accountability-and-transpareney. 13. At the time of the trial in July, Father did not have his own home, but lived in the home of friends. Recently in his bond paperwork in CM-18-2892 he lists his home address as 415 W. Archer. See, Bond form, Exhibit B. That is the address of the Day Center for the Homeless. 14, The child reports that Father has told her to keep secrets from Mother. The Child specifically reports that Father does not use a seatbelt on the child. The seatbelt had been previously raised as an issue in this litigation resulting in a specific Order from the Court in the Agreed Temporary Order file on October 25, 2017, at paragraph 15 “Bach party is ordered to Properly restrain the child in an age and weight appropriate booster seat or child safety seat any time the vehicle is in motion.” 15. The charge regarding carrying a loaded gun in the vehicle is of concem, in part due to Father's escalating tendency to provoke confrontation with law enforcement and other civil servants, as evidenced by his YouTube channel, and partly because of an event at which Mother was present. Mother was in the car with Father on one occasion years ago in which he was carrying a loaded firearm. Another car followed Father too closely. Father and the other car then engaged in an exchange in which they each brake-checked the other, and then Father lowered his driver's window and pointed the loaded gun at the other driver. Petitioner is concemed about Father's possession of a gun, while he is on drugs and engaging in daily confrontations with law enforcement and security.16. Petitioner/Mother is extremely concerned that the child will suffer irreparable harm if this Application is not granted. Respondent/Father’s aggressive and combative behavior at libraries and police departments over the last month is unusual for him, and not his normal demeanor. 17. Petitioner fears for the child’s physical safety and is worried the child will be exposed to methamphetamine and the anger and aggression associated with meth consumption if Respondent is allowed unsupervised custodial time with the child. 18. Petitioner requests that Respondent be ordered to pay the costs of this action. 19, Respondent's counsel, Jonathan Nation, has been given notice of presenting t Application. WHEREFORE, Petitioner prays that the Court grant temporary custody to her until a hearing on this matter; and for such other and further relief as the Court deems just and proper. fi £ Kirsten I. Bemhardt, OBA #11755 401 S. Boston, Suite 415 Tulsa, Oklahoma 74103 (918) 582-0982 ‘Attorney for Petitioner CERTIFICATE OF MAILING 1, Kirsten I. Bernhardt, do hereby certify, that on this _// day of December, 2018, a true and correct copy of the above and foregoing was placed in the United States mail, postage prepaid thereon, to: Jonathan Nation 624 S. Denver, Ste 300 Tulsa, OK 74119 LLL he Kirsten I. Bernt itIN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA Tn Re the Marriage of: ) ) | Petitioner, ) Case No. FD-2017-744 ) and ) FD Docket A ) Judge Clifford Smith ANDREW BRAME, ) Respondent. ) AFFIDAVIT OF PETITIONER’S PERSONAL KNOWLEDG: STATE OF OKLAHOMA) ) ss COUNTY OF TULSA) ; | being first duly sworn, do hereby depose and states as follows: 1. Tam the natural mother of the parties’ child, R.C.B., born in April, 2013, 2. Thave first hand knowledge of the child subject to these proceedings. 3. I believe the child is in imminent harm and danger if Respondent is allowed to take the child in his custody without supervised visitation. Respondent was recently arrested for possession of methamphetamine [see Tulsa County Case No. CM-2018-5761] and recently pleaded guilty (with the court deferring sentencing) in a separate action to possession of a controlled drug, possession of paraphernalia and transporting a loaded firearm [see Tulsa County Case No. CM-2018-2892]. He is also currently charged with assault and battery in Tulsa Municipal case number 704118, 5. My child told me that Respondent has asked her to keep secrets from me, and specifically that he is not properly buckling her in while in the car or using proper child restraint,6. Thave witnessed Respondent point a loaded gun on another driver as a result of a road rage incident years ago, and fear that given this history, the loaded gun in his car together with recent aggressive incidents place my child in danger. 7. Respondent's physical appearance has deteriorated in the last six months consistent with use of methamphetamine 8. I recognize Respondent in the YouTube videos on the Not Now Maybe Later channel in which he is repeatedly provoking and antagonizing law enforcement officers and security at public locations such as public libraries. 9. fear for our child’s safety due to Respondent's usage of methamphetamine and the anger and aggression he has been exhibiting, 10. I have seen the bail bond document in which Father lists his address as the homeless shelter. 11. Tam seeking this Court’s intervention to secure and protect the minor child. 12. I incorporate herein by reference the Application for Emergency Ex Parte Custody Order and state that to the best of my knowledge, the application is truthful and accurate. FURTHER Affiant sayeth not. Subscribed and sworn to before me this \\ day of December, 2018, oa Wl yoru mmission Expit TATEE MARIE AUSTIN eee Notary Pubic, Stet of Oklahoma My Commission Number: uy Pui tatoo Onan My Commission Expires 03-06-2022|IN THE DISTRICT COURT IN AND FOR TULSA COUNTY * ‘STATE OF OKLAHOMA STATE OF OKLAHOMA KayRICT COU! Plaintiff, | e 4 £ La 7 vs. ‘Case No. CM-2018-2892 NOV 241 2018 IN NEWBES: ANDREW D BRAME pl ‘OF Of. APPLICATION TO ACCELERATE JUDGMENT AND SENTENCE ‘Comes Now STEPHEN A. KUNZWEILER, the duly elected and qualified District Attomey for Tulsa County, State of Oklahoma, and shows to the court that heretofore the above named defendant ‘was charged by Information(s) filed in the District Court of Tulsa County with the crimes of UNLAWFUL POSSESSION OF CONTROLLED DRUG, UNLAWFUL POSSESSION OF DRUG PARAPHERNALIA, TRANSPORTING LOADED FIREARM IN MOTOR VEHICLE, FAILURE ‘TO CARRY INSURANCE/SECURITY VERIFICATION FORM and thereafter on 11/05/2018 centered his plea of GUILTY to the seid charges of UNLAWFUL POSSESSION OF CONTROLLED DRUG, UNLAWFUL POSSESSION OF DRUG PARAPHERNALIA, TRANSPORTING LOADED FIREARM IN MOTOR VEHICLE, FAILURE TO CARRY INSURANCE/SECURITY VERIFICATION FORM before the Honorable April Seibert, Judge of the District Court of Tulsa County. ‘Thereafter, on 11/05/2018 the Court WITHHELD A FINDING OF GUILT AND DEFERRED SENTENCING for a term of ONE (1) YEAR. Subsequently, the defendant was released from custody and placed under the supervision ofthe Distriet Attorney’s Office, Probation Division, subject to certain written Rules and Conditions of Probation with the defendant's deferred sentence being conditioned upon the defendant abiding by said Rules and Conditions of Probation. ‘The District Attomey has been informed and alleges and states that the defendant has, subsequently failed to comply with the Rules and Conditions of Probation entered in the above entitled ‘and numbered cause(s) in that: Rule #9: I will not violate city, state or federal laws and will notify the Supervising Authority within forty-eight (48) hours of any arrest or contact with law enforcement. On or about November 23, 2018 in Tulsa County, State of Okiahoma and within the.) | jurisdiction of this court, did commit the crime of Assault and Battery: a MISDEMEANOR, Exhibit "A"by unlawfully, willfaly, and wrongfully, commit an Assault and Battery upon the person of one Jennie Atkins as alleged in Incident Number 2018071616, set before the Tulsa Municipal Wherefore, the State of Oklahoma requests thatthe deferred sentence entered inthe above entitled and numbered cause(6) be accelerated. The State further requests that a bench warrant be issued for the defendant's apprehension and that a detention hearing be ordered set within a reasonable time after the defendant's apprehension, and further, thatthe court order subpoenas issued forthe following persons : to attend said hearing and testify on behalf of the State of Oklahoma. Stephen A. Kunzweiler ‘Tulsa County District Attomey By, tate ‘Randall D. Young, OBA #33646 Assistant District Attorney WITNESS(ES) ENDORSED FOR THE STATE OF OKLAHOMA Kaily Obrien DA Supervison ‘Tulsa, OK 74103, 500 S. Denver Ave., Ste. 109 Officer D. Shipley 600 Civic Center Tulsa, OK 74103, Officer 8. Downie 600 Civie Center Tulsa, OK 74103,OSCN Case Details hntp/www.oscn.netdockets/GetCaselnformation.aspx?db=tul OKLAHOMA @ State Courts Network “he information on this page is NOT an official record. Do not rely on the correctness or completeness of this information. ‘erify all information with the official record keeper. The information contained in this report is provided in compliance with the >klahoma Open Records Act, 51 0.8. 244.1. Use of this information is governed by this act, as well as other applicable state Ind federal laws, IN THE DISTRICT COURT IN AND FOR TULSA COUNTY, OKLAHOMA No. CM-2018-2892 (Criminal Misdemeanor) State of Oklahoma v. BRAME, ANDREW D Filed: 07/05/2018 Closed: 11/05/2018 Judge: Traffic Court Judge (General) CASE MAY BE ELIGIBLE FOR ONLINE PAYMENTS, PARTIES 3RAME, ANDREW D, Defendant dklahoma Highway Patrol, ARRESTING AGENCY STATE OF OKLAHOMA, Plaintiff ATTORNEYS Attorney Represented Parties Persons, Tracey Elizabeth (Bar #15395) BRAME, ANDREW D 616 South Boston Ave Ste 307 Tulsa, OK 74119 EVENTS Event Party Docket Reporter ea eee BRAME, ANDREW D Arraignment Docket eee ene Cae BRAME, ANDREW D Arraignment Docket Uirencmesns cape Coo BRAME, ANDREW D Arraignment Docket Monday, October 1, 2018 at 9:00 AM ‘JURY TRIAL SOUNDING DOCKET BRAME, ANDREW D Traffic Court Judge (General) 1of 12 12/11/2018, 1:57 PM‘APPEARANCE BOND oo COURT See ato my ro ‘STATE OF OKLAHOMA, at EEC "b> * NOV 302018 no, Crm - 18-269 Aadrus I. Grammer aan BME OF OA TAA KNOW ALL MEN BY THESE PRESENTS, Tat 7 we the dove sued dfendent a princi ed the warned bonita, cosporton an oer signers a see Foiagandsevgrillyacknowipge ourslves o ove and be indebigdo te State of Ollaboms inthe vam of hen’ feouson od Dotan @ 25, 628 Ste lved on eur pope veal {a penoml oak depts sd ecw da, cc ad he nf Sen of Oi “Tie CONDITION Of Ts POND Is SUCH tif he sovenuned deendan sow chased ia he Dist Cou of Tal siete tm el We oe = gon il gol ps dala de a ac Sooebonte La ayot Sere ects ripen pony has Stator fend sy dyad ver ten ree arte rn tf day of eno fu tm of eid Com {Evo ode and om uy oy and tem erm hte a red by wd Coy do dep hrf wow lee td shal do and recive what shal be ejoined pon his hy sid Cou, utilis au ix inal determined theo tis bond 0 be ‘id oterve tobe nl force and ect. pe nanser Ont) Beane nate US poe Al ther Tolon, ol 74103 ess ore Adios L IPSS Teg DELTAS Deed Se nd per i 24 aay wa ore s So AFFIDAVIT AS TO UNDERTAKING AND QUALIFICATIONS OF SURETY STATE OF OKLAHOMA, COUNTY OF TULSA, SS “The vadeigaed essed boodsnss, being daly ss, oth sat: ‘That neither he or the, 20% anyore for his O here, bas bese promised or has receied any svat or conidestion for Soorherannting ocr th Consideration recived ot proased § 1, 06D Se ior oni no oer dish ome oe) ee Ope soe eens © area Alen Nese ‘Adie “That he or she is presen daly Heensed,repstered and nal ropes authorized by Iw to become arty i his undertaking 5905, 41501 erg 2208, 61101 seg! 12 OS, #60 er eg, 22 OS, #150. ‘That he or she is worh doable the sum tobe scered, over and above alt exemptions, Abts aad labile, 12 0S, 6 130% et seq 2208, #1101 et seq; 12 OS, 461 ese "That he or she as noe signed or counesgaed this bond in Man, or bas he or the gen a pome of attorney to, or otherwise surhosze, any person to courterign his or her ate otis boo valers hat person ia leensed bondsman dec employed by ‘bondsman gg such power of story, 59 OS, $136. ‘That he or she har atached hereto si tceipts fr collate accepted by him or her, filly desebed in deta, 9 OS. #1314; $905, 4182 "That he ot she is auchaxzed and legly capable, in al respects, to enter nto tis aodectaking, both personaly ado bibs ofthe crporte sey abore-atne snd tht this wadertakig is witho, and doesnot excecd the listatons sn conditions of the over of storey grand him or he ysl corporate sey al pasuac fo $9 OS, 41320, “That he or she farllar wih he provisos of OKbota State ropa he elect of defect, mlsions and iregslaces in sachuaderaings, 59 OS, § 1325. “Tava gl egrets of icesing estan and ceication hve bees mt by this bondsman, 59 OS, § 1320. ‘Tha the Boodsman fll anderstanct tha will mitten of any cnc fas herein muy abject him a ext poseetion for pray and/or 0 proceedings tsk dei rpnson oy treason of he bondymaa's cere 59 OS, $1340. ‘Thabo hes weaken ofthe County of Oli 5 = teem psnaeipwpon is 4 ayoe_flow 2018 easy ped TTaoenw net be Oeil pon wo coal iia regimen Soci mrs acne esi ie vom ot ond Sed Gen ear ysgol foe os ‘etd ute wen Oo S = ExhibitNOTTOEXCEED $100,000 POWER OF ATTORNEY POWERS OF ee TOOK KNOWALLMEVAY THESE PRESENT 136224 SPRINGER, OKLAHOMA TBIS6 deka Pitcher, of Springer, Oklahoma, Carter County, State of Oklahoma, have made and constituted and appointed by these Pyne ag make, constitute and appoint the below named agent, my true and lawful attomey,for me and in my name, pact aod seat ontag forthe purpose this__ OC day oe I 20 at fobe— rv a Pletcher’ case Nomter_ CN 1B DEG Mati Conny Age Bondsman Bond Amount $_ [0p 20> pppoe dae ID le=18 - GanrBen |NOMA Hp, IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA a “tag, Bey In Re the Marriage oft D oy % 4 yee ca Oi, 8 FY OG ) "May, Petitioner, ) Case No. FD-17-744 ‘ing ) and ) FD Docket A ) ANDREW BRAME, ) ) Respondent. ) CONTEMPT CITATION TO: Andrew Brame 14072 S, 26" E Ave Bixby, OK 74008 THIS matter coming on for hearing on this@G upon Petitioner's Application for Contempt Citation, ‘The Court orders that a citation for contempt should issue against Respondent, Justin D. Berry. and a hearing should be held IT IS THEREFORE ORDERED that you, the Respondent above named be and you are hereby cited for contempt of court for your failure to obey the orders of this Court as set forth in Petitioner's Application for Contempt Citation, YOU ARE THEREFORE COMMANDED AND ORDERED to appear in person with your attorney on the 1™ day of Awuse —_, 2019, at__]__o'elock 4m. before the undersigned Judge of the District Court of Tulsa County, courtroom $71, for your arraignment on the charge of indirect contempt of court. If'you cannot afford an attomey, one will be appointed for you. YOUR FAILURE TO APPEAR MAY RESULT IN A WARRANT FOR YOUR ARRE! Page 1 of 2Prepared by Kirsten I. Bernhardt, OBA #11755 401 S. Boston Avenue, Suite 500 Tulsa, Oklahoma 74103 (918) 582-0982 Attorney for Petitioner Page 2 of 2ony e e OU @) IN THE DISTRICT COURT OF TULSA COUNTY | STATE OF OKLAHOMA = vs case no, eo 1T- 144 Budrew Brame ) FDDOCKET A Is RESPONDENT ‘ Fe Tge gor COURT ORDER soy OCF 16 aay Oct Ne, 2014, HE "Reapeale mph as tie a acc get ty & hin Sail b Ei) fae Scazace be stayed Pendial romlpnce jet moval of anne 7 Social meald aboot child fro c teins from add Fienal posh. Attorneys Fees pafiog Asa Hitherbbseh I Parlier Seabed Dome gee ‘GUARDIAN AD LITEMIATTORNEY FOR MINOR CHILD