Plaintiff, §

v. § Case No.

Defendant. §


NOW COMES Sarah Keeney Schneider, Plaintiff, and files this Complaint against Melanie
Schneider, Defendant, and for cause would show this Honorable Court as follows:


1. Plaintiff Sarah Keeney Schneider is a law-abiding female adult of sound mind and
a resident of 8912 Spring Lake Dr., Austin, TX 78750.
2. Defendant Melanie Schneider is a female adult of sound mind and a resident of
[Insert Address].


3. Jurisdiction exists in this Court pursuant to Article V, § 8 of the Texas
4. Venue is proper in this Court because the causes of action that give rise to this
Complaint took place within Travis County.


5. Plaintiff was married to Steven Schneider, the son of Defendant.
6. During the time that Plaintiff was married to Defendant’s son, Defendant always
made efforts to alienate Plaintiff from her daughters. She intentionally ensured that Plaintiff is
not in their lives.
7. At a dance competition where Plaintiff’s daughter was participating, Defendant
ensured that Plaintiff was the only mother who did not participate.
8. Defendant has repeatedly made posts on social media that are meant to disparage
Plaintiff. She has also called her obscene names such as “cunt” and “little bitch.”
9. Defendant has taken actions to ensure that Plaintiff does not have a parental
relationship with her daughters.
10. Defendant allowed her son to constantly abuse Plaintiff. Defendant herself was
abused for more than 40 years by Steven’s father who died in a drunk boating accident last year.
11. Whenever Plaintiff sent gifts to her daughters, Defendant would throw them away
or remake them and take credit for the gifts.
12. Defendant has lied to Plaintiff’s daughters that their father is not abusive, even
though they witnessed the abuse which is documented in a report.

Alienation of Affections

13. Plaintiff hereby incorporates by reference the contents of ¶ 1-12 of this Complaint
as though set out in full herein.

14. “The common law also recognized a father’s right to recover for loss of filial
consortium caused by certain direct injuries to his relationship with his child, excluding
alienation of affections, but it did not extend that recovery, as for loss of spousal consortium, to
indirect injuries to the relationship. Prosser 124, at 924-29, and § 125, at 934-35; Restatement of
Torts §§ 699-707 (1938); Restatement (Second) of Torts §§ 699-707 (1977).
15. The common law did not extend to wives and mothers the recovery for loss of
consortium afforded husbands and fathers, principally because married women were subject to
legal disabilities and were not legally entitled to the service of their husbands and children. With
the statutory removal of those disabilities came the recognition that women should have the same
rights as men to sue for loss of consortium. Prosser 124, at 916-17; Restatement of Torts § 690
comment a (1938); Restatement (Second) of Torts § 683 comment d (1977).” Reagan v. Vaughn,
804 SW 2d 463 (1990).
16. Defendant perpetrated the alienation of affections when she prevented Plaintiff
from seeing her daughters, blocked Plaintiff’s participation in her daughter’s dance competition,
and threw away Plaintiff’s gifts to her daughters or remade them and took credit for them.
17. As a result of Defendant’s actions, Plaintiff was not able to have normal,
meaningful mother-daughter relationships with her daughters. She experienced untold suffering
and mental anguish as a result of Defendant’s actions.
18. Plaintiff has spent thousands of dollars in undoing the damage that Defendant has
19. Defendant is liable for alienation of affections and ought to pay damages to


REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests this
Honorable Court to grant her the following reliefs:
a. GRANT judgment in favor of Plaintiff and against Defendant;
b. AWARD Plaintiff damages for alienation of affections in the sum of $___________;
c. AWARD Plaintiff punitive damages;
d. AWARD Plaintiff costs of this suit;
e. AWARD Plaintiff pre- and post-judgment interests;
f. AWARD Plaintiff such equitable relief as this Court deems fair; and
g. AWARD Plaintiff such further relief as this Court deems proper.

Dated this ____ day of September, 2022.

Respectfully Submitted,

Sarah Keeney Schneider,
Plaintiff in pro per


I, Sarah Keeney Schneider, being duly sworn depose and say that I am the Plaintiff in the above
action, that I have read the foregoing Complaint and know the contents thereof. That the same is
true of my own knowledge except as to those matters and things stated upon information and
belief, and as to those things, I believe them to be true.

(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this ____ day of September, 2022.

Notary Public

(Printed Name of Notary Public)

My Commission Expires:


I hereby certify that a true and correct copy of the foregoing document was sent on the ____ day
of September, 2022 by regular U.S. mail, by facsimile, or certified mail, return receipt requested,
to the following party of record:
Melanie Earl Schneider
Insert Address
Insert State & ZIP Code
Insert Phone Number
Insert Email

Dated this ____ day of September, 2022.

Respectfully Submitted,

Sarah Keeney Schneider,
Plaintiff in pro per

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