PETITIONER/FATHER’S VERIFIED MOTION FOR TEMPORARY INJUNCTION TO PREVENT REMOVAL OF MINOR CHILD AND/OR DENIAL OF PASSPORT SERVICES
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
In Re: The Matter of Case Number:
JACK KING,
Petitioner/Father,
and
JAMIE CROWN,
Respondent/Mother.
________________________/
PETITIONER/FATHER’S VERIFIED MOTION FOR TEMPORARY INJUNCTION TO PREVENT REMOVAL OF MINOR CHILD AND/OR DENIAL OF PASSPORT SERVICES
The Petitioner/Father, JACK KING, requests the Court to set a hearing to
enter a temporary injunction to prevent removal of the following listed minor child from the
jurisdiction of this Court and deny passport services for the child and says:
- The minor child subject to this request is:
JM, born on xx/xx/20__ in Florida.
- The child has been a resident of Broward County, Florida since birth.
- The Petitioner, JACK KING, is the Father of the minor child,
JM, born on xx/xx/20__ in Florida
- A completed Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), Florida Supreme Court Approval Family Law Form 12.902(d) is filed with this Motion. The Father has had 100% timesharing and sole parental responsibility of the minor child in that the child has been residing with the Father exclusively and continuously for the last four (4) years.
- It is in the best interests of the minor child that the Court set a hearing to order the following:
The child not be removed from the jurisdiction of this Court. The child has been residing with the Father exclusively and continuously for the past four (4) years and has been in the Father’s school district receiving A’s and B’s. The Mother has been residing in Pennsylvania while the child has been living here with the Father. The Mother has been in and out of drug rehabilitation.
- It is imperative that this Motion be granted as same is in the child’s best interests.
WHEREFORE, the Petitioner/Father requests the following from the Court: Set a hearing and enter a temporary injunction to prevent removal of the child named above from the jurisdiction of this Court while this action is pending.
Under penalties of perjury I declare that I have read the foregoing petition and that the facts stated in it are true to the best of my knowledge and belief.
_____________________________
JACK KING
STATE OF FLORIDA )§:
COUNTY OF BROWARD )
BEFORE ME, the undersigned authority, personally appeared JACK KING who is known to me or who produced a Florida Driver’s License as identification, under penalties of perjury and having been sworn under oath, verifies that the above contents and information is true and correct to the best of she personal knowledge and that she executed this document this _____ day of ________________20__.
WITNESS my hand and seal in the State and County aforesaid this ______ day of _____________ 20__.
___________________________
NOTARY PUBLIC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to: Jamie Crown, by personal service.
LAW OFFICE OF LARRY D. SCHOTT
Attorneys for Father
By:____________________________
LARRY D. SCHOTT, ESQUIRE
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