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MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

 

In Re: The Former Marriage of                                          Case Number:

 

JAMIE CROWN,

 

Petitioner/Former Wife,

and

 

JACK KING,

 

Respondent/Former Husband.

_____________________________________/

MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

The Petitioner/Former Wife, JAMIE CROWN, requests that the Court enter an order appointing a guardian ad litem with all powers, privileges, and responsibilities authorized in section 61.403, Florida Statutes, and states:

  1. There is currently pending before the Court is a Petition for Modification of Shared Parental Responsibility to Sole Parental Responsibility and Petition for Modification of Child Support and Enforcement of Child Support.
  2. The following minor children are subject to this proceeding to wit: XX,

born on xx/xx/20__, XX, born on xx/xx/20__, XX, born on xx/xx/20__

  1. The Petitioner/Former Wife believes the Respondent/Former Husband has a drug problem which impacts his parenting abilities and is dangerous to the minor children. The Former Husband smokes marijuana and uses poor judgment regarding the children as reflected below.
  2.         On Friday, XXXXXX XX, 20__ the children went for timesharing with their Father.  The youngest child, XX, had been sick and was still taking antibiotics.  On Saturday, XXXXXX XX, 20__  the Former Wife went to the Paternal Grandmother’s house, where the children were to give the child her antibiotics.  The older daughter said they were just getting ready to go into the pool.  The Former Wife told them it was too cool out to go in the pool and all of the children had recently been sick and the youngest child had been sick to two (2) weeks and had just had tubes put into her ear.  The Former Wife received a text from the Former Husband Saturday night that the oldest child was running a fever and had a sore throat asking what he should do.  On Sunday, XXXXX XX, 20__ the Former Wife called to check on the youngest child.  The Former Husband when asked did inform the Former Wife that the children had gone into the pool on Saturday.
  3. When the children returned home from their Father’s the oldest daughter informed the Former Wife not only did the youngest child go into the pool she almost drowned and busted her lip when she jumped into the pool.  The child said there was no adults outside in the pool area that they were all inside the house.  The child said that the Paternal Grandmother told them not to tell their Mother.  The child told her Father she wanted to tell her Mother, but the Father told her not to tell her.
  4. The Former Wife sat the children down to discuss when it is okay to keep secrets and what to do if an adult tells you to keep secrets from your parents.
  5. The oldest child then proceeded to tell his Mother that during his last visit (XXXXXXX XX) the Father took him to go buy drugs.  The child said he was really scared because his Father had been drinking a lot and was driving really fast and blasting the music.  The child was able to tell his Mother the area in which his Father took him because his Father was bragging about a prior accident he had on that street in the Former Wife’s automobile and left the scene of the accident and come back because he had drugs in the car.   The child said they went to the corner store and his Father purchased wrapping stuff and saw his Father hold up the bag of drugs and flicked the contents and then he watched him roll up the packaging.
  6. For all these reasons, it is in the best interests of the children for a Guardian Ad Litem to be appointed.

 

WHEREFORE, the Former Wife requests a Guardian Ad Litem be appointed and same is in the best interests of the children and any other relief deemed necessary by the Court.

 

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.

 

________________________________

JAMIE CROWN

Former Wife

 

STATE OF FLORIDA         )

)§:

COUNTY OF BROWARD  )

 

BEFORE ME, the undersigned authority, personally appeared, JAMIE CROWN, known to me or who produced___________________ 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 her personal knowledge and that her executed this document this ______ day of ____________, 20__.

WITNESS my hand and seal in the County and State aforesaid this ___ day of _____________, 20__.

_______________________________

Notary Public, State of Florida

 

 

CERTIFICATE OF SERVICE

            I HEREBY CERTIFY that a true and correct copy of the foregoing was provided

to:  Jack King, Former Husband, by personal service.

 

LAW OFFICES OF LARRY D. SCHOTT

Attorney for Former Wife

 

By:_____________________________

LARRY D. SCHOTT

 

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