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URGENT MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

URGENT 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 Marriage of                                            Case Number:

 

JACK KING,

 

Petitioner/Husband,

and

 

JAMIE CROWN,

 

Respondent/Wife.

 

__________________________/

URGENT MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

 

The Respondent/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. The following minor child is subject to this proceeding: NHV, born on xx/xx/2015.
  2. The matters before the Court regarding the minor child are timesharing, including overnights.
  3. The Husband is not taking proper care of the child’s needs and allergy issues causing severe trauma to the child.
  4. The child has been returned from overnight timesharing hysterical crying with itching and bumps and marks all over.
  5. It is in the best interests of the minor child that a Guardian ad Litem be appointed to advance the best interests of the minor child and to address the issues mentioned in Wife’s Urgent Motion to Suspend Timesharing.
  6. Former Wife requests that both parties share equally the Guardian Ad Litem fees and costs.

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was provided to:  XXXXXXX, Esquire, Attorney for Husband, XXXXXXXXXXXX on this _______day of XXXXXX 20__.

 

 

LAW OFFICES OF LARRY D. SCHOTT

Attorney for Wife

 

BY:___________________________

LARRY D. SCHOTT

 

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This document is a sample pleading related to a specific set of facts and circumstances and should not be used or relied upon for any family law matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced divorce lawyer for professional advice as each case is unique.

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