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VERIFIED PETITION FOR TEMPORARY CUSTODY BY EXTENDED FAMILY

VERIFIED PETITION FOR TEMPORARY CUSTODY BY EXTENDED FAMILY (Broward)

This is the verified petition for custody, which includes supporting facts that justify why JIMMY DOE, paternal grandfather, should obtain custody of a minor child.

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

In Re: The Matter of  XXXX (a minor)                                                           Case Number:

JIMMY DOE,

Petitioner/Paternal Grandfather,

and

JANE DOE,

Mother,

JOHN DOE,

Father.

_______________________________/

VERIFIED PETITION FOR TEMPORARY CUSTODY BY EXTENDED FAMILY

  1. Pursuant to Ch. 751, Fla. Stat., Petitioner requests temporary custody of the

following minor children: XXXXX, born on xx/xx/20__ and XXXXX, born on xx/xx/20__ (copy of birth certificates will be provided).

  1. Petitioner is an extended family member who is related to the child within the third degree by blood.  Petitioner’s relationship to the children is Paternal Grandfather.
  1. Petitioner is qualified to seek custody because he is caring full time for the children in the role of substitute parent since birth.
  2. The legal Mother of the children, JANE DOE , has consented, see attached Exhibit “A”.
  3. The legal Father of the child, JOHN DOE , has consented Exhibit “B”.
  4. A completed Uniform Child Custody Jurisdiction Enforcement Act (UCCJEA) Affidavit is being filed with this Petition. The children have been residing with the paternal grandparent since birth, in his home at 32 N 4th Street, North Miami Beach, Florida.
  1. The Mother has a drug abuse issue and is unable to care for the children. She has consented to the paternal grandfather having temporary custody.
  2. It is in the best interests of the children for the paternal grandfather to have temporary custody which he has had since birth.

The Petitioner/Paternal Grandfather, JIMMY DOE, verifies that all of the foregoing information is true and correct to the best of her personal knowledge.

_____________________
 JIMMY DOE

 Petitioner/Paternal Grandfather

 

STATE OF FLORIDA )

COUNTY OF BROWARD )

 BEFORE ME, the undersigned authority, duly authorized in the State and County aforesaid to take acknowledgments, personally appeared, JIMMY DOE, who produced _____________________ as identification, after first being duly sworn upon oath, deposes and says that he has read the allegations contained herein, that the information contained herein is true and correct, and that he executed this document.

WITNESS my hand and seal in the County and Sate 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 JANE DOE, Mother and JOHN DOE, Father by hand delivery.

 

SCHOTT & TOLCHINSKY, P.A.

Attorney for Petitioner

By:_____________________________
LAWRENCE 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.