Fill and Sign the Dunn V Stewart 235 F Supp 955 Sd Miss Justia Law Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI PLAINTIFFSAND V. CAUSE NO. DEFENDANT PETITION FOR TEMPORARY RESTRAINING ORDER AND PERTINENT INJUNCTION COME NOW, Plaintiffs, and , and file this their Petition for a Temporary Restraining Order and Permanent Injunction and in support Thereof, would show the following: 1.a. is an adult resident citizen of County, Mississippi, whose address is , , Mississippi . b. is an adult resident citizen of County, Mississippi, whose address is , , Mississippi .c. is an adult resident citizen of County, Mississippi, whose address is , , Mississippi . 2. During , , ended a relationship with . Subsequent to that time, became engaged to be married to .3. Since the time that and have become engaged to be married, has knowingly and willfully engaged in a pattern of conduct of threatening and harassing and . Specifically, has had conversations with and made telephone calls to , ... and employer, during which he/she used abusive and profane language and made threats regarding the safety of . Likewise, has made remarks to individuals who know and indicating that he/she intended to cause bodily harm to . has further made threatening statements to in person.4. As the proximate and foreseeable result of irrational, hostile, abusive and threatening conduct, and his/her intent and apparent ability to carry out the threats made by him/her to and , and are in fear for their safety.WHEREFORE, Plaintiffs and request that this Court enter a Temporary Restraining Order against prohibiting him/her from contacting both , , , ...., and employer, , or any employee thereof, by telephone, letter, or by any other means or method of communication and prohibiting him/her from coming to and home and place of business or otherwise coming within five hundred (500)feet of , , ...., , employer, , or any employee thereof. MOTION FOR PERMANENT INJUNCTION 5. and incorporate herein by reference the allegations contained in Paragraphs 1 through 4 above.6. and request that the Temporary Restraining Order remain in effect until such time as a hearing can be had on the merits of this cause, at which time and request that a Permanent Injunction be issued prohibiting any contact between the parties on a permanent basis.WHEREFORE, PREMISES CONSIDERED, and pray for the following relief:A. A Temporary Restraining Order prohibiting from contacting and .. and either of their employers; andB. A Permanent Injunction prohibiting any contact between the parties on a permanent basis; andC.Other such relief as the Court deems just and equitable.DATED this the day of , . Respectfully submitted,_______________________________________ Attorney for Of counsel: Telephone: MSB # Attorney for STATE OF MISSISSIPPICOUNTY OF Personally appeared before me, the undersigned authority in and for the said county and state, on this day of , , within my jurisdiction, the within named , duly identified before me, who acknowledged that he/she executed the above and foregoing instrument. _________________________________________NOTARY PUBLIC My Commission Expires:_______________________STATE OF MISSISSIPPICOUNTY OF Personally appeared before me, the undersigned authority in and for the said county and state, on this day of , , within my jurisdiction, the within named , duly identified before me, who acknowledged that he/she executed the above and foregoing instrument. ________________________________________NOTARY PUBLIC My Commission Expires:_______________________Of counsel: Telephone: MSB # Attorney for CERTIFICATE OF SERVICE I, , do hereby certify that I have this day caused to be mailed, via United States Mail1 postage prepaid, a true and correct copy of the foregoing document to: , Mississippi DATED this the day of , . ________________________________________-