Emergency Motion

EMERGENCY VERIFIED MOTION FOR CHILD PICK-UP ORDER

IN THE CIRCUIT COURT OF THE JUDICIAL CIRCUIT,

IN AND FOR COUNTY, FLORIDA

Case No.:

Division:

Petitioner,

and

Respondent,

EMERGENCY VERIFIED MOTION FOR CHILD PICK-UP ORDER

I, being sworn, certify that the following information is true:

1. This is a motion to enforce existing custody or time-sharing rights regarding the following minor child(ren):

2. Currently, the child(ren) subject to this motion is (are) in the physical possession of whose address or present physical location is:

This individual’s relationship to the minor child(ren) is:

3. I am am not married to the person named in paragraph 2.

4. Status of minor child(ren). I have a superior right to custody of or time-sharing with the minor child(ren) over the person named in paragraph 2 because:

a. Custody or Time-Sharing has been established by a court.

A final judgment or order was made on in case number .

This order applies to:

A certified copy of said final judgment or order is attached, has not been modified, and is still in effect. This order is an out-of-state court order entitled to full faith and credit.

b. Custody or time-sharing is established as an operation of law.

I am the birth mother of the minor child(ren) born out of wedlock and there is no final judgment or order awarding custody of or time-sharing with:

1. Paternity has NOT been established. A certified copy of the birth certificate is attached.

2. Paternity has been established. A certified copy of the final judgment of paternity is attached.

c. Other:

5. A completed Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) Affidavit is filed with this motion.

6. Facts relating to the minor child(ren)’s current situation. [Indicate all that apply]

a. The person named in paragraph 2 wrongfully removed or wrongfully detained the minor child(ren) on as follows:

Please indicate here if you are attaching additional pages to continue these facts.

b. I believe that the minor child(ren) is (are) in immediate danger of harm or removal from this court’s jurisdiction while with the person named in paragraph 2 based on the following:

c. The current location of the minor child(ren) is:

unknown believed to be at the following address(es) with the following people:

7. Advance notice of this motion to the individual named in paragraph 2 should not be required because:

8. If needed, I can be contacted for notice of an emergency or expedited hearing at the following addresses/locations:

9. Attorneys’ Fees, Costs, and Suit Monies. I have filed this motion because of wrongful acts of the person listed in paragraph 2 above. I request that this Court award reasonable attorney’s fees, costs, and suit monies as applicable or authorized under Florida law, the UCCJEA, and other legal authorities.

WHEREFORE, I request an Emergency Order to Pick-Up Minor Child(ren), without advance notice, directing all sheriffs of the State of Florida or other authorized law enforcement officers to pick up the previously named minor child(ren) and deliver them to my physical custody.

I understand that I am swearing or affirming under oath to the truthfulness of the claims made above and that the punishment for knowingly making a false statement includes fines and/or imprisonment.

Dated:

IF A NONLAWYER HELPED YOU FILL OUT THIS FORM, HE/SHE MUST FILL IN THE BLANKS BELOW:

This form was prepared for the: Petitioner Respondent

This form was completed with the assistance of:

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