Illinois Orders of Protection

AMENDED PETITION FOR PROTECTION FROM ABUSE AND MOTION FOR MODIFICATION

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI

and AS NEXT FRIENDS AND

ON BEHALF OF , MINOR CHILD

VS. NO.

AMENDED PETITION FOR PROTECTION FROM ABUSE AND MOTION FOR MODIFICATION

COMES NOW , and grandparents and next friend and on behalf of , minor child, and files this, by and through their attorney, their Amended Petition For Protection From Abuse and Modification pursuant to the Protection From Domestic Abuse Act, Mississippi Code 93-21-1, 1972, Annotated, and for cause would show unto the Court the following. to-wit:

1. That and are adult resident citizens of County, Mississippi having as their place of residence on , Mississippi. That and are the grandparents of minor child herein.

2. That is an adult resident citizen of County, Mississippi, whose address is , Mississippi. That is the mother/father of the minor child.

3. That is an adult resident citizen of County. Mississippi, whose address is , Mississippi. That is the mother/father of the minor child.

4. That the minor child, was born on is a minor resident citizen of the State of Mississippi having his/her residence at , P.O. Box , , Mississippi.

5. That lived with grandparents from until when the child was taken from them and placed in a residential facility namely .

6. That the minor child has been sexually and mentally abused in the past and has stated that he/she would commit suicide if he/she was forced to live with his mother in Mississippi.

7. That the minor child must be immediately released from this residential treatment facility before he/she can carry through with his/her threat to commit suicide. That the child was happy and well cared for while in the custody of his/her paternal/maternall grandparents. That immediate and irreparable harm may occur unless this minor child is released to the custody of the paternal/maternal grandparents.

8. That poses an immediate threat to the well-being of the minor child and this Court should order him/her to permanently refrain from abusing and order him/her to refrain from any contact whatsoever with the said minor child during the pendency of any order that is entered; order that the Petitioners, and should have sole temporary custody, both physical and legal custody of the minor child to the exclusion of and further that this order, if so issued, remain in effect until .

9. That the Petitioners are fit, suitable and proper persons to have temporary legal and physical custody of the said minor child and it is in the best interest of the minor child to be placed with the Petitioners until such time as a hearing may be held in this matter.

10. That no further proceedings have been filed with this Honorable, Court or with any other Court pertaining to this matter.

11. That initially, this relief is requested Ex parte due to the urgent and necessitous circumstances. On hearing, a date certain should be set before County Chancery Court on at which time should be ordered to appear and show cause why this order should not be made permanent.

MOTION FOR MODIFICATION

COMES NOW, , by and through his/her attorney, and files this his/her Motion for Modification, and would respectfully show the Court the following:

I.

All allegations as to the residence of the parties contained in the Amended Petition for Protection from Domestic Abuse are incorporated by reference herein.

That this Court granted a divorce to these parties on That the divorce granted the Defendant legal and physical custody of the parties two minor children, namely, born on , and born on . That the Defendant filed a Motion for Contempt on . That the Defendant filed another Motion for Contempt on .

II.

That a substantial and material change of circumstances has occurred since the Final Judgment of Divorce of the parties' on . Namely, the youngest of the parties minor children is () years of age and desires to live with the Plaintiff. The Plaintiff, being a fit and proper person to have custody of the minor child should be granted legal and physical custody of the minor child.

WHEREFORE, PREMISES CONSIDERED, and respectfully pray that this Court will issue an immediate Ex Parte Order giving and sole temporary legal and physical custody of the aforesaid minor child until such time as this matter is heard in full. Order to refrain from any contact whatsoever with until such time as a hearing may be had in this matter. Domestic Abuse is incorporated by reference herein.

Respectfully submitted,

Attorney for