IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI
and AS NEXT FRIENDS AND
ON BEHALF OF , MINOR CHILD
vs.
PETITION FOR PROTECTION FROM ABUSE
COMES NOW and , as next friends and on behalf of , minor child,
and files this, by and through their attorney, , their Petition For Protection From Abuse
pursuant to the Protection From Domestic Abuse Act, Mississippi Code 93 - 21 - l (1972),
Annotated, and for cause would show unto the Court the following, to - wit:
1. That and are married and are adult resident citizens of
County, Mississippi having as their place of residence , , 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 of the said minor child.
3. That the minor child, , born on , 20 . is a minor
resident citizen of the State of Mississippi having her residence at , County Medical
Center, P.O. Box , , Mississippi .
4 That lived with grandparents from , 20 until ,
20 when the child was taken from and placed in the residential facility, .
5. That the minor child, has been sexually and mentally abused in the past
and stated that she would commit suicide if she was forced to live with her mother in ,
Mississippi.
6. That the minor child must be immediately released from this residential treatment
facility before she can carry through with her threat to commit suicide. That the child was happy
and well cared for while in the custody of her paternal grandparents and that immediate and
irreparable harm may occur unless this minor child is released to the custody of the paternal
grandparents.
7. That poses an immediate threat to the wel1 - being of the minor child and
this Court should order her to permanently refrain from abusing and order her to refrain
from any contact whatsoever with the said minor child during the pendency of any order that is
entered; and 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 .
8. 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.
9. That no further proceedings have been filed with the Honorable Court or with any
other Court pertaining to this matter.
10 That initially this relief is requested Ex parte due to the urgent and necenaitous
circumstances. On hearing, a date certain should be set before Rankin County Chancery Court
in which should be ordered to appear and show cause why this order should not be made
permanent.
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
and order to refrain from any contact whatsoever with until such time as a hearing
may be had in this matter.
Respectfully submitted,
_______________________________________
Attorney for
Of Counsel:
Telephone:
MSB #
Attorney for
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