Fill and Sign the Ms Grandparents Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFFS VS. NO.             DEFENDANT COMPLAINT FOR GRANDPARENT'S VISITATION COMES NOW the Plaintiffs, and file their Complaint for Grandparent's Visitation Rights as provided by Section 93-16-1, et seq., and would show unto the Court the following: 1. Plaintiffs are adult resident citizens of             , and are the paternal/maternal grandparents of       ,       years of age, born       ,       , and             ,       years of age, born       ,       . 2. Defendant       is an adult resident citizen of       County, Mississippi, residing at       , Mississippi. Process may be had on the Defendant at that address. 3. The Defendant is the father/mother of the above named minor(s) and the child(ren) reside with him/her . 4. The Defendant was granted custody of said child(ren) in a divorce action against Plaintiffs' son/daughter ,             . A copy of his/her Divorce Judgment is attached to this Complaint as Exhibit "A". 5. Since the divorce action, the Plaintiffs have established a viable relationship with the child(ren) and the Defendant now unreasonably denies these grandparents their visitation rights. It would be in the best interest of the child(ren) for the Plaintiffs to be allowed visitation rights with them/him/her . 6. Subsequent to his/her divorce from       , the Defendant moved with his/her child(ren), but the Plaintiffs were able to establish and maintain visitation periods with the child(ren) and have had frequent visitation with the child(ren) since that time. This visitation included overnight and holiday visitation with the child(ren) for a period of not less than one year. 7. The Defendant now, without reason, wrongfully withholds from the Plaintiffs visitation with their grandchild(ren). 8. Plaintiffs herein live in       , a distance in excess of       miles from their grandchild(ren). The grandparents are without funds for advance court costs or attorney fees in this cause, as it would work a financial hardship on them. WHEREFORE, PREMISES CONSIDERED, Plaintiffs file their Complaint for Visitation Rights and pray that on a hearing hereof this court find they are the paternal/maternal l grandparents of       and             , minors, and that pursuant to Section 93-16-3, Mississippi Code of 1972, Annotated, they are entitled to visitation with said minor(s). Plaintiffs further pray that this Court enter its Judgment setting out the reasonable visitation rights of Plaintiffs. Plaintiffs further pray that this Court will enter its Order finding that no financial hardship will be imposed upon Defendant and will impose no attorney fees in this cause. Respectfully submitted, ____________________________________ ____________________________________ OF COUNSEL: _________________________ _________________________ _________________________ MSB#:       STATE OF MISSISSIPPI COUNTY OF       PERSONALLY appeared before me, the undersigned authority, in and for the above jurisdiction, the within named,             and       , who after being duly sworn on oath, state that the matters, facts and averments contained herein are true and correct as therein stated. _______________________________ _______________________________ SWORN to and subscribed before me this the       day of       ,       . ______________________________ NOTARY PUBLIC MY COMM. EXPIRES: ________________ (ATTACH COPY OF DIVORCE JUDGMENT -- EXHIBIT "A")