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IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI , AND , AS NEXT FRIENDS AND ON THE BEHALF OF , A MINOR VS. MOTION FOR EMERGENCY HEARING Comes now , Defendant, by and through his/her attorney and moves this Honorable Court for an emergency hearing in this matter and for support thereof would show the following: 1. That this case was set for a hearing and continued until , , . 2. That the Plaintiff, was ordered in the Judgment of Divorce to keep health insurance on the minor child, . 3. That since there is currently no health insurance coverage on the minor child, , on this medical problem, he/she cannot be admitted to without the payment of thirty (30) days in advance and each month's bill paid on or before the of the month. 4. That will take a minimum of ninety (90) days to determine coverage, if not more, with no guaranty of coverage by . 5. That the minor child, , will destabilize and regress without immediate treatment at . 6. That the father/mother, , Plaintiff, should be order to pay immediately the cost of entering the minor child, , into and pay each month's expenses as accrued until   accepts coverage. WHEREFORE, PREMISES CONSIDERED, Defendant prays for an emergency hearing in this matter. Respectfully submitted, _______________________________________ Attorney for Of counsel: Telephone: MSB # Attorney for