Motion,Ex Parte: FD-2012-00044

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                                IN THE DISTRICT COURT OF LEFORE counnl D

STATE OF OKLAHOMA JUL 13 apa
TORI ALYSSA WEST, ) STATE Of G HALL Cour
Petitioner, ) OF ORAL Conny
)
cvs: ) CASE NO. FD-2012-44
)
CHRISTOPHER RICE )
Respondent. )

APPLICATION FOR EX PARTE EMERGENCY ORDER

COMES NOW the Petitioner, Tori West, and in support of her Application for Ex Parte
Emergency Order, states as follows:

1. Petitioner and Respondent were divorced on August 9, 2012 in an Agreed Decree
of Dissolution filed on October 18, 2012.

2. That under the terms of the most recent Order the Respondent had custody of the
minor child, K.A.R. (DOB: 02/24/2011).

3. That due to the threat of irreparable harm to the minor child resulting from several
hardships and life trials, the Respondent has left the minor child in the control, custody and care
of the Petitioner, Tori West, maternal mother, for multiple months.

4, That Respondent, Christopher Rice, is unable to be located at the time in which

this application is being made.

5. The minor child is presently in need of counseling and medical insurance.

6. That there is an immediate need for an Order granting the Petitioner sole custody
of the children.

7. Respondent has not exercised any visitation or seen the child since the middle of

March, 2020.8. The children are unable to obtain SoonerCare benefits that would allow them

access to Medical, Dental, Vision, and Counselling that they so require at this time.

9. That Respondent should be required to pay the Petitioner’s attorney fees and other
costs associated with this litigation.

10. _ The Petitioner reserves the right to amend this pleading and to plead further as
justice is so required.

WHEREFORE premises considered, Petitioner prays that the Court grant her an
Emergency Temporary Custody order as to the minor children instanter and without delay,
allowing her to have temporary emergency custody of the minor child until such time as a
hearing can be held by the Court upon a date and time certain, to be set by separate Order,
together with such other and further relief as the Court deems fair and equitable, including an
award of reasonable attorney fees and costs incurred in the prosecution of this Application.

RESPECTFULLY SUBMITTED,

TORI WEST, Petitioner

ROB LAMBERT

P.O. Box 9

Poteau, OK 74953

Phone: (405) 657-9445

Email: attorneyroblambert@gmail.com

By: : = WBE
Rob Lambert 7
Oklahoma Bar #21981

VERIFICATION ATTACHED.
Attomey’s lien claimed.VERIFICATION

STATE OF OKLAHOMA _ )

) ss:
COUNTY OF LEFLORE _ )

TORI WEST of lawful age and being first duly sworn upon oath, states that she is the
Petitioner, above named and that she is familiar with the above and foregoing instrument and
states that all statements contained therein are true and correct to the best of her knowledge and

belief.
UDeak
WEST
day of ud ty

Subscribed and
2020, by TORI WESRS7143/2020 IMG_3467 jpeg

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