Motion,Ex Parte: In the matter of: Pereira, Giovanni Luis

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                                Docket No. Commonwealth of Massachusetts
VERIFIED MOTION FOR APPOINTMENT OF The Trial Court

TEMPORARY GUARDIAN FOR A MINOR Probate and Family Court
: G.L. c.190B, §5-204 Bil PIS)

 

 

 

 

 

 

In the interests of: . 7 Bivision
Fist Name ja Name Taat Name

Minor . >

on Petition filed Crewanns Lyre Verma .

 

 

 

 

 

 

_ B: =. =
a To 7
Now comes the moving party _/ uit> 2 Wests detrz — Verse -
- Middle ital fannie
who states as follows: : . .

4. An emergency éxists requiring the appointment of a Temporary Guardian as any delay In the appointment will cause
immediate and substantial harm to the health, safety or walfare of the Minor, and no other person has authority to
act in the circumstances.

2. The nature of the circumstances requiting the appointment of a Temporary Guardian are:
padeas
“ see prracdaon ews

3, The particular harm sought to be avoided is:

Doe atracam emt

4. The actions which need fa be taken by a Temporary Guardian to avoid the harm are:

WHEREFORE, PETITIONER REQUESTS THAT THIS HONORABLE COURT:

1. Appoint uve Ht Peres

as Temporary Guardian(s) of the Minor to serve Ciwith Gaoithout sureties for the fallowing reasons:
[the miner has no estate
( other:

 

2, (CJ The moving party further seeks specific court authorization:

3. [if Inaddition, 1 request that the Court: agooethien Dh >

we ace Repveriny VERENS

MPC 340 (6/90/11) MVER page 1 of

 

wsJam writing this letter concerning my daughter Nicole Pedro, an addict to drugs. She was clean for two
years, but something has changed in the last seven months. She has not been the.same. She has been
staying out all hours of the night change of behavior. Nicole has a history of drugs and treatments, and
she hasn't been at home for a month and a half. We are worried about my grandchild Giovanni that she
is using again; | also have custody of Nicole's other son Kevin Pedro {12-07-12} and have had custody
for many years due to her addiction. Nicole was fiving with us so that | can see firsthand of this behavior
change. I'm deeply concerned about my daughter's safety and my grandson Giovanni's. She has been
gone for a month in half, We are requesting temporary guardianship because she has abandoned her
child and walk away. If any medical issue arises, we will not be able to give him the proper care; her
location is unknown to us, and she has no phone to contact even if we could she is actively using and sell
drugs, so we request for the court to grant us the temporary guardianship.

Luis H Pereira -Grandfather L Aho —

«
Maria Daluz Camacho Pereira -Grandmother Hose; dais Fora, :

or “Ce

Que?Bese Ufo

lam writing this letter concerning my daughter Nicole Pedro, an addict to drugs. She was clean for two
years, but something has changed in the last seven months. She has not been the same. She has been
staying out all hours of the night change of behavior. Nicole has a history of drugs and treatments, and
she hasn't been at home for a month and a half. We are worried about my grandchild Giovanni that she
is using again; | also have custody of Nicole's other son Kevin Pedro (12-07-12) and have had custody
for many years due to her addiction. Nicole was living with us so that | can see firsthand of this behavior
change. I'm deeply concerned about my daughter's safety and my grandson Giovanni's. She has been
gone for a month in half. We are requesting temporary guardianship because she has abandoned her
child and walk away. If any medical issue arises, we will not be able to give him the proper care; her
location is unknown to us, and she has no phone to contact even if we could she is actively using and sell
drugs, so we request for the court to grant us the temporary guardianship.

Luis H Pereira -Grandfather use . é c

Maria Daluz Camacho Pereira -Grandmother Maxie cacy (resve, . oe

Lon 2
querSIGNED UNDER THE PENALTIES OF PERJURY
| affiem or swear under oath that | have read the foragoing petition and that the statements set forth therein are true and carrect

to the best of my knowledge. Ae bie
pas G-F- 2p or4

SPST rowing party
Aten ang Feria)

 

Attorney for moving party:
Frat Name

 

‘ddrass} 7 Ape Uni, No. ete)

 

CilyTowny wate ey
Primary Phone #
BBO No.:

 

MPC 340 (6/90/11) MVER pago 2 of 2