On August 31, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Ramualda De Almeida Valente, Irincia,
Ramualda De Almeida Valente, Irineia,
and
Duarte Andrade, Antonio Lucio,
for Special Immigration Juvenile Status
in the District Court of Middlesex County.
Preview
a
WHEREFORE, Irineia Ramualda de Almeida Valente, Petitioner in these proceedings, respectfully
requests that this Honorable Court enter the above findings.
Dated: August 24, 2021
Respectfully submitted. .
Irineia Ramualda de Almeida Valente
By her Attorney,
Quesnel, Esq.
Attorney for Plaintiff
BBO #705785”
235 Marginal Street
Chelsea, MA 02150
(t}6178841000
(£)6178841002
(e)TQuesnel@GeorgesCoteLaw.comCommonwealth of Massachusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
MIDDLESEX DIVISION DOCKET #_o/ RoSSASS
Irineia Ramualda de Almeida Valente
(OBO Child, Luana Duarte Almeida)
Niiddlesex, SS aera
PLAINTIFF The Above Motion Is Hereby
v. Attiowed - Dented
Antonio Lucio Duarte Andrad
fonio Lucio ie irade Justice of Probate
DEFENDANT
MOTION FOR SPECIAL FINDINGS OF FACT AND RULINGS OF LAW
Irineia Ramualda de Almeida Valente, Petitioner in these proceedings, hereby moves this
Honorable Court to conclude special findings of fact and rulings of law pursuant to M.G.L. c.190B,
§5-204(a)(v) and 8 U.S.C. § 1101(a)(27)(), for the following reasons:
1. Dependent, Luana Duarte Almeida, is a fifteen (15) year old child born on October 13, 2005
in Brazil and currently under the care and custody of her mother, Irineia Ramualda de
Almeida Valente, in Malden, Massachusetts. Dependent wishes to remain under her
mother’s care and custody.
2. Dependent, Luana Duarte Almeida, intends to petition the United States Citizenship and
Immigration Services (“USCIS”) for Special Immigrant Juvenile Status, an immigration
status granted to non-citizen juveniles who have been abused, neglected, or abandoned by
one or both of their parents and whose best interest would not be served by a return to their
country of origin. See 8 U.S.C. § 1101(a)(27)(J).
3. Pursuant to 8 U.S.C. § 1101(a)(27)(J), before Dependent, Luana Duarte Almeida, may
petition the USCIS for Special Immigrant Juvenile Status, a state court must enter the
following findings of fact and ruling of law:
a. The Dependent child is dependent upon the state court;
b. Reunification with one or both of the Dependent’s parents is not viable-due to abuse,
neglect, or abandonment, or a similar basis found under state law;
c. Itis not in the best interest of the Dependent child to be returned to his or her
country of origin.
FILED
‘AUG 3 4 2021
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a WHEREFORE, Irineia Ramualda de Almeida Valente, Petitioner in these proceedings, respectfully requests that this Honorable Court enter the above findings. Dated: August 24, 2021 Respectfully submitted. . Irineia Ramualda de Almeida Valente By her Attorney, Quesnel, Esq. Attorney for Plaintiff BBO #705785” 235 Marginal Street Chelsea, MA 02150 (t}6178841000 (£)6178841002 (e)TQuesnel@GeorgesCoteLaw.comCommonwealth of Massachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT MIDDLESEX DIVISION DOCKET #_o/ RoSSASS Irineia Ramualda de Almeida Valente (OBO Child, Luana Duarte Almeida) Niiddlesex, SS aera PLAINTIFF The Above Motion Is Hereby v. Attiowed - Dented Antonio Lucio Duarte Andrad fonio Lucio ie irade Justice of Probate DEFENDANT MOTION FOR SPECIAL FINDINGS OF FACT AND RULINGS OF LAW Irineia Ramualda de Almeida Valente, Petitioner in these proceedings, hereby moves this Honorable Court to conclude special findings of fact and rulings of law pursuant to M.G.L. c.190B, §5-204(a)(v) and 8 U.S.C. § 1101(a)(27)(), for the following reasons: 1. Dependent, Luana Duarte Almeida, is a fifteen (15) year old child born on October 13, 2005 in Brazil and currently under the care and custody of her mother, Irineia Ramualda de Almeida Valente, in Malden, Massachusetts. Dependent wishes to remain under her mother’s care and custody. 2. Dependent, Luana Duarte Almeida, intends to petition the United States Citizenship and Immigration Services (“USCIS”) for Special Immigrant Juvenile Status, an immigration status granted to non-citizen juveniles who have been abused, neglected, or abandoned by one or both of their parents and whose best interest would not be served by a return to their country of origin. See 8 U.S.C. § 1101(a)(27)(J). 3. Pursuant to 8 U.S.C. § 1101(a)(27)(J), before Dependent, Luana Duarte Almeida, may petition the USCIS for Special Immigrant Juvenile Status, a state court must enter the following findings of fact and ruling of law: a. The Dependent child is dependent upon the state court; b. Reunification with one or both of the Dependent’s parents is not viable-due to abuse, neglect, or abandonment, or a similar basis found under state law; c. Itis not in the best interest of the Dependent child to be returned to his or her country of origin. FILED ‘AUG 3 4 2021