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PETITION FOR TEMPORARY CUSTODY BY EXTENDED FAMILY
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT, IN AND FOR COLLIER COUNTY, FLORIDA
Case No:
11-2016-DR-001709-FM01-XX
ROBERT H. ADKINS,
Petitioner,
Vs.
NIKKI BABINEAU,
Respondent/Mother,
CHRISTOPHER ADKINS,
Respondent/Father.
Petitioner, ROBERT H. ADKINS, being sworn, certifies that the following information is true:
This is an action for temporary custody pursuant to Chapter 751, Florida Statutes.
1. Petitioner requests temporary custody of the following minor child(ren):
Name
Date of Birth
Current Address
Justin Adkins
09/26/2007
5501 Wilmar Lane, Naples, FL 34112
Alexander Adkins
12/28/2010
5501 Wilmar Lane, Naples, FL 34112
2. Petitioner completed a Uniform Child Custody Jurisdiction and Enforcement Act Affidavit, Florida Supreme Court Approved Family Law Form 12.902(d), which was filed with this Petition.
3. Petitioner is an extended family member who is, related to the minor children within the third degree by blood or marriage to a parent.
4. Petitioner's relationship to the minor children is paternal grandfather.
5. The residence and post office address of the Petitioner is 302 Audubon Point Drive, Brandon, MS 39047
6. Petitioner is a proper person to be awarded temporary custody because, the Petitioner has a signed, notarized consent from the Respondent/Father of the children.
8. The legal mother of the children is, Nikki Babineau, whose current address is, unknown.
7. The legal father of the children is, Christopher Adkins, whose current address is, 5501 Wilmar Lane, Naples, FL 34112
8. The Consent of the Respondent/Father is attached to the Petition.
11. Petitioner requests temporary custody be granted for the following period of time: Until the Respondent/Father is able to take care of the minor children. The reasons that support this request are:
A. The Respondent/Father of the children has a Circuit Criminal case in Collier County 2015-CF-399. The Respondent/Father will be unable to take care of the minor children for some time. The Respondent/Mother of the children as not had any contact with them for the past 6 months and is unstable to take care of the minor children.
12. It is in the best interests of the children that the Petitioner have temporary custody of the children for the following reasons:
A. The Respondent/Father of the children has a Circuit Criminal case in Collier County 2015-CF-399. The Respondent/Father will be unable to take care of the minor children for some time. The Respondent/Mother of the cbildren as not had any contact with them for the past 6 months and is unstable to care of the minor children.
13. Order of Protection:
Petitioner is not aware of any temporary or permanent order for protection entered on behalf of or against either parent, the Petitioner, or the children in Florida or any other jurisdiction. OR
14. Temporary or Permanent Child Support Orders:
Petitioner is not aware of any temporary or permanent orders for child support for the minor children.
15. Petitioner does not request that the court establish reasonable visitation or a time-sharing schedule with the parents.
WHEREFORE, Petitioner requests that this Court grant the Petitioner temporary custody of the children subject to this proceeding; award the Petitioner other relief as requested; and award any other relief that the Court deems necessary.
I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this petition or that the punishment for knowingly making a false statement includes fines and/or imprisonment.
Dated: 6-15-16
/s/ Robert H. Adkins
Robert H. Adkins
302 Audubon Point Dr.
Brandon, MS 39047
601-761-3733
/s/ Brenda S. Phillips
STATE OF MISSISSIPPI
NOTARY PUBLIC
ID# 92797
BRENDA S. PHILLIPS
Commission Expires
Jan. 16, 2017
RANKIN COUNTY
August 5, 12, 19, 26, 2016 16-01537C