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PETITION FOR TEMPORARY CUSTODY BY
EXTENDED FAMILY
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PASCO COUNTY, FLORIDA
Case No: 512018DR4927WS
Division: Z2
IN THE INTEREST OF
Aarabella McShan-Johnson,
Child(ren)
Crystal Johnson,
Petitioner,
and
Anna Johnson,
Respondent
Petitioner, Crystal Johnson, being sworn, certifies that the following is true:
1. This is an action for temporary custody pursuant to Chapter 751, Florida Statutes.
2. Petitioner requests temporary custody of the following minor child(ren):
Name Aarabella McShan-Johnson
Date of Birth 9-28-17
Current Address
4950 41st Ave. N, St. Pete, FL 33709
3. 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. The affidavit includes the names and current addresses of the persons with whom the child(ren) has(have) lived during the past 5 years, the places where the child(ren) has( have) lived during the past 5 years, and information concerning any custody proceeding in this or any other state with respect to the child(ren). If the Affidavit is not completely filled out, signed under oath, and filed with the Petition, the case may be dismissed without hearing.
4. Petitioner is: an extended family memeber who is Related to the minor child(ren) within the third degree by blood or marriage to a parent;
5. Petitioner's relationship to the minor child(ren) is: Grandmother
6. The residence and post office address of the Petitioner is: 4950 41st Ave. N., St. Petersburg, FL, 33709
7. Petitioner is a proper person to be awarded temporary custody because: Petitioner is caring full time for the child(ren) in the role of a substitute parent and the child(ren) currently live with the Petitioner.
If Petitioner does not have the signed consents from both parents or is not caring for the child(ren) full time as a substitute parent, Petitioner cannot obtain temporary custody under Chapter 751, Florida Statutes. Petitioner should consult an attorney about other options.
8. The legal parents of the child(ren) are:
a. Anna Johnson, whose current address is 9241 Crabtree Ln., Port Richey, FL, 34668
9. Consent has Not been obtained from the parents. The specific acts or omissions of the parents which demonstrate that the parents have abused, abandoned, or neglected the child(ren) as defined in Chapter 39, Florida Statutes are: There is an open CPI case, open and I was informed by the casworker to file, for temporary custody until my daughter is stable enough to care for my granddaughter.
10. Petitioner requests temporary custody be granted for the following period of time: until Anna is stable enough to care for the baby. The reasons that support this request are: She has no job, no way to care or feed the child and no home to take her to. Also she hasn't been taking her bipolar medication.
11. It is in the best interests of the child(ren) that the Petitioner have temporary custody of the child(ren) for the following reasons: She has thrived with her grandmother. She has medical care, she is in childcare and she eats 3 meals a day and has her own room.
12. ORDER OF PROTECTION
a. Petitioner IS NOT aware of any temporary or permanent order for protection entered on behalf of or against either parent, the Petitioner, or the child(ren) in Florida or any other jurisdiction.
13. TEMPORARY OR PERMANENT CHILD SUPPORT ORDERS
a. Petitioner IS NOT aware of any temporary or permanent orders for child support for the minor child(ren)
14. CHILD SUPPORT N/A
15. Petitioner requests that 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 child(ren) 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 and that the punishment for knowingly making a false statement includes fines and/or imprisonment.
Dated: 9-24-19
Crystal Johnson
Signature of Petitioner
Printed Name: Crystal Johnson
Address: 4950 41st Ave. N.
City, State, Zip Code:
St. Petersburg, FL, 33709
Telephone Number: 727-623-2260
Designated E-Mail Address(es):
[email protected]
STATE OF FLORIDA
COUNTY OF Pinellas
Sworn to or affirmed and signed before me on 9/24/18 by Crytsal Johnson Kathleen Strader
NOTARY PUBLIC OR DEPUTY CLERK
Kathleen Strader
Commission # GG091705
Expires: April 9, 2021
Sept. 27; Oct. 4, 11, 18, 2019 19-02032P