MOTION FOR INJUCTIVE RELIEF
COMES NOW, the Defendant, Michael A. McNeil, and moves that this Court grants an injunctive relief to order the Plaintiff to stop permitting Mr. Gary Napier to transport the Defendant’s daughter around and outside of the state and to be alone with her without the presence of the Plaintiff in the mediate area. Additionally, the Defendant moves that the Plaintiff Sarah McNeil be ordered to no longer discuss the pending legal actions before this Court and/or making various pleadings available to be read by the Defendant’s daughter. In support of the Defendant’s motions he states the following:
Concerning Mr. Gary Napier
1. Mr. Gary E. Napier is a 54 year old man that lives approximately 32 miles from the Plaintiff. …show more content…
The Plaintiff is not acting in accordance with the Best Interest of the Defendant’s daughter and is putting her in harms way. Therefore this Court should act to protect the Defendant’s daughter.
As to Plaintiff’s Discussing Legal Matters With Defendant Daughter That Are Pending Before This Court
25. Defendant’s daughter informed him when the Plaintiff was served with his Petition to Modify that she was angry with him.
26. When the Defendant served the Plaintiff when Discovery Requests, and Motion for Contempt, the Defendant’s daughter informed him of the fact and that she was angrier still.
27. Since then, the Defendant’s daughter has informed him that he was lying to the Court and that none of what he was saying was …show more content…
The Plaintiff has also informed the Defendant’s daughter that they would have to cut their vacation weekend to Ocean City short, because she had to work on answering her fathers complaint for custody. One thing that should be noted is that the Ocean City trip was occurring on the Defendant’s weekend.
29. The Plaintiff has told him that in the past, that both children have a tendency to get the mail before she does and read the Defendant’s pleadings that are sent to her.
30. Defendant’s daughter has also informed him that her mom is going to get the Judge to order him to pay for the Private School that she wants to go to.
31. The Plaintiff’s action clearly indicating that she is not acting in the Best Interest of the Defendant’s daughter in that she is trying to alienate her from her father.
32. This Court should order that the Plaintiff no longer discuss any legal matters concerning this case with the Defendant’s daughter and that she is to ensure that the Defendant’s daughter or son will be able to access any of the legal documents.
WHEREFORE, the Defendant prays, that this Court grant his request for relief in he following manner:
1. That the Plaintiff be ordered to not permit the Defendant daughter and Mr. Gary E. Napier to spend any time with her or to be in her
COMES NOW, the Defendant, Michael A. McNeil, and moves that this Court grants an injunctive relief to order the Plaintiff to stop permitting Mr. Gary Napier to transport the Defendant’s daughter around and outside of the state and to be alone with her without the presence of the Plaintiff in the mediate area. Additionally, the Defendant moves that the Plaintiff Sarah McNeil be ordered to no longer discuss the pending legal actions before this Court and/or making various pleadings available to be read by the Defendant’s daughter. In support of the Defendant’s motions he states the following:
Concerning Mr. Gary Napier
1. Mr. Gary E. Napier is a 54 year old man that lives approximately 32 miles from the Plaintiff. …show more content…
The Plaintiff is not acting in accordance with the Best Interest of the Defendant’s daughter and is putting her in harms way. Therefore this Court should act to protect the Defendant’s daughter.
As to Plaintiff’s Discussing Legal Matters With Defendant Daughter That Are Pending Before This Court
25. Defendant’s daughter informed him when the Plaintiff was served with his Petition to Modify that she was angry with him.
26. When the Defendant served the Plaintiff when Discovery Requests, and Motion for Contempt, the Defendant’s daughter informed him of the fact and that she was angrier still.
27. Since then, the Defendant’s daughter has informed him that he was lying to the Court and that none of what he was saying was …show more content…
The Plaintiff has also informed the Defendant’s daughter that they would have to cut their vacation weekend to Ocean City short, because she had to work on answering her fathers complaint for custody. One thing that should be noted is that the Ocean City trip was occurring on the Defendant’s weekend.
29. The Plaintiff has told him that in the past, that both children have a tendency to get the mail before she does and read the Defendant’s pleadings that are sent to her.
30. Defendant’s daughter has also informed him that her mom is going to get the Judge to order him to pay for the Private School that she wants to go to.
31. The Plaintiff’s action clearly indicating that she is not acting in the Best Interest of the Defendant’s daughter in that she is trying to alienate her from her father.
32. This Court should order that the Plaintiff no longer discuss any legal matters concerning this case with the Defendant’s daughter and that she is to ensure that the Defendant’s daughter or son will be able to access any of the legal documents.
WHEREFORE, the Defendant prays, that this Court grant his request for relief in he following manner:
1. That the Plaintiff be ordered to not permit the Defendant daughter and Mr. Gary E. Napier to spend any time with her or to be in her