STATE OF NORTH XXX
COUNTY OF XXX
XXX
Plaintiff
vs.
XXX
Defendant
IN THE GENERAL COURT OF JUSTICE
DISTRICT COURT DIVISION
18-CVD-32
MOTION FOR ATTENTION DEFICIT
DISORDER (ADD) TESTING
NOW COMES, Defendant, Julian Daily, pro se, and hereby respectfully submits his
Motion for Attention Deficit Disorder Testing. In this motion, Defendant prays this Court issues
an order for the minor children to be tested for Attention Deficit Disorder. In support of the
motion, the Defendant states as follows:
RELEVANT FACTUAL BACKGROUND
1. The parties were married on July XXX and separated on November XXX,
and divorced on March XXX
2. In the course of their marriage, the parties got two children namely, Layla G.
Dally, born on July XXX and Zoe M. Daily, born on May XXX
3. On March XXX a permanent child custody order was entered. A subsequent
custody modification order was entered on April XXX. The said orders were entered in
Pickens County, XXX. The parties then challenged the orders in the South Carolina
Supreme Court, which court upheld the orders, with slight modifications.
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4. The said orders gave the Plaintiff sole custody of the children while the Defendant
has certain visitation rights. Regarding legal custody, Plaintiff has sole-decision making
authority over all major decisions affecting the children.
5. On January XXX the aforesaid orders were registered and confirmed in Orange
County, North Carolina. North Carolina, since XXX, has been the home state for the children.
6. On March XXX, Plaintiff filed a Motion to Modify Child Custody. In the said
Motion, the Plaintiff alleged inter alia, the Defendant’s abuse and/or violence towards Layla,
that Defendant does not read or respond to the OFW, and that Defendant has refused to
communicate with the Plaintiff.
7. Defendant avers that despite the Plaintiff making several allegations of the minor
children suffering physical and emotional abuse, the minor children have not yet been taken to a
therapist.
ARGUMENTS
8. Defendant realleges and incorporates every allegation contained in the preceding
paragraphs of this Motion as though set forth herein.
9. The best interest of the children is the guiding factor in all matters involving
children. See “In XXXX
10. Further, “[t]here is a fundamental constitutionally protected liberty interest of
natural parents in the care, custody and management of their children. XXX
11. ADD is hereditary. Defendant’s father had it, and it passed on to Defendant. Since
the Plaintiff has custody of the children, she may frustrate the testing of the minor children.
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12. Defendant avers that it is in the best interest of the minor children to have the
ADD test done since it would benefit them to know whether they have ADD.
CONCLUSION
WHEREFORE, Defendant prays this Court grants this Motion for ADD testing, in the
interest of justice. Defendant further requests this Court to grant any other Order it deems just.
Respectfully Submitted,
__________________________
Julian D. Daily, Pro Se
Defendant
XXX
XXX
Telephone: XXX
XXX
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CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing was delivered upon the attorney for
Plaintiff in this action:
_____ Via U.S. mail
_____ Via facsimile
_____ Via hand delivery to the following address:
XXX
XXX
XXX
Telephone: XXX
Facsimile: XXX
XXXX
This the ______ day of __________, XXX
__________________________
Julian D. Daily, Pro Se
Defendant
XXX
XXX
Telephone :XXX
XXXX
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