IN THE 505TH JUDICIAL DISTRICT COURT
FOR FORT BEND COUNTY, TEXAS
IN THE INTEREST OF EMMANUEL §
EDGLEY, A CHILD §
§
§
CHRISTIAN EDGLEY § Cause No.: 15-DCV-228707
Petitioner, §
§
v. §
§
LATEISHA RAGLAND §
Respondent §
NOTICE OF MOTION FOR ENTRY OF TEMPORARY ORDERS
You are notified that on the ____ day of January, 20220, at ________ (am/pm), or as soon thereafter as the Petitioner can be heard, he will bring on for hearing his Motion for Entry of Temporary Orders for the reasons stated in the attached Motion.
Dated this ____ day of January, 2022.
Respectfully Submitted,
___________________________________
Christian Edgley,
Petitioner in pro per
IN THE 505TH JUDICIAL DISTRICT COURT
FOR FORT BEND COUNTY, TEXAS
IN THE INTEREST OF EMMANUEL §
EDGLEY, A CHILD §
§
§
CHRISTIAN EDGLEY § Cause No.: 15-DCV-228707
Petitioner, §
§
v. §
§
LATEISHA RAGLAND §
Respondent §
MOTION FOR ENTRY OF TEMPORARY ORDERS
NOW COMES Christian Edgley, Petitioner, and files this Motion for Entry of Temporary Orders, and hereby avers as follows:
- As it stands, the parties are joint conservators of Emmanuel Edgley, the Minor Child.
- Petitioner requests this Court to award him full legal and physical custody of the Minor Child as it is in his best interests to do so.
- Tex. Fam. Code § 153.002 provides thus, “The best interest of the child shall always be the primary consideration of the court in determining the issues of conservatorship and possession of and access to the child.”
- The considerations made by courts in determining the best interest of the child were outlined in Holley v. Adams, 544 SW 2d 367 (1976) as follows: “An extended number of factors have been considered by the courts in ascertaining the best interest of the child. Included among these are the following, (A) the desires of the child; (B) the emotional and physical needs of the child now and in the future; (C) the emotional and physical danger to the child now and in the future; (D) the parental abilities of the individuals seeking custody, (E) the programs available to assist these individuals to promote the best interest of the child, (F) the plans for the child by these individuals or by the agency seeking custody, (G) the stability of the home or proposed placement, (H) the acts or omissions of the parent which may indicate that the existing parent-child relationship is not a proper one; and (I) any excuse for the acts or omissions of the parent.”
- Petitioner is the father of the Minor Child and is fully capable of taking care of his emotional needs. As a man, he also understands the Minor Child’s emotional needs and will guide him whenever necessary.
- Petitioner is capable of providing the Minor Child with a safe and conducive environment for his growth. Petitioner will provide the Minor Child with a stable and secure home with peace and no imminent threat of harm.
- Petitioner is fully aware that he must be in a position to provide the Minor Child with basic needs to ensure the overall health and welfare of the Minor Child. Petitioner is employed and has the financial ability to cater for the needs of the Minor Child.
- Petitioner is and has always been a loving father to the Minor Child. He has never abused or neglected the Minor Child. Granted legal and physical custody of the Minor Child, Petitioner will take care of him and protect him.
REASONS WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully requests this Honorable Court to grant him the following reliefs:
- AWARD Petitioner sole physical and legal custody of the Minor Child;
- AWARD Petitioner such equitable relief as this Court deems appropriate under the circumstances; and
- AWARD Petitioner such further relief as this Honorable Court deems necessary and proper.
Dated this ____ day of January, 2022.
Respectfully Submitted,
___________________________________
Christian Edgley,
Petitioner in pro per
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was sent on the _____ day of _________________, 2022 by electronic mail and regular U.S. mail, to the following parties or attorneys of record:
Donnica Marie Blackful
D Marie Family Law
Bar No.: 24071293
19901 Southwest Freeway
Sugar Land, TX 77479
Phone: (281) 895-3776
Fax: (281) 892-1085
Email: dmb@dmariefamilylaw.com
Dated this 25th day of January, 2022.
Respectfully Submitted,
___________________________________
Christian Edgley,
Petitioner in pro per
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