Supreme Court Case No.: _________
IN THE SUPREME COURT OF THE STATE OF CALIFORNIA
________________________________________________
DENISE CHAVEZ, et al,
Petitioners,
vs.
SAN BERNADINO COUNTY DEPARTMENT OF CHILDREN & FAMILY
SERVICES,
Respondent
_________________________________________________
PETITION FOR REVIEW
_________________________________________________
After a Decision by the Court of Appeal,
Fourth Appellate District, Division Two (No. E077599)
_________________________________________________
DENISE CHAVEZ
[ENTER NAME]
Petitioner in Pro Per
[ENTER NAME]
[ENTER ADDRESS]
Attorneys for Respondents
2
TABLE OF CONTENTS
TABLE OF AUTHORITIES ii
ISSUES FOR REVIEW 1
NECESSITY FOR REVIEW 1
STATEMENT OF THE CASE 3
ARGUMENTS 8
A. THE COURT OF APPEAL JUDGE ERRED IN LAW AND FACT WHEN IT
FAILED TO ADDRESS THE SOCIAL WORKER’S ABUSE OF THE LAW AND
LEGAL MALPRACTICE 8
B. THE COURT OF APPEAL JUDGE ERRED IN LAW AND FACT WHEN IT
FAILED TO CONSIDER HOW LEGAL MALPRACTICE AFFECTED PETITIONER’S
CASE 10
C. THE COURT OF APPEAL JUDGE ERR IN LAW AND FACT WHEN IT HELD
THAT THERE WAS SUFFICIENT EVIDENCE TO SUPPORT THE COURT’S
REMOVAL OF THE CHILDREN 11
D. THE REUNIFICATION PROCESS LASTED MORE THAN SIX MONTHS 14
CONCLUSION 14
CERTIFICATE OF WORD COUNT 16
TABLE OF AUTHORITIES
3
Cases
In re Amy M. (1991) 232 Cal.App.3d 849, 864. 11
In re Crystal J. (1993) 12 Cal.App.4th 407, 412-413 11
In re Dolly D., 41 Cal.App.4th at p. 444 11
In re Jeanette V. (1998) 68 Cal.App.4th 811, 816 11
In re Malinda S. (1990) 51 Cal.3d 368, 383 12
Mirabito v. Liccardo, (1992) 4 Cal. App. 4 th 41, 45. 13
Santosky v. Kramer (1982) 455 U.S. 745, 753-754 [71 L.Ed.2d 599, 606] 11
St. Paul Title Co. v. Meier (1986) 181 Cal. App. 3d. 948, 951. 13
Stanley v. Illinois (1972) 405 U.S. 645, 658 [31 L.Ed.2d 551, 562-563] 11
Welsh v. Wisconsin (1984) 466 U.S. 740, 750 [104 S.Ct. 2091, 80 L.Ed.2d 732]. 14
Statutes
Evid. Code, § 500, 13
Rules
California Rules of Court 8.204 and 8.504(d) 17
4
TO THE HONORABLE CHIEF JUSTICE OF CALIFORNIA AND
ASSOCIATE JUSTICES OF THE CALIFORNIA SUPREME COURT:
Petitioners, Denise Chavez and Miguel R Luna Sr. respectfully petition for a
review of the August 8, 2022 decision of the Court of Appeal, Fourth District,
Division Two (hereinafter “opinion”). Review is necessary to settle important
questions of law.
ISSUES FOR REVIEW
The Appeal Judges made grave errors with this case and there is need for
reversal of the decision.
1. Did the Court of Appeal err in law and fact when it failed to address the Social
Worker’s abuse of the law and legal malpractice?
2. Did the Court of Appeal err in law and fact when it failed to address the legal
malpractice committed by the children’s attorneys and county counsel for the
County’s Department of Child and Family Services?
3. Did the Court of Appeal Judge err in law and fact when it held that there was
sufficient evidence to support the Court’s removal of the children?
NECESSITY FOR REVIEW
Petitioners ask this Court to review the Appellate Court’s decision affirming
the Trial Court’s jurisdictional and dispositional findings and orders. The Petitioners
had appealed the Trial Court’s decision on the grounds that the Trial Court lacked
jurisdiction over the case. Petitioners further aver that the Social Worker and the
attorneys in the case disregarded the law and violated the Petitioners’ rights to familial
association with their minor children Miguel Luna 2nd; Heriberta Luna; Miracle
5
Luna; Miguel Luna Jr; and Alyssa Luna, under both the Federal and California
Constitutions and the California Family Code.
This Court should grant review for three reasons, which raise pertinent
questions as to Petitioners’ substantive and procedural rights under the law.
First, the Social Worker in the Trial Court committed several violations of the
law. The Court of Appeal failed to acknowledge this fact. Failure to address the Social
Worker’s violations of the law would further impede Petitioner’s rights. The Court of
Appeal failed to consider the legal misconduct and/or malpractice committed by the
children’s attorneys in the case. For instance, the attorneys submitted hearsay
evidence, which the Court admitted. Accordingly, this Court should grant review and
reverse the Appeal Court’s decision thus protecting Petitioners’ rights.
Second, the Court of Appeal failed to consider the legal misconduct and/or
malpractice committed by the children’s attorneys and the county counsel for the
County’s Department of Child and Family Services in the case. For instance, the
attorneys submitted hearsay evidence, which the Court admitted. Accordingly, this
Court should grant review and reverse the Appeal Court’s decision thus protecting
Petitioners’ rights.
Third, the Court of Appeal erroneously held that there was sufficient evidence
to justify the removal of the children from Petitioner. On the contrary, there was no
good cause to interfere with the best interests of the children to wit, their right to
parental custody and affection. Accordingly, this Court should grant review and
reverse the Appeal Court’s decision thus protecting Petitioners’ rights.
STATEMENT OF THE CASE
6
On or about January 13, 2021, Respondent San Bernardino County Department
of Children and Family Services filed a case at the Superior Court of California, San
Bernardino County Juvenile Dependency Court 1 . In the said case, it was alleged that
Petitioner mother tested positive at the birth of Miguel 2 nd . It was also alleged that the
Petitioners had tested positive for substance abuse, and that the alleged substance
abuse has compromised the parents’ ability to properly and adequately care for and
parent the child. It was further alleged that the parents had failed to provide food,
shelter, and clothing to the child. Lastly, the Respondent alleged that the parents had
failed to benefit from previous interventions by the Children and Family Services
Contrary to the assertions, Petitioners aver that the Social workers in the case,
the State Court, and Loma Linda University Medical Center used Fabricated Drug test
Results for Miguel Luis Luna 2 nd to unlawfully interfere with Parents’ fundamental
liberty to raise their sons and daughters as parents deem fit (App 1- Miguel’s Medical
Report 2 ; App. 2- Status Review Report).
Petitioner mother signed a Release of Information with the confirming
laboratory, hoping to find the authentic results for the drug test. Interestingly, the
confirming laboratory replied to Petitioner and stated that after a complete search of
their electronic files at Mayo Clinic Laboratories, they were unable to locate the
patient’s name or the specific records requested, or both (App. 3- Response from
Mayo Clinic Laboratories). This is concrete proof that the Social Worker fabricated
the test results.
1 In Re M.L.L., H.L., M.L., M.S., JR., & A.L, Case No. J287762-66
2 App. ___, refers to the Exhibit number in the Appendix to this Petition.
7
Accordingly, the Social workers, without due cause, opened a cfs case against
the Petitiones, without a positive screening. Until this day the Respondent never
provided State court and the Appeal Court an actual drug screen for Denise.
During the hearing of the case on January 14, 2021, the Trial Court Judge was
openly impressed and observed that the Appellants had shown cooperation when they
showed up with the children in court. (App. 4- Tr. p. 8, lines 18-20) 3 .
The next hearing was on January 20, 2021. The Court noted that the
Petitioner’s home was being renovated, and that made it not conducive for the
children. However, the Court observed that the children were rightly placed at the
paternal grandmother’s house. (Tr. p. 14, lines 2-4). No contention was raised on this.
The Court also assured the Appellants that because of their cooperation, the children
would not be taken from them. (Tr. p. 16, lines 12-14).
Consequently, on March 10, 2021, during the hearing, the father’s attorney
informed the Court that the father would take care of the children adequately. (Tr. p.
25, lines 1-7). The mother’s attorney further informed the Court that contrary to the
Court’s assertions, the mother’s testing was clean, and that she had not missed any
testing. (Tr. p. 25, lines 14-15). The Petitioners were also still living at the
grandmother’s house as required. The Petitioner mother’s attorney further expressed
concerns of due process violations in that the Court sought to retain the children
without a detention notice. (Tr. p. 26, line 1). Besides, the children were not at any
risk that would warrant the Court to detain the children that day. The attorney further
informed the Court that the mother was willing to take another test that day since she
3 All references to (Tr. P__, Line(s) __) are to the transcript of the Court Proceedings.
8
was going to be tested for COVID-19 that day. (Tr. p. 26, lines 9-17). Besides, the
children had expressed their wish to remain in their grandmother’s house. (Tr. p. 27,
lines 2-5). The Petitioner’s attorney further stated that the mother’s previous testing
have been negative. (Tr. p. 27, lines 19-20).
Further, on the self-same day, the Court turned down the Petitioner father’s
concerns that no tests had turned positive, and that the Social Worker was aware of
this. (Tr. p. 29, lines 1-10). No issue was raised when the Social Worker visited the
children at the grandmother’s house. Ultimately, the Court ordered the detaining of the
children amidst the concerns raised by the Petitioners.
The next hearing happened in April 26, 2021. During the hearing, the
children’s attorney sought to include evidence that contained hearsay information.
Both of the Petitioners’ attorneys objected to the inclusion of the said evidence. (Tr. p.
40, lines 4-6 & Tr. p. 39, lines 19-21). However, the Court still proceeded to admit the
said evidence. (Tr. p. 45, lines 5-8). On that day, witness Billy Seals, who was the
Petitioners’ neighbor, testified that he had never seen Petitioner Denise Chavez under
the influence. (Tr. p. 51, lines 11-13). He had also never seen Petitioner Denise hit
her children or abuse them. (Tr. p. 51, lines 14-28). The said witness further testified
how good mannered the Petitioner Denise was. (Tr. p. 52, lines 8-11).
The next hearing was done in June 9, 2021. During the hearing, concern was
raised that the Court did not have the power to order a drug test prior to detention, per
In Re E.E. (Tr. p. 60, lines 27-28). However, the Court denied the argument and
stated that although the Court did not compel the Petitioners to take the drug tests, the
Court would consider the lack of drug tests in its findings. When the Social Worker
9
was being interviewed, she testified that part of the Detention Report needed to be
dismissed for lack of evidence. (Tr. p. 66, lines 16-17). Further, the minors had never
told the Social Worker that they had any problems with the Appellants. (Tr. p. 66,
lines 19-20). The social worker also testified that she had never been to the house
where the Petitioners lived to ascertain the living conditions of the children. (Tr. p. 69,
lines 6-9). The Social Worker also stated that she was not aware of any third party or
neighbors who informed her that the children were not being taken care of. (Tr. p. 74,
lines 14-17). Additionally, the Social Worker testified that there was nothing to show
that the father had done any conduct or was in a state that would cause the detention
of the children by the Court.
When cross examined by the Petitioner mother’s attorney, the Social Worker
stated that she recommended family reunification and that the children should be
returned to the Appellants. (Tr. p. 83, lines 23). The Social Worker further testified
that she had never seen the mother under the influence. (Tr. p. 88, line 1). Further,
when the mother tested positive, the Social Worker was not sure it was positive for
what test. (Tr. p. 89, lines 2-3). The Social Worker was therefore not sure what kind of
test was done and what it turned positive for, and whether the positive result was for
the mother or the baby. Further, the Social Worker had not booked an appointment
with the mother’s attorney, to set up an interview with the mother to ascertain whether
the mother indeed abused drugs. (Tr. p. 97, lines 5-12). The Social Worker further
testified that she had not ascertained the veracity of the positive results from the
hospital and that she was not aware whether they could not be relied upon due to lack
of confirmation. (Tr. p. 100, lines 4-6). The Social Worker further stated that it is
10
traumatic for children not to be placed with their biological parents. (Tr. p. 106, lines
5-8).
The next hearing occurred on August 19, 2021. During the hearing, the
Petitioner mother’s attorney stated that the Respondent had failed to provide sufficient
evidence to show why the children should be removed from the Petitioners by reason
of the mother’s conduct. (Tr. p. 180, lines 10-24). The father’s attorney also stated that
the Respondent had failed to provide sufficient evidence to show why the children
should be removed from the Appellants by reason of the father’s conduct. (Tr. p. 182,
lines 25-28 & p. 183, lines 1-3). The Judge was also informed that the children had
intimated that they felt more comfortable with the Appellants and wanted to live with
them. (Tr. p. 202, lines 1-5). However, the Court held that the Respondent had
sufficiently produced for its allegations against the Petitioners and that the children
needed to be removed from the custody of the parents.
Accordingly, the Petitioners filed an appeal against the Trial Court’s decision 4 .
On or about August 8, 2022, the Court of Appeal affirmed the Trial Court’s decision
to remove the children from the Petitioners.
On or about February 7, 2022, the Social Worker further restrained the
Petitioner mother from exercising her parental right over the child. Miguel Luis Luna
2 nd had initially went to the hospital for an unknown insect bite on his right cheek. The
doctors claimed that Miguel had a mass on his face and that he required immediate
medical attention and that he had tested positive for covid-19. On February 6, 2022,
Miguel was restrained from consuming anything as he was scheduled to undergo a
4 San Bernardino County Children and Family Services v. D.C. et al., Appeal Case No. E077599
11
biopsy procedure on February 7, 2022. However, on February 7, the doctor missed the
appointment with Miguel. However, upon further consultation, the Petitioners
discovered that it is not a requirement to restrict meals when awaiting to undergo a
biopsy. Concerned for the safety of the child’s safety, the Petitioners sought to have
the child removed and transferred to another hospital. However, the social worker
placed at the hospital restrained the Petitioner sfrom removing the child from the
hospital. At some point, the Petitioner mother was escorted away from the child under
the custody of four security personnel. Consequently, the mother was alienated and
kept away from her child.
ARGUMENTS
A. THE COURT OF APPEAL JUDGE ERRED IN LAW AND FACT
WHEN IT FAILED TO ADDRESS THE SOCIAL WORKER’S ABUSE
OF THE LAW AND LEGAL MALPRACTICE
It is axiomatic that due process guarantees apply to dependency proceedings.
Santosky v. Kramer (1982) 455 U.S. 745, 753-754 [71 L.Ed.2d 599, 606]; Stanley v.
Illinois (1972) 405 U.S. 645, 658 [31 L.Ed.2d 551, 562-563]. Parties to such
proceedings have a due process right to confront and cross-examine witnesses, at least
at the jurisdictional phase. In re Jeanette V. (1998) 68 Cal.App.4th 811, 816; In re
Dolly D., 41 Cal.App.4th at p. 444; In re Amy M. (1991) 232 Cal.App.3d 849, 864.
The essence of due process is fairness in the procedure employed; a meaningful
hearing, one including the right to confront and cross-examine witnesses, is an
essential aspect of that procedure. In re Crystal J. (1993) 12 Cal.App.4th 407, 412-
413. But due process also is a flexible concept, whose application depends on the
12
circumstances and the balancing of various factors. In re Jeanette V., 68 Cal.App.4th
at p. 817; see In re Malinda S. (1990) 51 Cal.3d 368, 383.
The Court of Appeal failed to address the Social Worker’s abuse of the law.
First, the Social Worker presented fabricated evidence of Miguel Luis Luna 2nd test
results. As proof that the Social Worker fabricated the results, Petitioner mother
signed a Release of Information with the confirming laboratory, hoping to find the
authentic results for the drug test. Interestingly, the confirming laboratory replied to
Petitioner and stated that after a complete search of their electronic files at Mayo
Clinic Laboratories, they were unable to locate the patient’s name or the specific
records requested, or both (App. 3- Response from Mayo Clinic Laboratories 5 ).
Next, on or about February 7, 2022, the Social Worker restrained the Plaintiff
from exercising her parental right over the child. Miguel Luis Luna 2nd had initially
went to the hospital for an unknown insect bite on his right cheek. The doctors
claimed that Miguel had a mass on his face and that he required immediate medical
attention and that he had tested positive for covid-19. On February 6, 2022, Miguel
was restrained from consuming anything as he was scheduled to undergo a biopsy
procedure on February 7, 2022. However, on February 7, the doctor missed the
appointment with Miguel. However, upon further consultation, the Plaintiffs
discovered that it is not a requirement to restrict meals when awaiting to undergo a
biopsy. Concerned for the safety of the child’s safety, the Plaintiffs sought to have the
child removed and transferred to another hospital. However, the social worker placed
at the hospital restrained the Plaintiffs from removing the child from the hospital. At
5 App. 1, refers to the first Exhibit in the Appendix to this Petition.
13
some point, the mother of the child was escort away from the child under the custody
of four security personnel. Consequently, the mother was alienated and kept away
from her child.
B. THE COURT OF APPEAL JUDGE ERRED IN LAW AND FACT
WHEN IT FAILED TO CONSIDER HOW LEGAL MALPRACTICE
AFFECTED PETITIONER’S CASE
Rule 3.3 of the California Rules of Professional Conduct requires lawyers to
always be truthful when addressing a court. The California Rules of Professional
Conduct further sets forth duties owed by attorneys to their clients. See Mirabito v.
Liccardo, (1992) 4 Cal. App. 4 th 41, 45. The law extends an attorney’s liability to a
third party for professional negligence. See St. Paul Title Co. v. Meier (1986) 181 Cal.
App. 3d. 948, 951.
Petitioners aver that the Court of Appeal also failed to address the legal
malpractice committed by the children’s attorneys and the county counsel for the
County’s Department of Child and Family Services. In the hearing that took place on
April 26, 2021 at the Trial Court, the attorneys sought to include evidence that
contained hearsay information. Both of the Petitioners’ attorneys objected to the
inclusion of the said evidence. (Tr. p. 40, lines 4-6 & Tr. p. 39, lines 19-21). However,
the Court proceeded to admit the attorneys’ evidence, despite the Petitioners’
objection.
C. THE COURT OF APPEAL JUDGE ERR IN LAW AND FACT WHEN
IT HELD THAT THERE WAS SUFFICIENT EVIDENCE TO SUPPORT THE
COURT’S REMOVAL OF THE CHILDREN
14
According to Evid. Code, § 500, “[e]xcept as otherwise provided by law, a
party has the burden of proof as to each fact the existence or nonexistence of which is
essential to the claim for relief or defense that he is asserting.” It follows; “[b]efore
agents of the government may invade the sanctity of the home, the burdens on the
government to demonstrate exigent circumstances that overcome the presumption of
unreasonableness that attaches to all warrantless home entries.” Welsh v. Wisconsin
(1984) 466 U.S. 740, 750 [104 S.Ct. 2091, 80 L.Ed.2d 732].
Here, the Court of Appeal failed to consider the glaring insufficiency of
evidence to warrant the children’s removal from the Petitioners. First, no issue was
raised when the Social Worker visited the children at the grandmother’s house.
Second, during the hearing on April 26, 2021, witness Billy Seals, who was the
Petitioners’ neighbor, testified that he had never seen Petitioner Denise Chavez under
the influence. (Tr. p. 51, lines 11-13). He had also never seen Petitioner Denise hit
her children or abuse them. (Tr. p. 51, lines 14-28). The said witness further testified
how good mannered the Petitioner Denise was. (Tr. p. 52, lines 8-11).
Further, when the Social Worker was being interviewed, she testified that part
of the Detention Report needed to be dismissed for lack of evidence. (Tr. p. 66, lines
16-17). Further, the minors had never told the Social Worker that they had any
problems with the Appellants. (Tr. p. 66, lines 19-20). The social worker also testified
that she had never been to the house where the Petitioners lived to ascertain the living
conditions of the children. (Tr. p. 69, lines 6-9). The Social Worker also stated that she
was not aware of any third party or neighbors who informed her that the children were
not being taken care of. (Tr. p. 74, lines 14-17). Additionally, the Social Worker
15
testified that there was nothing to show that the father had done any conduct or was in
a state that would cause the detention of the children by the Court.
Accordingly, Petitioners aver that the Social Worker withheld pertinent
information from the Court. For instance, although it is alleged that Petitioners
neglected the children educationally, Petitioner mother had provided social worker the
information for the children’s online home school. The Petitioners also bought laptops
for all children so they could attend but the foster mother took the laptops. It can also
not be alleged that the Petitioners neglected the children yet the children were not in
the Petitioners’ care to neglect them educationally, and social workers failed to state
that in the beginning of the case.
Sheriff Hernandez asked the social worker if she was going to press charges
against Petitioners and if she had proof. The Social Worker denied that she was not
pressing charges on Petitioners and that she did not have any evidence to back her
allegations. The Social Worker also withheld the police report form the Court, which
report is dated January 7, 2021.
The Respondent also failed to mention to the Court that judge Browdie denied
their detention warrant. Petitioners aver that if the Respondent’s allegations were true,
the report clearly states that when social worker interviewed the children, she
observed the children were free from bruises, were dressed appropriately for the
weather, that she had no concerns medically, socially, educationally, emotionally and
physically. The Social Worker further observed that the children had all provisions
including necessary beds, clothes, and that the baby had a bed, formula, and diapers.
Petitioners aver that failure to acknowledge the reason for a cps intervention is
16
not a sufficient reason to detain the children. Also on March 30, 2021, the children
were removed due to the Social Worker refusing to enter the home because she
withheld Petitioner mother’s signed cfs 32 form that was needed so Petitioner mother
could undergo a drug test.
It is also notable that when cross examined by the Petitioner mother’s attorney,
the Social Worker stated that she recommended family reunification and that the
children should be returned to the Appellants. (Tr. p. 83, lines 23). The Social Worker
further testified that she had never seen the mother under the influence. (Tr. p. 88, line
1). Further, when the mother tested positive, the Social Worker was not sure it was
positive for what test. (Tr. p. 89, lines 2-3). The Social Worker was therefore not sure
what kind of test was done and what it turned positive for, and whether the positive
result was for the mother or the baby. Further, the Social Worker had not booked an
appointment with the mother’s attorney, to set up an interview with the mother to
ascertain whether the mother indeed abused drugs. (Tr. p. 97, lines 5-12). The Social
Worker further testified that she had not ascertained the veracity of the positive results
from the hospital and that she was not aware whether they could not be relied upon
due to lack of confirmation. (Tr. p. 100, lines 4-6). The Social Worker further stated
that it is traumatic for children not to be placed with their biological parents. (Tr. p.
106, lines 5-8).
In light of the foregoing, there was insufficient evidence to find the Petitioners
unfit to keep the children. The Court of Appeal failed to acknowledge this fact and for
that reason, its decision should be reversed.
D. THE REUNIFICATION PROCESS LASTED MORE THAN SIX MONTHS
17
According to the Parents’ ‘Guide to Dependency Court’, provided by the
Judicial Council of California, “[a]fter the court order [the parent] to participate in
reunification services, [the parent’s] next court hearing is not for 6 months”. The
guide further provides that “if [the parent’s] child is under three years old, [the parent]
will have only six months to show that [he/she is] committed to finishing up
everything.”
In this action, the services to facilitate reunification were held in contravention
to the above requirement. On January 14, 2021, the court held a detention hearing in
the instant case. The Court ordered the Petitioners to engage in reunification services,
have their home assessed, and drug/alcohol test that day, and the parents agreed.
However, up until August 19, 2021, which is about eight months later, hearings were
still being held, with a jurisdiction/disposition hearing held on the said date.
CONCLUSION
In light of the foregoing, the Appeal Court erred in affirming the Trial Court’s
decision for the aforesaid reasons. Accordingly, the Appeal Court’s decision should be
reversed, and judgment entered in favor of the Petitioner. The Petitioner also prays for
any other relief this Court deems just.
Date:
Respectfully submitted,
18
_______________________
Denise Chavez;
11755 Star Street
Adelanto California 92301
(760)980-5715
Chavezdenise609@gmail.com
Mother, Petitioner, pro se
_______________________
Miguel R Luna Sr.
11755 Star Street
Adelanto California 92301
(760)980-5715
Lunamiguel813@gmail.com
Father, Petitioner, Pro se
CERTIFICATE OF WORD COUNT
I certify pursuant to California Rules of Court 8.204 and 8.504(d) that this
Petition is proportionally spaced, has a typeface of 13 points or more, contains 3914
words, excluding the cover, the tables, the signature block, verification, and this
certificate, which is less than the total number of words permitted by the Rules of
19
Court. Petitioner relies on the word count of the Microsoft Word word-processing
program used to prepare this brief.
I certify under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Date:
_______________________
Denise Chavez;
11755 Star Street
Adelanto California 92301
(760)980-5715
Chavezdenise609@gmail.com
Mother, Petitioner, pro se
_______________________
Miguel R Luna Sr.
11755 Star Street
Adelanto California 92301
(760)980-5715
Lunamiguel813@gmail.com
Father, Petitioner, Pro se
CERTIFICATE OF SERVICE
I certify that a copy of this Petition was served on [ENTER DATE] to the Respondent
in this action.
DATE:
[ENTER RESPONDENT’S ADDRESS]
20
SS
_______________________
Denise Chavez;
11755 Star Street
Adelanto California 92301
(760)980-5715
Chavezdenise609@gmail.com
Mother, Petitioner, pro se
_______________________
Miguel R Luna Sr.
11755 Star Street
Adelanto California 92301
(760)980-5715
Lunamiguel813@gmail.com
Father, Petitioner, Pro se
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