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STATE OF INDIANA ) IN THE JOHNSON CIRCUIT COURT

)SS:
COUNTY OF JOHNSON ) CAUSE NUMBER 41C0l-1808-JC-000097
4 I CO l-1808-JC-000096
IN RE: THE MATIER OF
DENVER FRANCIS
ASPEN FRANCIS

EMERGENCY MOTION TO STAY UNSUPERVISED


VISITATION WITH FATHER

COMES NOW, Lacey Morse, Mother, by counse~ Valerie Horvath, and files her

Emergency Motion to Stay Unsupervised Visitation with Father and in support thereof

states as follows:

I. Father has six (6) Driving Under the Influence ("DUI") arrests/convictions

in two (2) states, Oklahoma and Indiana.

2. Father has a history of Domestic Violence ("DV") arrests and convictions

in Oklahoma. See news article and certified business records of criminal history attached

hereto as Exhibit A.

3. Immediately prior to the recent accident which led to the filing of this

action, Father threatened Mother that he would kill himself and the children if she

wouldn't take him back.

4. The recent accident is not a simple DUI case, this is a DV case with

incredibly high lethal risks of murder-suicide.

WHEREFORE, Lacey Morse, Mother, requests that Court stay the Order for the

children's unsupervised visitation with Father and all other relief as is just and proper.