IN RE: THE MARRIAGE OF NANCY ST. GEORGE, 22) Petitioner, = vs. JAMES ST. GEORGE, Respondent. IN THE CIRCUIT COURT OF THE 18™ JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA CASE NO: 05-2005-DR-22015-XXXX-XX, = = 2 2: 2 TANI OF 11d SH 2 clibl avn coy SITI3 11098 0 / MOTION FOR APPOINTMENT OF PRIVATE GUARDIAN AD LITEM COMES NOW the Petitioner, NANCY ST. GEORGE, by and through her undersigned counsel and files this Motion for the Appointment of a Private Guardian Litem and in support thereof would state as follows: ib ‘The parties are embroiled in a bitter and acrimonious dissolution of marriage action. ‘There are already exists a Temporary Injunction for Protection Against Domestic Violence in favor of the Wife and against the Husband. ‘The Wife has alleged, among other things, that the Husband held her at knife point for a period of time one evening back in February, leading to the entry of the Temporary Injunction for Protection Against Domestic Violence. Asa result of that event, the Husband did not have any visitation or contact with the parties” minor child for a period of approximately 2 to 3 months. ‘The Husband did have visitation with the minor child this past weekend, May 14" and 15, 2005. Upon return from visitation, the Wife has leamed the following things from the minor child: Case #: _05-2005-DR-022015-1000K Document Page #: 35 {A a poveid |The minor child commented to my client upon being returned from. visitation something to the effect that she had “large drooping boobs and that she should have surgery to correct that problem”. ‘The minor child reported to my client that his father had commented on his weight, which is the minor child’s weight, asking the minor child why he was so fat. ‘The minor child also advised Ms. St. George that some time during the visit, mid day, that your client went into a bedroom with Sonya, closed the door and that he was watched or babysat by some unknown adult male who had a large dog with him. The minor child did not know who this person was and did not know how long he was watched by this person. Further, apparently this did not ocour at Dr. St. George’s home and occurred somewhere else, a location unknown to the minor child, making him uncomfortable. Upon being returned from visitation, the minor child began acting ‘out in a manner that he had previously done prior to the suspension of contact between the minor child and your client. He was throwing his head and told Mrs. St. George that he was going to “cut her into pieces with a knife” and also “cut up her veins”. ‘Also, the minor child was returned from visitation with substantial bruises on both knees and when asked how those bruises got there, the minor child responded “Daddy told me not to tell”. The statements by the child were unsolicited by the Wife herein and were rather spontaneous in nature. To better advise the Court and to protect the best interests of this child, the Petitioner feels that itis imperative that the Court appoint a private Guardian Ad Litem to protect the interests of the child and to advise this Court as to what is going on between the minor child and the Respondent. ‘The Petitioner is a traditional stay at home housewife and the Respondent is employed as a medical physician and has substantial income of 000615approximately $300,000.00 to $400,000.00 per year and is in a far better position to pay for the private Guardian Ad Litem that is requested herein. WHEREFORE, based upon the foregoing, the Petitioner/Wife, NANCY ST. GEORGE, respectfully requests that the Court enter an Order appointing a private Guardian Ad Litem to protect the best interests of the minor child and order that the Respondent/Husband pay for the private Guardian Ad Litem’s services and grant the Petitioner/Wife any further relief that the Court deems necessary and proper. I HEREBY CERTIFY that a true copy of the foregoing has been furnished to Philip J. Fougerousse, Esquire, 1329 Bedford Drive, Melbourne, Florida 32940 this 18" day of May, 2005, via U.S. Mail. RICHARD J. FEINBERG, ESQUIRE 503 Fifth Avenue, Suite 202 Indialantic, Florig4$2903 G21) 959}4545 Richard ¥%inberg, Esquire Florida Bar No: 347612 Attomey for Petitioner 000616