• Complained for dependency Legal notice Plaintiff Ana M Garcia Quitero — Defendant
• Juan David Garcia Middlesex Family and Probate Court — Woburn Massachusetts
Por Tatiane Martinelli | GNEWSUSA
X abuse X neglect X abandonment or X a similar basis under state law, namely:
AS SET FORTH IN THE ATTACHED AFFIDAVIT OF ANA MARIA GARCIA QUINTERO, AND MEMORANDUM OF LAW IN SUPPORT OF THE COMPLAINT FOR DEPENDENCY AND MOTION FOR SPECIAL FINDINGS, ANA CLAUDIA FARIA WAS NEGLECTED AND ABANDONED BY THE DEFENDANT, GARCIA MONTOYA JUAN DAVID.
4. If applicable:
Parent Two, First Name M.I.
who resides at:
(Address) (Apt, Unit, No. etc.)
• the mother of Child who is the subject of the Complaint.
t h e father of Child who is the subject of the Complaint.
• the deceased mother of Child who is the subject of the Complaint.
• the deceased father of Child who is the subject of the Complaint.
(City/Town)
Reunification with Parent Two is not a viable option for Child due to:
• abuse • neglect • abandonment or a similar basis under state law, namely:
Last Name
(State) is,
(Zip)
(set forth legal standard, statutory law and/or case law)
5. Child is unmarried and under 21 years of age.
6. Child is dependent on the Court for his/her protection, well-being, health, and safety.
7. It is not in Child’s best interest to return to
COLOMBIA Country
, the country of his/her and/or his/her
parents’ nationality or last habitual residence.
8. It is in the best interest of Child to continue in the care of:
First N a m e M.T.
Last Name
9. Affidavit(s) and/or other evidence regarding the facts alleged is/are attached in support of this Complaint.
WHEREFORE, Plaintiff/Child requests that the Court:
X find that Child is dependent on the Court
X find that Child is under age 21
X find that Child is unmarried
X find that reunification of Child with Parent One is not a viable option due to:
abuse & neglect & abandonment or X a similar basis under state law, namely:
AS SET FORTH IN THE ATTACHED AFFIDAVIT OF ANA MARIA GARCIA QUINTERO, AND MEMORANDUM OF
LAW IN SUPPORT OF THE COMPLAINT FOR DEPENDENCY AND MOTION FOR SPECIAL FINDINGS, ANA
MARIA GARCIA QUINTERO WAS NEGLECTED AND ABANDONED BY THE DEFENDANT, GARCIA MONTOYA
JUAN DAVID.
by Parent One.
If applicable: find that reunification of Child with Parent Two is not a viable option due to:
• abuse neglect • abandonment or [ a similar basis under state law, namely:
by Parent Two.
• find that it is not in Child’s best interest to return to,
COLOMBIA
Country ., the country of his/her and/or
his/her parents’ nationality of last habitual residence.
• find that it is in the best interest of Child to continue in the care of:
First Name M.T. Last Name
X enter a Judgment pursuant to G. L. c. 119, § 39M
X order that Child be referred to the Probation Service for the following services:
X educational X occupational & medical X dental X counseling X social X domestic violence
anti-trafficking X and/or
ANY AND ALL OTHER ORDERS AND SERVICES THIS HONORABLE COURT DEEMS REASONABLE,
NECESSARY AND JUST.
services a s needed.
enter any other orders the Court deems necessary for the protection from abuse, abandonment, and neglect, and for
the well-being, care, support, health and safety, and best interest of Child.
X enter an order for relief requested below, namely:
DECLARE THAT PLAINTIFF IS DEPENDENT UPON THIS COURT; DECLARE THAT PLAINTIFF REMAIN UNDER
THIS COURT’S JURISDICTION UNTIL SHE ATTAINS THE AGE OF TWENTY-ONE; DECLARE THAT PLAINTIFF
WAS NEGLECTED AND ABANDONED BY THE DEFENDANT, AND THAT REUNIFICATION WITH THE DEFEDANT
IS NOT VIABLE OPTION FOR HER; DECLARE THAT PLAINTIFF HAS NO SUPPORT OR PROTECTION IF
RETURNED TO COLOMBIA, THUS THAT IS NOT AN OPTION; DECLARE THAT IT IS IN PLAINTIFF’S BEST
INTEREST NOT TO RETURN TO COLOMBIA; AND DECLARE THAT IT IS IN PLAINTFF’S BEST INTEREST TO
REMAIN IN THE UNITED STATES.
Date: 10-15-24
Signature of Attorney or Plaintiff, if pro se
MICHAEL F. MACDONALD, ESQ
(Print name)
431 WASHINGTON STREET
(Address)
MA
(State)
(Apt, Unit, No, etc.) 01902
(Zip)
Primary Phone #: 781-598-3990
B.B.O. # 557522
Email: MIKEMACDONALDLAW@AOL.COM
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