PETITION FOR AN INJUNCTION AND FOR A TEMPORARY RESTRAINING by zfg52569

VIEWS: 302 PAGES: 3

									                                                                           6:       0   ’
                                                              I                 .
             IN THE DISTRICT COTJRT OF WYANDOTTE COUNTY, &SA;I/



TINY SAMPEL,
                               Plaintiff,
            vs.
                                                         >
ROBERT BALBERNIE,                                        >
                               Defendant.                >



                      PETITION FOR AN INJUNCTION AND FOR
                       A TEMPORARY RESTRAINING ORDER
 Pursuant To K.S.A. 60-901 et sea:


            PLAINTIFF, for her cause of action against the defendant alleges and states:
  I
            1.    That she is a bona fide resident of Kansas City, Wyandotte County,

Kansas.                                                                                     I
  !‘i
  i_. ’
  _
        2.        That defendant may be personally served with summons in this matter

located at Dwight D. Eisenhower VA Hospital, 116 Al, Bldg. 122, Levenworth,

Kansas.
      .._
      i,’ 3.      -That defendant has trespassed onto the plaintiffs property, forcibly

entered her residence and assaulted and battered her. The plaintiff has been unable

to obtain adequate protection from the police because she does not have a restraining
order.
   T..,
       4 .         Because of these actions by the defendant and the inability or

unwillingness of the proper law enforcement officers to assist her, plaintiff is in fear
that, unless enjoined, the defendant will continue to bother, threaten, interfere with,

harm her, or disrupt the peace of her place of residence through word of mouth,

threatening language, physical acts, or the like.
,




 \,,; 5.       Plaintiff has exhausted every other remedy known to her at law, and

that without action of this Court, she will be without any remedy at all.

    .;> 6.     To the best of her knowledge and belief, defendant is unrepresented in

this matter.

        WHEREFORE, plaintiff petitions the court to issue an Injunction and a

Temporary Restraining Order pursuant to K.S.A 60-903; and for such other and

further relief as the court may find fair, just, and equitable in this matter.




                                                 THEA RAD!EhJACHER
                                                 Sup. Ct. I.D. #15025
                                                 Wyandotte-Leavenworth
                                                   Legal Services
                                                 825 North 7th Street
                                                 Fourth Floor
                                                 Kansas City, KS 66101
                                                 (913) 621-0200 (telephone)
                                                 ATTORNEY FOR PLAINTIFF
                               POVERTY AFFIDAVIT

STATE OF KANSAS
                                   ;ss
COUNTY OF WYANDOTTE                )

        Tiny Sampel, of lawful age, on oath being first duly sworn, deposes and states:

       That she is the plaintiff above named; that she has read the above and
foregoing Petition; knows the contents thereof, and that the facts, matters, and
statements therein contained are true to the best of her knowledge and belief.

       That “I do solemnly swear that I am a resident of the State of Kansas, and
that the cause of action set forth in the Petition hereto prefixed is just, and that by
reason of my poverty, I am unable to give security for costs. I do further swear that
my income is $ $403.00 per month from Aid to Families with Dependent Childen and
that I am currently supporting myself and two minor children.”




                                             ‘
        Subscribed and sworn to before me /thisp d a y            o f   & &      7
1993.
                                                & c & L o               &   @
                                                N’OTARY PUBLIC
My Appointment Expires:
     KmuEENJbNAu
        - # # I c

                                     CERTIFICATE

        I hereby certify that I have carefully examined the Petitioner as to her
financial condition, and to my knowledge and belief the Poverty statement filed herein
is true. I further represent that I am one of the attorneys for Wyandotte-
Leavenworth Legal Services; that no fees are paid by the clients we serve and this
litigant has met our standards of indigency and is eligible for our services.




                                                Sup. Ct. I.D. #15025
                                                Wyandotte-Leavenworth
                                                 Legal Services
                                                825 N. 7th Street, 4th Floor
                                                Kansas City, Kansas 66101
                                                (913) 621-0200 (telephone)
                                                (913) 621-3817 (facsimile)

								
To top