MOTHER'S PETITION TO ESTABLISH LEGAL CUSTODY AND REQUEST FOR HEARING CAUSE NO. 20D06-1604-JP-133 IN THE ELKHART SUPERIOR COURT 6 FOR THE STATE OF INDIANA, ELKHART COUNTY IN RE: THE CUSTODY OF: Itzel Janeth Hernandez Morales, Tanya Hernandez, Alexandria Hernandez, MINOR CHILDREN COMES NOW, Mother, by Counsel Felipe N. Merino, requesting that this Court establish full legal custody of the minor Children in her favor. In support of this request, Mother hereby declares the following under penalties of perjury: 1. The Minor Children and their Mother reside in Elkhart County, Indiana. 2. The Father of the Children left to Mexico six (6) years ago and his whereabouts are unknown. 3. Mother is the Sole Provider for the Children. 4. Mother is Petitioning this Court to grant sole custody so that she may make educational, healthcare and religious decisions for the well-being of the children. WHEREFORE, Petitioner/Mother, by Counsel, requests that this Court establish full legal custody of the minor Children in her favor, as well as set this matter for hearing, and for all other just and proper relief. Dated April 11, 2016 Wendy Hudson, Clerk of Elkhart Superior Court 6, Elkhart County, Indiana Felipe N. Merino, Attorney for Petitioner MERINO LAW FIRM, P.C. 102 N. Main Street, Goshen, Indiana 46526 (574) 807-0512 April 28 May 5, 12 hspaxlp
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