IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA GILBERT FREEMAN, JR., Plaintiff, vs.

JODY EBRIGHT TODD, Defendant. CIVIL ACTION NO. 12-CV-1077-TB

PLAINTIFF'S MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM

COMES NOW Gilbert Freeman, Jr., Plaintiff herein, and files his Motion for Appointment of Guardian Ad Litem and shows the Court as follows 1. Plaintiff herein filed a Petition for Custody of Minor Children in this case, in which Plaintiff is seeking permanent custody of the parties' two minor children. 2. In Defendant's Answer and Counterclaim previously filed in this matter, Defendant is requesting that she be awarded permanent primary physical custody of the parties' younger minor child with the Plaintiff being awarded primary physical custody of the parties' older child. 3. Plaintiff shows that both children should be placed in the Plaintiff's permanent primary physical custody and that Plaintiff is a fit and proper parent to have custody of said minor children.

4. Plaintiff shows that the minor children are not represented in this action and that it would be in the minor children's best interest to have a guardian ad litem appointed for said children so that their rights can be protected herein to the fullest extent possible. Further, Plaintiff shows that the appointment of a guardian ad litem will assist the Court in the determination of the best interests of the minor children. 5. Due to the fact there is currently pending an action between Plaintiff and Defendant regarding the future custody of the parties' minor children, Plaintiff requests that this Court appoint a guardian ad litem to represent and speak for the minor children in this litigation and to assist the Court in the determination of the best interests of the children. WHEREFORE, Plaintiff moves this Court to enter an Order appointing a guardian ad litem to represent the minor children in this action. Respectfully submitted this L

i&-

day of

2012.

LAW OFFICE OF JANA L. EVANS 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 (phone) (770) 443-9013 (fax) na L. Evans
a. Bar No. 200090

IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA GILBERT FREEMAN, JR., Plaintiff, vs. JODY EBRIGHT TODD, Defendant. ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 12-CV-1077-TB

CERTIFICATE OF SERVICE
This is to certify that I have this day served a true and correct copy of Plaintiff's Motion for Guardian ad litem upon all parties in this matter, by either e-mail or by placing the same in the United States Mail, with adequate postage, addressed as follows: Parisa N. Herrin parisa@herrinlawfirm.com 30 Trammell Street Marietta, GA 30064 Respectfully submitted this day of 2012.

Jc na L. Evans (Ia. Bar No. 200090 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 fax (770) 443-9013

IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA GILBERT FREEMAN, JR., Plaintiff, vs. JODY EBRIGHT TODD, Defendant. CIVIL ACTION NO. 12-CV-1077-TB

BRIEF IN SUPPORT OF PLAINTIFF'S MOTION FOR APPOINTMENT OF GUARDIAN AD L1TEM COMES NOW Gilbert Freeman, Jr., Plaintiff herein, and submits his Brief in Support of her Motion for Appointment of Guardian ad litem and shows this Court that pursuant to O.C.G.A. Section 9-11-17, the Court has the authority to appoint a guardian ad litem for a minor not otherwise represented in an action. Since the issue of custody of the parties' minor children has been raised, and since the Court is required to make decisions regarding the permanent custodial arrangement relating to the minor children, the appointment of a guardian ad litem would be in the minor children's best interests.
14,

Respectfully submitted this C

day of

(A..7vv-Q_

, 2012.

LAW OFFICE OF JANA L. EVANS 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 (phone) (770) 443-9013 (fax) na L. Evans
a. Bar No. 200090

IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA GILBERT FREEMAN, JR., Plaintiff, vs. JODY EBRIGHT TODD, Defendant. ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 12-CV-1077-TB

CERTIFICATE OF SERVICE This is to certify that I have this day served a true and correct copy of Brief in Support of Plaintiff's Motion for Guardian ad litem upon all parties in this matter, by either e-mail or by placing the same in the United States Mail, with adequate postage, addressed as follows: Parisa N. Herrin parisaherrinlavvfirm.com 30 Trammell Street Marietta, GA 30064

Respectfully submitted this

day of

, 2012.

na L. Evans a. Bar No. 200090 355 Camden Woods Drive Dallas, GA 30157 (770) 443-4108 fax (770) 443-9013

-2-