Emergency Custody Modification Petition

Sure, ****! I'd be happy to help. Before you upload, can you tell me a bit about the reason for the emergency modification? This will help ensure your petition addresses all necessary points.

I'm really sorry to hear about your situation, ****. To help your daughter with an emergency petition for modification of custody, she should include the following key points:
- Details of the October 22nd incident.
- Evidence of the lies in the mother-in-law's petition.
- The current living arrangements and her desire to regain custody.
- Any evidence supporting her case (like police reports or witness statements).
Would you like to connect with a local lawyer who can assist further with this case?

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I understand, ****. You can upload the petition, and I can provide feedback on the format, language, and wording to make sure it's as strong as possible. Feel free to upload your document.

Case Rating: *
****, whenever you are ready, please upload the petition. I'll review it and provide feedback on the format, language, and wording to help you strengthen the document.

Case Rating: *
****, the emergency petition you uploaded is detailed and contains significant evidence supporting your daughter's concerns. Here are some suggestions to improve it:
*. Clarify each point with concise, clear language.
*. Ensure all exhibits are clearly labeled and referenced correctly.
*. Highlight immediate risks to the children prominently.
*. Emphasize any legal violations by the other party.
Would you like any specific sections reviewed further?

Case Rating: *
****, your emergency petition is well-drafted and detailed. Here are revised sections to help you:
Emergency Petition for Modification of Custody:
*. Introduction:
Petitioner, Melissa Heldin, residing at * Alison Rd D15, Horsham, PA *, mother of E.K. and V.K., respectfully files this Emergency Petition for Modification of Custody.
*. Respondents:
- Henry Kleyman, residing at * Eberly St., Hatboro, PA *, father of minor children (hereinafter referred to as “Father”).
- Alexander and Grandmother Kleyman, residing at * Valley Hill Trail, Southampton, PA *-*, paternal grandparents who currently have physical custody of minor children (hereinafter referred to as “Grandparents”).
*. Minor Children:
- E.K., age *, DOB XX/XX/XXXX
- V.K., age *, DOB XX/XX/XXXX
*. Current Custody Arrangement:
The current custody arrangement was established by Emergency Order dated October *, *. (EXHIBIT *.a. Emergency Custody Order */*/*)
*. Custody Order:
Following a conciliation meeting on November *, *, a Custody Order was issued granting Grandparents physical custody of the children with supervised, partial custody for each parent (EXHIBIT *.b. Custody Order */*/*).
*. Supervision Requirement:
Specifically, Section *, page * of the Custody Order states the following: "Paternal Grandparent or paternal grandparents shall be present at all times during each parent's custodial time". (EXHIBIT *.b. Pg *, Section *.)
*. Timing of Petition:
Mother previously attempted to file an emergency petition when these concerns were first observed in December *. Unfortunately, she had difficulty with approval for In Forma Pauperis Status. This, combined with her full-time work schedule (* AM-* PM) at a new place of employment, resulted in significant challenges that had to be overcome.
*. Immediate Safety Risks:
This emergency petition is necessitated by immediate safety risks to the children:
- Concern Over Proposed Out-of-State Travel: Grandmother recently informed Mother of her intent to take E.K. and V.K. on a trip to Florida next month. Given Mother's shared legal custody rights, this development raises significant concerns about the custodial dynamics and decision-making processes.
- Unilateral Decision-Making: Grandmother's approach of informing rather than asking Mother about the trip exemplifies a growing pattern of unilateral decision-making.
- Impact on Mother-Child and Sibling Relationships: The potential trip will further reduce the limited time Mother and the children’s older sister currently have with E.K. and V.K., which could strain family bonds.
*. Communication Concerns:
Mother has consistently experienced minimal communication regarding the children's welfare even when they are * minutes away. The idea of them being *,* miles away, with possibly even less communication, is deeply concerning.
*. Request for Court Intervention:
Mother respectfully requests the court’s intervention to ensure that any significant travel or decisions affecting the children involve her active consent. Clear guidelines are needed to prevent overreach in decision-making and to uphold her custodial rights.
Would you like to be connected to local lawyers who can better assist you with your case?

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****, it sounds like this is a complex and urgent situation with significant safety concerns. Would you like to be connected to local lawyers who can better assist you with your case? If so, please provide the following information:
- What is your phone number?
- What is your name? (if different from ****)
- What is your email address? (optional)
- What is your zipcode?

Case Rating: *
****, given the urgency and complexity of your situation with significant safety concerns, it's crucial to ensure each section of your petition is well-addressed. Here's a revised version of your petition:
Emergency Petition for Modification of Custody:
*. Introduction:
Petitioner, Melissa Heldin, residing at * Alison Rd D15, Horsham, PA *, mother of E.K. and V.K., respectfully files this Emergency Petition for Modification of Custody.
*. Respondents:
- Henry Kleyman, residing at * Eberly St., Hatboro, PA *, father of the minor children (hereinafter referred to as “Father”).
- Alexander and Grandmother Kleyman, residing at * Valley Hill Trail, Southampton, PA *-*, paternal grandparents who currently have physical custody of the minor children (hereinafter referred to as “Grandparents”).
*. Minor Children:
- E.K., age *, DOB XX/XX/XXXX
- V.K., age *, DOB XX/XX/XXXX
*. Current Custody Arrangement:
The current custody arrangement was established by Emergency Order dated October *, *. (EXHIBIT *.a. Emergency Custody Order */*/*)
*. Custody Order:
Following a conciliation meeting on November *, *, a Custody Order was issued granting Grandparents physical custody of the children with supervised, partial custody for each parent (EXHIBIT *.b. Custody Order */*/*).
*. Supervision Requirement:
Specifically, Section *, page * of the Custody Order states the following: "Paternal Grandparent or paternal grandparents shall be present at all times during each parent's custodial time." (EXHIBIT *.b. Pg *, Section *.)
*. Timing of Petition:
Mother previously attempted to file an emergency petition when these concerns were first observed in December *. Unfortunately, she had difficulty with approval for In Forma Pauperis Status. This, combined with her full-time work schedule (* AM-* PM) at a new place of employment, resulted in significant challenges that had to be overcome.
*. Immediate Safety Risks:
This emergency petition is necessitated by immediate safety risks to the children:
- Concern Over Proposed Out-of-State Travel: Grandmother recently informed Mother of her intent to take E.K. and V.K. on a trip to Florida next month. Given Mother's shared legal custody rights, this development raises significant concerns about the custodial dynamics and decision-making processes.
- Unilateral Decision-Making: Grandmother's approach of informing rather than asking Mother about the trip exemplifies a growing pattern of unilateral decision-making.
- Impact on Mother-Child and Sibling Relationships: The potential trip will further reduce the limited time Mother and the children’s older sister currently have with E.K. and V.K., which could strain family bonds.
*. Communication Concerns:
Mother has consistently experienced minimal communication regarding the children's welfare even when they are * minutes away. The idea of them being *,* miles away, with possibly even less communication, is deeply concerning.
*. Violations of Custody Order and Court-Ordered Supervision:
Father has been in direct violation of court-ordered supervision. Multiple instances have been documented where the children were left unsupervised with Father, including:
- December *, *: Police civil standby incident where children were found alone with Father (EXHIBIT *.a. Upper Moreland Police Report #UM-*-*).
- December *, *: Children observed being dropped off at Father's home unsupervised after Mother’s visit (EXHIBIT *.b. Video */*/*).
- December *, *: Children observed outside with Father, with no other adults present (EXHIBIT *.d. Statement of **** Fisher re: */*/*).
- January *, *: Children seen leaving Father’s home with Grandmother, contradicting Grandfather’s statement (EXHIBIT *.b. Text messages).
- January *, *: Surveillance video shows Grandparents dropping children at Father’s home (EXHIBIT *.c. Surveillance video */*/*).
- January *, *: Admissions made at conciliation hearing confirming unsupervised custody.
- February *, *: Father's text admitting he is "all alone with them" (EXHIBIT *.a. Text exchange */*/*).
- March *, *: Father's text confirming children living with him (EXHIBIT *.b. Text message */*/*).
*. Substance Abuse Concerns:
- Father failed a drug test in July * and September *, *, for methamphetamine, ecstasy, and marijuana (records pending).
- Unsafe use of marijuana around children.
*. Seizure Disorder:
- Father suffers from a seizure disorder, with frequent "breakthrough seizures".
- Seizures pose a significant risk as children are too young to respond to medical emergencies.
*. Untreated Mental Health Conditions:
- Father’s untreated mental health issues (major depressive disorder, possible bi-polar disorder) present immediate danger.
*. Volatile Behavior:
- Documented instances of aggressive and intimidating behavior by Father, impacting the safety and well-being of the children.
*. Unsafe Transportation Practices:
- Documented instances of children being transported without proper child safety seats, in violation of the custody order and Pennsylvania State Law.
Request for Court Intervention:
Mother respectfully requests the court’s intervention to ensure the safety and well-being of the children by:
- Prohibiting any significant travel without Mother's active consent.
- Enforcing supervised custody as per the current order.
- Reviewing and modifying the current custody arrangement to prioritize the children's safety and family unity.
Would you like to be connected to local lawyers who can better assist you with your case? If so, please provide the following information:
- What is your phone number?
- What is your name? (if different from ****)
- What is your email address? (optional)
- What is your zipcode?

Case Rating: *
****, your situation is complex and there are significant safety concerns for the children. Would you like to be connected to local lawyers who can better assist you with your case? If so, please provide the following information:
- What is your phone number?
- What is your name? (if different from ****)
- What is your email address? (optional)
- What is your zipcode?

Case Rating: *
****, here's a revised structure to help you:
Emergency Petition for Modification of Custody:
*. Introduction:
- Petitioner: Melissa Heldin, residing at * Alison Rd D15, Horsham, PA *, mother of E.K. and V.K., respectfully files this Emergency Petition for Modification of Custody.

*. Respondents:
- Henry Kleyman, residing at * Eberly St., Hatboro, PA * (Father).
- Alexander and Grandmother Kleyman, residing at * Valley Hill Trail, Southampton, PA *-* (Grandparents).
*. Minor Children:
- E.K., age *, DOB XX/XX/XXXX
- V.K., age *, DOB XX/XX/XXXX
*. Current Custody Arrangement:
- Established by Emergency Order dated October *, *. (EXHIBIT *.a)
*. Custody Order:
- Issued on November *, *, granting Grandparents physical custody with supervised, partial custody for each parent. (EXHIBIT *.b)
*. Supervision Requirement:
- Section *, page * of the Custody Order states: "Paternal Grandparent or paternal grandparents shall be present at all times during each parent's custodial time." (EXHIBIT *.b. Pg *, Section *.)
*. Timing of Petition:
- Mother previously attempted to file an emergency petition in December * but faced challenges with approval for In Forma Pauperis Status and her work schedule.
*. Immediate Safety Risks:
- Concern Over Proposed Out-of-State Travel: Grandmother's intent to take E.K. and V.K. to Florida without Mother's consent.
- Unilateral Decision-Making: Grandmother's pattern of bypassing Mother's input.
- Impact on Mother-Child and Sibling Relationships: Reduced time with Mother and older sister.
*. Communication Concerns:
- Minimal communication regarding the children's welfare, especially concerning with potential travel.
*. Violations of Custody Order and Court-Ordered Supervision:
- Multiple documented instances of unsupervised custody with Father.
- December *, *: Police incident where children were found alone with Father. (EXHIBIT *.a)
- December *, *: Children observed being dropped off at Father's home unsupervised. (EXHIBIT *.b)
- December *, *: Children observed outside with Father. (EXHIBIT *.d)
- January *, *: Children seen leaving Father’s home with Grandmother. (EXHIBIT *.b)
- January *, *: Surveillance video of Grandparents dropping children at Father’s home. (EXHIBIT *.c)
- January *, *: Admissions confirming unsupervised custody.
- February *, *: Father's text admitting unsupervised custody. (EXHIBIT *.a)
- March *, *: Father's text confirming children living with him. (EXHIBIT *.b)
*. Substance Abuse Concerns:
- Father failed drug tests in July * and September *, *. (records pending)
- Unsafe use of marijuana around children.
*. Seizure Disorder:
- Father suffers from frequent "breakthrough seizures," posing significant risks.
*. Untreated Mental Health Conditions:
- Father’s untreated mental health issues present immediate danger.
*. Volatile Behavior:
- Documented instances of aggressive behavior by Father.
*. Unsafe Transportation Practices:
- Documented instances of children being transported without proper child safety seats.
Request for Court Intervention:
- Vacate the order of November *, *.
- Return custody to Mother with visitation for Father.
- Prohibit significant travel without Mother's consent.
- Enforce supervised custody as per the current order.
- Modify the current custody arrangement to prioritize the children's safety and family unity.
Would you like any specific sections reviewed further?

Case Rating: *
****, here is how you can incorporate the points about the mother's sobriety and the father's drug use into the petition:
Substance Abuse Concerns:
- Mother’s Sobriety: Mother's sobriety is well-documented. She has never failed a drug test and maintains a clean record, demonstrating her commitment to the children's well-being.
- Father’s Drug Use: Father failed drug tests in July * and September *, *, for methamphetamine, ecstasy, and marijuana. This repeated drug use poses a significant risk to the children's safety.
Would you like additional help with any other specific sections?

Case Rating: *
****, your situation is highly detailed and there are serious concerns regarding the safety and well-being of the children. Here is how you can incorporate the point about the father's intimidation and verbal abuse:
Volatile Behavior:
- Intimidation and Verbal Abuse: Father has demonstrated aggressive and intimidating behavior towards his own parents, calling them derogatory names and verbally attacking them in front of the children. This behavior casts doubt on the grandparents' ability to protect and supervise the children effectively.
Would you like to be connected to local lawyers who can better assist you with your case? If so, please provide the following information:
- What is your phone number?
- What is your name? (if different from ****)
- What is your email address? (optional)
- What is your zipcode?

Case Rating: *
****, you can incorporate the specific dates, examples, and exhibits in a more streamlined way by utilizing headers and bullet points for clarity. Here’s how you can structure it: