Notice: Contains Sensitive Information

Notice: Contains Sensitive Information

<p>NOTICE: CONTAINS SENSITIVE INFORMATION</p><p>CAUSE NO. (______)</p><p>IN THE INTEREST OF § IN THE DISTRICT COURTS OF § (CHILD’S NAME), § ______COUNTY, TEXAS § A MINOR CHILD(REN) § (__TH) JUDICIAL DISTRICT</p><p>GUARDIAN/ATTORNEY AD LITEM’S MOTION FOR MONITORED RETURN OF CHILD(REN) TO PARENT</p><p>TO THE HONORABLE JUDGE ______:</p><p>The Guardian/Attorney Ad Litem for the child, ______, brings this Motion for </p><p>Monitored Return of Child to Parent and in support of same, respectfully shows the following:</p><p>1. The Department of Family and Protective Services (“the Department”) presently has </p><p> temporary managing conservatorship of CHILD.</p><p>2. CHILD is presently placed Describe placement; do not reveal Foster Parent names.</p><p>3. It is in the best interest of CHILD to be returned to Respondent Mother/Father for a </p><p> monitored return as provided by Tex. Fam. Code Ann. § 263.403 based on the following </p><p> grounds:</p><p> a. EXAMPLES</p><p> b. Respondent Mother/Father has completed all services and continues to participate </p><p> in counseling</p><p> c. Respondent Mother/Father has completed drug counseling and has not tested </p><p> positive since Date.</p><p> d. Respondent Mother/Father has established a permanent home located at </p><p>______. GAL/AAL and CASA visited this home on ______, and</p><p>GUARDIAN/ATTORNEY AD LITEM’S MOTION FOR MONITORED RETURN PAGE 1 NOTICE: CONTAINS SENSITIVE INFORMATION</p><p> it appears to be a safe environment for a Age child with the abilities and </p><p> limitations of ______(child’s name).</p><p>4. All necessary parties are before the Court. GAL/AAL makes this request </p><p> pursuant to the authority of Tex. Fam. Code Ann. §§ 107.003(D), (G), (H) and 160.612, and </p><p> the requested relief is in the child’s best interest. </p><p>5. GAL/AAL requests that the Court set a hearing and issue appropriate orders for a</p><p> monitored return of the subject child to Respondent Mother/Father at ______address, where </p><p> subject child will live with parent unless a change of address is submitted to Child Protective </p><p>Services prior to relocation. At no time should child be removed from the State of Texas </p><p> during the monitored return.</p><p>6. GAL/AAL requests that the Court issue temporary orders and retain jurisdiction </p><p> of this case as it is in the best interest of the subject child for this Court to retain jurisdiction. </p><p>GAL/AAL requests that the Court not dismiss this suit or render a final order.</p><p>7. GAL/AAL requests that the Court order the Department to return the child to </p><p>Respondent Mother/Father, while ordering the Department to continue to serve as temporary </p><p> managing conservator of the child.</p><p>8. GAL/AAL requests that the Court order the Department to monitor the child’s </p><p> placement to ensure the child is in a safe environment.</p><p>9. GAL/AAL Requests that the Court enter an order permitting GAL/AAL and </p><p>CASA to make announced or unannounced visits for the purpose of monitoring the return of </p><p> the child.</p><p>10. GAL/AAL requests that the Court order GAL/AAL to continue to serve in her </p><p> current capacity until a final order is issued in this suit or the suit is dismissed.</p><p>GUARDIAN/ATTORNEY AD LITEM’S MOTION FOR MONITORED RETURN PAGE 2 NOTICE: CONTAINS SENSITIVE INFORMATION</p><p>11. GAL/AAL requests that the Court set a new dismissal date, not later than the 180th</p><p> day after the date of this requested temporary order, unless a trial on the merits has </p><p> commenced.</p><p>Respectfully Submitted,</p><p>______</p><p>Attorney Name State Bar No. Email Address Physical Address Phone Number Fax Number</p><p>GUARDIAN/ATTORNEY AD LITEM FOR (CLIENT’S NAME)</p><p>CERTIFICATE OF CONFERENCE</p><p>I hereby certify that I conferred/attempted to confer with all parties regarding the relief sought in this this Motion and result of conferences/dates and means of attempted conferences as applicable.</p><p>______</p><p>GUARDIAN/ATTORNEY AD LITEM’S MOTION FOR MONITORED RETURN PAGE 3 NOTICE: CONTAINS SENSITIVE INFORMATION</p><p>CERTIFICATE OF SERVICE </p><p>I hereby certify that, on the day of , 20___ a true and correct copy of the foregoing instrument was served upon each attorney of record in accordance with the </p><p>Texas Rules of Civil Procedure.</p><p>______</p><p>NOTICE OF HEARING</p><p>A hearing on GAL/AAL’s Motion for Monitored Return is set for ______, </p><p>20____ at ______. before the ______District Court, ______County, Texas.</p><p>______Judge Presiding</p><p>GUARDIAN/ATTORNEY AD LITEM’S MOTION FOR MONITORED RETURN PAGE 4</p>

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