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)SS:
COUNTY OF JOHNSON ) CAUSE NUMBER 41C0l-1808-JC-000097
4 I CO l-1808-JC-000096
IN RE: THE MATIER OF
DENVER FRANCIS
ASPEN FRANCIS
COMES NOW, Lacey Morse, Mother, by counse~ Valerie Horvath, and files her
Emergency Motion to Stay Unsupervised Visitation with Father and in support thereof
states as follows:
I. Father has six (6) Driving Under the Influence ("DUI") arrests/convictions
in Oklahoma. See news article and certified business records of criminal history attached
hereto as Exhibit A.
3. Immediately prior to the recent accident which led to the filing of this
action, Father threatened Mother that he would kill himself and the children if she
4. The recent accident is not a simple DUI case, this is a DV case with
WHEREFORE, Lacey Morse, Mother, requests that Court stay the Order for the
children's unsupervised visitation with Father and all other relief as is just and proper.