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Ferrari, Don F Jr vs Lopez, Laura E
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Ferrari, Don F Jr vs Lopez, Laura E

December 01, 2017

Montgomery County. Christina Wilkes, Attorney Wilkes Legal, LLC 7050 Carroll Avenue, Suite 202 Takoma Park Maryland 20912 Circuit Court for Montgomery County, Maryland DON FROST, JR. & CAROLYN FERRARI (Plaintiffs) v LAURA ELIZABETH PEREIRA & DANILO ERNESTO LOPEZ LOPEZ (Defendants) Case No: 146065FL. Notice By Publication A Complaint for Sole Legal and Physical Custody of a Child was filed with the Circuit Court for Montgomery County, Maryland in June 2017. The Complaint alleges, in substance: that Plaintiffs are residents of Maryland; that the Child who is the subject of the proceedings is presently a 17-year-old male born on January 9, 2000 in EI Salvador to Defendants; that the Child has been residing with Plaintiffs since January 2017; that Plaintiffs are financially and emotionally fit to provide for the Child and have been doing so since January 2017; that Defendant Pereira is not a fit or proper person to have custody of the Child because she abandoned him from 2001 to 2014 and beginning in 2014, neglected him by failing to provide him with adequate food, shelter, clothing, and to maintain his school enrollment, and by exposing the Child to crime and violence; Defendant Lopez Lopez is not a fit or proper person to have custody of the Child because he physically, emotionally, and psychologically abused the Child in El Salvador and also neglected him; that the Child meets the eligibility requirements for Special Immigrant Juvenile Status (SIJS) under the Immigration and Nationality Act and applicable regulations and that it is in the Child's best interests to petition tor SIJS; that reunification of the Child with his parents is not viable due to abuse, abandonment, and neglect; and that it is in the best interest of the Child to remain in the U.S. in the custody of Plaintiffs. Plaintiffs request sole legal and physical custody of the Child and move the Court to issue orders making the factual findings necessary to enable the Child to petition USCIS for SJJS. It is this 28th day of November, 2017, ORDERED that the Plaintiffs cause a copy of this Notice to be published at least once a week for three consecutive weeks in a newspaper of general circulation published in Montgomery County, Maryland; publication to be completed by December 15, 2017; Defendant must file a response on on before January 16th, 2018; Defendant is warned that failure to file a response within the time allowed may result in a default judgment or the granting of the relief sought. BARBAR H. MEIKLEJOHN Clerk of the Circuit Court d1,8,15

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