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24TH JUDICIAL DISTRICT COURT FOR THE PARISH OF JEFFERSON

STATE OF LOUISIANA
NO. 744-750
DIVISION I

DOMESTIC RELATIONS

IN INTEREST OF MINOR CHILDREN: JORDAN W. AND JORDAE W. CARTER


FILED: ________________________

____________________________

DEPUTY CLERK
MOTION TO ENROLL AS COUNSEL OF RECORD AND MOTION TO APPOINT CURATOR
TO REPRESENT ABSENT DEFENDANT

MOTION TO ENROLL AS COUNSEL


Now into court, through undersigned counsel, comes petitioner SOLOMON CARTER and moves this
court to enroll COLLIN K. WADE as counsel of record for petitoner in these proceedings.

Respectfully Submitted,

_______________________
Collin K. Wade
La. Bar No. 34221
The Pro Bono Project
615 Baronne St # 203
New Orleans, LA 70113
Telephone: 337-501-5371
Fax: 504 566 0518
Attorney for Solomon Carter

ORDER
Considering the above and foregoing:

IT IS ORDERED that Collin K. Wade be, and is hereby, enrolled as counsel of record for ________,
petitioner Solomon Carter in these proceedings.
Abbeville, Louisiana, this 23rd day of March, 2015.

__________________________
JUDGE
MOTION TO APPOINT CURATOR TO REPRESENT ABSENT DEFENDANT
NOW INTO COURT, through undersigned counsel, comes plaintiff SOLOMON CARTER, who
respectfully avers that:
1.
Plaintiff filed In Re: Jordan and Jordae Carter seeking custody of the minor children of Plaintiff's
deceased sister Ana'Alicia Carter. Plaintiff only knows the children's father by the name "Wayne" and
has not seen this person since the children's birth. Plaintiff believes that at one point the father was
incarcerated. Plaintiff does not know Wayne's last known address.
2.
Plaintiff does not know how to serve defendant. Plaintiff does not know defendants last name nor
where defendant is residing. Plaintiff does not know if defendant is currently employed or where he
may be working. Defendant is not represented by counsel. Plaintiff has no further information on
defendant.
3.
Therefore, in order to proceed to judgment, plaintiff requests a Curator Ad Hoc be appointed herein, in
accordance with C.C.P. arts. 1235 and 5091. Appointment of a Curator is proper because this court has
jurisdiction over the status involved and the defendant is an absentee who has not been served with
process and has not waived objection to jurisdiction.
WHEREFORE, Plaintiff prays that an attorney be appointed Curator Ad Hoc to represent the absent
Defendant pending these proceedings.
Respectfully Submitted,

_______________________
Collin K. Wade
La. Bar No. 34221
The Pro Bono Project
615 Baronne St # 203
New Orleans, LA 70113
Telephone: 337-501-5371
Fax: 504 566 0518
Attorney for Solomon Carter
ORDER
Considering the foregoing petition,
Let _______________ be hereby appointed to represent the absent Defendant herein.

Signed in ___________________, Louisiana on ______________________, 2015

____________________
JUDGE

TO THE SHERIFF, PLEASE SERVE THIS MOTION AND A CERTIFIED COPY OF THE
PETITION IN THE INTEREST OF THE MINOR CHILDREN JORDAN W. AND JORDAE W.
CARTER:
Attorney appointed Curator Ad Hoc to represent the
absent Defendant.

______________________________