IN THE COURT OF COMMON PLEAS
COUNTY OF GEAUGA, OHIO
MAURICE E. BRAHIER : CASE NO. 91 DC000792
DEFENDANT : JUDGE HANS R. VEIT
vs.
GAIL S. BRAHIER : AFFIDAVIT IN SUPPORT
OF MOTION FOR
PLAINTIFF TEMPORARY
CONTROLED AND OR
State of Ohio : RESTRICTED ACCESS
ss
County of Geauga
MAURICE E. BRAHIER, being first duly sworn, according to law, deposes
and states that:
1. He is the defendant in the within action.
2. He and the plaintiff were married on or about April 26, 1982, in
Richmond, Kentucky.
3. He and the plaintiff are the natural parents of two (2) minor
children, daughter {name removed by request}, born November 24, 1985, and son[name removed]
Brahier, born December 14, 1987.
4. Affiant states that it is in the best interest of the children for
the plaintiff to be limited in access to the children for safety concerns.
5. Affiant states that through out the minor childrens lives the
plaintiff has been a possible and real danger to the safety of the
children.
6. Affiant states as referance two (2) instances occuring during the
month of 9/91.
a. 9/1/91 plaintiff attempts to give possible poisoned candy to
children.
b. 9/?/91 plaintiff leaves adult scissors on bed, children jumping
on bed, plaintiff in kitchen.
7. Affiant states that he has a real concern for the safety of the
minor children when alone with the plaintiff.
FURTHER AFFIANT SAYETH NAUGHT.
________________________
MAURICE E. BRAHIER
Sworn to before me and subscribed in my presence this ______ day of
______________________, 1991.
________________________________
NOTARY PUBLIC
PREPARED BY:
MAURICE E. BRAHIER
11654 Claridon-Troy Rd.
Chardon, Ohio 44024
(216) 635-0361
next page please if applicable page no. 2
|