24TH JUDICIAL DISTRICT COURT FOR THE PARISH OF JEFFERSON

STATE OF LOUISIANA

NO. 744-750DOMESTIC RELATIONS DIVISION I

IN INTEREST OF MINOR CHILDREN: JORDAN W. AND JORDAE W. CARTERFILED:____________________________________________________DEPUTY CLERKMOTION TO ENROLL AS COUNSEL OF RECORDAND MOTION TO APPOINT CURATOR TO REPRESENT ABSENT DEFENDANT

MOTION TO ENROLL AS COUNSELNow into court, through undersigned counsel,comes petitioner SOLOMON CARTERand moves this court to enrollCOLLIN K. WADEas counsel of record forpetitonerin these proceedings.

Respectfully Submitted,

_______________________Collin K. WadeLa. Bar No. 34221The Pro Bono Project615 Baronne St # 203New Orleans, LA 70113Telephone: 337-501-5371Fax:504 566 0518Attorney for Solomon Carter

ORDERConsidering the above and foregoing:IT IS ORDERED thatCollin K. Wadebe, and is hereby, enrolled ascounselof record for ________,petitioner Solomon Carterin these proceedings.Abbeville,Louisiana, this23rdday ofMarch, 2015.__________________________JUDGEMOTION TO APPOINT CURATOR TO REPRESENT ABSENT DEFENDANTNOW 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 withC.C.P. arts. 1235and5091. 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. WadeLa. Bar No. 34221The Pro Bono Project615 Baronne St # 203New Orleans, LA 70113Telephone: 337-501-5371Fax:504 566 0518Attorney for Solomon CarterORDERConsidering 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.

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