Bristol DIVISION PROBATE & FAMILY COURT

COMMONWEALTH OF MASSACHUSETTS

TRIAL COURT

Bristol DIVISION PROBATE & FAMILY COURT

Docket No. _P73112016_____

Anna Jones

______

Plaintiff

V.

Arthur Jones

______

Defendant

AFFIDAVIT IN SUPPORT OF MOTION FOR TEMPORARY SOLE LEGAL AND PHYSICAL CUSTODY

I, Anna Jones, do swear as follows:

1. I am the mother of Belle Jones, born April 1, 2006.
2. Arthur Jones is Belle’s father.
3. Arthur and I signed a Voluntary Acknowledgment of Paternity on April 2, 2006. A copy is attached.
4. Arthur, Belle, and I lived together as a family from January 2015 until May 2016.
5. On or about May 5, 2016 Arthur moved out at my request.
6. From May, 2016 until now Belle has spent about 3 or 4 days a week at Arthur’s house, including overnights.
7. I work cleaning offices.
8. For the past six months I have had to be at work from 7am until 3pm.
9. It takes me about an hour and a half to get to and from work.
10. During this school year, Belle has spent Monday through Wednesday nights at Arthur’s.
11. Our arrangement has been that he would pick Belle up from school on Monday, Tuesday, and Wednesday, and take her to school on Tuesday, Wednesday, and Thursday.
12. My mother takes Belle to school and picks her up from school on the other days.
13. During the past month, Arthur has been depressed.
14. During the 3 weeks, Arthur has not gotten up in time to take Belle to school 3 times. Belle had to call my mother to come and take her to school.
15. On 4 other times during the past 3 weeks, Arthur has not picked Belle up from school.
16. On November 14 and November 16, my mother was not able to go get Belle, and the school called me at work to come and get her. I had to leave my shift early and it took me an hour and a half to get to the school. When I got there Belle was in tears and the school secretary was angry with me for leaving Belle.
17. During the past month Belle has been having trouble sleeping. She has stomach aches all the time and does not have an appetite.
18. Last week, the school principal called me to make an appointment with him and the school psychologist about Belle’s behavior in school.
19. I asked Arthur to come with me to the appointment with the principal and the psychologist, but he said he will not.
20. I have been able to change my work hours so that either my mother or I can take Belle to and from school.
21. Last week, I asked Arthur to make a written schedule for parenting time and taking Belle to and from school, but he said he does not want to.

Signed under penalties of perjury this 20th day of November, 2016.

Signature