IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO DIVISION OF DOMESTIC RELATIONS
KATHERINE E. McCLAIN : CASE NO: 2022 DR 0353
502 Shiloh Drive
Dayton OH 45415
DOB: 09/15/1981
Plaintiff,
: Judge Denise L. Cross
vs
DANIEL W. McCLAIN
MOTION TO SUSPEND
1505 Shroyer Road, Apt. 2 : PARENTING TIME; MOTION
Oakwood OH 45419 FOR DEFENDANT TO DOB: 11/22/1977 : PRODUCE PSYCHOLOGICAL EVALUATION: MOTION FOR Defendant. : COUNSELING WITH OLDEST CHILD TO BEGIN
Now comes Plaintiff, KATHERINE E. McCLAIN, by and through counsel, and hereby moves the Court for an Order suspending the Defendant’s parenting time with the parties’ minor children due to Defendant’s behavior in the presence of the children, and concerns over his mental and emotional stability.
Plaintiff further moves the Court to Order Defendant to produce the psychological evaluation that was completed by him per an agreement of the parties. Plaintiff has requested said report numerous times, but Defendant has failed to provide a copy. Said evaluation should also be provided to the GAL.
Plaintiff moves the Court to Order counseling between Plaintiff and the parties’ oldest child to begin as was previously agreed between the parties
WHEREFORE, Plaintiff moves the Court for an Order suspending the Defendant’s parenting time, an Order requiring the Defendant to provide the Plaintiff and the Guardian Ad Litem with a copy of the Defendant’s psychological evaluation, and an Order for counseling between Plaintiff and the parties’ oldest child to begin.
Respectfully submitted,
/s/ Michael A. Sheets Michael A. Sheets #0052043 Attorney for Plaintiff1331 Woodman Drive
Dayton, Ohio 45432
(937) 298-1515
Email: msheetslaw@gmail.com
CERTIFICATE OF SERVICE
The undersigned does hereby certify that on the date of filing, a copy of the foregoing was served by the efiling system in accordance with Civ. R. 5 on the following: Adam Mesaros
/s/ Michael A. Sheets Michael A. Sheets Attorney at Law