Documente Academic
Documente Profesional
Documente Cultură
COMES NOW, the Plaintiffs, Matthew Parr, individually and C.C.H. and A.V.H., B/N/F
Matthew Parr, in the above-styled and numbered matter, and respectfully moves this court
pursuant to Rule 65, for entry of an immediate temporary restraining order entered upon the
pleadings and thereafter, a preliminary injunction, entered following the requisite hearing,
restraining Defendant Jill Jones and Defendant Hardy Jones, hereinafter referred to as
Defendants, from transporting minor children C.C.H. and A.V.H. outside of Harrison County,
Mississippi except for times Ordered by the Youth Court of Jackson County and from requiring
through use of coercion, threat of consequence, or otherwise the attendance of C.C.H. or A.V.H.
at any religious service or church sponsored event for which C.C.H. or A.V.H. do not wish to
attend. In support of said Motions for immediate temporary restraining order entered upon the
pleadings and thereafter, a preliminary injunction, entered following requisite hearing, Plaintiffs
state as follows:
1. Plaintiffs C.C.H., age 16 and A.V.H., age 15, have established religious beliefs and
practices and are capable of making choices independent of the State or its agents. The
Constitution.
2. Defendants are members of a church for which the beliefs and practices are not supported
by Plaintiffs or their parents. Parental rights have been recognized by the Supreme Court
practices of the children, C.C.H. or A.V.H. This right is granted to Shalom Jones and
Matthew Parr, jointly, by Temporary Order of the 288th Judicial District Court in Bexar
County, Texas.
4. On one or more occasions including those outlined in the above-styled and numbered
Complaint, Defendants Jill Jones and Hardy Jones have threatened consequences for not
5. One of the Churches the Defendants have required C.C.H. and A.V.H. is located outside
of the State of Mississippi and would require transportation of the children across state
lines into the State of Alabama. The Youth Court of Jackson County Mississippi has no
jurisdiction in the State of Alabama. The jurisdiction of the Youth Court is defined in §
7. The relief requested by Plaintiffs is necessary to protect Plaintiffs from substantial and
8. A narrowly drawn proposed temporary restraining order, which Plaintiffs seek to have
A. A temporary restraining order without Bond entered immediately upon the pleadings
B. An order providing for a prompt hearing date on Plaintiffs' Motion for Preliminary
Injunction.
C. A Preliminary Injunction enjoining Defendants Jill Jones and Hardy Jones from
transporting minor children C.C.H. and A.V.H. outside of the State of Mississippi or
Based on Plaintiffs' Complaint and Motion for Temporary Restraining Order, the Court finds
sufficient grounds for concluding that irreparable injury to Plaintiffs will likely occur absent
1. Defendant Jill Jones and Defendant Hardy Jones are temporarily restrained from
transporting minor children C.C.H. and A.V.H. outside of Harrison County, Mississippi
except for those times ordered by the Youth Court of Jackson County.
2. Defendant Jill Jones and Defendant Hardy Jones are temporarily restrained from
3. This temporary restraining order shall expire in ten days unless it is extended for good
4. This temporary restraining order shall become effective immediately upon entry by the
2009 at