Guardian pending contestwithout pending contest issuingnotice without issuing noticeand and citation citation iifftheCourt findsthattheappointment the Court finds that the appointment is necessary is necessary to Proposed protectaa Proposed to protect Wardor Ward the or the ProposedW Proposed ard'sEEstate. Ward's state. In thiscase, Inthis thePetitioners case,the Petitionersbelievethereis believe necessityfor there is aa necessity the forthe immediate immediate appointment appointment of disinterested of a disinterested third Temporary partyTemporary third party Guardian Guardian oover theProposed verthe Proposed Ward'sPerson Ward's andEstate Personand Estate pending theactual pendingthe appointment actualappointment andqualification of and of aaPermanent Permanent Guardian Guardian assuch, as such, u determination ponaa determination upon oftheneed of the need for samebytheCourt, for same andshould by the Court, and should tthe hePower Power ofAttorney of of Petitioners bedeclared Attorney ofPetitioners be declared u nenforceable unenforceable as well. as well.
15. 15. Based theforegoing uponthe Based upon foregoingfactsand facts allegations, and allegations, thePetitioners the Petitionersbelievethe believe the appointment appointment of Guardian, of aa Temporary Guardian, andsubsequently and subsequently a Permanent a Permanent Guardian Guardian oftheProposed of the Proposed Ward's Ward's Person andEstate Personand isnecessary Estate is necessarytoprotect to theProposed protect the Ward,and Proposed Ward, andherEstate, andthatthe her Estate, and that the givento powersgiven powers theTemporary to the Guardian Temporary Guardian pending uchaa termination pending ssuch termination should should include att least include a the least the following: following:
692687.1 692687.1
Silverado Appx. 0069 No. 1-15-586-CV 19 A. Totakepossession A. To take possession ofallfunds belonging of all funds belonging to Proposed to Proposed Ward,wherever Ward, wherever located;
B. B. Tomakedemands To make demands of ofCarol CarolPeterson Peterson Manleyand Manley andDavid TroyPeterson David Troy for Peterson for 0 accountins ofall accountings of all Pro osedWard's Proposed funds; Ward's funds;
C. C. Todemand To demand accountings of all accountings of of any actsof all acts forProposed agentsfor anyagents Wardunder Proposed Ward under powers of powers of attorney; attorney;
D. Topay D. To allreasonable payall andnecessary reasonable and necessary expenses expenses of Proposed of Proposed Ward,subject Ward, subjectto to approval approval andratification ofthis and of this Court;
0 E. E. Toarrange To arrangeffor ormedical ofProposed careof medical care Ward; Proposed Ward;
F. F. To sellany To sell realproperty anyreal propertybelonging belonging Proposed to Proposed to Ward,subject Ward, subjectto further tofurther ordersofthisCourt; orders and of this Court; and
G. To G. Toapply apply to thisCourt to this foradditional Court for additional powers powers o modifythe tomodify orrto thepowers ordered powersordered herein herein that that are to protect Proposed necessary toprotect arenecessary Proposed Ward andher Wardand estate. her estate.
forTemporary Application for Temporary R estraining Restraining Order, Order, andPermanent Temporary Injunction, and Permanent Injunction 16. 16. Petitioners Petitioners asktheCourt ask the Court ttoo grant grantaa temporary temporary restraining restraining orderand order and to their settheir to set application application for for temporary injunction injunctionffor or aa hearing, hearing, andafterthehearing, issueaatemporary and after the hearing, issue temporary injunction injunction which: which:
•· Prohibits Prohibits C arolPeterson Carol Peterson Manleyand/orDavidTroyPeterson, Manley and/or David Troy Peterson, or any anyperson person purporting o be purporting tto actingas