ofthe assetsof Proposed the Proposed Ward, isolated haveisolated Ward,have hher from remaining erfrom familym remaining family embers, members,
having lacedherin havingpplaced nursinghome, her in aa nursing of the choosing ofRuby not ofthechoosing home,not S.Peterson, of Ruby S. andin Peterson, and over in effect over
her objection. her objection. RubyS.S.Peterson Ruby isinthe Peterson is company in the company offreeroaming of domestic free roaming domestic animalswithinher animals within her
presentliving present facility, having living facility, agitating effect having aannagitating ponthe effect uupon Proposed Ward. the Proposed Forthe Ward. For purpose the purpose ofthe of the
protection protection aand ndbest best interest theProposed interestooff the Proposed Ward pending resolution Wardpending of thisPetitionforthe resolution of this Petition for the
Appointment Appointment of Permanent of a Permanent Guardian aand Guardian ndthe determination the determination of thenecessity of of the same, the necessity of the same,
Petitioners Petitioners would would seekthe appointment of seek the appointment Temporary of aa Temporary Guardian ooffthePerson Guardian andEstateof the Person and Estate of
S.Peterson, RubyS. Ruby Peterson, at the discretion ofthe atthediscretion of the Court, again, pending tthe again,pending hedetermination oftheneedfor determination of the need for
Permanent aa Permanent Guardianship Guardianship ofthePerson and Estate ofthe of the Person andEstate Proposed of the Proposed Wardandthe Ward and the qualification,
ifappointed, if ofsame. appointed, of same. 12. Furthermore, Furthermore, andin connection and in connection withtheAppointment with the Appointment of Guardian, ofaa Temporary Guardian, 12. Petitioners Petitioners would would seek Temporary seekaa Temporary Restraining Restraining Order, Temporary Order,Temporary andPermanent Injunction, Injunction, and Permanent
692687.1 692687.1
Silverado Appx. 0067 No. 1-15-586-CV 17 Injunction Injunction ppreventing reventing tthe he further and self-serving further unwarranted and self-servingintervention interventionof two of oftwo the of the
N children, children, Carol Carol P eterson Peterson M anleyaand Manley ndDavid Troy Peterson intoherbusiness David Troy andpersonal into her business and affairs. personal affairs. G C. is,Petitioners Thatis, That Petitioners would would s howtheneed show forCourt totorestrain the need for restrain saidpersons said persons from from exercising exercising
unlawful unlawful dominion dominion ofcontrol of control o off assets andperson assets and oftheProposed person of the Proposed Ward, withher Ward,interfering with her
dayto day daypersonal today affairs a personal affairs ndtheselection and the selection o off a living livingand andcare facilityssuited carefacility uitedto to herneeds and her needs and
liking,as liking, opposed asopposed herpresent ttoo her placement presentplacement inSilverado in Silverado Sugar LandMemory SugarLand Memory CareCommunity Care Community
notat not at her selection a herselection ndagainst and against herwill. Intheabsence her will. hi ofan the absence of Order anOrder restraining restraining suchactivity, such activity, Ca appointing appointing Temporary a Temporary Guardian Guardian iin n herbehalf RubyS. her behalf Ruby S.Peterson willlikely Peterson will sufferirreparable likely suffer irreparable NJ harm, a harm, ndas and herassets toher asto forwhich assetsfor judgment moneyjudgment which aamoney alonewould alone wouldnot necessarily notnecessarily suffice for sufficefor herprotection her protection andforwhich and for which there would be there would be no otheradequate no other adequateremedy remedy a lawindamages att law alone, in damages alone,
particularly ifdenied if denied theimmediate