2021

/ The Revenge (2021) 

In May 2021 Jane Doe's mother's complaint says as follows:

1. From birth to present, Jane Doe's child primarily lived with Jane Doe's mother - Jane Doe's mother only.

2. Both Defendants have allowed Plaintiff to act as the primary custodian of the minor

child.

3. On or about the early morning of May 5, 2021, Defendant Badarin was involuntarily committed to Forsyth Medical Center.

4. Jane Doe's mother reported Jane Doe did not sleep for three days, has been diagnosed with bipolar disorder, and inconsistently uses her prescribed medications.

5. Jane Doe's mother reported she has recently acted paranoid when, late at night, Jane Doe got up in the middle of the night to use the

bathroom and found Jane Doe in the living room with four unplugged night lights. Jane Doe's mother reported Jane Doe accused Jane Doe's step dad of spying and constantly surveilling Jane Doe through cameras in the night lights. There are no cameras inside the home.

6. Made multiple calls the police to investigate an incident claiming that people were trying to break into the home by messing with the locks on the door.

7. Jane Doe's mother reported, Jane Doe reported to the police a "sex toy bunny flashlight with a remote control" that was hidden under Jane Doe's daughter's bed. When the police investigated, they found a plain stuffed rabbit under the bed.

8. Jane Doe's mother reported that Jane Doe accused Jane Doe's step dad of corresponding with someone in New York in order to spy on her and when confronted, Jane Doe's step father was actually corresponding with his mother who resides in Montana.

9. Jane Doe's mother reported Jane Doe called her sister and told her that her life was in severe danger. When Jane Doe's mother went to investigate and found Jane Doe in her room with

Jane Doe's daughter. Jane Doe's mother reported Jane Doe acted as if she believed that there was a recording device in the room.

10. Jane Doe then called the police herself and officers responded to the scene.

11. In front of the police officers responding to the scene, Jane Doe made a second phone call to 911 requesting emergency assistance that her life was in danger.

12. Jane Doe's mother reported Jane mmDoe has falsely accused Jane Doe's step dad of abusing the minor child. Jane Doe's daughter has been examined by Brenner Children's Hospital and

her pediatrician who were unable to find any signs of sexual or physical abuse.

and continues to state Jane Doe's step dad has a criminal history of sexual abuse of minors despite Plaintiff's husband having no criminal

record of any kind.

13. Jane Doe's mother reported when Jane Doe's daughter is in Jane Doe's care, she frequently does not have Jane Doe's daughter change clothes or bathe, and allows her to miss preschool frequently. Claiming she keeps Jane Doe's daughter up late at night and then Jane Doe's mother reported she appears sluggish at preschool when Jane Doe drops her off.

14. Jane Doe's mother reported Jane Doe does not have reliable access to transportation and once released from, Jane Doe will reside with her father, who does not have sufficient space in his residence for both Jane Doe and her daughter.

15. Jane Doe's mother requests that the Court

award her both temporary and permanent custody of Jane Doe's daughter, awarding her immediate custody and preventing Jane Doe from removing her daughter from her care, custody, control, and the jurisdiction of the Court.