Sample Motion For Injunction

                             STATE OF TEXAS
                             COUNTY OF HARRIS

JENNY A. JONES                          CASE NO:95-45554-DM

VS                                      JUDGE: NORMAN MAILER

JOHN B. JONES                           MOTION FOR PERSONAL
                                        PROTECTION ORDER
James Whalen
2467 E Hill Rd
Houston, TX. 77001
TX: 713-695-6950
Attorney For Plaintiff
Janis R. Joplin
8221 Longstreet
Houston, TX. 77002
TX: 713-234-1212
Attorney For Defendant

Now comes the Plaintiff, Jenny Jones, by and through her attorney, James Whalen, who represents to this Honorable Court the following:

1. That the Plaintiff, Jenny Jones, lives at 144 Shady Lane, in the City of Houston, Texas, separate from the residence of the Defendant, who lives in Houston Texas.

2. That on August 17th, 2018, Plaintiff provided the parties’ minor children to the Defendant, for a period of visitation, even though there is at present no Order from this Court requiring same.

3. That the Defendant, John Jones, returned the children to their home (the marital home) at about six in the evening.

4. That the Defendant, John Jones, then instigated a violent argument, with the Plaintiff and her brother, John Kevorkian, which was totally unprovoked, and included the Defendant exhibiting a total lack of control, and screaming at the top of his lungs, “I’ll kill you, motherf*****”, and “Stop smiling like that” and other bizarre statements, and assaulted Plaintiff, by pushing her toward the house, and assaulted the brother, by punching him once in the chest, all of which was witnessed by at least three neighbors of the Plaintiff, presumably because of the ruckus Defendant was making in the front yard and driveway of the home.

5. That the City of Houston Police Department was called to the scene, and the Defendant was removed to the jail from the premises.

6. That your Plaintiff is in fear of the Defendant, and believes that, absent an injunction from this Court, the Defendant will assault Plaintiff again.

7. That an injunction from this Court, that directs Defendant to stay at least 500 feet from the Plaintiff, and her residence and business, and from her children, should be sufficient to protect the Plaintiff, if the Order provides that upon any violation of same, or probable cause of a violation, that the Defendant will be immediately arrested.

Wherefore, your Plaintiff prays that this Honorable Court will enter the injunction prayed for above, and provide your Plaintiff such other and further relief to which she might show herself entitled.

(signed) Jenny A. Jones