Motion for Leave to Take Child Testimony

IN THE CIRCUIT COURT OF BRAXTON COUNTY, WEST VIRGINIA

SNOW WHITE,

Plaintiff/Respondent,

VS. CIVIL ACTION NO. 56-C-78

HARRY WHITE, Defendant/Petitioner.

MOTION FOR LEAVE TO TAKE CHILD TESTIMONY

Comes now the Defendant/Petitioner, HARRY WHITE, by his counsel, James Wilson Douglas, pursuant to Rule 16 of the Rules of Practice and Procedure for Family Law, and moves the Family Law Master or Circuit Judge, as an ancillary measure to his Petition to Modify, filed herewith, for leave to offer the testimony of his three (2) children, all being under the age of 14 years, in support of his said Petition to Modify, said infants being identified as SLEEPY G. WHITE, born February 4, 1983, and LAZY L. WHITE, born March 11, 1985; and Defendant/Petitioner does assign as his grounds, in support thereof, the following:

1. That the testimony of said children and each of them, is more probative on the point for which it is offered than any other evidence which the Defendant/Petitioner can procure through other reasonable efforts;

2. That the said children and each of them, are interested Parties, or the real Parties in interest, with regard to said Petition to Modify;

3. That justice so requires; and,

4. For such other reasons as may appear upon the hearing of this Motion.

HARRY WHITE

By Counsel

____________________________
JAMES WILSON DOUGLAS
Attorney at Law
100 North Hill Road
Post Office Box 425
Sutton, West Virginia 26601