PETITION AND ORDER FOR APPOINTMENT OF GUARDIAN AD LITEM
LISA BOE, a party to this action, states as follows:
1. I am an adult resident of the County of Lassen, California, currently residing in Janesville, California.
2. I am about to commence an action in this Court on behalf of myself and my son, Z. B.
2. On April 28, 2008, my husband, Frank Boe, and myself, were decreed the parents through adoption of Tegegne Bekele, a child of approximately 4 years old.
3. The decree of adoption was duly authorized by the court in Addis Ababa, Ethiopia.
4. I traveled to Ethiopia and brought my son home to live with my family in Janesville, CA in May 2008.
5. During the adoption process Tegegne Bekele name was changed to Z. B.
6. Z. B. continues to live with my family at the Janesville address.
7. I am a competent and responsible person and fully competent to represent my son's interests in this lawsuit.
8. There is no conflict of interest between my interests in this lawsuit and those of my son as both of us seek redress against defendants herein for injuries incurred by myself and Z. B. during his adoption, and injuries related to my son's past and current well being, and both of us pray for damages to secure his long term care.
9. WHEREFORE, petitioner moves this Court for an order appointing myself, LISA BOE, as guardian ad litem for my son, Z. B., for the purpose of brining action against Christian World Adoption, Inc., A South Carolina Corporation, Christian World Adoption Foundation, Inc., a South Carolina Corporation, Christian World Adoption, Inc. dba Christian World Adoption, Ethiopia, Tomilea Harding, individually and in her official capacity as CEO of Christian World Adoption Foundation, Inc., Tomiliea Harding, individual, and in her official capacity as CEO of Christian World Adoption, Inc., Robert L. Harding, individually, and in his official capacity as CFO of Christian World Adoption Foundation, Inc., and Robert L. Harding, individually, Robert L. World Adoption, Inc., Tracy Froidcoeur, in her official capacity as Director of Christian World Adoption Ethiopia, and DOES 1-50.
I, Lisa Boe, verify that I have read the petition and know the contents thereof and declare that the statements therein are true and correct of my own personal knowledge. This declaration was made this_____day of January, 2010, in Janesville, California.