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Vuk Nastic; Verica Nastic Individually and In Her Capacity As Next Friend of the Minors, D.N. and N.N. and v. County of San Joaquin
April 5, 2012
VUK NASTIC; VERICA NASTIC INDIVIDUALLY AND IN HER CAPACITY AS NEXT FRIEND OF THE MINORS, D.N. AND N.N. AND
DOES 1 THROUGH 20,
COUNTY OF SAN JOAQUIN;
LIANNE WILLEY, INDIVIDUALLY AND IN HER CAPACITY AS A SOCIAL WORKER FOR THE COUNTY OF SAN JOAQUIN;
VENUS ESPARZA-ZAVALA INDIVIDUALLY AND IN HER CAPACITY AS A SOCIAL WORKER FOR THE COUNTY OF SAN JOAQUIN;
LAZARO GONZALEZ, INDIVIDUALLY AND IN HIS CAPACITY AS A SOCIAL WORKER FOR THE COUNTY OF SAN JOAQUIN; NICHOLAS MORENO JR., INDIVIDUALLY AND IN HIS CAPACITY AS A PEACE OFFICER FOR THE COUNTY OF SAN JOAQUIN;
COLIN MCGRATTAN, INDIVIDUALLY AND AS AN AGENT OF THE COUNTY OF SAN JOAQUIN HUMAN SERVICES AGENCY;
ALEKSANDRA DRECUN, INDIVIDUALLY AND AS AN AGENT FOR THE COUNTY OF SAN JOAQUIN HUMAN SERVICES AGENCY AND DOES 1 THROUGH 20, DEFENDANTS.
The opinion of the court was delivered by: John A. Mendez United States District Judge
PETITION FOR THE APPOINTMENT OF GUARDIAN AD LITEM FOR THE MINORS D.N. and N.N. AND ORDER
Petitioner states as follows:
1. Petitioner is the natural mother and legal guardian of the minors identified herein as D.N. born in 2001 and N.N. born in 2005 who are named as plaintiffs in this action.
2. I request an order approving my petition for the appointment of Vesna Marjanovic as guardian ad litem for each of the minor children in this action.
3. I have confidence in the judgment of Ms. Marjanovic to act in the children's best interest and I believe that she is competent to discharge the responsibilities of a guardian. I have known Ms. Marjanovic for thirty-five years. She knows the children. She speaks to me frequently by telephone and chats with the children when she calls. The children like her and trust her.
4. I have no financial ties with the proposed guardian nor does my husband. I declare under penalty of perjury that the foregoing is true and correct and that this petition was executed on April 4, 2012 at Lafayette, California.
VERICA NASTIC CONSENT TO ACT AS GUARDIAN AD LITEM
I, Vesna Marjanovic, declare as follows:
1. I make this declaration of my own personal knowledge and if called as a witness, I would testify competently to the facts stated herein.
2. I am a personal friend of the plaintiffs in this case. I have known Verica Nastic for thirty-five years. We attended high school together. At that time, I also knew relatives of Vuk Nastic. I have an excellent rapport with the minor plaintiffs in this case. I am over the age of eighteen years. I am employed as a quality control technician for a dental supply company. I am a citizen of the United States. I have a daughter who is 27 years old.
3. I have no financial interest in the outcome of this action.
4. Mr. Beauvais has explained what my role would be as guardian ad litem and I am competent to protect the interests of the children in this litigation. I declare under penalty of perjury that the foregoing is true and correct and that ...
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