UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

PARR, individually, §
C.C.H. AND A.V.H., minor children,
B/N/F MATTHEW PARR,
Plaintiffs, §
§
v. § CASE NUMBER: SA09CA0411 XR
§
SHARON SIGALAS, individually, §
and in her official capacity as Judge of the
Youth Court of Jackson County,
YOUTH COURT OF JACKSON COUNTY
MISSISSIPPI, MISSISSIPPI
DEPARTMENT OF HUMAN SERVICES,
JILL PATRICE JONES, individually,
TERRELL H. JONES, individually,
CYNTHIA WILSON, in her official
capacity as Administrator of the Youth
Court of Jackson County, MICHAEL
BRELAND, in his official capacity as
prosecutor for the Youth Court of Jackson
County, HARRISION COUNTY SCHOOL
DISTRICT, ELMER MULLINS, in his
official capacity as principal of D'Iberville
High School and agent or employee of the
Harrison County School District,
HARRISON COUNTY SHERIFF'S
DEPARTMENT, VAN MCCLENDON,
Individually, and in his official capacity
as deputy sheriff of the Harrison County
Sheriffs Department, MATT MATTHEWS,
in his official capacity as supervisor of
the Mississippi Department of Human
Services, LAURA TAYLOR, in her official
capacity as clerk of the Youth Court of
Jackson County, LENA PARKER,
individually, and in her Official capacity
as social worker for the Mississippi
Department of Human Services,
LARRY ELLIS, individually,
COURTNEY GIBBS, in her capacity
as an agent of the Mississippi Department
of Human Services,
Defendants, §

EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER

AND PRELIMINARY INJUNCTION

COMES NOW, the Plaintiffs, Matthew Parr, individually and A.V.H., B/N/F Matthew

Parr, in the above-styled and numbered matter, and respectfully moves this court pursuant to

Rule 65, for entry of an immediate temporary restraining order entered upon the pleadings and

thereafter, a preliminary injunction, entered following the requisite hearing, restraining

Defendant, Jill Patrice Jones, hereinafter referred to as Defendant, from administering,

possessing, or requiring the ingestion of any medication, not ordered as medically necessary to

C.C.H. and A.V.H., by a licensed medical provider, and from coercing, threatening or

implementing any consequence or punishment on said children for refusing to take any

medication not medically necessary. In support of said Motions for immediate temporary

restraining order entered upon the pleadings and thereafter, a preliminary injunction, entered

following requisite hearing, Plaintiffs state as follows:

1. On one or more occasions as outlined in the above-styled and numbered Complaint,

Defendant has coerced minor child A.V.H. to take against her will, prescription birth

control pills through use of threats of social isolation and other consequences.
 2. Plaintiffs C.C.H., age 16 and A.V.H., age 15, are competent and capable of asserting

their right to refuse medical treatment in decisions that are non-life threatening

independently of the State or its agents.

3. A.V.H. does not wish to take birth control pills because she is not currently sexually

active. Her right to choose regarding contraception has been established in Roe v. Wade.

4. There is no lawful order by a Court in place nor any statutory authority which grants

Defendant any right to require non-life saving medical treatment nor have the parental

rights of Matthew Parr, granted by the 288th Judicial District Court in Bexar County

Texas been terminated. No Court has found A.V.H. or C.C.H. to be incapable of making

decisions regarding their own healthcare or restricting them from exercising their right to

refuse treatment.

5. Defendant is a registered nurse and as such is required to know the content and

requirements set forth in the Nurse Practice Act and the Rules and Regulations of the

Board of Nursing for the State of Mississippi.

6. Plaintiffs have no alternative remedies at law or in equity.

7. The relief requested by Plaintiffs is necessary to protect Plaintiffs from substantial and

irreparable injury from Defandant.

8. A narrowly drawn proposed temporary restraining order, which Plaintiffs seek to have

entered immediately upon the pleadings is attached hereto.

WHEREFORE, Plaintiff prays for the entry of the following orders:

A. A temporary restraining order without Bond entered immediately upon the pleadings

under the authority of Rule 65 of the Federal Rules of Civil Procedure.

 B. An order providing for a prompt hearing date on Plaintiffs' Motion for Preliminary

Injunction.

C. A Preliminary Injunction enjoining Defendant Jill Patrice Jones from administering or

requiring the administration of any medication to C.C.H. and A.V.H.

Respectfully submitted on the 26th day of May, 2009,

/
Matthew M. Parr, pro se.
For Plaintiffs
2424 Gold Canyon Road, Apt 1617
San Antonio, TX 78259
Telephone: (210) 519-8344
Matthew Parr, pro se.
For Plaintiffs
2424 Gold Canyon Road, Apt 1617
San Antonio, TX 78259
Telephone: (210) 519-8344

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

MATTHEW PARR, individually, §

C.C.H. AND A.V.H., minor children,
B/N/F MATTHEW PARR,
Plaintiffs, §
§
v. § CASE NUMBER: SA09CA0411 XR
§
SHARON SIGALAS, individually, §
and in her official capacity as Judge of the
Youth Court of Jackson County,
YOUTH COURT OF JACKSON COUNTY
MISSISSIPPI, MISSISSIPPI
DEPARTMENT OF HUMAN SERVICES,
JILL PATRICE JONES, individually,
TERRELL H. JONES, individually,
CYNTHIA WILSON, in her official
capacity as Administrator of the Youth
Court of Jackson County, MICHAEL
BRELAND, in his official capacity as
prosecutor for the Youth Court of Jackson
County, HARRISION COUNTY SCHOOL
DISTRICT, ELMER MULLINS, in his
official capacity as principal of D'Iberv ille
High School and agent or employee of the
Harrison County School District,
HARRISON COUNTY SHERIFF'S
DEPARTMENT, VAN MCCLENDON,
Individually, and in his official capacity
as deputy sheriff of the Harrison County
Sheriffs Department, MATT MATTHEWS,

Page 1 of 3 - TEMPORARY RESTRAINING ORDER (PROPOSED)

in his official capacity as supervisor of
the Mississippi Department of Human
Services, LAURA TAYLOR, in her official
capacity as clerk of the Youth Court of
Jackson County, LENA PARKER,
individually, and in her Official capacity
as social worker for the Mississippi
Department of Human Services,
LARRY ELLIS, individually,
COURTNEY GIBBS, in her capacity
as an agent of the Mississippi Department
of Human Services,
Defendants,

TEMPORARY RESTRAINING ORDER (PROPOSED)

Based on Plaintiffs' Complaint and Motion for Temporary Restraining Order, the Court finds

sufficient grounds for concluding that irreparable injury to Plaintiffs will likely occur absent

entry of a temporary restraining order. Therefore, it is hereby ordered as follows:

1. Defendant Jill Patrice Jones is temporarily restrained from obtaining, possessing or

administering directly or indirectly any prescription or over-the counter medication to

minor children A.V.H. or C.C.H.

2. Defendant Jill Patrice Jones is temporarily restrained from initiating any conversation

with minor children C.C.H. or A.V.H. concerning medical care or treatment.

3. This temporary restraining order shall expire in ten days unless it is extended for good

cause shown by further order of this Court.

4. This temporary restraining order shall become effective immediately upon entry by the

Court. Plaintiffs are not required to post a bond or other security.

Page 2 of 3 - TEMPORARY RESTRAINING ORDER (PROPOSED)

 5. Hearing on Plaintiffs' Motion for Preliminary Injunction is set for

2009 at

DATED this day of , 2009

UNITED STATES DISTRICT COURT JUDGE

Submitted by: Matthew Parr, pro se.

For Plaintiffs.

Page 3 of 3 - TEMPORARY RESTRAINING ORDER (PROPOSED)