[Title of Court]
____________,
[Plaintiff, Petitioner],
v. No. _________
____________, [Designate name of document]
[Defendant, Respondent].
PETITION FOR WRIT OF HABEAS CORPUS
1. Petitioner, _________, is _________[state facts on which petitioner bases right to custody, for example: the mother of _________, who was born on _________[(date)], the issue of a marriage between petitioner and _________, now deceased].
2. The minor is now in the custody and control of respondent, _________, at _________[address] _________ [set forth facts showing that minor is within the geographical jurisdiction of the court].
3. Petitioner has repeatedly demanded that respondent surrender to petitioner the person of the minor, but respondent has refused and still refuses to do so.
4. Petitioner is in all respects a fit and proper person to have custody of the minor, and the minor's interests and welfare will be best served by placing the minor in petitioner's custody.
5. Respondent is an unfit person to have custody and control of the minor, in that _________[specify], and the circumstances surrounding the minor's life with respondent are such as not to conduce to the minor's best welfare.
Wherefore, petitioner requests a writ of habeas corpus, commanding respondent to bring the minor before the court, that the court may make such order concerning the minor's custody as will best serve the minor's welfare.
[Signature]
[Verification, if required]