COUNTY OF CANTERBURY
Personally appeared, the undersigned, being duly sworn who hereby
deposes and says the following:
1. She is the mother of the minor child, STEVEN FERGUSON, born May 20,
1977 and by divorce decree in Superior Court, Judicial District of
Canterbury at Canterbury, Docket Number: FA XXXXXXXXXX dated April 14,
1983 which was subsequently modified by a Motion for Modification dated
March 5, 1987 whereby the parties did hereby stipulate and agree that the
minor child, STEVEN FERGUSON, be in the sole custody of the husband,
HOWARD G. FERGUSON, who resides at 25 Happy Hills Road, Canterbury.
2. The undersigned resides at 234 Oak Creek Drive, Hometown, USA and
has sole custody of the other two children of the marriage who have
resided with her since the date of the judgment of dissolution.
3. On or about July 5, 1985 my son, STEVEN, informed me that his father
was touching him in a manner that made him feel uncomfortable and afraid,
specifically he was sleeping with him in the same bed, touching him
between his legs and his father's penis became hard when this occurred.
4. The undersigned is aware that STEVEN'S father is homosexual and he
was involved in a stable relationship until his partner moved away in May
5. The minor child indicates that since May of 1988, this touching has
occurred and he first informed the undersigned of this fact as previously
6. The minor child is to commence school in the Canterbury School
District on August 31, 1988.
7. I feel that my son's welfare is at stake and I believe that his
health and emotional well being is not being served in the present
8. I believe an emergency situation exists with respect to the best
interests of my son.
HELEN J. FERGUSON