Fill and Sign the A Happy Dance for Plaintiffs Who Moot a Motion to Dismiss by Moving Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI VS. CIVIL ACTION NO. MOTION TO DISMISS AND FOR SANCTIONS COMES NOW the Defendant, and moves the Court in accordance with Rule 12 of the Mississippi Rules of Civil Procedure to dismiss the above styled and numbered cause, and in support thereof would show unto the Court the following, to-wit:1.THAT this Court does not have jurisdiction of the subject matter as proposed in this cause.2.THAT this Court does not have jurisdiction to enforce the orders of the Courts of the States of or as alleged in the pleading by the Plaintiff in this cause and as such cannot render any relief as requested for failure of that jurisdiction.3. THAT this Court does not have jurisdiction in the cause as filed to enforce this Court's prior Order which was entered in cause number of the records of this Court; and that said judgment was rendered pursuant to specific statutory authority granted to this Court through specific statutes; and that any action taken in said cause must be filed arid initiated in that cause under appropriate terms and circumstances; and that this Court cannot enforce a judgment from another cause in the same Court in another case and; therefore, all attempts of this cause to enforce a prior judgment of this Court in cause number are without the jurisdiction of this Court to act in such fashion.4. THAT many of the issues presented for adjudication by this Court in cause number , which is the case at bar, have already been presented to this Court in cause number , and have been previously ruled on by this Court and as such are barred by the doctrine of res judicata from further presentation to this Court; and this Court does not have jurisdiction over said matters and is collaterally estopped from asserting such jurisdiction over those matters.5.THAT the Court of the originating jurisdiction in this matter of County, has complete arid full jurisdiction over all matters in this cause and; that all matters as filed in this cause should be dismissed in deference to the jurisdiction of the Chancery Court of County, .WHEREFORE, PREMISES CONSIDERED, the Defendant, moves the Court to dismiss cause number as filed against him/her in this Court and; further, moves the Court for sanctions in accordance with Rule 11 of the Mississippi Rules of Civil Procedure for the filing of a frivolous complaint to the expense of the Defendant and in support thereof would show unto the Court the following, to wit: 1.THAT cause number of the Chancery Court of County, Mississippi is a case on file in the office of the Chancery Clerk of County, Mississippi, and as such, is a public record for any interested person to examine.2.THAT in examination of cause number of the Chancery Court of County, Mississippi, would show that the Chancery Court of County, Mississippi, has considered the claims of the Plaintiff for past due child support and has ruled that it does not have jurisdiction to adjudicate those claims and has refrained from so adjudicating on those claims without prejudice to the Plaintiff.3.THAT the filing of cause number in the face of the prior opinion and ruling of the Court in cause number is frivolous and wasteful and creates a circumstance requiring the Defendant to respond to issues which he/she has previously litigated before this Court and which have been finally considered and dismissed by this Court and for the Plaintiff to revive those issues is without merit arid frivolous and detrimental to the Defendant.4. THAT Plaintiff had an obvious course of action to ask tile Court to enforce its prior Order in cause by the appropriate Motion or Petition in that cause for the enforcement of said Order and that the filing of this separate stand alone action outside of the jurisdictional pre-requisites of cause number has no merit, is surplus is judicially wasteful and creates a burden on the Court and the Defendant to review and renew matters from the previous cause which acted on these issues specifically and to recall them specifically to this case. That such actions are not necessary and are wasteful and frivolous and that the Plaintiff should be cited for the frivolity and potential fraudulent allegations of his/her Complaint.WHEREFORE, PREMISES CONSIDERED, the Defendant again moves this Court to dismiss cause number in its entirety and to award sanctions against the plaintiff in the amount of his/her attorney's fees and in the amount of $ for the harassment and inappropriateness of having to answer this cause. Respectfully submitted,_______________________________________ Attorney for Of counsel: Telephone: MSB # Attorney for