Fill and Sign the Arkansas Circuit Courts Judges Benchbook Domestic Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI IN THE MATTER OF THE DISSOLUTION OF THE MARRIAGE OF AND NO. PLAINTIFFVS. DEFENDANT MOTION TO MODIFY JUDGMENT OF DIVORCE COMES NOW , Plaintiff and files this his/her Motion to Modify Judgment of Divorce and in support hereof would show unto the Court the following, to-wit:1.Plaintiff and Defendant were divorce by Judgment of this Court on the day of , on the grounds of irreconcilable differences. Said Judgment incorporated the Separation and Property Settlement Agreement of the parties dated .2. Since the rendition of said Judgment of Divorce material changes in the circumstances have occurred which justify the modification of the custody provisions of said Agreement and Judgment. Plaintiff has remarried and can provide a stable and wholesome environment for the minor child of the parties. Defendant is living with a man who is not her husband. 3. It is in the best interest of the child of the parties that the Judgment of Divorce be modified to place custody of the minor child with the Plaintiff subject to reasonable visitation rights with the Defendant. On a temporary basis the Defendant has voluntarily allowed Plaintiff to have the care of the child and until a final hearing can be held on this Motion custody should remain in Plaintiff.4. Plaintiff is in dire and necessitous circumstances and it is necessary to have a temporary hearing to determine the issues of temporary custody and support. Plaintiff fears that the Defendant will try to regain physical custody of the minor child even though she voluntarily has placed the child with Plaintiff. Plaintiff is entitled to reasonable attorneys fees.WHEREFORE PREMISES CONSIDERED Plaintiff prays that process will issue to the Defendant commanding her to be and appear and defend this motion and show cause if any she can why said Judgment of Divorce should not be modified to place care, control and custody of the minor child of the parties with the Plaintiff. Upon a temporary and final hearing hereof Plaintiff prays that said Judgment of Divorce will be temporarily and finally modified to vest custody of said child with Plaintiff and set support to be paid by Defendant and award Plaintiff his reasonable attorneys fees. Plaintiff prays for general relief. Respectfully submitted: __________________________