Motion for Contempt

Motion for Contempt

In the Court of County

State of

)

)

)

Petitioner/Plaintiff,

)

Vs.

)

)

NO.

)

Respondent/Defendant

MOTION FOR CONTEMPT

COMES NOW, , through and by her attorney, and files with the Court, this her Motion for Contempt against , and in support thereof would show unto the Court the following, to-wit:

1. That the Final Decree of this Court dated , 20 , in this cause granted unto the movant, , requiring the respondent, ; to pay the mortgage payments on the marital domicile until the movant shall become employed full-time which includes escrows and insurance and taxes and late fees in the amount of ($) plus late fees.

2. That the respondent was required to reimburse the movant for medical expenses and drug expenses incurred from of 20 until , 20 , in the amount of ($).

3. That the respondent is required to produce from his income tax filings IRS form 8332 which was necessary by guidelines set up from the Internal Revenue Service.

4. That the respondent is required to return personal property belonging to the movant, more specifically, her two diaries from the children of this marriage which have been kept from before the date of their birth.

Respondent is required to pay alimony in the amount of Dollars ($) to be paid in monthly installments of ($) each beginning the first day of , 20 , with a like payment due on the first of each month thereafter until the same is paid in full.

6. That the said respondent, , is willful, obstinate, deliberate and malicious contempt of and for this Court and its said Final Orders and Decrees. That he is failed and refuses to pay the mortgage payment on said marital domicile until the movant becomes employed, and the movant has been notified by the mortgage company of their intentions to proceed with foreclosure proceedings against the marital domicile if said mortgage payment have not been brought up-to-date by , 20 .

That said respondent has refused to reimburse the movant for medical and drug expenses in the amount of and 00/100 ($) for repairs made to said automobile, that said respondent has refused to produce IRS Form 8332 from his income tax filings for the year .

That said respondent has refused to produce certain personal property of the movant, specifically, her two diaries on the children of the marriage, and that said respondent has refused to make monthly alimony payments in the amount of ($) per month beginning , 20 .

That the movant has made repeated demands on the said defendant, , to pay all of said sums, but these demands have been totally ignored by the said ; thereby necessitating movant, , to hire an attorney to bring her cause before this Court: therefore, respondent, , should be ordered to pay in addition to the arrearage of monthly mortgage payments, alimony payments, and all other relief requested, a reasonable sum in which to pay her attorney for having to acquire his services in this regard, particularly since the hiring of said attorney was solely caused by s willful, deliberate and malicious disregard for this Court and Its Orders.

7. That the said should be found in contempt of this Court and immediately incarcerated in the County Jail at , or otherwise dealt with accordingly. That the movant, , should be awarded a Judgment against the said for the sum in the amount of Dollars ($) in mortgage payments, plus late fees of approximately Dollars ($) a month for the past three (3) months, plus Dollars and cents ($) for repairs made to movant's automobile, plus Dollars ($) in past due alimony payments, for the sum of Dollars and cents ($), together with any additional sum for attorney's fees, court costs, and interest on the above referenced amount.

8. WHEREFORE, PREMISES CONSIDERED, movant prays that this her Motion be filed, that a hearing be held hereupon at the earliest convenient date: that this Court will find in contempt for his willful, malicious, obstinate, and deliberate failure to abide by the Final Orders of this Court. That the defendant, , be immediately incarcerated in the County Jail at , or otherwise dealt with accordingly for contempt: that the movant, be granted a Judgment against the defendant, for the sum of Dollars and thirty-five cents ($), plus attorney's fees, court costs and interest on the above referenced amount. Movant, , prays for other such relief either special or general as she may be entitled.

Respectfully submitted,

State of

County of

This day before me the undersigned authority in and for the jurisdiction aforesaid, personally appeared, , who after having been by me first duly sworn, states on oath that the matters and facts contained in the above and foregoing Motion for Contempt are true and correct as therein stated, and that all matters and things stated on information and belief, she verily believes to be true and correct as therein stated.

SWORN TO AND SUBSCRIBED BEFORE ME, this the day of A.D., 20 .

CERTIFICATE OF SERVICE

I, , attorney for plaintiff, , do hereby certify that I have this day, served a true and correct copy of the above and foregoing Motion for Contempt by United States Mail, postage prepaid, to

WITNESS MY SIGNATURE, this the day of A.D., 20 .