Fill and Sign the Full Text of Ampquota Treatise on Suits in Chancery Setting Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI , AND , AS NEXT FRIENDS AND ON THE BEHALF OF , A MINORVS. NO. ANSWER TO AMENDED PETITION FOR PROTECTION FROM ABUSE AND MOTION FOR MODIFICATION AND CROSS PETITION FOR CONTEMPT Comes now , Defendant in the above styled cause, and files this his/her Answer to the Amended Petition for Protection from Abuse and Motion for Modification filed against him/her in this cause and would show unto the Court the following: 1. Defendant admits the allegations of paragraph 1 of the Amended Petition for Protection from Abuse and Motion for Modification. 2. Defendant admits the allegations of paragraph 2 of the Amended Petition for Protection from Abuse and Motion for Modification. 3. Defendant admits the allegations of paragraph 3 of the Amended Petition for Protection from Abuse and Motion for Modification. 4. Defendant admits the allegations of paragraph 4 of the Amended Petition for Protection from Abuse and Motion for Modification. 5. Defendant denies the allegations of paragraph 5 of the Amended Petition for Protection from Abuse and Motion for Modification. 6. Defendant denies the allegations of paragraph 6 of the Amended Petition for Protection from Abuse and Motion for Modification. 7. Defendant denies the allegations of paragraph 7 of the Amended Petition for Protection from Abuse and Motion for Modification. 8. Defendant denies the allegations of paragraph 8 of the Amended Petition for Protection from Abuse and Motion for Modification. 9. Defendant denies the allegations of paragraph 9 of the Amended Petition for Protection from Abuse and Motion for Modification. 10. Defendant admits the allegations of paragraph 10 of the Amended Petition for Protection from Abuse and Motion for Modification. 11. Defendant denies the allegations of paragraph 11 of the Amended Petition for Protection from Abuse and Motion for Modification. 12. Defendant submits that the allegations of paragraph I of the Amended Petition for Protection from Abuse and Motion for Modification require no answer. 13. Defendant denies the allegations of paragraph II of the Amended Petition for Protection from Abuse and Motion for Modification. 14. Defendant denies the allegations of paragraph III of the Amended Petition for Protection from Abuse and Motion for Modification. CROSS-PETITION FOR CONTEMPT And now having fully answered the Amended Petition for Protection from Abuse and Motion for Modification filed against him/her, files this Cross-Petition for Contempt and would show unto the Court the following: A. Defendant realleges all of his/her admissions and denials in the foregoing Answer to Amended Petition for Protection from Abuse and Motion for Modification. B. On a Final Judgment of Divorce was entered in this cause ordering to pay unto Defendant $ per month for the support and maintenance of the minor child. is in arrears in the amount of $ as shown by Exhibit "A" and further in contempt by failing to have medical and hospitalization insurance as required in the Final Judgment of Divorce for current child support. C. Defendant would show that comes into this court with unclean hands in that he/she has not paid child support as ordered by this court and by not providing medical and hospitalization insurance as required by the Final Judgment of Divorce. D. Defendant requests that upon a final hearing of this cause that the Plaintiff be incarcerated in the County Jail until he/she purges himself of this contempt. E. Defendant has been forced to hire an attorney to defend the petition of the Plaintiff and to obtain compliance with the orders of this Court; therefore, Plaintiff should be required to pay Defendant a reasonable attorney's fee for the services of the attorney representing him/her, plus all court costs.WHEREFORE PREMISES CONSIDERED, Defendant pays that his/her Answer to Amended Petition for Protection from Abuse and Motion for Modification and Cross-Petition for Contempt be received and filed and that upon a final hearing herein the Court will dismiss the Amended Petition for Protection from Abuse and Motion for Modification filed against him/her, find the Plaintiff in contempt of the previous orders of this Court and incarcerate him/her in the County Jail, and, that the Defendant be awarded attorney's fees. And Defendant prays for general relief. Respectfully submitted, _______________________________________ Attorney for Of counsel: Telephone: MSB # Attorney for