Fill and Sign the Memorandum Defendant Form

_____________ : ______ JUDICIAL DISTRICT COURT VS : PARISH OF ______ , LOUISIANA _____________ : DOCKET NO. ______ _________________________________________________________________ * * * PRETRIAL MEMORANDUM MAY IT PLEASE THE COURT: In accord with Rule 7.l of the Rules of the ______ Judicial District Court, this, the pretrial memorandum of _____________ , with respect, represents that: _____________ is filing Rules to Show Cause for Contempt, to Determine Amount of Delinquency and make Judgment Executory, for Attorney's Fees and Court costs, which have been scheduled for hearing on ______ ___ , 20 ___ . No responsive pleadings have been filed in connection therewith. As is the case in most domestic matters, there are no unique questions of law involved herein. The Court is, once again, faced with the task of applying well-settled principals of law to a somewhat complicated set of factual circumstances. Evidence will be introduced at the hearing herein to show that _____________ has repeatedly failed and refused to pay his child support payments on behalf of the children, namely, _____________ and _____________ , as ordered by the Judgment dated ______ ___ , 20 ___ . Such failure to pay the child support as provided in the judgment of this court constitutes contempt of court and should be punished accordingly (LSA-C.C.P. arts. 224 and 227 ; and LSA-R.S. 13:4611) . Accordingly, judgment should be rendered in the amount of unpaid child support determined by the Court to be delinquent and said judgment should be made executory in accord with LSA-C.C.P. art. 3945 . It is now a well-settled principal of Louisiana law that when the mother of minor children is forced to institute legal proceedings to enforce the collection of delinquent child support as a result of the conduct of the father of said children, she is entitled to receive a reasonable legal fee for representation therein since to hold otherwise would result in the legal fees consuming said child support and the children would thereby be deprived of the object and purpose of awarding child support. (LSA-R.S. 9:375; LITTON v. LITTON, (App. 1974), 299 So. 2d 458; and GAUTREAUX v. GAUTREAUX, (App. 1975), 315 So. 2d 402). Accordingly, it is respectfully submitted that judgment should be rendered herein as requested by _____________ . RESPECTFULLY SUBMITTTED, ___________________________ _____________ _____________ ______ , LA ______ ATTORNEY FOR ______ CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing has this day been forwarded to Defendant, _____________ , _____________ , _____________ , LA ______ , by First Class United States mail, properly addressed, postage prepaid, at the last known address. _____________ , Louisiana, this ____ day of ______ , 20 ___ . ____________________________ _____________