Fill and Sign the Mississippi Motion Contempt 497314968 Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF V. CIVIL ACTION NO.             DEFENDANT ANSWER TO MOTION FOR CONTEMPT AND COUNTERMOTION FOR MODIFICATION COMES NOW       , by and through counsel, who files this his/her Answer to the Motion for Contempt exhibited against him/her as well as his/her Countermotion for Modification and for such would show unto the Court the following, to - wit: ANSWER 1. All allegations contained in paragraph 1 of the Motion are admitted. 2. All allegations contained in paragraph 2 of the Motion are denied. 3. All allegations contained in paragraph 3 of the Motion are denied. The Defendant would respectfully show unto the court that he/she has told and offered the Plaintiff,       , to bring the automobile to him/her so that said automobile could be repaired pursuant to the terms and conditions of the Final Judgment heretofore entered in this cause. The Plaintiff,       fails and refuses to tender said automobile to the Defendant so that the repairs could be effectuated, and the said       would show, on information and belief, that       ÉMotion are denied. 5. The Final Judgment of Divorce mentions nothing in regards to the allegations of paragraph 5 and the said       would allege that the allegations in paragraph 5 are frivolous and without merit. 6. That all allegations contained in paragraph 6 of the Motion are denied. 7. That all allegations Motion are denied. 8. That all allegations Motion are denied. 9. That all allegations Motion are denied. 10. That the said       would affirmatively show that the Plaintiff is in willful contempt of this court for his/her failure and refusal to attempt to sell said home of the parties, and the failure of       to take reasonable steps in order to sell the home, and has placed the Defendant in dire financial states, thereby warranting this court entering its Judgment of Modification reducing the monthly obligations due and owing to       . 11. That the Defendant       would affirmatively show that       is coming into court with unclean hands and that he/she has failed to abide by the terms and conditions of the Final Judgment in this cause for his/her failure to tender to the said       the silver called for in said Final Judgment and for his/her failure and refusal to take reasonable efforts in order to sell the contained in paragraph 7 of the contained in paragraph 8 of the contained in paragraph 9 of the reducing the monetary obligations due and owing       . 13. That since the rendition of the Final Judgment of Divorce the said       income has decreased. The Final Judgment was predicated upon both parties making reasonable efforts to sell the home, and further predicated on the home selling sometime in the summer of       . 14. That the said       has taken no efforts which would reasonable have the home of the parties on the market for sale and the summer of       has now passed and the home has not been sold which is placing the Defendant       in dire financial straights. 15. That this court should order, that beginning             ,       , all future house payment on the home of the parties be paid by       holding the said       harmless from same. 16. That the said       should be ordered a reasonable attorney's fee and all cost of court incurred herein. WHEREFORE, PREMISES CONSIDERED, the said       prays that this court would dismiss the Motion for Contempt exhibited against him/her and would enter its Judgment of Modification eliminating the responsibility of       from having to pay the house payment on the home of the parties. The said       prays for a reasonable attorney's fee. The said       prays such further relief as the Court deems right. Respectfully submitted this ______ day of _________________________ , 20 ______ .       By_______________________________________       Attorney for       CERTIFICATE OF SERVICE I,       , do hereby certify that I have this date mailed by U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to Hon. This       day of       ,       .