Fill and Sign the Motion Contempt Sample Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             DEFENDANT MOTION FOR CONTEMPT AND MODIFICATION COMES NOW Plaintiff,       , by and through counsel and files this Motion to cite       for contempt and to modify the divorce judgment entered in this Cause, and in support hereof would show unto the Court the following: 1. This Court entered a Judgment of Divorce dated       , and by virtue of the terms thereof, the Defendant is required to pay       Dollars ($       ) on the       (       ) and       (       ) of each month. Defendant has failed to pay the support due for       and       , and by his failure has demonstrated his contempt for the judgment of the Court and should be held in contempt for failure to make said payments. 2. The Plaintiff is without sufficient funds in which to pay her attorney without suffering a severe hardship and, therefore, the Court should award unto Plaintiff his/her reasonable attorney's fees in this action. 3. Defendant has failed to provide Medical Insurance information to the Plaintiff, although he has been requested to on many occasions. Defendant should be held in contempt for failure to provide Health and Hospitalization Insurance as required by the Judgment of Divorce and should be ordered to obtain said insurance prior to exercising any further visitation. 4. A material change in circumstances has occurred since the decree was entered on       , which justifies the modification of the Divorce Decree. It is in the best interest of the children that the Divorce Decree be modified so as to provide as follows: (a) Child Support payments be increased in a reasonable amount and be payable twelve (12) months a year instead of       (       ); (b)       night visitation be terminated; (c) Proof of Medical Insurance from husband be provided every six (6) months together with proof of Life Insurance coverage as required by the Final Decree; (d) Reduce summer visitation to       (       ) weeks, (last       (       ) weeks in       ); (e) Terminate joint custody and award physical care and control of custody of the minor children to the Plaintiff; (f) Child Support be payable on the first (1st) day of the month rather than half (1/2) on the first (1st) and half (1/2) on the fifteenth (15th); (g) Require Defendant to pay       (       ) of all Medical Bills to Plaintiff upon receipt; (h) Enter a Withholding Order; (i) Require that all visitations be exercised by Defendant by picking the children up at Plaintiff's residence and returning them to Plaintiff at her residence; (j) Restrict visitation to       unless written authorization is received from Plaintiff prior thereto, such permission not to be granted unless Plaintiff is provided with the times, dates, location and telephone numbers necessary to know at all times where the children are. (k) Disallow Defendant visitation on       weekend. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that upon a hearing hereof, the Court will find the Defendant in contempt and will require him to pay all past due Child support and attorney's fees, as well as provide proof of Medical Insurance and Life Insurance prior to exercising any future visitation. Further, that the Final Divorce Decree be modified to increase the amount of child support, terminate joint custody and vest full custody with Plaintiff; require the Plaintiff to provide proof of Medical and Life Insurance coverage every       (       ) months; reduce summer visitation to       (       ) weeks only, (last       (       ) weeks in       ); require Child Support payments to be made on the first (1st) day of the month rather than on the first (1st) and fifteenth (15th); require Defendant to pay       (       ) of all Medical Bills upon receipt; enter a Withholding Order; restrict visitation to the Jackson Metropolitan Area without prior written permission; require that all visitation be exercised by Defendant by picking the children up at the residence of Plaintiff and returning the children to said residence; disallow Defendant visitation on       weekend. Plaintiff prays for general relief. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for       CERTIFICATE OF MAILING I,       do hereby certify that I have mailed this day by U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing Motion for Contempt and Modification to the Honorable       Dated this the       day of       , 20       . ______________________________________