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Motion to Enforce Time

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Verified Motion Concerning Parenting Time Disputes Pursuant to §14-10-129.5, C.R.S.

District Court Denver Juvenile Court

County, Colorado

Court Address:

In re:

The Marriage of:

The Civil Union of:

Parental Responsibilities concerning:

Petitioner:

Co-Petitioner/Respondent:

COURT USE ONLY

Attorney or Party Without Attorney (Name and Address):

Case Number:

Phone Number:

E-mail:

FAX Number:

Atty. Reg. #:

Division:

Courtroom:

VERIFIED MOTION CONCERNING PARENTING TIME DISPUTES PURSUANT TO §14-10-129.5, C.R.S.

Note to Responding Party: If you disagree with this motion, the Colorado Civil Rules of Procedure allow you to file a written response with the Court which must be filed within 21 days of the date this motion was served on you or mailed to you.

I am the Petitioner Co-Petitioner/Respondent. I request the Court to enforce the existing parenting time order or schedule, entered on in Case No. . If the order was issued in another state or county, please identify:

The Petitioner Co-Petitioner/Respondent is violating the parenting time order. (Describe)

I request the Court to:

Set this matter for hearing as quickly as possible.

Require both parties to attend mediation and report the results to the Court within 63 days.

Require the Petitioner Co-Petitioner/Respondent to pay reasonable attorney fees, court costs, and expenses associated with bringing this action before the Court.

Impose sanctions as follows (see page 3 regarding sanctions):

By checking this box, I am acknowledging I am filling in the blanks and not changing anything else on the form.

By checking this box, I am acknowledging that I have made a change to the original content of this form. (Checking this box requires you to remove JDF number and copyright at the bottom of the form.)

VERIFICATION AND ACKNOWLEDGMENT

I swear/affirm under oath that I have read the foregoing Motion and that the statements set forth therein are true and correct to the best of my knowledge.

Signature of Attorney, if applicable

Date

Signature of Petitioner or Signature of Co-Petitioner/Respondent

Date

Address

City, State, Zip Code

(Area Code) Telephone Number (home)

(Area Code) Telephone Number (work)

Subscribed and affirmed, or sworn to before me by

State of

this day of

My Commission Expires:

Notary Public/Deputy Clerk

CERTIFICATE OF SERVICE

I certify that on a true and accurate copy of the Verified Motion Concerning Parenting Time Disputes Pursuant to §14-10-129.5, C.R.S. was served on the other party by:

Hand Delivery or Faxed to this number or

by placing it in the United States mail, postage pre-paid, and addressed to the following:

To:

Your Signature

Possible sanctions that may be imposed by the Court, pursuant to §14-10-129.5, C.R.S.

The possible sanctions to be imposed by the Court may include but are not limited to one or more of the following:

1. An order imposing additional terms and conditions on parenting time consistent with the Court’s previous order; except that the court shall separate the issues of child support and parenting time and shall not condition child support upon parenting time.

2. An order modifying the previous order to meet the best interests of the child.

3. An order requiring either or both parties to attend a parental education program as described in §14-10-123.7, C.R.S., at the expense of the non-complying party.

4. An order requiring the parties to participate in family counseling pursuant to §13-22-313, C.R.S., at the expense of the non-complying party.

5. An order requiring the party who violated the parenting time order to post bond or security to insure future compliance.

6. An order requiring that make up parenting time be provided for the aggrieved party or child under the following conditions:

- That such parenting time is of the same type and duration of parenting time as that which was denied, including but not limited to parenting time during weekends, on holidays, and on weekdays and during the summer.

- That such parenting time is made-up within six months after the non-compliance occurs, unless the period of time or holiday can not be made up within six months in which case the parenting time shall be made up within one year after non-compliance occurs.

- That such parenting time takes place at the time and in the manner chosen by the aggrieved party if it is in the best interest of the child.

7. An order finding the non-complying party in contempt of court and imposing a fine or jail sentence.

8. An order on the non-complying party imposing a civil fine not to exceed $100.00 per incident of non-compliance.

9. An order scheduling a hearing for modification of the existing order concerning parental responsibility (custodial arrangements) or the allocation of decision-making responsibility with respect to a motion filed pursuant to §14-10-131, C.R.S.

10. Any other orders that the Court finds to promote the best interests of the child involved.

In the event the party responding to an action brought pursuant to §14-10-129.5(2)(a-h), C.R.S., is found not to be in violation of the parenting time order or schedule, the Court may order the party who filed the motion to pay the court costs, attorney fees, and expenses incurred by the other party.

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What a Motion to Enforce Time Is

Motion to Enforce Time is a formal court filing used in civil litigation to ask the court to compel compliance with scheduling orders or other time‑based obligations. It describes the missed deadline, attaches supporting evidence, and requests a specified remedy such as sanctions, contempt, entry of default, or a modified schedule. Courts evaluate the factual record, prejudice to the moving party, and applicable procedural rules before granting relief; procedures and allowable remedies vary by federal and state court rules.

Why this Motion Matters

A Motion to Enforce Time preserves litigation rights, reduces delay, and creates a formal record supporting sanctions or schedule relief. It organizes evidence, frames legal argument, and prompts judicial intervention when opposing counsel or a party fails to meet court‑ordered timelines.

Why this Motion Matters

Who Typically Files or Responds

Parties, litigators, and in-house counsel commonly file a Motion to Enforce Time when scheduling orders or deadlines are violated during litigation.

  • Plaintiffs and defendants seeking enforcement, sanctions, or schedule adjustments from the court.
  • Trial judges and clerks who monitor docket compliance and enforce scheduling orders.
  • Attorneys handling discovery disputes, continuance motions, and performance deadline enforcement.

Understanding who uses the motion helps tailor relief requests, cite applicable rules, and present clear supporting evidence to the court.

Common Roles and Responsibilities

Civil Litigant

Individuals or entities in civil suits who seek court enforcement of scheduling orders by documenting missed deadlines, compiling declarations and exhibits, and asking the court for sanctions, date adjustments, or other remedies to address prejudice or delay.

Defense Counsel

Attorneys representing responding parties who may oppose enforcement or request cures. They evaluate compliance with orders, file oppositions, propose stipulations or alternative remedies, and aim to avoid sanctions or default outcomes.

Essential Information and Fields to Include

Case Caption: Plaintiff v. Defendant as styled.
Docket Number: Court-assigned case number and division.
Relief Requested: Specific remedy sought such as sanctions or reset.
Relevant Dates: Missed deadlines and original timeframes.
Supporting Evidence: Declarations, notices, correspondence, and filings.
Signature: Signed by counsel or authorized party.

Consequences of Not Preparing Properly

Sanctions: Monetary or procedural penalties.
Contempt: Possible contempt findings.
Default Judgment: Entry against noncompliant party.
Lost Remedies: Waiver of relief options.
Fee Shifting: Adverse cost award.
Appeal Risk: Creates appellate issue risk.

Common Mistakes to Avoid

  • Failing to attach dated proof of service or notices that demonstrate the opposing party received the deadline, which undermines the motion's factual foundation.
  • Relying on unsupported assertions without sworn declarations or authenticated documents, which courts often require to find prejudice or justify sanctions.
  • Missing local rule timelines for filing or for requesting hearings, resulting in denial for procedural noncompliance rather than on the motion's merits.
  • Requesting overbroad remedies without tailoring relief to actual prejudice, increasing the chance the court narrows or denies requested sanctions.

Step-by-Step: Prepare and File the Motion

[INTRO] Follow these steps to prepare, file, and present a Motion to Enforce Time in civil litigation, from drafting to courtroom presentation.

  • 01
    Gather Facts: Document missed dates, correspondence, and scheduling orders.
  • 02
    Draft Motion: State facts, relief sought, and legal basis.
  • 03
    Attach Evidence: Include declarations, exhibits, and proof of service.
  • 04
    File & Serve: File per court rules and serve all parties.

Where and How to Submit the Motion

[INTRO] Filing varies by court: electronic filing systems, clerk's office, or in-court submission depending on local rules.

  • E-Filing: Use court's electronic filing system where available.
  • Clerk Filing: Deliver or mail paper copies per local procedure.
  • Service: Serve opposing counsel and file proof of service.
  • Hearing: Request a hearing or submit on briefs per rule.

Anatomy of a Professional Motion to Enforce Time

[INTRO] A professional Motion to Enforce Time organizes facts, evidence, and argument into discrete sections that allow the court to evaluate timeliness and appropriate remedies.

Caption

Include full case caption, court name, and docket number. Accurate styling ensures the clerk places the document in the correct case and preserves procedural standing.

Introduction

Open with a concise purpose statement identifying the scheduling order or deadline at issue, a summary of relief sought, and the grounds for judicial intervention.

Statement of Facts

Present dates, notices, communications, and missed obligations in chronological order. Number exhibits, reference them in the facts, and show any attempts to cure the default.

Legal Argument

Cite the applicable local rules and case law that authorize relief. Explain how the facts meet standards for sanctions, contempt, or schedule modification.

Relief Requested

Specify exact remedies sought—such as denial of continuance, monetary sanctions, cost shifting, or a revised schedule—and explain why the relief is proportional.

Signature Block

Provide counsel or party signature, printed name, bar number if applicable, firm, mailing address, phone, email, date, and certificate of service.

How to Customize and Complete the Motion Online

[INTRO] Configure an online workflow to prepare, collaborate on, and sign the Motion to Enforce Time securely and in compliance with court filing rules.

Field Configuration
Document Template Use standardized template with numbered exhibits.
Collaborators Assign editing rights to counsel and paralegals.
Signature Order Set signer roles and sequential signing order.
Authentication Require email or SMS code for signer verification.

Digital Signing and eSubmission Essentials

Choose a platform that supports secure signing, audit trails, and the export formats required by your court's e-filing system.

  • Formats: PDF, DOCX, and PDF/A support.
  • Integrations: Link to case management and cloud storage.
  • Authentication: Support email, SMS, and advanced auth.

Ensure the platform preserves audit trails including timestamps, IP addresses, and signer identity; stores records securely with AES-256 encryption at rest and TLS in transit; and can produce court-ready PDFs plus a certificate of completion for filing.

Timelines and Typical Deadlines to Expect

[INTRO] Timing obligations for a Motion to Enforce Time depend on local rules; plan for prompt filing, timely service, and realistic hearing scheduling windows.

File Promptly:

File as soon as the missed deadline is documented to preserve relief options.

Service Window:

Serve opposing parties per local rules, often within 24–48 hours of filing.

Response Period:

Allow standard response time, commonly 14 or 21 days depending on court rules.

Hearing Scheduling:

Expect hearings within weeks to months based on docket congestion.

Emergency Relief:

Seek expedited or emergency hearing if irreparable prejudice exists.

Key Milestones from Discovery to Ruling

Follow this sequential milestone timeline to prepare, file, and obtain a court decision on a Motion to Enforce Time.

01

Issue Identified

Document missed deadline and gather supporting correspondence and notices.

02

Draft Motion

Draft motion, attach exhibits, and prepare declarations.

03

File & Serve

File with clerk and serve all parties according to rules.

04

Court Ruling

Attend hearing or await ruling; implement court's remedy promptly.

eSignature Solutions — Pricing and Feature Snapshot

Comparison of common eSignature vendors on entry price and key capabilities relevant to preparing and signing motions and related exhibits; signNow is listed first per vendor ordering rules.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies by vendor Varies by vendor Varies by vendor Varies by vendor
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Frequently Asked Questions

Answers to common questions about drafting, filing, signing, and preserving a Motion to Enforce Time, including electronic signing and court procedure considerations.


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