Fill and Sign the Motion to Cite Plaintiff for Contempt Form

- 1 - IN THE CIRCUIT COURT OF ________ COUNTY, __________ NAME OF PLAINTIFF ) ) ) V. ) ) NO. ) ) NAME OF DEFENDANT ) ) MOTION TO CITE PLAINTIFF FOR CONTEMPTOF TEMPORARY JUDGMENT COMES NOW the Defendant _____________, by and through counsel, who files this his Motion to Cite the Plaintiff for Contempt of the Amended Temporary Judgment heretofore entered in this cause and for such would show unto the Court the following, to-wit: 1. That on the ____th day of ____________, 20____, the Honorable ____________, sitting as Special Master in the ____________ Court of _____________ County, _______________, entered a Report of Special Master after conducting a hearing on the Motion to Modify the Temporary Judgment that had previous to that date been entered in t his cause. A true and correct copy of said Report of Special Master is attached hereto as Exhibi t "A" and is hereby incorporated by reference. 2. That part and parcel of the Special Master's Report, which amended the Temporary Judgment already entered in the cause required the Plaintiff, commencing _______________, 20____, to be responsible for one/half of the monthly house note due and owing against the residence owned by the parties; and to allow the Defendant phone visit ation. Also, the Defendant has not had phone visitation for two weeks. 4. That the defendant has exhausted all means of getting the Plaintiff to pay one/ half of the January house payment and therefore has had to cite the Plaintiff to be in wil lful contempt of this court. 5. That the actions of the Plaintiff are willful and wanton and shows a disregard for the prior Judgments entered in this cause and this Court should cite her to be in willful contempt of court and require her to pay one/half of the _____________, 20____ house payment directly to the Defendant, as well as all cost of court incurred herein and a reasonable attorney's fee. 6. That the Plaintiff should be required to pay a reasonable attorney's fee unto the Defendant. - 2 - WHEREFORE, PREMISES CONSIDERED, the Defendant prays that after a full and complete hearing, this Court would enter its Judgment citing the Plaintiff to be in willful contempt of this Court, and requiring the Plaintiff to pay to the Defendant one/half of t he ________, 20____ mortgage payment on the home of the parties, as well as all cost of court incurred to date in this case, as well as reasonable attorney's fee, and further, pra y that this Court enforce the phone visitation. Defendant prays for general relief, ____________________________ ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I, ______________________, do hereby certify that I have this date, hand delivered, a true and correct copy of the above and foregoing to _________________ at his usual office address. This _____ day of ___________, 20_____.