Fill and Sign the Plaintiffmovant Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI PLAINTIFF/MOVANTVS. CIVIL ACTION NO. DEFENDANT/RESPONDANT MOTION FOR CONTEMPT COMES NOW, , through and by his/her attorney, and files with the Court, this his/her Motion for Contempt against , and in support thereof would show unto the Court the following, to-wit: 1. That the Final Decree of this Court dated , in this cause granted unto the movant, , requiring the respondent, ; to pay the mortgage payments on the marital domicile until the movant shall become employed full-time which includes escrows and insurance and taxes and late fees in the amount of Dollars ($ ) plus late fees.2. That the respondent was required to reimburse the movant for medical expenses and drug expenses incurred from until , in the amount of Dollars ($ ).3. That the respondent is required to reimburse the movant in the amount of Dollars ( ) for repairs to the automobile.4. That the respondent is required to produce from his/her income tax filings IRS form 8332 which was necessary by guidelines set up from the Internal Revenue Service.5. That the respondent is required to return personal property belonging to the movant, more specifically, .6. That the respondent is required to pay alimony in the amount of Dollars ($ ) to be paid in monthly installments of Dollars ($ ) each beginning the day of , with a like payment due' on the first of each month thereafter until the same is paid in full.7. That the said respondent, , is willful, obstinate, deliberate and malicious contempt of and for this Court and its said Final Orders and Decrees. That he/she is failed and refuses to pay the mortgage payment on said marital domicile until the movant becomes employed, and the movant has been notified by the mortgage company of their intentions to proceed with foreclosure proceedings against the marital domicile if said mortgage payment have not been brought up-to-date by . That said respondent has refused to reimburse the movant for medical and drug expenses in the amount of Dollars ($ ); that respondent has refused to reimburse the movant for repairs made to said , that said respondent has refused to produce IRS Form 8332 from his/her income tax filings for the year . that said respondent has refused to produce certain personal property of the movant, specifically, , and that said respondent has refused to make monthly alimony payments in the amount of Dollars ($ ) per month beginning . That the movant has made repeated demands on the said defendant, , to pay all of said sums, but these demands have been totally ignored by the said ; thereby necessitating movant, , to hire an attorney to bring his/her cause before this Court. Therefore, respondent, , should be ordered to pay in addition to the arrearage of monthly mortgage payments, alimony payments, and all other relief requested, a reasonable sum in which to pay his/her attorney for having to acquire his/her services in this regard, particularly since the hiring of said attorney was solely caused by ’s willful, deliberate and malicious disregard for this Court and Its Orders.8. That the said should be found in contempt of this Court and immediately incarcerated in the County Jail at , Mississippi or otherwise dealt with accordingly. That the movant, , should be awarded a Judgment against the said for the sum in the amount of Dollars ($ ) in mortgage payments, plus late fees of approximately Dollars ($ ) a month for the past ( ) months, plus Dollars ($ ) for repairs made to movant's automobile, plus Dollars ($ ) in past due alimony payments, for the sum of Dollars ($ ), together with any additional sum for attorney's fees, court costs, and interest on the above referenced amount. Further, movant, is without funds to pay his/her attorney in the absence of an award from the Court.9. WHEREFORE, PREMISES CONSIDERED, movant prays that this his/her Motion be filed, that a hearing be held hereupon at the earliest convenient date: that this Court will find in contempt for his/her willful, malicious, obstinate, and deliberate failure to abide by the Final Orders of this Court. That the defendant, , be immediately incarcerated in the County Jail at Mississippi, or otherwise dealt with accordingly for contempt: that the movant, be granted a Judgment against the defendant, for the sum of Dollars($ ), plus attorney's fees, court costs and interest on the above referenced amount. Movant, , prays for other such relief either special or general as he/she may be entitled. Respectfully submitted,CELINA MEYNELL WILSON______________________________ATTORNEY FOR PLAINTIFF STATE OF MISSISSIPPICOUNTY OF RANKIN This day before me the undersigned authority in and for the jurisdiction aforesaid, personally appeared, CELINA MEYNELL WILSON, who after having been by me first duly sworn, states on oath that the matters and facts contained in the above and foregoing Motion for Contempt are true and correct as therein stated, and that all matters and things stated on information and belief, she verily believes to be true and correct as therein stated. SWORN TO AND SUBSCRIBED BEFORE ME, this the _____ day of ______ A.D.,1991. ____________________NOTARY PUBLICMy Commission Expires:_______________________ CERTIFICATE OF SERVICE I, ______________________, attorney for plaintiff, Celina Meynell Wilson, do hereby certify that I have this day, served a true and correct copy of the above and foregoing Motion for Contempt by United States Mail, postage prepaid, to WITNESS MY SIGNATURE, this the ___ day of __________ A.D. , 1991.