Fill and Sign the Pre Trial Memorandum on Behalf of Plaintiff Form

______________ : ______ JUDICIAL DISTRICT COURT VS : PARISH OF ______, LOUISIANA ______________ : DOCKET NO. ______ _________________________________________________________________ PRE-TRIAL MEMORANDUM ON BEHALF OF PLAINTIFF MAY IT PLEASE THE COURT: This matter comes before the Court on Rules for Child Support, Visitation and Restraining Orders scheduled for ______ ___, 20 ___, at ___ o’clock ___.M. before the Honorable ______________, as a ______ fixing. LSA -R.S. 9:3l5 et seq., known as "Louisiana Uniform Child Support Act", codified the jurisprudence requiring that child support be in an amount to maintain the children at the standard of living to which the y have been accustomed and that it is not only the "free Income" of the father which is to be considered in setting child support, but the gross income and totality of the financial abilities and circumstances of the parents which determine the amount of child support to be awarded ( ROBERTS vs. ROBERTS , [4th Cir. App. l962), l45 So.2d 69; LORMAND vs. LORMAND, [3rd Cir. App. l976], 337 So.2d 920; NELSON vs. NELSON, [lst Cir. App. l976], 335 So.2d 787; FRAZIER vs. FRAZIER , [La. App. 2nd Cir. l975], 3l8 So.2d 625; and BERNARD vs BERNARD [La. App. 3rd Cir. l974], 300 So. 2d 499. Evidence will be introduced at the hearing herein to establish not only ______________ 'S and ______________ 'S financial capabilities, but also the needs of their minor child, ______________, all in accord with LSA-C.C. ART. 227, 230 and 231 and LSA -R.S. 9:3l5, et seq. and the above cited cases. The child support worksheet completed in accord wit h LSA -R.S. 9:3l5.8 is attached hereto and made a part hereof. Accordingly, it is respectfully submitted that judgment should be rendered herein as requested by ______________ . Respectfully Submitted, ______________ ______________ ______, LA ______ ( ___ )______ La. Bar Roll No. ______ * * * C E R T I F I C A T E I HEREBY CERTIFY that a copy of the above and foregoing Pre -Trial Memorandum on Behalf of Plaintiff has been served upon ______________, ______________, ______________, Louisiana ______, attorney for Defen dant, by placing a copy of same in the United States mail, postage prepaid and properly addressed. ______________, Louisiana, this ___ day of ______ 20___ . ___________________________ ______________