Fill and Sign the Pretrial Memorandum Requesting Change of Custody and Amendment of Visitation Louisiana Form

_______________ : ______ JUDICIAL DISTRICT COURT VS. NO. ______ :PARISH OF ______ _______________ :STATE OF LOUISIANA PRETRIAL MEMORANDUM MAY IT PLEASE THE COURT: In accord with Rule 7.1 of the Rules of the ______ Judicial District Court, this, the pretrial memorandum of _______________ , with respect, represents that: _______________ is filing rules to Show Cause for Change of Custody from Sole Custody to Joint Custody and to Amend Visitation, which have not yet been scheduled for hearing. No responsive pleadings have been filed in connection therewith. As is the case in most domestic matters, there are no unique questions of law involved herein. The Court is, once again, faced with the task of applying well settled principles of law to a set of factual circumstances. It is a well settled principal of law that there is a rebuttable presumption that joint custody is in the best interest of the child. Guillory v. Guillory , App. 3RD Cir. 1992, 602 So. 2D. 769. It is also well settled that the former husband did not have burden of establishing that joint custody was in best interest of children in proceeding on his rule to change custody provision of divorce decree but rather, party opposing joint custody had burden of rebutting statutory presumption in favor of joint custody. Owen v. Guillory , App. 3RD Cir. 1985, 477 So. 2D 1240. _______________ , has attached hereto and made a part hereof a Joint Custody Implementation plan required by law. According it is respectfully submitted that Judgement should be rendered herein as requested by _______________ . RESPECTFULLY SUBMITTED, _______________________________ _______________ CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing has this day been forwarded to opposing counsel, _______________ , _______________ , _______________ , LA ______ by First Class United States Mail, properly addressed, postage prepaid, at the last known address. _______________ , ______ Parish, Louisiana, this ___ day of ______ , 20 ___ . ______________________________ _______________