Fill and Sign the Reconsideration or Rehearing is There a Differencethe Form

IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI VS. CIVIL ACTION NO. PETITION FOR RECONSIDERATION OF OPINION AND NEW TRIAL COMES NOW Defendant and files this a motion for reconsideration of the Court's opinion dated , , and for a new hearing in this cause and in support of said Motion, Defendant would show unto the court the following, to wit:1.That attached to this motion as Exhibit "A" is a copy of a transcript of proceedings which took place in the Chancery Court of County, on , , between the parties to this cause. Said transcript is incorporated by reference as if fully copied in this motion.2.That the transcript attached to this motion as Exhibit "A" clearly shows that at the proceeding in the Chancery Court of County, , on , , both and were represented by counsel and further, the was personally present at those proceedings. The Transcript further shows that there is some argument about the jurisdiction of the Court to continue hearing the matter arid that the Court at that time specifically retained jurisdiction for the hearing of the case arid did not acknowledge jurisdiction of the Court over any part of this matter.3. THAT Defendant would further show that on pages 7 and 8 of the Transcript the Court specifically abated any child support due under the Order from arid after the date of the hearing on , , and that said Order of the Court was done in the presence of his/her attorney arid the attorney for .4. THAT Defendant would show the Court that the Pleadings filed by in this cause and the testimony given by in this cause constitute a fraud upon this Court, misrepresentation of the current status of the cause in and perjury on the part of in those pleadings and in his/her testimony he/she indicated that the Order was still current and in force and that he/she was entitled to collect money as it accrued under the Order. It is clear from the Transcript attached to this Motion as Exhibit "A" that this is not the case, that as of , , the Court in had abated all child support due to under the Order until such time as the Court made further Orders in the case and that said Order was made in the presence of and with the full knowledge of ’s attorney in . For to come before the Chancery Court of County, Mississippi, and allege that she was entitled to collect money under the Order is fraud and misrepresentation of the worst sort and should not be allowed to further come before the Court to argue his/her cause after having by fraud and perjury obtained the sympathy of this Court arid an Opinion of this Court strongly in his/her favor. 5. THAT Defendant would further show that the action of the Court is clearly an action of sanction against for his/her failure to comply with tile Orders of the Court in regarding making himself available for a deposition in order that the Court in might make a decision regarding what court, either or should take jurisdiction over this matter. It is clear from the tenor of the Transcript and from the actions of that he/she has engaged in forum shopping of the worst sort by hiding behind the laws of the state of and exiting that state only to take a specific cause of action such as the one filed before this Court without any risks to himself that he/she might be called to account for his/her failure to obey the Orders of the Court of the state of and further, that he/she would not be held in account for his/her failure to allow the Defendant to have visitation with the minor children of these parties.6. THAT Defendant would further show unto the Court that when lie attempted in the hearing on this matter that was held before this court on , , to inquire into the visitation matters and the further inquire into whether or not had complied with the Orders of the state of that this Court specifically held that such matters were not relevant to the matters pending before the Court that being only the issue of support for the minor children in this cause. Defendant would show that the Transcript and Orders of the state of clearly indicate that there is relevance to these matters as the Court of the state of has sanctioned for his/her failure to obey that Court’s orders and that sanction is to abate any child support obligations of toward until he/she decides to comply with the Orders of the Court of the state of .7. THAT Defendant would further show unto the Court that the transcript attached to this cause as Exhibit "A" clearly indicates that lie is not in willful and contumacious contempt of this Court and that he/she had every legal reason to believe that lie did not owe child support to until he/she acted affirmatively in complying with the Orders of the Court of the state of .8. THAT Defendant would further show unto the Court that this Court's opinion of , , should be abrogated arid set aside arid that this Court should order a new hearing based on all of the evidence now before the Court and based on tile actions of the Court as exhibited by the Transcript attached as Exhibit "A" to this Motion arid that all issues regarding support, custody, arid visitation should come before Court for resolution if this Court takes jurisdiction on any of the matters as alleged in ’s petition filed in Cause Number .WHEREFORE, PREMISES CONSIDERED, Defendant moves this Court to reconsider its opinion of , , and to further order a new hearing regarding the Petition filed by the Plaintiff herein, and to further reverse all costs and charge all costs of this proceeding against the Plaintiff . Respectfully submitted,_______________________________________ Attorney for Of counsel: Telephone: MSB # Attorney for