Fill and Sign the Reconventional Demand 497308639 Form

__________________ : _______ JUDICIAL DISTRICT COURT VS : PARISH OF _______ , LOUISIANA __________________ : DOCKET NO. ____ ______________________________________________________________________________ ANSWER AND RECONVENTIONAL DEMAND NOW INTO COURT, through undersigned counsel, comes __________________ , who, in answer to plaintiff's petition for divorce, respectfully represents that: l. The allegations of Paragraph 1 of the petition for divorce are denied. 2. The allegations of Paragraph 2 of the petition for divorce are denied. 3. The allegations of Paragraph 3 of the petition for divorce are admitted. 4. The allegations of Paragraph 4 of the petition for divorce are admitted. 5. The allegations of Paragraph 5 of the petition for divorce are admitted. 6. The allegations of Paragraph 6 of the petition for divorce do not require an answer. 7. The allegations of Paragraph 7 of the petition for divorce are admitted. 8. The allegations of Paragraph 8 of the petition for divorce are admitted. 9. The allegations of Paragraph 9 of the petition for divorce are denied. 10. The allegations of Paragraph 10 of the petition for divorce are denied. 11. The allegations of Paragraph 11 of the petition for divorce are denied. 12 The allegations of Paragraph 12 of the petition for divorce are denied. 13. The allegations of Paragraph 13 of the petition for divorce are denied. 14. The allegations of Paragraph 14 of the petition for divorce are denied. 15. The allegations of Paragraph 15 of the petition for divorce are denied. 16. The allegations of Paragraph 16 of the petition for divorce are denied. 17. The allegations of Paragraph 17 of the petition for divorce are denied. AND NOW ASSUMING the position of plaintiff in reconvention, __________________ respectfully represents that: I. Plaintiff in reconvention, __________________ , avers that it would be in the best interest of both minor children of the marriage, namely, __________________ and __________________ , if their custody be awarded jointly to Plaintiff and Defendant, with Plaintiff in reconvention being designated as the custodial parent, subject to Defendant = s rights of reasonable visitation to be determined by this Honorable Court. II. The defendant in reconvention, __________________ , is capable of earning an income sufficient to provide for the support and maintenance of the minor children, namely, __________________ and __________________ , in an amount to be determined by this Honorable Court. III. Defendant in reconvention is gainfully employed, earning a sufficient income and has adequate means to provide, and Plaintiff in reconvention needs a reasonable amount of alimony pendente lite to be determined by this Honorable Court in accord with LSA-C.C. Art. lll, to commence from the date of the filing of these proceedings and to continue thereafter until further orders of this Honorable Court. IV. Plaintiff in reconvention, __________________ , is a citizen of this state and because of her poverty and want of means, she is unable to pay the costs of this petition in advance or as they accrue, or to give security therefor, and desires to file and prosecute this action under the provisions of La. C.C.P. Arts. 5l8l-5l88. WHEREFORE, Petitioner, __________________ , prays for judgment in her favor and against the defendant, __________________ , as follows: 1. The custody of both minor children, namely, __________________ and __________________ , be awarded jointly to Plaintiff and Defendant, with Plaintiff in reconvention ____ ____ ____ ____ being designated as the custodial parent, subject to Defendant = s rights to reasonable visitation. 2. Plaintiff in reconvention be awarded a reasonable amount of alimony pendente lite to be determined by this Honorable Court. 3. Defendant in reconvention, __________________ , be ordered to pay a reasonable of child support to the minor children of the marriage, namely, __________________ and __________________ , in an amount to be determined by this Honorable Court. Plaintiff in reconvention further prays that she be permitted to prosecute this action without prior payment of costs or as they accrue and without giving bond for costs, according to the provisions of La. C.C.P. Art. 5l8l. Respectfully Submitted: ____________________________ __________________ __________________ _______ , LA ____ ( ____ ) _______ La. Bar Roll No. ____ Attorney for Defendant Please serve defendant in reconvention through his counsel of record: __________________ __________________ _______ , LA ____