Fill and Sign the Reconventional Divorce 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 I of the petition for divorce are admitted. 2. The allegations of Paragraph II of the petition for divorce are admitted. 3. The allegations of Paragraph III of the petition for divorce are admitted. 4. The allegations of Paragraph IV of the petition for divorce are admitted. 5. The allegations of Paragraph V of the petition for divorce does not require an answer. 6. The allegations of Paragraph VI of the petition for divorce are denied. 7. The allegations of Paragraph VII of the petition for divorce are denied. 8. The allegations of Paragraph VIII of the petition for divorce are denied. 9. The allegations of Paragraph IX of the petition for divorce are denied. 10. The allegations of Paragraph X of the petition for divorce does not require an answer. 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 the 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. Since irreparable injury, loss or damage may otherwise result, to protect petitioner's interest in the community property, it is necessary that both an injunction and a preliminary injunction be issued herein, enjoining the Defendant in reconvention from disposing of, alienating or encumbering any of the community property. Unless restrained from doing so, the Defendant in reconvention will dispose of, alienate or encumber some or all of the community property before notice can be served and a hearing had on the application for a preliminary injunction, resulting in immediate and irreparable injury, loss or damage to petitioner, hence, it is necessary that a temporary restraining order be issued immediately, in the form and substance of the injunction and the preliminary injunctions mentioned above. V. Petitioner desires that a temporary restraining order issue herein restraining, enjoining and prohibiting defendant from in any manner threatening, harassing or inflicting bodily harm upon Plaintiff, at her home, place of employment, places of recreation, or at any other place, until further orders of this Court. VI. In accordance with Louisiana Code of Civil Procedure Article 3947, plaintiff in reconvention desires that this Honorable Court enter an order confirming her name as ________________ , which was the name she was using at the time of her marriage, without complying with the provisions of LSA-R.S. 13:4575-4755. WHEREFORE, Petitioner, ________________ , prays for judgment in her favor and against the defendant, ________________ , as follows: 1. The custody of the 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. 4. A temporary restraining order be issued herein, according to law, directed to the Defendant in reconvention, and restraining, enjoining and prohibiting his, his agents, employees and all other persons, firms, or corporations acting or claiming to act in his behalf, from disposing of, alienating, or encumbering any of the property owned by the community of acquets and gains existing between Petitioner and Defendant, and further from withdrawing, converting, or disposing of any of the funds on deposit in any bank or trust company in the name of Defendant. 5. A temporary restraining order be issued herein directed unto Defendant, ________________ , restraining, enjoining and prohibiting him from in any manner threatening, harassing or inflicting bodily harm upon Plaintiff, ________________ , at her home, her place of employment, place of recreation or at any other place, without bond; 6. An order issue herein confirming Petitioner = s name as ________________ , which was the name she was using at the time of her marriage, without complying with the provisions of LSA-R.S. 13:4575- 4755. Respectfully Submitted: ____________________________ ________________ ________________ _______ , LA ____ ( ____ ) _______ La. Bar Roll No. ____ Attorney for Defendant Please serve defendant in reconvention through his counsel of record: ________________ ________________ _______ , LA ____