Fill and Sign the Reply to Motion to Cite Plaintiff for Contempt and Counterclaim Mississippi Form

      CHANCERY CLERK.       COUNTY REC. IN BK. PG. IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. CIVIL ACTION NO.             DEFENDANT AMENDED COMPLAINT FOR DIVORCE COMES NOW the Plaintiff,       , and files this, his/her sworn Amended Complaint For Divorce against the Defendant,       , and in support of his/her claim for relief would respectfully show unto this Honorable Court the following matters and facts, to - wit: I. That Plaintiff and Defendant are now and have been for more than six (6) months next preceding the commencement of this suit, actual, bona fide adult resident citizens of the State of Mississippi, and while your Plaintiff continues to reside in the marital domicile located at       ,       ,       County, Mississippi       , the Defendant,       , temporarily continues to reside at       ,       ,       County, Mississippi       , where he/she can be personally served with the process of this Court. II. That Plaintiff and Defendant are members of the       Race and are       , were heretofore lawfully married to each other on             ,       , in       County, Mississippi, and two (       ) children have been born of their marriage union, namely:       , age       (       ), having been born       and dutiful husband/wife to Defendant in spite his/her habitual cruel and inhuman treatment of him/her . That the parties had continued to live together as husband and wife until on or about             ,       , at which time your Plaintiff was forced to discontinue normal marital cohabitation with the Defendant and to sever his/her normal marital relationship with him/her because of his/her misconduct, insincerity and hostile attitude, all of which have been pursued by Defendant over a long course of time and which conduct has severely and adversely affected the Plaintiff's physical, mental and emotional well-being, thereby proximately causing the aforesaid separation. The aforesaid conduct and actions on the part of the Defendant constitute habitual cruel and inhuman treatment, and Plaintiff is advised and believes that she is entitled to a divorce from Defendant on the ground of habitual cruel and inhuman treatment as provided by Sec. 93 - 5 - 1, of the Mississippi Code of 1972, Annotated, as amended, as well as on the alternative ground of irreconcilable differences, as provided by Sec. 93 - 5 - 2, of the Mississippi Code of 1972 Annotated, as amended. IV. Plaintiff would show that Defendant is a successful businessperson and is capable of producing substantial income. In addition, Defendant owns substantial assets, which have been accumulated during the course of the marriage of the parties through their joint efforts. V. Plaintiff would further show that she is entitled to the following relief: (A) Of education expenses of said children; (B) Lump sum periodic alimony and monthly support for your Plaintiff in an amount to be determined by this Court; (C) The permanent, exclusive use, possession, control and ownership of the marital domicile located at       ,       ,       County, Mississippi       , together with the permanent, exclusive use, possession, control and ownership of all household goods, furnishings, appliances, and other items of personality contained in and around said residence or located on said premises; (D) The permanent, exclusive use, possession, control and ownership of the       automobile; (E) Defendant should be ordered and required to maintain in full force and effect a comprehensive policy of health and hospitalization and dental insurance for the benefit of the Plaintiff and the minor children of the parties, and he should promptly pay, as and when due, any and all doctor, hospital, dental, optical, psychological and/or prescription drug expenses of the Plaintiff and said children which are not covered by his policy of insurance; (F) Defendant should be ordered and required to maintain in full force and affect a policy of insurance on his/her life, naming your Plaintiff as primary beneficiary thereon; (G) And when due, all outstanding debts incurred by the parties during the course of their marriage through the final hearing, including, but not limited to, the mortgage, taxes and insurance on the marital domicile, all credit card accounts, the notes on the automobile; (H) Defendant should be ordered and required to pay Plaintiff's reasonable attorney's fees, Court costs and related fees and expenses incurred in bringing this action, for said action has been made necessary by the misconduct of the Defendant. VI. Plaintiff would further show that his/her case and situation is fast developing into an urgent and necessitous one, for defendant has refused to remove him/her self from the marital domicile and is continuing his/her threats and acts of intimidation toward your Plaintiff. In addition the Defendant has failed to voluntarily contribute a reasonable monetary amount for the support and material needs of his/her family, being Plaintiff and the minor children of the parties, prior to and following the separation of the parties, and Plaintiff would show that if Defendant persists in his/her present course of action and unreasonable behavior and attitude, he/she is entitled to a temporary hearing; Plaintiff would further show that he/she is entitled to and should be awarded the temporary, exclusive care, custody and control of the minor children of the parties, exclusive use, possession and control of the marital domicile, together with all contents of the marital domicile, debts incurred by the parties during the course of their marriage, including, but not necessarily limited to, the mortgage payment, taxes and insurance on the marital domicile, car notes, credit cards, charge accounts and bank loans of the parties, together with temporary attorney's fees and suit money. WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that this, his/her sworn Amended Complaint For Divorce, be received and filed, and that process issue to Defendant, requiring him/her to answer within the time provided by law, but not under oath, answer under oath being hereby expressly waived, and that upon final hearing, and a full accounting to Plaintiff, his/her attorney and accountant by Defendant as to his/her financial condition, assets, liabilities, income and prospective income, and that unless presented by Plaintiff with a written Agreement which can be made part of the Final Judgment of Divorce on the ground of irreconcilable differences, that this Honorable Court will enter its Final Judgment awarding unto Plaintiff a divorce absolute of and from the Defendant on the fault ground alleged herein, and awarding unto her the care, custody and control of the minor children of the parties, together with a reasonable amount of support for the minor children of the parties, and awarding unto Plaintiff alimony, both lump sum and periodic, for the benefit of your Plaintiff; and awarding unto Plaintiff the exclusive use, possession and control of the marital domicile, together with all household goods, furnishings, appliances and other items of personality contained in and around the marital minor children of the parties, while ordering him to pay any and all uninsured medical and related expenses not covered by his/her health insurance,; and further ordering and requiring Defendant to pay, as and when due, all outstanding debts incurred by the parties during the course of their marriage through the date of the hearing, including, but not necessarily limited to, the mortgage, taxes and insurance on the marital domicile, any indebtedness associated with Plaintiff's continued use, possession, control and ownership of the       automobile, and any and all bank loans, charge accounts and credit cards; while awarding unto Plaintiff an equitable shard of all properties, real and personal, accumulated by the parties during the course of their marriage; together with an equitable share of all monies on deposit in any checking or savings account or other savings program of the parties, either jointly or individually held at the time of the separation; while awarding unto Plaintiff her reasonable attorney's fees, Court costs and related expenses incurred in obtaining a Judgment of Divorce. And Plaintiff further prays that this Court will see fit to grant him/her a temporary hearing in order to provide him/her with temporary relief. If your Plaintiff has prayed for wrong, improper or insufficient relief, then he/she now prays for such other relief, either general or special, to which he/she may be entitled in a Court of Equity. As in duty bound, Plaintiff will ever so pray. Respectfully submitted,       ____________________________ ATTORNEYS FOR PLAINTIFF STATE OF MISSISSIPPI COUNTY OF       PERSONALLY CAME AND APPEARED BEFORE ME, the undersigned authority in and for the jurisdiction aforesaid, the within named       , who, after being by me first duly sworn, on her oath stated that each and every allegation in the above and foregoing Amended Complaint For Divorce is true and correct and that the cause for divorce stated in said Amended Complaint is also true as alleged, and that the Amended Complaint as the same relates to the charge of habitual cruel and inhuman treatment is not filed by collusion with the Defendant for the purpose of obtaining a divorce, but that said cause for divorce set out in said Amended Complaint are true and correct as therein stated. SWORN TO AND SUBSCRIBED BEFORE ME, this the       day of       ,       . ________________________________ NOTARY PUBLIC