Fill and Sign the Response to Motion for Summary Judgment Mississippi Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       ,       AND       , AS NEXT FRIENDS AND ON THE BEHALF OF       , A MINOR VS.       MOTION FOR EMERGENCY HEARING Comes now       , Defendant, by and through his/her attorney and moves this Honorable Court for an emergency hearing in this matter and for support thereof would show the following: 1. That this case was set for a hearing and continued until       ,             ,       . 2. That the Plaintiff,       was ordered in the Judgment of Divorce to keep health insurance on the minor child,       . 3. That since there is currently no health insurance coverage on the minor child,       , on this medical problem, he/she cannot be admitted to       without the payment of thirty (30) days in advance and each month's bill paid on or before the       of the month. 4. That       will take a minimum of ninety (90) days to determine coverage, if not more, with no guaranty of coverage by       . 5. That the minor child,       , will destabilize and regress without immediate treatment at       . 6. That the father/mother ,       , Plaintiff, should be order to pay immediately the cost of entering the minor child,       , into       and pay each month's expenses as accrued until       accepts coverage. WHEREFORE, PREMISES CONSIDERED, Defendant prays for an emergency hearing in this matter. Respectfully submitted, _______________________________________       Attorney for       Of counsel:                         Telephone:       MSB #       Attorney for