Fill and Sign the Rule Contempt Form

DOCKET NO. ______ ______ JUDICIAL DISTRICT COURT IN AND FOR THE PARISH OF _______________ , LOUISIANA __________________ VS __________________ PRE-TRIAL MEMORANDUM MAY IT PLEASE THE COURT: This case is scheduled to come before Your Honor on a Rule for Contempt filed by _______________ and will be heard in front of Your Honor in _______________ , Louisiana, on the ___ day of ______ 20 ___ , at ______ o’clock ___ .M. FACTS AND ARGUMENT: The court ordered the Plaintiffs and Defendants to refrain from doing anything on their property in the future that would restrict or impede the natural flow of water into and across the natural drainage ditch. (See Judgment, rendered ______ ___ , 20 ___ attached as Exhibit A A @ .) The Court further ordered that the defendants remove the temporary drainage ditch they recently dug along the Northern portion of the _______________ / _______________ property which parallels said natural drain, as shown on said plat of survey, from point A to point B. Since that time, _______________ has failed to close in the temporary drainage ditch that exists on the Northern part of his property from point C to point D, more or less, on above- referenced survey. _______________ , however, has complied with the court = s order by filling in the temporary drainage ditch in front of his property from point A to point C, more or less, as per said survey. Also, _______________ has filled in the previously existing drainage which drained _______________ ’s property into the natural drainage ditch. This was a direct violation of the Judgment, and therefore, he should be held in Contempt of Court for violation of the court order. Furthermore, _______________ should be held in violation for Contempt of Court by directly refusing to fill in the temporary drainage ditch on the northern part of his property. Furthermore, _______________ blocked up the natural drainage ditch in a manner that would prevent the water from flowing off the _______________ property onto the _______________ property, because the flow of the water is from West to East. As a result, he is also in direct violation of the Court Order and should be held in Contempt of Court. Respectfully Submitted, _________________________________ _______________ _______________ ___________ , LA ______ ( ___ ) ______ La. Bar Roll No. ______ Attorney for _______________