Guardianship
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Combine Motion For Reconsideration Motion For Forthwith Hearing And Emergency Interim Orders
Drafted this motion after a court granted a party interim orders taking all custody away from mom. Child was taken away from mom and she had not seen child for several weeks
Respondent’s Verified Motion to Modify Allocation of Parenting Time
A post decree motion to modify parenting time and child support based on one parent not taking or using his time with one of the children.
PURSUANT TO C.R.S. § 14-10-129  AND MOTION TO MODIFY CHILD SUPPORT PURSUANT TO C.R.S. § 14-10-122 and C.R.S. § 14-10-115
Verified Motion to Modify Child Support & Parenting Time
VERIFIED MOTION TO MODIFY
Motion for Abduction Prevention Measures
Motion for Abduction Prevention Measures, which included a restriction of Parenting Time. What’s not in the motion is Crazy Mom’s constant assertion the court and I were engaged in ex-parte communications in an attempt to deprive her of her rights to due process and the fact she filed a Federal Notice of Removal instead of answering the motion (denied, of course, with an admonishment from the Federal judge that she is required to abide by Rule 11). As always, these are fact specific, but this one worked (especially as Crazy Mom failed to appear at the hearing, or otherwise respond to the motion in any way).
Verified Motion to Enforce Parenting Time
Verified Motion to Enforce Parenting Time
Motion for Attorney Fees with Attached Affidavit-Marriage and Divorce
Filed a motion for attorney fees in case and in divorce case. Motion was granted
Motion to modify parenting time and request for payment of arrears and child support
filed this motion to modify the parenting schedule so parents could have 50/50 parenting every 7 days. Also father owed past arrears and a child support needed to be made.
Order Determining Total Incapacity-Guardianship
Order Determining Total Incapacity-Guardianship
Motion to quash subpoena deuces tecum
Filed a motion to quah a subpoena for the release of state health records regarding marijuana use
Petition to Determine Incapacity-Guardianship
Petition to Determine Incapacity-Guardianship
Interrogatories for Modification of Parenting Time & Child Support
Set of interrogatories for Custody case
Response to Petitioner’s Motion for Sanctions – Child Custody
RESPONDENT’S RESPONSE TO PETITIONER’S MOTION FOR SANCTIONS