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Verified Motion to Modify Child Support & Parenting Time
VERIFIED MOTION TO MODIFY
Petitioner’s motion for reappointment of Dr. as child and family investigator
A request to hire a certain CFI in a custody case
Motion to Change from a Non-Contested Hearing to a Contested Hearing
PETITIONER’S MOTION TO CHANGE FROM A NON-CONTESTED HEARING TO A CONTESTED HEARING
Motion to Appear Telephonically for the Scheduling Conference
MOTION TO APPEAR TELEPHONICALLY FOR THE SCHEDULING CONFERENCE SET FOR(DATE)
Motion to Dismiss or in the Alternative Reinstate
MOTION TO DISMISS OR IN THE ALTERNATIVE REINSTATE the State is permitted to place a case into “VL” status when the Defendant Fails to appear at a criminal proceeding at which his attendance is required, and the prosecutor believes the defendant cannot be readily found. Defendant has been denied his right to a speedy trial as guaranteed under the United States and North Carolina Constitutions
Motion for Deposition (Criminal)
A Motion under CRCP 15 for a deposition of an invaluable witness to preserve testimony. As can be seen, the alibi witness was elderly and in very poor health, so we needed to preserve her testimony. Did not actually get to that point as the DA made a very favorable offer, which was accepted, after this motion was filed.
Motion to Dismiss FED Case-Landlord and Tenant
Motion to Dismiss a FED case for lack of proper service and improper pleading. Ultimately, it worked, but the court still required a hearing.
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).
Motion to Preclude Use of the Term Victim
Somewhat standard Motion to precude referring to the accuser/complaining witness as “victim” at trial. Added language includes preclusion of using the term “defendant” in reference to the defendant at trial.
Joint Stipulated Motion to Vacate Final Pretrial Conference
JOINT STIPULATED MOTION TO VACATE FINAL PRETRIAL CONFERENCE OR, IN THE ALTERNATIVE, FOR APPEARANCE BY TELEPHONE
Ex Parte Motion – Funds for Investigative Assistance
A motion for court payment of investigator
Ex Parte Motion for Funds for Expert Assistance
An ex parte motion to ask federal district court for payment of defendants expert witness fee.
Motion to Quash Service Pursuant–Landlord and Tenant
A Motion to Quash Service in a FED (Eviction) case, where Plaintiff failed to follow Rule 304 regarding proper service of a Complaint and Summons. While it may seem so, the Defendants were not married, nor were they otherwise related. As the Rule requires service in this instance separately on each, even had Plaintiff properly served one tenant, he did not properly serve the other.
Verified Motion to Enforce Parenting Time
Verified Motion to Enforce Parenting Time
Motion for Contempt Family Law
Filing a Motion for Contempt might cause the other party to file a motion to change the court order. After a divorce decree was entered, one party failed to follow the court order, a contempt was filed and an alias summons was also issued. In family law, a finding of contempt is a way for the Court to enforce child support, spousal support, custody and visitation orders that a party has violated.