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FATHER’S MOTION TO ENFORCE TIMESHARING; MOTION FOR MAKE UP TIMESHARING; MOTION TO SET UP DAILY TELEPHONE CONTACT WITH CHILD AND MOTION FOR ATTORNEY FEES AND COSTS

FATHER’S VERIFIED MOTION TO ENFORCE TIMESHARING; MOTION FOR MAKE UP TIMESHARING; MOTION TO SET UP DAILY TELEPHONE CONTACT WITH CHILD AND MOTION FOR ATTORNEY FEES AND COSTS.

This is an example of a Father requesting that the court enforce a previously agreed up on timesharing plan, where the Mother is refusing to comply.

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

In Re: The Matter of                                                            Case Number:

Section XX

KING JACK,

 

Petitioner/Father,

and

 

JAMIE CROWN

and

JOHN SHMIT,

 

Respondent/Mother.

____________________________________/

FATHER’S VERIFIED MOTION TO ENFORCE TIMESHARING; MOTION FOR MAKE UP TIMESHARING; MOTION TO SET UP DAILY TELEPHONE CONTACT WITH CHILD AND MOTION FOR ATTORNEY FEES AND COSTS

The Petitioner/Father, KING JACK, hereby files his Motion to Enforce Timesharing; Motion for Makeup Timesharing; Motion to Set Up Daily Telephone Contact With Child and Motion for Attorney Fees and Costs:

  1. There is currently pending a Petition for Modification of Timesharing and Child Support and Other Relief before the Court.
  2. Pursuant to the Report of General Magistrate/Notice of Filing and Final Judgment of Paternity, Parenting Plan, Timesharing Schedule, and Child Support (With Paternity Settlement) the Father was awarded timesharing with the parties’ minor child every other weekend from Friday at 6:00 p.m. to Sunday at 6:00 p.m. with drop off and pick up at the Cutler Ridge Police Station.
  3. On XXXX XX, 20__ the Mother refused to allow the Father his timesharing for the weekend.
  4. The Mother brought old pleadings from the case to the police station.
  5. The Father had the paperwork showing that he had the alternating weekend timesharing with him, however, he did not have a certified copy so the police officer was not able to intervene.
  6. The Mother informed the Father that she will not be bringing the child to for the Father’s timesharing for the rest of the summer.
  7. The Father requests the Court enter an Order to enforce his timesharing and order make up timesharing for the weekends the Father missed due to the Mother’s non-compliance with the Court Order.
  8. Additionally, the Father has been requesting that daily contact with his son be coordinated. The Mother refuses and her counsel does not respond to any letters regarding same (copy attached hereto).
  9. The Father has incurred attorney fees and costs for having to file this motion for the Mother’s non-compliance with the Court Order and requests she pay for same.

WHEREFORE, the Petitioner/Father requests the following from the Court:

  1. Enter an order enforcing the Father’s timesharing with the parties’ minor child;
  2. Enter an Order which includes make up timesharing for the Father;
  3. Enter an Order for the Father to have daily telephone contact with the child when the child is not in his care;
  4. Order the Mother be responsible for the Father’s attorney fees and costs;
  5. Order any other relief deemed necessary by the Court.

 

Under penalties of perjury I declare that I have read the foregoing petition and that the facts stated in it are true to the best of my knowledge and belief.

_____________________________

KING JACK

STATE OF FLORIDA         )

)§:

COUNTY OF BROWARD  )

 

BEFORE ME, the undersigned authority, personally appeared KING JACK who is known to me or who produced a Florida Driver’s License as identification, under penalties of perjury and having been sworn under oath, verifies that the above contents and information is true and correct to the best of he personal knowledge and that he executed this document this _____ day of ________________20__.

WITNESS my hand and seal in the State and County aforesaid this ______ day of _____________ 20__.

___________________________
NOTARY PUBLIC

 

CERTIFICATE OF SERVICE

I HEREBY certify the following has been provided to:  XXXXXXX, Esquire, Attorney for Mother, XXXXXXXXXXXXXXXX at XXXXXXXXX on this ______day of XXXX 20__.

 

LARRY D. SCHOTT

Attorneys for Father

By:____________________________

LARRY D. SCHOTT, ESQUIRE

 


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This document is a sample pleading related to a specific set of facts and circumstances and should not be used or relied upon for any family law matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced divorce lawyer for professional advice as each case is unique.

To Learn About Larry Schott’s Qualifications as a Divorce Lawyer and Family Law Advocate, See His About Me Page.