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FATHER’S EX PARTE MOTION TO COMPEL MANDATORY DISCLOSURE

FATHER’S EX PARTE MOTION TO COMPEL MANDATORY DISCLOSURE

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

 

In Re: The Matter of                                                            Case Number:

 

 

JACK KING,

 

Petitioner/ Father,

and

 

JAMIE CROWN,

 

Respondent/Mother.

_______________________________/

FATHER’S EX PARTE MOTION TO COMPEL MANDATORY DISCLOSURE

The Petitioner/Father, JACK KING, by and through his undersigned counsel, files this his Ex Parte Motion to Compel Mandatory Disclosure and in support thereof states the following:

  1. On XXXXXX XX, 20__ the Father filed a Petition to Determine Paternity,

Shared Parental Responsibility, Majority Timesharing, Parenting Plan, Child Support and

Other Relief.

  1. Pursuant to Rule 12.285 the Mother was required to produce

the documents listed in 12.285 (d) within forty-five days after service (XXXXX XX, 20__) of the Former Husband’s Petition for Modification of Timesharing and Child Support which occurred on XXXXXX XX, 20__.

  1.                  The Mother has not produced the other documents required to be produced under Rule 12.285.
  2. No objections to mandatory disclosure have been filed by the Mother

 

  1. The Father’s attorney had to file and present this motion because of the Mother’s failure to comply with the rules of discovery. He requests that this Court award him reasonable fees, costs and suit money for preparing and presenting this motion.

WHEREFORE, the Father requests that this Court do the following:

  1. Order the Mother to comply with mandatory disclosure mmediately;

 

  1. Reserve on an award for reasonable attorney fees and costs for the preparation and presentation of this motion.
  2. Order any such relief as this Court deems appropriate.

 

CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that the foregoing has been provided to: XXXXXXXX, Esquire, XXXXXXXXXXXXX by e-service at: XXXXXXXX on this ______day of XXXXXX 20__.                                          

 

LAW OFFICES OF LARRY D. SCHOTT

Attorney for Father

By:______________________________

LARRY D. SCHOTT

 

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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.

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