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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

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.

____________________________________/

REQUEST FOR HEARING

Special Setting

  1. Motion for which hearing requested (full title)

PETITIONER/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

evidentiary (requires testimony) _____X_______   non-evidentiary (legal argument only) ______(courtesy copy of motion(s) must be attached)

  1. Amount of time requested for both sides to complete presentation: Thirty (30) Minutes.

To be completed by counsel:

I certify that a copy of these motion(s) have been received by the opposing counsel or party.

Check one of below:

_X__ I have been unable to confer with opposing counsel or pro se party.

 

_______________________
Larry D. Schott

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to: XXXXXXX, Esquire, Attorney for Mother, XXXXXXXXXXX at XXXXXXXX and Honorable XXXXXXXXXX on this ______day of XXXX 20__.

 

LARRY D. SCHOTT

Attorneys for Father                                    

By:______________________________
LARRY D. SCHOTT

 

for judge/staff use only: dated received:___________________date set:___________________________________

Disposition: hearing and ruling _________________agreed order__________________abandoned______________

The undersigned judge has received the emergency motion for which a hearing is requested and has determined that it is not an emergency matter, and directes that it be handled in the ordinary course of court affairs.

Date:_____________                                                                   By:________________________________                      Circuit Court Judge

 

 

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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.