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RESPONDENT’S VERIFIED MOTION TO VACATE DOMESTIC VIOLENCE INJUNCTION AND/OR MODIFY DOMESTIC VIOLENCE INJUNCTION

RESPONDENT’S VERIFIED MOTION TO VACATE DOMESTIC VIOLENCE INJUNCTION AND/OR MODIFY DOMESTIC VIOLENCE INJUNCTION

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

In Re: The Matter of                                                            Case Number:

JACK KING,

 

Petitioner/Husband,

and

 

JAMIE CROWN,

 

Respondent/Wife.

____________________________/

RESPONDENT’S VERIFIED MOTION TO VACATE DOMESTIC VIOLENCE INJUNCTION AND/OR MODIFY DOMESTIC VIOLENCE INJUNCTION

The Respondent, JAMIE CROWN, through his undersigned counsel, hereby files this her Verified Motion to Vacate Domestic Violence Injunction and/or Modify Domestic Violence Injunction and further states the following:

  1. A Temporary Domestic Violence Injunction has been entered by the Court in this matter.
  2. The Wife moves to vacate and/or modify the Domestic Violence Injunction.
  3. The Husband has filed a false Domestic Violence Injunction in order to gain an unfair advantage in a subsequent divorce and custody case.
  4. The Husband wanted to obtain sole decision making and 100% timesharing regarding the parties minor child, which he has now done, when the Mother, who is a registered nurse, has been the child’s primary caretaker during the marriage. This is a huge abuse of the system.
  5. The Husband has now withdrawn the parties small three year old child from the school he was attending just to exercise control over the Mother, knowing that there is an injunction in place and there’s nothing she can do at the moment.
  6. The Husband is employed as a computer technician, however, he calls out of work all the time and is very lazy and sleeps most of the day, watching television until 4:00 a.m, who has hardly worked and is now trying to position himself for custody, child support, and alimony from the Wife. As a result of this Domestic Violence Injunction the Wife cannot see the small child.  This is a travesty and is not in the child’s best interests.
  7. The Wife has never abused, hit, or pushed the Husband in anyway which would cause him to reasonably be in fear of bodily harm. On the contrary, he is the one who, in the past put a hole in the wall at the house because of his anger. He has made threats to the Wife.
  8. The Wife is a very responsible, professional person. She is a registered nurse working and studying to be a nurse practitioner.  She takes care of people and helps them.  She is a caring and loving Mother and a good person.  She misses her three year old child terribly.  It is not in the child’s best interests for there to be no timesharing with the Mother when she has been the primary caretaker of this child throughout the marriage.
  9. The Husband caused an argument with the Wife and then has taken what she said completely out of context and twisted it to suit his purposes to obtain a Domestic Violence Injunction wrongfully. This should not be allowed and should be vacated.
  10. The Husband called the Police (see attached police report). The Husband told the police that the Wife invited two (2) guests to stay at the house and he wanted them to leave.  The Police told him to file an eviction.  He then went to the Courthouse and filed a Domestic Violence Injunction, a much quicker remedy.
  11. For all of these reasons, the Wife requests that the Injunction be vacated and/or modified.

WHEREFORE, the Respondent requests that the Petition for Injunction for Protection Against Domestic Violence be vacated and/or modified.

 

I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this notice and that the punishment for knowingly making a false statement includes fines and/or imprisonment.

 

Dated:_________________________                            _________________________

JAMIE CROWN

 

STATE OF FLORIDA         )

)§:

COUNTY OF BROWARD  )

 

BEFORE ME, the undersigned authority, personally appeared SHEVONNE EVANS,  known to me or who produced  __________________ 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 her personal knowledge and that she executed this document.

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

 

______________________________

NOTARY PUBLIC

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to Jack King, XXXXXX, XXXXXXXX XXXXXX and XXXXXXXX on this _______day of XXXXXX 20__.

 

LAW OFFICES OF LARRY D. SCHOTT

Attorney for Wife

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.

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