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WIFE’S VERIFIED URGENT MOTION TO SUSPEND HUSBAND’S TIMESHARING

WIFE’S VERIFIED URGENT MOTION TO SUSPEND HUSBAND’S TIMESHARING

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

 

In Re: The Marriage of                                            Case Number:

 

JACK KING,

 

Petitioner/Husband,

and

 

JAMIE CROWN,

 

Respondent/Wife.

 

__________________________/

WIFE’S VERIFIED URGENT MOTION TO SUSPEND HUSBAND’S TIMESHARING

The Respondent/Wife, JAMIE CROWN, hereby files this Urgent Motion to Suspend Husband’s Timesharing and states the following:

  1. There is currently pending before the Court a Petition for Dissolution of Marriage.
  2. The following minor child is subject to this proceeding to wit, NHV, born on xx/xx/20__.
  3. The Husband has been exercising timesharing on a trial basis overnight.
  4. There have been severe issues each time the Husband has the child.
  5. The child is extremely allergic and the Husband doesn’t properly care for the child.
  6. The last time Husband gave the child a peanut and the child is allergic to peanuts.
  7. This past weekend the child was returned hysterically crying all night with itching and bumps all over her legs. The Wife contacted the Husband but he refused to respond.
  8. This timesharing is not in the child’s best interest and must be immediately suspended.
  9. The Wife is filing an Urgent Motion to Appoint a Guardian Ad Litem contemporaneously with this motion.

 

WHEREFORE, the Wife requests the relief requested herein and same is in the best interests of the child and any other relief deemed necessary by the Court.

 

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

 

________________________________

JAMIE CROWN

Respondent/Wife

 

STATE OF FLORIDA         )

)§:

COUNTY OF BROWARD  )

 

BEFORE ME, the undersigned authority, personally appeared, JAMIE CROWN , 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 her executed this document this ______ day of ____________, 20__.

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

_______________________________

Notary Public, State of Florida

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was provided to:  XXXXXXXX, Esquire, Attorney for Husband, XXXXXXXXXXXXX on this _______day of XXXXXXXX 20__.

 

LAW OFFICES OF LARRY D. SCHOTT

Attorneys 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.