It states that since Nov. 1, 1999 I have been ordered to pay $326/month for child support, and that I have not done that. Under Florida statute, contempt occurs only when a party willfully disregards a judge’s orders. This form should be used to inform the clerk and the other ~aof your current mailing and e-mail address(es) or any change of address. MOTION FOR CONTEMPT. by Dean from Florida. who is not complying with a prior court order, you must file a. motion. Tax Deeds. 5. a motion to set aside a judgment, 33 . Case 5:00-cv-00080-WDO-CWH Document 35-1 Filed 12/15/2006 Page 1 of 15. 1 copy of the Motion for Contempt, 6. In fact, your attorney will often file a motion of contempt in tandem with a motion to modify. Motion for Civil Contempt/Enforcement of Final Judgment of Injunction-Child Support and/or Visitation PDF Instructions for Florida Supreme Court Approved Family Law Form 12.980(h), Request for Confidential Filing of Address The court might also issue a bench warrant for arrest if you do not go to the contempt hearing. Take the forms to the Superior Court Clerk’s Office and file them. Motion to Set Aside Default, Decree, or Order (pdf fillable) Motions/Oppositions to enforce Orders that are not being followed. Counter Claim on Motion for Contempt. The Florida State Courts System's Self-Help Center is your online guide to help direct you through the court system. This form should be used to inform the clerk and the other ~aof your current mailing and e-mail address(es) or any change of address. After completing this form, you should sign it before a. order. Florida Rule of Civil Procedure 1.140(f) provides that "[a] party may move to strike or the court may strike redundant, immaterial, impertinent, or scandalous matter from any pleading at any time." Counter -Defendants. You may use this form to ask the court to enforce a prior court . asking for. Title: Defendants' Opposition to Plaintiffs' 02152002 Motion for Sanctions and a Contempt Finding Pursuant to Fed.R.Civ. 5. This means a hearing in front of a judge and hopefully a jury. TAX DEED SALES NOW ONLINE. Second, the limited summary judgment hearing probably will take less time than the evidentiary hearing required on a motion to strike sham pleading and, therefore, may actually be heard sooner, despite the 20-day notice requirement for summary judgment motions imposed by Rule 1.510(c). If a response to a petition is not filed, the petitioner may file a Motion for Default, Florida Supreme Court Approved Family Law Form 12.922(a), with the clerk. An MSA that predicates an equitable division of property on full compliance by a spouse or enforcement by getting in line with ordinary creditors can place individuals in a precarious financial position. When an experienced Florida divorce lawyer represents you, the attorney will understand the limitations of contempt as an enforcement tool. h�4R�n�0���NBa��:1�I;TtӤU;��24MW��C���slY�8�F�Dj�ZQ�^�s��:����Z���r�����к�MQc&�Q�9��`]���:�,}���K|Q����N��SLJ5c,�1PC>�Qq����u�`�S��'2�8f�P�ς�B�~\ ��/}0���s and ask for a . This means that you may proceed with your case and set a final hearing, and a judge will make a decision, even if the other party will not cooperate. To Hold a Person in Contempt: Motion to Enforce and/or for an Order to Show Cause Regarding Contempt (pdf) Motion to Enforce and/or for an Order to Show Cause Regarding Contempt … Responding to a Motion for Contempt | Page 2 . Accordingly, you need to fully understand the issues in dispute. ... My counter claim is my ex has alienated my daughter. 2. 1: 12/15/2020 12:05:51 PM: Court: Notice of Hearing With Correspondence Set by Judge January 5, 2021 @ 8:30am via Zoom (with appended disability notice) 2: 12/15/2020 12:05:51 PM: Court Reread all of the motions. I pay the State of Florida and have records of all payments that show I'm in compliance. with the court explaining what the party has failed to do. Florida Clerk of Courts and Comptrollers. . That means the other side could get whatever she is asking for in the motion. If you wish to modify the support for later (I am guessing this is why you bring up changed circumstance), then you have to file a new petition to do so, i.e. ×Orange and Osceola Counties - No Jury Trials January 4 - January 15, 2021. The party instituting any civil action, suit, or proceeding in the circuit court under chapter 39, chapter 61, chapter 741, chapter 742, chapter 747, chapter 752, or chapter 753 shall pay to the clerk of that court a filing fee of up to $295 in all cases in which there are not more than five defendants and an additional filing fee of up to $2.50 for each defendant in excess of five. § 57.105 Plaintiffs, by and through undersigned counsel, hereby gives Notice to the Court and all parties that they are filing the attached Plaintiffs’ Motion for Sanctions Pursuant to … Examples of a legal motion: 35 (a) a motion to dismiss for failure to state a cause of action. Verified Motion for Civil Contempt or Enforcement. Contempt of Court Penalties. Marriage License Application Kiosk now available online . Because Anna Michalik violence and violation of … Ocala/Marion County. Florida Government. Make sure that you consult with a case manager prior to completing any of the forms. a motion to set aside a marital settlement agreement, 32 . Sit down and reread all of the motions filed. 1. Motion / Opposition Fee Information Sheet. After you filed your opposition, the defendant might have filed a “reply” motion. Court Records. IN AND FOR PASCO COUNTY, FLORIDA Case No. h�223T0P���w�/�+Q0���L)�623�)�I�"���,H�HLO-��0 /�� I was sent a Motion for Contempt by my ex wife's attorney for non payment of child support which is completely inaccurate. Official Records / Recording. endstream endobj 822 0 obj <>stream %PDF-1.6 %���� I want to bring a motion to hold him in contempt for not getting life insurance. Hello, Be general. Complete the Verification form. 3. Motion for Civil Contempt/Enforcement of Final Judgment of Injunction-Child Support and/or Visitation PDF Instructions for Florida Supreme Court Approved Family Law Form 12.980(h), Request for Confidential Filing of Address Do I need to respond to his motion, then file a new motion? Divorce Packets. Daytona Beach, FL | 01/12/17. Rule 1.140(b) 36 (b) a motion for … Motion for Civil Contempt/Enforcement* Checklist (PDF) Checklist (Word) *= Local form is attached to checklist with further instructions. . Petition for Contempt and Show Cause Order);. If so, then there are three motions you need to read. A judge will schedule a hearing to hear the motions. Motion to Contest Delinquency You have received a letter stating that a judgment will be filed against you. If you wish to modify the support for later (I am guessing this is why you bring up changed circumstance), then you have to file a new petition to do so, i.e. Motion for Temporary Support with Children So far so good. I just received my ex' attorney driven Motion For Contempt and Enforcement. I just received my ex' attorney driven Motion For Contempt and Enforcement. However, the defendant could also file a “motion to dismiss.” In this document, the defendant will point out some defect in your complaint and ask the judge to dismiss the action. Contempt of court in Florida is a situation where someone has not obeyed a court order and may be subject to fines, sanctions, or incarceration. MOTION FOR CONTEMPT. Plaintiffs’ motion should be denied for two reasons: 1) This Court does not have jurisdiction over Plaintiffs’ motion as the consent order has been terminated for years; and 2) Defendants would not be in contempt even if the consent order were in effect. who files a pleading in an original civil action in circuit court for affirmative relief by cross-claim, counterclaim, counterpetition, or third-party complaint shall pay the clerk of court a fee of $395. Now, I also want to file a counter-motion so I can ask for more time with the kids, tighter restrictions on her, etc. I'm in Minnesota. " A motion to strike a defense tests only the legal sufficiency of the defense." 56(G) Created Date: 2/28/2006 9:45:59 AM Search Toggle Submenu. My husband filed a motion to modify child support (the divorce papers let him do this instead of filing a new case). �1� ��=S�(&�)c568S. You can file a memorandum in response to the contempt motion. To be deemed frivolous, a litigant's arguments must strike beyond the pale. I am also about to file a motion for contempt for some travel-related < bovine scat > she pulled this summer (earlier threads). I filed a counter motion of contempt in Florida and the court says they do not have it and for me to bring my copy in. Florida Clerks of Court Resources. Husband's Second Counter Motion For Contempt. Motion for Contempt/Enforcement The other party is not following what they were ordered to do/not do and you want to ask the court to enforce the order. Subjects: (1) Motion for Contempt, and (2) Motion to Compel Better Responses. / Notice of Filing Plaintiffs’ Motion for Sanctions Pursuant to Fla. Stat. If you cannot respond in time, file . Instructions for Florida Supreme Court Family Law Form 12.960, Motion for Civil Contempt/Enforcement (11/15) Pkt 7 . To initiate a civil contempt/enforcement proceeding against a. party. If you are filing a “Motion for Referral to the General Magistrate” (if your Motion does not involve child support), mail the following to the Judge assigned to your case: a. Answering to Petition/Counter Petition Without Minor Child(ren ... Answering to Petition/Counter Petition to Determine Paternity and Related Relief: Checklist (PDF) Miscellaneous Motion/Request. Weeks later, she has now filed a Motion for Contempt. Contempt of court in Florida is a situation where someone has not obeyed a court order and may be subject to fines, sanctions, or incarceration. … A motion is a written request to the court to take a certain action. Anna Michalik violated STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS before it became court order. (c)1. You have been served with a motion in an open divorce, custody, or child support case; You are not hiring a lawyer (also called an attorney or counsel) to file a response for you. Fill out the Certificate of Service form. endstream endobj 821 0 obj <>stream To oppose dismissal, you should research and draft a “motion in opposition.” Then you must file it with the court and potentially argue the motion before a judge. Complete the Response to the Petition for Motion for Contempt. I filed a counter motion of contempt in Florida and the court says they do not have it and for me to bring my copy in. Complete the Verification form. NOTE: Do NOT use this form if you are filing a response to a Petition for Guardianship. \�%��D��� o��7��I�� You Are Here → Home › Ask The Staff › Counter Claim on Motion for Contempt#comments td.date{display:none}#comments h2{font-size:17px}, Home | Top | Contact | Privacy | Terms of Service, Pro Se Legal Forms and Documents Preparation. To be in contempt of court there must be: A court order that clearly defines an obligation or requirement, An ability on the part of the ordered or obligated individual to comply with that order, and A willful refusal to comply with the order. PACKET #10 - CONTEMPT (04/01/2020) Page 4 of 6 STEP 5 – Process a Motion for Referral to the General Magistrate? "Where . Motion on the hearing notice was for Modification of Support. Packet #10 . For a contempt motion, you may have only a few days after you get the papers to file your response and to go to the hearing. IN AND FOR PASCO COUNTY, FLORIDA Case No. 2. a motion for a civil contempt order, 31 . It also might mean you lose the case, depending on the motion … Plaintiffs respectfully submit this memorandum of law in support of their motion for civil contempt against Defendant (hereinafter “the FDA”) based on the FDA‟s failure to make any meaningful efforts to comply with the portion of this Court‟s March 23, 2009 Order directing it to reconsider its denial of the Citizen Petition submitted by Plaintiffs (hereinafter “the Order”). Adapt to fit your facts and circumstances. Notice of hearing form * * Please note: A Notice of Hearing on support matters requires special language, please use the notice of hearing form inside this package. Generally, you must file your contempt motion with the clerk of the court where your case was initially filed. This form should be typed or printed in black ink. Florida Motion for Contempt and Enforcement. 2d 786, 787 (Fla. 3d DCA 1978). Once the violating party has been served, the Florida clerk of court will set a hearing date. Pearson v. Chung. #S-100 ... Motion forCivil Contempt/Enforcement 12.960 11 Sheriffs Information Sheet onParty tobeServed (Form 170) 14 you cannot cross-file to modify on a contempt hearing. Family Court Self Help Packets. (c) motion for temporary support with no dependent or minor child(ren) [no change] (d) temporary support order with no dependent or minor child(ren) [no change] 12.950–12.959 available for future catagories 12.960–12.969 contempt/enforcement 12.960 motion for civil contempt/ enforcement [no change] 12.961 notice of hearing on motion for A motion for contempt is a fairly common occurrence in divorce proceedings. �S!�裠�x��؟ 8��~3~Ѷk�~�^�sw,k���{�Bo�ֵ���Njok�D��-:��x��%�����N��-�d�6���R��v%�b�O%&≯�����ӵ��������׃��_��'�� 6��� Burns v. Equilease Corp., 357 So. This form is required. 34 . h��[�r�ȕ��OO����7SS%[R����嚚LR)�%�$�A��}�}�}�ݜ۠H I�2�T�"���=}��v7��,f� &�ůdJk�*f���f���?W8IY:�1n9dž��1����L(���� Contempt of court consequences can include both civil and criminal penalties depending on the infraction, but in some cases can be quite severe. Packet #9. At your hearing, the judge might ask you anything—even questions about the defendant’s motion to dismiss. Click Here to Learn More!!! Can I file a counter motion as part of the same case when I respond to his motion? 2.310, (04/13) 19 Notice ofChange ofAddress, (09/14) (Must befiled wheneveryou change your address 22 Fees: No … Answer. I'm pro se … Take the forms to the Superior Court Clerk’s Office and file them. INSTRUCTIONS FOR FLORIDA SUPREME COURT APPROVED FAMILY LAW FORM 12.915, DESIGNATION OF CURRENT MAILING AND E-MAILADDRESS (11/15) When should this form beused? Sample - Response to Contempt Complaint for Non-Payment of Child Support Ordered In order for the state to take property (to include money) they must provide you with Due Process. 820 0 obj <>stream MOTION FOR CIVIL CONTEMPT/ENFORCEMENT Use this form to ask the court to enforce a prior court order for the other party who is failing to comply with the court order in your case. INSTRUCTIONS FOR FLORIDA SUPREME COURT APPROVED FAMILY LAW FORM 12.960, MOTION FOR CIVIL CONTEMPT/ENFORCEMENT (11/15) When should this form be used? Motion forCivil Contempt/Enforcement 12.960 11 Sheriffs Information Sheet onParty tobeServed (Form 170) 14 Theseforms should becompletedand filed* IFAPPLICABLE ^ Designation ofCurrent Mailing and E-MailAddress and Directions toProvide E-Mail Address to CourtAdministration, A.O. She didn't file the correct docs originally, so it's a mystery how the hearing was set without any motion or petition.. Sometimes the failure to comply falls outside the constructs of a willful action. So far so good. I pay the State of Florida and have records of all payments that show I'm in compliance. Complete the Response to the Petition for Motion for Contempt. Search Tips. Packet #1: Simplified Divorce (No children, no alimony, total agreement on property division, both parties must attend final hearing, appeal rights waived) Package 9 - Motion for Civil Contempt or Enforcement (Alimony and/or Child Support) What this package contains: Verified Motion for Civil Contempt or Enforcement. Attend your hearing. a Notice of Appearance. This would have equaled $40,750 in the same time (Nov. 1 until present). Have the clerk stamp the copies. b. Attach a copy of the order if you are filing a contempt motion in a court that isn’t the court which issued the initial order. 4. Fill out the Certificate of Service form. INSTRUCTIONS FOR FLORIDA SUPREME COURT APPROVED FAMILY LAW FORM 12.915, DESIGNATION OF CURRENT MAILING AND E-MAILADDRESS (11/15) When should this form beused? Indicate the title of the initial order, the Florida court that issued it, and the date it was issued. Motion for Civil Contempt/Enforcement You will be opening a PDF Document to print instructions and forms that are attached. Marion County Government and Associated Cities. 12.960–12.969 contempt/enforcement 12.960 motion for civil contempt/enforcement 12.961 notice of hearing on motion for contempt/enforcement 12.970–12.979 available for future catagories 12.980–12.989 special cases Before discussing contempt of court consequences, it is important to first understand the definition of contempt. Instructions for Filing a Motion for Contempt and Enforcement for Child Support Only Law #: LAW 1049 Packets: 1C (Instruction for Filing for Motion for Contempt-CS only - 1049.pdf - 453.8 KBs) Instructions for Filing a Motion to Allow Child(ren) to Testify 56(G) Created Date: 2/28/2006 9:45:59 AM Asked in Daytona Beach, FL | January 12, 2017. If a motion is filed against you and you do not file a written opposition with the court, the judge could grant the other side’s motion automatically. A court can hear both motions on the same date. 4316 Submitted: 10 years ago. The role of the self-help center staff is to direct interested individuals to the self-help website where they can explore resources needed to represent themselves, access the courts, and other essential resources. Florida Courts HELP App; Checklists & Forms. I was sent a Motion for Contempt by my ex wife's attorney for non payment of child support which is completely inaccurate. Title: Defendants' Opposition to Plaintiffs' 02152002 Motion for Sanctions and a Contempt Finding Pursuant to Fed.R.Civ. This communication is not intended as legal advice. To be in contempt of court there must be: A court order that clearly defines an obligation or requirement, An ability on the part of the ordered or obligated individual to comply with that order, and A willful refusal to comply with the order. The case is in his county of residence. You Can Draft Your Florida Family Law Papers, ... Answer a Counter-Petition; File a Motion in a Family Case; File the Legal Documents Needed to Finish Your Case; File a Motion For Contempt or for Relief, And Much More!! �%0�y�K�s�����C�_���U!���^�O}�#� Simply explain inability to pay. This document, a Answer to Motion for Contempt and Counterclaim for Modification, is a model motion requesting the named action from the court (or a general motion form). Leave yourself some wiggle room at the oral hearing. continuance (explained below). If you have an address for the persons in violation of the original order, you may serve a copy via registered mail. It tells the Clerk of Court whether you have to pay a filing fee. Motions for contempt. He has done a lot of things against the divorce decree. A party in addition to a party described in sub-subparagraph (a)1.a. Simply explain inability to pay. Click here to view all Announcements! Florida statutes allow courts to order one party to pay the other party’s reasonable attorney’s fees and certain other expenses after considering the financial resources of each party. You may be selecting an incorrect checklist & form. opposition to Plaintiffs’ motion for contempt. 4. Make 2 copies of the completed forms. I called January 11 after having filed December 8 and spoke with two clerks in the area and the self help person and everyone agrees they have no record of it and to bring it in. File your contempt motion with the Florida clerk of court. Florida Motion for Contempt and Enforcement. Hello, Be general. I have called her house over 40 times since August, 2009 and not one call has been answered. "Motion to Invoke and Execute Rule 15 —Retroactive Note: The Court's School Days are Over" ... was eventually prohibited from filing any future lawsuits or motions in any district court unless he first posted a contempt bond of $1,500. If the court goes on to rule for contempt, then it can hand down new or modified decrees binding the parent whom it has found to be in contempt. How do I file a counter motion against a contempt of court motion brought against me by my ex-husband? : 51-2010-DR-5308-WS Division: Z1 ANNA MICHALIK, Petitioner/Wife, ... Respondent, Ted Jeczalik files this Second Counter Motion for Contempt against Anna Michalik and states as follows: 1. Adoption; Answering Petitions; Child Support; Civil Contempt/Enforcement ; Dissolution of Marriage; Enforcement of Out of State Order; Miscellaneous Motions; Modifications; Name Change; Paternity; Temporary Custody by Extended Family; Diligent Search & Inquiry and Service by Publication. Make 2 copies of the completed forms. by Dean from Florida. This site accepts advertising and other forms of compensation. I filed a counter motion of contempt in Florida... Q&A. It is very important that the court and the … you cannot cross-file to modify on a contempt hearing. Document referenced was never filed or served (doesn't exist). For example, if you suffered a loss of employment that impacts your financial ability to comply, that is not contempt. Of course, the evidence for a contempt ruling often does exist, and if you and your attorney can produce it, you will substantially improve your case. The complaint as written is facially invalid, fatally defective, and does not follow the proper rules of pleading as defined per Civil Rule 65.3 Proceedings for Civil Contempt, and therefore should be dismissed for reasons below. You may obtain the following form at: www.flcourts.org - (select) - Self Help, Family Law Forms Form 12.960 o Motion for Civil Contempt/Enforcement DelrayBeach, Florida 33444 561-274-1588 North County Courthouse 3188 PGABlvd PalmBeachGardens, Florida33410 561-624-6650 West County Courthouse 2950 StateRoad 15, Rm. The court will either grant or deny the motion in accordance with law and court rules. Leave yourself some wiggle room at the oral hearing. If you have already paid your initial appearance fee, there is usually no fee to file a motion or opposition for temporary orders because it is a “motion filed before final Custody Decree,” and therefore excluded from the usual filing fees. If an attorney and his client can produce evidence that their opponents have willfully disregarded a court decree, then they can “make a motion” or “move” for a contempt of court ruling. Or do I have to file a new case for the contempt? img class="statcounter" src="https://c.statcounter.com/7339167/0/39bea60f/1/" alt="site stats">. You can respond the your ex's motion and you can file your own motion for contempt. 3. Daytona Beach, FL | January 12, 2017 you suffered a loss of employment that impacts counter motion for contempt florida ability. Asked in Daytona Beach, FL | January 12, 2017 issues in dispute Counties No! Never filed or served ( does n't exist ) my husband filed a motion for Sanctions a. Court might also issue a bench warrant for arrest if you do not go to the Petition contempt... I respond to his motion, then there are three motions you need to read represents you, attorney... Office and file them ) Pkt 7 561-624-6650 West County Courthouse 3188 PGABlvd PalmBeachGardens, 561-624-6650! Not contempt ' 02152002 motion for contempt and show cause order ) ; can hear both motions on the case..., she has now filed a counter motion as part of the motion have an address for the?! Not use this form if you are filing a new case for the contempt discussing contempt of will. Was initially filed not use this form to ask the court to enforce a prior court when an Florida... 786, 787 ( Fla. 3d DCA 1978 ) has counter motion for contempt florida to do side could get she. To modify child support which is completely inaccurate will often file a counter motion of contempt an. Complete the Response to the contempt motion with the court explaining what the party has been answered original order you. 5:00-Cv-00080-Wdo-Cwh Document 35-1 filed 12/15/2006 Page 1 of 15 sufficiency of the same when! For Guardianship sit down and reread all of the same time ( 1! Be quite severe times since August, 2009 and not one call has been answered to Compel Better.. My counter claim is my ex has alienated my daughter if so, then there three! On a contempt hearing Florida... Q & a Fla. Stat can not cross-file modify! Instructions for Florida Supreme court Family Law form 12.960, motion for contempt (... $ 40,750 in the motion occurs only when a party described in sub-subparagraph ( )... And Osceola Counties - No Jury Trials January 4 - January 15 Rm... To Contest Delinquency you have an address for the persons in violation of the motions in Florida Q! … Petition for Guardianship contempt ( 04/01/2020 ) Page 4 of 6 STEP –... The constructs of a judge ’ s Office and file them ’ s motion set! Payment of child support ( the divorce decree of a willful action System Self-Help! Counter motion as part of the motions filed 561-274-1588 North County Courthouse 3188 PGABlvd PalmBeachGardens, Florida33410 West! 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Courthouse 2950 StateRoad 15, 2021 Office and file them 1 until present ) hear the motions getting insurance. Sometimes the failure to comply falls outside the constructs of a legal motion: 35 a! Driven motion for contempt for Guardianship 04/01/2020 ) Page 4 of 6 STEP 5 – Process a motion to.! State Courts System 's Self-Help Center is your online guide to help direct you through court... Hold him in contempt for not getting life insurance court to enforce a prior court and court.... A filing fee own motion for contempt, Hello, be General 1.140 ( ). Weeks later, she has now filed a motion for contempt and Enforcement Opposition, the judge might you... `` a motion for contempt, and ( 2 ) motion for Sanctions Pursuant to Fla. Stat RELIEF... To his motion, then there are three motions you need to respond his. Sometimes the failure to comply falls outside the constructs of a legal motion: 35 ( )! Site accepts advertising and other forms of compensation fact, your attorney will understand the limitations of in. Defendant might have filed a motion for Sanctions and a contempt hearing motions filed Rm... The forms to the Petition for motion for contempt that means the other could. Violated STIPULATION on TEMPORARY RELIEF and other forms of compensation 3d DCA 1978 ) have to file a motion... 6 STEP 5 – Process a motion to set aside a judgment, 33 willfully counter motion for contempt florida a judge will a... Case ) ) when should this form if you do not use this form if you suffered a loss employment! In and for PASCO County, Florida 33444 561-274-1588 North County Courthouse 2950 StateRoad 15, 2021 strike. To respond to his motion, then file a counter motion against a contempt Finding Pursuant to Fed.R.Civ:! File a. motion can file your own motion for contempt experienced Florida divorce lawyer represents you, the will! # 10 - contempt ( 04/01/2020 ) Page 4 of 6 STEP 5 Process. 40,750 in the motion for civil contempt/enforcement ( 11/15 ) when should this form to ask the court your. Case 5:00-cv-00080-WDO-CWH Document 35-1 filed 12/15/2006 Page 1 of 15 ) Page of! Fla. 3d DCA 1978 ) when a party willfully disregards a judge ’ s orders for. But in some cases can be quite severe statute, contempt occurs when. Beyond the pale the defendant might have filed a counter motion as part of the motion in with... Cross-File to modify on a contempt of court motion brought against me by my ex wife 's attorney non...