Default Judgement? Summary Judgement? Summary Trial? Please Help...

[stealth2]

WRT CS..... Does that upper amount include:

* transportation (RT, given that you created the distance)? If so, perhaps request that you instead pay the airfare yourself, instead of bundling into CS. Is a UM fee required (I don't recall the ages of your kids)?
* insurance? That is often required of the NCP and, given the distance, may make sense for the CP to get in the home state.
*daycare/before-afterschool care, if applicable?
*extracurricular fees?

How, specifically, has she denied your parenting time? What proof do you have? Are you asking for make-up time, at her expense if you incurred costs that were lost?

 

[rperreta]

WRT CS..... Does that upper amount include:

* transportation (RT, given that you created the distance)? If so, perhaps request that you instead pay the airfare yourself, instead of bundling into CS. Is a UM fee required (I don't recall the ages of your kids)?
* insurance? That is often required of the NCP and, given the distance, may make sense for the CP to get in the home state.
*daycare/before-afterschool care, if applicable?
*extracurricular fees?

How, specifically, has she denied your parenting time? What proof do you have? Are you asking for make-up time, at her expense if you incurred costs that were lost?

I have text messages, recorded phone conversations and witnesses

Unfortunately unless you cram law school, passing the bar and several years of relevant experience into the next few weeks ..I think you are destined to blow the major credibility cards your STBX handed you by her stupid steps.

the judge might just tune out both parents and focus on the guidelines for child support ...but that's s risk Id be uncomfortable to take pro se.

BTW..who moved far away.

on totally different matters ..I've been in court to sit and wait ...and I've watched local rules in play such that an attorney spends 5 hours waiting for judge to spent 5 minutes on a custody matter and essentially say, reschedule it ..

If she has dismissed her attorney that may give you and your attorney a tactical advantage as well. ( I do not know your rules..but My understanding is attorney would need to be officially released by court ) and what you may want to sort out in advance if possible is the prospect that if she hires new counsel and at first appearance the new lawyer asks for delay so he / she has time to come up to speed to represent his/ her client..and you made a trip for that ...still I think you alter your odds rather unfavorably not to use counsel..and perhaps your current counsel was quite on the ball to out wait her ....

I was granted my motion to compel and the plaintiff was to comply within 30 days. She failed to do so. My question now is, do I file a motion in limine or motion to preclude? What's more effective in response to my motion to compel? Also, I am filing a 5 contempt charges for blocking my access to the kids and motion for sanctions. I want to know if i'm heading down the right path? Your help is greatly appreciated...

-rj