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E MAIL ADDRESS:


Name of Court:

Name of State:

Plaintiff:

Plaintiff Attorney,

Defendant Name:

Defendant Attorney,

Case Number:

Motion Title:

Jurisdiction Statement:
The Jurisdiction of the Court is bestowed upon the court by some statute or some rule of the court.

Comes now the plaintiff, , and does request that the honorable court enforce the Order of the Honorable Court issued on the date of . Pursuant to RSMo 476.110 the court has the power to enforce the Judgment and Order of the Honorable Court by means of contempt pursuant to RSMo 476.120.

Here is where you put your argument. Since this is a contempt motion, and you are filing it the contempt was not made in the presence of the court. You need to show the disregard for the Order and/or Judgment of the Court and with specificity how it has occurred.

Specifically, plaintiff requests that the official Order detailing the payment of out of pocket medical expenses be shared by both parties to the proportion of 50% each. The Plaintiff has incurred said expenses in the amount of $ for minor child, name child , at such hospital, name hospital, and by doctors and other medical professionals on the dates of , list dates. The Order of this court is not ambiguous and is in no way confusing. The defendant has the means to pay such costs and has refused to do so in a conversation on , such date.

This where you tell the court what you want the court to do.

Wherefore, the Order of the Court does read that out of pocket medical expenses shall be shared equally among the parties, and that defendant has not done so, and that by failing to pay half of the out of pocket expenses, defendant is in contempt of the clear meaning of this court's Order. Plaintiff requests that the court enforce the judgment and order of the Court upon the defendant and grant what ever relief that the court may find appropriate to the Plaintiff

Respectfully Submitted,

CERTIFICATE OF SERVICE

I hereby certify this pleading was served upon all attorneys of record for each of the parties to this action and All parties not represented by counsel, in the following manner:
___ By delivering a copy to him/her;
___ By leaving a copy at his/her office with the clerk;
___ By leaving a copy at his/her office with an attorney associated with him/her;
___ By mailing a copy to him/her, as prescribed by law;
___ By faxing a copy to him/her.

NOTICE OF HEARING

The foregoing pleading will be called for hearing before the court on at 1 pm or as soon thereafter as petitioner may be heard. So noticed: _______________________________

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