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Thanks Soc

Started by MissouriGal, Dec 15, 2003, 08:31:57 PM

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MissouriGal

For your reply below.

Yes, I did find an attorney that's willing to be a consultant for me if I need him. I re-did that previous motion at his request though because,... well.... it was 6 pages long. :(   This is the revised motion (pertinant changed part only, everything else is the same):

MOTION TO MODIFY CHILD CUSTODY, VISITATION, AND CHILD SUPPORT

COMES NOW the Respondent, Txxxx Dxxxxxx Mxxxxxx, Pro Se, for her motion to modify and states to the court as follows:
1.) On August 27, 2002 the Superior Court of Wxxxx County Georgia entered a Final Judgment and Decree of Divorce dissolving the marriage of the parties (see copy of Judgment, attached).

2.) Pursuant to said Decree, Petitioner was awarded sole physical custody of the minor children, Kxxx Exxxx Nxxxx Mxxxx, Txxxx Kxxxx Mxxxx, and Bxxxx Axxxx Mxxxx, and the parties were awarded joint legal custody of the minor children.

3.) The minor children of the parties have resided with the Respondent within the County of Mxxxx, State of Missouri for the past 6 months at 000 Highways 00/00 East, Mxxxx City, Missouri 55555. The minor children reside with the Respondent by Petitioner's agreement. Pursuant to RSMo 452.450.1(1)(a)(b), and RSMo 452.450.1(2)(a)(b), this Court has authority to assume jurisdiction over the matter of child custody.

4.) Respondent states that since the Superior Court of Worth County, Georgia entered it's Judgment and Decree of Divorce dissolving the marriage of the parties, the following substantial and continuing change of circumstances have occurred which include but are limited to:

A.) Petitioner is unable or unwilling to seek needed medical, psychiatric, and dental care for the minor children of the parties;
B.) Petitioner is unable or unwilling to promote the minor children's proper care and attention educationally;
C.) Petitioner has endangered the health and welfare of the minor children by administering prescribed controlled substance medications, which were prescribed by a physician to a third party unknown to the Respondent;
D.) Petitioner is unable or unwilling to provide age-appropriate clothing for the minor children and facilitate proper grooming techniques for the children.
E.) The children have resided with the Respondent in Missouri since May 30, 2003 and have received the proper educational, medical, psychiatric, and dental care they need and deserve.


Now, I have to get my decree registered here (which the attorney has drafted the paperwork for that for me, I just need to pick it up tomorrow and file it with my decree), and file for in forma pauperis status with the court.

Of course, I'm dealing with imbeciles in the Clerk's office here.... she told me she didn't know how to register a decree, that they've never had to do that, and that she doesn't know what the filing fee is. Hell, she referred me to the Recorder's Office, who records land titles, and deed transfers and such! I'm going to walk in there with the printed statutes saying what the Circuit Clerk's job is in registering a decree and see if she recognizes those.

Wish me luck. I'm gonna need it, I think.  LOL

socrateaser