petition of custody examples

[braveheart503]

Can anyone give me some pointers on what to add in a petition fo Custody. Are there any petitions on the net that I can look so that I can get ideas while putting my own petition together?

[littlebit]

Here is a copy (personal info excluded of course) of the motion my attorney filed for me this year.  Hope it helps.

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IN THE CIRCUIT COURT OF NOWHERE COUNTY, ALABAMA
DOMESTIC RELATIONS DIVISION

BILLY B. BOB,

     PLAINTIFF,

VS                                                     CASE NO.   DR 123456.12-C

JEZABELL L LYER (f/k/a JEZABELL L BOB),

     DEFENDANT.


MOTION TO MODIFY AND CHANGE OF CUSTODY

   Comes now Billy Bob, and files this Motion To Modify and Change Custody and in support thereof shows the following:

1.  That this Court previously changed the custody of the minor child from the Petitioner (father) herein to the Defendant on January 1, 1942.

2.  That since the last Order in this matter the child has suffered in his xxxxxx needs
to such an extent that he was xxxxxx two to three days per week.  After the father's repeated attempts to discover the problems associated with his xxxxxx by inquiry to the Defendant and the xxxx, the Defendant withdrew the child from xxxxx and is purportedly "xxxxxxx" the child.  This has been going on this entire xxxxxx.

3.  The only method the father had to monitor the child's progress was through his xxxxx and the xxxxx he formerly xxxxxx.  Since the Defendant removed him from the xxxxx  the father has had no xxx xxx, xxx, xxx xxx, etc.

4.  The Defendant has sixteen other children at home.   While supposedly "xxxxxxx" all sixteen children the Defendant operates a lollipop store at a circus full time.  She leaves the children unsupervised the majority of the daytime hours.

5.  The Defendant has and will continue to cause the child psychological harm in that she forces the child to xxxxxx.

6.  The Defendant will not allow communication between the child and the father on a regular basis.  Every time the father calls to speak to the child, the child is "conveniently" unavailable.

7.  The Defendant has refused to participate in counseling with the father and son as per the last Court Order.



8.  The Defendant intentionally violates the terms of this Court's previous Order by unilaterally denying or changing the visitation schedule.  


9.  Since the last Court Order there has been a change in circumstances such that a modification of the child custody provision is warranted, the father's affidavit is attached hereto in support.

10.  It is in the best interest of the minor child that the Court's Order be modified to grant primary physical custody of the minor child to the Plaintiff/father.

   WHEREFORE, the premises considered, the petitioner herein would pray that this cause be set for hearing, appoint a guardian ad litem for the minor child, and upon presentation of the evidence grant the father primary physical custody of the minor or whatever relief to which he may be entitled.

   Respectfully submitted this ___day of January, 2004.


                     ____________________________
                     MIGHTY Q ABRAMS (ABR555)
                     Attorney for Plaintiff
                     1234 Courthouse Rd.
                     Nowhere, AL 55555
                     (555) 555-5555

PLEASE ALLOW SERVICE BY S.P.S. WILE E KYOTE 555-4444