FORM
5.9 Petition for Contempt of Order of Custody
IN THE COURT OF COMMON PLEAS OF
__________________ COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
PLAINTIFF
vs
No.
CI -
DEFENDANT
PETITION FOR CONTEMPT OF ORDER OF CUSTODY
AND NOW, Plaintiff,
__________________, files a Petition for Contempt of Order of
Custody against
Defendant, and in support thereof, avers the following:
1. Plaintiff is __________________
[Mother/Father], who currently resides at
__________________.
2. Defendant is __________________
[Mother/Father], who currently resides at
__________________.
3. The
parties hereto are the parents of the following minor [child/children], who
currently
reside(s) at
__________________.
4. On __________________, 20______,
the Honorable __________________
__________________,
entered an Order of Custody in the Court of Common Pleas of
__________________
County, Pennsylvania. A true and correct copy of said Order of Court
is marked Exhibit
``A,'' attached hereto and made part hereof.
5. Since the entry of said Order of
Court, [Mother/Father] has willfully failed to comply with
the custody
provisions as required by this Honorable Court, in spite of the fact that
[Mother/Father] has
been and continues to be physically able to comply with the terms thereof.
Specifically, [set
forth facts showing willful failure to obey of the Order of Custody].
6. [Mother/Father]
has incurred substantial counsel fees and costs as a result of
[Mother's/Father's]
contempt.
7. [Mother/Father]
should be responsible for [Mother's/Father's] reasonable counsel fees and
costs.
WHEREFORE, Plaintiff
respectfully requests that this Honorable Court enter an Order
adjudicating
Defendant in Contempt of Court and [set forth specific requests for relief,
i.e.,
transfer of custody,
make-up time with the child/children, counsel fees, costs and expenses,
incarceration, etc.].
Respectfully
submitted,
__________________
[Verification]