FORM 5.9 Petition for Contempt of Order of Custody

IN THE COURT OF COMMON PLEAS

OF __________________ COUNTY, PENNSYLVANIA

PLAINTIFF : No.

v. :

DEFENDANT

: IN CUSTODY

PETITION FOR CONTEMPT OF ORDER OF CUSTODY

AND NOW, Plaintiff, by and through [his/her] attorney, __________________, Esquire, 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

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child/children, counsel fees, costs and expenses, incarceration, etc.].

Respectfully submitted,

__________________

, Your Name

[Verification]