Child Custody Motion for Modification
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Child Custody Motion for Modification
Unit 6 Assignment
Kimberly Glackin
PA250-01
Kaplan University
Professor Atkins
December 14, 2012
Maureen Foley
Full Name of Party Filing This Document
400 Potato Field Lane
Mailing Address (Street or Post Office Box)
McCall, Idaho 83710
City, State and Zip Code
(698)-555-1234
Telephone Number
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF
THE STATE OF IDAHO, IN AND FOR THE COUNTY OF VALLEY
Maureen Foley,___________
Plaintiff,
Richard Turrow,___________
Defendant.
Case No.: 689071
MOTION TO MODIFY AN ORDER OR
DECREE
Fee Category:
Filing Fee:
I, Maureen Foley, [X] Mother [ ] Father, ask the court to enter an order pursuant to Rule 60(c), I.R.C.P., modifying a previous Order/Decree entered in this case, and state:
1. The following child/ren under the age of 18 years, or 19 years and still pursuing a high school education, was/were born to or adopted by the parties:
Date of Birth
Addresses for last 5 years
(Beginning with most recent city & state)
Colin Turrow 03/04/2002 400 Potato Field Lane McCall, Idaho 83710______
Tyler Turrow 04/19/2000
400 Potato Field Lane McCall, Idaho 83710
2. Mother resides at (city, county, state) McCall, Valley, Idaho. Father resides at (city, county, state) McCall, Valley, Idaho.
3. UCCJEA Jurisdiction. This court has jurisdiction to modify custody of our child/ren pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act, Idaho Code § 32-11-101, et seq.
a. [X] I have not participated as a party or witness, in any other case involving our child/ren. or
[ ] I have participated as a party or witness in the following case involving our children (provide all specifics including the parents name, the state, the court, the case number and the date of the child custody order, if any):
b. [X] I do not know of any other case that could affect our child/ren. or
[ ] I know of the following court case that could affect our child/ren (provide all specifics including the parents name, the state, the court, the case number and the nature of the proceeding):
c. [X] Other than the parents, no one claims custody or visitation rights with our child/ren. or
[ ] In addition to the parents, the following person/s claim custody or visitation for our child/ren (list names and addresses):
d. [X] Our child/ren live(s) only with both parents. or
[ ] If our child/ren lives(s) with someone other than a parent, the name(s) and present address(es) of the person(s) with whom our child/ren live(s) is/are:
4. There have been substantial and material changes in the circumstances of the parties since the date of the last Order/Decree herein. The following changes have occurred (check all boxes that apply):
[ ] The custodial arrangement.
[X] The gross annual income of one or both parents.
[X] A parent is providing medical insurance.
[ ] The parent claiming the tax dependency exemption should be changed.
[ ] (other reason)
5. Custody. [X] No change. or
Legal Custody. [X] No change. or
[ ] Both parties are fit persons to act as parents. It is in the best interest of our child/ren that we be awarded joint legal custody. or
[ ] It is in the best interest of our child/ren that ____________________________ be awarded sole legal custody because _________________________________________________________ ___________________________________________________________________________________________________________________________.
Physical Custody. [X] No change. or
[ ] It is in the best interest of our child/ren that we be awarded joint physical custody of our child/ren on the terms and according to the Parenting Plan which is attached as Exhibit A. or
[ ] _________________________ should be awarded sole physical custody of our child/ren because_________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________.