for Divorce Court
NOTEThis list is far from complete.
It is only a sample of what is possible.
Motion for Mental Examination of Spouse
CAVEAT: Be very
careful of this motion. You don't want to
get acquitted and
then end up having to pay spousal support until the rest of your
life if your spouse were to be found mentally ill. Of course, if
your spouse is truly mentally ill, you will have to pay support, but if
your spouse was only pretending to be ill and would not otherwise have
been diagnosed but for your motion, you would have shot yourself in the
Motion to Compel Documents Requested
A motion to compel is brought
pursuant to Rule
37 of your state's rules of civil procedure. This particular
presumes that you or your attorney have made requests
for the production of documents pursuant to Rule 34 of your
rules of civil procedure.
Motion to Compel Answers to Interrogatories Propounded by [your name]
A motion is brought pursuant to Rule 37 of your state's rules of civil procedure to compel your spouse to answer interrogatories. This particular motion presumes (a) that you or your attorney have, pursuant to Rule 33 of your state's rules of civil procedure, written a list of questions, sent them to your spouse's attorney, and asked that your spouse answer them and (b) that your opponent did not answer any of the "interrogatories."
Answers to interrogatories must
written. They may be used to impeach whoever wrote them
that party takes the witness stand.
Motion to Compel Further Answers to Interrogatories Propounded by [your name]
This particular Rule 37 motion presumes (a) that you or your attorney have, pursuant to Rule 33 of your state's rules of civil procedure, sent interrogatories to your opponent, (b) that your opponent did answer some of the "interrogatories," but (c) you want further answers because the answers are not complete in number and/or in substance.
SAMPLE: Pursuant to Rule 37(a)(2) of the State Name Rules of Civil Procedure Plaintiff Name moves this Court to order Defendant Name to serve and file, within 30 days, further answers to Interrogatories numbered 1, 4-12, and 15-16, and to provide timely updates of his answers to Interrogatories 13 (expert question) and 14 (documents to be used at trial). Plaintiff's Interrogatories to Defendant are attached to this motion as Exhibit A.
Then for each and every
interrogatory you want
answered or supplemented, you must type in your interrogatory,
answer, and your rebuttal, stating why the defendant's answers are
and objections are incorrect. See the rule and form books for
You are allowed to oppose
motions with which you disagree.
In case you fear your spouse will leave the state with the child, a ne exeat motion is possible.