Attorney-Drafted Motion for Contempt of Court Form for Enforcing Court Orders

              IN THE CIRCUIT COURT OF THE [NTH] JUDICIAL CIRCUIT
              IN AND FOR [COUNTY] COUNTY, FLORIDA
                       FAMILY DIVISION


[PETITIONER FULL LEGAL NAME],        )
                                     )
              Petitioner,            )    Case No. [Case Number]
                                     )
v.                                   )    Division: [Letter]
                                     )    Judge [Last Name]
[RESPONDENT FULL LEGAL NAME],        )
                                     )
              Respondent.            )
_____________________________________)


      PETITIONER'S VERIFIED MOTION FOR CONTEMPT
       AND PROPOSED ORDER TO SHOW CAUSE
   (Fla. Fam. Law R. Civ. P. 12.615 / Tex. Fam. Code 157.166)


    Petitioner [Petitioner Full Legal Name] ("Petitioner"),
by and through undersigned counsel and pursuant to Florida
Family Law Rule of Civil Procedure 12.615 (or Texas Family
Code section 157.166 in Texas filings), respectfully moves
this Court to enter an Order to Show Cause and to find
Respondent [Respondent Full Legal Name] in contempt for
willful violation of this Court's [Order Title] entered on
[Order Date]. In support of this motion, Petitioner alleges:


I.   THE UNDERLYING ORDER

     1.  On [Order Date], this Court entered a [Order Title]
         (the "Order"), a certified copy of which is
         attached as Exhibit A.

     2.  The Order required Respondent to [specific
         requirement, quoted verbatim from the Order], by
         [Deadline or condition].


II.  RESPONDENT'S KNOWLEDGE OF THE ORDER

     3.  Respondent had actual knowledge of the Order
         because Respondent was [present in court when the
         Order was entered / personally served with the
         Order on [Service Date] as shown by Exhibit B /
         signed an Acknowledgement of Receipt attached as
         Exhibit B].


III. RESPONDENT'S ABILITY TO COMPLY

     4.  At the times Respondent was required to comply,
         Respondent had the financial means, physical
         capacity, and practical access required to obey
         the Order, as set out in Petitioner's supporting
         Affidavit and the financial records attached as
         Exhibit C.


IV.  WILLFUL VIOLATIONS

     5.  Respondent willfully violated the Order on the
         following dates and in the following manner:

         (a)  On [Date 1], Respondent [specific violation,
              identified by date, manner, and the
              paragraph of the Order violated];

         (b)  On [Date 2], Respondent [specific violation];

         (c)  On [Date 3], Respondent [specific violation].

     6.  Petitioner has been damaged by Respondent's
         violations in the amount of [Damages, if civil
         compensatory contempt is sought], plus reasonable
         attorney fees and costs incurred in bringing this
         enforcement action.


V.   RELIEF SOUGHT

     7.  Petitioner requests that this Court:

         (a)  Issue the proposed Order to Show Cause
              attached as Exhibit D, directing Respondent
              to appear and show cause why Respondent
              should not be held in contempt;

         (b)  Upon hearing, find Respondent in [civil
              contempt / criminal contempt] for the
              violations alleged above;

         (c)  Award Petitioner the relief the Court deems
              appropriate from the sanctions tier
              corresponding to the contempt finding
              (compensatory damages, coercive sanctions, or
              punitive sanctions);

         (d)  Award Petitioner reasonable attorney fees
              and costs incurred in bringing this motion;
              and

         (e)  Grant such other relief as the Court deems
              just and proper.


    WHEREFORE, Petitioner respectfully requests that the
Court enter the Order to Show Cause and, upon hearing, find
Respondent in contempt and award the relief set out above.


Dated: ____________, 20____.


                     Respectfully submitted,



                     _______________________________________
                     [Attorney Name], Esq.
                     [State] Bar No. ______________
                     [Firm Name]
                     [Firm Address]
                     [City, State ZIP]
                     Telephone: (___) ___-____
                     Email: __________________
                     Attorney for Petitioner


================================================================
                          VERIFICATION
================================================================

STATE OF [State]                  )
                                  ) ss.
COUNTY OF [County]                )

    I, [Petitioner Full Legal Name], being first duly
sworn upon oath, depose and state that I have read the
foregoing Motion for Contempt, that the factual allegations
contained in paragraphs 1 through 6 are true and correct of
my own knowledge, and that I make this verification freely
and voluntarily.


                     _______________________________________
                     [Petitioner Full Legal Name]


    Sworn to and subscribed before me this _____ day of
________________, 20____.


                     _______________________________________
                     Notary Public, State of [State]
                     My Commission Expires: _______________


================================================================
                  CERTIFICATE OF SERVICE
================================================================

    I HEREBY CERTIFY that on this _____ day of
________________, 20____, I electronically filed the
foregoing with the Clerk of the Court and served a copy on
Respondent and counsel of record via the e-filing portal or
by [process server / certified mail return receipt
requested]:

    [Respondent Name, Address, Email]
    [Respondent Counsel Name, Firm, Address, Email]


                     _______________________________________
                     [Attorney Name], Esq.