Custody Modification Attachment Format

Summary

When filing a petition for custody modification in Pennsylvania, you can use an attachment titled Attachment A: Additional Responses to Pretrial Memorandum for extra space. Follow the existing format for consistency. Include all issues and requests for relief in the attachment. The Pennsylvania Rules of Civil Procedure require pleadings to be concise and clear, and mediation is typically the first step in custody disputes. For specific issues, identify each separately, provide explanations, reference relevant laws, and propose resolutions. Consult an attorney for personalized advice.

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Do you know the Pennsylvania rules of civil court?
The Pennsylvania Rules of Civil Procedure guide civil court proceedings. Key points include:
- All pleadings must be concise and clear.
- Additional attachments are permissible, titled sequentially (Attachment A, B, etc.)
- Mediation is typically the first step in custody disputes.
- All issues should be included in the pretrial memorandum.

Always consult with an attorney for personalized advice.
How to include issues in the pretrial memorandum?
To include issues in the pretrial memorandum:
- Identify each issue separately.
- Provide a brief explanation or argument for each.
- Reference relevant laws or previous court decisions.
- Include your proposed resolution for each issue.
Please consult a lawyer for personalized advice on your case.
If I give you an example of an issue, can you reword it to be appropriate for a court document and reference any relevant laws for it?
Could you please provide me with an example of an issue you'd like to include in your pretrial memorandum? I can help you frame it appropriately for a court document, as well as point out any relevant Pennsylvania laws.
Relocation violation, father (custodial parent) moved into his girlfriends house without filing a motion to the courts and without notifying the mother (noncustodial parent) and during this move, told our daughter that they were only going to stay the night, but they never went back home, and also during this time the father withheld our daughter for a period of 3 months for no reason and this is unlawful due to our standing custody order where the mother is to get every other weekend. During this period of withholding the father also withhheld phone communication from the child preventing any contact with the mother and the mother found out about this move thru the child calling the mother to provide her the mailbox number and child memorized the two names on the corner street sign to have the mother help them figure out the address. This move also changed the child’s school district as well from Neff Elementary school to Landisville Elementary school without notification to the mother and mother was not added to the school paperwork as the child’s mother
You can frame your issue as such:
"Allegation of Breach of Custody Order and Child Relocation: The respondent, without proper notice or court permission, relocated our minor daughter. This move changed her school district and inhibited the petitioner's (mother's) custodial rights as outlined in our existing order, which grants every other weekend to the mother. Additionally, the respondent withheld contact between the child and petitioner for a period of three months. This breach is in direct violation of Pennsylvania’s Child Custody Act, * Pa.C.S. § *."
Please consult with a lawyer for personalized advice.