JOHN DOE 1234 MAIN STREET PHILADELPHIA, PA 19000 PRO SE FOR PLAINTIFF 215-555-1234 ________________________________ JANE DOE : COURT OF COMMON PLEAS : PHILADELPHIA COUNTY vs. : FAMILY DIVISION : D.R. NO.: 97-00001 JOHN DOE : IN CONTEMPT PETITION FOR CONTEMPT OF CUSTODY TO THE HONORABLE JUDGES OF SAID COURT: The plaintiff, John Doe, respectfully submits this Petition for Contempt and represents as follows: 1. The plaintiff is John Doe, (here-in-after "Father"), who resides at 1234 Main Street, Philadelphia, Pennsylvania, 19000. 2. The defendant is Jane Doe, (here-in-after "Mother"), who resides at 1234 Broad Street, 1st Floor Apt., Philadelphia, Pennsylvania, 19000. 3. The parties are separated and the parents of one (1) minor child, Justine, age 10. 4. A Court Order granting the father periods of partial custody since approximately 1988 and was last modified on November 01, 1995. (Order attached) 5. Mother has failed to comply with said order on numerous occasions (your chose to put dates in but remember it can help prepare the other sides defense). 6. The failure to abide by the custody order is not in the child's best interest. WHEREFORE, the father prays that this Honorable Court will grant the following relief: a) Find the defendant in contempt; b) Fine the defendant $500, the maximum allowed under 23 Pa C.S.A. §4346. c) Sentence the defendant to probation for a period of six (6) months. d) Order make-up periods in accordance with the periods of custody lost by the plaintiff and child. (If it is the first contempt filed, the above sanctions should be requested. As for subsequent contempt filings, you should stiffen the sanctions - ask for costs to be reimbursed and ask for imprisonment for six (6) months.) Respectfully Submitted ______________________ John Doe Pro Se for the Plaintiff Dated: April 08, 1997 CERTIFICATION I, John Doe, the plaintiff, hereby certifies that I served a copy of the Petition for Contempt on ___________ , 1997, upon the following: U.S. First Class Mail/proper postage attached Jane Doe 1234 Broad Street Philadelphia, PA 19000 (If mother has attorney, list him/her. Send copy of pleadings after filing) ____________________ John Doe VERIFICATION I, John Doe, the plaintiff, verify that the statements made in this Petition for Contempt are true and correct. I understand that giving false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. ____________________________ DATED: April 04, 1997 JOHN DOE 1234 MAIN STREET PHILADELPHIA, PA 19000 PRO SE FOR PLAINTIFF 215-555-1234 ________________________________ JANE DOE : COURT OF COMMON PLEAS : PHILADELPHIA COUNTY vs. : FAMILY DIVISION : D.R. NO.: 97-00001 JOHN DOE : IN CONTEMPT RULE TO SHOW CAUSE AND NOW, this ____ day of __________ , 1997, upon consideration of the attached Petition a Rule is hereby entered upon the defendant, Jane Doe, to show cause, why the attached petition should not be granted. IT IS ORDERED that the parties hereto and their attorneys, if any, to appear before this Court on the ____ day of _________ , 1997, at ___ o'clock __ M in Courtroom ___ , at Philadelphia Family Court, 34 South 11th Street, Philadelphia, PA 19107. IT IS FURTHER ORDERED that respondent cause a copy of this Rule, along with a copy of the Petition and accompanying papers, to be served upon petitioner. BY THE COURT ____________________________ J.