"Counts" for Orders of Contempt/Show Cause


#1

I have multiple documented texts, emails, blogs and facebooks posts of my ex in direct violation of our Current Order.
Order states:
4. Neither party shall directly or under pseudonyms blog, comment, like or post on any website, blog, social networking site, forum or any other electronic online place, the following:
a. Information about this case, including but not limited to, court dates, court hearings, legal issues, status and dispositions of the Court.
b. Sarcastic, rude, insulting, condescending, untrue or disparaging remarks about the opposing party.
c. Any comments whatsoever concerning the opposing party’s significant other or spouse.
d. Comments about the marriage and/or divorce of the parties, including but not limited to their opinions regarding the same.
e. Information about the minor children as relates to this case. Information about the children’s, or respective child’s, relationship with the opposing party, the opposing party’s spouse or significant other.
f. Quoting or paraphrasing the minor children on the opposing party, the opposing party’s spouse or significant other.
g. Feelings about the opposing party or the minor children’s relationship with the opposing party.
h. Direct or indirect comments or blogs, that tend to defame, discredit, insult, or vilify the other party.
5. The above Paragraph 4 is intended to be broad and encompassing for the purposes of prohibiting and preventing defamation of the other party, their significant other or spouse and unnecessary and inappropriate commentary which adversely affects the minor children or which alienates the minor children from the other parent or his/her significant other.
6. Neither party shall speak ill of the other party to the children or in the presence of the children.
7. Plaintiff shall in no way interfere with or deny the Defendant’s parenting time with the children upon the required seven day notification per aforementioned Voluntary Separation and Property Settlement Agreement is given and Defendant shall in no way interfere with the Plaintiff’s parenting time with the children.

Examples
6/12/13
"No I do NOT agree to Spring Break ~ you had them last year, this is my year. In fact, you have monopolized their Spring Break the last 3 years. The children will be with me this year as we have ‘vacation’ plans already and will not be changing them. " I went to pick up kids she had left area… call cops said to file with the court system…
9/12/13
"OMG, I’m going to vomit. I just sent a text that I do not agree to the children been"

There are Facebook posts on a weekly and sometimes daily bases about Narcissistic father, bi-polar, etc etc" over 100 occurrences in past 5 months since order was in place
Just two Examples
"Dealing Conflict Parent-
“It’s coming I know it! I won’t be blindsided this time! I might freak out and not know what to do, but I’m expecting the worst already! I’m no Dr., but I believe their dad is NPD, Narcissistic Personality Disorder”
“and a splash of Bi-polar”
“My protection from him a compact 12 gauge shot gun”
“What he didn’t say outright is that he and his girl-friend are going to take custody of the kids, NO GOING TO HAPPEN.”

Basically I want to know when I write out my motion to show cause or motion for contempt of two orders we have on file, can/should I list each event since it occurred at a different time as a “COUNT” or what should I do to show the amount instead of just a one time thing Paragraph 4, contempt?


#2

When you are filing to have another party held in contempt, your motion for an order to appear and show cause should be as specific as possible because you have to put the other party on notice as to what your allegations are. I usually draft my motion my allegations like the following:

  1. Paragraph X of the court order states “…”
  2. Defendant has willfully failed to comply with the Paragraph X of the court order in that, on xx/xx/xxxx, Defendant …"
  3. Paragraph Y of the court order states “…”
  4. Defendant has willfully failed to comply with the Paragraph Y of the court order in that, on xx/xx/xxxx, Defendant …"

I do this for all the different paragraphs and instances of violations.