Motion to Modify Custody


#1

I am Filing the “Motion to Modify Child Custody or Visitation [MCUS]” document from the instructions (http://www.nccourts.org/Courts/CRS/Policies/LocalRules/Documents/1484.pdf).

Under Item 5 [Since the current Order for Custody and/or Visitation was entered, a substantial change in circumstances relating to the minor child(ren) has occurred as follows:] I am listing the changes in circumstances. i.e.
Defendant alienates Plaintiff from the minor children.
Defendant is sleeping with the minor children.
Defendant constantly calls the minor children on their cell phones during the Plaintiff time with the minor children.
Defendant makes the minor children talk to the Plaintiff about visitation/drop off/pick up changes.
Defendant forces the oldest (15) child to ‘be the adult/parent’, as the Defendant takes on the role of a child.

MY QUESTION: Do I need to include specific examples of (i.e.):
HOW the Defendant alienates Plaintiff from the minor children ?
HOW the Defendant forces the oldest child to ‘be the adult/parent’ ?

Or do I show/tell the Judge during trail ?


#2

You will disclose the details at the hearing.