Response, counter claim & discovery

You may file a responsive motion and include your counter points in numbered paragraphs which correspond to the numbered paragraphs in the motion your ex filed. This gives you the opportunity to refute or explain each allegation in a concise format which will be easy for the judge to read. He or she will then have a summary of each of your positions prior to the hearing. Make sure to include the case caption and file number on the top of the motion. (party names, county, state, court division and file number).

If your ex is trying to modify custody and you are seeking to keep custody as is you do not need to file a counter motion, just a responsive motion denying his allegations and denying that any change has taken place which affects the children

I will have a hearing sometime at the end of January or first of February. I am waiting for calendar call on Friday.

I will be pro se. I would like to file a response to my ex’s motion to modify custody, visitation and child support. I know to address each point that he raised (all fabrications) and then can bring up on my own points. Does this have to be in an particular format or can I just write it with number bullets?

Can I file a counter-motion at the same time? I would like to request sole legal custody and modification to visitation. Do I lay out in this document the visitation schedule that I propose or do I wait until we have our hearing to tell the judge what I propose?

How do I make requests for discovery? Again, do I have to complete a specific form or put in a specific format? Can I simply write a letter to his attorney requesting what I need?