1129327 Motion to Modify Parenting Time

Motion to Modify

Publish August 11, 18, 25, 2010

NOTICE OF MOTION AND

MOTION TO MODIFY

PARENTING TIME

STATE OF MINNESOTA

COUNTY OF OTTER TAIL

IN DISTRICT COURT

SEVENTH JUDICIAL DISTRICT

FAMILY DIVISION

COURT FILE NO. 56-FA-07-2571

Hon. Barbara Hanson

In Re the Custody of:

K.E.H., D.O.B. 12/28/04

Jordan R. Hanson,

Petitioner,

And

Holly N. Hoppe,

Respondent.

TO: Petitioner Jordan R. Hanson

NOTICE OF MOTION

PLEASE TAKE NOTICE that on the 13th day of September, 2010, at 9:30 a.m., at the Otter Tail County Courthouse, 121 West Junius Avenue, City of Fergus Falls, County of Otter Tail, State of Minnesota, before the Honorable Barbara Hanson, Judge of District Court, Respondent Holly N. Hoppe, shall request the following relief:

MOTION

1. Amending Order dated and filed February 27, 2008, to award Petitioner supervised parenting time until such time as Petitioner can establish that a) he has a place to live that is safe for his daughter K.E.H.; b) he can maintain sobriety; and c) he completes a mental health evaluation and is following any and all recommendations.

2. In the alternative, modifying the parenting time schedule to take into consideration the minor child will be starting school in Mankato.

3. Ordering that such supervised parenting time take place in Mankato or, once Petitioner has a residence, at a half-way point between the parties’ residences.

4. For such other relief as the Court deems just and equitable on the premises.

ALL RESPONSIVE PLEADINGS SHALL BE SERVED AND MAILED TO OR FILED WITH THE COURT ADMINISTRATOR NO LATER THAN FIVE (5) DAYS PRIOR TO THE SCHEDULED HEARING. THE COURT MAY, IN ITS DISCRETION, DISREGARD ANY RESPONSIVE PLEADINGS SERVED OR FILED WITH COURT ADMINISTRATOR LESS THAN FIVE (5) DAYS PRIOR TO SUCH HEARING IN RULING ON THE MOTION OR MATTER IN QUESTION.

Dated: August 6, 2010

Respectfully submitted,

TILLITT MCCARTEN JOHNSON

& HASEMAN LTD

By /s/ Michelle L. Clark (#293556)

Attorneys for Respondent

801 Broadway, P.O. Box 188

Alexandria, MN 56308

(320) 762-8171

ACKNOWLEDGMENT

The above signed hereby acknowledges that costs, disbursements, and reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. § 549.211 to the party against whom the allegations in this pleading are asserted.

1129327

Tags: motion to modify parenting time, jordan hanson, holly hoppe, legals