Motion to Modify
Publish August 11, 18, 25, 2010
NOTICE OF MOTION AND
MOTION TO MODIFY
STATE OF MINNESOTA
COUNTY OF OTTER TAIL
IN DISTRICT COURT
SEVENTH JUDICIAL DISTRICT
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,
Holly N. Hoppe,
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:
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
TILLITT MCCARTEN JOHNSON
& HASEMAN LTD
By /s/ Michelle L. Clark (#293556)
Attorneys for Respondent
801 Broadway, P.O. Box 188
Alexandria, MN 56308
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.