Attorney Perry represents the petitioner wife in a divorce matter. It is apparent from her husband's conduct during the marriage that this is not going to be an easy split. During the pendency of the divorce, the court may approve necessary orders to protect custody and provide financial security for his client and her children. List what motions Attorney Perry should file and briefly describe the purpose(s) of each one.
What will be an ideal response?
Attorney Perry should file the following motions:
| • | Motion for alimony: The petitioner is a stay-at-home wife and mother with no independent |
| • | Motion for custody of minor children: She is better prepared to be their primary caretaker being at |
| • | Motion for child support: Both spouses have the obligation of child welfare. |
| • | Motion for visitation: Defendant spouse has a right to see his children during reasonably |
| • | Motion for exclusive possession of the martial home: It is the children's home and all community |
| • | Motion for use of motor vehicle: If both cars are titled in the defendant spouse's name, and she |
| • | Motion to pay mortgage and insurance premiums: Defendant spouse currently is making these |
| • | Motion to restrain entrance into the marital home: Defendant spouse has shown violent tendencies in |
| • | Motion to freeze martial assets: Defendant spouse may try to empty bank accounts or transfer title, |
Last but not least, a motion for attorney fees. But Attorney Perry knows that this is a long-shot. Courts usually will not rule on this motion until the final decree and may not grant it to his client depending on the final property distribution.
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