Q: I had a 3-month return date for a pro se motion I filed in family. I amended it once and need to again. Is that doable?
The first time my ex-wife did something after I filed that needed to be addressed and I left off one Exhibit by accident. Now she has done something serious again and I want to amend once more. How do I write that?
I put in the word 'amended' on the Notice page etc. the first time. What would I write this time?
A: Either put 2nd amendment on the pleading page and recirculate it to the court and to your ex or make life easy and file a new application with all of the corrections -so that it is clean and clear for the court and so that there is a greater likelihood that the court will have the correct version in front of him on the return date.
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A: You are emotionally involved in this case and you are not a trained attorney. So instead of risking not obtaining the desired results, you need to retain an experienced matrimonial attorney. You are at a major disadvantage since you do not know the Court Rules, Rules of Evidence, procedural rules, and customs.
A: Thank you for your question. What you can do is file a Reply Certification after the wife files her opposition to your motion. This way you can advise the court of her recent acts. The good thing about the Reply Certification is that the other party is not allowed to file a response to it. So hold off until she files her opposition and then file a reply. I hope this was helpful to you.
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