Father's contempt petition vs. mother's jurisdiction transfer request - response timing?

Question

I, the father, have filed a petition of contempt against the mother for arranging a psychological evaluation for our child without my consent, though we have joint legal custody. The mother has filed a petition to transfer the case to a new jurisdiction, as she and the child have moved to a different state per a 2020 relocation order. There is no hearing date set for her petition to transfer. The child spends significant time in the court's current jurisdiction where I reside, and there are no standing orders altering jurisdiction per state statute. Should I wait until the hearing for the Petition of Contempt is scheduled before submitting my Rule Returnable Response, or should I file the response before the April 7 deadline, given these circumstances?

Christina J. Corr · Answer

File your Answer before the deadline, assuming that Mother filed her petition to change venue in the current jurisdiction where you reside.  If she filed in the state she relocated to, consider filing preliminary objections or a motion to dismiss instead, but also before the deadline.

Patrick J Cooper · Answer

You should always file your response timely according to the rules of civil procedure. You will want to check to verify whether the prior relocation order specified whether issuing court retains jurisdiction or if it provides for a transfer to the new state of primary residence of the child. I definitely recommend that you retain a skilled local family law attorney, if you have not already, since matters of jurisdiction can be complicated. Further, if you object to the transfer, and have a valid basis for that objection, you need guidance as to how best to successfully oppose that transfer.

Q: Father's contempt petition vs. mother's jurisdiction transfer request - response timing?