Juvenile Court _Garfield__________________________________ County, ColoradoCourt Address:109 8
street suite 104 Glenwood springs ColoradoIn re:
The Marriage of:
Parental Responsibilities concerning:Petitioner: Jane smithandCo-Petitioner/Respondent: John smith
COURT USE ONLY
Attorney or Party Without Attorney (Name and Address):John SmithPhone Number: 555-555-5555 E-mail:FAX Number: Atty. Reg. #:Case Number:Division Courtroom
RESPONSE TO MOTION FOR: MODIFY PARENTING PLAN
I am the
Co-Petitioner/Respondent in this action. I am requesting that:Case be dismissed from this court of record for failure to state a claim upon which relieve can be granted.
My reasons are:
1) Claimant has failed to state a claim upon which relief can be granted. No justicable controversy has beenpresented into the court of record.2) No forseeable benefit can be derived from the proposed action at law. The claimant wishes to imposeunreasonable conditions on the defendant/counter-claimant with not reason for that force.3) The elements of a cause of action are clearly missing. The defendant cannot confirm or deny the existance of the elements as they have not been iledged. No facts have been established or eledged that could prove adamage or it's possible remedy.4) The existance of damages has not been proposed. Where no controversy exists in an adversarial court, theclaimant lacks standing, and the court is void of subject matter jurisdiction. Where jusrisdiction is lacking, the courthas no authority to act. All judgments shall be void
5) An existing lawful contract ruled by a duly sworn magistrate be prudent and in the best interest of the partiesinvolved is still in effect. No conditions in any of the parties lives, or statutes, ordinances or bylaws have changedin such a way as to affect the existing contract. No president changing appellate court rulings, or supreme courtsof either the State of Colorado, or The federal courts of the United States are known to have changed the waycontracts are considered valid, or reshape how courts affect family matters or property rights. Thedefendant/counter-claimant asserts his rights based on those grounds. The defendant/counter-claimant assertshis original jurisdiction over the matter at law.
JDF 1315 R7/00 RESPONSE TO MOTION FOR __________________________Page