D-202-DM-2014-02584

By on March 2, 2018

STATE OF NEW MEXICO
COUNTY OF BERNAILLO
SECOND JUDICIAL DISTRICT COURT
D-202-DM-2014-02584
CHELSEA BROWNING,
Petitioner,
vs. JOHN BROWNING
Respondent.
VERIFIED MOTION FOR PRETRIAL SCHEDULING CONFERENCE
AND TO ENFORCE OCTOBER 23, 2014 MINUTE ORDER
COMES NOW, Petitioner, Chelsea Browning, by and through her attorneys of record NEW MEXICO LEGAL GROUP, P.C. (Meredith A. Johnstone) and moves this Court for the scheduling of a Pretrial Scheduling Conference in this matter and its Order enforcing the Minute Order of October 23, 2014, and, in support thereof, states:
1. This Court has jurisdiction over the parties and the subject matter herein.
2. Petitioner and Respondent are the parents of one minor child, Wesley Benjamin Browning, born 2007, currently age 9.
3. A Petition for Dissolution of Marriage was filed in this matter on July 2, 2014.
4. A Minute Order was entered with this Court on October 23, 2014. Such Order sets forth that Respondent shall pay to Petitioner the amount of $291.00 per month beginning in November 2014 as interim support for Petitioner.
5. On April 29, 2015, this Court entered a Dismissal by Lack of Prosecution and the case was subsequently closed.
6. Petitioner now wishes to have the case reopened and requests that the Court set a Pretrial Scheduling Conference so as to move these matters to finalization and closure.
7. Respondent has not substantially complied with this Court’s Order regarding the payment of interim support to Petitioner in the amount of $291.00 per month as ordered on October 23, 2014.
8. The Dismissal by Lack of Prosecution entered by the Court states that all writs, judgments, final orders or stipulations remain in full force and effect.
9. The parties have remained physically separated since the October 23, 2014 order was entered by this Court with the exception of November and December 2016.
10. Petitioner has remained the primary custodian for the parties’ minor child and the minor child has had little to no contact with Respondent since May 2016.
WHEREFORE Petitioner asks this Court to set a Pretrial Scheduling Conference; to enter an Order enforcing the October 23, 2014 Minute Order; and for any further relief this Court deems proper and just.
Respectfully Submitted, NEW MEXICO LEGAL GROUP, P.C.
/s/ Meredith A. Johnstone Meredith A. Johnstone Attorney for Petitioner 2701 Arizona St. N.E. Albuquerque, NM 87110 (505) 843-7303
I hereby certify that a true copy of the foregoing pleading will be served upon opposing party, and that counsel for Petitioner will submit a Certificate of Service regarding same.
/s/ Meredith A. Johnstone
Meredith A. Johnstone
HCS Pub. March 2, 9, 16, 2018

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