IN THE _____________ (DISTRICT/CIRCUIT) COURT OF ______________ (COUNTY), _________(STATE)

STATE OF_____________                            CASE NO.____________

VS.

_____________________

Motion to modify custody based on interference with Parental Rights and Alienation. ___________has deprived me of my rights of visitation for a substantial period of time(______) although I’m a fit and proper person to have visitation and custody. _______is committing an egregious act by attempting to create emotional distance between me and my child __________. Berlin v. Berlin, 239 Md. 52, 210 A. 2d 380 (1965) is a basis by which this motion should/could be granted. ___________has my child _________under threat if he/she contacts me. In order to “remedy the deteriorating relationship” it’s in my child’s best interest that I be awarded custody of my son/daughter__________(name of child). It’s in my child’s best interest due to the verbal, mental and spiritual, physical abuse inflicted on her daily. Grounds to award me custody can also be found in Walden v. Walden, 112 A.D. 2d 1035,492 N.Y.S. 2d 827 (1987), 492 N.Y.S.2d at 829.______________’s(custodial parents name) aggressive attempt to alienate my daughter by frustrating my rights concerning visitation is such a changed condition. Garrett v. Garrett, 464 S.W.2d 740,743 (Mo.[ct.]App.1971) established when a parent who has custody makes disrespectful and abusive statements against the other parent and attempts to wean the child away, the custody decree can properly be modified and custody changed. Case after case law has shown that if one parent speaks in a derogatory manner about the other parent and engages in other efforts to destroy the child’s relationship with the other parent, the other parent should be awarded custody. My child’s best interests and my visitation has been frustrated and _______________(custodial parent’s name) is engaging in an aggressive effort to alienate my child’s affections towards me. My child is suffering because he/she/they is unable to spend time with me. I am requesting a hearing on_________(custodial parent’s name) repeated denials and aggressive alienation which is causing emotional injury to my child_________(child’s name).

*This is not legal advice but can be used as a guidepost*