On December 31, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Rhodes, Sandra Jean,
and
Rhodes, Adam,
for Divorce with Children
in the District Court of Montgomery County.
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Received and E-Filed for Record
7/8/2014 3:25:07 PM
Barbara Gladden Adamick
District Clerk
Montgomery County, Texas
NO. 13-12-13831-CV
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
SANDRA JEAN RHODES §
AND § 418th JUDICIAL DISTRICT
ADAM RHODES §
§
AND IN THE INTEREST OF §
ADAM PAUL RHODES AND § MONTGOMERY COUNTY, TEXAS
CHRISTIAN RHODES, CHILDREN §
MOTION TO ENFORCE MEDIATED SETTLEMENT AGREEMENT
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, SANDRA JEAN RHODES, Petitioner and filed this Motion to Enforce
Mediated Settlement Agreement and would dhow:
1. On or about February 28, 2014, the parties entered into a Mediated Settlement
Agreement. A true copy of the MSA has been filed with the Court and is attached hereto
and incorporated by reference.
2. This MSA provides that “H shall pay Wchild support in the anount of $1800.00 due on
April 1, 2014 and continuing on the 1st day of each month thereafter until further order of
the Court:” As of the filing of this Motion, Respondent has failed to pay the agreed child
support.
3. This MSA further provides that “H shall pay W spousal support in the amount of $800.00
due on March 15, 2014.” Respondent has failed and refused to pay the agreed spousal
support.
4. This MSA further provides shall pay W spousal support in the amount of $600.00 due on
April 1, 2014 and continuing on the 1st day of each month thereafter until further order of
the court.” Respondent has failed and refused to pay the agreed spousal support.
5. This MSA further provides that “H’s bonus (expected March 2014) Within three days of
receiving such bonus, H shall give to W a copy of the paystub and ½ of the net bonus
received " Respondent has failed and refused to comply with the agreed terms.
Petitioner requests that, upon notice and hearing, that the Court enter judgment in her
favor and against Respondent for all amounts due and owing under the Mediated
Settlement Agreement.
6. Petitioner also requests that the Court award reasonable attorney’s fees for the
preparation and hearing of this Motion to Enforce Mediated Settlement Agreement.
Petitioner prays the Court grant this Motion to Enforce Mediated Settlement Agreement/
Petitioner prays for general relief.
Respectfully submitted,
_________________________
James R. Jones
Texas Bar Number 10911450
4185 Technology Forest Blvd., Suite 160
The Woodlands, Texas 77381
(281) 466-1951 Telephone
(210) 547-7846 Telecopier
email lawman77380@gmail.com
Attorney for Petitioner
CERTIFICATE OF SERVICE
I certify that copies of the attached document were served on all counsel and pro se
parties of record on July 8, 2014 pursuant to the Texas Rules of Civil Procedure.
_________________________
James R. Jones
Document Filed Date
July 08, 2014
Case Filing Date
December 31, 2013
Category
Divorce with Children
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Received and E-Filed for Record 7/8/2014 3:25:07 PM Barbara Gladden Adamick District Clerk Montgomery County, Texas NO. 13-12-13831-CV IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § SANDRA JEAN RHODES § AND § 418th JUDICIAL DISTRICT ADAM RHODES § § AND IN THE INTEREST OF § ADAM PAUL RHODES AND § MONTGOMERY COUNTY, TEXAS CHRISTIAN RHODES, CHILDREN § MOTION TO ENFORCE MEDIATED SETTLEMENT AGREEMENT TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, SANDRA JEAN RHODES, Petitioner and filed this Motion to Enforce Mediated Settlement Agreement and would dhow: 1. On or about February 28, 2014, the parties entered into a Mediated Settlement Agreement. A true copy of the MSA has been filed with the Court and is attached hereto and incorporated by reference. 2. This MSA provides that “H shall pay Wchild support in the anount of $1800.00 due on April 1, 2014 and continuing on the 1st day of each month thereafter until further order of the Court:” As of the filing of this Motion, Respondent has failed to pay the agreed child support. 3. This MSA further provides that “H shall pay W spousal support in the amount of $800.00 due on March 15, 2014.” Respondent has failed and refused to pay the agreed spousal support. 4. This MSA further provides shall pay W spousal support in the amount of $600.00 due on April 1, 2014 and continuing on the 1st day of each month thereafter until further order of the court.” Respondent has failed and refused to pay the agreed spousal support. 5. This MSA further provides that “H’s bonus (expected March 2014) Within three days of receiving such bonus, H shall give to W a copy of the paystub and ½ of the net bonus received " Respondent has failed and refused to comply with the agreed terms. Petitioner requests that, upon notice and hearing, that the Court enter judgment in her favor and against Respondent for all amounts due and owing under the Mediated Settlement Agreement. 6. Petitioner also requests that the Court award reasonable attorney’s fees for the preparation and hearing of this Motion to Enforce Mediated Settlement Agreement. Petitioner prays the Court grant this Motion to Enforce Mediated Settlement Agreement/ Petitioner prays for general relief. Respectfully submitted, _________________________ James R. Jones Texas Bar Number 10911450 4185 Technology Forest Blvd., Suite 160 The Woodlands, Texas 77381 (281) 466-1951 Telephone (210) 547-7846 Telecopier email lawman77380@gmail.com Attorney for Petitioner CERTIFICATE OF SERVICE I certify that copies of the attached document were served on all counsel and pro se parties of record on July 8, 2014 pursuant to the Texas Rules of Civil Procedure. _________________________ James R. Jones