Motion for Enforcement of [ Name of Order Violated ] by Contempt

1. This Motion is brought by [name], Plaintiff / Defendant / status in case.

Respondent to this Motion is [name of respondent].

2. Process should be served upon Respondent at: [address, city, state, zip code]].

(NOTE: Personal Service of Motion and Notice of Hearing must be personally served upon

Respondent for civil or criminal contempt).

order by contempt. An order directing a party to turn over bank records on April 30, 2020, is

NOT an enforceable order by contempt. An order commanding Party B to produce Bank of

America records for account number XXY for time period x/x/x thru y/y/y to Party A’s attorney

at the address of BBB on date such and such by time such and such IS enforceable by contempt.]

Movant was the [plaintiff/defendant] and Respondent was the [plaintiff/defendant] in the

prior proceedings.

4. Respondent [NAME] has failed to comply with the order described above as

follows: [Note SPECIFICALLY how respondent has failed to comply. Your Motion must give

fines and confinement in the Harris County Jail. Movant requests that at Respondent’s initial

appearance on this Motion that the Court read Respondent his legal rights and warnings, hold an

indigence hearing, if appropriate and requested, and appoint counsel, as appropriate.

6. Movant seeks an order directing Respondent to: [If you want the respondent to

have to do a certain act- or refrain from doing a certain act – list it specifically here]

6. Movant alleges that [describe performance that was expected of Respondent but

which believe is no longer available – such as delivery of property ] is no longer an adequate

remedy. Movant requests judgment for $[amount] to compensate Movant for the loss of

Court’s previous order and requests that Respondent be held in civil contempt confined in the

Harris County jail until Respondent complies with the order of the Court, but no longer than ( )

months. Alternatively, Movant requests that Respondent be held in civil contempt and

commitment be deferred to a date certain but no later than [give date] and Respondent be given

specific orders to [list actions to be performed] before [list date] and Respondent be sworn to re-

appear in Court on [give date] to determine if Respondent has complied and if Respondent

should or should not be committed to the Harris County jail to be confined there until

Respondent complies with the Order of this Court.

8. Movant alleges that Respondent had the past ability to comply with this Court’s

orders and that an appropriate remedy for Respondent’s willful noncompliance is criminal

9. Movant requests that, if the Court finds that any part of the order sought to be

enforced is not specific enough to be enforced by contempt, the Court enter a clarifying order

more clearly specifying the duties imposed on Respondent and giving Respondent a reasonable

time within which to comply.

10. It was necessary to secure the services of [name of attorney], a licensed attorney,

to enforce and protect the rights of [name of Movant]. Respondent should be ordered to pay

reasonable attorney’s fees, expenses, and costs, and a judgment should be rendered in favor of

the attorney and against Respondent; or, in the alternative, reasonable attorney’s fees, expenses,

and costs should be taxed as costs and should be ordered paid directly to the undersigned

attorney, who may enforce the order in the attorney’s own name. Movant requests postjudgment

held in contempt and punished as requested, that the Court clarify any part of its prior order

found not to be specific enough to be enforced by contempt, [include if applicable: for a

judgment for $[amount],] for attorney’s fees, expenses, costs, and interest, and for all further

relief authorized by law.

___________________________________

[Name]

[Address]

[Telephone]

[Telecopier]