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this non-molestation order is about 16 pages long need any advice on how to prepare a defence so its half decent at least
what would be the best way to lay this out
2 ways of replying - either 16 page reply refuting every allegation or just quick 1.5 page summary saying denying all these allegations and stating your reasons for why she may be doing this. Eg using the kids due a messing contact and residence order etc....
some thing like this maybe
Childs mother has lied section one and I have enclosed proof of this marked document 1 with attached screen shots
Childs mother did have a affair screen shots of messages between them marked document 2 etc.
Make sure you pack as much evidence in to prove your being victimised by the ex and her lies/game playing.
You need to reference each page of evidence so that you can refer to it when in court as per the above suggestion.
Section 1.
1a. My statement.
Basically your chance to comment on her statement points – if she claims something you didn’t do then say it here.
E.g. Her statement Point A - Denied, Point B - Denied, Point C – See evidence 2.1.12 and 2.3.1
This way the judge can clearly see the points you’re making and defending quickly and its easier for you to recall when defending yourself.
Section 2. Evidence
2.1. Texts 1-100
2.2 Emails 1-20
2.3 Police notes 1-10
2.4. 3rd Party notes (e.g. witnesses to any claimed events)
Again any evidence you are relying on you will have to submit to court and the other party a week in advance of the hearing....i think minimum is 3 or 4 working days.
Section 2
I agree I started a relationship with ......................on 5th July 2008
Our son Liam .....................was born on 26/12/09
Section 3
.................was exchanging sexually explicit text messages and arranging to meet a married man named ............in a hotel
I have copies of these messages that show their intent
I also have had a phone conversation with Mr ...........in which mr towers conformed they started exchanging messages in May
...........also conformed Miss .............. sent explicit photos to him via what’s app and face book and also conformed they was going to meet in a hotel
I did not find out about this till 16th June
Miss........... claims she was not aloud to take the children to school
I took my step daughter Abby to school at ................school
Miss .............to our son Liam to his pre school nursery
The school and nursery is 30 minutes apart walking distance which is why we took one child each to there school. Never was there any time she was prevented from doing this.
............. claims she did not have her own bank card and was not aloud to go shopping
This is totally untrue as Miss ........... had her own bank card and I had mine we shared the benefit money to buy all the necessary items we needed for the house
Miss ......... went shopping on many occasions and also took money out of my bank for the items we needed
Miss ............also went to a bar called........every other Friday while I looked after the kids at home
how about this
Hello mate,
all fine, but stick with the main issue....why is she got the non-mol order in place?
Does she not want contact with you? If not why not?
How does she propose to facilitate the contact....
affairs, texts, OK - but need to get to the meat straight away! Page and half limit.
If you have an electronic or scanned copy of her order one of us could take a look.
BW
I have scanned the injunction in the computer but I cant edit out names case number etc. so not sure weather to put it on here but need as much help as possible
got layout format covered now thanks to everyone
just need to find what is important to prepare my case
she says she was scared when she had me arrested 2nd time
while I was on bail
she sent pictures to me
we had [censored] 3 times
meet her in pub one night and was kissing me
after bail
let me have my son stay with me for overnight stays 2 nights a week
does all this matter to show she aint scared and she is doing this to continue to abuse me and hurt me when she wants to
seeing my son and then it being stop start kills me inside
im going to fight all the battles she wants but her solicitor is going to wipe to floor with me
I do it so I can tell my son I cared and I never gave up on him
Whole point is she is trying to do this to build a case to prevent you seeing your kids.
If she has stopped contact she is trying to use the non mol order to stop you seeing you kids....i think...
Dont post any personal docs on here. You may need to pm, or Ill take guidance from the mods.....
last contact I had with her was 4 august when taking my son back she was shouting at me in front of my son
she took it out on 8 august
my dad dealt with her till last week about arrangements to be in writing so they can be made legally binding
I went to my sons school made sure I was on his paper work and I want to be involved in his schooling, plays, parents evening etc.
now she is accusing me through my dad, of telling the head teacher things I never said how stupid is that, this all made up in her mind
she has told so many lies and to be honest she is a bit crazy
I don't think I will ever get my son from her, but if she gets help from all the people that are going to talk to her, at least my son will be safer with her, its not a psychical thing but mental thing she has had mental health problems for ten years 29 now
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