Below is a list of motions Attorney Grew regularly files on behalf of his clients in divorce and child-related litigation.

  • Motion to Appoint a Gardian Ad Litem

  • Motion

  • Document List

    Complaints and Court Forms

    Adoption Surrender
    Affidavit of Denial of Paternity
    Affidavit of Irretrievable Breakdown
    Affidavit of Irretrievable Breakdown (Joint)
    Affidavit of Irretrievable Breakdown (Same Sex)
    Complaint for Annulment
    Complaint for Contempt
    Complaint for Custody - Next Friend
    Complaint for Custody - Parent
    Complaint for Divorce 
    Complaint for Modification
    Complaint for Separate Support
    Complaint for Support - Custody - Visitation
    Complaint to Establish Paternity
    Defendant's Answer to Complaint for Contempt
    Defendant's Answer to Complaint for Divorce
    Defendant's Answer to Complaint for Modification
    Joint Petition for Divorce (Sec. 1A)
    Joint Petition for Modification of Child Support Judgment
    Marriage of Minors
    Marriage without Delay
    Military Affidavit
    Mittimus for Contempt
    Motion to Waive Participation in the Parent Education Program
    Petition for Adoption
    Petition for Grandparent(s) Visitation
    Petition for Guardianship of Minor
    Correspondence - General

    Financial Forms

    Asset Division Schedule
    Child Support Guidelines Worksheet
    Rule 401 Long Form
    Rule 401 Short Form

    Motions

    Defendant's Motion to Dismiss Complaint for Divorce
    Defendant's Motion to Dismiss Complaint to Establish Paternity
    Motion for Appointment of an Expert
    Motion for Appointment of Master to Monitor Discovery
    Motion for Continuance
    Motion for Genetic Marker Tests
    Motion for Issuance of Bench Warrant
    Motion for Leave to Take A Limited Deposition (with Children)
    Motion for Leave to Take A Limited Deposition (without Children)
    Motion for Mental Examination Under Rule 35
    Motion for Partial Dissolution of Restraining Order
    Motion for Protective Order - General
    Motion for Reconsideration of Judgment
    Motion for Reconsideration of Judgment (with Request for Hearing)
    Motion for Reconsideration of Order
    Motion for Relief from Judgment
    Motion for Relief from Judgment (with Request for Hearing)
    Motion for Relief from Order
    Motion for Relief from Order (with Request for Hearing)
    Motion for Restraining Order
    Motion for Restraining Order Against Unrelated Third Parties
    Motion for Sanctions Under Rule 37
    Motion for Short Order of Notice on Contempt
    Motion for Short Order of Notice on Motion
    Motion for Summary Judgment
    Motion for Temporary Order of Support
    Motion for Temporary Order to Prohibit Transfer of Property
    Motion for Temporary Orders (with Children)
    Motion for Temporary Orders (Without Children)
    Motion for Trustee Process
    Motion for Wage Assignment
    Motion for Waiver of Notice to Department of Social Services
    Motion for Writ Ne Exeat
    Motion for Writ of Habeas Corpus
    Motion in Limine
    Motion in Objection to Request for Trial
    Motion of Chapter 7 Trustee to Intervene
    Motion to Advance Trial Date
    Motion to Amend Complaint for Divorce
    Motion to Amend Complaint for Divorce (1B to 1A)
    Motion to Amend Complaint for Divorce Pursuant to M. G. L. Chapter 208, Sec. 1A
    Motion to Amend Conclusions of Law
    Motion to Amend Conclusions of Law (with Request for Hearing)
    Motion to Amend Findings of Fact
    Motion to Amend Findings of Fact (with Request for Hearing)
    Motion to Amend Judgment
    Motion to Amend Judgment (with Request for Hearing)
    Motion to Appoint Attorney for Minor Child(ren)
    Motion to Appoint Guardian Ad Litem
    Motion to Appoint Stenographer
    Motion to Approve QDRO
    Motion to Attach Personal Property
    Motion to Attach Personal Property (Ex Parte)
    Motion to Attach Real Estate
    Motion to Attach Real Estate (Ex Parte)
    Motion to Compel Answers to Interrogatories & for Fees
    Motion to Compel Completion of Parent Education Program
    Motion to Compel Filing of Financial Statement & for Fees
    Motion to Compel Production of Documents & for Fees
    Motion to Compel Psychiatric Examination
    Motion to Compel Sale of Marital Home
    Motion to Disqualify Opposing Counsel for Conflict of Interest
    Motion to Dissolve Ex Parte Real Estate Attachment
    Motion to Exclude Tax Returns from Evidence
    Motion to File Marriage Certificate Late
    Motion to File More than Thirty Interrogatories
    Motion to Impound
    Motion to Maintain Life Insurance (with Children)
    Motion to Maintain Life Insurance (without Children)
    Motion to Maintain Medical Insurance (with Children)
    Motion to Maintain Medical Insurance (without Children)
    Motion to Modify Order of Temporary Custody
    Motion to Permit Inspection of Real Estate
    Motion to Remove Minor Child(ren) from the Commonwealth
    Motion to Remove Personal Property from the Marital Home
    Motion to Restrain Removal of Minor Child(ren) from the Commonwealth
    Motion to Resume Former Name
    Motion to Resume Maiden Name
    Motion to Schedule Case Management Conference
    Motion to Set Discovery Schedule and to Establish Pre-Trial Conference
    Motion to Strike Affidavit
    Motion to Strike Portion of Pre-Trial Memorandum
    Motion to Vacate Marital Home
    Motion to Waive Appearance of Party (with Affidavit)
    Motion to Waive Attendance of Parent Education Program
    Motion to Waive Participation in the Parent Education Program (CJ-D Form)
    Motion to Withdraw as Counsel
    Second Motion to Compel Production of Documents
    Statement of Attempt by Attorney to Resolve Discovery Dispute
    Stipulation of Dismissal
    Stipulation of Parties Re Support
    Temporary Order on Agreement of Parties
    Witness' Motion to Quash Subpoena

    Pre-Trial Memorandum

    Pre-Trial Memorandum

    Separation Agreements

    Separation Agreement (Husband-Wife with Children)
    Separation Agreement (Husband-Wife without Children)
    Separation Agreement (Same Sex - Female with Children)
    Separation Agreement (Same Sex - Female without Children)
    Separation Agreement (Same Sex - Male with Children)
    Separation Agreement (Same Sex - Male without Children)
    Separation Agreement Addendum - Bankruptcy (with Children)
    Separation Agreement Addendum - Bankruptcy (without Children)
    Separation Agreement Addendum - Businesses, Copyrights, Trademarks
    Separation Agreement Addendum - Change of Name
    Separation Agreement Addendum - Education and Other Expenses
    Separation Agreement Addendum - Effect of Agreement
    Separation Agreement Addendum - General
    Separation Agreement Addendum - Health Insurance (with Children)
    Separation Agreement Addendum - Health Insurance (without Children)
    Separation Agreement Addendum - Inheritances
    Separation Agreement Addendum - Life Insurance and Death Benefits
    Separation Agreement Addendum - Marital Debt
    Separation Agreement Addendum - Pension Plans
    Separation Agreement Addendum - Personal Property
    Separation Agreement Addendum - Real Estate
    Separation Agreement Addendum - Taxes (with Children)
    Separation Agreement Addendum - Taxes (without Children)

    Subpoenas

    Deposition - Notice of Taking & Certificate of Service
    Deposition Subpoena
    Deposition Subpoena Duces Tecum
    Trial Subpoena
    Trial Subpoena Duces Tecum

    Tools

    Caption
    Certificate of Service & Notice of Hearing - General
    Certificate of Service - General
    Closing

     

  • Motion for Allowance (alimony, spousal support)
    Motion for Legal Fees
    Motion for Continuance (delay of a hearing or trial)
    Motion for Mental Examination
    Motion for Protective Order (restraining order)
    Motion for Partial Dissolution of Restraining Order
    Motion for Sanctions (Under Rule 37)
    Motion for Short Order of Notice
    Motion for Expedited Hearing
    Motion for Temporary Orders
    Motion to Vacate the Marital Home
    Motion for Drug Test (hair follicle or urine)
    Motion for Random Testing (drugs or alcohol)
    Motion for Appointment of an Expert
    Motion for Appointment of Discovery or Real Estate Master
    Motion for Trustee Process
    Motion to Appoint Guardian Ad Litem
    Motion to Approve QDRO
    Motion to Attach Real Estate
    Motion to Compel Sale of Real Estate
    Motion to Compel (compliance with discovery requests)
    Motion to Impound
    Motion to Maintain Insurance
    Motion to Modify Temporary Orders (restrict overnight visitors in front of children, etc.)
    Motion for (Opposing Party) to Participate in the Job Search Program
    Motion to Remove Personal Property From the Home
    Motion to Restrain Removal of Children from the Commonwealth
    Motion for Alternative Service

     

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