Form 56-11

This motion is intended to be filed in an existing suit.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

Motion Regarding Possession and Transfer of Child[ren]’s Passport[s]

This Motion Regarding Possession and Transfer of Child[ren]’s Passport[s] is brought by [name of movant], Movant, who shows in support:

1.Movant is [the sole managing conservator/a possessory conservator/a joint manag­ing conservator/[state other relationship]] of the child[ren]. Respondent, [name of respon­dent], is [the sole managing conservator/a possessory conservator/a joint managing conservator/[state other relationship]] of the child[ren]. The child[ren] the subject of this suit [is/are] [name[s] of child[ren]].

2.The government of [the United States of America/[name of other nation that issued the passport[s]]] issued [a] passport[s] to the child[ren], which at the time of this motion [is/are] still valid. Movant and Respondent are not able to agree on which party shall have possession of the passport[s] when the child[ren] [is/are] not traveling, and they are not able to agree when each party should be entitled to use the passport[s] for international travel.

3.Movant asks the Court—

a.to award Movant possession of the passport[s];

b.to order Respondent to transfer possession of the passport[s] to Movant by a date certain;

c.to make orders stating the circumstances under which Respondent is entitled to temporary possession of the passport[s];

d.to make orders requiring each party to provide prior, written notice to the other party if a party intends for the child[ren] to travel outside the United States of America during a party’s period of possession of the child[ren]; and

e.to require each party to execute, have notarized, and deliver to the other party all forms needed for intended international travel of the child[ren].

[Name of movant] prays that the Court grant the Motion Regarding Possession and Transfer of Child[ren]’s Passport[s].

   
[Name]
Attorney for [name of movant]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]