Legal Writing Graded Project 2 - Petitioner

Legal Writing Graded Project 2 - Petitioner

IN RE THE MARRIAGE OF
SALLY BRIGHT PETITIONER
V. MEMORANDUM
JOHN BRIGHT RESPONDENT
Comes Petitioner, by counsel, and for her Memorandum states as follows:
    I. FACTS
  Sally Bright (Petitioner), filed for divorce and custody of 14 year old daughter, Chastity.   John Bright (Respondent) also requested custody. The court ordered temporary custody of the minor child to Petitioner and visitation with Respondent every weekend. Petitioner will be moving to another part of the country to take a job.
  Respondent has realized he is gay and has met a male companion who doesn’t reside with him presently, but someday might. Chastity testified that she feels weird around Respondent’s male companion. Psychologist, Dr. Samuel Stoller, testified that Chastity would prefer to stay in the area so she can be with her friends as she moves into high school as she has been having problems in school since the divorce. Psychologist, Dr. Frank Edwards, testified that Chastity has stated she feels uncomfortable around her father’s new companion.
  Respondent has, on several occasions, physically abused Petitioner, but not in front of Chastity and has never abused Chastity. Both parents have been actively, and almost equally, involved in day-to-day care of Chastity throughout her life.
II. SHOULD PETITIONER RETAIN CUSTODY OF 14 YEAR OLD DAUGHTER?
    A. PETITIONER MOVING TO ANOTHER PART OF THE COUNTRY
      Petitioner will be moving to take a job in another part of the country. She is seeking to relocate with Chastity out of the state of Nevada to live with her.
      NRS 125C.200 states as follows:
   If custody has been established and the custodial parent intends to move his or her residence to a place outside of this State and to take the child with him or her, the custodial parent must, as soon as possible and before the planned move, attempt to obtain the written consent of the noncustodial parent to move the child from this State. If the...

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