MOTION TO MODIFY FINAL DECREE by txpovertylaw

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									                                       No.____________
IN THE MATTER OF                               §                 IN THE DISTRICT COURT OF
THE MARRIAGE OF                                §
______________                                 §
AND                                            §                     _____________, T E X A S
_______________                                §
                                                                _______TH
                                               §                            JUDICIAL DISTRICT



                     RESPONDENT’S AMENDED MOTION TO
            MODIFY, CHANGE OR REFORM FINAL DECREE OF DIVORCE


TO THE HONORABLE____________________

       Respondent ___________, moves this Court under the Texas Rules of Civil Procedure

306(a) & 329(b)(g), to Modify, Change or Reform the Agreed Final Decree of Divorce, hereafter

referred to as Final Decree, to include provisions which allocate responsibility for 50% of

medical expenses, incurred by the Respondent, after the termination of Health Insurance

coverage to each party as contained in the filed Proposed Final Decree of Divorce, hereafter

referred to as Proposed Decree.

                                                I.

                                   RESPONDENTS MOTION

In support of this motion, the Respondent contends:

       1.      After permanent separation, Petitioner canceled the Respondent’s Medical

               Insurance coverage during open enrollment in violation of the ___________

               Standing Order.

       2.      Respondent’s Insurance coverage terminated on _______ and on

               _______Respondent incurred $_________ in medical charges as a result of being

               uninsured. (Respondent’s Exhibit B)
                         
								
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