ear Paralegal:

As you know, we have an unusual divorce case involving Jett Obeejebos and Harper Awezon and their precious family member, a dog named "Express." There has been a change in circumstance since the court ordered the couple's divorce. Harper's attorney, Mikael Ivengetti, won't be happy about the modification of decree you are being asked to prepare.

The following is what the court originally ordered in its judgment of the couple's divorce:

• Harper has full legal and physical custody of Express with visitation only on two weekends a month for Jett.
• Jett and Harper must pay individually for the food Express consumes whenever the dog is with either party.
• Jett and Harper must pay individually for any of Express's veterinary bills that result when Express is with either party.
• Jett and Harper must pay individually for Express's dog chef, Gigi Stephani, that portion of her salary whenever the dog is with either party.
• Spousal support has been waived, so you don't need to worry about this aspect.

Below are some of facts regarding a change in circumstances since the divorce judgment was made:

• Harper's boyfriend, with whom she now lives, refuses to feed Express if Harper is not at home.
• Express has been eating twice as much, as her last vet visit indicated that she is pregnant and going to have puppies! Her food cost has increased.
• Most of the veterinary bills have been paid by Jett as per the court order, as Express has only needed to go to the vet when she was with Jett. So far, Jett has paid over $650 in veterinary bills.
• Harper is traveling more and more with her AweMyPet business and is hardly ever home to care for Express.

Instructions

a modification of divorce decree for Jett Obeejebos with the following requests in mind:

• Full legal and physical custody of Express whereby Express will be able to reside in Settle, Washington, where Jett's new job is located. He feels he can give Express more attention than Harper, since she is so busy with her AweMyPet business as well as remaining as a financial advisor for some of her private clients. Further, Jett will have Express with him 24/7, as he is able to take her to work with him at his new job.
• Even though he is traveling, he has hired a live-in puppy sitter for when Express gives birth to her litter if he is flying at that time for his job.
• Supervised visitation rights to Express for Harper twice a month, for which Jett will fly Express to Harper as Express is able to travel. (Recall, Jett is only going to be 150 miles away from Harper in San Medina, California.)
• Jett would like pet support for Express to cover half of the cost of paying Chef Gigi's annual salary of $42,000 for her dog food preparation service. Also, as part of pet support, Jett would like half of the cost of Express's monthly dog food bill of $550 plus the additional cost of food while Express is pregnant and for up to 10 weeks after delivery of the puppies. Further, Jett wants half of the amount for Express's annual veterinary pet insurance of $600, along with half of the costs for any vet bills that may arise regardless of whom the dog is with at the time they are incurred. You may be creative in how you express this last request by Jett.

Previous facts that may assist you in preparing your motion for modification.

• Jett has a successful career as a private pilot and author making $145,000 per year.
• Harper's income has exceeded $1.2M in the 6 short months of the couple's marriage.
• Jett has accepted a job offer to be a private pilot for Phil Bates, a biotechnical genius who has found the secret to longevity in Seattle, Washington. His new salary will be $175,000 per year, and he will receive benefits that include a pension plan, short- and long-term disability, and medical and dental insurance for him and his family. Seattle, Washington, is about 150 miles away from San Medina, California. His new job allows him to take Express with him wherever he goes.

Do not forget your APA-formatted title page and APA-formatted reference page.

Use the motion for modification to a divorce decree in Chapter 19 at page 473 as a guideline for requesting modification of a divorce decree.

The sample modification to a divorce decree in your text is to be usedonlyas a guideline as it is an example of a modification in the State of Connecticut.You are preparing a modification of divorce decree using California law.

Additional Instructions

• Be sure to include the following portions of the decree based on California law: (1) Custody (physical and legal), visitation (parenting time), and all issues incidental and necessary; (2) property rights; (3) insurance provisions if any (health and life); (4) pet support; (5) spousal support; (6) which provisions of the decree survive and which terms merge; and (7) miscellaneous issues incidental and necessary to the decree. Of course, the standard caption and introductory paragraph and signature line for the judge should also be included.
• After you have reviewed, proofread, and corrected your assignment, please upload the assignment into the Unit 9 Dropbox. Remember, Chapter 19 of your textbook has a sample for this assignment.