How to File a Cross Motion in a Custody Case

My question involves a marriage in the state of: NJ

We have been divorced for a year but my ex refuses to move on with his life.

I just received a motion he filed to make changes to our mediated custody agreement. Although we have an attorney, I spoke with him on his way to the airport and he gave me information on how to file a cross motion but between his need to hurry and the noise over the phone I apparently missed some language. Hopefully I have enough that maybe someone here can help fill in the blanks.

The motion that was filed was ambiguous at best and my ex included numerous pages of texts and emails between us but in his motion never mentioned any of it so of course no one knows what or where in the pages is he referring.

My lawyer said the following:
Notice of motion does not relate any specific page to "missing word". He said something here but I am not sure what he said
Secondly Not accompanied by certificate of "missing word here"

He said these are procedural issues.

I know this is sketchy but if you can help I would greatly appreciate it.

Quote:

---

Quoting Diggar

---

My question involves a marriage in the state of: NJ

We have been divorced for a year but my ex refuses to move on with his life.

I just received a motion he filed to make changes to our mediated custody agreement. Although we have an attorney, I spoke with him on his way to the airport and he gave me information on how to file a cross motion but between his need to hurry and the noise over the phone I apparently missed some language. Hopefully I have enough that maybe someone here can help fill in the blanks.

The motion that was filed was ambiguous at best and my ex included numerous pages of texts and emails between us but in his motion never mentioned any of it so of course no one knows what or where in the pages is he referring.

My lawyer said the following:
Notice of motion does not relate any specific page to "missing word". He said something here but I am not sure what he said
Secondly Not accompanied by certificate of "missing word here"

He said these are procedural issues.

I know this is sketchy but if you can help I would greatly appreciate it.

---

I am sorry but there is not enough here to even begin.

What I can tell you is that your response should follow his motion in format and you should either agree or deny each of his items (with an explanation) and then include anything more you want included.

That is really vague as well but that is about the best you are going to get based on what you have said.

What I think your lawyer was trying to tell you is about the certification from the person with the knowledge of the facts that the motion is based on. Without that, there are no facts to consider.