How to Get an Order to Show Cause Over Denial of Visitation

My question involves a child custody case from the State of: New York


1. Original order was for roughly 50% custody; mom is residential
2. Mom has clearly alienated, and refuses visits
3. Have a Modification Petition pending
4. After 31 years, my attorney just up and quit practicing law
5. Until PD appointment, it's me and God doing this :)
6. Want to file Order to Show Cause in the meantime

Need help...

Case Law to suggest it's appropriate to file, demonstrate harm, etc...

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Quoting RickRock

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My question involves a child custody case from the State of: New York


1. Original order was for roughly 50% custody; mom is residential
2. Mom has clearly alienated, and refuses visits
3. Have a Modification Petition pending
4. After 31 years, my attorney just up and quit practicing law
5. Until PD appointment, it's me and God doing this :)
6. Want to file Order to Show Cause in the meantime

Need help...

Case Law to suggest it's appropriate to file, demonstrate harm, etc...

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I am truly sorry, but an internet forum really cannot do your legal research for you nor write your motions. However, when you have a motion for modification pending, generally any show cause issues should have been included with that motion for modification. Did you not include in your pending modification the problems associated with your parenting time? If so, it may not be appropriate to file a separate show cause for those same issues.

Explain how mom has "clearly" alienated the child(ren). That might get you some more advice. Also, how old are the children?

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Quoting RickRock

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5. Until PD appointment, it's me and God doing this :)

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Does NY provide public defenders for child custody cases?

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Quoting PayrolGuy

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Does NY provide public defenders for child custody cases?

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I believe they're the oddity, and do indeed if necessary.