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A motion for pendite lite is not used to stop the spouse from taking property or entering the home. You need a motion or praecipe for temporary possession of the home and contents, which is where you ask the court to grant you temporary possession of the marital home and to order that no property can be removed from the marital home until such time as the marital property division has been decided by settlement of the parties or the court.
As far as payment of bills a Motion for Pendite Lite can now be used under VA Code 20-103 to ask the court for an order to have your spouse pay any marital debts
or their share of marital debts that are due during the time the divorce
is pending in the court, which would include back income taxes as well.
You can file the Motion for Temporary Possession and Temporary Injunction to prevent removal on an emergency ex parte basis to prevent her entry and removal of contents of marital property which is causing you damage. This means you could file it now and explain you tried to contact opposing counsel and were not able to do so but damage is occurring in the removal of marital property and ask the court to issue an order giving you temporary possession plus an injunction against removal of any more property from the residence without mutual written agreement or court order.
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