Thank you for your patience, and your additional information and clarification,
I would be very surprised if the Judge granted his Motion for the reasons I stated in my previous Answer - Family Court Judges do not want to favor one parent at the expense of the other parent because this would not reflect their ideal or their philosophy of promoting a relationship with both parents. If the Judge were to award the father what he is requesting, he would be doing so at your expense because you would barely have the children at all during their summer vacation.
In order to prevent this from happening, you must file a "Motion in Opposition to Plaintiff's Motion" as soon as possible so that the Judge will see it, read it, and take it into serious consideration when making his or her decision. By the Rules of Civil Procedure, anything which is not denied by a party, is deemed "Admitted". Therefore, if you do not file an Answer, the Judge will assume that you have no objection to the father's requests in his Motion, and include the reasons that I stated in my previous Answer, i.e., If this Honorable Court granted Plaintiff Father's Motion, such arrangement would be inequitable, unjust, and highly prejudicial to XXXXX's summer timeshare rights, and would effectively deprive her of these rights". You should include the Order of November, 2012 as Exhibit "A" and attach it to the back of your Answer in Opposition.
You might also want to include the fact that, "In providing the timeshare already Ordered by this Honorable Court, it was not its intention to bestow benefits on one parent at the expense of the other parent, yet this is exactly what Plaintiff is requesting of this Honorable Court."
In the "Wherefore" clause at the end, you would ask the Court for the following relief with words to the effect as follows,
"Wherefore, Defendant Your Name respectfully XXXXX XXXXX Honorable Court Deny Plaintiff's Motion, enter an Order setting forth the exact days to which Plaintiff shall exercise his rights to vacation timeshare with the aforesaid minor children, and to give such other and further relief as this Honorable Court may deem just and proper.
You should file the original of your Motion in Opposition in person and as soon as possible, and, if no hearing date has been set, ask the Court Clerk for an "Expedited Hearing Date" so that there will be no misunderstanding on the father's part and he will not have the opportunity to make believe he does not understand and come for the children sooner than he is supposed to.
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