How to file a motion if you don't have address?

BM is getting ready to move out of state about 800 miles away. She won't agree to a schedule of keeping the kids for spring break and the summer because she refuses any schedule that involves her paying child support. My FH plans to file a motion as soon as she leaves, but he's pretty sure she won't even tell him when she's leaving and she'll most likely refuse to give him her address.

What do you do in this case? The court requires you to send a certified copy of the motion to her, but how can he if he won't have the address? The courts in our state has been very lax and pretty much gives her every opportunity to duck and dodge hearings and child support.

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Why is he waiting until she

Why is he waiting until she leaves? He should file something now BEFORE she leaves, so that he can serve her at her last known address and to avoid future drama.

Additonally, if he files now he can get an order that requires her to provide her contact information with in a certain amount of time BEFORE moving, so that way she can't try to duck and dodge him. My SO has a clause like this in the current CO.

If he is adamant about filing after she moves, he can hire a company to do a "skip trace" on her to find her current address or to do a public records search.

There is service by publication too, but it gets a lot murkier and harder to do when you don't have someone's address, if they move out of your state, etc.

If it were me, I would file before she moves in anticipation of the move.

The court mediator told them

The court mediator told them last month that the court can't change the visitation or child support until she actually leaves, he'll need to file once she's actually moved.

Do they have a court order in

Do they have a court order in place? I know in DH's court order they are both required to keep a current address on file with the court. If they move they are to give a 30 day notice to the other parent & send a copy to the courthouse with the updated address.

If there's nothing like that in their order, I would suggest contacting a lawyer to find out what needs to happen. I wouldn't wait for her to leave to do something. I'd get a start on it ASAP. Take care of what you can before she leaves & you don't have any address for her.

"Do they have a court order

"Do they have a court order in place? I know in DH's court order they are both required to keep a current address on file with the court. If they move they are to give a 30 day notice to the other parent & send a copy to the courthouse with the updated address."

This is true too, that many states require parties to update when they have a change of address.

Yes, they have a court order

Yes, they have a court order in place. And the court has told her a million times to update her address, but she never does it and they never do anything about it.

Even if he ends up waiting

Even if he ends up waiting until after she moves, someone will be able to locate her...I'm sure. If you guys end up having to pay a lawyer or someone to track her down, when you do get her back to court, be sure you sue for those fees as well.

If she's been told to update her address & she doesn't & the judge knows that you guys have had to go through an ordeal to find her after she's been ordered to update, maybe they'll do something then. If not, at least you'll have an address for her. Just be sure to sue for the additional money you had to pay because of her lack of responsibility to update.