So, my associate in drafting a response to motion for enforcement wrote this “As written, because each of the 15 bases provides a conclusory statement without a detailed description of contemptible conduct in accordance with controlling authority, infra, BILLY BOB THORNTON is forced into the awkward position of embarrassment by having to discern the undiscernible. “
Two things must happen to make an order enforceable. First, the underlying order must set out specifically the what, when, where and how what someone was supposed to do or not do. Secondly, the Motion for Enforcement must also set out with specificity the what, when, where and how someone was supposed to do something but failed to do what they were supposed to do.
A Motion for Enforcement is quasi-criminal in nature. In that regard, the Motion itself is an indictment.