STATE OF SOUTH CAROLINA	)	IN THE FAMILY COURT
)	JUDICIAL CIRCUIT
COUNTY OF	)
)
)	COMPLAINT
Plaintiff (Obligee)	)	Wage Withholding
)	(To Establish Judgment)
vs.	)
)
)
Defendant (Payor)	)	Docket No.

IN RE:
Employee (Obligor)
SSN: DOB:
PLAINTIFF COMPLAINING OF THE DEFENDANT ABOVE NAMED, respectfully alleges and shows unto this Court:

1.	That Plaintiff is the obligee of child support rights pursuant to the order of this court and that Defendant is the employer of the obligor of said child support and this Court has jurisdiction of the parties and the subject matter;

2.	That Defendant was notified by the Clerk of Court on (date) regarding the following requirements:

a.	to withhold the sum of $ per from the wages of the obligor; and

b.	to notify the clerk's office if health insurance is available to the obligor for the benefit of the child(ren) for whom child support is being withheld.

Pursuant to Section 63-17-1410 of the 1976 South Carolina Code of Laws as amended.

3.	That Defendant has failed and refused to comply with one or both of the following requirements of the Clerk's Notice to Withhold, pursuant to Section 63-17-1410 of the 1976 South Carolina Code of Laws as amended:

a.	to withhold the designated sum from the wages of the obligor; and/or

b.	to notify the clerk's office if health insurance is available to the obligor for the benefit of the child(ren) for whom child support is being withheld

4. That the Plaintiff believes that Defendant has willfully refused to comply with the Clerk's Notice to Withhold

a.	that a judgment should be entered and execution issued against the Defendant for the total amount that Defendant has willfully failed to withhold since the date of the notice to withhold

b.	that the defendant is subject to a civil fine not to exceed five hundred dollars which may be imposed by the court in its discretion.

WHEREFORE, have fully set forth its complaint, the Plaintiff prays:

a.	That a judgment be entered and execution issued against the Defendant in the total amount of child support that the Defendant willfully failed to withhold since the date of the notice to withhold; and,

b.	For such other and further relief as may be reasonable, just and proper.

Date: _______________________, 20___
Name of Plaintiff
___________________________, S.C.	By:

SCCA 444 (12/2009)

STATE OF SOUTH CAROLINA

Carolyn W Yon

2009-12-14

wclark

SCJD