The mother has obviously filed the motion but the possibility of money collection is irrelevant to her, the ultimate goal is the adoption of the child to exclude the possibility of the biological father ever reappearing in the child's life.  Failure to pay child support is not good enough here either but how are the grounds of not being there for the child? The mother has already retained the best attorney in the area who tells her it is possible but I am interested to know if the attorney is making it appear simpler (and less expensive) than the process actually will turn out to be?