Lorenzo Hammonds, the custodial father, filed a contempt petition alleging that Eden Parks violated a custody order concerning their child. At the contempt hearing, Parks orally sought a change of custody even though Georgia law required a separate action filed in the county where the legal custodian resided. The trial court nevertheless changed custody, ordered evaluations and financial disclosures, imposed child support and attorney fees, and later held Hammonds in contempt for not producing documents. The Georgia Court of Appeals held that OCGA § 19-9-23’s separate-action and venue requirements were mandatory and that a custody modification could not be raised as a response to contempt. Hammonds had objected and had not waived those requirements. The Court reversed the custody modification, the order denying Hammonds’s motion to set it aside, the document-production directive, and the related attorney-fee award. It affirmed an uncontested contempt ruling against Parks. Hammonds’s appeal from the incarceration contempt order was moot because he had already served the jail term, and his reimbursement request presented no enumerated trial-court error. The judgment was affirmed in part, reversed in part, and dismissed in part.