[Court Heading and Caption. Should include the court name, plaintiffs and defendants and case number. You can probably just copy the header of a court document they sent you.]

MOTION TO VACATE AND SET ASIDE ORDER
 
    

Comes now [name of petitioner], mother of [minor child], and moves the court to vacate and set aside its order removing [minor child] from the custody of movant, entered in the above-entitled matter on [date], on the following grounds: 
    

1. [Name of petitioner] is the natural [mother/father/parent] of [minor child] and is the proper person to have custody of the child.

2. On [date], this court entered its order declaring [minor child] a dependent and neglected child and terminating movant's right of custody.

3. Since the court's order of [date], movant's situation has changed, in that [set forth change of conditions relied on for vacation of order].

4. It is in the best interest of [minor child] that the child's custody be awarded to [his or her] natural mother.
 
    

This motion is based on the notice of motion heretofore filed and served and on all the pleadings, papers, records, and files in this action. 
    

Dated: _________.

[Signature and address]