The father, relying on Opinion of the Clerk No. 21, 375 So.2d 1066 (Ala.1979), argues that the mother failed to properly institute her contempt action because she did not file her contempt action separately or pay a separate filing fee. Although it appears that the opinion the father relies upon supports his contention, as does Opinion of the Clerk No. 25, 381 So.2d 58, 59 (Ala.1980) (“The basic differences between contempt proceedings and proceedings to modify a final decree preclude the inclusion of a petition for rule nisi and a petition to modify in the same pleading.”), we note that both opinions predate the adoption of Rule 70A, Ala. R. Civ. P., which now governs contempt proceedings arising out of civil actions. See Ex parte Boykin, 656 So.2d 821, 827 n. 5 (Ala.Civ.App.1994) (<HOLDING>). Rule 70A expressly provides that contempt
recognizing that as of july 11 1994 contempt proceedings arising from civil actions are no longer governed by rule 333 ala rcrim p and instead are governed by rule 70a holding that constructively fraudulent transfers are governed by rule 8 holding that with respect to civil forfeiture actions property issues concerning ownership are governed by the laws of the state in which the property is located recognizing that it is an open question whether drpa is a federal agency governed by the apa or a state agency governed by state administrative law holding that the standard of review for the denial of rule 11 sanctions is governed by the law of the regional circuit