Discovery set: Request for Disclosure

Concerning discovery requests In Texas Family Law cases: What are Request for Disclosure(s)?

Discovery sets in Texas typically consist of Request for Disclosure, Interrogatories, Request for Production and Request for Admissions. Responses to Request for Disclosure’s are to be prepared and returned 30 day’s from the date it is received by your attorney. Typically in family law cases, a request for disclosure will first ask to state your correct name, and if there are any potential parties to the suit. More importantly, the request for disclosure will ask you to DISCLOSE the identity of person’s who have knowledge of relevant facts, their addresses and phone numbers. The request for disclosure will also ask you to DISCLOSE any expert’s you have retained and are expected to testify in your case. Prepare your responses to the request for disclosure in a timely manner and then send it to your client as quickly as possible to make sure they can meet the 30 day discovery deadline.

The trick to sharing information with your ex WITHOUT COMMUNICATING with them

The trick to sharing information with your ex WITHOUT COMMUNICATING with them

Interacting with an ex can become uncomfortable and the source of repeated conflict. Interaction, to a degree, becomes a necessity for parties to a divorce with children. I recommend that client’s sign up for Family Wizard, a computer software program that allows you to send/tract messages to your ex about the goings on of your children. Family Wizard also allows you to post important events/dates concerning your child. Posting information over the “cloud” minimizes your interaction and allows you to focus on the needs of your child. Family Wizard is now available as an app for all smart phones. Visit for more information.

How do you define “best interest” of the child in the State of Texas?

In Holly v. Adams the Texas Supreme Court listed factors that a court should consider in determining what is in the best interest of the child. The factors include: 1.The desires of the child, 2. The emotional and physical needs of the child now and in the future;
3. The emotional and physical danger to the child now and in the future, 4. The parental abilities of the individuals seeking custody, 5. the programs available to assist these individuals to promote the best interest of the child, 6. the plans for the child by these individuals or by the agency seeking custody, 7. the stability of the home or proposed placement, 8. the acts or omissions of the parent which may indicate that the existing parent-child relationship is not a proper one; and 9. any excuse for the acts or omissions of the parent. The list is not exhaustive. Remember that the court will want the custodial parent to respect their ex’s rights to interact with the child at issue. Matt Sossi