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Chapter 13

Form 13-9

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents.

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

[Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney]’s Original Answer in Suit Affecting the Parent-Child Relationship

This original answer is filed by [name], who is [Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney] for the child[ren], [name[s] of child[ren]].

1.Answer

[Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney] enters a general denial.

2.Best Interest of Child[ren]

[Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney] requests that the following factors be considered in determining the best interest of the child[ren], [name[s] of child[ren]]:

the desires of the child;

the emotional and physical needs of the child now and in the future;

any emotional and physical danger to the child now and in the future;

the parenting ability of each person seeking managing conservatorship of the child;

the programs available to assist each person seeking managing conservatorship of the child in promoting the best interest of the child;

the plans for the child of each person seeking managing conservatorship of the child;

the stability of the home of each person seeking managing conservatorship of the child;

the acts or omissions of each person seeking managing conservatorship of the child; and

any excuse for the acts or omissions of each person seeking managing conservatorship of the child.

3.Fees and Expenses for [Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney]

It was necessary to render services to represent the child[ren] in this suit. The parties should be ordered to pay reasonable fees and expenses [include if applicable: as costs, for all fees attributable to the prosecution of a claim for child support], and judgment should be ren­dered against the parties in favor of [Guardian Ad Litem/Attorney Ad Litem/Amicus Attor­ney].

[Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney] prays that all factors requested above be considered. [Guardian Ad Litem/Attorney Ad Litem/Amicus Attorney] requests a judgment for reasonable fees and expenses.

   
[Name]
[Guardian Ad Litem/Attorney Ad Litem/
            Amicus Attorney] for [name[s]]
State Bar No.: [if applicable]
[E-mail address]
[Address]
[Telephone]
[Fax]

If the court-appointed representative employs counsel, plead separately for attorney’s fees.

Certificate of Service

I certify that a true copy of this [document/[title of document]] was served in accor­dance with rule 21a of the Texas Rules of Civil Procedure on the following on [date]:

[Name of attorney of record or party to be served] by [electronic filing manager/e-mail at [e-mail address]/fax at [fax number]/personal delivery at [address]/commercial delivery service at [address]/certified mail at [address]/first-class mail at [address]]. [Repeat for each attorney of record or party to be served.]

   
[Name]
[Guardian Ad Litem/Attorney Ad Litem/
            Amicus Attorney] for [name[s]]