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Include the following notice if this is a response to a petition, if a minor is named in the caption, or if the document contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents. |
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
[Caption. See § 3 of the Introduction in volume 1 of this manual.]
Response to [Petition/Motion] to Compel Arbitration
This Response to [Petition/Motion] to Compel Arbitration is brought by [name of respondent]. In support, [name] shows:
1.[The last three numbers of Respondent’s driver’s license number are [numbers]./ Respondent has not been issued a driver’s license.] [The last three numbers of Respondent’s Social Security number are [numbers]./Respondent has not been issued a Social Security number.]
2.Respondent objects to the assignment of this matter to an associate judge for a trial on the merits.
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Continue with the following. |
3.The [Premarital Agreement/Postnuptial Agreement] containing the agreement to arbitrate is not valid or enforceable because [state reasons].
4.It was necessary to secure the services of [name], a licensed attorney, to preserve and protect the rights of [name of respondent] [include if applicable: and preserve the best interests of the child[ren]]. [Name of petitioner or movant] should be ordered to pay reasonable attorney’s fees, expenses, and costs through trial, and a judgment should be rendered in favor of this attorney and against [name of petitioner or movant]; or, in the alternative, [name of respondent] requests that reasonable attorney’s fees, expenses, and costs through trial be taxed as costs and ordered paid directly to [name of respondent]’s attorney, who may enforce the order in the attorney’s own name.
Respondent prays that this Court deny the [Petition/Motion] to Compel Arbitration.
Respondent prays for recovery of attorney’s fees and costs of court.
Respondent prays for general relief.
[Name]
Attorney for Respondent
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
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]
Attorney for Respondent