Form 36-23

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

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

Response to Petition for Enforcement of Child Custody Determination

[Name of respondent], Respondent, submits to the Court this response to the Petition for Enforcement of Child Custody Determination filed in this cause by [name of petitioner], Petitioner. [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.]

1.Respondent enters a general denial.

2.The child custody determination has not been registered and confirmed in accor­dance with section 152.305 of the Texas Family Code, and the issuing court did not have jurisdiction under subchapter C of chapter 152 of the Texas Family Code.

2.The child custody determination has not been registered and confirmed in accor­dance with section 152.305 of the Texas Family Code, and the child custody determination for which enforcement is sought has been vacated, stayed, or modified by a court of a state having jurisdiction to do so under subchapter C of chapter 152 of the Texas Family Code.

2.The child custody determination has not been registered and confirmed in accor­dance with section 152.305 of the Texas Family Code, and Respondent was entitled to notice, but notice was not given in accordance with the standards of section 152.108 of the Texas Family Code in the proceedings before the court that issued the order for which enforcement is sought.

2.The child custody determination for which enforcement is sought was registered and confirmed under section 152.305 of the Texas Family Code but has been [vacated/stayed/modified] by the [designation of court] in [state] in [cause number] on [date], that state hav­ing jurisdiction to do so under subchapter C of chapter 152 of the Texas Family Code.

2.This Court has temporary emergency jurisdiction to protect the child because the child, or a sibling or parent of the child, is subjected to or threatened with mistreatment or abuse.

3.It was necessary to secure the services of [name of attorney], a licensed attorney, to preserve and protect the rights of the child[ren]. Petitioner should be ordered to pay a rea­sonable attorney’s fee, and a judgment should be rendered in favor of this attorney and against Petitioner.

Respondent prays that this Court deny the Petition for Enforcement of Child Custody Determination.

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