Form 45-2

The respondent’s answer should be limited to a response to the matters set out in the petition. Claims for affirmative relief should not be included in the answer but should instead be set out in a counterpe­tition, which may be filed as a separate document or immediately following the answer in the same document. An answer to a counterpetition should be filed by the petitioner/counterrespondent. If the respondent contests personal jurisdiction, a special appearance must be filed before any other pleading. See form 3-14.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

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

Respondent’s Original Answer

[Name of respondent], Respondent, files this Original Answer to [title or description of pleading]. [Include the following if this is respondent’s initial pleading: [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.General Denial
TRCP 92

1.General Denial

Respondent enters a general denial.

2.Information about Child[ren]
§§ 152.209, 154.181(b), 154.1815(c)

2.Information about Child[ren]

Information required by section 152.209 of the Texas Family Code is provided in the affidavit attached as Exhibit [exhibit number/letter].

Information required by sections 154.181(b) and 154.1815(c) of the Texas Family Code is provided in the statement attached as Exhibit [exhibit number/letter].

3.Expedited Hearing
§ 153.707

3.Request for Expedited Hearing

Respondent requests that the Court grant an expedited hearing.

4.Request to Present Testimony by Electronic Means
§ 153.707(c)

4.Request to Present Testimony by Electronic Means

Respondent requests that the Court, after reasonable advance notice and for good cause shown, allow Respondent to present testimony and evidence by electronic means, including by teleconference or through the Internet.

5.Attorney’s Fees, Expenses, Costs, and Interest

5.Attorney’s Fees, Expenses, Costs, and Interest

It was necessary for Respondent to secure the services of [name of attor­ney], a licensed attorney, to preserve and protect the child[ren]’s rights. [Include if applicable: If the parties are unable to reach an agreement on all issues,] Petitioner should be ordered to pay reasonable attorney’s fees, expenses, and costs, and a judgment should be rendered in favor of this attor­ney and against Petitioner and be ordered paid directly to Respondent’s attor­ney, who may enforce the judgment in the attorney’s own name. Respondent requests postjudgment interest as allowed by law.

6.Prayer

6.Prayer

•Required

Respondent prays that Petitioner take nothing and that Respondent be granted all relief requested in this Original Answer.

•Attorney’s Fees, Expenses, Costs and Interest

Respondent also prays for attorney’s fees, expenses, costs, and interest as requested above.

•Required

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