Pending changes to Tex. R. Civ. P. 194, as it pertains to family law cases, may render some items requested in this form inappropriate. Eliminate any items listed in this form that duplicate items covered in the request for disclosure in rule 194 when amended.
The cover sheet at form 5-41 should precede these and any other interrogatories.
Pattern Interrogatories—Conservatorship
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Select only as applicable. |
1.If any unrelated adult spent the night with you at any time since [date] while you were in possession of your child[ren], state—
a.the identity and location of each person and
b.the dates and locations of each such occurrence.
2.If you contend that it is not in the best interest of the child[ren] that [name[s]] be appointed [sole managing conservator/joint managing conservator/joint managing conservator with the exclusive right to designate the primary residence of the child[ren] [include if applicable: subject to a geographic restriction]], state in general the legal theories that support your contention and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
3.If you contend that it is in the best interest of the child[ren] that you be appointed [sole managing conservator/joint managing conservator/joint managing conservator with the exclusive right to designate the primary residence of the child[ren] [include if applicable: subject to a geographic restriction]], state in general the legal theories that support your contention and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
4.If you contend that it is in the best interest of the child[ren] that the primary residence of the child[ren] be subject to a geographic restriction, identify the geographic area to which the residence should be restricted and state in general the legal theories that support your contention and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
5.State what periods of possession and access each conservator should have and, in general, the legal theories that support your contention and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
6.If the court requires your periods of possession or access to be supervised, state your contention of how that supervised possession or access should be conducted (including the payment of the cost of any supervisor), state in general the legal theories and factual bases that support your contention, and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
7.If you contend the court should require your [former] spouse’s periods of possession or access to be supervised, state your contention of how that supervised possession or access should be conducted (including the payment of the cost of any supervisor), state in general the legal theories that support your contention, and identify facts of which you are specifically aware that establish, demonstrate, or prove that contention.
8.State each day you have exercised possession of or access to the child[ren] since [the filing of this suit/[date]] and the amount of time you spent with [the/each] child on each such day.
9.If the court orders you to pay child support, state the monthly amount of support the court should order you to pay, state the calculations you used to determine that amount, and identify facts of which you are specifically aware that establish, demonstrate, or prove your contention.
10.If the court orders [name] to pay child support, state the monthly amount of support the court should order [name] to pay, state the calculations you used to determine that amount, and identify facts of which you are specifically aware that establish, demonstrate, or prove your contention.
11.If you have dependent health or dental insurance coverage available to you, state how much it would or does cost you to cover the child[ren] the subject of this suit on that policy in addition to whatever you pay for health or dental insurance coverage for yourself and any other person.
12.State how the court should order that health and dental insurance coverage be provided for the child[ren] and identify facts of which you are specifically aware that establish, demonstrate, or prove your contention.
13.If the child[ren] exhibit[s] changes in demeanor or behavior immediately before or after the child[ren] [has/have] been in the possession of [name[s]], state—
a.the changes you have observed and
b.each date on which you have observed these changes.
14.Generally, what hours do you work and on which days of the week?
15.If there are any children not the subject of this suit for whom you owe a legal duty of support, for each child state the identity and location, birth date, Social Security number, and, if applicable, the court of continuing jurisdiction for that child.
16.If your child[ren] [has/have] any special medical, psychological, or educational needs that necessitate additional expenditures or will necessitate additional expenditures in the future, state—
a.the nature of each need;
b.to whom the expenditures will be made;
c.the amount of the expenditures required or to be required on an annual basis;
d.whether [the/any] child[ren] require[s] or will require substantial care and personal supervision because of a mental or physical disability and will not be capable of self-support; and
e.if [the/any] child[ren] require[s] or will require substantial care and personal supervision because of a mental or physical disability and will not be capable of self-support, the date on which the disability first existed or the cause of the disability was first known to exist.
17.If the child[ren] [is/are] involved in extracurricular activities, for each activity state—
a.the nature of the activity;
b.the average annual cost of the activity; and
c.the schedule of the activity.
18.If you contend that you have been denied possession of or access to the child[ren] since [date], for each period of possession or access identify facts of which you are specifically aware that establish, demonstrate, or prove your contention, including—
a.the date;
b.the circumstances of each denial; and
c.any reasons or excuses given for each denial.