Form 5-47

Use the interrogatories in form 5-45 as appropriate. 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—Modification of Conservatorship

1.For each person whose circumstances you allege have materially and substantially changed since the [rendition of the order to be modified/signing of the [mediated/collabora­tive law] settlement agreement on which the order to be modified is based]:

a.state the identity and location of the person;

b.describe the circumstances you allege have changed, both as they existed on [date of rendition of the order to be modified or signing of the mediated or col­laborative law settlement agreement on which the order is based] and as they currently exist; and

c.identify facts of which you are specifically aware that establish, demonstrate, or prove the basis as to why each change of circumstances supports your request that the order be modified.

2.If you contend that the child[ren]’s present living environment may endanger the child[ren]’s physical health or significantly impair the child[ren]’s emotional development, 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.