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Include the following notice 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.]
Preservation of Evidence: Petitioner is put on notice to preserve and not destroy, conceal, or alter any evidence or potential evidence relevant to the issues in this case, including tangible documents or items in Petitioner’s possession or subject to Petitioner’s control and electronic documents, files, or other data generated by or stored on Petitioner’s home computer, work computer, storage media, portable systems, electronic devices, online repositories, or cell phone.
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Include 2. if applicable. |
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.:
[Email address]
[Address]
[Telephone]
[Fax]
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For certificate of service, see form 21-11. |
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If this is a response to a petition, see form 5-18 for initial disclosures required by Tex. R. Civ. P. 194 (generally within thirty days after filing of the first answer or general appearance). |