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APPENDIX 6


NO. __________

IN THE MATTER OF THE MARRIAGE OF X IN THE DISTRICT COURT OF
X
X
AND X JEFFERSON COUNTY, TEXAS
X
AND IN THE INTEREST OF THEIR X
MINOR CHILDREN X _______ TH JUDICIAL COURT

PETITONER/RESPONDENT'S REQUESTS FOR
DISCLOSURE UNDER LOCAL RULES OF THE COURT

TO: [Name], by and through[his/her] attorney of record, [name and address of attorney].

Pusuant to the Local Rules of the District COurts of Jefferson County, Texas - Family Law Proceedings, you are requested to disclose, within 30 days [or 50 days] of service of this request, the information or materials set forth in the attached request. Each written response must be preceded by the request to which it applies. No objection or assertion of work product privilege is permitted to a request under this rule. If you fail to comply with this request, the court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Your response must be signed.

Respectfully submitted,
BY: ________________________
TBA# _______________
ATTORNEYS FOR ____________

Appendix 6

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the above and foregoing instrument has been forwarded to __________, on the the ________ day of __________ _____.

_________________________

Appendix 6


REQUEST

  1. State the name, address, phone number, DL#, DOB, place of birth and Social Security number of (name of responding party).

  2. State the name, address, phone number, DL#, DOB, place of birth and Social Security number of all children under the age of eighteen born to this marriage.

  3. Produce (responding party's name) tax returns for the years _______ through ________.

  4. State the name, mailing address and phone number of (name of responding party) employer and all previous employers since date of marriage.

  5. Produce payroll proof of income for the year-to-date. (If responding party is self-employed request any documents necessary to to prove income).

  6. Produce copies of all documents or reports or responding letters with enclosures from any entity obtained by (name of responding party) by virtue of an authorization furnished by the requesting party.

  7. Execute the attached authorizations to obtain information pertaining to (name of responding party) employee benefits, salary and income.

  8. Describe all property claimed to be separate property, the method you intend to use to prove same and the factual basis of the claim of separate property. (attach to your answer copies of all indicia of ownership such as deeds or titles).

  9. State the amount, the method you intend to use to prove and the factual basis of any claim for reimbursement and whether said claim is for a separate property claim against the community or a community claim against (petitioner's/respondent's) separate property.

  10. State the name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case.

  11. For any testifying expert:

    1. state the expert's name, address and telephone number;

    2. state the subject matter on which the expert will testify;

    3. state the general substance of the expert's mental impressions and opinions and a brief summary of the basis of them, or if the expert is not retained by, employed by, or otherwise subject to the control of (name of responding party) documents reflecting such information;

    4. if an expert is retained by, employed by, or otherwise subject to the control of (name of the responding party), produce the originals or copies of the following:

      1. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and

      2. the expert's current resume' and bibliography.
Appendix 6

[Local Rules - Family Law Proceedings]

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