To: (Individual and Adrs/Fax)

NO. ______

§ IN THE DISTRICT COURT § § ______JUDICIAL DISTRICT § § § HARRIS COUNTY, TEXAS

REQUEST FOR INTERROGATORIES

To: (individual and adrs/fax)

Pursuant to Rule 197 of Texas Rules of Civil Procedure, Petitioner NAME serves these

Interrogatories to RECEIVING PARTY. In accordance with Rule 197, each interrogatory must be answered separately and fully, in writing, and under oath. The interrogatories must be signed by the Respondent or its attorney. The answers must be delivered to (adrs), within thirty (30) days after the date of service for these interrogatories, unless the deadline is modified by the

Court.

Pursuant to Rule 193.5, these interrogatories are “continuing,” meaning you must supplement your answers in accordance with Rule 193.5 of Texas Rules of Civil Procedure. If

RECEIVING PARTY objects to any particular interrogatory or part of an interrogatory,

RECEIVING PARTY is to answer all other interrogatories or parts of interrogatories to which it has no objection.

1. If you contend that it is not in the best interest of the children that NAME be appointed sole managing conservator, joint managing conservator, or possessory conservator, subject to a geographic restriction, state in general the legal theories and factual bases that support your contention.

3. State what periods of possession and access each conservator should have and, in general, the legal theories and factual bases that support your contention.

4. 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) and state in general the legal theories and factual bases that support your contentions.

5. If the court orders NAME to pay child support, state the monthly amount of support the court should order NAME to pay, and state in general the legal theories and factual bases that support your contention.

6. If you contend the court should deviate from the child support guidelines, state in general the legal theories and factual bases that support your contention and how the court should deviate from these child support guidelines.

7. State how the court should order that health insurance coverage be provided for the children, and state in general the legal theories and factual bases that support your contention.

8. If the children exhibit changes in demeanor or behavior immediately before or after the children have been in the possession of NAME, state-

a. each date on which you have observed these changes and

b. what changes you have seen.

8. If you feel that the children have any special medical, psychological, or educational needs, provide which such needs you believe that they are in need of.

Sincerely,

Signature

NAME Certificate of Service

I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on May 10, 2012.

Signature