Requests for Admission in Texas: The Quiet Trap for Pro Se Litigants
Miss the deadline on requests for admission in Texas and every statement is deemed admitted. What Wheeler v. Green held, and how to withdraw deemed admissions.
Texas family law
Rule 194a Request for Disclosure: The Texas Discovery Rule Most Pro Se Litigants Miss
There’s a trap in Texas discovery that catches self-represented people constantly, and it comes from reading the wrong rule. The automatic disclosure rule everyone quotes does not apply to your case If you go looking online, you’ll find a bunch of articles saying that since 2021 Texas requires automatic initial disclosures. Both sides have to … Read more
Text Message Evidence in Texas Family Court: Getting Your Screenshots Admitted
I see this one constantly. Somebody shows up with a three-inch binder of text message screenshots, absolutely certain it’s going to end the case, and then it never gets in front of the judge because they don’t know how to admit it. Having text message evidence in Texas family court and getting that evidence admitted … Read more
Why Most Pro Se Enforcement Motions Get Denied — And How to Draft One That Doesn’t
I’ve read a lot of enforcement motions written by self-represented parents, and I can usually tell in the first paragraph whether it’s going to survive. Not because the facts are bad. Usually the facts are terrible, in the sense that the other parent has genuinely been doing something outrageous for months. The motions fail on … Read more
Modifying Child Support in Texas: The 3-Year, 20%, and $100 Triggers
Child support modification is one of the few places in Texas family law where the legislature gave you a genuinely simple path, and hardly anybody uses it. Most people assume they have to prove a material and substantial change, they can’t figure out how to prove one, and they never file. There’s a second door, … Read more
Should You File a Counter-Petition? What Being Served Does and Doesn’t Limit
There’s a mindset problem that shows up in almost every person who gets served, and I want to name it early because it costs people more than any single filing mistake I see. The mindset is this: they filed, so it’s their case, and my job is to respond to whatever they do. That’s wrong, … Read more
The Standing Order Came With Your Citation — Here’s What You Can’t Do Now
When you got served, you probably focused on the petition, because that’s the document with your name on it and your ex’s accusations in it. But if your case was filed in one of the many Texas counties that use them, there was another document in that stack, and it’s the one that’s going to … Read more
You’ve Been Served in Texas: The 20-Day Answer Deadline and What Happens If You Miss It
So you got served. Somebody knocked on your door or caught you in the parking lot at work, handed you a stack of paper, and now you’re sitting at the kitchen table trying to make sense of what just happened to your life. I’ve been in that chair myself, and I’ve walked hundreds of people … Read more
Before You Sign That Texas Mediated Settlement Agreement, Understand This
A mediated settlement agreement in Texas isn’t a proposal, and it isn’t a draft you get to sleep on and revise in the morning. If it meets the requirements in the Texas Family Code, it’s about as close to bulletproof as anything gets in family law, and most pro se litigants don’t find that out … Read more
The Holley Factors: What a Texas Judge Actually Weighs in a Custody Case
I get some version of this question every week: “What is the judge actually looking at when they decide who gets primary custody?” People assume it’s about who’s the better person, or who makes more money, or who has the bigger house. It’s not. Texas courts use a specific framework that’s been the law since … Read more