Texas Modification Suit Disclosures

Summary

In Texas modification suits, you can request various disclosures such as financial statements, employment details, tax returns, and child-related records. Additional requests can include phone records, credit reports, and evidence of payments for child-related expenses. For more complex cases, you might request forensic accounting reports, business records, and digital communication logs. When requesting disclosures, ensure you demonstrate their relevance to the case. Consider consulting a local attorney for personalized guidance.

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yes this is a motion to modify so I want some disclosures pertaining to everything and anything under the sink but first starting with the items you listed
In a motion to modify in Texas, you can request the following disclosures from the other party:
- Financial information (income, expenses, assets, and liabilities)
- Employment details
- Tax returns
- Bank statements
- Insurance policies
- Child's medical and educational records
Is there any specific information you need beyond these standard disclosures?
Okay so give me examples of those items in a written disclosure format to ask the other party
Sure! Here are some example requests for disclosures in a written format to ask the other party in a motion to modify in Texas:
*. Financial Information:
- Please provide complete financial statements, including all income, expenses, assets, and liabilities for the past two years.
*. Employment Details:
- Please provide your current employment details, including the name and address of your employer, job title, and salary information.
*. Tax Returns:
- Please provide copies of your federal income tax returns, including all schedules and attachments, for the past three years.
*. Bank Statements:
- Please provide copies of all bank statements for any accounts held individually or jointly by you for the past two years.
*. Insurance Policies:
- Please provide copies of any health, life, and auto insurance policies currently in force, including details of coverage and beneficiaries.
*. Child's Medical Records:
- Please provide copies of all medical records for our child, including any records of doctor visits, hospital stays, and treatments received in the past two years.
*. Child's Educational Records:
- Please provide copies of all educational records for our child, including report cards, attendance records, and any special education plans, if applicable.
Is there any additional information you need or any specific details you want to request?
Can I ask for complete and full phone records or not?
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Yes, you can request complete and full phone records in a motion to modify in Texas, especially if you believe they are relevant to the case. However, you must demonstrate the relevance and necessity of these records to the court. Would you like to know more about how to make this request?
yeah
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Sure! To request complete and full phone records, you can include a specific request in your disclosure format like this:
*. Phone Records:
- Please provide complete and full phone records, including call logs, text messages, and data usage for the past two years.
Would you like any further assistance or have additional questions?
can i ask or request to see all credit reports for the past three years, credit cards, venmo account, pay pal, or other financial accounts
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Yes, you can request to see all credit reports, credit card statements, Venmo, PayPal, or other financial account records, especially if they are relevant to your case. Here is an example request format:
*. Credit Reports:
- Please provide copies of all credit reports from the past three years.
*. Credit Card Statements:
- Please provide copies of all credit card statements for any accounts held individually or jointly by you for the past three years.
*. Venmo, PayPal, and Other Financial Accounts:
- Please provide copies of all transaction records for Venmo, PayPal, and any other financial accounts for the past three years.
Is there any additional information you need or specific details you need to request?
Okay what are some more difficult disclosure requests
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For more difficult disclosure requests in Texas related to a modification suit, you might consider the following:
- Forensic Accounting Reports: Requesting a forensic accountant to analyze the other party's financial records for hidden assets.
- Business Records: If the other party owns a business, request detailed business financial records.
- Digital Communication Records: Request detailed logs of emails and other digital communications.
- Social Media Activity: Request records of social media activities relevant to the case.
Is there anything else you need help with?
Forensic Accounting Reports: Requesting a forensic accountant to analyze the other party's financial records for hidden assets. How would I ask for this
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To request forensic accounting reports in a motion to modify in Texas, you can include a specific request like this:
*. Forensic Accounting Reports:
- Please provide a forensic accounting report analyzing all financial records, including but not limited to bank statements, tax returns, and asset documents, to identify any hidden assets.
Is there any other assistance you need with this request?
okay I need more disclosures, you're not giving me enough
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Here are a few additional disclosure requests you might consider for your motion to modify:
*. Investment Accounts:
- Please provide statements for all investment accounts, including stocks, bonds, retirement accounts, and other securities, for the past three years.

*. Real Estate Holdings:
- Please provide documentation for all real estate holdings, including property deeds, mortgage statements, and rental income records for the past three years.

*. Loans and Debts:
- Please provide documentation for all loans and debts, including personal loans, student loans, mortgages, and lines of credit, for the past three years.
Would you like assistance with anything else?
Okay so I want proof and evidence in the form of receipts or whatever which includes payments that she's made to Matt Mahoney which is her attorney For the past five years
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To request proof and evidence of payments made to Matt Mahoney, her attorney, for the past five years, you can include a specific request in your disclosure format like this:
*. Attorney Payment Records:
- Please provide receipts, invoices, and any other documentation of payments made to Matt Mahoney, Esq. for legal services rendered over the past five years.
Would you like assistance with anything else?
Okay what are some other disclosures
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Here are some additional disclosure requests you might consider:
- Electronic Devices: Request copies of data from electronic devices, such as computers, tablets, and smartphones.
- Medical Records: Request comprehensive medical records, including mental health records.
- Professional Licenses: Request documentation of any professional licenses or certifications.
- Travel Records: Request records of travel, including flight, hotel, and car rental receipts.
Do you need more specific examples or guidance on any of these?
for example, I want evidence of financial payments like receipts with her name on them which can be authenticated that she paid for acitivities pertaining to the children like extracurricular, sports, clothes, groceries, and anything else the children need.
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To request evidence of financial payments related to children's activities, you can include a specific request in your disclosure format like this:
- Child-Related Expenses:
- Please provide receipts, invoices, and any other documentation showing payments made for the children's extracurricular activities, sports, clothing, groceries, and any other necessary items over the past three years.
Would you like additional information or guidance?
Professional Licenses: Request documentation of any professional licenses or certifications. help me request this
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Sure! To request documentation of any professional licenses or certifications, you can include the following request in your disclosure format:
- Professional Licenses and Certifications:
- Please provide copies of all professional licenses and certifications currently held, including details of issuing authorities and dates of issuance.
Would you like assistance with any other specific disclosures or legal information?
okay give me some other requests for disclosures that I can ask for give me your most toughest top *
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Sure! Here are some tough disclosure requests you can include in your motion to modify:
*. Financial Statements:
- Full financial statements for the past five years, including income, expenses, assets, and liabilities.
*. Employment Records:
- Detailed employment history and records from all employers for the past five years.
*. Tax Returns:
- Federal and state tax returns with all schedules and attachments for the past five years.
*. Bank Statements:
- Statements from all bank accounts (individual and joint) for the past five years.
*. Insurance Policies:
- Copies of all current and past insurance policies, including health, life, auto, and property insurance.
*. Medical Records:
- Complete medical records, including mental health records, for the past five years.
*. Educational Records:
- Complete educational records for the children, including report cards, attendance records, and IEPs.
*. Credit Reports:
- Copies of credit reports from the past five years.
*. Credit Card Statements:
- Statements for all credit cards for the past five years.
*. Investment Accounts:
- Statements for all investment accounts for the past five years.
*. Real Estate Holdings:
- Documentation of all real estate holdings, including deeds, mortgage statements, and rental income.
*. Loans and Debts:
- Documentation of all loans and debts, including personal loans, student loans, and lines of credit.
*. Phone Records:
- Complete phone records, including call logs, text messages, and data usage.
*. Social Media Activity:
- Records of social media activities.
*. Digital Communication Records:
- Detailed logs of emails and other digital communications.
*. Forensic Accounting Reports:
- Forensic accounting report analyzing financial records for hidden assets.
*. Business Records:
- Detailed financial records of any businesses owned.
*. Travel Records:
- Records of all travel, including flights, hotels, and car rentals.
*. Professional Licenses:
- Documentation of all professional licenses and certifications.
*. Attorney Payment Records:
- Receipts and invoices of payments made to attorneys.
*. Child-Related Expenses:
- Receipts for children's extracurricular activities, clothing, groceries, etc.
*. Venmo, PayPal, and Other Financial Accounts:
- Transaction records for Venmo, PayPal, and other financial accounts.
*. Electronic Devices:
- Copies of data from computers, tablets, and smartphones.
*. Utility Bills:
- Copies of utility bills for the past five years.
*. Receipts for Major Purchases:
- Receipts for purchases over a specified amount.
*. Contracts and Agreements:
- Copies of any contracts or agreements entered into.
*. Vehicle Records:
- Documentation of vehicle ownership and related expenses.
*. Memberships and Subscriptions:
- Records of memberships and subscriptions.
*. Wills and Trusts:
- Copies of any wills, trusts, or estate planning documents.
*. Retirement Accounts:
- Statements from retirement accounts.
*. Inheritance Records:
- Documentation of any inheritances received.
*. Gifts Given and Received:
- Records of significant gifts given or received.
*. Divorce Decrees and Settlements:
- Copies of any previous divorce decrees and settlement agreements.
*. Guardianship and Custody Orders:
- Copies of any guardianship or custody orders.
*. Child Support Payment Records:
- Records of child support payments made and received.
*. Alimony Payment Records:
- Records of alimony payments made and received.
*. Pension Plan Documents:
- Copies of pension plan documents.
*. Compensation and Benefits Statements:
- Detailed statements of compensation and benefits received from employers.
*. Bankruptcy Records:
- Documentation of any bankruptcy filings.
*. Litigation Records:
- Records of any litigation involving the party.
*. Criminal Records:
- Copies of any criminal records.
*. Civil Judgments:
- Records of any civil judgments.
*. Safety Deposit Box Records:
- Documentation of safety deposit box contents.
*. Personal Property Inventory:
- Inventory of valuable personal property.
*. Charitable Contributions:
- Records of charitable contributions.
*. Tax Assessments:
- Copies of tax assessments for real property.
*. Childcare Provider Records:
- Documentation of payments made to childcare providers.
*. Health Savings Account Statements:
- Statements for health savings accounts.
*. Disability Insurance Records:
- Copies of disability insurance policies and claims.
*. Annuity Contracts:
- Copies of annuity contracts.
Would you like any further assistance or have additional questions?
I need or want to request any life insurance policies that she has on the children or her father
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In Texas, you can request life insurance policies as part of your disclosures. Here’s how you can frame your request:
- Life Insurance Policies:
- Please provide copies of any life insurance policies currently in force on the children or her father, including details of coverage and beneficiaries.
Would you like assistance with anything else?
Request how many times she's denied the opportunity to let me know of appointments regarding the children ahead of time
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To request information on how many times she's denied you the opportunity to know about appointments regarding the children ahead of time, you can frame your disclosure request like this:
- Appointment Notifications:
- Please provide a record of all instances in which you were notified of appointments regarding the children, including the date and time of notification, and any instances where you failed to notify me ahead of time over the past two years.
Would you like any further assistance with this?