Sample Agreed Temporary Mutual Injunctions

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NOTICE:  THIS DOCUMENT CONTAINS SENSITIVE DATA

201511111

IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §  
  §  
JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. §  
AND § 310th JUDICIAL DISTRICT
JANE “I MADE HIM WHAT HE IS” DOE §  
  §  
AND IN THE INTEREST OF §  
JILL “CAN’T WE JUST GET ALONG” DOE, A CHILD § HARRIS COUNTY, TEXAS

AGREED TEMPORARY MUTUAL INJUNCTIONS

The Court examined the pleadings JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and finds that JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and JANE “I MADE HIM WHAT HE IS” DOE are entitled to the joint and mutual temporary injunctions below.

IT IS THEREFORE ORDERED that the joint and mutual temporary injunctions are GRANTED, and JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and JANE “I MADE HIM WHAT HE IS” DOE are immediately restrained, from:

  1. Communicating with the other party in person, by telephone, or in writing in vulgar, profane, obscene, or indecent language or in a coarse or offensive manner.
  2. Threatening the other party in person, by telephone, or in writing to take unlawful action against any person.
  3. Placing one or more telephone calls, anonymously, at any unreasonable hour, in an offensive and repetitious manner, or without a legitimate purpose of communication.
  4. Causing bodily injury to the other party or to a child of either party.
  5. Threatening the other party or a child of either party with imminent bodily injury.
  6. Destroying, removing, concealing, encumbering, transferring, or otherwise harming or reducing the value of the property of one or both of the parties.
  7. Falsifying any writing or record relating to the property of either party.
  8. Misrepresenting or refusing to disclose to the other party or to the Court, on proper request, the existence, amount, or location of any property of one or both of the parties.
  9. Damaging or destroying the tangible property of one or both of the parties, including any document that represents or embodies anything of value.
  10. Tampering with the tangible property of one or both of the parties, including any document that represents or embodies anything of value, and causing pecuniary loss to the other party.
  11. Selling, transferring, assigning, mortgaging, encumbering, or in any other manner alienating any of the property of Petitioner or Respondent, whether personalty or realty, and whether separate or community, except as specifically authorized by this order.
  12. Incurring any indebtedness, other than legal expenses in connection with this suit, except as specifically authorized by this order.
  13. Making withdrawals from any checking or savings account in any financial institution for any purpose, except as specifically authorized by this order.
  14. Spending any sum of cash in each party’s possession or subject to each party’s control for any purpose, except as specifically authorized by this order.
  15. Withdrawing or borrowing in any manner for any purpose from any retirement, profit-sharing, pension, death, or other employee benefit plan or employee savings plan or from any individual retirement account or Keogh account, except as specifically authorized by this order.
  16. Entering any safe-deposit box in the name of or subject to the control of Petitioner or Respondent, whether individually or jointly with others.
  17. Withdrawing or borrowing in any manner all or any part of the cash surrender value of life insurance policies on the life of Petitioner or Respondent, except as specifically authorized by this order.
  18. Changing or in any manner altering the beneficiary designation on any life insurance on the life of Petitioner or Respondent or the parties’ child.
  19. Canceling, altering, failing to renew or pay premiums, or in any manner affecting the present level of coverage of any life, casualty, automobile, or health insurance policies insuring the parties’ property or persons, including the parties’ child.
  20. Opening or diverting mail addressed to the other party.
  21. Signing or endorsing the other party’s name on any negotiable instrument, check, or draft, such as tax refunds, insurance payments, and dividends, or attempting to negotiate any negotiable instrument payable to the other party without the personal signature of the other party.
  22. Taking any action to terminate or limit credit or charge cards in the name of the other party.
  23. Discontinuing or reducing the withholding for federal income taxes on each party’s wages or salary while this case is pending.
  24. Destroying, disposing of, or altering any financial records of the parties, including but not limited to records from financial institutions (including canceled checks and deposit slips), all records of credit purchases or cash advances, tax returns, and financial statements.
  25. Destroying, disposing of, or altering any e-mail or other electronic data relevant to the subject matters of this case, whether stored on a hard drive or on a diskette or other electronic storage device.
  26. Terminating or in any manner affecting the service of water, electricity, gas, telephone, cable television, or other contractual services, such as security, pest control, landscaping, or yard maintenance, at 1214 Miramar Street, Houston, TX 77006 or in any manner attempting to withdraw any deposits for service in connection with those services.
  27. Entering, operating, or exercising control over the motor vehicle in the possession of Petitioner.
  28. Disturbing the peace of the child or of another party;
  29. Withdrawing the child from enrollment in the school or day-care facility where the child is enrolled without the written permission of the other party;
  30. Permitting an unrelated adult with whom either party has an intimate or dating relationship to remain in the same residence with the child between the hours of 10 P.M. and 8 A.M.
  31. Hiding or secreting the child from another party;
  32. Making disparaging remarks regarding any party or party’s family in the presence or within the hearing of the child;
  33. Allowing others to make disparaging remarks regarding any party or party’s family in the presence or within the hearing of the child;
  34. Consuming alcohol within the 24 hours before or during the period of possession of or access to the child;
  35. Transporting the child as a driver in a motor vehicle within the previous 8 hours of having consumed an alcoholic beverage, or permitting a third party who has consumed alcohol within the previous 8 hours to so transport the child;
  36. Ingesting, consuming, or using any narcotic substance within the 48 hours before or during the period of possession of or access to the child;
  37. Allowing others who have ingested, consumed, or used any narcotic substance within the 48 hours before or during the period of possession of or access to the child to have access to the child;
  38. Using corporal punishment for the discipline of a child or permitting anyone under either parent’s control to inflict such punishment upon either child;
  39. Communicating with each other through the child; nor
  40. Discussing any matters of the litigation with the child.

IT IS FURTHER ORDERED that each party is authorized only as follows:

To make expenditures and incur indebtedness for reasonable and necessary living expenses for food, clothing, shelter, transportation, and medical care.

To make expenditures and incur indebtedness for reasonable attorney’s fees and expenses in connection with this suit.

To make withdrawals from accounts in financial institutions only for the purposes authorized by this order.

To engage in acts reasonable and necessary to conduct each party’s usual business and occupation.

Service of Writ and Waiver of Bond

JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and JANE “I MADE HIM WHAT HE IS” DOE waive issuance and service of the writ of injunction, by stipulation or as evidenced by the signatures below.  IT IS ORDERED that JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and JANE “I MADE HIM WHAT HE IS” DOE shall be deemed to be duly served with the writ of injunction.

This joint and mutual injunctions order is effective immediately and shall continue in force and effect until further order of this Court. This order shall be binding on JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR. and JANE “I MADE HIM WHAT HE IS” DOE; on JOHN “SHE’S NOTHING WITHOUT ME” DOE, JR.’s and NEDRA JANE “I MADE HIM WHAT HE IS” DOE’s agents, servants, and employees; and on those persons in active concert or participation with them who receive actual notice of this order by personal service or otherwise.

SIGNED on ___________________

 

________________

JUDGE PRESIDING

AGREED AS TO FORM AND SUBSTANCE:

 

_______________ _______________
JOHN DOE, JR. JANE DOE

 

AGREED AS TO FORM ONLY:

 

Ramos Law Group, PLLC Big Money & Associates, P.C.
1214 Miramar Street 3355 W. Alabama, Suite 444
Houston, Texas 77006 Houston, Texas 77098
Tel: (713) 225-6200 Tel.: (281) 555-5000
Fax: (713) 225-6201 Fax: (281) 555-5001
info@ramosfamilylaw.com Tex@bigmoneyassociates.com
 

 

By:______________ By:______________
Mary E. Ramos Big Tex NewHouse
State Bar No. 24045170 State Bar No. 24099999
Attorneys for JOHN DOE, JR Attorney for JANE DOE

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