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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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The following is a list of House Bills and Senate Bills that have caused changes, effective currently unless otherwise noted, in the area of Family Law:

House Bills

  1. HB 826.  This bill amends Section 105.006 (e-2) of the Texas Family Code to require additional mandatory language in orders that orders child support.  The orders are now to include a boldface statement in capital letters that outlines the circumstances under which the court may modify a child support order.
  2. HB910.  This bill amends the law to permit the carrying of handguns that are not concealed.  Numerous provisions in the Family Code were amended to remove the word concealed.  Effective January 1, 2016.
  3. HB 1500.  This bill amends Section 156.006(b-1) of the Texas Family Code.  When filing a motion for a temporary order based on the allegation that the child’s present circumstances would significantly impair the child’s physical health or development, the person requesting the temporary order must execute and attach an affidavit based on his/her personal knowledge or representations made by someone with personal knowledge that contain the facts and support the allegation.   The court shall deny the relief and decline to set the matter for a hearing unless it determines on the basis of the affidavit that the facts are adequate to support the allegation.
  4. HB 1781.  Section 102.0045 of the Texas Family Code is modified to allow the sibling of a child separated for a sibling as a result of an action by the Department of Family Protective Services to file an original suit for access to the child.
  5. HB 3121.  Sections 157.001 and 157.062 of the Texas Family Code are amended to grant the courts broader authority with respect to enforcing temporary orders, including temporary restraining orders, standing orders, injunctions, and any other temporary order rendered by the court.
  6. HB 4086.  Section 201.015(a) of the Texas Family Code is amended relating to the right to a de novo hearing before the referring court after a temporary order was rendered by an associate judge in certain family law proceedings.

Senate Bills

  1. SB 206.  Effective September 1, 2016, Section 161.001(b) is amended to include that a parent who has been convicted of places on community supervision in another jurisdiction under a law that contains elements substantially similar to the elements of any the sections of the Penal Code listed in Section 161.001(b)(1)(L) of the Texas Family code can lead to involuntary termination of the parent-child relationship.
  2. SB 314.  Section 263. 409 is amended to include a requirement that the Department of Family and Protective Services provide a nonparent managing conservator of a child with an explanation of the differences between adoption and appointment as managing conservator and to inform them of the rights and duties of a managing conservator before the court renders an order appointing them as managing conservator.
  3. SB 737 (HB 1660).  Section 85.042 is amended to require courts to send protective orders to law enforcement by the end of the next business day and to permit transmission in electronic form.
  4. SB 812 (HB 1826).  Section 201.001 is amended to allow associate judges to hear and render orders on name change suits pursuant to Title 1, Chapter 45 of the Texas Family Code.
  5. SB 814.  Section 6.4035 is amended to remove the requirement that a waiver of service be sworn before a notary public if the party executing the waiver is incarcerated.  Also, the section is amended to prohibit the use of a digitized signature on a waiver.  In addition, parties are now authorized to waive the issuance or service of citation in suits to remove the disability of a minor, a suit to change the name of an adult or a child, or a suit relating to the parent child-relationship through amendment of sections 31.008. 45.0031, 45.107 and 102.0091.
  6. SB 815.  Section 6.501(a) is amended to include new forms of electronic communications and documents in temporary injunctions the court may issue and adds a list of additional protections of parties after filing for a divorce.
  7. SB 817.  Section 153.005, regarding the issuance of a protective order and the appointment of a managing conservator in certain family law proceedings is amended.
  8. SB 818.  Sections 153.076 is amended to add subsections (b-1) and (c-1) and amending subsection (d).  Section 153.076(b-1) require a court to order that each conservator of a child has the duty to inform the other conservator under certain circumstances concerning whether the conservator establishes a residence with someone subject to a protective order, lives with or provides unsupervised access to a child to someone subject to a protective order, or is subject to a protective order themselves after the date of the order establishing conservatorship.  Section (c-1) outlines the notice requirements and (d) is amended to include failure to provide notice required by (b-1) and (c-1) as Class C misdemeanor.
  9. SB 821 (HB 1825).  This bill amends the Texas Family Code to change the definition of school from a primary school to an elementary school and that elementary school includes prekindergarten.
  10. SB 1929.  Amends 155.207 of the Texas Family Code by extending the period from one to ten days for the clerk of the court to send to the proper court the required documents and adds that a certified copy of the order of transfer signed by the transferring court to the list of required documents.  Additionally, it adds that notice shall be given to the judge of the transferee court on the receipt of the documents, items that must be included in the order of transfer, and the authority of the court to which a suit is transferred to either retain an attorney ad litem or guardian ad litem appointed by the transferring court or to appoint a new attorney ad litem or guardian ad litem by wither the 10th day after receiving the order of transfer or the date of the first scheduled hearing after the transfer.
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Ramos Law Ramos Law Group, PLLC, was founded by board certified attorney Mary E. Ramos, founder of Ramos Law Group, PLLC, who is board certified in family law by the Texas Board of Legal Specialization.

Why should you choose a board certified attorney in Texas over a non-board certified attorney? There are several reasons why choosing a board certified attorney could mean a better experience for the client and a more favorable outcome for their case.

More Experience

Becoming a board certified attorney in Texas requires that an attorney in the state of Texas to have practiced law for at least five years, with a minimum of three years in the specialty area. After passing an evaluation by fellow lawyers and judges the attorney must take and pass a 6-hour written certification exam, the attorney is required to continue ongoing involvement in their specialty area and attend Texas Board of Legal Specialization approved legal education courses.

Higher Standards

The standard that Board Certified Attorneys must meet, shows a level of commitment to their specific field of law and an ongoing interest in learning the current trends in their practice area. A board certified attorney has more knowledge and experience in a certain, specific area of law as compared to an attorney who practices in several different areas of law.

Powerful Reputation

The advantage of a board certified attorney to a non-board certified attorney is more than passing a certification test. A board certified attorney possesses a greater level of experience in a single field, maintains close relations with other attorneys within their specific field, and gains ongoing notoriety amongst their peers in the legal community.

Each of these advantages provide better results for the Board Certified Attorney’s client because experience, close relationships, and notoriety all work together in obtaining the best legal result possible for the client.

Contact Us Today

Mary E. Ramos understands that being a board certified attorney in Texas means staying fully committed to each case along with continued education to provide the best possible outcomes for each client. If you’re looking for an attorney with a higher level of experience, standards, and reputation, contact our team at Ramos Law Group today to schedule your initial consultation.


Video Transcription:

Things not to do during your divorce process. Don’t date. Don’t do drugs. Don’t drink and drive. Don’t use your children as pawns or put them in the middle. Don’t dredge on the past of your divorce process. Let the past be the past. We’re trying to move forward. It’s not gonna be beneficial emotionally or financially for you to focus on the past when we’re trying to get you moving forward. If you need counseling to deal with issues in the past, that’s probably a good idea to seek counseling or a support group in some form or fashion. Let us guide you in the divorce process and make sure you don’t step in any of those land mines in moving forward. We wanna make sure you get through the divorce process in the least financially impacting way and the most beneficial for you family and your situation.

Ramos Law Group, PLLC, your family law team of experts.

Video Transcription by Speechpad.com.

Reducing the Cost of Legal Representation

A divorce is one of the most challenging and emotionally draining experiences someone can go through. An effective and experienced family law attorney can help guide you through this trying process, but it’s no secret that hiring legal representation in Texas can be expensive. Consider these tips:

  • Send specific, numbered questions via email
  • Gather documents and do your own homework
  • Create a timeline of your case

In this video, Mary E. Ramos outlines these tips to help reduce the cost of representation in Texas. If you’re going through a divorce, or any other difficult family law situation, contact the expert attorneys at Ramos Law Group, PLLC for more information.

1. Send Your Questions Via Email

Divorce can get expensive, especially when people won’t agree to things. As soon as attorneys get involved, expenses begin to skyrocket. One of the ways that you can reduce your attorney fees during the divorce process is to communicate via email to your attorney when you have questions and concerns.

At Ramos Law Group, attorneys may request that clients send questions, numbered one through five, in an email so that they can addressed and dealt with in an efficient and timely manner. The office policy is to return all emails within a 24 hour period.

2. Do Your Own Homework

Another way to mitigate your expenses is to do as much homework as you can on your own and gather documents to provide your attorneys. The less time that your attorneys have to work on your case, the less expensive it is for you.

3. Create a Timeline

One of the most effective tips to help reduce the cost of representation in Texas is to create a timeline of your case for your attorney. In other words, write out the ‘story’ of your case. Your divorce case is a story, and the only way your attorney is going to be able to relay that story to the judge is to know exactly what is going on. Remember: this your case, this is your marriage, these are your children, this is your life.

By providing as much detail as possible to your attorneys, they will be able to express your concerns to the judge more accurately; it’s like drawing a picture in a coloring book, and filling out that picture with as much detail as possible. This puts your attorneys in a better position to reach the goals set in your case.

Contact Our Team Today

Mary E. Ramos is committed to achieving positive outcomes for each and every one of her clients. As a board certified family law attorney, she has the knowledge, experience, and reputation you’re looking for when you’re going through a divorce. Consider these tips to help reduce the cost of representation in Texas, and schedule a consultation with our attorneys at Ramos Law Group, PLLC, today.

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