On June 09, 2014 a
Order
was filed
involving a dispute between
and
for MODIFICATION-CUSTODY
in the District Court of Tarrant County.
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322-558426-14 FILED
TARRANT COUNTY
8/29/2014 2:57:48 PM
THOMAS A. WILDER
CAUSE NO. 322-558426-14 DISTRICT CLERK
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
ALYSON WOLFLE §
AND § TARRANT COUNTY, TEXAS
ROBERT LOWELL WOLFLE, JR. §
§
AND IN THE INTEREST OF §
ROBERT LOWELL WOLFLE, III, §
JULIA LORRAINE WOLFLE, AND §
EVAN MICHAEL WOLFLE § 322ND JUDICIAL DISTRICT
MOTION OF ALYSON WOLFLE TO OVERRULE
OBJECTIONS OF ROBERT LOWELL WOLFLE, JR.
Petitioner, Alyson Wolfle, moves the Court to overrule certain objections served to
Requests for Production and Inspection by Respondent, Robert Wolfle, Jr., and to compel him to
produce the requested items for inspection and forensic imaging.
Factual and Procedural Background
Petitioner served Request for Production and Inspection to Respondent which included
requests that Respondent produce for inspection and forensic imaging any cellphone or laptop
computer possessed by him at any time from June 1, 2013 to date. Respondent served
prophylactic objections to these specific requests and did not produce the items requested.
Motion to Compel
Respondent’s prophylactic objections to these discovery requests are improper.
Petitioner respectfully requests the Court overrule each of Respondent’s objections to Request
for Production and Inspection Nos. 44 and 45. Petitioner further requests that Respondent be
compelled to produce for inspection and forensic imaging any responsive items withheld from
production.
MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 1
322-558426-14
Prayer
WHEREFORE, PREMISES CONSIDERED, Petitioner asks the Court to set this Motion
for hearing, and after the hearing, to overrule each of Respondent’s objections to Request for
Production and Inspection Nos. 44 and 45 and to compel Respondent to produce any responsive
items withheld from production for inspection and forensic imaging. Petitioner further seeks
such other and further relief, both general and special, at law or in equity, to which she may
show herself to be justly entitled.
/s/Katherine L. Lackey
RALPH H. DUGGINS
rduggins@canteyhanger.com
State Bar No. 06183700
JORDAN M. PARKER
jparker@canteyhanger.com
State Bar No. 15491400
KATHERINE L. LACKEY
klackey@canteyhanger.com
State Bar No. 24035518
CANTEY HANGER LLP
Cantey Hanger Plaza
600 W. 6th Street, Suite 300
Fort Worth, Texas 76102
Telephone: (817) 877-2800
Facsimile: (817) 877-2807
ATTORNEYS FOR PETITIONER
CERTIFICATE OF CONFERENCE
I hereby certify that I attempted to confer with Elizabeth Hunter, counsel for Respondent
on this Motion on the 28th day of August 29, 2014, via telephone, but was unable to reach her.
Therefore, this Motion is submitted to the Court for resolution.
/s/Katherine L. Lackey
KATHERINE L. LACKEY
MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 2
322-558426-14
NOTICE OF HEARING
The foregoing Motion is set for hearing before this Court on the 4th day of September 2014,
at the hour of 8:00 a.m.
SIGNED on the day of , 2014.
___________________________________
JUDGE PRESIDING
MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 3
322-558426-14
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document was served in the following
manner to the following individual on the 29th day of August, 2014.
VIA E-SERVE
Elizabeth Hunter
VIA E-SERVE
David L. Hoffmann
Attorney at Law
Quilling, Selander, Lownds, Winslett & Moser, P.C.
2001 Bryan Street Suite 1800
Dallas, TX 75201
/s/Katherine L. Lackey
Katherine L. Lackey
MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 4
Document Filed Date
August 29, 2014
Case Filing Date
June 09, 2014
Category
MODIFICATION-CUSTODY
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322-558426-14 FILED TARRANT COUNTY 8/29/2014 2:57:48 PM THOMAS A. WILDER CAUSE NO. 322-558426-14 DISTRICT CLERK IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § ALYSON WOLFLE § AND § TARRANT COUNTY, TEXAS ROBERT LOWELL WOLFLE, JR. § § AND IN THE INTEREST OF § ROBERT LOWELL WOLFLE, III, § JULIA LORRAINE WOLFLE, AND § EVAN MICHAEL WOLFLE § 322ND JUDICIAL DISTRICT MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. Petitioner, Alyson Wolfle, moves the Court to overrule certain objections served to Requests for Production and Inspection by Respondent, Robert Wolfle, Jr., and to compel him to produce the requested items for inspection and forensic imaging. Factual and Procedural Background Petitioner served Request for Production and Inspection to Respondent which included requests that Respondent produce for inspection and forensic imaging any cellphone or laptop computer possessed by him at any time from June 1, 2013 to date. Respondent served prophylactic objections to these specific requests and did not produce the items requested. Motion to Compel Respondent’s prophylactic objections to these discovery requests are improper. Petitioner respectfully requests the Court overrule each of Respondent’s objections to Request for Production and Inspection Nos. 44 and 45. Petitioner further requests that Respondent be compelled to produce for inspection and forensic imaging any responsive items withheld from production. MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 1 322-558426-14 Prayer WHEREFORE, PREMISES CONSIDERED, Petitioner asks the Court to set this Motion for hearing, and after the hearing, to overrule each of Respondent’s objections to Request for Production and Inspection Nos. 44 and 45 and to compel Respondent to produce any responsive items withheld from production for inspection and forensic imaging. Petitioner further seeks such other and further relief, both general and special, at law or in equity, to which she may show herself to be justly entitled. /s/Katherine L. Lackey RALPH H. DUGGINS rduggins@canteyhanger.com State Bar No. 06183700 JORDAN M. PARKER jparker@canteyhanger.com State Bar No. 15491400 KATHERINE L. LACKEY klackey@canteyhanger.com State Bar No. 24035518 CANTEY HANGER LLP Cantey Hanger Plaza 600 W. 6th Street, Suite 300 Fort Worth, Texas 76102 Telephone: (817) 877-2800 Facsimile: (817) 877-2807 ATTORNEYS FOR PETITIONER CERTIFICATE OF CONFERENCE I hereby certify that I attempted to confer with Elizabeth Hunter, counsel for Respondent on this Motion on the 28th day of August 29, 2014, via telephone, but was unable to reach her. Therefore, this Motion is submitted to the Court for resolution. /s/Katherine L. Lackey KATHERINE L. LACKEY MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 2 322-558426-14 NOTICE OF HEARING The foregoing Motion is set for hearing before this Court on the 4th day of September 2014, at the hour of 8:00 a.m. SIGNED on the day of , 2014. ___________________________________ JUDGE PRESIDING MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 3 322-558426-14 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this document was served in the following manner to the following individual on the 29th day of August, 2014. VIA E-SERVE Elizabeth Hunter VIA E-SERVE David L. Hoffmann Attorney at Law Quilling, Selander, Lownds, Winslett & Moser, P.C. 2001 Bryan Street Suite 1800 Dallas, TX 75201 /s/Katherine L. Lackey Katherine L. Lackey MOTION OF ALYSON WOLFLE TO OVERRULE OBJECTIONS OF ROBERT LOWELL WOLFLE, JR. PAGE 4