Motion for Divorce in In the Matter of the Marriage of Rachel Ann Puente and Luis Puente| Trellis.Law

On August 21, 2023 a Family Matters was filed involving a dispute between Puente, Rachel Ann, and Puente, Luis, for Divorce - No Children in the District Court of Fort Bend County.

Preview
DO NOT FILE THIS DOCUMENT WITH THE COURT. =e
===2 z=
a2
eg

Cause Number: 237DOV. 307571
Fill in cause number and exactly as assigned when the original petition was filed.
#°3
In the Matter of the Marriage of
In the
Petitioner: Rachel Ann Puente (Court Number)
Print first, middle and last name of the spouse filing for
divorce.
O District Court
And
(County Court at Law
Respondent: Luis Puente
Print first, middle and last name of other spouse Fort Bend County,
Texas
And in the interest of the following child(ren)
4 4 FIL
2
3.
5.
6
Ade 04 288
AT——teatr—_
Pw.
Wale aa
Required Initial Disclosures in Dissolution of-Marri BEND CO, TE

Parties to suits for divorce, annulment, or to declare marriage void must give the other party this
information, as required by Texas Rule of Civil Procedure 194.2

Keep a completed copy of this form for yourself. Attach the documents (like bank statements) that
are required. You can attach additional pages on separate sheets of paper if you need more space
for listing information.

You must give this information to your spouse no later than 30 days after either party files an
answer, waiver of service, or counter-petition with the court clerk. You and the other party may
agree in writing to waive the initial disclosures. Forms to waive initial disclosures by Rule 11
Agreement are available at TexasLawHelp.org.

If a question does not apply to your case, write “N/A,” “none,” or leave it blank. For example, if
you have no property to list in a particular category, write “none.”

1. Correct names and addresses of parties to the lawsuit.
See Texas Rule of Civil Procedure 194.2(b)(1).

Petitioner: Rachel Ann Puente
First Middle Last
1807 Bridge Gate Lane Katy T™ 77494
Street Address City State Zip
(214)794-7344 fpuentesal@ aol.com
Phone Email

Respondent: Luis Puente
First Middle Last
9314 Lindaro Lane Dallas TX 75228
Street Address City State Zip
(214)328-8893 None
Phone Email
List the full names and dates of birth of the child(ren).
FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 1 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

Child's name Date of Birth Place of Birth State where
child lives now

2. Potential parties to the lawsuit.
See Texas Rule of Civil Procedure 194.2(b)(2).

You must provide the names, addresses, and telephone numbers of any potential parties.

Check any that apply. If none apply skip to next section

C The Office of the Attorney General—Child Support Division (OAG). The local field office
address and phone number are:

(1 The Texas Department of Family and Protective Services. The office address and phone
number are:

0 Other:

3. Legal theories and factual bases of claims or defenses.
See Texas Rule of Civil Procedure 194.2(b)(3).

The pleadings in this case contain the legal theories and general factual bases for claims, or
defenses.
4. Amount and any method of calculating economic damages.
See Texas Rule of Civil Procedure 194.2(b)(4).

At the time of this initial required disclosure, economic damages have not been pled for as part
of this family law case. No response to this request is needed at this time. If an amended
petition or counterpetition is filed that alleges economic damages, a response to this request will
be made within 30 days of the filing of the amended petition or counterpetition.
FM-Oiv-Disc-101-Required Initia! Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 2 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

5. Persons with Knowledge of Relevant Facts (Potential Witnesses)
See Texas Rule of Civil Procedure 194.2(b)(5).

You also need to give the other side the names, phone numbers, and addresses of potential
witnesses—that is, people with knowledge of relevant facts. What is each person’s connection
with the case? The list should include all potential witnesses regardless of who they would be
testifying for. Attach another sheet of paper if you need more room

IF this case is contested, this list could include family members, neighbors, teachers, doctors,
counselors, employers, and financial advisors, among others

Name Address Phone number Connection to case

6. Documents, electronic items, or tangible things.
See Texas Rule of Civil Procedure 194.2(b)(6).

The following is a list of documents, electronically stored information, and tangible things that have been
identified that may be used to support a claim or defense in this case. This Response will be
supplemented, as needed, as responsive items are identified

Describe documents, electronically stored information, and tangible things that you have in your
possession, custody, or control, and may use to support your claims or defenses. The list of
documents, electronic items, or tangible things should include all items in your possession that
you might want admitted as evidence in your case

No. Item/Name of Item | Type of Item (Document, Location of Brief Description of
or Document electronic info, or tangible document or document or item
item) item

If not producing copies of all the documents; access to electronically stored information; and
tangible things, a reasonable time and method for the production of these items is:

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 3 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

7. Indemnity and insuring agreements
See Texas Rule of Civil Procedure 194.2(b)(7).

Produce the originals or copies of any indemnity and insuring agreements described in Rule
192.3(f).

(Check one).

L) At the time of this initial response no indemnity and insuring agreements have been
identified. This Response will be amended, as needed.

(J Any indemnity and insuring agreements that have been identified are attached.
This Response will be amended, as needed.
8. Settlement agreements.
See Texas Rule of Civil Procedure 194.2(b)(8).

Produce the originals or copies of any settlement agreements described in Rule 192.3(g) of the
Texas Rule: of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements.
A party may obtain discovery of the existence and contents of any relevant portions of a
settlement agreement

(Check one)

(J The Parties have not entered into any active settlement agreements that would resolve, or
partially resolve, the disputed issues in this case. This Response will be amended, as needed.

CJ Any active settlement agreements that would resolve, or partially resolve, the disputed
issues in this case are attached. This Response will be amended, as needed

9. Witness statements
See Texas Rule of Civil Procedure 194.2(b)(9).

Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas
Rules of Civil Procedure

(Check one)

CD Attached to this response are copies of any witness statements that have been made by
any of the individuals identified in the fifth response above. This Response will be amended, as
needed, as qualifying witness statements are discovered or obtained in this case.

J No witness statements are available at this time. This Response will be amended, as
needed, as qualifying witness statements are discovered or obtained in this case.

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 4 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

10. Medical records or bills.
See Texas Rule of Civil Procedure 194.2(b)(10).

Produce copies of all medical records and bills that are reasonably related to the injuries
or damages asserted or, in lieu thereof, an authorization permitting the disclosure of
such medical records and bills

At the time of this initial response, this family law case does not allege physical or mental injury,
and therefore is not requesting damages resulting from any physical or mental injury. Therefore
no response to this request is needed at this time. This Response will be amended, as needed.

11. Medical records or bills from 3rd party authorizations.
See Texas Rule of Civil Procedure 194.2(b)(11).

Produce copies of all medical records and bills that you have obtained by using an authorization
that the other party gave you

At the time of this initial response, this family law case does not allege physical or mental injury,
and therefore is not requesting damages resulting from any physical or mental injury. No
response to this request is needed at this time. This Response will be amended, as needed.

12. Responsible 3rd parties.
See Texas Rule of Civil Procedure 194.2(b)(12).

State the name, address, and telephone number of any person who may be designated as a
responsible third party

At the time of this initial response no responsible third parties have been identified. This
Response will be amended, as needed.

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 5 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

Required Initial Disclosures for Family Law Cases

See Texas Rule of Civil Procedure 194.2(c).

1. Information Related to Real Property
See Texas Rule of Civil Procedure 194.2(c)(1)(A)

You need to gather documents related to real property. Give your spouse:

° All deed and lien information on any real property owned, and
. All lease information on any real property leased

You will need information that goes back for the past two years, unless you have been married
less than two years. If you have been married less than two years, you give your spouse
documents going back to the date you got married

This can include things like deeds, closing documents, and mortgage statements. And you
need to include documents related to property you owned before the marriage or inherited

If you do not have access to the accounts, and your name is on the account, you need to make
a good faith effort to get the documents. For example, you can reach out to the title company
landlord, or lender.

Home
Closing Mortgage Equity Loc Lease
Documents Statements documents documents
attached attached attached Date of attached?
Property Address/Location (YIN) (YIN) (YIN) Purchase | (Y/N)

2. Information Related to Pensions and Retirement (including SEP/IRA, IRA's, 401k
accounts, profit-sharing or other employee benefit plan)
See Texas Rule of Civil Procedure 194.2(c)(1)(B).

If you do not have access to the accounts and your name is on the account, make all efforts to get
the documents. You will need information that goes back for the past two years, unless you have
been married less than two years. If you have been married less than two years, you give your
spouse documents going back to the date you got married.

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 6 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

Company name/Financial Last four digits of Description of Current
Institution Name Account No. documents Balance/Date

3. Insurance Policies: Life, Homeowners, Automobile and Health
See Texas Rule of Civil Procedure 194.2(c)(1)(C).

Declaration
Page Invoices for
Last four digits attached to premiums Name of
Insurance company Type of of policy this form? attached to person
name coverage number (YIN) this form? who pays

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 7 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

4. Information Related to Bank Accounts
See Texas Rule of Civil Procedure 194.2(c)(1)(D).

Name of Bank, Federal Credit
Union, Savings and Loans, Last four digits of Description of Current
Brokerage Firms account number documents Balance/Date

5. Health Insurance Policies available for child(ren) and spouses
See Texas Rule of Civil Procedure 194.2(c)(2)(A)

In a suit in which child or spousal support is at issue, a party must, without awaiting a discovery
request, provide to the other party: (A) information regarding all policies, statements, and the
summary description of benefits for any medical and health insurance coverage that is or would
be available for the child or the spouse).
If you do not have access to the accounts and your name is on the account, make all efforts to get
the documents. You will need information that goes back for the past two years, unless you have
been married less than two years. If you have been married less than two years, you give your
spouse documents going back to the date you got married.

Declaration
Page/Premium
invoices Name of
Last four digits | Type of attached? person who
Insurance company name of policy no. Coverage (Y/N) pays

FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
© TexasLawHelp.org Page 8 of 9
DO NOT FILE THIS DOCUMENT WITH THE COURT.

6. Federal Income Tax Information
See Texas Rule of Civil Procedure 194.2(c)(2)(B).

If child support, spousal support, or both are part of this case: Attach two years of returns (if you do not
have possession of the return, log into www.irs.gov and request a copy of the transcript AND the return)

Have you attached it? Y/N (circle one)

Attach IRS Form W-2's, IRA Form 1099's and Schedule K-1 for the previous two years

Have you attached it? Y/N (circle one)

7. Payroll Information
See Texas Rule of Civil Procedure 194.2(c)(2)(C).

If child support, spousal support, or both are part of this case: Produce complete copies of your two most
recent payroll check stubs (log into your employee account, request from your human resources
department, request from company office manager/bookkeeper).

Have you attached it? Y/N (circle one)

Signature.

| have completed the required disclosures and | have served them on my spouse.

Your signature: _y\5 Doe nte
Your printed name: Luis Puente
Certificate of Service

| certify that a copy of the Required Disclosures and attached documents were served on my
spouse, Rachel Ann Puente (name of your spouse) on
B~b- 2032 (date), by (Check all that apply):

( electronic file manager (e-filing)
C email
(1 first class (regular) U.S. Mail
LC certified U.S. Mail
LU registered U.S. Mail (date).
O by fax, to (number).
{Personal delivery by (fheymy agent) (circle one).
(1 commercial courier defivery service (such as Federal Express).
LO giving a copy to my spouse’s lawyer, (lawyer's name)
via one of the above methods.

huis Cuente.
Your signature

For full print and download access, please subscribe at https://www.trellis.law/.

Family Matters: In the Matter of the Marriage of Rachel Ann Puente and Luis Puente

Preview

Case Info

Parties

Family Matters: In the Matter of the Marriage of Rachel Ann Puente and Luis Puente

Preview

Related Topics

Case Info

Parties