On August 24, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Vaughan, Daniel & Karen,
and
Vaughn, Aaron,
Vaughn, Lacy,
for Modify - Custody
in the District Court of Smith County.
Preview
Electronically Filed
9/11/2014 2:30:53 PM
Lois Rogers, Smith County District Clerk
Reviewed By: Lois Rogers
CAUSE NO. 12-2355-D
IN THE INTEREST 0F § IN THE 3215‘” JUDICIAL DISTRICT
§
TRISTAN VAUGHAN, TANNER
VAUGHAN, TARIN GAUHJAM AND
TRINITY VAUGHAN § COURT IN AND FOR
§
CHILDREN § SMITH COUNTY, TEXAS
MOTION FOR PSYCHOLOGICAL EVALUATIONS
NOW COMES, AARON VAUGHAN and LACY VAUGHAN and files this
Motion for Psychological Evaluations and would respectfully request that this
Honorable Court order as follows:
I.
Movants, requests the Court to order the Psychological Evaluation of Dan
Vaughan; Karen Vaughan, Michael Broyles and Kristin Broyles. The Court
continually refers to the Psychological Evaluations of the parents. In that the
Petitioners and Interveners seek to be conservators and have primary possession of
the children the Court should have the benefit of Psychological Evaluations of those
parties. The undersigned will certify to the Court that he attempted to resolve this
via conference and in good faith but the ofi'er and suggestion was rejected so this
motion is being filed only after such conference took place (see letters attached
hereto). Movants request that the Court order the Psychological Evaluations to be
performed by Dr. Donald Winsted, PhD, in Longview, Texas and that Dan Vaughan,
Karen Vaughan, Michael Broyles and Kristin Broyles be ordered to attend and
participate in said evaluations.
Respectfully submitted.
LAW OFFICES OF RIC FREEMAN
621 Chase Drive, Suite B
Tyler, Texas 75701
'RIC F EMAN
State ar No. 07425450
Attorney for Aaron Vaughan
Respectfully submitted.
LAW OFFICES OF ROB FOSTER
227 East Tyler Street
Longview, Texas 75601
Tel (903)236 3777
yROB
V
FOSTER
State Bar No. 07295200
Attorney for Lacy Vaughan
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or
party in accordance with the Texas Rules of Civil Proc e on September 11, 2014.
A
m0 FREEMAN
.\ [A
Attorney for Aaron Vaughan
LAW OFFICES OF
Jolm E. ”R1'c”17}'eeman
621 Chase Drive, Suite B
Tyler, Texas 75701
RIC FREEMAN
LEGAL ASSISTANT TEL! (903)595-2070
AMANDA HENSON FAX: (903)595'1970
CREDE' OWENS
September 9, 2014
Via Facsimile fiansmission
Mr. Mike Hogan, Attorney at Law
(903)597-3870
Via Facsimile fiansmission
Mrs. Alicia Barkley, Attorney at Law
(903)597-5664
M Cause No. 12-2355-D; Vaughan Matter
Dear Counseli
In reviewing the file it appears t0 me that your clients have never had psychological
evaluations by Dr. Winstead. Please consider this my Certificate 0f Conference on this issue
and I am happy to discuss the same by phone so that we have satisfied the Judge’s
requirements. However, ifyour clients will not agree to itwe will ask that that be addressed
at the hearing that is scheduled for October 7, 2014.
urs very truly,
Igch’w
FREEMAN
0
cc- Client
Mr. Matthew 'I‘higpen, Attorney at Law
(903)705-7221
Mr. Rob Foster, Attorney at Law
Sen. l0. 2014 1:49PM Lav Utnce U! Alma oarxley no.3“; u. u;
LAW OFFICES OF ALICIA BARKLEY, P.C.
217 w. Houston Street
Tyler, Texas 75702
Phone: (903) 597-5683
Fax: (903) 597.5864
Email: Alicia@Nicia cashell.com
September IO, 2014
VIATELE-COPIER VIA TELE-COPmR
(903) 595-1970 (903) 757-8137
Ric Freeman Rob Foster
621 Chase Dr. 227 East Tyler Street
Tylcr, Texas 75713 Longview, Texas 75601
RE: NO. 12-2355-D; ITIO VAUGHAN CHILDREN; IN THE 321” JUDICIAL
DISTRICT COURT, SMTH COUNTY. TEXAS
Dear Mr. Freeman:
My clients and I have reviewed your letter of this date and would advise that my clients
are not in ageement to submit to psychological evaluations. These children have lived with my
clients since Child Protective Services and Judge Clark placed them in their home. The parents
requwted that the childxen he placed with my clients. [believe if Judge Clark had any
have
reservations about these children being with Dan and Karen Vaughan, she never would
placed them there in the first place. Additionally, this case has already been a huge financial
dollars
hardship. Your client has still not paid my clients the twenty-five thousand ($25,000.00)
that he was ordered to pay them for reimbursement of attorney fees.
If you insist upon my clients submitting to a psychological, the Court will have to make
that ruling.
Sincerely.
fa
Alicia Barkley
ABzwc
cc: Dan and Karen Vaughan
Document Filed Date
September 11, 2014
Case Filing Date
August 24, 2012
Category
Modify - Custody
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Filed 9/11/2014 2:30:53 PM Lois Rogers, Smith County District Clerk Reviewed By: Lois Rogers CAUSE NO. 12-2355-D IN THE INTEREST 0F § IN THE 3215‘” JUDICIAL DISTRICT § TRISTAN VAUGHAN, TANNER VAUGHAN, TARIN GAUHJAM AND TRINITY VAUGHAN § COURT IN AND FOR § CHILDREN § SMITH COUNTY, TEXAS MOTION FOR PSYCHOLOGICAL EVALUATIONS NOW COMES, AARON VAUGHAN and LACY VAUGHAN and files this Motion for Psychological Evaluations and would respectfully request that this Honorable Court order as follows: I. Movants, requests the Court to order the Psychological Evaluation of Dan Vaughan; Karen Vaughan, Michael Broyles and Kristin Broyles. The Court continually refers to the Psychological Evaluations of the parents. In that the Petitioners and Interveners seek to be conservators and have primary possession of the children the Court should have the benefit of Psychological Evaluations of those parties. The undersigned will certify to the Court that he attempted to resolve this via conference and in good faith but the ofi'er and suggestion was rejected so this motion is being filed only after such conference took place (see letters attached hereto). Movants request that the Court order the Psychological Evaluations to be performed by Dr. Donald Winsted, PhD, in Longview, Texas and that Dan Vaughan, Karen Vaughan, Michael Broyles and Kristin Broyles be ordered to attend and participate in said evaluations. Respectfully submitted. LAW OFFICES OF RIC FREEMAN 621 Chase Drive, Suite B Tyler, Texas 75701 'RIC F EMAN State ar No. 07425450 Attorney for Aaron Vaughan Respectfully submitted. LAW OFFICES OF ROB FOSTER 227 East Tyler Street Longview, Texas 75601 Tel (903)236 3777 yROB V FOSTER State Bar No. 07295200 Attorney for Lacy Vaughan Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Proc e on September 11, 2014. A m0 FREEMAN .\ [A Attorney for Aaron Vaughan LAW OFFICES OF Jolm E. ”R1'c”17}'eeman 621 Chase Drive, Suite B Tyler, Texas 75701 RIC FREEMAN LEGAL ASSISTANT TEL! (903)595-2070 AMANDA HENSON FAX: (903)595'1970 CREDE' OWENS September 9, 2014 Via Facsimile fiansmission Mr. Mike Hogan, Attorney at Law (903)597-3870 Via Facsimile fiansmission Mrs. Alicia Barkley, Attorney at Law (903)597-5664 M Cause No. 12-2355-D; Vaughan Matter Dear Counseli In reviewing the file it appears t0 me that your clients have never had psychological evaluations by Dr. Winstead. Please consider this my Certificate 0f Conference on this issue and I am happy to discuss the same by phone so that we have satisfied the Judge’s requirements. However, ifyour clients will not agree to itwe will ask that that be addressed at the hearing that is scheduled for October 7, 2014. urs very truly, Igch’w FREEMAN 0 cc- Client Mr. Matthew 'I‘higpen, Attorney at Law (903)705-7221 Mr. Rob Foster, Attorney at Law Sen. l0. 2014 1:49PM Lav Utnce U! Alma oarxley no.3“; u. u; LAW OFFICES OF ALICIA BARKLEY, P.C. 217 w. Houston Street Tyler, Texas 75702 Phone: (903) 597-5683 Fax: (903) 597.5864 Email: Alicia@Nicia cashell.com September IO, 2014 VIATELE-COPIER VIA TELE-COPmR (903) 595-1970 (903) 757-8137 Ric Freeman Rob Foster 621 Chase Dr. 227 East Tyler Street Tylcr, Texas 75713 Longview, Texas 75601 RE: NO. 12-2355-D; ITIO VAUGHAN CHILDREN; IN THE 321” JUDICIAL DISTRICT COURT, SMTH COUNTY. TEXAS Dear Mr. Freeman: My clients and I have reviewed your letter of this date and would advise that my clients are not in ageement to submit to psychological evaluations. These children have lived with my clients since Child Protective Services and Judge Clark placed them in their home. The parents requwted that the childxen he placed with my clients. [believe if Judge Clark had any have reservations about these children being with Dan and Karen Vaughan, she never would placed them there in the first place. Additionally, this case has already been a huge financial dollars hardship. Your client has still not paid my clients the twenty-five thousand ($25,000.00) that he was ordered to pay them for reimbursement of attorney fees. If you insist upon my clients submitting to a psychological, the Court will have to make that ruling. Sincerely. fa Alicia Barkley ABzwc cc: Dan and Karen Vaughan