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NO. 16-07015-158
IN THE INTEREST OF IN THE DISTRICT COURT
K.E.A. and R.A.A, 158TH JUDICIAL DISTRICT
MINOR CHILDREN DENTON COUNTY, TEXAS
PETITION TO MODIFY PARENT-CHILD RELATIONSHIP
AND MOTION TO APPOINT PARENT FACILITATOR
i Discovery Level
Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas
Rules of Civil Procedure.
2. Parties and Order to Be Modified
This suit to modify a prior order is brought by STEPHANIE MARIE ADAMS, Petitioner.
The last three numbers of STEPHANIE MARIE ADAMS's driver's license number are XXX. The
last three numbers of STEPHANIE MARIE ADAMS's social security number are xxx-657.
Petitioner is the mother of the children and has standing to bring this suit. The requested
modification will be in the best interest of the children.
Respondent is KEVIN JAMES ADAMS.
The order to be modified is entitled Final Decree of Divorce and was rendered on
November 28, 2017.
3. Jurisdiction
This Court has continuing, exclusive jurisdiction of this suit.
Children
The following children are the subject of this suit:
Name: KARIS ELIVIAN ADAMS (hereinafter “K.E.A.”)
Sex: Female
Birth date: 10/16/2009
PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 1
County of residence: Denton
Name: RIVEN A. ADAMS (hereinafter “R.A.A.”)
Sex: Female
Birth date: 09/21/2015
County of residence: Denton
Parties Affected
The following parties may be affected by this suit:
Name: KEVIN ADAMS
Relationship: Father
No service is necessary at this time.
6. Health Insurance Information
Information required by section 154.181(b) of the Texas Family Code is provided through
Petitioner’s employer and will be supplemented.
7 Children's Property
There has been no change of consequence in the status of the children's property since the
prior order was rendered.
8 Modification of Conservatorship, Possession and Access
The circumstances of the children, a conservator, or other party affected by the order to be
modified have materially and substantially changed since the date of rendition of the order to be
modified. The Final Decree was entered in November 2017. Dr. Michelle Greer was appointed as
a therapist for Petitioner, STEPHANIE MARIE ADAMS. Petitioner has been meeting with Dr.
Greer for Cognitive Behavior Therapy. Petitioner has been paying 100% of the costs to meet with
Dr. Greer.
PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 2
Dr. Greer has recommended that the parties would benefit from a Parent Facilitator being
appointed. Dr. Greer believes that a Parent Facilitator could improve the parties ability to
communicate and provide a platform for long term accountability.
Petitioner requests that the Court appoint a Parent Facilitator. Petitioner requests that the
parties split the costs 50/50.
The requested modification is in the best interest of the child.
9. Request for Temporary Orders
Petitioner requests the Court, after notice and hearing, to make temporary orders for the
safety and welfare of the child, including but not limited to the following:
Appointing a Parent Facilitator for the parties and splitting the costs 50/50.
10. Denton County Standing Orders
Petitioner requests the Court to make the Denton County Standing Order a mutual
injunction. A copy of the Denton County Standing Order is attached hereto as Exhibit A and is
incorporated herein by reference.
11. Prayer
Petitioner prays that citation and notice issue as required by law and that the Court enter
its orders in accordance with the allegations contained in this petition.
Petitioner prays for general relief.
Respectfully submitted,
ORSINGER, NELSON, DOWNING
& ANDERSON, L.L.P.
5950 Sherry Lane, 8th Floor
Dallas, Texas 75225
Tel: (214) 273-2400
Fax: (214) 273-2470
PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page3
|
By:
LO M. Li ‘LESS
State Bar No. 24043792
lon@ondafamilylaw.com
Attorney for STEPHANIE MARIE ADAMS
PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 4
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ENTON COUNTY STANDING ORDER REGARDING 7
CHILDREN, PROPERTY AND CONDUCT OF THE PARTIES %
_
THIS DENTON COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY AN 7
OF THE PARTIES IS BINDING ON (1) THE PARTIES, (2) THE PARTIES’ OFFICERS, AGENTS, lee
EMPLOYEES, AND ATTORNEYS, AND (3) ANY OTHER PERSON WHO ACTS IN CONCERT W. HE
PARTIES OR THEIR AGENTS AND WHO RECEIVES ACTUAL NOTICE OF THESE ORDERS, $D IS
ENFORCEABLE BY CONTEMPT, INCLUDING A FINE OF UP TO $500, CONFINEMENT IN THE COUNTY
JAIL FOR SIX MONTHS, OR BOTH SUCH A FINE AND CONFINEMENT IN JAIL FOR EACH VIOLATION,
AND A MONEY JUDGMENT FOR PAYMENT OF ATTORNEY’S FEES AND COURT COSTS.
No party to this lawsuit has requested this order. Rather, this order is a standing order of the Denton County District
Courts that applies in every divorce suit and every suit affecting the parent-child relationship, including a suit for
modification or enforcement of a prior order, filed in Denton County, Texas. The Denton County District Courts have
adopted this order pursuant to Texas Family Code §§6.501-6.503, 105.001, and 105.009 because the parties and their
children should be protected and their property preserved while the lawsuit is pending before the court. IT IS THEREFORE
ORDERED:
1 NO DISRUPTION OF CHILDREN, All parties are ORDERED to refrain from doing the following acts
concerning any children who are subjects of this cause:
1 Removing the children from the State of Texas for the purpose of changing the children’s domicile or
residence, acting directly or in concert with others, without the written agreement of all parties or an order
of this Court; provided, however, that this paragraph shall not prohibit or restrict a party from so removing
the children if an active prior court order gives that party the right to designate the children’s primary
residence outside the State of Texas or without regard to geographic location.
12 Disrupting or withdrawing the children from the school or day-care facility where the children are presently
enrolled without the written agreement of all parties or an order of this Court; provided, however, that this
paragraph shall not prohibit or restrict a party from so withdrawing the children from a school or day-
facility if that party is changing the children's domicile or residence within that party’s rights pursuant to an
active prior court order as described in §1.1 above.
13 Hiding or secreting the children from any other party.
1.4 Changing the children’s current place of abode without the written agreement of all parties or an order of
this Court; provided, however, that this paragraph shall not prohibit or restrict a party from changing such
place of abode if an active prior court order gives that party the right to designate the children’s primary
residence without geographic restriction, or if the new place of abode lies within the geographic limits
established by that active prior court order.
LS Disturbing the peace of the children.
1.6 Making disparaging remarks about another party or another party’s family members, including but not
limited to the child’s grandparents, aunts, uncles, stepparents, or anyone with whom the party has a dating
relationship.
17 Discussing with the children, or with any other person in the presence of thechildren, any litigation related
to the children or the other party.
18 f this is an original divorce action, allowing anyone with whom the party has a dating relationship to be in
the same dwelling or on the same premises overnight while in possession of the child. Overnight is defined
from 10:00 p.m. until 7:00 a.m.
2 CONDUCT OF THE PARTIES DURING THE CASE. All parties are ORDERED to refrain from doing the
following acts with the intent to harass, annoy, alarm, abuse, torment, or embarrass another party:
21 Using vulgar, profane, obscene, coarse, offensive, or indecent language to communicate with another party,
whether in person, by telephone, or in writing, including by email, text message, or any other electronic
communication,
2.2 Threatening another party in person, by telephone, or in writing, including by email, text message, or any
other electronic communication, to take unlawful action against the party, a member of the party’s family,
including but not limited to anyone with whom the party has a dating relationship, or the party’s property.
2.3 Placing or transmitting one or more telephone calls, emails, text messages, or other electronic
communications to another party at an unreasonable hour, in an offensive or repetitious manner,
anonymously, or without a legitimate purpose of communication.
EXHIBIT
Denton County Standing Order Regard
Children, Property and Conduct of the Parties 1/09/17 Page I of4
ee
3. PRESERVATION OF PROPERTY AND USE OF FUNDS DURING DIVORCE CASE. If this is a divorce
case, both parties to the marriage are ORDERED to refrain from the following conduct:
3.1 Destroying, removing, concealing, encumbering, transferring, or otherwise harming or reducing the value
of the property of one or both of the parties, regardless of whether it is intellectual, personal, or real
property and regardless of whether it is claimed as separate or community property.
3.2 Misrepresenting or refusing to disclose to the other party or to the Court, on proper request, the existence,
amount, or location of any property, including electronically stored or recorded information, of one or both
of the parties, regardless of whether it is intellectual, personal, or real property and regardless of whether it
is claimed as separate or community property.
3.3 Damaging, destroying or tampering with the tangible or intellectual property of one or both of the parties,
including any document or electronically stored or recorded information that represents or embodies
anything of value, regardless of whether it is intellectual, personal, or real property and regardless of
whether it is claimed as separate or community property.
3.4 Selling, transferring, assigning, mortgaging, encumbering, or in any other manner alienating any of the
property of either party, regardless of whether it is intellectual, personal, or real property and regardless of
whether it is claimed as separate or community property, except as specifically authorized by this order or a
subsequent order of this Court.
3.5 Incurring any indebtedness, including cash advances from a credit card or line of credit, other than legal
expense in connection with this suit, except as specifically authorized by this order or a subsequent order of
this Court.
3.6 Making withdrawals from any account in any financial institution for any purpose, except as specifically
authorized by this order or a subsequent order of this Court.
3.7 Spending any sum of cash in either party’s possession or subject to either party’s control for any purpose,
except as specifically authorized by this order or a subsequent order of this Court.
3.8 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 or a subsequent order of this Court.
3.9 Signing or endorsing the others 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. This includes affixing the other party’s
digital signature to any electronic document.
3.10 Taking any action to terminate, close, restrict, or limit lines of credit, credit cards, charge cards, or financial
accounts in the name of or subject to the control of the other party, whether owned individually or jointly,
except by subsequent court order or written agreement signed by each party permitting such action.
3.11 Entering, operating, or exercising control over the motor vehicle in the possession of the other party.
3.12 Discontinuing or altering the withholding for federal income taxes on wages or salary while this suit is
pending.
3.13 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 the other
party’s residence or in any manner attempting to withdraw any deposits for service in connection with such
services.
3.14 Unlawfully intercepting or recording the other party’s electronic communications.
3.15 Opening or diverting mail, email, or any other electronic communication addressed to the other party.
3.16 Excluding a spouse from the use and enjoyment of the marital residence in which the spouse had been
residing within the thirty (30) day period prior to the date the original petition for divorce was filed.
3.17 Communicating with the other party’s employer or a person with whom the other party has a business
relationship without a legitimate purpose.
3.18. Entering any safe deposit box in the name of or subject to the control of a party, whether owned
individually or jointly, except by subsequent court order or written agreement signed by each party
permitting such entrance.
3.19 Destroying, disposing of, or altering any e-mail, text message, video message, or chat message or other
electronic data or electronically stored information relevant to the subject matter of the divorce suit,
regardless of whether the information is stored on a hard drive, in a removable storage device, in cloud
storage, or in another electronic storage medium.
320 Modifying, changing, or altering the native format or metadata of any electronic data or electronically
stored information relevant to the subject matter of the suit for dissolution of marriage, regardless of
whether the information is stored on a hard drive, in a removable storage device, in cloud storage, or in
another electronic storage medium. This prohibition shall likewise apply to any suit affecting the parent-
Denton County Standing Order Regarding
Children, Property and Conduct of the Patties 1/09/17 Poge2 of4
vee
child relationship with regard to any electronic data or electronically stored information relevant to the
subject matter of the suit affecting the parent-child relationship.
3.21 Deleting any data or content from any social network profile used or created by either party or a child of
the parties.
3.22 Using any password or personal identification number to gain access to the other party’s email account,
bank account, social media account, or any other electronic account.
4. PERSONAL AND BUSINESS RECORDS IN DIVORCE CASE. If this is a divorce case, both parties to the
marriage are ORDERED to refrain from doing the following act
41 Concealing, destroying, disposing of, or altering any of the parties’ family records, property records,
financial records, business records or any records of income, debts, or other obligations, including, but not
limited to, a canceled check, deposit slip, other records from a financial institution, records of credit
purchases or cash advances, tax returns, and financial statements.
42 Falsifying any writing or record relating to the property of either party.
43 “Records” includes e-mail or other digital or electronic data, whether stored on a computer hard drive,
diskette or other electronic storage device.
5. INSURANCE IN DIVORCE CASE, If this is a divorce case, both parties to the marriage are ORDERED to refrain
from doing the following acts, except by written agreement signed by each party permitting such acts:
5.1 Withdrawing or borrowing in any manner all or any part of the cash surrender value of life insurance
policies on the life of either party, except as specifically authorized by this order or a subsequent order of
this Court.
5.2 Changing or in any manner altering the beneficiary designation on any life insurance on the life of either
party or the parties’ children.
53 Canceling, altering, or in any manner affecting any casualty, automobile, or health insurance policies
insuring the parties’ property or persons including the parties’ minor children.
6. SPECIFIC AUTHORIZATIONS IN DIVORCE CASE. If this is a divorce case, both parties to the marriage are
specifically authorized to do the following:
6.1 To engage in acts reasonably and necessary to the conduct of that party’s usual business and occupation.
6.2 To make expenditures and incur indebtedness for reasonable attorney’s fees and expenses in connection
with this suit.
63 To make expenditures and incur indebtedness for reasonable and necessary living expenses commensurate
with such expenditures and indebtedness incurred for the past six months.
6.4 To make withdrawals from accounts in financial institutions only for the purposes authorized by this order.
SERVICE AND APPLICATION OF THIS ORDER.
7 The Petitioner shall attach a copy of this order to the original petition and to each copy of the petition. At
the time an original petition is filed by non-electronic means, ifthe Petitioner has failed to attach a copy of
this order to the petition and any copy of the petition, the Clerk shall ensure that a copy of this order is
attached to the petition and every copy of the petition presented. At the time an original petition is filed
electronically, if the Petitioner has failed to attach a copy of this order to the petition and any copy of the
petition, the Clerk shall decline to issue citation until the petition is resubmitted with a copy of this order
attached in conformity with this section. Additionally, the Court may decline to grant temporary ex parte
relief, decline to set a hearing in the case, or strike the petition without further notice i the Petitioner fails
to resubmit the petition with a copy of this order attached in conformity with this section.
72 This order is effective upon the filing of the original petition and shall remain in full force and effect as a
temporary restraining order for fourteen days after the date of the filing of the original petition. The
requirement of a bond is waived. If, after service, no party contests this order by presenting evidence at a
hearing on or before fourteen days after the date of service of the original petition, this order shall continue
in full force and effect as a temporary injunction until further order of this court. This entire order will
terminate and will no longer be effective only upon further order of the court, entry of a final order or
dismissal of the case.
73 In addition to any other remedies available for the enforcement of this order, at the Court’s discretion, the
Court may award reasonable and necessary attorney fees and court costs against a party found to have
violated a provision of this order.
Denton County Standing Order Regarding
Children, Property and Conduct of the Parties 1/09/17 Poge 3 of4
1%
8. EFFECT OF OTHER COURT ORDERS. If any part of this order is different from any part of a protective order
that has already been entered or is later entered, the protective order provisions prevail. Any part of this order not changed by
some later order remains in full force and effect until the court signs a final decree.
9. PARTIES ENCOURAGED TO MEDIATE/COLLABORATE. The parties are encouraged to settle their
disputes amicably without court intervention. The parties are encouraged to use alternative dispute resolution methods, such
as mediation or the collaborative law process, to resolve the conflicts that may arise in this lawsuit.
10. PARENT EDUCATION AND STABILIZATION. f this is a suit a ing or seeking modification of the nt
child relationship, all parties are ORDERED to attend one of the following parent education and stabilization programs
within sixty (60) days of the date of filing or service of the suit, as applicable:
10.1 Children in the Middle (www.childreninthemiddle.com or 800-239-3971).
10.2 Divorce Sanity Co-Parenting (www.ccdcounseling.com/divorce-sanity or 800-897-7068).
10.3 Crossroads of Parenting & Divorce (www.patschanz.com/co-parenting or 940.453.8700).
Waiver of the requirement that both parents shall complete a parent education and stabilization program may only be
granted by order of the court. Completion of online programs or programs not listed above will not be accepted without prior
approval by the court for good cause shown. Proof of completion of the program must be filed with the court upon meeting
this requirement. Failure to provide such proof in a timely manner may result in the cancellation of any scheduled hearing or
trial and denial of requested relief at the Court’s discretion.
THIS DENTON COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY AND CONDUCT
OF THE PARTIES IS EFFECTIVE IN EVERY DIVORCE SUIT AND EVERY SUIT AFFECTING THE PARENT-
CHILD RELATIONSHIP, INCLUDING A SUIT FOR MODIFICATION OR ENFORCEMENT OF A PRIOR
ORDER, FILED ON OR AFTER JANUARY 20, 2017.
'Y SHIPMAN
AY SS \WS SS TS
BY
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NO. 16-07015-158 IN THE INTEREST OF IN THE DISTRICT COURT K.E.A. and R.A.A, 158TH JUDICIAL DISTRICT MINOR CHILDREN DENTON COUNTY, TEXAS PETITION TO MODIFY PARENT-CHILD RELATIONSHIP AND MOTION TO APPOINT PARENT FACILITATOR i Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Parties and Order to Be Modified This suit to modify a prior order is brought by STEPHANIE MARIE ADAMS, Petitioner. The last three numbers of STEPHANIE MARIE ADAMS's driver's license number are XXX. The last three numbers of STEPHANIE MARIE ADAMS's social security number are xxx-657. Petitioner is the mother of the children and has standing to bring this suit. The requested modification will be in the best interest of the children. Respondent is KEVIN JAMES ADAMS. The order to be modified is entitled Final Decree of Divorce and was rendered on November 28, 2017. 3. Jurisdiction This Court has continuing, exclusive jurisdiction of this suit. Children The following children are the subject of this suit: Name: KARIS ELIVIAN ADAMS (hereinafter “K.E.A.”) Sex: Female Birth date: 10/16/2009 PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 1 County of residence: Denton Name: RIVEN A. ADAMS (hereinafter “R.A.A.”) Sex: Female Birth date: 09/21/2015 County of residence: Denton Parties Affected The following parties may be affected by this suit: Name: KEVIN ADAMS Relationship: Father No service is necessary at this time. 6. Health Insurance Information Information required by section 154.181(b) of the Texas Family Code is provided through Petitioner’s employer and will be supplemented. 7 Children's Property There has been no change of consequence in the status of the children's property since the prior order was rendered. 8 Modification of Conservatorship, Possession and Access The circumstances of the children, a conservator, or other party affected by the order to be modified have materially and substantially changed since the date of rendition of the order to be modified. The Final Decree was entered in November 2017. Dr. Michelle Greer was appointed as a therapist for Petitioner, STEPHANIE MARIE ADAMS. Petitioner has been meeting with Dr. Greer for Cognitive Behavior Therapy. Petitioner has been paying 100% of the costs to meet with Dr. Greer. PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 2 Dr. Greer has recommended that the parties would benefit from a Parent Facilitator being appointed. Dr. Greer believes that a Parent Facilitator could improve the parties ability to communicate and provide a platform for long term accountability. Petitioner requests that the Court appoint a Parent Facilitator. Petitioner requests that the parties split the costs 50/50. The requested modification is in the best interest of the child. 9. Request for Temporary Orders Petitioner requests the Court, after notice and hearing, to make temporary orders for the safety and welfare of the child, including but not limited to the following: Appointing a Parent Facilitator for the parties and splitting the costs 50/50. 10. Denton County Standing Orders Petitioner requests the Court to make the Denton County Standing Order a mutual injunction. A copy of the Denton County Standing Order is attached hereto as Exhibit A and is incorporated herein by reference. 11. Prayer Petitioner prays that citation and notice issue as required by law and that the Court enter its orders in accordance with the allegations contained in this petition. Petitioner prays for general relief. Respectfully submitted, ORSINGER, NELSON, DOWNING & ANDERSON, L.L.P. 5950 Sherry Lane, 8th Floor Dallas, Texas 75225 Tel: (214) 273-2400 Fax: (214) 273-2470 PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page3 | By: LO M. Li ‘LESS State Bar No. 24043792 lon@ondafamilylaw.com Attorney for STEPHANIE MARIE ADAMS PETITION TO MODIFY PARENT-CHILD RELATIONSHIP Page 4 Ye om % as of '% ¢ ENTON COUNTY STANDING ORDER REGARDING 7 CHILDREN, PROPERTY AND CONDUCT OF THE PARTIES % _ THIS DENTON COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY AN 7 OF THE PARTIES IS BINDING ON (1) THE PARTIES, (2) THE PARTIES’ OFFICERS, AGENTS, lee EMPLOYEES, AND ATTORNEYS, AND (3) ANY OTHER PERSON WHO ACTS IN CONCERT W. HE PARTIES OR THEIR AGENTS AND WHO RECEIVES ACTUAL NOTICE OF THESE ORDERS, $D IS ENFORCEABLE BY CONTEMPT, INCLUDING A FINE OF UP TO $500, CONFINEMENT IN THE COUNTY JAIL FOR SIX MONTHS, OR BOTH SUCH A FINE AND CONFINEMENT IN JAIL FOR EACH VIOLATION, AND A MONEY JUDGMENT FOR PAYMENT OF ATTORNEY’S FEES AND COURT COSTS. No party to this lawsuit has requested this order. Rather, this order is a standing order of the Denton County District Courts that applies in every divorce suit and every suit affecting the parent-child relationship, including a suit for modification or enforcement of a prior order, filed in Denton County, Texas. The Denton County District Courts have adopted this order pursuant to Texas Family Code §§6.501-6.503, 105.001, and 105.009 because the parties and their children should be protected and their property preserved while the lawsuit is pending before the court. IT IS THEREFORE ORDERED: 1 NO DISRUPTION OF CHILDREN, All parties are ORDERED to refrain from doing the following acts concerning any children who are subjects of this cause: 1 Removing the children from the State of Texas for the purpose of changing the children’s domicile or residence, acting directly or in concert with others, without the written agreement of all parties or an order of this Court; provided, however, that this paragraph shall not prohibit or restrict a party from so removing the children if an active prior court order gives that party the right to designate the children’s primary residence outside the State of Texas or without regard to geographic location. 12 Disrupting or withdrawing the children from the school or day-care facility where the children are presently enrolled without the written agreement of all parties or an order of this Court; provided, however, that this paragraph shall not prohibit or restrict a party from so withdrawing the children from a school or day- facility if that party is changing the children's domicile or residence within that party’s rights pursuant to an active prior court order as described in §1.1 above. 13 Hiding or secreting the children from any other party. 1.4 Changing the children’s current place of abode without the written agreement of all parties or an order of this Court; provided, however, that this paragraph shall not prohibit or restrict a party from changing such place of abode if an active prior court order gives that party the right to designate the children’s primary residence without geographic restriction, or if the new place of abode lies within the geographic limits established by that active prior court order. LS Disturbing the peace of the children. 1.6 Making disparaging remarks about another party or another party’s family members, including but not limited to the child’s grandparents, aunts, uncles, stepparents, or anyone with whom the party has a dating relationship. 17 Discussing with the children, or with any other person in the presence of thechildren, any litigation related to the children or the other party. 18 f this is an original divorce action, allowing anyone with whom the party has a dating relationship to be in the same dwelling or on the same premises overnight while in possession of the child. Overnight is defined from 10:00 p.m. until 7:00 a.m. 2 CONDUCT OF THE PARTIES DURING THE CASE. All parties are ORDERED to refrain from doing the following acts with the intent to harass, annoy, alarm, abuse, torment, or embarrass another party: 21 Using vulgar, profane, obscene, coarse, offensive, or indecent language to communicate with another party, whether in person, by telephone, or in writing, including by email, text message, or any other electronic communication, 2.2 Threatening another party in person, by telephone, or in writing, including by email, text message, or any other electronic communication, to take unlawful action against the party, a member of the party’s family, including but not limited to anyone with whom the party has a dating relationship, or the party’s property. 2.3 Placing or transmitting one or more telephone calls, emails, text messages, or other electronic communications to another party at an unreasonable hour, in an offensive or repetitious manner, anonymously, or without a legitimate purpose of communication. EXHIBIT Denton County Standing Order Regard Children, Property and Conduct of the Parties 1/09/17 Page I of4 ee 3. PRESERVATION OF PROPERTY AND USE OF FUNDS DURING DIVORCE CASE. If this is a divorce case, both parties to the marriage are ORDERED to refrain from the following conduct: 3.1 Destroying, removing, concealing, encumbering, transferring, or otherwise harming or reducing the value of the property of one or both of the parties, regardless of whether it is intellectual, personal, or real property and regardless of whether it is claimed as separate or community property. 3.2 Misrepresenting or refusing to disclose to the other party or to the Court, on proper request, the existence, amount, or location of any property, including electronically stored or recorded information, of one or both of the parties, regardless of whether it is intellectual, personal, or real property and regardless of whether it is claimed as separate or community property. 3.3 Damaging, destroying or tampering with the tangible or intellectual property of one or both of the parties, including any document or electronically stored or recorded information that represents or embodies anything of value, regardless of whether it is intellectual, personal, or real property and regardless of whether it is claimed as separate or community property. 3.4 Selling, transferring, assigning, mortgaging, encumbering, or in any other manner alienating any of the property of either party, regardless of whether it is intellectual, personal, or real property and regardless of whether it is claimed as separate or community property, except as specifically authorized by this order or a subsequent order of this Court. 3.5 Incurring any indebtedness, including cash advances from a credit card or line of credit, other than legal expense in connection with this suit, except as specifically authorized by this order or a subsequent order of this Court. 3.6 Making withdrawals from any account in any financial institution for any purpose, except as specifically authorized by this order or a subsequent order of this Court. 3.7 Spending any sum of cash in either party’s possession or subject to either party’s control for any purpose, except as specifically authorized by this order or a subsequent order of this Court. 3.8 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 or a subsequent order of this Court. 3.9 Signing or endorsing the others 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. This includes affixing the other party’s digital signature to any electronic document. 3.10 Taking any action to terminate, close, restrict, or limit lines of credit, credit cards, charge cards, or financial accounts in the name of or subject to the control of the other party, whether owned individually or jointly, except by subsequent court order or written agreement signed by each party permitting such action. 3.11 Entering, operating, or exercising control over the motor vehicle in the possession of the other party. 3.12 Discontinuing or altering the withholding for federal income taxes on wages or salary while this suit is pending. 3.13 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 the other party’s residence or in any manner attempting to withdraw any deposits for service in connection with such services. 3.14 Unlawfully intercepting or recording the other party’s electronic communications. 3.15 Opening or diverting mail, email, or any other electronic communication addressed to the other party. 3.16 Excluding a spouse from the use and enjoyment of the marital residence in which the spouse had been residing within the thirty (30) day period prior to the date the original petition for divorce was filed. 3.17 Communicating with the other party’s employer or a person with whom the other party has a business relationship without a legitimate purpose. 3.18. Entering any safe deposit box in the name of or subject to the control of a party, whether owned individually or jointly, except by subsequent court order or written agreement signed by each party permitting such entrance. 3.19 Destroying, disposing of, or altering any e-mail, text message, video message, or chat message or other electronic data or electronically stored information relevant to the subject matter of the divorce suit, regardless of whether the information is stored on a hard drive, in a removable storage device, in cloud storage, or in another electronic storage medium. 320 Modifying, changing, or altering the native format or metadata of any electronic data or electronically stored information relevant to the subject matter of the suit for dissolution of marriage, regardless of whether the information is stored on a hard drive, in a removable storage device, in cloud storage, or in another electronic storage medium. This prohibition shall likewise apply to any suit affecting the parent- Denton County Standing Order Regarding Children, Property and Conduct of the Patties 1/09/17 Poge2 of4 vee child relationship with regard to any electronic data or electronically stored information relevant to the subject matter of the suit affecting the parent-child relationship. 3.21 Deleting any data or content from any social network profile used or created by either party or a child of the parties. 3.22 Using any password or personal identification number to gain access to the other party’s email account, bank account, social media account, or any other electronic account. 4. PERSONAL AND BUSINESS RECORDS IN DIVORCE CASE. If this is a divorce case, both parties to the marriage are ORDERED to refrain from doing the following act 41 Concealing, destroying, disposing of, or altering any of the parties’ family records, property records, financial records, business records or any records of income, debts, or other obligations, including, but not limited to, a canceled check, deposit slip, other records from a financial institution, records of credit purchases or cash advances, tax returns, and financial statements. 42 Falsifying any writing or record relating to the property of either party. 43 “Records” includes e-mail or other digital or electronic data, whether stored on a computer hard drive, diskette or other electronic storage device. 5. INSURANCE IN DIVORCE CASE, If this is a divorce case, both parties to the marriage are ORDERED to refrain from doing the following acts, except by written agreement signed by each party permitting such acts: 5.1 Withdrawing or borrowing in any manner all or any part of the cash surrender value of life insurance policies on the life of either party, except as specifically authorized by this order or a subsequent order of this Court. 5.2 Changing or in any manner altering the beneficiary designation on any life insurance on the life of either party or the parties’ children. 53 Canceling, altering, or in any manner affecting any casualty, automobile, or health insurance policies insuring the parties’ property or persons including the parties’ minor children. 6. SPECIFIC AUTHORIZATIONS IN DIVORCE CASE. If this is a divorce case, both parties to the marriage are specifically authorized to do the following: 6.1 To engage in acts reasonably and necessary to the conduct of that party’s usual business and occupation. 6.2 To make expenditures and incur indebtedness for reasonable attorney’s fees and expenses in connection with this suit. 63 To make expenditures and incur indebtedness for reasonable and necessary living expenses commensurate with such expenditures and indebtedness incurred for the past six months. 6.4 To make withdrawals from accounts in financial institutions only for the purposes authorized by this order. SERVICE AND APPLICATION OF THIS ORDER. 7 The Petitioner shall attach a copy of this order to the original petition and to each copy of the petition. At the time an original petition is filed by non-electronic means, ifthe Petitioner has failed to attach a copy of this order to the petition and any copy of the petition, the Clerk shall ensure that a copy of this order is attached to the petition and every copy of the petition presented. At the time an original petition is filed electronically, if the Petitioner has failed to attach a copy of this order to the petition and any copy of the petition, the Clerk shall decline to issue citation until the petition is resubmitted with a copy of this order attached in conformity with this section. Additionally, the Court may decline to grant temporary ex parte relief, decline to set a hearing in the case, or strike the petition without further notice i the Petitioner fails to resubmit the petition with a copy of this order attached in conformity with this section. 72 This order is effective upon the filing of the original petition and shall remain in full force and effect as a temporary restraining order for fourteen days after the date of the filing of the original petition. The requirement of a bond is waived. If, after service, no party contests this order by presenting evidence at a hearing on or before fourteen days after the date of service of the original petition, this order shall continue in full force and effect as a temporary injunction until further order of this court. This entire order will terminate and will no longer be effective only upon further order of the court, entry of a final order or dismissal of the case. 73 In addition to any other remedies available for the enforcement of this order, at the Court’s discretion, the Court may award reasonable and necessary attorney fees and court costs against a party found to have violated a provision of this order. Denton County Standing Order Regarding Children, Property and Conduct of the Parties 1/09/17 Poge 3 of4 1% 8. EFFECT OF OTHER COURT ORDERS. If any part of this order is different from any part of a protective order that has already been entered or is later entered, the protective order provisions prevail. Any part of this order not changed by some later order remains in full force and effect until the court signs a final decree. 9. PARTIES ENCOURAGED TO MEDIATE/COLLABORATE. The parties are encouraged to settle their disputes amicably without court intervention. The parties are encouraged to use alternative dispute resolution methods, such as mediation or the collaborative law process, to resolve the conflicts that may arise in this lawsuit. 10. PARENT EDUCATION AND STABILIZATION. f this is a suit a ing or seeking modification of the nt child relationship, all parties are ORDERED to attend one of the following parent education and stabilization programs within sixty (60) days of the date of filing or service of the suit, as applicable: 10.1 Children in the Middle (www.childreninthemiddle.com or 800-239-3971). 10.2 Divorce Sanity Co-Parenting (www.ccdcounseling.com/divorce-sanity or 800-897-7068). 10.3 Crossroads of Parenting & Divorce (www.patschanz.com/co-parenting or 940.453.8700). Waiver of the requirement that both parents shall complete a parent education and stabilization program may only be granted by order of the court. Completion of online programs or programs not listed above will not be accepted without prior approval by the court for good cause shown. Proof of completion of the program must be filed with the court upon meeting this requirement. Failure to provide such proof in a timely manner may result in the cancellation of any scheduled hearing or trial and denial of requested relief at the Court’s discretion. THIS DENTON COUNTY STANDING ORDER REGARDING CHILDREN, PROPERTY AND CONDUCT OF THE PARTIES IS EFFECTIVE IN EVERY DIVORCE SUIT AND EVERY SUIT AFFECTING THE PARENT- CHILD RELATIONSHIP, INCLUDING A SUIT FOR MODIFICATION OR ENFORCEMENT OF A PRIOR ORDER, FILED ON OR AFTER JANUARY 20, 2017. 'Y SHIPMAN AY SS \WS SS TS BY