Appendix B

CAUSE NO. ________________

IN THE INTEREST OF:

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IN THE DISTRICT COURT OF

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§ HARRIS COUNTY, TEXAS

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A CHILD

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______ JUDICIAL DISTRICT

_________________________'S WRITTEN INTERROGATORIES TO

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES

To: TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, by and through its attorney of record, Steven Dieu, 2211 Norfolk Street, Suite 737, Houston, TX 77098

Under Rules 190 and 197 of the Texas Rules of Civil Procedure, you are required to answer in complete detail and in writing each of the attached interrogatories; sign your answers to the interrogatories; swear to the truth of your answers before a notary public or other judicial officer as required by Rules 191.3(a) and 197.2(d) of the Texas Rules of Civil Procedure; and deliver a complete, signed, and notarized copy of your answers to the undersigned attorney within thirty (30) days following service of this request. If you fail to comply with the requirements above, the Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure.

Definitions

"Identity and location" means the person's name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual.

"Person" includes and is intended to mean any natural person or the representative of any company, limited liability company, firm, non publicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.

"Entity" or "entities" includes and is intended to mean any company, limited liability company, firm, non publicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.

Instructions

All information that is not privileged that is in the possession, custody, or control of DFPS, its attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of DFPS is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item.

If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory.

Option to Produce Records

If the answer to an interrogatory may be derived or ascertained from public records, from your business records, or from a compilation, abstract, or summary of your business records, and the burden of deriving or ascertaining the answer is substantially the same for Respondent as for you, you may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract, or summary of the records. The records from which the answer may be derived or ascertained must be specified in sufficient detail to permit Respondent to locate and identify them as readily as you can. If you have specified business records, you must state a reasonable time and place for examination of the documents. You must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the Court, and must provide Respondent a reasonable opportunity to inspect them.

Respectfully submitted,

CONNOLLY & SHIREMAN, LLP

________________________________

William B. Connolly

State Bar No. 04702400

W. Leslie Shireman

State Bar No. 24047791

2211 Norfolk Street, Suite 737

Houston, Texas 77098

Telephone (713) 520-5757

Facsimile (713) 520-6644

ATTORNEY FOR ________________

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing ________________'s Written Interrogatories to Texas Department of Family and Protective Services was forwarded to:

on this the day of _______.

William B. Connolly