Appendix D

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

REQUEST FOR ADMISSIONS

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

Respondent, ________________, requests Petitioner, TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES (DFPS), to admit the truth of the matters, including statements of opinion or of the application of law to fact or the genuineness of any documents served with this request, as set forth in the attachment. These requests for admissions are made under Rule 198.1 of the Texas Rules of Civil Procedure, and each of the matters of which an admission is requested shall be deemed admitted unless a response is delivered to William B. Connolly within thirty (30) days after service of this request. Unless DFPS states an objection or asserts a privilege, DFPS must specifically admit or deny each request or explain in detail the reasons that DFPS cannot admit or deny the request. A response must fairly meet the substance of the request. DFPS may qualify an answer, or deny a request in part, only when good faith requires. Lack of information or knowledge is not a proper response unless DFPS states that a reasonable inquiry was made but that the information known or easily obtainable is insufficient to enable DFPS to admit or deny. An assertion that the request presents an issue for trial is not a proper response.

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 Request for Admissions to Texas Department of Family and Protective Services was forwarded to:

on this the day of_______.

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William B. Connolly