Required Initial Disclosures

Parties to new civil lawsuits in Texas usually must exchange information within 30 days of the filing of an answer, waiver of service, or counterpetition.

Family law cases, such as divorces and custody suits, require you to share additional information even beyond what a typical civil lawsuit requires. You may be able to agree that you do not have to exchange the information (using a Rule 11 agreement).

Checklist Steps

Read Required Initial Disclosures in Texas Civil Cases, which explains what is a required initial disclosure is; what you have to give the other side; what to do with your material; exceptions; and consequences for not exchanging the required information. Also see the following articles:

As part of the required disclosures under Texas Rules of Civil Procedure 194.2, you need to give the other party or parties the correct names and addresses of parties to the lawsuit—your name and contact information, including your mailing address and phone number, and contact information for anyone else involved.

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

Gather up documents related to insurance. This includes all statements or policies for each current life, casualty, liability, and health insurance policy.



In a suit in which child support is at issue, you must, without being asked, give the other party:

  • your income tax returns for the previous two years or, if no return has been filed, your Form W-2, Form 1099, and Schedule K-1 for the past two years; and
  • your two most recent payroll check stubs. 

(Note that this doesn't apply in child support cases filed by or against the Texas Office of the Attorney General.)

Unless you and the other parties to the lawsuit have agreed otherwise, you need to prepare your forms. 

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