When you’re involved in a Texas family law case—whether it involves child custody, conservatorship, child support, or allegations of family violence—one of the most critical phases is discovery. During discovery, both parties are required to exchange relevant documents that support their claims or defenses.
If you’re wondering what documents you might need to provide, we’ve created this practical guide to help. Below is a breakdown of the types of discovery documents commonly requested in cases involving custody, support, visitation, and more.
- Conservatorship, Possession, or Access to the Child
In custody-related disputes, courts want a clear picture of each parent’s involvement and the child’s needs. Useful documents include:
- Prior court orders (temporary or final) related to custody or visitation
- Parenting plans or proposed possession schedules
- Communication logs between parents (texts, emails, co-parenting apps)
- School records indicating parental involvement
- Therapy or counseling records (if relevant to parenting capacity or the child’s emotional needs)
- Witness statements or affidavits regarding parenting abilities
- Reports from parenting coordinators, therapists, or custody evaluators
These documents help show who is acting in the best interest of the child, a key standard in Texas conservatorship cases.
- Child Support, Including Medical Support and Health Insurance
Whether you’re requesting or contesting support, documentation of income and expenses is essential:
- Pay stubs or income statements (typically the past two years)
- Tax returns and W-2s
- Receipts or statements for child-related expenses (e.g., daycare, school, sports)
- Health insurance policy information
- Medical bills for the child
- Proof of insurance coverage or availability
- Records of out-of-pocket medical costs
This information helps the court apply (or deviate from) the Texas child support guidelines.
- Attorney’s Fees
If you’re requesting that the other party cover your legal expenses, you’ll need to provide:
- Billing statements and itemized invoices
- Retainer agreements
- Proof of payment (receipts, bank statements)
- Affidavits explaining the necessity and reasonableness of fees
- Assault Allegations
In cases involving accusations of assault—whether physical, emotional, or both—these records may be relevant:
- Police reports or incident reports
- Photos of injuries
- Medical records and associated bills
- Protective Orders or Temporary Restraining Orders (TROs)
- Eyewitness accounts
- Texts or emails referencing the incident
- Intentional Infliction of Emotional Distress
If you’re making or defending against a claim for emotional harm, you may need to present:
- Mental health evaluations or therapy notes
- Written communications (emails, texts) showing abuse or harassment
- Witness statements
- Journals or diaries (if used to document abuse or distress)
- Affidavits from psychologists or counselors
- Family Violence
These serious claims require comprehensive evidence. Helpful documents include:
- Protective orders (TROs, Final Orders)
- Police reports or CPS investigations
- Photos, videos, or audio recordings
- Eyewitness statements or affidavits
- Medical or psychological evaluations
- Requests for Injunctive Relief
Injunctive relief may be needed to protect a party or a child. Supporting documentation might include:
- Draft orders or proposed injunction language
- Communications showing why restrictions are necessary
- Evidence of prior violations
- Any records showing potential risk or danger
- Arguments That Child Support Guidelines Are Inappropriate
To deviate from Texas child support guidelines, courts need specific financial proof, such as:
- Detailed income/expense statements
- Costs of medical or educational needs
- Records showing significant travel or special expenses
- Affidavits about financial hardship
- Proof of additional dependents or financial obligations
Why Proper Documentation Matters
Whether you’re seeking modification of custody, requesting injunctive relief, or contesting child support, the right documentation can make or break your case. These records offer the court a fuller picture of your family dynamics, financial situation, and parenting abilities.
Need Help Preparing for Discovery?
At Denis Law Group, we know how stressful it is to navigate the discovery process in a family law case. Our experienced attorneys are here to help you understand your obligations, prepare your documentation, and present a strong case in court.
Call us today to schedule a consultation and let us support you through every step of your Texas custody or support matter.