DO NOT FILE THIS DOCUMENT WITH THE COURT.
FM-Div-Disc-101-Required Initial Disclosures-Divorce (Rev. 06-2021)
5. Persons with Knowledge of Relevant Facts (Potential Witnesses)
See Texas Rule of Civil Procedure 194.2(b)(5).
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. What is each person’s connection
with the case? The list should include all potential witnesses regardless of who they would be
testifying for. Attach another sheet of paper if you need more room.
IF this case is contested, this list could include family members, neighbors, teachers, doctors,
counselors, employers, and financial advisors, among others.
6. Documents, electronic items, or tangible things.
See Texas Rule of Civil Procedure 194.2(b)(6).
T
he following is a list of documents, electronically stored information, and tangible things that have been
identified that may be used to support a claim or defense in this case. This Response will be
supplemented, as needed, as responsive items are identified
Describe documents, electronically stored information, and tangible things that you have in your
possession, custody, or control, and may use to support your claims or defenses. The list of
documents, electronic items, or tangible things should include all items in your possession that
you might want admitted as evidence in your case.
or Document
electronic info, or tangible
document or
document or item
If not producing copies of all the documents; access to electronically stored information; and
tangible things, a reasonable time and method for the production of these items is:
__________________________________________________________________________
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