Transcript

​​Mary Neal: The point of the UCCJEA is to help with the various states and the mobility that we have nowadays for families to be able to freely move between states. So the idea is, is that if a court is able to put into play something with regard to the children, then let’s keep jurisdiction there, or just trying to figure out jurisdiction in general because of the mobility.

Voiceover: You’re listening to The Texas Family Law Insiders podcast, your source for the latest news and trends in family law in the state of Texas. Now, here’s your host attorney Holly Draper.

Holly: Today we’re excited to welcome Mary Neal to The Texas Family Law Insiders podcast. Mary is a partner at Albin Oldner Law in Frisco, Texas. She’s board certified in family law, has been consistently recognized as a rising star by Super Lawyers, and has been recognized as one of the top 100 up-and-coming lawyers in Texas, and the top 50 up-and-coming women lawyers in Texas by Super Lawyers. Mary has experience with all types of family law cases but has found her niche in high-conflict child custody litigation. In her free time, Mary enjoys traveling with her husband as they work to visit every state. Thank you so much for joining us today.

Mary: Hey, of course, thanks for having me.

Holly: And for anyone watching on video, Mary just had surgery. So she’s laid up, but she’s still doing our podcast with us today. So just a little bit of background for anyone who might be watching the video. But why don’t you start by telling us a little bit about yourself.

Mary: So my name is Mary, I am a sixth-generation Texan. So the family has been here for a really long time, primarily here in the Dallas area. I’m one of five children. I’m actually the baby, which I think explains a lot about my personality. I’ve been married now for about 10 and a half years. My husband and I actually went to high school together. That’s where we met originally. But the fun fact about us is that we were actually born in the same hospital, and then went to the same elementary school, middle school, and high school, but because of the age difference we just didn’t meet until high school. So yeah, that’s about me.

Holly: So how would you describe your current practice?

Mary: I would say that, as the years have gone on, I have honed in on trying to do a lot more high-conflict child custody-type cases. I still do divorces. Typically the divorces that I’m dealing with are ones that were fighting over kid issues. But primarily really honing in on the child custody stuff at this point.

Holly: I definitely prefer the child custody stuff myself to be property stuff, but I’m glad there are property lovers out there. So today, we’re gonna chat about the Uniform Child Custody Jurisdiction and Enforcement Act, or the UCCJEA. I think this is something that a lot of especially newer Family Lawyers don’t understand or don’t know how to deal with it when it comes up. So can you give us just a high-level overview of what is the UCCJEA?

Mary: Sure. The point of the UCCJEA is to help with the various states and the mobility that we have nowadays for families to be able to freely move between states. So the idea is, is that if a court is able to put into place something with regard to the children, then let’s keep jurisdiction there, or just trying to figure out jurisdiction in general because of the mobility.

So if the family has been living in one particular state, and then you know, mom and the kids moved to another state, where is the proper way to go about it, instead of someone just kind of jumping ship because they’re ready to be free of their soon to be ex and running somewhere where they think it’s going to be a better forum for them. So this is really to try and just hone in on making sure things are done, I guess, fairly for the families.

Holly: So when will a particular case implicate the UCCJEA? And what specifically should attorneys be looking for?

Mary: I think if the moment you hear any kind of fact pattern that involves another state in general, a lot of times when you’re in your initial consult with a client, they might talk about being married in Massachusetts, and then they’ve moved to Texas at some point. So just making sure you find out when exactly they moved to Texas and when the kids were born and where they were born, is going to be imperative.

But really, the times that UCCJE is going to come into effect are if, fortunately, your clients are going to tell you if there’s already an order out of state, they’re going to tell you, hey, this order was originally done in Oklahoma, and I need it modified or I need it enforced. But in the divorces, UCCJEA can come up in those or initial cases. And you just need to be listening for where does everybody live. And how long have they been in Texas?

Holly: So if we have a situation where, let’s say the parties were living in Oklahoma, and they have a prior order from there, and now both parties have moved to Texas, do we need to think about the UCCJEA in that situation, or only if one parent has stayed?

Mary: I mean, I think you need to constantly be thinking about the UCCJEA, but in that circumstance, the UCCJEA says that if no parent, or anyone acting as a parent is still living in Oklahoma, then Oklahoma loses jurisdiction. You do have to have the state of Texas officially make that finding. So you have to bring that to the court’s attention in whatever your initial hearing is, to make that happen. But until that time, Oklahoma does retain jurisdiction. So you have to think about it just to make sure you cover your bases on jurisdiction. But really, UCCJEA has gone away at that point, because everyone has left Oklahoma.

Holly: So one of the things that the UCCJEA tells us is related to jurisdiction to make an initial child custody determination. Can you talk a little bit about you know, how do we determine what state has that jurisdiction and what the different criteria are?

Mary: You know, the easiest time that you’re going to be able to figure out when a certain state has jurisdiction, is the very clean cut, the child has been in that state for at least six months. And not just in the state, they have to be living. The whole purpose of them being in that state is that they were residing there. So you can look at stuff like school, what school have they been going to. Daycare, even. If they’ve been set up with a pediatrician.

Some small stuff like that. Have they been living there? Those are the easiest ones, those are the easy ones that I enjoy. The more complicated ones are, where potentially maybe we’ve got one parent in one state and one parent in Texas. And they’ve been freely going back and forth between the two parties because the parties are ideally working together fairly well at that point. And so at that point, you have to start looking at the significant connection aspect to Texas.

And so typically, that’s going to be requiring a court hearing, unless for whatever reason the other party in the other state is just willing to allow Texas to take jurisdiction. But typically, you’re going to have to have some kind of a hearing on really which state is best to actually have a determination hearing or trial over it.

And so we’re looking at stuff like how much time has been spent here. To what extent a life has been created. An important one always is, we’re gonna be able to issue subpoenas easily for evidence that we might need as the case progresses. Witnesses, and then also just kind of really what is the kid’s life in both states to figure out where the more proper and efficient state would be to have this fight.

Holly: So if we already have a custody order that is coming from another state, this is I think my biggest pet peeve, as a family lawyer is when, and you know what I’m going to say before I even say it, is when lawyers talk about transferring a case from one state to another. Is that something that can be done?

Mary: No, it’s not a thing. And it’s actually pretty funny because we have a couple of UCCJEA cases at the firm right now. And one of the other lawyers was coming in and asking me some questions about it. And he said, okay, well, so I need to transfer it from Colorado, right? And I was like, no, that’s just not how this works. So then he would go out, and we would talk to other people in the firm about various things that we need to do.

And he would start to say, we’re going to transfer it from Colorado, and he’d catch himself and say, I know what you’re gonna say, Mary, you don’t transfer it. So yes, no, you don’t transfer between states. And it is, it’s frustrating, because the idea is, is that you’re never going to get all of that detail of information out of the docket like we have in Texas. I don’t know if other states do it the way that we do it.

But I think that’s one reason why the attorney in my firm was getting frustrated because he was like, but there’s so much detail that we’re going to lose from a judge’s docket and the little notes that they put in there that now the Texas judge isn’t going to get that nuance about it all. And yeah, it sucks, but no you don’t transfer between states.

Holly: So when can you modify an order from another state, child custody order, here in Texas?

Mary: So the circumstances have to be perfect for you to do it in Texas, so long as not everyone has left the state. So going back to the example of Oklahoma. We have the order in Oklahoma, and one parent continues to live there. But the primary parent and the child have been living in Texas, let’s say for three years. Officially, that doesn’t matter.

So long as a parent, or someone acting as a parent continues to live in Oklahoma, Oklahoma continues to retain jurisdiction. And it would be up to the Oklahoma court to relinquish that jurisdiction down to Texas. Now Texas would have the potential of being able to get an emergency jurisdiction if something TRO-worthy was happening to the child or was going to happen to the child that we needed to take care of.

Texas can have emergency jurisdiction, but the real point of the emergency jurisdiction is just a bandaid until you can get to Oklahoma and get something going. So the times that you can get something modified down here, the easier ones are when everyone has left the original state. Beyond that, you can have Texas modify, it’s just going to be a little bit more work and a little bit more of a fight.

You have to kind of gather all of your ducks in a row and get all your evidence together to be able to convince the Texas court that this would be the better place and then request them to have a UCCJEA conference with that other state, convincing them here are the reasons why you should probably push for Texas to have it. But ultimately, it’s going to be up to that other state. I do know, and in my reading of the UCCJEA, I think proper procedure would be to hire an attorney in that other state, and actually engage in that state first and ask them to relinquish.

But really, in common practice what I see most of the courts in Texas do is that so long as you have that request for a UCCJEA conference and a jurisdiction hearing first before you try and move on to temporary orders or discovery or any nitty gritty stuff, the Texas courts tend to take in that information and go have that UCCJEA conference.

Holly: So they’ll do that without you first filing a motion to relinquish or whatever you want to call it in the original state?

Mary: You know, and I, so fortunately, in my world, the UCCJEA conferences that I have had, or the cases where I’ve needed to go back to the other states, they’ve either already had hearings, and so someone had already brought a petition to modify or something like that in that state, and they had the fight on whether or not they were going to keep it, or the circumstances were just right enough in Texas, that we were able to kind of already convince the judge that you are the proper place to have. So why don’t you just go have that conversation with the other state?

So I prefer just doing it here in Texas because I know how Texas does it. And as you were saying, at the very top of this podcast, UCCJEA is not fully understood by all the attorneys. So what I have run into a lot is when we call other states to get an attorney on board to go to the courthouse to maybe have that fight for us, is they tend to tell us on the phone, why would we do that?

Why don’t you just call, or why don’t you just start this all down in Texas? It seems like Texas is the appropriate place. So either the places that I’m calling, they’re doing it the way that I prefer it down here in Texas anyway. Or they’re not understanding the process. Not sure which.

Holly: Do you see judges, when you’re trying to meet, you’re trying to get jurisdiction here in Texas, if the child has been living here for more than six months, is it pretty standard procedure for the other state to relinquish? Or are you seeing it kind of depending on the facts of this poor dad got left in another state and his wife and kid ex-wife and kid left him and now he’s gonna have to go find the spouse somewhere else? They don’t want him to have to do that. So they keep it in the current state.

Mary: You know, it’s been so fact-dependent, I think, and I don’t even know if it’s even fact-dependent on the actual case facts, more so the judge that we’re dealing with. So I had a case where, unfortunately, mom had passed, and grandmother ended up taking custody of the kids. And at some point, and I think this case was originally out of Ohio or somewhere up in the Midwest. And grandmother took custody, and at some point, grandfather also got possession rights, because grandmother and grandfather were not together anymore.

And dad was I think alloted maybe phone calls only. He wasn’t even allowed actual possession of these children. But ultimately grandmother, grandfather, and all the children end up moving down here to Texas. And there at least were two different fights that I had been part of. We were trying to get Ohio to relinquish jurisdiction, to give it down here to Texas, because really, the fight was between grandmother and grandfather.

And Ohio continued to keep it. They would not handed over. So that was one of the weird ones. But then we’ve got others where the, I think the case that for instance, the case that I had on my appeal, that kind of got me into the UCCJEA world was dad was still in Florida, the case was originally in Florida. But there was no geographic restriction.

And so it specifically stated that she could move to Texas. But I think there was even language in there where there was, they’re supposed to keep the jurisdiction in Florida. There was some kind of agreement that they were going to let Florida keep jurisdiction. But she comes to Texas, and we file here in Texas, and we try and have a conference in Florida, but the Florida judge just wouldn’t even answer her phone.

Judge tried multiple times. And then dad even went to Florida to try and file there to get a modification done, and no court hearings ever got set. So in those circumstances, we got jurisdiction because Florida clearly didn’t care anymore. But yeah, it’s kind of wild to see, just like, family law is wild, right? So whoever knows whatever is gonna happen. But yeah, it totally depends on the judge you’re trying to take jurisdiction from.

Holly: So when can Texas not modify a foreign order?

Mary: So obviously, if there’s someone still in the other state, and then the court is just refusing to relinquish jurisdiction, that’s the biggest one. But so long as there’s a court of continuing jurisdiction that wants jurisdiction to some extent, they get to keep it.

Voiceover: This episode of The Texas Family Law Insiders podcast is sponsored by The Draper Law Firm, providing family law appellate representation across Texas. For more information, visit draperfirm.com, or call 469-715-6801.

Holly: What can cause the court to lose continuing jurisdiction?

Mary: So you know, we’ve talked about some of them. If everyone leaves, if I think the the wording of the code specifically is if no child, no parent, or no person acting as a parent have or have all left the state, that’s a pretty easy one. And then, inconvenient forums can come up.

So there’s a court of appeals case, I think out of Dallas. Yeah, because it was a Dallas County case where Texas had jurisdiction at the time that they filed, but then the case just kind of went on and on and on no real resolution to anything. So about 18 months later, they ended up having a request to decline jurisdiction in Dallas, because the child and one of the parents had moved to Oklahoma.

So they had an inconvenient forum hearing. And ultimately, the court in Dallas said, yeah, at this point, everyone’s been living up in Oklahoma long enough that we don’t want it anymore. Let Oklahoma take over this case. So that’s kind of a wild one where you do everything properly.

The child had been in Texas for six months, jurisdiction, venue, and everything was proper in Dallas County at the time, but for whatever reason, Dallas County had allowed the parent to move. Or she might have moved for it before the case started. I’m not totally positive on what the facts were. But either way, 18 months in, because she’d been gone long enough, Dallas was like we don’t want it anymore and they passed it off.

Holly: And did the Court of Appeals uphold that decision?

Mary: They did. Yes. Yeah. They found that that was an appropriate application of the inconvenient forums part of the UCCJEA.

Holly: So, when we’re dealing with people in multiple states, how does personal jurisdiction tie into the UCCJEA?

Mary: Personal jurisdiction, look, family law is Wild Wild West, right? We don’t follow the laws, what a lot of people joke about. So personal jurisdiction isn’t nearly as important when it’s UCCJEA. When you look at the UCCJEA factors, they don’t go into personal jurisdiction. You don’t have to have anything to do with the state of Texas in order to be able to get subject matter jurisdiction here over a child.

So, for instance, going back to the case that I had that ended up going up on appeal, he had never set foot in Texas. He remained in Florida. All of his visitation had occurred in Florida. He had no real connection to Florida other than the fact that his children lived here. And so personal jurisdiction at that point doesn’t come into play.

Personal jurisdiction is going to come into play more if we’re dealing with child support. So if you’re going to try and get Texas to take jurisdiction under UIFSA, then we have to make sure we’ve got personal jurisdiction. But officially, the court is going to move forward in Texas, if subject matter jurisdiction is proper here.

Holly: So if you have a situation where there’s not personal jurisdiction, you could find yourself fighting a battle on two fronts then if you’re wanting to get child support out of the person that does not live here, correct?

Mary: Correct. Yeah. So usually, when I’m talking to potential clients, or other attorneys about it, you know, I kind of have to warn them, you might be having to hire attorneys in two different states to deal with the totality of this case.

Holly: So can you walk us through the process of modifying an out-of-state order?

Mary: Sure. So here’s another thing that I think a lot of attorneys are confused about, and maybe even some of the court clerks because I think I’ve had to fight this. And by fight I mean, I don’t fight it because it is what it is. The clerks want it. But officially, you don’t have to register an out-of-state order before you want to modify it.

The UCCJEA, specifically states registration of a foreign order is only required if you want to enforce that order. And of course, the kind of policy behind that is just really to ensure that that is a valid order because when you register it, you then let everyone know that it’s been registered and let someone either object or try and challenge the validity of that order. So when you’re trying to modify, really you just need to stick it to the back.

You attach it to the back of your petition to modify, letting the court know here’s what the previous order was that we’re trying to modify. So you’ll prepare a petition to modify like you would any other time. Even if it’s just a Texas case, you will attach that order to the back.

And then you’ll also need your UCCJEA affidavit attached, which will have a listing of all of the addresses that the child or the parties, well the child specifically, but the parties are typically included in that because the child has lived with the parties. But where the child has lived over the last, I think it’s two years, I can’t remember the exact amount of time, but he had to put a certain amount of time where the place, or where all the places are, that the child has lived.

Holly: So are there any differences, and this is branching out a little bit from the UCCJEA when it comes to registration if it’s dealing with child support?

Mary: No, it’s pretty much the same. Just register it the same way. You know, I think the code says you have to have the certified copy of the order from the other states. And you have to give the clerk two copies of that. Clearly, this has not been updated for modern times, because I’m pretty sure the last few times I’ve had to register an order, I just scanned in the certified copy and recorded it like you file normally. And it was accepted and no big deal. But the same thing for the UIFSA and UCCJEA to register.

Holly: So if you have registered a foreign order, does that alone give Texas jurisdiction to modify it?

Mary: No. Absolutely not. And in fact, the case I was talking about with that, I think the Ohio order, one of the fights that we were having down here in Texas was enforcement. But for whatever reason, one of the attorneys on the case kept trying to file a modification with the enforcement and so we kept having to have these UCCJEA conferences on whether or not we can move forward on the modification as opposed to the enforcement. The enforcement, unfortunately, because of that just kind of kept getting kicked down the road. Because we had the court was unwilling to do anything until we had a jurisdiction fight over it.

Holly: So if you are the one defending this, basically, and you do not believe Texas should have jurisdiction under the UCCJEA, what do you do?

Mary: So usually with that, you can file a special appearance. I don’t think it’s going to go very far with you. Really what the court wants to see is some kind of a plea to the jurisdiction or request to decline jurisdiction. To me, I think they’re the exact same thing. As we know, Texas is, they care more about the substance instead of what you call it.

But plea to the jurisdiction, request to decline jurisdiction, and your original answer or as a standalone document, whichever one you want to do. But just kind of reciting back to the code procedures about why you don’t believe that it’s appropriate. And again, we don’t have to get fact-specific in our pleadings in Texas.

I usually just put maybe a one or two-sentence thing in there that says, Oklahoma has jurisdiction under cause number blah, blah, blah, in the county of Oklahoma County, Oklahoma, and therefore, we do not believe that Texas has jurisdiction, so we’re asking the court to decline it. And then you can set that hearing, set that issue for a hearing at the first hearing, too.

Holly: So do you normally file a more substantive brief before you actually have a hearing on it? Or do you go into that hearing with only your short little couple of sentences?

Mary: I think it kind of depends on the underlying facts of the case. I’ve gone in with briefing on when I know there’s going to be a fight on an inconvenient forum. So if that is why they’re there trying to get Texas to take jurisdiction, then I’ll have a brief on that. But if it’s just a fairly simple, you know, my client still lives in the other state, even though mom and kid live here, or dad and kid live here, and my client still lives over there, I just bring the code and show the judge, it is what it is. There’s not much you can do about it.

Holly: So is there any difference when it comes to jurisdiction of enforcing an order under the UCCJEA as compared to modifying it?

Mary: So enforcement, I think that’s really where we’re going to deal with personal jurisdiction because you can’t, you’re not going to be able to enforce under the US Constitution, without having personal jurisdiction. So that is going to be a little bit different. We’re gonna have to actually make sure you can get the jurisdiction, whatever you need to actually bring that person before the State.

I usually encourage people that the only reason to enforce in Texas is because the respondent is in Texas. So because otherwise, what’s the point? I’m sure you’ve heard of cases, or even had clients who have been held in contempt in another state, but they live in Texas. And you’re just like, well, what was the point of that? They’re just never gonna go back that state, you know.

So I mean, overall, you’re gonna do your enforcement the same way as you would do an enforcement of a normal Texas case, you just have to look at who are you suing. And are they actually here? Because you have to worry about that personal jurisdiction part.

Holly: So you mentioned a little bit ago about emergency jurisdiction. Can you talk about what temporary emergency jurisdiction is? How do you establish that you have it? And what can you do with that?

Mary: Yeah. So this has to be fairly extreme circumstances of what you’re needing to do. And the idea is that you’re only coming to Texas for that help because you can’t get to the other state fast enough. So perhaps it’s in a state that’s just not as easily accessible to you. I think it’s going to be a little bit more difficult in the day and age of where we are now. I think this might have been something that was utilized more pre-COVID.

But with the onset of Zoom hearings, and stuff like that, and the ability to get an attorney pretty quickly, I don’t know how often emergency jurisdiction is going to be utilized now. However, with that, you can still ask Texas to please don’t let the kid go back to someone or give emergency custody to someone else.

Because, ‘ve read some case law where emergency jurisdiction has occurred because the child was just traveling in Texas, with only one parent, and that parent ended up getting arrested. So you know, CPS or I think, CPS or even, you know, another adult that was with them, but just not a family member could quickly go and get jurisdiction or get the emergency jurisdiction to get some kind of orders to be able to continue traveling with that child.

Getting on a plane with them, whatever it is. But, I mean, it’s short-term. The idea is that the court is only supposed to be putting whatever this emergency order is in place until such time the other state can get a hearing set and moving forward. So it is supposed to be in fairly extreme circumstances.

Holly: So what are the most common mistakes you see lawyers making with regard to the UCCJEA?

Mary: I think, one of my frustrations with understanding of UCCJEA, is thinking that on a modification, so long as the kid has been here for six months, check, we’ve got it. Now Texas could take jurisdiction. It’s just not that simple. The home state portion is only for an initial child custody determination. So the six months only matters if there is no court order out there whatsoever.

So I think that’s a common pitfall. If someone hears, oh, they’ve been here for six months, boom, I don’t have to worry about all these other things. And I think from you I’ve heard that I know, at least Collin County will potentially issue sanctions if you’re going to not follow UCCJEA to a T.

So if you’re not following some of these rules properly in certain courts, you might have attorneys fees being awarded against you, or some kind of sanctions, because you should have brought this case in the other state or, or something. I mean if you’re not following. So you just have to be careful with UCCJEA that you’re following it properly. Because the real problem is that let’s pretend you’re able to get a default, because the other person ignores it, and doesn’t do anything about it.

It’s a subject matter jurisdiction thing, which means it can be brought up on appeal. So you might have an order in place for your client and then a year and a half later, they’re getting that thrown aside. And so you just have to be careful you’re not doing something improperly, that could kick you in the butt later.

Holly: So what procedurally do you do here in Texas, if your client brings it to your attention that, hey, somebody is trying to modify a Texas order in another state, but I think Texas should still keep this case and should keep jurisdiction. Is there anything you should do here?

Mary: So I think it kind of depends on the ultimate goal of the client because if they’re not wanting anything modified, obviously filing something in Texas, you’re potentially shooting yourself in the foot by opening the case for someone to come down here and slide in. So I think there’s not a lot that we can do without an open case here, in my opinion.

Instead, I would just kind of try and work with the clients about finding an attorney who is knowledgeable on UCCJEA in another state. Whether that’s me calling and interviewing attorneys, or just being on the phone call with other attorneys when my client is calling them just to confirm that they comprehend and understand our perspective and what we’re trying to accomplish.

Other than that, the only thing you can do is reopen the case. And if you’re not wanting anything modified, then don’t file it. But if you are open to something, then yeah, go ahead and get something on file as quickly as possible. And let them know that and by let them know, I mean, let the court know that something’s been filed in another court, and you need to get on the phone with them to let them know you’re not relinquishing.

Holly: So we’re just about out of time. But one question I like to ask everyone that comes on the podcast is if you could give one piece of advice to young family lawyers, what would it be?

Mary: Run! No.

Holly: You can give more than one. Since you have such a wealth of information.

Mary: No, I was saying that my advice is to run the other way. But, I personally, I think family law takes certain personalities to enjoy it. So I think if you’re a young attorney, and you know for sure you want to do family law, that’s great. I think find mentors if you’re not in a law firm. So if you decide to hang your own shingle, start mingling and going to networking events to find someone that you trust and like to start kind of bouncing ideas off of and asking about.

Because as we all know, law school just didn’t teach you how to practice law. So getting in with other people and getting to know your colleagues in the county, the judges in the county, is helpful to you and your clients moving forward. I think if you are starting in family law, because you’re just like, well, I need a job after law school, and this is the firm that’s hiring. I think, be open-minded.

And check in with yourself about burnout. Burnout is going to happen regardless of whether or not you like family law or not. But I see it happening more often with people who aren’t personality-driven for the kind of work that we do in family law. So watch burnout. Make sure you can have vacations planned. Turn off your emails when it’s not office hours.

Start setting up boundaries for yourself. Because one thing that I always say is like, I cannot care more than my client cares. That’s never going to be a healthy relationship with the law, with the family, with family law, or with my clients. So, just healthy boundaries, finding mentors, I think really, is what’s gonna keep you going in family law.

Holly: So where can our listeners go if they want to find out more about you?

Mary: So I don’t do much on Facebook or well, the internet in general, except for my personal one and all you’re gonna see they’re are a bunch of cats and me cursing about things and my obsession with Diet Dr. Pepper. But you can go to albinlawgroup.com. There you will find information about the law firm and more info about my bio. But beyond that, I pretty much am nowhere online.

Holly: Well they’ll be able to find you on that website if they’re trying to track you down. All right, so thank you so much for joining us today. For our listeners, if you enjoyed today’s episode, please take a minute to leave us a review and subscribe to enjoy future episodes.

Voiceover: The Texas Family Law Insiders podcast is sponsored by The Draper Law Firm. We help people navigate divorce and child custody cases and handle family law appellate matters. For more information, visit our website at www.draperfirm.com.