CAUSE NO.

2011-02279J IN THE INTEREST OF JEREMIAH CARNELL KEVIN GALLIEN TYNEAL GREEN, III TANIYA GREEN MARIYA GREEN SAKIYA GREEN BABY B GIRL BABY A GIRL CHILDREN IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS

315TH JUDICIAL DISTRICT

ATTORNEY AD LITEMS CERTIFICATE OF WRITTEN DISCOVERY Attorney Ad Litem, Raiysa A. Reece, certifies under the applicable local rules and the Texas Rules of Civil Procedure that the following documents have been served on Petitioners, Texas Department of Family and Protective Services on the ______ day of May, 2011. 1. 2. 3. RESPONDENTS FIRST SET OF WRITTEN INTERROGATORIES TO PETITIONERS ; RESPONDENTS REQUEST FOR DISCLOSURE; AND RESPONDENTS REQUEST FOR PRODUCTION OF DOCUMENTS . Respectfully submitted, By: Raiysa A. Reece State Bar No. 24065956 4119 Montrose Blvd. Suite 200 Houston, Texas 77006 Telephone: (713) 489-5720 Facsimile: (713) 481-1729 ATTORNEY AD LITEM FOR THE UNKNOWN FATHER

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document has been forwarded via facsimile and/or first-class mail, postage prepaid to the following counsel of record on this the 9h day of May, 2011. Via Facsimile (713) 578-3995 Susan M. Sciacca 2525 Murworth Drive, Suite 300 Houston, Texas 77054 Raiysa A. Reece

CAUSE NO. 2011-02279J IN THE INTEREST OF IN THE DISTRICT COURT OF

JEREMIAH CARNELL KEVIN GALLIEN TYNEAL GREEN, III TANIYA GREEN MARIYA GREEN SAKIYA GREEN BABY B GIRL BABY A GIRL CHILDREN

HARRIS COUNTY, TEXAS

315TH JUDICIAL DISTRICT

RESPONDENTS FIRST SET OF WRITTEN INTERROGATORIES TO PETITIONER(S) To: Texas Department of Family and Protective Services, by and through their attorney or record, Susan M. Sciacca, 2525 Murworth, Suite 300, Houston, Texas 77054.

Under rules 190 and 197 or the Texas Rules of Civil Procedure, you are required to answer in complete detail and in writing each of the attached interrogatories, sign your answers to the interrogatories, swear to the truth of your answers before a notary public or other judicial officer as required by rules 191.3(a) and 197.2(d) or the Texas Rules of Civil Procedure, and deliver a complete, signed, and notarized copy of your answers to the undersigned attorney within 30 days following service of this request. If you fail to comply with the requirements above, the Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Definitions Identity and location means the persons name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual. Person includes and is intended to mean any natural person or the representative of any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. Entity or entities includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.

Instructions All information that is not privileged that is in the possession of Petitioner, his attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives or Petitioner is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. Option to Produce Records If the answer to an interrogatory may be derived or ascertained from public records, from your business records, or from a compilation, abstract, or summary of your business records, and the burden of deriving or ascertaining the answer is substantially the same for Respondent as for you, you may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract, or summary of the records. The records from which the answer may be derived or ascertained must be specified in sufficient detail to permit Respondent to locate and identify them as readily as you can. If you have specified business records, you must state a reasonable time and place for examination of the documents. You must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the court, and must provide Respondent a reasonable opportunity to inspect them. Respectfully submitted, By: Raiysa A. Reece State Bar No. 24065956 4119 Montrose Blvd. Suite 200 Houston, Texas 77006 Telephone: (713) 489-5720 Facsimile: (713) 481-1729 AD LITEM FOR THE UNKNOWN FATHER

ATTORNEY

CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document has been forwarded via facsimile and/or first-class mail, postage prepaid to the following counsel of record on this the 9th day of May, 2011. Via Facsimile (713) 578-3995 Susan M. Sciacca 2525 Murworth Drive, Suite 300 Houston, Texas 77054 Raiysa A. Reece

INTERROGATORIES 1. If you contend that it is not in the best interest of the child(ren) that THE UNKNOWN FATHER, be appointed joint managing conservator, or sole managing conservator, state each fact that is known to you or reported to you by others (and the names of those other reporting persons) that supports you contention. Answer: 2. If you contend that it is in the best interest of the child(ren) that you be appointed sole managing conservator, state each fact that is known to you or reported to you by others (and the names of those other reporting persons) that supports your contention. Answer: 3. If you contend that it is in the best interest of the child(ren) that the biological mother/father of the child parental rights be terminated, state each fact that is known to you or reported to you by others (and names of those other reporting persons) that supports your contention. Answer: 4. If you contend that THE UNKNOWN FATHER, has engaged in criminal conduct that endangers the welfare of the child(ren), state date and place of each occurrence. Answer: 5. List the dates and times maternal family members, including but not limited to grandparents, aunts, and/or uncles, have visited with child(ren) since you have had custody and control of the child subject of this suit. Answer: 6. List the dates and amounts maternal family members, including but not limited to grandparents, aunts, and/or uncles, have contributed to the support of the child(ren) subject of the suit since you have had custody and control of the child(ren) subject of this suit. Answer: 7. List the dates and times paternal family members, including but not limited to grandparents, aunts, and/or uncles, have visited

with child(ren) since you have had custody and control of the child subject of this suit. Answer: 8. List the dates and amounts paternal family members, including but not limited to grandparents, aunts, and/or uncles, have contributed to the support of the child(ren) subject of the suit since you have had custody and control of the child(ren) subject of this suit. Answer: 9. State the name, address, and telephone number of any person who is expected to be called to testify at the trial of this lawsuit. Answer: 10. State which of your answers to these interrogatories are based on information obtained from other persons and state the name, address, and telephone number of each person from whom you obtained the information and the date the information was obtained. Answer: 11. List all exhibits that Texas Department of Family and Protective Services plan to use and introduce as exhibits at that time of trail in this suit. Answer: 12. State the identity and location of all mental and physical health care providers whom the child(ren) subject of this suit have seen in the since you have had custody and control of the child subject of this suit. Answer: 13. List the dates and places in which the Respondent was provided a family plan and the person(s) who provided that family plan to Respondent. Answer:

CAUSE NO. 2011-02279J IN THE INTEREST OF JEREMIAH CARNELL KEVIN GALLIEN TYNEAL GREEN, III TANIYA GREEN MARIYA GREEN SAKIYA GREEN BABY B GIRL BABY A GIRL CHILDREN IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS

315TH JUDICIAL DISTRICT

ATTORNEY AD LITEM FOR RESPONDENTS RULE 194 REQUESTS FOR DISCLOSURE To: Texas Department of Family and Protective Services, by and through their attorney or record, Susan M. Sciacca, 2525 Murworth, Suite 300, Houston, Texas 77054.

Pursuant to rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within 30 days after service of this request, the information or material described in rule 194 as set forth in the attached request. The originals or copies of documents and other tangible items requested must be produced for inspection and copying at 2211 Norfolk St., Suite 920, Houston, Texas 77098 within 30 days after service of this request, together with a written response. Each written response must be preceded by the request to which it applies. No objection or assertion or work product privilege is permitted to a request under this rule. If you fail to comply with this request, the court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Your response must be signed. Respectfully submitted, By: Raiysa A. Reece State Bar No. 24065956 4119 Montrose Blvd. Suite 200 Houston, Texas 77006 Telephone: (713) 489-5720 Facsimile: (713) 481-1729 ATTORNEY AD LITEM FOR THE UNKNOWN FATHER CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document has been forwarded via facsimile and/or first-class mail, postage prepaid to the following counsel of record on this the 9th day of May, 2011. Via Facsimile (713) 578-3995 Susan M. Sciacca 2525 Murworth Drive, Suite 300 Houston, Texas 77054 Raiysa A. Reece

RULE 194 REQUEST (a) (b) (c) State the correct names of the parties to the lawsuit. State the names, addresses, and telephone numbers of any potential parties. State the legal theories and, in general, the factual bases of the claims or defenses of Texas Department of Family and Protective Services. State the names, addresses, and telephone numbers or persons having knowledge of relevant facts, and give a brief statement or each identified persons connection with the case. For any testifying expert(1) (2) state the experts name, address, and telephone number; state the subject matter on which the expert will testify;

(d)

(e)

(3) state the general substance of the experts mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the Texas Department of Family and Protective Services, documents reflecting such information; (4) if an expert is retained by, or otherwise subject to the control of the Texas Department of Family and Protective Services, produce the originals or copies of the following: (A) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the experts testimony; and (B) (f) the experts current resume and bibliography.

Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement.

(g)

Produce the originals or copies of any witness statements described in rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts-a witness statement-regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type or recording of a witnesss oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party.

(h)

Produce the originals or copies of all medical records and bills obtained by Texas Department of Family and Protective Services by virtue of an authorization furnished by KATRINA CARNELL.

CAUSE NO. 2011-02279J IN THE INTEREST OF JEREMIAH CARNELL KEVIN GALLIEN TYNEAL GREEN, III TANIYA GREEN MARIYA GREEN SAKIYA GREEN BABY B GIRL BABY A GIRL CHILDREN IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS

315TH JUDICIAL DISTRICT

RESPONDENTS REQUEST FOR PRODUCTION OF DOCUMENTS To: Texas Department of Family and Protective Services, by and through their attorney or record, Susan Sciacca, 2525 Murworth, Suite 300, Houston, Texas 77054.

THE UNKNOWN FATHER, Respondent, requests that petitioner, Texas Department of Family and Protective Services, produce for inspection and copying the items described below, at the time and places set out below. Definitions Petitioner, you and your refer to and are intended to include Texas Department of Family and Protective Services, your employees, and/or your agents, either individually or as a representative of any corporation, association, or partnership, as the case may be, as well as any testifying expert witnesses retained by you or retained on your behalf relating to this litigation and any consulting experts whose work product has been reviewed by, relates to, or forms the basis, either in whole or in part, or the mental impressions and opinions or any testifying experts. Person includes and is intended to mean any natural person or the representative or any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any form of business entity. Entity or entities includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.

Relates to means in whole or in part constitutes, contains, concerns, embodies, relates, analyzes, identifies, states, refers to, deals with, or in any way pertains to. Item, document, or documents includes, but is not limited to, each tangible thing, recording, or reproduction of any visual or auditory information, including but not limited to papers, books, accounts, drawings, graphs, charts, photographs, electronic or videotape recordings, data, and data compilations, however made, whether handwritten, typewritten, or printed material, drafts, duplicates, carbon copies, photocopies, e-mail, scanned documents, digital documents, and all other copies. Parties means Petitioner or Respondent or both Petitioner and Respondent. Instructions All information responsive to this request that is not privileged and that is in your possession, custody, or control is to be produced. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession or the item that is equal or superior to that of the person who has physical possession of the item. If any of this information is solely in electronic or magnetic form, you must produce this information by providing Respondent with this information on 1.4 MB 31/2-inch or 100MB Zip computer disks formatted for IBMcompatible computers with a notation identifying the computer program (including version identification) necessary to access the information. Time Period The discovery requested is for documents prepared, received, or generated since date Petitioners have taken child into their custody unless otherwise provided in this request. All requested documents, whenever actually prepared or generated, that relate to this period are to be produced. Documents to Be Produced All items set forth in Exhibit A are to be produced for inspection, examination, and copying within 30 days following service of this request at 4119 Montrose Blvd. Suite 200, Houston, Texas 77006. You must either produce documents and tangible things as they are kept in the ordinary course of business or organize and label them to correspond with the categories in this request. Amendment or Supplementation of Response If you learn that your response to this request was incomplete or incorrect when made or that, although it was complete and correct when

made, it is no longer complete and correct, you must amend or supplement the response1. to the extent that the request seeks the identification of persons with knowledge of relevant facts, trial witnesses, or expert witnesses, and 2. to the extent that the request seeks other information, unless the additional or corrective information has been made known to the other parties in writing, on the record at a deposition, or through other discovery responses. You must make amended or supplemental responses reasonably promptly after you discover the necessity for such a response. Content of Response With respect to each item or category or items, you must state objections and assert privileges as required by the Texas Rules of Civil Procedure and state, as appropriate, that1. 2. 3. production, inspection, or other requested action will be permitted as requested; the requested item are being served on Respondent with the response; production, inspection, or other requested action will take place at a specified time and place, if you are objecting to the time and place or production; or no items have been identified-after a diligent search-that are responsive to the request. Respectfully submitted, By: Raiysa A. Reece State Bar No. 24065956 4119 Montrose Blvd. Suite 200 Houston, Texas 77006 Telephone: (713) 489-5720 Facsimile: (713) 481-1729 ATTORNEY AD LITEM FOR THE UNKNOWN FATHER

4.

CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document has been forwarded via facsimile and/or first-class mail, postage prepaid to the following counsel of record on this the 9th day of May, 2011. Via Facsimile (713) 578-3995 Susan M. Sciacca 2525 Murworth Drive, Suite 300 Houston, Texas 77054 Raiysa A. Reece

EXHIBIT A 1. All correspondence or other documents, including enrollment, attendance, and grade records, that relate to the children the subject of this suit from any school in which the children have been enrolled since date of Petitioners have taken child(ren) under their custody and care. All records, including invoices, relating to medical, psychological, and psychiatric treatments, consultations, or diagnoses of the child(ren), including but not limited to any prescriptions. All permanency plans relation to the Respondent, THE UNKNOWN FATHER, and child(ren) subject of this suit organized in chronological order from most recent to least recent. All diaries, notes, memoranda, journals, or calendars, including electronic diaries, notes, memoranda, journals, or calendars, or other written logs that constitute or contain matters relevant to the subject matter of this lawsuit. All letters and correspondence, including electronic writings (e.g., e-mail), that constitute or contain matters relevant to the subject matter of this lawsuit. All drawings, graphs, charts, photographs, tape or electronic recordings, and audio/video recordings that constitute or contain matters relevant to the subject matter of this lawsuit. All telephone records of the parties, including but not limited to residence, business, mobile, and portable telephone records relating to the subject matter of this lawsuit. All documents, including invoices and billing statements, evidencing the contractual relationship with attorneys, experts, and/or investigators in connection with this case. All court orders entitling TDFPS or any other persons to receive child support for the benefit of the child(ren) subject of this suit.

2.

3.

4.

5.

6.

7.

8.

9.

10. All family plans submitted to the parties, with dates that they were submitted to the parties.