Fathers 4 Equal Rights
Tarrant County Bar Association
Texas Trial Lawyers Association
Collin County Bar Association
Hood County Bar Association
Dallas Bar Association
National Association of Realtors
State Bar of Texas

Modifications

Recent Jury Trial Victory in Collin County for Dad

Divorce Issue: Dad decided to seek Modification of Prior Divorce Decree to Impose Geographical Restriction and keep Mom from moving the child to Tennessee.

Facts: Both parties were from another state (about 12 hours drive from Texas) but had moved to Texas in the early 2000’s. After living in Texas for few years, Dad and Mom divorced three years ago. At the time of the divorce, Mom wanted to return to the former state of residence with the child, Dad wanted to stay here. The parties compromised and settled in mediation for Mom staying in Texas for three more years. After the three years elapsed, Mom said she was returning to the former state. Dad hired me to modify the Decree to keep the geographical restriction in place permanently.After a temporary hearing where the Judge ordered the child to remain in Texas pending final trial, Mom demanded a Jury trial for final hearing.

Result: In a unanimous verdict, the jury found, as we requested for Dad, that there had been a material and substantial change in circumstances to justify modifying the Decree now tp impose a restriction on the child’s residence and that doing so would be in the child’s best interest. As a result, the Decree was modified to impose a geographical restriction on the child’s residence to Collin County and surrounding counties.


Modification of Custody (Rockwall County)

Issue and Result: Dad, divorced years earlier with one daughter, came to me seeking more visitation time with his child because he had finally gotten the chance to move closer to his ex-wife and daughter that he’d lived for a quite a while. We filed in court asking for “50-50” with realistically a goal of getting extended standard possession. Well, Mom fiercely opposed him getting any more time and it turned out the judge philosophically opposed “50-50” unless the parties lived in the same school area. After the suit was filed, his daughter began saying she wanted to live with Dad.

We amended our suit to ask for primary custody and requested a social study to have the girl interviewed. The study confirmed the child’s desire to live with her Dad. In addition, we also had uncovered some evidence against Mom and her current husband in the deposition. Dad, who started out just wanting more visitation, ended up winning full, primary custody, moving his daughter to new school, with Mom having standard visitation and paying child support.


Modification of Custody (Rockwall County)

Issue and Result: H and W divorced several years prior. Tensions built. Then, after his ex- W came to his house one time with her current police officer husband and caused an ugly scene, with cursing, name calling, threatening Dad and his wife in front of the child, then denying possession for a month in the form of telling the child not to go with his Dad for visits while putting the child out on the front porch to tell his Dad “he didn’t want to go”, Dad finally hired me. We won Dad custody of the child.


Modification of Custody (Collin County)

Issue and Result: Dad hired me because his son’s 2nd grade age child reported facts to his teacher indicating that he had been kicked out of his home in the cold by his mom, that mom had yelled at and slapped him, and other concerns. We filed for a modification of custody and got an emergency order followed by a temporary hearing. We subpoena’d the teachers and school counselor, who confirmed what Dad had been told. Dad won custody. Mom required to undergo psychotherapy and pay child support.


Modification of Custody (Dallas County)

Issue and Result: Dad hired me bc his ex wife, the primary custodial parent, had suddenly fallen in love with another man who lived in another city several hundred miles away and wanted to take the child with her. We stopped the move and eventually got custody. She chose to move away even if she couldn’t take her child with her. She now has standard possession and pays all her own travel expenses to visit with the child.


Issue: Dad decided to seek Modification of Prior Divorce Decree to Impose Geographical Restriction and keep Mom from moving the child to Tennessee. Facts: Both parties were from another state (about 12 hours drive from Texas) but had moved to Texas in the early 2000’s. After living in Texas for few years, Dad and Mom divorced three years ago. At the time of the divorce, Mom wanted to return to the former state of residence with the child, Dad wanted to stay here. The parties compromised and settled in mediation for Mom staying in Texas for three more years. After the three years elapsed, Mom said she was returning to the former state. Dad hired me to modify the Decree to keep the geographical restriction in place permanently.

After a Temporary Hearing Where the Judge Ordered the Child to Remain in Texas Pending Final Trial, Mom Demanded a Jury Trial for Final Hearing

Result: In a unanimous verdict, the jury found, as we requested for Dad, that there had been a material and substantial change in circumstances to justify modifying the Decree now to impose a restriction on the child’s residence and that doing so would be in the child’s best interest. As a result, the Decree was modified to impose a geographical restriction on the child’s residence to Collin County and surrounding counties.


Issue: Modification of two-year-old divorce. Father had obtained standard rights in divorce. Mother was a stay-at-home mom with no bad facts against her other than her refusal to co-parent with Father.

Result: Obtained modification to give father equal possession and rights.


Issue: Modification of custody in Dallas County involving 3 y/o and 5 y/o girls.

Result: Modified custody and won primary for father. Mom was given SPO and ordered to pay guideline CS.


Issue: Father, an executive with a large company, wanted to achieve a more equal parenting status with his children than he received in his divorce. He wanted approximately equal time, lowered child support, more decision-making powers, etc. Before hiring us, former spouse refused to consider any changes.

Result: We set the case for jury trial. Just before trial, ex-wife agreed to a settlement, giving our client virtually everything he’d requested.Issue: Dad decided to seek Modification of Prior Divorce Decree to Impose Geographical Restriction and keep Mom from moving the child to Tennessee.


Issue: Both parties were from another state (about 12 hours drive from Texas) but had moved to Texas in the early 2000’s. After living in Texas for few years, Dad and Mom divorced three years ago. At the time of the divorce, Mom wanted to return to the former state of residence with the child, Dad wanted to stay here. The parties compromised and settled in mediation for Mom staying in Texas for three more years. After the three years elapsed, Mom said she was returning to the former state. Dad hired me to modify the Decree to keep the geographical restriction in place permanently. After a temporary hearing where the Judge ordered the child to remain in Texas pending final trial, Mom demanded a Jury trial for final hearing.

Result: In a unanimous verdict, the jury found, as we requested for Dad, that there had been a material and substantial change in circumstances to justify modifying the Decree now to impose a restriction on the child’s residence and that doing so would be in the child’s best interest. As a result, the Decree was modified to impose a geographical restriction on the child’s residence to Collin County and surrounding counties.


Issue: Modification of two-year-old divorce. Father had obtained standard rights in divorce. Mother was a stay-at-home mom with no bad facts against her other than her refusal to co-parent with Father.

Result: Obtained modification to give father equal possession and rights.


Issue: Modification of custody in Dallas County involving 3 y/o and 5 y/o girls.

Result: Modified custody and won primary for father. Mom was given SPO and ordered to pay guideline CS.


Issue: Father, an executive with a large company, wanted to achieve a more equal parenting status with his children than he received in his divorce. He wanted approximately equal time, lowered child support, more decision-making powers, etc. Before hiring us, former spouse refused to consider any changes.

Result: We set the case for jury trial. Just before trial, ex-wife capitulated in mediation and gave our client virtually everything he’d requested.

Client Reviews
★★★★★
Knowledgeable, respectful and great! Renee Moore
★★★★★
Jon, once again – Great job! I can’t begin to express how grateful I am for your overall knowledge of the law and your impressive trial skills. Simply outstanding! It may have been just another day at the office for you, but you’ve made a huge positive impact on my life and more importantly on my son’s life. Thanks again. Anonymous
★★★★★
My experience as Jon’s client was stellar and I can’t imagine having gone through everything the last few years without him going to bat for me. My case was a high conflict child custody modification. Jon is incredibly knowledgeable and he expertly applied this knowledge to my case. He has a very confident, commanding presence in the courtroom and his loyalty to the success of me and my case was clear in his actions. Our outcome was better than I expected and I am happy with the results. He and his staff are diligent, skilled and worth every cent. If you need assertive, sharp, highly skilled representation, then I absolutely recommend Jon. Anonymous
★★★★★
A most genuine ‘Thank You’ from me and my family. (I am) very fortunate that I found you in 2006 to represent me in battling The Devil in Divorce-Custody #1. It’s no secret that I hold you in high regard and probably place unfair expectations on your back to carry into battle with me. Just know that there is no one I trust more than you when it comes to guiding/representing/fighting for me and my family. You earned my respect and trust nine years ago now. I already know the quality of man I walk into the courtroom with. And that provides me a level of confidence which cannot be replaced. I’m loyal to a fault, my friend. The quality of your work and your office staff’s support and responsiveness have all been top notch in dealing with me and my family’s legal issues... Anonymous