Legal Question in Family Law in Texas

You need an attorney--you have no business fighting a custody battle by yourself. However, assuming that it's too late for that now, I would do the following:

FIRST. Type up a document like this:

SUMMARY OF TESTIMONY OF [YOUR NAME]

1. On [date] at [time], [name] [describe offensive behavior].

2. On October 15, 2011 at approximately 7:15 p.m., John Doe parked in my driveway, banged on my door, and demanded that I release Jane to him or he would burn the house down. I called the Dallas Police and, when they arrived, they told John Doe to leave.

Just create a neate, FACT-BASED (no histrionics--just facts) document like that.

SECOND: Label the document as "Respondent's Exhibit 1".

THIRD: Print 4 copies and bring them to court.

FOURTH: When it's your turn to testify, say these words:

"Your honor, I have in my hands a document marked as Respondent's Exhibit 1. May I show a copy to opposing counsel?"

(or Mr. Doe, if your ex does not have an attorney). (The judge will say yes. Hand a copy to either your ex or his attorney, a copy to the judge, and a copy to the court reporter, if there is one. Keep a copy.)

Then say, "Your honor, I have prepared this myself. If I were to testify about each and every incident described in this exhibit, this is exactly how I would testify. I move that Respondent's Exhibit 1 be admitted into evidence as a summary of my testimony."

The court is very likely to admit the exhibit, read it, and that will save you a lot of testimony.

HOWEVER, you must make sure that the exhibit only contains words that came out of your mouth, your ex's mouth, or that describe events and actions that you saw with your own eyes. If it contains anything like "After he left, his mother called me and said he always does that when he's drunk," your exhibit may get excluded for containing hearsay.

Preparing exhibits requires a lot of training and knowledge of the rules of evidence, which you don't have. So it's likely that you'll include some objectionable statements in there. If you include a sentence that the other attorney objects to as hearsay, say "Your honor, I move that this exhibit be admitted into evidence as a summary of my testimony with redactions made to statements that the court rules as inadmissible."

Good luck!!