CAUSE NO. ##########

YOUR CASE STYLING GOES HERE					§										IN THE DISTRICT COURT
																																§	
EXACTLY AS IT NORMALLY ALSO				§										999th JUDICIAL DISTRICT
																																§
APPEARS ON OTHER CASE DOCS						§										XXXXXX COUNTY, TEXAS

Motion to Vacate All Child-Related Orders for Lack of Jurisdiction

COMES NOW FirstName LastName, PartyLabel herein, moving the Court to vacate all prior orders in these matters about parent-child relationships, such as, but not limited to, child custody, support, and parenting time, for refund of monies falsely taken, and other relief, stating thusly:

INTRODUCTION
This Motion includes direct challenges to the very existence of any matters herein involving parent-child relationships, because such exists only upon state statutes facially repugnant to the federal Constitution for at least five (5) distinct “structural” violations of due process, the same set of constitutional infirmities that render every other such Texas state case also void ab initio.
The issues raised herein are *statewide challenges* and not limited to any particular orders or judgments of this instant state court itself, but focused upon the unconstitutional statewide practices of violating the fundamental rights of every person passing through the system doors.
All of Texas’ state court cases styled as “Parent-v-Parent” or are, at their core, suits between pairs of adversarial natural parents litigating over child custody rights and other matters of the parent-child relationship, are absolutely and wholly void for shocking total lack of even the most basic due process, including: (1) the state courts cannot actually “award” or “grant” custody to either natural parent because both already have full custody rights before ever entering the state court; (2) lack of using the clear and convincing evidentiary standard to attempt impacting the custodial rights of any minor child; (3) lack of jury trial availability, up front, to defend against losing that fundamental right; (4) natural parents have no legal standing to sue each other over their fundamental rights, but only the State itself can attack such rights; and (5) the Title IV-D scheme creates direct manifest conflicts of pecuniary interest in the court officers themselves.
Each of these five (5) glaring reasons of shocking infirmity is a “structural” violation of due process, i.e., of such manifest error against even the foundation of a court case, that all is void.
Because the primary, overarching issue is the set of facial challenges to Texas’ state statutes, the State of Texas is now a legally necessary party herein, regardless of party labels affixed.
No other party herein may attempt to speak in the stead of AG Paxton upon the state statutes.
Because all such cases are patently and manifestly void ab initio, while using the power of the state as threats and/or actual acts of incarceration for extortion of monies via such false and void state case, the state family law industry is also therefore involved in massive human trafficking.
Accordingly, the undersigned could also invoke various formal claims for appropriate awards of compensatory, consequential, punitive, and other civil damages and such other related relief, whereas currently the facial challenges have been raised herein solely for declaratory relief which is therefore appropriate, i.e., for correction of Texas’ wayward practices concerning child custody rights into constitutional compliance with the fundamental rights of all natural parents.
FACTUAL ALLEGATIONS
1.	  All natural [biological] parents already have full and fully vested child custodial rights to their child/ren from the very moment(s) of each such said child’s birth, which is why only the parents may legally sign school field trip permission slips, approve any doctors/treatments for their child, and dictate their child’s residence, nutrition, religion if any, life activities, and etc.
2.	  The aforementioned rights are constitutionally-protected rights of the highest order, clearly entitled to at least all of same due process protections that are afforded for the enumerated rights in the federal Constitution, particularly the First Amendment, if said rights are not already necessarily included as part of the rights inherent under the Ninth and/or Tenth Amendments.
3.	  The required constitutional due process protection of those same rights implicates other rights under at least the First, Fifth, and Fourteenth Amendments, as well as implicates issues under Article 1, Section 10 of the federal Constitution, issues of our state constitution, and more.
4.	  The same pre-existing, constitutionally protected rights of child custody cannot be taken away (“removed” or “terminated”) by any state action, unless and until there is first proven, by clear and convincing evidence under full due process, something of very serious nature in imminent harm to the given minor child/ren (serious abuse, serious neglect, and/or abandonment of said child/ren), i.e., state action regarding parental rights is limited strictly and only to “removing” or “terminating” a given parent’s child custodial rights upon the required legal proof of serious unfitness via a bona fide CPS/TPR (child protection services/termination of parental rights) type of case with full due process case procedures including right to jury trial option.
5.	  Without proof of serious unfitness achieved via such CPS/TPR case conducted under constitutionally-compliant procedures, both of the natural (biological) parents of any given child/ren are legally still presumed as fit – and even more importantly – as equally fit parents.
6.	  Presuming legal fitness, those same child custodial rights (direct blood relationships / direct kinships of the first degree) are fully and equally shared by both said fit natural parents, regardless of any marriage or cohabitation or not between such parents (any of which is only a social construct arrangement or not between persons of non-blood relationship) (further noting that such arrangements involving blood relationship are inherently unlawful in all jurisdictions).
7.	  The State of Texas and its various state courts cannot simply and completely ignore and bypass those pre-existing and fully-vested child custodial rights of a natural parent, by using ostensible statutes that pretend that they can do that – all such statutes are repugnant and void.
8.	  Therefore, all such Texas child custody determination statutes are, in clear fact, facially unconstitutional for illegally pretending exactly that – falsely creating state court cases that automatically deprive natural parents of those pre-existing federal rights by completely and totally ignoring those rights, even without pre-deprivation notices of any kind, and then pretending further falsely via absolutely void dog-and-pony-show proceedings that either or both parents might be given back part or all of their same pre-existing rights after the state court “awards” or “grants” those very same rights, fundamental rights which were never even lawfully taken away (“removed” or “terminated”) in the first place.
9.	  In addition to all of that facial infirmity in wholly fraudulent and total deprivations of constitutionally-protected rights without ANY pre-deprivation due process or notice whatsoever, said same state statutes are also repugnant to the federal Constitution for falsely pretending within all such similar cases that the custodial rights of minor children may be changed under mere preponderance evidentiary standards, when in fact the clear and convincing evidentiary standard is always required for any such process involving direct blood relationships, let alone direct blood relationships of the first degree.
10.	  Although state courts reasonably have jurisdiction to settle matters between non-blood relationship parties (dissolution of marriage, legal separation, and/or similar issues between formerly cohabitating adult persons), state courts have absolutely no jurisdiction over said direct blood relationships between each and every natural parent and his or her child/ren, unless and until a given CPS/TPR case establishes [serious] parental unfitness via full due process first.
11.	  That in addition to the above facial constitutional infirmities, all such state court cases are also constitutionally void on their faces for illegally allowing direct pecuniary conflicts of interest by state court judges, local prosecutors, clerks, and even the counties themselves in regards to every Title IV-D child support case, which further relates to the federal Consumer Credit Protection Act issues raised herein as well as also to the federal False Claims Act issues raised herein, hence those state statutes are also generally named and facially challenged herein.
12.	  All such state statutory schemes, all predicated on the Federal Government’s enactment of “welfare” laws that were designed strictly to help provide support of children *abandoned* by their parents (hence, welfare laws like Title IV-D including provisions for child support orders strictly within the follow-up context of only CPS/TPR cases...), have been grossly misapplied via the other above constitutional infirmities, now into a completely falsified systemic welfare scam against all natural parents illegally dragged into and through such facially void state court cases.
13.	  Accordingly, all said repugnant state statutes of the State of Texas must be struck down for said multiple infirmities in violation of the federal Constitution, or at minimum corrected to a reasonable level of constitutional compliance regarding deprivations of fundamental rights.
14.	  The undersigned is a victim of unconstitutional rights deprivations and related injuries suffered from these sham proceedings, by having my pre-existing child custody rights stolen by the Court without ever once being first found, by clear and convincing evidence, as too seriously unfit to retain the same custody rights, further depriving my parenting time with my progeny to less than equal shares with the other natural parent herein, and further subjecting me to Title IV-D child support and related orders under color of law, including threats of being falsely arrested and jailed without due process, to falsely deprive me of my monies, and therefore also causing consequential damages to the undersigned’s reasonably expected life, livelihood and life station.
15.	  All other similarly situated natural parent victims of Texas’ courts are all victims of the very same unconstitutional rights deprivations suffered from the State of Texas vis-à-vis being parties to court cases of Texas counties, each having their pre-existing child custody rights stolen by Texas and the given court actors involved without ever once being first found, by clear and convincing evidence, as too seriously unfit to retain the same custody rights, each further deprived of their parenting time with their respective blood children to less than equal shares with the given corresponding other natural parent, and each further subjected to Title IV-D child support and related orders under color of law, including threats and/or implied threats of even being arrested and facing jail time, to falsely deprive them of their monies and finances in ongoing manner, and therefore also causing consequential damages to each such other similarly situated natural parent’s otherwise reasonably expected life, livelihood and life station.
16.	  Each and every such said Title IV-D child support order – and the determination of the actual regular and/or lump sum amount of “child support” falsely ordered to be paid by each such similarly situated parent – was directly fashioned and was directly controlled and is directly enforced by elected and/or appointed officials of the exact same corresponding Texas county, including Texas’ state and county judges, Texas’ county clerks, Texas’ county prosecutors, and Texas’ counties, and it has all been perpetrated at the State of Texas’ full insistence within each and every such court case.
17.	  The State of Texas’ agents described just above in ¶ 16 have all falsely profited due to creating and enforcing their Title IV-D scheme of unjust enrichment, by using repugnant statutes to attempt justifying ongoing massive statewide daily patterns and practices of various fundamental rights violations, so as to falsely drum up massive financial flow to their Title IV-D accounts, earning all pass-through interest, and then sharing those profits amongst themselves.
18.	  The State of Texas’ agents described above in ¶¶ 16 and 17 reasonably knew and/or should have known that illegally created Title IV-D child support orders and attendant income garnishment orders violates the federal Consumer Credit Protection Act, because failing to afford the given natural parents described herein any due process whatsoever in stealing their same parental pre-existing rights of child custody obviously violates the requirement of 15 U.S.C. § 1673(b)(1)(A) to always afford “substantial due process” regarding such orders, and that therefore also, the State of Texas and its agents reasonably knew and/or should have known that any enforcement of such illegal orders was strictly prohibited. 15 U.S.C. § 1673(c).
19.	  The State of Texas and its agents described above in ¶¶ 16 and 17 reasonably knew and/or should have known that submitting invoices to the Federal Government for Title IV-D reimbursement claims based upon illegally created Title IV-D child support orders was and is in itself an unlawful routine pattern and practice of acts of making false claims to the United States, in violation of various federal laws, including the False Claims Act, 31 USC § 3729, et seq.
20.	  Within this instant state court case, the legal professionals, i.e., the various officers of this Court, knowingly conspired to use false “orders” to deprive me of my fundamental parenting rights and to also falsely threaten me with jail for shocking extortion of my monies.

ARGUMENT:		EVERY SUCH STATE CASE IS VOID FOR THESE FIVE (5) REASONS
21.	  There are five (5) main systemic constitutional violations of every such state case.
Argument 1 – The family court *literally* steals fundamental rights of natural parents to their children, without ANY due process, whatsoever, by totally ignoring their pre-existence.
22.	  Natural parents *already have* full custody rights to their child/ren *before* they ever got involved with any family court.  There is no magical difference of any kind between them (a natural parent opposing the other natural parent over their mutual child/ren), versus some given parent targeted by an actual CPS case, versus the random other natural parent out there who has never been involved with any court for anything -- every natural parent *already has* full legal and physical custody rights to their minor child from the very moment of that child's birth.  This is why parents (and ONLY the actual parents) can *legally* sign school field trip permission slips, make any and all medical, education and all other life decisions for their child, dictate the child's diet, the child's religion if any, and also decide literally everything else for their child.  It is *because* the fundamental rights of child custody *already exist* in each corresponding natural parent in total regards to their minor child/ren.
23.	  This is also *why* the legal goal of every CPS case is to “terminate” or “remove” the targeted parent’s child custody rights... because those rights *already pre-exist* in every natural parent, so the State has to terminate or remove (takeover) the legal custody rights to the poor child/ren in that sad situation (by proving serious unfitness), so that the State THEN can later *actually give away* those child custody rights to someone else “better” (as a temporary “grant” or “award” of child custody to foster parents, or as a permanent “grant” or “award” of child custody to adoptive parents).
24.	  But the family court (the power of the State) in their own personal case never terminated or removed those exact same pre-existing fundamental rights of child custody, and that family court never actually took over custody rights of their natural child/ren in the first place, all properly done via an actual CPS case with full due process, so that it could then actually “award” or “grant” custody of their child/ren to *either* opposing parent... let alone the glaring fact that, without ever being proven as legally unfit by a bona fide CPS case, both opposing parents already had and have full and equal shares of those same fundamental child custody rights, as still deemed legally fit (and under law, equally fit) parents.
25.	  The family court can NEVER actually “grant” or “award” custody to EITHER natural parent in such type of situation, because both parents *already had and have* full and equal custody rights.  The ONLY thing that the state court can ACTUALLY do to parent-child relationships is “terminate” or “remove” pre-existing child custody rights (but again, only via an authentic, full-blown CPS case proven first).
26.	  The family court cannot giveaway custody it has not yet obtained, to either of parents who both already have full custody.  The entire notion is ridiculous, and is a blatantly unconstitutional fraud, farce and sham on its plain face.  The family court *literally* steals fundamental custody rights by just pretending that they don’t even exist (and by further pretending that it can then “award” or “grant” those fundamental rights in whole or part BACK or not as it pleases).  And yet the same family court judges, and many family law attorneys, work in CPS cases also, so they already know natural parents already have those very same pre-existing fundamental rights.
27.	  Literally stealing a parent’s pre-existing fundamental constitutional rights, by just falsely pretending that they don’t even exist, is a blatant fraud of such epic magnitude to clearly void the entire case for absolutely total lack of ANY of the required pre-deprivation due process ever performed, whatsoever – an egregiously manifest “structural” violation of due process which voids the entire case as fatally invalid.
Argument 2 – Family courts cannot use an insufficient evidentiary standard over child custody.
28.	  Family courts simply cannot use the mere preponderance evidentiary standard to affect child custody rights, but must always use the clear and convincing evidentiary standard when it comes to any direct-blood relationship, let alone regarding any parent-child relationship, which is a direct-blood relationship of the *first* degree of kinship... the most important kind of direct-blood relationship that exists under law.
29.	  Courts can use preponderance of the evidence to separate non-blood relationships, like between opposing parents themselves, and attend to the intertwined matters between those non-blood parties, like division of marital assets and debts, but courts cannot use mere preponderance to separate or even diminish direct-blood relationships like any parent-child relationship.
30.	  Again, this is why an actual CPS case (filed only by the State itself) always uses the clear and convincing evidentiary standard of proof to attack parental custody rights.
31.	  Using an insufficient evidentiary standard is a “structural” violation of due process which voids the entire case as fatally invalid.
Argument 3 – Lack of available jury trial option *before* deprivations of fundamental rights. 
32.	  Child custody rights of natural parents are well recognized as fundamental rights, the highest form of constitutional rights, absolutely protected by full due process procedures before any fundamental right may be deprived, and such full due process includes the right to have the proof proven by way of full jury trial at the option of the person whose such right is being attacked.  Texas is the only State that does, in fact, provide for a jury trial option over normal child custody disputes between the adverse parents (which itself is invalid because the State is the only proper party that can even attempt to modify any parent’s child custody...), but even Texas courts issue “temporary” and other orders (whether in a divorce case, paternity case, child support case, protective order case, and/or similar/related case) that unconstitutionally bypass the required due process availability of jury trial option to defend against just being summarily deprived of your basic fundamental rights, i.e., under various Texas statutes, the state courts unconstitutionally pretend they can just negatively impact and deprive any parent of their protected fundamental custody rights without ever (1) even recognizing that those same pre-existing rights already exist, (2) further recognizing those rights as protected fundamental rights entitled to full due process procedures (3) under clear and convincing evidence, and specifically also (4) providing said parent with that option of jury trial to defend against the potential loss of parenting rights.  Lack of available jury trial option *up front* for defense against any possible deprivation of fundamental rights, by such “temporary” and/or by such other described “family” orders, is a “structural” violation of due process which voids the entire case as fatally invalid.
Argument 4 – Natural parents cannot actually sue each over fundamental child custody rights.
33.	  Let me rephrase that just slightly: private parties cannot sue each other directly over fundamental rights.  Regarding the normal child custody dispute between the adverse parents, that in itself is directly invalid on its face, because the State is the *only proper party* that can even attempt to modify or decrease or deprive any natural parent’s fundamental rights of child custody.  ONLY the State itself has the potential cause of action, and legal standing, under the “parens patriae” legal doctrine, to attempt to modify and/or limit, in any way, some natural parent’s fundamental rights of child custody.  Simply put, no private citizen, including the other natural parent of someone’s child/ren, has EVER had valid legal “standing” to sue that adverse natural parent in any attempt to either modify or decrease or deprive fundamental rights of child custody.  Only the State itself has legal standing to sue any natural parent in regards to their child custody rights....  See again, a bona fide CPS/TPR case.
34.	  Another private party can *indirectly* attack you regarding public speech (fundamental First Amendment rights), but ONLY if they invoke the government power, via complaint, because you allegedly *abused* that constitutional right.  Another private party can *indirectly* attack you over your possession of guns (Second Amendment right to bear), but only if they are a victim of your guns (personal harm or threat of personal harm), thereby invoking government power because you allegedly *abused* that fundamental constitutional right.  The private party can sue for torts like personal injury, mental anguish, etc., but only the State can directly attack the “possession” (2A right to bear) aspect, because that is a fundamental right.  Another private party, even the opposing natural parent, cannot sue another private person *directly* to limit or modify or take away their fundamental constitutional rights of child custody.
35.	  However, a private party can still *indirectly* invoke the government power (the State) against your child custody rights, but once again, ONLY if you have *abused* that fundamental right, i.e., you have committed serious child abuse and/or serious child neglect, by that private party (even your opposing parent) filing a valid complaint with some arm of the government to investigate (the whole idea falling under the very same parens patriae legal doctrine as CPS cases).  And so likewise again, the only direct legal standing for such situation is by the State itself, via filing a bona fide CPS/TPR case with full due process steps including jury trial defense option.  Every child custody case, regardless of which parent “sued” the other, is flatly and entirely void for lack of ever having proper parties in the first place, i.e., it is void for lack of proper parties (lack of standing), and once again, such a manifestly erred foundation of the case itself is a “structural” violation of due process which voids the entire case as fatally invalid.
36.	  To clarify an important distinguishing aspect, natural parents (who are not blood related, by definition) can sue each other directly all day long, under mere preponderance, to separate their *own* relationship (divorce or similar, divisions of assets and debts, and related matters), but they have no legal standing to *directly* sue each other for seeking any impingement and/or deprivation of each other’s direct-blood parent-child relationships, because those rights are constitutionally protected fundamental rights, which can only be attacked by the State itself.
Argument 5 – The Title IV-D kickback scheme unlawfully incentivizes direct conflicts of interest by court officers.
37.	  The reason *why* every Texas family court orders any and all child support to be paid into the official “SDU” (State Disbursement Unit) accounts is because these “holding” accounts earn interest -- LOTS of interest money earned upon all of the many child support payment amounts passing through, on their way to being later disbursed out to the so-called “custodial” parents.  This huge amount of bonus monies earned via said interest-bearing pass-through accounts is then divided out in pro-rata shares paid to the salaries and/or budgets of the judges of the county, the main clerk of the county, the local prosecutor, and even to the county itself.
38.	  The more child support is ordered, the higher each of their respective kickback interest share cut amounts.  This direct pecuniary benefit of each child support case processed is a directly unethical conflict of interest, i.e., the officers of the court themselves have direct conflicts of interest in every single Title IV-D child support case that they create and process and enforce, all of which is highly unconstitutional on its face.  Even the county itself has a conflict of interest (as to proper venue) regarding its own Title IV-D cases.
39.	  It is basic Legal 101, it is axiomatic, that no judge may ever be involved with either creating and/or presiding over any case in which the judge derives any pecuniary benefit (not to mention also the conflicts by the main clerk, and potentially by the local prosecutor too for any such future enforcement of said child support amounts whether civilly and/or criminally).
40.	  Having a judge with a (known, i.e., premeditated) direct pecuniary conflict of interest to the case itself is a “structural” violation of due process which voids the entire case as fatally invalid.  Normally such an ongoing sham is called a fully premeditated criminal spree of endless theft and/or fraud, which also makes it graft, subject to federal RICO claims, and so forth.
I AM ENTITLED BY LAW TO BE MADE CONSTITUTIONALLY WHOLE AGAIN
41.	  In American jurisprudence, to be “made constitutionally whole” means that the courts must use their remedial powers to restore a person to the position they would have been in had a constitutional violation not occurred.  This bedrock principle is a key part of constitutional law, particularly civil rights law.
42.	  Key aspects of being made constitutionally whole include restoration of rights.  The concept is tied to the idea that for every constitutional right, there must be an effective remedy if that right is violated.  For example, the right to due process, the right to equal protection, and the right against unreasonable searches all have corresponding legal remedies.
43.	  Courts have broad authority to fashion remedies that address and correct constitutional infringements by government actors.  The remedies can vary depending on the nature of the constitutional violation and may include injunctions, declaratory relief, and damages as monetary compensation to address harm caused by the violation.
44.	  It is not a form of punishment.  The goal of a constitutional remedy is not to punish the offending government entity but to provide complete relief to the victim of the constitutional violation(s) and related injuries and harms suffered thereby.
45.	  Relief may not always be perfect.  While the goal is to make a person “whole again,” courts and legal scholars acknowledge that it is not always possible to fully erase the harm caused by a violation.  The remedy is often the most appropriate and just course of action available under the circumstances.
46.	  The undersigned victim natural parent is therefore entitled to an award of compensatory damages for such injuries, for refund of all monies taken and/or lost due to such wholly void travesty of injustice against his fundamental rights, an appropriate award of civil damages for the false and tortious deprivation of my parent-child relationship rights, the loss of society and companionship with my progeny in less than equal shares than that of the other natural parent, and damages for being falsely threatened with arrest and jailing for extortion of my monies.
47.	  If I do not substantially receive the relief below within the thirty (30) days next, then I can and may raise such related formal causes of action, against various actors herein, for civil damages much higher than what I am briefly offering by and within the prayer for relief below.
48.	  I further note that the issues raised herein point to very serious other matters that could also be addressed, such as under Chapter 98 of the Texas Civil Practice and Remedies Code, Sec. 98.001, et seq., Liability for Trafficking of Persons, as well as also under Chapter 106 of the Texas Civil Practice and Remedies Code, Sec. 106.001, et seq., Discrimination Because of Race, Religion, Color, Sex, or National Origin, also under Chapter 7  of the Texas Civil Practice and Remedies Code, Sec. 7.001, et seq., Refusal or Neglect in the Performance of Official Duties, also under Chapter 12 of the Texas Civil Practice and Remedies Code, Sec. 12.001, et seq., Liability Related to a Fraudulent Court Record or a Fraudulent Lien or Claim Filed Against Real or Personal Property, and so forth for civil liabilities, and of course there are variously related criminal liabilities that could also come into play, such as Securing Execution of Document by Deception, in violation of Texas Penal Code, Title 7, Section 32.46, also Tampering With Governmental Record, in violation of Texas Penal Code, Title 8, Section 37.10, also Abuse of Official Capacity, in violation of Texas Penal Code, Title 8, Section 39.02, also Official Oppression, in violation of Texas Penal Code, Title 8, Section 39.03, along with charges for first degree felony racketeering under Texas Penal Code, Chapter 71, Organized Crime, and charges for first degree felony continuous trafficking of persons under Texas Penal Code, Chapter 20A, Trafficking of Persons, and so on and so forth, not to even start mentioning the various federal penal violations, such as those regarding the violations of the federal Consumer Credit Protection Act in also routinely violating the federal False Claims Act, all as aforementioned.
CONCLUSION AND PRAYER FOR RELIEF
49.	  The state statutes of Texas that pretend to “award” or “grant” custody of children betwixt fit natural parents are utterly and manifestly void, for multiple reasons, all as aforementioned.
50.	  Unless enjoined by the Court, the State of Texas and its state courts and actors therein will continue to violate the constitutional rights of all similarly situated natural parents, including of the undersigned, and I am therefore entitled to an order of the Court enjoining Texas and its state courts from further violations of all natural parents’ rights to due process in relation to their well-established, protected fundamental parental rights of physical and legal child custody.
51.	  Accordingly, I am entitled by law to at least the following forms of prompt relief:
a)	  vacatur of all prior orders relating to any child issues, i.e., custody, support, parenting time schedules, income garnishment orders, and so forth;
b)	  total purging of this case information, my name, and so forth, from the Title IV-D / SDU accounts system;
c)	  for any related negative information existing, total purging of this case information, my name, and so forth, from any and/or all of the three (3) major U.S. credit rating bureaus, i.e., Equifax, Experian, and Transunion;
d)	  full refund of all monies taken from me under the guise of child support, with interest as by law provided;
e)	  full reimbursement of all of my attorney fees needlessly forced to be expended in defense litigation of any and all such child issues of these proceedings from the beginning, also with interest as by law provided;
f)	  full reimbursement of all other monies I was unlawfully forced to pay herein (NAME AND LIST/DESCRIBE THAT/THOSE AMOUNTS HERE, OR DELETE THIS LINE);
g)	  removal of my name from the official Texas Courts listing of vexatious litigants (IF THIS SITUATION IS NOT APPLICABLE TO YOU, THEN DELETE THIS LINE);
h)	  issuance of a new parenting time schedule Order that incorporates an immediate commencement of full 50/50 parenting time schedule and the same continuing throughout minority, together with one (1) of the following four (4) options at the available choice of the other natural parent herein, also commencing immediately:
i.	  pay me civil damages for all false deprivations of my equal parent-child relationship rights [of my equal legal and physical custody rights] at the rate of $206/child/day for each full day, or portion of a day, that I have been so deprived of less than the full 50/50 parenting time that I was always due from the beginning of these matters; OR,
ii.	  in addition to full 50/50 parenting time, that I will exercise/have an ongoing, regular amount of “makeup” time of an amount calculated to finally balance out at actual 50/50 parenting time by the last day of child minority; OR,
iii.	  any mixture/combination of options “i” and “ii” just above that includes a minimum of fourteen percent (14%) of the amount of ongoing “makeup” extra parenting time otherwise required by option “ii” just above; OR,
iv.	  fail to choose and formally agree to any of the above (3) options within thirty (30) days of today’s filing date, in which event all above options are forfeited to my choice from amongst the same options;
i)	  that the new parenting time schedule between the parties, as determined above, be spelled out exactly from the present day until the last day of child minority herein, including all future dates and times of child exchanges;
j)	  that the aggregate of all above monetary sums combined be reduced to judgment in writing against the other parent and in favor of this undersigned parent, enforceable by right in my name, with said judgment to duly let execution lie thereupon;
k)	  further, that said final Order of this Court shall include terms specifying the calendar years of each party for federal and state tax purposes of claiming dependent deductions, Earned Income Credits, and so forth, also ensuring to balance out as needed that both parties shall have had an equal number by the year of the last day of child minority herein, of such favorable tax year benefits, even by increasing the undersigned parent’s future share of said tax years by one (1) as needed to obtain such balance, unless the parties themselves mutually agree otherwise and present the same agreement in writing signed by both parties to this Court within the coming thirty (30) days next;
l)	  further, that the Court retain continuing exclusive jurisdiction until the last day of child minority herein in order to enforce all terms of said final Order, including by contempt, as may become necessary and appropriate; AND,
m)	  all other just relief good and proper within these premises.

WHEREFORE, the PartyLabel herein, FirstName LastName, now prays this Court issue a declaratory judgment enjoining said repugnant child custody statutes and statewide court practices of manifest unconstitutionality, orders the above relief to make this PartyLabel constitutionally whole again, and further prays for all other relief that is true, just and proper within these premises.
Dated:  October 6th, 2025
																																			Respectfully submitted,

																																			/s/ FirstName LastName
______________________________
																																			FirstName LastName
Street Address
City, State, ZIP
Tel:		(###) ###-###
Email:		myemailaddress@somewhere.com

CERTIFICATE OF SERVICE

I hereby certify: that on this _6th_ day of October, 2025, a true and complete copy of the foregoing motion to vacate all child-related orders, et seq., by e-service to all registered filers of this case automatically provided via the Texas E-File system, has been duly served on:

(for Other Parent’s Name Here)														(for the State of Texas)
Other Parent or Attorney Name														State of Texas
Address Line 1																									c/o Attorney General W. Kenneth Paxton
Address Line 2 as needed																		P.O. Box 12548
City, State, ZIP																									Austin, TX  78711-2548

																																			/s/ FirstName LastName
______________________________
																																			FirstName LastName