Thomas J. Daley
Thomas J. DaleyKoonsFuller, P.C. - Texas Family Law Powerhouse
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Litigation StrategiesOpinion LibraryOur TeamFAQ
FAQ/Question

Do I have to complete an Examination Under Oath before suing my insurance company in Texas?

This question has been addressed in 1 Texas court opinion:

In re Allied Trust Insurance Company

COA01 — February 24, 2026

In an insurance dispute with significant implications for family law discovery, the First Court of Appeals denied mandamus relief after a trial court refused to abate a lawsuit for alleged failure to satisfy conditions precedent. While the insurer argued that an examination under oath (EUO) was a mandatory prerequisite to litigation, the respondent claimed her severe PTSD necessitated a remote (Zoom) format, which the insurer refused. The court analyzed whether a 'total failure' to comply had occurred and held that because there were unresolved factual disputes regarding the reasonableness of the insurer's demands and the format of the performance, the trial court did not abuse its discretion in denying the abatement.

Litigation Takeaway

“To successfully abate a case for non-compliance, you must first secure a court order defining the 'parameters of performance'; mere disagreement over the format of discovery (such as in-person vs. Zoom for a traumatized party) creates a factual dispute that prevents abatement from becoming mandatory.”

Thomas J. Daley

Texas Family Law Litigation

Sophisticated litigation strategies for Texas families. Experience, integrity, and results when it matters most.

Targeted Resources

  • Divorcing a Narcissist
  • Dividing Retirement Assets
  • Fathers' Involvement
  • High-Asset Divorce

Contact Info

  • 1-972-769-2727
  • tdaley@txfamlaw.com
  • 5700 W. Plano Parkway Ste 2200, Plano, TX 75093
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