Texas Post-Judgment Interrogatories: Questions to Ask the Debtor

You have a Texas judgment but no idea what the debtor owns or where their money is. Post-judgment interrogatories are your primary tool for finding out. Under TRCP Rule 500.9(b), you can serve written questions on the debtor without court permission — and they're required to respond, subject to any objections.

How Post-Judgment Interrogatories Work in Justice Court

Texas Justice Courts draw a sharp line between pre-trial and post-trial discovery. Pre-trial discovery requires a written motion, service on the other side, and a signed court order approving it (Rule 500.9(a)). Post-judgment discovery skips all of that.

After the final judgment is signed, you can serve interrogatories directly on the debtor (or their attorney) at any time. No motion, no court hearing, no judge approval. The debtor has 30 days from the date of service to respond in writing under oath.

What Questions to Ask

Your interrogatories should target every asset category that's relevant to enforcement:

Bank and financial accounts:

• Name and address of every bank, credit union, or financial institution where you hold an account
• Account numbers and current balances for each account
• Whether any account receives direct deposits and from whom

Employment and income:

• Current employer's name and address
• Position, pay rate, and frequency of payment
• Any secondary sources of income (freelance, rental, business distributions)

Real property:

• Address and legal description of every parcel of real property you own in any Texas county
• Whether each property is your homestead
• Mortgage balances and lender names

Vehicles and titled property:

• Year, make, model, and VIN of every motor vehicle you own or lease
• Loan balances on each vehicle
• Boats, trailers, or recreational vehicles

Business interests:

• Name and type of every business entity in which you hold an ownership interest
• Value of your interest
• Business bank account locations

Other assets:

• Cash on hand exceeding $100
• Anticipated payments (insurance settlements, tax refunds, commissions, inheritance)
• Safe deposit box locations

Serving the Interrogatories

Prepare your interrogatories in writing, include a certificate of service, and serve them on the debtor by:

• Certified mail, return receipt requested
• Hand delivery
• Through eFileTexas if the debtor has an attorney of record

Keep proof of service — you'll need it if you end up filing a Motion to Compel.

When the Debtor Doesn't Answer

If 30 days pass with no response, your options escalate:

1. Send a follow-up letter reminding the debtor of the 30-day deadline and that you intend to file a Motion to Compel.
2. File a Motion to Compel under TRCP Rule 215. The court schedules a hearing, and the judge can order the debtor to respond within a set number of days.
3. Sanctions for continued refusal. If the debtor violates a court order compelling responses, the judge can impose monetary sanctions or hold the debtor in civil contempt.

In practice, most debtors respond after a Motion to Compel is filed — the prospect of a contempt hearing gets their attention.

What You Can't Ask

Keep post-judgment interrogatories focused on information relevant to identifying assets. Don't ask about the debtor's personal relationships, medical history, or political activities. Overly broad or harassing questions give the debtor grounds to object, slowing down the process.

Also remember TRCP Rule 21c: when you file any documents with the court that contain the debtor's responses, you must redact sensitive data — Social Security numbers, full bank account numbers, birth dates, driver's license numbers, home addresses, and names of individuals who were minors when the lawsuit was filed.

Interrogatories vs. Oral Deposition

Written interrogatories are cheap and don't require scheduling. An oral deposition (a sworn, recorded interview under TRCP Rule 199) lets you ask follow-up questions in real time, which is useful when the debtor's written answers are evasive or incomplete. Depositions cost more — you may need a court reporter — but they're available for post-judgment use if interrogatory answers aren't enough.

The Collecting a Small Claims Judgment in Texas guide includes sample interrogatory question sets and a discovery timeline so you can start identifying assets immediately after judgment.

See more Texas guides →