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Click here for the full text of this decision FACTS:Judgment debtors Ron Smith and Main Place Custom Homes Inc. filed motions seeking review of the trial court’s order setting aside their cash deposits in lieu of supersedeas bond to suspend enforcement of the trial court’s judgment and sustaining the judgment creditors’ challenge to their net worth affidavits (in the affidavits, Smith averred that his net worth was negative $167,206 and that Main Place’s net worth was $0). The court treats the motions as petitions for writ of mandamus. HOLDING:The court conditionally grants the writ and directs the trial court to enter additional findings as to Smith’s net worth and the determination that R. A. Smith & Company Inc. is Smith’s alter ego. The court further directs the trial court to determine Main Place’s net worth and to issue an order that states with particularity the factual basis for that determination. The trial court abused its discretion by issuing an order that did not state with particularity the factual basis for its determination of Smith’s net worth and that did not state Main Place’s net worth as required by Teas Rule of Appellate Procedure 24. When a judgment creditor files a contest to the judgment debtor’s affidavit of net worth, the trial court must hold a hearing and “issue an order that states the debtor’s net worth and states with particularity the factual basis for that determination.” Rule 24.2(c)(3). The trial court abused its discretion here because it failed to state with particularity the factual basis for its determination that Smith’s net worth was $1,142,951. The trial court did not make any findings that would permit a reviewing court to ascertain the basis for that determination. Further, the trial court found that R.A. Smith & Company Inc. was Smith’s alter ego without stating the factual or legal basis for that conclusion. Because the trial court must enter additional findings to support its alter ego determination, and because post-judgment discovery is, at the time of the opinion, still ongoing, the court reserves judgment on whether the trial court abused its discretion in determining that R.A. Smith & Company Inc. is Smith’s alter ego for purposes of Rule 24.2(c). However, the trial court’s consideration of the alter ego theory in the post-judgment net worth proceeding was not an abuse of discretion. But an alter ego finding in a post-judgment net worth proceeding may not be used to enforce the judgment against the unnamed alter ego or any other nonjudgment debtor, but only to determine the judgment debtor’s net worth for the purposes of Rule 24. The trial court failed to determine Main Place’s net worth as required by Rule 24.2(c)(3). Rule 24.2(c)(3) clearly provides that after the hearing the trial court must issue an order that states the judgment debtor’s net worth. To the extent that a judgment debtor is uncooperative with reasonable discovery concerning the judgment debtor’s net worth, the trial court may take appropriate steps to ensure that discovery is completed before the hearing on the judgment creditor’s contest. The trial court’s conclusion that Smith and Main Place were attempting to avoid answering post-judgment enforcement discovery by filing the cash deposits in lieu of bond and affidavits of net worth was reasonable, the court determines. The court declines Smith’s and Main Place’s requests to review the discovery sanctions order in this proceeding. A sanctions order is appealable when the judgment is signed. Smith and Main Place filed a separate appeal of the trial court’s sanctions order; accordingly, they have an adequate remedy by appeal. The court of appeals should have conducted a legal and factual sufficiency analysis of the trial court’s net worth determination, but the trial court’s failure to make the required findings prevented the court of appeals from conducting the necessary sufficiency review. OPINION:Per curiam.

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