G. Filing Suit Prior to Taking Possession of Child

1. When it is Not Necessary to Remove a Child Prior to Notice and Hearing

An original suit filed by a governmental entity that requests to take possession of a child after notice and a hearing must be supported by an affidavit sworn to by a person with personal knowledge and stating facts sufficient to satisfy a person of ordinary prudence and caution that:

•   Reasonable efforts have been made to prevent or eliminate the need to remove the child from the child’s home; and

•   Allowing the child to remain in the home would be contrary to the child’s welfare. Tex. Fam. Code § 262.113.