Discovery Interrogatories from Plaintiff to Defendant with Production Requests - Texas 2025

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Unlike interrogatories Requests to Produce are not limited in number. Upon receipt from the opposing party your business lawyer working with you will assess whether any requests are objectionable and what should be produced. These production requests are regularly used in lawsuits.
(2) Total time for oral depositions. Each side may have no more than 50 hours in oral depositions to examine and cross-examine parties on the opposing side, experts designated by those parties, and persons who are subject to those parties control.
The discovery period for Level 1 cases begins when the first initial disclosure is due and continues for 180 days, unlike Level 2 discovery in family cases, which continues until 30 days before trial. If you plead a Level 1 case, do not get trapped by this deadline!
Rule 190.3. Discovery Control Plan - By Rule (Level 2) (2021) (a) Application. Unless a suit is governed by a discovery control plan under Rules 190.2 or 190.4, discovery must be conducted in ance with this subdivision.
4. Rule 193.3(d) is a new provision that allows a party to assert a claim of privilege to material or information produced inadvertently without intending to waive the privilege. The provision is commonly used in complex cases to reduce costs and risks in large document productions.
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The request must specify the items to be produced or inspected, either by individual item or by category, and describe with reasonable particularity each item and category. The request must specify a reasonable time (on or after the date on which the response is due) and place for production.
Rule 197 - Interrogatories to Parties 197.1 Interrogatories. A party may serve on another party - no later than 30 days before the end of the discovery period -written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195.
Each side may have no more than 50 hours in oral depositions to examine and cross-examine parties on the opposing side, experts designated by those parties, and persons who are subject to those parties� control. �Side� refers to all the litigants with generally common interests in the litigation.

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