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Rule 190 - Discovery Limitations 190.1 Discovery Control Plan Required. Every case must be governed by a discovery control plan as provided in this Rule. A plaintiff must allege in the first numbered paragraph of the original petition whether discovery is intended to be conducted under Level 1, 2, or 3 of this Rule.
An examination for discovery is an important part of almost every civil lawsuit. It is not a trial but rather a pre-trial process at which lawyers for each of the parties questions other parties or their employees, under oath, about the matters involved in the lawsuit.
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.
Under new Rule 190.3, discovery begins when initial disclosures are due (as opposed to when suit is filed under the old rules) and continues until: 30 days before the trial date in Family Code cases; or. In other cases, the earlier of. 30 days before the trial date, or. Nine months after initial disclosures are due.
Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
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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.
Interrogatories are to be raised at a pre-trial stage and must have a close connection with the matter in question, whereas cross examinations have a wider scope of questions that can be asked.
The answers given in interrogatories can be used in court during a trial. The information from the interrogatories saves time in a trial because the basic facts have already been established and do not need to be repeated through questions of the witnesses in court.
How to Persuade a Judge Your arguments must make logical sense. Know your audience. Know your case. Know your adversarys case. Never overstate your case. If possible lead with the strongest argument. Select the most easily defensible position that favors your case. Dont try to defend the indefensible.
Any party may serve on any other party no more than 15 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents. Each discrete subpart of an interrogatory is considered a separate interrogatory.

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