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192.3 Scope of Discovery. (a)Generally. In general, a party may obtain discovery regarding any matter that is not privileged and is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party.

(e) Custody, inspection and copying. The party obtaining the production must make all materials produced available for inspection by any other party on reasonable notice, and must furnish copies to any party who requests at that party's expense.

3 Time for Motion and Ruling. A motion to dismiss must be: (a) filed within 60 days after the first pleading containing the challenged cause of action is served on the movant; (b) filed at least 21 days before the motion is heard; and (c) granted or denied within 45 days after the motion is filed.

A party seeking discovery by subpoena from a nonparty must serve, on the nonparty and all parties, a copy of the form of notice required under the rules governing the applicable form of discovery.

(1) The expedited actions process in this rule applies to a suit in which all claimants, other than counter-claimants, affirmatively plead that they seek only monetary relief aggregating $100,000 or less, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees.

(e) Custody, inspection and copying. The party obtaining the production must make all materials produced available for inspection by any other party on reasonable notice, and must furnish copies to any party who requests at that party's expense.

When a party asserts a privilege in response to a discovery request, TRCP 193.3 controls the discovery process. In many instances, TRCP 193.3 allows the asserting party to withhold the privileged material, but TRCP 193.3 requires the withholding party to notify the opposing party of the privilege assertion.

Under Texas Rule 193.6, a party's failure "to make, amend, or supplement" a written discovery response, including a required disclosure, in a timely manner will prevent the party from introducing in evidence the undisclosed material or information and from using the testimony of an undisclosed witness (other than named ...

193.7 Production of Documents Self-Authenticating If objection is made, the party attempting to use the document should be given a reasonable opportunity to establish its authenticity.