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If a request, notice, response, or objection is not signed, it must be stricken unless it is signed promptly after the omission is called to the attention of the party making the request, notice, response, or objection. A party is not required to take any action with respect to a request or notice that is not signed.

A party may obtain discovery of the name, address, and telephone number of persons having know ledge of relevant facts, and a brief statement of each identified person's connection with the case. A person has knowledge of relevant facts when that person has or may have knowledge of any discoverable matter.

Rule 47: Claims for relief – the $100,000 categories replaced with $250,000 categoriesConsistent with the change to Rule 169, the Texas Rules of Civil Procedure no longer distinguish between suits for less than $100,000 from suits for less than $250,000.

191.1 Modification of Procedures. Except where specifically prohibited, the procedures and limitations set forth in the rules pertaining to discovery may be modified in any suit by the agreement of the parties or by court order for good cause.

Thus, unless the court in which the case is pending has local filing rules approved by the Supreme Court that require the filing of a certificate of written discovery, no such filing is required.

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.

Rule 92. General Denial (1941) A general denial of matters pleaded by the adverse party which are not required to be denied under oath, shall be sufficient to put the same in issue.

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.

A pleading setting up any of the following matters, unless the truth of such matters appear of record, shall be verified by affidavit. 1. That the plaintiff has not legal capacity to sue or that the defendant has not legal capacity to be sued.