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Additionally, the new rules that went into effect September 1, 2023, require disclosure of the expert's qualifications to include all publications authored by the expert in the last 10 years, a list of cases in which the expert testified as an expert at trial or deposition (unless the expert is an attorney testifying ...

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.

1. This rule imposes a duty upon parties to make a complete response to written discovery based upon all information reasonably available, subject to objections and privileges. 2. An objection to written discovery does not excuse the responding party from complying with the request to the extent no objection is made.

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.

194.2Initial Disclosures. (a)Time for Initial Disclosures. A party must make the initial disclosures within 30 days after the filing of the first answer or general appearance unless a different time is set by the parties' agreement or court order.

Rule 192.4 of the Texas Rules of Civil Procedure constrains the scope of discovery stating that discovery should be limited if: “(a) the discovery sought is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome, or less expensive; or (b) the burden or ...

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.

Rule 21d in the Texas Rules of Civil Procedure allows, "Upon appropriate notice by a party or the court, a court may allow or require a participant to appear at a court proceeding by videoconference, teleconference, or other available electronic means, except as otherwise provided in (2)." (2) states, "A court must not ...

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.