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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.

The correct names of the parties to the lawsuit; The name, address, and telephone number of any potential parties; The legal theories and, in general, the factual bases of the responding party's claims or defenses (the responding party need not marshal all evidence that may be offered at trial);

Under Level 2 discovery, each side is only allowed 25 written interrogatories that ask for more than identifying information about a document. Additionally, the responding party may respond by telling the other side where the information can be found in public records instead of answering the question directly.

Do I file the initial required disclosures with the court? No. But if this is a contested case, you will have to file something different with the court called pretrial disclosures.

Texas court rules require every party in a lawsuit to send certain information about their claims or defenses to the other parties at the beginning of the case.

The Rules of Civil Procedure govern the proceedings in civil trials. The Code of Criminal Procedure governs criminal proceedings. When a case is appealed, the Rules of Appellate Procedure govern the appeals process.

Under amended Rule 194, disclosures are due within 30 days after the first answer is filed. Further, a party cannot serve discovery until after the initial disclosures are due, unless otherwise agreed to by the parties or ordered by the court.

The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories.