Any party may serve on any other party no more than 25 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.
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 ...
Discovery requests typically follow a common format that you can mirror. First, list instructions detailing the request for production. Be sure to mention Rule 34 and Rule 26(b), which outline the scope of the discovery request. It's also necessary to include a section with definitions.
Levels of Discovery Control Plans in Texas Most family law cases are conducted under the Level 2 Control Plan. In family law cases conducted under a Level 2 Control Plan, the parties have more time to depose witnesses and can propound more Interrogatories than under Level 1.
Procedures: More extensive than Level 1, Level 2 discovery allows a wide range of discovery tools, including interrogatories, requests for production of documents, requests for admissions, and depositions.
You must respond to each request individually. You do not need to repeat the text of the question, but your responses must be in the same order as the requests, and each response should be labeled with the same number or letter as the request.
Procedures: More extensive than Level 1, Level 2 discovery allows a wide range of discovery tools, including interrogatories, requests for production of documents, requests for admissions, and depositions.
However, most personal injury cases settle before trial. Instead, they may offer the settlement well after the trial starts. This typically happens after discovery, but it may even happen after the jury reaches a verdict.
The discovery rule is a “narrow exception” to the legal injury rule that “defers accrual of a cause of action until the plaintiff knew or, exercising reasonable diligence, should have known of the facts giving rise to the cause of action.” Berry, 646 S.W.
When a party requests documents or answers to questions from the opposing party in a lawsuit, you must do so in the form of a Motion for Discovery. A Motion for Discovery may be filed with the Court via E-File, Email, in person, or by US Mail.