Compared to most other state court jurisdictions, the mandated notice period for motions is very short, only three (3) days. Limitations on Interrogatories: Limitations on Requests for Production: Other: 120 days before.Initial Trial Setting. The responding party must serve a written response on the requesting party within 30 days after service of the request. Tex. This article explains "requests for production," which are a tool for gathering evidence in a lawsuit as part of discovery. This article's purpose is to provide a guide for properly responding (and objecting) to interrogatories and production requests under the Texas. The rules absolutely allow the simultaneous serving of both interrogatories and document requests as separate documents. Attorneys must use the electronic filing system. Sworn to under oath, within 30 days after service of these Interrogatories. You will need to fill out and sign the document and then follow the procedure the county requires for submitting a subpoena request.