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A motion to compel discovery from a party should be made in the court in which the action is pending or in any district court in the district in which the deposition is being taken. Tex. R. Civ.
A motion to compel a response to discovery must include: the nature of the questions or request at issue; the response or objections of the party upon whom the request was served; arguments in support of the motion; and.
For example, a party may file a motion asking the court to: Order another party or person to: ... Quash a subpoena that improperly seeks documents or testimony. Order the parties to maintain the confidentiality of commercially sensitive, trade secret, proprietary, or personal information.
You should respond to each interrogatory in the order received. Start by retyping each interrogatory and then follow each question with your answer. If an answer comes from information you received from other people, you should write that as part of your response. Your answers must be signed under oath.
A motion to compel shall not be filed less than 10 days before the first day of the hearing on the merits, unless good cause is shown. A judge may deny or limit relief sought in a motion to compel if the judge determines that the discovery requests at issue are improper or unduly burdensome.