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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.
Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
Discovery allows you to get information and evidence from the other party or other persons you can use in your lawsuit.
You only need to sign and deliver the discovery request to the other party or the other party's attorney. If you are serving a discovery request on a non-party, then the request must be filed. Texas Rules of Civil Procedure Rule 191.4 governs the filing requirement for discovery requests.
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.