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(d) Failing to respond or to submit to an authorized method of discovery. (e) Making, without substantial justification, an unmeritorious objection to discovery. (f) Making an evasive response to discovery. (g) Disobeying a court order to provide discovery.
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.
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 abuse takes a variety of forms including evasive discovery responses, boilerplate objections to written discovery, speaking objections during depositions, the failure to produce responsive documents, and even making misrepresentations.
Some examples that your lawyer may request as part of their motion for discovery are: Photos or videos of the crime scene. Witness statements. Police reports or notes. Lab tests and reports. Alibi witness statements.