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Texas Rules of Civil Procedure Rule 190 identifies the three levels of discovery. In most cases, discovery level 2 (Rule 190.3) governs the timing of discovery. After initial disclosures, you can serve requests for discovery until 30 days before the date set for trial, or the date set by the court.
The scheduling order will usually set a deadline when discovery must be completed, and can prohibit discovery outside the timeframe set forth in the scheduling order. Similarly, many scheduling orders require each side to provide copies of exhibits to the other side in advance of trial.
A scheduling order is a court order designed to manage the flow of a case from the date it is entered through the beginning of trial. The court may enter the order on its own motion, or either party may seek one by motion.
Every case filed in Texas state court requires the plaintiff to choose a discovery plan: Level One, which applies only for cases where the plaintiff seeks less than $100,000 in damages; Level Two, which applies by default to all other cases and has its own specific set of deadlines; and Level Three, which allows the ...
(3) Requests for admissions. Each party may serve no more than 25 requests for admissions. Requests for admissions may be used only to address jurisdictional facts or the genuineness of any documents served with the request. (4) Requests for disclosure.
The court, after considering the joint attorney conference report and after reviewing the case file, enters this case specific order which controls disposition of this action pending further order of the court. The following actions shall be completed by the date indicated.