Texas Plaintiff's Response to Request for Production and Inspection
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FAQ
Like Federal Rule of Civil Procedure 26(b)(2), Rule 196.4 states that parties must comply with "reasonable" production requests, but are not forced to produce electronic information for discovery if it cannot be retrieved "through reasonable efforts." So, when it comes to unduly burdensome discovery requests, don't
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. (b)Content of response. A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules.
196.6 Expenses of Production. Unless otherwise ordered by the court for good cause, the expense of producing items will be borne by the responding party and the expense of inspecting, sampling, testing, photographing, and copying items produced will be borne by the requesting party.
(a) Time for response. The responding party must serve a written response on the requesting party within 30 days after service of the request, except that a defendant served with a request before the defendant's answer is due need not respond until 50 days after service of the request.
Each party may have no more than six hours in total to examine and cross-examine all witnesses in oral depositions. The parties may agree to expand this limit up to ten hours in total, but not more except by court order. The court may modify the deposition hours so that no party is given unfair advantage.
Rule 190.4. Discovery Control Plan - By Order (Level 3) (1999) (a) Application. The court must, on a party's motion, and may, on its own initiative, order that discovery be conducted in ance with a discovery control plan tailored to the circumstances of the specific suit.
Requests for inspection or entry let you examine physical evidence like documents, emails, and property from the other side. These requests must be specific and relevant to your case (Rule 196.1(b)). Discovery requests must be specific. The request must identify the particular evidence you are looking for.