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Rule 193.6. Failing to Timely Respond - Effect on Trial (Aug1998) (2) the failure to timely make, amend, or supplement the discovery response will not unfairly surprise or unfairly prejudice the other parties. (b) Burden of establishing exception.
193.7 Production of Documents Self-Authenticating An objection must be either on the record or in writing and must have a good faith factual and legal basis. An objection made to the authenticity of only part of a document does not affect the authenticity of the remainder.
A party may not use - at any hearing or trial - material or information withheld from discovery under a claim of privilege, including a claim sustained by the court, without timely amending or supplementing the party's response to that discovery.
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.
192.3 Scope of Discovery. (a)Generally. In general, a party may obtain discovery regarding any matter that is not privileged and is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party.
Rule 192.7. Definitions (1999) As used in these rules: (a) Written discovery means requests for disclosure, requests for production and inspection of documents and tangible things, requests for entry onto property, interrogatories, and requests for admission.
If the producing party thus amends the response to assert a privilege, any party who has obtained the specific material or information must promptly return the specified material or information and any copies pending any ruling by the court denying the privilege.
This rule imposes a duty upon parties to make a complete response to written discovery based upon all information reasonably available, subject to objections and privileges. 2. An objection to written discovery does not excuse the responding party from complying with the request to the extent no objection is made.