Texas Requests for Production of Documents and Things
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FAQ
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
(a) Forms of written discovery. Unless otherwise provided by this section or ordered by the judge, parties may use the forms of written discovery provided by the TRCP, with the following modifications: (1) Requests for production. Each party may serve no more than 25 written requests for production.
In contrast to interrogatories and requests for admission, which are limited to 35 questions as a "matter of right", there is no limit on demands for production.
A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
The request must specify the items to be produced or inspected, either by individual item or by category, and describe with reasonable particularity each item and category. The request must specify a reasonable time (on or after the date on which the response is due) and place for production.
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.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. The propounding (requesting) party must include enough information to make the requested documents easily identifiable.
Any party may serve on any other party no more than 15 written requests for admissions. Each discrete subpart of a request for admission is considered a separate request for admission.
