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Any party may serve on any other party no more than 25 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents. Each discrete subpart of an interrogatory is considered a separate interrogatory.
194.2 Initial Disclosures. (a) Time for Initial Disclosures. A party must make the initial disclosures within 30 days after the filing of the first answer or general appearance unless a different time is set by the parties' agreement or court order.
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.
no later than 30 days before the end of any applicable discovery period move for an order compelling another party to: (1) submit to a physical or mental examination by a qualified physician or a mental examination by a qualified psychologist; or (2) produce for such examination a person in the other ...
Rule 194.3. Testifying Expert Disclosures (2021) In addition to the disclosures required by Rule 194.2, a party must disclose to the other parties testifying expert information as provided by Rule 195.
Rule 194.1. Duty to Disclose; Production (2021) (a) Duty to Disclose. Except as exempted by Rule 194.2(d) or as otherwise agreed by the parties or ordered by the court, a party must, without awaiting a discovery request, provide to the other parties the information or material described in Rule 194.2, 194.3, and 194.4.
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.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.