Texas Interrogatories and Requests for Production - Personal Injury

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US-PI-0310
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This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.

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FAQ

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.

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.

An interrogatory may inquire whether a party makes a specific legal or factual contention and may ask the responding party to state the legal theories and to describe in general the factual bases for the party's claims or defenses, but interrogatories may not be used to require the responding party to marshal all of ...

Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)

196.1 Request for Production and Inspection to Parties. (a) Request. A party may serve on another party - no later than 30 days before the end of the discovery period - a request for production or for inspection, to inspect, sample, test, photograph and copy documents or tangible things within the scope of discovery.

(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.

197.3 Use. Answers to interrogatories may be used only against the responding party. An answer to an interrogatory inquiring about matters described in Rule 194.2(b)(3) and (b)(4) that has been amended or supplemented is not admissible and may not be used for impeachment.

(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.

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Texas Interrogatories and Requests for Production - Personal Injury