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An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless he states that he has made reasonable inquiry and that the information known or readily obtainable by him is insufficient to enable him to admit or deny.

Under Level 2 discovery, each side is only allowed 25 written interrogatories that ask for more than identifying information about a document. Additionally, the responding party may respond by telling the other side where the information can be found in public records instead of answering the question directly.

Under Rule 202, a person can submit a verified petition to the court for authorization to take a deposition to perpetuate testimony for use in an anticipated suit, or to investigate a potential claim or suit. The petitioner does not need to set forth a claim but must include the intended action's subject matter.

(4) Requests for Production. Any party may serve on any other party no more than 15 written requests for production. Each discrete subpart of a request for production is considered a separate request for production.

Rule 92. General Denial (1985) A general denial of matters pleaded by the adverse party which are not required to be denied under oath, shall be sufficient to put the same in issue.

If they produce documents which prove not to be producible under R. 7-1(1), they may be guilty of breaching their client's confidence; yet if they decline to produce they may breach their duty as officer of the court.

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 accordance with a discovery control plan tailored to the circumstances of the specific suit.

A party may gain entry on designated land or other property to inspect, measure, survey, photograph, test, or sample the property or any designated object or operation thereon by serving - no later than 30 days before the end of any applicable discovery period -.

(a) Remedies Under State Law?In General. At the commencement of and throughout an action, every remedy is available that, under the law of the state where the court is located, provides for seizing a person or property to secure satisfaction of the potential judgment.

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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Thirteenth Court of Appeals, Corpus Christi, Texas. —Corpus Christi Oct.CITY OF CORPUS CHRISTI, TEXAS, ). SOUTHERN DISTRICT OF TEXAS. For convenience, the following forms are available for downloading, printing and completing. IN THE UNITED STATES DISTRICT COURT. How long do I have to complete discovery? Do I need to file my discovery requests with the clerk? J.D. with Honors, The University of Texas School of Law. — Corpus Christi 1996, orig.

Corpus Christi Texas Plaintiff's Request for Production

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