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Written Discovery Toolkit (TX)
Practical Law Toolkit w-042-5077 (Approx. 5 pages)
Resources to assist counsel with drafting, serving, objecting to, and responding to written discovery requests in Texas district and county courts. Specifically, this Toolkit includes resources about interrogatories, requests for the production of documents (RFPs) (also called document requests), and requests for admission (RFAs). It also includes resources about challenging discovery deficiencies.
Texas has liberal discovery rules that permit parties to obtain information relevant to their claims or defenses. Parties may seek discovery about any nonprivileged matter that is relevant to the action's subject matter so long as it is admissible or reasonably calculated to lead to the discovery of admissible evidence (Tex. R. Civ. P. 192.3).
Parties in cases not governed by the Family Code must exchange required written initial, expert, and pretrial disclosures. The Texas Rules of Civil Procedure (TRCP) list the categories of information and timing for each required disclosure (Tex. R. Civ. P. 194.1 to 194.6 and 195.1 to 195.7). In addition to those required disclosures, the TRCP provides various other written discovery devices that parties may use. This Toolkit offers resources to guide attorneys requesting, serving, and responding to various written discovery devices available in Texas, including:
- Requests for admission (RFAs).
- Requests for the production of documents (RFPs) (also called document requests).
These resources discuss the rules governing each of these discovery devices and explain when, how, and why to use them.
For information on conducting e-discovery in Texas district and county courts, see E-Discovery Toolkit (TX). For information on issuing and responding to subpoenas in Texas district and county courts, see Subpoena Toolkit (TX).