A responding party - not an agent or attorney as otherwise permitted by Rule14- must sign the answers under oath except that: (1)when answers are based on information obtained from other persons, the party may so state, and. (a) Time for response. Request for Motion for Entry Upon Property %%EOF fCE@pl!j The signature of an attorney or party on a disclosure constitutes a certification that to the best of the signer's knowledge, information, and belief, fanned after a reasonable inquiry, the disclosure is complete and correct as of the time it is made. As with requests for disclosure, interrogatories may be used to ascertain basic legal and factual and defenses but may not be used to force a party to marshal evidence. 197.3 Use. Subpoenas. Response to Interrogatories (2021) TEXT (a) Time for response. (b) This presumption applies only to those surveys conducted by a surveyor duly appointed, elected, or licensed, and qualified. Amended by order of Dec. 23, 2020, eff. (a) In a civil case, proof of the existence of a traffic control device on or alongside a public thoroughfare by a party is prima facie proof of all facts necessary to prove the proper and lawful installation of the device at that place, including proof of competent authority and an ordinance by a municipality or order by the commissioners court of a county. (2) a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. /ColorSpace /DeviceGray The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. (b-2) If a medical bill or other itemized statement attached to an affidavit under Subsection (b-1) reflects a charge that is not recoverable, the reference to that charge is not admissible. HS]K@|n+J4* &W? In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. INTERROGATORIES TO PARTIES 197.2 Response to Interrogatories. The ten-day period (which may be shortened by the court) allowed for an amended response does not run from the production of the material or information but from the party's first awareness of the mistake. Under a 1949 amendment to 28 U.S.C., 2072, the Chief Justice of trailer A responding party - not an agent or attorney as otherwise permitted by Rule 14 -must sign the answers under oath except that:". (1) be taken before an officer with authority to administer oaths; (2) be made by: (A) the person who provided the service; or (B) the person in charge of records showing the service provided and charge made; and (3) include an itemized statement of the service and charge. 0000058841 00000 n Texas Rules of Civil Procedure Rule 107. Use of the answers to such interrogatories is limited, just as the use of similar disclosures under Rule 194.6 is. Telephone: 361-480-0333 1. cH)W"PGsb#4Bz/s/~i3o!@7W;e|C~sElC? This rule governs the presentation of all privileges including work product. (3) the date the party offering the counteraffidavit in evidence must designate any expert witness as required by the Texas Rules of Civil Procedure. 1. Thus, when large numbers of documents are being produced, a party may amend the initial response when documents are found as to which the party claims privilege. 679), Sec. HN@Htqtj0J|}g2sRR 7 (i) Notwithstanding Subsections (d), (d-1), (d-2), (e), (e-1), (g), and (h), a deadline under this section may be altered by all parties to an action by agreement or with leave of the court. If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. Telephone: 817-953-8826 If the answer to an interrogatory may be derived or ascertained from public records, from the responding party's business records, or from a compilation, abstract or summary of the responding party's business records, and the burden of deriving or ascertaining the answer is substantially the same for the requesting party as for the responding party, the responding party may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract or summary of the records. ,B?t,'*~ VJ{Awe0W7faNH >dO js The focus is on the intent to waive the privilege, not the intent to produce the material or information. 0 Acts 2007, 80th Leg., R.S., Ch. Admissions The counteraffidavit may not be used to controvert the causation element of the cause of action that is the basis for the civil action. 1. 2. The failure to sign or verify answers is only a formal defect that does not otherwise impair the answers unless the party refuses to sign or verify the answers after the defect is pointed out. While interrogatories might inquire about legal theories and factual bases for a claim or denial of a claim, this part of the discovery process does not require evidence to substantiate or refute a claim. 191.3 Signing of Disclosures, Discovery Requests, Notices, Responses, and Objections (Aug. 1998). Rule 193.3(d) is a new provision that allows a party to assert a claim of privilege to material or information produced inadvertently without intending to waive the privilege. STATE BAR OF TEXAS COMMITTEE ON COURT RULES REQUEST FOR NEW RULE OR CHANGE OF EXISTING RULE TEXAS RULES OF CIVIL PROCEDURE I. endstream endobj 469 0 obj <>/Metadata 71 0 R/PageLayout/OneColumn/Pages 463 0 R/StructTreeRoot 85 0 R/Type/Catalog>> endobj 470 0 obj <>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 471 0 obj <>stream A party's production of a document in response to written discovery authenticates the document for use against that party in any pretrial proceeding or at trial unless - within ten days or a longer or shorter time ordered by the court, after the producing party has actual notice that the document will be used - the party objects to the authenticity of the document, or any part of it, stating the specific basis for objection. The failure to sign or verify answers is only a formal defect that does not otherwise impair the answers unless the party refuses to sign or verify the answers after the defect is pointed out. Answers to interrogatories may be used only against the responding party. All information provided on Silblawfirm.com (hereinafter "website") is provided for informational purposes only, and is not intended to be used for legal advice. endstream endobj 334 0 obj <>stream 0000001529 00000 n /Subtype /Image (3) not unreasonable or unduly burdensome or expensive, given the needs of the case, the discovery already had in the case, the amount in controversy, and the importance of the issues at stake in the litigation. /Name /ImagePart_0 197.3 Use. (d-1) Notwithstanding Subsection (d), if services are provided for the first time by a provider after the date the defendant files an answer, the party offering the affidavit in evidence or the party's attorney must serve a copy of the affidavit for services provided by that provider on each other party to the case by the earlier of: (1) the date the offering party must designate any expert witness under a court order; or. Hiring a lawyer who is knowledgeable about the requirements and details of discovery will help a litigant avoid the difficulties that result from not handling interrogatories appropriately. Dallas, TX 75252 Telephone: 210-714-6999 Telephone: 409-240-9766 954, Sec. In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. Aug. 30, 1993. E-mail: info@silblawfirm.com, Beaumont Office The responding party must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the court, and must provide the requesting party a reasonable opportunity to inspect them. Disclaimer: The information presented on this site is for . (a) Signature required. Back to Main Page / Back to List of Rules, Rule 193.7. (c) Effect of signature on discovery request, notice, response, or objection. 0000007074 00000 n A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules. 1. 696 (SB 2342), and invited public comment. Bar. A party is not required to take any action with respect to a request or notice that is not signed. . (2) by the party, if the party is not represented by an attorney, and must show the party's address, telephone number, and fax number, if any. (c) Option to produce records. 1, eff. E-mail: info@silblawfirm.com. 1992), to the extent the two conflict. This rule expressly states the obligation of parties and their attorneys to cooperate in conducting discovery, and to conduct discovery only as permitted by the rules. September 1, 2019. An example would be material or information described by Rule 503(d)( 1) of the Rules of Evidence. Amended by order of Nov. 9, 1998, eff. written interrogatories."). For any questions about the rules, please call (512) 463-4097. Jan. 1, 1999. R. Evid. In order to facilitate that exchange, the discovery process includes interrogatories, questions relevant to the case which must be answered by the opposing party. (f) The counteraffidavit must give reasonable notice of the basis on which the party serving it intends at trial to controvert the claim reflected by the initial affidavit and must be taken before a person authorized to administer oaths. The information contained in the records was transmitted to me in the regular course of business by __________(PERSON WHO PROVIDED THE SERVICE)__________ or an employee or representative of __________(PERSON WHO PROVIDED THE SERVICE)__________ who had personal knowledge of the information. In Texas, the Rules of Civil Procedure only allow attorneys to object on 3 grounds: form, non-responsive answer, or leading. } B.,n6L]66_RRcbH+4\6Z8Z1m 1K*5|XR-No6;\9E8|z@?o+$MG |_)OhsjWn X If objection is made, the party attempting to use the document should be given a reasonable opportunity to establish its authenticity. June 18, 2005. E-mail: info@silblawfirm.com, Corpus Christi Office The responding party must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the court, and must provide the requesting party a reasonable opportunity to inspect them. Hj@z h:iM S(Y("KHjp_#yMB98,=8*oL?4MZ =g8~S'b2Go96K c0x9B)$SoP~k +4m5h14f9iNfm_ e u9DA%}4T>:{,)7lhahMwP?h]lrOvpL?oz88(4P&u^E;uC~'pmC]z5NqG`. The service I provided was necessary and the amount that I charged for the service was reasonable at the time and place that the service was provided. (d) Verification required; exceptions. A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules. amendments to Rules 47, 169, 190, 192, 193, 194, and 195 of the Texas Rules of Civil Procedure to comply with Act of May 27, 2019, 86th Leg., R.S., ch. 710 Buffalo Street, Ste. (h) If continuing services are provided after a relevant deadline under this section: (1) a party may supplement an affidavit served by the party under Subsection (d) or (d-1) on or before the 60th day before the date the trial commences; and. The rules, and subsequent amendments, were not to take effect until (1) they had been first reported to Congress by the Attorney General at the beginning of a regular session and (2) after the close of that session. Interrogatories To Parties (Aug1998). To learn how to contact the presiding judge of the administrative judicial region in which the court is located,please visit https://www.txcourts.gov/organizations/policy-funding/administrative-judicial-regions/. SWORN TO AND SUBSCRIBED before me on the __________ day of __________, 19___. hbbd```b```RD(Hjl,X|Xd=L;``k6XD^Ad8XD\u@{=W September 1, 2013. The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant served with interrogatories before the defendant's answer is due need not respond until 50 days after service of the interrogatories. /Height 3296 Court Deadlines contains reference information and calculators for common deadlines in the federal rules of civil procedure. Litigants should avoid overly broad questions, questions addressed in other parts of discovery, or questions with answers available from other resources. Silberman Law Firm, PLLC Copyright 2016 | DisclaimerPrincipal office located in Houston, TX. 511 and overturns Granada Corp. v.First Court of Appeals, 844 S.W.2d 223 (Tex. 1, eff. (3) the date the party offering the counteraffidavit must designate any expert witness as required by the Texas Rules of Civil Procedure. A trial court may also order this procedure. Below is Rule 197, which details the guidelines and procedures for making and responding to interrogatories: A party may serve on another party - no later than 30 days before the end of the discovery period -written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule195. 0 167, Sec. SWORN TO AND SUBSCRIBED before me on the __________ day of _____, _____. (e-1) Notwithstanding Subsection (e), if the party offering the affidavit in evidence serves a copy of the affidavit under Subsection (d-1), the party offering the counteraffidavit in evidence or the party's attorney must serve a copy of the counteraffidavit on each other party to the case by the later of: (1) 30 days after service of the affidavit on the party offering the counteraffidavit in evidence; (2) the date the party offering the counteraffidavit must designate any expert witness under a court order; or. Answers in amended and supplemental responses must be signed by the party under oath only if the original answers were required to be signed under oath. texas rules of civil procedure part i - general rules rule 1. objective of rules rule 2. scope of rules 250 rule 197. interrogatories to parties rule 198. requests for admissions rule 199. depositions upon oral examination rule 200. depositions upon written questions rule 201. depositions in foreign jurisdictions for use in texas . See Loftin v.Martin, 776 S.W.2d 145 (Tex. The latter two are easy enough to decipher as a lay person. In comment 5 to Rule 193, the reference to Rule 195.6(b) is changed to Rule 195.6. 4 0 obj 1, eff. 802 0000049836 00000 n The self-authenticating provision is new. Sec. {u-,gVP#'{W@=Q6o""u7l!R;_WC[eTb0aa,KQbZS#vuJ#n,Gz^rDGZg^W~nKp4Kd8 xb```"SVs eah`\v&.&Xp}a4m9ursq`+Tb>q#k!)v;ji"l/&-|y5K#&FXvMLs-}/8Lb# This post on Interrogatories is the third part of a seven-part series on forms of discovery in Texas. *HFKt.-: A#yv7:lq|e7u]U1 lJ5WH%1y%(sD'QT-p&I0Dr%g0[ =G;+oB43LI (a) Time for response. 1. Added by Acts 2005, 79th Leg., Ch. (2) a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. Sec. A trial court may also order this procedure. 108 Wild Basin Rd. Sept. 1, 1985. Xf]],b|EIX~~k rI)Qb*9VN@7qq 8ZVd6E9%p86>. Answers in amended and supplemental responses must be signed by the party under oath only if the original answers were required to be signed under oath. Amended by order of Nov. 9, 1998, eff. Fax: 210-801-9661 Sept. 1, 1985. 1693), Sec. Corpus Christi, TX 78401 0000001820 00000 n Except as provided by the Texas Rules of Evidence, the affidavit is not required to be filed with the clerk of the court before the trial commences. 505 0 obj <>stream To avoid complications at trial, a party may identify prior to trial the documents intended to be offered, thereby triggering the obligation to object to authenticity. (b-1) Notwithstanding Subsection (b), an affidavit concerning proof of medical expenses is sufficient if it substantially complies with the following form: ____________________________________________. 901(a). (a) Except as provided by Subsection (b), a business record is not admissible in a civil action if the business record is provided to law enforcement personnel in connection with an investigation of an alleged violation of Section 32.51, Penal Code (fraudulent use or possession of identifying information). The responding party should either provide responsive answers or state clearly and specifically where the litigant can find answers to their questions. Docket No. Trial courts cannot simply "opt out" of these rules by form orders or approve or order a discovery control plan that does not contain specified matters, including a trial date and deadline for the joinder of parties. Sec. I am of sound mind and capable of making this affidavit, and personally acquainted with the facts herein stated. 132.001. (d) Verification required; exceptions. Texas Civil Practices and Remedies Code. Telephone: 214-307-2840 (b) Unless a controverting affidavit is served as provided by this section, an affidavit that the amount a person charged for a service was reasonable at the time and place that the service was provided and that the service was necessary is sufficient evidence to support a finding of fact by judge or jury that the amount charged was reasonable or that the service was necessary. 1. Fax: 817-231-7294 Added by Acts 1999, 76th Leg., ch. 2060 North Loop West Ste. Requests for Admission must be in writing, and each request has to be listed separately in the document. The Office of Court Administrations Local Rules, Forms, and Standing Orders website holds searchable local rules, forms, and standing orders. (b) If any claimant seeks recovery for loss of earnings, loss of earning capacity, loss of contributions of a pecuniary value, or loss of inheritance, the court shall instruct the jury as to whether any recovery for compensatory damages sought by the claimant is subject to federal or state income taxes. Sept. 1, 1995. endstream endobj startxref Added by Acts 2003, 78th Leg., ch. 468 0 obj <> endobj CERTAIN INFORMATION RELATING TO IDENTITY THEFT. Users of this website should not take any actions or refrain from taking any actions based upon content or information on this website. E-mail: info@silblawfirm.com, Dallas Office Telephone: +231 770 599 373. It dispenses with objections to written discovery requests on the basis that responsive information or materials are protected by a specific privilege from discovery. The Rules of Civil Procedure govern the proceedings in civil trials. Rule 191's requirement that a party's attorney sign all discovery responses and objections applies to interrogatory responses and objections. Answers in amended and supplemental responses must be signed by the party under oath only if the original answers were required to be signed under oath. HR&c?5~{5ky\g} 6*:K!#;Z$P"N" DzIb Requests that are made by you or to you asking to admit or deny facts that relate to the case. If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. Use of the answers to such interrogatories is limited, just as the use of similar disclosures under Rule 194.6 is. 679), Sec. (c) Notwithstanding the provisions of Subsections (a) and (b), a communication, including an excited utterance as defined by Rule 803(2) of the Texas Rules of Evidence, which also includes a statement or statements concerning negligence or culpable conduct pertaining to an accident or event, is admissible to prove liability of the communicator. Rule 197 - Interrogatories to Parties 197.1 Interrogatories. 13.09, eff. The Code of Criminal Procedure governs criminal proceedings. 1, eff. 5The Texas discovery rules are Texas Rules of Civil Procedure 190-215. A responding party - not an agent or attorney as otherwise permitted by Rule 14 -must sign the answers under oath except that:". (1) when answers are based on information obtained from other persons, the party may so state, and (2) a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. The only duty to supplement deposition testimony is provided in Rule 195.6. 3. Exact wording of existing Rule: Rule 197. (( Amended by order of Nov. 9, 1998, eff. 560 (S.B. ,$@54rHT"]Vt'8[qN S?%JD!Ar2rT~pY xMD3X4Y_N BB\?`o84m{F23FNtCb8tvbSMaa%!vSUR?Ekow[h83}YRz#Q ? 1J$00*hb&A>a6kzPC/y tYzQ+-aBh>APr^2$ UugE__Z?|H~%ytAe0zHiz9v'8[-/g'T0*T3dIdb?+9)L4h{#?0+y$W.DR1CS)c- 8"yq?FTg~gm0.xp mXNMXiwi]p3KSsbxE SZnVhd{7DY. 6jJYd[elqlc`F&__wS{(;]R*v{ " 340 0 obj <>stream The topics are listed below: Initial Disclosures An interrogatory may inquire whether a party makes a specific legal or factual contention and may ask the responding party to state the legal theories and to describe in general the factual bases for the party's claims or defenses, but interrogatories may not be used to require the responding party to marshal all of its available proof or the proof the party intends to offer at trial. 41$@ Z UNSWORN DECLARATION. Hn0wxslnRUVuH+J@}mLa8oA' This paper is a guide to the background, text, and intent of the 1999 revisions to the Texas Rules of Civil Procedure pertaining to discovery. (2) the date the offering party must designate any expert witness as required by the Texas Rules of Civil Procedure. S., Ste. Each side may have no more than 50 hours in oral depositions to examine and cross-examine parties on the opposing side, experts designated by those parties, and persons who are subject to those parties' control. Return of Service The officer's return or authorized person executing the citation shall be endorsed on or attached to the same; it shall state when the citation was served and the manner of service and be signed by the officer officially or by the authorized person. 2, eff. 8000 IH-10 West, Suite 600 18.062. (b) A business record described by Subsection (a) is admissible if the party offering the record has obtained the record from a source other than law enforcement personnel. 600 Rules about interrogatories during discovery are strict and complex, and failing to follow those rules can have serious repercussions. Added by Acts 2003, 78th Leg., ch. 18.002. In the first sentence of Rule 193.3(b), the word "to" is deleted. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. b`Pg8x2^aLc|xaUe10X3\wbP )gVs@AXmw vd An objection to authenticity must be made in good faith. Attached to this affidavit are records that provide an itemized statement of the service and the charge for the service that __________(PERSON WHO PROVIDED THE SERVICE)__________ provided to __________ (PERSON WHO RECEIVED THE SERVICE)__________ on __________(DATE)__________. (d) Verification required; exceptions. (d-2) The party offering the affidavit in evidence or the party's attorney must file notice with the clerk of the court when serving the affidavit that the party or the attorney served a copy of the affidavit in accordance with this section. com : This website provides general address, phone and email information of foreign consulates located in Houston Texas. TRAFFIC CONTROL DEVICE PRESUMED TO BE LAWFUL. Rule 197.2. Further, amended Rule 190.2 increases the aggregate amount of oral deposition time permitted for expedited actions from 6 hours to 20 hours. << (a) This section applies to civil actions only, but not to an action on a sworn account. (3) the date the offering party must designate any expert witness as required by the Texas Rules of Civil Procedure. A court can issue a temporary order requiring both spouses to prepare and file a separate sworn inventory and appraisement. Request for Motion for Entry Upon Property, Request for Motion for Entry Upon Property in Texas, Civil Suits Arising From Criminal Violations in Texas, Protecting Your Property with a Right of First Refusal in Your Texas Estate Plan, Caring for Your Home When Your Co-Owner is an Absentee, Landlord Liability For Breach of Lease in Texas. Questions about the substance of a courts local rule should be directed to the relevant courts clerk. Acts 1985, 69th Leg., ch. I am a custodian of records for __________. 0000000016 00000 n E-mail: info@silblawfirm.com, Austin Office But a party may object to a request for "all documents relevant to the lawsuit" as overly broad and not in compliance with the rule requiring specific requests for documents and refuse to comply with it entirely. Ask a Librarian for help if you have questions about locating or accessing Texas court rules.. Court Proceedings. Depositions 1, eff. (TRCP 197.2) Objections and Answers to Requests for Admissions 30 days from service, unless served before the defendant's answer is due, in which event the defendant has 50 days after service to respond. The questions should be relevant to the claims and be as specific as possible. Amended by Acts 1987, 70th Leg., ch. THE TEXAS RULES OF CIVIL PROCEDURE _____ ORDERED that: 1. A party may serve on another party - no later than 30 days before the end of the discovery period -written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195. The records from which the answer may be derived or ascertained must be specified in sufficient detail to permit the requesting party to locate and identify them as readily as can the responding party. An objection made to the authenticity of only part of a document does not affect the authenticity of the remainder. Rule 191's requirement that a party's attorney sign all discovery responses and objections applies to interrogatory responses and objections. 0000003067 00000 n /Type /XObject Access Texas court rules online. Houston, TX 77018 Texas Court Rules: History and Process - Excerpted from Nathan L. Hecht & E. Lee Parsley, Procedural Reform: Whence and Whither (Sept. 1997), updated by Robert H. Pemberton (Nov. 1998), How Texas Court Rules Are Made - By Nathan L. Hecht, Martha G. Newton, and Kennon L. Wooten (May 2016). The attached records are kept by me in the regular course of business. -1!o7! ' Jan. 1, 2021. FOREIGN INTEREST RATE. Sept. 1, 1987. 18.001. These new rules attempt to broaden the applicability of expedited action procedures, with the expressed attempt of lowering discovery costs for such lawsuits. Rule 190.3 governs the permissible discovery for all cases except those seeking relief of $250,000 or less (the new Rule 190.2) and those a court permits, on a case-by-case basis, to have discovery tailored to the circumstances of the suit (Rule 190.4). Sec. Texas Rules of Civil Procedure 198 governs requests for admissions. (a) Except as provided by Subsection (b), an unsworn declaration may be used in lieu of a written sworn declaration, verification, certification, oath, or affidavit required by statute or required by a rule, order, or requirement adopted as provided by law. Sec. This website was created in response to Texas Rule of Civil Procedure 3a, Texas Rule of Appellate Procedure 1.2, and Texas Rule of Judicial Administration 10, which require (effective January 1, 2023) that courts post their local rules, forms, and standing orders to this website to be effective. (1) . If the answer to an interrogatory may be derived or ascertained from public records, from the responding party's business records, or from a compilation, abstract or summary of the responding party's business records, and the burden of deriving or ascertaining the answer is substantially the same for the requesting party as for the responding party, the responding party may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract or summary of the records. A party who fails to diligently screen documents before producing them does not waive a claim of privilege. If the certification is false without substantial justification, the court may, upon motion or its own initiative, impose on the person who made the certification, or the party on whose behalf the request, notice, response, or objection was made, or both, an appropriate sanction as for a frivolous pleading or motion under chapter 10 of the Civil Practice and Remedies Code. s"*JISBHQDa p" S"! This paper explains how the Texas Supreme Court has derived its authority to promulgate procedural rules like the 1999 discovery rules revisions, the new combined Rules of Evidence and the new Rules of Appellate Procedure and describes the process by which the Court drafts such rules. (c) Option to produce records. 18.061. Any party can request a hearing in which the court will resolve issues brought up in objections or withholding statements. An itemized statement of the service and the charge for the service is attached to this affidavit and is a part of this affidavit. AFFIDAVIT CONCERNING COST AND NECESSITY OF SERVICES. Interrogatories (TRCP 198.2) Amending or Supplementing Responses to Written Discovery 30 days before trial or presumed not made reasonably promptly (TCRP 1. The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. Telephone: 512-501-4148 !QHn stream The records are the original or an exact duplicate of the original. The court must still set the case for a trial date that is within 90 days after the discovery period ends. . A party who objects to production of documents from a remote time period should produce documents from a more recent period unless that production would be burdensome and duplicative should the objection be overruled. The provision is commonly used in complex cases to reduce costs and risks in large document productions. (T*(B{TZhp{3;3#aur:% 1b#Z-@M_S *:hY^xP@30z@=AmR=7G9N* (9lBBBLa!4lda1L6sZ2N4HzV}!6v-CK_|o@*>746jDe _sP2&E) \RM*bd#R\RWp G Request for Production and Inspection how long after lipo can i get a tattoo,