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Chapter 18
- § 18.1 Form and Scope of Pretrial Discovery
- § 18.2 Discovery Control Plans and Discovery Period
- § 18.3 Exemptions from Discovery
- § 18.4 Ethical Considerations in Pretrial Discovery
- § 18.5 Attorney’s Fees for Pretrial Discovery
- § 18.6 Separate or Combined Submission of Interrogatories and Requests for Admissions
- § 18.7 Supplementation of Discovery
- § 18.8 Protective Orders
- § 18.9 Objections to Written Discovery
- § 18.10 Assertions of Privilege
- § 18.11 Cooperation in Discovery and Certification of Conference
- § 18.12 Signatures on Discovery Documents
- § 18.13 Filing and Service of Discovery Materials
- § 18.14 Availability of Mandamus
- § 18.15 Failure to Timely Respond
- § 18.16 Discovery from Financial Institutions
- § 18.21 Source of Rule and Purpose of Deposition
- § 18.22 Length of Examination
- § 18.23 Forms of Deposition
- § 18.24 Deposition before Suit Is Filed or to Investigate Claims
- § 18.25 Depositions in Foreign Jurisdictions
- § 18.26 Deposition by Nonstenographic Recording
- § 18.27 Deposition by Telephone or Other Remote Electronic Means
- § 18.28 Oral Deposition
- § 18.29 Deposition on Written Questions
- § 18.30 Subpoenas
- § 18.31 Postdeposition Procedure
- § 18.32 Necessity for and Form of Response
- § 18.33 Use and Effect of Deposition
- § 18.41 Admissions Generally
- § 18.42 Scope of Requests for Admissions
- § 18.43 Form of Requests for Admissions
- § 18.44 Method of Service
- § 18.45 Responses
- § 18.46 Withdrawal or Amendment of Admissions
- § 18.47 Sanctions
- § 18.48 Use, Effect, and Evidentiary Value of Requests and Responses
- § 18.51 Interrogatories Generally
- § 18.52 Scope of Interrogatories
- § 18.53 Form of Interrogatories
- § 18.54 Service and Filing of Interrogatories
- § 18.55 Response
- § 18.56 Use and Effect of Interrogatories and Answers
- § 18.61 Purpose and Nature of Requests for Disclosure
- § 18.62 Who May Be Served
- § 18.63 Requesting and Using Requests for Disclosure
- § 18.64 Deadline for Response
- § 18.65 Form for Response
- § 18.66 No Objection or Claim of Work Product Privilege
- § 18.71 Requests for Production Generally
- § 18.72 Scope of Requests for Production
- § 18.73 Form of Requests for Production
- § 18.74 Method of Service
- § 18.75 Responses and Objections to Requests for Production
- § 18.76 Production
- § 18.77 Authentication of Documents Produced
- § 18.78 Production from Nonparties
- § 18.81 Source of Rule and Purpose of Sanctions
- § 18.82 Abuse of Discovery
- § 18.83 Attorney’s Fees and Expenses on Motion to Compel
- § 18.84 Sanctions against Parties
- § 18.85 Sanctions against Nonparties
- 18-1 Notice to Nonparty of Request for Financial Records
- 18-2 Motion to Inspect Financial Records of Nonparty
- 18-3 Notice of Intention to Take Oral Deposition [with Subpoena Duces Tecum]
- 18-4 Subpoena [with Duces Tecum Language]
- 18-5 Notice of Intention to Take Deposition on Written Questions [with Subpoena Duces Tecum]
- 18-6 Pattern Written Deposition Questions to Prove Up Business Records
- 18-7 Plaintiff’s Request for Admissions
- 18-8 Pattern Requests for Admissions—Sworn Account
- 18-9 Pattern Requests for Admissions—Contract or Revolving Credit Agreement
- 18-10 Pattern Requests for Admissions—Promissory Note
- 18-11 Pattern Requests for Admissions—Foreclosure of Security Interest or Deficiency Judgment
- 18-12 Pattern Requests for Admissions—Lease of Personal Property
- 18-13 Pattern Requests for Admissions—Guaranty Agreement
- 18-14 Plaintiff’s Written Interrogatories
- 18-15 Pattern Interrogatories—Sworn Account
- 18-16 Pattern Interrogatories—Contract or Consumer Revolving Credit Account
- 18-17 Pattern Interrogatories—Promissory Note
- 18-18 Pattern Interrogatories—Foreclosure of Security Interest or Deficiency Judgment
- 18-19 Pattern Interrogatories—Lease of Personal Property
- 18-20 Pattern Interrogatories—Guaranty Agreement
- 18-21 Plaintiff’s Motion to Enlarge Number of Written Interrogatories
- 18-22 Order Enlarging Number of Interrogatories
- 18-23 Plaintiff’s Requests for Disclosure
- 18-24 Plaintiff’s Request for Production of Documents and Tangible Things
- 18-25
- 18-26 Plaintiff’s Motion to Compel Discovery
- 18-27 Order Compelling Discovery
- 18-28 Plaintiff’s Motion for Sanctions
- 18-29 Order Imposing Sanctions