This notice should be addressed to the defendant through his attorney if he is represented by one. Otherwise, the notice should be sent directly to the defendant, addressed “To: [name of defendant], Defendant.” Requests for disclosure are discussed generally at part V. in this chapter.
[Caption. See § 3 of the Introduction in volume 1 of this manual.]
Plaintiff’s Requests for Disclosure
To: [name of defendant], Defendant, by and through [his/her] attorney of record, [name and address of attorney].
Pursuant to rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within thirty days of service of this request, the information or material described in rule 194.2(a)–(i).
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Include the following for level 1 discovery control plan only. |
Pursuant to rule 190.2(b)(6), you are requested to disclose all documents, electronic information, and tangible items that you have in your possession, custody, or control and may use to support your claims or defenses.
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Continue with the following. |
[Name]
Attorney for Plaintiff
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Telecopier]
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Serve a copy on the responding party and all other parties. Include a certificate of service (form 19-1). |