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Chapter 5

Form 5-20

For required initial disclosures, see form 5-18. For required testifying expert disclosures, see form
5-19.

No objections or assertions of work product are allowed to a rule 194 disclosure. Tex. R. Civ. P. 194.5. However, a party may assert any applicable privileges other than work product.

Include the following notice if a minor is named in the caption or if the response contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

[Petitioner/Respondent]’s Required Pretrial Disclosures

[Name], [attorney for Petitioner/attorney for Respondent/Petitioner/Respondent], pro­vides the attached pretrial disclosures required under rule 194.

The disclosures must be signed as required by Tex. R. Civ. P. 191.3.

   
[Name]
Attorney for [Petitioner/Respondent]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]

For certificate of service, see form 21-11.

Required Pretrial Disclosures

1.The name and, if not previously provided, the address and telephone number of each witness [Petitioner/Respondent] expects to present at trial.

RESPONSE:

2.The name and, if not previously provided, the address and telephone number of each witness [Petitioner/Respondent] may call at trial if the need arises.

RESPONSE:

3.Each document or other exhibit, including summaries of other evidence, [Peti­tioner/Respondent] expects to offer at trial.

RESPONSE:

4.Each document or other exhibit, including summaries of other evidence, [Peti­tioner/Respondent] may offer at trial if the need arises.

RESPONSE:

Forms 5-21 and 5-22 are reserved.