No objections or assertions of work product are allowed to a rule 194 request for disclosure. Tex. R. Civ. P. 194.5. However, a party may assert any applicable privileges other than work product, e.g., a protective order to prevent the person’s residence from being revealed if harm could result.
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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 Response to Rule 194 Requests for Disclosure
[Name], [attorney for Petitioner/attorney for Respondent/Petitioner/Respondent], provides the attached response to the rule 194 requests for disclosure.
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The response must be signed as required by Tex. R. Civ. P. 191.3. |
[Name]
Certificate of Service
I certify that a true copy of this [document/[title of document]] was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on [date]:
[Name of attorney of record or party to be served] by [electronic filing manager/e-mail at [e-mail address]/fax at [fax number]/personal delivery at [address]/commercial delivery service at [address]/certified mail at [address]/first-class mail at [address]]. [Repeat for each attorney of record or party to be served.]
[Name]