Discovery from nonparties is governed by the requirements of Tex. R. Civ. P. 205.
Suggested Language for Production of Employment Records
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Select only as applicable. |
1.The complete personnel file maintained for [name] for the entire period of employment.
2.The original employment contract or agreement for [name].
3.The payroll records showing the gross pay, including commissions, deferred bonus, and severance pay, withholding deductions, and net pay for all compensation paid to [name] for the period from [date] to the date of production of the records.
4.The expense-account records showing the nature and amount of all expenses reimbursed to [name] under the terms of employment for the period from [date] to the date of production of the records.
5.The original or official ERISA wrap document, written health insurance plan, medical reimbursement plan, life insurance plan, employee stock ownership plan, stock option plan, phantom stock plan, stock appreciation plan, restricted stock plan, deferred compensation plan, employee retirement plan, pension plan, profit-sharing plan, and savings plan or other employee benefit plan or official summary thereof, and any loan, withdrawal, or distribution information, together with the annual report of the interest of [name] in those plans, for the period from [date] to the date of production of the records.
6.The travel records showing the date and place of destination and duration of all periods of travel of [name] for the period from [date] to the date of production of the records.