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Chapter 5
Practice Notes
Forms
§ 5.1 Forms of Discovery Generally
§ 5.2 Discovery Control Plan
§ 5.3 Modification of Discovery Procedures
§ 5.4 Certificate for Discovery Motions
§ 5.5 Signature Required
§ 5.6 Filing, Retention, and Service of Discovery Materials
§ 5.7 Orders for Protection from Discovery
§ 5.8 Discovery from Nonparties
§ 5.9 Discovery of Customer Records from Financial Institution
§ 5.10 Mandamus as Remedy
§ 5.21 Scope of Discovery Generally
§ 5.22 Documents and Tangible Things
§ 5.23 Potential Parties and Witnesses
§ 5.24 Testifying and Consulting Experts
§ 5.25 Witness Statements
§ 5.26 Other Topics of Discovery
§ 5.27 Work Product
§ 5.28 Privileged Matters
§ 5.29 Waiving Objections to Discovery or Assertions of Privilege
§ 5.40 Written Discovery Defined
§ 5.41 Requests for Disclosure—Claims Arising under Family Code on or after September 1, 2023, and Suits Filed before January 1, 2021
§ 5.42 Required Disclosures—Suits Filed Between January 1, 2021, and August 31, 2023, and All Suits Not Under the Family Code
§ 5.43 Requests for Production and Inspection of Documents and Tangible Things
§ 5.44 Request or Motion for Entry on Property
§ 5.45 Interrogatories to Parties
§ 5.46 Requests for Admissions
§ 5.47 Responses and Objections to Written Discovery
§ 5.48 Amending or Supplementing Responses to Written Discovery
§ 5.49 Effect of Failure to Timely Respond
§ 5.61 Permitted Means of Discovery
§ 5.62 Designation of Experts
§ 5.63 Depositions
§ 5.64 Reports of Experts
§ 5.65 Protected Communications, Expert Reports, and Disclosures
§ 5.66 Amendment and Supplementation of Discovery
§ 5.71 Motion and Order for Mental or Physical Examination
§ 5.72 Cases Arising under Title 2 or Title 5 of Family Code
§ 5.73 No Examination
§ 5.74 Selection and Report of Examining Professional
§ 5.81 Oral Depositions
§ 5.82 Compelling Appearance; Production of Documents and Things at Oral Deposition
§ 5.83 Written Questions at Oral Deposition
§ 5.84 Conduct and Objections during Oral Deposition
§ 5.85 Hearing on Objection or Privilege
§ 5.86 Nonstenographic Recording; Deposition by Telephone
§ 5.87 Depositions on Written Questions
§ 5.88 Depositions in Foreign Jurisdictions
§ 5.89 Depositions before Suit or to Investigate Claims
§ 5.90 Signing, Certification, and Use of Depositions
§ 5.91 Amending or Supplementing Deposition Testimony
§ 5.101 Subpoenas
§ 5.102 Enforcement of Subpoenas
§ 5.111 Motion for Sanctions or Order Compelling Discovery
§ 5.112 Failure to Comply with Order or Discovery Request
§ 5.113 Abuse of Discovery Process
§ 5.114 Failure to Comply with Rule 198
§ 5.115 Failure to Attend or Serve Subpoena
§ 5.116 False Certification
5-1 Motion for Discovery Control Plan
5-2 Agreed Order on Motion for Discovery Control Plan
5-3 Motion to Modify Discovery Control Plan
5-4 Order on Motion to Modify Discovery Control Plan
5-5 Motion for Protective Order
5-6 Order on Motion for Protective Order
5-7 Motion for Confidentiality Order
5-8 Confidentiality Order
5-9 Request for Identification of Withheld Production
5-18 [Petitioner/Respondent]’s Required Initial Disclosures
5-19 [Petitioner/Respondent]’s Required Testifying Expert Disclosures
5-20 [Petitioner/Respondent]’s Required Pretrial Disclosures
5-21 [Petitioner/Respondent]’s Request for Disclosure
5-22 [Petitioner/Respondent]’s Response to Requests for Disclosure
5-23 [Petitioner/Respondent]’s Request for Production and Inspection
5-24 Response to Request for Production and Inspection
5-25 [Petitioner/Respondent]’s Notice for Production or Inspection of Documents and Other Tangible Things
5-26 Suggested Language for Production of Bank Records
5-27 Suggested Language for Production of School Records
5-28 Suggested Language for Production of Employment Records
5-29 Suggested Language to Secure Social Worker’s Report
5-30 Affidavit for Business Records
5-31 Declaration for Business Records
5-32 Authorization to Disclose Protected Health Information
5-33 Motion for Order to Obtain Protected Health Information
5-34 Order on Motion for Order to Obtain Protected Health Information
5-35 Subpoena to Compel Production of Protected Health Information of [name of patient]
5-36 Notice That Document[s] Will Be Used at Trial
5-37 Response to Notice That Document[s] Will Be Used at Trial
5-38 [Petitioner/Respondent]’s Request for Entry upon Property
5-39 Motion for Entry upon Property
5-40 Order on Motion for Entry upon Property
5-41 [Petitioner/Respondent]’s Written Interrogatories to [Respondent/Petitioner]
5-42 Answers to Interrogatories
5-43 Pattern Interrogatories—General
5-44 Pattern Interrogatories—Property
5-45 Pattern Interrogatories—Conservatorship
5-46 Pattern Interrogatories—Modification of Child Support
5-47 Pattern Interrogatories—Modification of Conservatorship
5-61 Request for Admissions
5-62 Response to Request for Admissions
5-63 Motion to Withdraw or Amend Admissions
5-64 Order on Motion to Withdraw or Amend Admissions
5-65 Motion to Determine Sufficiency of Answers or Objections to Request for Admissions
5-66 Order on Motion to Determine Sufficiency of Answers or Objections to Request for Admissions
5-71 Notice of Intent to Take Oral Deposition of [name]
5-72 Notice of Recording Deposition [Stenographically/by Video Recording/by Audio Recording]
5-73 Motion to Require Transcription of Deposition Recording
5-74 Order on Motion to Require Transcription of Deposition Recording
5-75 Notice of Intent to Take Deposition on Written Questions
5-81 Motion for Court-Ordered Reports
5-82 Order on Motion for Court-Ordered Reports
5-83 Motion for [Physical/Mental] Examination
5-84 Order on Motion for [Physical/Mental] Examination
5-91 Motion [to Compel Discovery/for Sanctions/to Compel Discovery and for Sanctions]
5-92 Order on Motion [to Compel Discovery/for Sanctions/to Compel Discovery and for Sanctions]
5-93 Subpoena
5-94 Subpoena to Compel Production of Documents and Tangible Things
5-95 Letter to Nonparty Requesting Execution of Affidavit or Declaration for Business Records
5-96 Notice of Business Records [Affidavit/Declaration]
Form5-33
5 Discovery
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