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Include the following notice if a minor is named in the caption or if the document 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.]
Answers to Interrogatories
[Name], [Respondent/Petitioner], provides the attached Answers to Interrogatories and states under oath that all answers are true, subject to the following qualifications:
1.Answers to [Interrogatory/Interrogatories] number[s] [number[s]] are based on information obtained from another person.
2.Answers to interrogatories inquiring about persons with knowledge of relevant facts, trial witnesses, and legal contentions are not made under oath.
[Name of party], Affiant
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An unsworn declaration may be used in place of a written sworn declaration. See form 8-27. |
SIGNED under oath before me on ______________________________.
Notary Public, State of Texas
[Name]
Attorney for [Respondent/Petitioner]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]
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For certificate of service, see form 21-11. |
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Attach answers to interrogatories. Assertions of privilege may be contained in the answers or in a separate document. Tex. R. Civ. P. 193.3(a). The assertion of privilege shown in form 5-24 may be adapted. |
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The following are sample objections. |
Objection is made to this interrogatory because it was served on [Respondent/Petitioner] later than thirty days before the end of the discovery period. Tex. R. Civ. P. 197.1.
Objection is made to this interrogatory because it is in excess of the [twenty-five written interrogatories [Petitioner/Respondent] may serve on [Respondent/Petitioner]/number of written interrogatories [Petitioner/Respondent] may serve on [Respondent/Petitioner] under the level 3 discovery control plan in this suit]. Tex. R. Civ. P. 190.
Objection is made to this interrogatory because it seeks discovery of information that is not relevant to the subject matter of this suit and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P. 192.3(a).
Objection is made to this interrogatory because it is overly broad and seeks to require [Respondent/Petitioner] to provide more than a basic statement of [her/his] legal contentions and the factual bases for those contentions. [Respondent/Petitioner] is not required to marshal [her/his] evidence in response to a written interrogatory. Tex. R. Civ. P. 192.3(j), 192 cmt. 5.
Objection is made to this interrogatory to the extent that the discovery sought is unreasonably cumulative or duplicative. Tex. R. Civ. P. 192.4(a).
Objection is made to this interrogatory to the extent the discovery sought is obtainable from some other source that is more convenient, less burdensome, or less expensive. Tex. R. Civ. P. 192.4(a).
Objection is made to this interrogatory to the extent the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties’ resources, the importance of the issues at stake in the litigation, and the importance of the proposed discovery in resolving the issues. Tex. R. Civ. P. 192.4(b).
Objection is made to this interrogatory to the extent it subjects [Respondent/Petitioner] to undue burden, unnecessary expense, harassment, or annoyance. Tex. R. Civ. P. 192.6(b).
Objection is made to this interrogatory to the extent it subjects [Respondent/Petitioner] to an invasion of personal, constitutional, or property rights. Tex. R. Civ. P. 192.6(b).
Objection is made to this interrogatory because it exceeds the scope of discovery by seeking information about testifying expert witnesses through a written interrogatory. Tex. R. Civ. P. 195.1.
Objection is made to this interrogatory because it exceeds the scope of discovery by seeking information about consulting expert witnesses whose mental impressions and opinions have not been reviewed by a testifying expert. Tex. R. Civ. P. 192.3(e).