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Include the following notice if a minor is named in the caption or if the motion 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.]
Motion to Determine Sufficiency of Answers or Objections to Request for Admissions
This Motion to Determine Sufficiency of [Answer[s]/Objection[s]/Answer[s] and Objection[s]] to Request for Admissions is brought by [name of movant], [party designation], who shows in support:
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Include one or both of the following. |
[Name of other party] has provided [an answer/answers] to the following Request for Admissions that [is/are] [insufficient/evasive/incomplete/[or applicable combination of these terms]], as follows: [provide request for admission number and whether the answer given is insufficient, evasive, and/or incomplete]. [Name of movant] asks that the Court order that each such Request for Admission be admitted or that an amended answer be served by [name of other party].
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And/Or |
[Name of other party]’s objections to the following Request for Admissions are unjustified, as follows: [provide request for admission number for each unjustified objection]. [Name of movant] asks that the Court order that [an answer/answers] be served by [name of other party].
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Continue with the following. |
[Name of movant] prays that the Court grant this motion as requested above.
[Name]
Attorney for [name of movant]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
Certificate of Conference
I certify that a reasonable effort has been made to resolve the discovery dispute without the necessity of court intervention and has failed.
[Name]
Attorney for [name of movant]
Notice of Hearing
The above motion is set for hearing on __________________ at ____________ __.m. in [designation and location of court].
SIGNED on ________________________________.
Judge or Clerk
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]
Attorney for [name of movant]