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Chapter 5
- § 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—Suits Filed before January 1, 2021
- § 5.42 Required Disclosures—Suits Filed on or after January 1, 2021
- § 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 Rule 194 Requests for Disclosure
- 5-22 [Petitioner/Respondent]’s Response to Rule 194 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 Reduction of [Expert’s/Experts’] Report[s] to Tangible Form
- 5-82 Order on Motion for Reduction of [Expert’s/Experts’] Report[s] to Tangible Form
- 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]