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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 for Reduction of [Expert’s/Experts’] Report[s] to Tangible Form
This Motion for Reduction of [Expert’s/Experts’] Report[s] to Tangible Form is brought by [name of movant], [party designation], who shows in support:
1.[Name] has disclosed the name[s] of [an expert/experts] who may be called as [a witness/witnesses] in this case.
2.[Name of movant] requests, pursuant to rule 195.5 of the Texas Rules of Civil Procedure, that [each of] [name]’s expert[s] prepare a complete written report detailing the expert’s factual observations, tests, supporting data, calculations, photographs, and opinions.
3.[The/Each] expert’s report should be produced to [name of movant] at [location] on [date] not later than [time].
[Name of movant] prays that this Motion for Reduction of [Expert’s/Experts’] Report[s] to Tangible Form be granted.
[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]