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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 Discovery Control Plan
This Motion for Discovery Control Plan is filed by [name of movant], [party designation], under rule 190.4 of the Texas Rules of Civil Procedure.
[Name of movant] requests that the Court tailor a discovery control plan to the circumstances of this family law case.
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Include the following if applicable. |
The parties have agreed to a discovery control plan as set forth in an agreed order tendered with this motion. [Name of movant] requests that the Court approve and sign the agreed order. If the Court does not approve the agreed order, [name of movant] requests that the Court order a discovery plan in substantial conformity with the discovery plan set forth in the agreed order.
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Continue with the following. |
[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]