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Chapter 5

Form 5-20

This form is for use only in cases filed on or after January 1, 2021. For cases filed on or after that date, certain required pretrial disclosures about the evidence a party may present at trial, other than solely for impeachment, must be made without waiting for a request. See Tex. R. Civ. P. 194.4.

For required initial disclosures, see form 5-18. For required testifying expert disclosures, see form
5-19.

No objections or assertions of work product are allowed to a rule 194 disclosure. Tex. R. Civ. P. 194.5. However, a party may assert any applicable privileges other than work product.

Include the following notice if a minor is named in the caption or if the response 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.]

[Petitioner/Respondent]’s Required Pretrial Disclosures

[Name], [attorney for Petitioner/attorney for Respondent/Petitioner/Respondent], pro­vides the attached pretrial disclosures required under rule 194.

The disclosures must be signed as required by Tex. R. Civ. P. 191.3.

   
[Name]
Attorney for [Petitioner/Respondent]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]

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 [Petitioner/Respondent]

Required Pretrial Disclosures

1.The name and, if not previously provided, the address and telephone number of each witness [Petitioner/Respondent] expects to present at trial.

RESPONSE:

2.The name and, if not previously provided, the address and telephone number of each witness [Petitioner/Respondent] may call at trial if the need arises.

RESPONSE:

3.Each document or other exhibit, including summaries of other evidence, [Peti­tioner/Respondent] expects to offer at trial.

RESPONSE:

4.Each document or other exhibit, including summaries of other evidence, [Peti­tioner/Respondent] may offer at trial if the need arises.

RESPONSE: