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Chapter 5

Form 5-22

This form is for use only in cases filed before January 1, 2021. Amendments to the Texas Rules of Civil Procedure effective for cases filed on or after that date eliminate the request for disclosure and provide instead for required disclosure, without request, of an expanded list of items of discovery. For required disclosures for cases filed on or after January 1, 2021, see forms 5-18 through 5-20.

No objections or assertions of work product are allowed to a rule 194 request for disclosure. Tex. R. Civ. P. 194.5. However, a party may assert any applicable privileges other than work product, e.g., a protective order to prevent the person’s residence from being revealed if harm could result.

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 Response to Rule 194 Requests for Disclosure

[Name], [attorney for Petitioner/attorney for Respondent/Petitioner/Respondent], pro­vides the attached response to the rule 194 requests for disclosure.

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

   
[Name]

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]