Requests for production are the subject of Tex. R. Civ. P. 196. Requests for production may not request items available through disclosure under Tex. R. Civ. P. 194. Note: Documents provided to, reviewed by, or prepared by a testifying expert are subject to disclosure under rule 194. Likewise, medical records must also be requested under rule 194 in certain situations.
Sample Requests for Production
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Select as applicable. |
1.Produce for inspection and copying all documents related to this lawsuit given to or obtained, reviewed, or prepared by each person used for consultation and who is not expected to be called as a witness at trial if the consulting expert’s work product forms a basis in whole or in part of the opinions of an expert who is to be called as a witness or the consulting expert’s report or work product is reviewed by or received by the expert who is to testify in this case.
2.Produce for inspection and copying all documents that relate directly or indirectly to the mental condition of [name of proposed ward] from [date] through the present.
3.Produce for inspection and copying all documents that relate directly or indirectly to the physical condition of [name of proposed ward] from [date] through the present.
4.If you are or have been a party to any lawsuit (other than this lawsuit) from [date] through the present, please produce for inspection and copying the pleadings in any such suit.
5.If you are indebted to [name of proposed ward] or to any trust or business entity in which [name of proposed ward] has an interest, please produce for inspection and copying all documents relating to any such debt.
6.If you have any claim that is adverse to [name of proposed ward] or to any property, real or personal, of [name of proposed ward], please produce for inspection and copying all documents relating to that claim or property.
7.Please produce for inspection and copying all documents relating to any claim you have against [list any trusts or entities in which the proposed ward has an interest] or to any property, real or personal, of any such entity.
8.Please produce for inspection and copying all diplomas from degrees you have earned, professional licenses you hold, and all documents relating to any disciplinary proceeding held against you.
9.If you have been divorced, please produce for inspection and copying any divorce decree or judgment entered in any such divorce case.
10.Please produce for inspection and copying all documents relating to any gift or loan in an amount or value in excess of $500 made to you by [name of proposed ward].
11.Please produce for inspection and copying all documents that relate to any crime, other than minor traffic violations, for which you have been charged or arrested.
12.Please produce for inspection and copying all documents that relate to your claim that [name of proposed ward] is unable to manage [his/her] person and estate.
13.Please produce for inspection and copying all documents that relate to your claim that a necessity exists for the appointment of a permanent guardian of [name of proposed ward]’s person and estate.
14.Please produce for inspection and copying all documents that [name of physician] provided you.
15.Please produce for inspection and copying all documents that relate to any personal or business matter involving you and [name of proposed ward] from [date] through the present.
16.Please produce for inspection and copying all documents relating to your claim for attorney’s fees and expenses from [name of proposed ward] including, but not limited to, all attorney’s fee contracts, letter agreements, billing statements, and invoices.
17.Please produce for inspection and copying all documents relating to written complaints or concerns you have prepared (except to or for your lawyers) relating to [name of proposed ward]’s personal and financial matters.
18.Please produce for inspection and copying [include as applicable: (a) [name of proposed ward]’s last will, (b) the last will of [name of proposed ward]’s spouse, (c) all trust agreements signed by [name of proposed ward], (d) all trust agreements signed by [name of proposed ward]’s spouse, including all exhibits thereto, (e) all powers of attorney signed by [name of proposed ward], (f) all powers of attorney signed by [name of proposed ward]’s spouse, (g) all directives to physicians signed by [name of proposed ward], and (h) all directives to physicians signed by [name of proposed ward]’s spouse].
19.Please produce for inspection and copying all witness statements from anyone concerning any matters relevant to this lawsuit.
20.Please produce for inspection and copying the documents related to any actions taken by you as agent for [name of proposed ward], including but not limited to financial records, invoices you have paid, checks, account agreements, beneficiary designations, guarantees, consents, engagement agreements, and other contracts.
21.Please produce for inspection and copying all documents reviewed or relied upon in the preparation of your Answers to [title of requestor]’s Request for Disclosure in this litigation.
22.Please produce for inspection and copying all documents related to the investigation of your allegations in the litigation.
23.Please produce for inspection and copying all documents and materials you intend to use in any deposition in the litigation.
24.Please produce for inspection and copying all documents or evidence you intend to use for impeachment purposes in the litigation.
25.Please produce for inspection and copying all exhibits you intend to use at trial.
26.Please produce for inspection and copying all documents that have not been produced under the above requests for production numbers 1. through 25. that relate to or reflect facts relevant to this lawsuit.