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Level Three Discovery Control Plan
CAUSE NO. ________
§ IN THE COUNTY COURT
PLAINTIFF §
§ AT LAW NO. ___
§
§
VS. §
§
DEFENDANT §
§ [COUNTY, STATE]
LEVEL THREE DISCOVERY CONTROL PLAN
On this day, the Plaintiff appeared before the Court and submitted the following proposed Level Three Discovery Control Plan:
LIMITS ON DISCOVERY Request for Disclosure: May be propounded by any party to any other party in conformity with the Texas Rules of Civil Procedure.
Interrogatories: The Court shall approve 10 pattern interrogatories which shall be propounded by each Plaintiff and 10 which shall be propounded by each Defendant. These interrogatories shall be answered fully without objection by the answering party. Each party may propound a maximum of 15 additional individual requests to another party.
Request for Production: The Court shall approve 25 pattern requests which shall be propounded by each Plaintiff and 25 which shall be propounded by each Defendant. These requests shall be answered fully without objection by the answering party. Each party may propound a maximum of 25 additional individual requests to another party.
Admissions: No numerical limit.
Fact Witness Depositions: The parties shall be allowed to depose a fact witness for five (5) hours per side plus a maximum of one (1) hour for each plaintiff regarding plaintiff- specific areas of discovery.
Expert Depositions: Retained experts shall be allowed ten (10) hours per side.
[specify date] PLAINTIFF’S EXPERT WITNESSES: By this date, Plaintiff will serve a designation of experts which will include:
the identity of testifying experts and consulting experts whose opinions or mental impressions have been reviewed in whole or in part by the testifying experts (this does not include treating healthcare providers);
producing expert reports and CV’s for experts identified in paragraph (a).
[specify date] DEFENDANTS’ EXPERT WITNESSES: By this date, Defendants will serve a designation of experts which will include:
the identity of testifying experts and consulting experts whose opinions or mental impressions have been reviewed in whole or in part by the testifying experts (this does not include treating healthcare providers);
producing expert reports and CV’s for experts identified in paragraph (a).
[specify date] PLAINTIFF’S REBUTTAL EXPERTS: By this date, Plaintiff will serve a designation of rebuttal experts which will...
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- Discovery Forms
- Medical records authorization
- Authorization for Texas Worker’s Compensation Commission Records
- Employment Records Authorization
- Scholastic Records Authorization
- Military Records Authorization
- Oral and Video Deposition Duces Tecum Propounded to Defendant for Employment Cases in General
- Oral and Video Deposition Duces Tecum to Plaintiff for Employment Cases in General
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Deposition Outline (Plaintiff) - False Imprisonment
- Standard Responses, Objections, and Answers to Interrogatories For Defendants and Plaintiffs
- Standard Responses, Objections, and Answers to Request for Production of Documents for Both Defendants and Plaintiffs
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff in Employment Cases in General
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff Employee's Spouse
- Sworn Statement by Non-Managerial Employee of Defendant
- Standard Instructions and Definitions for Plaintiff's Written Discovery to Defendant
- Plaintiff's "Triple Threat" Discovery to Defendant in Age Discrimination Case
- Plaintiff's Standard "Triple Threat" Discovery to Defendant in Employment Cases in General
- Plaintiff's "Triple Threat" Discovery Propounded to Defendant in Sexual Harassment Case
- Plaintiff's First Request for Production of Documents Propounded to Defendant City in a Whistleblower Case
- FOIA Request to the EEOC
- Open Records Request to the TCHR
- Standard Responses, Objections, and Answers to Interrogatories for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Standard Responses, Objections and Answers to Request for Production of Documents for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Request for Disclosures (Short Form) (State)
- Request for Disclosures (Long Form) (State)
- Discovery Plan (Worksheet)
- Deposition Outline - Economist
- Deposition Outline - Medical/Mental Health Professional
- Plaintiff's Proposed Pattern Interrogatories and Request for Production
- Level Three Discovery Control Plan
- Authorization for Release of Financial Records
- Motion to Compel Discovery (State)
- Deposition Outline - Corporate Representative - Products Liability
- "About Your Upcoming Deposition"
- Defendant's "Triple Threat" Discovery to Plaintiff - Race, Age & Firing
- Defendant's "Triple Threat" Discovery to Plaintiff - Sexual Harassment and Firing
- Plaintiff's "Triple Threat" Discovery to Defendant - Sex Discrimination (State Court)
- Plaintiff's "Triple Threat" Discovery to Former Employee Stealing Trade Secrets
- Petition Requesting Deposition Before Suit
- Opposition to Pre-Suit Deposition
- Order Authorizing Deposition
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
- Defendant's First Set of Requests for Production to Plaintiff-FLSA
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Request For Disclosure To Defendant-FMLA, ADEA
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