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...