Request For Disclosure To Defendant-FMLA, ADEA

IN THE UNITED STATES DISTRICT

FOR THE __________ DISTRICT OF TEXAS

__________ DIVISION

________, §

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Plaintiff, § §

§ Civil Action No. ____________

v. §

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________ §

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Defendant. §

REQUEST FOR DISCLOSURE TO DEFENDANT

TO: Defendant ________, by and through its counsel of record, ______:

COMES NOW, Plaintiff, and pursuant to Texas Rule of Civil Procedure 194, requests Defendant to disclose, within thirty three (33) days of service of this request, the information and material described in Rule 194.2(a) through (k), inclusive.

Pursuant to Texas Rule of Civil Procedure 194.4, Defendant is requested to produce for inspection and copying (or attach copies to your disclosures, if not voluminous), within thirty-three (33) days of service of this request, copies of all documents which reference, refer or relate to the information and material described in Defendant’s response to Plaintiff’s Request for Disclosure.

I.

DISCLOSURE REQUEST

1. State the correct names of the parties to the lawsuit.

   RESPONSE:

2. State the name, address, and telephone number of each potential party.

   RESPONSE:

3. State each of your legal theories and, in general, the factual bases for each of your claims or defenses.

   RESPONSE:

4. State the amount and method of calculating any economic damages.

   RESPONSE:

5. State the name, address, and telephone number of persons having knowledge of relevant facts, and state each person's connection with the case.

   RESPONSE:

6. For each testifying expert state:

   a. the expert's name, address, and telephone number;

   b. the subject matter on which the expert will testify;

   c. the general substance of the mental impressions and opinions held by the expert and a brief summary of the basis for them (or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control);

   d. if the expert is retained by, employed by, or otherwise subject to your control:

   i. produce all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and

   ii. produce the expert's current resume and bibliography.

   RESPONSE:

7. Produce all discoverable witness statements.

   RESPONSE:...