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Request For Disclosure To Defendant-FMLA, ADEA
IN THE UNITED STATES DISTRICT
FOR THE __________ DISTRICT OF TEXAS
__________ DIVISION
________, §
§
Plaintiff, § §
§ Civil Action No. ____________
v. §
§
________ §
§
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
-
State the correct names of the parties to the lawsuit.
RESPONSE:
-
State the name, address, and telephone number of each potential party.
RESPONSE:
-
State each of your legal theories and, in general, the factual bases for each of your claims or defenses.
RESPONSE:
-
State the amount and method of calculating any economic damages.
RESPONSE:
-
State the name, address, and telephone number of persons having knowledge of relevant facts, and state each person's connection with the case.
RESPONSE:
-
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:
-
Produce all discoverable witness statements.
RESPONSE:...
To continue reading
Request your trial- Appendices
- Discovery
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- 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
- Scholastic Records Authorization
- Military Records Authorization
- Medical records authorization
- Employment Records Authorization
- Authorization for Texas Worker’s Compensation Commission Records
- Deposition outline (plaintiff)-false imprisonment
- Plaintiff's first request for production of documents propounded to defendant city in a whistleblower case
- Plaintiff's "triple threat" discovery to defendant in age discrimination case
- Sworn Statement by Non-Managerial Employee of Defendant
- Defendant's "triple threat" discovery propounded to plaintiff employee's spouse
- Defendant's "triple threat" discovery propounded to plaintiff in employment cases in general
- Standard instructions and definitions for plaintiff's written discovery to defendant
- FOIA Request to the EEOC
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Plaintiff's "triple threat" discovery propounded to defendant in sexual harassment case
- 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 for federal court cases only
- Plaintiff's standard "triple threat" discovery to defendant in employment cases in general
- Level Three Discovery Control Plan
- Request for disclosures (long format) (state)
- Deposition outline-economist
- Deposition outline-medical/mental health professional
- 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 format) (state)
- Motion to Compel Discovery (State)
- Open Records Request to the TCHR
- Plaintiff's proposed pattern interrogatories and request for production
- Authorization for Release of Financial Records
- Discovery Plan
- Defendant's first set of requests for production to plaintiff-FLSA
- Petition Requesting Deposition Before Suit
- Plaintiff's "triple threat" discovery to former employee stealing trade secrets
- Opposition to Pre-Suit Deposition
- Plaintiff's "triple threat" discovery to defendant - sexual harassment
- Sexual Harassment and FirinG
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Race, Age and Firing-Short Version
- "About Your Upcoming Deposition"
- Request For Disclosure To Defendant-FMLA, ADEA
- Deposition outline-corporate representative-products liability
- Order Authorizing Deposition
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
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Over 100 Countries
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Updated daily, vLex brings together legal information from over 750 publishing partners, providing access to over 2,500 legal and news sources from the world’s leading publishers.
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