Request for Disclosures (Long Form) (State)

[Insert Heading]

REQUEST FOR DISCLOSURES

TO: [insert name of receiving party], by and through its/his/her attorney of record, [insert name of counsel of receiving party]

Pursuant to the provisions of Rule 194 of the Texas Rules of Civil Procedure, in the above-entitled and -numbered cause, serves its Request for Disclosures on and request that they disclose the information or material listed below as described in Rule 194.2(a)-(l), fully and separately, and serve such answers upon ’s attorney of record no later than thirty (30) days after service of this Request for Disclosures upon the ‘s counsel of record. No extension of time with respect to filing objections or responses to this Notice of Disclosure shall be valid unless such agreement is specifically set forth in writing and signed by ’s counsel of record.

REQUESTS

is requested to make disclosure of each of the following:

(a) the correct names of the parties to the lawsuit;

(b) the name, address, and telephone number of any potential parties;

(c) the legal theories and, in general, the factual basis of ’s claims;

(d) the amount and any method of calculating economic damages;

(e) the name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person’s connection with the case;

(f) for any testifying expert:

(1) the expert’s name, address and telephone number;

(2) the subject matter on which the expert will testify;

(3) the general substance of the expert’s mental impressions and opinions, and a brief summary of the basis for them or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information;

(4) if the expert is retained by, employed by, or otherwise subject to the control of the responding party;

(A) 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

(B) the expert’s current resume and bibliography;

(g) any indemnity and insuring agreements described in Rule 192.3(f);

(h) any settlement agreements described in Rule 192.3(g);

(i) any witness statements described in Rule 192.3(h);

(j) in a suit alleging physical or mental injury and damages...