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- Discovery
Request for disclosures (long format) (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...
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Request your trial- Appendices
- Discovery
- Standard responses, objections, and answers to interrogatories for defendants and plaintiffs
- Deposition duces tecum propounded to defendant city, whistleblower case
- Military records authorization
- Deposition outline checklist: plaintiff's deposition of defendant's employees: general questions
- Oral and video deposition duces tecum propounded to defendant for employment cases in general
- Scholastic records authorization
- Oral and video deposition duces tecum to plaintiff for employment cases in general
- Authorization for Texas worker's compensation commission records
- Employment records authorization
- Standard responses, objections and answers to request for production of documents for both defendants and plaintiffs for federal court cases only
- Medical Records Authorization
- Deposition checklist: deposing the plaintiff in employment cases (in general)
- Deposition outline (plaintiff)-false imprisonment
- Open records request to the TCHR
- Plaintiff's "triple threat" discovery propounded to defendant in sexual harassment case
- Plaintiff's "triple threat" discovery to defendant in age discrimination case
- Foia request to the EEOC
- Standard instructions and definitions for plaintiff's written discovery to defendant
- Sworn statement by non-managerial employee of defendant
- Plaintiff's standard "triple threat" discovery to defendant in employment cases in general
- Defendant's "triple threat" discovery propounded to plaintiff employee's spouse
- Standard responses, objections and answers to request for production of documents for defendants and plaintiffs under texas rules of civil procedure
- Standard instructions and definitions for defendant's written discovery to plaintiff
- Defendant's "triple threat" discovery propounded to plaintiff in employment cases in general
- Plaintiff's first request for production of documents propounded to defendant city in a whistleblower case
- Standard responses, objections, and answers to interrogatories for defendants and plaintiffs under Texas rules of civil procedure
- Race, age and firing-short version defendant's first requests for admissions, first set of interrogatories and first requests for production of documents propounded to plaintiff
- Level three discovery control plan
- Plaintiff's proposed pattern interrogatories and request for production
- Motion to compel discovery (state)
- Deposition outline-economist
- Deposition outline-medical/mental health professional
- Deposition outline-corporate representative-products liability
- Request for disclosures (long format) (state)
- Authorization for release of financial records
- Request for disclosures (short format) (state)
- Sexual harassment and firing defendant's first requests for admissions, first set of interrogatories and first requests for production of documents propounded to plaintiff
- "About your upcoming deposition"
- Discovery Plan
- Plaintiff's triple-threat to defendant re: stealing trade secrets
- Opposition to pre-suit deposition
- Order authorizing deposition
- Petition requesting deposition before suit
- Plaintiff's "triple threat" discovery to former employee stealing trade secrets
- Plaintiff's "triple threat" discovery to defendant - sexual harassment
- Request For Disclosure To Defendant-FMLA, ADEA
- Defendant's first set of interrogatories to plaintiff-FLSA
- Defendant's first set of requests for production to plaintiff-FLSA
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Over 100 Countries
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