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Rule 194a.2. Content (2023)

TEXT

A party may request disclosure under Rule 194a.1 of any 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 bases of the responding party's claims or defenses (but the responding party need not marshal all evidence that may be offered at trial);

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

(e) the name, address, and telephone number of any person 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 that information; and

(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 biography;

(g) any discoverable settlement agreement described by Rule 192.3(g);

(h) any discoverable witness statement described by Rule 192.3(h);

(i) in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case:

(1) all medical records and bills that are reasonably related to the injuries or damages asserted; or

(2) an authorization permitting the disclosure of the information described by paragraph (i)(1);

(j) in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills obtained by the responding party through an authorization provided by the requesting party; and

(k) the name, address, and telephone number of any person who may be designated as a responsible third party.

Added by order Nov. 17, 2023, eff. Sept. 1, 2023.

Prior Amendments	Future Amendments

Notes and Comments

Comment to 2023 change: New Rule 194a is added to implement chapter 301 of the Family Code.