Discovery Request Formatter Discovery Request Formatter Cause No.(Required)Name of Plaintiff(s)(Required)Name of Defendant(s)(Required)Type of Court(Required) IN THE DISTRICT COURT IN THE COUNTY COURT AT LAW PROBATE COURT Court Number and Title(Required)County(Required)Anderson CountyAndrews CountyAngelina CountyAransas CountyArcher CountyArmstrong CountyAtascosa CountyAustin CountyBailey CountyBandera CountyBastrop CountyBaylor CountyBee CountyBell CountyBexar CountyBlanco CountyBorden CountyBosque CountyBowie CountyBrazoria CountyBrazos CountyBrewster CountyBriscoe CountyBrooks CountyBrown CountyBurleson CountyBurnet CountyCaldwell CountyCalhoun CountyCallahan CountyCameron CountyCamp CountyCarson CountyCass CountyCastro CountyChambers CountyCherokee CountyChildress CountyClay CountyCochran CountyCoke CountyColeman CountyCollin CountyCollingsworth CountyColorado CountyComal CountyComanche CountyConcho CountyCooke CountyCoryell CountyCottle CountyCrane CountyCrockett CountyCrosby CountyCulberson CountyDallam CountyDallas CountyDawson CountyDeaf Smith CountyDelta CountyDenton CountyDeWitt CountyDickens CountyDimmit CountyDonley CountyDuval CountyEastland CountyEctor CountyEdwards CountyEl Paso CountyEllis CountyErath CountyFalls CountyFannin CountyFayette CountyFisher CountyFloyd CountyFoard CountyFort Bend CountyFranklin CountyFreestone CountyFrio CountyGaines CountyGalveston CountyGarza CountyGillespie CountyGlasscock CountyGoliad CountyGonzales CountyGray CountyGrayson CountyGregg CountyGrimes CountyGuadalupe CountyHale CountyHall CountyHamilton CountyHansford CountyHardeman CountyHardin CountyHarris CountyHarrison CountyHartley CountyHaskell CountyHays CountyHemphill CountyHenderson CountyHidalgo CountyHill CountyHockley CountyHood CountyHopkins CountyHouston CountyHoward CountyHudspeth CountyHunt CountyHutchinson CountyIrion CountyJack CountyJackson CountyJasper CountyJeff Davis CountyJefferson CountyJim Hogg CountyJim Wells CountyJohnson CountyJones CountyKarnes CountyKaufman CountyKendall CountyKenedy CountyKent CountyKerr CountyKimble CountyKing CountyKinney CountyKleberg CountyKnox CountyLa Salle CountyLamar CountyLamb CountyLampasas CountyLavaca CountyLee CountyLeon CountyLiberty CountyLimestone CountyLipscomb CountyLive Oak CountyLlano CountyLoving CountyLubbock CountyLynn CountyMadison CountyMarion CountyMartin CountyMason CountyMatagorda CountyMaverick CountyMcCulloch CountyMcLennan CountyMcMullen CountyMedina CountyMenard CountyMidland CountyMilam CountyMills CountyMitchell CountyMontague CountyMontgomery CountyMoore CountyMorris CountyMotley CountyNacogdoches CountyNavarro CountyNewton CountyNolan CountyNueces CountyOchiltree CountyOldham CountyOrange CountyPalo Pinto CountyPanola CountyParker CountyParmer CountyPecos CountyPolk CountyPotter CountyPresidio CountyRains CountyRandall CountyReagan CountyReal CountyRed River CountyReeves CountyRefugio CountyRoberts CountyRobertson CountyRockwall CountyRunnels CountyRusk CountySabine CountySan Augustine CountySan Jacinto CountySan Patricio CountySan Saba CountySchleicher CountyScurry CountyShackelford CountyShelby CountySherman CountySmith CountySomervell CountyStarr CountyStephens CountySterling CountyStonewall CountySutton CountySwisher CountyTarrant CountyTaylor CountyTerrell CountyTerry CountyThrockmorton CountyTitus CountyTom Green CountyTravis CountyTrinity CountyTyler CountyUpshur CountyUpton CountyUvalde CountyVal Verde CountyVan Zandt CountyVictoria CountyWalker CountyWaller CountyWard CountyWashington CountyWebb CountyWharton CountyWheeler CountyWichita CountyWilbarger CountyWillacy CountyWilliamson CountyWilson CountyWinkler CountyWise CountyWood CountyYoakum CountyYoung CountyZapata CountyZavala CountyAbout Our ClientWho is our client?(Required)What is our position in this case?(Required) Plaintiff Defendant The opposing position is the:(Required) Plaintiff Defendant About the RequestCaption of the RequestWhich defendant is the receiving party to this discovery request?(Required)What is the defendant's name shortened?(Required)What kind of discovery request is this?(Required) Combined Request for Production Request for Admissions Interrogatories Opposing Counsel InformationHow many opposing counsel?(Required)OneTwoThreeFourFiveWhat is opposing counsel number 1's full name?(Required)What is opposing counsel number 1's law firm name?(Required)What is opposing counsel number 1's address?(Required)What is opposing counsel number 1's email?(Required)What is opposing counsel number 2's full name?What is opposing counsel number 2's law firm name?What is opposing counsel number 2's address?What is opposing counsel number 2's email?What is opposing counsel number 3's full name?What is opposing counsel number 3's law firm name?What is opposing counsel number 3's address?What is opposing counsel number 3's email?What is opposing counsel number 4's full name?What is opposing counsel number 4's law firm name?What is opposing counsel number 4's address?What is opposing counsel number 4's email?What is opposing counsel number 5's full name?What is opposing counsel number 5's law firm name?What is opposing counsel number 5's address?What is opposing counsel number 5's email?What is opposing counsel number 6's full name?What is opposing counsel number 6's law firm name?What is opposing counsel number 6's address?What is opposing counsel number 6's email?This field is hidden when viewing the formToday's Date MM slash DD slash YYYY This field is hidden when viewing the formToday's Date Written FormallyThis field is hidden when viewing the formAlternative DateDefinitionsModify Definitions Below“You,” “yours,” “,” and “,” mean , its officers, agents, employees, successors, assigns, and any person who or entity which acts for or on its behalf. “Document” or “Documents” means the original and all copies of the original which differ in any respect from the original (whether by interlineation, draft copy, notations written thereon, indication of copies sent or received or to whom routed, or otherwise) of any letter, correspondence, pamphlet, memorandum, handwritten note, work paper, contract, chart, paper, drawing, screenshot, video file, audio file, digital file, or any other type of written, recorded or transcribed matter of any description, however produced or reproduced, and all supplements and amendments thereto. “Communication” means any oral, written, electronic, or other transmission of information, including but not limited to any discussion, conversation, negotiation, agreement, understanding, meeting, letter, correspondence, note, e-mail, text message, instant message, social media communication, facsimile, app message, voice message, or other form of interaction, whether formal or informal, and whether transmitted in person, over the phone, or via any other medium. “Identify” (as it pertains to a person) means to state (a) the full name; (b) the current or last known address and telephone number; (c) the person’s job title or position at the relevant time; (d) the person’s relationship to the parties in this case; and (e) any other known identifying information such as an email address or employee identification number. “Identify” (as it pertains to an entity) means to state (a) the full legal name of the entity; (b) the type of entity (e.g., corporation, LLC, partnership); (c) the entity’s principal place of business and last known address; (d) the jurisdiction in which the entity is incorporated or organized; (e) the entity’s relationship to the parties in this case; and (f) the name and contact information of any officer, director, or agent acting on behalf of the entity in the matter at issue. “Identify” (as it pertains to a document) means: (a) describe the documents by generic type (e.g. invoice, debit memo); (b) state the identification number on each document if has been bates stamped; (c)state the name of the present custodian, all past custodians, and the dates during which each custodian had custody of each document. Follow procedures (a)-(c) for each document which originated with ABD or anyone else who generated documents relevant to this litigation and responsive to these interrogatories. InstructionsModify Instructions BelowUnless otherwise stated, the relevant time period for these requests is from and including January 2019 until the present. For each document that Defendant claims is privileged or otherwise not discoverable: (1) describe the nature or substance of the documents, information, communications, or tangible things not produced; (2) identify the author and recipient(s) of the documents or communications; (3) identify the date of the communication, (4) state where the document is currently located; and (5) identify the privilege or ground under which the document is being withheld. If any copy of any document whose production is sought is not identical to any other copy thereof, by reason of any alterations, different form (e.g., electronic form), metadata or metatags, marginal notes, comments or other material contained thereon, attached thereto, or otherwise, all such non-identical copies shall be produced separately. Such other copies include, without limitation, all revisions in electronic or magnetic format. Electronic or magnetic data that is responsive to any of these document requests shall be produced in its native computer readable format with an identification of the specific computer or computer device from which it was taken and its associated software application and computer system. The data produced must contain an exact copy of the source, or other electronic or magnetic media or storage device containing the original data, and include not only active files, but all deleted, erased, or discarded copies, and prior versions or drafts of the data. Requests for production specifically request electronically-stored information and all meta-data associated with said electronically-stored information. In producing documents, all documents which are physically attached to each other in your files shall be left so attached. Documents shall be produced in the order in which they were maintained. If any document or tangible thing requested to be produced by these requests was, but no longer is, in your possession, custody or control, or if the document or tangible thing is no longer in existence, please state the reason for whether the document or thing is (1) missing or lost; (2) destroyed; (3) in the possession or control of others, and if so, please identify the current custodian; or (4) disposed of, or otherwise unavailable.Requests for ProductionRFP No. 1RFP No. 2RFP No. 3RFP No. 4RFP No. 5RFP No. 6RFP No. 7RFP No. 8RFP No. 9RFP No. 10RFP No. 11RFP No. 12RFP No. 13RFP No. 14RFP No. 15RFP No. 16RFP No. 17RFP No. 18RFP No. 19RFP No. 20RFP No. 21RFP No. 22RFP No. 23RFP No. 24RFP No. 25Request for AdmissionsRFA No. 1RFA No. 2RFA No. 3RFA No. 4RFA No. 5RFA No. 6RFA No. 7RFA No. 8RFA No. 9RFA No. 10RFA No. 11RFA No. 12RFA No. 13RFA No. 14RFA No. 15RFA No. 16RFA No. 17RFA No. 18RFA No. 19RFA No. 20RFA No. 21RFA No. 22RFA No. 23RFA No. 24RFA No. 25InterrogatoriesROG No. 1ROG No. 2ROG No. 3ROG No. 4ROG No. 5ROG No. 6ROG No. 7ROG No. 8ROG No. 9ROG No. 10ROG No. 11ROG No. 12ROG No. 13ROG No. 14ROG No. 15ROG No. 16ROG No. 17ROG No. 18ROG No. 19ROG No. 20ROG No. 21ROG No. 22ROG No. 23ROG No. 24ROG No. 25 Δ