Discovery Request Formatter

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Google Sheets ID(Required)

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
SOUTHERN DISTRICT OF TEXAS

Court Number and Title(Required)

County(Required)

About Our Client

Who is our client?(Required)

This should be the name of the party who is propounding the discovery.

What is our position in this case?(Required)

Plaintiff
Defendant

The opposing position is the:(Required)

Plaintiff
Defendant

About the Request

Caption of the Request

Which 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 Information

Opposing Counsel Block 1(Required)

Opposing Counsel Block 2

Opposing Counsel Block 3

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Today's Date

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Today's Date Written Formally

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Alternative Date

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Alternative Date

Definitions

Modify 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.

Instructions

Modify Instructions Below

Unless 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 Production

N1 Starting Number(Required)

RFP Number

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N2(Required)

RFP Number

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N3(Required)

RFP Number

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N4(Required)

RFP Number

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N5(Required)

RFP Number

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N6(Required)

RFP Number

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N7(Required)

RFP Number

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N8(Required)

RFP Number

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N9(Required)

RFP Number

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N10(Required)

RFP Number

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N11(Required)

RFP Number

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N12(Required)

RFP Number

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N13(Required)

RFP Number

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N14(Required)

RFP Number

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N15(Required)

RFP Number

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N16(Required)

RFP Number

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N17(Required)

RFP Number

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N18(Required)

RFP Number

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N19(Required)

RFP Number

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N20(Required)

RFP Number

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N21(Required)

RFP Number

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N22(Required)

RFP Number

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N23(Required)

RFP Number

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N24(Required)

RFP Number

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N25(Required)

RFP Number

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N26(Required)

RFP Number

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N27(Required)

RFP Number

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N28(Required)

RFP Number

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N29(Required)

RFP Number

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N30(Required)

RFP Number

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N31(Required)

RFP Number

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N32(Required)

RFP Number

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N33(Required)

RFP Number

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N34(Required)

RFP Number

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N35(Required)

RFP Number

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N36(Required)

RFP Number

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N37(Required)

RFP Number

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N38(Required)

RFP Number

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N39(Required)

RFP Number

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N40(Required)

RFP Number

RFP No. 1

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RFP No. 40

Request for Admissions

N1 Starting Number(Required)

RFA

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N2(Required)

RFA

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N3(Required)

RFA

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N4(Required)

RFA

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N5(Required)

RFA

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N6(Required)

RFA

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N7(Required)

RFA

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N8(Required)

RFA

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N9(Required)

RFA

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N10(Required)

RFA

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N11(Required)

RFA

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N12(Required)

RFA

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N13(Required)

RFA

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N14(Required)

RFA

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N15(Required)

RFA

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N16(Required)

RFA

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N17(Required)

RFA

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N18(Required)

RFA

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N19(Required)

RFA

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N20(Required)

RFA

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N21(Required)

RFA

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N22(Required)

RFA

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N23(Required)

RFA

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N24(Required)

RFA

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N25(Required)

RFA

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N26(Required)

RFA

RFA No. 1

RFA No. 2

RFA No. 3

RFA No. 4

RFA No. 5

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Interrogatories

N1 Starting Number(Required)

ROG No.

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N2(Required)

ROG No.

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N3(Required)

ROG No.

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N4(Required)

ROG No.

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N5(Required)

ROG No.

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N6(Required)

ROG No.

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N7(Required)

ROG No.

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N8(Required)

ROG No.

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N9(Required)

ROG No.

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N10(Required)

ROG No.

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N11(Required)

ROG No.

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N12(Required)

ROG No.

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N13(Required)

ROG No.

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N14(Required)

ROG No.

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N15(Required)

ROG No.

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N16(Required)

ROG No.

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N17(Required)

ROG No.

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N18(Required)

ROG No.

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N19(Required)

ROG No.

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N20(Required)

ROG No.

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N21(Required)

ROG No.

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N22(Required)

ROG No.

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N23(Required)

ROG No.

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N24(Required)

ROG No.

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N25(Required)

ROG No.

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N26(Required)

ROG No.

ROG No. 1

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