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1 Information or instructions: Combined discovery requests, admissions, production of documents and interrogatories 1. The practitioner may desire to combine Request for Admissions, Interrogatories and Request for Production of Documents into one broad overall request. 2. The practitioner may also desire to have a standard set of Admissions, Interrogatories and Production requests for all litigation cases. 3. Thereafter, the practitioner may add more specific and detailed Interrogatories, Admissions and Production requests, as warranted by the case. 4. The following discovery requests are extremely broad in their nature and since the discovery requests were drafted with a broad basis in mind, the practitioner should review them to determine whether or not they should be made more specific.

2 5. Judges have wide discretion regarding whether or not a request is acceptable or objectionable. Accordingly, the practitioner should review the request before using it. 6. The discovery requests contain broad definitions and instructions and standard questions that may apply to many different cases. 7. The case of Overall d/b/a Painting Professionals v Southwestern Bell Yellow Pages No C CV (Houston) decided 1/6/94, held that when interrogatories and production of documents are combined in one request, the party must make the response within 31 days instead of 30 days. Form: Party's request for admissions, production of documents and interrogatories CAUSE NUMBER _____ [Name], PLAINTIFF IN THE [Type of Court] COURT vs.

3 [Court number] [Name], DEFENDANT OF [NAME], COUNTY, TEXAS [PLAINTIFF'S or DEFENDANT'S] REQUEST FOR ADMISSIONS, PRODUCTION OF DOCUMENTS AND INTERROGATORIES To: [Name of plaintiff or defendant] by and through [its or their or his or her] attorney of record, [Name and Address]: For Preview Only - Please Do Not copy Please be advised that [Name of plaintiff or defendant], "Movant", makes the following discovery requests upon you pursuant to Texas Rules of Civil Procedure Numbers 196,197 and 198. 1. REQUESTS FOR ADMISSIONS 1. You are required to admit or deny the truth of each of the numbered requests set forth in the Requests for Admissions attached to this Request and serve your answers regarding the requests to the undersigned attorney's office within thirty-one (31) days from the date the above identified party's attorney receives these pleadings.

4 2. You may not give lack of information or knowledge as a reason for failure to admit or deny unless you state that you have made reasonable inquiry and that the information known or easily obtainable by you is insufficient to enable you to admit or deny. 3. If you cannot answer a Request for Admission, you must state the reason why you are unable to admit or deny that Request for Admission. 4. If you do not admit the truth of the facts stated in the Request for Admissions, you must specifically set forth the reasons in detail why the request(s) cannot be truthfully admitted. 5. Each matter for which an admission is requested shall be admitted unless your sworn response is served upon the undersigned attorney's office during the specified thirty-one (31) day time period.

5 6. Any answer which does not comply with the above cited Texas Rules of Civil Procedure will be admitted against you or in the alternative a Motion for Sanctions may be filed requesting reimbursement for attorney fees and other sanctions for your failure to answer completely any request of law or fact contained in this Request. 7. If you deny a request and Movant thereafter proves the truth of that matter, you may be ordered to pay the costs of proof, including attorney fees. For Preview Only - Please Do Not copy 8. The attorney of record or the party upon whom these requests are directed should sign his or her Name to the answers and return the Requests for Admissions and Answers to the following Address: [Address].

6 9. A true copy of these discovery requests is being served upon you as the attorney of record for [Name] in accordance with the provisions of Rule 21a. 2. INTERROGATORIES AND REQUEST FOR PRODUCTION 1. Per TRCP you are required to answer fully, factually and in full detail each of the Interrogatories and Request for Production of Documents set forth attached to this Request. 2. You should make a full written response, sign your Name, swear to it and deliver it to the undersigned attorney's office within thirty-one (31) days from the date the above identified party's attorney received these pleadings. 3. ADMISSIONS, PRODUCTION OF DOCUMENTS AND INTERROGATORIES 1.

7 A list of instructions and definitions applicable to these discovery pleadings is attached to this Request as Exhibit "A". 2. The Requests for Admissions, Production of Documents and Interrogatories which you are requested to produce and answer to the undersigned law offices are listed in Exhibit "B" to this Request. 3. Your answers to the Requests for Admissions, Production of Documents and Interrogatories should be answered in the space immediately following the request or interrogatory. If additional space is required, Please continue the answer on a separate sheet of paper. 4. Your answers should be signed by the party to whom they are directed.

8 If the party is a public or private corporation, partnership or association, then the answer of the public or private For Preview Only - Please Do Not copy corporation, partnership or association or trust should be signed by an officer or agent of the same and reflect his or her capacity in that organization. 5. You and your attorney are under a duty to supplement your answers to these discovery pleadings by amending your answers and serving a copy of the amended answers on the undersigned counsel at the undersigned's Address not less than fourteen (14) days prior to the commencement of a summary judgment hearing or trial of this matter.

9 A. If you obtain information that may change or modify your answers or production, or if the same was incorrect, modified or changed due to supplemental information received by you, your attorney or other parties under your control must supplement the answers as specified above. b. If you receive or know of additional documents which are included in the Request for Production of Documents but were not produced to the undersigned attorney, you are under a duty to produce those other discovery documents to the undersigned attorney within the above stated fourteen (14) day time deadline. Respectfully Submitted, _____ [Law Firm Name] By _____ _____ [Attorney s Name] Attorney for [Plaintiff, Defendant or Movant] [Attorney s Address] [Telephone Number] [Facsimile Number] [Bar Card Number] CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing pleading or document has been served upon all attorneys of record and any parties who are not represented by an attorney on _____.

10 For Preview Only - Please Do Not copy Attorney for: [Other attorney s client s name] Attorney s name: [Other attorney s name] Attorney s address [Other attorney s address] Type of Service: ___ Mail, Certified Return Receipt Request No. _____. ___ Mail, First Class. ___ Hand delivery by [name of delivery service]: _____. ___ Facsimile transmission to _____ [fax number] before 5 _____ [Attorney s signature] EXHIBIT A LIST OF INSTRUCTIONS AND DEFINITIONS FOR REQUEST FOR ADMISSIONS, PRODUCTION AND INTERROGATORIES As used in this list, the words defined below shall be deemed to have the following meanings unless indicated otherwise in an individual request or interrogatory: Discovery Request: The term "discovery request" includes, but is not limited to, an Interrogatory, Request for Admissions and Requests for Production of Documents.