Pursuant to Rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose the information or material described in Rule 194.2 as set forth below. Please also ensure that copies of documents and other tangible items are served with the response as set forth in Rule 194.4.
Please disclose:
(a.) The correct names of the parties to the lawsuit.
(b.) The name, address (work and home) and telephone number (work and home) of any potential parties.
(c.) The legal theories and, in general, the factual basis of the responding parties claims or defenses (all evidence that may be offered at trial is not marshalled hereby).
(d.) The amount and any method of calculating economic damages.
(e.) The name, address (work and home), and telephone number (work and home) of person(s) having knowledge of relevant facts, and a brief statement of each identified person’s connection with the case. Please include any consulting experts who have first-hand knowledge of the facts of the case or have knowledge of the facts about the case that were not obtained in preparation for trial or in anticipation of litigation and all family members who are aware of the facts about the case.
(f.) Information about testifying experts as required by Rule 194.2(±). A complete answer will include a list of all witness fees paid by you to each expert within the last five (5) years. Please answer to the full extent authorized by the rule while including the following information.
For any retained testifying experts:
The expert’s name, address and telephone
The subject matter on which the expert will
The general substance of the expert’s mental impressions and opinions and a brief summary of the basis for
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
The expert’s current resume and bibliography. The resume should include a list of all other cases in which the expert has testified as an expert at trial or by deposition within the last four (4)
For nonretained testifying experts:
The expert’s name, address and telephone
The subject matter on which the expert will
Either the general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or documents reflecting such
For consulting experts whose work was reviewed by a testifying expert
The expert’s name, address and telephone
The subject matter on which the expert will
The general substance of the expert’s mental impressions and opinions and a brief summary of the basis for
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
The expert’s current resume and bibliography. The resume should include a list of all other cases in which the expert has testified as an expert at trial or by deposition within the last four (4)
(g.) Any discoverable indemnity and insuring agreements; (h.) Any discoverable settlement agreements;
(i.) Any discoverable witness statements by disclosing a list of the names of all witnesses who have given written statements or made oral statements that were recorded about the facts of the case to you, your agents, employees, representatives, insurance company’s representatives, and attorneys. The only witness statement you are permitted to withhold is a witness statement made by Defendants to Defendants’ attorney, which is privileged under Texas Rule of Evidence 503. Attach to your response all the witness statements listed in your response to this request.
G.) 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 that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills.
(k.) 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 by virtue of an authorization furnished by the requesting party; and
(1.) The name, address (home and work), and telephone number (home and work) of any person who may be designated as a responsible third party.