Texas Discovery: A Guide to Taking and Resisting Discovery Under the Texas Rules of Civil Procedure

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Discovery is the largest cost in most civil actions—as much as ninety percent in complex cases! The key is properly drafting, and responding to, written discovery.

Discovery is the largest cost in most civil actions—as much as ninety percent in complex cases! It also can be the most frustrating part of trial. The key is properly drafting, and responding to, written discovery. This book will greatly assist Texas practitioners in effectively and properly drafting, responding, and resisting discovery under the Texas discovery rules.

Additional Information
SKU TXDIS19
Division Name Texas Lawyer
Volumes 0
Product Types Books
Brand Texas Lawyer
Publication Date August 28, 2018
Jurisdiction Texas
ISBN 978-1-62881-502-3
Page Count 984
Author Robert K. Wise, Kennon Wooten
Edition 2019
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Kennon Wooten

Kennon. L. Wooten is a partner at Scott Douglass & McConnico LLP in Austin, Texas. Before joining the firm, she clerked for former Chief Justice Wallace B. Jefferson of the Supreme Court of Texas, worked at Baker Botts L.L.P. (in the trial, pharmaceutical, and appellate practice groups), and served as the Rules Attorney for the Supreme Court of Texas. In her current practice, she represents a wide range of clients on both sides of the docket. Her practice areas include complex commercial litigation, personal injury, products liability, professional malpractice, and general civil litigation and appeals.

Ms. Wooten’s experience as the Rules Attorney gave her a specialized understanding of local and statewide rules in Texas.As the Rules Attorney, she responded to public inquiries regarding rules, assisted the Supreme Court of Texas with promulgating and amending rules, and worked with committees and task forces to analyze and address issues confronting Texas litigants. She continues to focus on rule-related matters in private practice. She is a member of the American Law Institute, the Supreme Court Advisory Committee, and the State Bar of Texas Court Rules Committee (which she chaired for two years), and she previously served on the Supreme Court of Texas Task Force for Rules in Expedited Actions and the Texas Commission to Expand Civil Legal Services.

Ms. Wooten is actively involved in the bar. She is a frequent CLE speaker and received a volunteer award for her contributions to the State Bar’s CLE efforts in 2017. She served as the President of the Austin Young Lawyers Association in 2012-2013. Currently, she serves on the Executive Committee for the Austin Bar Association and on the Editorial Board for The Advocate and the Board of Directors for the Texas Legal Services Center. She is also the Editor-in-Chief for Austin Lawyer.

In 2011, Ms. Wooten received a Special Commendation of the Supreme Court of Texas and State Bar of Texas for her work as the Rules Attorney. In 2018, she received the Litigation/Appellate Attorney Award from the Travis County Women Lawyers’ Association. She was named as a Texas Rising Star in 2008, 2009, and 2013-2017 (Thomson Reuters Business).

Robert K. Wise

Robert K. Wise is a founding member of Lillard Wise Szygenda PLLC. Since completing his clerkship for the Hon. Paul C. Weick of the U.S. Court of Appeals for the Sixth Circuit, he has practiced law in Dallas, Texas, for more than thirty years. A former equity partner in the international law firm of Hunton & Williams LLP, Mr. Wise left Hunton to form LWS, a boutique litigation firm focused on providing its clients with elite representation at reasonable rates. Mr. Wise’s practice centers on trial and appellate litigation. He has tried more than thirty lawsuits and arbitrations and has argued more than forty appeals in both Texas and federal appellate courts, including the Texas and Oklahoma Supreme Courts. His practice areas include: complex commercial litigation involving contract, misrepresentation, and breach of fiduciary duty claims, primarily in the energy, construction, banking, and real estate industries; construction-defects litigation; accounting-malpractice defense; complex personal-injury litigation, and complex insurance-coverage claims.

Mr. Wise is an accomplished writer, having taught legal writing at the Dedman School of Law of Southern Methodist University and having published one other book, A Practitioner’s Guide To Drafting And Responding To Written Discovery Under The Texas Rules Of Civil Procedure (published in 2014 by Texas Lawyer Books, an ALM publication) and many law review articles on different topics. He repeatedly has been recognized as a “Super Lawyer” by the publishers of Texas Super Lawyers (Thompson Reuters Business), was named “Litigator of the Week” in the March 25, 2012 edition of the Texas Lawyer for beating the Federal Trade Commission in FTC v. Financial Freedom Processing, Inc., et al., No. 3:10-CV-2446-N (N.D. Tex. Mar. 12, 2012), aff’d, No. 12-10520, 2013 U.S. App. LEXIS 16766 (5th Cir. Aug. 12, 2013), and “Appellate Lawyer of the Week” in the November 24, 2014 edition of the Texas Lawyer for preserving a summary-judgment in a multi-million dollar fire case, and received the Texas Bar Foundation’s 2015 “Outstanding Law Review Article Award” for his 2014 St. Mary Law Journal article, A Guide to Properly Using and Responding to Requests for Admission under the Texas Discovery Rules.

Table of Contents
1 Harris County Courts at Law — Civil
1-1 Court Directory
1-2 Local Rules
1-3:1 Harris County Civil Court at Law No. 2, Hon. Jim F. Kovach
1-3:2 Harris County Civil Court at Law No. 3, Hon. LaShawn A. Williams
1-3:3 Harris County Civil Court at Law No. 4, Hon. William “Bill” McLeod
2 Harris County Courts at Law — Criminal
2-1 Court Directory
2-2 Local Rules
2-3:1 Harris County Criminal Court at Law No. 16, Hon. Darrell Jordan
3 Harris County District Court — Civil
3-1 Court Directory
3-2 Local Rules
3-3:1 Harris County 11th Civil District Court, Hon. Kristen Brauchle Hawkins
3-3:2 Harris County 55th Civil District Court, Hon. Latosha Lewis Payne
3-3:3 Harris County 127th Civil District Court, Hon. R. K. Sandill
3-3:4 Harris County 129th Civil District Court, Hon. Michael Gomez
3-3:5 Harris County 133rd Civil District Court, Hon. Jaclanel Moore McFarland
3-3:6 Harris County 151st Civil District Court (Electronic Court), Hon. Mike Engelhart
3-3:7 Harris County 152nd Civil District Court, Hon. Robert K. Schaffer
3-3:8 Harris County 190th Civil District Court, Hon. Beau A. Miller
3-3:9 Harris County 270th Civil District Court, Hon. Dedra Davis
4 Harris County District Courts — Criminal
4-1 Court Directory
4-2 Local Rules
4-3:1 Harris County 208th Criminal District Court, Hon. Greg Glass
4-3:2 Harris County 337th Criminal District Court, Hon. Herb Ritchie
4-3:3 Harris County 351st Criminal District Court, Hon. George Powell
5 Harris County District Court — Family
5-1 Court Directory
5-2 Local Rules
5-3:1 Harris County 245th Judicial District Court, Hon. Tristan H. Longino
5-3:2 Harris County 246th Family District Court, Hon. Angela L. Graves-Harrington
5-3:3 Harris County 257th Family District Court, Hon. Sandra Peake
5-3:4 Harris County 309th Family District Court, Hon. Linda Marie Dunson
5-3:5 Harris County 310th Family District Court, Hon. Sonya L. Heath
5-3:6 Harris County 311th Judicial District Court, Hon. Germaine J. Tanner
5-3:7 Harris County CPS Project Court, Hon. Katrina M. Griffith
6 Harris County District Court — Juvenile
6-1 Court Directory
6-2 Local Rules7 Harris County Probate Courts
7-1 Court Directory
7-2 Local Rules
8 Harris County Justice Courts
8-1 Court Directory
8-2 Local Rules
8-3:1 Harris County Justice Court Precinct 1, Place 2, Hon. David M. Patronella
8-3:2 Harris County Justice Court Precinct 2, Place 1, Hon. Jo Ann Delgado
8-3:3 Harris County Justice Court Precinct 2, Place 2, Hon. George E. Risner
8-3:4 Harris County Justice Court Precinct 3, Place 2, Hon. Joe Stephens
8-3:5 Harris County Justice Court Precinct 5, Place 1, Hon. Russ Ridgway
8-3:6 Harris County Justice Court Precinct 5, Place 2, Hon. Jeffrey S. Williams
8-3:7 Harris County Justice Court Precinct 6, Place 1, Hon. Richard C. Vara
8-3:8 Harris County Justice Court Precinct 6, Place 2, Hon. Angela D. Rodriguez
8-3:9 Harris County Justice Court Precinct 7, Place 2, Hon. Sharon M. Burney
8-3:10 Harris County Justice Court Precinct 8, Place 1, Hon. Holly Williamson
9 Harris County Municipal Courts
9-1 Court Directory
9-2 Local Rules
9-3:1 Houston Municipal Court, Hon. Elaine Jefferson
9-3:2 Houston Municipal Court, Hon. Mimi M. Berkowitz
9-3:3 Houston Municipal Court, Hon. Grant Coleman
9-3:4 Houston Municipal Court, Hon. Sherilyn D. Edwards
9-3:5 Houston Municipal Court, Hon. David O. Fraga
9-3:6 Houston Municipal Court, Hon. Kimberly Maura Gamble
9-3:7 Houston Municipal Court, Hon. Esmeralda Peña Garcia, Associate Presiding Judge
9-3:8 Houston Municipal Court, Hon. Kathy Khanh Han
9-3:9 Houston Municipal Court, Hon. Margaret Muñoz-Harkins
9-3:10 Houston Municipal Court, Hon. Gordon G. Marcum II
9-3:11 Houston Municipal Court, Hon. Elaine Marshall, Presiding Judge
9-3:12 Houston Municipal Court, Hon. Megan McLellan
9-3:13 Houston Municipal Court, Hon. Meg Ahern Oswald
9-3:14 Houston Municipal Court, Hon. Imelda Reyes-Castillo
9-3:15 Houston Municipal Court, Hon. Lawrence A. Rousseau
9-3:16 Houston Municipal Court, Hon. Adam Silverman
9-3:17 Houston Municipal Court, Hon. Cheryl Lee-Collins
9-3:18 Spring Valley Municipal Court, Hon. James R. Smith
9-3:19 Houston Municipal Court, Hon. Francelia Totty
9-3:20 Houston Municipal Court, Hon. Kim Edwards
9-3:21 Bellaire Municipal Court, Hon. Lisa Wesely
9-3:22 Houston Municipal Court, Hon. Mihoa Vo
9-3:23 Houston Municipal Court, Hon. Leigh Faoro Saint-Germain
9-3:24 Hedwig Municipal Court, Hon. Jess W. Mason
9-3:25 Jersey Village Municipal Court, Hon. Jeffrey C. Brashear
10 U.S. District Courts — Southern District of Texas
10-1:1 Court Directory, Houston Division10-1:2 Court Directory, Corpus Christi Division
10-1:3 Court Directory, Galveston Division
10-1:4 Court Directory, Laredo Division
10-1:5 Court Directory, McAllen Division
10-1:6 Court Directory, Victoria Division
10-1:7 Court Directory, Brownsville Division
10-2 Local Rules
10-3:1 U.S. District Court, Southern District of Texas, Hon. Nancy F. Atlas
10-3:2 U.S. District Court, Southern District of Texas, Hon. Keith Ellison
10-3:3 U.S. District Court, Southern District of Texas, Hon. Vanessa D. Gilmore
10-3:4 U.S. District Court, Southern District of Texas, Hon. Melinda Harmon
10-3:5 U.S. District Court, Southern District of Texas, Hon. David Hittner
10-3:6 U.S. District Court, Southern District of Texas, Hon. Kenneth M. Hoyt
10-3:7 U.S. District Court, Southern District of Texas, Hon. Lynn N. Hughes
10-3:8 U.S. District Court, Southern District of Texas, Hon. Sim Lake
10-3:9 U.S. District Court, Southern District of Texas, Hon. Marina Garcia Marmolejo
10-3:10 U.S. District Court, Southern District of Texas, Hon. Gray H. Miller
10-3:11 U.S. District Court, Southern District of Texas, Hon. Lee H. Rosenthal
10-3:12 U.S. District Court, Southern District of Texas, Hon. Ewing Werlein, Jr.
10-3:13 U.S. District Court, Southern District of Texas, Hon. Diana Saldaña
10-3:14 U.S. District Court, Southern District of Texas, Hon. Nelva Gonzales Ramos
10-3:15 U.S. District Court, Southern District of Texas, Hon. Alfred H. Bennett
11 U.S. District Courts — Eastern District of Texas
11-1 Court Directory
11-2 Local Rules
11-3:1 U.S. District Court, Eastern District of Texas, Hon.
11-3:2 U.S. District Court, Eastern District of Texas, Hon.
11-3:3 U.S. District Court, Eastern District of Texas, Hon.
11-3:4 U.S. District Court, Eastern District of Texas, Hon.
Ron Clark
Marcia A. Crone
Thad Heartfield
Richard A. Schell
12 U.S. District Courts — Bankruptcy
12-1 Court Directory
12-2 Local Rules
12-3:1 U.S. Bankruptcy Court, Southern District of Texas, Hon. Jeff Bohm
12-3:2 U.S. Bankruptcy Court, Southern District of Texas, Hon. Marvin Isgur
12-3:3 U.S. Bankruptcy Court, Southern District of Texas, Hon. Jeffrey P. Norman
13 U.S. District Courts — Southern District of Texas Magistrate Judges
13-1 Court Directory
13-2:1 United States Magistrate Judge, Hon. Nancy K. Johnson
13-2:2 United States Magistrate Judge, Hon. Stephen Wm. Smith
13-2:3 United States Magistrate Judge, Hon. Frances H. Stacy
13-2:4 United States Magistrate Judge, Hon. Juan F. Alanis
14 Brazoria County
14-1 Court Directory
14-2 Local Rules
14-3:1 Brazoria County Court at Law No. 1, Hon. Jerri Lee Mills14-3:2
14-3:3
14-3:4
14-3:5
14-3:6
Brazoria
Brazoria
Brazoria
Brazoria
Brazoria
County
County
County
County
County
Court at Law No. 2, Hon. Marc W. Holder
Court at Law No. 3, Hon. Jeremy E. Warren
149th District Court, Hon. Terri Tipton Holder
239th District Court, Hon. Patrick E. “Pat” Sebesta
300th District Court, Hon. K. Randall Hufstetler
15 Chambers County
15-1 Court Directory
16 Fort Bend County
16-1 Court Directory
16-2 Local Rules
16-3:1 Fort Bend County 328th District Court, Hon. Ronald R. Pope
16-3:2 Fort Bend County 387th Civil District Court, Hon. Brenda Mullinix
17 Galveston County
17-1 Court Directory
17-2 Local Rules
17-3:1 Galveston County 10th District Court, Hon. Kerry L. Neves
17-3:2 Galveston County 56th Judicial District Court, Hon. Lonnie Cox
17-3:3 Galveston County Probate Court, Hon. Kimberly Sullivan
18 Jefferson County
18-1 Court Directory
18-2 Local Rules
18-3:1 Jefferson County 317th Civil District Court, Hon. Larry Thorne
18-3:2 Jefferson County Criminal District Court, Hon. John B. Stevens, Jr.
19 Liberty County
19-1 Court Directory
19-2 Local Rules
20 Montgomery County
20-1 Court Directory
20-2 Local Rules
20-3:1 Montgomery County
20-3:2 Montgomery County
20-3:3 Montgomery County
20-3:4 Montgomery County
Index
Court No. 3, Hon. Patrice McDonald
221st District Court, Hon. Lisa Michalk
284th District Court, Hon. Cara C. Wood
359th District Court, Hon. Kathleen A. Hamilton

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