|(a) Permissible forms of discovery by parties are:
(1) oral depositions of a party or a nonparty;
(2) written interrogatories to a party;
(3) requests to a party for admission of facts or the
genuineness or identity of documents or things;
(4) requests to a party for production, examination,
and copying of documents or other tangible materials;
(5) requests to a party for entry upon and examination
of real or personal property, or both; and
(6) requests to a party for disclosures pursuant to
Texas Rule of Civil Procedure 194.
(b) The scope of discovery shall be the same as provided
by the Texas Rules of Civil Procedure and shall be subject to the
constraints provided therein for privileges, objections, protective
orders, and duty to supplement as well as the constraints provided
in the APA.