| (a) Forms of written discovery. Unless otherwise ordered
by the judge, parties may use the forms of written discovery provided
by the TRCP, with the following modifications:
(1) Requests for production. Each party may serve no
more than 25 written requests for production. Each discrete subpart
of a request for production is considered a separate request for production.
(2) Interrogatories. Each party may serve no more than
25 written interrogatories, excluding interrogatories asking a party
only to identify or authenticate specific documents. Each discrete
subpart of an interrogatory is considered a separate interrogatory.
(3) Requests for admissions. Each party may serve no
more than 25 requests for admissions. Requests for admissions may
be used only to address jurisdictional facts or the genuineness of
any documents served with the request.
(b) Written discovery requests shall be served at least
30 days before the end of the discovery period.
(c) Response. Unless otherwise ordered by the judge
or agreed by the parties, responses to written discovery requests
shall be made within 30 days after receipt.
(1) Responses and documents produced in discovery shall
be served upon the requesting party, and notice of service shall be
given to all parties.
(2) A party producing documents in response to a discovery
request must retain the original documents or exact duplicates of
the original documents.
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