Telephone: 713-255-4422 (1) be taken before an officer with authority to administer oaths; (2) be made by: (A) the person who provided the service; or (B) the person in charge of records showing the service provided and charge made; and (3) include an itemized statement of the service and charge. The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. Rule 193.3(d) is a new provision that allows a party to assert a claim of privilege to material or information produced inadvertently without intending to waive the privilege. 0000001720 00000 n Each side may have no more than 50 hours in oral depositions to examine and cross-examine parties on the opposing side, experts designated by those parties, and persons who are subject to those parties' control. Amended by order of Dec. 23, 2020, eff. 0000005461 00000 n 167, Sec. (a) Except as provided by Subsection (b), an unsworn declaration may be used in lieu of a written sworn declaration, verification, certification, oath, or affidavit required by statute or required by a rule, order, or requirement adopted as provided by law. In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. The records are the original or an exact duplicate of the original. As with requests for disclosure, interrogatories may be used to ascertain basic legal and factual claims and defenses but may not be used to force a party to marshal evidence. E-mail: info@silblawfirm.com, Austin Office Interrogatories are written questions which focus on any information relevant to the case. (c) The form of an affidavit provided by this section is not exclusive and an affidavit that substantially complies with Section 18.001 is sufficient. 1, eff. 0000049836 00000 n Acts 1985, 69th Leg., ch. The information contained in the records was transmitted to me in the regular course of business by __________(PERSON WHO PROVIDED THE SERVICE)__________ or an employee or representative of __________(PERSON WHO PROVIDED THE SERVICE)__________ who had personal knowledge of the information. hVmo6+0DHE '[wKI5dH Texas Civil Practices and Remedies Code. %3.3 !QHn (( %%EOF AFFIDAVIT CONCERNING COST AND NECESSITY OF SERVICES. But a party may object to a request for "all documents relevant to the lawsuit" as overly broad and not in compliance with the rule requiring specific requests for documents and refuse to comply with it entirely. Sept. 1, 1987. The rules listed below are the most current version approved by the Supreme Court of Texas. (b) An affidavit concerning cost and necessity of services by the person who is in charge of records showing the service provided and the charge made is sufficient if it follows the following form: Before me, the undersigned authority, personally appeared ______(NAME OF AFFIANT)______, who, being by me duly sworn, deposed as follows: I am the person in charge of records of __________(PERSON WHO PROVIDED THE SERVICE)__________. (b-2) If a medical bill or other itemized statement attached to an affidavit under Subsection (b-1) reflects a charge that is not recoverable, the reference to that charge is not admissible. The ten-day period allowed for objection to authenticity (which period may be altered by the court in appropriate circumstances) does not run from the production of the material or information but from the party's actual awareness that the document will be used. startxref (a) Time for response. Exact wording of existing Rule: Rule 197. 0000005069 00000 n If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. HSj1W9Lz`6+qN6rIhaAURp]$P"p%^A`R 3O(eCY4NP1AXauzAvI#7\\\;AAcSnv>R'k2"u|R=tQayL}K"%I'DXm`,1V:GtkA q#c&_hqI+q`m{7&(,k]q@mgZCpvv)K=L\0*o U=RnOJ[z2C)Uzi_o"yd9L~E ^b View Local Rules, Forms & Standing Orders, Judicial Committee on Information Technology, Task Force on Judicial Emergency Preparedness, Texas Commission to Expand Civil Legal Services, Timothy Cole Exoneration Review Commission, Guardianship Abuse, Fraud and Exploitation Deterrence Program (GAFEDP), Pretrial Risk Assessment Information System for Texas, Statewide Rules Governing Electronic Filing in Criminal Cases, Judicial Branch Certification Commission Rules, Texas Disciplinary Rules of Professional Conduct, Judicial BypassRules under Ch. STATE LAND RECORDS. Interrogatories To Parties (Aug1998). All local rules, forms, and standing orders are uploaded by court clerks or court staff and are currently viewable by the public. _sP2&E) \RM*bd#R\RWp G {u-,gVP#'{W@=Q6o""u7l!R;_WC[eTb0aa,KQbZS#vuJ#n,Gz^rDGZg^W~nKp4Kd8 If objection is made, the party attempting to use the document should be given a reasonable opportunity to establish its authenticity. what does level 2 of rule 190 mean in the Texas Rules of civil procedure Answered in 2 minutes by: Lawyer: Daniel Solutions Here is the rule for level 2 pasted below: (1) Discovery period. (c) Option to produce records. E-mail: info@silblawfirm.com, Corpus Christi Office 752 (Sept. 1998), and Rule 215 are modified to reflect public comments and are adopted as attached. a7 D~H} To avoid complications at trial, a party may identify prior to trial the documents intended to be offered, thereby triggering the obligation to object to authenticity. Sept. 1, 1987. Sec. 17330 Preston Rd., Ste. Houston Office (d) Verification required; exceptions. This Order A party may serve on another party - no later than 30 days before the end of the discovery period - written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195. If it is confirmed to be necessary, the court can rule that it be required. (b) Content of response. UNSWORN DECLARATION. (a) Time for Response. 0000001820 00000 n Dernire modification : 05/07/2018. Further, amended Rule 190.2 increases the aggregate amount of oral deposition time permitted for expedited actions from 6 hours to 20 hours. 511 and overturns Granada Corp. v.First Court of Appeals, 844 S.W.2d 223 (Tex. Amended by order of Nov. 9, 1998, eff. This rule imposes a duty upon parties to make a complete response to written discovery based upon all information reasonably available, subject to objections and privileges. 1. 165, Sec. Under a 1949 amendment to 28 U.S.C., 2072, the Chief Justice of An itemized statement of the service and the charge for the service is attached to this affidavit and is a part of this affidavit. (f) The counteraffidavit must give reasonable notice of the basis on which the party serving it intends at trial to controvert the claim reflected by the initial affidavit and must be taken before a person authorized to administer oaths. 0000000736 00000 n STATE BAR OF TEXAS COMMITTEE ON COURT RULES REQUEST FOR NEW RULE OR CHANGE OF EXISTING RULE TEXAS RULES OF CIVIL PROCEDURE I. In individual instances, courts may order, or parties may agree, to use discovery methods other than those prescribed in these rules if appropriate. On __________(DATE)__________, I provided a service to __________(NAME OF PERSON WHO RECEIVED SERVICE)__________. Hj@z h:iM S(Y("KHjp_#yMB98,=8*oL?4MZ =g8~S'b2Go96K c0x9B)$SoP~k +4m5h14f9iNfm_ e u9DA%}4T>:{,)7lhahMwP?h]lrOvpL?oz88(4P&u^E;uC~'pmC]z5NqG`. (b) A business record described by Subsection (a) is admissible if the party offering the record has obtained the record from a source other than law enforcement personnel. If the answer to an interrogatory may be derived or ascertained from public records, from the responding party's business records, or from a compilation, abstract or summary of the responding party's business records, and the burden of deriving or ascertaining the answer is substantially the same for the requesting party as for the responding party, the responding party may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract or summary of the records. Disclaimer: The information presented on this site is for . (d) The party offering the affidavit in evidence or the party's attorney must serve a copy of the affidavit on each other party to the case by the earlier of: (1) 90 days after the date the defendant files an answer; (2) the date the offering party must designate any expert witness under a court order; or. 13.09, eff. /ColorSpace /DeviceGray In the first sentence of Rule 193.3(b), the word "to" is deleted. The responding party must serve a written response on Interrogatories about specific legal or factual assertions such as, whether a party claims a breach of implied warranty, or when a party contends that limitations began to run - are proper, but interrogatories that ask a party to state all legal and factual assertions are improper. P. 197.1 ("A party may serve on another party . (b) The method of service of citation provided by this section is in addition to any other method authorized by statute or the Texas Rules of Civil Procedure for service on the secretary of state. The records from which the answer may be derived or ascertained must be specified in sufficient detail to permit the requesting party to locate and identify them as readily as can the responding party. 98-9136, dated August 4, 1998, 61 Tex. Back to Main Page / Back to List of Rules, Rule 197. 505 0 obj <>stream Request for Production and Inspection To learn how to contact the presiding judge of the administrative judicial region in which the court is located,please visit https://www.txcourts.gov/organizations/policy-funding/administrative-judicial-regions/. To avoid complications at trial, a party may identify prior to trial the documents intended to be offered, thereby triggering the obligation to assert any overlooked privilege under this rule. (b) In this section, "communication" means: (3) a gesture that conveys a sense of compassion or commiseration emanating from humane impulses. Acts 1985, 69th Leg., ch. U;Ra[Hlrw5,;pUgPZL)p9kx>]L muYjQ[mhYfI=J"A%.D#ELOB5~in2! nvf>&,8hi_:0wl|NgVM= !gUn5u&6@lpTdVD?!f>Pc!&*p'[WX0sj]m2I83i. An interrogatory may inquire whether a party makes a specific legal or factual contention and may ask the responding party to state the legal theories and to describe in general the factual bases for the party's claims or defenses, but interrogatories may not be used to require the responding party to marshal all of its available proof or the proof the party intends to offer at trial. 0000003067 00000 n 1, eff. Beaumont, TX 77706 Except as provided by the Texas Rules of Evidence, the affidavit is not required to be filed with the clerk of the court before the trial commences. 18.002. (c) Option to produce records. See Tex. ,B?t,'*~ VJ{Awe0W7faNH >dO js An example is a statement that privileged material or information has been withheld, which may be separate from a response to the discovery request but is nevertheless part of the response. s"*JISBHQDa p" S"! Back to Main Page / Back to List of Rules. Attached to this affidavit are records that provide an itemized statement of the service and the charge for the service that __________(PERSON WHO PROVIDED THE SERVICE)__________ provided to __________ (PERSON WHO RECEIVED THE SERVICE)__________ on __________(DATE)__________. 7. endstream endobj 332 0 obj <>stream 2. Hereinafter, individual Texas Rules of Civil Procedure and Federal Rules of Civil Procedure will be referred to respectively as "Texas Rule __" and "Federal Rule ___." 6TEX. Houston, TX 77018 amendments to Rules 47, 169, 190, 192, 193, 194, and 195 of the Texas Rules of Civil Procedure to comply with Act of May 27, 2019, 86th Leg., R.S., ch. %PDF-1.4 % 8000 IH-10 West, Suite 600 An objection to authenticity must be made in good faith. 0000058841 00000 n Back to Main Page / Back to List of Rules, Rule 191.3 Signing of Disclosures, Discovery Requests, Notices, Responses, and Objections (Aug. 1998). A trial court may also order this procedure. 560 (S.B. Jan. 1, 1999. Sept. 1, 1985. For any questions about the rules, please call (512) 463-4097. 108 Wild Basin Rd. A matter admitted under this rule is conclusively established as to the party making the admission unless the court permits the party to withdraw or amend the admission. "Side" refers to all the litigants with generally common interests in the litigation. Use of the answers to such interrogatories is limited, just as the use of similar disclosures under Rule 194.6 is. (T*(B{TZhp{3;3#aur:% 1b#Z-@M_S *:hY^xP@30z@=AmR=7G9N* (9lBBBLa!4lda1L6sZ2N4HzV}!6v-CK_|o@*>746jDe 0000004170 00000 n U1}9yp 1, eff. 2, eff. /Filter /JBIG2Decode 959, Sec. Court Deadlines contains reference information and calculators for common deadlines in the federal rules of civil procedure. (c) In this section, "traffic control device" includes a control light, stop sign, and one-way street sign. If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. The service provided was necessary and the amount charged for the service was reasonable at the time and place that the service was provided. Co. v. Valdez, 863 S.W.2d 458 (Tex. Jan. 1, 2021. 1379), Sec. 1. Telephone: 214-307-2840 It dispenses with objections to written discovery requests on the basis that responsive information or materials are protected by a specific privilege from discovery. However, in the interest of full disclosure the responding party must either answer the questions in the interrogatories, or if denying all or part of the request, state appropriate objections and/or applicable privileges. Instead, the rule requires parties to state that information or materials have been withheld and to identify the privilege upon which the party relies. The statement should not be made prophylactically, but only when specific information and materials have been withheld. Rule 197.2. endstream endobj 334 0 obj <>stream Free court deadline calculators and resources for lawyers, legal professionals, and others. T+eh*NyJ]IA:6;7;vug;mVtM)o^A)*saDR`Y4rsi4-CRlj~ '! (e) Sanctions. fCE@pl!j 779 (H.B. Jan. 1, 1999. HN@Htqtj0J|}g2sRR 7 HR&c?5~{5ky\g} endstream endobj 327 0 obj <>stream If the certification is false without substantial justification, the court may, upon motion or its own initiative, impose on the person who made the certification, or the party on whose behalf the request, notice, response, or objection was made, or both, an appropriate sanction as for a frivolous pleading or motion under chapter 10 of the Civil Practice and Remedies Code. Sec. While interrogatories might inquire about legal theories and factual bases for a claim or denial of a claim, this part of the discovery process does not require evidence to substantiate or refute a claim. -1!o7! ' %PDF-1.4 Rule 191's requirement that a party's attorney sign all discovery responses and objections applies to interrogatory responses and objections. 1, eff. ?3Z-RRqu&pamS6eWVgzg{L64l:G-@0LzQI` * endstream endobj 320 0 obj <> endobj 321 0 obj <> endobj 322 0 obj <>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 323 0 obj <> endobj 324 0 obj <> endobj 325 0 obj <> endobj 326 0 obj <>stream 0000004303 00000 n Response to Interrogatories (2021) TEXT (a) Time for response. June 18, 2005. Any party can request a hearing in which the court will resolve issues brought up in objections or withholding statements. rule 197. interrogatories to parties rule 198. requests for admissions rule 199. depositions upon oral examination rule 200. depositions upon written questions rule 201. depositions in foreign jurisdictions for use in texas . 1. Part III - Rules of Procedure for the Courts of Appeals ( 352 473) Part IV - Rules of Practice for the Supreme Court ( 474 518) Part V - Rules of Practice in Justice Courts ( 523 510.13) Part VI - Rules Relating to Ancillary Proceedings ( 592 734) Part VII - Rules Relating to Special Proceedings ( 735 813) Users of this site should contact a licensed Texas attorney for a full and complete review of their legal issues. The Code of Criminal Procedure governs criminal proceedings. The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were provided. Requests for Admission must be in writing, and each request has to be listed separately in the document. Bar. 2. (b) Content of response. 5. 0000006404 00000 n Rule 191's requirement that a party's attorney sign all discovery responses and objections applies to interrogatory responses and objections. The records were made at or near the time or reasonably soon after the time that the service was provided. R. CIV. Ms. ", 3. An objection made to the authenticity of only part of a document does not affect the authenticity of the remainder. (3) the date the offering party must designate any expert witness as required by the Texas Rules of Civil Procedure. 2. 17.027. Sec. >> CERTAIN INFORMATION RELATING TO IDENTITY THEFT. 6*:K!#;Z$P"N" DzIb An objection to written discovery does not excuse the responding party from complying with the request to the extent no objection is made. (i) Notwithstanding Subsections (d), (d-1), (d-2), (e), (e-1), (g), and (h), a deadline under this section may be altered by all parties to an action by agreement or with leave of the court. This paper explains how the Texas Supreme Court has derived its authority to promulgate procedural rules like the 1999 discovery rules revisions, the new combined Rules of Evidence and the new Rules of Appellate Procedure and describes the process by which the Court drafts such rules. This rule expressly states the obligation of parties and their attorneys to cooperate in conducting discovery, and to conduct discovery only as permitted by the rules. Added by Acts 2003, 78th Leg., ch. (a) Time for response. THE TEXAS RULES OF CIVIL PROCEDURE _____ ORDERED that: 1. If this is a lawsuit filed after January 1, 2021, Texas Rule of Civil Procedure 194.2 says that, without awaiting a discovery request, a party must provide to the other parties: The correct names of the parties to the lawsuit; The name, address, and telephone number of any potential parties; hb```~Vw!b`0p;$PSA+QmxYdP9M>~w Q8|(S9{;CGn`Y[@\J10%M[0v4040t0(w40u0t HE, B$'_ - 3.04(a), eff. 673, Sec. Before me, the undersigned authority, personally appeared __________, who, being by me duly sworn, deposed as follows: My name is ___________________________________. 679), Sec. Depositions 1989). This paper is a guide to the background, text, and intent of the 1999 revisions to the Texas Rules of Civil Procedure pertaining to discovery. Rule 191's requirement that a party's attorney sign all discovery responses and objections applies to interrogatory responses and objections. Telephone: 409-240-9766 696 (SB 2342), and invited public comment. 191.3 Signing of Disclosures, Discovery Requests, Notices, Responses, and Objections (Aug. 1998). 560 (S.B. Any admission made by a party under this rule may be used solely in the pending action and not in any other proceeding. Added by Acts 1993, 73rd Leg., ch. This rule is thus broader than Tex. Austin, TX 78746 The affidavit is not evidence of and does not support a finding of the causation element of the cause of action that is the basis for the civil action. Interrogatories 0 d texas rules of civil procedure part i - general rules rule 1. objective of rules rule 2. scope of rules Sec. The total amount paid for the services was $_____ and the amount currently unpaid but which __________ has a right to be paid after any adjustments or credits is $_____. 710 Buffalo Street, Ste. The attached records are a part of this affidavit. 1, eff. 200D 340 0 obj <>stream endstream endobj 330 0 obj <>stream SWORN TO AND SUBSCRIBED before me on the __________ day of _____, _____. Below is Rule 197, which details the guidelines and procedures for making and responding to interrogatories: 197.1 Interrogatories. (1) consistent with the rules of civil procedure and these discovery rules and warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law; (2) not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation; and Silberman Law Firm, PLLC Copyright 2016 | DisclaimerPrincipal office located in Houston, TX. Rule 193.4(c) is modified as follows: "Use of material or information withheld under claim of privilege. Request for Motion for Entry Upon Property 5The Texas discovery rules are Texas Rules of Civil Procedure 190-215. Following public comment, the Court made revisions to those rules and also revised Texas Rules of Civil Procedure 99, 196, 197, and 198. This rule governs the presentation of all privileges including work product. If a request, notice, response, or objection is not signed, it must be stricken unless it is signed promptly after the omission is called to the attention of the party making the request, notice, response, or objection. xref September 1, 2003. A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules. The party must amend or supplement the statement if additional privileged information or material is found subsequent to the initial response. Any other rule in the Texas Rules of Civil Procedure shall not govern the justice courts except: (a) to the extent the judge hearing the case determines that a particular rule must be followed to ensure that the proceedings are fair to all parties; or, (b) where otherwise specifically provided by . /Name /ImagePart_0 An objection to written discovery does not excuse the responding party from complying with the request to the extent no objection is made. 0000007074 00000 n 1. COMMUNICATIONS OF SYMPATHY. 2. (3) the date the party offering the counteraffidavit in evidence must designate any expert witness as required by the Texas Rules of Civil Procedure. Answers to interrogatories may be used only against the responding party. The topics are listed below: Initial Disclosures }>k!LJ##v*o'2, 0000005926 00000 n A responding party - not an agent or attorney as otherwise permitted by Rule14- must sign the answers under oath except that: (1)when answers are based on information obtained from other persons, the party may so state, and. 0000003145 00000 n (2) a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. Unless the interest rate of another state or country is alleged and proved, the rate is presumed to be the same as that established by law in this state and interest at that rate may be recovered without allegation or proof. Sept. 1, 1985. In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. Parties cannot by agreement modify a court order. Amended by Acts 1987, 70th Leg., ch. A trial court may also order this procedure. Subject to any objections stated in the response, the responding party must produce the requested documents or tangible things within the person's possession, custody or control at either the time and place requested or the time and place stated in the response, unless otherwise agreed by the parties or ordered by the court, and must provide the 1, eff. A party may serve on another party no later than 30 days before the end of the discovery period - written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195. 197.3 Use. b`Pg8x2^aLc|xaUe10X3\wbP )gVs@AXmw vd The counteraffidavit must be made by a person who is qualified, by knowledge, skill, experience, training, education, or other expertise, to testify in contravention of all or part of any of the matters contained in the initial affidavit. 0000003662 00000 n (a) Except as provided by Subsection (b), a business record is not admissible in a civil action if the business record is provided to law enforcement personnel in connection with an investigation of an alleged violation of Section 32.51, Penal Code (fraudulent use or possession of identifying information). See Loftin v.Martin, 776 S.W.2d 145 (Tex. (2) a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. Answers in amended and supplemental responses must be signed by the party under oath only if the original answers were required to be signed under oath. An objection must be either on the record or in writing and must have a good faith factual and legal basis. An answer to an interrogatory inquiring about matters described in Rule194.2(c) and (d)that has been amended or supplemented is not admissible and may not be used for impeachment. (h) If continuing services are provided after a relevant deadline under this section: (1) a party may supplement an affidavit served by the party under Subsection (d) or (d-1) on or before the 60th day before the date the trial commences; and. <<7F1D1753F15E094A871993BC5086A2C4>]>> 33 of the Family Code, https://www.txcourts.gov/organizations/policy-funding/administrative-judicial-regions/, Uniform Format Manual for Texas Reporters' Records, Texas Records and Information Locator (TRAIL). The responding party must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the court, and must provide the requesting party a reasonable opportunity to inspect them. 4. The following sentence is added to the end of Rule 193.4(b): "A party need not request a ruling on that party's own objection or assertion of privilege to preserve the objection or privilege. 250 0000058592 00000 n 0 Back to Main Page / Back to List of Rules, Rule 193.7. 319 22 (a) Notwithstanding any other law, if any claimant seeks recovery for loss of earnings, loss of earning capacity, loss of contributions of a pecuniary value, or loss of inheritance, evidence to prove the loss must be presented in the form of a net loss after reduction for income tax payments or unpaid tax liability pursuant to any federal income tax law. A party's production of a document in response to written discovery authenticates the document for use against that party in any pretrial proceeding or at trial unless - within ten days or a longer or shorter time ordered by the court, after the producing party has actual notice that the document will be used - the party objects to the authenticity of the document, or any part of it, stating the specific basis for objection. Fax: 210-801-9661 The party seeking to avoid discovery has the burden of proving the objection or privilege. /Type /XObject TRAFFIC CONTROL DEVICE PRESUMED TO BE LAWFUL. SWORN TO AND SUBSCRIBED before me on the __________ day of __________, 19___. A local court's rules may also require it. (1) . (c) Effect of signature on discovery request, notice, response, or objection. Every disclosure, discovery request, notice, response, and Objection must be signed: (1) by an attorney, if the party is represented by an attorney, and must show the attorney's State Bar of Texas identification number, address, telephone number, and fax number, if any; or. 1. Answers to interrogatories may be used only against the responding party. A responding party must sign the answers under oath except that: (1) when answers are based on information obtained from other persons, the party may so state, and. } B.,n6L]66_RRcbH+4\6Z8Z1m 1K*5|XR-No6;\9E8|z@?o+$MG |_)OhsjWn X .s;}-/lo&/kVOThNi4kqs&< O,QHvpT_0M9V Added by Acts 2003, 78th Leg., ch. Interrogatories about specific legal or factual assertions such as, whether a party claims a breach of implied warranty, or when a party contends that limitations began to run - are proper, but interrogatories that ask a party to state all legal and factual assertions are improper. (yvrXJ2TYBFW/1U>YS)YQmKg{1f.uMa7ebi$x!=-6^-N7{BAE!MC@\ 7t!M` pzTx|}j3%Db#7cxbxFhn0EnO;>E"Ff|"WH}Wg kg'fM dmU@~hRT x Texas Rules of Civil Procedure 198 governs requests for admissions. Users of this website should not take any actions or refrain from taking any actions based upon content or information on this website. Sept. 1, 1995. September 1, 2013. 18.033. The service I provided was necessary and the amount that I charged for the service was reasonable at the time and place that the service was provided. (g) The party offering the counteraffidavit in evidence or the party's attorney must file written notice with the clerk of the court when serving the counteraffidavit that the party or attorney served a copy of the counteraffidavit in accordance with this section. H_O0b|hL4K}2>6l'-YXVxi=r Interrogatories about specific legal or factual assertions - such as, whether a party claims a breach of implied warranty, or when a party contends that limitations began to run - are proper, but interrogatories that ask a party to state all legal and factual assertions are improper.
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