texas rules of civil procedure 197
(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. Interrogatories 600 In comment 5 to Rule 193, the reference to Rule 195.6(b) is changed to Rule 195.6. (d) Verification required; exceptions. (1) The expedited actions process in this rule applies to a suit in which all claimants, other than counter-claimants, affirmatively plead that they seek only monetary relief aggregating $ 100,000 250,000 or less, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees excluding interest, statutory or 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. 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. 5The Texas discovery rules are Texas Rules of Civil Procedure 190-215. 560 (S.B. If it is confirmed to be necessary, the court can rule that it be required. (c) This presumption may be overcome only on a showing of clear and convincing evidence that the boundary as described and depicted in the archives of the General Land Office is erroneous. (a) Time for response. ,$@54rHT"]Vt'8[qN S?%JD!Ar2rT~pY xMD3X4Y_N BB\?`o84m{F23FNtCb8tvbSMaa%!vSUR?Ekow[h83}YRz#Q ? 1J$00*hb&A>a6kzPC/y tYzQ+-aBh>APr^2$ UugE__Z?|H~%ytAe0zHiz9v'8[-/g'T0*T3dIdb?+9)L4h{#?0+y$W.DR1CS)c- 8"yq?FTg~gm0.xp mXNMXiwi]p3KSsbxE SZnVhd{7DY. 6jJYd[elqlc`F&__wS{(;]R*v{ S., Ste. (a) This section applies to civil actions only, but not to an action on a sworn account. *HFKt.-: A#yv7:lq|e7u]U1 lJ5WH%1y%(sD'QT-p&I0Dr%g0[ =G;+oB43LI ,B?t,'*~ VJ{Awe0W7faNH >dO js 1. . 752 (Sept. 1998), and Rule 215 are modified to reflect public comments and are adopted as attached. Questions about the substance of a courts local rule should be directed to the relevant courts clerk. Kathmandu is the nation's capital and the country's largest metropolitan city. (TRCP 198.2) Amending or Supplementing Responses to Written Discovery 30 days before trial or presumed not made reasonably promptly (TCRP 1, eff. As with requests for disclosure, interrogatories may be used to ascertain basic legal and factual and defenses but may not be used to force a party to marshal evidence. 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. 15. 132.001. Requests that are made by you or to you asking to admit or deny facts that relate to the case. The Rules of Civil Procedure govern the proceedings in civil trials. 18.062. Added by Acts 1995, 74th Leg., ch. 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. 17330 Preston Rd., Ste. Jan. 1, 1999. In civil litigation, discovery refers to the process where parties in a lawsuit exchange relevant facts and information about a case. 18.033. In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. TRAFFIC CONTROL DEVICE PRESUMED TO BE LAWFUL. 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) _sP2&E) \RM*bd#R\RWp G Sec. This rule imposes no duty to supplement or amend deposition testimony. /Width 2560 INTERROGATORIES TO PARTIES 197.2 Response to Interrogatories. E-mail: info@silblawfirm.com, San Antonio Office /BitsPerComponent 1 (d) Verification required; exceptions. 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 Ask a Librarian for help if you have questions about locating or accessing Texas court rules.. Court Proceedings. 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. Bar. 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. 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. 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. 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 CERTAIN INFORMATION RELATING TO IDENTITY THEFT. "Side" refers to all the litigants with generally common interests in the litigation. THE TEXAS RULES OF CIVIL PROCEDURE _____ ORDERED that: 1. 18.002. 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 in the regular course of business at or near the time or reasonably soon after the time the service was provided. J. The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were provided. Added by Acts 1987, 70th Leg., ch. 0000058841 00000 n Sept. 1, 1985. The court must still set the case for a trial date that is within 90 days after the discovery period ends. Request for Production and Inspection 319 0 obj <> endobj An objection to authenticity must be made in good faith. 1. The provision is commonly used in complex cases to reduce costs and risks in large document productions. Added by Acts 2003, 78th Leg., ch. %PDF-1.4 % Further, amended Rule 190.2 increases the aggregate amount of oral deposition time permitted for expedited actions from 6 hours to 20 hours. September 1, 2013. The revisions to the Texas Rules of Civil Procedure promulgated by Order in Misc. Acts 1985, 69th Leg., ch. 18.032. 0000049836 00000 n 0000003145 00000 n R. Evid. 0000001444 00000 n (a) Signature required. SWORN TO AND SUBSCRIBED before me on the __________ day of _____, _____. 2. Rules about interrogatories during discovery are strict and complex, and failing to follow those rules can have serious repercussions. (( (a) In a civil case, proof of the existence of a traffic control device on or alongside a public thoroughfare by a party is prima facie proof of all facts necessary to prove the proper and lawful installation of the device at that place, including proof of competent authority and an ordinance by a municipality or order by the commissioners court of a county. Sept. 1, 2003. 468 0 obj <> endobj E-mail: info@silblawfirm.com, Beaumont Office The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. 1, eff. 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. All discovery must be conducted during the discovery period, litigation Daniel Solutions, Lawyer (JD) 9,934 Satisfied Customers Practing General Attorney, Acts 2007, 80th Leg., R.S., Ch. 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 . 1, eff. Fax: 713-255-4426 1. 2. If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. Authentication is, of course, but a condition precedent to admissibility and does not establish admissibility. {u-,gVP#'{W@=Q6o""u7l!R;_WC[eTb0aa,KQbZS#vuJ#n,Gz^rDGZg^W~nKp4Kd8 However, the rule does not prohibit a party from specifically requesting the material or information if the party has a good faith basis for asserting that it is discoverable. 18.091. 1993). Acts 2013, 83rd Leg., R.S., Ch. A responding party - not an agent or attorney as otherwise permitted by Rule 14 -must sign the answers under oath except that:". (3) the date the party offering the counteraffidavit must designate any expert witness as required by the Texas Rules of Civil Procedure. 679), Sec. Complaints that a local rule, form, or standing order conflicts with other laws or rules, is ineffective, or is unfair or unduly burdensome may be presented first in writing to the presiding judge of the administrative judicial region in which the court is located, then in writing to the Supreme Court of Texas at rulescomments@txcourts.gov. An itemized statement of the service and the charge for the service is attached to this affidavit and is a part of this affidavit. 2. 901(a). For any questions about the rules, please call (512) 463-4097. 511 and overturns Granada Corp. v.First Court of Appeals, 844 S.W.2d 223 (Tex. September 1, 2019. (e-1) Notwithstanding Subsection (e), if the party offering the affidavit in evidence serves a copy of the affidavit under Subsection (d-1), the party offering the counteraffidavit in evidence or the party's attorney must serve a copy of the counteraffidavit on each other party to the case by the later of: (1) 30 days after service of the affidavit on the party offering the counteraffidavit in evidence; (2) the date the party offering the counteraffidavit must designate any expert witness under a court order; or. An example would be material or information described by Rule 503(d)( 1) of the Rules of Evidence. A responding party - not an agent or attorney as otherwise permitted by Rule 14 -must sign the answers under oath except that:". (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. Depending on the discovery level in the case, litigants may request as many as 25 interrogatories. 98-9136, dated August 4, 1998, 61 Tex. (2) by the party, if the party is not represented by an attorney, and must show the party's address, telephone number, and fax number, if any. 1. FOREIGN INTEREST RATE. 197.1 Interrogatories. The attached records are kept by __________ in the regular course of business, and it was the regular course of business of __________ for an employee or representative of __________, with knowledge of the service provided, to make the record or to transmit information to be included in the record. H|Ao G`7rk"JzRV>{7,\7q-/Ri$( 7(O/ Od&C:b}_"S*PPBBM Qv.r90vQF75_~%V\`A"$9}|J1yEiV2 M1cmJzH?# /Subtype /Image 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. 560 (S.B. The focus is on the intent to waive the privilege, not the intent to produce the material or information. (d) Verification required; exceptions. " 250 Added by Acts 2005, 79th Leg., Ch. Code of Civil Procedure 607a provides: "In every case which is being tried before the court with a jury, it shall be the duty of counsel for the respective parties, before the first witness is sworn, to deliver to the judge presiding at the trial and serve upon opposing counsel, all proposed instructions to the jury . Silberman Law Firm, PLLC Copyright 2016 | DisclaimerPrincipal office located in Houston, TX. 4. Free court deadline calculators and resources for lawyers, legal professionals, and others. 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. 0000005926 00000 n 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. (b) Content of response. texas rules of civil procedure part i - general rules rule 1. objective of rules rule 2. scope of rules Subpoenas. Texas Rules of Civil Procedure 198 governs requests for admissions. Fax: 469-283-1787 STATE BAR OF TEXAS COMMITTEE ON COURT RULES REQUEST FOR NEW RULE OR CHANGE OF EXISTING RULE TEXAS RULES OF CIVIL PROCEDURE I. 1989). 779 (H.B. R. Evid. 2. 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. (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. %%EOF (a) Time for Response. Request for Motion for Entry Upon Property, Request for Motion for Entry Upon Property in Texas, Civil Suits Arising From Criminal Violations in Texas, Protecting Your Property with a Right of First Refusal in Your Texas Estate Plan, Caring for Your Home When Your Co-Owner is an Absentee, Landlord Liability For Breach of Lease in Texas. Rule 197 - Interrogatories to Parties 197.1 Interrogatories. Docket No. 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. E-mail: info@silblawfirm.com. 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. Telephone: 713-255-4422 xref Fax: 512-318-2462 1. 3. (1) . 13.09, eff. 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. (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 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 $_____. (2)a party need not sign answers to interrogatories about persons with knowledge of relevant facts, trial witnesses, and legal contentions. The records are the original or a duplicate of the original. 673, Sec. Added by Acts 2003, 78th Leg., ch. The signature of an attorney or party on a discovery request, notice, response, or objection constitutes a certification that to the best of the signer's knowledge, information, and belief, formed after a reasonable inquiry, the request, notice, response, or objection is: (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. If the responding party has specified business records, the responding party must state a reasonable time and place for examination of the documents. 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. 319 22 802 endstream endobj 469 0 obj <>/Metadata 71 0 R/PageLayout/OneColumn/Pages 463 0 R/StructTreeRoot 85 0 R/Type/Catalog>> endobj 470 0 obj <>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 471 0 obj <>stream R. CIV. The responding party should either provide responsive answers or state clearly and specifically where the litigant can find answers to their questions. For any questions about the rules, please call (512) 463-4097. 1, eff. Sept. 1, 1995. (3) is offered to prove liability of the communicator in relation to the individual. 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. (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 Below is Rule 197, which details the guidelines and procedures for making and responding to interrogatories: 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 Rule195. HS]K@|n+J4* &W? Added by Acts 1993, 73rd Leg., ch. trailer 0000006404 00000 n 1992), to the extent the two conflict. On __________(DATE)__________, I provided a service to __________(NAME OF PERSON WHO RECEIVED SERVICE)__________. In Texas, the Rules of Civil Procedure only allow attorneys to object on 3 grounds: form, non-responsive answer, or leading. UNSWORN DECLARATION. J. Interrogatories to Parties (Rule 197) 15 K. Requests for Admissions (Rule 198) 15 L. Depositions Upon Oral Examination (Rule 199) 15 1. . startxref 2060 North Loop West Ste. Fort Worth, TX 76102 Fax: 210-801-9661 0000004170 00000 n Admissions An objection must be either on the record or in writing and must have a good faith factual and legal basis. A trial court may also order this procedure. The party seeking to avoid discovery has the burden of proving the objection or privilege. Back to Main Page / Back to List of Rules, Rule 191.3 Signing of Disclosures, Discovery Requests, Notices, Responses, and Objections (Aug. 1998). 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. Sec. Below is Rule 197, which details the guidelines and procedures for making and responding to interrogatories: 197.1 Interrogatories. 18.031. 0000003067 00000 n SWORN TO AND SUBSCRIBED before me on the __________ day of __________, 19___. (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. Telephone: 361-480-0333 0000005069 00000 n (b) Content of response. 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. Rule 197.2(d) is modified as follows: "Verification required; exceptions. (b) Effect of signature on disclosure. 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. HR&c?5~{5ky\g} . Rule 501 of the Texas Rules of Civil Procedure. 191.3 Signing of Disclosures, Discovery Requests, Notices, Responses, and Objections (Aug. 1998). (d-2) The party offering the affidavit in evidence or the party's attorney must file notice with the clerk of the court when serving the affidavit that the party or the attorney served a copy of the affidavit in accordance with this section. This rule is thus broader than Tex. What is a Request for Production, Inspection or Entry? #220 The failure to sign or verify answers is only a formal defect that does not otherwise impair the answers unless the party refuses to sign or verify the answers after the defect is pointed out. hbbd```b```RD(Hjl,X|Xd=L;``k6XD^Ad8XD\u@{=W The responding party must serve a written response on The attached records are kept by me in the regular course of business. Amended by order of Nov. 9, 1998, eff. 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. 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. Response to Interrogatories (2021). 1. Telephone: +231 770 599 373. 1. I am of sound mind and capable of making this affidavit, and personally acquainted with the facts herein stated. This post on Interrogatories is the third part of a seven-part series on forms of discovery in Texas. stream HN@Htqtj0J|}g2sRR 7 Texas Civil Practices and Remedies Code. hTPn0[dt4NwE1%$8 :7{ae#W`[Wt :GZ; Sec. Return of Service The officer's return or authorized person executing the citation shall be endorsed on or attached to the same; it shall state when the citation was served and the manner of service and be signed by the officer officially or by the authorized person. (b) If any claimant seeks recovery for loss of earnings, loss of earning capacity, loss of contributions of a pecuniary value, or loss of inheritance, the court shall instruct the jury as to whether any recovery for compensatory damages sought by the claimant is subject to federal or state income taxes. 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)__________. Back to Main Page / Back to List of Rules, Rule 197. ?3Z-RRqu&pamS6eWVgzg{L64l:G-@0LzQI` * Thus, when large numbers of documents are being produced, a party may amend the initial response when documents are found as to which the party claims privilege. %PDF-1.4 Sept. 1, 1987. I am a custodian of records for __________. 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. 18.001. The topics are listed below: Initial Disclosures The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant served with interrogatories before the defendant's answer is due need not respond until 50 days after service of the interrogatories. 8000 IH-10 West, Suite 600 Back to Main Page / Back to List of Rules. Acts 1985, 69th Leg., ch. com : This website provides general address, phone and email information of foreign consulates located in Houston Texas. Sec. Use of the answers to such interrogatories is limited, just as the use of similar disclosures under Rule 194.6 is. o})Lle,S]&s*giBi $^gr@,4O\UDiaDr'Y{ :U8b nzL1$[ t.7crYo{W8j%X{OBp !gRqJ*J#/&CaXI;:X#84( Houston, TX 77018 Added by Acts 1999, 76th Leg., ch. Rule Last Amended Texas Rules of Civil Procedure February 1, 2023 Texas Rules of Appellate Procedure February 1, 2023 Texas Rules of Evidence June 1, 2020 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. (d) Effect of failure to sign. Amended by order of Nov. 9, 1998, eff. hb```~Vw!b`0p;$PSA+QmxYdP9M>~w Q8|(S9{;CGn`Y[@\J10%M[0v4040t0(w40u0t HE, B$'_ - 777 Main Street, Ste. Requests for Admission must be in writing, and each request has to be listed separately in the document. %%EOF Litigants should avoid overly broad questions, questions addressed in other parts of discovery, or questions with answers available from other resources. 0 The questions should be relevant to the claims and be as specific as possible. Answers to interrogatories may be used only against the responding party. 2, eff. s"*JISBHQDa p" S"! 108 Wild Basin Rd. 0000001820 00000 n (2) the date the offering party must designate any expert witness as required by the Texas Rules of Civil Procedure. Dernire modification : 05/07/2018. 1, eff. Exact wording of existing Rule: Rule 197. % }`\8.u*])( Fub ^=EZS. 1693), Sec. , , A $ $b6)M The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. (b) In this section, "communication" means: (3) a gesture that conveys a sense of compassion or commiseration emanating from humane impulses. 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. (b) Proof of the existence of a one-way street sign is prima facie proof that the public thoroughfare on or alongside which the sign is placed was designated by proper and competent authority to be a one-way thoroughfare allowing traffic to go only in the direction indicated by the sign. fCE@pl!j Sec. The records were made at or near the time or reasonably soon after the time that the service was provided. That ability is broad but not unbounded. (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. Amended by Acts 1987, 70th Leg., ch. 959, Sec. xb```"SVs eah`\v&.&Xp}a4m9ursq`+Tb>q#k!)v;ji"l/&-|y5K#&FXvMLs-}/8Lb# Acts 2019, 86th Leg., R.S., Ch. endstream endobj startxref (3) not unreasonable or unduly burdensome or expensive, given the needs of the case, the discovery already had in the case, the amount in controversy, and the importance of the issues at stake in the litigation.
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