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Certificate of written discovery
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I have been traveling and practicing in various jurisdictions throughout Texas. I had recently encountered local rules I was unfamiliar with that I wanted to pass along…That rule being a Certificate of Written Discovery. Although TRCP 191.4 contains no such requirement, Some local rules are permitted and do require parties to file a Certificate of Written Discovery with the court when serving discovery requests or responses…Moral of the story: Local rules, local rules, local rules…
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