Texas Pretrial Practice

Texas Pretrial Practice

A step-by-step outline format and proven practice tips help you avoid pitfalls. Procedure and law outlines in the publication are supported by 2,700 case citations summarized in plain English.

Texas Pretrial: Step by Step

When civil procedure challenges arise, sage advice can make a big difference in your hours, stress, and results. Texas Pretrial Practice probes every step of civil procedure before trial. This problem-solving manual covers each portion of pretrial procedure and focuses on the issues that arise in pleading, motions, and discovery.

Chief Justice Scott Brister of the 14th Court of Appeals and veteran Dallas trial lawyer Dan Boyd have set a new standard of excellence for Texas legal resources with thorough coverage of:

•   Jurisdiction & venue
•   Pleadings
•   Citation & service of process
•   Special exceptions
•   Defaults
•   TROs & injunctions
•   Privileges
•   Motion practice
•   Discovery disputes
•   Depositions
•   Requests for admission
•   Inspection of documents
•   Interrogatories
•   Physical & mental exams
•   Settlement & ADR
•   Summary judgment

Outline format and tight writing. The frequent headings, short paragraphs, plain English, and clear writing speed your access and understanding. Chapter tabs and a detailed index make searching quick and easy.

Proven practice tips. Advantages and disadvantages, cautions, caveats, examples, tactics, tips, and more keep you clear of pitfalls and help you plot strategy.

Recent cases. Legal principles are supported with current, summarized cases rather than lengthy string citations with no differentiation.

Direct answers to tough discovery questions. Texas Pretrial Practice provides authoritative and direct responses to every discovery issues like these:

Paper discovery

•   Must I answer this interrogatory? §30:99-286
•   What are the best grounds and tactics for refusing to respond to interrogatories? §30:184-87
•   How do I respond to interrogatories containing confusing or numerous subparts? §30:192-97
•   How do I obtain full responses to interrogatories and requests for admission? §30:262-67
•   Which objections to a request for admission are likely to stand up? §31:12-19
•   What are the best grounds and tactics for withholding documents from production? §27:182-214
•   On which topics are my own RFAs likely to bear fruit? §31:24-37
•   How do I know whether the opposition has produced all the documents I requested? §30:74-78
•   How do I avoid waiving privileges, both in paper discovery and during depositions? §25:55-88

Depositions

•   How do I depose an out-of-state witness? §28:13
•   What are the procedures for subpoenaing a non-party witness for deposition? §28:86-92
•   How do I deal with obstreperous behavior of opposing counsel during deposition? §28:180-86
•   What should examining counsel do when a witness refuses to answer questions at deposition? §28:188, 200, 222
•   When representing a deposition witness, when should I instruct the deponent not to answer a question? §28:270-72
•   What objections are proper during a deposition? §28:304-12

Other issues

•   What can I do when intransigent opposition stonewalls my discovery? §32:01-04
•   How do I formally compel compliance with my discovery requests? §32:22-42
•   What result can I realistically expect if I move for sanctions? §32:32-42
•   Which objections are most likely to survive a motion to compel? §30:172-98
•   What information can I protect under a privilege? §25:01-617
•   What is and isn't protected as work product? §25:224-75
•   How can I streamline my discovery without sacrificing thoroughness? §24:108-49

And much more—nine detailed chapters are devoted to discovery issues.

Procedure and law outlines are supported by 3,200 cases and over 220 forms. Principles of law are illustrated with recent case examples, not strings of undifferentiated case citations. And the book is packed with tips on how to:

•   Avoid and fix mistakes
•   Resolve peripheral disputes
•   Craft better documents
•   Answer ethical questions
•   Process cases efficiently
•   Improve your advocacy

Texas Pretrial Practice delivers quick and reliable answers with its fast-access outline format, tight writing, superb scholarship, and extensive citations. Its practice-tested forms speed drafting.

Additional forms materials are available from James Publishing; access to those materials can be requested directly from James by following guidelines provided within the eBook or emailing forms@jamespublishing.com.

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