Texas Discovery: A Practitioner’s Guide to Taking and Resisting Discovery Under the Texas Rules of Civil Procedure

Discovery often represents the most resource-intensive phase of civil litigation, particularly in complex matters where costs can escalate significantly. Texas Discovery: A Practitioner’s Guide to Taking and Resisting Discovery Under the Texas Rules of Civil Procedure delivers in-depth, rule-by-rule analysis designed to help practitioners approach discovery with precision and strategic awareness.

Authored by leading Texas litigators, this treatise examines each stage of discovery under Texas Rules of Civil Procedure 176 and 190–215, offering practical direction for both pursuing and resisting discovery. It addresses common challenges such as overbroad objections, delayed production and procedural disputes that can increase costs and complicate litigation.

This resource helps attorneys align their discovery practices with the Texas Supreme Court’s directive to achieve just, fair and efficient outcomes. Whether handling written discovery, depositions or motions to compel, practitioners will find actionable guidance grounded in real-world litigation experience.

Key Topics Covered

• Discovery purpose and control plans
• Scope of permissible discovery and work product
• Written discovery, objections and privilege assertions
• Disclosures and expert discovery
• Depositions and interrogatories
• Requests for production and admission
• Discovery from nonparties
• Sanctions and motions to compel

This single-volume softbound treatise is updated annually to reflect evolving Texas discovery practice, making it a reliable resource for litigators, trial attorneys and legal professionals working in Texas civil procedure.

Testimonial 

"A big “thank you” for the excellent “Practitioner’s Guides” you have authored over the years. I have been using them routinely since I began practicing in 2014, and I genuinely believe that they helped establish my fair and direct approach to discovery, which has been an asset in my practice." 

-Emily Williams

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