Generally, in Texas, a party to a lawsuit may request and obtain discovery about anything so long as the information or documents sought are (1) relevant and (2) not privileged. See TRCP 192.3(a). Importantly, the party from which the information or documents is requested, is required to produce documents or tangible things within the party's possession, custody, or control. See TRCP 192.3(b).
In Expedited Rules Decoded: Things You Need To Know About TRCP 169, we examined the broad impact that Texas' Expedited Rules can have on both lawyers' strategy and the outcomes of cases. The Expedited Rules provide a process for developing and following "a schedule of events that achieves its earliest disposition."1