Responding To Legal Document Requests

Summary

When responding to legal document requests in Texas, review each request carefully. For production requests, gather and list relevant documents. For interrogatories, provide truthful and concise answers. Attorney-client privilege generally protects communications but may not cover basic billing information. Redact sensitive personal information from documents, such as phone numbers and addresses, and label them as Redacted. If a request does not apply, respond with No responsive documents within my possession, custody, or control. Always ensure your responses are accurate and truthful.

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Documents, including invoices and billing statements, evidencing the contractual relationship with any attorney not designated as an expert, consulting experts on whom testifying experts rely, and/or investigators in connection with this case.
In response to the request for production of documents:
- Gather all invoices and billing statements related to the attorneys, consulting experts, and investigators.
- Ensure these documents evidence the contractual relationship with those not designated as experts.
- Organize and label the documents clearly for submission.
Is there a specific aspect of this request you need further clarification on?
Isn't that attorney client privledge?
Attorney-client privilege generally protects communications between an attorney and their client. However, certain billing and invoice information may not be protected if they don't reveal the substance of the legal advice.
Is your concern about revealing specific information within the invoices and billing statements?
I only consulted with my attorney though
Understood. In Texas, the attorney-client privilege typically protects communications between you and your attorney. However, the privilege might not cover basic information such as the existence of the attorney-client relationship or general billing information.
To clarify, are you concerned about disclosing the existence of the consultation, or the detailed content within the billing statements?
so how would i answer this?
In Texas, while attorney-client privilege generally protects communications between you and your attorney, it might not cover the existence of the attorney-client relationship or general billing information. To provide accurate guidance, could you clarify if your concern is about disclosing the existence of the consultation or the detailed content within the billing statements?
so they want to see what i was charged for my lawyer?
In Texas, while attorney-client privilege generally protects communications, basic billing information may not be protected. To respond:
- Provide the requested invoices and billing statements.
- Redact any detailed descriptions revealing the substance of legal advice.
Would you like further clarification on redacting specific details?
what if the agreement has my personal information on there, can i white it out?
You can redact personal information from the agreement. Here are steps to follow:
- Redact sensitive personal information like Social Security numbers, addresses, and financial details.
- Ensure the redactions do not obscure the context of the document.
- Clearly label the document as "Redacted."
Would you like more guidance on specific details to redact?
can I put redact by my phone number?
Yes, you can redact your phone number. Here are the steps:
- Redact your phone number and any other sensitive personal information.
- Ensure the redactions do not obscure the context of the document.
- Clearly label the document as "Redacted."
Would you like more guidance on redacting other specific details?
*. Documents, including invoices and billing statements, evidencing the contractual relationship with any attorney not designated as an expert, consulting experts on whom testifying experts rely, and/or investigators in connection with this case. *. Diaries, notes, memoranda, journals, or calendars, including electronic diaries, memoranda, journals, or calendars, letters and correspondence, including electronic writings (for example, email and text messages), or other written logs that relate to— a. conservatorship; b. possession and access; c. child support and health insurance for the child; g. attorney’s fees; i. tort claims; and j. requests for permanent injunctions.
For the request regarding diaries, notes, and other documents, follow these steps:
- **Gather Relevant Documents:** Collect all documents listed, ensuring they relate to the specified categories (e.g., conservatorship, child support).
- **Review for Privilege:** Identify any attorney-client privileged communications.
- **Redact Personal Information:** Redact sensitive information, such as phone numbers and addresses.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
Is there a specific category you need more guidance on?
what if this does not apply what do you put as a response?
If a request does not apply to you, you can respond with "No responsive documents." Make sure your response is accurate and truthful. Would you like more guidance on how to phrase your response for specific requests?
yes
For requests that do not apply to you, you can use the following phrasing:
- "No responsive documents within my possession, custody, or control."
If you need guidance on a specific request, please let me know which one.
Reports, statements, notes, memoranda, correspondence, billing statements, records of payments, underlying documentation, references and resources, and/or any other documents relevant to this cause which are contained in any file of, or held by, any potential expert witness in this case working for or on behalf of Petitioner.
For the request regarding documents held by any potential expert witness, follow these steps:
- **Gather Documents:** Collect all relevant documents related to the case.
- **Review for Privilege:** Identify any privileged communications.
- **Redact Personal Information:** Redact sensitive details.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
If there are no responsive documents, you can respond with "No responsive documents within my possession, custody, or control."
Would you like more guidance on any specific aspect of this request?
*. Documents pertaining to the employment by you, or on your behalf, your relationship with your attorney, accountants, appraisers, actuaries, and/or other professionals in reference to this cause of action, including without limitation employment contracts, fee contracts, bills forwarded to you by said professional, records of payments made to said professional by you or on your behalf, and/or time slips prepared by said professional and/or his/her or his/her staff.
For the request regarding documents pertaining to your relationship with attorneys, accountants, appraisers, and other professionals, follow these steps:
- **Gather Documents:** Collect all employment contracts, fee contracts, bills, records of payments, and time slips.
- **Review for Privilege:** Identify any privileged communications.
- **Redact Sensitive Information:** Redact personal details and privileged information.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
If no documents apply, respond with "No responsive documents within my possession, custody, or control."
Would you like more guidance on any specific detail?
so this is asking for my contract with my lawyer?
Yes, it appears to be asking for your contract with your lawyer. Follow these steps:
- **Gather Documents:** Collect your employment contract, fee contract, bills, records of payments, and time slips related to your lawyer.
- **Review for Privilege:** Identify any privileged communications.
- **Redact Sensitive Information:** Redact personal details and privileged information.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
Would you like more guidance on a specific part of this request?
Discovery Objection texas to request for credit report
In response to a discovery request for a credit report in Texas, you can object based on relevance and privacy. Here are potential objections:
- **Relevance:** "Objection. The request for the credit report is not relevant to the issues in this case."
- **Privacy:** "Objection. The request for the credit report violates privacy and is overly broad."
Would you like more guidance on formulating a specific objection?
How would i put this on the discovery document
To document your objections in a discovery response, you can use the following format:
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**Response to Request for Credit Report:**
"Objection. The request for the credit report is not relevant to the issues in this case and violates privacy. The request is overly broad and seeks information not proportional to the needs of the case."
---
Would you like more help with any other discovery requests or objections?
*. Text messages and Emails with Respondent. All texts, social media messages, and/or emails between you and Respondent (No time limit.)
In response to the request for all texts, social media messages, and emails with the Respondent:
- **Gather Communications:** Collect all relevant texts, social media messages, and emails between you and the Respondent.
- **Review for Privilege:** Identify any privileged communications.
- **Redact Personal Information:** Redact sensitive personal details.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
Would you like more guidance on a specific aspect of this request?
object to this
To object to a request for all texts, social media messages, and emails with the Respondent, you can use the following format:
---
**Response to Request for Text Messages and Emails:**
"Objection. The request for all texts, social media messages, and emails between myself and the Respondent is overly broad, unduly burdensome, and not limited in time or scope. The request seeks information that is not proportional to the needs of the case."
---
Would you like more help with any other discovery requests or objections?
respondent also has the text and emails
Understood. In this case, you can still object to the request but acknowledge that the Respondent might already possess the requested information. Here’s how you can phrase it:
---
**Response to Request for Text Messages and Emails:**
"Objection. The request for all texts, social media messages, and emails between myself and the Respondent is overly broad, unduly burdensome, and not limited in time or scope. The Respondent already possesses these communications."
---
Would you like more help with any other discovery requests or objections?
All accounts reflecting funds, including mutual funds, on deposit with banks, brokerage firms, or other financial institutions, including— a. statements of account reflecting account balances; b. originals or true and correct copies, front and back, of all canceled checks; c. carbon copies of all checks written; d. all deposit slips; e. all withdrawal and debit slips; f. Documents evidencing transfers into or withdrawals from the account; and g. all check registers.
For the request regarding financial accounts, follow these steps:
- **Gather Documents:** Collect all relevant financial documents, including account statements, canceled checks, deposit slips, withdrawal slips, transfer documents, and check registers.
- **Review for Privilege:** Identify any privileged information.
- **Redact Sensitive Information:** Redact personal details such as account numbers.
- **Label Clearly:** Mark documents as "Redacted" where necessary.
Would you like more guidance on any specific part of this request?
INTERROGATORY *: If any person or entity with which you are associated provides you with any fringe benefits, state for each fringe benefit—
To respond to Interrogatory * regarding fringe benefits, follow these steps:
- **Identify Benefits:** List any fringe benefits provided by any person or entity you're associated with.
- **Describe Each Benefit:** Provide a brief description of each benefit, including type and value.
- **Exclude Irrelevant Details:** Only include information relevant to the benefits.
Would you like more specific guidance on how to list or describe these benefits?
if i do not receive benefits how do i respond
If you do not receive any fringe benefits, you can respond to Interrogatory * as follows:
---
**Response to Interrogatory *:**
"No fringe benefits are provided by any person or entity with which I am associated."
---
Would you like more guidance on any other discovery requests or responses?
INTERROGATORY *: State the identity and location of all mental and physical healthcare providers whom you have treated, and the reasons for seeing each healthcare provider, including any recommendations made by such mental health and physical health-care provider.
To respond to Interrogatory *, follow these steps:
- **Identify Providers:** List all mental and physical healthcare providers you have seen.
- **Provide Locations:** Include the location of each provider.
- **State Reasons:** Briefly state the reasons for your visits.
- **Recommendations:** Mention any recommendations made by the providers.
If you have no healthcare providers to list, you can respond with:
---
**Response to Interrogatory *:**
"No healthcare providers have treated me."
---
Would you like further assistance with this response?
If since October *, you have taken or used any controlled substance for which you did not have a valid prescription, state for each use—
To respond to this question, follow these steps:
- **State Use:** If you have used any controlled substance without a valid prescription since October *, provide the details.
- **Include Details:** State the name of the substance, frequency, and circumstances of use.
- **Be Truthful:** Ensure your response is accurate and complete.
If you have not used any controlled substances without a valid prescription, you can respond as follows:
---
**Response:**
"I have not taken or used any controlled substance for which I did not have a valid prescription since October *."
---
Would you like more guidance on any other discovery requests or responses?
i dont take any controlled substances at all
If you don't take any controlled substances at all, you can respond to the question as follows:
---
**Response:**
"I have not taken or used any controlled substance for which I did not have a valid prescription since October *."
---
Would you like more guidance on any other discovery requests or responses?
If, while the child have been in your care, you have left the child unattended for any amount of time, please state:
To respond to this question, follow these steps:
- **State the Instances:** If you have left the child unattended, provide details of each instance.
- **Include Details:** State the duration, circumstances, and reasons for leaving the child unattended.
- **Be Truthful:** Ensure your response is accurate and complete.
If you have never left the child unattended, you can respond as follows:
---
**Response:**
"I have not left the child unattended at any time while the child has been in my care."
---
Would you like more guidance on any other discovery requests or responses?
INTERROGATORY *: If you have been charged with a crime (“crime is defined as an action or omission that constitutes an offense that may be prosecuted by the state and is punishable by law) please state:
To respond to Interrogatory *, follow these steps:
- **State Charges:** If you have been charged with a crime, provide details of each charge.
- **Include Details:** State the nature of the crime, the date, and the outcome.
If you have not been charged with a crime, you can respond as follows:
---
**Response to Interrogatory *:**
"I have not been charged with any crime."
---
Would you like more guidance on any other discovery requests or responses?
INTERROGATORY *: State the identity and location (name, address, and telephone number) of your employers since October * and the dates you were employed by each.
To respond to Interrogatory *, follow these steps:
- **Employer Information:** List the name, address, and telephone number of each employer you have had since October *.
- **Employment Dates:** Include the dates you were employed by each employer.
If you have not had any employers since October *, you can respond as follows:
---
**Response to Interrogatory *:**
"I have not had any employers since October *."
---
Would you like more guidance on any other discovery requests or responses?
address and telephone number aren't relavent
Understood. If the address and telephone number aren't relevant, you can respond by providing just the employer names and dates of employment. Here's how you can phrase it:
---
**Response to Interrogatory *:**
"I have been employed by the following since October *:
- [Employer Name], [Dates of Employment]
- [Employer Name], [Dates of Employment]"
---
Would you like more guidance on any other discovery requests or responses?
Licenses and Identification Cards. Documents pertaining to any licenses, memberships, and/or benefit cards of Petitioner, issued by any local, state, or federal government or private entity, subdivision or agency, including social security cards, driver’s licenses, professional or occupational licenses, complaints filed with an agency, investigations made by agencies,
For the request regarding licenses and identification cards, follow these steps:
- **Gather Documents:** Collect documents related to licenses, memberships, and benefit cards issued by any governmental or private entity.
- **Review for Privilege:** Identify any privileged or sensitive information.
- **Redact Personal Information:** Redact sensitive personal details such as Social Security numbers.
- **Label Clearly:** Mark documents as "Redacted" where applicable.
If you have no responsive documents, you can respond with:
---
**Response:**
"No responsive documents within my possession, custody, or control."
---
Would you like more guidance on any other discovery requests or responses?
not wanting to pruduce this information due to respondent commiting tax fraud
If you believe the request for documents is related to the respondent committing tax fraud, you can object to the production based on relevancy and potential self-incrimination. Here's how you can phrase your objection:
**Response:**
"Objection. The request for documents related to licenses, memberships, and benefit cards is not relevant to the issues in this case and may lead to self-incrimination. The request is overly broad and seeks information not proportional to the needs of the case."
Would you like more guidance on any other discovery requests or objections?
Please provide a copy of IRS Letter * (letter concerning advance child tax credits) or any other tax documents relating to payments you received for the child(ren) the subject of this suit.
To respond to the request for IRS Letter * or other tax documents relating to child tax credit payments, follow these steps:
- **Gather Documents:** Collect IRS Letter * and any other relevant tax documents.
- **Review for Privacy:** Ensure sensitive information, such as Social Security numbers, is protected.
- **Redact Personal Information:** Redact any sensitive details.
- **Label Clearly:** Mark documents as "Redacted" where necessary.
If you do not have such documents, you can respond as follows:
**Response:**
"No responsive documents within my possession, custody, or control."
Would you like more guidance on any other discovery requests or responses?
*. Prescriptions. True and correct copies from every pharmacy which you have obtained a prescription, of any sort, since January * through the present.
To respond to the request for prescription records from every pharmacy since January *, follow these steps:
- **Gather Records:** Collect true and correct copies of all prescription records from each pharmacy.
- **Review for Privacy:** Ensure that sensitive information, such as personal medical details, is protected.
- **Redact Personal Information:** Redact sensitive details, such as your address or insurance information.
- **Label Clearly:** Mark documents as "Redacted" where necessary.
If you do not have such documents, you can respond with:
---
**Response:**
"No responsive documents within my possession, custody, or control."
---
Would you like more guidance on any other discovery requests or responses?
unable to obtain copies
If you are unable to obtain copies of the requested prescriptions, you can respond as follows:
---
**Response:**
"I am unable to obtain copies of the requested prescription records at this time."
---
Would you like more guidance on any other discovery requests or responses?