Texas Civil Procedure Deadlines

Texas Rules of Civil Procedure (TRCP)

Defendant - Responding & Defending a Claim

Answer

Initial Disclosures w/in 30 days from Answer or General Appearance Rule TRCP 194.2

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Plaintiff - Filing a Claim

Research - Identify Parties & Legal Claim, Jurisdiction to File, & Statute of Limitations

File Petition

Service of Process (Defendant's Legal Notice of Suit) TRCP 106

Defendant is served Citation & Petition

Texas Rules of Civil Procedure (TRCP)

Jurisdictional & Miscellaneous Motions (Pre-Trial/Non-Dispositive Motions) - Special Appearance, Motion to Transfer, Plea to Jurisdiction, Special Exceptions, Motion to Dismiss, Motion to Abate, Motion to Quash, etc.

Pre-Discovery Motions - Request for Jury, Motion to Challenge the Judge, Motion for Continuance, Motion to Amend Pleadings, Motion to Transfer, Motions for Severance & Separate Trials, Joining Parties or Claims, Motions for Sanctions, Motion to Seal Court Records, Motion for Judicial Notice, Motion to Exclude Expert, etc.

Alternative Dispute Resolution (ADR) - Conducted after non-dispositive process & Discovery

DISCOVERY

Dispositive Motions - Filed either before or after ADR and may include Motion for Summary Judgment, Motion for Judgment on Agreed, Non-suit, Involuntary Dismissal, Offer of Settlement, Settlement of the Suit, etc.

TRIAL

Discovery Control Plan - Leve 1-3 (TRCP 190.1, 190.2, & 190.3)

Request for Production

Request for Admission

Interrogatories

Depositions

Billing Affidavits TCPRC 18.0001

Affidavits - Plaintiff has 90 days after Defendant answers to serve affidavits?? Check on this

Counter-affidavits to controvert claim (120 days after defendant files answer if Affidavits are served before Defendant Answers. 30 days to controvert if Defendant answers. Check on this??