Discovery
S.D. Tex. — SDTX district-wide discovery rules are spare — heavy lifting is the Joint Discovery/Case Management Plan at Rule 16 conference.
SDTX district-wide discovery rules are spare — heavy lifting is the Joint Discovery/Case Management Plan at Rule 16 conference. Discovery materials NOT filed. Every response preceded by the question/request. 25 interrogatories max. Video depositions allowed without stenographic recording. Galveston: 2-page joint letter before motion to compel. LR 5.4, 26.1-26.2, 30.1, 33.1.
District-Wide Rules
| Rule | Requirement |
|---|---|
| LR 5.4 | Discovery materials NOT filed with clerk |
| LR 26.1 | File portions as exhibit when needed for motion/trial |
| LR 26.2 | Every response preceded by the question/request |
| LR 30.1 | Video depositions without stenographic recording allowed |
| LR 33.1 | 25 interrogatories max counting subparts |
Joint Discovery/Case Management Plan
Within 140 days: judge conducts initial pretrial conference under FRCP 16.
Rosenthal: 14 days before Rule 16 conference.
Galveston: 10 days before.
Scheduling order sets cutoffs for: joinder, amendments, expert designation, discovery completion, dispositive motions, trial.
Exempt: prisoner civil rights, habeas, student/veteran loan, Social Security, bankruptcy appeals, forfeiture.
Discovery Disputes
Galveston: joint letter (2 pages max) before motion to compel. Typically resolved via Zoom.
Rosenthal: pre-motion conference required. Email case manager + opposing counsel. 1-2 page letter as agenda.
Other judges: check individual procedures.