Texas Pretrial Practice

When civil procedure challenges arise, sage advice can make a big difference in your hours, stress, and results. Texas Pretrial Practice probes every step of civil procedure before trial. This problem-solving manual covers each portion of pretrial procedure and focuses on the issues that arise in pleading, motions, and discovery.

Chief Justice Scott Brister of the 14th Court of Appeals and veteran Dallas trial lawyers Dan Boyd and Ellen Presby have set a new standard of excellence for Texas legal resources with thorough coverage of:

Jurisdiction & venue
Pleadings
Citation & service of process
Special exceptions
Defaults
TROs & injunctions
Privileges
Motion practice
Discovery disputes
Depositions
Requests for admission
Inspection of documents
Interrogatories
Physical & mental exams
Settlement & ADR
Summary judgment

Outline format and tight writing. The frequent headings, short paragraphs, plain English, and clear writing speed your access and understanding. Chapter tabs and a detailed index make searching quick and easy.

Proven practice tips. Advantages and disadvantages, cautions, caveats, examples, tactics, tips, and more keep you clear of pitfalls and help you plot strategy.

Recent cases. Legal principles are supported with current, summarized cases rather than lengthy string citations with no differentiation.

Direct answers to tough discovery questions. Texas Pretrial Practice provides authoritative and direct responses to every discovery issues like these:

Paper discovery

Must I answer this interrogatory? §30:99-286
What are the best grounds and tactics for refusing to respond to interrogatories? §30:184-87
How do I respond to interrogatories containing confusing or numerous subparts? §30:192-97
How do I obtain full responses to interrogatories and requests for admission? §30:262-67
Which objections to a request for admission are likely to stand up? §31:12-19
What are the best grounds and tactics for withholding documents from production? §27:182-214
On which topics are my own RFAs likely to bear fruit? §31:24-37
How do I know whether the opposition has produced all the documents I requested? §30:74-78
How do I avoid waiving privileges, both in paper discovery and during depositions? §25:55-88

Depositions

How do I depose an out-of-state witness? §28:13
What are the procedures for subpoenaing a non-party witness for deposition? §28:86-92
How do I deal with obstreperous behavior of opposing counsel during deposition? §28:180-86
What should examining counsel do when a witness refuses to answer questions at deposition? §28:188, 200, 222
When representing a deposition witness, when should I instruct the deponent not to answer a question? §28:270-72
What objections are proper during a deposition? §28:304-12

Other issues

What can I do when intransigent opposition stonewalls my discovery? §32:01-04
How do I formally compel compliance with my discovery requests? §32:22-42
What result can I realistically expect if I move for sanctions? §32:32-42
Which objections are most likely to survive a motion to compel? 30:172-98
What information can I protect under a privilege? §25:01-617
What is and isn’t protected as work product? §25:224-75
How can I streamline my discovery without sacrificing thoroughness? §24:108-49

And much more—nine detailed chapters are devoted to discovery issues.

Procedure and law outlines are supported by 3,200 cases and over 220 forms. Principles of law are illustrated with recent case examples, not strings of undifferentiated case citations. And the book is packed with tips on how to:

Avoid and fix mistakes
Resolve peripheral disputes
Craft better documents
Answer ethical questions
Process cases efficiently
Improve your advocacy

Texas Pretrial Practice delivers quick and reliable answers with its fast-access outline format, tight writing, superb scholarship, and extensive citations. Its practice-tested forms speed drafting. And the accompanying full-text CD provides a second and portable reference at no extra charge.

Updated annually. ISBN 1-58012-062-8. Book price: $129.00

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Related Titles:

Model Interrogatories

Texas DTPA Forms and Practice Guide

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Updated 07/15/10