Certificate of written discovery

I have been traveling and practicing in various jurisdictions throughout Texas. I had recently encountered local rules I was unfamiliar with that I wanted to pass along…

That rule being a Certificate of Written Discovery. Although TRCP 191.4 contains no such requirement, Some local rules are permitted and do require parties to file a Certificate of Written Discovery with the court when serving discovery requests or responses…

Moral of the story: Local rules, local rules, local rules…