Texas Rule of Civil Procedure 192.3 outlines the scope of discovery. This article explains "requests for production," which are a tool for gathering evidence in a lawsuit as part of discovery.(1) the court may order discovery materials to be filed;. The motion must be served on the responding party. A person alleging failure to comply with discovery shall file a motion to compel as soon as practicable. Form §46.120 from this resource contains a template for a Motion for Pretrial Discovery. Any inspection shall be in the presence of a representative of the State. Motion. The motion must be served on the responding party. An application for an order to a deponent who is not a party shall be made to the court in the district where the deposition is being taken. No request for discovery may be served on an opposing party without permission of the court.