The Houston Texas Defendant's First Request for Disclosure is a formal document that is filed by the defendant in a lawsuit, aimed at obtaining relevant information from the plaintiff. This request is based on the rules and procedures set forth by the Texas Rules of Civil Procedure, specifically Rule 194. The purpose of the defendant's request for disclosure is to seek information and documents that the plaintiff has in their possession, custody, or control, and are relevant to the lawsuit. It is an essential step in the discovery process, which allows both parties to gather evidence and facts before trial. The request typically consists of specific questions and requests for documents, asking the plaintiff to disclose certain information. The questions are designed to elicit details about the plaintiff's claims, the evidence they possess, and any witnesses involved. Some keywords and phrases that may be included in the request for disclosure are: 1. Identity of persons with knowledge: The defendant may request the plaintiff to identify any individuals who have knowledge of the facts relevant to the lawsuit. This includes not only the plaintiff but also any witnesses, employees, or experts they intend to present as evidence during trial. 2. Expert reports: In cases that involve expert testimony, the defendant may request the plaintiff to disclose any expert reports or written statements prepared by experts retained by the plaintiff. This allows the defendant to understand the expert's opinion and potentially challenge it. 3. Documents and tangible things: The defendant can ask the plaintiff to produce any documents, recordings, photographs, or other tangible items that are relevant to the case. This can include contracts, medical records, correspondence, or any other evidence that supports the plaintiff's claims. 4. Calculation of damages: If the plaintiff is seeking monetary compensation, the defendant can request a detailed calculation of the damages claimed. This includes providing a breakdown of how the damages were assessed and any evidence or supporting documents used in the calculations. 5. Insurance information: The defendant may ask the plaintiff to disclose any insurance policies that may cover the claims made in the lawsuit. This is important for determining potential sources of recovery and for assessing the plaintiff's position in the case. It is important to note that the specific content and wording of the request for disclosure may vary depending on the circumstances of the case and the preferences of the defendant's legal counsel. Additionally, different types of lawsuits or legal disputes may have variations in the request for disclosure process.