Respond & protect (Texas)

The objection discipline

Tex. R. Civ. P. 193.2

• Objections must be SPECIFIC and grounded — a laundry-list or prophylactic objection is itself improper (193.2(a), (e)).
• A party must comply with the unobjectionable part and object only to the rest (193.2(b)).
• Objections are WAIVED if not timely made — and obscuring a valid objection among invalid ones is sanctionable conduct the rule itself condemns.
• Privilege is NOT asserted by objection: it rides 193.3's withholding-statement lane (below).

The privilege lane — withholding statement first, log on request

Tex. R. Civ. P. 193.3

Texas inverts the federal habit: you assert by WITHHOLDING and stating it, then serve a description only if the other side asks.

• Withhold + STATE that responsive material is being withheld, identifying the request and the privilege asserted (193.3(a)).
• The requesting party may then serve a written request; only THEN is the withholding party obliged to serve the identifying description (193.3(b)) — the 'log' is on demand, not automatic.
• The attorney-work-product exemption for material created after suit or in anticipation (193.3(c)) requires no statement at all — know which lane the document is in before writing anything.
• Inadvertent production: the 193.3(d) snap-back — material 'produced inadvertently without intending to waive the privilege' can be reclaimed by amended assertion; verify the rule's current response window before relying on it (the figure is a per-edition fact, not assumed here).