THE FIRST OPPOSING COUNSEL YOUR DISCOVERY MEETS WORKS FOR YOU
The Discovery War Room (Texas)
Every other tool tells you your request is fine. The Self-Audit Mirror reads it the way the other side's counsel would — re-keyed to the Texas objection signals: is it proportional (192.4), is the objection specific enough to survive (193.2), does a deposition line cross the form-only rule (199.5)?
The objection signals it hunts
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 deposition rails it enforces
Tex. R. Civ. P. 199.5
- No side may examine or cross-examine an individual witness for more than SIX HOURS, breaks excluded (199.5(c)).
- Objections are limited to 'Objection, leading' and 'Objection, form' — argument, explanation, or coaching waives the objection (199.5(e)).
- Private conferences with the witness are barred during the deposition except to decide privilege assertion (199.5(d)).
- Instructions not to answer only for privilege, court-ordered limits, or abusive questions (199.5(f)) — anything else is itself sanctionable.
Deterministic checks — reproducible, never simulated. Legal information, not legal advice; the call stays yours.