Don't Be Late To Designate: Deadlines Under Rule 193.6

Deadlines abound in litigation. The one requiring timely responses to discovery requests—including disclosure of witnesses and experts—is one of the most important.

Thirty days is standard for responding to most written discovery requests. But, under Texas Rule of Civil Procedure 195.2, experts must be designated either (1) as ordered by court in a scheduling order or (2) by the later of 30 days after the request is served or 90 days before discovery ends (for parties seeking affirmative relief—60 days for all others).

Amendments and supplements of responses—including witness designations—must also be timely. Under Rule 193.5(b), amendments are timely if made "reasonably promptly after the party discovers the necessity for such a response."