One of our specialties at The Legal Connection is preparing and overseeing the issuance of Depositions Upon Written Questions (“DWQ”) and Subpoenas Duces Tecum from non-parties.  Texas Rules of Civil Procedure, Rule 200 guides the issuance of a Notice and Questions.  It states:  “A party may take the testimony of any person or entity by…

I am often asked, when discussing record retrieval and requests by authorization, about the admissibility of documents. I thought a series on the process might be helpful.  Let’s start with the components of an Affidavit.  They are: Commencement: This is the beginning of the document where the affiant or the person making the affidavit is…

In my nearly 30 years of working the legal profession, I sometimes think I have seen it all, but know, of course, that is nowhere near true. I started my career in the age of early computers with the green blinking lights on a black screen. Every desk had an IBM Selectric typewriter but not…

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