When filing a motion seeking permission to conduct discovery, must I be specific about what I will seek from the defendants?
I have filed a small claims lawsuit and am now preparing a "motion seeking permission to conduct discovery" pursuant to Rule 500.9 of the TEXAS RULES OF CIVIL PROCEDURE. To be successful (get permission) must I fully explain to the court what exact information, documents, etc I am seeking from the defendants? What I have written so far – "Plaintiffs hereby asks to send the Defendants a Request for Disclosure, a request for admissions, production of documents, and interrogatories relative to the charges and allegations established in our lawsuit and subject to whatever limits the Court determines are appropriate." In response to my suit the defendants filed a "general denial" and my reasoning in the motion is that they "possess facts that prove the accuracy of our claims and that discovery is reasonable and necessary in order to establish agreement about the truth of our claims and allegations and minimize taking up the Court’s valuable time."
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