Litigation ATTORNEY CLIENT RELATIONS GENERAL PROCEDURES & PRACTICE. continued on page 2

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1 Litigation Hundreds of Louisiana litigators already successfully modify Texas forms to work in Louisiana. ProDoc makes it far easier by combining hundreds of forms from its Texas Litigation Library with its incredible automation features. Encompassing all areas of litigation, this volume includes more than 400 procedural forms from client intake through appeal. ATTORNEY CLIENT RELATIONS FILE MANAGEMENT DOCUMENTS Client Information Sheet - DETAILED Notice of Party s Current Address Summary of Medical Bills (Manual) Summary of Medical Bills (Chart) Summary of Medical Treatment (Manual) Summary of Medical Treatment (Chart) Summary of Settlement Negotiations ATTORNEY - CLIENT CORRESPONDENCE Letter to New Client - Fees, Expenses, Representation Letter Declining Representation (Optional Release) Letter to Client - Discovery to Answer Letter to Client - Relocation of Office Letter to Client - Notify of Deposition & Instructions Letter to Client - Transmitting Final Payout Letter to Client - Transmitting Court Costs ATTORNEY - CLIENT AGREEMENTS Contract - Standard Personal Injury with Power of Attorney Contract - General Contingent Fee (Short form) Contract - Hourly and Expenses with Power of Attorney Letter - Disbursement of Settlement Funds RELEASES Release - General Records Release - Medical Records Authorization (HIPAA) Release - Medical Records & Discussions (HIPAA) Release - Texas Workforce Commission Records Release - Psychotherapy Records Authorization (HIPAA) GENERAL PROCEDURES & PRACTICE GENERAL CORRESPONDENCE Letter to Clerk - General Transmittal Letter to Court Reporter - General Transmittal Letter to Opposing Counsel - General Transmittal Letter to Opposing (pro se) Party - General Letter to Sheriff - General Transmittal Letter to Constable - General Transmittal Letter to Private Process Server - General Letter to Juror After Jury Duty CITATION, PROCESS & SUBPOENA Waiver of Citation Citation for Personal Service Citation for Published Notice Notice by Publication Order Authorizing Service of Process, TRCP Motion for Substituted Service, with Order, TRCP Affidavit for Substituted Service by Publication Motion for Substituted Service, with Order, TRCP 109a Subpoena & Subpoena Duces Tecum Motion to Quash Service, with Order Motion to Quash Subpoena Duces Tecum, with Order Response to Motion to Quash Subpoena Duces Tecum, with Order Motion for Private Process, with Order PRE-TRIAL FILINGS AND MOTIONS Motion for Docket Control Order Docket Control Order Demand for Jury Trial Motion to Appoint Interpreter, with Order Motion to Extend Time, with Order Response to Motion to Extend Time, with Order Forum Non Conveniens, with Order Response to Forum Non Conveniens, with Order Motion to Disqualify Attorney, with Order Response to Motion to Disqualify Attorney, with Order Motion to Disqualify Judge, with Order Notice of Motion to Disqualify Judge Response to Motion to Disqualify Judge, with Order Motion to Recuse, with Order Notice of Motion to Recuse Response to Motion to Recuse, with Order Objection to Assigned (Visiting) Judge, with Order Motion for Gag Order, with Order Motion to Compel Electronic Filing, with Order Motion for Pretrial Consolidation with Order, TRJA Response to Motion for Pretrial Consolidation with Order, TRJA Motion to Consolidate, with Order Response to Motion to Consolidate, with Order Petition, Deposition before Suit, with Order, TRCP Response to Petition for TRCP 202 Deposition, with Order Motion for Guardian Ad Litem, with Order Motion for Separate Trial, with Order Response to Motion for Separate Trial, with Order Motion for Separate Trial, Exemplary Damages, with Order Response, Motion for Separate Trial, Exemplary Damages, with Order Motion for Sanctions, with Order, TRCP Response to Motion for Sanctions, with Order, TRCP Motion for Sanctions, with Order, CPRC sec Response to Motion for Sanctions, with Order, CPRC sec Motion for Sanctions, Failure to Serve, with Order Response to Motion for Sanctions, Failure to Serve, with Order Request for Appointment of a Master, with Order Objection to Appointment of a Master, with Order Request for Record of Master s Proceedings Objection to Master Appointed, with Order Objection to Master s Report, with Order Motion to Show Authority to Act, with Order Response to Motion to Show Authority to Act, with Order Motion to Seal Records, with Order & Temporary Order Response to Motion to Seal Court Records, with Order Response to Motion for Temporary Sealing Order, with Order Intervenor s Response to Motion to Seal, with Order Motion to Reconsider Sealing Order, with Order Designation of Attorney in Charge Appearance of Counsel Motion for Substitution of Counsel, with Order Motion for Withdrawal of Counsel, with Order continued on page 2

2 continued from page Motion to Set for Trial, with Order Motion to Abate, with Order (Defendant) Response to Motion to Abate, with Order Special Appearance with Order - Personal Jurisdiction Response to Special Appearance, with Order Motion to Transfer Venue, with Order (Plaintiff) Response to Motion to Transfer Venue, with Order (Defendant) Motion to Transfer Venue, with Order (Defendant) Response, Motion to Transfer Venue, with Order (Plaintiff) Joint Motion to Transfer Venue, with Order Petition in Intervention Motion to Strike Intervention, with Order Motion to Continue Summary Judgment Hearing, with Order Motion for Pre-Trial Conference Order, Pre-Trial Conference Motion for Preferential Setting, with Order Motion for Special Setting, with Order Motion to Continue Trial, with Order Response to Motion to Continue Trial, with Order Motion to Continue Hearing, with Order Agreement to Conduct Hearing by Electronic Means, with Order Motion to Strike from Jury Docket, with Order Response to Motion to Strike from Jury Docket, with Order Motion to Strike from Non-Jury Docket, with Order Response to Motion to Strike from Non-Jury Docket, with Order Withdrawal of Jury Demand, with Order Objection to Withdrawal of Jury Demand, with Order Motion to Appear Pro Hac Vice Motion in Support of Appearance Pro Hac Vice, with Order Pauper s Oath DISPOSITIVE MOTIONS Motion for Judgment on Agreed Statement of Facts Response to Motion for Non-Suit, with Order Motion for Non-Suit, with Order Motion to Dismiss, Lack of Subject Matter Jurisdiction, with Order Response to Plea to Jurisdiction, with Order Motion for No Evidence Summary Judgment, with Order Response to No Evidence Summary Judgment, with Order Motion for Summary Judgment, with Order Response to Summary Judgment, with Order Motion to Strike - Summary Judgment Affidavit, with Order Special Exceptions, with Order Notice of Intent to Use Unfiled Discovery Joint Motion for Nonsuit & Voluntary Dismissal, with Order Motion to Dismiss, with Order Certificate of Conference Affidavit in Support of Attorney s Fees TRIAL WORK-UP Stipulations of Fact, with Order Motion in Limine, with Order Response to Motion in Limine, with Order Motion to Sever, with Order Response to Motion to Sever Claim, with Order Motion to Equalize Jury Strikes, with Order Response to Motion to Equalize Jury Strikes, with Order Motion to Oppose Juror Challenges (Batson), with Order Memorandum of Law (Shell) Motion to Take Judicial Notice, with Order Response to Motion to Take Judicial Notice, with Order Motion to Permit Juror Note Taking, with Order Response to Motion to Permit Juror Note Taking, with Order Motion to Open and Close (Burden of Proof), with Order Response to Motion to Open and Close (Burden), with Order Motion to Open and Close (Affirmative Defense), with Order Response to Motion to Open and Close (Affirmative Defense), with Order Motion to Suppress Deposition, with Order Response to Motion to Suppress Deposition, with Order Motion to Strike Witness, with Order, TRCP Motion to Exclude Expert Witness (Daubert), with Order Response to Motion to Exclude Expert Witness (Daubert), with Order Motion to Amend Pleading, with Order, TRCP Objection to Motion to Amend - Before Trial, with Order Motion to Strike Amended Pleading, with Order Notice of Use at Trial of Self-Authenticated Document TRIAL PROCEEDINGS Motion to Amend Pleading, with Order, TRCP Motion to Amend Pleading, with Order, TRCP Motion to Amend Pleading After Verdict, with Order Objection to Motion to Amend After Trial Commenced, with Order Requested Special Jury Charge, with Order Objections to the Jury Charge POST - TRIAL JUDGMENT - Non-Jury JUDGMENT - Jury JUDGMENT - Default JUDGMENT - Default with Personal Injury Findings Motion - Judgment Non Obstante Veredicto (NOV-Notwithstanding Verdict) Objection to Motion - Judgment Non Obstante Veredicto (NOV), with Order Motion for Directed Verdict, with Order Objection to Motion for Directed Verdict, with Order Motion for Mistrial, with Order Motion for New Trial, with Order Response to Motion for New Trial, with Order Motion to Reinstate After Dismissal without Prejudice, with Order Response to Motion to Reinstate, with Order Request for Findings of Fact & Conclusions of Law Response to Request for Findings of Fact Notice of Past Due Findings of Fact & Conclusions Request for Amended or Additional Findings and Conclusion Motion for Judgment Nunc Pro Tunc, with Order Response to Motion for Judgment Nunc Pro Tunc, with Order Motion to Preserve Court Reporter s Notes, with Order Motion to Enter Judgment, with Order Motion to Sign Judgment, Losing Party, with Order Motion to Reform Judgment, with Order Motion to Reopen, with Order Certificate of Last Known Mailing Address Motion to Withdraw Funds, with Order Motion for Determination of Lien Motion to Return Posted Bond, with Order Motion for Remittitur, with Order Response to Motion for Remittitur, with Order Motion for Default Judgment Nonmilitary Affidavit - General litigation BILL OF REVIEW Petition for Bill of Review and Order Answer, Bill of Review Bill of Exception Bill of Exception, Bystander SETTLEMENT Settlement Agreement & Release Refusal of Settlement Offer EQUITABLE AND INJUNCTIVE RELIEF Application for Temporary Restraining Order Application for Temporary Injunction Writ of Injunction DISCOVERY PRIVILEGES Affidavit - Attorney-Client - Work Product continued on page 3

3 continued from page Affidavit - Consulting Expert Affidavit - Trade Secret Affidavit - Undue Burden Affidavit - Work Product (Non-Attorney) Withholding Statement, TRCP 1933(a) Request for Information Withheld, TRCP 1933(b) Response to Request Under TRCP 1933(b) LETTERS - GENERAL Letter - Records Custodian - Employee Information Letter - Department of Public Safety (DPS) - (Requesting Crash Report) Letter - Records Custodian - General Request Letter - Internal Revenue Service (IRS) - Requesting Tax Information Letter - Expert Witness - Initial Contact Letter - Expert Witness - Preparation for Deposition or Trial Testimony Letter - Attorney - Rule 11 Agreement, Deposition Letter - Attorney - Rule 11 Agreement, Discovery Letter - Videographer - Set up Deposition Letter - Health and Human Services Commission (HHSC) - Medicaid Info Application for Copy of Driver Record Request for Texas Motor Vehicle Information Request for Copy of Peace Officer s Crash Report Request for Person s Own Statement, TRCP 1923(h) Request for Copy of Driver s Crash Report PRODUCTION OF DOCUMENTS & TANGIBLE THINGS Request for Production - General Response to Requests for Production Motion to Compel Production of Documents, with Order Notice - Subpoena Production From Non-party Supplemental or Amended Responses to Request for Production Agreement to Preserve the Confidentiality of Discovery Documents INSPECTION OF PREMISES Request - Inspection of Premises Response to Request for Inspection of Property Motion for Entry on Property INTERROGATORIES Interrogatories (Shell) Motion to Serve Additional Interrogatories, with Order Response to Interrogatories Motion to Compel Answers to Interrogatories, with Order Post-Judgment Interrogatories to Defendant Supplemental or Amended Answers to Interrogatories ADMISSIONS Requests for Admissions (Shell) Response to Requests for Admissions Motion to Compel Responses to Requests for Admissions, with Order Motion to Determine Sufficiency of Responses Motion to Deem Facts Admitted, with Order Response to Motion to Deem Facts Admitted Motion to Strike Deemed Admissions, with Order Response to Motion to Strike Deemed Admissions, with Order DEPOSITIONS Notice of Oral Deposition of Party Notice of Oral Deposition of Non-Party Witness Notice to Take Deposition Outside of Texas Letter of Request, Motion for Deposition Outside of Texas Letter Rogatory, Motion for Deposition Outside of Texas Motion to Quash Deposition Notice (Party), with Order Response to Motion to Quash Deposition Notice (Party), with Order Motion to Quash Deposition Notice (Non-Party), with Order Response Motion to Quash Deposition Notice (Non-Party), with Order Notice of Deposition - Nonstenographic (Party) Notice of Deposition - Nonstenographic (Non-Party) Notice of Intention to Take Written Deposition Motion to Shorten Time for Video Deposition, with Order Motion for Telephone Deposition, with Order Cross Questions For Written Deposition Motion to Compel Appearance at Deposition, with Order Motion to Compel Answers to Deposition Questions, with Order Motion for Contempt - Failure to attend deposition Response to Motion for Contempt - Missed Deposition Response to Motion to Compel (Deposition Question), with Order Order to Show Cause Judgment of Contempt - Missed Deposition Notice of Delivery of Deposition, Rule Deposition Officer s Certification Disclosure Request for Disclosure Response to Request for Disclosure Motion to Compel Responses to Request for Disclosure, with Order GENERAL MOTIONS Certificate of Written Discovery Response to Motion to Compel (Written Discovery) with Order Motion to Examine the Person, with Order Response to Motion to Examine the Person, with Order Motion to Supplement or Amend Discovery Responses, with Order Motion to Modify Discovery Procedures, with Order Motion for Sanctions, with Order, TRCP Response to Motion for Sanctions, with Order, TRCP Motion to Extend Time to Respond to Discovery, with Order Response to Motion to Extend Time to Respond Discovery, with Order Motion for Level 3 Discovery Control Plan Order, Level 3 Discovery Control Plan Motion for Protective Order, with Order Response to Motion for Protective Order Motion for Sanctions, with Order, TRCP Response to Motion for Sanctions Motion and Judgment for Contempt (Comprehensive) Response to Motion for Contempt, with Order, (Party) Response to Motion for Contempt, with Order, (Non-Party) Motion to Designate Experts, with Order Motion to Reduce Expert Opinion, with Order Affidavit for Admission of Business Records Affidavit for Cost of Service by Custodian Notice of Filing of Business Records PLEADINGS - GENERAL Petition (Shell) Defendant s Original Answer (Counterclaim, Defenses, etc) Answer - General Denial DECLARATORY JUDGMENT Original Petition for Declaratory Judgment Answer, Petition for Declaratory Judgment Application for Supplemental Relief FOREIGN JUDGMENT Notice of Filing of Foreign Judgment Affidavit of Foreign Judgment Proof of Mailing Notice of Foreign Judgment MOTOR VEHICLE ACCIDENT CORRESPONDENCE - MOTOR VEHICLE ACCIDENT Demand Letter & Notice of Representation Demand for Personal Injury Protection (PIP) Forms Demand Letter - Uninsured Motorist Demand Letter - Underinsured Motorist Demand - Stowers Letter Denying Subrogation Entitlement Letter - Department of Public Safety (DPS)-Request Forms SR 42 & SR 62 DISCOVERY - MOTOR VEHICLE ACCIDENT Request for Production - Motor Vehicle Accident continued on page 4

4 continued from page Interrogatories - Motor Vehicle Accident Request for Admissions - Motor Vehicle Accident LITIGATION - MOTOR VEHICLE ACCIDENT Petition - Motor Vehicle Accident Petition - Uninsured or Underinsured Motorist MEDICAL MALPRACTICE CORRESPONDENCE - MEDICAL MALPRACTICE Letter - Transmitting Expert Report Notice of Claim Authorization for Release of Medical Records - Medical Malpractice DISCOVERY - MEDICAL MALPRACTICE Letter - Treating Physician (MD) - Request Information Letter - Treating Physician (MD) - Request Records Letter - Provider - Letter of Protection Letter - Emergency Medical Service (EMS) - Records & Bills Request Letter - Hospital - Billing Records Request Letter - Hospital - Medical Records Request Letter - Provider - Notification & Request Letter - Provider - Transmitting Funds Requests for Production - Medical Malpractice (Plaintiff s) Interrogatories - Medical Malpractice (Plaintiff s) Request for Admission - Medical Malpractice (Plaintiff s) LITIGATION - MEDICAL MALPRACTICE Petition - Medical Malpractice Affidavit Confirming Existence of Expert s Opinion Cost Bond - Health Care Liability Claim Certificate of Escrow Deposit - Health Care Liability Claim Motion to Extend Expert Report Submission Date, with Order Motion to Exclude Expert Witness (Daubert), with Order (Med Mal) Response to Motion to Exclude Expert (Daubert), with Order (Med Mal) Settlement Agreement & Release - (Medical Malpractice) PREMISES LIABILITY CORRESPONDENCE - PREMISES LIABILITY Notice Letter to Property Owner DISCOVERY - PREMISES LIABILITY Request for Production - Premises Liability Interrogatories - Premises Liability Request for Admissions - Premises Liability LITIGATION - PREMISES LIABILITY Petition - Premises Liability PRODUCTS LIABILITY CORRESPONDENCE - PRODUCTS LIABILITY Letter to Manufacturer Concerning Representation DISCOVERY - PRODUCTS LIABILITY Request for Production - Products Liability Interrogatories - Products Liability Request for Admissions - Products Liability LITIGATION - PRODUCTS LIABILITY Petition - Products Liability EMPLOYMENT ATTORNEY-CLIENT RELATIONS Letter - Engagement Worksheet - Client Intake Memo - Consultation Letter - Explanation of Administrative Process Letter - Right to Sue - Agency Time Period Has Expired Letter - Right to Sue - Agency Time Period Has Not Expired Letter, Cover - Client Worksheets Worksheet - Loss of Future Earnings Worksheet - Damages Assessment Worksheet - Employment Record Letter - Request Witness List, Chronology, or Document List Letter - Request Review of Witness List CORRESPONDENCE - EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Letter, Cover - EEOC Investigator Letter - EEOC - Representation Letter - Request for Right To Sue Letter - Request for EEOC Investigative File Letter - Appeal of EEOC s Denial of File Request Letter - Request to Re-Open Investigation Letter, Cover - Withdrawal of Charge Letter - Withdrawal of Counsel Memo - EEOC - Suggested Charge Language CORRESPONDENCE - TEXAS WORKFORCE COMMISSION - CIVIL RIGHTS DIVISION Letter, Cover - TWC - Civ Rights Div - Investigator Letter - TWC - Civ Rights Div - Representation Letter, Cover - Verified Intake Form Form - TWC - Civ Rights Div - Intake Form - TWC - Civ Rights Div - Intake (Blank) Letter - Request for Right to File Civil Action Letter -TWC - Civ Rights Div - Withdrawal of Counsel TEXAS WORKFORCE COMMISSION Wage Claim Form Proposed Questions for Examination of Employer Appeal of TWC Determination Letter - TWC - Evidence for Appeal Tribunal Hearing Request for Witness Subpoena Appeal of TWC Tribunal Decision Petition for Trial De Novo DEMAND LETTERS - EMPLOYMENT Demand Letter - Disability (ADA) Demand Letter - Age Demand Letter - Breach of Employment Contract Demand Letter - Fair Labor Standards Act Demand Letter - Family Medical Leave Act Demand Letter - Race, Color or National Origin Demand Letter - Retaliation Demand Letter - Religion Demand Letter - Sex Discrimination Demand Letter - Sexual Harassment Demand Letter - Withholding of Pay Demand Letter - Whistleblower Demand Letter - Wrongful Discharge for Refusal to Perform Illegal Act Demand Letter - Multiple Causes of Action DISCOVERY - EMPLOYMENT Interrogatories - Employer Requests for Production - Employer Interrogatories - Employee Requests for Production - Employee SETTLEMENT DOCUMENTS Letter - Proposed Settlement Tolling Agreement Regarding Settlement Negotiations LITIGATION - STATE Petition - State - Disability Petition - State - Age Petition - State - Race, Color or National Origin Petition - State - Retaliation Petition - State - Religion Petition - State - Sex Discrimination Petition - State - Sexual Harassment Petition - State - Multiple Causes of Action continued on page 5

5 continued from page 4 LITIGATION - FEDERAL Petition (Complaint) - Federal - Americans with Disabilities Act (ADA) Petition (Complaint) - Federal - Age Petition (Complaint) - Federal - Family Medical Leave Act Petition (Complaint) - Federal - Race, Color or National Origin Petition (Complaint) - Federal - Religion Petition (Complaint) - Federal - Sex Discrimination Petition (Complaint) - Federal - Sexual Harassment Petition (Complaint) - Federal - Multiple Causes of Action Notice - Federal - Removal Motion - Federal - Remand, with Order Civil Cover Sheet - Federal - All Districts Summons - Federal - Civil Case Notice of Lawsuit - Federal - with Waiver of Service Motion - Federal - Pro Hac Vice, with Order DECEPTIVE TRADE PRACTICES ACT (DTPA) Docketing Statement Petition for Writ of Mandamus Mandamus - Appellate Brief Cover Sheet Notice of Appeal Certificate of Parties and Attorneys - Recusal Facts CORRESPONDENCE - DTPA Notice of Claim - Deceptive Trade Practices Act (DTPA) Request to Inspect and for Evidence of Defects Response to Notice of Claim - Reject Claim or Offer Settlement PLEADINGS - DTPA Plaintiff s Original Petition Defendant s Original Answer Affidavit Certifying Rejection of Settlement Offer Plea in Abatement Response to Plea in Abatement (with Controverting Affidavit) Motion to Compel Mediation Original Answer of Consumer Defendant to Collection Suit DISCOVERY - DTPA Interrogatories (from DTPA claimant) Requests for Production (from DTPA claimant) Interrogatories (to DTPA claimant) Requests for Production (to DTPA claimant) POST-TRIAL - DTPA Judgment Motion for Appointment of Receiver (with Order to Show Cause) Order for Appointment of Receiver MISCELLANEOUS- DTPA Waiver of DTPA Rights ALTERNATIVE DISPUTE RESOLUTION Motion for Mediation, with Order Court s Notice Intent to Refer to Alternative Dispute Resolution (ADR) Motion to Refer to Alternative Dispute Resolution (Detailed), with Order Motion to Refer to Alternative Dispute Resolution (Simple), with Order Objection to Motion to Refer to Alternative Dispute Resolution, with Order Objection to Court s Referral to Alternative Dispute Resolution, with Order Order on Motion to Refer - Mediation Agreed Order on Motion to Refer - Mediation Order on Motion to Refer - Moderated Settlement Agreed Order on Motion to Refer - Moderated Settlement Order on Motion to Refer - Summary Trial Agreed Order on Motion to Refer - Summary Trial Agreed Order on Motion to Refer - Mini Trial Mediation Information Sheet Motion to Compel Arbitration, with Order Objection to Motion to Compel Arbitration, with Order MANDAMUS & APPEAL CORRESPONDENCE - MANDAMUS & APPEAL Letter - Court Reporter - Request Reporter s Record Letter - Clerk, Designate Matters in Clerk s Record LITIGATION - MANDAMUS & APPEAL Designation of Matters In Clerk s Record 5