Legal Question in Family Law in Texas

How about these:

Objection is made to this interrogatory because it was served on Respondent less than thirty days before the end of the discovery period. Texas Rule of Civil Procedure 197.1(a).

Objection is made to this interrogatory because it is in excess of the twenty-five written interrogatories allowed by Texas Rule of Civil Procedure 190.

Objection is made to this interrogatory because it seeks discovery of information that is not relevant to the subject matter of this suit and is not reasonably calculated to lead to the discovery of admissible evidence. Rule 192.3(a), Texas Rules of Civil Procedure.

Objection is made to this interrogatory because it is overly broad and seeks to require to provide more than a basic statement of his legal contentions and the factual bases for those contentions. is not required to marshal evidence in response to a written interrogatory. Rule 192.3(j), Texas Rules of Civil Procedure (comment 5).

Objection is made to this interrogatory to the extent that the discovery sought is unreasonable cumulative or duplicative. Tex R. Civ. P. 192.4(a).

Objection is made to this interrogatory to the extent the discovery sought is obtainable from some other source that is more convenient, less burdensome, or less expensive. Texas Rule of Civil Procedure 192.4(a).

Objection is made to this interrogatory to the extent the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' resources, the importance of the issues at stake in the litigation, and the importance of the proposed discovery in resolving the issues. Texas Rule of Civil Procedure 192.4(b).

Objection is made to this interrogatory to the extent it subjects to undue burden, unnecessary expense, harassment, or annoyance. Rule 192.6(b), Texas Rules of Civil Procedure.

Objection is made to this interrogatory to the extent it subjects to an invasion of personal, constitutional, or property rights. Texas Rule of Civil Procedure 192.6(b).

Objection is made to this interrogatory because it exceeds the scope of discovery by seeking information about testifying expert witnesses through a written interrogatory. Texas Rule of Civil Procedure 195.1.

Objection is made to this interrogatory because it exceeds the scope of discovery by seeking information about consulting expert witnesses whose mental impressions and opinions have not been reviewed by a testifying expert. Texas Rule of Civil Procedure 192.3(e).

asserts his doctor-patient /medical-patient privilege, as this request violates his right to privacy under these privileges, as well as under the Health Insurance Portability and Accountability Act (HIPAA).

Information or material responsive to the interrogatory has been withheld. asserts the following privileges:

Work-product privilege

Husband-wife privilege

Privilege for communication to members of the clergy

Trade secret privilege

Physician-patient privilege

Mental health information privilege

Peer review committee privileges (Texas Occupation Code '160.007(e))

Hospital committee privilege (Texas Health & Safety Code '161.032)

Blood donor privilege (Texas Health & Safety Code '162.010(e))

Privilege against self-incrimination

Disclosure of a membership list

Health and safety audit privilege