§ 193.1. Responding to Written Discovery; Duty to Make Complete Response

193.1. Responding to Written Discovery; Duty to Make Complete Response

A party must respond to written discovery in writing within the time provided by court order or these rules. When responding to written discovery, a party must make a complete response, based on all information reasonably available to the responding party or its attorney at the time the response is made. The responding party's answers, objections, and other responses must be preceded by the request to which they apply.