How to use contention interrogatories –

In a rare grant of mandamus relief about written discovery, based on the “heart of a party’s case” concept of irreparable injury, the Fifth Court strongly endorsed the use of “contention” interrogatories and related requests for production. Requests as to which it granted relief included ones seeking:

• “Specific factual and legal basis for establishing a fiduciary duty owed by Coralli
  to Vola. (Interrogatory No. 17)”;
• “Documents Vola contends establish, demonstrate, or prove the amount of
  uniforms Sting Soccer committed to purchasing from Vola as alleged in
  paragraph 17 of the first amended petition. (Request No. 27)”; and
• “Documents Vola contends establish, demonstrate, or prove the amount of damages alleged owed to Vola by Sting Soccer. (Request No. 35).”

The opinion makes other useful statements about appropriate discovery objections and requests for admission. In re Sting Soccer Group, No. 05-17-00317-CV (Nov. 30, 2017) (mem. op.)