Under Level 2 for most cases, discovery begins when suit is filed and continues until the earliest of the following dates:
1. 30 days before trial (TRCP 190.3(b)(1)(B)(i)) or
2. nine months after the date of first oral deposition or due date of the 1st response to written discovery, whichever is first. (ii)
so first go to 2 above and find the earliest date, then, compare that date to 1. above and find the earliest date between those two dates. Whatever the earliest date is, that is the end of date for the discovery period.
You must serve the ROGS 30 days before that date, however to be safe, do it at least 34 days before. TRCP 190.2(c)(1), 190.3(b) and 197.1
As to your Q about the mediator, the court may appoint one or more third parties, on whom the parties agree, to mediate the case, provided generally that the third party is qualified. CPRC 154.051(b)-(c).
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