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4 verbatim chambers requirements from Judge David Counts's published procedures (discovery & conferral).
United States District Court for the Western District of Texas — Judge David Counts's cases only. Chambers procedures change without notice; the judge's own published document controls. Procedural information only; not legal advice.
If a party believes targeted email/ESI discovery is necessary, it shall propose a procedure identifying custodians and search terms it believes the opposing party should search.
Reviewer note: Composed 2026-09-26 from what the judge's own official page (https://www.txwd.uscourts.gov/team/david-counts/) and the court's procedure pages publish for the judge: https://www.txwd.uscourts.gov/wp-content/uploads/2022/12/Standing-Order-Governing-Patent-Proceedings-080222.pdf (sha256 b6ee74347f38, scanned PDF without a reliable text layer, 8 pages, transcribed by eye from the page images in two passes, 0 second-pass corrections). Whole sentences with mandatory language, verbatim, whitespace normalised only; grouped by topic as the Florida federal lane (2026-09-14). Custody: BenchPath's private custody store. Documents without a reliable text layer were transcribed by eye from their page images (vision lane, two passes; BenchPath's private custody store); a sentence with any illegible word is not published.
1 verbatim requirement on discovery in DANIEL J. KANNER's division.
1 verbatim requirement on discovery in BETSY BENSON's division.
1 verbatim requirement on discovery.
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