[MED]

Based on the timetable in O'Conner's Texas Rules, the Discovery period (Level 1) ends 30 days before the trial. Now, the hearing date for my MSJ is less than 30 days from now. I understand they won't answer before the MSJ hearing, but I at least want to send them out to get it started... unless you think I shouldn't bother at this point.

[MED]

I see there is case law regarding delays (due diligence) by the Plaintiff, but not a defendant.