How to Respond to Discovery Requests Without a Lawyer (California, Texas, and Wyoming)

Savage Lex Team · 2026-08-07

You open the envelope and it's 40 pages of numbered questions and document demands. Don't panic. The clock started ticking the day you got served, but you have time if you move now.

In California, Texas, and Wyoming, the default deadline to respond to written discovery is 30 days. Figure out what type of request you got, answer every single item in writing, sign what needs signing, and serve the response before the deadline. Miss the window and the consequences get ugly fast. In Texas and Wyoming, unanswered requests for admission become true. In California, a late response wipes out your objections. Here's how to handle it.

What you actually received

Discovery is the phase where both sides trade evidence and information before trial. The three written requests that pro se litigants see most:

The title or caption usually tells you which one you're holding.

The deadline table

| State | Interrogatories | Requests for Production | Requests for Admission |

|-------|----------------|------------------------|------------------------|

| California | 30 days after service | 30 days after service | 30 days after service |

| Texas | 30 days after service | 30 days after service | 30 days after service |

| Wyoming | 30 days after service | 30 days after service | 30 days after service |

Now the caveats that trip people up.

How you got the request changes the California math. California's court self-help guide counts 30 days if someone personally delivered the request to you, but at least 35 days from the mailing date if it came by mail from within California. Mail from another state stretches it to 40 days.

Eviction cases run fast. In a California unlawful detainer, discovery responses are due 5 days after service, or 10 days if mailed from within California. Do not use the 30-day number in an eviction.

Texas family cases get more time. Under Texas Rule 196.2, a defendant in a Family Code case served with a request before their answer is due has 50 days to respond.

How to answer each type

Interrogatories

Retype each question, then write your answer underneath it, in the order received. Answer fully based on what you know and what's reasonably available to you. Wyoming Rule 33 requires each interrogatory to be answered "separately and fully in writing under oath" unless you object. Texas says the same thing: answers are signed under oath and must truthfully state the facts as you understand them. California wants a signed declaration that your answers are true under penalty of perjury.

Don't dodge. If you don't know something, say what you did to find out. "I checked my records and found nothing responsive" is a legitimate answer when it's true.

There are limits on how many interrogatories you can be served. California caps it at 35 specially prepared ones (Cal. Code Civ. Proc. § 2030.030). Texas limits most cases to 25 under its Level 2 discovery plan (Rule 190.3). Wyoming's cap is 25, counting subparts (Rule 33(a)(1)). If you get more than that, you may be able to object to the excess.

Requests for Production

Go request by request. For each one, say whether you'll produce the item or object. Texas Rule 196.2(b) gives you four options: permit production as requested, serve the items with your response, propose a different time and place, or state that a diligent search found nothing responsive.

Here's the one habit that keeps you organized: make a folder for each request number and put the responsive documents in it. When the folder is empty, you know you missed something.

Requests for Admission

This is where cases die. For each statement, admit it if true, deny it if false, or explain in detail why you can't truthfully admit or deny. In Texas, "I lack information" doesn't count unless you also state that you made a reasonable inquiry and still couldn't answer. And in both Texas and Wyoming, if you don't respond within 30 days, every unanswered matter is admitted automatically. No motion, no hearing, no court order. It's just true now. California's version requires the other side to file a motion, but a late response strips your right to object and triggers mandatory monetary sanctions.

One more thing. Never answer "I can't admit or deny this because it's an issue for trial." Wyoming Rule 36 and Texas Rule 198.2(b) both say that objection alone doesn't count.

What happens if you ignore discovery

It gets worse, not better.

If you can't make the deadline, ask the other side for an extension early, in writing, and get their agreement in writing. California's self-help guide recommends exactly this. A written stipulation beats a blown deadline every time.

Common mistakes

Practical next steps

FAQ

Do I file discovery responses with the court?

Usually no. Texas generally doesn't require discovery to be filed with the clerk, and California treats responses the same way. They're served on the other side and only go to the court if used in a motion or if the judge orders filing.

What if a request asks for something privileged?

Object specifically and name the privilege. Don't skip it. An unstated objection is waived in Wyoming, and California strips late objections entirely.

Can I get more time?

Yes, if the other side agrees. Ask early, in writing, and confirm the agreement in writing.

Sources

General legal information, not legal advice. Rules vary by jurisdiction and can change.