Part II. Rules of Practice in District and County Courts
Rule 21A. 
nonparty whose medical records are sought if:
the nonparty signs a release of the records that is effective as to the requesting party;
the identity of the nonparty whose records are sought will not directly or indirectly be disclosed by production of the records; or
the court, upon a showing of good cause by the party seeking the records, orders that service is not required.
production, inspection, or other requested action will be permitted as requested;
the requested items are being served on the requesting party with the response;
production, inspection, or other requested action will take place at a specified time and place, if the responding party is objecting to the time and place of production; or
no items have been identified - after a diligent search - that are responsive to the request.
produce copies in lieu of originals. If originals are produced, the responding party is entitled to retain the originals while the requesting party inspects and copies them.
To obtain discovery of data or information that exists in electronic or magnetic form, the requesting party must specifically request production of electronic or magnetic data and specify the form in which the requesting party wants it produced. The responding party must produce the electronic or magnetic data that is responsive to the request and is reasonably available to the responding party in its ordinary course of business. If the responding party cannot - through reasonable efforts
-retrieve the data or information requested or produce it in the form requested, the responding party must state an objection complying with these rules. If the court orders the responding party to comply with the request, the court must also order that the requesting party pay the reasonable expenses of any extraordinary steps required to retrieve and produce the information.
Testing, sampling or examination of an item may not destroy or materially alter an item unless previously authorized by the court.
Unless otherwise ordered by the court for good cause, the expense of producing items will be borne by the responding party and the expense of inspecting, sampling, testing, photographing, and copying items produced will be borne by the requesting party.
a request on all parties if the land or property belongs to a party, or
a motion and notice of hearing on all parties and the nonparty if the land or property belongs to a nonparty. If the identity or address of the nonparty is unknown and cannot be obtained through reasonable diligence, the court must permit service by means other than those specified in Rule 21a that are reasonably calculated to give the nonparty notice of the motion and hearing.
order for entry upon a nonparty's property, must state the time, place, manner, conditions, and scope of the inspection, and must specifically describe any desired means, manner, and procedure for testing or sampling, and the person or persons by whom the inspection, testing, or sampling is to be made.
entry or other requested action will be permitted as requested;
entry or other requested action will take place at a specified time and place, if the responding party is objecting to the time and place of production; or
entry or other requested action cannot be permitted for reasons stated in the response.
Document and tangible things are defined in Rule 192.3(b).
A party requesting sampling or testing must describe the procedure with sufficient specificity to enable the responding party to make any appropriate objections.
A party requesting production of magnetic or electronic data must specifically request the data, specify the form in which it wants the data produced, and specify any extraordinary steps for retrieval and translation. Unless ordered otherwise, the responding party need only produce the data reasonably available in the ordinary course of business in reasonably usable form.
The rule clarifies how the expenses of production are to be allocated absent a court order to the contrary.
The obligation of parties to produce documents within their possession, custody or
control is explained in Rule 192.3(b).
Parties may request production and inspection of documents and tangible things from nonparties under Rule 205.3.
Rule 196.3(b) is based on Tex. R. Evid. 1003.
Rule 196.1(c) is merely a notice requirement and does not expand the scope of discovery of a nonpartys medical records.
Notes and Comments: Comment to 1999 change:
Rule 197. Interrogatories to Parties
A party may serve on another party - no later than 30 days before the end of the discovery period
-written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195. An interrogatory may inquire whether a party makes a specific legal or factual contention and may ask the responding party to state the legal theories and to describe in general the factual bases for the party's claims or defenses, but interrogatories may not be used to require the responding party to marshal all of its available proof or the proof the party intends to offer at trial.