I have not had this problem before as we usually agree or plea out a case which disposes of the seizure in some fashion. The problem of which I speak is answering discovery on filed forfeiture and seizures.
I have received an approximate 50 or so discovery questions covering everyhting ceonceivable. So, does anyone have any guidance on how informative my answeres should be? I know I can't use the old "it's protected because its under investigation or charged or etc..." I am just, I don't know, puzzled as to the amount or type of information to provide...

Assuming the civil discovery provisions apply to the forfeiture proceedings you're litigating, Rule 190.3 of the Rules of Civil Procedure generally provides the relevant discovery limitations. It says, at subsection (b)(3), that a party can serve no more than 25 interrogatories (what generally would be considered to be "discovery questions") on another party. Each discrete subpart of an interrogatory is considered a separate interrogatory. The case law says you handle that by objecting to the excessive number, then answering only the first 25.

Also, the Texas Supreme Court repeatedly admonishes civil pencilnecks like me that discovery requests must be reasonably targeted; they may not constitute "fishing expeditions." Nor may they seek your entire litigation file (from the forfeiture or the underlying prosecution); the makeup of the file constitutes privileged work product. Here, you don't object. Instead you make a "withholding statement" and, if the other side thinks to ask about the basis for withholding, you file a privilege log (see Tex. R. Civ. P. 193.3). Also, turnabout is fair play. Serve them with discovery asking about the nature of the property. Usually, they're much more interested in asking the questions than in answering them. Perhaps that's a starting point for you.

Thanks...I may be calling you to get some specifics. Tuck has decided I will be the "go to" guy for forfeiture and seizure. This is the first true discovery I have yet to receive. So, let the games begin

Scott:

You're correct. The civil rules control the discovery process in a Chapter 59 Forfeiture proceeding.

Ronnie:

Let me know if you need anything in the way of forms or go-bys for answering written discovery.

You will find that O'Connor's Civil Procedure book is a necessary item if you plan on doing a lot of these.

You can have a lot of fun--and usually get the other side to settle if you send the Defendant written discovery and follow it up with a notice of deposition. If he doesn't want to show for the deposition, he'll usually settle the case (typically when he has pending criminal charges he doesn't want to answer questions about). If he does show and does nothing but take the 5th--there's a lot of good case law out there about the "offensive use doctrine" that will help you in a summary judgment proceeding.

Again, let me know if you need anything.