SCOPE OF REQUEST FOR DISCLOSURE RE DAMAGE AMOUNT AND CALCULATION

Rule 194.2 T.R.C.P. provides in part for disclosure of
" . . . (d) the amount and any method of calculating economic damages; . . . ."

The Court construes that provision as follows: For any number that you can add up or calculate, tell us the number and how you got it.

In other words, tell the inquiring party the basis for that claim regardless of whether the claim is property damage, lost profits, an offset, claim for reimbursement or otherwise. Tote it up and tell 'em.