A Practice Note explaining the first steps that counsel should take when expecting to receive a set of requests for the production of documents and tangible items (RFP) under Texas Rule of Civil Procedure (TRCP) 196 in connection with a lawsuit in Texas district or county court. This Note discusses retaining relevant documents, including ensuring compliance with a document retention policy and implementing a litigation hold. This Note also outlines how to avoid liability for spoliation, how to secure documents and ESI in preparation for production, and the importance of cooperation with other parties in discovery.