in Re Reassure America Life Insurance Company, 421 S.W.3d 165

Reassure sought a writ of mandamus to compel the trial court to vacate an order granting presuit depositions under Rule 202.
Garcia filed a petition seeking oral depositions and document production to investigate a potential claim regarding policy MP0153991.
The petition sought depositions from individuals with knowledge about the policy, its sale, corporate structure, and related manuals.
Reassure objected, arguing the petition failed to satisfy Rule 202 requirements and that certain requested discovery exceeded the petition and was confidential.
The trial court granted the petition, determining that its deposition and document production would prevent a failure or delay of justice and were outweighing burdens.
The court of appeals held that the petition was insufficient under Rule 202 and that the trial court abused its discretion by ordering broader discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Rule 202 petition satisfied statutory requirements	Reassure contends Garcia's petition failed to state the action's subject matter, adverse parties, or basis for why deposition is warranted.	Garcia argues that Rule 202's broad investigatory purpose allows such pleadings without specifying a viable claim.	Petition insufficient under Rule 202; findings not supported.
Whether the order impermissibly expanded discovery beyond the petition	Reassure argues the order required production beyond what Garcia requested and included improper subjects.	Garcia contends the court properly allowed discovery within the petition's scope and permissible limits.	Abuse of discretion to order unrequested or broader discovery.
Whether mandamus is appropriate given the remedy by appeal	Reassure asserts there is no adequate remedy by appeal and mandamus is proper to correct abuse of discretion.	Garcia challenges mandamus relief as premature or unnecessary if relief could be sought by appeal.	Mandamus relief appropriate; adequate remedy by appeal lacking.

In re Wolfe, 341 S.W.3d 932 (Tex. 2011) (Rule 202 abuse of discretion standard for ordering presuit depositions)
In re Jorden, 249 S.W.3d 416 (Tex. 2008) (presuit depositions ancillary to anticipated suit; mandamus vehicle)
In re Does, 337 S.W.3d 862 (Tex. 2011) (Rule 202 findings cannot be implied; petition must contain factual basis)
In re Hewlett Packard, 212 S.W.3d 356 (Tex. App. — Austin 2006) (limits and evidentiary considerations for Rule 202 orders)
In re Exmark Mfg. Co., Inc., 299 S.W.3d 519 (Tex. App. — Corpus Christi 2009) (scope of discovery must align with anticipated action's subject matter)
In re CSX Corp., 124 S.W.3d 149 (Tex. 2003) (broader discovery standards and relevance for Rule 202 context)