context: Although Rule 215.2(b) states that a trial court may impose discovery sanctions only "after notice and hearing," the Texas Supreme Court has expressly held that a "hearing" does not necessarily contemplate a personal appearance before the court or an oral presentation' to the court.
citation_a.signal: see also
citation_a.identifier: 189 S.W.3d 413, 413
citation_a.parenthetical: oral hearing not required prior to imposition of discovery sanctions
citation_a.sentence: Cire, 134 S.W.3d at 843-44 (observing that nothing in the rule indicates that a trial court must hold an oral or evidentiary hearing before imposing discovery sanctions); see also Tidrow, 189 S.W.3d at 413 (oral hearing not required prior to imposition of discovery sanctions).
citation_b.signal: no signal
citation_b.identifier: 134 S.W.3d 843, 843-44
citation_b.parenthetical: observing that nothing in the rule indicates that a trial court must hold an oral or evidentiary hearing before imposing discovery sanctions
citation_b.sentence: Cire, 134 S.W.3d at 843-44 (observing that nothing in the rule indicates that a trial court must hold an oral or evidentiary hearing before imposing discovery sanctions); see also Tidrow, 189 S.W.3d at 413 (oral hearing not required prior to imposition of discovery sanctions).