Page 2 of 5 – Requests for Production
and drafts, including both sides thereof, and including, but not limited to, papers, books, letters,
photographs, objects, tangible things, correspondence, telegrams, cables, telex messages,
memoranda, notes, notations, work, papers, transcripts (including trial and deposition transcripts),
pleadings, minutes, report and recordings of telephone or other conversations of interviews or of
conferences or other meetings, affidavits, statements, summaries, opinions, reports, studies,
analysis, evaluations, contracts, agreements, journals, statistical records, desk calendars,
appointment books, diaries, lists, tabulations, sound recordings, computer printouts, data
processing input and output, microfilms, computer discs or other memory elements, and all other
records kept by electronic, photographic, or mechanical means, and things similar to the
foregoing, however denominated by you.
3. “Tangible thing” means any material inanimate object or living organism other than human and
includes any human being or part thereof displaying relevant information communicable in any
manner other than verbal testimony of that human being.
4. “In your possession” or “under your control” means the documents or tangible things in your
custody or possession, although located elsewhere; documents or tangible things in your care,
custody, and control, although in the possession of your attorneys, accountants, agents, or
employees, and all documents or tangible things, wherever located, as to which you have the right
of possession.
5. “You” or “your” means Plaintiff / Defendant (other party’s name)
__________________,
and all other persons acting or purporting to act on his/her behalf.
6. The term “and” means and/or and the term “or” means and/or.
7. The term “concerning” means relating to, referring to, describing, evidencing, or constituting.
8. “Including” shall be interpreted to expand the meaning or interpretation of a term or question and
shall not be interpreted in a restrictive manner.
9. The use of the singular form of any words includes the plural and vice versa.
10. “Address” means street number and street name, office, suite, or apartment number, city or town,
state and zip code.
11. “Residence” means any property or home in which you reside or resided.
INSTRUCTIONS
1. Document Production. You are requested, within thirty (30) days, to produce the documents
listed below at: