This document, Breach of Contract Request for Production of Documents, sets forth the
important documents that should be requested by a party in a breach of contract case.
This request covers all of the relevant areas pertinent to this sort of request, including
breach, damages and many others. This document can be easily altered to fit the user's
specific situation. This document should be used by attorneys or individuals that want
information about which type of documents to request in a breach of contract case.
DEMANDING PARTY: ________________ [Instructions: Insert name of demanding
RESPONDING PARTY: ________________ [Instructions: Insert name of responding
SET NUMBER: ________________ [Instructions: Since multiple sets of requests
are permitted, the User should set forth the number]
________________ [Instructions: Insert name of demanding party] hereby demands that
________________ [Instructions: Insert name of responding party], produce the documents
described herein, in accordance with ________________ [Instructions: Cite to governing law
that permits the discovery demand] and this notice.
PLEASE TAKE NOTICE that ________________ [Instructions: Insert name of
responding party], is required to produce each and every document, paper, book, account,
letter, photograph, object or other tangible thing which fall within the categories described herein
which are in your possession, custody or control, at ________________ [Instructions: Set forth
location for delivery of documents]. Legible photocopies of front and back of each such
document will be accepted, in lieu of personal production of the originals, provided such
photocopies are received at the above address not later than the date and time required for the
production of such documents and things.
It is not the intention of ________________ [Instructions: Insert name of demanding
party] to request production of privileged matter. If any materials requested are claimed to be
privileged, please list the following for each item claimed to be privileged:
1. A brief description of the nature and contents of the matter claimed to be privileged;
2. The name, occupation and capacity of the individual from who the privileged matter was
3. The name, occupation and capacity of the individual to whom the allegedly privileged mater
4. The date the item bears; and
5. The privilege claimed.
If you object to the production of any document or category of documents, you must identify
with particularity any document being withheld from production, and set forth clearly the extent
of, and the grounds for, the objection.
Full compliance with the request requires production of actual photographs or negatives.
Prints will be made at our expense and all photographs returned immediately thereafter.
Reproductions or other photocopies of any requested photographs will not be deemed in
compliance with the request.
If any materials/documents requested herein are claimed to be privileged, or objections
are made on any ground, each such matter/document must be identified in such a manner that the
description will serve as a adequate basis for a motion to compel production. Such identification
should include (1) the name and capacity of the individual from whom the document emanated
and to whom it was directed; (2) the type of document (i.e., a letter, memorandum, report, etc.);
(3) the date the item bears; and (4) all “cc’s” and/or “bcc’s” on each such documents.
PLEASE TAKE NOTICE that if you fail to identify or produce said documents or if
you object without substantial justification, ________________ [Instructions: Insert name of
demanding party] will move the Court for an order for compliance wherein reasonable
expenses and attorney’s fees may be required.
PLEASE TAKE FURTHER NOTICE that ________________ [Instructions: Insert
name of demanding party] will object to admitting into evidence any documents predating the
date of the scheduled production, if a copy of such document is not produced at the time and
place herein indicated.
DOCUMENTS TO BE PRODUCED
REQUEST NO. 1:
Any and all DOCUMENTS (“DOCUMENTS” a writing, as defined in
________________ [Instructions: Cite to relevant evidence code section in state that sets
forth definition for “document” or set forth definition in its entirety here], and includes the
original or a copy of handwriting, typewriting, printing, photostating, photographing, and every
other means of recording upon any tangible thing and form of communicating or representation,
including letters, words, pictures, sounds, or symbols, or combinations of them, including, but
not limited to, papers, agreements, contracts, notes, memoranda, correspondence, letters,
telegrams, statements, books, reports, studies, minutes, records, accounting books, maps, plans,
drawings, diagrams, photographs, analysis, surveys, transcriptions, and recordings of which you
have any knowledge or information, whether in your possess