IN THE SUPERIOR COURT OF CLARKE COUNTY

							            IN THE CIRCUIT COURT OF ______________ COUNTY, ARKANSAS
                                 _____ DIVISION

________________                                                             PLAINTIFF

vs.                         CASE NO. CV _____________

________________                                                             DEFENDANT


                     DEFENDANT’S FIRST REQUEST FOR
                  PRODUCTION OF DOCUMENTS TO PLAINTIFF

       Pursuant to Arkansas Rules of Civil Procedure, you are hereby served with the following
request for production of documents. Production of the items requested herein shall be at the
offices of Defendant's counsel, {Attorney}, {Attorney address}, at 10:00 a.m. on the 30th day
after service hereof upon you. In lieu of producing such documents in person at such time and
place, you may serve the undersigned with legible copies of any of the documents designated
herein, on or before such date; provided, however, that such service of copies of less than all of
the items requested herein shall not relieve you of your obligation to produce those items in your
possession which you have not served at the time and place requested.
       Renewal of all previously asserted objections and affirmative defenses: The service
of these discovery requests should not in any manner be interpreted as a waiver or an
abandonment of Defendant’s previously-asserted objections and affirmative defenses, including
but not limited to any and all defenses asserted under Arkansas Rules of Civil Procedure.
Defendant hereby expressly renews all earlier objections and affirmative defenses.


                            INSTRUCTIONS AND DEFINITIONS

       The following definitions apply to the document requests:

       1.      The terms “Plaintiff” and “you” and any synonym or plural thereof and
               derivatives therefrom means {plaintiff or alleged assignee}{{,}, as assignee of
               {alleged assignor},}} and, in addition, counsel for Plaintiff and all agents,
               masters, servants, associates, employees, representatives, private investigators,
               insurers and others who are or have been in possession of, or who may have
               obtained, information for or on Plaintiff’s behalf.

       2.      The term “Defendant” and any synonym and derivative therefrom means
               {defendant}.


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3.    The word “person” means an individual, firm, partnership, corporation,
      proprietorship, association, governmental body, joint venture, or any organization
      or entity.

4.    The word “date” means the exact day, month and year, if ascertainable, or if not,
      the best available approximation (including relation to other events).

5.    The word “document” as used hereinafter includes, but is not limited to, all
      written, printed, recorded, or typed records, reports, proposals, drafts, papers,
      contracts, documents, books, letters, statements of witnesses, statements of
      persons who were not witnesses but who have information relating to the
      occurrence which is the subject matter of this lawsuit, notes, accounting records,
      logs, memoranda, minutes, statistical compilations, work sheets, insurance
      policies, films, photographs, videotapes, voice recordings, drawings, computer
      disks, computer tapes, computer stored information, lists and correspondence,
      whether or not in your possession or under your immediate control (insofar as
      these Interrogatories are concerned), relating to or pertaining in any way to the
      subject matter in connection with which it is used, and further includes, without
      limitation, file copies and other copies, no matter how or by whom prepared and
      all drafts prepared in connection with such “documents”, whether used or not.

6.    The words “identify” or “identity” used in conjunction with “documents” means
      to state the date of the document, its author and sender (if appropriate), its
      intended recipient (if appropriate), and a general statement of the form and
      content of each such document reflecting the contents of the document and the
      identity of its custodian.

7.    The words “identify,” or “identity” when used in conjunction with a request for
      the identity of a “person” means to state the person's complete name, home
      address, home phone, business address, business phone, and job description if you
      can describe it.

8.    The word “Corporation” means corporation, Inc., and all predecessors, affiliates,
      managing agents, officers, and directors.

9.    The word “electronic storage device” means any disk, including hard disks and
      floppy disks, CD-ROMs, DVDs, audio tape, network servers, shared servers,
      computers, magnetic tape, back-up tape, voicemail, temporary files, and PDAs,
      whether currently on Plaintiff’s premises or otherwise (e.g., at an employee's
      home or remote office).

10.   The words “electronic data” means any information, including files, documents,
      images, video, metadata or any combination thereof stored, created or used on any
      electronic storage device.

11.   The term “evidence” or any variant thereof, including, but not limited to, the term
      ''evidencing,'' when applied to the content of any document, shall be understood to
      apply if the document directly or indirectly mentions, discusses, constitutes,

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               concerns, supports, contradicts, refers to or in any other way deals with the
               subject matter described in the Request in which the term appears.

        12.    “And” and “or” have both conjunctive and disjunctive meanings; “all” and “any”
               means both “each” and “every”; the plural shall include the singular and vice
               versa.

        13.    “Any” shall be understood to include and encompass “all.” As used herein, the
               singular shall always include the plural and the present tense shall also include the
               past tense. The words “and” as well as “or” shall be construed disjunctively or
               conjunctively as necessary to bring within the scope of this request all documents
               or things that might otherwise be construed to be outside its scope.

        This request is intended to cover all documents in possession of the Plaintiff, or subject to
its custody and control, regardless of location.

                     REQUEST FOR PRODUCTION OF DOCUMENTS

                                                     1.

        All documents relating to the alleged debt of Defendant.

                                                     2.

        All documents relating to Plaintiff’s activities to collect the alleged debt, including all

form letters, enclosures, envelopes, memoranda, etc. used by the Plaintiff in its debt collection

activity.

                                                     3.

        An organizational chart for the Plaintiff.

                                                     4.

        All documents between Plaintiff and Plaintiff’s assignors regarding the Defendant and

collection of Defendant’s alleged debt. {{omit paragraph in suit by original creditor}}

                                                     5.

        All documents in Plaintiff’s possession that are under the hand of (i.e. drafted by and

signed by) Plaintiff’s alleged assignor that Plaintiff purports to prove the alleged assignment of

Defendant’s debt to Plaintiff. {{omit paragraph in suit by original creditor}}


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                                                  6.

       All documents relating to the Plaintiff’s procedures to provide verification of the alleged

debt. {{omit paragraph in suit by original creditor}}

                                                  7.

       These Requests shall be deemed continuing so as to require further and supplemental

production if Plaintiff obtains additional documents required to be produced herein between the

time of the initial production and the time of trial.



       Respectfully submitted this       day of               , 20

                                                        By: __________________________
                                                        ATTORNEY NAME
                                                        LAW FIRM
                                                        ABN 2000000
                                                        PHONE NUMBER
                                                        ATTORNEY FOR DEFENDANT




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