i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR DOCUMENTS WHAT IS THE DOCUMENT? Written request between parties for the production of documents in the lawsuit. WHAT ARE THE APPLICABLE FEDERAL/LOCAL COURT RULES? 1. FRCP, Rule 34 2. L.R. 34-1, 34-2, and 34-3 SPECIAL RULES OR OTHER REQUIREMENTS 1. May only be served on other parties [FRCP, Rule 34(a)]. 2. Multiple sets must be sequentially numbered [L.R. 34-1]. 3. Responses are due in 30 days if personally served [FRCP, Rule 34(b)] 4. Response must reprint text of request [L.R. 34-2]. 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STEIN & ASSOCIATES Michael D. Stein (SBN 132540) 5235 West Allen Street Suite 200 Los Angeles, CA 90067 Tel: (213) 555-0994 Fax: (213) 555-0995 Attorneys for Plaintiff SCOTT ALAN WOODWARD UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SCOTT ALAN WOODWARD, Plaintiff, vs. B-2 VIDEO INCORPORATED, a Missouri corporation; and DOES 1 through 20 inclusive, Defendants. ) ) ) ) )))))) ))) )) ) ) ) ) )) Case No.: PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT B-2 VIDEO INCORPORATED ) PROPOUNDING PARTY: Plaintiff SCOTT ALAN WOODWARD RESPONDING PARTY: Defendant B-2 VIDEO INCORPORATED SET NO.: One 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Rule 34 of the Federal Rules of Civil Procedure, plaintiff Scott Alan Woodward (“Plaintiff”) requests that defendant B-2 Video Incorporated (“B-2”) produce for inspection and copying the documents requested below within 30 days of service hereof. REQUESTS REQUEST NO. 1: All DOCUMENTS (For the purpose of these interrogatories, the term “DOCUMENTS” is used in the broad sense and includes, but is not limited to, anything coming within the definition of “writings” and “recordings” set forth in Rule 1001(l) of the Federal Rules of Evidence) relating to or reflecting the facts and circumstances of any discipline of PLAINTIFF (For the purpose of these interrogatories, the term “PLAINTIFF” shall mean plaintiff Scott Alan Woodward) or concerning any alleged misconduct engaged in by PLAINTIFF. REQUEST NO. 2: Any and all video and/or audio investigation tapes reflecting the facts and circumstances of any alleged misconduct engaged in by PLAINTIFF. 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST NO. 3: All DOCUMENTS supporting or relating to YOUR (For the purpose of these interrogatories, the terms “YOU” or “YOUR” shall mean defendant B-2 Video Incorporated) Fifth Affirmative Defense that “Any and all alleged defamatory statements made by Defendants or their agents were true.” REQUEST NO. 4: All DOCUMENTS identified in YOUR responses to PLAINTIFF’S First Set of Special Interrogatories served concurrently herewith. REQUEST NO. 5: All DOCUMENTS identified in YOUR responses to PLAINTIFF’S First Set of Form Interrogatories served concurrently herewith. DATED: March 31, 2004 STEIN & ASSOCIATES By: _________________________________ Michael D. Stein Attorneys for Plaintiff SCOTT ALAN WOODWARD 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss: COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action. My business address is 5235 West Allen Street Suite 200, Los Angeles, CA 90067. On March 31, 2004, I served the foregoing document described as PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT B-2 VIDEO INCORPORATED on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Peter Crawford, Esq. 27255 Van Buren Road Torrance, California 93627 ___ BY MAIL I deposited such envelope into the Firm’s office mail at Los Angeles, California. I am readily familiar with the Firm’s practice of collection and processing correspondence for mailing. Under that practice, in the ordinary course of business, the mail is affixed with postage thereon fully prepaid and deposited with the U.S. Postal Service in Los Angeles, California on the same day. I am aware that on motion of a party served, service is presumed invalid if the postal cancellation date or the postage meter date is more than one (1) day after the date of deposit for mailing in this affidavit. ___ BY PERSONAL SERVICE I hand delivered such envelope to the offices of the addressee(s) listed above. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made. Executed March 31, 2004 at Los Angeles, California. _____________________________ Harriet Evans