i _____________________ REQUEST FOR DOCUMENTS 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 STATE/LOCAL COURT RULES? 1. CCP Section 2031 SPECIAL RULES OR OTHER REQUIREMENTS 1. May only be served on other parties 2. Plaintiff must wait 10 days after the defendant is served with the complaint or appears in the action before serving document request. Defendant can serve document request at any time. 3. No limit 4. The party serving the document request keeps custody of the original and serves copies on the responding party and on all other parties that have appeared in the action. 5. Responses (indicating intent to produce the requested documents, inability to comply or objections) must be verified and served, and documents produced, within 30 days if the document request was personally served and 35 days if the document request was mail served.1 _____________________ REQUEST FOR DOCUMENTS 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 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES SCOTT ALAN WOODWARD, Plaintiff, vs. B-2 VIDEO INCORPORATED, a California corporation; and DOES 1 through 20 inclusive, Defendants. ) ) ) ) )))))) ))) )) ) ) ) ) )) Case No.: ASSIGNED FOR ALL PURPOSES TO JUDGE JOHN SMITH Department 27 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 _____________________ REQUEST FOR DOCUMENTS 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 Code of Civil Procedure Section 2031, 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. DEFINITIONS 1. “YOU” or “YOUR” or “YOURSELF” refers to defendant B-2 Video Incorporated, its divisions, subsidiaries, affiliated entities, predecessors and successors in interest, and all officers, servants, employees, agents, representatives, persons or entities acting on its behalf or on behalf of any division, subsidiary or affiliated entity, whether individually or collectively. 2. “PLAINTIFF” refers to plaintiff Scott Alan Woodward. 3. “DOCUMENT” or “DOCUMENTS” are used in the broad sense and include, but are not limited to, anything coming within the definition of “writings” and “recordings” set forth in California Evidence Code Section 250. Without limiting the foregoing, the terms “DOCUMENT” and “DOCUMENTS” include, but are not limited to, the following items in YOUR actual or constructive possession, custody or control, whether such items are typed, printed, recorded, stored in a computer, reproduced by any mechanical process, copied or written by hand: contracts, 3 _____________________ REQUEST FOR DOCUMENTS 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 communications, correspondence, telegrams, memoranda, statements, records, reports, books, summaries and/or records of telephone conversations, summaries and/or records of personal conversations, lists, manuals, databases, quotes, bids, rating methodology, diaries, forecasts, orders, bills, invoices, checks, studies, graphs, charts, accounts, work papers, indexes, data sheets, data processing cards, analytical records, minutes and/or records of meetings and conferences, reports and/or summaries of interviews, reports and/or opinions of consultants, accountants and/or financial advisors, e-mail transmissions, records, reports and/or summaries of negotiations, brochures, lists, periodicals, pamphlets, circulars, trade letters, newspaper clippings, press releases, notes, projections, drafts, working papers, copies, marginal notations, photographs, drawings, tape recordings, financial statements, and all other written, printed, recorded or graphic matter, however produced, reproduced and/or stored. REQUESTS REQUEST NO. 1: All DOCUMENTS relating to or reflecting the facts and circumstances of any discipline of PLAINTIFF or concerning any alleged misconduct engaged in by PLAINTIFF. /////////4 _____________________ REQUEST FOR DOCUMENTS 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. 2: Any and all video and/or audio investigation tapes reflecting the facts and circumstances of any alleged misconduct engaged in by PLAINTIFF. REQUEST NO. 3: All DOCUMENTS supporting or relating to YOUR 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 5 _____________________ REQUEST FOR DOCUMENTS 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 documents 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 State of California that the foregoing is true and correct. Executed March 31, 2004 at Los Angeles, California. _____________________________ Harriet Evans