IN THE SUPERIOR COURT OF THE STATE OF <YOUR STATE>
IN AND FOR THE COUNTY OF <YOUR COUNTY>
MIDLAND CREDIT MANAGEMENT )
Plaintiff ) Case No._____________________
) REQUEST FOR PRODUCTION,
Joseph Consumer ) OF DOCUMENTS
Pursuant to Rule 34 of the Federal Rules of Civil Procedure, plaintiff Joseph Consumer requests
that the defendant produce the following described documents for inspection and copying by
Plaintiff at a time and place to be mutually agreed upon by the parties within thirty days of
service thereof. This request is continuing in nature, and in the event you become aware of or
acquire in your possession, custody or control, additional responsive documents, you are asked
promptly to produce such additional documents for inspection and copying.
For the purposes of this request for production, the following definitions control:
A. "Documents" are documents, records, books, papers, contracts, memoranda, invoices,
correspondence, notes, studies, reports, photographs, drawings, charts, maps, graphs, other
writings, recording tapes, recording discs, mechanical or electronic information or recording
elements, and any other "documents" as defined in Rule 34, Fed. R. Civ. P. If a document has
been prepared in several versions, or if additional copies have made which are not identical or
are no longer identical by reason of subsequent notation or marking of any kind, each
nonidentical copy is a separate document.
B. "Relating" means referring to, being evidence of, memorializing, or concerning in any
way all or any portion of the specified facts or contentions.
1. All copies of all credit reports produced by Defendant since 2003
2. All documents and correspondence from Defendant to furnishers of information on
Plaintiff’s credit report, past or present.
3. All documents and correspondance sent from furnishers of information on Plaintiff’s
credit report, past or present, to Defendant
4. All returned/completed documents and correspondence sent from furnishers of
information on Plaintiff’s credit report, past or present, to Defendant
5. All documentation relating to any consumer dispute investigations conducted on
Plaintiff’s behalf since 2004.
Joseph R. Consumer