These sample requests for documents are for use in a Federal civil case under rule 34 of the Federal Rules of Civil Procedure. The sample includes some brief instructions and a proof of service by mail. The author is a freelance paralegal with over 15 years of experience in California and Federal civil litigation and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.
1 Any Party Any Street 2 Any Town, CA 55555 3 714-555-5555 4 Plaintiff, In Pro Per 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRI CT OF CALIFORNIA 10 11 Any Plaintiff, ) Case No. ) 12 Plaintiff, ) DEMAND FOR P RODUCTION OF DOCUMENTS, ) SET ONE 13 vs. ) ) 14 Any Defendant, and DOES 1-5 ) ) 15 Defendants. ) ) 16 ) ) 17 18 PROPOUNDING PARTY: Any Plaintiff 19 RESPONDING PARTY: Any Defendant 20 SET NUMBER: One 21 DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE 22 23 TO ANY DEFENDANT AND HIS COUNSEL OF RECORD: 24 Pursuant to the provisions of Federal Rule of Civil Procedure 34, it is hereby requested and 25 demanded of Defendant ______________________, that YOU respond separately, under oath and in 26 writing, to each and every category of documents set forth herein, within thirty (30) days of service of 27 this request. 28 - 1 - DEMAND FOR PRODUCTION OF DOCUMENTS 1 PLEASE TAKE NOTICE THAT, within thirty (30) days of service of this request, you 2 directed to produce for inspection and copying of the same, all the documents and materials described 3 below which are in your possession, custody, and/or control to the ADDRESS WHERE YOU 4 WANT DOCUMENTS SENT. Unless otherwise indicated, a copy of the documents requested shall 5 be sufficient for this production of documents. 6 7 Dated________________ _______________________________________________ 8 ANY PLAINTIFF 9 10 Remember that there is no numerical limit for production of 11 documents unless there is a local rule that says otherwise. So be sure to 12 13 check the local rules for your Court. 14 15 These documents requests are designed to be asked by the 16 Plaintiff but can be modified for use by a defendants in a Federal Court 17 18 case. 19 PRODUCTION CATEGORIES 1 20 REQUEST NUMBER 1 21 22 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 23 INFORMATION in support of YOUR contention, if YOU so contend, that YOU are not responsible 24 for the damages suffered by PLAINTIFFS. 25 REQUEST NUMBER 2 26 27 1 28 Please see infra for definit ions. - 2 - DEMAND FOR PRODUCTION OF DOCUMENTS 1 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 2 INFORMATION in support of YO UR responses to the written interrogatories, set one, concurrently 3 served on you by PLAINTIFFS. 4 REQUEST NUMBER 3 5 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 6 7 INFORMATION identified in YOUR response to Special Interrogatory Number 4 co ncurrently 8 served on you by PLAINTIFFS. 9 REQUEST NUMBER 4 10 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 11 INFORMATION identified in YOUR response to Special Interrogatory Number 7 concurrently 12 13 served on you by PLAINTIFFS. 14 REQUEST NUMBER 5 15 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 16 INFORMATION identified in YOUR response to Special Interrogatory Number 10 concurrently 17 served on you by PLAINTIFFS. 18 19 REQUEST NUMBER 6 20 Any and all DOCUMENTS, FILES, RECORDS, or ELECTRONICALLY STORED 21 INFORMATION identified in YOUR response to Special Interrogatory Number 13 concurrently 22 ser
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