Sample Requests For Production of Documents

     Maryland Rule 2-422 allows accident and medical malpractice lawyers in Maryland the opportunity to require the defendant to produce documents in defendant's possession that relate to the car or truck accident. Subsection (b) provides that the request must set forth the items to be inspected, ''either by individual item or by category, and shall describe each item and category with reasonable particularity.'' This language tracks the language used in Federal Rule of Civil Procedure Rule 34. There is no limit in Maryland on the number of requests a personal injury lawyer can make.
     The defendant has 30 days in Maryland (33 if send by mail) after service of the request unless the request is served before the date Defendant's initial pleading or motion is required, in which case the responding party has until 15 days after the time for responding to the initial pleading. Because our lawyers file the bulk of our requests for production of documents with the Complaint, the latter rule is usually applicable.

     The Defendant must provide a response stating whether he/she will comply wit the request. Specific grounds or reasons must be given with some specificity explaining why the request for documents is overly broad or the reasons why having to produce the documents would be unduly burdensome. Defense lawyers in Maryland, particularly in serious medical malpractice and truck accident cases, typically object to document requests initially because it takes real effort from the defendant's attorney to comply with the request. A good accident or malpractice lawyer needs to stay on the defendant's attorney to ensure compliance with their discovery obligations.

Back to Sample Discovery (depositions, interrogatories, requests for production of documents, etc.)
Back to Injury Lawyer Help Center (sample pleadings, opening statements, jury instructions, etc.)

See also Maryland Medical Malpractice Lawyer Blog
See also Maryland Accident Lawyer Blog