Plaintiff Attorney Legal Information CenterPreparing a strong case begins with effective discovery, and that requires precise and well-crafted document requests. This resource provides a comprehensive collection of sample requests for the production of documents in plaintiff’s personal injury cases, primarily drawn from litigation in Maryland. However, these requests are drafted broadly enough to serve as highly effective templates in other jurisdictions as well.
Whether you are looking for a sample request for production of documents Florida, Texas, or California, these materials can be easily adapted to comply with the rules and practices in those states. The requests for production examples included here are both practical and customizable, allowing attorneys to modify them based on the specific facts, procedural posture, and local rules applicable to each case.
In addition to traditional discovery methods, attorneys must now give careful attention to electronically stored information. This includes emails, cloud storage, text messages, and other digital records that can play a crucial role in personal injury and tort litigation. The sample materials provided here include examples of how to request electronic data effectively, along with guidance on common objections and how to respond to them.
So whether your case involves a slip and fall, medical malpractice, or a motor vehicle accident, these sample requests—drawn from both plaintiff and defendant perspectives—offer a clear framework for building strong discovery demands. While some examples are tailored to states like Florida, the underlying strategies can be adapted to most jurisdictions.
Documents can win cases. So it is never too soon to start planning document discovery. These sample requests are both boilerplate and carefully tailored to the individual case. You need both.
Sample Plaintiff’s Request for Production of Documents
Car Accident
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- Plaintiff’s Request in a car crash
- Plaintiff’s Request in a truck crash to the owner
- Plaintiff’s Request in a truck crash to the driver
- Plaintiff’s Request (uninsured motorist)
Medical Malpractice
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- Plaintiff’s Request (medical malpractice)
- Plaintiff’s Request (nursing home, with answers) [PDF]
- Plaintiff’s Request (birth injury)
Other Tort Claims
- Plaintiff’s Request (sexual abuse)
- Plaintiff’s Request (legal malpractice)
- Plaintiff’s Request (product liability – includes incredibly obstructionist defendant’s answers)
- Plaintiff’s Request (dog bite)
Example Defendants’ Request for Production of Documents
- Nursing home
- Car accident/brain injury
- Malpractice
- Truck crash (with answers/objections)
- Dog bite (with answers/objections)
Sample Requests for Production
Workplace Sexual Abuse of Minor Employee Case
Plaintiff J.R. was a 16-year-old high school student who began working in June 2024 at a franchised fast food restaurant in Prince George’s County, Maryland. During her employment, she reported inappropriate sexual comments and conduct by older male coworkers to shift supervisors and an assistant manager.
Plaintiffs allege the complaints were ignored, no meaningful action was taken, and J.R. was later sexually assaulted by an adult coworker on restaurant premises after closing. Plaintiffs further allege the franchisor and franchisee knew or should have known of prior similar incidents, failed to implement adequate hiring and supervision practices, failed to protect minor employees, and retained substantial control over restaurant operations, training, safety, and compliance.
These requests are directed to the franchisor defendant. (You could easily adapt them for the franchisee, management company, or property owner.)
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT FRANCHISOR
Pursuant to the applicable rules of civil procedure, Plaintiff requests that Defendant produce the documents and electronically stored information described below within the time required by the rules.
Definitions
For purposes of these requests:
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“Defendant” means the franchisor defendant, together with its parents, subsidiaries, divisions, affiliates, agents, employees, representatives, investigators, insurers, attorneys, and anyone acting on its behalf.
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“Restaurant” means the franchise location where Plaintiff worked and where the abuse is alleged to have occurred.
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“Franchisee” means the entity that owned or operated the Restaurant.
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“Plaintiff” means J.R., individually and through her parent or guardian.
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“Incident” means the sexual abuse, sexual assault, sexual harassment, grooming, or inappropriate sexual conduct alleged in this case, including the events leading up to it.
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“Document” means any written, printed, recorded, stored, or electronically maintained material of any kind, including emails, text messages, instant messages, chats, personnel files, policies, manuals, reports, memoranda, notes, photographs, videos, recordings, spreadsheets, databases, inspection forms, complaints, and drafts.
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“Communication” means any oral, written, electronic, or recorded transmission of information, including emails, text messages, internal messaging platforms, and handwritten notes memorializing conversations.
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“Minor employee” means any employee under the age of 18.
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“Relating to” means concerning, discussing, describing, evidencing, reflecting, mentioning, summarizing, or referring to in any way.
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If any responsive document is withheld under a claim of privilege, produce a privilege log identifying the date, author, recipients, general subject matter, privilege asserted, and basis for withholding.
Requests for Production
Request No. 1
Produce all insurance policies, excess policies, indemnity agreements, reservation of rights letters, and non waiver agreements that may provide coverage for any claim or judgment in this case.
Request No. 2
Produce all franchise agreements, amendments, addenda, operating agreements, compliance agreements, and related contracts in effect at any time from January 1, 2023 through December 31, 2024 concerning the Restaurant.
Request No. 3
Produce all documents showing the franchisor’s right to control, or actual exercise of control over, hiring, screening, supervision, training, security, staffing, workplace safety, reporting obligations, or employment practices at the Restaurant.
Request No. 4
Produce all operations manuals, employee handbooks, manager manuals, safety manuals, compliance manuals, workplace conduct policies, and sexual harassment or abuse prevention policies in effect during 2023 and 2024 that applied to the Restaurant or franchise locations in Maryland.
Request No. 5
Produce all prior versions and all later revised versions of the documents requested in Request No. 4 for the period January 1, 2020 through December 31, 2025.
Request No. 6
Produce all training materials used or approved by Defendant from January 1, 2023 through December 31, 2024 concerning:
a. sexual harassment prevention
b. reporting misconduct
c. protection of minor employees
d. workplace safety
e. employee supervision
f. hiring and screening
g. security procedures
h. closing procedures
i. anti grooming or abuse awareness
Request No. 7
Produce all orientation videos, safety videos, online modules, manager training presentations, and employee training presentations used or approved by Defendant from January 1, 2023 through December 31, 2024 concerning workplace conduct, employee safety, reporting misconduct, harassment prevention, or protection of minors.
Request No. 8
Produce all documents concerning the hiring, application, interview, screening, onboarding, discipline, suspension, complaints, evaluations, promotions, demotions, and termination of the alleged perpetrator.
Request No. 9
Produce all documents concerning the hiring, training, supervision, discipline, evaluations, and complaints involving any manager, supervisor, or assistant manager who received, should have received, or responded to complaints by Plaintiff or other employees about inappropriate sexual conduct at the Restaurant.
Request No. 10
Produce all documents reflecting complaints, reports, allegations, investigations, or concerns from January 1, 2020 through December 31, 2024 involving:
a. sexual harassment
b. sexual assault
c. inappropriate touching
d. grooming behavior
e. sexually explicit comments
f. misconduct toward minor employees
g. unsafe closing conditions involving minor employees
at the Restaurant.
Request No. 11
Produce all documents reflecting complaints, reports, allegations, investigations, or claims from January 1, 2020 through December 31, 2024 involving sexual harassment, sexual assault, or inappropriate sexual conduct toward minor employees at any franchise or corporate location in Maryland, Virginia, or the District of Columbia.
Request No. 12
Produce all lawsuits, claims, demand letters, administrative charges, agency complaints, or internal legal notices from January 1, 2020 through December 31, 2024 alleging sexual abuse, sexual assault, sexual harassment, or grooming of a minor employee at any franchised or corporate location in Maryland, Virginia, or the District of Columbia.
Request No. 13
Produce all communications between Defendant and the Franchisee relating to:
a. Plaintiff
b. the alleged perpetrator
c. sexual harassment complaints
d. reports of inappropriate conduct
e. safety of minor employees
f. staffing of minors
g. the Incident
from January 1, 2024 through December 31, 2024.
Request No. 14
Produce all communications between Defendant and any insurer relating to:
a. the Incident
b. Plaintiff’s allegations
c. prior sexual misconduct allegations at the Restaurant
d. prior abuse or harassment claims involving minor employees
Request No. 15
Produce all site visit reports, audits, compliance reviews, inspections, risk assessments, safety reviews, brand standard evaluations, or corrective action reports concerning the Restaurant from January 1, 2023 through December 31, 2024.
Request No. 16
Produce all blank inspection forms, audit forms, checklists, scorecards, compliance templates, or review forms used by Defendant during 2023 and 2024 to evaluate franchise locations for employee safety, workplace conduct, staffing, or compliance.
Request No. 17
Produce all documents identifying what standards, failures, violations, or conditions would permit Defendant to issue warnings, require corrective action, suspend operations, terminate a franchise, or declare a default based on employment practices, safety issues, harassment complaints, or failure to protect minor employees.
Request No. 18
Produce all documents reflecting any requirement imposed by Defendant that franchise locations maintain specific staffing, security, supervision, or closing procedures for minor employees.
Request No. 19
Produce all job descriptions, role descriptions, and duty statements in effect during 2024 for crew members, shift leaders, assistant managers, general managers, district managers, and any person responsible for employee supervision or safety at the Restaurant.
Request No. 20
Produce all employment applications, background check authorization forms, screening questionnaires, interview guides, and hiring criteria used or approved by Defendant during 2024 for non managerial employees and managers at franchise restaurants.
Request No. 21
Produce all documents reflecting whether background checks, reference checks, immigration verification, age verification, or criminal history screens were required, recommended, or optional for employees or managers at the Restaurant during 2024.
Request No. 22
Produce all internal communications, memoranda, presentations, meeting minutes, white papers, or reports from January 1, 2020 through December 31, 2024 reflecting Defendant’s awareness of the risk of sexual abuse, sexual harassment, grooming, or exploitation of minor employees in franchised restaurant settings.
Request No. 23
Produce all documents reflecting communications between Defendant and the Franchisee concerning prior allegations of misconduct by the alleged perpetrator or any other employee accused of sexually inappropriate conduct at the Restaurant.
Request No. 24
Produce all witness statements, interview summaries, investigation notes, recorded statements, or written reports relating to the Incident or to prior complaints of sexual misconduct at the Restaurant.
Request No. 25
Produce all surveillance video, security footage, access control logs, alarm records, point of sale login records, schedule records, time clock records, and closing checklists for the Restaurant for the date of the Incident and the seven days before and after.
Request No. 26
Produce all schedules, staffing rosters, shift assignments, manager schedules, and employee time records for the Restaurant for the date of the Incident and the thirty days before.
Request No. 27
Produce all documents reflecting how the Restaurant was required to report employee misconduct, harassment complaints, abuse allegations, or threats to employee safety to Defendant.
Request No. 28
Produce all documents reflecting any report made to Defendant concerning Plaintiff, the alleged perpetrator, or the Incident, including hotline complaints, ethics reports, HR complaints, compliance reports, and legal department notifications.
Request No. 29
Produce all documents showing what action, if any, Defendant took after learning of Plaintiff’s complaints or after learning of the Incident, including suspension decisions, franchise intervention, investigation steps, training changes, or policy revisions.
Request No. 30
Produce all documents reflecting any remedial measures, policy changes, training changes, supervision changes, security changes, or reporting changes implemented after the Incident to address the safety of minor employees.
Request No. 31
Produce all documents reflecting joint advertising, brand standards, mandatory appearance requirements, or public facing uniformity requirements imposed by Defendant on franchise locations in Maryland during 2024.
Request No. 32
Produce all documents reflecting the financial reporting, operational reporting, compliance reporting, or audit reporting that the Franchisee was required to provide to Defendant during 2023 and 2024.
Request No. 33
Produce all documents reflecting the Restaurant’s ownership, management structure, corporate relationship to Defendant, or any change in ownership or operational control from January 1, 2023 through December 31, 2024.
Request No. 34
Produce all communications with public relations firms, crisis management consultants, or media personnel concerning the Incident or allegations of sexual abuse, sexual assault, or harassment involving minor employees.
Request No. 35
Produce all electronically stored information, including emails, text messages, chat messages, Slack or Teams messages, and phone notes, sent or received by any district manager, franchise business consultant, HR representative, compliance officer, or in house counsel relating to the Incident, Plaintiff, the alleged perpetrator, prior complaints, or minor employee safety.
| Category | What to Request | Why It Matters |
|---|---|---|
| Notice | Prior complaints, incident reports, prior lawsuits, prior claims, internal warnings, hotline reports | Shows the defendant knew or should have known about the danger before your client was hurt |
| Control | Franchise agreements, policies, manuals, audit forms, inspection reports, compliance requirements | Helps prove who actually controlled the people, premises, safety rules, or operations |
| Hiring and Supervision | Personnel files, applications, background checks, training materials, discipline records, evaluations | Supports negligent hiring, retention, supervision, and failure to train claims |
| What Happened | Surveillance video, schedules, time records, emails, texts, witness statements, investigation files | Locks down the facts, timeline, staffing, and internal response to the incident |
| Electronic Evidence | Emails, text messages, Slack or Teams chats, cloud files, metadata, phone logs, access logs | This is often where the most candid evidence lives, especially when the paper file is thin or sanitized |
Federal Rule of Civil Procedure 34 – Requests for Production of Documents and ESI
Federal Rule of Civil Procedure 34 is the go-to tool for obtaining documents and electronically stored information (ESI) during discovery in federal court. Most states have a rule very similar if not identical to Rule 34. It is not flashy, but it is foundational. This is how you get the emails, contracts, text messages, spreadsheets, and metadata that make or break a case.
This rule lets a party request the production of documents, tangible items, or entry onto land for inspection. But in the modern era, it is mostly about ESI. Email servers, Slack messages, internal databases, cloud backups, and all the messy data that lives in places litigants often pretend they did not know existed.
Reasonable Particularity and Production Requirements
According to Rule 34(b), a requesting party must:
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Describe with reasonable particularity each item or category of items to be produced. This means that vague, overly broad, or generic requests are disfavored. Instead, the request must clearly identify what is being sought so the responding party can fairly respond without undue burden or guesswork.
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Specify a reasonable time, place, and manner for the production. This is particularly important when ESI is involved, as the format and method of production (e.g., PDF, native format, metadata included) can significantly affect both the utility and cost of the produced materials.
Cost and Objections
Generally, the responding party bears the cost of production. However, courts have discretion to shift costs or limit the scope of production if it is determined that compliance would impose an undue burden or expense, particularly in cases involving massive volumes of data or inaccessible sources. Judges will often weigh the proportionality of the request, balancing the relevance and importance of the requested materials against the burden of producing them.
If a party objects to a Rule 34 request, the objection must be stated with specificity. Blanket or boilerplate objections—such as simply stating that a request is “overly broad” or “unduly burdensome” without further explanation—are insufficient. Similarly, a party cannot outright refuse to produce responsive documents without justification.
The rules require parties to engage in good faith efforts to meet their discovery obligations. Courts have little patience for gamesmanship or evasive conduct. And crucially, objections must be raised during the discovery process, not at trial. Failing to assert discovery rights or make proper objections in a timely manner can result in waiver, meaning the party loses the opportunity to challenge the request later on.
Maryland Rule 2-422
Maryland Rule 2-422 governs requests for the production of documents in civil litigation and is a critical tool for personal injury attorneys seeking to build a strong evidentiary foundation. This rule allows a party to require the opposing party—most often the defendant in personal injury litigation—to produce documents, tangible things, or electronically stored information (ESI) within their possession, custody, or control that are relevant to the claims or defenses at issue. In car accident and truck accident cases, this often includes insurance documents, repair records, vehicle maintenance logs, photographs, dash cam footage, employment files (in commercial vehicle claims), and any other materials that may shed light on liability or damages.
Subsection (b) of Rule 2-422 specifically requires that each request “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 mirrors the language and intent of Federal Rule of Civil Procedure 34, which means Maryland practitioners can rely on federal case law interpreting Rule 34 when litigating the scope or sufficiency of a Rule 2-422 request. The emphasis on “reasonable particularity” helps to prevent fishing expeditions while also requiring defendants to engage with the requests in good faith.
A common misconception among attorneys is that Maryland imposes a numerical limit on how many document requests may be served, often believed to be 30, as is the case in some jurisdictions. We have had defense lawyers make objections saying exactly this. But it is incorrect.
Maryland imposes no formal limit on the number of document requests a party may issue. In practice, personal injury lawyers in Maryland often receive and serve more than 100 requests for production of documents, particularly in serious injury cases where multiple theories of liability, defenses, and damages must be thoroughly explored. The absence of a numerical cap provides flexibility to request documents across a wide range of topics, as long as they are relevant and proportionate to the needs of the case.
Attorneys should use this rule aggressively and strategically. Well-drafted document requests are often the gateway to identifying additional evidence, strengthening your client’s claims, and compelling a settlement. As illustrated in our sample request for production of documents provided above, detailed and comprehensive discovery is not only permitted under Rule 2-422, it is essential.
More Samples You Can Use
The defendant has 30 days in Maryland (33 days if served by mail) after service of the request, unless the request is served before the date the defendant’s initial pleading or motion is required. In that 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 RFPD with the Complaint, the latter rule is usually applicable.
The defendant must provide a response stating whether he/she/it will comply with 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, particularly in serious injury cases, typically object to document requests initially because it takes real effort from the defendant’s attorney to comply with the request. Competent counsel stays on the defendants to ensure compliance with their discovery obligations.
Providing Help to Other Lawyers
Most of our personal injury cases come from referrals from other lawyers. You can collect a fee in accordance with our ethical rules while transferring primary responsibility for your case to us.
- Discovery samples, including depositions, interrogatories, requests for production of documents, etc.)
- Trial documents (transcripts, jury instructions, you name it)
Electronic Discovery
In 2025, more than 99% of information will be created and housed electronically. Personal injury attorneys have to do a good job from the beginning of the case to figure out what electronic discovery is. They need to know and how the defendant is going to produce it.
The key is to ask the right questions to elicit information on how the records are stored and how to access them. You also need to be cautious about accepting things at face value.
Most defense lawyers reflexively tell you that producing the electronic information you need is just too difficult to pull up. Too many plaintiffs’ lawyers, and ultimately, judges, accept these excuses because they don’t fully appreciate the technology to see through the nonsense.
- Court ruling on cell phone records production
- Motion to compel production of records from Microsoft
Getting Help (or Co-Counsel) for Your Case
If you need assistance with your personal injury case, call 800-553-8082 or schedule a free, no-obligation online consultation. This offer is both for potential clients and referring lawyers throughout the United States. Our firm handles only serious personal injury accidents, malpractice, and product liability cases. But we are nice people! So we will offer direction on any tort case.