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Example Request for Production of Documents

Below is a sample request for production of documents in a motor vehicle crash case that later settled for $750,000. 

This is a general first set request for admissions that is narrowly tailored to the specific facts of the case. Near the end of discovery, it is wise to send out a more case-specific set to tie up any loose ends and follow-up on information obtained over the course of discovery.

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

AMY WHITE,
- Plaintiff
v
BOBO HARMON, et al,
- Defendants

CASE NO.: 05-C-06-6511

Plaintiff’s Request for Production of Documents to Defendants

TO: BOBO HARMON and JACK HARMON, Defendants
FROM: AMY WHITE, Plaintiff

You are requested to file within thirty (30) days a written response to request on the (attached Document Schedule) and to produce those documents for inspection and copying on

More Information
  1. Your written response shall state for each item or category, that inspection-related activities will be permitted as requested, unless the request is refused (if this is the case, please state basis for  refusal and, if the refusal relates to part of an item or category, identify the part so we can worth together to best deal with it).
  2. Per the Maryland Rules, the documents shall be produced as they are covered in the usual course of business or you shall organize and label them to correspond with the categories in the request.
  3. These requests shall encompass all items within your possession, custody, or control.
  4. These requests are continuing in character, requiring you to promptly amend or supplement your response if you obtain further material information.
  5. If in responding to these requests you encounter any ambiguity in construing any request, instruction, or definition, set forth the matter deemed ambiguous in the construction used, in responding.
DEFINITIONS

As used in these requests, the following terms are to be interpreted under these definitions:

  1. The term "person" includes any individual, joint-stock company, unincorporated association or society, municipal or other corporation, state, which agencies or political subdivisions, and court, or any other governmental entity.
  2. The terms "you" or "your" include the persons to whom these requests are addressed, and all that person's agents, representatives, or attorneys.
  3. In accordance with the Maryland Rules, the terms, "document" or "documents" includes all writings, drawings, graphs, charts, photographs, recordings, and any other data computations from which information can be obtained, translated, if necessary by (you), through detection devices, into a reasonably usable form.
  4. The term "occurrence" means the incident complained out in the Plaintiff's complaint, specifically the car accident involving the parties on November 10, 2020. 
DOCUMENTS TO BE PRODUCEDsample requestion production documents
  1. All documents identified in your answers to Interrogatories.
  2. All written, recorded, and/or signed statements of any person, including the Plaintiffs, Defendant, witnesses, investigators, or any agent, representative, or employee of the parties, concerning the subject matter of this action.
  3. All photographs, videotapes or audiotapes, x-rays, diagrams, medical records, surveys, or other graphic representations of information concerning the subject matter of this action, the Plaintiffs, or other damage.
  4. Any documents which afforded liability insurance for the incident which is the subject matter of the Plaintiffs' Complaint.
  5. Any documents received under any subpoena request of any party.
  6. Any document prepared during the regular course of business as a result of the incident complained of in the Plaintiffs' Complaint, including recorded statements of witnesses and persons involved in the subject collision.
  7. All maintenance records concerning the vehicle and equipment used by Defendant on the date of the accident for the two (2) years before the accident.
  8. Any invoices, logs, sales receipts, itineraries, or schedules for Defendant if Defendant was driving and operating equipment in the scope of his employment.
  9. Your cell phone records, including call logs and data usage logs, for the day of the accident.
EXPERT WITNESS DOCUMENTATION
  1. All written reports, and drafts, of each person whom you expect to call as an expert witness at trial.
  2. All documents upon which any expert witness you intend to call at trial reviewed to form any opinions.
  3. The most recent resume or curriculum vitae of each expert whom you expect to call as an expert witness at trial.
  4. Any list of cases maintained by any expert witness identified in which the witness has testified as an expert at trial or by deposition.
  5. All written reports, including drafts, of each expert you intend to call at trial.
  6. All notes, diagrams, photographs, medical records, medical bills, medical literature, case studies, research articles, x-rays, radiological films, or any other documents prepared or reviewed by each person whom you expect to call as an expert witness at trial.
  7. All bills or invoices generated by each expert witness for performing expert witness services for you in this case, including but not limited to, the fees for the medical examination, the records review, the pretrial preparation, any telephone conference, any trial testimony anticipated, and any other fee or bill paid by the Defendant for forensic services.
  8. Any correspondence, including e-mails, etc., exchanged between representatives for Defendant and each expert.
  9. The current fee schedule for each expert whom you expect to call as an expert witness at trial.
  10. 1099 forms for each expert witness sent by any insurance company or law firm that compensated the expert for forensic work performed for the last two years.
  11. Quickbooks, Quicken, Timeslips, or any other accounting documents that demonstrate each of Defendant's expert's fees associated with forensic work.
  12. Tax returns for the past three years documenting payments from any insurance company to each expert whom you expect to call as an expert witness at trial.
  13. Each publication, treatise, book or chapter thereof, literature, studies, academic or scholarly articles, journals, papers, pamphlets, peer-reviewed articles, or other documents in your possession, custody, or control which you or your experts will use as evidence that Plaintiff's injuries were not caused, or not exacerbated, by the Incident. (If the document is protected by copyright, disclosure of the identity of the document, e.g., via identification in an expert's report, will suffice).
  14. Every publication, treatise, book or chapter thereof, literature, studies, academic or scholarly articles, journals, papers, pamphlets, peer-reviewed articles, or other documents which you or your experts will use as evidence that Plaintiff's injuries were not caused, or not exacerbated, by the Incident. (If the document is protected by copyright, disclosure of the identity of the document, e.g., via identification in an expert's report, will suffice).
  15. Every publication, treatise, book or chapter thereof, literature, studies, academic or scholarly articles, journals, papers, pamphlets, peer-reviewed articles, or other documents which is part of the whole of the foundation for the opinion, which you or your experts will use as evidence that Plaintiff's injuries were not caused, or not exacerbated, by the Incident. (If the document is protected by copyright, disclosure of the identity of the document, e.g., via identification in an expert's report, will suffice).
  16. Any document that you may introduce into evidence or refer to at trial.

It is requested that the aforesaid production be made within thirty (30) days of service of this request at the offices of Law Offices of Miller & Zois, LLC, 1 South St, #2450, Baltimore, MD 21202.

Respectfully submitted,
Miller & Zois, LLC

Ronald V. Miller, Jr.
Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (fax)
Attorneys for the Plaintiff

In litigation with voluminous documents, requests for production and the required responses can become mired in confusion. The discovery plan should anticipate the possibility of overlooked requests, costly responses, obscured failures to respond, and uncertainty about the specifics of requests and production.

After Serving Requests for Production of Documents 
Defense lawyers often do not produce all the sought documents that could lead to admissible evidence.  Usually, this is by mistake but it can be intentional, too. So good lawyers anticipate this by looking for possible missing documents, what should be there that is not. Also, fight back on any efforts to claim privilege by making sure they fully explain the basis for attorney-client privilege or work product.

Authenticate the Records You Need for Trial 
You want to establish the foundation for admission of documents you want to present to the jury long before trial.  Use request for admissions to get these admissions and, if that fails, make sure you have witnesses who can properly authenticate the documents.  


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