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Sample Requests For Production of Documents

Our firm handles serious injury tort cases. We have handled virtually every type of injury claim imaginable in a civil case. 

We provide here a list of example request for production of documents in various tort cases:

Plaintiff's Request for Production of DocumentsRequest Production DocumentsExample Defendants' Request for Production of Documents

Maryland Rule 2-422 allows 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. (Everyone seems to think it is 30. It is not.)

More Samples You Can Use
  • Get sample discovery, interrogatories, depositions, etc.
  • Review demand packages for settlement

The defendant has 30 days in Maryland (33 days if sent by U.S. 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 RFPD with the Complaint, the latter rule is usually applicable.

The Defendant must respond stating whether he/she will comply with the request. Specific legal 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.

In some cases where the parties have had previous dealings, some lawyers think requests for documents are unnecessary because everyone knows what the key documents are. Make the "official" request anyway. You may be amazed at what you get.

Defense lawyers in Maryland, particularly in severe injury cases typically object to document requests initially because it takes a real effort from the defendant's attorney to comply with the request. Smart counsel stays on top of 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. Learn how you can still collect a fee within our ethical rules while transferring primary responsibility for your case to us.

  • Get discovery samples, including depositions, interrogatories, requests for production of documents, etc.)
  • Get trial documents (transcripts, jury instructions, you name it)
  • Get sample pleadings, opening statements, jury instructions, etc.)
Electronic Discovery

In 2021, more than 99% of information now being created is housed electronically. Personal injury attorneys have to do a good job from the beginning of the case to figure out what electronic discovery they need and how the defendant is going to produce it. 

The big thing is to make sure you are asking the right questions to elicit information on how the records are stored and how to get to them. You also really need to make sure you are accepting little 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.

Getting Help (or Co-Counsel) for Your Case

If you are looking for assistance in handling your personal injury case, call 800-553-8082 or get a free online no obligation consultation. This offer is both for potential clients and referring lawyers throughout the United States. Our firm handles only serious personal injury accident, malpractice, and product liability case. But, we are nice people and, where we can, we will offer direction in any tort case.

Client Reviews
They quite literally worked as hard as if not harder than the doctors to save our lives. Terry Waldron
Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Aaron Johnson
Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Bridget Stevens
The last case I referred to them settled for $1.2 million. John Selinger
I am so grateful that I was lucky to pick Miller & Zois. Maggie Lauer
The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Suzette Allen
The case settled and I got a lot more money than I expected. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Nchedo Idahosa