Request for Production – Standard Requests
REQUEST FOR PRODUCTION
REQUEST 1: Produce {specify documents or other items to be produced or inspected, either by individual item or by category, and describe with reasonable particularity each item and category}.
REQUEST 2: Produce the following {documents/tangible things} for testing and sampling: {identify items for testing and sampling}. The {documents/tangible things} will be {sampled/tested} by {describe specific means, manner, and procedure for testing or sampling and identify to what extent the testing or sampling will destroy the item}.
REQUEST 3: Produce {medical/mental-health} records regarding {name}, a nonparty. {See note below.}
REQUEST 4: Produce all {electronic/magnetic} data relating to {identify subject} in the following form: {specify the form in which data must be produced and any extra steps necessary for retrieval and translation}.
REQUEST 5: Produce any and all communications and documents sent to or received from, or exchanged by and between you and {party} and {his/her/its} agents, employees, or representatives concerning the subject matter of this lawsuit.
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