Use Request for Production
Use a Request for Production when you want the other side to produce documents and things as well as a statement under oath that they have provided the documents or things requested, or what they haven't produced and why.
Before you start
A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
Typically, if you requested a document, but the other side claims it doesn't exist, you can object to the judge if they try to introduce the document at trial. This helps prevent surprise evidence at trial.
- Produce all account statements issued between the dates of January 1, 2019 and July 31, 2020 for the account alleged in the Complaint.
- Produce the contract alleged in the Complaint.
- Produce all photographs taken on or after May 12, 2020 showing any vehicle involved in the collision alleged in the Complaint.
- Allow access to and inspection and photographing of the plaintiff's vehicle involved in the collision described in the Complaint.
How to Request Production of Documents and Things
Download the template for Request for Production
There are many different templates available for Special Interrogatories. You can get a template from your local law library, or use the simple template below. In the template below, replace the text contained in [brackets] with your questions and delete the brackets. Other templates may be better suited for demands for inspection, or more specialized requests
Fill out basic information at the top
A few definitions that may help when you fill out the top of the template:
If either the plaintiff or defendant is a corporation, LLC, or other legal entity, use the name of the entity. If the entity name is long, you may abbreviate it.
The person who started the case is the Plaintiff, the person responding to the case is the Defendant.
You are the Asking Party. The other side is the Answering Party.
Set No. refers to the number of times you’ve sent interrogatories. Write “one” if this is the first time.
Choose a location for the other side to bring the documents
Select a place where you can easily make photocopies, such as a photocopy shop, or photocopying service.
The other side will bring the original documents to this location, and you are expected to make copies of the documents and return them immediately to the person delivering them.
Write the name and address for the photocopying shop or service you intend to use in the paragraph entitled "Place of Production." If you are not using an outside service, you may delete the name and use only the address.
Next, select a time and date for production.
The time must be during regular business hours and at least 30 days from the date you are having your Request for Production personally served.
If you are having the Request for Production served by mail, you must allow an additional 5 days, so set the date least 35 days from the date you will have the Request for Production served by mail.
Add your own definitions (if useful)
The second page has series of sample definitions. These definitions tell the person answering that any time they see this term in the questions (in uppercase letters) it should be defined as it is in the list of definitions.
Feel free to use them if they are useful for you, or delete them if they are not. Add your own definitions in the same format.
Write your requests for production
Write your requests for production in a list as shown in the template. Add each one as a numbered item.
Your request for production can request a described document, or a described category of documents.
examples of request wording
Produce the contract signed on September 14, 2020 by the plaintiff.
Produce all account statements for the account described in the complaint that were created between September 1, 2019 and September 31, 2020.
Produce all photographs of any of the vehicles involved in the collision on May 15, 2020 taken on or after May 15, 2020.
Sign and date the document
When you are done, sign and write the date at the end of the document.
Make a copy of your Request for production of documents for each attorney or self-represented party in your case. You will keep the original. They are not filed with the court.
Discovery from a party in your case
Once you’ve completed the form, you’ll serve it by mail to the other attorneys or self-represented parties.