Respond to Request for Production

When you receive a Request for Production, the other side is asking you to hand over a document or item, usually to be copied. Sometimes, this is called a Demand for Inspection.


You have 30 days to respond to a Request for Production. If you were served by mail, you typically have 35 days from the date of mailing to respond.

Before you start

Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection.

Responding to the request has 2 parts: 

  • State if you can comply with the request (all of it or some of it) or give the reason why you can’t comply.

  • Produce the documents or items requested according to the directions in the request. This might be sending by mail, delivering in person, etc.

You might be asked to produce a category of documents or things and you may get asked for a single specific item.

  • Example: Requesting a category 

    Produce all account statements between the dates 11/01/2019 and 6/1/2019 

  • Example: Request a single item 

    Produce an account statement dated 5/7/2019

How to respond to Requests for Production

  • Download the blank response template and fill in basic information

    There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number. This is called "pleading" paper. You may create pleading paper in your word processor, or download the sample pleading paper captioned and formatted for your answer below:

    The checkbox version is best for completing responses in handwriting, while the blank one is best for typing your responses.

  • Prepare the template for your responses

    Complete the top portion

    Complete the top caption with your name, address, and phone number, the names of the parties in your case, and case number. Copy the name of the Asking Party, Answering Party, and Set Number from the Request for Production.

    Make a list of the items requested

    Whether on a form or not, the Request for Production will have a numbered list of documents or items they want you to produce.

    Make a list in the template. For each item, write “Response to Request for Production Number” followed by the number of the request.

    • example

      Response to Request for Production Number 1: 

      Response to Request for Production Number 2: 

      Response to Request for Production Number 3: 

  • Read and answer the questions

    Read the request very carefully. If you are using the checkbox response, check the appropriate response for each category. If you are typing responses, type in one of the following responses:

    • If you have the documents and are producing them

      Check or type: “I will allow this request in whole and will provide the documents or things as requested.”

    • If there are no documents to turn over, and no such documents have ever existed

      Check or type: "I cannot comply with the request because no such documents or things exist. A diligent search and reasonable inquiry have been made in an attempt to comply with this demand.”

    • If you had them at one time, but no longer have them

      Check or type: “I cannot comply with the request because the documents or things are no longer in my possession and control. These items are as follows:” followed by a description of what documents you know of, and why you no longer have them.

    • If you have some, but no longer have all of the documents or things requested

      Check or type: “I will allow the request in part but cannot wholly comply because some of the requested items are no longer in my possession and control. These items are as follows:” followed by a description of what you are not producing, and why those documents are no longer in your possession

    If you falsely deny a document exists,

     you will not be allowed to introduce the document at trial. 

    It is also possible that you might object to one or more of the requests. To raise an objection you would write “Responding party objects on the grounds” followed by the basis of your objection(s). 

    Example common objections

    Answers and objections can be complicated, 

    so you may consider hiring an attorney to assist with or review your responses before you send them.


  • Sign the document

    Once you are done, date and sign under the language “I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct.” By signing, you are stating that your answers are true and you could be prosecuted for perjury if they are not.

    This perjury language is called a “verification,” and is required unless your responses contain only objections. For anything other than objections, if this language is missing it is considered the same as not responding at all.

Responding to discovery requests

What's next?

After you complete your response, you’ll need to produce the documents or items in the way that the Request describes.

You also must share your response with the opposing side. You follow a specific court process to do this called serving papers.

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