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
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Get a template or create your own Request for Production
There is no form for a Request for Production, but you typically have to create it 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.
- You may also be able to get a template from your local law library, or ask your court's self-help center if they have one. Then, you can input information about your case in the template.
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Fill out basic information in the caption
A few definitions that may help when you fill out the caption, which is at the top of the form:
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The person who started the case is the Plaintiff, the person responding to the case is the Defendant.
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.-
You are the Asking Party. The other side is the Answering Party.
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Set No. refers to the number of times you’ve sent interrogatories. Write “one” if this is the first time.
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Choose a location for the other side to take 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.
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Add your own definitions (if useful)
After you specify the location to take the documents, you may want to add definitions. The 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.
Examples of definitions:
- YOU OR ANYONE ACTING ON YOUR BEHALF includes you, your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf.
- PERSON includes a natural person, firm, association, organization, partnership, business, trust, limited liability company, corporation, or public entity.
- DOCUMENT means a writing, as defined in Evidence Code section 250, and includes the original or a copy of handwriting, typewriting, printing, photostats, photographs, electronically stored information, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them.
- ADDRESS means the street address, including the city, state, and zip code.
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Write your requests for production
Write your requests for production in a list. Add each one as a numbered item.
Your request for production can request a described document, or a described category of documents.
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examples of request wording
Produce the contract signed on September 14, 2024 by the plaintiff.
Produce all account statements for the account described in the complaint that were created between September 1, 2013 and September 30, 2024.
Produce all photographs of any of the vehicles involved in the collision on May 15, 2024 taken on or after May 15, 2024.
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Sign and date the document
When you are done, sign and write the date at the end of the document.
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Make copies
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
What's next?
Once you’ve completed the form, you’ll serve it by mail to the other attorneys or self-represented parties.
