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Any Defendant Any Street Anytown, California 55555 Telephone: (714) 555-5555 Defendant, In Pro Per SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF _______________
Any Plaintiff, Plaintiff, vs. Any Defendant, and DOES 1-5 Defendant.
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Case No.: REQUEST FOR PRODUCTION DOCUMENTS, SET ONE TO DISMISS Date: ______, 2011 Time: Dept.: OF
PROPONDING PARTY: RESPONDING PARTY: SET NO.: TO:
ANY DEFENDANT ANY PLAINTIFF ONE
PLAINTIFF, ____________________, AND HIS ATTORNEYS OF RECORD.
PLEASE TAKE NOTICE THAT pursuant to California Code of Civil Procedure sections 2031.010-2031.510, et. seq., plaintiff/cross-defendant [Name] (“Plaintiff”) demands that on [Date] at [Time] defendants [Name]. (collectively the “Defendants” or “Responding Party” and/or individually “Defendant” or “Responding Party”) produce the following documents for inspection and copying at [Location]. The production and inspection shall continue from day to
1 REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
the conditions of or reasons for such destruction and the person requesting or performing the destruction. B. if applicable. specific grounds for the objection must be stated in the response. which 15 16 17 18 19 20 21 22 sent. If Responding Party objects to the whole or any part of the request. (5) specifies. (4) specifies the date on which the DOCUMENT was prepared or transmitted. to which you may add five (5) days if this request is served by mail. C. (2) identifies the person who prepared or authored the DOCUMENT. Responding Party shall submit. or be organized and labeled to correspond with the categories contained in this demand. Such 8 9 10 11 12 13 14 custody and/or control of responding party or are otherwise available to responding party.1 2 3 4 5 6 7 day thereafter. pursuant to Code of Civil Procedure sections 2031. which are in the possession. (3) identifies the person to whom the DOCUMENT was . and (2) whether Responding Party lacks the ability to comply. to serve a written response under oath within thirty (30) days after service of this request.010-2031. SET ONE or both. weekends and holidays excepted. are responsive to the following requests. custody and/or control of Responding Party and has been lost or destroyed. in lieu of such DOCUMENT. shall be produced and identified.510. the date on which the DOCUMENT was lost or destroyed. possession. 23 24 25 26 27 28 2 REQUEST FOR PRODUCTION OF DOCUMENTS. and (6) if destroyed. so long as reasonably required. All documents demanded shall either be produced as they are kept in the usual course of business. If any DOCUMENT (as defined below) herein requested was formerly in the response is to include the following statements: (1) whether inspection and copying or photocopying will be permitted. a written statement which (1) describes in detail the nature of the DOCUMENT and its contents. if possible. INSTRUCTIONS A. All originals and copies of the items requested. Responding Party is hereby requested.
reports. circulars. you are requested to provide a listing of such recorded or graphic matter. G. memoranda. Attachments to a document shall not be unfastened. reports. or "writing" of any kind. including. contracts. As used herein. DOCUMENTS shall not be scrambled or otherwise jumbled and shall be produced in a way which preserves their identify. maps. unless a particular demand defines a different time period. DEFINITIONS A. tapes. . the folder or other container of it shall 8 9 10 11 12 13 14 DOCUMENTS containing a description of the DOCUMENTS and a description of the claim of 15 16 17 18 19 20 21 22 invoices. photographs. F. transcriptions. DOCUMENTS are to be produced either as they are kept in the usual course of business or organized and labeled to correspond with the categories in this demand.510. forms. data processing cards or tapes. financial statements. telegrams. indices. DOCUMENTS being produced shall be maintained in their original format. All DOCUMENTS requested herein refer to the time period beginning [Date] up to and including the present. studies. E. the term "DOCUMENT" or "DOCUMENTS" means any written. Whenever a DOCUMENT falling within the request is withheld from production. imprinted cards. accounts. drawings. be produced with it. work papers. notes. minutes and records of meetings. but not limited to. analyses. privilege sufficient to enable propounding party to present a motion to the appropriate court to compel production of same. agreements. papers. recordings. records. letters. Pursuant to Code of Civil Procedure sections 2031. bulletins. graphs. charts. SET ONE entries. H. according to a claim of privilege or otherwise. however produced or reproduced. advertisements. Whenever the item being produced is a file. data sheets.010-2031. correspondence. books. magnetic tapes.1 2 3 4 5 6 7 D. 23 24 25 26 27 28 3 REQUEST FOR PRODUCTION OF DOCUMENTS. disks. brochures.
"DOCUMENT" or "DOCUMENTS" includes all drafts and all finalized and/or executed writings. As used herein. reports of telephone or oral conversations. calendars or diaries. photostating. reproductions or facsimiles thereof. and statements of changes in financial position) financial calculations. or combinations thereof. bonds. typewriting. appointment books. reproduction or facsimiles. As used herein. and includes all electronic recordings of any information whether that information is electronic mail or other form of electronic means of preserving information and/or is stored on a "hard" disk. or symbols. pictures. the term "writing" as that term is defined in California Evidence Code section 250. 5 ¼" or 3 ½" disk. If YOU do not have custody or control 15 16 17 18 19 20 21 22 this case. laser disk. balance sheets. security agreements. closing statements. escrow documents. income statements. SET ONE C. photographing. including any and all "handwriting. title documents. If YOU have custody or control of the original and copies. and every other means of recording upon any tangible thing any 8 9 10 11 12 13 14 or other tape. “DENIAL” refers to denials made in YOUR answer to the of the original. 23 24 25 26 27 28 4 REQUEST FOR PRODUCTION OF DOCUMENTS. As used herein. letters of credit. printing." Evid. Code § 250. sounds. promissory notes. magnetic COMPLAINT. D. but not limited to. deeds of trust. . personal computer or mainframe computer. including letters. telephone messages. the term "DOCUMENT" or "DOCUMENTS" shall mean the original of any copy or reproduction or facsimile that is in any way different from the original. transactional documents. B. "PLAINTIFF" refers to Plaintiff [Name]. "COMPLAINT" refers to the complaint filed by PLAINTIFF in form of communication or representation. but is not limited to.1 2 3 4 5 6 7 (including. the term "DOCUMENT" or "DOCUMENTS" shall also include any carbon or photograph or any other copies. words. estimates. and includes.
the terms "YOU” and "YOUR” refers to DEFENDANT. and oral contact by such means as face-to-face meetings and telephone conversations. directors. As used herein. limited liability company. representatives. evidence. As used herein. refer to. and each of them. firm. electronic mail or any other DOCUMENTS. H. support. As used herein. and includes without limitation. or connect in any way 15 16 17 18 19 20 21 22 J. the term "ANY" as well as "ALL" shall be construed to include legally. past and present officers. SET ONE "each" and "every" within their meanings. pertain to. joint venture or public entity. corporation. refute. employees. but not limited to. her or its behalf. comprise. 23 24 25 26 27 28 5 REQUEST FOR PRODUCTION OF DOCUMENTS. its or their affiliates and parent company and anyone acting on their. investigators. As used herein. factually or logically with. affiliates. 8 9 10 11 12 13 14 respond to. involve." "RELATED TO. embody. "COMMUNICATION" or "COMMUNICATIONS" includes any G. individually and collectively. accountants. or at their. telexes. As used herein. her or its request. F. mention. memorialize. agents. As used herein. and his or her. memoranda. shareholders. "DEFENDANT” refers to defendant [Name]. the terms "RELATE TO. summarize.1 2 3 4 5 6 7 E. contain. attorneys. concern. the term "PERSON" includes ANY natural person. including. reflect. association. her or its interest. contacts between or among two or more PERSONS. the matter therein. her or its behalf. business." and/or "RELATING TO" mean discuss. I. partnership. on their. trust. or anyone else acting in their. . telegrams. written contact by such means as letters. organization.
separately state the following: (1) the nature of the DOCUMENT (i. (10) the subject PERSON who participated in its preparation. so as to be inclusive of any DOCUMENTS which may otherwise be excluded from production.1 2 3 4 5 6 7 8 9 10 11 12 13 14 K.e. without limitation. sent. business address. (9) each and every present custodian of said DOCUMENT and every copy thereof. or provided. (7) the name. the terms "and" and "or" have both conjunctive and disjunctive meanings so as to be inclusive of any documents which otherwise may be excluded from production. the use of the singular includes the plural and the use of the plural includes the singular. tape recording. memoranda. or provided. In these Requests. the attorney-client privilege or the attorney work-product privilege) applies. sent. of each PERSON who has seen or to whom the DOCUMENT or any part thereof was disclosed. SET ONE position. (4) the position at the time the DOCUMENT was prepared of each PERSON who participated in its preparation. (3) the name. CLAIMS OF PRIVILEGE Pursuant to California Code of Civil Procedure Section 2031. handwritten notes. business address and present position of each 15 16 17 18 19 20 21 22 whom the DOCUMENT was seen or to whom it or any part thereof was disclosed.. (6) the position. of each PERSON to whom it or any copy thereof was addressed. as to which YOU make any objection on the grounds that any privilege (including. and present position of each PERSON by .). as of the time the DOCUMENT or any part thereof was seen or disclosed. correspondence. (8) the 23 24 25 26 27 28 6 REQUEST FOR PRODUCTION OF DOCUMENTS. (5) the name. L. In these Requests. etc. business address and present position of each PERSON to whom the DOCUMENT or any copy thereof was addressed. (2) the date of or upon the DOCUMENT. with respect to each DOCUMENT called for by this demand. as of the time the DOCUMENT was prepared and as of the time it was received.060(b)(3).
(11) the basis of the claim of privilege. 1. 5. refute or in ANY way RELATE TO YOUR DENIAL of the allegation in Paragraph 7 of the COMPLAINT. ANY and ALL DOCUMENTS. and (12) if the basis of the claim of privilege is the attorney-work product doctrine. 15 16 17 18 19 20 21 22 REQUEST FOR PRODUCTION NO. refute or in ANY way RELATE TO YOUR DENIAL of the allegations in Paragraph 3 of the COMPLAINT. within 30 days of service of this request: 8 9 10 11 12 13 14 ANY way RELATE TO YOUR DENIAL of the allegations in Paragraph 6 of the COMPLAINT. tangible things and other items that support. including but not limited to commission statements. REQUEST FOR PRODUCTION NO. refute or in . ANY and ALL DOCUMENTS. tangible things and other items that support. tangible things and other items that support. REQUESTS FOR PRODUCTION PLAINTIFF hereby demands that Defendants produce the following DOCUMENTS and things at the office of the above named attorney for Defendants. identify the proceeding for which the DOCUMENT was prepared. ANY and ALL DOCUMENTS. REQUEST FOR PRODUCTION NO. 2. 3.1 2 3 4 5 6 7 matter(s) of said DOCUMENT and every portion thereof. 23 24 25 26 27 28 7 REQUEST FOR PRODUCTION OF DOCUMENTS. REQUEST FOR PRODUCTION NO. SET ONE ANY and ALL DOCUMENTS that constitute or RELATE TO DOCUMENTS that DEFENDANT gave or submitted to PLAINTIFF. 4. REQUEST FOR PRODUCTION NO. ANY and ALL DOCUMENTS given to DEFENDANT by PLAINTIFF.
e-mails or 23 24 25 26 27 28 8 REQUEST FOR PRODUCTION OF DOCUMENTS. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. REQUEST FOR PRODUCTION NO. ANY and ALL DOCUMENTS RELATED TO requests by DEFENDANT for reimbursement for expenses from PLAINTIFF. 7. memory devices. that contain any information. REQUEST FOR PRODUCTION NO. DOCUMENTS and/or files requested in ANY of these Requests for Production. REQUEST FOR PRODUCTION NO. ANY and ALL DOCUMENTS RELATING TO sales made by DEFENDANT on behalf of PLAINTIFF. 6. The computer and any related items. 12. 9. SET ONE Dated: [Date] facsimile transmissions between DEFENDANT and [Name] between [Date] and [Date]. 10.1 2 3 4 5 6 7 8 9 10 11 12 13 14 REQUEST FOR PRODUCTION NO. . including ANY and ALL storage media and 15 16 17 18 19 20 21 22 ANY and ALL DOCUMENTS sufficient to determine all telephone calls. 8. 11. ANY and ALL DOCUMENTS that support. ANY and ALL computer backup media containing information and/or files requested in these Requests for Production. refute or RELATE TO ANY and ALL affirmative defenses in your Answer. DEFENDANT’S current customer list. REQUEST FOR PRODUCTION NO.
SET ONE /// /// /// BY __________________________ [Name] [Name of Law Firm] Attorneys for [Name] .1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 9 REQUEST FOR PRODUCTION OF DOCUMENTS.
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