Plaintiff's First Request for Production of Documents Propounded to Defendant City in a Whistleblower Case

[Style of Case]

PLAINTIFF'S FIRST REQUEST FOR

PRODUCTION OF DOCUMENTS TO THE CITY OF

TO: Defendant, CITY OF _____, by and through its counsel of record, _____.

[OPTION:]

TO: Defendant, CITY OF _____, by and through its registered agent for service of process, _____.

Pursuant to the [Federal/Texas] Rules of Civil Procedure, Plaintiff, _____ (hereafter "Plaintiff"), submits to you the following Request for Production of Documents.

[INSERT STANDARD INSTRUCTIONS AND DEFINITIONS FOR PLAINTIFF’S WRITTEN DISCOVERY TO DEFENDANT, FORM DIS016]

[Additional Instructions/Definitions tailored specifically for a Whistleblower case are listed below.]

“Illegal activities Plaintiff reported” means _____.

“City” means the City of _____.

"City employee" means an employee hired/employed by the City of _____.

DOCUMENTS TO BE PRODUCED

[INSERT PLAINTIFF’S STANDARD REQUESTS FOR PRODUCTION, FORM DIS018]

[Additional Requests for Production tailored specifically for a Whistleblower case are listed below.]

REQUEST NO. : Please produce all memos, analyses, studies, or other similar documents generated by the City regarding Plaintiff's appeal of Plaintiff’s termination of employment with the City.

RESPONSE:

REQUEST NO. : Please produce all memos, analyses, studies, or other similar documents that any employee or person hired by the City reviewed in making a decision on Plaintiff's appeal from Plaintiff’s termination.

RESPONSE:

REQUEST NO. : Please produce all petitions or counterclaims filed in the last _____ years through the time of trial alleging that you or your employees violated any law.

RESPONSE:

REQUEST NO. : Please produce all documents generated by City employees regarding a decision by the City to terminate or discipline any City employee for [insert act that Defendant claims justified firing Plaintiff].

RESPONSE:

REQUEST NO. : Please produce all documents generated by City employees regarding all appeals that any City employee has made in the last _____ years through the time of trial from a decision by the City to terminate or discipline any City employee for [insert act that Defendant claims justified firing Plaintiff].

RESPONSE:

REQUEST NO. : Please produce all documents from all personnel files generated in the last _____ years through the present regarding the termination of a City employee for [insert act that Defendant claims justified firing Plaintiff].

RESPONSE:

REQUEST NO. : Please produce all documents from all personnel files generated in...