Plaintiff's Request for Production of Documents

PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS

Plaintiffs, by and through counsel, and pursuant to MCR 2.310, hereby request that Defendant produce for inspection and copying at the Law Offices of Michael J. Morse, P.C., at 25657 Southfield Road, Southfield, Michigan, a complete and legible copy of the hereafter designated documents concerning the within action, which are in your possession, custody or control.

Instructions:

a) You must serve a written response within twenty-eight (28) days after service of this request. Your response must state that production and related activities will be permitted as requested or that the requested production is objected to, in which event the reasons for your objection must be stated.

b) Documents produced for inspection must be produced as they are kept in the usual course of business or be organized and labeled to correspond with the categories in this request.

c) If you do not agree to allow the requested production at a reasonable time and on reasonable conditions, a motion may be filed seeking a court order requiring the requested production.

d) The word “documents” means writings, drawings, graphs, charts, photographs, phone records, and other data compilations from which information can be obtained and translated into a reasonably usable form.

e) The words “you” and “your” mean you, your representatives, agents, insurers, attorneys, employees, directors, officers, subsidiaries, affiliates, and all others over whom you have control.

f) The words “possession, custody, or control” mean all documents and things belonging to you that are in your possession, all documents and things belonging to others over which you have custody, and all documents and things in the custody of others over which you have the right to control.

g) The word “occurrence” shall mean the motor vehicle accident which occurred on subject date of accident.

Documents to Produce

1. Copy of Defendant’s Driver’s License, front and back.

2. Copy of Defendant’s registration, front and back.

3. Complete copy of the automobile insurance policy for the vehicle that was involved in the above-referenced accident, including the Declaration page.

4. All statement(s) a party has given to some person and/or entity other than his/her attorney.

5. The name, address and telephone number of all witnesses, or other participant(s), who have, or may have claimed, knowledge of the occurrence, and/or the damages resulting therefrom, and a copy of...