Request for Production of Documents (Alternate)

REQUEST FOR PRODUCTION OF DOCUMENTS AND OTHER TANGIBLE THINGS

Plaintiff/Defendant (insert name of plaintiff/defendant) is hereby requested, pursuant to Rule 34, to produce the following documents for inspection and/or copying at (insert location) on (insert time and date), subject to all applicable objections. Plaintiff/Defendant is hereby requested to produce originals of such documents where available.

1. All estimates, invoices or other documents pertaining to the value of the (insert description of property damage) that you claim to have sustained as a result of the incident.

2. Any and all invoices pertaining to repairs made to your (insert property)

   between the date on which you purchased it and the date of the incident.

3. Any and all documents that reflect any other costs you incurred as a result of the property damage that you claim to have sustained as a result of the incident.

4. Any and all medical records including, but not limited to, hospital records (admission summary, histories, progress notes, nurse's notes, physician's orders, laboratory reports, pharmacy receipts, diagnostic studies and reports, and discharge summaries), physician's records (office notes, forms completed by the physician on your behalf for submission to any third party, diagnostic studies and reports, prescription records, and any correspondence from you, your attorney or any person on your behalf to your physician), and all statements of charges, invoices or receipts for medical services, equipment or medication that you received as a result of the incident, whether or not you or a third party (insurance company) paid such costs.

5. Any documents which in any way substantiate your claim for lost earning capacity or wages, including, but not limited to:

   a. Medical disability forms

   b. W-2 statements

   c. Tax returns

   d. Payroll records.

6. Any and all claims forms that you submitted to any third party in order to obtain any monetary or other benefits as a result of the incident, including, but not limited to:

   a. Medical insurance

   ...