Requests for production of documents

[Name]

[Address]

[Phone number] Attorney for [propounding party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

__________________________________________

)

[Name], ) REQUESTS

Plaintiff, ) FOR PRODUCTION

) OF DOCUMENTS

v. )

)

[Name], )

Defendant. )

__________________________________________)

PROPOUNDING PARTY: [Name of Party]

RESPONDING PARTY: [Name of Party]

SET NUMBER: [Number]

Pursuant to FRCP 34, [propounding party] submits the following requests for documents to [responding party] to produce on [date] at [time] at the offices of [name] located at [address].

DEFINITIONS

1. The term “you” or “your” refers to [responding party] and each of its affiliates, attorneys, accountants, divisions, subdivisions, predecessors, directors, officers, employees, agents, representatives and all persons acting or purporting to act on (responding party’s) behalf.

2. The term “document” means any writing or recording as defined in Rule 1001 of the Federal Rules of Evidence, including any drafts, revisions and computer readable materials. “Document” shall also mean electronic mail, tapes, disks, diskettes, data...