1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of ________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) REQUESTS FOR PRODUCTION OF
) DOCUMENTS, SET ONE
13 vs. )
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17

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- 1 -
REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 http://legaldocspro.net/california-discovery-litigation-document-
2

3
package/
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Be sure to remove these notices and all other notices before using
5

6 this document.
7 PROPOUNDING PARTY: NAME AND CAPACITY OF PROPOUNDING PARTY
8
RESPONDING PARTY: NAME AND CAPACITY OF RESPONDING PARTY
9
SET NUMBER: ONE
10

11
TO NAME AND CAPACITY OF RESPONDING PARTY AND THEIR ATTORNEYS OF
12
RECORD:
13

14
PLEASE TAKE NOTICE THAT pursuant to California Code of Civil Procedure 2031.010

15 and 2031.210 et. seq., you are directed to respond separately, under oath and in writing, to each and

16 every category of documents set forth herein, within thirty (30) days of service of this request.
17
PLEASE TAKE NOTICE THAT, within thirty (30) days of service of this request, you are
18
directed to produce for inspection and copying of the same, all the documents and materials described
19

20 below which are in your possession, custody, and/or control to: Put in your complete
21

22
address here including city, state and zip code.
23
Moreover, pursuant to this Code, the responding party is required to serve a written response,
24
under oath, to this Demand within 30 days after service. The response shall identify the documents
25
falling within the category specified and that inspection and related activities will be permitted as
26

27 requested, unless the request is objected to, in which event the reasons for objection shall be stated.

28

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REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 Unless otherwise indicated, a copy of the documents requested shall be sufficient for this
2 production of documents.
3
DEFINITIONS
4
1. YOU or YOU OR ANYONE ACTING ON YOUR BEHALF means you, the
5

6
NAME AND CAPACITY OF RESPONDING PARTY, your agents, your employees, your

7 insurance companies, their agents, their employees, your attorneys, your accountants, your

8 investigators, and anyone else acting on your behalf.

9
2. YOUR or YOURSELF means NAME AND CAPACITY OF RESPONDING
10
PARTY, your agents, your employees, your insurance companies, their agents, their employees, your
11
attorneys, your accountants, your investigators, and anyone else acting on your behalf.
12

13 3. DOCUMENT means a writing, as defined in Evidence Code 250, and includes the

14 original or a copy of handwriting, type-writing, printing, photostating, photographing, and every

15
other means of recording upon any tangible thing and form of communicating or representation,
16
including letters, words, pictures, sounds, or symbols, or combinations of them.
17
4. ADDRESS means the street address, including, the city, state, and zip code.
18

19 5. FULLY IDENTIFY means in relation to persons to state the full name, telephone

20 number and last known address, including city, state and zip code; in relation to documents, FULLY
21
IDENTIFY means to provide the name of the document, date of the document, and the type of
22
document.
23
6. PERSON includes a natural person, firm, association, organization, partnership,
24

25 business, trust, limited liability company, corporation, or public entity.

26

27

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- 3 -
REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 7. PLAINTIFF or PLAINTIFF AND ANYONE ACTING ON THEIR BEHALF in
2 this set of request for production of documents means the NAME AND CAPACITY OF
3
PROPOUNDING PARTY in this action.
4
INSTRUCTIONS
5

6
1. In answering these requests, you are required not only to furnish documents in

7 your possession, custody and control, but also documents which are in the possession, custody and

8 control of your attorneys, investigators or anyone else acting on your behalf or their behalf regardless
9
of who prepared or signed the documents.
10
2. The documents produced must be complete and accurate reproductions of any
11
originals and that such copies can be used for any purpose, including at trial, as and in place of such
12

13 originals.

14 3. Any comments, notations or markings appearing on any documents, and not a

15
part of the original, is considered a separate document, and any drafts, preliminary form or
16
superseded version of any documents is also considered a separate document.
17
4. As used herein, the singular name and masculine gender shall mean also the
18

19 plural and feminine or neuter, as may be appropriate; the conjunctive includes the disjunctive, and the

20 disjunctive includes the conjunctive; and "all" and "each" includes each and every.
21
5. As used herein, "person" refers to and includes natural persons, as well as
22
businesses and all other artificial entities, unless otherwise limited herein.
23
6. If any claim of privilege is asserted with respect to any document responsive to
24

25 any of the requests herein, identify each such document responsive to any of the requests herein,

26 identify each such document by stating the following information with respect to each such
27
document:
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- 4 -
REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 (a) The description of the subject matter of such document with sufficient particularity to
2 enable the same to be identified;
3
(b) The dates of preparation and sending of the document and the date, if any, appearing on
4
such document as the date thereof;
5

6
(c) The identity of each person who signed, prepared or sent the document, including his or

7 her full name, his or her present or last known residence address and telephone number, his or

8 her present or last known business address and telephone number, his or her employer's
9
name, and his or her position of employment, including titles of employment;
10
(d) The identity of each person who originated, circulated or published such document, or on
11
whose behalf such document was signed by the signer of behalf of a person other than the
12

13 signer;

14 (e) The identity of each person who originated, circulated or published such document, or on
15
whose behalf such document was originated, circulated or published;
16
(f) The name and address of each person who was an
17
addressee thereof, or to whom such document was sent; and
18

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production-of-documents-for-california
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REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE