Form 4.

2 Combined Discovery Request

UNITED STATES DISTRICT COURT
FOR A SAMPLE DISTRICT
_______________________________
)
Case [Form] No.:
Peter Plaintiff,
)
Plaintiffs,
)
)
v.
)
Donald Defendant,
)
Defendant
)
______________________________)
Requesting Party: ________________
Responding Party: _________________
COMBINED DISCOVERY REQUEST
Including Requests for Admissions, Interrogatories and Notices For Production
PLEASE TAKE NOTICE that in accordance with the applicable court rules, the
Requesting Party hereby requests that the Responding Party comply with and respond to
each of the discovery requests set forth hereunder within 30 days from the date that this
request is received by the Responding Party unless otherwise indicated in the request.
FOR ALL ITEMS DESIGNATED AS: Request For Admissions, the Responding
Party is requested to admit the truth of each of the requests for purposes of this action
only, and subject to all pertinent objections as to the admissibility thereof that may be
interposed at trial.
FOR ALL ITEMS DESIGNATED AS: Interrogatories, the Responding Party is
required to answer the questions separately and under oath. The requested information
must be provided regardless of whether it is possessed by the Responding Party
personally or by his agents, employees, representatives or persons acting on his behalf.
FOR ALL ITEMS DESIGNATED AS: Notices For Production, the Responding
Party is to produce the requested documents at the offices of your undersigned attorney
located at ___________, on the date of________, at _____ oclock (am/pm).
Request For Admission 1:
You are requested to admit that on the ______ day of _____, 20___ at approximately ___
oclock (am/pm), you personally engaged in the following activity:
____________________.
Interrogatory 1:
If your response to Request for Admission 1 is anything other an unequivocal
admission, please set forth the following information concerning the said activity
specifically and in detail: (A) __________________ (B) ________________

Interrogatory 2:
If your response to Request For Admission 1 is anything other an unequivocal admission,
please identify all documents written or produced between __________ and _________
pertaining to the subject activity. As used herein, the term document shall include
writings, notes, drafts, outlines, recordings and files, regardless of storage media; they
include, but are not limited to, writings contained on paper, recordable tape, celluloid,
disks, hard drives, electronic mail servers or any other digitally stored media. The term
document shall also include the full range of writings described in Rule 1001 of the
Federal Rules of Evidence. For each such document, please set forth the following
information specifically and in detail:
[a] Its title
[b] Its date
[c] Its author
[d] The circumstances surrounding its creation
[e] The media it occupies (i.e. printed, typewritten, floppy disk, etc.)
[f] The person or entity who presently has possession
[g] The location of the document
[h] A very brief description of its contents
Notice For Production 1:
Please produce all of those documents in your possession or under your control that
satisfy the following conditions:
[a] Its title ___________, or [and]
[b] dated between _______________
[c] authored by _______________
[d] involving _______________
[e] whose media is _______________
[f] that is in the possession of _______________
[g] located at _______________
[h] containing _______________
[Be careful about your use of or and and. Too many of the former may result in the
production of far too many irrelevant documents, while too many of the latter will
produce too few. You should not use all of the parameters set forth above; use only those
that are necessary. But if you must err, err on the side of too many.]
Date: _______________
_____________________________
Signature of Attorney