Rule 34 was amended in 2016 to recognize the common practice of producing copies of documents rather than permitting inspection of the originals. You must ask for Discovery soon after you get the Summons and Complaint.See instructions on the next page about deadlines. At the request of the Committee on Rules and Practice of the Judicial Conference of the. How to send Discovery requests to the Plaintiff ; 1. Fill out the form(s). Section 2 - Written interrogatories; notice to adverse party; production of documents. Fill in the "certificate of service" on the last page before mailing them back to the other side. How To Respond To Requests for Production of Documents. Add the Discovery Interrogatories from Defendant to Plaintiff with Production Requests - Massachusetts for redacting.