Unlike interrogatories Requests to Produce are not limited in number. Upon receipt from the opposing party your business lawyer working with you will assess whether any requests are objectionable and what should be produced. These production requests are regularly used in lawsuits.
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
FRCP Rule 34 says that a party may serve any other party a request for production and information. A party may request writings, drawings, photographs, graphs, charts, sound recordings, images, data, and data compilations. In addition, a party may also request tangible objects.