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You must make a ?diligent search and reasonable inquiry? into finding the requested items, and include this language in your response. You must also describe which items will not be produced, and why they cannot be produced. This verification is required if your responses include any factual assertions.
A party may serve on another party - no later than 30 days before the end of the discovery period - a request for production or for inspection, to inspect, sample, test, photograph and copy documents or tangible things within the scope of discovery.
How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.
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).