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Plaintiff Richard A. Gorman's Requests for Production to Defendant as follows: GENERAL STATEMENT. The easiest and non-controversial response is when the responding party has agreed to produce all documents for production without objection.If you have received requests to produce, you have thirty days to prepare your written responses (unless the court has ordered something else). Pursuant to Rule 196 of the Texas Rules of Civil Procedure, Defendant responds as. And production of all responsive documents. If the other person did not respond or didn't provide complete responses, try to work it out with them directly first. CLAIM SPECIFIC REQUEST FOR PRODUCTION TO DEFENDANT INSURER. 6. Any and all documents of any nature whatsoever referred to in Defendant's(s') Answers to Plaintiff's(s') Interrogatories. If the other person did not respond or didn't provide complete responses, try to work it out with them directly first. PLEASE TAKE NOTICE that pursuant to Rule 34 of the Hawai'i Rules of Civil.