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A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P. §2031.230) or (3) object (C.C.P. §2031.240).
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
The process of delivering, or making available for review, documents in response to a request for documents, such as a request for production and a subpoena. A request for documents may call for the production of paper (hard copy) documents and electronically stored information (ESI).