Illinois Plaintiff's Request for Production to Defendant - Personal Injury

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US-PI-0225
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This form is a sample request for production of documents, tangible items and things submitted by the plaintiff to the defendant in a personal injury action involving the disposal of hazardous containers.

Title: Detailed Description of Illinois Plaintiff's Request for Production to Defendant — Personal Injury Keywords: Illinois, Plaintiff's Request for Production, Defendant, Personal Injury, types Introduction: In personal injury cases in Illinois, the plaintiff's attorney often sends a Plaintiff's Request for Production to the defendant, typically during the discovery phase. This legal document aims to gather important information, documents, and evidence from the defendant that are relevant to the personal injury claim. In Illinois, there are various types of Plaintiff's Requests for Production to Defendants in personal injury cases, each serving a specific purpose. Types of Illinois Plaintiff's Request for Production to Defendant — Personal Injury: 1. General Request for Production: The General Request for Production seeks the defendant to provide various documents and evidence related to the personal injury incident. This may include accident reports, medical records, photographs, witness statements, insurance policies, maintenance records, and any other relevant material that might support or refute the plaintiff's claim. 2. Medical Records Request: In personal injury cases, the plaintiff often demands the defendant to produce all medical records related to the injuries sustained. This includes medical reports, doctor's notes, diagnostic test results, treatment plans, and invoices for medical services rendered. The goal is to assess the extent of injuries, their impact on the plaintiff's life, and any potential negligence on the defendant's part. 3. Employment Records Request: If the personal injury claim involves lost wages or diminished earning capacity, the plaintiff's attorney may request the defendant to produce the plaintiff's employment records. This includes pay stubs, tax returns, employment contracts, and any documentation related to job benefits, promotions, or future career prospects. 4. Vehicle Information Request: In cases involving automobile accidents or personal injury claims related to vehicle incidents, a vehicle information request is crucial. It requires the defendant to produce details about the vehicle involved, such as registration documents, maintenance records, repair bills, and any evidence indicating prior mechanical issues or negligent vehicle operation. 5. Surveillance Material Request: In cases where the defendant argues that the plaintiff's injuries are exaggerated or fabricated, the plaintiff's attorney may submit a request specific to surveillance material. This kind of request demands the defendant to produce any video footage, photographs, or other surveillance evidence that they may possess to support their allegations. Conclusion: In personal injury cases in Illinois, the Plaintiff's Request for Production to Defendant is a crucial step in gathering evidence and information to support the plaintiff's claim. Through various types of requests, the plaintiff's attorney aims to uncover essential details relevant to the case, including accident reports, medical records, employment details, vehicle information, and surveillance material. By conducting thorough discovery, the plaintiff seeks to build a solid foundation for their personal injury claim and obtain a favorable outcome in court.

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If you do not, the requesting party may file a motion to have the facts deemed admitted by the court, or a motion to compel further responses, both of which may carry sanctions (monetary penalties) against you.

The requesting party must include a due date for the response. This timeline cannot be less than 28 days. The party who receives the request must copy and provide the documents like they are normally kept.

A Request for Admission asks the other side in your case to admit that a fact is true or that a document is authentic. If the other side admits that something is true or authentic, you will not need to prove that at trial. This can make your trial faster and less expensive.

A request for production occurs when one party asks another to procure ESI or physical evidence. For example, this may include emails, photographs, text messages, charts, or graphs. On the other hand, physical evidence may encompass items like paper and gifted objects.

In a civil action, a request for admission is a discovery device that allows one party to request that another party admit or deny the truth of a statement under oath. If admitted, the statement is considered to be true for all purposes of the current trial.

Rule 213 - Written Interrogatories to Parties (a)Directing Interrogatories. A party may direct written interrogatories to any other party. A copy of the interrogatories shall be served on all other parties entitled to notice. (b)Duty of Attorney.

(a) Any party may by written request direct any other party to produce for inspection, copying, reproduction photographing, testing or sampling specified documents, including electronically stored information as defined under Rule 201(b)(4), objects or tangible things, or to permit access to real estate for the purpose ...

The most important aspect of Rule 213 is the requirement that parties disclose the identity of any witnesses they plan to call at trial to provide expert testimony as well as a written report detailing the opinions and basis for those opinions of the witness.

For example, Plaintiff may send Defendant a request for admission that states, ?Admit that the front of the vehicle you were operating struck the front of the vehicle the Plaintiff was operating on the date of the car crash.?

However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.

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Sample requests for production of documents in personal injury cases. Free example RPDs for car accident, medical malpractice, and other personal injury ... Identify any statements, information and/or documents known to you and requested by any of the foregoing interrogatories which you claim to be work product or ...REQUEST FOR PRODUCTION NO.​​ All written, recorded, or signed statements of any party, including the PLAINTIFF, DEFENDANT, witnesses, investigators, or agent, ... RESPONSE: 8. A complete copy of any incident or accident report concerning the incident referred to in the Plaintiff's Petition. RESPONSE: DEFENDANTS' CONSOLIDATED REQUESTS FOR PRODUCTION. OF DOCUMENTS TO THE PLAINTIFF. Pursuant to court order, the Illinois Code of Civil Procedure, and the Rules of ... Dec 23, 2008 — One of the most important tools of discovery available to personal injury attorneys in Illinois ... requests for the admission of facts (“requests ... After explaining the basics, Lee writes some sample requests for admission based on an imagined defamation case. Lee concludes, "Take the time to look for ... Jul 27, 2020 — Another category of documents regularly requested in an injury case include your medical records. WE often see requests like this: TO: Pursuant to Rule 214, Plaintiff requests the Defendants to produce for inspection and copying within twenty-eight (28) days from the date of mailing of ... DOCUMENTS OR THINGS TO BE PRODUCED 1. Copies of any statements made by Plaintiff, any defendant, and any witness. 2. Copies of any photographs, videotapes or  ...

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Illinois Plaintiff's Request for Production to Defendant - Personal Injury