Write simple requests for categories of documents that are relevant to your case. There is not a specific limit on the number of requests, but the other party may object if responding would cause an unfair burden.
P. 34. Rule 34 - Producing Documents, Electronically Stored Information, and Tangible Things, or Entering Onto Land, for Inspection and Other Purposes (a) In General.
(A) No party may serve upon any other single party to an action more than 40 requests for admission under Rule 36(a)(1)(A) without obtaining: (i) a written stipulation under Rule 29 of the party to which the additional requests are directed; or (ii) upon a showing of good cause, a court order granting leave to serve a ...
Rule 26(b)(3) protects communications between the party's attorney and any witness required to provide a report under Rule 16.1(a), 16.2(d) or (e), or 16.205(d) or (e), regardless of the form of the communications, except to the extent that the communications: (i) relate to compensation for the expert's study or ...
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
4) Although there are no limits on how many requests you can include in an RFA they must pertain to the claims or defenses in your lawsuit. Consider limiting the content of your RFAs to: ? Whether a fact is true or false. ? How a law or legal principle applies to the facts of your case.
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.