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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.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
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.
For interrogatories, action words such as ?list,? ?describe,? ?identify,? or ?state? are very useful. You may ask the other side to identify a document but you cannot use this form of discovery to get them to give it to you. Requesting documents requires a different kind of discovery process.
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).