Fill and Sign the Alabama Rules for Expedited Civil Actions Form 1 in the

IN THE CIRCUIT COURT OF ________________ COUNTY, ALABAMA________________________________PlaintiffVs. CIVIL ACTION NO._____ ________________________________Defendants.REQUEST FOR PRODUCTION OF DOCUMENTS BY (DEFENDANT) TO (PLAINTIFF) Comes now the Defendants in the above styled cause, ____________________________, and pursuant to Rule 34 of the Alabama Rules of Civil Procedures request that the Plaintiff, _________________________, respond within 30 days and that said Plaintiff provide for inspection and/or making copies of the following documents at the law offices of ______________________, Post Office Box ________, ________________, Alabama _____ during regular business hours, to wit: 1.Any and all photographs depicting any damage sustained to the vehicle operated by ______________________________ a result of the accident of _______________, 200____ which is made the basis of this suit. 2. Any and all photographs depicting any damage to the vehicle operated by ______________________ __ as a result of the accident of __________________, 200___ which is made the basis of this suit. 3. Any and all photographs purporting to depict the scene of the accident of __________________________, 200_____, which is made the basis of this suit. 4.Any and all photographs purporting to depict any object or factual setting involved in the accident of ___________________, 200____, which is made the basis of this suit.5. Any and all photographs purporting to depict any injury or ailment sustained by ___________________________ as a result of the accident of ________________, 200_____ which is made the basis of this suit.6.Any and all photographs that may be introduced into evidence on behalf of the Plaintiff, __________________________, at the trial of this case.7.Any written statement, taped statement, oral statement or other statement which has been taken from ____________________________ regarding the accident of ____________________________, 200______ which is made the basis of this suit.8. Any written statement, taped statement, oral statement or other statement which has been taken from Defendant regarding the accident of ______________, 200_____ which is made the basis of this suit.9.Any and all bills, repair invoices, repair estimates and other documents Regarding amounts charged for repairs of damage and/or amounts estimated for repairs of damage to the vehicle operated by __________________ as a result of the accident of ______________________________, 200_______ which is made the basis of this suit.10.Any and all bills, repair invoices, repair estimates and other documents regarding amounts charged for repairs of damage and/or amounts estimated for repairs of damage to the vehicle operated by James Norman as a result of the accident of _________________________, 200______, which is made the basis of this suit. 11. Any and all medical bills to be claimed at trial on behalf of the Plaintiff, ______________________, including any and all chiropractic bills, doctor bills, hospital bills, emergency medical bills, ambulance bills, prescription bills and other bills for medical services alleged to have been performed for __________ as a proximate result of the accident of ____________________, 200______ which is made the basis of this suit.12. A true and correct copy of all medical reports and medical records regarding medical services provided to __________ as a proximate result of the accident of ____________________________, 200_______ which is made the basis of this suit.13. A true and correct copy of all federal and state income tax returns, W-2 Forms and other supporting tax documents for ____________________ for the years __________, _________, _________, and _________, inclusive.14.A statement from the employer of __________ on ________________, 200____ verifying his wages and/or salary at the time of the accident of March ___________________, 200_____ and total wages alleged to have been lost as a result of time lost from work as a result of the accident on ________________, 200_____.15.True and correct copies of all repair bills and repair estimates regarding the vehicles involved in the accident of ______________, 200______ which is made the basis of this suit. 16.A true and correct copy of all medical records, medical reports and other medical documents which may be introduced into evidence at the trial of this case on behalf of _______________________.17. A true and correct copy of all exhibits, objects documents and photographs, which may be introduced into evidence at the trial of this case on behalf of ________________________. You may comply with this request for the production of documents by producing the documents and items referenced herein to _______________________, Post Office Box ________, ______________, Alabama ________________within 30 days of the date hereof. _____________________________ Defendant’s counsel