Fill and Sign the Documents Plaintiff Form

IN THE CIRCUIT COURT OF ________________ COUNTY, ALABAMA ________________________________ Plaintiff Vs. 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