Legal RFPD Set

LEGAL REQUEST FOR PRODUCTION OF DOCUMENTS — SET

Court:   Case Title:

Case No.:   Set No.:   Date of Service:

To: Responding Party Name:    Responding Counsel:

From: Requesting Party Name:    Requesting Counsel:

RECITALS

WHEREAS, Requesting Party seeks documents and tangible things in the possession, custody or control of Responding Party that are relevant to claims or defenses in the above-captioned action; and

WHEREAS, these Requests for Production are propounded pursuant to the applicable rules of civil procedure and are intended to obtain discoverable information reasonably calculated to lead to admissible evidence; and

WHEREAS, the parties are expected to preserve relevant documents and electronically stored information from the date of notice forward and to meet and confer in good faith regarding any disputes concerning these requests.

NOW THEREFORE

Requesting Party, by counsel, requests that Responding Party produce the following documents and things for inspection and copying at the office of Requesting Counsel or by electronic transmission within days of service of these requests, unless a different date is specified for a particular request.

DEFINITIONS AND INSTRUCTIONS

1. "Document" or "documents" means the original and all non-identical copies of writings, drawings, graphs, charts, photographs, sound recordings, images, emails, text messages, notes, calendars, appointment books, reports, analyses, compilations, data, databases, log files, metadata and other tangible things responsive to a request, whether in paper or electronic form.

2. "Communication" means disclosure, transfer or exchange of information by any means. "You" or "Your" means the Responding Party and, when applicable, any agent, attorney, representative or person acting on the Responding Party's behalf.

3. These requests are continuing. If at any time after service of your responses you obtain additional documents or discover additional responsive materials, you must promptly supplement your responses and produce such materials.

4. If any document is withheld on the basis of privilege, work product, or any other ground, produce a log identifying each withheld document with sufficient detail to enable the Court and opposing counsel to assess the claim of privilege, including author, recipient, date, subject matter, and privilege asserted.

REQUESTS FOR PRODUCTION

1. All documents evidencing the facts and circumstances underlying the claims or defenses in the Complaint and any Answer, including but not limited to correspondence, internal memoranda, notes, reports, and photographs, for the period from through .

2. All documents relating to communications between Responding Party and any third party concerning the subject matter of this action, including email threads, text messages, and instant messages, during the period from to .

3. All contracts, agreements, statements of work, purchase orders, invoices, and payment records relevant to the transactions at issue.

4. All policies, procedures, training materials and internal guidelines that mention, describe, or govern the events or subjects at issue in this litigation.

5. All documents sufficient to show the identity and contact information for each person who participated in, witnessed, or has knowledge of the matters complained of, including title, role, and dates of involvement.

6. All documents reflecting any investigation conducted by or on behalf of Responding Party concerning the events at issue, including investigation notes, interview memoranda, photographs, and final reports.

7. All electronically stored information underlying any reports, analytics, spreadsheets, or summaries that Responding Party intends to rely upon or that relate to damages or liability.

8. All insurance policies, certificates of insurance, or endorsements that may provide coverage for any of the claims asserted in this action.

9. All documents evidencing preservation communications, litigation holds, or steps taken to preserve relevant documents and electronically stored information after notice of potential litigation.

10. All documents reflecting communications with experts, including engagement letters, drafts of reports, and underlying data provided to experts (subject to applicable rules regarding discovery of expert materials).

11. All documents sufficient to show financial records, accounting entries, billing statements, or ledgers related to the claims or defenses asserted in this action for the period from through .

12. All non-privileged drafts of any document produced in response to these requests and all correspondence discussing the preparation or revision of such drafts.

FORMAT OF PRODUCTION; ELECTRONICALLY STORED INFORMATION

Unless otherwise agreed, electronic documents shall be produced in the following format. Select all applicable:

Produce native electronic files with associated metadata

Produce searchable PDF files with extracted text

Produce single-page TIFF images with load file (image-to-text mapping)

For each produced electronic document, include readily-available metadata fields including author/creator, recipient(s), To/Cc/Bcc fields, filename, file path, file creation and last modified dates, and native file format.

PRIVILEGE, REDACTION AND PRIVILEGE LOG

Documents withheld on the basis of privilege or work product must be identified on a privilege log that describes, for each withheld document, the date, author, recipient(s), document type, general subject matter and the specific privilege or protection asserted. If redaction is applied, produce a redacted copy and a log describing the basis for redaction.

PRESERVATION; MEET AND CONFER

Responding Party is on notice to preserve all documents and electronically stored information potentially relevant to this action. If you object to any request, you must serve a written response stating the specific basis for each objection and identify any portion of a document that will be redacted or withheld. Counsel shall meet and confer in good faith to resolve disputes before seeking court intervention.

RESPONSES; CERTIFICATION

Responses must state whether documents will be produced, specify the production date or dates, and identify any documents withheld. The person signing the responses or objections must certify under penalty of perjury that the responses are complete and correct to the best of the signer's knowledge after a diligent inquiry.

NOTICES; SERVICE

Service of documents and responses shall be made at the service addresses provided above by hand delivery, commercial courier, or electronic mail to a counsel of record, subject to agreement of the parties. Notices required by these requests shall be in writing and delivered to the counsel listed above.

AMENDMENTS; WAIVER; COUNTERPARTS

These requests may be amended by written notice. No failure to insist upon strict compliance shall operate as a waiver of any provision. This document may be executed in counterparts and by facsimile or electronic signature, each of which shall be deemed an original.

GOVERNING LAW; SEVERABILITY; ENTIRE AGREEMENT

This Request for Production shall be governed by the laws and rules of civil procedure applicable to the forum in which the action is pending. If any provision hereof is held invalid, the remainder shall remain in full force and effect. This document contains the entire request and supersedes any prior written discovery demand on the same subject matter.

CERTIFICATION OF SERVICE

I hereby certify that on the date set forth below I served a true and correct copy of this Request for Production of Documents on the persons and at the addresses listed above by the method indicated.

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