Fill and Sign the Plaintiff Request Production Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             ,       , AND       DEFENDANTS DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS COMES NOW, the defendants in the above styled and numbered civil action, and states the following in response to Plaintiff's Request for Production of Documents herein: REQUEST NO. 1: Copy of any complaints lodged against Plaintiff by Offender       , prior to             ,       , concerning allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 2: Copy of any complaint lodged against Plaintiff by Offender       , prior to             ,       , concerning allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 3: Copy of any complaints lodged against Plaintiff by       prior to             ,       , concerning allegations of       by Plaintiff. If the complaint was verbal, please produce the name(s), title and address of the       officials(s) to whom the complaint was lodged. RESPONSE:       . REQUEST NO. 4: The name and address of the       who the defendant       claim Offender       reported allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 5: The names, titles and addresses of all persons interviewed by       prior to             ,       , concerning allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 6: Any and all taped recordings, notes or other investigative reports and documents related to the allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 7: The names, titles and address of all Offenders and officials who actually took a polygraph examination, prior to             ,       , in connection with the investigation of allegations of       by Plaintiff. RESPONSE:       . REQUEST NO. 8: The names, titles and address of all Offenders and officials who actually took a polygraph examination, prior to             ,       , in connection with the investigation of allegations of       by Plaintiff. Please include the date of each examination. RESPONSE:       . REQUEST NO. 9: The Investigative Report submitted to the Disciplinary Committee, by the Disciplinary Investigator, in connection with the RVR written by       and issued to Plaintiff on             ,       . RESPONSE:       . REQUEST NO. 10: A complete and up - to - date audit opinion of the Inmate Welfare Fund deposited in       . RESPONSE:       . REQUEST NO. 11: The names, titles and addresses of all persons interviewed by the defendant       , prior to             ,       , regarding allegations of       by Plaintiff. RESPONSE:       . Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for