Fill and Sign the Plaintiffs First Request for Production of Documents and Form

Plaintiff’s First Request for Production of Documents Page 1 of 3 IN THE CIRCUIT COURT OF _______________________ COUNTY, MISSISSIPPI _______________________________ PLAINTIFFS/ COUNTER DEFENDANTS VS. CAUSE NO. ___________________________ _______________________________ DEFENDANT/ COUNTER CLAIMANT PLAINTIFFS' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS- INDIVIDUAL THE following Request for Production of Documents is made to the Defendant pursuant to Rule 34 of the Mississippi Rules of Civil Procedure. Request is hereby made that Defenda nt produce and permit the inspection of copying of the following documents at the offices of ________________________________ on _______________________ at _______ a.m./ p.m. REQUEST NO. 1: Produce all files maintained by you in relation to the construction of the residence of Plaintiffs on Lot _____, ________________ Mississippi. REQUEST NO. 2: Produce all invoices, statements, delivery tickets, contracts or other written documents pertaining to the purchase of materials by Defendant, or others, which were used in the construction of the subject residence. Also, provide all evidence of payment of said expenses, including, but not limited to, payment of said expenses, including, but not limited to, canceled checks. REQUEST NO. 3: Produce all contracts, subcontracts or other written instruments regarding any subcontractors engaged by Defendant or Plaintiffs in the construction of the subject residence. Plaintiff’s First Request for Production of Documents Page 2 of 3 REQUEST NO. 4: Produce all written documents regarding labor used in the construction of the subject residence, including time records, payroll records, payroll checks and such other documents as may reflect the payment of labor to employees of Defendant. REQUEST NO. 5: Produce all insurance policies wherein Defendant is the named insured, including, but not limited to, worker's compensation, contractor's liability, builder's risk, homeowner's, and automobile. Include in your production, all policies of insurance maintained during the period commencing _____________________________ through the date of this request. REQUEST NO. 6: Produce all plans and specifications used by Defendant in construction of the subject residence.REQUEST NO. 7: Produce all notes, memos, letters, correspondence, diaries, or other documents which may reflect the progress of work on the subject residence from its beginning to the date of this request.REQUEST NO. 8: Produce all invoices submitted by Defendant to Plaintiffs from the date construction commenced to the date of this request.Respectfully submitted, this the _____ day of ______________ , ______ . _______________________________________ Signature Attorney for ___________________________________________________________________ Type or Print Name Of counsel:____________________________________________________________________________________________________________________________ Telephone: ________________ Plaintiff’s First Request for Production of Documents Page 3 of 3 MSB #_______________ Attorney for _______________________________ CERTIFICATE OF SERVICE I, __________________________________ do hereby certify that I have this day mailed by U. S. Mail, postage prepaid, a true and correct copy of the above and foregoing Plaintiffs' First Request for Production of Documents to _________________________________, the attorney for _________________________________ . This the _____ day of _________________ , __________ . ______________________________________ Signature