Plaintiffs standard interrogatories 32 and requests for form
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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
PLAINTIFF
VS. CAUSE NO.
DEFENDANTS
PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS
THE following Request for Production of Documents is made to the Defendants pursuant
to Rule 34 of the Mississippi Rules of Civil Procedure. Request is hereby made that Defe ndants
produce and permit the inspection and copying of the following documents, at the offices of
, , Mississippi , on , 20 at : a.m./p.m.
Request No. 1: Produce all contracts, deeds, and other documents in the possession of
Defendants, individually, or as officers of which relate to the purchase of the real estate and
residence located on , Mississippi, which is the subject of this litigation.
Request No. 2: Produce all your individual and records, including canceled checks,
deposit slips and bank statements, commencing with the period of , through the date
of this request.
Request No. 3: Produce all contracts with contractors and/or subcontractors who have
been engaged by you and/or to perform any work on the site where the subject residence
was located, including, without limitation, any agreements with any person to demoli sh the subject
residence, and to purchase any materials which were part of the subject residence prior to or after
demolition.
Request No. 4: Produce all plans and specifications for the construction of streets,
drainage, and utilities to the property, which is the subject of this litigation.
Request No. 5: Produce all notes, memos, letters, correspondence, diaries, or other
documents, which may reflect the progress of work on the subject project from its beginning to the
date of this request.
Request No. 6: Produce any and all documents of any kind or character which would show
or indicate the cost of any delay which may, at any point, be the subject of a counterclaim.
RESPECTFULLY SUBMITTED, this the day of , 20 .
_______________________________________
Attorney for
Of counsel:
Telephone:
MSB #
Attorney for
CERTIFICATE OF SERVICE
This is to certify that I, , attorney for Plaintiff, , have forwarded t his date a true
and correct copy of the above and foregoing document, by U.S. Mail, postage fully prepaid, to , Esquire, , , Mississippi , attorney for Defendants.
This the day of , 20 .
_____________________________________
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