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Request for Production of Documents

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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI

PLAINTIFFS

VS.

DEFENDANT

CIVIL ACTION NO.

PLAINTIFFS' RESPONSE TO DEFENDANT'S FIRST
REQUEST FOR PRODUCTION OF DOCUMENTS

The Plaintiffs, Estate of , respond to the following Requests for Production propounded by as follows.

GENERAL OBJECTIONS

1. The Plaintiffs object to the production of documents which are not within their possession, custody or control.

2. The Plaintiffs object to the production of documents which are protected by the attorney-client privilege and/or work product doctrine.

RESPONSES

REQUEST NO. 1: Produce each and every writing, documents or other physical evidence referred to, described or identified in your Answers to Defendant's First Set of Interrogatories to Plaintiffs being served simultaneously with this Request.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 2: Any and all photographs, measurements, plats, drawings, surveys, maps, statements, recordings, reports, resumes, movies, videos, calculations, and other physical materials of any kind or nature which in any way describe, depict, refer to, or relate to in any manner:

(a) the accident;

(b) the scene of the accident;

(c) how the accident occurred;

(d) why the accident occurred;

(e) the damage or injury to any property or person;

(f) the credibility of any witness; and

(g) the liability of any party.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 3: Any and all statements in recorded, summarized and transcribed form from anyone concerning the accident, cause thereof or damages arising therefrom.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 4: All reports and correspondence prepared by investigators concerning the accident in any way.

RESPONSE: None.

REQUEST NO. 5: All reports and correspondence prepared by investigators concerning the accident in any way.

RESPONSE: None.

REQUEST NO. 6: All evidence or exhibits which Plaintiffs may tender as evidence at trial.

RESPONSE: The Plaintiffs object to this request to the extent that it is beyond the scope of the Mississippi Rules Civil Procedure. Subject to this objection, the Plaintiffs not yet determined what evidence or exhibits it intends to produce at trial. This response will be supplemented when such a determination is made.

REQUEST NO. 7: All insurance policies applicable to any person involved in the accident providing coverage for damages from the accident for any party or person.

RESPONSE: The Plaintiffs object to this request because it seeks the production of documents which are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

REQUEST NO. 8: All investigation files relating in any manner to the accident.

RESPONSE: None.

REQUEST NO. 9: All accident reports of any kind or nature.

RESPONSE: None.

REQUEST NO. 10: All documents and other physical evidence which support your description of exactly how you contend the accident occurred as described in your response to Interrogatory No. 7.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 11: All documents and other physical evidence which support what you contend the Defendant did or failed to do that contributed to the accident as described in your response to Interrogatory No. 9.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 12: All medical records, reports, summaries or like documents which in any matter relate to the injuries the deceased, , sustained in the subject accident and treatment he/she received for those injuries.

RESPONSE: Subject to the foregoing general objections, those documents within the scope of the request will be produced.

REQUEST NO. 13: All W-2 statements reporting income to for the years preceding his/her death.

RESPONSE: The Plaintiffs are not in the possession, custody or control of any such W-2 statements.

REQUEST NO. 14: All 1099 statements reporting income to for the five years preceding his/her death.

RESPONSE: The Plaintiffs are not in the possession, custody or control of any such 1099 statements.

REQUEST NO. 15: All employment applications completed by or on behalf of during the years preceding his/her death.

RESPONSE: The Plaintiffs are not in the possession, custody, or control of any such employment applications.

REQUEST NO. 16: All employment evaluations for for the years preceding his/her death.

RESPONSE: The Plaintiffs are not in the possession, custody or control of any such employment evaluations.

REQUEST NO. 17: All school records for .

RESPONSE: The Plaintiffs are not in the possession, custody or control of any such school records.

REQUEST NO. 18: All medical records for for the years preceding his/her death.

RESPONSE: The Plaintiffs object to this request because it is overly broad and unduly burdensome and because it seeks the production of documents which are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Subject to this objection, the Plaintiffs will produce the medical records of relating to the injuries at issue in this case.

INTERROGATORY

If Plaintiffs decline to produce any document requested in the foregoing Request for Production, then as to each document not produced or otherwise claimed as privilege, state:

(a) The name, address, employer and job description of the author who prepared such document;

(b) The date such document was prepared, and whether such document was prepared by you or on your behalf;

(c) A general description of the written matter in the document;

(d) Whether such document was prepared under the supervision or pursuant to the instructions of your attorney; and

(e) The name and address of the person who presently has custody of the document.

RESPONSE: The Plaintiffs object to this interrogatory to the extent that it requests that the Plaintiffs identify and give information regarding documents which are not in the possession, custody or control of the Plaintiffs. Documents withheld on the basis of privilege include correspondence between the Plaintiffs and their counsel and notes made by the Plaintiffs' counsel.

Respectfully submitted,

ATTORNEY FOR PLAINTIFFS

OF COUNSEL:

CERTIFICATE OF SERVICE

I, , certify that I have this day caused the above to be placed in the United States mail, postage fully prepaid, addressed as follows:

THIS, the day of ,

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What the Request for Production of Documents Is and When It’s Used

A Request for Production of Documents is a formal discovery tool used in civil litigation to obtain documents, electronically stored information (ESI), and tangible items from another party. Under the Federal Rules of Civil Procedure, Rule 34, a party may serve requests specifying categories of documents to be produced for inspection, copying, testing, or sampling. Requests should define scope, time periods, formats (including native ESI), and custodians. Responses may include produced materials, objections, or privilege logs, and supplemental productions may be required if new responsive materials are discovered.

Why a Clear Request Improves Case Preparation

A precise Request for Production narrows issues, preserves evidence, and reduces disputes about scope and format. Clear requests help opposing parties locate responsive materials faster and reduce motion practice over production disputes.

Why a Clear Request Improves Case Preparation

Who Prepares and Responds to These Requests

Typical users include litigators, in-house counsel, and records custodians responsible for discovery.

  • Plaintiff and defense counsel: Draft and serve requests tailored to claims and defenses, coordinate collection and review of responsive materials.
  • Corporate legal and compliance teams: Collect documents from business units, oversee ESI preservation, and manage privilege reviews.
  • Records custodians and third-party vendors: Locate files, provide custodian declarations, and deliver documents in requested formats.

Responses are usually certified by counsel or a custodian and may require a privilege log for withheld materials.

Core Elements to Include in a Professional Request

A well-structured Request for Production includes a case caption, precise definitions, clear categories, time frames, custodians, and production instructions to avoid disputes and streamline review.

Case Caption

Include court, docket number, and parties so the request is tied to the specific litigation and is easy to reference.

Definitions

Define terms such as 'document', 'communication', 'electronically stored information', and named entities to prevent ambiguity in responses.

Document Categories

List discrete, numbered categories (e.g., contracts, emails, invoices) with specific date ranges and custodians for each category.

Time Periods

Specify exact start and end dates (MM/DD/YYYY) and explain why the range is relevant to limit overbreadth objections.

Production Format

State required formats (PDF, native files, load files), metadata fields to include, and any pagination or Bates-numbering conventions.

Verification

Request a certification or custodian declaration identifying search methods, scope, and whether a comprehensive search was completed.

Security and Compliance Considerations for Production

Encryption: TLS 1.2/1.3 in transit; AES-256 at rest
Audit Trail: Document access, timestamps, and actions preserved
HIPAA: HIPAA-compliant workflows require a BAA
21 CFR Part 11: Support for FDA-regulated record controls
SOC 2: SOC 2 Type II available on request
Accessibility: WCAG 2.0 Level AA compliance

Consequences of Improper or Late Production

Sanctions: Court may impose monetary or evidentiary sanctions
Spoliation: Loss or destruction can lead to adverse inferences
Cost Shifting: Court can require producing party to pay discovery costs
Privilege Waiver: Overbroad disclosure can waive privilege
Default Risk: Extreme noncompliance may lead to default judgment
Reputational Harm: Discovery misconduct can harm client credibility

Common Pitfalls to Avoid When Drafting Requests

  • Overbroad categories that ask for 'all documents' without boundaries invite objections and motion practice over scope and burden.
  • Failing to request metadata or native files forces reviewers to re-create context and can conceal key communications.
  • Unspecific date ranges lead to overproduction; tie ranges to events, transactions, or relevant timelines when possible.
  • Not identifying custodians or systems (email, Slack, file servers) delays collection and increases the risk of missed evidence.

Step-by-Step: Preparing and Serving a Request for Production

Follow a consistent sequence to prepare, serve, and track production requests and responses to reduce discovery disputes and preserve evidence.

  • 01
    Define Scope: Identify issues, custodians, date ranges, and document categories.
  • 02
    Draft Request: Numbered requests with clear definitions and format instructions.
  • 03
    Serve Request: Serve per court rules and local civil procedure requirements.
  • 04
    Track Responses: Log produced items, objections, and privilege assertions.

How Electronic Submission and Production Typically Flow

Electronic collection and production use consistent workflows: preserve, collect, process, review, produce, and certify to maintain defensibility.

  • Preserve: Issue litigation hold notices and suspend routine deletion policies.
  • Collect: Export ESI from identified custodians and systems in native or agreed formats.
  • Review: Perform privilege and responsiveness review before production.
  • Produce: Deliver files with required metadata and a production log.

Setting Up a Digital Production Workflow

Configure a repeatable production workflow that covers collection scope, file formats, authentication, retention, and notifications.

Field Configuration
Document Type Email | Native | PDF | Attachments
Request Deadline 30 days default | Judge may shorten or extend
Authentication Email link | SMS code | KBA as required
Format Required PDF with metadata | Load file optional

Technology and Delivery Requirements for E-Production

Select platforms and formats that preserve metadata, support common file types, and allow secure transfer and audit logging.

  • File Formats: PDF, native Office files, and common ESI formats
  • Integrations: Connectors for Google Workspace, Microsoft 365, NetSuite
  • Authentication: Email or multi-factor signer verification

Ensure chosen tools support defensible collection, encryption in transit and at rest, and a searchable audit trail for production verification.

Key Deadlines and Timing Expectations

Timely responses, supplementation, and preservation obligations reduce the risk of sanctions; follow federal and local rules for specific timing.

Response Period (FRCP 34):

Typically 30 days to respond to a production request (FRCP 34(b)(2)(A)).

Supplemental Duty:

Ongoing duty to supplement responses if new materials are discovered.

Privilege Log Timing:

Provide privilege logs within the response timeframe or as ordered by the court.

Preservation Period:

Preserve relevant materials from the date of reasonable anticipation of litigation.

Local Rules:

Check court-specific e-discovery and e-filing timelines which can vary.

eSignature Vendor Pricing and Capabilities for Document Workflows

Compare starting prices and core capabilities relevant to producing and collecting documents electronically; signNow is listed first per comparison guidelines.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Plan 7-day free trial No No Yes, limited Yes, limited
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

FAQs and Troubleshooting for Requests for Production

Answers to common procedural and technical questions about drafting, serving, and producing documents during discovery.


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