Fill and Sign the Request for Production Mississippi Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       , ADMINISTRATRIX OF THE ESTATE OF       PLAINTIFF VS. NO.             , A MINOR, AND       DEFENDANTS PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS, TANGIBLE ITEMS AND THINGS, TO DEFENDANTS PURSUANT TO RULES 26 AND 34, MISSISSIPPI RULES OF CIVIL PROCEDURE COMES NOW, Plaintiff, by and through counsel, and serve these Requests for Production of Documents, Tangible Items and Things, Pursuant to Rules 26 and 34 of the Mississippi Rules of Civil Procedure, to be responded to by the Defendants within       (       ) days of the service on Defendant with documents to be produced at a time and place mutually agreeable to counsel for Plaintiff and Defendants. REQUESTS FOR PRODUCTION REQUEST NO.1: Produce all photographs of the scene of the collision, the vehicles involved in the collision, the body of       at the scene, all recorded measurements, diagrams or drawings of the scene which depict the vehicles, their paths of travel, the point of impact and the direction of each vehicle, both before and after the collision. REQUEST NO.2: Produce all statements taken on behalf of the Defendants, their insurers or representatives from any of the Plaintiffs in this cause. REQUEST NO.3: Produce certified copies of the insurance policies available to the Defendants as defined by Rule 26(b) of the Mississippi Rules of Civil Procedure which may satisfy all or any part of the Judgment demanded by Plaintiff in this cause. REQUEST NO.4: Produce every document, tangible item or thing which supports any affirmative defense asserted by the Defendants which seeks to charge       with any negligence or degree of fault in the cause of the collision in question. REQUEST NO.5: Produce all documents, treatises, writings or things, including the opinions of all witnesses, on which any expert witness which Defendants may use at the trial of this cause, relies to form the basis or formation as authority for his or her opinion. REQUEST NO.6: Produce the Driver's License application for       signed by       for       Mississippi Driver's license. REQUEST NO.7: Produce the birth certificate for       . REQUEST NO.8: Produce all maps, plats, drawings and diagrams made by, for or on behalf of the Defendants which depict       at the scene or point of collision, the point of impact, all marks left in the road by either             or             automobile or the movements of either vehicle before the collision. REQUEST NO.9: Produce all statements from all witnesses to the collision, who were present immediately after the collision, taken by or for the Defendants or anyone acting on their behalf. REQUEST NO.10: Produce all reservation of rights letters or       and/or excess demand letters to Defendants from any insurer providing automobile coverage. REQUEST NO.11: Produce all citations and writings received from any law enforcement official received by the Defendants or either of them concerning the collision in question. REQUEST NO.12: All reports, writings, photographs, and parts, if any, concerning the       automobile driven by       which was involved in the collision which is the subject of this action. REQUEST NO.13: All reports, writings photographs, and parts, if any, concerning the       driven by       which was involved in the collision which is the subject of this action. Respectfully submitted,       BY: _____________________________       , Their Attorney CERTIFICATE OF SERVICE I,       , one of the attorneys for the Plaintiff, do hereby certify that I have this day mailed by United States mail, postage fully prepaid, a true and correct copy of the above and foregoing Requests for Production to the following:       This the       day of       ,       . __________________________________________