JAMES C - MD Justice



Sample Request for Production of Documents. This example contains requests for information dealing with child custody, divorce, marital property, and alimony. Some requests for the same information, with more or less detail; pick the ones most relevant to your case. Some are generic, and some are very case specific. (Formatted for red line paper.)____________________,*IN THEPlaintiff*CIRCUIT COURT FORvs.*___________________ county____________________,*Defendant*CASE NO: __________________ ********** *PLAINTIFF’S REQUEST FOR PRODUCTION,INSPECTION, AND COPYING OF DOCUMENTS TO DEFENDANTTO: [Party], [Plaintiff/Defendant]C/o [opposing counsel][Address][City, State, Zip].FROM: [Party] [Plaintiff/Defendant]C/o [Attorney][Address][City, State, Zip]InstructionsPursuant to Md. Rule 2-422, you are hereby requested to produce the following documents, records, electronically stored information, and tangible things (including writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations stored in any medium from which information can be obtained, translated, if necessary, by the respondent through detection devices into reasonably usable form), for inspection and copying.Said production shall take place at the offices of [attorney], [physical address and mailing address] on or before thirty (30) days after receipt of this request, or at such other time and place as may be mutually agreeable to counsel for the above named parties. Md. Rule 2-422 further directs you to serve a written response within thirty days after your receipt of these requests. The response shall state, with respect to each item or category, that (1) inspection and related activities will be permitted as requested, (2) the request is refused, or (3) the request for production in a particular form is refused. The grounds for each refusal shall be fully stated. If the refusal relates to part of an item or category, the part shall be specified. If a refusal relates to the form in which electronically stored information is requested to be produced (or if no form was specified in the request) the responding party shall state the form in which it would produce the information.RequestsAny and all documents on which you relied or identified in your Answers to Interrogatories, or which relate to your Answers to or the subject matter of the Interrogatories. All documents that contain information about, refer to, or relate to your claim of custody in this case.All documents containing any statements made to you by anyone with personal knowledge of the facts at issue in this case, about the facts at issue in this case.Any and all correspondence between you and the plaintiff in the past five years, including letters, emails, text messages, and any other written or electronic communications.All documents related to any contact, in person, oral, written, or electronic between you and the plaintiff in the past five years.All documents that you intend to introduce as evidence in this case.All documents related to any criminal charges or serious traffic charges filed against you in Maryland or in any other jurisdiction, whether or not they resulted in convictions, for the past ten years.All documents related to any criminal charges or serious traffic charges filed against the plaintiff, in Maryland or in any other jurisdiction, whether or not they resulted in convictions, for the past ten years.All documents related to any criminal charges or serious traffic charges filed against the plaintiff’s husband, in Maryland or in any other jurisdiction, whether or not they resulted in convictions, for the past ten years.All documents related to any peace order or protective order cases filed by you or against you, in Maryland or in any other jurisdiction, in the past ten years.All documents related to any peace order or protective order cases filed by or against the plaintiff, in Maryland or in any other jurisdiction, for the past ten years.All documents related to any substance abuse treatment you have undergone in the past ten years, including, but not limited to, inpatient treatment and outpatient treatment.All documents evidencing the taking of and/or the results of any urinalysis, blood, or any other kind of screening for the presence of alcohol or any controlled dangerous substances you have undergone in the past ten years.Any diary or journal you have kept since October 4, 2007.Copies of your federal and state income tax returns, both personal and business, with accompanying work-sheets, including, but not limited to, Forms 1099, K-I, W- 2, W -4, estimated tax forms, extension requests, and any other supporting documents since October 4, 2007.All bank statements, cancelled checks and check registers for any checking accounts in your name alone or jointly with any person, firms, partnerships, companies, corporations, or limited partnerships since October 4, 2007.All your pay stubs or wage and salary statements received from any and all sources which evidence payment of any salaries, bonuses, stipends, or severance pay received since October 4, 2007.Copies of all written memoranda and reports and photographs submitted to you or your attorney by any potential witnesses named in your Answers to Interrogatories as well as all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance or recordings conducted by you or others on your behalf.Any and all records pertaining to medical treatment you have sought or received, of any kind or nature, including, but not limited to, therapy, counseling, psychiatric consultation or treatment and/or for alcoholism, emotional disorders, or drug abuse since October 4, 2007.Any and all reports of investigators or experts related to any issue in this case.Any and all documents evidencing any public benefits or subsidies of any kind whatsoever received by you since October 4, 2007.Any and all documents relating to your driving record, including a complete record of traffic offenses, failures to appear for traffic court, and suspensions of your driver’s license for the past 10 years.All records you have of the children’s school, pre-K, babysitting, or daycare records, including dates and hours on which the children were present at any daycare, child care, or had a babysitter and the cost of said care and including all school records.All the children’s medical records.Records or other evidence of all medications the children takes, including the name of the medication, the dosage, and for what condition the medication is prescribed.All records or other documentary evidence you have regarding the plaintiff’s residence(s) since October 4, 2007.For [years requested], all employment contracts, correspondences, and documents evidencing terms and conditions of employment between you and your employer, including, without limitation, information about wages, salaries, bonuses, stock options, commissions, earnings, income, pay raises, promotions, payroll deductions, other deductions of any kind, pension plans, pension funds, retirement plans, retirement funds, stock plans, and stock funds and other benefits or deductions of any kind which are, were previously, or which may in the future be paid, available, or withheld for any purpose, or otherwise, or to which you are, were, or may become, entitled in the future. All books and records reflecting any fringe benefits available to you from any business entity, including, without limitation, auto expenses, travel expenses, personal living and entertainment expenses, bonuses, life insurance, health insurance, accident insurance and hospital insurance, from [date], to the present.Any and all documents, memoranda, or writing related to any interest you may have in real estate, whether as owner, co-owner, fiduciary, trust beneficiary (vested or contingent), partner, limited partner shareholder, joint venture, mortgage, developer, manager or otherwise.Any and all documentation regarding any health insurance of any kind available to you from your employer, including any documentation evidencing the availability, cost to you, coverage, and whether you can include [name of spouse and/or name of child] on said insurance.All records pertaining to any account or accounts of every kind and nature whatsoever in which you have deposited or withdrawn funds or incurred debts or credits, including certificates of deposit from [date] to the present. Copies of all savings account passbooks or other documentary evidence of any such accounts, including accounts held in your name solely or jointly with anyone else, or as trustee for someone else, which are presently opened or closed, in which you have or have had any direct or indirect interest from [date] to the present. Any and all records that relate to any and all secured or unsecured personal loans made to you for the past [number of years] years, whether from a member of your family, a banking institution, or any individual or entity. Any and all records pertaining to or being evidence of any current outstanding indebtedness you have which has not been produced in response to the foregoing requests. All titles to and registrations for any motor vehicles currently being used or owned by you or your spouse. Any and all documents, not previously provided, upon which you intend to rely in the trial of this case.Any and all documents that you contend evidence any claim or defense that you have in this case.All applications for employment and responses made by you within the last [number of years] years.Any and all documentation in your possession custody or control related to your employment or training as a [party’s employment/profession].All employment records pertaining to persons employed by you for the past [number of years] years, including, without limitation to the names arid addresses of such employee, the amount paid to each employee, the date of each payment and the nature of the services performed by each employee. A list of all household furniture, furnishings and antiques owned by you, whether individually or jointly, including the purchase price of each item, the source of the funds used to purchase each item, and the current fair market value of each item. Any and all records of all information which you have regarding any and all safe deposit boxes which you maintain either individually or with any other person, whether corporate or any other enterprises to which you have access, including a list itemizing the contents of any such safe deposit boxes as well as a list of the dates the items were placed in or removed from said boxes, a list of all other persons who have access to said box, whether individual or corporate, as well as an indication of the names and addresses of the institutions where the box(as) are located. A detailed, itemized list of any and all property and assets of every nature and description owned by you or in which you have any interest, cither alone or with others, whether present, future or contingent, including, but not limited to, stocks, bonds, real and personal property of whatever nature and kind and wherever situated or held by others for your benefit for the past [number of years] years. Include in said itemization all of the following information: Value of each item and nature and extent of your interest therein; Where cash is the asset listed, state the amount and location where said cash is kept; When, for what amount, and from whom each item was purchased or acquired; The source if any funds used to purchase any asset having a value over $50.00; andIf titled, in whose name was the item originally titled and if changed, in whose name is now titled. Records that relate to any secured or unsecured personal loan made to you for the past [number of years] years, whether from a member of your family, a banking institution or any individual or entity. Any and all documents, memoranda or writing related to any interest you may have in real estate, whether as owner, co-owner, fiduciary, trust beneficiary (vested or contingent), partner, limited partner shareholder, joint venture, mortgage, developer, manager or otherwise.Copies of all real estate mortgages held by you, or by an entity (including, but not limited to realty trusts, partnerships or corporations) in which you have or had a present or contingent interests from [date] to the present.A copy of all documents indicating your interest in any type of retirement, pension, or profit sharing plan or fund, or any other deferred compensation plan, including, but not limited to, the following:Periods of employment;Date of termination from employment, if applicable;Salary for the three highest years of employment;Latest benefit statement;The plan summary and any amendments thereto, including details as to the type of contributions, whether the contributions are made by the employer or the employee or both, and the annual contribution by the employer and by the employee for the term of employment;Interest in the plan, whether legal, equitable, or beneficial and the amount vested to date;The latest actuarial report;The name and address of the plan administrator;The plan’s QDRO procedures;The plan’s sample QDRO, if applicable.Any booklets, pamphlets, information sheets or any other materials distributed by the plan concerning the rights to receive benefits, type and form of benefits payable, options, and elections available under any planAny and all documents to you from the Social Security Administration showing your potential Social Security benefits.Any and all documents related to any existing annuities, Keogh plans, or IRAs in which you have any interest.For any Keogh plan in which you are a participant, provide copies of the plan’s trust instruments or documents, including any amendments thereto, and the most recent statement issued by each bank and or custodian of the account.Any written materials of any kind relating to any non-ERISA plans including, but not limited to, military retirement benefits and federal, state, or local government pensions, retirement, or benefit plans.Respectfully submitted,AttorneyFirmAddressPhoneEmailAttorneys for the DefendantCertificate of ServiceI hereby certify that on this day of , , a copy of the foregoing [Party]’s Request for Production of Documents to [Party] was mailed, first class mail, postage prepaid, to [opposing counsel].Attorney ................
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