Sample California request for production of documents

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Any Defendant
Any Street
Any Town, CA 55555
714-555-5555
Defendant, In Pro Per
Superior Court of the State of California
For the County of ________________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant, and DOES 1-5
Defendants.
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Case No.
REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
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Documents-to-Plaintiff
1PROPOUNDING PARTY: ANY DEFENDANT
RESPONDING PARTY: ANY PLAINTIFF
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REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE

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SET NO.: ONE
1TO: PLAINTIFF,_______________________, AND HIS ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT pursuant to California Code of Civil Procedure §§
2031.010 and 2031.210 et. seq., you are directed to respond separately, under oath and in writing, to
each and every category of documents set forth herein, within thirty (30) days of service of this
request.
PLEASE TAKE NOTICE THAT, within thirty (30) days of service of this request, you are
directed to produce for inspection and copying of the same, all the documents and materials described
below which are in your possession, custody, and/or control to: Put in your complete
address here including city, state and zip code.
Moreover, pursuant to this Code, the responding party is required to serve a written response,
under oath, to this Demand within 30 days after service. The response shall identify the documents
falling within the category specified and that inspection and related activities will be permitted as
requested, unless the request is objected to, in which event the reasons for objection shall be stated.
Unless otherwise indicated, a copy of the documents requested shall be sufficient for this
production of documents.
DEFINITIONS
1. “YOU” or “YOU OR ANYONE ACTING ON YOUR BEHALF” means you, the
Plaintiff,____________________. your agents, your employees, your insurance companies, their
agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting
on your behalf.
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2. “YOUR” or “YOURSELF” means ______________________, your agents, your
employees, your insurance companies, their agents, their employees, your attorneys, your
accountants, your investigators, and anyone else acting on your behalf.
3. “DOCUMENT” means a writing, as defined in Evidence Code § 250, and includes the
original or a copy of handwriting, type-writing, printing, photostating, photographing, and every
other means of recording upon any tangible thing and form of communicating or representation,
including letters, words, pictures, sounds, or symbols, or combinations of them.
4. “ADDRESS” means the street address, including, the city, state, and zip code.
5. “FULLY IDENTIFY” means in relation to persons to state the full name, telephone
number and last known address, including city, state and zip code; in relation to documents, “FULLY
IDENTIFY” means to provide the name of the document, date of the
document, and the type of document.
6. “PERSON” includes a natural person, firm, association, organization, partnership,
business, trust, limited liability company, corporation, or public entity.
7. “DEFENDANT” or “DEFENDANT AND ANYONE ACTING ON THEIR
BEHALF” in this set of request for production of documents means the Defendant
__________________________ in this action.
INSTRUCTIONS
1. In answering these requests, you are required not only to furnish documents in
your possession, custody and control, but also documents which are in the possession, custody and
control of your attorneys, investigators or anyone else acting on your behalf or their behalf regardless
of who prepared or signed the documents.
2. The documents produced must be originals and not photostatic or xerographic
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Sample California request for production of documents

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