SAMPLE REQUESTS FOR PRODUCTION OF DOCUMENTS
Plaintiff's Request for Production of Documents
- Sample Plaintiff's Request for Production of Documents (car crash)
- Sample Plaintiff's Request for Production of Documents (truck crash - owner)
- Sample Plaintiff's Request for Production of Documents (truck crash - driver)
- Sample Plaintiff's Request for Production of Documents (truck accident | driver | includes answers | no liability dispute | negligent entrustment big issue to get in certain evidence at trial)
- Sample Plaintiff's Request for Production of Documents (medical malpractice)
- Sample Plaintiff's Request for Production of Documents (car crash #2, with answers)
- Sample Plaintiff's Request for Production of Documents (legal malpractice)
- Sample Plaintiff's Request for Production of Documents (product liability - includes incredibly obstructionist defendant's answers)
Defendants' Request for Production of Documents
- Sample Defendant's Request for Production of Documents (premises liability)
- Sample Defendant Request for Production of Documents (nursing home)
- Sample Defendant's Request for Production of Documents (car accident/brain injury)
- Sample Doctors Request for Production of Documents (malpractice)
Maryland Rule 2-422 allows accident and medical malpractice lawyers in Maryland the opportunity to require the defendant to produce documents in defendant's possession that relate to the car or truck accident. Subsection (b) provides that the request must set forth the items to be inspected, ''either by individual item or by category, and shall describe each item and category with reasonable particularity.'' This language tracks the language used in Federal Rule of Civil Procedure Rule 34. There is no limit in Maryland on the number of requests a personal injury lawyer can make. (Everyone seems to think it is 30. It is not.)
The defendant has 30 days in Maryland (33 if sent by mail) after service of the request unless the request is served before the date Defendant's initial pleading or motion is required, in which case the responding party has until 15 days after the time for responding to the initial pleading. Because our lawyers file the bulk of our requests for production of documents with the Complaint, the latter rule is usually applicable.
The defendant has 30 days in Maryland (33 if sent by mail) after service of the request unless the request is served before the date Defendant's initial pleading or motion is required, in which case the responding party has until 15 days after the time for responding to the initial pleading. Because our lawyers file the bulk of our requests for production of documents with the Complaint, the latter rule is usually applicable.
Providing Help to Other LawyersMost of our personal injury cases come from referrals from other lawyers. Learn how you can still collect a fee within our ethical rules while transferring primary responsibility for your case to us.
The Defendant must provide a response stating whether he/she will comply wit the request. Specific grounds or reasons must be given with some specificity explaining why the request for documents is overly broad or the reasons why having to produce the documents would be unduly burdensome. Defense lawyers in Maryland, particularly in serious medical malpractice and truck accident cases, typically object to document requests initially because it takes real effort from the defendant's attorney to comply with the request. A good accident or malpractice lawyer needs to stay on the defendant's attorney to ensure compliance with their discovery obligations.
- Sample Discovery (depositions, interrogatories, requests for production of documents, etc.)
- Sample Trial Documents (transcripts, jury instructions, you name it)
- Injury Lawyer Help Center (sample pleadings, opening statements, jury instructions, etc.)
If you are looking for assistance in handling your personal injury case, call 800-553-8082 or get a free online no obligation consultation. This offer is both for potential clients and potential referring lawyers throughout the United States. It is worth noting, however, that our firm handles only serious personal injury accident, malpractice, and product liability case. But, where we can, we will offer direction on any personal injury case.
