Combined Discovery Request
Combined Discovery Request
Combined Discovery Request
Interrogatory 2:
If your response to Request For Admission 1 is anything other an unequivocal admission,
please identify all documents written or produced between __________ and _________
pertaining to the subject activity. As used herein, the term document shall include
writings, notes, drafts, outlines, recordings and files, regardless of storage media; they
include, but are not limited to, writings contained on paper, recordable tape, celluloid,
disks, hard drives, electronic mail servers or any other digitally stored media. The term
document shall also include the full range of writings described in Rule 1001 of the
Federal Rules of Evidence. For each such document, please set forth the following
information specifically and in detail:
[a] Its title
[b] Its date
[c] Its author
[d] The circumstances surrounding its creation
[e] The media it occupies (i.e. printed, typewritten, floppy disk, etc.)
[f] The person or entity who presently has possession
[g] The location of the document
[h] A very brief description of its contents
Notice For Production 1:
Please produce all of those documents in your possession or under your control that
satisfy the following conditions:
[a] Its title ___________, or [and]
[b] dated between _______________
[c] authored by _______________
[d] involving _______________
[e] whose media is _______________
[f] that is in the possession of _______________
[g] located at _______________
[h] containing _______________
[Be careful about your use of or and and. Too many of the former may result in the
production of far too many irrelevant documents, while too many of the latter will
produce too few. You should not use all of the parameters set forth above; use only those
that are necessary. But if you must err, err on the side of too many.]
Date: _______________
_____________________________
Signature of Attorney