Volume II, Chapter §6.8c
Litigation Documents

Discovery: Request for Production of Documents

§6.8c

 

Introduction

Even though the Request for Production is usually the shortest of all discovery documents, it may be the most critical depending on what documents are available to be produced. It also poses the greatest challenge for paralegals, since anything disclosed through "Production" can wind up as evidence in court. Pay especially close attention to discoverable v. non-discoverable documents.

While you will be creating Requests for Production for this program, it is just as likely that you will be on the producing end of these requests in the real world. Knowing what should and should not be produced to the other side is critical. So pay attention to material that is:

  • privileged
  • work product
  • not relevant to the litigation

Documents falling into these categories will typically not be produced.

Commonly Asked Questions . . .

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InterActive Study
    

Demonstration

Discovery Documents

 

Lecture Notes . . .

About Requests for Production
Request for Production ask the opposing party to provide documents for inspection.

A Subpoena Duces Tecum, or a simple letter or phone call requesting something, may also be used to obtain documents. (If the person you need documents from is not a party, but a potential witness, you will need to use one of these since Requests for Production are for parties.)

There is an example of a set of Request for Production broken down for you in the manual. Notice the Certificate of Mailing at the end. Either the Receipt of Copy or a Certificate of Mailing is required!

 

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Exercise

Requests for Production

The Good, the Bad, and the Ugly Time Sheets
Click on the examples of Time Sheets below to zoom in and compare. Yours should look like the Good example.

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The Good
The Bad
The Ugly

Time Sheet Download
Click here to download a Time Sheet that automatically adds up your billable hours. You should keep track of any research or writing you do on behalf of your client, including the written assignments in this chapter.