Example Request For Production Of Documents (Page 5 of 6) in pdf

Example Request For Production Of Documents Page 5

COMMONWEALTH OF MASSACHUSETTS

THE TRIAL COURT OF THE COMMONWEALTH

____________, ss.

______________DISTRICT COURT

DOCKET NO. _______________

_______________________,

)

Plaintiff,

)

DEFENDANT’S REQUEST FOR

)

PRODUCTION OF DOCUMENTS

)

_______________________,

)

Defendant.

)

___

)

For the purpose of this Request, the following definitions shall apply:

“Agreement” shall refer to the alleged terms and conditions calling for the repayment of funds

underlying this cause of action.

“Creditor” shall refer to the parties past or present authorized to collect on the subject debt.

“Debt” shall refer to the alleged monies owed in connection with this cause of action.

“Defendant” shall refer to the party being sued in this action.

“Document” includes any written, recorded, electronic, or graphic matter, however produced or

reproduced, that is or was ever in the possession, custody, or control of the Creditor.

“Document” includes the originals and all drafts and copies which differ in any respect from the

original. “Document” includes all of the above materials, whether privileged or not. If any of the

documents designated below are withheld on the grounds of privilege or work product, such

document should be identified by author, recipient, date, and nature of the document.

With respect to any document designated below which was once, but is no longer, in the

Creditor’s possession, custody, or control, please indicate the date the document ceased to be in

the Creditor’s possession, custody, or control, the manner in which it ceased, and the name and

address of its present custodian.

If the document is responsive to more than one request, it need be produced only once, but the

written response should identify all the requests to which it is responsive.

Example Request For Production Of Documents Page 5